Annual Environmental Report for Becton Dickinson Insulin ...
Transcript of Annual Environmental Report for Becton Dickinson Insulin ...
Annual Environmental Report
for
Becton Dickinson Insulin Syringe Limited (Irish Branch) and Becton Dickinson Penel Limited (Irish Branch)
Licence Register No. P0648-01
2009
March 2010
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
Table of Contents
Table of Contents..................................................................................................................2
1.0 Introduction...................................................................................................... 1 1.1 General ........................................................................................................ 1 1.2 Company Environmental Policy ................................................................... 2 1.3 Company Organisation Chart for Environmental Management ................... 3
2.0 Summary Information ...................................................................................... 8 2.1 Self-Monitoring Data .................................................................................... 8 2.2 Agency Monitoring and Enforcement......................................................... 42 2.3 Energy & Water Consumption ................................................................... 43 2.4 Environmental Incidents & Complaints ...................................................... 45 2.5 Summary of Abatement Plant Bypass Events ........................................... 45
3.0 Management of the Activity ........................................................................... 46 3.1 Introduction ................................................................................................ 46 3.2 Schedule of Environmental Objectives & Targets...................................... 46 3.3 Environmental Management Programme (EMP) Report ........................... 46 3.4 Environmental Management Programme 2008 – 2012 ............................. 46 3.5 Pollution Emission Register – Report for 2008 .......................................... 47 3.6 Pollutant Emission Register – Proposal for 2010....................................... 47 3.7 Solvent Usage............................................................................................ 47 3.8 Fugitive Emissions Assessment Report..................................................... 48 3.9 Report on ELRA & CRAMP ....................................................................... 49
4.0 Licence-Specific Reports............................................................................... 50
ANNEX I AER/ PRTR ELECTRONIC REPORTING WORKBOOK ANNEX II SITE DRAWINGS ANNEX III ENVIRONMENTAL MANAGEMENT PROGRAMME:
REPORT ON PROGRAMMES COMPLETED IN 2009 ANNEX IV ENVIRONMENTAL MANAGEMENT PROGRAMME:
NEW PROGRAMMES FOR 2008 – 2012 ANNEX V BUND INTEGRITY TEST REPORT
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
1 March 2010
1.0 Introduction
1.1 General
This Annual Environmental Report (AER) is submitted to the Environmental Protection
Agency (EPA) in compliance with Condition 2.9.2 of the IPPC Licence, Register No. P0648-
01 as amended by Amendment A to the licence.
The AER contains summary information on the environmental performance of Becton
Dickinson Insulin Syringe Limited and Becton Dickinson Penel Limited for the year ended
31st December 2009. The items covered in this report are as follows:
• Emissions to Atmosphere
• Emissions to Sewer
• Groundwater Monitoring
• Surface Water Monitoring
• Agency Monitoring and Enforcement
• Resources Consumption
• Environmental Incidents and Complaints
• Environmental Objectives and Targets
• Environmental Management Programme
• Pollutant Release and Transfer Register
• Licence Specific Reports
Becton Dickinson (BD) is a manufacturer of a broad range of medical supplies, devices and
diagnostic systems for use by health care professionals, research institutions and the general
public. The Dún Laoghaire location is home to Becton Dickinson Insulin Syringe (Irish
Branch) and Becton Dickinson Penel (Irish Branch). These operations are carried out at the
facility on Pottery Road, Dún Laoghaire, Co. Dublin.
The plant is a major manufacturing and distribution centre for the BD Consumer division,
supplying the European market, Middle East and Far East, Africa, USA and Canada with
diabetes products.
The Becton Dickinson Penel (Irish Branch) operation comprises the manufacture of Pen
Needles for use with a Pen Injector. The operations within the plant have undergone
substantial expansion in the last 5 years and by now 12 Pen Needle production lines are
operating 24/7. The Pen Needles are disposable devices used to inject insulin.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
2 March 2010
1.2 Company Environmental Policy
HELPING ALL PEOPLE LIVE HEALTHY LIVES
The Dun Laoghaire location of Becton Dickinson is committed to the protection of the
environment in the interest of our customers, employees, and community.
We shall strive to minimise our impacts upon the environment while pursuing our business
activities of manufacturing medical devices. We are committed to the improvement of our
overall environmental performance to prevent pollution.
An Environmental Management System (EMS) is an integral part of managing the business
and we operate in accordance to ISO14001 since 1999 and our IPC Licence (Register
No. 648) since September 2003.
This system sets forth objectives, programmes, procedures and implementation of
conformance controls to review progress in the areas of our environmental objectives and
targets. Progress on objectives and system effectiveness is periodically reported to senior
management. All environmental activities are conducted in the spirit of continuous
improvement.
An Environmental Management Team (EMT), with members representing the major
functional areas, administers the EMS. The team is championed by the Environmental
Management Representative.
The EMS is documented, implemented and maintained on the computerised system, SE-PRO.
Reference to QDMS, the Quality System Computerised Documentation Control System, is
made for Specified Operating Procedures to guarantee consistent handling of controlled
documents. Access to both systems is open to all management representatives at their
computer terminal. However, changes are strictly controlled and restricted to authorised
individuals.
Our process is strictly controlled and audited in order to maintain the highest standards of
sustainability. We shall continue to increase the benefits that can be achieved by the reuse
and recycling of all our materials to the maximum extent in order to reduce to the minimum
our effect on the environment.
The EMT, taking into account the results of the senior management decisions and
requirements, updates this policy after each management review as stated in the minutes of
the review. The proposed draft policy is sent to senior management for proofing prior to
release.
BD Dun Laoghaire's Objective and Targets are reviewed and amended by the EMT and
thereto notified to the Agency as part of the preparation of the Annual Environmental Report
(AER), which is submitted to the EPA on 31st March of the following year. A list of our
Objective and Targets is contained in SE-Pro Action Item ISO.4.3.3.999 Schedule of
Objectives & Targets.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
3 March 2010
We shall implement, wherever possible, our policy to do business with companies achieving
the highest level of environmental compatibility and products with the least environmental
impact.
Contractors brought on site will be required to conform with mutually agreed high standards
and exercise codes of conduct consistent with carrying out their contractual commitments
with the least possible effect on the environment. Contractors will be informed about our
Environmental Policy by mail or on site.
Our whole work-force will be fully informed of the company's ecological ideals. They will
understand the contribution they can make and will be required to play their full part in
achieving our goals. Employees will be advised of the fundamentals of the ISO 14000
standard and Environmental policy via briefing sessions and environmental training.
Personnel who have direct impact on the company's environmental Objectives and Targets
will be fully versed on their contribution. Induction training for new employees will
incorporate a module on the Environmental Management System.
In addition, as a Becton Dickinson & Company business, we subscribe to the Corporate
Safety and Environment Policy statement. The EMS allows direct access to all relevant
National and European legislation, standards and regulations. The EMS will continually be
revised to ensure compliance with new and developing requirements.
Becton Dickinson is committed to promoting environmental awareness and therefore makes a
copy of its Environmental Policy available on request.
1.3 Company Organisation Chart for Environmental Management
1.3.1 Purpose
To outline Management, Operator and Staff structure, and define responsibilities and
authorities with regard to the Environmental Management System.
To outline Management's responsibilities to provide adequate resources and personnel to
ensure compliance to the Environmental Policy
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
4 March 2010
1.3.2 Scope
This procedure applies to Becton Dickinson facility at Dun Laoghaire, Ireland
and covers the following roles:
Director of Diabetes Care Manufacturing, Ireland
Management Representative
Plant & Environmental Engineer and his staff
Environmental Management Team
Operations Manager and his staff
HR Manager and her staff
Financial Controller, Country QA/ RA Manager, Supply Chain Manager and their staff
IT Structure
1.3.3 Definitions of responsibility and authority
1.3.3.1 Plant Manager
The Plant Manager in liaison with the Environmental Management Representative shall set
the Environmental Policy. He shall assure compliance of operations at BD Dun Laoghaire
with the policy through the Management Review.
1.3.3.2 Management Representative
Greg O'Malley, Plant and Environmental Engineer, is the management representative
responsible for implementing and maintaining an Environmental Management System (EMS)
which meets the requirements of ISO 14001:2004.
In his function as Management Representative he also reports performance of the EMS to
senior management during the Management Review.
1.3.3.3 Plant & Environmental Engineer and his staff
It is the Plant & Environmental Engineer's responsibility to communicate with relevant
external parties, oversee internal operations that have or are likely to have an impact upon the
environment and where necessary inform the appropriate Managers of departments about
cases of non-compliance to ISO 14001:2004.
His staff shall perform its tasks which are closely related to environmental impacts accurately
and attentively. They shall report any occurrences that might lead to deviation from the
Policy, Objectives and Targets, Programmes and/or procedures.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
5 March 2010
1.3.3.4 Environmental Management Team (EMT)
The Environmental Management System (EMS) is operated under the stewardship of the
Environmental Management Team. This team is a cross functional team consisting of
members from Engineering Services, Manufacturing, Purchasing and Continuous
Improvement. Membership changes from time to time. The current Management
Representative is the Plant and Environment Engineer. See attachment A for the current
composition of the team.
The Management Representative or his nominee organises the Environmental Management
Team meetings on a regular basis.
It is the responsibility of the Plant and Environmental Engineer or Environmental Engineer to
routinely review the Irish/European Legislation for notices affecting the Company or our
products and to disseminate the information to team members who, in turn, have the
responsibility to communicate the changes or new requirements to others throughout the
respective departments. This enables us to bring changing requirements to the attention of the
individuals who will implement specific changes.
Each member represents his or her functional area and conveys information to/from that area.
All team members have access to the SE-Pro system and can translate new or changing
requirements to action items which can be tracked.
The team should pay particular attention to new developments or processes in the plant. Their
input should be at the early stages of the relevant projects so that environmental issues are
given due consideration during the design phase. Production and Plant Engineering should
always be represented on the team, to ensure all future projects are brought forward for
review. Aspects and Impacts should be written/ updated and the team may consider that (a)
certain issue(s) should immediately be reflected in the list of Significant Impact items.
1.3.3.5 Operations Manager and his staff
The Operations Manager has the responsibility and authority to ensure the following is carried
out:
The correct and efficient operation of production processes and machines in accordance
with environmental requirements arising particularly from Objectives and Targets;
The provision, implementation and revision of environmental procedures, documentation
and records relating to the departments activities;
Compliance to environmental procedures;
Identification of training needs and implementation of training programmes in liaison
with EMT, HR and the Training Co-Coordinator.
It is the responsibility of staff working in all production areas to comply with environmental
procedures and to show environmental awareness where no procedures exist.
Staff should pay attention to any aspects of their tasks that have or are likely to have an
impact upon the environment and report observations to their supervisors.
Staff shall attend environmental training as per training programmes.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
6 March 2010
1.3.3.6 Manager Human Resources and her staff
Manager Human Resources and her staff shall support personnel to perform in accordance to
the Policy by planning and providing training to all employees and specific training to
employees in environmentally significant positions.
Staff shall attend environmental training as per training programmes.
1.3.3.7 Financial Controller, Manager Q.A/RA., Supply Chain Manager and their staff
The Financial Controller, Country QA/RA Manager, Supply Chain Manager and their staff
shall support the EMS by making available information required to maintain the EMS.
Staff shall attend environmental training as per training programmes.
1.3.3.8 IT Structure and support for the SEPro Database
Level 1 support is provided by BD Service Desk
Level 2 support is provided by Local IT Team and SE-Pro Coordinator:
Maintains the Lotus servers and networks.
Installs Lotus on networked PC's.
Maintains Access Control List for the database
Installs SE-Pro on local PC's
Reviews Access Control List
Creates and assigns access to documents in the system
Level 3 support is provided globally by the Corporate Environmental Manager:
Maintains database development and design
Maintains Access Control List (ACL) for the database (if allowed)
1.3.4 Responsibilities arising from SE-Pro maintenance
Environmental requirements of the EMS have been defined and broken out into action items.
These action items are stored in the SE-Pro system. Each action item has a primary
responsible person assigned who has the authority and responsibility for implementing the
action items. The progress and completion of the task are documented in SE-Pro.
Procedures pertaining to the EMS are maintained in the SE-Pro computerised system and
hard copies may be printed as required. Generally for environmental procedures a member of
the Environmental Program Team reviews and updates the procedure at least annually.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
7 March 2010
1.3.5 Organisation Flow Chart
The diagram in Figure 1 shows the relationships between the responsible parties and
illustrates the flow of information within the organisation.
OperationalManager
Plant &Environment
Engineer
Environmental
Management
Team
Staff/
Employees
Senior/Middle
Management
Communicate
Communicate
Inform
Appoint
Represent
Lead
Inform
Inform,
AssessTrainingNeeds
Report
Figure 1: Becton Dickinson - Relations between Responsible Parties
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
8 March 2010
2.0 Summary Information
2.1 Self-Monitoring Data
Summary information is provided for the period January to December 2009 inclusive, as
specified in the EPA’s Guidance Note for the Annual Environmental Report, unless otherwise
stated. This information is presented in accordance with the Guidance Note as an annualised
mass emission figure, derived from the average measured mass emission value multiplied by
the duration of the emission. The plant was operational for a total of 317 days during the 2009
calendar year.
2.1.1 Summary of Emissions to Atmosphere
IPPC Licence, Register No. P0648-01 as amended by Amendment A sets out Emission Limit
Values (ELVs) in Schedule 1(i) for emission points to atmosphere:
Vacuum Pump Exhaust, A2-1
VOC Abatement Plant, A2-2
Becton Dickinson’s licence requires monitoring of emissions to atmosphere to be carried out
biannually. However, Becton Dickinson carries out monitoring of emissions to atmosphere on
a quarterly basis to assist in the calculation of average emission values.
Table 1 summarises the mass emissions to atmosphere from Emission Point A2-1 during
2009.
Table 1: Summary of Licensed Emissions to Atmosphere from emission point A2-1
Parameter Mass Emission
2007
(kg)
Mass Emission
2008
(kg)
Mass Emission
2009
(kg)
Licensed Mass
Emission
(kg)
Total Organics
(as carbon) 1,293 666 348
1,569
Table 2 summarises the mass emissions to atmosphere from Emission Point A2-2 during
2009.
Table 2: Summary of Licensed Emissions to Atmosphere from emission point A2-2
Parameter Mass Emission
2007
(kg)
Mass Emission
2008
(kg)
Mass Emission
2009
(kg)
Licensed Mass
Emission
(kg)
Total Organics
(as carbon) n/a
1) 16 64 1,712
1) Emission point A2-2 is only commissioned since January 2008. A trend is not
available yet.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
9 March 2010
Figure 2 trends the mass emission of TOC to atmosphere from Emission Point A2-1 after the
ELC changed to 75 mg/m3 from October 2007.
Total Organics (as carbon)
(from 31st October 2007)
0
15
30
45
60
75
90
Nov-
07
Feb-0
8
Jun-
08
Sep
-08
Dec-
08
Mar
-09
Jul-0
9
Oct-0
9
Jan-
10
May
-10
mg/m
3
Figure 2: Mass Emissions to Atmosphere from Emission Point A2-1after October 2007
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
10 March 2010
2.1.2 Summary of Emissions to Sewer
The IPPC licence sets out in Schedule 2(i) Emission Limit Values (ELVs) for a single
emission point to sewer: SE-1. Monitoring of emissions to sewer is carried out every two
months. Table 3 summarises the monitoring results for 2009.
Table 3: Summary of Licensed Discharges to Sewer
Parameter Averaged Measured
Value 2007
Averaged Measured
Value 2008
Averaged Measured
Value 2009
Emission Limit Value
Concentration
(mg/l)
Annual
Load
(kg)
Concentration
(mg/l)
Annual
Load
(kg)
Concentration
(mg/l)
Annual
Load
(kg)
Daily
Mean
Load
(kg/day)
Annual
Load
(kg)
pH 7.6 - 7.4 - 7.7 - 6-10 pH
units -
BOD 165 1,866 325 3,812 356 3,950 16.0 5,072
COD 502 5,676 690 8,093 610 6,768 32.0 10,144
Suspended
Solids 238 2,716 260 3,050 251 2,785 16.0 5,072
Sulphates
(as SO4) 34 388 53 622 57 632 40.0 12,680
Detergents
(as MBAS) 0.13 1.47 0.08 0.94 0.13 1 4.0 1,268
Fats, oils
and greases 33.5 382 22.2 260 18.8 209 4.0 1,268
Phosphates 6.2 70.8 7.8 92 8.1 90 2.0 634
TOC n/a n/a 97.3 1,141 82.65 917 16.0 5,072
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
11 March 2010
A summary of the non-compliances in respect of emissions to sewer is given in Table 4.
Table 4: Details of Non-Compliance for Emissions to Sewer
Date Non compliance Cause Corrective Action
09 June 2009 Volume, BOD, COD
and Suspended
Solids exceeded.
(Volume 42 vs. 40
m3, BOD 1250 vs.
400 mg/l,
COD 1,601 vs. 800
mg/l,
Suspended Solids
733 vs. 400 mg/l)
The loading of sanitary
effluent to sewer has
increased in recent times
due to an increase in the
number of personal
working on site. At the
time of the application to
Dun Laoghaire Rathdown
for consent to discharge
to sewer in 1999 there
were 310 employees
working on site this
number has grown to 360
in 20098 and as a result
so has the loading of
sanitary effluent to sewer.
A review of the licence
limits has been requested
form the EPA and
DLRCC
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
12 March 2010
Figures 3 to 12 trend each of the licensed parameters emitted to sewer since the current
monitoring programme commenced following the granting of the IPPC licence. The licence
limits for each of the parameters are shown in red.
Volume Emitted to Sewer in One Day (Flow)
0
5
10
15
20
25
30
35
40
45
50
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
m3
Figure 3: Emissions to Sewer – Flow
Temperature
0.0
5.0
10.0
15.0
20.0
25.0
30.0
35.0
40.0
45.0
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
Figure 4: Emissions to Sewer – Temperature
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
13 March 2010
pH
0.0
2.0
4.0
6.0
8.0
10.0
12.0
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
pH
units
Figure 5: Emissions to Sewer – pH
BOD
(Daily Mean Concentration)
0
200
400
600
800
1,000
1,200
1,400
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
mg/l
Figure 6: Emissions to Sewer – BOD
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
14 March 2010
COD
(Daily Mean Concentration)
0
200
400
600
800
1,000
1,200
1,400
1,600
1,800
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
mg/l
Figure 7: Emissions to Sewer – COD
Suspended Solids
(Daily Mean Concentration)
0
100
200
300
400
500
600
700
800
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
mg/l
Figure 8: Emissions to Sewer – Suspended Solids
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
15 March 2010
Sulphates (as SO4)
(Daily Mean Concentration)
0
200
400
600
800
1,000
1,200
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
mg/l
Figure 9: Emissions to Sewer – Sulphates (as SO4)
Detergents
(Daily Mean Concentration)
0.00
20.00
40.00
60.00
80.00
100.00
120.00
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
mg/l
Figure 10: Emissions to Sewer – Detergents
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
16 March 2010
Fats, Oils & Grease
(Daily Mean Concentration)
0
20
40
60
80
100
120
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
mg/l
Figure 11: Emissions to Sewer – Fats, Oils & Grease
Phosphates (as P)
(Daily Mean Concentration)
0.00
10.00
20.00
30.00
40.00
50.00
60.00
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
May
-10
mg/l
Figure 12: Emissions to Sewer – Phosphates (as P)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0 648-01
17 March 2010
2.1.3 Summary of Groundwater Monitoring
The analyses of groundwater underlying the Becton Dickinson site for the 2009 reporting
period are presented in Tables 5 and 6. Biannual groundwater monitoring, undertaken by
Euro Environmental Services, was carried out in March and again in August 2009. The
groundwater is monitored in accordance with Condition 9.3 and Schedule 4(ii) of the IPPC
licence. Borehole BH4 is no longer available for taking groundwater samples. Becton
Dickinson informed the EPA of this situation by letter on 13th
December 2004. In addition,
there is only a single monitoring point at Borehole 10. In August 2009 Borehole 8 was
inaccessible due to temporary parking of a portacabin on the borehole.
In 2007, Becton Dickinson changed from monitoring for BTEX in the boreholes to
monitoring for the individual parameters: Benzene, Toluene, Ethylbenzene and Xylene. In
2008, BD reverted back to monitor the summary parameter BTEX.
Figures 13 to 30 trend each of the groundwater monitoring parameters, as listed in the licence,
since the licence was granted. The borehole locations have been grouped into shallow and
deep boreholes for ease of identification on the graphs. The monitoring results have been
compared against appropriate values from Irish and European legislation and guidance
documents, including the Agency’s Interim Guidance Values, as listed in Tables 5 and 6.
Table 5 lists the results of the borehole monitoring undertaken in 2009 which were above
their comparison value. All exceedances occurred on the parameter for Mineral Oils which
exceeded the Target Value of the Dutch Guideline Values from the circular on target values
and intervention values for soil remediation in four of the boreholes. The exceedances were
measured in March 2009 only and had normalised in August 2009.
Table 5: Groundwater Monitoring Results above Comparison Values
Date Parameter Borehole No. Measured Value
mg/l
Comparison Value
mg/l
BH1 (s) 67.39
BH1 (d) 60.33
BH2 (s) 118.86
BH2 (d) 197.15
BH3 (s) 106.5
BH3 (d) 144.63
BH5 (s) 238.65
Mar 2009 Mineral Oils
BH5 (d) 122.08
50/600
Becton Dickinson
Annual Environmental Report for 2008
Licence Register No.P0648-01
18 March 2010
Table 6: Summary of Groundwater Monitoring Results, March 2009
BH1 BH2 BH3 BH5 BH7 BH8 BH10 Parameter Units Comparison
Value S (1) D (2) S D S D S D S D S D
pH pH
units
6.5 – 9.5 (3)
7.4 7.6 7.6 7.5 7.2 7.4 7 7.3 7.4 7.6 7.6 7.5 7.4
COD mg/L 40 (4) 6 5 9 6 7 5 10 6 9 7 5 6 15
Conductivity µS/cm 2,500 (3) 637 606 866 703 1,159 1,002 789 610 526 645 408 698 706
Chloride mg/L 250 (3) 66.63 52.45 40.32 27.27 181.35 128.82 22.42 26.03 22.54 34.24 19.99 38.23 36.05
Diesel Range
Organics µg/L -
60.04 56.3 111.91 195.34 102.91 110.58 119.69 212.13 34.11 37.37 79.93 31.71 24.57
Petroleum Range
Organics µg/L -
5 5 5 5 5 5 5 5 5 5 5 5 5
PAHs µg/L 0.1 (3) 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1
Mineral Oils µg/L 50 / 600 (5) 67.39 60.33 118.86 197.15 106.5 144.63 238.65 122.08 13.07 4.33 3.08 2.5 15.57
BTEX µg/L 10 (6) 4.402 3.64 3.66 2.82 4.27 1 1 1 1 1 1 1 1
Major Anions
Nitrate mg/L 11.3 (3) 0.09 0.25 0.09 0.09 1.23 0.14 0.94 0.09 0.09 0.09 0.09 0.09 0.09
Sulphate mg/L 250 (3) 39.43 53.4 88.91 58.89 49.68 71.12 63.38 53.65 41.39 56.19 33.88 58.36 110.31
Major Cations
Calcium mg/L 200 (7) 73 58.89 56.99 71.92 168.6 86.42 144.7 65.95 47.21 52.93 34.92 51.73 63.6
Potassium mg/L 12 (7) 0.35 0.99 1.22 1.48 0.73 1.55 4.61 3.02 0.49 1.13 3.46 1.39 0.35
Sodium mg/L 200 (3) 16.88 22.33 83.11 24.78 32.06 28.12 14.77 14.42 30.79 61.49 12.62 28.83 24.32
Becton Dickinson
Annual Environmental Report for 2008
Licence Register No.P0648-01
19 March 2010
Table 6: Summary of Groundwater Monitoring Results, August 2009
BH1 BH2 BH3 BH5 BH7 BH8 BH10 Parameter Units Comparison
Value S (1) D (2) S D S D S D S D S D
pH pH
units
6.5 – 9.5 (3)
7.4 7.7 7.5 7.5 7.3 7.4 7.2 7.5 7.5 7.7 - - 7.2
COD mg/L 40 (4) 5 5 9 16 7 5 30 6 33 10 - - 15
Conductivity µS/cm 2,500 (3) 610 611 962 725 1,168 938 751 654 519 648 - - 789
Chloride mg/L 250 (3) 46.49 31.14 47.03 27.96 182.74 89.74 13.51 24.61 18.77 31.84 - - 37.85
Diesel Range
Organics µg/L -
12.91 4.58 1 3.22 6.23 5.56 5.01 2.72 6.68 3.44 - - 5.47
Petroleum Range
Organics µg/L -
5 5 5 5 5 5 5 5 5 5 - - 5
PAHs µg/L 0.1 (3) 0.10 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 - - 0.1
Mineral Oils µg/L 50 / 600 (5) 3.29 6.79 35.31 2.5 3.25 3.4 3.72 2.5 2.5 2.5 - - 2.5
BTEX µg/L 10 (6) 1 1 1 1 1 1 1 1 1 1 - - 1
Major Anions
Nitrate mg/L 11.3 (3) 0.09 0.56 0.09 0.09 0.35 0.09 0.09 0.09 0.09 0.09 - - 0.09
Sulphate mg/L 250 (3) 50.9 53.04 108.23 64.95 49.41 100.5 69.3 58.24 40.82 56.28 - - 121.37
Major Cations
Calcium mg/L 200 (7) 76.06 63.52 67.23 79.78 158.2 87.88 94.11 76.75 49.81 44.79 - - 94.08
Potassium mg/L 12 (7) 0.57 1.36 1.79 1.95 1.92 2.22 5.2 3.73 0.93 1.15 - - 0.59
Sodium mg/L 200 (3) 17.56 25.31 93.65 26.62 43.55 35.82 12.41 21.3 32.92 55.72 - - 32
Becton Dickinson
Annual Environmental Report for 2008
Licence Register No.P0648-01
20 March 2010
Notes for Tables 5 and 6:
(1)
S – shallow borehole
(2)
D – deep borehole
(3)
Parametric Value from SI 439 of 2000, the European Communities (Drinking Water) Regulations, 2000
(4)
Surface Water Quality Standards from SI 294 of 1989, the European Communities (Quality of Surface Water Intended for
the Abstraction of Drinking Water) Regulations, 1989
(5)
Dutch Guideline Values from the circular on target values and intervention values for soil remediation
(6)
EPA Interim Guideline Values (IGVs) for Groundwater from the interim report Towards Setting Guideline Values for the
Protection of Groundwater in Ireland
(7)
Maximum Admissible Concentrations from SI 81 of 1988, the European Communities (Quality of Water Intended for
Human Consumption) Regulations, 1988
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
21 March 2010
pH
6.8
7
7.2
7.4
7.6
7.8
8
8.2
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
pH
units
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 13(a): Groundwater Monitoring – pH (shallow boreholes)
pH
7
7.2
7.4
7.6
7.8
8
8.2
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
pH
units
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 14(b): Groundwater Monitoring – pH (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
22 March 2010
COD
0
20
40
60
80
100
120
140
160
180
200
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 14(a): Groundwater Monitoring – COD (shallow boreholes)
COD
0
50
100
150
200
250
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 14(b): Groundwater Monitoring – COD (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
23 March 2010
Conductivity
0
200
400
600
800
1,000
1,200
1,400
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µS
/cm
at
20°C
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 15(a): Groundwater Monitoring – Conductivity (shallow boreholes)
Conductivity
0
200
400
600
800
1,000
1,200
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µS
/cm
at
20°C
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 15(b): Groundwater Monitoring – Conductivity (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
24 March 2010
Chloride
0
50
100
150
200
250
300
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 16(a): Groundwater Monitoring – Chloride (shallow boreholes)
Chloride
0
20
40
60
80
100
120
140
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 16(b): Groundwater Monitoring – Chloride (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
25 March 2010
Diesel Range Organics
0
100
200
300
400
500
600
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 17(a): Groundwater Monitoring – Diesel Range Organics (shallow boreholes)
Diesel Range Organics
0
50
100
150
200
250
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 17(b): Groundwater Monitoring – Diesel Range Organics (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
26 March 2010
Petroleum Range Organics
0
5
10
15
20
25
30
35
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 18(a): Groundwater Monitoring – Petroleum Range Organics (shallow boreholes)
Petroleum Range Organics
0
5
10
15
20
25
30
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 18(b): Groundwater Monitoring – Petroleum Range Organics (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
27 March 2010
Polycyclic Aromatic Hydrocarbons
0
0.05
0.1
0.15
0.2
0.25
0.3
0.35
0.4
0.45
0.5
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 19(a): Groundwater Monitoring – Polycyclic Aromatic Hydrocarbons (shallow boreholes)
Polycyclic Aromatic Hydrocarbons
0
0.05
0.1
0.15
0.2
0.25
0.3
0.35
0.4
0.45
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 19(b): Groundwater Monitoring – Polycyclic Aromatic Hydrocarbons (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
28 March 2010
Mineral Oils
0
50
100
150
200
250
300
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 20(a): Groundwater Monitoring – Mineral Oils (shallow boreholes)
Mineral Oils
0
50
100
150
200
250
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 20(b): Groundwater Monitoring – Mineral Oils (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
29 March 2010
BTEX
0
0.5
1
1.5
2
2.5
3
3.5
4
4.5
5
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 21(a): Groundwater Monitoring – BTEX (shallow boreholes)
BTEX
0
0.5
1
1.5
2
2.5
3
3.5
4
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
µg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 21(b): Groundwater Monitoring – BTEX Oils (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
30 March 2010
Major Anions - Nitrate
0
0.2
0.4
0.6
0.8
1
1.2
1.4
1.6
1.8
2
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 22(a): Groundwater Monitoring – Nitrate (shallow boreholes)
Major Anions - Nitrate
0
0.2
0.4
0.6
0.8
1
1.2
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 22(b): Groundwater Monitoring – Nitrate (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
31 March 2010
Major Anions - Sulphate
0
20
40
60
80
100
120
140
160
180
200
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 23(a): Groundwater Monitoring – Sulphate (shallow boreholes)
Major Anions - Sulphate
0
20
40
60
80
100
120
140
160
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 23(b): Groundwater Monitoring – Sulphate (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
32 March 2010
Major Cations - Calcium
0
100
200
300
400
500
600
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 24(a): Groundwater Monitoring – Calcium (shallow boreholes)
Major Cations - Calcium
0
50
100
150
200
250
300
350
400
450
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 24(b): Groundwater Monitoring – Calcium (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
33 March 2010
Major Cations - Potassium
0
5
10
15
20
25
30
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 25(a): Groundwater Monitoring – Potassium (shallow boreholes)
Major Cations - Potassium
0
2
4
6
8
10
12
14
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 25(b): Groundwater Monitoring – Potassium (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
34 March 2010
Major Cations - Sodium
0
50
100
150
200
250
300
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (S)
BH2 (S)
BH3 (S)
BH5 (S)
BH7 (S)
BH8 (S)
BH10 (S)
Figure 26(a): Groundwater Monitoring – Sodium (shallow boreholes)
Major Cations - Sodium
0
20
40
60
80
100
120
140
160
180
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
Nov-
09
mg/l
BH1 (D)
BH2 (D)
BH3 (D)
BH5 (D)
BH7 (D)
BH8 (D)
BH10 (D)
Figure 26(b): Groundwater Monitoring – Sodium (deep boreholes)
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
35 March 2010
2.1.4 Summary of Surface Water Discharge Monitoring
The licence sets out in Schedule 4(i) two parameters that are used to monitor surface water
discharges at monitoring point SW1: pH and COD. Monitoring of surface water discharges is
carried out on a quarterly basis. A summary of the measured discharges at emission point
SW1 is presented in Table 7.
Table 7: Summary of Surface Water Discharge Monitoring
Parameter Units Averaged Measured
Value
2007
Averaged Measured
Value
2008
Averaged Measured
Value
2009
pH pH units 7.8 7.81)
8.0
COD mg/L 10.5 11.251)
7.5
Note 1): Quarter 4 monitoring of 2008 was carried out early in January 2009.
Figures 31 and 32 trend the surface water monitoring parameters, as listed in the licence,
since the licence was granted.
pH
6.8
7.0
7.2
7.4
7.6
7.8
8.0
8.2
8.4
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
pH
units
SW1
Upstream
Intermediate
Downstream
Figure 27: Surface Water Monitoring – pH
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
36 March 2010
COD
0
50
100
150
200
250
Dec-
04
Jun-
05
Jan-
06
Jul-0
6
Feb-0
7
Aug
-07
Mar
-08
Oct-0
8
Apr
-09
mg/l
SW1
Upstream
Intermediate
Downstream
Figure 28: Surface Water Monitoring – COD
Three additional monitoring locations were identified as part of the Hydrogeological Survey
undertaken in compliance with Condition 9.3.3 of the licence. The survey recommended that
monitoring be carried out at these additional locations in order to assess the impact, if any, of
Becton Dickinson’s operations on the local surface water. These monitoring locations were
agreed with the Agency in May 2005. They are located upstream of SW1, downstream of
SW1 and at an intermediate location upstream from the outfall. Monitoring was carried out at
these locations on a quarterly basis during 2009. The results are presented in Table 8.
Table 8: Summary of Additional Surface Water Discharge Monitoring, 2009
Parameter Units Averaged Measured
Value Upstream of
SW1
Averaged Measured
Value at Intermediate
Location
Averaged Measured
Value Downstream of
SW1
pH pH units 8.0 8.0 8.0
COD mg/L 6.3 11 6.5
2.1.5 Summary of Noise Monitoring
Condition 8 of the licence limits the noise level at noise sensitive locations to a sound
pressure level (Leq) of 55 dB(A) during the daytime and 45 dB(A) during the night-time.
In compliance with Condition 8 of the licence, Becton Dickinson commissioned Decibel
Noise Control to carry out the annual noise monitoring survey in December 2009.
The locations used for the noise monitoring survey are shown on the site diagram attached in
Annex III. Of the six locations selected for noise measurement, locations (2), (3) and (6) may
be regarded as noise sensitive, as they are adjacent to dwellings. The remaining locations,
(1), (4) and (5), may be taken as site boundary positions.
Daytime and night-time measurements were conducted on 12 December 2009. The results of
the annual noise monitoring survey are given in Table 9.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
37 March 2010
Table 9: Summary of Noise Monitoring
Location Time LAeq LAF90 LAF1 Tonal Impulsive Remarks
1 11:49:08 63 51 71 No No
Site & Pottery Road
traffic.
1 23:38:39 54 46 66 No No
Pottery Road traffic,
plant noise audible.
2 10:00:06 56 51 65
Yes @
25Hz No
Site traffic. Tonal
frequency not audible.
2 23:06:59 49 47 55 No No Pottery Road traffic.
3 10:37:30 53 51 60 No No
Site traffic & plant
noise audible.
3 22:41:15 54 47 65 No No
Distant traffic & plant
noise.
4 11:13:22 60 57 64 No No
Site traffic & plant
noise audible.
4 22:19:52 55 49 64 No No
Distant traffic & plant
noise.
5 12:58:49 61 60 66 No No Plant noise.
5 21:59:02 60 59 65
Yes @
250Hz No
Plant noise. Tonal
noise not audible in
noise sensitive
locations.
6 13:43:00 52 51 57 No No
Distant road traffic,
plant noise audible.
6 00:08:44 45 42 51 No No
Distant road traffic,
plant noise audible.
Table 10: Summary of Non-Compliances
Date Non- Compliance Cause Corrective Action
12 Dec 2009
Exceedance of night time noise
level in location (2)
(49 dB(A) vs. 45 dB(A))
Pottery road traffic
12 Dec 2009
Exceedance of night time noise
level in location (3)
(54 dB(A) vs. 45 dB(A))
Distant traffic & plant
noise
Plant noise is a
continuous contributor
and reflected mainly in
the LAF90 which is
47 dB(A) in both
locations. While
contribution of traffic to
the LAeq is outside the
plants control, the plant
will implement a new
programme to reduce
noise from equipment at
the back of the plant in
an effort to reduce the
LAF90.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No.P0648-01
38 March 2010
2.1.6 Waste Management Summary
In compliance with condition 7 of the IPPC licence, a waste record is maintained at Becton
Dickinson for hazardous and non-hazardous waste. The following details are recorded in the
waste record:
(a) The tonnages and EWC Code for the waste materials listed in Schedule 3(i)
Hazardous Wastes for Disposal/Recovery and Schedule 3(ii) Other Wastes for
Disposal/Recovery, sent off-site for disposal/recovery.
(b) The names of the agent and carrier of the waste, and their permit details (to include
issuing authority).
(c) Details of the ultimate disposal/recovery destination facility for the waste and its
appropriateness to accept the consigned waste stream, to include its permit details and
issuing authority.
(d) Written confirmation of the acceptance and disposal/recovery of any hazardous waste
consignments sent off-site.
(e) Details of all wastes consigned abroad for Recovery and classified as ‘Green’ in
accordance with the EU Transfrontier Shipment of Waste Regulations (Council
Regulation EEC No. 259/1993, as amended). The rationale for the classification must
form part of the record.
(f) Details of any rejected consignments.
(g) Details of any approved waste mixing as per Condition 7.6.
(h) The tonnages and EWC Code for the waste materials listed in Schedule 3(i)
Hazardous Wastes for Disposal/Recovery and Schedule 3(ii) Other Wastes for
Disposal/Recovery, recovered on-site.
Table 11 overleaf presents a summary of the annual waste arising for the 2009 reporting
period.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
39 March 2010
Table 11: Summary of Annual Waste Arising for 2009
European
Waste
Catalogue
Code
Hazardous
(Yes/No)
Description of Waste Quantity
(t/year)
Disposal/ Recovery
Code
Location of Disposal/
Recovery
Name of Waste Disposal
Recovery Contractor
Licence / Permit Reference
for Treatment Facility
06 08 02* Yes Recovered HFE
Waste
7.448 R2 Mullingar Business
Park, County
Westmeath.
Soltec (Ireland) Limited W0115-01
06 08 02* Yes Non –recovered HFE
Waste
16.226 R2 Mullingar Business
Park, County
Westmeath.
Soltec (Ireland) Limited W0115-01
11 01 13* Yes Degreasing waste
(kerosene)
0.092 R2 Safety Kleen Safety Kleen W0099-01
13 01 13* Yes Waste hydraulic oil 12.600 R9 ENVA Ireland,
Co. Laois
ENVA Ireland W0184-01
15 01 10* Yes Empty drums 1.18 R4 Rilta Environmental,
Co. Dublin
Rilta Environmental W0192-02
15 01 10* Yes Empty drums 0.439 D10 AVG, Germany Indaver Ireland IB2234/AVG-GENB-2
15 02 02* Yes Solid & oily waste 0.410 R1 Lindenschmidt,
Germany
ENVA Ireland E97095037
16 06 01* Yes Lead acid batteries 0.125 R5 KMK Metals,
Co. Offaly
Irish Lamp Recycling
Company
W0113-02
18 01 03 Yes Customer complaints 0.060 D1 SRCL Kylemore,
Dublin 10
Ecosafe System Limited W0054-02
20 01 21* Yes Fluorescent tubes 0.084 R4/R5 Irish Lamp Recycling
Company
Irish Lamp Recycling
Company
02/2000
20 01 35* Yes WEEE 3.221 R4 Irish Lamp Recycling
Company
Irish Lamp Recycling
Company
02/2000
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
40 March 2010
Table 11: Summary of Annual Waste Arising for 2009 (Cont/d)
European
Waste
Catalogue
Code
Hazardous
(Yes/No)
Description of Waste Quantity
(t/year)
Disposal/ Recovery
Code
Location of Disposal/
Recovery
Name of Waste Disposal
Recovery Contractor
Licence / Permit Reference
for Treatment Facility
15 01 01 No Paper and cardboard 90.92 R3 Ballymount Cross,
Tallaght, Dublin 24.
Veolia W0039-02
15 01 03 No Timber pallets 101.95 R3 Bailey Waste Paper Co.
Ltd., Dublin
P. Mulligan Pallet Sales WPT 01
16 03 06 No Off-spec.
components and
granulated waste
199.98 R3 Thorndale
Environmental
Thorndale Environmental WDL 14
16 03 06 No Off-spec. products
and general waste
264.58 D1 Ballymount Cross,
Tallaght, Dublin 24.
Veolia W0039-02
16 03 06 No Composite paper 161.07 D1 Ballymount Cross,
Tallaght, Dublin 24.
Veolia W0039-02
20 01 40 No Metal 20.30 R4 Ballymount Cross,
Tallaght, Dublin 24.
Veolia W0039-02
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
41 March 2010
Table 12 lists the Waste Collection Permit numbers for each waste contractors collecting
waste from Becton Dickinson in 2009.
Table 12: Waste Collection Permit Details
Waste Collection Contractor
Waste Collection Permit
No.
Soltec (Ireland) Limited
CP D 78/1
Safety Kleen
WCP-DC-09-1223-01
ENVA Ireland
CP D 160/1
Rilta Environmental
CP D 252/2
Irish Lamp Recycling Company
WPC-DC-08-1115-01
Ecosafe System Limited
CP/CD/09/1203/01
Thorndale Environmental
WCP-LK-08-580-01
Veolia Environmental Services
WCP-DC-08-1120-01
Guinan Haulage Ltd.
WCP/OY/09/626-01
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
42 March 2010
2.2 Agency Monitoring and Enforcement
2.2.1 Air Monitoring
On 19 June 2009 the EURO Environmental Services carried out air monitoring on behalf of
the EPA at emission points A2-1 and A2-2. The results of this monitoring exercise are listed
in Table 12.
Table 12: Results of Agency Air Monitoring
Emission Point Parameter Result mg/m3
A2-1 TOC 94.2
A2-2 TOC 2.5
The result for A2-1 exceeded the Emission Limit Value of 75 mg/m3. This non-conformance
was addressed as per letters to the Agency dated 12 and 21 October 2009.
2.2.2 Surface Water Monitoring
The Agency visited the site and carried out monitoring of the emissions to surface water at
emission point SW1 on 28 September 2009. No sample was obtained due to dry conditions.
2.2.3 Site Inspection Report
The Agency visited the site on 02 April 2009 and carried out a Site Inspection. The Site
Inspection Report found that Becton Dickinson was in non-compliance with two conditions
of the licence on the day of the inspection. The Agency also made five observations to
improve environmental performance of the facility. Becton Dickinson responded to the
report on 28 April 2009, setting out the actions that Becton Dickinson will take to address the
non-compliance issues and to improve environmental performance at the facility.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
43 March 2010
2.3 Energy & Water Consumption
2.3.1 Energy Consumption
Energy consumed by Becton Dickinson during 2009 as electricity, natural gas and gas oil is
summarised in Table 13. All values have been converted into megawatt hours (MWh).
Small quantities of gas oil are used on an annual basis to test run and maintain the fire water
pumps and standby generator and therefore some of the figure included is estimated.
Table 13: Summary of Energy Consumption
Energy Source 2005 Usage
(MWh)
2006 Usage
(MWh)
2007 Usage
(MWh)
2008 Usage
(MWh)
2009 Usage
(MWh)
Electricity 20,395 20,368 19,897 19,596 19,381
Natural Gas 1,740 1,528 1,776 2,046 2,456
Gas Oil 8.61)
8.51)
2.1 13.1 9.8
Total 22,144 21,905 21,675 21,655 21,847
Note 1) Estimates
2.3.2 Water Consumption
Becton Dickinson has not received meter readings for the municipal water supply from Dún
Laoghaire-Rathdown County Council since the first quarter of 2003. Becton Dickinson
contacted the County Council in February 2005 seeking to obtain meter readings in order to
complete the AER for the previous reporting period. Further contact was made in June 2005
and again during 2006. Becton Dickinson was informed that the County Council was in the
process of updating the municipal water meters.
During 2007 Becton Dickinson installed a water meter on the water supply to the storage
tanks at the site, which in turn supply the process areas. Following calibration of this meter,
the records indicate that an average of 21.8 m3 is supplied per day, yielding an estimated total
supply to the production areas of 6,900 m3 per annum.
In March 2008 the Local Authority installed a water metre on the incoming supply line to the
site. This meter records the total quantity of water supplied to the site, including both the
production and office areas. The meter is operational since June 2008 and our own readings
obtained from this meter indicate a daily consumption of 40 m3, or an annual total of
12,720 m3. Once data is available from the Local Authority, Becton Dickinson will report this
in our Annual Environmental Report.
For 2009 water consumption was obtained from invoice data and the annual volume used is
21,521 m3.
2.3.3 Trending of Resource Consumption
In accordance with the Agency’s inspection observation of 25th
May 2006 following the site
inspection on 27th
April 2006, Table 14 and Figures 33 and 34 trend resource consumption
against production output. As can be seen from the figures, the specific energy and specific
water consumption have decreased over the five year period from 2004.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
44 March 2010
Table 14: Summary of Resource Consumption
2004 2005 2006 2007 2008 2009
Million Units
produced 1,607
Note 1 1,806
Note 1 1,955
Note 1 2,123 2,361 2879
Specific Energy
Consumption
(MWh per million
units)
12.8
12.3
11.2
10.2
9.2
7.6
Specific Water
Consumption
(m3 per million units)
13.8
12.3
11.3
3.3 Note 2
5.4
7.5
Note 1: This includes units that were only packaged at the site.
Note 2: Meter readings for water consumption in ancillaries were available from mid 2007. Refer to Section
2.3.2.
Spec. Energy Consumption (MWh per MM units)
0.0
2.0
4.0
6.0
8.0
10.0
12.0
14.0
2005 2006 2007 2008 2009
MW
h p
er
MM
un
its
Specif ic Energy Consumption (MWh per MM units)
Figure 29: Specific Resource Consumption – Energy Usage
Specific Water Consumption (m3 per million units)
0
2
4
6
8
10
12
14
16
2004 2005 2006 2007 2008 2009
m3 p
er
MM
units
Specif ic Water Consumption (m3 per million units)
Figure 30: Specific Resource Consumption – Water Usage
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
45 March 2010
2.4 Environmental Incidents & Complaints
There were no environmental incidents at the site during 2009.
There were three noise complaints during the 2009 reporting period the summary of which is
given in Table 15.
Table 15: Summary of Complaints
Date Complaint Cause Corrective Action
11 March 09 A general complaint to a local
councillor.
As the complaint was of a
general nature we are not in
a position to link it back to
any particular aspect of our
operation.
Noise levels from the site
have been in compliance
with noise levels set in
our licence as confirmed
by annual surveys.
17 July 09 Neighbour requested update on
noise surveys of the site and
technical updates.
Neighbour felt noise was
caused by equipment ot he
back of the plant.
The most recent noise
survey at the time from
Dec 2008 was forwarded
to the neighbour.
07 Dec 09 Neighbour complaining about
high pitch ringing noise in his
bedroom.
The equipment located on
the roof of the boiler house
maybe audible at high
level.
A subsequent noise
survey did not capture
any tonal noise at 3 and 3
m height. We will
undertake noise
monitoring at roof level
before and after
modifications to the area
as per our noise
programme outline in
Annex IV.
2.5 Summary of Abatement Plant Bypass Events
Four bypass events were recorded in 2009 as summarised in Table 16. All of these events led
to non-significant release of solvent into the air.
Table 16: Summary of Complaints
Date Duration
hr
Cause Corrective Action
08/06/2009 26.00
ID Fan contactor failed on restart ,
this also look out the NST 2004 safety
lock stop relay
Contactor repaired. New contactor
and safety relay were ordered from
Lesni.
10/06/2009 1.00
18/06/2009 1.13
19/06/2009 0.05
Fan 80.40 Trip due to high air
temperature from scrubber
Plant PLC needed to be reset to
correct a program fault that prevented
chilled water from being supplied to
scrubber during drying stage of
regeneration. During annual
maintenance service Lesni Contractor
to verify that all program functions
operate correctly
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
46 March 2010
3.0 Management of the Activity
3.1 Introduction
In this section of the AER, we report on the recent initiatives undertaken at Becton Dickinson
to improve our environmental performance. We also set out our environmental objectives
and targets and report on the progress of our Environmental Management Programme (EMP)
for the period 2008 – 2012.
3.2 Schedule of Environmental Objectives & Targets
Our Environmental Objectives and Targets for the 5-year period 2008 – 2012 are set out in
Table 17.
Table 17: Schedule of Environmental Objectives & Targets
Top-tier Environmental
Objective
Environmental Targets
Waste Reduction Measures 1) Monitor waste levels at pen needle assembly,
moulding and pen packaging on a daily basis
and generate report of same.
2) Recycle cartonette waste from packaging
area
Energy Reduction Opportunities 1) Continuation of energy savings in moulding
2) Reduce Compressed Consumption
Control of Solvent emissions 1) Continue to improve solvent usage efficiency
and monitoring of line solvent usage versus
lubricant waste, regenerated solvent and
process emissions
Noise Reduction 1) Improvements to cooling plant on top of
boiler house
3.3 Environmental Management Programme (EMP) Report
Annex III contains individual EMP Reports for programmes completed in 2009. Each report
contains an overview of the programme objectives, the tasks required to complete the
programme and a summary of the progress on each task.
3.4 Environmental Management Programme 2008 – 2012
Our Environmental Management Programme for the period 2008 to 2012 is set out in
Annex IV.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
47 March 2010
3.5 Pollution Emission Register – Report for 2009
Table 18 lists the emissions reported to the Agency in the AER/ PRTR Electronic Reporting
Workbook under the Agency’s Web-Based Reporting System and the PRTR in accordance
with EC Regulation 166/2006 concerning the establishment of a European Pollutant Release
and Transfer Register. These emissions are included in Annex I and submitted to the Agency
electronically.
Table 18: Emissions Reported in the AER/ PRTR Electronic Reporting Workbook for 2009
Emission
Release Medium Type of Emission / Potential Emission
Total Organics (as C) Air Routine (process)
Carbon Dioxide Air Routine (combustion)
Non-methane VOCs Air Routine (process)
BOD Water (Sewer) Routine (process)
COD Water (Sewer) Routine (process)
Oils, Fats & Grease Water (Sewer) Routine (process)
Suspended Solids Water (Sewer) Routine (process)
Sulphates (as SO4) Water (Sewer) Routine (process)
Detergents (as MBAS) Water (Sewer) Routine (process)
Total Organic Compounds (as C or
COD/3) Water (Sewer) Routine (process)
3.6 Pollutant Emission Register – Proposal for 2010
BD do not envisage any significant change in the operations. Therefore BD propose to report
on the same emissions in 2010 as shown for the current year in Table 18 above.
3.7 Solvent Usage
Table 19 lists the solvents used at the site during 2009.
Table 19: Solvent Usage (2009)
Material Annual Usage
2006 (kg)
Annual Usage
2007 (kg)
Annual Usage
2008 (kg)
Annual Usage
2009 (kg)
1 1,2 transdichloroethylene
19,559 26,157 21,600 15,300
2 Methyl nonafluoroisobutyl ether
11,366 15,200 12,480 8,840.00
3 Methyl nonafluorobutyl ether
11,366 15,200 12,480 8,840
4 Ethyl alcohol
1,174 1,569 1,440 1,020
5 Ethylacetate
410 600 410 537
6 Isopropanol
615 600 750 660
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
48 March 2010
3.8 Fugitive Emissions Assessment Report
3.8.1 History of Solvent Use
VOC solvents have been used for the surface coating of cannula for more than 20 years at BD
Dun Laoghaire. In recent years the company has replaced the solvent used in the surface
coating process, from CFC to HCFC and more recently to a new solvent mixture. This switch
was carried out to replace substances that had a high ODP (Ozone Depleting Potential) as
well as being a Hazardous Air Pollutant. The currently used substitute solvent is classified as
having an ODP of 0 compared to 0.11 for the HCFC. In addition to the introduction of a less
harmful solvent the quantity of solvent used has decreased in recent years against a backdrop
of increased production volumes.
Figure 27: Solvent usage in Dun Laoghaire-FY98 – FY 09
3.8.2 Application of Best Available Techniques
A key element of our IPC licence has been the application of BAT (Best Available
Techniques) in addressing the aspects & impacts that arise due to our manufacturing
operations. BD has been actively applying the BAT principal in reducing the fugitive
emissions of VOC Solvent. In 2006/2007 BD commenced a process of reducing the quantities
of solvent used by substitution with pure Silicon Oil in NP lubrication. In particular the use of
solvent in the NP lubrication process caused the overall high fugitive emissions levels. The
use of solvent in the NP lubrication was a customer requirement until August 2009 and as
such was outside of our control. Since using Si Oil the solvent consumption figure has
reduced considerably.
In addition, the company has been using high efficiency application techniques in the surface
coating process. As a result the quantities of solvent consumed in this process per annum has
Solvent usage in Dun Laoghaire - FY98 to FY09
37.3 49.1
58.9 64.9
88.1 104.1
84.9
19.1
23.1
39.6
59.6 48.4
36.0
0.0
20.0
40.0
60.0
80.0
100.0
120.0
FY98 FY99 FY00 FY01 FY02 FY03 FY04 FY05 FY06 FY07 FY08 FY09 (Budget)
Tons
Replacement HCFC
1 PN line
and 1ml
line using
HCFC
2 PN lines
and 1ml
line using
HCFC
3 PN lines
and 1ml
line using
HCFC
5 PN lines
and 1ml
line using
HCFC
8 PN lines using HCFC.
Phase out of HCFC on IV
end and conversion of
same to HFE. Only using
HFE from Q2 onwards.
NP conversion to Si oil #4 : Oct 04
#5 : Dec 04
#8 : May 05
5 PN lines
and 1ml
line using
HCFC
7 PN lines and
1ml line using
HCFC.
NP conversion to
Si oil #1 : Dec 03
#2 : Jan 04 #3 : Apr 04 #7 : May 04 #6 : Aug 04
2 PN lines
and 1ml line
using
HCFC
9 PN lines using
HFE. NP
conversion back
to HFE #6 : Apr 06
#8 : May 06 #1 : Jun 06 #9 : Aug 06
11 PN lines
using HFE.
On average
4 lines had
HFE on NP
end
throughout
year
11 PN lines
using HFE.
On average 4
lines had HFE
on NP end
throughout
year.
Abatement
plant started
up in Q1
12 PN lines
using HFE
on IV end. 2
lines only
using HFE
on NP end
for Q1 only.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
49 March 2010
reduced from 58 tonnes in 2007 to 48 tonnes in 2008 and 34 tonnes in 2009 despite an
increase in production volumes.
In 2007 a vapour collection system was installed at each pen needle assembly line. The
collected vapours are then treated in the Abatement Plant which was installed in 2007/2008.
A recovered solvent stream is now recovered from this plant.
3.8.3 Fugitive Emissions Status
A summary of the development of reducing solvent consumption and fugitive emissions is
summarised in Table 20. Most of the consumption is made up of solvent used in the
lubrication process.
Reduction at point of use, introduction of the abatement plant and replacement of the solvent
based lubricant with Silicon Oil on the NP have all contributed to the reduction of fugitive
emissions from 80 to 44 %.
Table 20: Fugitive Emissions Status
2007 2008 2009
Solvent Consumption t 59 49 35
Stack Emissions A2-1 t 5 3 2
Recovery t 0 6 10
Waste t 6 13 8
Fugitive t 48 27 15
Fugitive % 80% 56% 44%
In early 2010 a Management Review of our fugitive emissions was conducted and it was
noted that despite the significant improvements in vapour collection and abatement BD is not
reaching the 20% limit for fugitive emissions. To work towards this target a programme
throughout 2010 is proposed in Annex IV.
3.9 Report on ELRA & CRAMP
The site’s Closure Restoration & Aftercare Management Plan was revised to update minor
changes in the operation and include further monitoring results of groundwater sampling
carried out since the original CRAMP in 2005.
There was no new contamination and the known risk of groundwater contamination is being
managed by groundwater monitoring as per Schedule 4(ii) of the licence. No results exceeded
the Dutch Intervention Levels.
As there were no changes in the Risk Category of the site the closure plan and financial
provisions remain adequate.
Becton Dickinson Annual Environmental Report for 2009
Licence Register No. P0648-01
50 March 2010
4.0 Licence-Specific Reports
In accordance with the conditions of the licence, Schedule 5(i) in particular, the following
items were completed to report on between January and December 2009: Table 21: Licence Specific Reports
Report Licence
Condition
Status
Emissions to atmosphere summary 5.5
5.6
A summary report on emissions to atmosphere was
submitted to the Agency following each round of the
monitoring programme. See Section 2.1.
Emissions to sewer summary 6.2
6.3
A summary report on emissions to sewer was submitted
to the Agency following each round of the monitoring
programme. See Section 2.1.
Waste Management report 7.8 A summary of reports compiled during 2009 is included
in Section 2.1.6.
Resource consumption summary n/a A summary report on consumption of energy and water
is included in Section 2.3.
Complaints summary 12.3 Three noise complaint received during 2009 are
summarised in Section 2.4.
Schedule of Environmental
Objectives & Targets
2.2.1 See Section 3.2.
Environmental Management
Programme - Proposal
2.3 Proposed programmes for the 2008-2012 period
contained in Annex IV
Environmental Management
Programme - Report
2.3 Completed programmes for period 2009 refer to
Annex III
Pollution Emission Register -
proposal
2.4 Emissions as per 2009 PRTR are proposed for 2010. See
Section 3.6.
Pollution Emission Register - report 2.4 Pollutant Release and Transfer Register was submitted
with the AER for 2008. See section 3.5.
Fugitive Emissions to atmosphere
report
5.8 The report on fugitive emissions for the 2009 reporting
period is in Section 3.8.
Noise Monitoring Report 8.1 An annual survey was done in December 2009. A
summary of the report is contained in Section 2.1.4.
Surface water monitoring summary 9.1.3 Summary report in Section 2.1.4
Groundwater monitoring summary 9.3.6 Summary report in Section 2.1.3
Active underground tank and
pipeline testing and inspection report
(every three years)
9.4.5 No such installations exist on site.
Bund integrity report (every three
years)
9.4.1 The bund test certificates were submitted to the Agency
during 2005. A bund integrity report is attached in
Annex VI.
Reported Incidents 4.3 No incidents occurred during the 2009 reporting period.
Environmental Liabilities Risk
Assessment (Closure, Restoration
and Aftercare Management Plan)
15.3.1 The CRAMP was revised in 2009 as per Section 3.9
Energy Audit 10.1 Not required for this reporting period. An energy Audit
was conducted during 2005 and the findings of the audit
were reported to the Agency in the 2005 AER.
Diversion of surface water emissions
away from the sewer
9.1.6 A proposal was submitted to the Agency on 18th
July
2006 for diverting surface water from sewer. The
Agency has approved the proposal and BD has initiated
this programme set out in the proposal.
ANNEX I
AER/ PRTR Electronic Reporting Workbook
ANNEX II
SITE LAYOUT
Noise Monitoring Locations
1
2
3
4
5
6 Meadow Vale.
ANNEX III
ENVIRONMENTAL MANAGEMENT PROGRAMME
PROGRESS REPORT ON PROGRAMMES COMPLETED IN 2009
Project Title: Phase Out R 22
Related Objective & Target: To eliminate the use of R 22 refrigerant gases
Rationale for undertaking this project: To comply with Ozone depleting substances Regulation 2000/2037 - Phase Out of ODS - Refrigeration
Units
Targets Programme Responsibility (Position/ Job Title)
The use of R 22 at BD Dun Laoghaire shall
cease by 1st January 2010.
We have completed a survey of all
refrigeration equipment on site. See Action
Item AIR.000.010 Maintain Inventory of
HCFC and HFC Sources. All opportunities to
replace older units will be taken and a final
phase out plan will be set out in 2008 for any
remaining units.
Since 2006 all new units use non-ozone
depleting refrigerants. Air conditioners on site
are service annually and report maintained of
equipment containing R22. The current list is
placed in Action Item AIR.000.010 Maintain
Inventory of HCFC and HFC Sources.
Units replaced in 2009 were
Microlab air conditioners x 2 units
In June 09 BD decided to keep the remaining
4 split R 22 units until they fail and replace
them after failure.
In the case of the Cobalt Chiller we have
requested Aggreko to propose a contingency
plan to install a rental unit until a new one can
be installed. There is a back up system
Plant & Environmental Engineer
installed on the moulding Chiller unit which
can maintain the system on failure until a more
permanent fix can be put in place. There is
also the possibility of retrofitting the Cobalt
chiller to an alternative gas should it fail. This
would require some gaskets replacement and
disposal of the refrigerant gas as hazardous
waste. Should it be required we will do this
modification. In early 2010 we expect a
decision on the new sterilisation facility and
we will know whether or now it will go ahead.
This will influence our decision on the chiller
for the existing sterilization unit as it would be
decommissioned in 2 years time.
Management of the remaining units is now
tracked routinely in EMS Action Item
AIR.000.011 Use of ODS
Estimate Completion % : 100 % Date of Estimate:
31 December 2009
Comments/ Rational for Estimates:
Time Frame: Manage waste refrigerant gases in compliance with national legislation until their ban in 2014.
Project Title: Minimise Incidents of bypass of the HFE Abatement Plant
Related Objective & Target: Control of Solvent Emissions
Rationale for undertaking this project: During a bypass of the HFE Abatement Plant untreated solvent vapours are released to the atmosphere
and so bypass events should be reduced to a minimum.
Targets Programme Responsibility (Position/ Job Title)
Monitor incidents of bypass
Receive approval from EPA for Procedure in the
event of bypass
The Trend BMS system receives a signal from the
Lesni HFE Abatement Plant indicating that the
plant is either running in process or in bypass.
Each bypass event will be recorded, the duration
of the bypass calculated and notified to the
agency. A full record of bypass events will be
retained and included with the AER.
There were no bypass incidents in 2008. Four
bypass events occurred in 2009 and were reported
to the EPA. A summary of these bypass event will
be submitted annually in the AER.
Make submission to EPA on the procedures that
will be taken in the event of a bypass event.
A written bypass procedure was submitted to the
EPA.
The revised procedure is submitted to the EPA by
01 April 2010.
The event report log was revised after its initial
submission to the EPA and was accepted after
review.
Environmental Engineer
Environmental Engineer
Estimate Completion % : 100 % Date of Estimate: 16 March 2010 Comments/ Rational for Estimates:
Time Frame: complete
ANNEX IV
ENVIRONMENTAL MANAGEMENT PROGRAMME
NEW PROGRAMMES FOR 2008 – 2012
Project Title: Monitor waste levels at pen needle assembly, moulding and pen packaging on a daily basis and generate report of same.
Related Objective & Target: Waste Reduction Measures
Rationale for undertaking this project: In FY 07 BD Dun Laoghaire produced > 400 tonnes that ultimately ended up in landfill. With landfill
costs in excess of €260 per tonne and the requirements from the waste management there is a need to reduce this figure.
Targets Programme Responsibility (Position/ Job Title)
Reduce Waste at pen needle assembly to
7.05%.
Track Moulding Production Waste and reduce
waste levels by – 5% over FY08
The total pen needle production waste figure
for 2007 was 7.35 down from 7.61% in 2006.
Weekly production reports highlight the levels
of waste at cannulator, PILS & Labeller Stages
of assembly.
The weekly production reports for 2008 show
total waste for assembly at 5.93%. This is a
significant improvement from 2007 and is as a
result of a comprehensive maintenance
programmes.
Moulding production and waste data is tracked
in the weekly production report. From this
report the total moulding output in tonnes of
product is calculated. All moulding waste is
sent to Thorndale Environmental for recycling.
2009
Moulding Output 3,678 Tonnes
Recycled moulding waste 83 Tonnes
Moulding Waste 2.26%
2008
Moulding Output 3,070 Tonnes
Recycled moulding waste 84 Tonnes
Moulding Waste 2.73%
Operations Manager
Environmental Engineer
Track Packaging waste levels and reduce by -
5% over FY 08
The moulding waste % will now be used as a
baseline for comparisons.
An accurate method of tracking packaging
waste data has not been identified as yet.
However the proposed EMP for 2009 will
address packaging waste arising and it hoped
that and accurate method of measurement will
form part of this programme.
We have investigated the data available post
assembly:
Waste in packaging arises as product, material
and QC rejects. There is no report available
and figures tracked as part of SAP work
orders.
Steri waste is reported on a log sheet and is
not compiled into total units.
Product rejected for quality reasons post Steri
is not tracked, but included in MRB reports.
Environmental Engineer
Estimate Completion % : 75 % Date of Estimate: 31 March 2009 Comments/ Rational for Estimates:
Time Frame: Programme to continue until 2012.
Project Title: Recycle cartonette waste
Related Objective & Target: Opportunities to divert waste from landfill
Rationale for undertaking this project: Cartonettes are a valuable material of high quality to recycle.
Targets Programme Responsibility (Position/ Job Title)
Identify a recycler.
Achieve 100 % segregation of
cartonettes from general waste.
Contact current collector from DL or DR and suggest
collection.
Our waste contractor Veolia has confirmed that they
can accept this material for recycling provided it is
baled.
Agree collection containers and size.
FIBC can be used to collect cartonette waste for
recycling
Provide collection points at source.
A small baler can be located in the Japan Packaging
area in early 2010 as a pilot to assess handling by the
operators.
The packaging area is going to be moved to a new
location in the warehouse. When this move is
completed a collection system for this area will be
looked at.
Train packaging operators in necessity to break out
product and separate cartonettes.
Train packaging operators in all suitable materials
arising on site.
Environmental Engineer
Environmental Engineer
Environmental Engineer
Provide material for collection
Obtain EPA approval
Implement handling system to prepare material for
collection, e.g. bags, bales etc.
Pending outcome of the pilot bales will be presented
for collection.
Notify EPA of new waste stream and approved
collector.
As Veolia are an approved waste contractor EPA
approval is not required
Environmental Engineer
Environmental Engineer
Estimate Completion % : 25 % Date of Estimate: 04 December 2009
Comments/ Rational for Estimates:
Time Frame: By end of FY11 divert all cartonette waste into separate waste stream.
Project Title: Continuation of energy savings in moulding
Related Objective & Target: Energy Reduction Opportunities
Rationale for undertaking this project: In FY 08 BD Dun Laoghaire used 20 GWH of electricity, moulding uses 48% of this and makes
further initiatives worthwhile for savings targets.
Targets Programme Responsibility (Position/ Job Title)
Introduce large electric cover moulding
machine.
Carryout trial on electric moulding machine
for cover moulding. With the development of
larger tonnage electric moulding machines
this trial will determine the feasibility and cost
benefit of installing an electric cover moulding
machine
Trials were carried out on an Engel
EM1640/280 T electric machine. It satisfied
the selection criteria and an order has been
placed with Engel for a machine to produce
hybrid covers for PN Lines 14 & 15. The
expected electrical savings compared to the
current moulding machines was >40%.
Factory acceptance testing exceeded these
expectations with a saving of 45 kW per
machine or 62.5%.
The machine was installed December 09 and
detailed energy comparison will continue after
installation.
Financial justification for more machines of
this type will be based on the results of the
energy survey.
Senior Moulding Engineer/ Moulding
Technician
Install induction heating to barrel of moulding
machines.
Install camera vision system on the Fanuc
Moulding Machines
The barrels of all moulding machines currently
use a coil heating system. The quantity of
electricity consumed by the coil heating
system will be measured with using a
dedicated electricity meter and then compared
to the induction heating system. A cost benefit
analysis and payback will then be generated to
determine the viability of this project.
Energy monitoring completed on KM
machines. Feedback from BD Fraga who were
testing induction heating in 2009 did not
indicate benefits making it worthwhile to
pursue this installation.
This will enable moulding to run hub moulds
on faster cycle times. This will lead to an
overall saving as the presses are making more
product per hour.
The vision system has been installed on all 15
FANUC machines and is operational on 12
machines in production at the end of 2009.
The remaining 3 systems will be operational in
2010 when validation of the machines is
complete.
The numbers of cycles were studied on
machine B3 and improvements compared to
machine A6. The output per kW per day has
increase by 9.74%.
Senior Moulding Engineer/Moulding
Technician
Senior Moulding Engineer/ Moulding
Technician
Software changes to clamp pressure and
injection pressure on Krauss Maffei machines.
The accumulator used to supplement clamp
pressure can be taken out by a software
change.
Change software to start injection at a lower
clamp pressure to reduce cycle time.
Senior Moulding Engineer/ Moulding
Technician
Estimate Completion % : 80%
Date of Estimate: 18 March 2010
Time Frame: While these projects will be completed in 2010, additional machine changes may continue until 2012.
Project Title: Continue to improve solvent usage efficiency and monitoring of line solvent usage versus lubricant waste, regenerated
solvent and process emissions
Related Objective & Target: Control of Solvent Emissions
Rationale for undertaking this project:
To control the emissions of VOCs from the site to achieve compliance with the 20% target for fugitive emissions from solvent usage on
site.
Targets
Programme Responsibility
(Position/ Job Title)
To maintain usage level of
Replacement of HFE with silicone oil for surface coating of NP end of pen
needles.
In 2009 we ceased the usage of lubricant on the NP end.
Monitoring, Controlling and Standardizing of Chiller Temperatures:
The Chiller temperatures of all Pen Needle Lines has been standardised at
5 °C to help reduce evaporation of HFE solvent. The temperature reading
from the chillier has been linked into the PLC controller for the Pen Needle
lines and if it goes out of range an alarm is displayed on the operator screen.
Design and installation of IV Cascade Flush Block and Cascade bath made
of stainless steel to avoid jellying and to reduce the usage.
In 2008 the installation of the new cascades was completed.
In 2010 we will work on an interlock system to shutdown the lubricant flow
if the cover of the cascade is removed to stop unauthorised removal of the
cover.
Operations Manager
Production Engineer
Production Engineer
Production Engineer
Account for unknown losses of
HFE
Analyse the correlation between
TOC monitoring and HFE
concentration in stack
emissions.
Monitoring of HFE usage on a daily / weekly basis to control and maintain
the gains achieved.
The HFE usage is monitored on-going and is the input into our mass
balance calculation.
Carry out a Blitz in 2010 with regard to all processes on site where HFE is
handled. From decanting to dispensing into process to collection of waste.
The Blitz was carried out 19 March 2010. The resulting map of the HFE
usae flow was documented and describes opportunities for improvement. A
number of follow-up actions were identified which will by addressed in the
next few months.
During routine monitoring of stack emissions we will take a grab sample of
the stack gas and ask the solvent manufacturer to use FDIR analysis to
determine the HFE concentration.
A grab sample was taken during the first quartely monitoring of stack A2-1
and is being sent to 3M for analysis.
Senior Production
Engineer PM
Plant and
Environmental
Engineer
Environmental
Engineer
Estimate Completion % : 50 % Date of Estimate: 22 Feb 2010 Comments/ Rational
for Estimates:
Time Frame: End 2010
Project Title: Reduce noise from top of boiler house though improvements to cooling plant
Related Objective & Target: Noise reduction
Rationale for undertaking this project: Response to neighbourhood complaint during 2009
Targets Programme Responsibility (Position/ Job Title)
Demonstrate measurable reduction in sound
pressure levels through modification to plant
items.
Modify potential source of noise contribution:
Noise monitoring at roof level on warehouse
to confirm sound pressure levels prior to
modifications.
Noise monitoring at roof level on warehouse
to confirm sound pressure levels after
modifications.
Improve ramp up of cooling towers using
VSD
Replace old tower fans with new ones
Raise parapet around cooling towers
Close openings around ladder and ducting
Improve general cladding to reduce break out
noise
Environmental Officer
Plant & Environmental Engineer
Estimate Completion % : 0 % Date of Estimate:
16 March 2010
Comments/ Rational for Estimates:
Time Frame: Completion by June 2011
ANNEX V
BUND INTEGRITY TEST REPORT
List of Bunds & Test Status
Name Purpose / Location Model Type Serial
No. Capacity
Litres Risk
Class. Tested Due for
test Scheduled
for Test Valid Cert.
BDB:01 ETO Corridor Decanting Area for 20 Litre Drums
2 DP - Chemstore
Steel 6050 280 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5929 180 1 03/06/2008 Jun-11 Jun-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 9320 180 1 03/06/2008 Jun-11 Jun-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5921 180 1 03/06/2008 Jun-11 Jun-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5926 180 1 03/06/2008 Jun-11 Jun-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5932 180 1 03/06/2008 Jun-11 Jun-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5928 180 1 03/06/2008 Jun-11 Jun-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5980 180 1 03/06/2008 Jun-11 Jun-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 9322 220 1 23/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 9323 220 1 23/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 7097 220 1 23/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5920 180 1 23/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 9324 180 1 23/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5927 180 1 23/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5931 180 1 31/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5924 180 1 31/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 9325 240 1 31/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 9321 240 1 31/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5933 180 1 31/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5923 180 1 31/07/2008 Jul-11 Jul-11 Yes
BDB:02 HFE Drum Bund HFE Drum storage at lines and staging area in warehouse
1 DV - Chemstore
Steel 5925 180 1 31/07/2008 Jul-11 Jul-11 Yes
BDB:04 Compressor House Diesel for Emergency Generator Compressor House
1 DP - Chemstore
Steel 5417 245 2 29/07/2008 Jul-11 Jul-11 Yes
BDB:05 Hazardous waste Stores
Smalls in Haz stores 2 DP - Chemstore
Steel 5418 2 Not required as it is within a bund n/a
BDB:06 Chiller Room (Above)
Environmental Chiller Cooling Towers and Chilled Water System Dosing Chemicals
2 DP Mod - Chemstore
Steel 5419 240 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:07 Chiller Room (Above)
Environmental Chiller Cooling Towers and Chilled Water System Dosing Chemicals.
2 DP Mod - Chemstore
Steel 5420 240 2 31/07/0/8 Jul-11 Jul-11 Yes
BDB:08 Boilerhouse (Rear) Moulding Chiller Cooling Towers and Chilled Water System Dosing Chemicals Plus Boiler system
2 DP Mod - Chemstore
Steel 5421 300 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:09 Boilerhouse (Rear) Moulding Chiller Cooling Towers and Chilled Water System Dosing Chemicals Plus Boiler system
2 DP Mod - Chemstore
Steel 5422 300 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:10 Compressor Cooling Towers
Compressor Cooling Towers Dosing Chemicals
2 DP Mod - Chemstore
Steel 5423 300 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:11 Compressor Cooling Towers
Compressor Cooling Towers Dosing Chemicals
2 DP Mod - Chemstore
Steel 5424 300 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:12 Ink Room - Outside Lube Mix PP 2000 - Chemstore
Poly 5425 220 2 03/03/2004 n/a n/a Obsolete
BDB:13 Ink Room - Outside Lube Mix PP 2000 - Chemstore
Poly 5426 220 2 03/03/2004 n/a n/a Obsolete
BDB:14 ETO Corridor Decanting Area for 20 Litre Drums (Overflow)
PP 2000 - Chemstore
Poly 5427 220 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:15 Steel stores Cutting Fluid 3 DP - Chemstore
Steel 5432 360 2 01/08/2008 Jul-11 Jul-11 Yes
BDB:16 Rear of factory by waste area
Vacuum Pump Oil DS4S - Empteezy
Steel 54713 420 2 05/08/2008 Aug-11 Aug-11 Yes
BDB:17 ETO Corridor Decanting Area for 20 Litre Drums
Custom Made - Empteezy
54878 490 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:18 ETO Corridor Decanting Area for 20 Litre Drums
Custom Made - Empteezy
54879 490 2 31/07/2008 Jul-11 Jul-11 Yes
BDB:19 Rear Of Factory - waste area - Currently being used in moulding for oil
For 2 IBC's used for bund testing water
PIBC2 - Empteezy (For 2 IBC's)
54880 1140 2 24/10/2005 n/a n/a Obsolete
BDB:20 16 pallet steel Bunds - Empty 200 Liter Drums
Waste Area at rear 64 DSD - 16 Pallet mobile Bund - Steel sump
6962 4800 2 07/02/2008 Feb-11 Feb-11 Yes
BDB:21 16 pallet plastic
Bunds - Empty 20 Liter Drums
Waste Area at rear 16 Pallet mobile Bund - Plastic sump
6961 4800 2 07/02/2008 Feb-11 Feb-11 Yes
BDB:22 Haz Chemical stores Back of car park Concrete 7099 400 2 07/02/2008 Feb-11 Feb-11 Yes
BDB:23 Chemical stores Bottom ETO Corridor Concrete 7098 3500 2 05/06/2008 Jun-11 Jul-11 Yes
BDB:24 Pumphouse 2 (Twin tanks)
Diesel tanks Concrete 7100 2200 2 Not required as it is a double line vessel n/a
BDB:25 Pumphouse 1 (Large Tank)
Diesel tanks Concrete 7101 950 2 Not required as it is a double line vessel n/a
BDB:26 Diesel Engine - Generator - Compressor House Aluminium 1001 1000 2 16/03/2006 Mar-09 Mar-09 Yes
BDB:27 Hydraulic Oil Tanks - rear of warehouse
Hydraulic Oil Tank - Virgin & Waste 2 Not required as it is a double line vessel n/a
BDB:28 16 pallet steel Bunds - Supplementary Factory Chemical Stores for 200 Liter Drums -
HFE and other production related chemicals - Rear Yard opposite Main Chemical store
64 DSD - 16 Pallet mobile Bund - Steel sump
7497 4800 3 Feb 2010 Feb 2013 Feb 2013 Yes
BDB:29 Flamvault - Outside Haz waste Stores
Lubricants Flamvault Steel 5429 294 04/06/2008 Jun-11 Jul-11 Yes
BDB:30 Flamvault - Rear Aisle by Trim Removal
Lubricants Flamvault Steel 5430 294 04/06/2008 Jun-11 Jul-11 Yes
BDB:31 Flamvault - ETO Corridor
Cleaning Solvents Flamvault Steel 7103 294 04/06/2008 Jun-11 Jul-11 Yes
BDB:32 Flamvault - Compressor House
Lubricants Flamvault Steel 1795 294 04/06/2008 Jun-11 Jul-11 Yes
BDB:33 Flamvault - Smalls in Chemical stores
Chemical stores Flamvault Steel 6960 Not required as it is within a bund n/a
BDB:34 Flame Vault for Epoxy
Warehouse racks by engineering stores
Flamvault Steel 6963 420 03/11/2005 Nov-08 Jul-08 Yes
BDB:35 Flamvault - Engineering stores
Flamvault for oils stored Flamvault Steel 7102 80 12/12/2005 Dec-08 Jul-08 Yes
BDB:36 Flamvault Out of service
Flamvault - Nissan Hut Area Flamvault Steel 5431 160 03/03/2004 n/a n/a Obsolete
BDB:37 HFE Effluent Outside Chemical Store Single IBC Plastic 10259 1130 26/02/2010 Feb 2013 Feb 2013 Yes