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



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.



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.



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



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.



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.



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.


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.


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.



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



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.



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



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



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



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



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



14 March 2010

COD


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


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



15 March 2010

Sulphates (as SO4)


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


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



16 March 2010

Fats, Oils & Grease


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)


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)



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



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



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



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)



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)



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)



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)



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)



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)



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)



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)



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)



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)



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)



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)



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)



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)



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



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.



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


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,


6 00:08:44 45 42 51 No No

Distant road traffic,


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))


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.



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.



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


Company

02/2000

20 01 35* Yes WEEE 3.221 R4 Irish Lamp Recycling

Company


Company

02/2000



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,


Veolia W0039-02

16 03 06 No Composite paper 161.07 D1 Ballymount Cross,


Veolia W0039-02

20 01 40 No Metal 20.30 R4 Ballymount Cross,


Veolia W0039-02



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



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.



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.



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



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



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.



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



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.



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.



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.


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


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.


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


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.


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.


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.




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



Estimate Completion % : 25 % Date of Estimate: 04 December 2009


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.


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


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.


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


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


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


1 DV - Chemstore

Steel 9320 180 1 03/06/2008 Jun-11 Jun-11 Yes


1 DV - Chemstore

Steel 5921 180 1 03/06/2008 Jun-11 Jun-11 Yes


1 DV - Chemstore

Steel 5926 180 1 03/06/2008 Jun-11 Jun-11 Yes


1 DV - Chemstore

Steel 5932 180 1 03/06/2008 Jun-11 Jun-11 Yes


1 DV - Chemstore

Steel 5928 180 1 03/06/2008 Jun-11 Jun-11 Yes


1 DV - Chemstore

Steel 5980 180 1 03/06/2008 Jun-11 Jun-11 Yes


1 DV - Chemstore

Steel 9322 220 1 23/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 9323 220 1 23/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 7097 220 1 23/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 5920 180 1 23/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 9324 180 1 23/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 5927 180 1 23/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 5931 180 1 31/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 5924 180 1 31/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 9325 240 1 31/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 9321 240 1 31/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 5933 180 1 31/07/2008 Jul-11 Jul-11 Yes


1 DV - Chemstore

Steel 5923 180 1 31/07/2008 Jul-11 Jul-11 Yes


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.


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


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


Steel 5422 300 2 31/07/2008 Jul-11 Jul-11 Yes

BDB:10 Compressor Cooling Towers

Compressor Cooling Towers Dosing Chemicals


Steel 5423 300 2 31/07/2008 Jul-11 Jul-11 Yes

BDB:11 Compressor Cooling Towers

Compressor Cooling Towers Dosing Chemicals


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


Custom Made - Empteezy

54878 490 2 31/07/2008 Jul-11 Jul-11 Yes


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


BDB:31 Flamvault - ETO Corridor

Cleaning Solvents Flamvault Steel 7103 294 04/06/2008 Jun-11 Jul-11 Yes

BDB:32 Flamvault - Compressor House


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

annual environmental report for becton dickinson insulin

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