Servier International B.V. Annual Environmental Report 2008 IPC LICENCE REGISTER NUMBER 128

Transcription

1 Servier International B.V. Annual Environmental Report 28 IPC LICENCE REGISTER NUMBER 128 May 29

2 May 29 Page 2 of 45

3 TABLE OF CONTENTS SECTION CONTENTS PAGE NO. 1. INTRODUCTION 4 2. SUMMARY INFORMATION Self-monitoring data Emissions to sewer Emissions to atmosphere Waste management Agency monitoring and enforcement Energy and water consumption Energy consumption Water consumption Environmental incidents and complaints Environmental incidents Environmental complaints IPC Licence non-compliances AER returns worksheet ENVIRONMENTAL MANAGEMENT Environmental Management Programme (EMP) Report Schedule of Environmental Objectives and Targets Pollution Emission Register, (PER) Groundwater monitoring Noise monitoring Bund integrity testing Surface water monitoring Emissions to sewer May 29 Page 3 of 45

4 SUMMARY INFORMATION 1. Introduction Servier International B.V., operating as Servier (Ireland) Industries Limited, Gorey Road, Arklow Co. Wicklow, was issued with an Integrated Pollution Control Licence (IPC) by the Environmental Protection Agency in accordance with the Environmental Protection Agency Act, 1992 on 21st November IPC Licence Register Number 128. The main activity of the Arklow site is the manufacture and packaging of solid oral dose pharmaceuticals. The Pharmaceutical Plant began manufacturing in A Chemical Synthesis Plant was built in 1991 and manufactured active ingredient until July 23. Over the past number of years a number of building extensions have been developed, extending packaging and warehouse facilities, while existing facilities have undergone renovations, most recently included a sizeable extension to the existing packaging and warehouse facility and a new formulation plant. Since ceasing production in the chemical synthesis plant in 23 and despite continued developments, Servier no longer falls within the scope of the IPPC licensing directive. Under the direction of the Agency, Servier are in the process of surrendering their IPC licence and have agreed new water discharge licences from Wicklow County Council. Documentation relating to the surrender has been submitted to the Agency and an Exit Audit was carried out by Inspector Michelle Purcell on 7/5/9. Since commencing manufacturing, Servier has maintained a very high level of environmental awareness and protection. This was recognised when in June 25 the company was awarded the international ISO 141 Environmental Management Systems Standard by the National Standards Authority of Ireland. Since this time the company have also achieved the OHSAS 181 Occupational Health and Safety Management System Standard. During 28 Servier became members of Repak. The company is a member of the Irish Responsible Care group and has contributed environmental performance data to national reports issued by Responsible Care and PharmaChem Ireland Group. Since IPC Licensing the Company has maintained an excellent environmental record. Over the past decade compliance with licence conditions has ranged from 95% to 1%. This Annual Environmental Report, (AER) is presented for the calendar year 28. May 28 Page 4 of 45

5 SUMMARY INFORMATION 2. Summary Information 2.1 Self monitoring data Emissions to sewer Table 1 Parameter Mass Emissions (kg) (26) Mass Emissions (kg) (27) Mass Emissions (kg) (28) Licensed Mass Emissions (kg) Volume (m 3 ) ph BOD COD Total solids Suspended solids Sulphates All data is based on annual values, including licence limits Emissions to atmosphere N/A May 28 Page 5 of 45

6 SUMMARY INFORMATION Waste management Figure 1 shows the increasing trend in paper and cardboard recycling. 14 Paper and cardboard recycling 12 1 Tonne Year Figure 2 shows the ultimate disposal type for waste generated in 28. 2% 47% 13% 2% Incinerated Landfilled Re-used Recycled March 28 Page 6 of 45

7 SUMMARY INFORMATION 2.2 Agency monitoring and enforcement During the reporting period of January to December 28 the Agency did not carry out any sampling. The agency conducted an Inspection in April 28 which focussed on the IPC Licence surrender process. In May 28 the company were successfully re-certified to the ISO 141 Environmental Management System Standard by the NSAI. May 29 Page 7 of 45

8 SUMMARY INFORMATION 2.3 Energy and Water Consumption Energy consumption Types of fuels used include light fuel oil, natural gas and electricity. The increase in energy consumption can be attributed to the sizeable building expansions opened in 28. Table Std boxes produced 63,541, 76,592,478 88,82, Heavy fuel oil Light fuel oil Natural gas Electricity Coal TOTAL, (Megawatts) Energy per box, (Megawatts) Water consumption The total water consumed during 28 from a municipal supply was 29,16 m³. Table Std boxes produced Water consumption, (m 3 ) Water per box (m3) Litres per box May 29 Page 8 of 45

9 SUMMARY INFORMATION 2.4 Environmental incidents and complaints Environmental incidents There were no environmental incidents during Environmental complaints There were no environmental complaints during Summary of IPC Licence non-compliances Date Non-compliance Cause Corrective action 24/6/8 Waste water volume discharged to sewer exceeded licence limit. 27/6/8 Waste water volume discharged to sewer exceeded licence limit. 22/8/8 Waste water volume discharged to sewer exceeded licence limit. 1/1/8 Waste water volume discharged to sewer exceeded licence limit. 7/11/8 Waste water volume discharged to sewer exceeded licence limit. 28/11/8 Waste water volume discharged to sewer exceeded licence limit. 23/12/8 Waste water volume discharged to sewer exceeded licence limit. High production demands High production demands High production demands High production demands High production demands High production demands High production demands N/A N/A N/A N/A N/A N/A N/A May 29 Page 9 of 45

10 SUMMARY INFORMATION 2.5 AER Returns Worksheet Table 4 May 29 Page 1 of 45

11 SUMMARY INFORMATION Table 4 (cont d) 4.3 RELEASES TO WASTEWATER OR SEWER PRTR# : P128 Facility Name : Servier International B.V. Filename : P128_28.xls Return Ye 29/5/29 16: SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year.... * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 238 Ammonia (as N) M PER Analytical method BOD M PER Analytical method COD M PER Spectrophotometer Nitrate (as N) M PER Analytical method Sulphate M PER Spectrophotometer Suspended Solids M PER Analytical method May 29 Page 11 of 45

12 SUMMARY INFORMATION Table 5 (cont d) 5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE PRTR# : P128 Facility Name : Servier International B.V. Filename : P128_28.xls Return Year : 28 29/5/29 16: Method Used Transfer Destination European Waste Code Hazardous Quantity T/Year Description of Waste Waste Treatment Operation M/C/E Method Used Location of Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Veolia Environmental Within the Country No Paper and cardboard R3 M Weighed Offsite in Ireland Services Ballymount, Dublin 24 Within the Country No Plastic R3 M Weighed Offsite in Ireland Veolia Environmental Services Ballymount, Dublin 24 Within the Country No Wood R3 M Weighed Offsite in Ireland Veolia Environmental Services Ballymount, Dublin 24 Within the Country No 81.3 Wooden pallets R3 M Weighed Offsite in Ireland Woodfab Industries Arklow, Co.Wicklow Within the Country No 3. Glass R3 M Weighed Offsite in Ireland Rehab Recylcing Clondalkin, Dublin 12 Within the Country No.55 Cooking oil R3 M Weighed Offsite in Ireland Veolia Environmental Services Ballymount, Dublin 24 Within the Country No 1.65 Electonic waste R4 M Weighed Offsite in Ireland Irish Lamp Recycling Kilkenny Road, Athy, Co. Kildare Within the Country Yes.114 Flourescent light tubes R4 M Weighed Offsite in Ireland Irish Lamp Recycling Kilkenny Road, Athy, Co. Kildare Kilkenny Road, Athy, Co. Kildare WCP/WW/51/5B Within the Country No.315 Printer cartridges R5 M Weighed Offsite in Ireland Jack and Jill Foundation Johnstown Manor, Johnstown, Naas, Co. Kildare Within the Country No.45 Un-cooked food R3 M Weighed Onsite in Ireland Servier (Ireland) Industries Gorey Road, Arklow, Co. Kildare Within the Country No Metal waste R3 M Weighed Offsite in Ireland Veolia Environmental Services Ballymount, Dublin 24 Within the Country No Canteen wastes D1 M Weighed Offsite in Ireland Veolia Environmental Services Ballymount, Dublin 24 Within the Country No General waste, garbing, packaging, etc. D1 M Weighed Offsite in Ireland Veolia Environmental Services Ballymount, Dublin 24 To Other Countries Yes Mixed pharmaceutical waste, (eg tablets, filters, contminated garbing, etc.) D1 M Weighed Abroad Ekokem Oy Ab PO Box 181 Fin 1111, Riihhimaki, Finland PO Box 181 Fin 1111, Riihhimaki, Finland PO Box 181 Fin 1111, PO Box 181 Fin 1111, To Other Countries Yes Labotatory waste solvents D1 M Weighed Abroad Ekokem Oy Ab Riihhimaki, Finland Riihhimaki, Finland YSO/119/27 YSO/119/27 May 29 Page 12 of 45

13 ENVIRONMENTAL MANAGEMENT 3. Environmental Management 3.1 Environmental Management Programme, (EMP) Report Licence Objectives Licensee Targets and Reports Department Responsible 1 Process modifications resulting in improved yields, elimination or reduction of wastes or the use of alternative less hazardous materials. 2 Improved process control (equipment and management) to reduce waste. 3 Improvements in equipment cleaning procedures resulting in reduced materials usage or alternative materials usage. 4 Maintenance and calibration of control and monitoring equipment. 5 Improvements in treatment/abatement systems to reduce emissions. It is planned to install a process waste water drain in the raw materials warehouse. This allows for waste water from cleaning to be directed to waste water treatment system for neutralisation prior to discharge. [Currently this water is collected and transported to a process waste water drain] Time Scale Engineering 28 Report: A process waste water drain has been installed in the raw material warehouse for disposal of water from cleaning the sampling booth. There were no objectives and targets for 28. There were no objectives and targets for 28. The company plans to improve its existing groundwater protection measures by installing a fifth monitoring well. It is planned to locate this well on the southern section of the site to provide baseline data for future expansion. Once installed, this well will be incorporated into the bi-annual monitoring programme. EHS 28 Report: This target has not been implemented, but has been given a revised target date of Sept 29. In conjunction with planned production increases and the construction of a second production plant the company will investigate means of further improving our waste water balancing and discharge system. A new system will give constant quality water to the proposed new municipal waste water treatment plant. EHS and Engineering 28 Report: A new waste water treatment system has been installed at out new UPA 2 production facility. This system uses best available technology for controlling, monitoring and sampling of waste water. May 29 Page 13 of 45

14 ENVIRONMENTAL MANAGEMENT Licence Objectives Licensee Targets and Reports Department Responsible 6 The use of alternative treatment/abatement systems 7 Recovery, reuse, recycling of waste material both on-site and off-site. There were no objectives and targets for 28. During 28 the company will become members of REPAK. Through Repak membership the company will help fund recycling initiatives throughout the country. Logistics and EHS Time Scale 28 Report: In December 28 Servier became members of Repak, (membership number 5454). 8 Reduction in fugitive emissions There were no objectives and targets for Prevention of incidents with the potential for environmental consequences and the preparation and implementation of contingency plans in the event of an incident. There were no objectives and targets for Savings in energy and material usage. It is planned to investigate the possibility of using groundwater well number 1 as a supplementary water source. The well offers a safe yield of 17 m 3 per day. A Engineering feasibility study into using this natural and Dalkia water source will be conducted. If 28 successful this could reduce water requirements from Arklow s municipal supply by 4%. Report: This target remains on-going. See Section 3.2 for more information. 3.2 Schedule of Environmental Objectives and Targets, (29 to 213). Not applicable due to licence surrender Summary of Objectives and Targets, (29 to 213). Not applicable due to licence surrender. 3.3 Pollution Emission Register, (PER). There is no Pollution Emission Register required for 28. May 29 Page 14 of 45

15 4. Licence Specific Reports 4.1 Groundwater Monitoring MONITORING WELL 1 MONITORING WELL 2 Date sampled: 14/1/8 Date sampled: 14/1/8 Date of analysis: RESULTS 15/1/8, 16/1/8 and 18/1/8 Date of analysis: 16/1/8 RESULTS COD 27 mg/l COD mg/l ph 7.21 ph Other Other Oils fats greases < 1 mg/l Oils fats greases < 1 mg/l Toluene <.5 mg/l Isopropyl alcohol < 2 mg/l Ethyl acetate < 2 mg/l MONITORING WELL 3 MONITORING WELL 4 Date sampled: 14/1/8 Date sampled: 14/1/8 Date of analysis: RESULTS 15/1/8, 16/1/8 and 18/1/8 Date of analysis: 16/1/8 RESULTS COD 27 mg/l COD mg/l ph 727 ph Other Other Oils fats greases < 1 mg/l Oils fats greases < 1 mg/l Toluene <.5 mg/l Isopropyl alcohol < 2 mg/l Ethyl acetate < 2 mg/l May 29 Page 15 of 45

16 MONITORING WELL 1 MONITORING WELL 2 Date sampled: 27/3/8 Date sampled: 27/3/8 Date of analysis: 27/3/8 Date of analysis: 27/3/8 RESULTS RESULTS COD 5 mg/l COD 91 mg/l ph 7.64 ph 7.35 Other n/a Other MONITORING WELL 3 MONITORING WELL 4 Date sampled: 27/3/8 Date sampled: 27/3/8 Date of analysis: 27/3/8 Date of analysis: 27/3/8 RESULTS n/a RESULTS COD 216 mg/l COD 66 mg/l ph 7.63 ph 8.5 Other n/a Other n/a MONITORING WELL 1 MONITORING WELL 2 Date sampled: 25/9/8 Date sampled: 25/9/8 Date of analysis: 25/9/8 Date of analysis: 25/9/8 RESULTS RESULTS COD 6 mg/l COD 118 mg/l ph 7.8 ph 7.71 Other Other n/a n/a MONITORING WELL 3 MONITORING WELL 4 Date sampled: 26/9/8 Date sampled: 25/9/8 Date of analysis: 26/9/8 Date of analysis: 25/9/8 RESULTS RESULTS COD 249 mg/l COD 118 mg/l ph 7.51 ph 7.73 Other Other n/a n/a May 29 Page 16 of 45

17 MONITORING WELL 4 Date sampled: 31/1/8 Date of analysis: 31/1/8 and 3/11/8 RESULTS COD 42 mg/l ph 7.3 Other DRC < 2.5 µg/l Mineral oil < 2.5 µg/l TPH < 2.5 µg/l MONITORING WELL 3 MONITORING WELL 4 Date sampled: 2/11/8 Date sampled: 2/11/8 Date of analysis: 2/11/8 Date of analysis: 2/11/8 RESULTS RESULTS COD 23 mg/l COD 14 mg/l ph 7.11 ph 7.11 Other Other n/a n/a May 29 Page 17 of 45

18 4.2 Noise Monitoring Noise monitoring on-site Table 5 Noise emission ref. number Noise source description Measurement refernce distance (m) Actual Result; db(a) L eq (3 mins) Sound Presure Limit; db(a) L eq (3 mins) N1 Dust collector (N11) N6 Stand-by generator Noise monitoring off-site Table 6 Location Location description Actual Result; db(a) Leq (15 mins) Sound Presure Limit; db(a) L eq (15 mins) Gorey Road, close to "Knockmore" housing estate. Minor road leading to "Moneylands Farm", close to "Avalon" housing estate Site boundary to the side of the restaurant building 7.1 * * * Note: * During monitoring traffic on the road was as follows; No. of cars: 127 No. of vans: 9 No. of HGV: 6 * * During monitoring traffic on the road was as follows; No. of cars: 1 No. of vans: No. of HGV: May 29 Page 18 of 45

19 4.3 Bund integrity testing During 28 bund integrity testing was conducted by Cedar Building Company Limited. Two bunds were assed over a period of 3 days. All bunded areas passed the integrity test, (test reports attached). Report 1: UPA 1 Diesel tank bund May 29 Page 19 of 45

20 Report 2: Chemical waste store bund May 29 Page 2 of 45

21 4.4 Surface Water Monitoring SURFACE WATER SURFACE WATER Date sampled: 25/3/8 Date sampled: 28/7/8 Date of analysis: 25/3/8 Date of analysis: 5/8/8 RESULTS RESULTS COD 23 mg/l COD mg/l ph 7.74 ph Other Other n/a V.O.C. s < 1 µg/l SURFACE WATER Date sampled: 25/9/8 Date sampled: 3/1/8 Date of analysis: RESULTS 25/9/8 Date of analysis: 4/1/8, 15/1/8, 3/1/8 RESULTS COD 25 mg/l COD 17 mg/l ph 6.58 ph 7.6 Other Other n/a DRC 8.81 µg/l Mineral oil < 2.5 µg/l TPH < 2.5 µg/l May 29 Page 21 of 45

22 4.5 Emission to Sewer TEST January 28 EMISSIONS TO SEWER Monthly Sample Analysis MONITORING FREQUENCY LIMITS Temperature 25 ºC 18 ºC ph RESULTS Biochemical oxygen demand Monthly 1,428 mg/l 4 mg/l Chemical oxygen demand Daily 2,285 mg/l 111 mg/l Suspended solids Monthly 6 mg/l 19 mg/l Sulphates as SO4 Quarterly 1,2 mg/l n/a mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 15/1/28 Sample discharged on: 14/1/28 May 29 Page 22 of 45

23 Volume, (litres) Daily Discharge Volume Chart Daily volume licence limit Month average volume Calender days 3 25 Daily C.O.D. Chart C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 23 of 45

24 February 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 14.8 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 2 mg/l Chemical oxygen demand Daily 2,285 mg/l 95 mg/l Suspended solids Monthly 6 mg/l 7 mg/l Sulphates as SO4 Quarterly 1,2 mg/l n/a mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 12/2/28 Sample discharged on: 11/2/28 May 29 Page 24 of 45

25 Volume, (litres) Daily Discharge Volume Chart Daily volume licence limit Month average volume Calender days 3 Daily C.O.D. Chart C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 25 of 45

26 March 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 14.9 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 31 mg/l Chemical oxygen demand Daily 2,285 mg/l 16 mg/l Suspended solids Monthly 6 mg/l 14 mg/l Sulphates as SO4 Quarterly 1,2 mg/l 22 mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 12/3/28 Sample discharged on: 11/3/28 May 29 Page 26 of 45

27 Daily Discharge Volume Chart 8 7 Daily volume licence limit Volume, (litres) Month average volume Calender days 3 25 Daily C.O.D. Chart C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 27 of 45

28 April 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 8.5 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l <2 mg/l Chemical oxygen demand Daily 2,285 mg/l 113 mg/l Suspended solids Monthly 6 mg/l 11 mg/l Sulphates as SO4 Quarterly 1,2 mg/l n/a mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 22/4/28 Sample discharged on: 21/4/28 May 29 Page 28 of 45

29 . Daily Discharge Volume Chart 8 Daily volume licence limit 7 Volume, (litres) Month average volume Calender days 3 25 Daily C.O.D. Chart C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 29 of 45

30 May 29 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 18.7 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 6 mg/l Chemical oxygen demand Daily 2,285 mg/l 19 mg/l Suspended solids Monthly 6 mg/l 13 mg/l Sulphates as SO4 Quarterly 1,2 mg/l n/a mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 14/5/28 Sample discharged on: 13/5/29 May 29 Page 3 of 45

31 Daily Discharge Volume Chart 8 7 Daily volume licence limit Volume, (litres) Month average volume Calender days 3 Daily C.O.D. Chart 25 C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 31 of 45

32 June 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 23.1 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 3 mg/l Chemical oxygen demand Daily 2,285 mg/l 645 mg/l Suspended solids Monthly 6 mg/l 31 mg/l Sulphates as SO4 Quarterly 1,2 mg/l 15 mg/l Chlorides Bi-annually Measure 128 mg/l Nitrate, (as N) Bi-annually Measure <.9 ppm Ammonia Bi-annually Measure <.9 ppm Date of sampling: 18/6/28 Sample discharged on: 17/6/28 May 29 Page 32 of 45

33 Daily Discharge Volume Chart 8 7 Daily volume licence limit Volume, (litres) Month average volume Calender days. 3 Daily C.O.D. Chart 25 C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 33 of 45

34 July 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 2.7 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l <2 mg/l Chemical oxygen demand Daily 2,285 mg/l 54 mg/l Suspended solids Monthly 6 mg/l 5 mg/l Sulphates as SO4 Quarterly 1,2 mg/l n/a mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 16/7/28 Sample discharged on: 15/7/28 May 29 Page 34 of 45

35 Daily Discharge Volume Chart Volume, (litres) Daily volume licence limit Month average volume Calender days 3 25 Daily C.O.D. Chart C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 35 of 45

36 August 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 2.8 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 5 mg/l Chemical oxygen demand Daily 2,285 mg/l 52 mg/l Suspended solids Monthly 6 mg/l 6 mg/l Sulphates as SO4 Quarterly 1,2 mg/l 35.6 mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 19/8/28 Sample discharged on: 18/8/28 May 29 Page 36 of 45

37 Volume, (litres) Daily Discharge Volume Chart Daily volume licence limit Month average volume Calender days 3 25 Daily C.O.D. Chart C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 37 of 45

38 September 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 18.7 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 37 mg/l Chemical oxygen demand Daily 2,285 mg/l 533 mg/l Suspended solids Monthly 6 mg/l 58 mg/l Sulphates as SO4 Quarterly 1,2 mg/l n/a * mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 16/9/28 Sample discharged on: 15/9/28 Note * Sulphates were not measured. Test was conpleted in October. May 29 Page 38 of 45

39 Daily Discharge Volume Chart Volume, (litres) Daily volume licence limit Month average volume Calender days 3 Daily C.O.D. Chart 25 C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 39 of 45

40 October 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 15.9 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 2 mg/l Chemical oxygen demand Daily 2,285 mg/l 6 mg/l Suspended solids Monthly 6 mg/l 6 mg/l Sulphates as SO4 Quarterly 1,2 mg/l mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 22/1/28 Sample discharged on: 21/1/28 May 29 Page 4 of 45

41 Volume, (litres) Daily Discharge Volume Chart Daily volume licence limit Month average volume Calender days 3 25 Daily C.O.D. Chart C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 41 of 45

42 November 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 15.9 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 2 mg/l Chemical oxygen demand Daily 2,285 mg/l 6 mg/l Suspended solids Monthly 6 mg/l 6 mg/l Sulphates as SO4 Quarterly 1,2 mg/l mg/l Chlorides Bi-annually Measure n/a mg/l Nitrate, (as N) Bi-annually Measure n/a ppm Ammonia Bi-annually Measure n/a ppm Date of sampling: 22/1/28 Sample discharged on: 21/1/28 May 29 Page 42 of 45

43 Volume, (litres) Daily Discharge Volume Chart Daily volume licence limit Month average volume Calender days 3 Daily C.O.D. Chart 25 C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Calendar days May 29 Page 43 of 45

44 December 28 EMISSIONS TO SEWER Monthly Sample Analysis TEST MONITORING FREQUENCY LIMITS RESULTS Temperature 25 ºC 2.9 ºC ph Biochemical oxygen demand Monthly 1,428 mg/l 43 mg/l Chemical oxygen demand Daily 2,285 mg/l 195 mg/l Suspended solids Monthly 6 mg/l 39 mg/l Sulphates as SO4 Quarterly 1,2 mg/l mg/l Chlorides Bi-annually Measure mg/l Nitrate, (as N) Bi-annually Measure.9 ppm Ammonia Bi-annually Measure 36 ppm Date of sampling: 17/12/28 Sample discharged on: 26/12/28 May 29 Page 44 of 45

45 Daily Discharge Volume Chart Volume, (litres) Daily volume licence limit Month average volume Daily volume licence limit Calender days 3 Daily C.O.D. Chart 25 Daily C.O.D. Month licence average limit volume C.O.D. (mg/l) Calendar Days C.O.D. (kg) Daily C.O.D. (kg) Daily C.O.D licence 16 17limit Calendar days May 29 Page 45 of 45