AER 2009 - EPA
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 1 of Date: April 2010
Annual Environmental Report Licence Number: P0297-02 Braun Oral-B Ireland Ltd. Green Road, Newbridge, County Kildare.
AER 2009
Olivia Hopkins April 2010
35
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 2 of Date: April 2010
Table of Contents Section 1 Introduction 1.1 1.2
Section 2 2.1
Introduction Environmental Policy
Page Number 5 6
Background & Current Status General description of company activities 7
Section 3 3.1
Data Emissions to atmosphere summary
9
3.1.1 Super floss emission to air (A2-2)
9
3.1.2 Ultra floss emissions to air (A2-3)
10
3.2.1
Emissions to Sewer (SE6)
11
3.2.2
Emissions to surface water (SW1)
12
3.3
Waste Management
13
3.4
Noise Summary
15
3.5
Resource Consumption Summary
17
3.5.1 Energy
17
3.5.2 Water
18
3.6
Environmental Incidents & Complaints
18
3.7
Environmental Expenditure
18
35
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report Section 4
Page 3 of Date: April 2010
Pollution Emission Register
4.1
Ultra floss Process
19
4.2
Method of measurement
19
4.2.1 How mass balance for each material was calculated
19
4.2.2 Methods of measurement for mass balance
19
4.2.3 Accuracy of analysis
20
4.3
PER proposal 2009
20
4.4
Summary of PER tables
21
Environmental Management Programme Objectives & Targets, the Braun Oral-B approach
22
Section 5 5.1
Section 6 1
5.1.1 Review of EMP 2009
23
5.1.2 EMP Objectives 2010
24
Appendices
25
Process water estimation
25
Waste graphs for 2009
26
3 4 5 6 7 8 9 10
28 29 30 31 32 33 34 35
Annual Noise Survey Report (BNM report no ECS3357-Noise-June 09) Report surface water/effluent QTR1 2009 (BNM report no.:21875 ) Report surface water/effluent QTR2 2009 (BNM report no.: 23242) Report surface water/effluent QTR3 2009 (BNM report no.: 24452) Report surface water/effluent QTR4 2009 (BNM report no.: 25258) Report on air emissions 1st biannual 09 (BNM report no.:ECS3275) Report on air emissions 2nd biannual 09 (BNM report no.:ECS3421) AER / PRTR Returns Worksheet 2009
35
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 4 of
35
Date: April 2010
List of tables & figures Table 1.
Synopsis of Superfloss A2-2 TOC Emissions to Atmosphere Jan - Dec 2009
9
Figure 1.
TOC emissions from Superfloss A2-2 Process vs. IPPC limit Jan - Dec 2009
9
Table 2.
Synopsis of Superfloss A2-2 TDI Emissions to Atmosphere Jan – 2009
10
Table 3.
Synopsis of airflow rate Superfloss A2-2 Jan - Dec 2009
10
Table 4.
Synopsis of TA Luft Class 1 Testing Superfloss A2-2
10
Table 5.
Synopsis of Ultrafloss A2-3 TOC Emissions to Atmosphere Jan - Dec 2009
10
Figure 2.
TOC emissions from Ultrafloss A2-3Process vs. IPPC limit Jan - Dec 2009
11
Table 6.
Synopsis of airflow rate Ultrafloss A2-3 Jan - Dec 2009
11
Table 7.
Synopsis of TA Luft Class 1 emissions Ultrafloss
11
Table 8.
Emission to sewer (SE6) Summary Jan - Dec 09
11
Table 9.
Emission to sewer summary SE6
12
Figure 4.
Emission to sewer. SE6. Concentrations Vs IPPC licence limit
12
Table 10
Summary of surface water discharge monitoring results for SW1
12
Table 11
Annual Waste Arising- Hazardous Waste - January to December 2009
13
Table 12.
Annual Waste Arising- Non-Hazardous Waste- January to December 2009
14
Table 13.
National Waste Database Report Sheet
14
Table 14.
Site Boundary Noise Levels
15
Table 15.
Electricity usage 2002 to 2009
17
Table 16.
Gas Usage 2002 to 2009
17
Table 17.
Water Consumption 2001 to 2009
18
Table 18.
Expenditure on Environmental Protection January-December 2009
18
Table 19.
Pollution Emissions Register Form: Ultrafloss
21
Figure 5.
Waste generated versus units shipped 1999 to 2009
26
Figure 6.
Total solid waste in tonnes 2000 to 2009
26
Figure 7.
Tonnes of cardboard recycled 2009
27
Figure 8.
Tonnes of plastic recycled 2009
27
A2-3 Jan - Dec 2009
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report 1.0
Page 5 of
35
Date: April 2010
Introduction This Annual Environmental Report (AER) has been drafted in accordance with the EPA Guidance Note for AER’s and is submitted in order to comply with the requirements of Schedule 5(i), “Recording and Reporting to the Agency”, of the Braun Oral-B IPC Licence, Reg. No. P0297-02. This AER covers the period January to December 2009.
The following items are included in this report: •
Summary of emissions to atmosphere
•
Summary of emissions to sewer
•
Waste management report
•
Noise summary
•
Resource consumption summary
•
Energy usage
•
Water usage
•
Environmental incidents and complaints summary
•
Pollution Emission Register (PER)
•
Environmental management programme report for 2009
•
Schedule of objectives and targets for 2009
Braun Oral-B has developed its environmental policy as part of its environmental management system. Braun Oral-B has been registered to the ISO 14001 Environmental Management Systems standard since 1996. Braun Oral-B’s environmental policy is outlined in the next section.
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 6 of
35
Date: April 2010
P & G Braun Oral-B Environmental Policy Revision: 9
Revision Date: 01/09/09
The core business of P & G Braun Oral B Ireland is the manufacture and distribution of Toothbrushes and Dental Floss. These products are distributed globally. Among the stated values of P & G Braun Oral-B Ireland are the following: • • • •
That our products will be safe to make, use and ensure that all our products, packaging and operation are safe for our employees, consumers and the environment. We will conserve natural resources and we will continue to invest in a better environment. It is our belief that what is good for the environment, is good for P & G Braun Oral-B, our customers, our employees and the communities we serve. The challenge is to achieve a high quality environment without deterring economic purpose. To this end, the company is committed to continuous improvement - “prevent, reduce, and recycle” - at all levels throughout the organisation.
To sustain continuous improvement and meet its obligation to the environment, P & G Braun Oral-B will: ♦
Measure, reduce and prevent the environmental impact, of our products and packaging in their design, manufacture, distribution, use and disposal where possible.
♦
Meet or exceed all the relevant laws, Regulations and Directives, at Local, National and International levels, meet the requirements of IPPC License No. P0297-02 issued by the Environmental Protection Agency and to comply with P & G’s Braun Oral B Environmental Policy.
♦
Develop and follow an Environmental Management System in accordance with ISO14001 and Internal P & G requirements.
♦
Determine and prioritise the significant effects of the operation. Currently, the most significant environmental aspect is energy usage.
♦
Establish objectives, with defined plans and targets for achievement, to reduce P & G Braun Oral-B’s impact on the environment and monitor progress towards environmental goals.
♦
Continually assess and improve the effectiveness and performance of the Environmental Management System, by way of Internal Audit and Management Review.
♦
Communicate this policy to all working for or on behalf of the company, and participate in educating and motivating our business associates towards a more environmentally interactive industrial sector.
♦
Strive to meet Procter & Gamble corporate sustainability targets
♦
This policy will be subjected to annual review per QSI document control system
Signed:____________________________ Mark Masterson Managing Director, P & G Braun Oral-B Ireland
Date:______________
QS1 Document N3088/environmental policy
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 7 of
35
Date: April 2010
2.0
Background & Current Status
2.1
General Description of Company Activities at Braun Oral-B The manufacturing facility located at the IDA Business Park, Newbridge was established in 1984. Braun Oral-B now employs approximately 320 people. Braun Oral-B is involved in the oral dental care industry. The main activities on-site are the manufacture of toothbrushes and dental floss. Toothbrush Manufacture: Newbridge produces all the Oral-B premium manual toothbrush products including Vitalizer, Pulsar and Cross Action. Products are produced by utilizing breakthrough technology including Multi Colour Injection Moulding and Automated Cellular Manufacturing. Braun Oral-B manufactures around 145 million toothbrushes every year. Dental Floss: Braun Oral-B also manufactures Dental Floss. This involves the extrusion of polymers into yarn, spinning of this yarn, application of molten wax and flavourings. Following the coating process the yarn is wound into creels and sent to our sister company in Mexico for final packaging. Braun Oral-B also produces specialist floss products called Superfloss & Ultrafloss. Superfloss Manufacture: Superfloss is a specialist floss product designed to aid dentists in the cleaning of orthodontic appliances. The Superfloss manufacturing process is a solvent free process. Ultrafloss Manufacture: Ultrafloss is a specialist product with an expanded brush-section. The characteristics of the yarn are achieved through the use of resins, which are suspended in organic solvents.
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 8 of
35
Date: April 2010
General overview of changes, January to December 2009 •
The plant is now part of the Procter and Gamble group of companies.
•
Vitalizer Project 2 has been commissioned and is now in full production. (Vitalizer is a top end manual toothbrush)
•
Plant divided into two separate Value Streams. Value Stream is a self contained manufacturing centre.
•
Integrating processes from Braun Carlow, which is closing down in 2010 to new building in IDA Business Park adjacent to Newbridge site.
•
Value Stream 2
•
Procter & Gamble has set 5 year corporate Sustainability targets.
•
Successful ISO 14001:2004 recertification audit
•
Introduced a water based dental floss coating process called Neptune. Line will be commissioned in
Declan McDermot appointed VS2 Manager
2010 •
Technical Amendment granted to IPPC Licence P0297-02 regarding relocation of Air Emission point A2-1 .
•
Emission Point A2-1 renamed A2-3 following Technical Amendment
•
Evaluation of IPPC Licence requirement underway in conjunction with EPA
Overview on Agency Protocol for the Bypass of Air Emmission Abatement Equipment In September 2008 the EPA provided a protocol for the bypass of Air Emission Abatement Equipment . This protocol outlined actions required by licensees to ensure that procedures are in place to include criteria for assessment of both the potential bypass emission points and the likely impact on the ambient atmosphere.
Air Emission Abatement Equipment is not part of Braun Oral-B Ireland Ltd operations, therefore bypass events can not occur on site.
Page 9 of
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
35
Date: April 2010
3.0 Data 3.1 Emissions to Atmosphere Summary All sampling and analysis is conducted in accordance with NIOSH standard air monitoring methods. Bord na Mona, conducted all air sampling. The method of collection for the Volatile Organic Emissions testing was adsorbent trapping with subsequent thermal desorption analysis via GC-FID. TDI is trapped onto a pre-treated filter and analyzed via HPLC. Sampling is conducted using calibrated pumps traceable to a commercial standard calibration cell. The chromatographic systems were calibrated by generating calibration curves for the target analytes while running blank samples and controls. Braun Oral-B is required to test two air emission points: Superfloss (A2-2), Ultrafloss (A2-3) However Superfloss (A2-2) emission point has virtually no emissions due to the installation of the solvent free process in late 2003..
3.1.1 Superfloss Emissions to Air (A2-2) Table 1. Synopsis of Atmospheric Emissions for the Superfloss Process Jan – Dec 09 Concentration Estimated max. IPPC Limit Emission Point TOC (mg/m3) (mg/Nm3) mass TOC flow Stack A2-2 (kg/hr) Test dates 75 0.9 4.0 x 10-3 March 2009 75 < 2.47 < 0.05 November 2009 75 1.685 0.027 Average Emission point A2-2
Calculation
Estimated TOC for 2009
220hrs2 x 0.027
TOC Mass Emissions* (kg) 5.94 kg
% compliance 100 100
Max IPPC TOC Limit (kg)
% compliance
9526
100
1
Values preceded with a less than sign “
Page 1 of Date: April 2010
Annual Environmental Report Licence Number: P0297-02 Braun Oral-B Ireland Ltd. Green Road, Newbridge, County Kildare.
AER 2009
Olivia Hopkins April 2010
35
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 2 of Date: April 2010
Table of Contents Section 1 Introduction 1.1 1.2
Section 2 2.1
Introduction Environmental Policy
Page Number 5 6
Background & Current Status General description of company activities 7
Section 3 3.1
Data Emissions to atmosphere summary
9
3.1.1 Super floss emission to air (A2-2)
9
3.1.2 Ultra floss emissions to air (A2-3)
10
3.2.1
Emissions to Sewer (SE6)
11
3.2.2
Emissions to surface water (SW1)
12
3.3
Waste Management
13
3.4
Noise Summary
15
3.5
Resource Consumption Summary
17
3.5.1 Energy
17
3.5.2 Water
18
3.6
Environmental Incidents & Complaints
18
3.7
Environmental Expenditure
18
35
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report Section 4
Page 3 of Date: April 2010
Pollution Emission Register
4.1
Ultra floss Process
19
4.2
Method of measurement
19
4.2.1 How mass balance for each material was calculated
19
4.2.2 Methods of measurement for mass balance
19
4.2.3 Accuracy of analysis
20
4.3
PER proposal 2009
20
4.4
Summary of PER tables
21
Environmental Management Programme Objectives & Targets, the Braun Oral-B approach
22
Section 5 5.1
Section 6 1
5.1.1 Review of EMP 2009
23
5.1.2 EMP Objectives 2010
24
Appendices
25
Process water estimation
25
Waste graphs for 2009
26
3 4 5 6 7 8 9 10
28 29 30 31 32 33 34 35
Annual Noise Survey Report (BNM report no ECS3357-Noise-June 09) Report surface water/effluent QTR1 2009 (BNM report no.:21875 ) Report surface water/effluent QTR2 2009 (BNM report no.: 23242) Report surface water/effluent QTR3 2009 (BNM report no.: 24452) Report surface water/effluent QTR4 2009 (BNM report no.: 25258) Report on air emissions 1st biannual 09 (BNM report no.:ECS3275) Report on air emissions 2nd biannual 09 (BNM report no.:ECS3421) AER / PRTR Returns Worksheet 2009
35
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 4 of
35
Date: April 2010
List of tables & figures Table 1.
Synopsis of Superfloss A2-2 TOC Emissions to Atmosphere Jan - Dec 2009
9
Figure 1.
TOC emissions from Superfloss A2-2 Process vs. IPPC limit Jan - Dec 2009
9
Table 2.
Synopsis of Superfloss A2-2 TDI Emissions to Atmosphere Jan – 2009
10
Table 3.
Synopsis of airflow rate Superfloss A2-2 Jan - Dec 2009
10
Table 4.
Synopsis of TA Luft Class 1 Testing Superfloss A2-2
10
Table 5.
Synopsis of Ultrafloss A2-3 TOC Emissions to Atmosphere Jan - Dec 2009
10
Figure 2.
TOC emissions from Ultrafloss A2-3Process vs. IPPC limit Jan - Dec 2009
11
Table 6.
Synopsis of airflow rate Ultrafloss A2-3 Jan - Dec 2009
11
Table 7.
Synopsis of TA Luft Class 1 emissions Ultrafloss
11
Table 8.
Emission to sewer (SE6) Summary Jan - Dec 09
11
Table 9.
Emission to sewer summary SE6
12
Figure 4.
Emission to sewer. SE6. Concentrations Vs IPPC licence limit
12
Table 10
Summary of surface water discharge monitoring results for SW1
12
Table 11
Annual Waste Arising- Hazardous Waste - January to December 2009
13
Table 12.
Annual Waste Arising- Non-Hazardous Waste- January to December 2009
14
Table 13.
National Waste Database Report Sheet
14
Table 14.
Site Boundary Noise Levels
15
Table 15.
Electricity usage 2002 to 2009
17
Table 16.
Gas Usage 2002 to 2009
17
Table 17.
Water Consumption 2001 to 2009
18
Table 18.
Expenditure on Environmental Protection January-December 2009
18
Table 19.
Pollution Emissions Register Form: Ultrafloss
21
Figure 5.
Waste generated versus units shipped 1999 to 2009
26
Figure 6.
Total solid waste in tonnes 2000 to 2009
26
Figure 7.
Tonnes of cardboard recycled 2009
27
Figure 8.
Tonnes of plastic recycled 2009
27
A2-3 Jan - Dec 2009
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report 1.0
Page 5 of
35
Date: April 2010
Introduction This Annual Environmental Report (AER) has been drafted in accordance with the EPA Guidance Note for AER’s and is submitted in order to comply with the requirements of Schedule 5(i), “Recording and Reporting to the Agency”, of the Braun Oral-B IPC Licence, Reg. No. P0297-02. This AER covers the period January to December 2009.
The following items are included in this report: •
Summary of emissions to atmosphere
•
Summary of emissions to sewer
•
Waste management report
•
Noise summary
•
Resource consumption summary
•
Energy usage
•
Water usage
•
Environmental incidents and complaints summary
•
Pollution Emission Register (PER)
•
Environmental management programme report for 2009
•
Schedule of objectives and targets for 2009
Braun Oral-B has developed its environmental policy as part of its environmental management system. Braun Oral-B has been registered to the ISO 14001 Environmental Management Systems standard since 1996. Braun Oral-B’s environmental policy is outlined in the next section.
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 6 of
35
Date: April 2010
P & G Braun Oral-B Environmental Policy Revision: 9
Revision Date: 01/09/09
The core business of P & G Braun Oral B Ireland is the manufacture and distribution of Toothbrushes and Dental Floss. These products are distributed globally. Among the stated values of P & G Braun Oral-B Ireland are the following: • • • •
That our products will be safe to make, use and ensure that all our products, packaging and operation are safe for our employees, consumers and the environment. We will conserve natural resources and we will continue to invest in a better environment. It is our belief that what is good for the environment, is good for P & G Braun Oral-B, our customers, our employees and the communities we serve. The challenge is to achieve a high quality environment without deterring economic purpose. To this end, the company is committed to continuous improvement - “prevent, reduce, and recycle” - at all levels throughout the organisation.
To sustain continuous improvement and meet its obligation to the environment, P & G Braun Oral-B will: ♦
Measure, reduce and prevent the environmental impact, of our products and packaging in their design, manufacture, distribution, use and disposal where possible.
♦
Meet or exceed all the relevant laws, Regulations and Directives, at Local, National and International levels, meet the requirements of IPPC License No. P0297-02 issued by the Environmental Protection Agency and to comply with P & G’s Braun Oral B Environmental Policy.
♦
Develop and follow an Environmental Management System in accordance with ISO14001 and Internal P & G requirements.
♦
Determine and prioritise the significant effects of the operation. Currently, the most significant environmental aspect is energy usage.
♦
Establish objectives, with defined plans and targets for achievement, to reduce P & G Braun Oral-B’s impact on the environment and monitor progress towards environmental goals.
♦
Continually assess and improve the effectiveness and performance of the Environmental Management System, by way of Internal Audit and Management Review.
♦
Communicate this policy to all working for or on behalf of the company, and participate in educating and motivating our business associates towards a more environmentally interactive industrial sector.
♦
Strive to meet Procter & Gamble corporate sustainability targets
♦
This policy will be subjected to annual review per QSI document control system
Signed:____________________________ Mark Masterson Managing Director, P & G Braun Oral-B Ireland
Date:______________
QS1 Document N3088/environmental policy
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 7 of
35
Date: April 2010
2.0
Background & Current Status
2.1
General Description of Company Activities at Braun Oral-B The manufacturing facility located at the IDA Business Park, Newbridge was established in 1984. Braun Oral-B now employs approximately 320 people. Braun Oral-B is involved in the oral dental care industry. The main activities on-site are the manufacture of toothbrushes and dental floss. Toothbrush Manufacture: Newbridge produces all the Oral-B premium manual toothbrush products including Vitalizer, Pulsar and Cross Action. Products are produced by utilizing breakthrough technology including Multi Colour Injection Moulding and Automated Cellular Manufacturing. Braun Oral-B manufactures around 145 million toothbrushes every year. Dental Floss: Braun Oral-B also manufactures Dental Floss. This involves the extrusion of polymers into yarn, spinning of this yarn, application of molten wax and flavourings. Following the coating process the yarn is wound into creels and sent to our sister company in Mexico for final packaging. Braun Oral-B also produces specialist floss products called Superfloss & Ultrafloss. Superfloss Manufacture: Superfloss is a specialist floss product designed to aid dentists in the cleaning of orthodontic appliances. The Superfloss manufacturing process is a solvent free process. Ultrafloss Manufacture: Ultrafloss is a specialist product with an expanded brush-section. The characteristics of the yarn are achieved through the use of resins, which are suspended in organic solvents.
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
Page 8 of
35
Date: April 2010
General overview of changes, January to December 2009 •
The plant is now part of the Procter and Gamble group of companies.
•
Vitalizer Project 2 has been commissioned and is now in full production. (Vitalizer is a top end manual toothbrush)
•
Plant divided into two separate Value Streams. Value Stream is a self contained manufacturing centre.
•
Integrating processes from Braun Carlow, which is closing down in 2010 to new building in IDA Business Park adjacent to Newbridge site.
•
Value Stream 2
•
Procter & Gamble has set 5 year corporate Sustainability targets.
•
Successful ISO 14001:2004 recertification audit
•
Introduced a water based dental floss coating process called Neptune. Line will be commissioned in
Declan McDermot appointed VS2 Manager
2010 •
Technical Amendment granted to IPPC Licence P0297-02 regarding relocation of Air Emission point A2-1 .
•
Emission Point A2-1 renamed A2-3 following Technical Amendment
•
Evaluation of IPPC Licence requirement underway in conjunction with EPA
Overview on Agency Protocol for the Bypass of Air Emmission Abatement Equipment In September 2008 the EPA provided a protocol for the bypass of Air Emission Abatement Equipment . This protocol outlined actions required by licensees to ensure that procedures are in place to include criteria for assessment of both the potential bypass emission points and the likely impact on the ambient atmosphere.
Air Emission Abatement Equipment is not part of Braun Oral-B Ireland Ltd operations, therefore bypass events can not occur on site.
Page 9 of
Braun Oral-B , Ireland Licence Register P0297-02 Annual Environmental Report
35
Date: April 2010
3.0 Data 3.1 Emissions to Atmosphere Summary All sampling and analysis is conducted in accordance with NIOSH standard air monitoring methods. Bord na Mona, conducted all air sampling. The method of collection for the Volatile Organic Emissions testing was adsorbent trapping with subsequent thermal desorption analysis via GC-FID. TDI is trapped onto a pre-treated filter and analyzed via HPLC. Sampling is conducted using calibrated pumps traceable to a commercial standard calibration cell. The chromatographic systems were calibrated by generating calibration curves for the target analytes while running blank samples and controls. Braun Oral-B is required to test two air emission points: Superfloss (A2-2), Ultrafloss (A2-3) However Superfloss (A2-2) emission point has virtually no emissions due to the installation of the solvent free process in late 2003..
3.1.1 Superfloss Emissions to Air (A2-2) Table 1. Synopsis of Atmospheric Emissions for the Superfloss Process Jan – Dec 09 Concentration Estimated max. IPPC Limit Emission Point TOC (mg/m3) (mg/Nm3) mass TOC flow Stack A2-2 (kg/hr) Test dates 75 0.9 4.0 x 10-3 March 2009 75 < 2.47 < 0.05 November 2009 75 1.685 0.027 Average Emission point A2-2
Calculation
Estimated TOC for 2009
220hrs2 x 0.027
TOC Mass Emissions* (kg) 5.94 kg
% compliance 100 100
Max IPPC TOC Limit (kg)
% compliance
9526
100
1
Values preceded with a less than sign “
