Page I of 22

Attachment N0.H. Remediation, Decommissioning, Restoration & Aftercare

H. 1 . Residuals Management Programme.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:01

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:01

CONTENTS

1 .o

2.0

3.0

3.1 3.2

4.0 4.1 4.2 4.3 4.4 4.5 4.6

4.7 4.8 4.9 4.10 4.1 1 4.12 4.13 4.14

5.0

6.0

Introduction

Company Profile

Overview of programme

Residuals Management Plan Statement Stated criteria for execution of the plan

Residual Management plan Decontamination of all equipment Materials removal Decommission plant and equipment Storage tanks Boiler decomissioning Waste disposal Hazardous waste Non Hazardous waste Fixtures and fittings Instrumentation Laboratory waste Decommissioning of underground storage tanks Decommissioning of waste water treatment plant Decommissioning of the thermal oxidiser Contractors and suppliers Final assessment

Validation report

Financial Provisions

Attachments Remediation and Evaluation Services: Mission Statement

Page 1 of 12 Revision 9 dated 21Sf September 2006

Page Page 3 of 12

Page 3 of 12

Page 3 of 12

Page 4 of 12 Page 4 of 12

Page 5 of 12 Page 5 of 12 Page 5 of 12 Page 6 of 12 Page 6 of 12 Page 7 of 12 Page 7 of 12 Page 7 of 12 Page 8 of 12 Page 8 of 12 Page 9 of 12 Page 9 of 12 Page 9 of 12 Page 10 of 12 Page 10 of 12 Page 11 of 12 Page 12 of 12

Page 12 of 12

Page 12 of 12

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:01

1. Introduction

In accordance with condition 14 of SAFC Arklow Ltd, Integrated Pollution Control Licence Register number 540/ POO89-2, the Company submits an update of its Residuals Management Programme which details the planned cessation of all or part of the site, a plan to decommission, render safe, or remove for disposal / recovery , any soil, subsoil’s, buildings, plant and equipment, or any waste materials, substances, or other matter contained therein, or thereon , that may result in environmental pollution.

A hlly detailed and costed plan for the decommissioning or closure of the site or part thereof is included. Following agreement of the agency, this plan shall be reviewed annually, and proposed amendments notified to the Agency for agreement as part of the Annual Environmental Report.

A scope statement of the plan is included along with the programme to achieve the stated criteria. In the event of closure of the site a final validation report including a certificate of completion for the residuals management plan shall be submitted to the EPA three months of execution of the plan.

The company proposes to submit certification as requested by the agency to confirm that there is no continuing risk to the Environment.

2. Company Profile.

SAFC Arklow Ltd was a privately owned company, specialising in the manufacture of a wide range of pharmaceutical products. As a contract manufacturer, Iropharm sold to clients worldwide for formulation.

In July 1997 Iropharm was successfully acquired by Allied Signal, a company based in Morristown, New Jersey which has a turn over of USD 14 billion /year and greater than 70,000 employees worldwide. It is the company’s policy to operate safe and environmentally sound facilities, and also to take responsibility for and keep informed about, health, safety and environmental risks and standards. Allied Signal is an advanced technology and manufacturing company serving customer’s world wide with quality aerospace and automotive products, chemicals, fibres, plastics and advanced materials. Iropharm forms part of the Specialty Chemicals Business Interest.

In 1999 AlliedSignal merged with Honeywell. AlliedSignal subsequently acquired the name of Honeywell. Iropharm PIC and remains a member company of Honeywell.

Page 2 of 12 Revision 9 dated 21 St September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:01

In June 2006, the site was acquired by Sigma Aldrich Corporation, St Louis, MO- Sigma Aldrich Corporation, is a leading Life Science and high technology company. The biochemical and organic chemical products and kits are used in scientific and genomic research, biotechnology, pharmaceutical development, the diagnosis of disease and as key components in pharmaceutical and other high technology manufacturing.

SAFC is the custom manufacturing group within Sigma Aldrich that focuses on both biochemical production and the manufacturing of complex, multi-step organic synthesis of API's and key intermediates. SAFC Arklow limited site is part of this group.

It is the company's policy to operate safe and environmentally sound facilities, and also to take responsibility for and keep informed about health, safety, and environmental risks and standards.

3. Overview of Programme.

SAFC Arklow Ltd's Residuals Management Programme is outlined in more detail in the next section. In this section an overview of the programme is presented.

3.1 Residuals Management plan statement.

SAFC Ark low Ltd, will decommission and render safe all or part of the site as necessary and submit all tests and investigations as necessary to confirm that there is no continuing risk to the environment. The Corporate Remediation and Evaluation Services Mission statement will also be fully complied with.

3.2 Stated criteria for execution of the plan

The criteria needed for the execution of the plan include financial resources, manpower and timefi-ames. These criteria will be looked at in each section of decommissioning of the plan. Each task will be carried out sequentially as far as is reasonably practical. There will be a team established to ensure that the plan is implemented. A few assumptions were made while drafting the Residuals Management plan.

Page 3 of 12 Revision 9 dated 2 1 st September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

4.0 Residuals Management plan

4.1 Decontamination of all equipment

All equipment shall be emptied of all materials. The materials from vessels, reactors distillation units, centrifuges, receivers, shall be cleaned in accordance with best practice cleaning procedures in operation at that time.

Manpower: 1 10 Man Weeks Time frame: 1 10 weeks cost: Not applicable Assump tion: It is assumed that the cost is a normal operational cost to the daily running of the plant.

4.2 Materials removal

a) All raw materials shall be returned to the respective suppliers.

Manpower: 2 people Time frame: 6 weeks Quantity Approximately 600 drums = 8 drumloads cost €40,640

Assumptions: Each drum load consists of 80 drums, the estimated cost of a shipment is E4000 as an average between halogenated and non halogenated compounds.. It is assumed that only 7 bulk storage tank contains virgin solvent at present. This will be used as the plant will be phased out over a certain period of time.

b) Intermediates produced during manufacture will be further processed into finished goods and sent to the respective customers. Alternatively, The material will be sent to a similar Strategic Business Unit of SAFC for further processing.

Manpower: 2 people Time frame: 2 weeks Quantity: 70 drums cost: €4,450 for non halogenated materials based on (12 tonne) =

€5,100 for halogenated materials based on (12 tonne) €1270 for solids based on (1 tonne)

80 drums = 80 drums

Assumptions: This is based on the assumption that 5% of the intermediate inventory would not be processed and have to be shipped off site. The quantities are estimated based on a random inventory. Prices are quoted based on full drum loads.

Page 4 of 12 Revision 9 dated 2 1 st September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

c) Finished materials will be sent to the respective customer or if unsold, will be sent to a similar site of SAFC for storage until sold.

Manpower - Timeframe - Quantity: 2 tonne solids/ week

cost: Not determined 1 tonne liquids/ week

Assumptions: The cost of shipping to customers cannot be determined. As a contract manufacturer we supply a large number of customers worldwide and the cost of shipping final product will vary depending on the destination.

4.3 Decommission plant and equipment.

Plant and equipment will be decommissioned in an orderly fashion and in accordance with the manufacturers recommendations. As plant equipment is available, it will be packed and sent to a similar site of Sigma Aldrich as soon as is practical, or sold as secondhand goods. Hazardous waste including solid waste and waste oils shall be disposed of to the contractors listed in the Integrated Pollution Control Licence.

Manpower: 10 men Time frame: 1 year cost: € 1,200,000 This is also based on the assumption that an external contractor consultancy firm is retained on site to oversee this operation.

4.4 Storage tanks.

All storage tanks containing virgin solvent shall be emptied and the solvents returned to the supplier. Alternatively these solvents will be sent for recovery to an approved waste recovery site. All storage tanks containing waste solvent shall be emptied in accordance with current environmental practice and sent off site for disposal or recovery to an approved waste disposal/ recycling contractor. All storage tanks containing waste aqueous phases, mother liquors etc shall be drummed up in accordance with current environmental practice for disposal off site to an agreed waste disposal / recycling contractor. When all storage tanks are emptied they shall be washed down and decontaminated. Wash water from this process shall go to the waste water treatment plant for treatment, while ensuring that the current emission limit values for the effluent parameters are not exceeded.

Page 5 of 12 Revision 9 dated 2 1'' September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

Tanks will be checked to ensure that they are indeed empty. Bunds will also be checked to ensure their integrity. Any modifications to bunds will be done to ensure protection to surface and groundwater is maintained.

Manpower: 2 man months Time frame: 43 days Quantity: 63 tanks cost: &125,000 €1 58,750

Assumption: This is based on the assumption that there are 63 bulk storage tanks on site varying from 1 m3 capacity to 25 m3 capacity. All lines shall be purged with nitrogen before dismantling. Almost all tanks can be removed without dismantling.

4.5 Boiler decommissioning

The three boilers currently on site (1 boiler associated with the thermal oxidiser plant) shall be decommissioned in accordance with good engineering practice and the manufacturers recommendations. This shall include decontamination of the boiler. Waste water from the boiler shall be released to the effluent treatment plant for treatment ensuring that the current emission limit values are not exceeded. The boilers shall be sold as a second hand boiler, or alternatively will be transported to another Sigma Aldrich facility

Manpower: Team of external engineers Time frame: 4 Weeks cost: €70,000

Assumption: Is based on the fact that decommissioning of boilers will be performed by Renick Engineering Company.

4.6 Waste disposal

Hazardous waste Hazardous waste including mixed waste solvent, various waste solvent streams, utilities waste oils, solid waste, fluorescent tubes, settled solids, asbestos, fibreboard drums, filter cartridges contaminated plastic and other waste requiring disposal / recovery shall be sent to an agreed waste disposal / recovery site.

Other hazardous waste requiring disposal shall be disposed of /recovered offsite after obtaining prior written agreement of the agency. All waste transported off site shall be transported in accordance with good environmental practice and appropriate National and European legislation and protocols.

Page 6 of 12 Revision 9 dated 2 1 st September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

For waste quantity it has been assumed that all tanks used for holding waste either solvent or aqueous were full at the time of shutdown. Manpower: 2 people Time frame: 3 months

* <

Quantity: Tank 10: 20,000 1 Tank 59: 25,000 1 Tanks 7,8,3,4,5: 70,000 1 total Tanks 27,28: 24,0001 total

Cost: 7 Tankers @ €3,500 per consignment €24,500

Tank 17 &60 40,0001

Cost: 2 tankers @ €7,000 per consignment €14,000 Total €38,500

E1,OOO per tonne for solid waste E1,OOO per tonne for waste solvent in drums

Non Hazardous waste Non hazardous waste including canteen, Production, Laboratory, Office, and maintenance solid waste, sludge from the wastewater treatment plant and other waste requiring disposal/ recovery shall be sent to an agreed waste disposal/ recovery site.

Other non hazardous waste requiring disposal shall be disposed of /recovered /recycled off site after obtaining prior written agreement of the agency. All waste transported off site shall be transported in accordance with good environmental practice and appropriate National and European legislation and protocols.

Manpower: 2 people Time frame: 3 months Quantity: refer to hazardous waste cost: E100,OOO €127,000

Assump tion: Is based on the fact that a provision of €127,000 is made available for Hazardous and Non Hazardous waste disposal.

4.7 Fixtures and fittings

Any fixtures and fittings from plant areas, laboratories, offices and stores shall be removed off site if necessary and sold or sent to a similar Strategic Business Unit of Sigma Aldrich plant for use.

Manpower: 2 people Page 7 of 12 Revision 9 dated 2 1 st September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

Time frame: 9 weeks Quantity: Not determined cost: Not applicable Assump tion: This is based on the assumption that the packing of instruments, computers etc is required. It would take 2 people one month to clear the labs, involving the packing of instrumentation etc, 1 week for each of the production buildings, 2 weeks for the Administration building. It is assumed that the cost is a normal operational cost to the daily running of the plant.

4.8 Instrumentation Any laboratory instrumentation' including GCs, computers etc shall be sold or sent to a similarsite of the SAFC corporation.. Manpower: 1 person Time frame: 2 weeks Quantity: Not determined cost: Not applicable

After all stores and plants are emptied they shall be cleaned and remaining rubbish, Hazardous chemicals etc shall be sent offsite for disposal in accordance with 4.6. The cost for instrumentation removal will be attributable to the normal operational costs of running the laboratories.

4.9 Laboratory waste

Research and QC Chemicals shall be transferred to SAFC labs in England or the USA. Retained QC samples will be disposed of as in 4.6.

Manpower: 2 people Time frame: 2 weeks Quantity: Not determined cost: As per 4.6

Assump tion: Is based on the fact that two people f'rom the labs will be retained to collect and pack any stored laboratory waste. The cost for this work will be attributable to the normal operational costs of running the laboratories.

4.10 Decommissioning of the underground storage tanks

The vacuum pump water tank and septic tank shall be decommissioned in accordance with good engineering practices. Underground storage tanks shall be emptied, cleaned and filled with an inert substance. This will ensure the surface and groundwater protection.

Page 8 of 12 Revision 9 dated 21Sf September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

Manpower: 2 people Time frame: 3 weeks Quantity: 2tanks cost: Assumption: The cost is based on the cost of filling the tanks with an inert substance costing €2.54 per m3 and the cost of labour.

8.8 and 5.0 m3 * €2.54 e 3 5

4.11 Decommissioning of wastewater treatment plant

This shall be one of the final jobs to be carried out after treatment of all possible waste on site have been completed. The waste water treatment plant shall be decommissioned in the following way. All tanks shall be emptied . The contents including sludges shall be treated as for 4.6 above. All equipment and back up equipment shall be cleaned and removed off site for sale or transport to a similarsite of Sigma Aldrich. Tanks shall be checked to ensure that they are not leaking to protect against surface and groundwater contamination. Tanks will be locked or covered where possible to prevent ingress of rain water. If deemed necessary, tanks will filled with an inert substance.

Manpower: 4 people Time frame: 2 months Quantity: cost €2 1,590 Assumption: This is based on the assumption that the plant if resold will no need for a wastewater treatment plant. also the cost of filling the tanks is €2.54 per m3 .

8 tanks @3940 m3* €2.54 = €10,007 and the cost of labour

Decommissioning of waste air treatment plant

This shall be one of the final jobs to be carried out after treatment of all possible waste on site have been completed. The waste air treatment plant shall be decommissioned in the following way. All tanks shall be emptied . The contents including sludges shall be treated as for 4.6 above. All equipment and back up equipment shall be cleaned and removed off site for sale or transport to a similar site of SAFC. The boiler shall be decommissioned as per 4.5 above. Tanks shall be checked to ensure that they are not leaking to protect against surface and groundwater contamination.

Manpower: 4 people Time frame: 2 months

Page 9 of 12 Revision 9 dated 21" September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

Quantity: cost €70,000 Assumption: This is based on the assumption that the plant if resold will have no need for a wastewater treatment plant, the cost of filling the tanks is €2.54 per m3.

4 tanks and the cost of labour

4.13 Contractors and Suppliers

It is the policy of SAFC Arklow Limited to ensure that each facility will make appropriate efforts to assure that its contractors, and suppliers pursue pollution prevention programmes for the protection of the environment while engaged in plant decommissioning.

Manpower: 1 person Time frame: Until plan is complete cost: €63,500

Assump tion: Contractors arriving on site will be trained in safety and environmental awareness issues A Contract engineer will be retained on site possibly from SAFC for 6 months to ensure that the plan is executed.

4.14 Final assessment

During the operation of the Residuals Management Plan, an assessment will be conducted by a qualified Environmental consultant to investigate the compliance status and environmental risk factors in particular, addressing the following points.

Agency contacts regarding the EPA Any enforcement actions pending Verification/ certification that underground storage tanks and lines are non leaking Verification to ensure that there is no risk to surface or groundwater contamination

0 Presence/ absence of spill releases that may have contributed to soil/ groundwater contamination.

Identification of any remedial activities carried out to remedy environmental problems and the results of such activities.

Presence/ absence of asbestos in building insulation 0 Physical examination of the facility to ensure removal of any or all contaminants 0 A summary list of environmental reports, surveys, results, assessments, studies, proposals, complaints, incidences, performed to date shall be available for inspection

Page 10 of 12 Revision 9 dated 2 1 ’* September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

' '- 5.0 Final validation reporf '. I

In accordance with the licence register No 540, a final validation report will be issued by the Sigma Aldrich Corporation to include a certificate of completion for the Residuals Management plan. This shall be done within three months of execution of the plan.

6.0 Financial Provisions

Financial provisions in the event of closure of the facility or part there of are detailed as part of the Environmental Liabilities risk assessment. The total cost of exercising the Environmental liabilities risk assessment is calculated at approximately €1,27 1,000.

Page 11 of 12 Revision 9 dated 2 1 st September 2006

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

Mr. Jonathan Derliam 1 Protection Agency

Estate

06 September, 2006

rklow Ltd - IPC LICENCE NO. 540

Marsh Ireland Ltd. 25-28 Adelaide Road Dublin 2 Ireland +353 1 6048100 Fax

than seventy two hours.

t clean-up of own lands and water. Any guidanc

sociate Partner ect Dial: 01 604 8280

Direct Fax: 01 604 8470 Ernail: Pat.tormcv6iharsh.com

cc kXr. Ian Jacob

Marsh & McLennan Companies 528 Adelaido Road. Oubfin 2 VAT No. 63335920

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:20:20:02