annual environmental report 2009 pdm limited, ippc register … · 2014. 12. 16. · 2.3. schedule...
TRANSCRIPT
-
Saint Gobain Building Distribu\49340721 Saint Gobain Kill AER 2010\DURP0001/KK/KK
Annual Environmental Report 2009
PDM Limited, IPPC Register P0325-01
March 2010 Final
-
March 2010 Annual Environmental Report 2009
PDM i
CONTENTS
Section Page No
1. INTRODUCTION.............................................................................................................. 1
1.1. General............................................................................................................................. 1 1.2. Site & Process Description............................................................................................... 1
2. MANAGEMENT OF THE ACTIVITY ............................................................................... 2
2.1. Environmental Management System ............................................................................... 2 2.2. PDM Management Structure............................................................................................ 3 2.3. Schedule of Environmental Objectives and Targets ........................................................ 3 2.4. Environmental Management Programme Report ............................................................ 3 2.5. Environmental Management Programme Proposal ....................................................... 14 2.6. Pollution Emission Register Report................................................................................ 17
3. EMISSIONS TO ATMOSPHERE................................................................................... 18
4. EMISSIONS TO WATER ............................................................................................... 19
4.1. Effluent Emissions.......................................................................................................... 19 4.2. Emissions to Surface Water........................................................................................... 23 4.3. The EPA Monitoring ....................................................................................................... 24 4.4. Additional Monitoring...................................................................................................... 25 4.5. Groundwater Monitoring................................................................................................. 25 4.6. Testing and Inspection of Underground Tanks & Pipelines and Bund Integrity ............ 32
5. WASTE .......................................................................................................................... 33
5.1. Introduction..................................................................................................................... 33 5.2. Summary of Waste Statistics ......................................................................................... 33
6. NOISE ............................................................................................................................ 37
6.1. Introduction..................................................................................................................... 37
7. RESOURCE CONSUMPTION....................................................................................... 38
7.1. Introduction..................................................................................................................... 38 7.2. Electricity Usage............................................................................................................. 38 7.3. Diesel Usage .................................................................................................................. 38 7.4. Woodchip Usage............................................................................................................ 39 7.5. Light Fuel Oil Consumption............................................................................................ 40 7.6. Water Consumption........................................................................................................ 40 7.7. Discussion ...................................................................................................................... 40
8. ENVIRONMENTAL INCIDENTS AND COMPLAINTS.................................................. 42
8.1. Complaints ..................................................................................................................... 42 8.2. Incidents ......................................................................................................................... 42
9. REVIEW OF RESIDUALS MANAGEMENT PLAN ....................................................... 42
-
March 2010 Annual Environmental Report 2009
PDM ii
CONTENTS
Section Page No
10. ENVIRONMENTAL LIABILITIES INSURANCE COVER.............................................. 44
APPENDIX A - ISO 14001 CERTIFICATE
APPENDIX B - COMPLETED PRTR WORKSHEETS
-
March 2010 Annual Environmental Report 2009
PDM 1 Final
1. INTRODUCTION
1.1. General
This Annual Environmental Report (AER) is prepared for the PDM Limited
facility, Oldmilltown, Kill, Co. Kildare in accordance with the conditions of the
operating IPPC licence, which states:
Condition 2.9.2
“The licensee shall submit to the Agency, eighteen
months from the date of grant of this licence, and each
calendar year thereafter, an AER which shall be to the
satisfaction of the Agency. This report shall include as a
minimum the information specified in Schedule 5
Recording & Reporting to the Agency and shall be
prepared in accordance with any relevant guidelines
issued by the Agency.”
The Environmental Protection Agency (the EPA) granted the IPPC licence
register number PO325-01 to PDM Limited (PDM) on December 23rd, 1998.
The company is licensed under the Environmental Protection Agency Act,
1992 to carry out the following activity:
“The treatment or protection of wood involving the use of
preservatives with a capacity exceeding 10 tonnes per
day.”
This AER has been prepared in accordance with the EPA guidelines.
1.2. Site & Process Description
1.2.1. Site Description
PDM is located in Oldmilltown, in the hinterlands of Kill town, in Co. Kildare.
PDM is a subsidiary of the French group Saint-Gobain. The site is situated
approximately 25km south-west of Dublin city and has been in operation for
41 years, specialising in the manufacture and pressure impregnation of
wood with preservative. There are 31 people employed at the site.
The site occupies an area of approximately 16 hectares, with adjacent land
owned by the ESB on the western perimeter. Surrounding land use is
dominated by agricultural activities. There is a network of open surface
water drains occurring across and around the site. The drains tend to follow
boundary lines, however regionally surface water flows in a north-west
direction reflecting topography. Surface water from the site and the
surrounding area discharges to Painestown River, which subsequently
discharges to the Morrell River, and finally to the River Liffey located 8 km
north-west of PDM.
-
March 2010 Annual Environmental Report 2009
PDM 2 Final
1.2.2. Process Description
Site activities comprise the manufacture and pressure impregnation by
creosote and Osmose Naturewood®, of timber products, namely poles,
railway sleepers, posts, rails and round fencing. Under direction of the
company that owns PDM, Saint Gobain, the Osmose Naturewood® replaced
Tanalith (CCA) in November 2003 as a wood preservative due to restrictions
in marketing and use of CCA. The main active ingredient in the Osmose
Naturewood is copper which has long been known as an effective wood
preservative. The copper is coupled with an organic co-biocide for enhanced
performance against copper tolerant fungi and insects.
Site operations may be summarised as follows: Poles are received onto the
site. Natural seasoning of the poles, approximately 9-12 months, takes place
at this stage. When suitably seasoned (thus allowing proper penetration of
the treatment materials), the inner bark is removed with dressing machines.
The poles are then transferred to the fabrication shed where the poles are
fabricated to the required client specification. This is followed by a treatment
stage where the poles are pressure treated with creosote or Osmose
Naturewood® on a batch basis in large pressure cylinders. The treated
poles are then stored on concrete pads on-site, prior to delivery to
customers.
In relation to other timber products, timber is received onto the site and
stored in a designated area. Depending on the timber type and moisture
content of the timber, drying in kilns may be required at this stage. When the
moisture content is correct (i.e. 26%) thus allowing proper penetration of the
treatment materials, the timber is pressure treated with creosote or Osmose
Naturewood® on a batch basis in large pressure cylinders. The treated
timber products are then stored in sheds on concrete pads on-site, prior to
delivery to customers.
2. MANAGEMENT OF THE ACTIVITY
2.1. Environmental Management System
An Environmental Management System (EMS), required under Condition
2.1 of the License, facilitates the management of the environmental impacts
of the PDM’s activities. The EMS currently includes the following elements:
• The Environmental Policy;
• A Schedule of Objectives and Targets;
• The Environmental Management Programme;
• The Pollution Emission Register; and
• Programmes relevant to documentation, corrective action, awareness
and training, responsibilities and communications.
The Environmental Quality Policy is the fundamental building block for the
EMS. It serves as the foundation for the rest of the system. This policy sets
-
March 2010 Annual Environmental Report 2009
PDM 3 Final
out the principles, which govern PDMs approach to environmental
management.
PDM Limited is accredited to I.S. EN ISO 9001:2000 and ISO 14001 and
PDM’s compliance with these standards is audited twice per annum. A copy
of the ISO 14001 certificate is presented in Appendix A.
2.2. PDM Management Structure
The management structure at the PDM facility is detailed in Figure 2.1
2.3. Schedule of Environmental Objectives and Targets
The Schedule of Objectives and Targets submitted as part of the 2008 AER
is presented as Table 2.1. Table 2.1 combined with the discussion on
individual projects in Section 2.4 of the AER forms the Environmental
Management Programme Report for the calendar year 2009.
The status column in Table 2.1 has been updated to reflect project progress
in 2009.
2.4. Environmental Management Programme Report
PDM are required in accordance with Condition 2.3.2 of the IPPC licence, to
submit an Environmental Management Programme Report, as part of the
AER for the reporting period January 2009 to December 2009. The EMP
report is detailed in the following sections.
Refer to Table 2.1 during the following discussion. Key projects are
described.
-
March 2010 Annual Environmental Report 2009
PDM 4 Final
Figure 2.1 - PDM Limited Organisation Chart
-
March 2010 Annual Environmental Report 2009
PDM 5 Final
Table 2.1 – Schedule of Objectives for Calendar Year 2009 (presented in 2008 AER)
No.
Environmental
Aspect Objective Planned
Completion Date
Status
OB1 Purchasing of timber Re-examine the opportunities of sourcing product from more sustainable sources.
Dec ‘09
During 2009, over 80% of timber used at PDM was Forest
Stewardship Council (FSC) sourced
OB2 Stream Plant reeds in the stream that is now no longer used. Feb ‘09 Completed
OB3 Review Of Licence Submit to the EPA a revised proposal regarding the conditions of PDM’s IPPC Licence taking into account OCM’s report sent to PDM
April ‘09
Revised proposal submitted but
dialogue with EPA in relation to this is
ongoing
OB4 Surface and Ground Water Protection
Complete the implementation of the Groundwater Monitoring and Containment System as agreed with the EPA.
Dec ‘09 Outstanding
OB5 Boiler Emissions Carry out another boiler emissions test. March ‘09 Completed in Sept
‘09
OB6 Fugitive Emissions Submit to the EPA findings of the fugitive emissions project carried out by URS. Jan ‘09 Completed
OB7 Concrete Yard Assess the integrity of the concrete in the drag out areas and complete the necessary repairs.
Feb ‘09 Completed
OB8 Training Define training needs for each individual whose activities have directly impact on the environment.
Nov ‘09 On-going
OB9 Concrete Pads Clean individual concrete pads once that particular pad becomes empty. On-going On-going
OB10 Groundwater MW5 Provide a cap for the MW5 monitoring borehole. Jan ‘09 Completed
OB11 Audits Carry out at least 3 audits of sub-contractors carrying out work related to environment.
Sept ‘09 Completed
-
March 2010 Annual Environmental Report 2009
PDM 6 Final
OBJECTIVE OB1 PURCHASING OF TIMBER
Overall Target:
• To purchase over 80% of timber products from Forest Stewardship
Council (FSC) accredited sources.
Scheduled Benefits:
• Encourage and promote sustainable development;
• Improve the environmental performance of the company;
• Comply with the requirements of the operating IPPC licence;
Project Summary:
An on-going objective of the Saint Gobain company is to purchase 80% of its
raw materials from sources that are accredited to the FSC Certification
scheme. In participating in this scheme, the company is certified to state that
its timber originates from sustainable and well managed sources.
Summary of Work Completed in the Previous EMP:
PDM is aware that the scope of this project is very large, with the targets
attainable in the long term rather than the short term. Due to the competitive
nature of the timber markets, the company is anticipating that its existing raw
material sources will aim to achieve certification with this scheme. During
2009, over 80% of timber used at PDM was FSC sourced. Hence, the target
of sourcing more than 80% of raw materials from FSC Sources is currently
being met by the site.
Summary of Work to Do in the Forthcoming EMP:
The company will continue to actively investigate the sourcing of raw
materials from companies certified to the FSC. This project is long term in
nature and also susceptible to market variations and trends. PDM sourced
one new supplier during 2009 and all material purchased from this supplier in
2009 was FSC sourced.
OBJECTIVE OB2: PLANT REEDS IN THE STREAM THAT IS NO LONGER USED
Overall Target:
• To plant reeds in a stream that is no longer used.
Scheduled Benefits:
• Clean up of the stream that was previously contaminated with creosote;
• Improving environmental performance of the company;
Project Summary:
This stream was cleaned out via the removal of sediment in stages from
2006 through to 2008. The final stretch of stream was cleaned in September
-
March 2010 Annual Environmental Report 2009
PDM 7 Final
2008. The sediment removed from the stream was disposed by Indaver.
Reeds were planted in the stream channel in early 2009.
Summary of Work to Do in the Forthcoming EMP:
General maintenance and upkeep of the reedbed.
OBJECTIVE 0B3: REVIEW OF LICENCE
Overall Target:
• To submit to the EPA a revised proposal in regard to the conditions of
our IPPC Licence taking into account O’Callaghan, Moran & Associates
audit report of the facility sent to PDM.
Scheduled Benefits:
• Re-assess emission limit values;
• Re-assess particular sampling as agreed with the EPA on present
licence;
• Improve the environmental performance and management within the
company.
Project Summary
A letter was sent to the EPA (June 15th 2007) requesting a review of our
existing IPPC licence. PDM requested the review of the license to allow for
the amendment of some monitoring requirements in their current IPPC
license. This main amendment requested included:
• Changes in frequency of required monitoring;
• Removal of surface water point G as there is no surface water flow at
this location;
• Removal of requirement to monitor chromium, arsenic, and
pentachlorophenol, as these substances are not used on the site;
• Removal of requirement to monitor mineral oil as the site is not a
significant user of mineral oils.
The EPA replied on the 31st July 2007 stating that on the basis of the
information provided to them that a review was necessary and that an
application for a review should be submitted to the Agency in Accordance
with Section 09 of the EPA Acts 1992 and 2003.
PDM had intended to submit the IPPC review application in 2009 however
PDM have reconsidered the position with regard to a full license review and
now hope to under a technical amendment the current license.
-
March 2010 Annual Environmental Report 2009
PDM 8 Final
Summary of Work Completed in the Previous EMP:
PDM submitted a request to the EPA on 19th August 2009 requesting a
reduction in a frequency of monitoring of various parameters in effluent and
groundwater at the facility under condition 1.2 of IPPC License register
number P0325-01. The EPA replied on the 25th August 2009 stating that a
number of the requests could only be dealt with under a license review. The
EPA agreed to the request to reduce the monitoring of Phenols at Emission
point E from monthly to quarterly. The EPA requested additional information
before deciding if the requirement to monitor mineral oil at Emission point E
could be removed form the license. The EPA also agreed to a change in the
annual monitoring requirements for groundwater, effluent and surface water
from arsenic, boron, cadmium, chromium, hexavalent chromium, copper,
manganese, lead, nickel, zinc, mercury, calcium, sodium, potassium,
chloride, ammonium, sulphate, sulphide, nitrite, alkalinity, tebuconazole,
propiconazole, permethrin, ethanolamine and benzalkonium chloride to
arsenic, boron, cadmium, chromium, copper, lead, nickel, zinc, mercury,
ethanolamine and benzalkonium chloride provided that hexavalent
chromium, ammonia and manganese are also monitored on a annual basis.
Other changes which were agreed with and approved by the EPA during
2009 include a reduction in the frequency of monitoring required for Chemical
Oxygen Demand (COD) and suspended solids from weekly to monthly at
Emission Point E;
Summary of Work to Do in the Forthcoming EMP:
PDM will submit a detailed request to the EPA for all other desired
amendments to the IPPC license to be dealt with via a technical amendment
to the license.
OBJECTIVE OB4: SURFACE AND GROUND WATER PROTECTION
Overall Target:
• To implement the Groundwater Monitoring Network and the
groundwater Remedial Strategy as agreed with the EPA in January
2007.
Scheduled Benefits:
• Problems with water quality are likely to be highlighted sooner;
• Increased confidence in water quality data as increased data bank;
• Minimise on-going off-site migration of Poly Aromatic Hydrocarbons
(PAH) contaminated groundwater in the vicinity of the production area.
Project Summary:
An ongoing objective of the PDM facility is to ensure all effluent and
emissions arising onsite and surface and groundwater are monitored and
treated appropriately so that the risk of emission limit value (ELV) non-
compliances are minimised as a result and to prevent environmental
-
March 2010 Annual Environmental Report 2009
PDM 9 Final
pollution. As a result of a report submitted to the EPA by PDM on 21
December 2005 Groundwater Monitoring and Review of Remedial Strategy
certain recommendations were made notably the decommissioning of MW07
due to contamination with Creosote, the fitting of well caps to all wells and
the installation of a hydraulic containment system. This report was updated
by a report submitted in December 2006 - Review of Remedial Strategy.
Recommendations in this report included providing improved secondary
containment at the Cresote storage tank filling points, hydraulic testing of the
treatment plant bunds and regular inspections, cleaning of drains in the
treated timber storage areas and the replacement of MW07 with MW08 and
monitoring be carried out on MW08 on a quarterly basis.
In December 2007, PDM submitted an updated proposal to the EPA for the
installation of the hydraulic containment system to reduce the potential for off-
site migration of PAH contaminated groundwater in the vicinity of MW8. The
EPA have proposed a trial period of 1-month (EPA Letter, dated 01/02/2008)
and completion of a report on the findings. The report should include, as per
the EPA letter, a detailed remediation strategy for the existing contamination
and a detailed risk assessment on the potential impacts of a full-scale
remediation strategy. The letter also reminded PDM of an EPA letter 13/01/06
requiring PDM to carry out a risk assessment addressing all contamination
arising from the site. As part of this Hydraulic Containment strategy, two
additional groundwater monitoring wells (MW11 and MW12) were installed by
URS in April 2008. Hydraulic testing of MW12 was carried out in June 2008,
which found MW12 to be a suitable abstraction well for the hydraulic
containment system.
Summary of Work Completed in the Previous EMP:
• PDM has prepared and submitted a proposal for the design, installation
and commissioning of a groundwater containment system.
Summary of Work to Do in the Forthcoming EMP:
Completion of the groundwater containment system and a Quantitative Risk
Assessment (QRA) during 2010. The QRA will assess the risk to sensitive
receptors of any contamination which may have migrated off-site.
OBJECTIVE OB5: BOILER EMMISSIONS TESTING
Overall Target:
• To carry out another boiler emissions test.
Scheduled Benefits:
• Maintain high efficiency of the boiler;
• Identify issues at early stage;
• Promotes a proactive approach to environmental management within
the company.
Project Summary:
-
March 2010 Annual Environmental Report 2009
PDM 10 Final
In March 2008 a report was submitted to the EPA on the emissions from the
boiler which was carried out by Bord Na Mona on January 31st 2009. It was
noted that due to the presence of burning embers in the emission stream,
Bord Na Mona recommended that further particulate testing on the stack be
carried out using the ESEPA approved method 5 isokinetic sampler which is
based on the monitoring principles set out in the European Standard
EN13284-1. A revised monitoring programme was undertaken in July 2008
and the report was forwarded to the EPA.
Summary of Work Completed in the Previous EMP:
Another boiler emissions test was completed by EMP in October 2009 to
address the EPA’s concern regarding particulates in the air emissions form
the woodchip boiler. This report was submitted to the EPA in November
2009.
Summary of Work to Do in the Forthcoming EMP:
Not applicable.
OBJECTIVE OB6: FUGITIVE EMMISSIONS
Overall Target:
• To carry out more fugitive emissions monitoring and submit findings to
the EPA.
Scheduled Benefits:
• Reduce the quantity of fugitive emissions arising from the facility.
• Improve the environmental performance of the company.
• Comply with the requirements of the operating IPC licence.
Project Summary:
An ongoing objective of the PDM facility is to ensure all fugitive emissions
arising on-site are minimised. One area of the site identified as a potential
source of fugitive emissions is the storage of creosote in the on-site storage
tanks. In early 2002, PDM commissioned URS Ireland Limited to undertake
a fugitive emissions study at the creosote plants. The results from this study,
detailed in Appendix (iii) to the AER 2002, indicate an estimated 23 kg/a of
fugitive emissions to atmosphere of creosote. Given the reasonably constant
annual creosote consumption, it is assumed that the fugitive emissions are
equivalent each year.
An additional study was completed in 2005 aimed at verifying the findings of
the 2002 report, which was based on computer modelling (TANKS4 software
and manual flash calculation), with actual monitoring data. The 2005 report
measured losses far less than was predicted in the 2002 study.
-
March 2010 Annual Environmental Report 2009
PDM 11 Final
Summary of Work Completed in the Previous EMP:
Several recommendations were made in the 2005 report, including the
recommendation to monitor all operational stages to improve the accuracy of
the estimate of total fugitive emissions from the production processes at
PDM and noting limitations in the sampling carried out in 2005.
Further fugitive emission monitoring was undertaken at PDM during July
2008. As a result of this assessment, the annual fugitive emissions from
production processes and related activities at PDM of the primary PAH
compounds, phenols and BTEX compounds have been characterised and
quantified, and recommendations from the 2005 Fugitives Study have been
satisfied, to the extent practicable.
The percent fugitive losses of input for each compound has been estimated
as follows:
�
-
March 2010 Annual Environmental Report 2009
PDM 12 Final
OBJECTIVE OB8: TRAINING
Overall Target:
• Define training needs for each individual whose activities have directly
impact on the environment.
• Conduct on-going environmental awareness and training at the facility.
Scheduled Benefits:
• To promote environmental awareness within the company;
• Reduce risk of incidences, through improved training programmes for
employees;
• Comply with the requirements of the operating IPPC licence.
Stage Project Area Time scale
Responsibility
1 Implement new training programmes on-site. On-going Operations Manager
2 Schedule regular environmental meetings. On-going Operations Manager
3 Fire, Chemical, and Auditing Training On-going Operations Manager/
H&S Officer
Project Summary:
The company has developed and implemented a system of standardised
procedures for all environmental operations, including the operation of the
wastewater treatment facility. The company will ensure that all personnel with
environmental responsibilities shall be adequately trained in relevant
procedures, and are familiar with the operating IPPC licence. In addition,
meetings will be scheduled on a regular basis to discuss environmental
matters and increase environmental awareness within the company.
Various members of staff have completed courses such as spill control
techniques, waste management, acoustic sound barriers. Environmental
meetings are held every six weeks, and are attended by members of
company management and key environmental personnel. These meetings
are held in order to raise awareness of environmental issues on site. With
regard to positions with specific environmental responsibilities, the company
developed a skill-block system to identify required requisites and develop a
training program on this basis. All records of training are maintained on file.
Summary of Work Completed in the Previous EMP:
PDM undertook all training requirements for staff whose activities have
directly impact on the environment.
Summary of Work to Do in the Forthcoming EMP:
-
March 2010 Annual Environmental Report 2009
PDM 13 Final
The company will continue to develop the present training programme to
extend on the environmental awareness section. PDM will establish a review
procedure to ensure all relevant personnel are included.
OBJECTIVE OB9: CONCRETE PADS
Overall Target:
• Clean individual concrete pads once that particular pad becomes
empty.
Scheduled Benefits:
• Reduce run off to surface water drain;
• Reduce odour;
• Prevent soil and groundwater contamination;
• Identify faults on pads which require repair;
Summary of Work Completed in the Previous EMP:
Concrete pads are cleaned as each new batch of timber is removed from the
area.
Summary of Work to Do in the Forthcoming EMP:
Ongoing housekeeping within the concrete pad area.
OBJECTIVE OB10: GROUNDWATER MW5
Overall Target:
• Provide a cap for the MW5 monitoring borehole.
Scheduled Benefits:
• Protection of groundwater.
Summary of Work Completed in the Previous EMP:
A cap was fitted to the MW5 monitoring borehole in January 2009.
Summary of Work to Do in the Forthcoming EMP:
Not applicable.
OBJECTIVE OB11: AUDITS OF SUB-CONTRACTORS
Overall Target:
• Carry out at least 3 audits of sub-contractors carrying out work related to
environment.
Scheduled Benefits:
-
March 2010 Annual Environmental Report 2009
PDM 14 Final
• Ensures that these contractors operate to high standards and in
environmentally sound manner;
• Meeting the EPA’s requirements;
Summary of Work Completed in the Previous EMP:
PDM carried out an audit of Bord Na Mona laboratory, who provide testing
services for PDM’s water samples.
In July, PDM carried out an audit of Indaver, PDM’s waste management
contractor.
In September 2009, PDM carried out an audit of SSI Environment, a
company who supplies spill kits to PDM.
Summary of Work to Do in the Forthcoming EMP:
Audit sub-contractors on annual basis.
2.5. Environmental Management Programme Proposal
A revised Table of Environmental Objectives and Targets for 2010 is
presented in Table 2.2.
It is proposed that Table 2.2, in conjunction with the paragraphs “Summary of
Work to Do in the Forthcoming EMP” paragraphs detailed in Section 2.4
above, will form the Environmental Management Programme for 2010.
-
March 2010 Annual Environmental Report 2009
PDM 15 Final
Table 2.2 – Proposed Schedule of Objectives and Targets for Calendar Year 2010
EMP No.
Objective Targets Person Responsible Completion Date
OB1 Purchasing Re-examine the opportunities of sourcing product from more European countries who have proof of FSC
Catherine O’Sullivan/ Managing Director
December 2010
OB2 QRA Carry out the Quantitative Risk Assessment as agreed with the EPA
Catherine O’Sullivan/ URS
March 2010
OB3 Review Of Licence/Technical amend
To submit to the EPA a letter outlining our requirements for some technical amendments to our current IPC Licence.
Catherine O’Sullivan/ URS
January 2010
OB4 Surface and Ground Water Protection
To complete the implementation of the Groundwater Monitoring and Containment System as agreed by the EPA after the completion of the QRA
Catherine O’Sullivan/ URS
July 2010
OB5 Financial Provision
Finalise the issue of the Financial Bond with the EPA Catherine O’Sullivan/ Saint Gobain
June 2010
OB6 Old Batteries Dispose of all old batteries on site Catherine O’Sullivan/T. Horan
March 2010
OB7 Greener Office Conserve energy, conserve water, and become a greener cleaner office
Catherine O’Sullivan December 2010
OB8 Training Define our training needs with each individual who is directly involved with the environment
Catherine O’Sullivan November 2010
OB9 Audit Training Carry out internal audit training for all members of the auditing team.
Catherine O’Sullivan September 2010
-
March 2010 Annual Environmental Report 2009
PDM 17 Final
2.6. Pollution Emission Register Report
The Pollutant and Emission Register (PER) has been succeeded by the
Pollutant Releases and Transfer Register (PRTR). Relevant substances on
the PRTR will be reported via an EPA web-based system.
The completed PRTR worksheet is included in Appendix B of this report.
-
March 2010 Annual Environmental Report 2009
PDM 18 Final
3. EMISSIONS TO ATMOSPHERE
Condition 5.2 of the IPPC licence Reg. No. PO325-01 requires the company
to submit a summary report of emissions to atmosphere including fugitive
emissions. The URS report on fugitive emissions was submitted in 2008
AER. No further fugitive emissions assessment was undertaken in 2009.
The boiler emissions test completed by EMP in October 2009 to address the
EPA’s concern regarding particulates in the air emissions form the woodchip
boiler was submitted to the EPA in November 2009.
In accordance with the conditions of the operating licence, PDM are not
required to monitor emissions to atmosphere.
-
March 2010 Annual Environmental Report 2009
PDM 19 Final
4. EMISSIONS TO WATER
4.1. Effluent Emissions
4.1.1. Introduction
The PDM facility controls and monitors one licensed effluent emission,
emissions point reference ‘E’, which discharges directly to the Kill River. This
receiving water is situated in close proximity to the PDM site.
Condition 6.1, in conjunction with Schedule 1 of the IPPC licence, governs
the monitoring and control of final effluent emissions from the wastewater
treatment plant to receiving waters.
Schedule 2(i) of IPPC licence Reg. No. PO325-01 specifies the maximum
volume of effluent to be discharged in any one day at 2500m3, and an hourly
discharge licensed at 125 m3.
At the facility, contaminated surface waters may be diverted to a pump sump
and balance tank, which channels the surface water to a two-stage aerated
lagoon system. Treated water is then polished in a twin-reed bed system.
Polished surface water is subsequently discharged, with uncontaminated
surface water to the Kill River.
4.1.2. Summary of Monitoring Results
Schedule 2(iii) of the operating IPPC licence requires the company to
monitor the final effluent discharge for a range of parameters.
All data summarised herein, relates to the period January 1st 2009 to
December 31st 2009 inclusive, and has been compiled from Emission
Monitoring Registers (EMRs), as submitted to the Agency on a monthly
basis.
Table 4.1 presents the percentage compliance with the relevant parameter.
The percentage compliance has been calculated using the following formula:
% Compliance = Number of Compliant Samples x 100
Number of Samples 1
-
March 2010 Annual Environmental Report 2009
PDM 20 Final
Table 4.1: Summary of Monitoring Results at Emission Point ‘E’ for January 2009 to December 2009
Parameter Emission Limit
Value (ELV)
Average
Measured
Value 2005
Average
Measured
Value 2006
Average
Measured
Value 2007
Average
Measured
Value 2008
Average
Measured
Value 2009
Required
Monitoring
Frequency
2009
%
Compliance
(2009)
Flow1 2500 m
3/d 61 m
3/d 74.26 m
3/d 60.12 m
3/d 30m
3/day 78 m
3/day Weekly %
Temperature2
25°C - - - - - Continuous -
pH2
6-9 - - - - - Continuous -
COD 100 mg/l 41.08 mg/l 44.47 mg/l 39.5 mg/l 37.3mg/l 33.72 mg/l Weekly 100%
BOD 25 mg/l 3.25 mg/l 2.0 mg/l 2.25 mg/l 2.25mg/l 2 mg/l Quarterly 100%
Suspended Solids 30 mg/l 19.18 mg/l 12.91 mg/l 10.83 mg/l 10.47mg/l 7.59 mg/l Weekly 100%
Phenols 1 mg/l 0.0017 mg/l 0.0430 mg/l 0.095 mg/l
-
March 2010 Annual Environmental Report 2009
PDM 21 Final
Table 4.2: Summary of Mass Emissions*(2003 – 2009
Parameter Mass
Emissions
2003
Mass
Emissions
2004
Mass
Emissions
2005
Mass
Emissions
2006
Mass
Emissions
2007
Mass
Emissions
2008
Mass
Emissions
2009
Flow 25,095 m3 29,960 m
3 22,265 m
3 27,106 m
3 21,943 m
3 21,900 m
3 28,477 m
3
COD 1057.3 kg 965.9 kg 914.7 kg 1205.3 kg 867 kg 817 kg 959 kg
BOD 50.2 kg** 59.9 kg** 72.4 kg** 54.2 kg** 49.4 kg** 49 kg** 57 kg
Suspended
Solids
522.5 kg 477.0 kg 427.0 kg 350.2 kg 237.7 kg 229 kg 215 kg
Phenols 5.5 kg** 12.9 kg**
-
March 2010 Annual Environmental Report 2009
PDM 22 Final
4.1.3. Discussion of Results
Overall, monitoring results for emissions to surface water at Emission Point E
proved compliant with emission limit values (ELVs) as specified in the IPPC
licence, for all parameters except PAH’s. Non-compliances with licence ELVs
were recorded for this particular parameters, during the monitoring period
January to December 2009. Flow increased from 2008 to 2009 due to
increased rainfall in 2009 versus 2008.
There is an ongoing issue of detection of PAH’s in the effluent discharge at
Point E, PDM only manage to succeed in obtaining the ELV limit of
0.0002mg/l approximately 4 months of the year. This seems to be the case
from data dating back to 1999. Over the years it has been noticed that during
a long dry spell the PAH limit may be achieved. PDM are in the process of
obtaining a technical amendment to their IPPC Licence at present and will be
seeking a number of changes in respect of effluent conditions within that
licence.
As the average daily volume discharged in 2009 was only 78 m3/d (less than
1/30th of the allowable discharge) the overall quantity of PAH discharged
was only fraction of the maximum allowed in the IPPC licence.
This issue will be re-examined as part of the proposed technical amendment
proposals which will be submitted to the EPA 2010.
4.1.4. Toxicity Monitoring
In accordance with requirements of the IPPC licence, in particular condition
6.6 requires the company to determine the acute toxicity of the undiluted final
effluent to at least four aquatic species from different trophic levels.
PDM carried out toxicity testing on samples of the treated effluent discharged
from the on-site treatment plant (emission point ‘E’) in the second half of
2004, the result of which was submitted in the 2005 AER. These results
indicated that the treated effluent is of low toxicity to the receiving waters.
PDM are required to undertake this toxicity testing only once as per IPPC
requirements, hence toxicity testing was not required in 2009.
4.1.5. Conclusion
The treatment plant has proved very effective in reducing the concentration
of a wide range of contaminants. For PAH also it gives a very large reduction
but not always to the required level of 0.0002 mg/l.
The PAH issue and the appropriateness of its standard is currently being
reassessed and a request for a change in this ELV will be submitted to the
EPA as part of a technical amendment request to be submitted in 2010.
-
March 2010 Annual Environmental Report 2009
PDM 23 Final
4.2. Emissions to Surface Water
4.2.1. Introduction
In accordance with Condition 9.1 of the operating IPPC licence, monitoring of
surface water discharges is conducted at monitoring point locations A, B, and
D (Monitoring at Point G was suspended in February 2003). These
emissions points are detailed in the company’s IPPC licence application.
Monitoring of surface water discharge from the site at the above 3 locations
is conducted to ensure that site operations do not adversely impact on
surface waters. Furthermore, the company is required to conduct a daily
visual inspection of the surface water emission points. Following
correspondence with the EPA (14/2/03), monitoring for PAHs’s at A, B, D:
was reduced to quarterly. Monitoring at Point G was suspended, as there is
no flow at this point.
4.2.2. Summary of Surface Water Emission Monitoring Results
All results of surface water discharge monitoring are detailed in Table 4.3
Table 4.3 - Summary of Surface Water Monitoring Results
Parameter Average
Measured Value
(A)
Average
Measured Value
(B)
Average
Measured Value
(D)
PAH (total) 2009 0.00184 mg/l 0.00128 mg/l 0.00644 mg/l
PAH (total) 2008 0.000635 mg/l 0.000205 mg/l 0.0007 mg/l
PAH (total) 2007 0.00001 mg/l 0.000377 mg/l 0.000147 mg/l
PAH (total) 2006 0.0001375 mg/l 0.0002675 mg/l 0.0000584 mg/l
PAH (total) 2005 0.00053 mg/l 0.00021 mg/l 0.00010 mg/l
Chromium (total) 2009 -
-
March 2010 Annual Environmental Report 2009
PDM 24 Final
4.2.3. Discussion of Results
The figures in Table 4.3 show a higher level of PAH compared to 2008.
There is no obvious reason why this should be so and the company plans to
continue to monitor the drains to see if any trend emerges.
The results for Chromium for 2009 appear to be a magnitude of value higher
than in 2008 and previous years, however it is noted that the limit of
detection on the Bord na Mona monitoring report was also an order of
magnitude greater. The results obtained were below the limit of detection so
the values quoted for chromium above are considered an overestimate. The
results for arsenic are slightly higher than in 2008 and previous years.
4.3. The EPA Monitoring
The EPA visited the site on 17th February 2009 and took effluent samples
from the emission point E and tested the samples for COD and Suspended
Solids (SS). The results were compliant with the ELVs set in the site’s IPPC
license and are presented in Table 4.4.
On 29th June 2009, the EPA tested samples from emission point B, D and E
for PAHs. The EPA also tested samples from Emission points A, B and D
collected on the 29th June 2009 for various VOCS. The results were below
the limit of detection for all VOC’s.
On 12th October 2009, the EPA also collected a sample in the emission point
E and the test results are presented in Table 4.4. All results collected on that
date were compliant with the ELVs set in the site’s IPPC licence.
Table 4.4. – Results of EPA Monitoring
Parameter ELV (Emission point E)
Emission point E
17th
February 2009
Emission point E
29th June
2009
Emission point E
12th
October 2009
SW Emission Point D
29th June
2009
SW Emission Point B
29th June
2009
pH 6-9 7.6
BOD 25 mg/l 2 mg/l
COD 100 mg/l 30 mg/l 33 mg/l
SS 30 mg/l 11 mg/l 16 mg/l
Chromium 0.5 mg/l
0.007
mg/l
Arsenic 0.5 mg/l
0.015
mg/l
PAHs
0.0002 mg/ l
0.001025 mg/l
0.001409 mg/l
0.001474 mg/l
-
March 2010 Annual Environmental Report 2009
PDM 25 Final
4.4. Additional Monitoring
The EPA obtained additional samples of treated effluent emissions at
emission point E, surface water at point B and D, and from groundwater well
MW8 on 6th October 2009. The samples were tested for ammonia,
hexavalent chromium, and manganese and the results are shown in Table
4.5. The results are compliant with the Surface Waters Regulations (1989).
Table 4.5. – Results of EPA Monitoring on 6th October 2009
Parameter Regulatory limit
Emission point E
Surface water sampling point B
Surface water sampling point D
Groundwater well MW8
Ammonia 0.2* mg/l
-
March 2010 Annual Environmental Report 2009
PDM 26 Final
and results obtained reinforce this. This well is going to be used as the
abstraction well for the hydraulic containment system.
4.5.3. Discussion of Groundwater Quality
The following points summarise the current status of groundwater related
issues at the site:
• The EPA requested a programme of management of contamination on
site in September 2005 in line with a URS report on sediment and
groundwater report dated April 2001. URS indicated that access to the
ESB land to assess off-site migration of contamination, if any, is a very
important factor in this work. However, access to the E.S.B land was
not granted in 2005. Meanwhile, the EPA requested PDM to start
assessing on-site issues in more detail. A proposal was submitted to
the EPA for their approval proposing to assess current groundwater
quality in the vicinity of the timber treatment area, and also to survey the
condition of groundwater monitoring wells close to the treatment area.
The proposal submitted to the EPA on October 17th 2005 was agreed
by the Agency subject to two conditions being addressed:
1. An assessment of the adequacy of monitoring wells on-site for
representative groundwater monitoring and proposals for changes
where required should be carried out.
2. PDM should take the necessary measures to obtain information by
way of investigation if it is not possible to obtain information from
the ESB. The schedule of works required in No 1 above should
adequately address off –site migration of contamination.
• URS carried out the scope of work outlined in the October 2005 proposal.
The key conclusions from that report (December 2005) were:
o There is an area of impacted groundwater in the vicinity of the
production area at the site. There are indications of free-phase
creosote being present in the bedrock in the vicinity of wells MW05
and MW07.
o Although measures to prevent further losses of creosote to ground
have been installed in treated timber storage areas since 2000, it is
likely that groundwater contaminated with creosote continues to
migrate off-site towards the west.
o It was recommended to put in place a hydraulic containment system
that can be used to minimise on-going off-site migration of PAH
contaminated groundwater in the vicinity of the production area. It
would not be designed to recover contaminated groundwater that has
already migrated beyond the down-gradient site boundary. The final
design of this system is currently underway and it is expected to be
installed in 2009 (see details further down).
• The above report submitted to the EPA on 21st December 2005 was
agreed by the Agency subject to a number of conditions being addressed:
-
March 2010 Annual Environmental Report 2009
PDM 27 Final
1. The recommendations detailed throughout the report are
implemented;
2. MW07 is replaced for groundwater quality monitoring purposes;
3. The feasibility of recovery of free phase creosote/sources of
contamination is addressed and reported to the Agency;
4. Comment on whether the contamination on-site has been fully
characterised;
5. A conceptual site model is developed for the site;
6. Comment on whether the works carried out on-site since 2000 are
sufficient to prevent any further contamination of soil and
groundwater providing recommendations where required;
7. Comment on whether additional monitoring wells are required to
ensure that an adequate monitoring well network is in place providing
recommendations where required;
8. Comment on whether the monitoring programme is adequate
providing recommendations where required; and,
9. Works should also include:
o Addressing the drainage ditch which showed evidence of
contamination;
o Addressing the plume of contamination that has migrated off-site;
o Carry out a risk assessment to address all contamination arising
from the site;
o Assess the impact of the contamination on-site on the effluent
discharge providing proposals for measures necessary to ensure
that effluent discharges are below emission limit values set out in
Schedule 1(i) Treated Effluent Emissions of the IPPC licence;
and,
o A database of all monitoring results is established to contain all
previous and future results.
• In response to these conditions, in January 2006 PDM submitted the
following proposed schedule of works to be undertaken at the PDM
facility.
o Task 1: Review of Potential Sources; Development of Conceptual
Site Model
- This involves a detailed inspection of the site to be undertaken
by URS to determine whether all potential contamination sources
on the site have been identified and their potential impacts
-
March 2010 Annual Environmental Report 2009
PDM 28 Final
assessed. This will include a review of the results of previous
investigations carried out on the site, and discussions with PDM
site management with regard to both current and past operations
at the site. URS will be asked to recommend infrastructure
improvements in any areas where a risk of further contamination
is identified.
- Following on from the above source assessment, the conceptual
site model will be reviewed and updated. This will consider
potential source-pathway-receptor linkages and will highlight any
linkages that require further assessment.
- This report entitled “Review of Remedial Strategy 2006” was
completed and submitted to the EPA in December 2006 (further
details below).
o Task 2: Groundwater Monitoring Network & Monitoring Programme
- In conjunction with Task 1, URS reviewed the adequacy of the
groundwater monitoring network at the site, and the adequacy of
the current groundwater monitoring programme.
o Task 3: Remediation of Drainage Ditch
- The drainage ditch in question lies close to the northern site
boundary in the vicinity of MW5.
- Contaminated sediment have been fully removed from this drain
in stages over the past three years (i.e. since 2005). The
contaminated sediments removed have been disposed of off-site
by Cara Environmental Services. The contaminated sediments
are underlain by low permeability clay soils, and as such, the
potential for these sediments to contaminate the surrounding
environment is very low.
- PDM intend to plant the ditch with Reeds during 2009.
o Task 4: Implementation of a Groundwater Remedial Strategy
- Details of this are provided below.
o Task 5: Risk Assessment of Off-Site Migration of Contamination
- URS will undertake a risk assessment of any contamination that
appears to have migrated off-site.
• A request for information was sent by the EPA in January 2006 to an
Environmental Specialist at the ESB. In this letter the EPA requested
that the ESB provide the Agency with any reports, monitoring results
and hydrological information from their site which is located down
gradient of the PDM facility at Oldmilltown, Kill, Co. Kildare. In order to
assist PDM with establishing the nature and extent of contamination
migration off-site. This information was sent via email to URS Ireland
from the ESB in March 2006.
-
March 2010 Annual Environmental Report 2009
PDM 29 Final
• During 2006, URS carried out the scope of works submitted to the EPA
in January 2006. The key conclusions from this are outlined in the
report “Review of Remedial Strategy 2006”. These are outlined below:
- Cresote storage tank fill points – consideration should be given
to providing improved secondary containment at the creosote
storage tank filling points, sufficient to contain major loss of
creosote (i.e. failure of a hose during tank filling).
- Bunding under treatment vessels – hydraulic testing of the
treatment plant bunds should be performed to confirm their
integrity. This was carried in August 2007 and the integrity of the
bunds was confirmed.
- During the site inspection, some of the drains in the treated
timber storage areas were blocked. It was recommended that
these should be inspected regularly and cleaned as required.
- The groundwater monitoring network and the current monitoring
programme are considered adequate; however as MW7 has
been decommissioned, it is recommended that its replacement
well, MW8, be monitored on a quarterly basis in its place. MW9
and MW10 should be added to the list of wells at the site that are
monitored annually.
- Given the use of Celcure AC 500 at the site, it is recommended
that the samples from wells in the treatment area be analysed on
an annual basis for a key indicator of this product (e.g. Copper)
as well as speciated PAHs.
- With regard to the three newly-installed monitoring wells (MW8,
MW9 and MW10), analysis of samples from these three wells
indicates that only MW8 needs to be converted to a remedial
abstraction well.
• Groundwater Sampling began at MW8, MW9 and MW10 in Q2, 2007.
• In December 2007, PDM submitted an updated proposal to the EPA for
the installation of the hydraulic containment system to reduce the
potential for off-site migration of PAH contaminated groundwater in the
vicinity of MW8. The EPA have proposed a trial period of 1-month (EPA
Letter, dated 01/02/2008) and completion of a report on the findings.
The report should include, as per the EPA letter, a detailed remediation
strategy for the existing contamination and a detailed risk assessment
on the potential impacts of a full-scale remediation strategy. The letter
also reminded PDM of an EPA letter 13/01/06 requiring PDM to carry
out a risk assessment addressing all contamination arising from the site.
• As part of this Hydraulic Containment strategy, two additional
groundwater monitoring wells (MW11 and MW12) were installed by URS
in April 2008. Hydraulic testing of MW12 was carried out in June 2008,
which found MW12 to be a suitable abstraction well for the hydraulic
containment system.
-
March 2010 Annual Environmental Report 2009
PDM 30 Final
• In 2009 PDM has requested URS to undertake the final design of the
hydraulic containment system. This was submitted and agreed with the
EPA in 2009. It is intended that the containment system will become
operational in 2010.
• It is intended to complete the groundwater containment system and
carry out a Quantitative Risk Assessment (QRA) during 2010. The QRA
will assess the risk to sensitive receptors of any contamination which
may have migrated off-site.
-
March 2010 Annual Environmental Report 2009
PDM 31 Final
Table 4.5: Groundwater monitoring results – Wells MW1 to MW 12
Parameter - PAH
(total) (mg/l) MW 1 MW 2 MW 3 MW 4 MW 5 MW 7 MW 8 MW 9 MW 10 MW 11 MW 12
January 2009 0.0002 0.0003 0.0002 0.0003 4.6 ** 0.83 0.0099 0.0005 0.011 3.12
January 2008
-
March 2010 Annual Environmental Report 2009
PDM 32 Final
4.6. Testing and Inspection of Underground Tanks & Pipelines
and Bund Integrity
4.6.1. Bund Testing
The site holds an IPPC licence (Licence No. PO325-01) and under this
licence, PDM is required to perform integrity testing of all bunded structures
on the site. The licence requires that:
“The integrity and water tightness of all the bunding structures and their
resistance to penetration by water or other materials stored therein shall be
tested and demonstrated by the licensee to the satisfaction of the Agency”
In January 2008, Punch & Co. were contracted to conduct hydrostatic bund
testing on 3 bunds at the site. One of these, the waste creosote bund, failed
the test (i.e. a significant drop in water level). This was repaired in April 2008
and has been retested. The results showed no significant drop in water in
any of the bunds, therefore the site is compliant with its IPPC Licence
requirements regarding integrity testing of bunds.
During the August 2008 plant shutdown, the main separator at the site, the
plant no. 4 bund and the drip trays for the creosote fill points were all tested
for integrity. All were found to be compliant with IPPC Licence requirements.
4.6.2. Pipeline and Underground Tank Testing and Inspection
In accordance with Condition 9.4.9 of the operating licence, the company is
required to implement a programme to ensure the integrity testing and
inspection of underground tanks and pipelines is carried out once every three
years.
The previous assessment took place in August 2005 and therefore testing of
all pipeline and underground tanks was required during 2008. The
assessment programme was completed in August 2008 by technical experts
Meehan Underground Survey and Technology Ltd. (*M.U.S.T). The
assessment report was submitted to the EPA in Q4 2008.
-
March 2010 Annual Environmental Report 2009
PDM 33 Final
5. WASTE
5.1. Introduction
Waste generated at the site is primarily non-hazardous in nature, comprising
typically of wood-chips and general waste. Quantities arising on-site for the
period January to December 2009 are presented in Tables 5.1 to 5.4.
Wood-chips generated by the site activities are re-used by local equestrian
groups for bedding etc. while treated wood waste is also used by local
equestrian groups mainly for show-jumping.
Other waste disposed of during 2009:
• Non-hazardous: 22 truck tyres and 2 earth movers, removed by
Crossmore Transport; and
• Hazardous waste: 9 No. IBCs and 28 No. 200 litre drums of waste
creosote, fluorescent tubes, and 1,500 litres of waste oil, removed by
Indaver.
5.2. Summary of Waste Statistics
A summary of wastes generated on-site for the period January 2009 to
December 2009 inclusive is summarised in Tables 5.1 to 5.4. Licence and
permit details are presented in Table 5.5.
-
March 2010 Annual Environmental Report 2009
PDM 34 Final
Table 5.1. Annual Hazardous Waste
Waste Management Option
On-Site Recovery Off-Site Recovery On-Site Disposal Off-Site Disposal Year Waste Material
EWC Code Source t On-Site Treatment
Method t Method t Method t Method t
2009 Waste Oil 130206 Maintenance 1.5 None None None None D10 1.5
2009 Fluorescent Tubes
200121 Buildings, offices, etc.
0.1 None None None None D10 0.1
2009 Creosote 07 04 11* Production 6.511 None None None None D 10 6.511
Table 5.2 Hazardous Waste sent off-site for Recovery/Disposal
1. Broker T Description and
Nature of Waste
2. Haulage Contractor
Recovery
Contractor
Disposal
Contractor
0.1 Fluorescent Tubes Indaver - Indaver
1.5 Waste Oil Indaver - Indaver
6.511 Waste Creosote
1. Cedar
2. J P Ryan
- Cedar Resource
Management
-
March 2010 Annual Environmental Report 2009
PDM 35 Final
Table 5.3 Annual Non-Hazardous Waste
Waste Management Option
On-Site Recovery Off-Site Recovery On-Site Disposal Off-Site Disposal Year Waste
Material
EWC
Code
Source T On-Site
Treatment
Method t Method t Method t Method t
2009 End of
Tyres
160103 Vehicles used
on-site
1 None None R4 1 None None
2009 Metal 200140 Maintenance 8.81 None None R4 8.81 None None
2009 Mixed
Municipal
Waste
200301 Canteen,
Offices, etc.
18.35 None None None None D1 6.14
Table 5.4 Non-Hazardous Waste sent off-site for Recovery/Disposal
1. Broker Reporting Period Waste Material EWC
Code
T Description and
Nature of Waste
2. Haulage Contractor
Recovery
Contractor
Disposal Contractor
January to
December 2009 End of Life Tyres 160103 1
End of life vehicle
tyres Crossmore Transport Ltd - -
January to
December 2009 General waste 200301 6.14
Mixed Municipal
Waste derived from
canteen. Office.
Thortons (Jan. to Dec.) - Kyletalesha Landfill
January to
December 2009 Metal 200140 8.81
Metal waste derived
from Maintenance Thortons (Jan. to Dec.) Thorntons Kileen Road
-
March 2010 Annual Environmental Report 2009
PDM 36 Final
Table 5.5 Waste Permit Details
INDAVER AES Waste Rehab
Recycling Returnbatt
Thorntons
Recycling Centre
Ltd
Cedar Greenogue
Waste Facility
Crossmore
Transport Limited
Waste Collection Permit
WCP/KE/20C/05c WCP/KE/051C/05b - WCP/KE/045C/06b WCP/KE/042C/05b WCP/KE/044C/02b WCP/KE/013C/02b
Waste Permit - - WPR 033 - - - WP 02/2002
Waste Licence 36-2 194-1 - 97/2002 210-1 185-1 -
Kommunekemi a/s, Denmark
Waste License Permit HCE/DS/LSA 131-070-0002
Kyletalesha Landfill
EPA License 26-2
-
March 2010 Annual Environmental Report 2009
PDM 37 Final
6. NOISE
6.1. Introduction
On the 14th February 2003 PDM received notification from the EPA that the
requirement to carry out annual noise monitoring surveys has been
suspended, due to the fact that there is sufficient noise monitoring
information available and the site received no noise complaints.
-
March 2010 Annual Environmental Report 2009
PDM 38 Final
Figure 7.1 Electricity Usage (2002 - 2009)
507.64
535.52
545.53
635.09661.92733.57
681.24
500
550
600
650
700
750
January to
December
'03
January to
December
'05
January to
December
'07
January to
December
'09
MW
H
Electricity Usage
7. RESOURCE CONSUMPTION
7.1. Introduction
The utilisation of energy at PDM consists of diesel, wood-chips and electricity
usage. The primary consumer of energy on-site is the process equipment,
kilns and on-site boiler.
Other resource consumption includes groundwater extracted from an on-site
well, which is used for all site water needs. Light fuel oil is also used
periodically as a back-up fuel for the boilers.
The period considered for this AER is that from January 2009 to December
2009.
7.2. Electricity Usage
Electricity usage at the facility is demonstrated in Figure 7.1. The site used
507.64 MWh of electricity during 2009. Overall electricity usage has
decreased slightly comparing to the previous years figures.
7.3. Diesel Usage
The usage of diesel at the facility for the 12-month reporting period is
presented in Figure 7.2. Diesel usage for 2009 has increased since 2008.
The reason for this increase was as a result in a change in the timber
delivery system. In 2009, PDM conducted an economic assessment of timber
delivery and as a result are now collecting all timber purchased from
suppliers within Ireland and transporting this from the suppliers to PDM
resulting in a higher diesel usage in PDM vehicles. However it should be
noted that this means that diesel usage at their supplier sites would have
decreased as they no longer deliver to PDM.
-
March 2010 Annual Environmental Report 2009
PDM 39 Final
Figure 7.2 Diesel Usage (2004 - 2009)
100,601105,263
91,626 91,270
123,900
90,760
70,000
80,000
90,000
100,000
110,000
120,000
130,000
January -
December
2004
January -
December
2005
January -
December
2006
January -
December
2007
January -
December
2008
January -
December
2009
Lit
res
Diesel Usgae
7.4. Woodchip Usage
Quantities of wood chip utilised in the on-site boiler, for the period January to
December 2009 detailed in Figure 7.3. Wood Chip usage during 2009 has
increased slightly over the same as the previous year.
Figure 7.3 Woodchip Usage (2004 - 2009)
1007800799.06
578.45578.45
578.45
0
200
400
600
800
1000
1200
January
-
Decem
ber
2004
January
-
Decem
ber
2005
January
-
Decem
ber
2006
January
-
Decem
ber
2007
January
-
Decem
ber
2008
January
-
Decem
ber
2009
To
nn
es
-
March 2010 Annual Environmental Report 2009
PDM 40 Final
7.5. Light Fuel Oil Consumption
The backup fuel for the boiler is light fuel oil, therefore use is dependent on
boiler operation and typically intermittent and unpredictable. The light fuel oil
usage for the AER 2009 monitoring period at the PDM facility is presented in
Figure 7.4. This includes for light fuel oil usage in the on-site vehicles. There
has been a significant decrease since 2008.
Figure 7.4 Light Fuel Usage (2004 - 2009)
205,005
101,055
85,195
189,707
101,306
57516
0
50000
100000
150000
200000
250000
January -
December
2009
January -
December
2008
January -
December
2007
January -
December
2006
January -
December
2005
January -
December
2004
Lit
res
7.6. Water Consumption
Water consumption at PDM is divided into two main groups:
• Utilities
• Domestic, production and washing processes
The on-site groundwater well supplies the PDM site. This includes the
provision of domestic water for the canteen and office and plus water for the
boiler and other miscellaneous uses including vehicle washing. Water
abstracted from the well has been metered since June 2002, and for the
period January to December 2009 a total of 368m3 was metered out of the
ground water well for the canteen.
7.7. Discussion
In order to get an overview on resource consumption and to define patterns
in resource use, Efficiency Indices may be considered. It is noted that such
indices can be calculated for differing time periods and yet compared with
one another since the measurement is based on production over that period.
An example for electricity is as follows:
Efficiency Index = Electricity Consumption (GJ)/tonnes raw materials used.
-
March 2010 Annual Environmental Report 2009
PDM 41 Final
For PDM, a more appropriate measure of production is the total volume of
wood treated over the period of time in question. For the 12 month period
January 2009 to December 2009, the quantity of product produced was
32,591 m3.
An example calculation is as follows (for electricity January to December
2009):
Electricity consumed: 1,825.20 GJ (MWh x 3.6)
Product produced: 46,350 m3
Therefore, Efficiency Index = 1,825.20/46,350 = 0.039 GJ/m3
Table 7.1 - Summary Indices of Resource Efficiency.
Index 2009 2008 2007 2006 2005 2004 2003
Electricity
usage
(GJ/m3)
0.039 0.0459 0.0467 0.0504 0.0492 0.0539 0.0535
Light fuel oil
usage (L/m3)
1.24 2.41 4.51 1.88 2.09 4.19 3.50
Diesel usage
(L/m3)
2.67 2.16 2.17 2.02 2.17 2.05 2.40
Woodchip
usage (t/m3)
0.021 0.020 0.019 0.0127 0.0119 0.0118 0.0275
Production volume in 2009 (46,350m3) was slightly increased on the previous
two years.
The Electricity Index has gone down indicating a more efficient use of this
energy source over 2008. The Light fuel oil and woodchip index have also
decreased slightly and increased slightly respectively over this two year
period. The Diesel index increased over 2008. In 2008, the majority of timber
supplied to PDM was delivered by the supplier and hence there was no
diesel used by PDM in the delivery process. In 2009, PDM conducted an
economic assessment of timber delivery and as a result are now collecting all
timber purchased from suppliers within Ireland and transporting this from the
suppliers to PDM resulting in a higher diesel usage in PDM vehicles.
However it should be noted that this means that diesel usage at their supplier
sites would have decreased as they no longer deliver to PDM.
-
March 2010 Annual Environmental Report 2009
PDM 42 Final
8. ENVIRONMENTAL INCIDENTS AND COMPLAINTS
8.1. Complaints
For the monitoring period January 1st to December 31
st, 2009 there were no
environmental complaints received by the company.
8.2. Incidents
There were no reported spills at the facility, or any other incidents of
environmental concern for the monitoring period of this AER.
9. REVIEW OF RESIDUALS MANAGEMENT PLAN
PDM originally submitted an RMP to the Agency in August 2000. Since 2000
costs have been updated on an annual basis to take account for inflation.
During 2008, the RMP was amended at the request of the EPA. The revised
RMP was requested by the EPA in a letter to PDM dated the 28th May 2008.
The update was concerned the revision of the Section entitled “Restoration
and Aftercare Management Plan – Management of any Potential Long Term
Residual Soil and Groundwater Contamination”.
The RMP and the associated revisions were prepared by external
consultants, URS Ireland Ltd., and employed the most Recent EPA
Guidance Document entitled “Guidance on Environmental Liabilities Risk
Assessment, Residuals Management Plans and Financial Provision,
copyright 2006”.
The RMP was reviewed in March 2009 by URS. Revisions proposed to the
plan in 2009 relate to the groundwater containment and remediation
programme and costs associated with decommissioning to more accurately
reflect current market conditions in 2009. The cost table below is Table 9.1 of
the RMP report dated 24th March 2009, and includes all costs identified
during the analysis of the Short Term and Long Term Programmes of the
RMP. No other changes are proposed to the RMP.
Table 9.1 Summary of RMP Costs
ITEM DESCRIPTION COST (£)
STP 1
STP 2
STP 3
STP4
LTP1
LTP 2
LTP.3
STP Residuals disposal (See Table 7.5)
Project Management STP
Specialised contractors
Decommissioning of the WWTP
SUB TOTAL STP (approximate)
Groundwater containment and remediation (*)
Soil investigation
Soil remediation (**)
Sediment assessment and removal
112,264
17,157
27,772
16,813
173,966
165,000
32,595
200,000
20,000
-
March 2010 Annual Environmental Report 2009
PDM 43 Final
LTP.4 Reed Bed decommissioning
SUB TOTAL LTP (approximate)
3,337
420,932
RMP TOTAL (approximate) 594,898
(*) – A period of system operation of 15 years has currently been allowed for. The hydraulic containment approach is yet to be discussed with the EPA and is subject to their approval. (**) –Should the on-site remediation of soil prove not to be successful, the estimated cost for off-site soil disposal and site re-instatement is €470,000.
In conclusion, in the unlikely event of site closure, it has been estimated that
approximately € 594,000 would be required to bring the site to an
environmentally safe condition.
-
March 2010 Annual Environmental Report 2009
PDM 44 Final
10. ENVIRONMENTAL LIABILITIES INSURANCE COVER
As part of the requirements of IPPC Licence PDM Ltd. are required by the
EPA to undertake an Environmental Liability Risk Assessment (ELRA).
The ELRA was prepared by external consultants, URS Ireland Ltd., and
employed the most Recent EPA Guidance Document entitled “Guidance on
Environmental Liabilities Risk Assessment, Residuals Management Plans
and Financial Provision, copyright 2006”.
PDM originally submitted an ELRA to the Agency in September 2000. This
has been updated as required as part of the site Annual Environmental
Report (AER) submitted to the Agency annually. In 2007, a revised ELRA
was prepared for the site in accordance with the most recent guidelines
published by the Agency. The revised ELRA was requested by the EPA
during an audit in November 2006.
URS assessed a number of identified environmental risks in terms of
probability of occurrence and severity in accordance with the EPA Guidance
Document. A worst-case financial scenario of approximately €1,685,000 was
determined using the guidelines in the EPA Guidance Document.
URS undertook a review of the ELRA in March 2009. Revisions proposed to
the assessment in 2009 relate to the costs determined in the previous
assessment. This is proposed in order to more accurately reflect current
market conditions in 2009. It is considered that a revised worst-case financial
scenario of approximately €1,432,250 is appropriate. No other changes are
proposed to the ELRA.
Financial provisions at PDM Ltd are summarised in Table 10.1 below.
Table 10.1 – Assessment of PDM Financial Provision
Risk Type Existing PDM
Financial Provision
Comment
Immediate, sudden and unforeseen discharge consequent upon an accident.
Current Insurance policies maintained by the site.
Excess of €450,000 for each and every claim.
Gradual unforeseen discharge consequent upon failure of control systems.
Funding to be provided by in-house funds or funds available from Parent Company Saint-Gobain.
These are excluded from current insurance cover at the site.
Closure Restoration and Aftercare Liabilities
Parent Company Guarantee.
See separate Residuals Management Plan prepared specifically for this.
Based on the assessment of the current financial provisions in place, it is
considered that PDM have sufficient insurance cover to provide for any
liabilities resulting from immediate, sudden and unforeseen discharge
-
March 2010 Annual Environmental Report 2009
PDM 45 Final
consequent upon an accident. Any liabilities resulting from gradual
unforeseen discharge consequent upon failure of control systems, if not
covered via the existing insurance policies fro the site will be funded
internally via funds released from both PDM or their parent company Saint-
Gobain.
-
Appendix A - ISO 14001 Certificate
-
Appendix B - Completed PRTR
Worksheets
-
Sheet : Facility ID Activities AER Returns Worksheet 30/3/2010 14:36
| PRTR# : P0325 | Facility Name : P.D.M. | Filename : P0325_2009.xls | Return Year :
2009 |
Version 1.1.10
REFERENCE YEAR 2009
1. FACILITY IDENTIFICATION
Parent Company Name P.D.M.
Facility Name P.D.M.
PRTR Identification Number P0325
Licence Number P0325-01
Waste or IPPC Classes of Activity
No. class_name
8.3
The treatment or protection of wood, involving the use of
preservatives, with a capacity exceeding 10 tonnes of wood per day.
Address 1 Oldmilltown
Address 2 Kill
Address 3 Co. Kildare
Address 4
Country Ireland
Coordinates of Location -6.53406 53.2456
River Basin District IEEA
NACE Code 1610
Main Economic Activity Sawmilling and planing of wood
AER Returns Contact Name Catherine OSullivan
AER Returns Contact Email Address [email protected]
AER Returns Contact Position Assistant to M.D.Env & Quality Mngr
AER Returns Contact Telephone Number 045-877165
AER Returns Contact Mobile Phone Number
AER Returns Contact Fax Number 045- 877467
Production Volume 46350.0
Production Volume Units cubic metres
Number of Installations 1
Number of Operating Hours in Year 1700
Number of Employees 31
User Feedback/Comments
Web Address
2. PRTR CLASS ACTIVITIES
Activity Number Activity Name
50.1 General
3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)
Is it applicable?
Have you been granted an exemption ?
If applicable which activity class applies (as per
Schedule 2 of the regulations) ?
Is the reduction scheme compliance route being
used ?
AER Returns Worksheet
| PRTR# : P0325 | Facility Name : P.D.M. | Filename : P0325_2009.xls | Return Year : 2009 | Page 1 of 1
-
Sheet : Releases to Air AER Returns Worksheet 30/3/2010 14:36
4.1 RELEASES TO AIR | PRTR# : P0325 | Facility Name : P.D.M. | Filename : P0325_2009.xls | Return Year : 2009 | 30/03/2010 14:36
8 8 16 18 26 26 6 6 6
SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS
QUANTITY
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
0.0 0.0 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
SECTION B : REMAINING PRTR POLLUTANTS
QUANTITY
Woodchip Burner
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
02 Carbon monoxide (CO) M CRM iso9096 289.0 289.0 0.0 0.0
08 Nitrogen oxides (NOx/NO2) M CRM iso9096 323.0 323.0 0.0 0.0
11 Sulphur oxides (SOx/SO2) M CRM iso9096 51.0 51.0 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)
QUANTITY
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
0.0 0.0 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
Additional Data Requested from Landfill operators
Landfill: P.D.M.
Please enter summary data on the
quantities of methane flared and / or utilised
additional_pollutant_no T (Total) kg/Year M/C/E Method Code
Designation or
Description
Facility Total Capacity m3
per hourTotal estimated methane generation (as per
site model) 0.0 N/A
Methane flared 0.0 0.0 (Total Flaring Capacity)
Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)
Net methane emission (as reported in Section
A above) 0.0 N/A
POLLUTANT METHOD
Method Used
For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared
or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the
environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:
Method Used
Method Used
RELEASES TO AIR
POLLUTANT METHOD
Method Used
POLLUTANT
RELEASES TO AIR
RELEASES TO AIR
METHOD
| PRTR# : P0325 | Facility Name : P.D.M. | Filename : P0325_2009.xls | Return Year : 2009 | Page 1 of 1
-
Sheet : Releases to Waters AER Returns Worksheet 30/3/2010 14:37
4.2 RELEASES TO WATERS | PRTR# : P0325 | Facility Name : P.D.M. | Filename : P0325_2009.xls | Return Year : 2009 | 30/03/2010 14:37
8 8 16 18 26 28 6 6 6 9 6 7
SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility
QUANTITY
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
0.0 0.0 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
SECTION B : REMAINING PRTR POLLUTANTS
QUANTITY
A B D E
No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 Emission Point 4
T (Total)
KG/Year
A
(Accidenta
l)
KG/Year
F
(Fugitive)
KG/Year
17 Arsenic and compounds (as As) M PER AA/ICP 0.00042 0.1277 0.0189 0.23 0.37702 0.0 0.0
19 Chromium and compounds (as Cr) M PER AA/ICP 0.0 0.426 0.0946 0.06 0.5806 0.0 0.0
72 Polycyclic aromatic hydrocarbons (PAHs) M PER AA/ICP 0.0319 0.01817 0.0203 0.0309 0.10127 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)
QUANTITY
E
Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 T (Total) KG/Year
A (Accidental)
KG/Year
F
(Fugitive)
KG/Year
303 BOD M PER AA/ICP 57.0 0.0 57.0 0.0 0.0
306 COD M PER AA/ICP 959.0 0.0 959.0 0.0 0.0
240 Suspended Solids M PER AA/ICP 215.0 0.0 215.0 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
Method Used
POLLUTANT
Method Used
POLLUTANT
POLLUTANT
RELEASES TO WATERS
Method Used
RELEASES TO WATERS
RELEASES TO WATERS
| PRTR# : P0325 | Facility Name : P.D.M. | Filename : P0325_2009.xls | Return Year : 2009 | Page 1 of 1
-
Sheet : Treatment Transfers of Waste AER Returns Worksheet 30/3/2010 14:37
5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0325 | Facility Name : P.D.M. | Filename : P0325_2009.xls | Return Year : 2009 | 30/03/2010 14:37
5 9 9
Quantity
(Tonnes per
Year)
Haz Waste : Name and
Licence/Permit No of Next
Destination Facility Non
Haz Waste: Name and
Licence/Permit No of
Recover/Disposer
Haz Waste : Address of Next
Destination Facility
Non Haz Waste: Address of
Recover/Disposer
Name and License / Permit No. and
Address of Final Recoverer /
Disposer (HAZARDOUS WASTE
ONLY)
Actual Address of Final Destination
i.e. Final Recovery / Disposal Site
(HAZARDOUS WASTE ONLY)
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)
To Other Countries 07 04 11 Yes 30.0 Creosote D10 M Weighed Abroad
Cedar Resource
Management,WL185-1
Greenogue Business
Park,Rathcoole,Dublin
,.,Ireland
Kommunekemi a/s
Denmark,Waste License
Permit HCE/DS/LSA 131-070-
0002,.,.,.,.,Denmark .,.,.,.,Denmark
To Other Countries 13 02 06 Yes 1.5 Waste Oil D10 M Weighed Abroad Indaver,WL36-02 .,.,.,.,Ireland
Kommunekemi a/s
Denmark,Waste License
Permit HCE/DS/LSA 131-070-
0002,.,.,.,.,Denmark .,.,.,.,Denmark
Within the Count