re: annual environmental report - avara shannon ... dutch intervention target s

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Verdé Environmental Consultants Ltd is registered in Ireland No. 432891. Registered offices at The Bush, Dunshaughlin, Co. Meath part of the Verdé Environmental Group Directors: P. Van den Bergh B.A., Dip. Mkt. Mgt. (Managing), H.P. Van den Bergh B.E., O. Van den Bergh B.A. (Mod) MSISS, K. Cleary BSc., MSc., FGS, PGeo., EurGeol. Lourda Moloney, Environmental Officer, Avara Shannon Pharmaceutical Services Ltd., Shannon Industrial Estate, Shannon, Co. Clare. 21 st March 2017 Verdé Ref: 50374 RE: Annual Environmental Report - Avara Shannon Pharmaceutical Services Ltd Dear Lourda, Verdé Environmental Consultants (Verdé) are pleased to submit this report providing a review of groundwater quality at the Avara Shannon Pharmaceutical Services Ltd (Avara) facility located in Shannon Industrial Estate, Shannon, Co Clare. In this report, Verdé’s objective is to provide a summary on current groundwater quality at the site in relation to published standards, to make observations of trends in groundwater quality over time and also a discussion of potential impacts to nearby environmental receptors. If you have any queries in relation to the report please do not hesitate to contact us. Yours sincerely, Cyril Tynan Kevin Cleary Senior EHS Consultant Operations Director For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 29-05-2017:03:19:20

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Verdé Environmental Consultants Ltd is registered in Ireland No. 432891. Registered offices at The Bush, Dunshaughlin, Co. Meath – part of the Verdé Environmental Group

Directors: P. Van den Bergh B.A., Dip. Mkt. Mgt. (Managing), H.P. Van den Bergh B.E., O. Van den Bergh B.A. (Mod) MSISS, K. Cleary BSc., MSc., FGS, PGeo., EurGeol.

Lourda Moloney, Environmental Officer, Avara Shannon Pharmaceutical Services Ltd., Shannon Industrial Estate, Shannon, Co. Clare.

21st March 2017 Verdé Ref: 50374

RE: Annual Environmental Report - Avara Shannon Pharmaceutical Services Ltd

Dear Lourda,

Verdé Environmental Consultants (Verdé) are pleased to submit this report providing a review of

groundwater quality at the Avara Shannon Pharmaceutical Services Ltd (Avara) facility located in Shannon

Industrial Estate, Shannon, Co Clare.

In this report, Verdé’s objective is to provide a summary on current groundwater quality at the site in

relation to published standards, to make observations of trends in groundwater quality over time and also a

discussion of potential impacts to nearby environmental receptors.

If you have any queries in relation to the report please do not hesitate to contact us.

Yours sincerely,

Cyril Tynan Kevin Cleary Senior EHS Consultant Operations Director

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1 INTRODUCTION

1.1 Project Contractual Basis & Personnel Involved

Verdé have completed works in accordance with Verdé Proposal Ref: 50374 issued on 7th July 2016. The

Verdé personnel involved in the project included Ronan Doyle, a qualified Environmental Scientist with 20+

years’ experience in environmental monitoring. The report was prepared by Daniel Moore, an environmental

scientist with 7 years’ experience and Cyril Tynan, a Senior EHS Consultant with 17 years’ experience in

environmental monitoring and consultancy. The report was reviewed by Kevin Cleary a Verdé Director with

19 years’ experience in environmental consultancy and management.

The majority of the laboratory analysis was managed by Avara; some parameters were analysed in their in-

house laboratory whilst remaining parameters were analysed by the independent laboratory City Analysts

Ltd, an ISO17025 accredited laboratory in Ireland. Verdé managed the analysis of Total Petroleum

Hydrocarbons-Criteria Working Group (TPH-CWG) through Exova Jones Environmental, an independent

UKAS accredited laboratory.

1.2 Background and Scope

Avara is a medium sized Bulk Pharmaceutical Manufacturing facility, operating under Industrial Emissions

Licence No. P0020-02. Biannual groundwater monitoring is undertaken at the site under the terms of its

licence at seven licenced wells; GS01, G02, GS03, GS04, GS06, GS11, GS12. Historically, additional monitoring

wells were included which are referenced also in this report. Verdé’s objective is to provide a review of

current groundwater quality at the site in relation to published standards, make comparisons with previous

groundwater quality records and also to discuss potential impacts to nearby environmental receptors. In

order to meet these objectives, the following scope was completed:

Biannual groundwater sampling (conducted in May and November 2016);

A review of current groundwater quality at the site;

Comparison of groundwater results with historical data where significant trends are relevant;

A discussion of results with respect to current published standards and relevance to nearby

environmental receptors.

In completion of this report, Verdé have reviewed Laboratory data provided by Avara for 2016 and also bi-

annual data from 2015. This report focuses on the current groundwater status of the site.

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2 SITE DETAILS

2.1 Site Activities

The Avara site (formerly known as UCB Manufacturing Ltd.) began operations in 1982 and has expanded

over the years. The facility currently contains two Bulk Pharmaceutical synthesis facilities known as SP1 and

SP3 in which Synthetic Chemistry is undertaken to produce Bulk Pharmaceutical Product. The site also

contains a Pharmaceutical Finishing Facility. The relevant classes of activity at the site are:

The use of a chemical or biological process for the production of basic pharmaceutical products.

The recovery or disposal of waste in a facility, within the meaning of the Act of 1996, which facility is

connected or associated with another activity specified in this Schedule in respect of which a licence

or revised licence under Part IV is in force or in respect of which a licence under the said Part is or

will be required.

The key contaminants of potential concern (COPC) at the site are organic solvents involved in the

pharmaceutical manufacturing process. Solvent types include primarily alcohols, ketones, acetates and

organic acids. Chlorinated solvents and petroleum based organics are also included in the assessment to

account for small scale or historical activities and fuel storage. The assessment also provides for the

assessment of general parameters from other potential contamination sources such as wastewater or trade

effluent releases to surface water or potential uncontrolled discharges from on –site and off site sources.

2.2 Site Location & Environmental Setting

The site is located on the north-west corner of the Shannon Industrial Estate adjacent to the Shannon

International Airport and approximately 1 kilometre from Shannon town centre (See Figure 1). The site

occupies approximately 6.9 hectares (see Figure 2) and is physically separated from the Airport by an open

culvert used to carry surface water from the immediate catchment area to the Shannon River, which is

located approximately 1.5km from the site. To the east, the site is overlooked by the Westpark development.

Details of the site environmental setting are outlined in Table 2.1. The information on the site location,

hydrology, geology, hydrogeology and ecology of the area has been obtained from records held by the

Geological Survey of Ireland (GSI), Environmental Protection Agency (EPA), Ordnance Survey of Ireland (OSI),

Water Framework Directive (WFD) maps, National Parks and Wildlife Service (NPWS) databases and on-line

resources of Department of Environment, Community and Local Government (www.myplan.ie).

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Table 2.1 – Site Environmental Setting

FEATURE DETAILS & COMMENTS

Topography The site is predominantly flat and the surrounding lands are also regionally flat

Geology Overburden:

The overburden for the region consists of made ground, adjacent lands are underlain by

marine/estuarine silts and clays

Solid Geology:

The underlying bedrock is classified as Dinantian Lower Impure Limestones. Dark muddy

limestones and shales of the Ballysteen Formation

Hydrogeology Regional Classification:

The underlying aquifer is classified as Locally Important; bedrock which is moderately

productive only in Local Zones.

Vulnerability:

The underlying bedrock aquifer is described by the GSI as having Low vulnerability. A review of

historical borehole logs from the wells drilled at the site however suggests that a High to

Extreme vulnerability rating may be more appropriate for the site as bedrock was encountered

between 1.7 and 7.6mBGL. See Figure 3 for a cross section of the site showing areas of high

and extreme vulnerability. .

Well Search:

There are four recorded monitoring wells on the site according to the GSI. From site

documentation reviewed there are 19 monitoring wells on the site, seven of which are used for

EPA licence monitoring. There are 15 other wells recorded as being within 1km of the site with

agricultural and domestic wells to the north west and four wells of unknown use to the south

east within 500m of the site.

One water abstraction well is located on-site and is used for Avara industrial use and not for

drinking water.

Hydrology/Ecology Surface Water Courses/ Abstractions

An open culvert flows north east to south west along the western boundary of the site and into

the Urlan Beg River near the southern boundary of the site. The Urlan Beg River enters the

Shannon Estuary approximately 2.0km south of the site (tidal)

Water Framework Directive status:

The site is within the Tulla-Newmarket on Fergus Groundwater body region with a WFD 2007 -

2017 Good status. The Urlan Beg River and the Clongloghan Stream WFD 2010-2012 status is

unassigned. The Upper Shannon Estuary Transitional Waterbody has a 2010-2012 Moderate

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Status.

Protected Areas:

The nearest protected area is the Lower Shannon Estuary approximately 1.5km south of the

site. (SAC code 002165).

Surface Drainage and Flooding:

According to the OPW (Office of Public Works) there have been no recorded flood events in the

area for at least 1km.

3 SITE WORKS

3.1 Groundwater Monitoring

Verdé completed biannual groundwater monitoring at the site on 31st May and 28th November 2016.

Monitoring was undertaken on seven groundwater monitoring wells; GS01; GS02; GS03; GS04; GS06; GS11

and GS12 (see Figure 2). The seven monitoring wells sampled range from 2.0 to 16.2 meters in depth and are

50mm diameter installations.

All sampling was undertaken as per best practice and sampling guidelines including using dedicated sampling

equipment and purging three well volumes from the monitoring wells prior to sampling. Electrical

conductivity, pH and temperature field measurements were recorded using a calibrated water quality meter.

Samples were provided to Avara for internal and selected outsourcing of chemical analysis. Verdé also

submitted samples to an independent UKAS accredited laboratory for TPH-CWG analysis.

3.2 Well Surveying

A groundwater topographic survey was completed in February 2016 during which monitoring wells on site

were surveyed against an arbitrary site datum to allow calculation of groundwater flow direction at the site.

Groundwater level measurements taken in November 2016 suggest that groundwater flow direction on site

is in a westerly direction towards the culvert/ Urlan Beg River. This agrees with groundwater flow

calculations completed in February 2016 (see Table 3.1 below).

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Table 3.1- Well Survey

Well ID Elevation (mbtoc)

Groundwater Level (mbtoc)

Groundwater Level (mASD )

Groundwater Level (mbtoc)

Groundwater Level (mASD )

Date: 15/02/2016 28/11/2016

GS01 10.41 0.59 9.82 0.94 9.47

GS02 10.715 1.79 8.925 1.81 8.905

GS03 10.85 2 8.85 1.96 8.89

GS04 10.68 1.93 8.75 1.65 9.03

GS06 10.635 1.23 9.405 2.33 8.305

GS11 11.08 2.22 8.86 2.25 8.83

GS12 13.935 2.64 11.295 2.9 11.035

MW-4 10 0.86 9.14 - -

Notes: mASD = meters Above Site Datum, in this case MW-4 is taken as 10m site datum. mbtoc= meters below top of casing

It is noted that during analysis of groundwater levels, a strong influence in groundwater flow direction is

caused by the on-site water abstraction well located near well GS06 (see Figure 4).

A visual inspection of all wells indicates that they are all in good condition. No erroneous groundwater levels

were recorded across the site therefore results and observations indicate that all monitoring wells are

functioning correctly on site.

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4 GROUNDWATER RESULTS

Verdé completed biannual groundwater monitoring at the site in May and November 2016. Monitoring was

undertaken on seven groundwater monitoring wells; GS01; GS02; GS03; GS04; GS06; GS11 and GS12. Results

are discussed below. Comparisons are made with the Groundwater Regulations 2010 Threshold Values (GTV)

where available. In the absence of a GTV, comparison is made with EPA Interim Guideline Values 2003 (EPA

IGV) or Dutch Intervention (I values) or Target (S Values). Groundwater analytical results are presented in

Table 1.

4.1 Field Readings & Observations

An organic odour was evident in well GS04 during both monitoring rounds in 2016. In May, a slight organic

odour was evident in wells GS03 and GS11 and in November, a slight organic odour was observed in well

GS02. The odours identified in these wells were not described as being solvent-based organic odours and are

likely to be naturally-derived from the peaty subsoils found on-site. Otherwise, no physical evidence of

contamination was noted in the remaining wells throughout 2016. Groundwater physicochemical

parameters were within acceptable ranges across the site with key observations as follows:

Groundwater levels were slightly lower in May than November 2016 with average groundwater

levels at 2.09mbtoc in summer and 1.98mbtoc in winter.

pH trends are consistent across the site, ranging between pH 6.86 and pH 7.27 for the year and

averaging pH 7.05.

Groundwater temperatures were consistent throughout 2016 with an average summer temperature

of 12.8°C and an average winter temperature of 12.1°C with no significant localised variation.

Conductivity readings in summer averaged 831uS/cm and in winter averaged 994uS/cm.

Conductivity levels were slightly high in some wells in November 2016 but in general are low across

the site and within acceptable ranges. The slightly higher levels in winter are likely to be influenced

by lower temperatures leading to less dissolution of dissolved solids.

The site is located close to the Shannon estuary therefore there may be slight regional saline

influence on groundwater.

There were no spillages reported in the vicinity of any of the Groundwater wells in 2016.

4.2 Organics

The organics suite was developed with the laboratory in order to capture the relevant chemicals, solvents

and fuels used on-site. Organic compounds tested for include alcohols, ketones, acetates, organic acids,

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chlorinated solvents, and petroleum based organics and various hydrocarbon breakdown products. Results

are summarised as follows:

In May 2016, slightly elevated levels of Diesel Range Organics (DRO) were evident in all wells

sampled. Well GS04 recorded the highest DRO concentration of 207μg/l whilst the remaining wells

ranged between 21 and 45μg/l. In November 2016 however, DROs in all wells sampled were below

the laboratory Limit of Detection (LOD) of <21μg/l showing an overall improvement at the site. It is

noted that the EPA IGV of 0.01mg/l applies to Total Hydrocarbons to include mineral oil by gas

chromatography which includes Gasoline Range Organics, the separate BTEX parameters including

MTBE and DRO (to determine mineral oil concentration). Laboratory detection limits in this instance

are not sufficiently low to allow direct comparison with this value. It is noted however that this

analysis technique is not as reliable as the more detailed TPH analysis which was also completed at

the site and is discussed further in Section 4.5 below. Some hydrocarbons occur naturally due to

humic acids or peaty subsoils which are evident on-site.

In general, alkalinity levels (expressed as HCO3 and CaCO3) have remained relatively constant

throughout 2015 and 2016 for all wells sampled. In May 2016 a notable change in alkalinity was

observed in well GS12 (dropping below laboratory LODs for the first time). A review of related

parameters does not suggest any pollution issues on-site. Alkalinity results returned again to typical

levels in November 2016.

In 2016, cyclohexane levels were below laboratory LODs in all wells sampled. It is noted that in June

2015, low level cyclohexane (1.3mg/l) was observed in both GS02 and GS03, therefore an

improvement in conditions has been observed during 2016.

MTBE concentrations in all wells sampled throughout 2016 were below acceptable limits and the

laboratory LODs. Historically, low level MTBE was detected in GS04, GS11 and GS12 at separate

intervals during 2015 (though still below acceptable levels) showing an improvement over time in

these wells. MBTE is commonly associated with unleaded petrol but is also present in some

laboratory solvent and pharmaceutical agents. It is understood that no MTBE has been used at the

site since 2008.

Bacterial analysis is not typically a licence requirement but was undertaken on this occasion to

further investigate the reason for elevated phosphates and nitrate concentrations recorded in 2015.

Bacterial analysis was chosen to investigate the possibility of waste water sources contributing to

these elevated results. Coliform bacteria numbers exceeded the European Union (Drinking Water)

Regulations 2014 (S.I. No. 122) and EPA IGV in relation to groundwater in both monitoring rounds in

2016 in wells GS03, GS04 and GS12. Elevations were also observed in the remaining wells during the

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November 2016 monitoring round. It is noted that coliform limit values (S.I. No. 122 2014) refers to

groundwater intended for drinking water supply and therefore are not specifically relevant for this

site. No E.coli was detected in the samples suggesting that the coliforms do not come from a faecal

or sewage source and rather may be due to soils, surface water intrusion or other natural sources.

All other organic parameters were below the GTV (2010), EPA IGVs (2003) and the Dutch limit values

for 2016.

4.3 Metals

Metals results are summarised as follows:

Calcium concentrations were below the EPA IGV of 200mg/l in all wells sampled in May 2016. In

November, levels increased slightly above the limit in wells GS03 (302mg/l), GS06 (216mg/l) and

GS12 (233mg/l). Well GS01 saw a reduction in Calcium from slightly elevated levels in November

2015 (316mg/l) to below the IGV in May and November 2016 (146 and 151mg/l respectively).

Magnesium concentrations were below EPA IGVs in all wells sampled in 2016.

Sodium was only slightly elevated above the GTV and EPA IGV of 150mg/l in one well on-site in May

2016. GS02 recorded concentrations of 174.4mg/l however this level reduced to below the limit

value in November (90.4mg/l). A similar trend was observed in 2015 where Sodium concentration

fluctuated slightly in this well. All other wells through 2015 and 2016 had levels below the

acceptable limit.

Potassium concentrations are elevated above an EPA IGV of 5mg/l in all wells sampled throughout

2016. This trend follows-on from similar results recorded in June 2015 and previously which suggests

that potassium concentrations are naturally elevated.

Manganese concentrations were above the EPA IGVs (50μg/l) in GS02 and GS11 in 2016; most

notably in GS02, with concentrations of 660μg/l in November. These levels were also elevated in

both wells throughout 2015. Elevated dissolved manganese concentrations are commonly

associated with reduced hydrochemical conditions in groundwater. Since 2015, significant

improvements in wells GS01, GS04 and GS06 have been observed as levels reduced from above the

IGV to well below; most notably in well GS04 which reduced from 360μg/l in June 2015 to 3.2μg/l in

November 2016. All remaining wells have remained below the acceptable limit over the same

period.

Iron concentrations are above the EPA IGV (of 200μg/l) in well GS02 for 2016 which saw similar

levels recorded in the year prior. A marked reduction in Iron concentration has been observed in

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well GS11 however; which saw levels at 291μg/l in November 2015 reduce to below the IGV in

November 2016 (162.9μg/l). All other wells were below the EPA IGV over the same period.

In May 2016, Cadmium concentrations were slightly elevated above the GTV (3.75μg/l) in wells GS02

(4.29μg/l), GS06 (3.88μg/l) and GS11 (6.17μg/l). Well GS11 also exceeded the EPA IGV of 5μg/l. In

the most recent monitoring round however, these levels reduced to below these acceptable limits.

All remaining wells sampled through 2016 were below the GTV and IGVs.

Results for Aluminium, Chromium, Nickel, Zinc, Boron, Cobalt, Silver, Tin, Copper, Mercury, Lead,

Selenium and Beryllium are all below relevant guidelines and similar to observed results from 2015.

The above metal and major ion exceedances have been detected on-site historically and are most likely

associated with naturally occurring properties of groundwater in limestone bedrock and overlying glacial

till subsoils.

4.4 Major Ions

Results for major anions are summarised as follows:

Chloride results were within the GTV range of 24-187.5mg/l in all wells sampled throughout 2016

with the exception of two in November. GS01 recorded levels slightly below the GTV range

(17.3mg/l) whilst GS03 recorded the highest Chloride concentration of all wells (at 269.7mg/l). The

remaining wells sampled in 2016 had slightly elevated Chlorine concentrations exceeding the lower

IGV standard (of 30mg/l), a trend which was observed in 2015 also.

Ammoniacal Nitrogen was above the GTV and EPA IGV acceptable limits in all wells sampled

throughout 2016. The maximum concentrations were observed in wells GS04 (2.6mg/l) and GS11

(2.4mg/l) in November. Comparison with 2015 data shows Ammoniacal Nitrogen concentrations

have increased across all wells on-site. Typically, ammoniacal nitrogen levels above 0.1 mg/l indicate

potential sewage or industrial contamination; however it may also be an indication of slightly

reduced hydrochemical conditions. Nitrate and Nitrite concentrations were below the GTV and EPA

IGV limits throughout 2016 with the exception of well GS12 which recorded a one-off minor

exceedance of Nitrate (at 60.25mg/l). All remaining well results are similar to or show an improved

trend on those recorded in 2015.

Phosphate was above GTV and EPA IGVs in all wells in both the May and November 2016 sampling

rounds with a maximum of 0.93mg/l observed in well GS02 in May. This well has seen a marked

improvement from its June 2015 result of 1.18mg/l. All remaining wells recorded similar results to

2015.

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Potassium concentrations were slightly elevated above the EPA IGV of 5mg/l for all wells on-site

throughout 2016. The most elevated results being exhibited in well GS11 at 15.3mg/l in May

however all results are similar in those of 2015 in each well.

Sulphate was above the GTV of 187.5mg/l in wells GS01 and GS06 for both monitoring rounds in

2016. The most elevated result being in 254.5mg/l in GS01 in May which is a slight improvement

from 2015 results. Sulphate concentrations show localised variations across the site but overall are

quite stable and similar to results recorded for 2015 in all remaining wells.

Sulphide concentrations were below detection limits in all wells apart from low level sulphides in

GS04 (0.31-0.39mg/l). No limit value is available for sulphides but their presence may be an indicator

of reduced hydrochemical conditions.

Bromide is present at low levels across the site (0.313-1.726mg/l) at concentrations similar to those

recorded in 2015.

Overall the presence of slightly elevated potassium, chloride and sulphate ions maybe attributed to the

brackish water influence of the nearby Shannon Estuary as these parameters are elevated in brackish water.

4.5 Aliphatic & Aromatic Hydrocarbons

Results for Aliphatic and Aromatic Hydrocarbons are summarised as follows:

TPH concentrations reported in groundwater samples taken from all wells on-site throughout 2016

were below the EPA IGVs and laboratory LOD with the exception of two wells (GS01 and GS02).

Slightly elevated concentrations of aliphatic carbon chains C10-C16 were reported in wells GS01 and

GS02 in May 2016. These levels exceed the IGVs however; results from the same wells in November

saw concentration return to below the acceptable limits.

4.6 Potential Pollutant Linkages

Based on laboratory results from 2015 and 2016, the following observations are made in relation to

pollutant linkages between contamination sources, migration pathways and sensitive receptors.

4.6.1 Contamination sources summary

Direct and indirect contamination sources are listed below:

No evidence of groundwater solvent contamination was detected in 2015 or 2016 from on-site

activities.

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Slightly elevated DRO was recorded in all wells on-site in May 2016 with the highest level recorded in

well GS04. These results were similar to those observed throughout the 2015 monitoring rounds. In

November 2016 however, DRO levels in all wells were below the laboratory LODs. The more up-to-

date analysis for TPH (TPH Criteria Working Group) provides for more accurate banding of petroleum

components and results are less affected by naturally occurring or interfering substances. This

analysis suggests only slightly elevated concentrations of aliphatic carbon chains C10-C16 were

evident in wells GS01 and GS02 in May 2016. It is therefore likely that DRO results are affected by

natural humic acids from peaty clay subsoils in the area.

No elevated results for contaminants of potential concern (COPCs) from organic solvents on-site

have been observed.

Phosphates were elevated in all wells. Elevated Ammoniacal Nitrogen was also observed in all wells

throughout 2016. Localised elevations were also recorded for various other parameters including

Potassium, Manganese, Iron and Sulphates; these parameters may possibly be affected by site

activities but are more likely associated with naturally occurring ground and groundwater conditions.

4.5.2 Contamination Pathways

Contamination pathways are discussed below:

Localised contaminants may potentially migrate in shallow groundwater beneath the site. Although

the GSI has recorded the aquifer as having a low vulnerability, a review of site logs suggests that a

high to extreme vulnerability may be more appropriate.

Dissolved ions in groundwater potentially flowing towards sensitive environmental receptors such as

nearby streams and SPA of the Lower Shannon Estuary.

The groundwater flow direction has been measured to be in a westerly direction towards the Urlan

Beg River. This places a particular importance on the most downgradient monitoring wells on the

western side of the site; GS11, GS04 and GS03.

4.5.3 Receptors

Based on desk survey findings, the following potential environmental receptors have been identified:

Urlan Beg River and tributary streams adjacent to the western boundary;

SPA of the Lower Shannon Estuary;

Locally important aquifer of potentially high to extreme vulnerability;

One abstraction well is located on-site and used for industrial purposes only.

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There are several recorded off-site wells for agricultural and domestic use within 1km north-west of

the site; these are considered to be up-gradient of the site based on groundwater surveying data.

Four wells of unknown exact locations are recorded within 500m south east of the site. These are

considered to be up-gradient or side gradient and not at risk from any potential on-site releases. It is

noted that an accurate location of these wells is not available but considering local hydraulic flow is

towards the Urlan Beg River and no abstraction wells are between the site and the river,

groundwater abstraction wells are excluded as a potential receptor.

5 SUMMARY CONCLUSIONS AND RECOMMENDATIONS

5.1 Conclusions

Based on survey findings, the following conclusions are made:

Slightly elevated Diesel Range Organics (DRO) was recorded in all wells on-site in May 2016 with the

highest level recorded in well GS04. A more up-to-date analysis for TPH (TPH Criteria Working

Group) provides for more accurate banding of petroleum components and results are less affected

by naturally occurring or interfering substances. This detailed analysis indicated only slightly elevated

concentrations of aliphatic carbon chains C10-C16 evident in wells GS01 and GS02 in May 2016. It is

likely therefore that DRO results are affected by natural humic acids from peaty clay subsoils in the

area rather than a petroleum source.

Laboratory results indicate that organic solvent COPCs associated directly with site manufacturing

activities are below relevant groundwater limits or guidelines.

Phosphates and Ammoniacal Nitrogen were somewhat elevated in all wells together with localised

elevations for Potassium, Manganese, Iron and Sulphates. These parameters may be affected by

source releases from site e.g. wastewater or surface releases permeating beneath hardstanding but

considering trends across the site, it is likely that these results are mostly reflective of naturally

occurring levels. This is supported by the bacterial analysis which confirm the presence of elevated

Coliform bacterial in all wells on-site but the absence of E.coli; suggesting that the coliforms do not

come from a faecal / sewage source but rather may be due to natural sources or possibly run-off

from agricultural activities such as the spreading of fertilisers nearby.

Bacterial analysis is not a licence requirement but was undertaken to investigate the possibility of a

waste water source contributing to elevated phosphate and nitrate concentrations recorded in 2015.

Coliform bacteria exceeded drinking water standards in some wells however E.coli was not detected

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EPA Export 29-05-2017:03:19:20

Avara Groundwater Review 2016 Verdé Ref: 50374

Page 14

in any well during both monitoring rounds, indicating that the coliforms are not from sewage

sources.

5.2 Recommendations

Based on groundwater review findings, the following recommendations are made:

Continue biannual groundwater monitoring to identify trends in the data.

It is suggested that that DRO / PRO analysis is no longer required at the site considering that analysis

for TPH CWG including BTEX and MTBE is now currently being undertaken. Older analysis techniques

for TPH include analysis of DRO / PRO fractions which are less reliable that current techniques. More

up-to-date analysis for TPH (TPH Criteria Working Group) provides for more accurate banding of

petroleum components and results are less affected by naturally occurring or interfering substances.

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Verdé Environmental Consultants Ltd | Part of the Verdé Environmental Group

Figures

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B A L L Y C A L L Y

C A H E R T E I G E

S M I T H S T O W N

T U L L Y V A R R A G AT U L L Y G L A S S

K N O C K A U N

F I R G R O V E

B A L L Y C U N N E E N

C L O N L O G H A N

L I S C O N O R

C A R R O W

B A L L Y C A S E YB E G

B A L L Y C A S E YM O R E

C L O N M O N E YW E S T

C L O N M O N E YS O U T H

S T O N E H A L L

SHANNON

Ballycasey

SHANNONAIRPORT

SiteLocation

S H A N N O N E S T U A R Y

R472

R471

N19

N18

M18

www.verde.ieTel: + 353 1 201 1260 Date: Feb. 2016 Job Ref: 50953

Title:

Clien Avarat:

Site Location Map

Services armaceuticalhP annonhS Ltd.

Figure No. 1

VerdeScale 1:25,000 (at A4 size) Kilometres

0 0.2 0.4 0.6 0.8 1 2

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EPA Export 29-05-2017:03:19:20

URLA

N B

EG R

IVER

www.verde.ieTel: + 353 1 201 1260 Date: Mar. 2016 Job Ref: 50953

Title:

Clien varaAt: Ltd Services aceuticalmharP Shannon Verde

Scale 1:2,500 (at A4 size) Metres

0 20 40 60 80 100 120 140 160 180 200

LEGEND

Borehole LocationSite Boundary

MW/GS

Site Layout Map

Figure No. 2

MW19

MW20MW21

GS03

GS06

GS11

GS01

GS12

MW4

MW3

MW5

MW14

GS04

MW12

GS02

MW13

MW9

MW10

OPEN

CULVERT

A Section) Cross 3 Fig (See

East

A Section) Cross 3 Fig (See

West

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Scale 1:500 (at A4 size) Metres

0 5 10 15 20 25 30 35 40

Water Table

UCB PlantBuildings

Overburden

Made Ground

WeatheredLimestone

Bedrock

GS0

6

GS0

3

GS1

2

MW

4

MW

12

MW

19

MW

20

MW

13

MW

14

CompetentLimestone

Bedrock

Site

Bou

ndar

y

Urla

n Be

g Ri

ver

www.verde.ieTel: + 353 1 201 1260 Dat Mare: , 7201 Job Ref: 37450

Title:

Location:Verde

rossSite Section C

Figure No. 3

Avara Ltd Services Pharmaceutical Shannon

Met

res

abov

e si

te d

atum

14

12

10

8

6

2

0

-2

-4

4

LEGEND

Groundwater level

Groundwater �ow direction

Screened Section of Borehole

AWES

TA

EAST

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Verdewww.verde.ie

Tel: + 353 1 201 1260

Title:

Client:

Date: Job Ref: Figure No.

Avara Shannon Pharmaceutical Services Ltd.

50374Feb. 2017Scale 1:2,500 (at A4 size) Metres

0 20 40 60 80 100 120 140 160 180 200

Groundwater Contour Map(Feb. 2017)

BH

LEGENDBorehole LocationXXXSite Boundary

LEGEND

Borehole LocationSubsoil InstallationSubsoil & Bedrock InstallationBedrock InstallationWater Abstraction WellOOUT93UT93Groundwater ContourGroundwater Flow DirectionMetres above Site DatumGroundwater Level (mASD)Site Boundary

MW/GS

(mASD)

10

8.0

8.0

8.5

8.5

9.0

9.0

9.5

9.5

10.0

10.510.0

10.5

11.0

(8.84)

MW19

MW20MW21

GS03

GS06

GS11

GS01

GS12

MW4

MW3

MW5

MW14

GS04

MW12

GS02

MW13

MW9MW10

(8.90)

(9.03)

(9.47)

(8.30)

(11.04)

(8.83)WAW

WAW

(8.89)

4

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Verdé Environmental Consultants Ltd | Part of the Verdé Environmental Group

Tables

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EPA Export 29-05-2017:03:19:21

Table 1 - Groundwater Analytical Resuls

Sample ID:

Units 09/06/2015 24/11/2015 31/05/2016 28/11/2016 09/06/2015 24/11/2015 31/05/2016 28/11/2016

TPH-CWG

Aliphatics

>C5-C6 - 10 - - μg/l - - <5 <5 - - <5 <5

>C6-C8 - 10 - - μg/l - - <5 <5 - - <5 <5

>C8-C10 - 10 - - μg/l - - <5 <5 - - <5 <5

>C10-C12 - 10 - - μg/l - - 106 <5 - - 86 <5

>C12-C16 - 10 - - μg/l - - 20 <10 - - 20 <10

>C16-C21 - 10 - - μg/l - - <10 <10 - - <10 <10

>C21-C35 - 10 - - μg/l - - <10 <10 - - <10 <10

Total aliphatics C5-35 μg/l - - 126 <10 - - 106 <10

Aromatics

>C5-EC7 - 1 - - μg/l - - <5 <5 - - <5 <5

>EC7-EC8 - 4 - - μg/l - - <5 <5 - - <5 <5

>EC8-EC10 - 10 - - μg/l - - <5 <5 - - <5 <5

>EC10-EC12 - 10 - - μg/l - - <5 <5 - - <5 <5

>EC12-EC16 - 10 - - μg/l - - <10 <10 - - <10 <10

>EC16-EC21 - 10 - - μg/l - - <10 <10 - - <10 <10

>EC21-EC35 - 10 - - μg/l - - <10 <10 - - <10 <10

Total aromatics C5-35 - - - - μg/l - - <10 <10 - - <10 <10

Major Anions

NO3-N - - - - mg/l <0.76 0.70 <0.76 <0.76 <0.76 0.80 0.30 0.40

NO3 37.5 25 - - mg/l <3.366 3.10 <3.366 <3.366 <3.366 3.54 1.33 1.77

Fl - - - 0.5 mg/l 0.18 <0.20 0.20 0.20 0.39 0.40 0.50 0.50

Cl 24 - 187.5 30 - 100 mg/l 31.0 19.3 39.3 17.3 57.6 38.5 49.7 46.3

Br - - - - mg/l 0.186 0.467 0.424 0.313 0.396 1.669 1.572 1.262

NH3-N 0.065 - 0.175 0.15 - - mg/l 0.036 0.013 0.439 0.380 0.466 0.383 1.630 1.228

NH3 - - - - mg/l 0.04 0.02 0.53 0.46 0.57 0.47 1.98 1.49

PO4 3-

-P 0.035 0.03 - - mg/l 0.15 0.10 0.08 0.07 1.18 0.77 0.93 0.79

SO4 2- 187.5 200 - - mg/l 301.9 339.6 254.5 244.3 156.1 161.4 94.1 173.6

Nitrite 0.375 0.1 - - mg/l 0.100 <0.066 <0.066 <0.066 0.070 <0.066 <0.066 <0.066

Sulphide - - - - mg/l <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05

Organics

Alkalinity as HC03-

No abnormal

change- - mg/l 315.0 236.8 588.9 319.7 905.0 426.7 291.2 459.5

Alkalinity as CaC03-

No abnormal

change- - mg/l 258.0 194.1 482.7 262.1 742.0 348.1 238.7 376.6

pH - 6.5 - 9.5 - - pH units 7.0 7.1 7.2 7.1 7.0 7.1 7.0 7.0

Conductivity 800 - 1875 1000 - - uS/cm 1129 832 709 866 1275 859 952 1065

DRO - 10 - - μg/l <46 <21 21 <21 <46 <21 27 <21

PRO - 10 - - μg/l <100 <20 <20 <20 <100 <20 <20 <20

Methanol - - 24000 - mg/l <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

Ethanol - - - - mg/l <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

IPA - - 31000 - mg/l <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

MIBK - - - - mg/l <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

Tetrachloroethene 7.5 40 - - μg/l - 3.17 <2 <1 - <1 <2 <1

Cyclohexane - - - - mg/l <1 <1 <1 <1 1.3 <1 <1 <1

DCM - 10 1000 0.01 μg/l - <3 <3 <3 - <3 <3 <3

Toluene - 10 1000 7 μg/l <1 <1 <5 <5 <1 <1 <5 <5

MTBE - 30 9200 - μg/l <1 <1 <5 <5 <1 <1 <5 <5

m/p,o-Xylene - 10* 70* 0.2* μg/l <1 <1 - - <1 <1 - -

m/p-Xylene - 10* 70* 0.2* μg/l - - <5 <5 - - <5 <5

o-Xylene - 10* 70* 0.2* μg/l - - <5 <5 - - <5 <5

Benzene 0.75 1 30 0.2 μg/l - <7 <5 <5 - <1 <5 <5

Trichloroethene - 40 - - μg/l - <1 <3 <1 - <1 <3 <1

Ethylbenzene - 10 150 4 μg/l - <5 <5 <5 - <3 <5 <5

1,2-Dichloroethane 2.25 3 400 7 μg/l - <1 <3 <1 - <1 <3 <1

Bromodichloromethane - - - - μg/l - <1 <1 <1 - <1 <1 <1

Chlorobenzene - 1 - - μg/l - <1 <4 <1 - <1 <4 <1

E.coli - 0 - - MPN/100ml - - < 1.0 < 1.0 - - < 1.0 < 1.0

Coliforms - 0 - - MPN/100ml - - < 1.0 3448.0 - - < 1.0 461.1

All Other VOC's μg/l <LOD <LOD <LOD <LOD <LOD <LOD <LOD <LOD

Dissolved Metals

Ca2 - 200 - - mg/l 162 316 146 151 70 88 79 102

Mg2 - 50 - - mg/l 17.2 20.8 14.2 15.8 23.4 21.7 20.2 20.4

Na 150 150 - - mg/l 39.7 26.4 33.8 26.7 195.0 126.8 174.4 90.4

K - 5 - - mg/l 7.3 6.8 5.9 5.4 19.5 13.5 17.4 13.2

Manganese - 50 - - μg/l 33.0 343.9 1.00 14.2 830.0 619.0 140.6 660.0

Iron - 200 - - μg/l <20 109.1 < 7.2 < 7.2 364.0 151.3 294.9 247.3

Aluminium 150 200 - - μg/l <20 37.3 < 5.0 < 5.0 33.0 10.9 9.5 6.8

Chromium 37.5 30 30 1 μg/l <0.60 4.22 1.47 0.71 <0.60 2.23 2.70 0.84

Nickel 15 20 75 15 μg/l <2.00 3.51 1.55 2.58 <2..00 3.91 3.71 3.50

Zinc - 100 800 65 μg/l <1.9 7.0 6.0 2.0 2.0 6.0 9.0 5.0

Barium - 100 625 50 μg/l 711.0 68.1 55.6 54.8 328.0 29.0 24.1 45.4

Boron 750 1000 - - μg/l 30 53 < 50 < 50 511 392 514 345

Antimony - - 10 0.15 μg/l 0.38 <0.01 0.40 < 0.16 0.48 1.00 0.42 < 0.16

Cobalt - - 100 20 μg/l 0.34 <1.00 0.11 < 0.15 0.33 <1.00 0.20 0.46

Silver - - 40 - μg/l <1.50 <0.01 < 1.50 < 1.50 <1.50 <0.01 < 1.50 < 1.50

Arsenic - 10 60 10 μg/l 0.44 <0.05 0.13 0.66 1.29 <0.05 1.58 1.06

Tin - - 50 2.2 μg/l 0.57 <0.01 < 0.36 < 0.36 0.50 <0.01 < 0.36 < 0.36

Copper - 30 75 15 μg/l <5.00 3.89 4.85 3.83 <5.00 2.15 4.47 3.48

Cadmium 3.75 5 6 0.4 μg/l 0.40 0.72 2.53 0.62 0.30 0.65 4.29 0.49

Mercury 0.75 1 0.3 0.05 μg/l <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Lead 18.75 10 75 15 μg/l 1.60 3.57 4.03 < 0.80 1.90 3.69 7.85 2.67

Selenium - - - - μg/l 0.43 <0.01 < 0.39 < 0.81 2.22 <0.01 2.15 < 0.81

Beryllium - - 15 0.05 μg/l <0.07 <0.07 < 0.07 < 0.10 <0.07 <0.07 < 0.07 < 0.10

Notes

GTV = Groundwater Threshold Value Range - S.I. 9 of 2010 (Groundwater Regulations)

IGV taken from EPA Interim Guideline Values for the Protection of Groundwater 2003

"-" = Not Analysed

ND = Not Determined

LOD = Laboratory Limits of Detection

GTV - S.I. 9 of 2010 (Groundwater Regulations) exceedances are highlighted in bold

IGV taken from EPA Interim Guideline Values 2003 exceedences are underlined

Dutch S Target Value exceedances are in italics

Dutch Intervention Value exceedances are shaded

* Limit value applies to combined xylenes

GS02IGV

Dutch

InterventionAnalyte

GTV (SI 9 of

2010)

Dutch

Target S

GS01

Page 1 of 3

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EPA Export 29-05-2017:03:19:21

Sample ID:

Units

TPH-CWG

Aliphatics

>C5-C6 - 10 - - μg/l

>C6-C8 - 10 - - μg/l

>C8-C10 - 10 - - μg/l

>C10-C12 - 10 - - μg/l

>C12-C16 - 10 - - μg/l

>C16-C21 - 10 - - μg/l

>C21-C35 - 10 - - μg/l

Total aliphatics C5-35 μg/l

Aromatics

>C5-EC7 - 1 - - μg/l

>EC7-EC8 - 4 - - μg/l

>EC8-EC10 - 10 - - μg/l

>EC10-EC12 - 10 - - μg/l

>EC12-EC16 - 10 - - μg/l

>EC16-EC21 - 10 - - μg/l

>EC21-EC35 - 10 - - μg/l

Total aromatics C5-35 - - - - μg/l

Major Anions

NO3-N - - - - mg/l

NO3 37.5 25 - - mg/l

Fl - - - 0.5 mg/l

Cl 24 - 187.5 30 - 100 mg/l

Br - - - - mg/l

NH3-N 0.065 - 0.175 0.15 - - mg/l

NH3 - - - - mg/l

PO4 3-

-P 0.035 0.03 - - mg/l

SO4 2- 187.5 200 - - mg/l

Nitrite 0.375 0.1 - - mg/l

Sulphide - - - - mg/l

Organics

Alkalinity as HC03-

No abnormal

change- - mg/l

Alkalinity as CaC03-

No abnormal

change- - mg/l

pH - 6.5 - 9.5 - - pH units

Conductivity 800 - 1875 1000 - - uS/cm

DRO - 10 - - μg/l

PRO - 10 - - μg/l

Methanol - - 24000 - mg/l

Ethanol - - - - mg/l

IPA - - 31000 - mg/l

MIBK - - - - mg/l

Tetrachloroethene 7.5 40 - - μg/l

Cyclohexane - - - - mg/l

DCM - 10 1000 0.01 μg/l

Toluene - 10 1000 7 μg/l

MTBE - 30 9200 - μg/l

m/p,o-Xylene - 10* 70* 0.2* μg/l

m/p-Xylene - 10* 70* 0.2* μg/l

o-Xylene - 10* 70* 0.2* μg/l

Benzene 0.75 1 30 0.2 μg/l

Trichloroethene - 40 - - μg/l

Ethylbenzene - 10 150 4 μg/l

1,2-Dichloroethane 2.25 3 400 7 μg/l

Bromodichloromethane - - - - μg/l

Chlorobenzene - 1 - - μg/l

E.coli - 0 - - MPN/100ml

Coliforms - 0 - - MPN/100ml

All Other VOC's μg/l

Dissolved Metals

Ca2 - 200 - - mg/l

Mg2 - 50 - - mg/l

Na 150 150 - - mg/l

K - 5 - - mg/l

Manganese - 50 - - μg/l

Iron - 200 - - μg/l

Aluminium 150 200 - - μg/l

Chromium 37.5 30 30 1 μg/l

Nickel 15 20 75 15 μg/l

Zinc - 100 800 65 μg/l

Barium - 100 625 50 μg/l

Boron 750 1000 - - μg/l

Antimony - - 10 0.15 μg/l

Cobalt - - 100 20 μg/l

Silver - - 40 - μg/l

Arsenic - 10 60 10 μg/l

Tin - - 50 2.2 μg/l

Copper - 30 75 15 μg/l

Cadmium 3.75 5 6 0.4 μg/l

Mercury 0.75 1 0.3 0.05 μg/l

Lead 18.75 10 75 15 μg/l

Selenium - - - - μg/l

Beryllium - - 15 0.05 μg/l

Notes

GTV = Groundwater Threshold Value Range - S.I. 9 of 2010 (Groundwater Regulations)

IGV taken from EPA Interim Guideline Values for the Protection of Groundwater 2003

"-" = Not Analysed

ND = Not Determined

LOD = Laboratory Limits of Detection

GTV - S.I. 9 of 2010 (Groundwater Regulations) exceedances are highlighted in bold

IGV taken from EPA Interim Guideline Values 2003 exceedences are underlined

Dutch S Target Value exceedances are in italics

Dutch Intervention Value exceedances are shaded

* Limit value applies to combined xylenes

IGVDutch

InterventionAnalyte

GTV (SI 9 of

2010)

Dutch

Target S

Table 1 - Groundwater Analytical Resuls

09/06/2015 24/11/2015 31/05/2016 28/11/2016 09/06/2015 24/11/2015 31/05/2016 28/11/2016

- - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5

- - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10

- - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5

- - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10

0.90 <0.76 <0.76 <0.76 0.10 <0.76 1.10 <0.76

3.99 <3.366 <3.366 <3.366 0.44 <3.366 4.87 <3.366

0.22 <0.20 0.20 0.20 0.33 0.40 0.40 0.40

39.9 21.0 52.3 269.7 66.7 115.7 72.3 96.7

0.243 0.659 1.156 0.995 0.402 2.160 1.726 1.609

0.045 0.016 0.564 0.795 0.530 0.593 2.642 1.749

0.05 0.02 0.68 0.97 0.65 0.72 3.21 2.12

0.22 0.17 0.10 0.26 0.37 0.38 0.12 0.25

98.1 164.4 102 100 112.3 102.6 152.9 123.8

0.330 0.121 <0.066 <0.066 0.030 <0.066 <0.066 <0.066

<0.05 0.095 <0.05 <0.05 0.39 0.307 <0.05 <0.05

243.0 4163.8 376.0 351.0 592.0 486.0 371.6 408.2

199.0 3412.9 308.2 287.7 485.0 398.4 304.6 334.6

7.3 7.5 7.2 7.3 7.2 7.2 7.2 7.2

744 519 870 1084 1051 880 820 1050

<46 <21 45 <21 50.4 223 207 28

<100 <28 <20 <20 <100 23 <20 <20

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

- <1 <2 <1 - 6.5 <2 <1

1.3 <1 <1 <1 <1 <1 <1 <1

- <3 <3 <3 - <3 <3 <3

<1 <1 <5 <5 <1 <1 <5 <5

<1 <1 <5 <5 <1 1.19 <5 <5

<1 <1 - - <1 <1 - -

- - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5

- <1 <5 <5 - <1 <5 <5

- <1 <3 <1 - <1 <3 <1

- <1 <5 <5 - <1 <5 <5

- <1 <3 <1 - <1 <3 <1

- <1 <1 <1 - <1 <1 <1

- <1 <4 <1 - <1 <4 <1

- - < 1.0 < 1.0 - - < 1.0 < 1.0

- - 26.2 165.0 - - 83.3 121.0

<LOD <LOD <LOD <LOD <LOD <LOD <LOD <LOD

87 87 96 302 120 126 125 123

14.5 12.6 17.5 19.2 17.7 17.7 19.9 19.3

37.1 15.3 95.0 114.0 75.7 109.7 65.8 86.5

7.8 5.2 11.4 11.7 11.0 8.6 11.8 11.3

21.0 17.4 0.8 42.9 360.0 87.8 5.3 3.2

<20.0 15.6 10.4 < 7.2 <20.0 11.6 60.8 < 7.2

<20.0 21.3 5.3 < 5.0 <20.0 22.7 < 5.0 < 5.0

<0.60 2.62 2.11 < 0.60 <0.60 2.80 11.49 < 0.60

<2.00 3.49 3.44 1.68 2.80 3.86 10.93 1.75

<1.9 6.0 14.0 7.0 <1.9 7.0 11.0 5.0

182.0 21.5 35.9 32.6 441.0 44.8 45.4 42.6

55 59 68 60 84 97 65 97

0.75 <0.01 0.61 0.25 0.65 <0.01 0.51 0.20

0.19 <1.00 0.11 0.41 0.42 <1.00 0.16 0.19

<1.50 <0.01 < 1.50 < 1.50 <1.50 <0.01 < 1.50 < 1.50

1.39 <0.05 1.75 0.77 1.26 <0.05 1.43 0.79

0.62 <0.01 < 0.36 < 0.36 0.85 <0.01 < 0.36 < 0.36

<5.00 2.79 4.27 3.54 <5.00 2.35 4.12 3.10

0.40 0.56 4.24 0.98 0.30 0.75 2.16 0.77

<0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

<0.8 3.97 6.08 1.31 1.30 4.56 7.83 0.82

3.60 1.00 5.41 0.93 2.95 <0.01 3.65 < 0.81

<0.07 <0.07 < 0.07 < 0.10 <0.07 <0.07 < 0.07 < 0.10

GS03 GS04

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Sample ID:

Units

TPH-CWG

Aliphatics

>C5-C6 - 10 - - μg/l

>C6-C8 - 10 - - μg/l

>C8-C10 - 10 - - μg/l

>C10-C12 - 10 - - μg/l

>C12-C16 - 10 - - μg/l

>C16-C21 - 10 - - μg/l

>C21-C35 - 10 - - μg/l

Total aliphatics C5-35 μg/l

Aromatics

>C5-EC7 - 1 - - μg/l

>EC7-EC8 - 4 - - μg/l

>EC8-EC10 - 10 - - μg/l

>EC10-EC12 - 10 - - μg/l

>EC12-EC16 - 10 - - μg/l

>EC16-EC21 - 10 - - μg/l

>EC21-EC35 - 10 - - μg/l

Total aromatics C5-35 - - - - μg/l

Major Anions

NO3-N - - - - mg/l

NO3 37.5 25 - - mg/l

Fl - - - 0.5 mg/l

Cl 24 - 187.5 30 - 100 mg/l

Br - - - - mg/l

NH3-N 0.065 - 0.175 0.15 - - mg/l

NH3 - - - - mg/l

PO4 3-

-P 0.035 0.03 - - mg/l

SO4 2- 187.5 200 - - mg/l

Nitrite 0.375 0.1 - - mg/l

Sulphide - - - - mg/l

Organics

Alkalinity as HC03-

No abnormal

change- - mg/l

Alkalinity as CaC03-

No abnormal

change- - mg/l

pH - 6.5 - 9.5 - - pH units

Conductivity 800 - 1875 1000 - - uS/cm

DRO - 10 - - μg/l

PRO - 10 - - μg/l

Methanol - - 24000 - mg/l

Ethanol - - - - mg/l

IPA - - 31000 - mg/l

MIBK - - - - mg/l

Tetrachloroethene 7.5 40 - - μg/l

Cyclohexane - - - - mg/l

DCM - 10 1000 0.01 μg/l

Toluene - 10 1000 7 μg/l

MTBE - 30 9200 - μg/l

m/p,o-Xylene - 10* 70* 0.2* μg/l

m/p-Xylene - 10* 70* 0.2* μg/l

o-Xylene - 10* 70* 0.2* μg/l

Benzene 0.75 1 30 0.2 μg/l

Trichloroethene - 40 - - μg/l

Ethylbenzene - 10 150 4 μg/l

1,2-Dichloroethane 2.25 3 400 7 μg/l

Bromodichloromethane - - - - μg/l

Chlorobenzene - 1 - - μg/l

E.coli - 0 - - MPN/100ml

Coliforms - 0 - - MPN/100ml

All Other VOC's μg/l

Dissolved Metals

Ca2 - 200 - - mg/l

Mg2 - 50 - - mg/l

Na 150 150 - - mg/l

K - 5 - - mg/l

Manganese - 50 - - μg/l

Iron - 200 - - μg/l

Aluminium 150 200 - - μg/l

Chromium 37.5 30 30 1 μg/l

Nickel 15 20 75 15 μg/l

Zinc - 100 800 65 μg/l

Barium - 100 625 50 μg/l

Boron 750 1000 - - μg/l

Antimony - - 10 0.15 μg/l

Cobalt - - 100 20 μg/l

Silver - - 40 - μg/l

Arsenic - 10 60 10 μg/l

Tin - - 50 2.2 μg/l

Copper - 30 75 15 μg/l

Cadmium 3.75 5 6 0.4 μg/l

Mercury 0.75 1 0.3 0.05 μg/l

Lead 18.75 10 75 15 μg/l

Selenium - - - - μg/l

Beryllium - - 15 0.05 μg/l

Notes

GTV = Groundwater Threshold Value Range - S.I. 9 of 2010 (Groundwater Regulations)

IGV taken from EPA Interim Guideline Values for the Protection of Groundwater 2003

"-" = Not Analysed

ND = Not Determined

LOD = Laboratory Limits of Detection

GTV - S.I. 9 of 2010 (Groundwater Regulations) exceedances are highlighted in bold

IGV taken from EPA Interim Guideline Values 2003 exceedences are underlined

Dutch S Target Value exceedances are in italics

Dutch Intervention Value exceedances are shaded

* Limit value applies to combined xylenes

IGVDutch

InterventionAnalyte

GTV (SI 9 of

2010)

Dutch

Target S

Table 1 - Groundwater Analytical Resuls

09/06/2015 24/11/2015 31/05/2016 28/11/2016 09/06/2015 24/11/2015 31/05/2016 28/11/2016 09/06/2015 24/11/2015 31/05/2016 28/11/2016

- - <5 <5 - - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5 - - <5 <5

- - <10 <10 - - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10 - - <10 <10

- - <5 <5 - - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5 - - <5 <5

- - <10 <10 - - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10 - - <10 <10

- - <10 <10 - - <10 <10 - - <10 <10

1.60 <0.76 1.10 <0.76 <0.76 <0.76 1.40 <0.76 <0.76 <0.76 0.10 13.60

7.09 <3.366 4.87 <3.366 <3.366 <3.366 6.20 <3.366 <3.366 0.00 0.44 60.25

0.16 <0.20 0.20 0.20 0.38 0.40 0.40 0.50 0.14 <0.20 0.10 0.20

64.6 47.6 55.0 47.8 72.2 62.3 70.3 74.8 42.1 44.2 40.9 98.2

0.261 1.342 0.975 0.488 0.320 2.040 1.338 1.224 0.147 0.889 0.575 0.382

0.253 0.190 1.005 0.640 0.715 0.578 2.401 1.418 0.026 0.013 0.601 0.562

0.31 0.23 1.22 0.78 0.87 0.71 2.92 1.72 0.03 0.02 0.73 0.68

0.38 0.35 0.09 0.58 0.54 0.20 0.27 0.10 0.43 0.18 0.19 0.33

205.8 210.2 179.2 211.3 111 138.9 75.4 99.3 136.8 189.9 99.8 123.8

0.030 <0.066 <0.066 <0.066 0.030 <0.066 <0.066 <0.066 0.070 0.125 <0.066 <0.066

<0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05

336.0 356.9 516.1 341.9 720.0 542.8 462.1 554.9 528.0 340.6 < 36.9 485.6

275.0 292.5 423.1 280.3 590.0 444.9 378.7 454.8 433.0 279.2 < 30.0 398.1

6.8 7.1 7.1 7.0 6.9 7.2 6.9 7.0 6.9 7.0 6.9 6.9

1168 792 784 906 1238 888 882 1076 1062 731 800 912

<46 <21 21 <21 <46 <21 21 <21 <46 <21 21 <21

<100 <20 <20 <20 <100 <20 <20 <20 <100 <20 <20 <20

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

<0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

- <1 <2 <1 - <1 <2 <1 - <1 <2 <1

<1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1

- <3 <3 <3 - <3 <3 <3 - <3 <3 <3

<1 <1 <5 <5 <1 <1 <5 <5 <1 <1 <5 <5

<1 <1 <5 <5 10.4 3.29 <5 <5 11 <1 <5 <5

<1 <1 - - <1 <1 - - <1 <1 - -

- - <5 <5 - - <5 <5 - - <5 <5

- - <5 <5 - - <5 <5 - - <5 <5

- <1 <5 <5 - <1 <5 <5 - <1 <5 <5

- <1 <3 <1 - <1 <3 <1 - <1 <3 <1

- <1 <5 <5 - <1 <5 <5 - <5 <5 <5

- <1 <3 <1 - <1 <3 <1 - <1 <3 <1

- <1 <1 <1 - <1 <1 <1 - <1 <1 <1

- <1 <4 <1 - <1 <4 <1 - <1 <4 <1

- - < 1.0 < 1.0 - - < 1.0 < 1.0 - - < 1.0 < 1.0

- - < 1.0 2.0 - - < 1.0 3.0 - - 5.2 18.5

<LOD <LOD <LOD <LOD <LOD <LOD <LOD <LOD <LOD <LOD <LOD <LOD

134 153 152 216 102 116 111 106 111 347 166 233

19.2 17.6 15.0 16.5 37.1 39.4 33.1 33.6 15.6 19.3 16.6 17.6

49.2 45.7 48.8 35.3 116.0 121.0 86.9 84.7 25.3 26.1 29.1 26.1

5.9 5.2 6.5 6.9 16.8 14.7 15.3 15.2 5.1 5.8 6.1 5.6

188.0 218.5 1.0 29.6 278.0 173.7 417.3 279.4 <5 1.0 < 0.7 1.2

<20 51.8 < 7.2 < 7.2 291.0 68.7 142.2 162.9 <20.0 <7.20 9.4 < 7.2

<20 8.6 < 5.0 < 5.0 <20.0 11.3 < 5.0 < 5.0 <20.0 <5 < 5.0 < 5.0

<0.60 2.15 1.69 < 0.60 <0.60 2.44 1.72 < 0.60 <0.60 0.87 1.44 < 0.60

<2.00 2.82 4.64 3.10 <2.00 2.44 2.16 < 0.25 <2.00 1.89 2.57 1.24

<1.9 6.0 12.0 5.0 2.0 8.0 11.0 7.0 2.0 10.0 8.0 2.0

425.0 37.2 39.8 43.3 128.0 21.9 21.9 < 20.0 856.0 83.7 71.6 82.7

39 52 < 50 < 50 285 313 245 278 33 <50 < 50 < 50

0.68 <0.01 0.66 < 0.16 0.82 <0.01 0.55 < 0.16 0.93 <0.01 0.47 < 0.16

0.69 <1.00 0.22 0.90 0.53 1.00 0.24 < 0.15 0.24 <1.00 0.33 < 0.15

<1.50 <0.01 < 1.50 < 1.50 <1.50 <0.01 < 1.50 < 1.50 <1.50 <0.01 < 1.50 < 1.50

0.92 <0.05 0.36 0.87 1.62 <0.05 0.97 2.13 0.80 <0.05 0.53 0.70

0.94 <0.01 0.90 < 0.36 1.12 <0.01 0.43 < 0.36 1.19 <0.01 < 0.36 < 0.36

<5.00 2.77 4.30 3.10 <5.00 2.53 3.54 3.39 <5.00 2.82 4.36 3.29

0.40 0.79 3.88 0.48 0.20 0.78 6.17 0.58 0.40 0.61 3.02 0.59

<0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

2.30 3.50 6.33 1.71 1.20 3.41 4.81 < 0.80 1.30 3.07 4.36 < 0.80

1.16 <0.01 0.53 < 0.81 1.73 <0.01 1.32 < 0.81 1.80 <0.01 1.27 < 0.81

<0.07 <0.07 < 0.07 < 0.10 <0.07 <0.07 < 0.07 < 0.10 <0.07 <0.07 < 0.07 < 0.10

GS06 GS11 GS12

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