Annual Environmental Report 2009 PDM Limited, IPPC Register … · 2014. 12. 16. · 2.3. Schedule...

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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

Transcript of Annual Environmental Report 2009 PDM Limited, IPPC Register … · 2014. 12. 16. · 2.3. Schedule...

  • 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

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    CONTENTS

    Section Page No

    10. ENVIRONMENTAL LIABILITIES INSURANCE COVER.............................................. 44

    APPENDIX A - ISO 14001 CERTIFICATE

    APPENDIX B - COMPLETED PRTR WORKSHEETS

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    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.

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    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

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    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.

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    Figure 2.1 - PDM Limited Organisation Chart

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    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

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    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

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    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.

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    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

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    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:

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    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.

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    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:

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    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:

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    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:

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    • 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.

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    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

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    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.

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    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.

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    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