ANNUAL ENVIRONMENTAL REPORT (AER) 2008

Tel: 353 1 276 1428 Fax: 353 1 276 1561 Email: [email protected]

www.enviro-consult.com

Registered Office as above. Registered Number 243 412

ANNUAL ENVIRONMENTAL REPORT

(AER) 2008

For

P. Carney Ltd.,

Crossakiel, Kells, Co. Meath

IPPC Licence Number: P0402-02

(EEC Ltd. Document Number 1123-01 v2.00)

IPPC Licence Ref. P0402-2: P. Carney Ltd. Annual Environmental Report 2008

Environmental Efficiency Consultants (Ire) Ltd 2

Document no. 1123-01 v2.00

QF 1. v2 Document Lead Sheet

Document Title Annual Environmental Review (AER) 2008 (IPPC Licence Ref. P0402-2)

Project No. 1123-00 Document No. 1123-00 v2.00 Client P. Carney Ltd. Address Crossakiel, Kells, Co. Meath

Signed for and on behalf of Issue Status Date Author Environmental

Efficiency Client

2.00 Approved 18/05/2009 RnD

Where it is a requirement that this report be issued to a regulatory or other authority, then the client should sign the appropriate place in the above table and, unless specifically agreed in writing to the contrary, forward copies to the appropriate authority (e.g. EPA).

EEC Project Manager: Bob Sutcliffe, CEng, MIMechE

EEC Document Author: Róisín Ní Dhubhda B.Sc., M.Sc., AIEMA

Conditions relating to the issue of this report:

1. No alteration to this report by third parties is permitted

2. Where this report is reproduced, it shall only be reproduced in full.

3. Reports remain the property of Environmental & Efficiency Consultants

(Ireland) Limited until paid for in full.




TABLE OF CONTENTS

1 Introduction ......................................................................................................... 5 2 Company Information ........................................................................................ 6 3 Copy of the Company Environmental Policy ................................................... 7 4 Site Description.................................................................................................... 8 4.1 Company Profile ............................................................................................8 4.2 Description of Equipment ..............................................................................8 4.3 Manufacturing Process ...................................................................................9

5 Summary of Emissions...................................................................................... 10 5.1 Emissions from Storm Water .......................................................................10 5.2 Emissions to Atmosphere.............................................................................14

6 Waste Management........................................................................................... 17 7 Resource Consumption ..................................................................................... 18 7.1 Water Consumption......................................................................................18 7.2 Energy Consumption....................................................................................19 7.3 Environmental Incidents and Complaints ....................................................19

8 Environmental Management of Activity......................................................... 20 8.1 Report on Environmental Objectives and targets for 2008 ..........................20

9 Licence Specific Reports (IPPC licence PO402-02) ....................................... 30 9.1 Pollution Emissions Register (PER) 2008 ...................................................30 9.2 Determine PERL for site ..............................................................................30 9.3 PER Proposal 2008.......................................................................................32 9.4 Noise Monitoring Report 2008 ....................................................................32 9.5 Bund Integrity ..............................................................................................32 9.6 Tank and pipeline testing report...................................................................32 9.7 Energy Efficiency Audit Report...................................................................33 9.8 Raw Materials Assessment...........................................................................33 9.9 Water minimisation study ............................................................................33 9.10 Environmental Liabilities and financial provisions .....................................34

Figure 5-1: pH Storm Water Results (2005-2008).......................................................11 Figure 5-2: COD Surface Water Results (2005-2008).................................................12 Figure 5-3: Aluminium Storm Water Results (2005-2008) .........................................12 Figure 5-4: Copper Surface Water Results (2005-2008) Note 1 .....................................13 Figure 5-5: Lead Surface Water Results (2004-2008) Note 2 .........................................13

Table 2-1: AER Content.................................................................................................5 Table 2-1 Company details ............................................................................................6 Table 2-2 Summary of IPC licence ................................................................................6 Table 5-1 Parameters and Monitoring Schedule (licence number: P0402-02) ............10 Table 5-2 Emissions to Storm Water – Monitoring results (2005-2008) ...............11 Table 5-3 Air Monitoring Programme A2-1 (IPPC licence PO402-02) ......................15 Table 5-4 Monitoring Results 2008 from Emission Stack A2-1 .............................16 Table 6-1 Waste Generation during 2008 ................................................................17 Table 6-2 Summary of wastes generated in 2008 ....................................................18




Table 7-0-1 Energy Consumption for 2007-2008:.......................................................19 Table 8-1 Report on Objectives and targets for 2008 ..................................................21 Table 8-2 Objectives and Targets for 2009 ..............................................................23 Table 9-1 PER 2008 .....................................................................................................31 Table 9-2 Environmental liabilities..............................................................................34

Appendix 1 Copy of Certificates of Analysis – Storm water 2008 .........................36 Appendix 2 Copy of Certificates of Analysis – Air Monitoring 2008.....................39 Appendix 3 Copy of Dioxin Monitoring Report – May 2008 .................................44 Appendix 4 Copy of Dioxin Monitoring Report – September 2008........................50 Appendix 5 Tank and pipeline inspection report .....................................................56 Appendix 6 Noise Monitoring Report 2008 ............................................................58 Appendix 7 Energy Audit Report Summary............................................................59 Appendix 8 Emergency Response Plan ...................................................................60 Appendix 9 Accident Prevention Policy..................................................................61




1 Introduction

P. Carney Ltd was originally licensed by the Agency in April 1999 (Licence No. 402).

However, to accommodate changes in regulations and the installation of an abatement

system, the EPA required the company to request a review. A new licence was

granted by the Agency in August 2006 (P0402-02).

As laid out in Schedule D of IPPC Licence P0402-02, Table 2-1 shows the content

that has to be included in P. Carney Ltd. Annual Environmental Report (AER).

Table 2-1: AER Content

AER Content

• Emissions from the installation.

• Waste management record.

• Resource consumption summary.

• Complaints summary.

• Schedule of Environmental Objectives and Targets.

• Environmental Management Programme – report for previous year.

• Environmental Management Programme – proposal for current year.

• Pollution Emission Register – report for previous year.

• Pollution Emission Register – proposal for current year.

• Noise monitoring report summary.

• Ambient monitoring summary.

• Tank and pipeline testing and inspection report.

• Reported incidents summary.

• Energy efficiency audit report summary.

• Report on the assessment of the efficiency of use of raw materials in processes

and the reduction in waste generated.

• Statement of measures in relation to prevention of environmental damage and

remedial actions (Environmental Liabilities).

• Any other items specified by the Agency.




2 Company Information

Table 2-1 Company details

Company P. Carney Ltd

Address Crossakiel,

Kells.

County / City Co. Meath

Business Manufacturers of Aluminium Ingot,

Copper Granules, and Aluminium

Granules

Employees 36

Contact Name Mr. Declan Clarke

Position Company Manager

Telephone 046 9243634

Fax 046 9243916

Email [email protected]

IPPC Registration Number P0402-02

Table 2-2 Summary of IPC licence

IP(P)C Licence Reg: No. Period

402 (IPC licence) 30/4/1999 – 30/4/2006

PO402-02 (IPPC licence) 30/4/2006 - present




3 Copy of the Company Environmental Policy




4 Site Description

4.1 Company Profile

P. Carney Ltd is located on a site in the village of Crossakiel, Co. Meath,

approximately 9 km west of Kells. The company employs 36 people in total and

normally operates on a 5 day week schedule.

P. Carney Ltd is an Irish company established in 1964 and originally was a metal

trader that took in various types scrap metal. The main site process is taking in

aluminium and processing it into aluminium ingots for use in the automotive industry.

There is also a further side to the business that produces copper and aluminium

granules from copper and aluminium cables. The company falls under Class 3.4.2 of

the first schedule of the Protection of the Environment Act, 2003:-

“The production, recovery or processing of non-ferrous metals, their compounds or

other alloys including antimony, arsenic, beryllium, chromium, lead, magnesium,

manganese, phosphorus, selenium, cadmium or mercury, by thermal, chemical or

electrolytic means in installations with a batch capacity exceeding 0.5 tonnes, not

included in paragraph 3.4.1”.

P. Carney Ltd is a TS 16949 (automotive standard) and an ISO 9002 approved

company. The two main processes undertaken onsite comprise the production of the

following:

1. Aluminium Ingots, and

2. Aluminium and Copper Granules.

The company is committed to continuous improvement, which is the core of the

environmental management programme currently in operation at the facility.

4.2 Description of Equipment

The main pieces of equipment are as follows:

• Furnacing equipment with loading and casting machine equipment

• On site weighing facilities

• 3 no. complete granulation systems




• HGVs, trailers, skips, bins etc for transportation of material

• Forklifts and materials handling equipment

4.3 Manufacturing Process

The company is involved in the manufacture of aluminium ingots for the automotive

industry and the production of copper and aluminium granules.

A summary of the manufacturing process is given below:

High End Quality Scrap

Aluminium and Various Cables

Aluminium (sorted by quality)

Copper and Aluminium Cable

Copper Cable

Aluminium Cable

Furnace

Aluminium Ingot

Granulating

Process

Plastic/Rubber

Copper Granules

Aluminium Granules

Quality Control

Aluminium Ingot Product

Copper Granules Product

Aluminium Granules Product

Sold to horse arenas

Client




5 Summary of Emissions

The company has the following licensed emissions:

� Emissions to Surface Water

� Emissions to Atmosphere

� Waste Emissions

5.1 Emissions from Storm Water

Emission from Storm Water, monitoring programme

Under Schedule C.2.3 of the IPPC Licence P0402-02, Storm Water Emission

monitoring is required. The monitoring schedule for emissions to storm water is

provided in Table 5-1 below:

Table 5-1 Parameters and Monitoring Schedule (licence number: P0402-02)

Parameter Monitoring Frequency Analysis Method / Technique

COD Bi-annually Standard Method

Aluminium Bi-annually Standard Method

Copper Bi-annually Standard Method

Visual Inspection Weekly Sample and examine for colour

and odour

Emission from storm water, monitoring results

Analysis of emissions to surface water is carried out by Analytical Services and

Environmental Projects (ASEP), Queen’s University, Belfast on the 16th April 2008

and the 29th September 2008. A summary of monitoring results for 2008 is provided

in Table 5-2 along with results for the four previous years. There are no ELVs for

storm water emissions, however results were examined in the context of the Urban

Wastewater Treatment Regulations (S.I. No. 254 of 2001) 2001 and the Water Quality

(Dangerous Substances) Regulations, 2001. No chemical parameter exceeded the

specified limits of these regulations during 2008. Certificates of analysis are provided

in Appendix 1 of this report.




Table 5-2 Emissions to Storm Water – Monitoring results (2005-2008)

Parameters pH COD

(mg/l)

Aluminium

(ppm)

Copper

(ppm)

Lead

(ppm)

Temp

(0C)

2005 7.32 18 0.41 0.062 0.031 N/A

2006 7.4 8 0.01 0.02 0.04 N/A

2006 7.4 4 0.04 0.04 <0.01 6.0

2007 7.7 14 0.02 <0.01 <0.01 20.2

2007 7.0 19 0.29 0.05 0.11 22.8

2008 7.0 18 0.01 0.02 <0.01 21.4

2008 7.0 1.0 0.04 0.03 <0.01 20.8

N/A – Not available The pH readings for the storm water samples are relatively constant and within the

recommended pH 6-9 limit range.

pH Value 2005-2008

7.37.4 7.4

7.7

7 7 7

6.6

6.8

7

7.2

7.4

7.6

7.8

2005 2006 2006 2007 2007 2008 2008

Year

pH Value

Figure 5-1: pH Storm Water Results (2005-2008)

There are no ELVs for storm water emissions. The COD level monitored in April

2008 was similar to 2007 however there was a significant decrease in COD levels as

determined by the September 2008 result. Nonetheless, levels remain within the

levels specified in Urban Wastewater Treatment Regulations (S.I. No. 254 of 2001)

2001.




COD

18

8

4

14

1918

1

0

5

10

15

20

2005 2006 2006 2007 2007 2008 2008

Year

COD Value (mg/l)

Figure 5-2: COD Surface Water Results (2005-2008)

Aluminium

0.41

0.010.04 0.02

0.29

0.010.04

0

0.1

0.2

0.3

0.4

0.5

2005 2006 2006 2007 2007 2008 2008

Year

Al Value (ppm)

Figure 5-3: Aluminium Storm Water Results (2005-2008)

Copper level recording from the second monitoring half of 2008 demonstrated a slight

increase on 2008 first half levels. Results remain within the threshold of 0.05 mg/l as

specified under the Water Quality (Dangerous Substances) Regulations, 2001.




Copper

0

0.02

0.04

0.06

0.08

2005 2006 2006 2007 2007 2008 2008

Year

Cu Value (ppm)

Figure 5-4: Copper Surface Water Results (2005-2008)

Note 1

Note 1 – The value for first sample of 2007 is <0.01ppm

There are no ELVs for storm water emissions. Lead levels in the storm water

monitored during 2008 were <0.01 and within the environmental quality standards

(EQS) for surface waters.

Lead

0

0.02

0.04

0.06

0.08

0.1

0.12

2005 2006 2006 2007 2007 2008 2008

Year

Pb Value (ppm)

Figure 5-5: Lead Surface Water Results (2004-2008)

Note 2

Note 2

Lead values which are not denoted in the graph model are values of <0.01ppm.

2008 values for lead (Pb) are both less than 0.01ppm as indicated in Table 5-2.




Temperature

20.2

22.8

21.4

20.8

18

19

20

21

22

23

2007 2007 2008 2008

Year

Temperature Value

(Celsius)

2007 temperature values are given for comparative purposes only. Temperature values

for 2008 are all within the EPA recommended values of 6-9 pH.

5.2 Emissions to Atmosphere

Emissions to Atmosphere -monitoring programme

In accordance with Schedule C.1.2 of the IPPC Licence, monitoring of emissions to

atmosphere (A2-1) is required for the following parameters:

1. Fluorides (as HF)

2. Chlorine

3. Chlorides

4. Sulphur dioxide (as SO2)

5. Particulates

6. Dioxins

7. NOx

8. CO

A summary of the air monitoring programmes is in Table 5-3 and a summary of the

results and relevant ELVs are given in Table 5-4.




Table 5-3 Air Monitoring Programme A2-1 (IPPC licence PO402-02)

Emission point

reference

Parameters Monitoring

Frequency

Volumes &

Concentrations

Licensed Volume

Particulates Continuously 50 mg/m3

Chlorides (as HCl) Biannually 30 mg/m3

Chlorine (as Cl2) Biannually 5 mg/m3

Fluorides (as HF) Biannually 5 mg/m3

Sulphur dioxide (as SO2) Biannually 350 mg/m3

Dioxins Biannually 0.5 ng I-TEQ/Nm3

NOx Biannually Note 1

A2-1

CO Quarterly Note 1

Note 1: Not Specified

Emissions to atmosphere – Monitoring results

Monitoring on site was carried out during 2008 by ASEP C/O Queens University,

Belfast. The results for 2008 are summarised in Table 5-4. As can be seen from the

results below, none of the emission limit values (ELV) were breached in 2008.

Monitoring reports are provided in Appendix 2 of this report. Dioxin analysis of

emission point A2-1 was carried out in April 2008 and September 2008. The dioxin

level was 0.048 ng TEQ/Nm3 (April 2008) and 0.011 ng TEQ/Nm3 (September 2008).

The monitoring reports are attached in Appendix 3 and Appendix 4.




Table 5-4 Monitoring Results 2008 from Emission Stack A2-1

April 2008 September 2008 Parameter ELV

Run 1 Run 2 Run 1 Run 2

Flue Temperature (0C) - 93 94 95 97

Stack Flow (m3/h) 29,000 23014 23549 21718 22254

Particulate

(mg/m3)

50 26.9 9.94 10.48 3.41

Mass Flow (kg/h) - 0.619 0.117 0.228 0.076

Oxides of Nitrogen (mg/m3) - <5 <5 6 11

Sulphur Dioxide (mg/m3) 350 <5 <5 <5 <5

Carbon Monoxide (mg/m3) - <5 <5 <5 <5

Hydrogen Chloride (mg/m3) 30 <5 <5 <5 <5

Hydrogen Fluoride (mg/m3) - <1 <1 <1 <1

Chlorine (mg/m3) 5 <1 <1 <1 <1

Copper (mg/m3) - <0.05 <0.05 <0.05 <0.05

Titanium (mg/m3) - <0.05 <0.05 <0.05 <0.05

IPPC Licence Ref. P0402-2: P. Carney Ltd.

Annual Environmental Report 2008



6 Waste Management

A summary of all wastes generated during 2008 are summarised in Table 6-1 below.

Table 6-1 W

aste Generation during 2008

Waste

EWC No.

Hazardous

Annual

Quantity

(tonnes) 2008

Current Disposal

Waste

Contractor

Destination of

Waste – Onsite or

offsite

Permit /Licence number

of waste contractor

Oil

13 01 01*

Yes

0 Litres

Not applicable in 2008

Enva Portlaoise

Off site

WCP MH2001/107D

Plastic and

Plastic Dust

19 12 04

No

203.860 tonnes D1 Deposit on, in or under

land.

Green Energy

Recycling

Off site

WCP OY08058501

Timber

17 02 01

No

66.440 tonnes

Recycling

R3 Recycling/reclamation of

organic substances which are

not used as solvents

Greenstar

Doherty Waste

Management Ltd

Off site

WCP/MH/2005/63B

WP 2006/48b

General

Waste

20 03 01

No

91.200 tonnes

D1 Deposit on, in or under

land.

Green Energy

Recycling

Off site

WCP OY08058501




A breakdown of the amount of waste disposed and recovered is provided in Table 6-2

below.

Table 6-2 Summary of wastes generated in 2008

Quantity of wastes Quantity of wastes

disposed on site

Quantity of wastes

disposed off-site

Quantity of waste

recovered off-site

Non-hazardous

wastes

0 361.50 tonnes 66.44 tonnes

Hazardous wastes 0 - -

7 Resource Consumption

This section of the report details the total annual usage levels of water and energy.

7.1 Water Consumption

Water consumption for 2008 is detailed in Table 7-1 below. Water usage primarily

comes from the municipal supply though groundwater from the on site well is used. P.

Carney Ltd. installed metering of groundwater in mid-2007, therefore over the coming

3 years, water consumption will be carefully examined to assess consumption

volumes and determine where improved conservation measures can be applied.

Table 7-1 Water Consumption 2008

Year 2008

Water

Reading

m3

On-site

ground

851

On-site

surface

-

Municipal

supply

1225

P. Carney Ltd. Annual Environmental Report 2008


Document No. 1012-01 v1.00

7.2 Energy Consumption

Energy is provided by the following sources at the company namely:

� Oil

� Electricity

� Propane gas

A summary of energy consumption in 2008, in terms of the above, is shown in the

below.

Table 7-0-1 Energy Consumption for 2007-2008:

Source Consumption 2007 Consumption 2008 Units

Oil 901,249 702,763 Litre

Electricity 611,011 566,100 KWh

Propane gas 4,850 4,120 Litre

In 2008, energy consumption decreased significantly at the P. Carney facility. In

2008, oil consumption decreased by 22% whilst propane gas consumption decreased

by 15% over the same period. Electricity consumption at the facility was reduced by

over 7% during 2008, based on the consumption figures of 2007.

7.3 Environmental Incidents and Complaints

Reported Incidents Summary

There were no reported incidents during 2008.

Complaints Summary

There were no complaints from any member of the public or the Local Authority or

EPA during 2008 in relation to environmental matters at the site.




8 Environmental Management of Activity

The company has operated in accordance with the Environmental Management

System (EMS) since 1999. The EMS was updated in 2007 to reflect the new IPPC

licence requirements. As part of EMS, an Environmental Management Programme

(EMP) was formulated, outlining specific environmental objectives and targets for the

company. This section of this report summarises the objectives and targets proposed

for the coming year, 2009. A progress report on the EMP objectives and targets

implemented during 2008 is also provided. The schedule of environmental objectives

and targets has been established taking into account instruction within Condition 2.2.2

of the IPPC Licence.

8.1 Report on Environmental Objectives and targets for 2008

A report on the implementation of the 2008 environmental objectives and targets is

provided in Table 8-1.

P. Carney Ltd.


Environmental Efficiency Consultants (Ire) Ltd

21


Table 8-1 Report on Objectives and targets for 2008

Objective

reference No.

Objective

Target/Outcome

Achievem

ent / Additional Comment

1

Water Usage: Monitor

groundwater well abstraction

Monitoring of groundwater abstraction was

ongoing throughout 2008

A meter was installed onsite to monitor

volume of water abstraction from well and

water consumption at the facility

continues to be monitored.

2

Noise: Undertake noise survey in

compliance with licence

requirements

An annual environmental noise survey was

completed in 2008 in compliance with the

IPPC licence.

This report determined that noise levels at

the site were within the specified limits of

the licence, and in accordance with the

recommended levels as specified by the

EPA. This report is included in this AER.

3

Energy efficiency and resource

use: Review energy audit

undertaken at facility in 2007 and

oversee implementation of

recommendations to improve

energy efficiency at the facility e.g.

electricity use.

Continuing assessment of energy and

resources use throughout the facility.

Energy consumption fell significantly in

2008 at the P. Carney facility.

In 2008, oil consumption decreased by

22% whilst propane gas consumption

decreased by 15% over the same period.

4

Update MSDS relating to

hazardous substances in use onsite

e.g. fuels

MSDS were sought for all substances used

onsite.

All MSDS are kept on file in a specified

location in the event of an emergency.

P. Carney Ltd.



22


Objective

reference No.

Objective

Target/Outcome

Achievem

ent / Additional Comment

5

Improve environmental awareness

amongst staff

Training of staff has been implemented

during 2008

Continue updated training of staff and

ensure all new personnel receive training

upon commencement.

6

Storm water: Continue to conduct

a visual examination of the on site

storm water discharge on a daily

basis in accordance with licence.

Undertaken on a regular basis and is

working successfully.

There have been no incidents reported at

the facility and this system is proving

successful.

7

Undertake a Gap Analysis study to

assess current oil separator on site

with reference to I.S EN 858-

2:2003

Review of the current existing system has

been undertaken by the facility and a report

is pending.

Currently under review

8

Hydro-geological assessment: On

approval of hydro-geological

assessment by the Agency, the

proposal shall be implemented

Proposal submitted to EPA authorities and

P. Carney currently awaiting response.

Currently under review


Tel: 353 1 276 1428 Fax: 353 1 276 1561 Email: [email protected]

www.enviro-consult.com

Registered Office as above. Registered Number 243 412

Table 8-2 Objectives and Targets for 2009

Objective

No. Objective Target Date

OT1 Daily storm water inspection of site Ongoing

OT2

Bund integrity test to be undertaken in 2009 under

Condition 3.6.5 of the licence which stipulates such

testing every 3 years.

September 2009

OT3

Inspection and testing of oil tank and transporting

pipelines to be undertaken in 2009 under Condition

8.3.3 of the licence.

September 2009

OT4 Staff environmental training September 2009

OT5

Annual Noise monitoring to be undertaken under

condition 6.13.1 of the licence in accordance with

the EPA guidance document ‘Environmental Noise

Survey Guidance Document’

October 2009

OT6 Monitoring of the groundwater abstraction December 2009

QT7 Review MSDS pertaining to all hazardous materials

used onsite December 2009

OT8 Review of procedures to assess the efficient

operations of the facilities flue gas abatement system December 2009




Objective 1

Objective Number OT1

Objective Title Undertake a visual inspection of storm water discharge daily

Target Ongoing

Responsibility Environmental Manager

Plan

Means by which target is to achieved Who Target

• Undertake an examination of storm water discharge daily

to ensure the discharge is free from contamination

Environmental

Manager Daily/ Ongoing

Objective 2


Objective Title Undertake a Bund Integrity test in accordance with Condition 3.6.5 of the IPPC licence

Target June 2009


Plan


• Arrange for a bund integrity test to be completed on site in

compliance with IPPC Licence condition 3.6.5

Environmental

Manager September

• Review results to ensure compliance with IPPC licence

conditions

Environmental

Manager September

• *Should the existing bunds be determined to be in breach of

licence conditions, remediation works shall be undertaken in

accordance with the recommendations of the report without

delay. Upon completion of these works, a follow up bund

integrity test shall be undertaken.

Environmental

Manager September (*if required)

• Insert copy of the Bund Integrity Assessment Report in

AER 2010 in accordance with licence conditions

Environmental

Manager March 2010




Objective 3


Objective Title Undertake an inspection and testing of onsite oil tanks and transporting pipelines in accordance with Condition 8.3.3 of the IPPC licence

Target July 2009


Plan


• Arrange for an assessment and testing of all onsite oil tanks

and associated transporting pipelines in accordance with

Condition 8.3.3 of the IPPC licence

Environmental

Manager September


conditions

Environmental

Manager September

• *Should the existing onsite oil tanks and associated

transporting pipelines be determined to be in breach of

licence conditions, remediation works shall be undertaken in

accordance with the recommendations of the report without

delay. Upon completion of these works, a follow up

assessment shall be undertaken.

Environmental

Manager September (*if required)

• Insert copy of the report in AER 2010 in accordance with

licence conditions

Environmental

Manager March 2010




Objective 4


Objective Title Improve environmental awareness amongst staff

Target September 2009


Plan


• All staff from management level down to undergo and

update environmental training

Environmental

Manager August 2009

• Ensure all employees are aware of the impacts from

hazardous materials spills on site, and receive appropriate

training on hazardous materials spills or leakages, in

addition to non-hazardous material accidents.

Environmental

Manager August 2009

• All employees should be familiar with the Emergency

Response Procedure and of the appropriate actions to take in

the event of an emergency, and of the relevant emergency

and statutory bodies to contact if such a situation arises.

Environmental

Manager September 2009

• Ensure the Emergency Response Procedure is updated

includes the correct contact details of the EPA (both a

contact number for normal office hours and out of

office/emergency hours). Also include provisions for

minimising the effects of a spill/leakage on the environment

e.g. inspect all spill kits onsite and order new kits if

required.

Environmental

Manager September 2009




Objective 5


Objective Title Undertake Environmental Noise Survey at the facility

Target October 2009

Responsibility Environmental Manager to contact Environmental Efficiency Consultants Ltd

Plan


• Arrange for environmental noise survey to be completed on

site in compliance with IPPC Licence condition 6.13

Environmental

Manager /

EEC

September 2009


conditions

Environmental

Manager /

EEC

October2009

• Should noise levels be determined to breach licence

conditions, a review of procedures at the facility should be

implemented to address the issue without delay

Company

Director /

Environmental

Manager

October 2009

(*if licence conditions are breached)

• Insert Environmental Noise Report (2009) in AER 2010

Environmental

Manager /

EEC

March 2010




Objective 6


Objective Title Water Usage: Maintain a record of the volume of water abstraction (m3) from the groundwater well on site

Target December 2009


Plan


• Keep a record of the quantity m3. Environmental Manager Ongoing

• Compare the volume of water usage for with 2008 figures Environmental Manager

December

2009

• Assess quantities of water usage at the facility and

implement a programme to improve water efficiency onsite

Environmental Manager

December

2009

• AER 2010 to report on water consumption at the facility

EEC March 2010

Objective 7


Objective Title Update Material Safety Data Sheets (MSDS) for hazardous substances used onsite e.g. fuel



Plan


• Review all substances used onsite and assess whether

MSDS are available for each

Environmental Manager October

2009





• Ensure all MSDS onsite are up to date. These should be

reviewed and updated annually.

Environmental Manager November

2009

• Keep all MSDS on file and ensure all staff are aware of

location in the event of an emergency.

Environmental Manager December

2009

Objective 8


Objective Title Review of procedures to assess the efficient operations of the facilities flue gas abatement system



Plan


• Review of procedures to assess operation and effectiveness

of the facilities flue gas abatement system

Environmental

Manager June 2009

• Based on the review, the facility to update all procedures

incl. operational & maintenance, to maintain the most

efficient operations of the facilities abatement system

Environmental

Manager August 2009

• Implement any changed or new procedures and provide the

necessary staff training where required

Environmental

Manager

August / September 2009

• Continue with monitoring and recording as stated in the

IPPC licence conditions

Environmental

Manager Ongoing




9 Licence Specific Reports (IPPC licence PO402-02)

9.1 Pollution Emissions Register (PER) 2008

In accordance with Condition 6.15 Pollution Emissions Register (PER): “The licensee shall

prepare and maintain a PER for the site. The substances to be included in the PER shall be

agreed by the agency each year by reference to the lists specified in the Agency’s’ AER

Guidance Notes. The PER shall be prepared in accordance with any relevant guidelines

issued by the Agency and shall be submitted as part of the AER”.

9.2 Determine PERL for site

Having examined the substances used on site and reviewed the MSDSs for each substance

and compared them with the PERL, the following are the substances are included in the PER.

� Copper – present in copper cables

� Lead – present in cables. Lead containing cables are sometimes present in a

mixed batch of cables purchased. The lead containing cables are segregated for

sale. They are not subject to processing on site.

� Titanium – titanium is added to various grades of aluminium.

P. Carney Ltd.



31


Table 9-1 PER 2008

Facility Name

P. Carney Ltd.

Register Number:

P0402-02

Reporting Period

1ST Jan 2008 to 31st December 2008

Production Units

Aluminium alloy ingot and copper granules

Employees Number:

36

Pollution Emissions Register

Pollutant

CAS no.

Input (kg)

Gross

Usage

Air (kg)

MOM

Liquid

Effluent Kg

(storm

water)

Note 1

MOM

Waste

(kg)

MOM

Product

Kg

MOM

Recovery

Treated

Un-

accounted

Copper Cu

7440-50-8

448,000

448,000

- -

0.286

C

- -

477,999.71

- -

- -

Cable

containing

Lead

7439-92-1

13,400

13,400

- -

<0.114

C

- -

13,399.88

- -

- -

Titanium

7440-32-6

3,240

3,240

Note 2

- -

C

- -

-

- -

- C: Calculation

Note 1: Based on Met Éireann figures for annual rainfall (942.6mm rainfall/yr) and total surface area of site (1.214 ha or 1,2140.5sqm)

Note 2: Not recorded, trace quantities may be present.




9.3 PER Proposal 2008

It is proposed that during 2009 a review of all materials used on site will be carried

out to ensure that any PERL substances used on site are included. As per 2008 the

following substances will be included in the PER:

� Copper

� Lead

� Titanium

9.4 Noise Monitoring Report 2008

Noise monitoring is required to be undertaken annually under Condition 6.13 of the

licence. A noise monitoring assessment and report was completed by Environmental

Efficiency Consultants (Ire) Ltd and is attached in Appendix 6. The noise monitoring

report determined that P. Carney is not in breach of its IPPC licence as all noise levels

were within the permitted levels.

9.5 Bund Integrity

A bund integrity test was carried out by Environmental Efficiency Consultants in July

2006 and was passed. In accordance with condition 3.6.5 of the licence:

‘The integrity and water tightness of all the bunded structures, tanks and containers

and their resistance to penetration by water or other materials stored therein shall be

tested and demonstrated by the licensee at least once every three years. This testing

shall be carried out in accordance with any guidance published by the Agency’.

The latest bund inspection report carried out at the facility in 2006 and was submitted

to the Agency previously. The next Bund integrity test is required to be undertaken in

2009 in accordance with Condition 3.6.5 of the licence and will be included into the

AER 2010.

9.6 Tank and pipeline testing report

Inspection and testing of oil transporting pipelines was carried out by Cathal Usher,

Plumbing Contractor. Condition 8.3.3 of the licence requires that “The licensee shall




undertake a programme of testing and inspection of pipelines to ensure that all oil

transporting pipes are tested at least once every three years”. The most recent testing

and inspection was undertaken in August 2006 and the associated inspection report is

available in Appendix 5. In accordance with the licence conditions, testing should

once again be undertaken in 2009 and will be included into the AER 2010.

9.7 Energy Efficiency Audit Report

Environmental Efficiency Consultants have been contracted by P. Carney Ltd. to

carry out an energy audit at their site and premises. This is in accordance with

Condition 7.1 of the IPPC licence. See to view Appendix 7 summary report.

9.8 Raw Materials Assessment

In 2007, an assessment of raw materials was undertaken for P. Carney Ltd by

Environmental Efficiency Consultants to comply with Condition 7.4 of the licence.

This report identified areas where significant raw materials are used / wasted and their

associated waste streams; and gave recommendations in relation to the most

significant issues relating to the site.

With relation to raw materials used onsite, the raw materials are predetermined by the

quantities available for processing, available markets and production capacity of the

plant. As such these raw materials can not be changed. Recyclable materials are

stored separately from material being sent to landfill. The objectives and targets for

2008 has included assessing certain raw materials used onsite with the objective of

reducing the use of raw materials use i.e. water usage. This monitoring programme is

ongoing at the facility.

9.9 Water minimisation study

In compliance with Condition 7.3, a water minimisation study was carried out in

2007. As part of the water minimisation programme, it was recommended that the

water be metered. This was undertaken in 2007 and as part of the objectives and

targets, the water use onsite will continue to be monitored in order to determine use




and where if any, reductions can be made or improved conservation methods can be

applied. This monitoring programme is ongoing at the facility.

9.10 Environmental Liabilities and financial provisions

A statement of measures in relation to the prevention of environmental damage and

remedial actions (environmental liabilities) is provided in Table 9-2:

Table 9-2 Environmental liabilities

Measures Progress to

date

Environmental Objectives

• Oversee implementation of Objectives and Targets 2009

• Keep a record (noting quantity m3) of all abstractions from groundwater

well on site

• Ensure all the correct waste documentation is present on site

• Undertake bund integrity testing in 2009 in accordance with licence

conditions

• Assess study regarding the current oil separator onsite in with reference to

I.S EN 858-2:2003

• Undertake inspection and testing of oil pipelines in accordance with licence

condition 8.3.3

• Upon response/approval from EPA, carry out hydro-geological assessment

of the site in accordance with Condition 6.12 of the IPPC licence on

confirmation by the EPA to proceed according to proposal Doc. no. 861-14

v2.01.

• Carry out annual noise monitoring survey in accordance with licence

conditions

• Ensure Compliance with Condition 9: Accident Prevention and Emergency

Response

• Continue with the implementation of the updated Environmental

Management System in line with the existing Environmental Management

System.

Ongoing




Measures Progress to

date

Training

� All staff and new employees are provided with appropriate training

relevant to the individual’s particular job description.

� Records of training are kept and updated as appropriate

Ongoing

Equipment maintenance

� Ensure equipment in use is regularly checked in order to identify and

remedy any faults, which may compromise the health and safety of staff

or have a negative impact on the environment.

Ongoing

Environmental Monitoring

� Continue to monitor emissions to air as required by the IPPC licence

(Reg. No PO.402-02)

� Every effort is made to ensure the emissions are within emission limit

values. Investigations into non-conformances (if any) and ensure that

corrective actions are put in place if emission limit values are exceeded.

Ongoing




Appendix 1 Copy of Certificates of Analysis – Storm water 2008

This page is left intentionally blank




P CARNEY Crossakiel Kells Co Meath

A Report To P Carney on the analysis of a water sample.

Our Ref. 08ap053A

Your Ref. Water sample

Sample description 1 x 1l water sample in 1L plastic bottle

Samples Dated -------

Analysis Requested Temp, pH, COD, Al, Cu, Pb

Samples Received 16-4-08

Samples received by Paul Cole

Analysis report Issued 13-5-08

ANALYSIS METHOD / PROCEDURE

The samples as supplied were analysed by meter for temperature by digital thermometer, pH, by HACH for Cod and by ICP for Al, Cu and Pb.

SPECIAL CONDITIONS None. The samples were analysed according to standard operating procedures. DISPOSAL OF SAMPLES

It is our normal policy that the samples will be disposed of two months after the report has been issued. CONTACTS The client should contact Mr. Trevor Sewell with any queries about the analysis report and Ms W McKinney about administration / invoices.

ANALYSIS RESULTS pH 7.0 COD mg/l 18 Temperature 0C 21.4 Al ppm 0.01 Cu ppm 0.02 Pb ppm < 0.01 Compiled By Approved By

-------------------------------- ------------------------- P. Cole R.A.Patrick Technical Director




P CARNEY Crossakiel Kells Co Meath

A Report To P Carney on the analysis of a water sample.

Our Ref. 08oct011

Your Ref. Water sample

Sample description 1 x 1l water sample in 1L plastic bottle

Samples Dated -------

Analysis Requested Temp, pH, COD, Al, Cu, Pb

Samples Received 29-9-08

Samples received by Paul Cole

Analysis report Issued 14-10-08

ANALYSIS METHOD / PROCEDURE

The samples as supplied were analysed by meter for temperature by digital thermometer, pH, by HACH for Cod and by ICP for Al, Cu and Pb.

SPECIAL CONDITIONS None. The samples were analysed according to standard operating procedures. DISPOSAL OF SAMPLES

It is our normal policy that the samples will be disposed of two months after the report has been issued. CONTACTS The client should contact Mr. Trevor Sewell with any queries about the analysis report and Ms W McKinney about administration / invoices.

ANALYSIS RESULTS pH 7.0 COD mg/l 1.0 Temperature 0C 20.8 Al ppm 0.04 Cu ppm 0.03 Pb ppm < 0.01 Compiled By Approved By

-------------------------------- ------------------------- P. Cole R.A.Patrick Technical Director




Appendix 2 Copy of Certificates of Analysis – Air Monitoring 2008





Declan Clarke P Carney Ltd. Crossakiel Kells Co. Meath Ireland

Emission Analysis from Stack A2-1 at P. Carney Ltd., Crossakiel.

Emissions from the Stack A2-1 at P. Carney Ltd., Crossakiel were monitored using the following procedures. Particulate: Gravimetric determination, using a BCURA probe under isokinetic conditions Oxides of Nitrogen )

Oxides of Sulphur ) Electrochemical determination using a Kane-May Flue Carbon monoxide ) Gas Analyser Hydrogen Chloride )

Hydrogen Fluoride ) Self indicating adsorption tubes Chlorine ) Sampling was carried out using ports in the stack accessible via a permanent platform. Results Concentrations are quoted under standard conditions: 273

0K, 1.013 kPa,

Particulate was collected on the same filter assembly from the port over a continuous period. Gaseous parameters were determined during the particulate monitoring. Monitoring was carried out on the 17th April 2008




Smelting Process: Run 1 Run 2 Sample Period: 07.45 – 08.15 08.20 – 08.50 Flue temperature: 93 0C 94 0C Stack Flow: 23014 m3/hr 23549 m3/hr

Particulate: 26.9 mg/m3 9.94 mg/m3

Mass Flow: 0.619 kg/hr 0.117 kg/hr Oxides of Nitrogen: < 5 mg/m3 < 5 mg/m3

Sulphur Dioxide: < 5 mg/m3 < 5 mg/m3 Carbon monoxide: < 5 mg/m3 < 5 mg/m3

Hydrogen Chloride: < 5 mg/m3 < 5 mg/m3

Hydrogen Fluoride: < 1 mg/m3 < 1 mg/m3 Chlorine: < 1 mg/m3 < 1 mg/m3 Copper: < 0.05mg/m3 < 0.05 mg/m3 Titanium: < 0.05 mg/m3 < 0.05 mg/m3

.

______________________ _____________________ Paul Cole Dr. Robin Patrick

Technical Director 11th July, 2008




Declan Clarke P Carney Ltd. Crossakiel Kells Co. Meath Ireland

Emission Analysis from Stack A2-1 at P. Carney Ltd., Crossakiel.

Emissions from the Stack A2-1 at P. Carney Ltd., Crossakiel were monitored using the following procedures. Particulate: Gravimetric determination, using a BCURA probe under isokinetic conditions Oxides of Nitrogen )

Oxides of Sulphur ) Electrochemical determination using a Kane-May Flue Carbon monoxide ) Gas Analyser Hydrogen Chloride )

Hydrogen Fluoride ) Self indicating adsorption tubes Chlorine ) Sampling was carried out using ports in the stack accessible via a permanent platform. Results Concentrations are quoted under standard conditions: 273

0K, 1.013 kPa,

Particulate was collected on the same filter assembly from the port over a continuous period. Gaseous parameters were determined during the particulate monitoring. Monitoring was carried out on the 29th September 2008




Smelting Process: Run 1 Run 2 Sample Period: 07.38 – 08.08 08.11 – 08.41 Flue temperature: 95 0C 97 0C Stack Flow: 21718 m3/hr 22254 m3/hr

Particulate: 10.48 mg/m3 3.41 mg/m3

Mass Flow: 0.228 kg/hr 0.076 kg/hr Oxides of Nitrogen: 6 mg/m3 11 mg/m3

Sulphur Dioxide: < 5 mg/m3 < 5 mg/m3 Carbon monoxide: < 5 mg/m3 < 5 mg/m3

Hydrogen Chloride: < 5 mg/m3 < 5 mg/m3

Hydrogen Fluoride: < 1 mg/m3 < 1 mg/m3 Chlorine: < 1 mg/m3 < 1 mg/m3 Copper: < 0.05mg/m3 < 0.05 mg/m3 Titanium: < 0.05 mg/m3 < 0.05 mg/m3

.

______________________ _____________________ Paul Cole Dr. Robin Patrick

Technical Director 4th December, 2008




Appendix 3 Copy of Dioxin Monitoring Report – May 2008





DIOXIN MONITORING

AT THE

CARNEY SMELTER

A Report to

P CARNEY

Crossakiel

Kells

Co Meath

April, 2008




1. Introduction

Polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans, commonly

referred to as dioxins and furans or simply as "dioxins" are produced as by-products

from various chemical manufacturing processes and from combustion processes

where chlorine is present. This group of compounds has a very high toxicity to human

health and consequently very low guideline values have been set for human exposure.

2. Toxic Equivalent Value (TEQ)

There are a great many different isomeric chlorinated species covered by the term

"dioxins". Of these, the most toxic is the 2,3,7,8 tetrachlorodibenzo-p-dioxin. In

relative terms, many other "dioxins" are much less toxic. The accepted convention is

to derive a total toxic equivalent value for any sample relative to the 2,3,7,8 TCDD

which is given a TEQ of unity. This is achieved by applying the relevant agreed toxic

equivalent factor to the concentration of each dioxin and furan species.

3. IPC Licensing

P. Carney operate an aluminium recovery plant at Crossakiel in County Meath. The

operation of the plant is covered by an IPC Licence issued by the Environmental

Protection Agency.

This report presents the results of a monitoring exercise carried out by ASEP in April,

2008

4. Sampling Protocol

Sampling was carried out using a sampling train, compliant with IS EN 1948, which

has been described in detail previously.

5. Sampling Programme

A sample was collected from the smelter at a point after the dust abatement system by

ASEP personnel over an 8 hour period on 14-15 April. Sample details are tabulated

below.




Table 1: Samples

Sampling Period Volume Nm3

23.50 – 07.50 3.105

The sample was delivered directly to the analytical laboratory by a member of staff

from ASEP.

6. Analysis

Analysis was carried out by Envirolab, a specialist "dioxin" laboratory, based in

Manchester. The analytical procedure, which has been detailed previously, involves a

complex extraction, clean-up and concentration programme, followed by multiple ion

high resolution gas chromatography - high resolution mass spectrometry, allied with

UK acceptance criteria (Chemosphere, 21, 999 1990). All laboratory work is

undertaken under fully documented QA/QC control, providing reproducible and

traceable results under the UK UKAS scheme.

7. Results

Results are tabulated below, giving the weights of the various isomers detected in the

samples, together with the toxic equivalent value (derived from NATO/CCMS Toxic

Equivalent Factors). These data were used in conjunction with sampling data (air

volume, temperature and atmospheric pressure) to derive concentrations of "dioxins"

expressed to the standard reference conditions of 273oK and 101.3kPa, dry gas.




Table 2: Dioxin/Furan Content of Stack Emission Samples

( ng total in sample as received)

Envirolab Ref. No 83612

ASEP Ref. No. PC1

2378-TCDD 0.009

Total TCDD 0.58

12378 PeCDD 0.041

Total PeCDD 0.083

123478-HxCDD 0.021

123678-HxCDD 0.042

123789-HxCDD 0.014

Total HxCDD 1.6

1234678-HpCDD 0.51

Total HpCDD 1.5

OCDD 0.37

2378-TCDF 0.014

Total TCDF 2.5

23478-PeCDF 0.16

12378 PeCDF 0.067

Total PeCDF 1.1

123478-HxCDF 0.071

123678-HxCDF 0.070

234678-HxCDF 0.052

123789-HxCDF 0.004

Total HxCDF 0.59

1234678-HpCDF 0.23

1234789-HpCDF 0.046

Total HpCDF < 0.01

OCDF 0.18

I-TEQ (max) 0.15

Note: Total refers to all isomers of the congener group.

ITEQ (max) calculated with “<” values at their reported limits.




8. Emission to Atmosphere

The emission data, corrected to normal temperature and pressure, dry gas is tabulated

below.

Table 3: Emissions to Atmosphere

Sample Volume

in Nm3

Oxygen

%

Dioxin

ng TEQ

Dioxin Emission

in ng TEQ/Nm3

PC1 3.105 20.7 0.15 0.048

No correction has been made for oxygen content.

9. Confidence Limits

The emission standards applicable to "dioxins" emissions push sampling and

analytical techniques to the limit. The difficulty of collecting representative samples,

allied to the complexity of the extraction process, work-up and analytical procedures

results in precision of the order of + 50% at best.

Where the levels recorded above for individual targets are at or below the limit of

detection, in applying the TEQ factors, the approach adopted is to take the “less than”

value as absolute i.e. the worse case.

In determining the final emission to atmosphere, the worse case approach has been

adopted in that no correction has been made for any apparatus blank and “less than”

values have been taken as absolute.

_____________________________________ R.A. Patrick BSc. PhD, FICI, CChem FRSC 22 May, 2008

Technical Director




Appendix 4 Copy of Dioxin Monitoring Report – September 2008





DIOXIN MONITORING

AT THE

CARNEY SMELTER

A Report to

P CARNEY

Crossakiel

Kells

Co Meath

September, 2008




1. Introduction

Polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans, commonly

referred to as dioxins and furans or simply as "dioxins" are produced as by-products

from various chemical manufacturing processes and from combustion processes

where chlorine is present. This group of compounds has a very high toxicity to human

health and consequently very low guideline values have been set for human exposure.

2. Toxic Equivalent Value (TEQ)

There are a great many different isomeric chlorinated species covered by the term

"dioxins". Of these, the most toxic is the 2,3,7,8 tetrachlorodibenzo-p-dioxin. In

relative terms, many other "dioxins" are much less toxic. The accepted convention is

to derive a total toxic equivalent value for any sample relative to the 2,3,7,8 TCDD

which is given a TEQ of unity. This is achieved by applying the relevant agreed toxic

equivalent factor to the concentration of each dioxin and furan species.

3. IPC Licensing

P. Carney operate an aluminium recovery plant at Crossakiel in County Meath. The

operation of the plant is covered by an IPC Licence issued by the Environmental

Protection Agency.

This report presents the results of a monitoring exercise carried out by ASEP in

September, 2008

4. Sampling Protocol

Sampling was carried out using a sampling train, compliant with IS EN 1948, which

has been described in detail previously.

5. Sampling Programme

A sample was collected from the smelter at a point after the dust abatement system by

ASEP personnel over an 8 hour period on 28 – 29 September, 2008. Sample details

are tabulated below.

Table 1: Samples

Sampling Period Volume Nm3

23.25 – 07.25 3.395




The sample was delivered directly to the analytical laboratory by a member of staff

from ASEP.

6. Analysis

Analysis was carried out by Envirolab, a specialist "dioxin" laboratory, based in

Manchester. The analytical procedure, which has been detailed previously, involves a

complex extraction, clean-up and concentration programme, followed by multiple ion

high resolution gas chromatography - high resolution mass spectrometry, allied with

UK acceptance criteria (Chemosphere, 21, 999 1990). All laboratory work is

undertaken under fully documented QA/QC control, providing reproducible and

traceable results under the UK UKAS scheme.

7. Results

Results are tabulated below, giving the weights of the various isomers detected in the

samples, together with the toxic equivalent value (derived from NATO/CCMS Toxic

Equivalent Factors). These data were used in conjunction with sampling data (air

volume, temperature and atmospheric pressure) to derive concentrations of "dioxins"

expressed to the standard reference conditions of 273oK and 101.3kPa, dry gas.




Table 2: Dioxin/Furan Content of Stack Emission Samples

( ng total in sample as received)

Envirolab Ref. No 92731

ASEP Ref. No. PC1

2378-TCDD 0.006

12378 PeCDD 0.020

123478-HxCDD 0.033

123678-HxCDD 0.031

123789-HxCDD 0.038

1234678-HpCDD 0.16

OCDD 0.093

2378-TCDF 0.023

23478-PeCDF 0.028

12378 PeCDF 0.020

123478-HxCDF 0.048

123678-HxCDF 0.040

234678-HxCDF 0.072

123789-HxCDF 0.044

1234678-HpCDF 0.23

1234789-HpCDF 0.023

OCDF 0.029

I-TEQ (max) 0.068

Note: ITEQ (max) calculated with “<” values at their reported limits.




8. Emission to Atmosphere

The emission data, corrected to normal temperature and pressure, dry gas is tabulated

below.

Table 3: Emissions to Atmosphere

Sample Volume

in Nm3

Oxygen

%

Dioxin

ng TEQ

Dioxin Emission

in ng TEQ/Nm3

PC1 6.00 20.7 0.07 0.011

No correction has been made for oxygen content.

9. Confidence Limits

The emission standards applicable to "dioxins" emissions push sampling and

analytical techniques to the limit. The difficulty of collecting representative samples,

allied to the complexity of the extraction process, work-up and analytical procedures

results in precision of the order of + 50% at best.

Where the levels recorded above for individual targets are at or below the limit of

detection, in applying the TEQ factors, the approach adopted is to take the “less than”

value as absolute i.e. the worse case.

In determining the final emission to atmosphere, the worse case approach has been

adopted in that no correction has been made for any apparatus blank and “less than”

values have been taken as absolute.

_____________________________________ R.A. Patrick BSc. PhD, FICI, CChem FRSC 9 January, 2009

Technical Director




Appendix 5 Tank and pipeline inspection report







Appendix 6 Noise Monitoring Report 2008


(To be inserted)





Appendix 7 Energy Audit Report Summary


(To be inserted)





Appendix 8 Emergency Response Plan


(To be inserted)





Appendix 9 Accident Prevention Policy


(To be inserted)


Documents

ANNUAL ENVIRONMENTAL REPORT (AER) 2008