ANNUAL ENVIRONMENTAL REPORT (AER) 2008 · ANNUAL ENVIRONMENTAL REPORT (AER) 2008 For P. Carney Ltd., Crossakiel, Kells, Co. Meath IPPC Licence Number: P0402-02 (EEC Ltd. Document

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

19 18

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

0.01 0.04 0.02

0.29

0.01 0.04

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

21.420.8

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

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)


P. Carney Limited Environmental Noise Survey 2008

Environmental Efficiency Consultants (Ire) Ltd. 1 Document No. 1144-01 v1.00

Environmental Noise Survey 2008

For

P. Carney Limited.

Crossakiel, Kells,

Co. Meath.

IPPC Licence: PO402-02

Document Number: 1144-01 v1.00



QF 1. v2 Document Lead Sheet

Document Title Environmental Noise Survey 2008 Project No. 1144 Document No. 1144-01 v1.00 Client P. Carney Ltd. Address Crossakiel, Kells, County Meath


Efficiency Client

1.00 Approved 01/05/2009 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 Document Author: Róisín Ní Dhubhda B.Sc., M.Sc., AIEMA

Richard McElroy, B.Eng.








Table of Contents

1. Introduction ..........................................................................................................4 2. Noise.......................................................................................................................4 3. Summary ...............................................................................................................4 4. Sampling Methodology and Analytical Techniques..........................................5 3.1 Instrumentation Used .....................................................................................5 3.2 Noise Survey Personnel .................................................................................5 3.3 Report Terminology .......................................................................................5 3.4 Meteorological Conditions.............................................................................6 3.5 Measurement Positions ..................................................................................6 3.6 Measurement Locations .................................................................................6

5. Noise Survey..........................................................................................................8 6. Discussion & Conclussion..................................................................................10

Figure 3-1: Identified Nearest Noise Sensitive Locations.........................................................................7

Table 3-1: Equipment Used to Conduct Noise Monitoring Surveys.........................................................5

Table 4-1: Environmental Noise Monitoring Results ...............................................................................9

Appendix 1 Certificates of Calibration ..........................................................................................11



1 Introduction Environmental Efficiency Consultants (Ire) Limited was commissioned by P. Carney

Limited to carry out an annual environmental noise survey, in accordance with

Condition 6.13 of the IPPC licence. Condition 4.5 of the licence states: -

“Noise from the installation shall not give rise to sound pressure levels (Leq,T)

measured at noise sensitive locations of the installation which exceed the limit values

by more than 2 dB(A).”

These limit values are specified in Schedule B.4 as daytime noise values of 55 dB (A)

LAeq (30 minutes) and night-time noise values of 45 dB (A) LAeq (30 minutes). This

environmental noise survey report pertains to the licence year 2008 and has been

undertaken in accordance with the EPA publication “Environmental Noise Survey

Guidance Document” (2003).

2 Noise Excessive noise from development and commercial sites can have a significant

adverse effect on those living in close proximity to such sites. In Ireland, there are no

statutory limits for noise emissions or ambient noise levels; however the

Environmental Protection Agency (EPA)1 has produced noise guidelines, which

define the levels of acceptability in relation to noise from industrial/commercial

operations. The EPA endorse limit values of a maximum of 55 dB(A) during daytime

hours2 and night-time values of 45 db(A). These values should be measured at the

identified noise sensitive locations (NSLs). A Noise sensitive location is described by

the EPA as follows: -

‘Any dwelling, hotel or hostel, health building, educational establishment, place of

worship or entertainment, or any other facility or area of high amenity, which for its

proper enjoyment requires the absence of noise at nuisance levels3’.

3 Summary The noise levels recorded at the identified noise sensitive locations i.e. nearest two

residential dwellings are determined to be below the emission limit values set forth in

the licence. As such P. Carney Ltd. is NOT in breach of their IPPC licence Condition

6.13.

1 EPA (2006) Guidance Note for Noise in Relation to Scheduled Activities. 2nd Edition 2 Daytime hours (08.00-22.00): Night-time hours (22.00-08.00) 3 Guidance Note for Noise in Relation to Scheduled Activities, 2nd Ed. (2006) EPA



4 Sampling Methodology and Analytical Techniques

3.1 Instrumentation Used

The following equipment was used during the noise assessment:

Table 3-1 Equipment Used to Conduct Noise Monitoring Surveys Equipment Model (Cirrus) Serial No. EEC Lab ID.

Sound Level Meter (SLM) (Type 1) CR: 811B C16569FD LEN 002

Microphone MK: 224 20020028 N/A

Calibrator CR: 511E 035066 LEN 003

Tripod N/A N/A N/A

The SLM were calibrated to 93.7 dB (A) on-site immediately before

measurement and reassessed on completion. No drift in calibration level was

recorded. See Appendix for certificate of calibration.

3.2 Noise Survey Personnel

The noise survey was undertaken by Environmental Efficiency Consultants (Ire) Ltd.,

environmental consultant, Mr. Richard McElroy, B.Eng.

3.3 Report Terminology

The parameters used to assess the noise are as follows:

Leq (t): is the continuous equivalent sound level over a specified time (t),

where t represented a 30-minute period during this survey. This

measure is used to give an indication of the average noise level over

the specified time period.

L10 and L90: are both statistical noise levels. L10 indicates that for 10% of the

monitoring period, the sound levels were greater than the quoted value.

L90 indicates that for 90% of the monitoring period, the sound levels

were greater than the quoted value. L10 is used to express event noise.

L90 is used to express background noise, usually filtering out loud,

intermittent interferences such as traffic noise.



The following terms may be used to describe the characteristics of the noise:

Continuous: noise produced without interruption.

Intermittent: noise that is punctuated with interruptions e.g. equipment operating in

cycles or events such as single passing vehicle

Impulsive: a noise of short duration (typically less than one second), the sound

pressure of which is significantly higher than the background; brief and

abrupt.

Tonal: noise that contains a clearly audible tone i.e. a distinguishable, discrete

or continuous note (whine, hiss, hum or screech, etc.).

The noise measurements were ‘A’ weighted and the time-weighting ‘Fast’ was

applied (to equate to human ear hearing).

3.4 Meteorological Conditions

Weather conditions on the day of monitoring was considered appropriate for

surveying purposes and therefore, did not affect the readings i.e. conditions were dry

and wind speed was less than 5 m/s (the normal upper limit for taking measurements).

The Sound Level Meter was also fitted with a windshield to minimise interference

from potential meteorological conditions, in keeping with good practice.

3.5 Measurement Positions

All measurements were taken at between:

• 1.2 – 1.5 m height above local ground level

3.6 Measurement Locations

The locations of noise monitoring points are described in the following table and

shown in Figure. All readings were taken during daytime operating hours when the

facility was in operation and all equipment was in use.



Figure 3.1: Identified Nearest Noise Sensitive Locations

NSL1

NSL2

P. Carney Site



5 Noise Survey

Table shows the measurement results for the monitoring locations at the site at P.

Carney. Associated particulars such as a description of the noise recorded, in each

location are also provided in the table.

P. Carney Limited

Environmental Noise Survey 2008

Environmental Efficiency Consultants (Ire) Ltd.

9 Document No. 1144-01 v1.00

Table 4.1: Environmental Noise Monitoring Results Noise Result

Location

Reference

NSL Description

Type

Leq

(30 mins)

Leq

L10

L90

Description of On-site Noise

Sources

Description of Off-site

Noise Interference

NSL1

Residential Dwelling

Day

*

30

54.9 54.4 48.1 o

Transportation of

materials onsite

o Passing traffic from

adjacent public road

NSL2

Residential Dwelling

Day*

30

54.1 53.9 46.2 o

Transportation of

materials onsite

o Passing traffic from

adjacent public road

* Emission lim

it values as specified in the EPA (2003) Environmental Noise Survey Guidance Document



6 Discussion & Conclusion As can be seen in Table 3-1 the results for NSL 1 and NSL 2 are below the limits set

forth in the licence. Therefore P. Carney Ltd is within the terms of their licence

conditions.



Appendix 1 Certificates of Calibration





Appendix 7 Energy Audit Report Summary


(To be inserted)



Environmental Efficiency 1 Document No 861-19; Version No. 1.01

EPA SUMMARY ENERGY AUDIT

FOR

P. CARNEY

Document No. 861-19

Version 1.01

P. Carney Emergency Response Plan


QF 1. v2 Document Lead Sheet Document Title EPA Summary Energy Audit Project No. 861 Document No. 861-19 Client P. Carney Ltd. Address Crossakiel, Kells, Co. Meath.


Efficiency Client

1.01 Approved 26/09/2007 DR


EEC Document Author: David Reilly B.E.



8. Where this report is reproduced, it shall only be reproduced in full. Where extracts are taken for inclusion in the site’s AER or other management summary, then the extracts shall be identified as being taken from this report by quoting Environmental Efficiency as the corporate authors and the document number.





Table of Contents

1. Introduction ......................................................................................................... 4

2. Energy Management System.............................................................................. 4

3. Site energy consumption..................................................................................... 5

4. Energy Performance Indicators......................................................................... 7

5. Recommendations ............................................................................................... 8

6. Implication of audit findings ............................................................................ 10

Table 1 Site Energy Consumption .....................................................................................5 Table 2 SEC for the site .....................................................................................................7 Table 2 Recommendations .................................................................................................8 Appendix 1 Energy Management Matrix……………………………………………11



1 Introduction P. Carney has a licence issued by the EPA (Licence No. P0402-02). This licence requires that P. Carney have an energy audit carried out according to The EPA Document ‘Guidance Note on Energy Efficiency Auditing’. This document states that “two reports should be prepared for the Energy Audit, viz.:

Main Report for site use; Summary Report for submission to the Agency as part of the Annual

Environmental Report.”

The energy audit was carried out on the 25/07/2007. The main report was issued to P. Carney (Document No. 861-15). This report is the summary report requested for submission to the Agency as part of the Annual Environmental Report and was prepared in accordance with the Guidance Note, i.e. it includes:

• Table setting out the consumption of the different energy streams at the site • Table setting out the final list of Audit Recommendations that could be

incorporated into the implementation programme. • An overview of the status of the energy management system at the site • Any energy performance indicators calculated for the site for the Audit period

and previous periods • A summary of the implications of Audit findings.

2 Energy Management System An energy management system is a system to track the energy usage at a site in order to highlight any areas in need of improved energy management. The effectiveness of an energy management system can be determined by use of the matrix shown in Appendix . The status of the client’s energy management system is shown by the shaded boxes on the matrix. Level 4 of the matrix represents best practice. The energy consumption at the site is reviewed regularly. The relevant personnel have a very good awareness of energy issues and are knowledgeable of energy saving and energy cost saving techniques. A number of improvements have already been carried out, including:

• VSDs options exhausted on the site • Investigations made regarding upgrading of site furnace • In dept monitoring of furnace oil consumption

This indicates that the company is investing in energy saving equipment and is actively working to reduce the energy usage of the site.

P. Carney Ltd.


Environmental Efficiency

5

Document No 861-19; Version No. 1.01

3 Site energy consumption

The site energy consumption for the period 01/2006 to 12/2006 is shown below. Transport fuels are excluded.

Table 1 Site Energy Consumption

Fuel

Typ

e

El

ec tr ic it y

G a s O il

M o t o r D i e s e l

K e r o s e n e

P r o p a n e

T o t a l

Con

sum

ptio

n ,

kW h

6 0 2, 8 3 5

7 , 3 1 5 , 0 3 7

7 5 2 , 3 1 7

2 6 , 7 0 3

2 5 , 3 3 4

8 , 7 2 2 , 2 3 6 %

Con

sum

ptio

n

6. 9

8 3 . 8 7

8 . 6 3

0 . 3 1

0 . 2 9

1 0 0

P. Carney

Emergency Response Plan


6


Ton

nes

CO

2

4 6 7. 8

1 , 4 4 8 . 4

1 4 9

6 . 9

5 . 8

2 , 0 7 7 . 8

%

CO

2

2 2. 5

6 9 . 7 1

7 . 1 7

0 . 3 3

0 . 2 8

1 0 0

Ann

ual

Cos

t, €

9 6, 4 1 9

3 5 4 , 9 4 5

6 0 , 4 3 5

1 , 6 8 3

2 , 3 5 6

5 1 5 , 8 3 6 %

Ann

ual

Cos

t

1 8. 6 3

6 8 . 5 9

1 1 . 6 8

0 . 6 5

0 . 4 6

1 0 0

Cos

t,

c/k

1 6. 9

4 . 8

8 . 0

6 . 3

9 . 3

5 . 9

P. Carney



7


Wh

2 5

3

4 Energy Perform

ance Indicators

The overall Specific Energy Consumption (also known as EPI) for the site is shown below.

Table 2 SEC for the site

2006

Total

Annual Production Figure (tonnes)

4,744.09

Energy Consumption, kWh

8,722,236

SEC for site (kWh/tonne)

1,839

Previous SEC for site (kWh/tonne)

N/A

Best Practice SEC (kWh/tonne) 1

10,055

•

1 Best Practise SEC taken from Energy Consumption Guide 38 – Non-Ferrous Foundries. It must be noted that this figure is now 10 years old and includes processing of

aluminium ingots into their final end format, which does not happen at P. Carney

P. Carney



8


5 Recommendations

The audit recommendations are shown in the table below.

Table 2 Recommendations

Ref.

Measure

Predicted

annual

savings,

kWh

Predicted

annual

GHG

savings,

t CO

2

Predicted

annual cost

saving, €

Capital cost

measure, €

Sim

ple

payback

period, yrs

Target

Completion

Date

Person

Responsible

1

Reduce compressed air leaks

4,226

3.28

735

0 0

To be

determined

To be

determined

2

Investigate the possibility of

reducing compressed air pressure

1,942

1.51

338

0 0

To be

determined

To be

determined

3

Vent compressed air exhaust

outside

280

0.22

48

0 0

To be

determined

To be

determined

4

Investigate changing office

lighting to electronic ballast

900

0.7

157

800

5.11

To be

determined

To be

determined

5

Investigate changing process

lighting to electronic ballast

9,990

7.75

1,736

1,550

0.89

To be

determined

To be

determined

6

Investigate the introduction of

daylight sensors

216

0.17

37.54

50

1.33

To be

determined

To be

determined

7

Investigate the introduction of

occupancy sensors

216

0.17

37.54

65

1.73

To be

determined

To be

determined

8

Insulate all valves & flanges

1,620

0.32

102.1

125

1.22

To be

determined

To be

determined

9

Investigate using exhaust heat

from furnace for space heating

20,027

5.18

1,262

2,500

1.99

To be

determined

To be

determined

10

Use fuel additives in motor diesel

75,232

14.9

4,944

0 0

To be

determined

To be

determined

11

Change electricity supplier

0 0

7,000

0 0

To be

determined

To be

determined

P. Carney



9


Ref.

Measure

Predicted

annual

savings,

kWh

Predicted

annual

GHG

savings,

t CO

2

Predicted

annual cost

saving, €

Capital cost

measure, €

Sim

ple

payback

period, yrs

Target

Completion

Date

Person

Responsible

12

Monitoring & Targeting

436,111

107

25,792

4,000

0.16

To be

determined

To be

determined

Totals

550,760

(6% saving)

141

(7% saving)

42,189

(8% saving)

9,090

0.22

(average)

To be

determined

To be

determined

Full details for each recommendation are available in document 861-15.



6 Implication of audit findings The energy audit identified the site SEC. This will be used as a benchmark to identify the success or otherwise of the implementation of the recommendations. The energy audit identified a number of recommendations that could be implemented. Implementation of these will result in a significant reduction in energy cost and GHG emissions.

P. Carney Ltd.



11


Appendix 1 Energy M

anagem

ent Matrix

Level

Energy Policy

Organising

Motivation

Information systems

Marketing

Investm

ent

4

Energy policy, action plan

and regular review have

commitment of top

management as part of an

environmental strategy

Energy management fully

integrated into

management structure.

Clear delegation of

responsibility for energy

consumption.

Formal and informal

channels of communication

regularly exploited by

energy manager and

energy staff at all levels.

Comprehensive system sets

targets, monitors

consumption, identifies

faults, quantifies savings

and provides budget

tracking.

Marketing the value of

energy efficiency and the

performance of energy

management both within

the organisation and

outside it.

Positive discrimination in

favour of ‘green’

schemes with detailed

investment appraisal of

all new-build and

refurbishment

opportunities.

3

Formal energy policy, but

no active commitment

from top management.

Energy manager

accountable to energy

committee representing all

users chaired by a member

of the managing board.

Energy committee used as

main channel together with

direct contact with major

users.

M&T reports for individual

premises based on sub-

metering, but savings not

reported effectively to

users.

Programme of staff

awareness and regular

publicity campaigns.

Same pay back criteria

employed as for all other

investment.

2

Un-adopted energy policy

set by energy manager or

senior departmental

manager.

Energy manager in post,

reporting to ad-hoc

committee, but line

management and authority

are unclear.

Contact with major users

through ad-hoc committee

chaired by senior

departmental manager.

Monitoring and targeting

reports based on supply

meter data. Energy unit has

ad-hoc involvement in

budget setting.

Some ad-hoc staff

awareness training.

Investment using short-

term payback criteria

only.

1

An unwritten set of

guidelines

Energy management is the

part-time responsibility of

someone with limited

authority or influence

Informal contacts between

engineer and a few users.

Cost reporting based on

invoice data. Engineer

compiles reports for

internal use within

technical department.

Informal contacts used to

promote energy

efficiency.

Only low cost measures

taken.

0

No explicit policy

No energy management or

any formal delegation of

responsibility for energy

consumption

No contact with users.

No information system. No

accounting for energy

consumption.

No promotion of energy

efficiency.

No investment in

increasing energy

efficiency in premises.



Appendix 8 Emergency Response Plan


(To be inserted)





P. Carney Ltd

Document No.: 861-17



QF 1. V2.00 Document Lead Sheet

Document Title Emergency Response Plan Project No. 861 Document No. 861-17 Client P. Carney Ltd. Address Crossakiel, Kells, Co. Meath


Efficiency Client

2.00 Approved 05/04/2007 PG

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: Paula Galvin, M.A


� No alteration to this report by third parties is permitted

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

� Reports remain the property of Environmental & Efficiency Consultants (Ireland) Limited until paid for in full.



Table of Contents 1 Emergency Response Procedure............................................................................. 4 1.1 Introduction: .............................................................................................................. 4 1.2 Purpose: ..................................................................................................................... 4 1.3 Priorities: ................................................................................................................... 4 1.4 Potential Situations:................................................................................................... 4 1.5 Responsibilities: ........................................................................................................ 5 1.6 Training ..................................................................................................................... 5 1.7 Emergency Response Procedures.............................................................................. 6 1.8 Evacuation Procedures: ............................................................................................. 7 1.9 Containment Procedures: .......................................................................................... 7 1.10 Decontamination Procedure .................................................................................. 10 1.11 Follow-Up Procedure ............................................................................................ 10 1.12Review of Emergency Response Procedure........................................................... 13

Table 1 Emergency Preparedness & response training………………………6 Table 2 Spill response procedure…………………………………………….8 Table 11 Environmental incidence log……………………………………….11 Table 12 Environmental Incidence Record Form……………………………12



1 Emergency Response Procedure

1.1 Introduction: An emergency is any unplanned event that can potentially cause deaths or significant injuries to employees, customers or the public, or that can shut down the business, disrupt operations, cause environmental damage, or threaten the facility’s financial standing. The process of preparing for, mitigating, responding to and recovering from an emergency is integral to P. Carney Ltd’s management procedures. Training, undertaking drills, testing equipment and coordinating activities are integral to the process. 1.2 Purpose: The primary purpose of this plan is to provide management and staff at P. Carney Ltd’s premises with timely and effective response to any emergencies that may arise at the facility.

The goals of this emergency response plan are, to protect the lives of employees, customers or the public, to protect against environmental damage and to protect and minimise damage to the company property in the event of an emergency. 1.3 Priorities: The objectives of the plan are:

1. To evacuate and account for all employees and visitors 2. To contact local emergency services organisations; 3. To assemble the company’s emergency response team (ERT) for the

implementation of the response plan; 4. Contact pertinent regulatory agencies; 5. Turn off utilities; 6. Control any hazardous chemical spills or releases; 7. Perform cleanup and salvage as required; 8. Undertake post incident evaluation 9. File any applicable reports with regulatory agencies

1.4 Potential Situations: As part of this plan the following potential accidents or emergency situations that could arise at P. Carney Ltd’s premises have been identified as being:

1. Fire, storms, floods etc. 2. Spillages/leaks 3. Gas leaks 4. Power failures/surges 5. Transport accidents 6. Miscellaneous



1.5 Responsibilities: Personnel at P. Carney Ltd. that form the Emergency Response Team include: Name Role Mr. Jim McCabe Managing Director Mr. Declan Clarke Quality and Environmental Manager Mr. John Garry Works Manager Mr. Michael Farrelly Maintenance Manager Mr. Johnny Mongey First Aider Mr. John Garry has been designated as the primary Emergency Response Co-ordinator. In the event that Mr. Garry is absent during the incident Mr. Michael Farrelly will assume this responsibility. Emergency Response Co-ordinator

1. Evaluate the number and types of hazards and review on a regular basis; 2. Provide training for all employees for their roles in all emergency plans; 3. Conduct drills to practice response to emergency situations; 4. All other activities necessary to the development and implementation of an

effective Emergency Response Plan; The Maintenance Manager

1. Maintain sufficient inventory of emergency response equipment; 2. Ensure maintenance and inspection of process equipment; 3. Help train emergency response teams.

1.6 Training P. Carney Ltd. will train all employees on the procedures contained in this plan. New employees will be trained upon hiring, and re-trained any time the employees responsibilities under the plan change or whenever the plan changes. The company will provide copies of emergency response plans to be posted at various locations around the site. Supervisors and/or lead men in all work areas will be trained to assist in the safe and orderly evacuation of employees and visitors. Training will include:

o Emergency reporting; o Evacuation routes; o Alarm systems; o Specific assigned duties.

Periodic drills will be held to ensure that all employees know the appropriate actions to take in case of an emergency. The company will consult with local emergency services and invite them on site where necessary to participate in training. (See outline procedure below Table ).



Table 1 Emergency preparedness and response training

P. Carney Ltd. –Emergency Response Procedure

Author: EEC Approved by: RBS Date: 23/03/07 Revision No: 1.00

Status: Approved

Emergency Preparedness and Response Training Purpose:

Procedure to ensure that employees are trained in the relevant emergency procedures.

Procedure: 1. An assigned selection of staff shall be trained as the emergency response team on

fire safety, major spill control and/or first aid. 2. Staff must be made aware of the significant environmental issues related to their

job during staff training sessions. 3. Staff should also be made aware of non-conformance criteria and the importance

of reporting all problems. 4. Staff shall be trained so that in the event of an accident, malfunction or non-

conformance they will be aware whom to report the issue to. 5. Any changes in the processes must be reviewed to determine if there is a need to

update the training. 6. Staff shall all be aware that in the event of a fire, serious accident or major spillage

that all staff exit to the safety points except for those designated and trained as the emergency response team.

1.7 Emergency Response Procedures

Incident Notification If an emergency or situation that could become an emergency occurs, staff are to inform management immediately. Mr. John Garry will maintain an up-to-date emergency response notification list. Emergency Reponse Team Notification Contact Names and Telephone Numbers: P. Carney Ltd Personnel Contact Number Jim McCabe 046 9243732 John Garry 046 9433021 Michael Farrelly 044 9374793 / 087 673 8244 Declan Clarke 087 616 5156 Johnny Mongey 086 3658353



Emergency Services Contact Number Dr Lapin (Doctor) 046 9240052 Kells Fire Brigade 046 9240666 Ambulance Service 046 9021210 All Emergency Services 999/911 Authorities/Agencies Contact Number Meath County Council 046 9097200 Environmental Protection Agency 053 9160600 Employee Notification The alarm system or direct supervisory contact can be used to notify employees of emergency situations in the facility. External Notification Call 999 or equivalent to contact the local fire or Garda Siochana unit. Notify neighbours, local authorities, environmental agencies etc. 1.8 Evacuation Procedures: After the senior manager on the scene determines that evacuation is required, the evacuation alarm should be sounded, with instruction issued over the public address system. Specific responsibilities are as follows: Supervisors

1. Lead employees from the premises; 2. Assist any employees with disabilities and/or injuries; 3. Escort employees to the designated assembly area at the main gate; 4. Account for all employees upon reaching the designated assembly area; 5. Notify senior management of any employee not accounted for; 6. Ensure that employees remain in the assembly area until otherwise notified.

Fire Fighting No employee shall fight a fire that is beyond the incipient stage (able to be put out with a fire extinguisher), enter if the building is on fire to undertake search and rescue, or provide advanced medical care and treatment. These situations must be left to emergency services professionals, who have the necessary training, equipment and experience. 1.9 Containment Procedures: If there is an emergency stop button/shut off power switch in the vicinity of the incident, this should be pressed. If safe, directly stop at the source. Stop spill, leak, machine, shut off oil or gas etc where applicable. If the Fire Brigade is on site and there is a possibility of contaminated fire water leaving the site, it is the responsibility of the Emergency Response Co-ordinator to close the shut-off valve to the surface water drainage system.



Contaminated materials should be identified and every effort made to hold the damage within one area. Drains, doorways etc should be blocked off where possible to prevent the incident from dispersing. All high risk materials should be put in a sealed impervious container. All unsafe equipment should be taken out of service. Spill response procedure is provided in Table below. Table 2 Spill response procedure

P. Carney Ltd. –Emergency Response Procedure Author: EEC Approved by: RBS

Date: 22/03/2007 Revision No: 1.00

Status: Approved

Spill response procedure Purpose:

Procedure to ensure that spills are cleaned up in the proper manner and the least amount of environmental pollution occurs. Procedure:

Response and Clean-up Procedure for Low Risk Spills

Low risk spills are defined as spills that have a low risk of spreading and reaching on-site drains or nearby water courses and these spills can generally be handled by internal personnel and do not usually require an emergency response by fire department personnel. Spills of less than 2 metres in diameter are normally cleaned up by the spiller.

1. Always ensure that the absorbent material is suitable for the spilled material. 2. First, quickly contain the spill by stopping or securing the spill source. This may be

as simple as up-righting a drum/container and using absorbent material (oil dri) to soak up spilled material. Wear gloves and protective clothing, if necessary.

3. Isolate all near-by drains with absorbent containment materials or other measures e.g. close valve.

4. Put spill material and used absorbents into a secure container. 5. Wash any equipment or floors so that no traces of the chemical remain. 6. Absorb the wash water with absorbent material and place this material in the same

container as the contaminated absorbent materials. 7. Label the container with the appropriate contents, workplace and shipping labels. 8. Ensure the spill is contained before reopening the drain for normal operation.

Response and Clean-up Procedure for HIGH RISK SPILLS

High-risk spills are defined as spills that have a high risk of spreading quickly to on-site drains or nearby watercourses. The fire service and Local Authority may be required to help clean up high-risk spills. However, common sense also should be used when determining if outside help is necessary. High risk spills require the following actions:



P. Carney Ltd. –Emergency Response Procedure Author: EEC Approved by: RBS


Status: Approved

Spill response procedure 1. Try to contain the spill at its source e.g. quickly upright a container, put a lid on it or

put it in a spill-tray. If necessary, put on the personal protective equipment (PPE). 2. Once you have made a quick attempt to contain the spill, leave the area and alert the

Maintenance Manager and Environmental Manager. 3. Ensure that all near-by drains are protected with absorbent containment materials if

possible and if safe to do so. 4. Evaluate the spill and make the decision if the spill requires the assistance of the

emergency services: 5. Contacting the Fire Brigade

� Dial 999 � Ask for the fire brigade � Inform the operator that there is a spill at P. Carney Ltd, � Provide details regarding quantity and chemical type if known

6. After emergency personnel have arrived on site, be prepared to assist them with any other information that may be necessary e.g. MSDS sheets

7. A summary of the environmental incidence record and the method of response and

clean up is written by the Maintenance Manager and presented to the Environmental Manager.

8. The Environmental Manager will inform Meath County Council as soon as

practicable after the incident. (Meath County Council Ph. No: 046 9097000)

9. The Environmental Manager will inform Environmental Protection Agency as soon as practicable after the incident. EPA Headquarters Tel: 053-9160600



1.10 Decontamination Procedure 1. Remove all faulty equipment; 2. Identify and safely collect the hazardous or contaminated material; 3. Arrange for correct treatment or disposal of the contaminated material; 4. Use only authorised waste disposal companies. 5. Hold all relevant documents on site for inspection.

1.11 Follow-Up Procedure 1. Identify and document the cause of the incident and any contributing factors; 2. Identify what safety precautions were taken; 3. Record, inform and report on the incident using the Environmental incidence

log and records forms provided below (Table 3 & Table 4) 4. Analyse data collected and document a procedure to eliminate this and similar

occurrences taking place again.



Table 3 Environmental incidence log P. Carney Ltd. –Emergency Response Procedure

Author: EEC Approved by: RBS


Status: Approved

Environmental Incidence Log Date of

Incidence:

Area of

Incidence:

Description of

Incidence:

Area

Supervisor:

Action Taken:



Table 4 Environmental Incidence Record Form P. Carney Ltd. –Emergency Response Procedure

Author: EEC Approved by: RBS


Status: Approved

Environmental Incidence Record Form Incidence Recorded: EPA/ 3

rd Parties Informed (Y/N):

Date of Incidence: Time of Incidence:

Staff Member:

Maintenance Manager:

Cause of Incidence: (if cause not known, record ‘unknown’. Cause to be determined as soon as practical after incident)

Nature of Substance Involved:

Nature of losses: (life, injury, adverse environmental impact and property)

Actions Taken to Minimise Adverse Impacts:

Specific Advice of Environmental Manager regarding Incidence:

I have inspected the area of concern and all actions have been taken to

lessen/eliminate any negative impact on the environment.

Signature of Maintenance Manager:_______________________________________

Signature of Environmental Manager:______________________ Date:_____________



1.12 Review of Emergency Response Procedure

This procedure will be reviewed in the case of: 1. Revised environmental regulations; 2. Inadequacy of procedure during an emergency; 3. Major process changes 4. Major equipment change.



Appendix 9 Accident Prevention Policy


(To be inserted)


1

Accident Prevention Policy

For

P. Carney Ltd.

Crossakiel, Kells, Co. Meath

IPC Licence Reg No. P0402-02

(Document No: 861-12)

P. Carney Limited Accident Prevention Policy

Environmental Efficiency 2

Document No. 861-12 v 1.00

QF 2. Document Lead Sheet

Document Title Accident Prevention Policy

Project No. 861 Document No. 861-12 Client P. Carney Ltd. Address Crossakiel, Kells, Co. Meath


Efficiency Client

1.00 Approved 05/04/2007 TG & MR

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 Document Author: Tom Griffiths, MSc., BSc., ESAI

Maria Rochford, BSc. Env. Mgnt.




12. Reports remain the property of Environmental & Efficiency Consultants (Ireland)

Limited until paid for in full.




TABLE OF CONTENTS 1. Introduction ......................................................................................................... 4

2. Purpose................................................................................................................. 4

3. Potential Incidents............................................................................................... 4

4. Accident Prevention Procedure ......................................................................... 5




1 Introduction P. Carney Ltd are based in Crossakiel, Kells, Co. Meath and have IPPC licence number

P0402-02. Condition 9.1 of the licence states that:

“The licensee shall, within six months of the date of grant of this licence, ensure that a

documented Accident Prevention Policy is in place, which will address the hazards on-

site, particularly in relation to the prevention of accidents with a possible impact on the

environment. This procedure shall be reviewed annually and updated as necessary.”

This report is the Accident Prevention Policy (APP). The APP is designed to be

accompanied by the Emergency Response Plan (ERP) and supported by the

Environmental Management System (EMS) and the IPPC licence.

The IPPC licence requires the company to implement an environmental management

system at the facility in order to control and minimise and prevent all emissions to

environmental media.

Through the terms of the IPPC licence (register no. PO402-02)) P. Carney Ltd. are

required to carry out sampling and analysis of emissions to air, noise and storm water

emissions. Emission Limit Values have been set for all emissions and regular monitoring

is undertaken to establish compliance with the limits.

2 Purpose The primary purpose of this plan is to ensure management and staff at P. Carney Ltd’s

premises are provided with the training and knowledge needed to ensure the continued

protection of the environment and human health and eliminate the risk of accidents

occurring at the site.

3 Potential Incidents As part of this plan potential accidents that could arise at P. Carney Ltd’s premises have

been identified as being:

7. Fire, storms, floods etc.

8. Spillages/leaks from hazardous materials stored on site

9. Accidental release/emission to environmental media




10. Gas leaks

11. Power failures/surges

12. Transport accidents

13. Miscellaneous

4 Accident Prevention Procedure The company operates a comprehensive environmental management system (EMS). The

EMS is designed to manage the company’s environmental aspects in conjunction with the

IPPC licence. The EMS involves the implementation of a range of procedures at the

company, to ensure the elimination, prevention and control of all environmental hazards

on-site. The relevant procedures that will prevent the occurance of accidents on site are

outlined in the Environmental Management System Manual. The accident prevention

procedure provides the framework for which control and monitoring of the companies

activities are to be managed in order to avoid accidents.




P. Carney Ltd - Accident Prevention Policy Procedure

Author: P. Carney& EEC

Approved by: RBS Page 1 of 2

Date: 25/03/07 Revision No: 2.00 Status: Approved

Purpose:

To address the hazards on-site, particularly in relation to the prevention of accidents with a possible impact on the environment and to provide the framework for establishment of measures and controls to be implemented in order to avoid accidents occurring on site. General Procedure:

The accident prevention procedure outlines the processes in place at P. Carney Ltd that aid in the elimination and avoidance of accidents which are likely to impact of the environment. 1. Organisation and personnnel The roles and responsibilities of personnel involved in the management of hazards with environmental impacts at all levels in the organisation should be clearly defined. Regular management meetings are to be carried out to monitor compliance with the terms of IPPC and

continual improvement of environmental performance. The training needs of relevant personnel

are to be defined and the provision of the training determined. Training should involve the communication to all personnel regarding known potential hazards on site with environmental risks.

2. Hazard identification

All potential hazards associated with the process activities and other activities such as unloading of raw materials, which have the potential to impact on the environment, must be identified and appropriate controls determined, implemented and reviewed. Hazards and the associated controls should be communicated to all relevant staff.

3. Operational control Operational controls for the safe design and operation of plant, processes, equipment and storage facilities on site should be defined. Operational controls are to cover all phases of normal process activities and should include engineering and administrative controls. Operational control should also encompass a regular check, maintenance and inspection programme for process and all abatement equipment used on site.

4. Monitoring performance (continual improvement) Management are to regularly review compliance with the objectives set by the IPPC licence and environmental management system, and establish measures for investigation and taking corrective action in cases of non achievement of objectives and targets.

5. Audit and review

In addition to the routine monitoring of performance, regular audits of the environmental management system are to be carried out. The findings of previous audits will be reviewed prior to conducting of any internal audit and any past non-conformances raised will be included in the schedule for the audit. An audit should determine whether the overall performance of the Environmental Management System conforms to requirements, both external and those of the operator. The results of these audits should be used to decide what improvements should be made to the elements of the EMS and their implementation in order to achieve full compliance with the IPPC licence and prevent the possibility of accidental release of emissions or other accidents with environmental consequences.




P. Carney Ltd - Accident Prevention Policy Procedure

Author: P. Carney& EEC

Approved by: RBS Page 1 of 2

Date: 25/03/07 Revision No: 2.00 Status: Approved

Procedure References (see EMS Manual): � Procedure for a management review � Procedure for an EMS Audit � Procedure for the Determination & Update of Objectives, Targets and EMP � Environmental Audit Log � Audit and non conformance sheet � Internal EMS Audit Schedule Form � Corrective action request form � Procedure for environmental training of staff � Procedure to reduce leaks and spills on site

Documents

ANNUAL ENVIRONMENTAL REPORT (AER) 2008 · ANNUAL ENVIRONMENTAL REPORT (AER) 2008 For P. Carney Ltd., Crossakiel, Kells, Co. Meath IPPC Licence Number: P0402-02 (EEC Ltd. Document