attachment no j - environmental protection agency · emergency response and preparedness & out...

ATTACHMENT NO J

ACCIDENT PREVENTION & EMERGENCY RESPONSE

1. Emergency Management

2. Spill Response

3. On-site Emergency Equipment

4. Management of Materials

5. Bund Integrity

6. Underground Drainage Surveys

7. Firewater Retention Facilities

8. Emergency Response & Preparedness & Out of Office Hours Arrangements

Additional Documents Included:

ENVP052 Environmental accident prevention, emergency response & incident notification procedure

SmartPly Europe Ltd. P0001-03 Attachment J

1. Emergency Management

SmartPly Europe Limited has implemented a number of safety and environmental protection equipment and measures on-site, to prevent and minimise accidental emissions to the environment, including:

• Extensive fire alarms systems • Extensive sprinkler systems • Containment measures • Fully trained site Emergency Response Team (ERT) • Extensive emergency equipment resources • Accident/incident prevention & response procedures

A comprehensive procedure entitled “Environmental accident prevention, emergency response & incident notification” (ENVP052), is operated on the site and is attached. It is comprised of emergency response procedures that must be followed in the event of emergencies, which may arise at the SmartPly facility.

2. Spill Response at SmartPly Europe Limited

The company has prepared and implemented comprehensive spill response procedures (ENVP001) to address this emergency situation and remedial measures required in the event of a spillage on-site. Procedures are designed to provide guidelines for dealing with accidental releases of liquids, solids and gases. SmartPly Europe Ltd has prepared a generic Spill Response Procedure (as detailed in the Site Emergency Plan) as follows:

1. Secure the Spill area 2. Identify spilled material and don necessary PPE 3. Identify the source type and amount of spill 4. Establish if there are any casualties 5. Locate and identify the appropriate clean-up materials and spill kits 6. Contain the spill using spill kit or flakes and fines 7. Consult the ERT Coordinator or Quality & Environmental Manager for the correct clean-up

and disposal procedure 8. Clean and decontaminate all clean-up equipment

Spill kits are located in areas where spillage is most likely to occur and are routinely inspected. Spill kits are located on the SmartPly Europe Ltd site at the following locations:

• Diesel bund area • Outside mobile equipment garage • Inside mobile equipment garage • Outside Nijhuis treatment plant • Resins filling bund area • Chemical bund area

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• Press pit area • Thermal oil room

3. Emergency Equipment On-Site

SmartPly Europe Limited has a comprehensive stock of emergency response equipment stored on-site. The overall structure of emergency response equipment (as shown below in Figure 1) is tested and maintained by designated personnel on a regular basis.

Figure 1: Structure of Emergency Response Equipment at SmartPly Europe Ltd.

4. Provision of Secondary Containment/Management of Materials

The SmartPly Europe Limited site has a number of bunded areas for holding chemicals, oils and wastes. Bunds are inspected on a regular basis and integrity tested once every three years. Table 1 identifies the location of bunds and their contents at the SmartPly site.

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Table 1: Bund locations & contents

Bund Name Contents 1. Geka Dryer Gas Oil Bund Diesel 2. Mobile Equipment Diesel Bund Diesel

3. Mobile Equipment Hydraulic Oil Bund Hydraulic Oil/ Waste Oil

4. Thermal Oil Overflow Bund Oil 5. Resin & Wax Bund MDI, LPF, wax & release agent 6. Resin Infeed Bund MDI, LPF, wax & release agent 7. Hydraulic Oil Room Bund Hydraulic Oil 8. Press Pit Oil 9. (a) Chemical Storage Unit Mixed oils 9. (a) Chemical Storage Unit Mixed oils 9. (a) Chemical Storage Unit Mixed oils

9. (b) Chemical Storage Unit Water treatment & misc. chemicals

9. (c) Chemical Storage Unit Water treatment & misc. chemicals

10A. Pumphouse Diesel Bund Diesel 10B. Pumphouse Bund Pumps - diesel 11. Chemical Storage Bund Mixed chemicals

Raw materials associated with the production of OSB delivered to the site primarily consist of logs, resins, wax and MDI. Logs are stored in the log yard and are transported to the log in-feed area by mobile loader. Deliveries of wax, resin, release agent and MDI are delivered to the facility by bulk tanker. Internal movement of the raw materials is facilitated by a closed system.

External storage areas for liquids such as diesel include containment structures to provide the necessary bunding to satisfy IE licence requirements. Wastes arising on-site are segregated and stored in accordance with dedicated site standard operating procedures. Designated waste storage locations on-site accommodate the storage of hazardous and non-hazardous waste.

In the event of an emergency or spillage occurring, the site has two emergency holding tanks (EHTs) with a combined capacity of 5,000 m3. Surface water is diverted to these tanks as necessary as per the Environmental accident prevention, emergency response & incident notification procedure (ENVP052).

5. Bund Integrity Assessment

SmartPly Europe Ltd. assesses the integrity of all site bunds once every three years as per licence conditions. Routine visual inspections are conducted every week to ensure bunds are not damaged, leaking or overfilled. The most recent bund inspection report is included in Attachment H.

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6. Underground Drainage Surveys

Plant sewage is transported in underground pipelines as well as LPG from the process LPG fuel tank to the dryers. The integrity of the pipelines is inspected as required and the most recent underground pipeline integrity test report is included in Attachment H. In the plant upgrade, underground sewage lines will be relocated to accommodate the new building extension on the Western side of the plant.

7. Firewater Retention Facilities

The SmartPly Europe Limited facility is protected by the following systems:

7.1 Fire Fighting Equipment

There is a fire water reservoir located to the south of the main production building which can provide up to 450 m3 of water for fire fighting purposes. There is also an emergency pump system which can deliver water to the facility at a rate of 5,700 litres/minute at a pressure of 7 bar and a water supply of 7,600 litres/minute to the log yard, also at a pressure of 7 bar. There is a sprinkler system installed throughout the plant which can deliver 0.25 gallons/minute.ft2 with a maximum area of coverage of 3,000 ft2. Activation of the sprinkler system is initiated by fired temperature detectors and rate-of-rise heat detectors. In the yard area there is a 250mm diameter fire main located approximately 21m from the building. Fire hydrants are located at 90m intervals throughout the log yard as well as around the building. A fully equipped hose is provided at each hydrant. Fire extinguishers are located throughout the facility with one located in every 2,500 ft2 of floor space and a maximum walking distance of 20m to any extinguisher.

There are two emergency holding tanks each with a capacity of 2,500 m3 located to the east of the site. In the event of a major fire, fire water may be directed to these holding tanks which are considered to be of sufficient capacity to contain all fire waters. In addition there are two settlement ponds each with a capacity of 2,500 m3, one of which could also be utilised as a firewater storage area in the event of a major fire incident. The total combined firewater retention capacity at the site could therefore be up to 7,500 m3 which would be more than sufficient in any worst case scenario.

8. Emergency Response and Preparedness & Out of Office Hours Arrangements

SmartPly Europe Limited has adopted and implemented procedures to identify foreseeable emergencies through the systematic analysis of its on-site operations. An Emergency Plan has been developed to provide an organised response to such emergencies.

A specialist Emergency Response service is also in place on site. This service consist of teams trained in advanced emergency techniques such as fire fighting, spillage clean up and search/rescue. The Emergency Response Team (ERT) has comprehensive site knowledge and is trained in the steps required to shutdown specific site equipment, including environmental abatement, in the event of an emergency. In addition, there is an Emergency Response Room located within the car-park area at the site which contains stocks of firefighting equipment, PPE, emergency first aid equipment and rescue equipment. Each of the four shift cycles at the facility has an ERT so that cover is provided for the facility 24 hours a day, seven days a week. SmartPly also operates a management & supervisor

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on-call system for outside of normal working hours and in the event of any emergency the on-call person is notified. Additional support and resources can then be activated as may be required. Procedures for notifying the EPA and other relevant organisations of accidents or incidents are detailed in the Environmental accident prevention, emergency response & incident notification procedure (ENVP052).

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SmartPly® Doc No. - ENVP052

Work Procedure Page No. - 1 of 9

Title: Environmental Accident Prevention, Emergency Response & Incident Notification Procedure

Date of Issue - 11/04/2014

Revision No. - 03 1.0 Purpose

To provide operating guidelines to SmartPly personnel and to define the steps to be taken to meet the requirements of SmartPly IE Licence P0001-03 Condition 9; Accident prevention & emergency response, and condition 11; Notifications, records & reports.

2.0 Scope

The procedure applies to plant operations at SmartPly and is a subset of the overall Emergency Response Procedure for the site.

3.0 References

− IE Licence P0001-03 Condition 9: Accident prevention & emergency response. − IE Licence P0001-03 Condition 11: Notifications, records & reports. − IE Licence P0001-03 Schedule C: Control & Monitoring − EPA (2010) Guidance to Licensees/COA holders on the Notification, Management

and Communication of Environmental Incidents. − EPA (2004) IPC Guidance Note on Storage and Transfer of Materials for

Scheduled Activities. − Maps: Bund Locations; Run-off drain; Sewage Lines; Water Supply Hydrants

4.0 Authority & Responsibility

The Quality & Environmental Manager is responsible for the environmental accident prevention, emergency response and incident notification procedure. The Laboratory Technician is responsible for the procedure in the absence of the Quality & Environmental Manager. Outside of office hours, the Shift Co-ordinator is responsible for the procedure.

5.0 Health & Safety Site health and safety procedures apply as appropriate.

6.0 Procedure 6.1 Accident Prevention Policy

It is the policy of SmartPly to operate and accident prevention programme to ensure that accidents with a potential impact on health, safety and environment are prevented. This policy is implemented through a combination of activities including the following: − Site Safety Statement and associated risk assessments. − Clearance permit system incorporating risk assessment for routine & non-routine

tasks.

Controlled document if stamped ‘Controlled Document’.





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− Lock-out-tag-out system. − Planned preventive maintenance programme of plant incorporating maintenance

and electrical departments. − Continuous monitoring of operating conditions of essential plant equipment and

machinery. System incorporates warning alarms and automatic shutdown of equipment with significant health, safety and environmental impacts.

− Training of staff for plant and mobile equipment operations including incident & emergency response procedures.

− On-site 24hr emergency response team. 6.2 Environmental hazard to surface water emissions

SmartPly has an open drain (see Attachment 2) which encircles the enclosed production plant area. Surface water from this area is directed via the drain to two settlement ponds. The settlement ponds discharge to the River Suir at emission point SW-1A. Any spillage of oil, diesel, chemicals, resins, process scrubber water or fire water to the drains creates a risk of contaminated material being discharged to the river, particularly during heavy rain. Incident Prevention: − All chemicals, resins, oils and diesel are stored in labelled tanks or original

containers within bunded areas or storage units (Attachment 5). − Level sensors and high level alarms are fitted to relevant storage tanks and sumps. − Hauliers delivering bulk volumes of resins, diesel, gas, chemicals or removing

wastes are trained in correct handling, loading/unloading and emergency response procedures for that specific load, should an incident arise.

− Authorised SmartPly operators are trained in the unloading of resin tankers and in forklift driving for unloading miscellaneous deliveries of IBCs and drums of chemicals and oil.

− Spill kits and wood fines are available in the event of a spillage to assist with containment. All contaminated materials will be disposed of in accordance with the IE Licence conditions.

Emergency Response: − In the event of a large spill from a bulk road tanker or on-site tank of oil, diesel,

chemical, resin, process scrubber water or fire water spill to an outside yard area, the shift DGH Operator should be contacted to bring wood fines to the location of the spill.

− The shift DGH will use the L70 loader to spread sufficient wood fines on the spill to ensure containment and allow soakage.

− In the event that some of the spill has the drain, the DGH Operator will divert the drain to the emergency holding ponds to allow any contaminated surface water to






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be contained. There are two emergency holding ponds which can be used in such emergency situations. Each pond has a capacity of 2,500m3.

6.3 Environmental hazard to air emissions

Fire Risk SmartPly utilises a wet electrostatic precipitator (WESP) for the treatment of emissions from the press, four dryers and biomass furnace. In the event of extreme high temperatures there is a risk of fire along the crude gas lines and in the WESPs which could result in an explosion in the WESPs if left undetected. Incident Prevention: − Before treatment, air emissions are pre-moistened with process scrubber water

along the crude gas line to ensure gas is cooled and temperatures are maintained at a safe level.

− Temperature probes are used to monitor the crude gas line and WESP temperatures.

− Temperature alarms are in place to activate when temperatures exceed a specific limit.

− Emergency shutdown of WESP high tension wires will occur when specific temperature levels are exceeded.

− In emergency activation WESP inlet gates will automatically close and divert untreated air emissions to atmosphere via the emergency abort stack.

− The fire water system will automatically activate along the crude gas line in the event of a fire.

Emergency Response: − In the event of a fire in the crude gas line, the Control Room Operator will shut

down all in-feeding equipment and WESP high tensions if not automatically shutting down.

− WESP inlet gates will be closed to prevent fire travelling to the WESPs. − The Shift Emergency Response Team will be deployed and all required fire

control measures will be activated. Equipment Failure In the event of WESP equipment failure there is a risk of release of insufficiently treated air emissions from the WESPs or unscheduled releases from the emergency abort stack. Incident Prevention: − Key WESP equipment and operating parameters are monitored continuously

online. These included high tension mA and kV, pump flows and status,






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temperature and pressure readings and valve open – close status. Corrective and preventive action is taken in the event that a measured parameter is outside the acceptable limits of control.

− An alarm system for warning and failure of key WESP equipment and operating parameters is in place.

− A WESP preventive maintenance programme is operated. − A WESP cleaning schedule is adhered to. − An inventory of spare parts and replacements is maintained in the Stores. Emergency Response: − In the event of failure or underperformance of WESP equipment and operating

parameters, shift DGHs will investigate and rectify the issue immediately. − If WESP entry is required, the necessary dryers will be turned off, or a production

stop will be taken to facilitate safe entry to the WESPs. Actions required to rectify the issue will then be carried out.

− In the event it is not possible to rectify the issue immediately, the relevant equipment or WESP will be taken off-line and operations will be scaled back accordingly. This will be carried out in consultation with the Quality & Environmental Manager, Process Engineer, Production Manager and Operations Director on a case by case basis.

6.4 Environmental hazard to land and groundwater

SmartPly has a number of liquid storage tanks of various sizes on site. These are used to store LPG, gas oil, resins, release agent and wax. Smaller volumes of miscellaneous liquids including inks, chemicals and oils, are stored in 1,000L IBCs and various sized drums. A risk of contamination of land and groundwater may occur in the event of rupture or leaks from any of these vessels. Incident Prevention: − All storage tanks, with the exception of LPG, are located within bunded areas (see

Attachment 5) that comply with the EPA’s IPC Guidance Note on Storage and Transfer of Materials for Scheduled Activities.

− Bund integrity testing is carried out once every three years. − Bund inspections are carried out on a weekly basis by the Laboratory Technician. − Level indicators are provided on relevant storage tanks. Emergency Response: − In the event of a rupture of a storage tank to a containment bund the spill will be

contained immediately using wood fines and/or spill kit material. − In the event the spill reaches the site surface water drain, the response will be in

accordance with section 6.2 of this procedure.






Revision No. - 03 6.5 Incident Notification

Condition 11 of SmartPly’s IE Licence P0001-03 specifies requirements for reporting incidents to the EPA. The licence requires the following incidents be reported:

1. Any release of environmental significance to atmosphere from any potential emission point including bypasses.

2. Any emission which does not comply with the requirements of the licence. 3. Any malfunction or breakdown of key control equipment or monitoring

equipment, set out in Schedule C: Control & Monitoring, which is likely to lead to loss of control of the abatement system.

4. Any incident with the potential for environmental contamination of surface water or groundwater, or posing an environmental threat to air or land, or requiring an emergency response by the Local Authority.

6.5.1 SmartPly is required to report the details of the incident by telephone and through

ALDER to the EPA. Notification of the incident to the EPA should be carried out as soon as practicable after occurrence. − During office hours this is the responsibility of the Quality & Environmental

Manager or designated person. − Outside of office hours, it is the responsibility of the Shift Coordinator to notify

the EPA by telephone. − The incident will be reported through ALDER by the Quality & Environmental

Manager or designated person as soon as practicable. 6.5.2 To determine the significance of an incident, the EPA provides a classification system

which is based on the effect or the potential to impact the environment. All incidents must be categorised and reported in accordance with the EPA’s Guidance to Licensees/COA holders on the Notification, Management and Communication of Environmental Incidents. Incident categories are described in the guidance as follows:






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Ranking Classification Impact on the environment

1 Minor

No contamination, localised effects • Minor effect on air quality as evidenced by dust

or odour complaint(s) • ELV (emission limit value) breaches • An emission which does not comply with the

requirement of the licence/COA (A pattern of repeated minor incidents should be taken into account when considering the level of response)

2 Limited

Simple contamination, localised effects of short duration • Local limited impact to water, land and air • Notification to and short term closure of

potable water extractors required

3 Serious

Simple contamination, widespread effects of extended duration • Significant effects on water quality • Major damage to an ecosystem (e.g. significant

impact on fish population)

• Longer term closure of potable water extractors • Significant reduction in amenity value • Significant damage to agriculture or commerce • Significant impact on man

4 Very Serious Heavy contamination, localised effects of extended duration

5 Catastrophic Very heavy contamination, widespread effects of extended duration

The following should also be considered as part of the assessment: − The effects on water quality. − The potential for damage to an ecosystem (e.g. impact on fish population). − Any requirement for notification or closure of potable water extractors. − The potential reduction in amenity value. − The potential for damage to agriculture or commerce. − The broader impact on man. − The remedial action necessary. − The likely timescale of short term and longer term environmental consequences. − The environmental consequences of likely response action. − Any injury or loss of life caused by the incident.

6.5.3 ALDER Notification

The incident must be reported to the EPA via ALDER. The EPA Incident Notification Form must be uploaded to ALDER & all required details filled in on the EPA






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webform on ALDER (Responsibility of Quality & Environmental Manager or designate).

6.5.4 Telephone Notification

The incident must be communicated to the EPA by telephone. It is not appropriate to email or leave a telephone message for an inspector. EPA office hours are Monday to Friday, 9am to 5pm. Outside of office hours, incidents should be notified by telephone to the EPA headquarters, or if unavailable, by telephoning any of the Regional Inspectorates at the numbers below:

EPA Headquarters

EPA Regional Inspectorate

Kilkenny

EPA Regional

Inspectorate Cork


Dublin


Castlebar PO Box 3000 Johnstown Castle Estate Co. Wexford

Tel: 053-9160600

Seville Lodge Callan Road Kilkenny

Tel: 056-7796700

Inniscarra Co. Cork

Tel: 021-4875540

McCumiskey House Richview Clonskeagh Road Dublin 14

Tel: 01-2680100

John Moore Road Castlebar Co. Mayo

Tel: 094-9048400

Callers are given the option to record a message or an urgent environmental pollution incident message. Rank 2 to 5 incident notifications should be recorded as urgent environmental pollution incidents to ensure that the message is accessed and assessed by EPA staff. The EPA staff member will assess the message and decide what action/response is required by the EPA. Rank 1 incidents notifications should be recorded as regular messages. When calling outside of office hours, a standard greeting will be heard as follows: “Thank you for calling the Environmental Protection Agency. Our office hours are from 9am to 5pm, Monday to Friday. Please hold now for further options”. “If you wish to leave a message for the Environmental Protection Agency, which will not be dealt with until the following day, please dial 1 now” (Option 1 below – Rank 1 incident notifications). “If you wish to report an urgent environmental pollution incident requiring immediate response, please dial 2 now” (Option 2 below – Rank 2-5 incident notifications). “To listen to this recorded message again, please dial 3 now.” If the caller selects Options 1 or 2 a further message is played as follows:






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Option 1 “After the tone please leave a message for the Environmental Protection Agency and your name and contact telephone number. Your message will be dealt with when our offices reopen. If you wish to return to the main menu press 0”. Option 2 “After the tone please leave a message detailing the nature, extent and location of the environmental pollution and your name and contact telephone number. If you wish to return to the main menu press 0”. Other relevant Agencies should be notified where necessary. In the case of polluting discharges to river contact: Kilkenny County Council, Environment Section: 056-7794470 Inland Fisheries Ireland (Clonmel): 052-6180055 Irish Coast Guard, Pollution & Salvage Manager (Dublin): 01-6783454 Dunmore East RNLI Lifeboat: 051-383268 Port of Waterford: 051-874907 Other Agencies which may need to be contacted include: Calor Gas Emergency Service (Dublin): 01-2694800

6.5.5 Information to be communicated Details to be communicated to the EPA in the event of an incident are as follows:

1. Name, address and licence registration number (SmartPly = P0001-03) 2. Name of person submitting the incident notification 3. Incident classification and ranking 4. Details of the incident 5. Date of incident, approximate start time and details of when the incident was

first noticed 6. Whether or not the incident is still occurring and finish time and date if

stopped 7. New or reoccurring incident – a reoccurring incident is defined as an incident

that has taken place which is similar to a previous incident and both took place because of the same cause

8. Uncontrolled release/no uncontrolled release 9. Incident nature – e.g. explosion, fire, spillage, odour, breach of ELV 10. Details of any vulnerable receptors – list any receptors which may be impacted

on-site or off-site e.g. river, groundwater, town land area 11. Details of emission limit value exceedance if applicable 12. Specify grab or composite sample if incident is in relation to a water sample






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13. The location of the incident and discharge point if relevant 14. If digital photographs were taken 15. Odour details if applicable 16. Weather details at time of incident and wind direction. Check wind sock for

wind direction 17. Details of who was notified – list other Agencies if applicable 18. Corrective and preventive actions taken or planned 19. Likelihood of reoccurrence 20. Any other relevant detail or supporting information

A non-conformance report must also be completed on the incident and corrective/preventive actions taken. This will be maintained by the Quality & Environmental Manager.

6.6 Emergency response actions In the event of an emergency occurring on-site, the Quality & Environmental Manager or Shift Coordinator is required to ensure that the following on-site action is taken: − Deploy the necessary resources to deal with the incident. − Notify the EPA and relevant Agencies as deemed necessary. − Activate the facility’s Emergency Response Procedure where necessary. − Initiate appropriate corrective actions to deal with the incident. − Initiate appropriate preventive actions to prevent reoccurrence of the incident. − The potential for damage to an ecosystem (e.g. impact on fish population). − Any requirement for notification or closure of potable water extractors. − Comply with the requirements of licence conditions in relation to the

investigation, notification, management and reporting. − Ensure an appropriate level of contact with the public/media for the impact

ranking. 7.0 Records

− Online EPA ALDER Incident Notification Form − Non-conformance report

8.0 Attachments

Attachment 1: EPA (2010) Guidance to Licensees/COA holders on the Notification, Management and Communication of Environmental Incidents. Attachment 2: Map of surface water run-off drain Attachment 3: Map of sewage lines Attachment 4: Map of water supply hydrants Attachment 5: Map of bund locations


EPA Guidance to Licensees/COA holders on the Notification, Management and

Communication of Environmental Incidents

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1. Introduction

This guidance does not purport to be a legal interpretation of the requirements of licences/certificates of authorisation (COA) issued by the Environmental Protection Agency. The aim of this document is to provide guidance to licensees/COA holders on communicating the necessary information to those dealing with environmental incidents to ensure that they can respond promptly and effectively and relay the appropriate level of communication to stakeholders. This guidance is related primarily to notification of incidents to the EPA, and other bodies. Licence‟s/COA‟s issued by the Agency include conditions requiring notification of incidents to the Agency and other relevant bodies. Licensees/COA holders are reminded of their obligations under these conditions and should ensure compliance as required. Licensees/COA holders should strive to build a good relationship with their local community and keep local residences informed of the activities carried out within their area. The licensee/COA holder should ensure that the local community is kept informed of any incidents or issues that may affect them. This guidance also provides information on how information on incidents is published to the EPA‟s website. Although every effort has been made to ensure the accuracy of the material contained in this publication, complete accuracy cannot be guaranteed. The Environmental Protection Agency does not accept any responsibility whatsoever for loss or damage occasioned, or claimed to have been occasioned, in part or in full as a consequence of any person acting or refraining from acting, as a result of a matter contained in this publication. All or part of this publication may be reproduced without further permission, provided the source is acknowledged.

2. Classification of Environmental Incidents

To determine the significance of an incident the Agency provides the following classification system, which is based on their effect or potential to impact on the environment. Licensees/COA holders should rank all reported incidents into one of the rankings listed below when reporting incidents to the EPA. An incident is typically defined in the IPPC/Waste licences as:

(i) an emergency1; (ii) any emission which does not comply with the requirements of this licence; (iii) any exceedance of the daily duty capacity of the waste handling equipment; (iv) any trigger level specified in this licence which is attained or exceeded; (v) any indication that environmental pollution has, or may have, taken place.

and in UWWTP licences/COA‟s as: (i) any discharge that does not comply with the requirements of this licence; (ii) any incident with the potential for environmental contamination of surface water or

groundwater, or posing an environmental threat to land, or requiring an emergency response by the relevant Water Services Authority.

1An emergency is defined as any unexpected or potentially dangerous situation, requiring immediate action which may have caused, or

might have caused if the action had not taken place, an unauthorised environmental release or breach of licence conditions

ENVP052Attachment 1



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Table 1 provides the definitions associated with each level of environmental impact and should be used as a basis for the assessment of an incident. The following should also be considered as part of the assessment:

The effects on water quality The potential for damage to an ecosystem (e.g. impact on fish population) Any requirement for notification or closure of potable water extractors The potential reduction in amenity value The potential for damage to agriculture or commerce The broader impact on man The remedial action necessary The likely timescale of short term and longer term environmental consequences The environmental consequences of likely response action Any injury or loss of life caused by the incident

The environmental impact scale used in Table 1 is the same as that used in the National Framework for Major Emergency Management (MEM). The MEM definitions are given in italics below with further EPA criteria in regular font. The new classification system goes from 1 to 5 with one being a minor impact on the environment up to 5 being Catastrophic. The classification system being replaced went from 3 to 1 with 3 being the classification of minor impact.

Table 1 – Environmental Impact Assessment Criteria Ranking Classification Impact on the environment

1 Minor No contamination, localised effects Minor effect on air quality as evidenced by dust or odour

complaint(s) ELV breaches An emission which does not comply with the requirement of

the licence/COA (A pattern of repeated minor incidents should be taken into account when considering the level of response)

2 Limited Simple contamination, localised effects of short duration Local limited impact to water, land and air Notification to and short term closure of potable water

extractors required 3 Serious Simple contamination, widespread effects of extended

duration Significant effects on water quality Major damage to an ecosystem (e.g. significant impact on fish

population) Longer term closure of potable water extractors Significant reduction in amenity value Significant Damage to agriculture or commerce Significant Impact on man

4 Very Serious Heavy contamination, localised effects of extended duration

5 Catastrophic Very heavy contamination, widespread effects of extended duration



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Rankings of very serious or catastrophic impact on the environment are new incident classifications and are for incidents at a level that would be considered major emergencies. A major emergency is defined as an event which, usually occurs with little or no warning, causes or threatens death or injury, serious disruption of essential services, or damage to property, the environment or infrastructure beyond the normal capabilities of the principal emergency services in the area in which the event occurs and requiring the activation of specific additional procedures to ensure an effective, co-ordinated response.

3. Response by Licensees/COA holders to Incidents

Licensees/COA holders should take the appropriate response in accordance with the level of ranking of the incident. The licensee‟s/COA holder‟s response should include the following:

Deploy the necessary resources to deal with the incident. Notify the relevant bodies as specified in the licence/COA plus other bodies as deemed

necessary. Activate the facility‟s Emergency Response Procedure where necessary Initiate appropriate corrective actions to deal with the incident Initiate appropriate preventative actions to prevent a reoccurrence of the incident. Comply with the requirements of the licence/COA conditions in relation to the

investigation, notification, management and reporting. Ensure an appropriate level of contact with the public/media for the impact ranking.

4. Notification of the incident to the EPA and other Bodies

The licensee/COA holder is required to communicate the details of the incident by telephone and by fax to the EPA. The licensee/COA holder should fill in the Incident Notification Form in Annex 1 and fax it to the EPA as per the incident notification requirements of your licence/COA. The licensee should document an Incident Notification Procedure which incorporates the incident notification requirements of the licence and this guidance document. Licensees/COA holders should continue to report incidents to the EPA Regional Inspectorate from where your OEE inspector is based. The contact details for each of the Regional Inspectorates are provided in the attached guidance (Annex 2).

During Office Hours

The licensee/COA holder is required to communicate the details of the incident to an EPA inspector by telephone and by fax. It is not appropriate to email or leave a telephone message for an inspector. Office hours are 09:00 – 17:00, Monday to Friday.

Outside Office Hours (Annex 3)

The licensee/COA holder is required to communicate the details of the incident by telephone and by fax using the Incident Notification Form in Annex 1 of this Guidance. Notifications of environmental incidents outside normal working hours can be made by telephone to EPA headquarters on telephone



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number 053 9160600, or by telephoning any of the Regional Inspectorates2. Callers are given the option to record a message or an urgent environmental pollution incident message. Licensees/COA holders are advised that all Rank 2 to 5 incident notifications should be recorded as urgent environmental pollution incidents to ensure that the message is accessed and assessed by EPA staff. The EPA staff member will assess the message and decide what action/response is required by the EPA. Rank 1 Incident notifications should be recorded as a non-urgent environmental incident.

5. Emergency Response Procedure (ERP)

The typical licence/COA requires that a licensee/COA holder prepare and maintain an environmental emergency response procedure. The ERP should be activated where necessary in responding to incidents. The ERP should reference the Incident Notification Procedure and/or the incident notification requirements of the licence. As part of the ERP the Environmental Manager is required to ensure that at a minimum the following action is taken:

The Environmental manager is required to:

Contact the Emergency Response Agencies and the Environmental Protection Agency to communicate the incident details.

Be available to take calls regarding the incident. Keep appraised of the on-going situation in order to determine the appropriate level of

response from staff. Provide and support the technical response to the incident. Ensure that suitable safety precautions are in place regarding any on-site response. Provide and support the monitoring and analytical response. Advise on notification to the public and other Agencies. Advise on remedial action necessary including preventative action i.e. potable water

supplies. Ensure compliance with the incident notification conditions of the licence.

Interaction with Other Agencies

The following emergency response Agencies have a role to play in incident response and should be contacted where necessary: Local Authority, Fire Service, Health Service Executive, Gardaí, Health and Safety Authority, Fisheries Board, Sanitary Authority, Food Safety Authority, Irish Coast Guard, RNLI, Harbour Masters.

As part of the ERP the licensee/COA holder should identify the relevant Agencies and their contact details that may be required for incident response at their facility.

6. Policy on Publication to the EPA Website

Publication of incidents to the web-site

Typically incidents of Rank 2 and higher will be posted to the Web where the following occurs or has potential to occur.

Major fish kill.

2 Regional Inspectorates switchboards are forwarded to HQ at close of business each day. In the event of any line fault; licensees/COA holders should call the Wexford office directly.



5

Page 5 of 11

Gross environmental pollution. Significant disruption of downstream WWTP‟S. Disruption of drinking water supplies. Disruption to users of amenity areas. Danger as a result of environmental pollution to residents in the locality. Major fire resulting in environmental pollution. Significant clean-up expected as a result of a specific incident. Involvement of emergency services. Where there are a notable number of complaints or there is a need to reassure the public

that there is no environmental impact. Prior to publication of an incident on the website, a review with site personnel will be conducted by the EPA and the facility will be informed of the intention to post the notification. In general, incidents that have no offsite impact or onsite health impact will not be posted on the website. Typical incidents that will not be published to the EPA web site include:

Spills that are fully contained on site in bunds or tanks. Minor spills where the material is removed in sawdust/sand/soil. Non-compliance with licensed/COA emissions that are not significant and that are being

dealt with by way of an agreed programme of works or corrective action by the company. Thermal oxidiser bypasses that are in accordance with the EPA protocol for such by-

passes. Odour complaints unless indicating more significant pollution problems. Exceeded trigger levels at landfills that are not significant and that are being dealt with by

way of an agreed programme of works or corrective action by the company. Landfill Flare breakdown. Acts of vandalism with no environmental impact. Minor fires that are dealt with on-site.

Follow up and close out of incidents by the EPA

Following the investigation of an incident the EPA‟s site inspection report, when completed, will be placed on the public file. Further follow up of the incident may include verification of the corrective actions, preventative actions and remediation measures taken by the company, determination of the significance and impact if any and specification of any further enforcement action considered necessary by the Agency.

The timeline for close out of the notification on the website will vary depending on the complexity and seriousness of the incident. The objective will be to post an update to the original website notice within one month of the incident occurring in the case of non complex incidents and within two

months of complex incidents. Notices will be removed from the website two months after the close out paragraph has been added to the original notice or in the case of incidents which result in enforcement action after the case has been heard.

Annex 1 Incident Notification Form

Licence/COA Number Licence/COA Name

Licensee/COA Address:

Incident notification form submitted by:

Licensees/COA holders Environmental Impact Ranking:

1 2 3. 4. 5.

Details of incident:

Date of incident:

Approximate start time of incident(Provide range if time is not known)

Details of when incident first noticed:

Still ongoing: Yes/No Finish time and date

New or reoccurring incident1

Uncontrolled release: Air Water Sewer Ground No uncontrolled release

Incident Nature (Explosion, Fire, Spillage, Odour, Breach of ELV, Monitoring Equipment offline, Trigger Level Reached, Uncontrolled Release, Other – specify)

Details of any vulnerable receptors

Details of ELV Exceedance if available2 (Provide measurement units for values provided)

Parameter

Value

Grab or Composite sample

Location of incident: Discharge point/Other

Annex 1

Page 7 of 11 Guidance to Licensees/COA holders on the Notification, Management and Communication of Environmental Incidents

Digital Photographs taken: Yes/No

Odour3 Not applicable Odour detected

Odours detected

Extent4 Intermittent Persistent

Sensitivity5 Remote Low Moderate High Extra

Intensity6 Faint Moderate Strong Very strong

Weather at time of incident:

Wind Direction:

Details of who was notified: EPA by telephone Local Authority Fisheries Other

Corrective actions taken:

Preventative actions taken or planned:

Likelihood of reoccurrence

Details of any other relevant detail or supporting information for submission to the Agency

This section should be completed by the licensee/COA holder for their records once the corrective and

preventative actions are complete7

Follow up actions

Close out date Signed Position

Annex 1


Explanatory notes:

1. A Reoccurring incident is defined as an incident that has taken place which is similar to a previous incident and both took place because of the same cause.

2. If monitoring results are not available at the time of the incident notification they should be forwarded to the Agency as soon as they become available.

3. For further information on Odour Assessment please refer to the document „Odour impact Assessment Guidance for EPA licensed sites‟ on the EPA website: http://www.epa.ie/downloads/advice/air/emissions/name,28713,en.html

4. Odour Extent: Intermittent (detected intermittently during the period of assessment) or Persistent (detected throughout the period of assessment).

5. Odour Sensitivity: Remote (no housing, commercial/industrial premises or public area within 500m of observation point); Low sensitivity (no housing, commercial/industrial premises or public area within 100m of observation point); Moderate sensitivity (housing commercial/industrial premises or public area within 100m of observation point); High sensitivity (housing, commercial/industrial premises or public area within area of observation point); Extra sensitive (complaints arising from residents, business and users of public areas within area of observation point).

6. Odour Intensity: Faint Odour (barely detectable, need to stand still and inhale facing into wind); Moderate Odour (easily detectable while walking and breathing normally, possibly offensive); Strong Odour (bearable but offensive – might make clothes / hair smell?); Very Strong Odour (unbearable, difficult to remain in area affected by odour).

7. This section is separate to the initial incident notification. This section should be completed by the licensee/COA holder after the corrective and preventative actions have been completed and the incident can be closed out. It should be maintained on site as part of the licensee‟s /COA holder‟s records.

Annex 2


EPA Regional Offices

EPA Headquarters PO Box 3000 Johnstown Castle Estate Co. Wexford Tel: 053-9160600 Fax:053-9160699

EPA Regional Inspectorate Dublin McCumiskey House Richview Clonskeagh Road Dublin 14 Tel: 01-268 0100 Fax: 01-268 0199 EPA Regional Inspectorate Cork Inniscarra Co. Cork Tel: 021-4875540 Fax: 021-4875545 EPA Regional Inspectorate Castlebar John Moore Road Castlebar Co. Mayo Tel: 094-9048400 Fax: 094 9048499.

EPA Regional Inspectorate Kilkenny

Seville Lodge Callan Road Kilkenny Tel: 056-7796700 Fax: 056-7796798

Annex 2


Annex 3


Leaving a Phone Message Outside Office Hours

The licensee/COA holder is required to communicate the details of the incident by telephone and by fax. Notifications of environmental incidents outside normal works hours can be made by telephone to EPA headquarters on telephone number 053 9160600, or by telephoning any of the Regional Inspectorates3. Callers are given the option to record a message or an urgent environmental pollution incident message.

If a caller dials HQ, or a *Regional Inspectorate they will hear a standard greeting and are given options to record a message as follows:

“Thank you for calling the Environmental Protection Agency. Our office hours are from 9 am to 5pm Monday to Friday. Please hold now to hear further options”

“If you wish to leave a message for the Environmental Protection Agency, which will not be dealt with until the following day, please dial 1 now”

“If you wish to report an urgent environmental pollution incident requiring immediate response please dial 2 now”

“To listen to this recorded message again, please dial 3 now”

If the caller selects Options 1 or 2 a further message is played as follows:

Option 1

“After the tone please leave a message for the Environmental Protection Agency and your name and contact telephone number. Your message will be dealt with when our offices re-open” If you wish to return to the main menu press 0.

Option 2

“After the tone please leave a message detailing the nature, extent and location of the environmental pollution and your name and contact telephone number. If you wish to return to the main menu press 0.

Note: Urgent environmental Pollution incidents are for incidents with a ranking of 2 to 5.

3 Regional Inspectorates switchboards are forwarded to HQ at close of business each day. In the event of any

line fault; licensees/COA holders should call the Wexford office directly.

ENVP052Attachment 2

ENVP052Attachment 3

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6. RESI~~ l~jFEED BU~W

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8. PRESS PIT

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ENVP052Attachment 5

ATTACHMENT NO K

REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE

1. Existing Measures

Additional Documents Included:

Residuals Management Plan for SmartPly Europe Ltd.

Environmental Liabilities Risk Assessment for SmartPly Europe Ltd.

SmartPly Europe Ltd. P0001-03 Attachment K

1. Existing Measures

Measures to minimise closure impact and for post-closure care are addressed in the Residuals Management Plan included in this Attachment. This document applies to the current plant configuration. The RMP will be updated for the new plant configuration in due course.

An Environmental Liability Risk Assessment has also been carried out for the installation and is also attached.

K-2

Residuals Management Plan April 2006 SmartPly Europe

_______________________________________________________________________Malone O' Regan

TABLE OF CONTENTS 1.0 EXECUTIVE SUMMARY 1 2.0 INTRODUCTION 2 2.1 The Facility 2 2.2 Requirement for a Residuals Management Plan 2 2.3 Site Closure: Comments and Assumptions 3 2.4 Structure of Residuals Management Plan 4 3.0 SITE ASSESSMENT 5 3.1 Site Description and History 5 3.2 Site Evaluation and Issue Identification 6 3.2.1 Asbestos and Electrical Equipment 6 3.2.2 Aboveground Storage Tanks 6 3.2.3 Waste and Chemical Storage 7 3.2.4 Sumps and Drains 7 3.2.5 Oil and Gas Pipelines 7 3.2.6 Underground Storage Tanks 7 3.3 IPPC Licence Compliance 7 3.4 Scope of RMP 7 3.5 Exclusions from RMP 8 4.0 CRITERIA FOR SUCCESSFUL DECOMMISSIONING 9 5.0 MANAGEMENT OF THE RMP 10 5.1 Technical Review Team 10 5.2 Co-ordination with Relevant Authorities 10 6.0 PROGRAMME TO ACHIEVE STATED CRITERIA 12 6.1 Phase One Decommissioning and Decontamination 12 6.1.1 Introduction 12 6.1.2 Stage 1 : Production Decommissioning 13 6.1.3 Stage 2: Removal of Excess Raw Materials and Final

Product 17

6.1.4 Stage 3: Removal of Hazardous and Non-Hazardous Wastes

17

6.1.5 Stage 4: Cleaning of the Production and storage facilities 21 6.1.6 Stage 5: Drain Surveying and Cleaning 21 6.1.7 Stage 6: Decommissioning of Site Services 22 6.1.8 Stage 7: Removal of Residual Hazardous Materials 22 6.1.9 Stage 8: Documentation and Certification of Residuals

Management Plan 23

6.2 Phase Two – Long Term Monitoring and Residuals Management

23

6.2.1 Introduction 23


_______________________________________________________________________Malone O' Regan

6.2.2 Characterisation of Potential Source Areas of Chemical Release

23

6.2.3 Design / Implementation Source Area Soil Remediation Programme (as appropriate)

24

6.2.4 Management of Corrective Action Programme with Post Remediation Monitoring.

24

7.0 SUMMARY OF COSTS ASSOCIATED WITH THE RMP 25

8.0 UNDERWRITING THE RMP 26 Figure 1: Regional Location Figure 2: Site Boundary Figure 3: Process Flow Diagram


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1.0 EXECUTIVE SUMMARY MOR was commissioned by SmartPly Europe Limited to prepare a residual management plan (RMP) for a potential future decommissioning of its facility at Belview Port Slieverue, Co. Kilkenny in compliance with its commitments under condition 10 of Integrated Pollution Prevention and Control (IPPC) licence Reg. No. 731. SmartPly Europe operates to a strict environmental policy and is a wholly owned subsidiary of Coillte Teoranta, the state forest management company. As a result any closure of the facility is likely to be known well in advance and conducted in a highly organised and well funded fashion. Groundwater monitoring has been conducted on a bi-annual basis since 1995 and to date no evidence of groundwater or soil contamination has been detected. The programme for the RMP is primarily driven by the requirement for the decommissioning of the site in a manner which ensures minimum impact on the environment. It is envisaged that in the event of closure of the SmartPly facility that removal of hazardous wastes, decontamination of drains, sumps and pipelines will be carried out in an organised fashion over a 3 month period. The approximate cost of implementation of the RMP is estimated to be in the region of €500,000. The total cost includes the removal of all hazardous and non hazardous waste materials from the site, the cleaning of tanks and pipework and the on-going monitoring of ground water at the site for a period of 2 years following the cessation of operations. Coillte places a strong emphasis on achieving balance between commercial, environmental and social objectives in managing business. Should any potential cessation of operations occur while SmartPly is in Coillte's ownership, such a cessation will be a well managed exercise underwritten from Coillte's own internal resources.


_______________________________________________________________________Malone O' Regan -2-

2.0 INTRODUCTION 2.1 The Facility

SmartPly Europe Limited is located in Belview Port, Slieverue, Co. Kilkenny, adjacent to the N29, as shown in Figure 1 attached. SmartPly Europe is a wholly owned subsidiary of Coillte Teoranta, the semi-state forest management company. The facility was issued with an Integrated Pollution Control (IPC) licence (Reg. No. 1) by the Environmental Protection Agency (EPA) on the 8th of June 1995. This licence was replaced in September 2005 with an integrated pollution prevention and control (IPPC) licence (Reg. No. 731). The facility produces commodity and construction grade orientated strand board (OSB) products, which are composite wood-based panel products composed of thin wafers of pine and spruce pulp-grade wood pressed under heat and pressure with wax, polymeric diphenylmethanediisocyanate (MDI) and an amine based resin. The SmartPly Europe Limited facility utilises a single multi-opening batch press with fourteen flights and a nameplate capacity of 350,000m3 per annum. The facility operates on a 24 hour basis, 7 days per week for an average of 330 days per year.

2.2 Requirement for a Residuals Management Plan

SmartPly Europe Limited is required under Condition 10 of IPPC Licence Register No. 731 to prepare, to the satisfaction of the Agency, a fully detailed and costed plan for the decommissioning or closure of the site or part thereof. Condition 10 of the Licence consists of the following: 10.1 Following termination, or planned cessation for a period greater than six

months, of use or involvement of all or part of the site in the licensed activity, the licensee shall, to the satisfaction of the Agency, decommission, render safe or remove for disposal/recovery, any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter contained therein or thereon, that may result in environmental pollution.

10.2 Residuals Management Plan:

10.2.1 The licensee shall prepare, to the satisfaction of the Agency, a fully detailed and costed plan for the decommissioning or closure of the site or part thereof. This plan shall be submitted to the Agency for agreement within six months of the date of grant of this licence.


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10.2.2 The plan shall be reviewed annually and proposed amendments thereto notified to the Agency for agreement as part of the AER. No amendments may be implemented without the agreement of the Agency.

10.3 The Residuals Management Plan shall include as a minimum, the

following:- 10.3.1 A scope statement for the plan.

10.3.2 The criteria which define the successful decommissioning of the activity or part thereof, which ensures minimum impact on the environment.

10.3.3 A programme to achieve the stated criteria. 10.3.4 Where relevant, a test programme to demonstrate the successful implementation of the decommissioning plan.

10.3.5 Details of costings for the plan and a statement as to how these

costs will be underwritten.

10.4 A final validation report to include a certificate of completion for the residuals management plan, for all or part of the site as necessary, shall be submitted to the Agency within three months of execution of the plan. The licensee shall carry out such tests, investigations or submit certification, as requested by the Agency, to confirm that there is no continuing risk to the environment.

2.3 SITE CLOSURE: COMMENTS AND ASSUMPTIONS

In order to develop a fully costed RMP for the site, a number of assumptions have been made with regard to the mode and management of a hypothetical site shut down. SmartPly Europe Limited operates an environmental management system in compliance with a strict environmental policy. Therefore any shutdown of the site is assumed to be a well-planned and well resourced event. This implies that the shutdown date will be known well in advance and that both production schedules and raw materials purchasing will be planned with the shutdown already factored in. It also implies that SmartPly Europe Limited will have the financial resources to implement the RMP through to completion – with no requirement for external financing. The plan will result in a decommissioned and decontaminated site.

The RMP and associated costs have been developed for a number of discrete phases and arranged in a logical sequence to facilitate complete site closure. The actual steps to be carried out and their associated costs for any partial shut downs may be derived from the RMP by simply reviewing that part of the RMP


_______________________________________________________________________Malone O' Regan -4-

which covers that specific activity. A general assumption is that the RMP will be reviewed regularly and updated as necessary.

2.4 STRUCTURE OF RESIDUALS MANAGEMENT PLAN

This Residuals Management Plan (RMP) includes the following:

• A scope statement for the plan;

• The criteria which define the successful decommissioning of the activity or part thereof, which ensures minimum impact to the environment;

• A programme to achieve the stated criteria.

• Details of costings to implement the RMP.

This RMP does not include; • A test programme to demonstrate the successful implementation of the

decommissioning plan. A proposal regarding the content of a test programme will be submitted to accompany the RMP at the commencement of decommissioning operations.

• A final validation report to include a certificate of completion for the residuals

management plan, for all or part of the site, as necessary, shall be submitted to the Agency within three months of execution of the plan.

Section 2 provides an overview of the need for an RMP and any comments and assumptions made.

Section 3 provides an overview of the scope of the RMP in terms of those buildings, activities and issues that are covered in the plan. Section 4 describes the proposed criteria to be used to demonstrate successful decommissioning and decontamination. Section 5 describes the RMP in a Project Management style with discrete stages and associated tasks. Two phases are considered:

Phase One: Decommissioning and Decontamination of all above and below ground structures – including management of residues arising.

Phase Two: Management of potential long-term residual soil and ground water contamination.

Section 6 provides a summary of the costs associated with implementation of the RMP.


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3.0 SITE ASSESSMENT 3.1 SITE DESCRIPTION AND HISTORY

SmartPly Europe Limited is located approximately four miles from Waterford city, in Belview Port, Slieverue, Co. Kilkenny, off the N29. Prior to the facility becoming a wholly owned subsidiary of Coillte Teoranta in May 2001, the facility was known as Louisiana Pacific Coillte Ireland (LPCI) Limited. LPCI was incorporated in Ireland in 1993 as a joint venture concern of Coillte and the US building products company Louisiana Pacific Corporation based in Portland, Oregon. Site preparation began in July 1994 with the first board being produced in March 1996. The site is approximately 26 hectares in size, as outlined in Figure 2 attached, with a single 2.3 hectare building situated within 10 hectares of log yard and yard space and 13 hectares of planted woodland. There are a number of ancillary buildings located around the site including a security/weighbridge office, portacabin offices and a pump house. The main production building is subdivided as follows:-

Administration, offices and canteen,

Production areas including log handling, flaking, drying, blending, resin storage, forming and pressing, sawline and board handling and storage,

External yard area for log delivery and storage,

External plant facilities including atmospheric emission abatement system

(WESPs), WESP water treatment plant, settlement ponds, firewater pond, overground storage tanks, sewage treatment plants, propane tanks, ESB substation, Security hut and weighbridge.

The raw materials used in production and auxiliary processes are listed as follows:

1. Pulpwood logs 2. MDI resin 3. Amino based resins 4. Synthetic wax emulsion 5. Release agent 6. Oil based antifoam 7. Hydraulic oil 8. Thermal oil 9. Water based acrylic paint 10. Ethanol based ink 11. Water based ink 12. Gas oil 13. Propane 14. Polyelectrolyte flocculent 15. Hydrogen peroxide


_______________________________________________________________________Malone O' Regan -6-

16. Caustic soda 17. Cardboard 18. Plastic strapping 19. Steel strapping

Figure 3 attached, shows a flow diagram for the principle manufacturing process.

3.2 Site Evaluation and Issue Identification

The facility is currently in full production with approximately 150 persons employed. An environmental management system (EMS) is in place. The site is regularly subjected to environmental monitoring and is audited by the EPA. The main building has a concrete floor throughout and chemicals are stored within bunded areas. Outside areas are paved in most areas surrounding the main building. The log yard is largely unpaved and consists of a number of concrete roadways, with the majority of the yard surface consisting of coarse gravel fill material on top of compacted clay. Groundwater monitoring data for the site is comprehensive with monitoring conducted prior to site works commencing in 1993 and subsequently on a bi-annual basis between 1994 and 2005. Since November 2005 groundwater monitoring has been conducted on a quarterly basis in accordance with revised licence conditions. No indications of contamination of groundwater due to on site activities have been detected in the groundwater analytical results since the commencement of sampling.

3.2.1 Asbestos/Electrical Equipment

The facility was constructed in 1994 and therefore it is unlikely that any materials containing asbestos or PCBs are present on site.

3.2.2 Aboveground Storage Tanks

The locations of the main aboveground storage tanks are illustrated in figure 2 and are described as follows:

1. Two gas oil storage tanks are situated outside the main furnace area. 2. A road diesel tank is situated outside the mobile equipment garage. 3. A primary propane tank is located adjacent to the mobile equipment

garage. 4. A secondary propane tank is located near to the shipping yard. 5. Six resin storage tanks are located within the main production building. 6. A thermal oil expansion tank is located in a bunded area adjacent to the

furnace room. 7. A hydraulic oil expansion tank is located in a bunded room adjoining the

main press. 8. Three bunded barrel stores for the storage of lubricants, paints and inks

are located outside the main building close to the offices.


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9. A bunded barrel store for the storage of chemicals used in the air pollution control equipment is located to the west of the plant.

10. The air pollution control equipment contains three large tanks for the purpose of storing scrubber liquors used in the air pollution control process.

3.2.3 Waste Chemical Stores

A waste chemical store is located within the main production building. This store is in use primarily for the storage of empty or near empty barrels and IBCs prior to disposal or return to supplier.

3.2.4 Sumps and Drains

There are two surface water drainage systems on site. Run-off from the roof and paved portion of the site discharges to the River Suir via a series of open culverts, bar and mesh screens, oil/petrol interceptors, monitoring chambers and settling tanks. Surface water run-off from the log-yard drains to the mill race stream via a number of french drains. Facilities are in place to automatically divert contaminated yard run-off to emergency holding tanks in the event of a fire or chemical spill. Foul water from the facility’s canteen and toilets discharges to the River Suir via a series of enclosed pipes and two sewage treatment plants, which are operated in parallel. A number of sumps are in operation throughout the site.

3.2.5 Oil/Gas Pipelines

All gas and oil pipelines are constructed above ground, with the exception of the main hydraulic oil supply to the press, which runs in a concrete compartment underneath the main press area. This hydraulic pipe is accessed via a steel access panel set into the press area floor.

3.2.6 Underground Storage Tanks

There are no covered underground storage tanks on the site, however a number of site activities and open tanks are set into or are located below ground level.

3.3 IPPC Compliance

SmartPly operate in compliance with their existing IPPC licence.

3.4 Scope of RMP

This proposed RMP addresses both short/medium-term actions and a longer-term programme. The short/medium term actions, Phase One, will involve


_______________________________________________________________________Malone O' Regan -8-

decommissioning and decontamination of all process related structures currently used for production activities. This will involve decommissioning and decontamination of all:

Production buildings

Service areas and drains

Storage areas

Residuals arising as a direct result of decommissioning

The RMP will also address the long-term actions, Phase Two, associated with potential residual soil and groundwater contamination that may have occur as a result of SmartPly Europe Limited activities across the site.

3.5 Exclusions from the RMP

Removal programmes and costs associated with the removal of plant equipment, demolition of the buildings, including disposal of building materials are not included in the total cost estimate for implementation of the RMP.

The RMP has been formulated on the understanding that ESB substations will be left intact on site in the event of a cessation of operations.


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4.0 CRITERIA FOR SUCCESSFUL DECOMMISSIONING

The criteria for successful decommissioning to ensure minimum impact to the environment with respect to residuals management are as follows:

The decontamination of all process equipment according to good manufacturing practice (GMP).

Documented and fully costed reports to ensure that all raw materials and

finished product have been dispatched from the site.

Documented and fully costed reports on the disposal of hazardous waste including full certification required under law (Trans-frontier Shipment of Hazardous Waste Regulations, Waste Management Act, 1996, Waste Management (Amendment) Act, 2001, Protection of the Environment Act and IPPC Licence).

Documented and fully costed reports on the disposal of non hazardous

wastes including all certification required under the Waste Management Act and the IPPC licence.

Documentation to determine that SmartPly Europe Limited have not

installed asbestos containing material on the site.

Documentation to determine that SmartPly Europe have no equipment containing PCBs/PCTs on site.

Documentation to determine that SmartPly have no equipment containing

radioactive substances on site.

Remediation of site soil and groundwater to pre-determined, risk based, remedial goals, agreed with the EPA and verified by a programme of groundwater monitoring post corrective action.

Note that, with respect to the above criteria, the costs and time to complete decommissioning should not exceed that estimated in the most up-to-date revision of the Residuals Management Plan in place at the time of decommissioning.


_______________________________________________________________________Malone O' Regan -10-

5.0 MANAGEMENT OF THE RMP 5.1 Technical Review Team

It is envisaged that the management of the RMP during decommissioning of the facility will be a responsibility of the Technical Review Team. This team will include personnel who will oversee various significant aspects of the RMP and will include:

• an environmental management team comprised of in-house and contracted environmental specialists who will oversee technical aspects of the implementation of the RMP;

• a financial management team who will oversee costs associated with implementation; and

• an operational management team who have a working knowledge of facility infrastructure and past operations.

It is envisaged that Coillte’s management will select team personnel and submit the results of the Technical Review Team selection to the EPA for approval prior to commencement of final decommissioning works. It is likely that the team will comprise the following:

• SmartPly Europe Technical Director (Mr. George Whelan); • SmartPly Europe Engineering Manager (Mr. Liam Robinson); • A Consultant Environmental Management/Remediation Specialist;

It is envisaged that specialist input will be provided for specific tasks from a number of specialist companies currently used by SmartPly Europe during their normal operations:

• Onyx - Licensed waste disposal company • Atlas Ireland - Licensed waste disposal company • Advance Cleaners or Dynorod – Drain cleaning and CCTV

services • Indaver Ireland – Licensed hazardous waste disposal company

5.2 Co-ordination with Relevant Authorities

The environmental management team will conduct all necessary communications related to RMP implementation with relevant authorities, i.e. the EPA and Kilkenny County Council etc. Contact details for the relevant authorities are as follows:

o Environmental Protection Agency

PO BOX 3000, Johnstown Castle Estate, Co. Wexford, Site Inspector: Mr. Tony Dolan Telephone: +353 53 60600


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o Kilkenny County Council County Hall, John Street, Kilkenny, Co. Kilkenny

Telephone: +353 56 7794000

o Health and Safety Authority 10 Hogan Place, Dublin 2 Telephone: +353 1 6147042

o Southern Regional Fisheries Board

Anglesea Street, Clonmel, Co. Tipperary

Telephone: +353 52 80055

o Kilkenny Fire Brigade

Gaol Road Kilkenny Co. Kilkenny Telephone: +353 56 7794400


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6.0 PROGRAMME TO ACHIEVE STATED CRITERIA 6.1 Phase One Decommissioning and Decontamination 6.1.1 Introduction

Phase One involves the decommissioning and decontamination of all above and below ground structures – including management of residues arising. The structure of Phase One of the RMP is based on a logical sequence of events (project milestones) that would occur in the event of a shutdown, similar in logic to an annual maintenance shutdown. However, the end point would be the removal of all materials from the site that could pose a residual threat to the environment. Below ground structures, including in-ground sumps and drains, are dealt with in Phase One only in relation to decontamination of internal surface areas i.e. emptying and flush/rinse etc. Issues associated with removal of structures and assessments of soil/groundwater contamination are dealt with in Phase Two. This phase is constructed in a Project Management style format with a number of Stages, each with a set of specific tasks that involve the management of residual waste. The individual stages are in a logical sequence however, some overlap in terms of time-lines is expected.

The individual stages are:

Stage 1: Production decommissioning; this stage would include the

continual draw-down of raw materials, the cancellation of raw material supply orders and the transfer of residuals to the main plant facility.

Stage 2: Removal of excess raw materials, bulk liquids and final

product from the site.

Stage 3: Removal of production related hazardous and non-hazardous wastes from the site.

Stage 4: Cleaning of the production and storage facilities.

Stage 5: Drain and tank cleaning and surveying.

Stage 6: Decommissioning of site services.

Stage 7: Removal of remaining hazardous materials.

Stage 8: Documentation and Certification of Decommissioning and

decontamination. Stage 9: Testing and Validation.


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Each stage is considered under the following headings

Tasks to Complete Stage

Cost to complete

Time to complete

Plant Status at Completion of Stage 6.1.2 Stage 1 : Production Decommissioning

This stage may be applied to the following main unit operations that occur within the production building;

Table 6.1 Unit Processes within SmartPly Facility

Unit Process Number units

OEM Model Capacity

Bark burning furnace 1 GTS Energy Geka 11MW (th)

Debarker Drums 2 Kone Wood 3076 57ton/hour

Waferizers 2 CAE 37/118 80ton/hour

Dry Storage Bins 3 PS&E Ltd P94-550 283m3

Wet Storage Bins 4 PS&E Ltd P94-550 283m3

Dryers 4 MEC 1360T 10.58T/hr

Screens 4 PS&E 8’X20’ 10.5T/hr

Blenders 3 COIL 10’x30’ 15.48 T/hr

Formers 4 Schenck 8’x24’ 44.38T/hr

Press 1 WIW 9713T S/N412

20cycles/hr

Stacker 4 Globe 94124 24’x8’

T&G Line Saws 2 Globe Globe 16B Globe 13H

350,000m3/ yr

Sander 2 Steinemann /Globe

Nova 130/R

130ft/min

Wet Electrostatic Precipitators

2 Hydroair/Scheuch Senna WESP

247,000 Am3/hr


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Task 1: Transfer all raw material & products to warehouse and drum

storage

Scale back deliveries of raw materials to site in accordance with anticipated closure date.

Using the normal production processes draw down all inventories of raw

materials to minimum achievable levels. Once production process steps are completed allow for transfer of products to warehouse storage area. Then, in respect of residuals in production area.

Maintain Geka furnace, thermal oil circulation and Wet Electrostatic

Precipitators (WESPs) in operation until all on site fuel stocks are consumed and to prevent thermal oil degassing.

Isolate resin, wax, MDI manifolds, drain materials back to bulk drum

storage, and purge manifolds.

Remove drums/IBCs of paints to drum storage units in the main plant.

Transfer any containers of raw materials to the warehouse in the main plant.

Create an inventory of obsolete, contaminated chemicals and transfer to

waste storage.

Remove unused wood fuels from ladig bin and dry fuel bin.

Remove all residual solvent ink from ink jet system and place in UN approved barrels. Remove barrels to the main drum storage area.

Remove and clean all inkjet and coating lines.

Remove all residual flake from formers, haul up conveyors and blenders.

Particular attention to be paid to flake that has been treated with MDI resin.

Task 2: Transfer all production wastes, hazardous and non-

hazardous, to storage. This task will specifically include:

Shut down Geka Furnace and slowly cool thermal oil using diesel back up furnace as necessary.

Remove ash from furnace and ash storage area to appropriate landfill

facility.


_______________________________________________________________________Malone O' Regan -15-

Shut down WESPs, drain scrubber cones to bulk tankers for waste disposal. Flush WESP pipework in accordance with GMP. Licensed waste disposal contractor to tanker scrubber liquor to approved waste water treatment plant.

Once controlled cooling of thermal oil has been achieved, transfer thermal

oil to bulk tankers or to UN approved and labelled drums and remove to the waste storage area in the main plant.

Transfer of residual resins from main storage tanks to UN approved and

labelled drums and remove to the waste storage area in the main plant. Where feasible good quality resins are to be returned to the suppliers.

Transfer of solid hazardous waste to UN approved and labelled drums

and remove to the solid waste storage area in the main plant.

Transfer of liquid hazard waste to UN approved 200 litre labelled steel drums.

Transfer of drums, from production buildings to the waste storage area in

the main plant.

Transfer of pallets to solid waste storage area.

Removal of general skip waste (e.g., office paper, packaging not product contaminated) to the solid waste storage area.

Create an inventory of obsolete solid chemicals, product samples and raw

material samples in the building and transfer to waste storage.

Task 3. Clean down of production areas Equipment should be cleaned according to their specific procedure; the cleaning process is divided into major and minor clean. The basic steps of the major clean that will be followed are as follows:

Specialist advice on Health and Safety requirements for handling waxes and resins from product manufacturers is obtained.

Ancillary attachments are removed from the equipment.

Empty vessels, not contaminated with MDI are washed out with hot water

and dried if possible.

Empty vessels and equipment contaminated with MDI are vented through a carbon filter system and residual liquid MDI removed to 200 litre barrels using appropriate safety precautions and in line with manufacturer’s instructions.

Ancillary equipment is washed with hot water and dried.


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An equipment status label is attached and where possible a clear

polyethylene bag is used to cover the equipment item.

Washings which have been contaminated with wax or resin, which will be produced during the cleaning process, will be collected in UN approved 200l steel drums and labelled.

Plant equipment may be sold for reuse or for scrap metal.

Plant Status at Completion of Stage 1

All site production equipment decontaminated and in a “safe to work” (and environmentally secure) state.

All production related residuals transferred to bulk storage or warehouse.

All auxiliary systems decommissioned.

Time to complete Production occurs 7 days per week. It will take approximately one to two weeks to complete a clean down of each area. Allowing for contingency time, it is estimated that Phase One would take approximately three-five working weeks to complete utilising the full compliment of production and maintenance staff at the SmartPly Europe Limited site. Cost With the exception of disposal of WESP liquor the costs of completing Phase One have not been calculated in monetary terms. As described in Section 2.2 it is assumed that the shutdown is a well planned and resourced event and all costs in terms of manpower will be allocated to normal plant running costs for the period in question.

Table 6.1. WESP Liquor Inventory

Waste Type EWC Code

Amount (tonnes)

Disposal Method

Estimated Cost (€)

WESP Liquor 03 01 99

400 Waste water treatment

100,000


_______________________________________________________________________Malone O' Regan -17-

6.1.3 Stage 2: Removal of Excess Raw Materials and Final Product

Task 1: Dispatch of finished product from final production runs. In line with normal production scheduling, all product will be dispatched, as it is produced. Task 2: Raw material Raw material purchase is planned on a schedule directly related to the planned production schedule. The date for plant shutdown will be known in advance, it is assumed that stocks of raw materials will be reduced accordingly and that the remainder will be transferred to the plant as a raw material. Where possible, any remaining stocks of raw materials and intermediates (logs, chips, sawdust and bark) after the plant has ceased production will be sold within the industry for appropriate re-use. Liquid resins, waxes and all other compounds will be transferred into labelled UN approved barrels and stored within dedicated drum storage units on site to await transfer to a disposal site. Where feasible all usable resins will be returned to suppliers for re-use, however due to their limited shelf life this may not be possible for all resin. In the case of gas and fuel oil, it is assumed that remaining quantities of these materials will be returned to the respective supplier.

Time to Complete A period of 3 weeks to document (including inventory lists) and arrange transport from the site is estimated. Cost The cost associated with Task 1 is not considered as it is assumed that costs for shipping will be absorbed as part of the net value of intermediates and products. The cost associated with Task 2 above is considered to be minimal as inventories will be drawn down in advance of closure.

6.1.4 Stage 3: Removal of Hazardous and Non-Hazardous Wastes

All substances that can be considered waste, either hazardous or non-hazardous, will have been placed in designated areas. The waste may include raw materials (detailed in stage 2) that cannot be returned to suppliers, used in the plant or sold on to interested third parties. In the case of hazardous waste disposal, all requirements of the IPPC Licence will be considered. This waste will require the prior written approval of the EPA before the waste can be removed from the site. Stage 3 will include the following tasks:


_______________________________________________________________________Malone O' Regan -18-

Administrative organisation of shipments.

Removal of the waste in accordance with appropriate National and EU Legislation.

Administrative organisation of relevant paper work. All waste shipments

during this period will be documented according to EPA Guidelines. This will facilitate the requirement to have stated criteria for proper decommissioning (see Section 3.0).

Tables 6.1, 6.2 and 6.3 summarise the expected quantities of hazardous waste and non-hazardous waste respectively that are expected to be exported from the site during decommissioning. The cost is based on a flat rate of €500 per metric tonne for transport and disposal of liquid hazardous waste, €1,500 per metric tonne for disposal of solid hazardous waste, €250 per metric tonne for transport and disposal of non-hazardous waste for landfilling and €250 per metric tonne for transport and disposal of non-hazardous liquid waste.


_______________________________________________________________________Malone O' Regan -19-

Table 6.2. Hazardous Waste Inventory

Waste Type EWC Code

Amount (tonnes)

Disposal Method


LPF Resin 08 04 09 75 Offsite Incineration with Energy Recovery

37,500

MDI Resin 08 05 01 75 Offsite Incineration with Energy Recovery

37,500

Thermal Oil 13 03 08 113 Offsite Incineration with Energy Recovery

56,500

Hydraulic Oil 13 01 10 16 Recycling 8000

Lubricating Oil 13 02 05 13 02 06

8 Recycling 1200

Ink Jet Ink 08 03 12 1 Offsite Incineration With Energy

Recovery

500

Flocculent 03 01 99 1 Offsite Incineration with Energy Recovery

500

Liquid Sodium Hydroxide 06 02 05 1 Recycling 500

Oil Based Antifoam 13 02 05 1 Offsite Incineration with Energy Recovery

500

Hydrogen Peroxide 16 09 03 2 Recycling 500

Contaminated Washings 08 04 15 40 Offsite Incineration With Energy

Recovery

20,000

TOTAL 443 €163,200


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Table 6.3. Non Hazardous Waste Inventory

Waste Type EWC Code

Amount (tonnes)

Disposal Method


Blender Waste 030105 2 Onsite Energy

Recovery

None

Reject Product 030105 50 Onsite Energy

Recovery

None

Wood fines 030105 100 Onsite Energy

Recovery

None

Nijhuis Sludge 030105 2 Onsite Energy

Recovery

None

Waste Spray Booth Paint 080312 4 Offsite Incineration

2,000

General refuse 20301 10 Landfill 2,500

Settlement Ponds sludge 200304 400 Landfill 100,000

Sewage Treatment Plant sludge

200304 8 Treatment 2,000

Scrap metal 200140 100 Recycling None

Washings 030199 100 Treatment 25,000

Paper/Cardboard 200101 1 Recycling 250

Ash 100101 50 Landfill / Re-use

12,500

TOTAL 1823 €144,250

Time to Complete This stage will be carried out in tandem with the decommissioning stages. As the drum store and warehousing areas receive waste to be disposed, licensed waste disposal contractors shall remove waste for landfill, incineration or recovery.

Costs The predicted costs associated with this stage are summarised in Tables 6.2, and 6.3.


_______________________________________________________________________Malone O' Regan -21-

Plant Status at the end of Stage 3 All production related hazardous and non-hazardous wastes will be removed from the production building and log yard area.

6.1.5 Stage 4: Cleaning of the Production and Storage Facilities

This stage would be started when the production building is being emptied of all product, raw materials and waste for disposal. Plant cleaning will occur when all equipment has been decommissioned and cleaned. Time to complete As the cleaning process will generate liquid hazardous and non hazardous wastes and will take approximately 3 weeks to complete, the cleaning of the production facilities should be run in parallel with Stage 3 – Removal of Hazardous and Non-hazardous wastes. Cost The approximate average cost per day to clean is estimated to be on average €1,500. Therefore the total approximate cost would be €1,500 x 15 = €22,500. Plant Status at the end of Stage 4 The internal areas of the production building will be cleaned and returned to a safe state in respect of the environment and health and safety.

6.1.6 Stage 5: Drain Surveying and Cleaning

In order to return the site to an environmentally inert condition, there will be a requirement to clean all the drains on the site. This will involve the use of a specialist contractor who will utilise mobile CCTV cameras. It is recommended that cleaning and surveying run in parallel, so that any blockages detected by the camera can be cleared promptly. The survey will identify any repairs that will be required. Any residual material removed from the drains will be appropriately disposed off-site as required. Time to complete It is estimated that the drain surveying and cleaning will take approximately 1 week with reporting taking an additional week.


_______________________________________________________________________Malone O' Regan -22-

Cost The approximate average cost per day to clean and survey is estimated to be on average €1,400. Therefore the total approximate cost would be €1,400 x 5 = €7,000. Plant Status at the end of Stage 5 The process drains of the SmartPly Europe Limited facility will be cleaned, surveyed and any defects identified.

6.1.7 Stage 6: Decommissioning of Site Services

Bulk storage tanks All bulk storage tanks will require disposal. Following emptying and cleaning, all tanks will be disposed of, sold or scraped. Bunded areas The bunds will be required to be inspected and drained of any solid and liquid matter. Any material drained from bunds must where possible be discharged directly into the surface water settlement ponds. If it is determined following analysis of the bund contents that they are unsuitable for discharge to the surface water settlement ponds, the material will be transferred into suitable, clearly labelled drums and disposed of as a hazardous waste. Plant status at the end of Stage 6 All site utilities, with the exception of limited electrical supply will be effectively decommissioned. Time to Complete Utility decommissioning should not start until contract cleaning of the site and drains (Stage 5) has been completed. The surface water settlement ponds would be the final facility to be decommissioned.

6.1.8 Stage 7: Removal of Residual Hazardous Materials

This stage applies to the situation where there may be specific residuals associated with the building structure and plant equipment that may not be removed. This includes PCBs, Radioactive wastes and fluorescent tubes but does not include for actual concrete that may be contaminated.


_______________________________________________________________________Malone O' Regan -23-

Task 1 Remove Identified Hazardous Materials. There are no asbestos containing materials, PCBs/PCTs or radioactive sources on the site. Certification to this effect will be produced during the implementation of the RMP. Task 2. Remove and dispose of fluorescent tubing. All fluorescent tubes and gas vapour lamps will be removed and stored in coffin containers. A licensed company will then remove the waste for disposal. The estimated cost is €3000.

6.1.9 Stage 8: Documentation and Certification of Residuals Management

Plan Throughout the implementation of the RMP, documentation will be generated to track progress. All residues removed from site will be recorded and final clearance certificates will be prepared. A full report will be prepared and submitted to the appropriate agencies.

6.1.10 Stage 9: Testing and Validation

A testing and validation programme will run throughout the RMP. Validation inspections will be conducted upon completion of each stage, to ensure that all elements of the RMP have been completed successfully. A full validation report will be prepared following the completion of all stages.

6.2 Phase Two Long Term Monitoring and Residuals Management 6.2.1 Introduction

The SmartPly Europe Limited facility is a free standing building, with a solid concrete floor. It is surrounded by paved areas on all sides. One of the main resins used in production is isocyanate, which forms an impermeable solid upon contact with water or water vapour. There are three IPPC licensed groundwater monitoring wells in the vicinity of the site boundaries which are monitored on an annual basis. Monitoring data to-date indicates that SmartPly Europe Limited activities have not had an adverse impact on local groundwater quality since the commencement of operations in 1995. This is consistent with the expected results as activities on site are predominantly related to dry wood processing. Storm water drains located around the perimeter of the site and within the site drain to the settlement ponds located along the eastern site boundary. There are no process effluents generated by site activities and no discharges to ground. Based on monitoring data to-date (1994-2006), elevated concentrations of ammonia and nitrate are consistently reported relative to Maximum Allowable Concentrations (MAC’s) and EPA Interim Guideline Values (IGVs). These


_______________________________________________________________________Malone O' Regan -24-

elevated concentrations were shown to be present prior to the development of the SmartPly Europe Limited facility.

6.2.2 Characterisation of Potential Source Areas of Chemical Release

Following site closure, investigations of potential source areas of chemical release would be carried out by undertaking an intrusive investigation at various locations in the vicinity of the site. Undertaking a post site closure investigation also guarantees that data is collected at a point in time that marks the end of chemical use/transfer/storage on-site. The intrusive investigation would focus primarily on the bedrock zone to establish if there is potential for significant groundwater movement. The existing groundwater database from the existing site wells is comprehensive. Therefore only a relatively limited groundwater investigation will be needed. The budget required to complete a comprehensive investigation of potential source areas, including drilling, laboratory analysis, risk assessment and risk communication is estimated to be of the order of €11,000, (the drain survey has been priced separately).

6.2.3 Design / Implementation Source Area Soil Remediation Programme (As

Appropriate)

If the post-closure investigation encounters significant shallow soil contamination, it could continue to leach to groundwater (acting as an ongoing source of groundwater contamination) or have implications with respect to the potential future use of the site. Therefore the results of the post-closure investigation study will be used to establish whether specific corrective action will be required. This is considered unlikely to be required based on currently available data. Risk based decision making will be used to quantitatively evaluate the appropriate levels of residual contamination that can be left in place, if necessary. Comprehensive groundwater monitoring completed since the commencement of operations in 1994 provides no evidence that would suggest that there is a significant mass of residual contamination beneath the building. For the purposes of this RMP it has been assumed that no residual contamination beneath the building will be required and no groundwater interception and treatment will be required.

6.2.4 Management of Corrective Action Programme with Post Remediation

Monitoring

Following site closure a finite groundwater monitoring programme will be required. In a site closure and decommissioning situation, the scope of the groundwater-monitoring programme would be a variation on the current IPPC monitoring programme at SmartPly Europe Limited and would be based on the most up-to-date data available on the quality of groundwater at that time.


_______________________________________________________________________Malone O' Regan -25-

Assuming a total of two years monitoring until final closure and surrender of the IPPC licence, groundwater monitoring and data assessment/reporting costs for the site are predicted to be of the order of €7,000 per year, totalling €14,000.


_______________________________________________________________________Malone O' Regan -26-

7.0 SUMMARY OF COSTS ASSOCIATED WITH THE RMP AND CONCLUSION

This section briefly summarises the costs presented in Sections 6.1, 6.2 and 6.3 of this report. The summary is presented in Table 7.1 and includes all costs identified during the analysis of Phase one and Phase two.

Table 7.1 Costs associated with RMP

ITEM DESCRIPTION COST (€) Phase 1 Decommissioning and Decontamination

Stage 1 Production Decommissioning 100,000

Stage 2 Removal of excess raw material -

Stage 3 Hazardous and non –Hazardous waste disposal 307,450

Stage 4 Cleaning of production and storage facilities 22,500

Stage 5 Drain Surveying and Cleaning 7,000

Stage 6 Decommissioning of Site Services

Stage 7 Removal of Identified Hazardous Materials 3,000

SUB TOTAL Phase One (approximate) 439,950

Phase 2 Long Term Monitoring and Residuals Management

2.1 Further investigation of contamination (3 bedrock wells and drains survey) 11,000

2.2 Source area in situ soil corrective action -

2.3 Quarterly monitoring of soil & groundwater 14,000

SUB TOTAL Phase Two (approximate) 25,000

RMP TOTAL (approximate) 489,950

In conclusion it has been estimated that, in the event of site closure involving complete cessation of all production activities at SmartPly Europe Limited, an allowance of approximately €489,950 will be required to bring the site to an environmentally safe (inert) condition. This excludes any remedial work necessary in the event that this is required.


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8.0 UNDERWRITING THE RMP

The site is operated as a wholly owned subsidiary of Coillte Teoranta a state owned company operating in forestry, land based businesses and added-value processing operations. Coillte is owned by the Minister for Finance and the Minister for Agriculture and Food. In 2004, Coillte had a turnover of €185 m, a profit of €35 m and was named the 181st largest company in Ireland. All profits were re-invested in the business. Coillte’s forest estate comprises 445,000 hectares of forest land (approx. 7% land cover in Ireland). Coillte places a strong emphasis on achieving balance between commercial, environmental and social objectives in managing business. Should any potential cessation of operations occur while SmartPly is in Coillte's ownership, such a cessation would be a well managed exercise underwritten from Coillte's own internal resources.

Smartply Europe Ltd.,Belview Port,

Slieverue,Co. Kilkenny

Residuals Management PlanNo.

Job No. Scale. Issue. Chk. Date.

Regional Location

E 0 450 NTS 01 JMcG Mar 06

Figure 1

Site Location

River Suir

N25

N29

Waterford City





Title.

Site Boundary


Figure 2

ENVIRONMENTAL SERVICES LTD

Title.





Process Flow Diagram


Figure 3

ENVIRONMENTAL SERVICES LTD

October 2011

Insert Report type

GA

NG

AN

GA

NG

ANIPPC Licence Reg. No. P0001IPPC Licence Reg. No. P0001--0202

RE

GR

EG

RE

GR

EG

Environmental Liabilities Risk Environmental Liabilities Risk AssessmentAssessment

E O

’RE

O’R

E O

’RE

O’RAssessmentAssessment

LON

E

LON

E

LON

E

LON

E

MA

LM

AL

MA

LM

AL

MMMM

St. Catherine’s House,Catherine Street,

Waterford.

Tel: +353 51 876855Fax :+353 51 876828

e‐mail: [email protected]

13 Mill Street,Galway

Tel: +353 91 531069Fax :+353 91 531084e‐mail: [email protected]

2B Richview Office Park,Clonskeagh,Dublin 14.

Tel: +353 1 2602655Fax :+353 1 2602660

e‐mail: [email protected]

Environmental Liabilities Risk Assessment SmartPly Europe Limited Belview Port, October 2011 Co. Kilkenny

Malone O’Regan 1

Table of Contents

1.0 Introduction ........................................................................................................... 2

2.0 Methodology .......................................................................................................... 2

3.0 Initial Screening and Operational Risk Assessment ......................................... 2

4.0 Statement of Scope ............................................................................................... 3 4.1 Brief Site Description ........................................................................................ 3 4.2 Processes ......................................................................................................... 3 4.3 Scope of ELRA ................................................................................................. 4

5.0 Risk Identification & Classification ..................................................................... 5 5.1 Ranking of Risks ............................................................................................. 14 5.2 Quantification of Unknown Environmental Liabilities ...................................... 15 5.3 Review of Risk Assessment/ Financial Provision ........................................... 15

6.0 Financial Provision ............................................................................................. 15 6.1 Financial Instruments ...................................................................................... 16

7.0 Conclusions ......................................................................................................... 16


Malone O’Regan 2

1.0 Introduction MOR has been commissioned by SmartPly Europe Ltd. (SmartPly) to complete an Environmental Liabilities Risk Assessment (ELRA) for their facility at Belview Port, Co. Waterford (the site). This ELRA has been completed in accordance with the EPA Guidance Note titled “Guidance on Environmental Liability Risk Assessment, Residual Management Plans and Financial Provision” (hereafter referred to as the EPA Guidance Note). The aim of this ELRA is to consider the risk of unplanned events occurring during the operation of the site that could result in unknown environmental liabilities materialising. Accordingly this report identifies unplanned events which could occur, assesses their risk of occurrence and the level of severity and details the necessary financial provision required to ensure that any actions required to mitigate and/or remediate these liabilities are provided for. In order to comply with the requirements of the EPA Guidance Note the amount of financial provisions will be determined for unknown liabilities identified in this report.

2.0 Methodology The EPA Guidance Note was used as a methodology for the assessment documented herein. The following documents were also consulted in order to prepare the ELRA:

Residuals Management Plan completed by Malone O’Regan in 2006; IPPC Licence Application for Reg. No. P0001-02; Previous Annual Environmental Reports (AERs) for the facility; and The Emergency Plan developed for the facility.

A site visit by MOR personnel was conducted on 26th September 2011. In addition a large number of site visits have been completed at the site over the past number of years by MOR and information gathered during these visits was also utilised in carrying out this assessment.

3.0 Initial Screening and Operational Risk Assessment To ensure the appropriate approach is taken, the Risk Category (1, 2 or 3) has been determined for the site. The complexity band for the site is set out in Table 1 below. The licensed activity is assigned a complexity band of G4. Table 1: Complexity Band Licensed Activity Class Complexity

Band Action

Required The production of paper pulp, paper or board (including fibre-board, particle board and plywood) with a production capacity exceeding 20 tonnes per day.

G4 Automatically classified as Category 3 – Site Specific ELRA required

In accordance with the EPA Guidance Note, facilities which have a complexity band of G4 and G5 are automatically classified as Category 3. For Category 3 facilities a detailed site specific ELRA is required.


Malone O’Regan 3

4.0 Statement of Scope 4.1 Brief Site Description SmartPly Europe Limited is an Oriented Strand Board (OSB) manufacturing facility located in Belview, County Kilkenny and is a wholly owned subsidiary of Coillte since May 2002. The company was formerly known as Louisiana Pacific Coillte Ireland (LPCI) Limited. The site is approximately 26 hectares in size which includes 10 hectares of log yard/yard space and 13 hectares of planted woodland. The main production building is 2.3 hectares and is subdivided into a number of distinct areas including; administration, offices, canteen, log handling, flaking, drying, blending, resin storage, forming and pressing, sawline, board handling, finishing and storage. A bark burning furnace and a standby diesel furnace is also located internally. There are also a number of ancillary buildings located around the site including a security/weighbridge office and a pump house. External plant facilities include two Wet Electrostatic Precipitators (WESPs), settlement ponds (x2), emergency holding tank (x2), fire pond (contains fire fighting water), wastewater treatment plants (foul) (x2), overground fuel and chemical storage tanks/bunds and propane gas tanks (x2) and an ESB substation. The log yard is used to store incoming logs prior to processing in the plant. 4.2 Processes OSB is a composite wood-based panel product composed of thin wafers of pine and spruce pulp-grade wood pressed under heat and pressure with wax and synthetic resins. A number of process stages are involved in the manufacture of OSB:

Logs are fed into the plant via the log in-feed conveyor; The bark is removed by a debarker; A waferiser shreds the logs into the required flake size; The flakes are fed into one of four dryers and dried; Flakes pass to the blenders where resin and wax is added to help bind the

flakes together; The flakes enter the press where pressure and heat is applied in order to bind

the flakes together and form a board; and The pressed board is trimmed, cut to size, labelled and stacked ready for

delivery. The resins used are Methylene Diphenyl Diisocyanate (MDI) and phenol formaldehyde. Auxillary processes on site include operation of the WESPs, wastewater (foul) treatment, log storage, wheel washing and storage of flakes/fines, bark and ash at external locations. A bark burning furnace is also present on site which is used to heat thermal oil. Thermal oil is pumped to the press where it is used as a heat medium. Sludge from the settlement ponds is used in the building of onsite berms whilst the sludge generated from the operation of the WESPs is permitted for use as fuel.


Malone O’Regan 4

Surface water runoff, which includes that from the log storage area, roof and paved areas, is collected via drains which generally run around the footprint of the production building and drains to one of two settlement ponds. The surface water drains can also be diverted to the Emergency Holding Tanks (EHTs) if required. Each settlement pond has a storage capacity of 2,500m3. Water from the settlement ponds can also be pumped to the two EHTs each of which also has a capacity of 2,500m3. Foul emissions from the canteen and toilet areas are treated in two Rotating Biological Contactors (RBCs). The final effluent is combined with the settlement pond discharge on release. There are a number of external and internal bunds on site including the following: External:

Gas/diesel bund; Diesel bund (located in the externally located fire pumphouse); Interim Bulk Container (IBC) bund outside pumphouse; Resin infeed bund; and Bunded chemical storage units.

Internal:

Hydraulic oil room bund; Thermal oil overflow bund; Resin and wax bund; Chemical storage bund; Mobile equipment hydraulic oil bund; and The press pit bund.

These bunds were visually inspected by Malone O’Regan Engineers in 2009. All bunds were satisfactory in terms of capacity and integrity with the exception of the chemical storage bund and the diesel bund in the fire pumphouse. Minor repairs were recommended for the chemical storage bund whilst necessary repairs were recommended for the diesel bund in the fire pumphouse. These repairs were completed. 4.3 Scope of ELRA The objectives for this site specific ELRA, as taken from the Guidance Note, are set out as follows:

To identify and quantify environmental liabilities at the facility focusing on: unplanned, but possible and plausible events that could occur during the operational phase;

To calculate the value of financial provisions required to cover unknown liabilities;

To identify suitable financial instruments to cover the financial provisions for both planned and unplanned liabilities; and

To provide a mechanism to encourage continuous environmental improvement through the management of potential environmental risks.


Malone O’Regan 5

5.0 Risk Identification & Classification The next stage in preparing the ELRA is to identify operations on site which pose a potential risk to environment receptors and to assess and classify them. Table 2 below illustrates how the risks are classified whilst Table 3 overleaf lists the risks identified and provides details on classification. Table 2: Risk Classification Rating Occurrence Severity

Description* Likelihood of Occurrence

(%)

Severity¥ Cost of Remediation (€)

1 Very low 0-5 Trivial: no damage/ negligible change

0 – 1,000

2 Low 5-10 Minor: Localised impact/ nuisance

1 – 10,000

3 Medium 10-20 Moderate 10 – 50,000 4 High 20-50 Major 50,000 – 100,0005 Very High >50 Massive 100,000–

1,000,000 * Chance of hazard occurring in 30 year period. ¥ Impact/ Damage to the local environment. The calculated severity of risks in Table 3 does not take account of potential effects on employees on site as this is deemed to come under the remit of Health and Safety. For example, where an emission to air is a potential effect then only the potential impact on ambient air quality standards is considered in calculating the severity level. As is the case in most facilities there is a risk of fire at the site which arises from a number of pieces of equipment used in the process. The risk of fire at each of the appropriate pieces of equipment is detailed in Table 3 overleaf. Fire as a hazard overall at the site in terms of firewater generation is discussed separately in Table 3.


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Table 3: Risk Assessment Form Risk ID Process Potential Hazards Potential Environmental

Effect Severity Rating

Basis of Severity Occurrence Rating

Basis of Occurrence Risk Score

1

Log storage, bark/fines storage

Rainfall runoff from logs, bark/fines

Runoff impacting on surface water quality

2

Emissions with potential high BOD, COD, SS and of an acidic nature. All runoff is collected in the surface water drainage system and treated by settlement prior to release.

2

Surface water runoff tested on a monthly and quarterly basis. Exceedances of the BOD ELV have occurred and are attributed to high rainfall events.

4

Runoff impacting on groundwater

1

Emissions with potential high BOD, COD, SS and of an acidic nature can enter the soil, however a clay liner is in place and groundwater monitoring conducted upgradient and downgradient of the facility. No impact has been identified.

2

Groundwater tested quarterly for licence parameters. Bark/fines stored on hardstand. Clay substrate underlies log storage area with moderate hydraulic conductivity of 1x10-

5m/s. No evidence of impact of runoff from logs/bark/fines on groundwater.

2

2

Drying

Fire in the dryer or at the infeed/outfeed to the dryer Explosion

Emissions to air exceeding the ELV and in turn potentially the applicable Air Quality Standards (AQS)

2

Emissions likely to include formaldehyde, carbon monoxide, nitrogen oxides, particulates, phenol, oxides of sulphur, VOCs and MDI. The fire is likely to be confined within the dryer with minimal escape of emissions to ambient air (i.e. through doors etc).

3

Fire in the dryer has and does occur. However, this is regarded as being part of the normal operation of the dryer. Extent of fire controlled by: Dryer monitored by PLC system. Spark detection and deluge

6


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Risk ID Process Potential Hazards Potential Environmental Effect

Severity Rating



Quantity of emissions likely to be low as fire would be detected quickly and extinguished. Any emissions which leave the stack will dissipate readily due to stack height and are not likely to impact on ambient air quality.

system in place. Emergency procedures in place and operatives trained in this procedure.

3

Blending

Spillage of resins, wax and release agent

Entry of materials into surface water/groundwater

1

Resins non toxic to aquatic organisms - MDI forms a solid on contact with water. Storage is internal – unlikely to ever reach surface water or groundwater.

1

Used internally in production building on hardstand areas. Storage and mixing is within bunded areas.

1

4

Press

Fire


2

Emissions to air likely to include formaldehyde, carbon monoxide, nitrogen oxides, particulates, phenol, oxides of sulphur, VOCs and MDI. The fire is likely to be confined within the press with minimal escape of emissions to ambient air (i.e. through doors etc). Quantity of emissions likely to be low as fire would be detected quickly and

2

Fires in the press have previously occurred. Press monitored by control room and CCTV. Thermal oil supply immediately shut off in the event of fire. Lines and pumps isolated. Emergency procedures established for thermal oil fires in the press and operatives trained. Temperature monitoring being conducted and high

4


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Severity Rating



extinguished. Any emissions which leave the stack will dissipate readily due to stack height and are not likely to impact on ambient air quality.

temperature alarms and manual deluge in place. IR detection and manual deluge in place. Sprinkler system installed which automatically deluges on detection of high temperatures in the press area.

5

Hammermill, dry fuel bin, laidig bin, baghouse (areas containing high level of dust)

Dust explosion leading to fire Fire leading to explosion


2

Dust emissions and emissions from fire could contain formaldehyde. Emissions likely to be confined internally within the production building. Quantity of emissions likely to be low as fire would be detected quickly and extinguished.

1

Explosion suppression system in place in baghouses and related pipework. Automatic/manual deluge in place. Procedures in place for dealing with explosion/fire and operatives trained. ATEX zones designated and Explosion Protection Document (EPD) in place and implemented.

2

6

Bark Burning Furnace

Explosion leading to fire

Emissions to air exceeding the ELV and in turn potentially the applicable Air Quality Standards(AQS)

3

In the event of an unsafe condition of the bark burning furnace i.e. fire/explosion then the furnace would have to be aborted and emissions released to air. Emissions are likely to be localised in nature.

2

Fire has occurred at the inlet. Maintenance in place. New feeder installed to prevent fire at the inlet. Furnace monitored by PLC system.

6


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Severity Rating



7

Standby Diesel Furnace

Explosion leading to fire

Emissions to air exceeding the ELV and in turn potentially the Air Quality Standards (AQS)

2

Emissions are likely to be localised. Fire likely to be short in duration.

1

Has never occurred. Controls to ensure correct air/fuel mix installed on standby diesel furnace and therefore reduce risk of explosion. Temperature monitored by PLC system.

2

8

Thermal oil system

Fire


3

Emissions are likely to be localised. 10,000 gallons of oil in the system. Unlikely that fire would engulf the whole system as area affected would be immediately isolated.

1

Has never occurred. If oil escaped the system it could ignite due to the pressure being applied in the system. Procedures in place for isolation of the system in the event of fire. Maintenance of thermal oil system to prevent leaks.

3

9

Fuel, resin/wax and chemical storage tanks

Fire


3

Emissions from resin tank likely to include formaldehyde and MDI. Emissions are likely to be localised.

1

Has never occurred. Unlikely to occur as fuels are contained within tanks. No smoking policy in place.

3


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Severity Rating



10

Fuel, resin/wax and chemical storage tanks

Loss of integrity/rupture of tanks/overflows

Possible contamination of surface water, soil and groundwater.

2

A fuel spill reaching groundwater/surface water/soil would be detrimental to quality however quantities spilled likely to be low as tanks are bunded.

1

Has never occurred. Bunds are visually inspected for integrity in accordance with licence requirements.

2

11

Underground Pipelines and sumps

Leak from underground pipelines/sumps (foul) , thermal oil pipeline, resin pipeline, gas pipeline Wastewater Treatment system (RBC)/sump leak


2

Contents of pipelines would be detrimental to groundwater/surface water/soil quality however volume of any potential leak is likely to be low as checks are carried out. Majority of pipelines are overground where any leaks would be detected quickly.

2

Foul pipeline is tested in accordance with licence requirements. Defects noted in last pipeline survey have been repaired. Thermal oil pump area is bunded. Resin pump area and joints/bends bunded. Gas pipeline leak tests conducted The sumps have not been tested for integrity due to presence of pumps but these will be emptied and visually inspected by end 2011.

4


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Severity Rating



12

Wastewater Treatment – Rotating Biological Contactors (RBCs)

Leak from RBC units


2

Wastewater would be characterised by a high BOD, COD, SS and nutrient loading however the quantity released is likely to be very low as daily checks are carried out.

1

Visual checks conducted on effluent levels in RBCs daily. Groundwater monitoring wells located in the area and monitoring carried out in accordance with licence requirements.

2

13

Air emission abatement – baghouses and WESPs

Failure of abatement equipment and uncontrolled releases to air


2

Emissions likely to include formaldehyde, carbon monoxide, nitrogen oxides, particulates, phenol, oxides of sulphur, VOCs and MDI above licence limits. Minimal emissions likely to be released as abatement systems are connected to a PLC system and an alarm will sound in the event of a failure. If the WESPs go into emergency shutdown then process equipment also shutdown.

1

Abatement equipment linked to a PLC system which monitors critical control parameters. Ongoing maintenance of abatement equipment is performed. Alarms will sound in the event of failure and direct measures can then be taken.

2

14

Overall SmartPly Production

Fire generating large quantities of firewater

Contaminated firewater entering the River Suir either directly or via soil/groundwater

2

Firewater unlikely to contain a high volume of toxic materials as tanks containing fuels/resins/chemicals are bunded. Firewater would drain to

2

The majority of firewater would flow into the surface water drainage system and would be diverted to the EHTs and contained within. Based on preliminary calculations as per Guidance

4


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Severity Rating



the drainage channel which surrounds the footprint of the site and would then be diverted to the EHTs where there is adequate spare capacity assuming 11/2 of the two EHTs (3,750m3) are kept free and taking account of a 1 in 20 year 24hr rainfall event.

Notes, it appears likely that there is sufficient retention available to retain firewater.

15

Wastewater Treatment – Rotating Biological Contactors (RBCs)

Failure of the operation of the RBCs

Release of inadequately treated wastewater to the River Suir causing detrimental effect

1

Inadequately treated wastewater would be characterised by a high BOD, COD, SS and nutrient loading. Large dilution capacity available in the River Suir and quantities released likely to be small

1

Visual checks conducted on RBCs daily. Effluent is tested quarterly in accordance with licence requirements. RBCs are maintained in accordance with manufacturer instructions.

2

16

Mobile tanker accident.

Spill of oil/diesel, resins, wax and release agents

Contamination of soil, groundwater and surface water.

2

Fuel entering soil/groundwater/surface water would be detrimental to quality Volume likely to be small and would be captured within the surface water drainage system which would be diverted to the EHTs and contained within.

1

Coupling on tanker pipeline would reduce volume released. Spillage of fuel at the fuel tank would be captured in the bund. A spill as a result of a tanker accident/collision on site would likely occur on the roads around the site and yard areas which are covered in hardstand and drain to surface water drainage system. This would then be diverted to the EHTs. Spill procedure/ kits in place.

2


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Severity Rating



Plentiful supply of wood fines on site which would be utilised as an absorbent material in the event of a spill.


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5.1 Ranking of Risks Based on the risks identified in Table 3, a Risk Register was established to allow the risks to be listed and managed in order of priority. Risks equal to or below a score of 2 are not included in the Risk Register which is displayed in Table 4. The risks were also tabulated in matrix form as shown in Table 5. Table 4: Risk Register Risk ID

Description Severity Rating

Occurrence Rating

Risk Score

2 Fire in the dryer and potential emissions to air

2 3 6

6 Bark burning furnace – explosion/fire and potential emissions to air

3 2 6

1 Runoff impacting on surface water quality

2 2 4

4 Press – fire and potential emissions to air

2 2 4

14 SmartPly production – fire resulting in generation of firewater and possible contamination of surface water, groundwater and soil

2 2 4

11 Underground pipelines and sumps – leaks leading to contamination of surface water, groundwater and soil

2 2 4

8 Thermal oil system – fire and potential emissions to air

3 1 3

9 Fuel, resin/wax and chemical storage – fire and potential emissions to air

3 1 3

Table 5: Risk Matrix Occurrence

Very High

5

High 4

Medium 3 2

Low 2 1, 4, 11,14

6

Very Low

1 9, 8

Trivial Minor Moderate Major Massive

1 2 3 4 5

Severity

Risks located in the red zone require priority attention; Risks in the yellow zone require mitigation or management action; Risks in the green zone require continuing attention and monitoring


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As shown, the risks posed on site are all located in the green zone. Assessment of the risks has shown that these hazards are not likely to routinely occur, and risk prevention/mitigation is already in place as detailed in Table 3.

5.2 Quantification of Unknown Environmental Liabilities To quantify the risks associated with the site, a financial model was used using the information compiled during the risk assessment. The Most Likely Case scenario was calculated after the Risk Management Programme was applied and is shown in Table 6 below. A summary of Best Case and Worst Case Scenarios is shown in Table 7. Table 6: Most Likely Case Scenario Financial Model Risk ID

Occurrence Rating

Likelihood of Occurrence Range (%)

Severity Rating

Cost Range (€ 000)

Median Probability (%)

Median Severity (€)

Most Likely Scenario Cost (€)

2 3 10-20 2 1-10 15 5,000 750.00 6 2 5-10 3 10-50 7.5 30,000 2,250 1 2 5-10 2 1-10 7.5 5,000 375.00 4 2 5-10 2 1-10 7.5 5,000 375.00

14 2 5-10 2 1-10 7.5 5,000 375.00 11 2 5-10 2 1-10 7.5 5,000 375.00 8 1 0-5 3 10-50 2.5 30,000 750.00 9 1 0-5 3 10-50 2.5 30,000 750.00

6,000.00 Table 7: Summary of Financial Model Description Estimate of ‘Unknown’

Environmental Liabilities Assumptions

Worst Case Scenario

€200,000.00 Assumes all risks occur at their maximum cost

Most Likely Scenario

€6,000.00 Based on the median probability and severity for each risk after implementation of the Risk Management Programme

Best Case Scenario € 0 Assumes none of the risks occur

5.3 Review of Risk Assessment/ Financial Provision The risk assessment and accuracy of the financial model is dependent on the accuracy of the risk evaluation and the assumed costs of remediation. As these are subject to change, the Risk Register and the risks contained within will be reviewed annually as part of the AER and considered in light of any changes which have occurred on site. The Risk Register will then be updated if required. The financial model will be updated appropriately and financial provision re-examined if necessary to ensure the financial instruments supporting the ELRA remain in place.

6.0 Financial Provision Using the results of the ELRA, the financial provision and instruments proposed or in place are shown in Table 8 overleaf. A Residuals Management Plan (RMP) was conducted for the site in 2006 and the amount of provision and financial instruments to underwrite known liabilities are also included in Table 8.


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Table 8: Financial Provision Liability Type

Description Method of Quantification

Amount of Provision

Financial Instrument

Known Liability – Site closure

Site Closure and Decommissioning

Cost estimates provided in detailed Residuals Management Plan for the facility

Known = €489,950

Parent Company (Coillte) Guarantee

Unknown Liability

Risk of unplanned events occurring on site as described in Table 3.

Environmental Liability Risk Assessment report and analysis of likely cost scenario

Unknown = €6,000

Insurance Policy

6.1 Financial Instruments Known Liabilities The site is operated as a wholly owned subsidiary of Coillte. In the event of site closure Coillte would oversee such an event which would be underwritten by Coillte’s own internal resources. Unknown Liabilities Financial provision for the unknown liabilities on site is underwritten by a €6.5M insurance policy with Chartis. Sudden and accidental pollution cover is included in this policy.

7.0 Conclusions The unknown environmental liabilities for the site have been identified through this Environmental Liabilities Risk Assessment report. In accordance with the EPA Guidance Note, a risk assessment of activities on site was carried out and the appropriate estimation of financial provision required was calculated. The ELRA shall be reviewed as necessary to reflect any significant change on site, and in any case annually as part of the AER.