Annual Environmental Report of CROWN Packaging Ireland ...CROWN Packaging Ireland Ltd – Annual...
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Licence Register Number: P0098-01 Licensee: CROWN Packaging Ireland Limited Location of Activity: Woodstock Industrial Estate Athy Co. Kildare Attention: IPC Enforcement Administration Licencing and Control Division Environmental Protection Agency P.O. Box 3000 Johnstown Castle Estate Co. Wexford Prepared by: Dermot O’Callaghan Technical/ Environmental Manager CROWN Packaging Ireland Ltd Athy Co. Kildare. Date: April 2009
Annual Environmental Report of CROWN Packaging Ireland Limited Compliance with the Requirements of the IPC Licence
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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CONTENTS Page No.
Section 1: Overview
1.1 Introduction 4
1.2 Site Description 5
1.3 Local Environmental Conditions 6
1.4 Main Units / Products 7
1.5 Economic Contribution 8
Section 2: Data
2.1 Summary Data 9
2.1.1 Emission Data 10-11 2.1.2 Energy and Water Usage 12 2.1.3 Environmental Incidents and Complaints 13 2.1.4 Other Significant Environmental Assessments 14-15 2.2 Pollution Emissions Transfers Register 16
Section 3: Environmental Management System
3.1 Environmental Management System 17
3.2 Environmental Management Organisation 18
3.3 Environmental Training and Education 19
3.4 Environmental EPA Site Inspection and Site Audit 20
3.5 Environmental Management Programme for 2006 21
3.5.1 Policy Statement 22 Section 4: Other Reports
4.1 Bund Programme and Bund Testing 23
4.1.1 Bunding of Diesel Storage Tank 23 4.1.2 Bunding of Flam Store 23 4.1.3 Pumping out of Integrated Flam Store Bund and
Fire Water Retention Facility Reports 24
4.2 Summary details of the Surrender Application for
License P0098-01 25-27
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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APPENDICES Appendix 01 Verification of acceptance of AER/PRTR Emissions data
Appendix 02 Training Records 2008
Appendix 03 Environmental Management Programme 2008
Appendix 04 Bund Integrity Assessment of the Flamstore Bund
Appendix 05 Pumping out of the Flam Store Bund and Fire Water Retention Facility Reports
SECTION 1
OVERVIEW
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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1.1 Introduction In accordance with schedule 4 (i) of IPPC licence reference number P0098-01, the
following is the Annual Environmental Report for the year 2008 at CROWN Packaging
Ireland Ltd, Athy, Co. Kildare. It is considered that the company continues to make
significant improvements in the management of its environmental affairs and the
protection of the local environment in which it operates.
The Environmental Management Team on site are committed to implementing ongoing
improvements programme at the facility. The Environmental Management System
(EMS) implemented at the facility has been upgraded to international standards and was
recommended for ISO 14001 accredidation by SGS on the 09th of March 2009.
Through ongoing training all associates at the facility are involved in this improvement
programme. The continuous improvement requirement of the IPPC process is fully
embraced by the Environmental Management Team. Crown Packaging Ireland Ltd are
also in the process of surrendering IPPC licence P0098-01, and demonstrate their
commitment to ongoing environmental awareness and improvement by achieving ISO
accreditation of their Environmental Management System.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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1.2 Site Description
CROWN Packaging Ireland Ltd is situated in the Woodstock Industrial Estate, which
is located within a rural setting on the outskirts of Athy, Co. Kildare. The plant was
built in 1974 and occupies an area of approximately 5,000 square metres.
The land area is approximately 45,000 square metres.
The plant is under the administration of Athy Urban District Council.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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1.3 Local Environmental Conditions
Certain conditions were agreed with the Athy Urban District Council when planning
permission was first granted. These conditions were imposed to ensure the protection
of the local environment and are in all cases being diligently enforced by the
company.
These conditions include the following:
1.3.1 ‘The developers shall not permit any surface or storm water to pass, whether
directly or indirectly, to the council’s foul sewer. The developers shall not
permit discharge into the council’s sewers or drains, directly or indirectly, any
substances whatsoever whether chemical, dye, grease, solvent or volatile
corrosive material which whether by itself or in conjunction with anything
already in such sewer or drain might be or become a source of danger or injury
to the sewer or drainage system or part thereof or which at the out fall of the
drainage system might be a nuisance, annoyance, danger or injury to any
person, property and right of easement’.
1.3.2 ‘No effluent, other than domestic sewerage, shall be discharged into the public
sewer without the agreement of Athy Urban District Council. Before Athy
UDC agrees to accept any such effluent, it will be necessary for the developer
to submit details including volume and analysis of effluent and report of same
to the Institute for Industrial Research & Standards and Athy Urban District
Council will require that the developer meet the conditions laid down by them
before such effluent is accepted into the public sewer’.
1.3.3 ‘The developers shall not operate in the said factory building any noxious,
offensive or injurious process, shall not use the premises or permit them to be
used so as to be a nuisance or annoyance whether by smell discharge, deposit,
dust, smoke, fumes, noise, vibration, electrical interference or otherwise to
adjoining owners or occupiers or to the public or so as to impair the amenities
of the locality’.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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1.4 Main Units / Products.
The operation manufactures three-piece cans for whole milk powder and dry baby
food.
Tinplate is the major raw material in which most of the requirements are purchased
from the UK. The tinplate is purchased plain and shipped to lithography companies in
the UK for printing and then shipped to Athy for processing. Other raw materials
used include – Aluminium and Tinplate Easy Open Ends, Penny Lever Assemblies,
Copper Wire, Aluminium Foil and Lacquers.
The can production process begins with the cutting of the tinplate sheets into blanks to
the exact size of the circumference and height of the required can. The can body
blanks are fed into the bodymaker, formed into a cylinder and the two unlacquered
edges of the blanks are welded together to form a leak-proof side seam. Lacquer is
then applied to the weld area to protect against rusting. The body is then flanged and
if necessary beaded for additional strength. The flanged body is then conveyed to a
seamer where the maker’s end or assembly is seamed in position, creating a leakproof
joint with the help of a compound.
The can is then conveyed to a packing machine, which packs the cans onto a pallet.
Each layer of cans is separated by a layer of cardboard. Each pallet of cans is
strapped and stretch wrapped prior to despatch.
Normal working hours are 8.00am to 12 midnight Monday to Thursday and 8.00am to
10.000pm on Fridays. If demand exceeds capacity during these hours, overtime work
is introduced as required. All products and methodologies are detailed in Question 9
of IPPC Licence Application 098.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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1.5 Economic Contribution
This company was established in Athy in 1974 by Borden Inc. A change in ownership
was effected in July 1999. The workforce includes managers, administrative staff and
plant operatives. The majority of associates live in the immediate locality, and this
has a substantial positive economic impact on the area.
Goods and services are sourced as much as possible from local businesses and
enterprises, e.g., security, haulage, stationery etc. This provides additional
employment in the businesses supplying these goods and services. This further
contributes to the wellbeing of the local economy.
Thus, this company has become an important contributor to the local economy and an
important part of the fabric of local industry in Athy.
SECTION 2
DATA
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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2.1 Summary Data This section outlines all summary data derived from the ongoing monitoring
programme at CROWN Packaging Ireland as per the requirements of IPPC Licence –
Ref No. P0098-01
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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2.1.1 Emission Data
Tables 2.1 –2.4 below give the results of monitoring for the following emissions:
• Emissions to water & sewers • Solid waste emissions – hazardous • Solid waste emissions – non hazardous 2.1.1.1 Emissions to Water / Sewers
TABLE 2.1
Results of Biannual Monitoring Analysis on Surface Water Samples from Jan 1st to
Dec 31st 2008
Date Emission Point Ref. COD mgl-1 pH units
16/06/08 SW1 <10 7.9
14/11/08 SW1 <10 7.7
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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2.1.1.2 Solid Waste Emissions (Hazardous)
TABLE 2.2 Hazardous Waste Generated on Site from Jan 1st to Dec 31st 2008
Waste Category Quantity ( t/yr) Recycled/ removed by Address of Final Recovery/disposal site Fluorescent Tubes and Bulbs 0.05 Contec Technology Ltd Mercury Recycling, Mercury House, 17 Commerce Way, Trafford
Pk, Mancs M171HW Waste Thinners 0.205 Safetykleen, Ireland Ltd, ENVA, Clonminam Industrial Estate,Portlaoise, Co. Laoise Electrical and Electronic waste 0.544 KMK Metals Recycling Cappincur Industrial Estate, Daingean Rd, Tullamore, Co. Offaly 2.1.1.3 Solid Waste Emissions (Non-Hazardous)
TABLE 2.3 Non-Hazardous Waste Generated on Site from Jan 1st to Dec 31st 2008
Waste Category Quantity ( t/yr) Recycled/ removed by Address of Final Recovery/disposal site Mixed Municipal 2.74 AES AES Portlaoise, Kyletalisha, Portlaoise, Co. Laoise
Copper Wire 159.4 La Farga La Farga, 08509 Les Masies de Voltrega, Barcelona, Spain
Cardboard/Paper 23.31 AES AES Tullamore, Cappincur, Tullamore, Co Offaly Plastic 7.13 AES AES Tullamore, Cappincur, Tullamore, Co Offaly Waste Timber 87.94 AES AES Tullamore, Cappincur, Tullamore, Co Offaly Waste Tinplate 320.68 AES AES Portlaoise, Kyletalisha, Portlaoise, Co. Laoise
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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2.1.2 Energy and Water usage
Summary data for energy and water usage at CROWN Packaging is detailed in Table
2.4 below.
TABLE 2.4
Energy and Water Usage on Site for 2007 and 2008
Units 2007 2008
Electricity Kilowatt Hours 1,020,000 1,180,000
LPG Litres 22,481 11,083
Diesel Litres 66,544 57,000
Water Litres 2,631,000 6,500,000
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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2.1.3 Environmental Incidents and Complaints
All environmental incidents and complaints are recorded in the incidents and
complaints register (EMF014), which is held in the Technical Environmental
Managers office.
There were no environmental incidents reported for the reporting period
between the 1st of January 2008 and the 31st of December 2008.
Environmental Incidents are controlled under procedure EMP 004 and form EMF
018. EMP 004 is the procedure for notifying the agency in event of an environmental
incident - which outlines the mechanisms for the response to and reporting of
incidents. EMF 018 is the log sheet that details the incident.
Environmental Queries or Complaints are controlled under procedure EMP 003 and
forms EMF 004, EMF 005, EMF 006 and EMF 007. EMP 003 is the procedure for
handling environmental incidents and complaints. EMF 004, EMF 005, EMF 006 and
EMF 007 are the inquiry call log, the complaint call log, the inquiry visit log and the
complaint visit log respectively.
No environmental queries or complaints were received for the reporting period
between the 1st of January 2008 and the 31st of December 2008.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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2.1.4 Other Significant Environmental Assessments
Other significant environmental assesments carried out at CROWN Packaging under
the 2008 monitoring programme were:
Visual Analysis of Storm Water.
2.1.4.1 Visual Inspection and Analysis of Storm Water
In compliance with schedule 3 (i) of our IPPC Licence, monthly visual inspection of
the storm water was conducted. This inspection was controlled by the Environmental
Procedure EMP 002 (Procedure for Visual Monitoring of Storm Emissions) and the
Environmental Management Record Sheet EMF 012 (Visual Water Inspection Record
Sheet). These results are documented in table 2.5 below.
Table 2.5
Water Effluent Analysis 2008
Date Sample Appearance Odour Action
28/01/08 Clear None None
29/02/08 Clear None None
14/03/08 Clear None None
29/04/08 Clear None None
30/05/08 Clear None None
16/06/08 Clear None None
10/07/08 Clear None None
22/08/08 Clear None None
10/09/08 Clear None None
08/10/08 Clear None None
14/11/08 Clear None None
19/12/08 Clear None None
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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The results of the bi-annual pH and COD analysis of the surface water are
documented in Table 2.6 below
Table2.6 Bi-annual Surface Water Monitoring Results Parameter Monitoring event 1
(18/06/08) Monitoring event 2 (14/11/08)
COD <10 mg/l <10 mg/l pH 7.9 pH units 7.7 pH units
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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2.2 Pollution Emissions Transfer Register A Pollution Emissions Register (PRTR) is an electronic register of potentially harmful
pollutant releases or transfers, from the site. The annual publication of the PRTR will
provide the public with comprehensive information on the use, control, transfer and
release of pollutants in industry and create a powerful motivation for waste reduction.
The electronic PRTR submission has been compiled and uploaded onto the EPA
website, verification of acceptance of the upload and a copy of the report has been
included in Appendix 1 of this document.
SECTION 3
ENVIRONMENTAL MANAGEMENT SYSTEM
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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3.1 Environmental Management System
In compliance with IPPC License Ref Number P0098-01 (Condition 2 – 2.5.1) an
Environmental Management System has been established at CROWN Packaging Ltd.
All documents, procedures, forms and record sheets are controlled by revision
numbers, stamped master copy and stored in the Environmental Management filing
cabinet in the Main Office. The Environmental Management System for the site was
upgraded in 2008 and was recommended for ISO 14001 accreditation on the 09th of
March 2009 following an accreditation audit by an eternal auditor from SGS.
The following documentation is controlled:
I. Environmental Management Forms
II. Environmental Management Procedures
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3.2 Environmental Management Organisation The Environmental Management Programme is co-ordinated by the Environmental
Management Team (EMT) as represented in Table 3.1 below.
TABLE 3.1 Name
Job Title
Responsibilities
A. Devlin
General Manager
Overall management responsibility
D.O’ Callaghan
Technical / Environmental Manager
Overall Technical and Environmental responsibility
J. Dalton
Operations Manager
Day-to-day responsibility for manufacturing related environmental issues
Michael Peters / Barry Wright
Engineer
Energy conservation
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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3.3 Environmental Training and Education
In compliance with IPPC Licence Reference Number 098 (Condition No. 2.7), an
Environmental Training Programme has been established.
This section details the programme including procedures to control Environmental
Awareness and Training.
These procedures ensure that there is awareness throughout the organization at all
levels, of:
• The importance of compliance with the Licence
• The potential environmental effects of work activities and potential consequences
of departure from specified operating procedures
• Individual roles and responsibilities in achieving compliance with the Licence
• Environmental benefits of improved performance
CROWN Packaging Ltd has established procedures for identifying environmental
training needs and for providing appropriate training for all personnel whose work can
have significant effect upon the environment.
The environmental training plan for 2008 is recorded on Form EMF017. This is
included in Appendix 2.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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3.4 Environmental EPA Site Inspection and Site Audit Site Inspection The EPA carried out an un-announced site inspection on 14/04/08. The
Agency considered that the site is being well managed from an environmental
perspective. No non conformances with the license were noted.
There were two observations noted during the visit:
1. The licensable activity ceased on the 19/12/05. The observation required
the licensee to inform the agency if it intended to apply to surrender its
license and to carry out an independent exit audit of the site.
Following a communication from Crown Packaging dated the 12/06/09
proceedings were initiated to surrender License P0098-01. An
independent exit audit was conducted by Bord na Mona Environmental
Ltd and the report was submitted to the Agency in November 2008. An
exit audit of the facility was conducted by the EPA on the 11/03/09 (Ref
P0098-01 /gc16.doc).
2. The annual maintenance record for 2007/2008 was not available for
inspection on the day of the audit. The person in charge of the maintenance
contract was not on site on the day of the site audit. The maintenance
record in question was submitted to the agency in communication dated
the 12/06/08. Documentation observations regarding the diesel tank
inspection record were corrected and records were also submitted in the
communication dated the 12/06/08.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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3.5 Environmental Management Programme (EMP) for 2008
In accordance with Schedule 4 (i) of IPPC Licence 098, the Environmental
Management Team developed an Environmental Management Programme (EMP) for
2008. The purpose of the EMP is to ensure that the objectives and targets are
supported by a realistic programme that is implemented throughout the organization.
This programme of objectives and targets set for 2008 has been attached in Appendix
3. Progress made on the objectives and targets in the reporting period has been
detailed in the column labeled Comments/Progress made in 2008.
Objectives and targets are set annual and going forward shall be managed through the
ISO 14001 accredited Environmental Management System. Objectives and Targets
have been set for 2009. They ensure that progress is made in the areas of
environmental awareness, waste management, energy consumption, emissions from
the site. There is also an objective to complete the surrender of license P0098-01. The
system shall be independently audited to ensure progress towards set objectives and
targets and to ensure continual improvement with respect to the environmental
performance of the site.
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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3.5.1 Environmental Policy Statement The following is the Environmental Policy Statement of CROWN Packaging Ltd.
CROWN PACKAGING LTD
ENVIRONMENTAL POLICY
CROWN Packaging is committed to environmental excellence throughout our
operation, both to live up to our social responsibilities and as a means to build the
value of our business. Excellence means integrating environmental planning and
execution into all business activities, complying with the law, conserving natural
resources, responsibly managing environmental risks, and working collaboratively
with others in addressing issues and opportunities.
It is the policy of CROWN Packaging to conduct its business of manufacturing and
distributing tinplate packaging in such a manner that its activities minimise or
eliminate any potential adverse effects to the environment.
An appropriate Environmental Management System has been developed and
maintained to assure the effective implementation of the Environmental Management
Policy.
The Environmental Management Policy and the requirements of the Environmental
Management System are issued under the authority of the General Manager. All
associates will familiarise themselves and comply with this policy and its principles as
they apply to their specific job function.
SECTION 4
OTHER REPORTS
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4.1 Bund Programme and Bund Testing This section of the report presents the bunding inspection programme implemented at
CROWN Packaging as part of its ongoing environmental strategy.
4.1.1 Bunding of the Diesel Storage Tank Crown Packaging has a documented procedure associated with the inspection of the
diesel storage tank (EMP 015) and the Diesel Storage Inspection Record Sheets (EMF
008). The procedure ensures that the tank, bund and associated pipe work are visually
inspected for integrity at three month intervals. It also ensures that the bundman
interstitial alarm is operational. During 2008 the checks were conducted on the
following dates: 13/03/08, 09/06/08, 23/09/08, and 03/12/08. No issues were
observed during the checks and the tanks were deemed to have no physical damage,
no chemical deterioration and no liquid in the bund. There was no evidence of spills
in the surrounding area and the Bundman interstitial alarm was tested and was
operating correctly on all occasions.
4.1.2 Bunding of Flam Store
The procedures associated with the testing and inspection of the flam store bund
(EMP012) (EMP 014) and the flam store bund/fire water retention facility testing and
inspection record sheets (EMF010) (EMF 009). A visual inspection of the flamstore
bund is conducted on a biannual basis by the technical manager. In 2008 these checks
were conducted on the 09/06/08 and on the 03/12/08. No issues were observed with
respect to cracking, mechanical damage, chemical attack damage, or any other
deterioration. The flamstore bund was also integrity tested for liquid tightness for
seven days in accordance with BS8007:1987, Clause9.2 (Appendix 1). The report has
been included in Appendix 4 of this report
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4.1.3 Pumping out of the Flam Store Bund and Fire Water Retention Facility Reports
This section of the report presents the record sheet (EMF 011) associated with the
pumping out of the integrated flam store bund and firewater retention facility at
CROWN Packaging - see Appendix 5. The procedure associated with the pumping
out of the flam store bund (EMP 013) is included as Appendix 5
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4.2 Summary details of the Surrender Application for License P0098-01
Crown Packaging was granted an IPC license reference number P0098-01 in 1996
which was granted for Class 12.2.2 activities, i.e.
The manufacture or use of coating materials in processes with a capacity to make or
use at least 10 tonnes per year of organic solvents, and powder coating manufacture
with a capacity to produce at least 50 tonnes per year.
The licensable activity ceased on the 19/12/05. However the facility continues to
manufactures three-piece cans for the whole milk powder and dry baby food
industries. Previously, up until 19th of December 2005, the company operated a press
department at the facility which used a solvent based compound for the manufacture
of various types of ends for the three-piece cans. As a result of the introduction of the
VOC regulations this process line was decommissioned and the manufacture of these
ends was transferred to a sister plant in the UK. As a direct result the usage of organic
solvents ceased completely and the company no longer met the criteria for requiring
an IPPC licence as set out in the Environmental Protection Agency Acts 1992-2003.
The EPA conducted an inspection of the site on the 14/04/08. The inspector noted the
following observation:
“The licensee is required to inform the Agency if it intends to apply to surrender its
license on receipt of this site report, In any event, an independent closure audit is
required to be carried out by a suitable qualified person with demonstrated experience
in contaminated land”
Following the EPA inspection on the 14/04/08, the decision was taken by Crown
Packaging management that the ceased activity would not be resumed and that IPPC
licence P0098-01 would no longer be required. The application for surrender of
licence was initiated.
Page 26
Bord na Móna Environmental Ltd. was commissioned by Crown Packaging Ireland
Ltd to undertake an independent exit audit of their facility at Athy, Co. Kildare.
The impetus of this audit was to identify the decommissioning, rendering safe or
removal for disposal/recovery of any soil, sub-soils, buildings, plant or equipment, or
any waste materials or substances or any other matter contained therein or thereon,
that are associated with the licensed activity that may result in environmental
pollution. The audit was carried out on the 30th of September and entailed review of
documentation, site visit and interviews with relevant site personnel.
On the day of the audit it was noted that the manufacturing equipment, wastes and
raw materials associated with the licensable activity had been completely
decommissioned and removed from the site.
Based on the audit observations the decommissioning process of the licensable
activity were addressed. Crown Packaging has operated their facility under the strict
guidance of their Environmental Management System and in accordance with IPC
License P0098-01. In addition the have been recommended for ISO 14001
accreditation of their EMS. Crown Packaging is committed to continually monitor and
improve on the environmental performance of the site following the surrender of their
IPC License.
Based on the finding of the exit audit, it is considered that there are no remaining
environmental liabilities associated with the Press Department remaining at the
facility. The independent exit audit report was submitted to the Agency in November
2008.
An exit audit of the facility was conducted by the EPA on the 11/03/09 (Ref P0098-01
/gc16.doc). Special attention was paid to any wastes, chemicals, equipment and any
other materials remaining on-site, the flamstore bund, two double skinned tanks, the
former press department and the current surface water monitoring point. A review of
the following documentation was conducted:
• Waste Records
• Noise Survey Report
• Flamstore Integrity Test Report
• Surface Water Visual Inspection Log
• Surface Water Monitoring (2006/207/2008)
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• Oil Separator Maintenance Records (2007/2008)
• Diesel Tank Inspection Records
• Flamstore Bund Inspection Record
• PBC Survey Report
All documentation reviewed during the audit was deemed to be satisfactory. Crown
Packaging was commended on the progress made to date (16/03/09) and for their
commitment to comply with IPPC Licence P0098-01. The inspector noted that the
facility was in a satisfactory state and is not likely to cause environmental pollution.
The surrender of the licence can proceed contingent upon the satisfactory resolution
of the observation raised in the audit report.
The Observation required the preparation of and the submission of an AER for 2008
including the following information:
• Surface Water monitoring results
• Waste emissions
• Energy and water consumptions
• Summary of environmental incidents and complaints
• Progress on 2008 objectives and targets
• Pollutant Release and Transfer Register (PRTR) reporting for 2008.
This report has been prepared and shall be submitted to the Agency.
APPENDIX 01
APPENDIX 02
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
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CROWN PACKAGING IRELAND LIMITED, 2008
ANNUAL ENVIRONMENTAL TRAINING PLAN Page 1 of 1
ATHY,
CO.KILDARE.
DEPARTMENT: All Departments/Environmental
IDENTIFICATION OF TRAINING NEEDS/ OBJECTIVES TRAINING PLAN IMPLEMENTATION
Name/ Training Job Title Training Objective Method of Training / Course Title Completion Completion Training Training Comments
Category Date Date Mandays Record
All employees Environmental Awareness Internal Course by External Specialist 31-Dec-08 25/07/2008 y
All employees Use of the spill kits Internal Course by External Specialist 31-Dec-08 Not
completed
Technical Dept ISO 14001 In house by External Specialist 31-Dec-08 10/07/2008 y
20/11/2008 y
New employees Induction Training In house 31-Dec-08 Ongoing Y
Technical Dept AER Electronic Reporting External 31/12/2008 23/01/2008 y
SIGNED: Dermot O'Callaghan TITLE: Technical / Environmental Mgr DATE: 23/03/2009
SIGNED: TITLE: DATE: EMF017/R02
APPENDIX 03 Environmental Management
Programme for 2008
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
Page 29
Table 4.1 Air Emissions Activity / Emission Target
Target Date Objective Responsibility
Comments/Progress made in 2008
Boiler Emissions
Reduction of boiler emissions Ongoing
1) Management of ongoing boiler service Site Engineer Ongoing
programme
2) Minimise emissions by reducing Site Engineer Ongoing
energy consumption
Emergency Situations
Manage and reduce impact of emissions Ongoing
Training for CROWN Packaging associates on the
Tech./Environmental Manager
Ongoing programme of induction training for
as a result of accident or emergency emergency plan new employees
Implementation of ISO 14001
Procedural control of Environmental Dec-08
Implementation of ISO 14001 system
Tech./Environmental Manager
Recommended for ISO 14001 accreditation following
Issues SGS audit of 09/03/09
Page 30
Table 4.2 Water Emissions Activity / Emission Target
Target Date Objective Responsibility
Comments/Progress made in 2008
Storm Water
To monitor storm water in accordance with Ongoing
Maintain ongoing monitoring program including
Tech./Environmental Manager Ongoing
IPC licence. monthly visual analysis
Implementation of ISO 14001
Procedural control of Environmental Dec-08
Implementation of ISO 14001 system
Tech./Environmental Manager
Recommended for ISO 14001 accreditation following
Issues SGS audit of 09/03/09
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
Page 31
Table 4.3 Waste Activity / Emission Target
Target Date Objective Responsibility Comments/Progress made in 2008
Shipment of Waste
Maintain waste register Ongoing
Maintain a hazardous waste register
Tech./Environmental Manager Ongoing
Maintain a non-hazardous waste register
Tech./Environmental Manager Ongoing
Recycling
Maximise recycling of waste materials Ongoing
1) Review current recycling practices
Tech./Environmental Manager Maintain on going programme of recycling
2) Implement any improvements identified
Tech./Environmental Manager
Waste Production
Minimise volume of waste produced Ongoing
1) Review current waste production Operations Manager
Ongoing programme to reduce scrap levels as part of the company's KPI objectives
2) Implement any improvements identified Operations Manager
Implementation of ISO 14001
Procedural control of Environmental Dec-08
Implementation of ISO 14001 system
Tech./Environmental Manager
Recommended for ISO 14001 accreditation following
Issues SGS audit of 09/03/09
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
Page 32
Table 4.4 Energy Activity / Emission Target
Target Date Objective Responsibility Comments/Progress made in 2008
Energy Consumption
Reduce the energy requirements at Ongoing
Maintain training and awareness programme to Site Engineer
Crown Packaging Ireland Ltd.
inform and involve the Crown Packaging Ireland
associates in an energy conservation strategy, e.g., lighting, heating etc.
Implementation of ISO 14001
Procedural control of Environmental Issues Dec-08
Implementation of ISO 14001 system
Tech./Environmental Manager
Recommended for ISO 14001 accreditation following SGS audit of 09/03/09
APPENDIX 04
For the Attention of: Prepared by: Mr. Dermot O’Callaghan Mr. Peter Coogan
Crown Packaging Ireland Ltd. Monitoring Team Leader
Woodstock Industrial Estate
Athy Co. Kildare Reviewed by: Ms. Natalie Duncan
Environmental Scientist
Ref: ECS3215 - January 09
BUND INTEGRITY ASSESSMENT
AT
CROWN PACKAGING
WOODSTOCK INDUSTRIAL ESTATE,
ATHY,
CO. KILDARE.
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
CONTENTS
1.0 Executive Summary
2.0 Scope
3.0 Survey Methodology
3.1 Monitoring Requirements
3.2 Assessment Techniques
3.3 Determination of fill level.
3.4 Reporting
3.5 Rain Gauge
4.0 Discussion
Appendix 1. Determination of required fill level Daily Log and Photographic Evidence
Appendix 2. Graph of Rainfall
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Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
1.0 Executive Summary
Bord na Móna was commissioned by Crown Packaging Ireland Ltd to carry out Bund testing
at their facility in Athy, Co. Kildare. The survey was performed between 19/01/09 and
26/01/09. The bunded areas included in this study were referenced as follows:
1. Oil/Chemical Storage Bund
The above bunded area were tested for liquid tightness for seven days in accordance with B.S.
8007:1987 sections 9 (24 Hr Stabilisation period) and was found to be in compliance with the
test.
Signed:_____________________ _____________________ Peter Coogan Natalie Duncan
Monitoring Team Leader Environmental Scientist
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
2.0 Scope
Bord na Móna Technical Services was contracted by Crown Packaging Ireland Ltd to carry
out Bund testing at their facility in Athy, Co. Kildare. The scope of the survey is limited to the
following:
a. Identification and Inspection of the bunded area.
b. Test the bunded area for ‘liquid tightness’ as specified in section nine of B.S. 8007: 1987
as required for seven days.
c. Reporting and interpretation of the assessment results.
3.0 Survey Methodology
3.1 Monitoring requirements
As part of the ongoing assessment of the bunded areas on site as required by
IPPC licence No. P0098-01, Condition 8.3.2, this test was performed to
determine the integrity of the bund. The bund tested was referenced as
follows:
Bund I.D.
1 . Oil / Chemical Storage Bund
3.2 Assessment Techniques
The bunded area was allowed to fill with rain water to the fill level, marked and allowed to
stabilise for 24 hours on the 19th of January 2009. After stabilisation, the level of the liquid
surface was recorded by means of a photograph at 24-hour intervals for the test period of
seven days.
3.3 Determination of required fill level.
The required retention volume for each bund was determined prior to commencing filling.
Details of the bund are available in appendix 1.
3.4 Reporting
Daily photographic evidence for the bunded area is reported in Appendix 1.
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
3.5 Rain Gauge
An ISCO 675 rain gauge was installed within the bund area. The ISCO 675
logging rain gauge uses a tipping bucket design for accurate rainfall
measurement. The rain gauge has a built-in logger which records date, time
and rainfall data. Rain Gauge graphs and photographs are shown in Appendix 2
4.0 Discussion
The criteria used for testing of bunds, tanks and sumps are as follows:
1. A bund containing one vessel should have a nominal capacity of 110 % of the vessel’s
maximum capacity.
2. A bund containing more than one vessel should have a nominal capacity of 110% of the
largest vessel or 25% of the total capacity of all the vessels, which ever is the greater.
3. Sumps, built with double skins (i.e. an inner and outer layer) should have no water in
between the two layers.
The bunded areas, as detailed in previous sections, were allowed stabilise for 24 hours and
tested. During this 7-day test period the total permissible dip in level (allowing for
evaporation) should not exceed 1/500th of the average water depth of the full bund in all
cases.
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
APPENDIX 1
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
BUND TESTING REPORT CLIENT: Crown Packaging Ireland Ltd BUND LOCATION: Bund 1 – Oil/Chemical Storage Bund SURVEY DATES: 19/01/09 -26/01/09 PERSONNEL: Peter Coogan - Bord na Móna
DAILY LOG
DATE WATER LEVEL
EVAPORATION /24hr
PHOTO I.D. PERSONNEL
19/01/09 Fill/ Stabilisation 440 mm +/- 1mm No PC 20/01/09 Stabilisation/Test 460 mm +/- 1mm Yes PC 21/01/09 Test 465 mm +/- 1mm Yes PC 22/01/09 Test 482 mm +/- 1mm No DC 23/01/09 Test 505 mm +/- 1mm Yes DC 24/01/09 Test 520 mm +/- 1mm No DC 25/01/09 Test 543 mm +/- 1mm No DC 26/01/09 Test 590 mm +/- 1mm Yes PC
Total Area of Bund - 18.6 x 12m Water Catchment Area – 2 x 11.5m
DATE Rainfall (mm) Calculated Increase in Catchment Area Based on
Rainfall (mm/day) 19/01/09 1.9 18.4 20/01/09 0.6 5.82 21/01/09 1.8 17.46 22/01/09 2.3 22.31 23/01/09 1.6 15.52 24/01/09 2.5 24.25 25/01/09 4.1 39.77 26/01/09 0.3 2.91
I. COMMENTS
This bund (Bund 1) was tested for Seven days in accordance to B.S. 8007: 1987
(Design of concrete structures for the retaining aqueous liquids: Section Nine -
inspection and testing of the structure).
Conformance to B.S. 8007: 1987 Section 9 (24 Hr Stabilising Period) Compliant
Photo ID: Bund 1 - Day 1 (20/01/09)
Photo ID: Bund 1 - Day 2 (21/01/2009)
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
Photo ID: Bund 1 - Day 4 (23/01/2009)
Photo ID: Bund 1 - Day 7 (26/01/2009)
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
Bund Area
Collection Tank in Bunded (Catchment Area)
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
APPENDIX 2
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
Graph Representing Rain Fall
Crown Packaging Ireland Ltd ECS3215
Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009
ISCO 675 Rain Gauge
APPENDIX 05
CROWN Packaging Ireland Ltd – Annual Environmental Report 2008
Page 33
Crown Packaging Ireland Ltd Work Instructions Manual
Procedure Number Re
vision
Page
EWI 6.0 0 1 of 1 Procedure Pump out of flam store bund / fire water retention facility Purpose To ensure that the pumping out of the flame store bund does not cause
pollution of the storm water drains Responsibility Technical Department References EWIF 6.1 Flamestore bund fire Water Retention facility pump out
1. The above bund will be pumped out as required.
2. The Technical Manager or person designated by the Technical Manager shall carry out the pumping out of the flame store bund.
3. The water in the bund will be initially inspected for signs of chemical contamination.
4. If no signs of contamination are evident the bund water may be pumped into the storm water drain
having first recorded.
5. The depth of water in the bund shall be documented prior to pumping.
6. The results are recorded on the Flam Store Bund/Fire Water Retention Facility Pump Out Sheet EWIF 6.1.
7. These results are submitted annually to the EPA as part of the Annual Environmental Report.
8. A controlled hard copy of this record sheet is stored in the Technical / Environmental Managers Office.
9. If there are any signs of chemical contamination of the water, the Environmental Management Team
will initiate an investigation as per non-conformance, corrective &preventive action procedure EP 8.0.