For inspection purposes only. Attachment · 2013. 7. 25. · RISK ASSESSMENT 4.1 Methodology 4.2...

Kerry Ingredients (Ireland) Ltd. PO386-01 IPPC Licence Review Application Attachment No. F

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Attachment No. F - Accident Prevention and Response

F.0 Introduction

Kerry Ingredients Charleville Accident Prevention and Response systems are based on a number of common elements:

0

Risk Assessments 0

0

0

0 Training of Key Personnel 0

Identification of potential significant accident scenarios on the site - this has been done through I S 0 14001 Register of Environmental Aspects

Implementation of Accident Prevention Measures Provision and Maintenance of Emergency Response Facilities Testing of Controls and Response Facilities and Procedures

Corrective and Preventative Action Procedures

An overall Site Business Continuity Plan is in place to ensure overall co-ordination of any emergency situation on the site and specific emergency response procedures are in place.

The site is covered by 24-hour security 365 days per year therefore ensuring that any potential emergency situations are detected even when there is no production on the site.

An Environmental Liabilities Risk Assessment is carried out annually and adequate financial measures are in place to cover any potential accidental releases.

F.10 Charleville site.

Potential Significant Accident Scenarios from the Kerry Ingredients

0

0

0 Ammonia Release

Discharge of Contaminated Material to Surface WatedGroundwater Fire (including Dryer Explosion) and Contaminated Fire Water Run off

F.la Discharge of Contaminated Material to Surface WatedGroundwater

Risk Assessments Completed

0 Environmental Risk Assessment of the Storage and Transfer Systems

Controls in Place 0

0

0

0 Effluent Sump Alarms 0 Colour Coding of Drains 0 I S 0 14001 EMS Procedures

Modifications to Site Drainage to eliminate high risk areas Bunding of Chemicals and Fuels Dedicated LoadingAJnloading in Areas drained to ETP

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0 Surface Water and Groundwater Monitoring

Emergency Response Facilities 0 Stream Divert System 0

0 On Site Fire Engine 0

24 Hour Security 0

ETP Balance Tank and overflow to Old System

Emergency Spill Equipment (Drain Protector Mats etc.)

Emergency Response Procedures and Business Continuity Plan

Testing Carried Out 0 Bund Integrity Testing 0

Drain Surveying and Testing 0 Stream Divert System Testing 0 Spill Response Testing

Whole milk and Skim Milk Silo Integrity Testing

Q Training

0

0

Emergency Spill Training (As part of weekly Fire Crew Training) Emergency Response Procedure and Business Continuity Plan Training

F.lb Fire (including Dryer Explosion) and Contaminated Fire Water Run off

Risk Assessments Completed

0

0

Fire Water Run-Off Study (See Attachment Cl) Risk Assessment of the explosion risks within the ATEX Workplace Directive (1 999/92/EC).

Controls in Place 0

0

0 Dryer Ring Main System 0

Provision of Firebreaks 0

Dryer Suppression Systems and Interlocks Carbon Monoxide Detectors and Interlocks

Thermal Oil System Interlock Safety Controls

Permit to work systems e.g. Hot Work Permits

a

Emergency Response Facilities 0

0 Fire Wardens 0

0 Fire Hydrants 0 Fire Extinguishers 0 24 Hour Security 0 Stream Divert System 0

Fire Detection and Alarm Systems

On Site Fire Engine and Crew

ETP Balance Tank and Overflow to old system

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0 Emergency Response Procedures and Business Continuity Plan /

Testing Carried Out 0

0 Fire Detection System Testing 0 Fire Hydrant Testing 0 Fire Extinguisher Testing

Dryer Suppression System and Carbon Monoxide Detectors Supplier Maintenance

Training 0 Fire Crew Training 0 Fire Evacuation Drills 0 Fire Extinguisher Training 0 Fire Warden Training 0 Emergency Response Procedure and Business Continuity Plan Training

F.lc Ammonia Release

Risk Assessments Completed 0 Ammonia Plants Audit

Controls in Place Preventative Maintenance System System Interlocks

Emergency Response Facilities 0 Ammonia Detection 0 Quick Closing Valves 0

0 Personnel Masks 0

System Drawings and Isolation Procedures posted on plant room doors.

Alarm System (to facilitate evacuation)

Testing Carried Out 0 Emergency Procedure Testing

Training 0 Emergency Response Procedure and Business Continuity Plan Training

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Kerry Ingredients (Ireland) Ltd.

ENVIRONMENTAL RISK ASSESSMENT REPORT

File No. 101112.22.001 Document No: 101 1 12-22-RP-0001

PM Dublin lrefand T +353 1 404 0700 F +353 1 459 9785, E dubrnBpmaJe

BvPmpddimiizz EIWIRONMB(TALUDI EHyIAmQIEI(TIL\Ini1z-P.

PM Cork Ireland T +353 21 435 8922 F +353 21 435 8933. E [email protected] www.prnq.ie

TUC& i s ~ ~ p 4 1 4 IIM amm Coversheet and Oocumenl Template mi lwm

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Kerry Ingredients (Ireland) Ltd. Envlronmental Risk Assessment

101 112-22-RP-0001 Issue A 26 July 2005

CON TENTS

1.

2.

3.

4.

5.

6.

EXECUTIVE SUMMARY

INTRODUCTION

SITE DESCRIPTION

3.1 Surface water drainage

3.2 Process and Foul Drainage

3.3 Wastewater Treatment Plant

RISK ASSESSMENT

4.1 Methodology

4.2 4.3 4.4 ' Estimation of Risk

Sub-Division of Site into Catchment Areas

Source - Pathway - Receptor

PROPOSED REMEDIAL WORKS

5.1 5.2 Skimmed Milk Intake Area

5.3 Raw Materials

5.4 Diesel Unloading Area

5.5 Underground lines

Whole Milk Intake Storage Area.

RISK MANAGEMENT MEASURES - COST ESTIMATE

APPENDIX 1

ESTIMATION OF ENVIRONMENTAL RISK FROM STORAGE AREAS

ATTACHMENT I

FOUL & STORMWATER DRAINAGE OVERALL SITE PLAN

DRG. NO. 3000-00-GA-005

ATTACHMENT 2 ENVIRONMENTAL RISK RATINGS

DRG. NO. 101 112-49-SK-0006

ATTACHMENT 3

PROPOSEDRISKMANAGEMENTMEASURES

DRG. NO. 101 1 12-49-SK-0008

3

3

3

3

4

4

5

5 5 5

7

14

14 15

15

16

16

17

S~ledS\101112W EFMRONMCNTALWI ENVIRONMWTALM01112~~-2-RP.WOI WAdW Page 2

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Kerry Ingredients (Ireland) Ud. Environmental Risk Assessment

101 11 2-22-RP-0001 Issue A 26 July 2005

I. EXECUTIVE SUMMARY An environmental risk assessment was conducted on the storage and transfer systems on the Kerry Ingredients Ltd. site at Charleville, Co. Cork. This risk assessment identified a number of areas where additional retention or protection is required as follows:

1. The Whole Milk storage tanks and the Milk Intake Area;

2. The Skimmed Milk Tanks:

3. The Raw Material Tanks; and '

4. The lines and equipment used for filling and emptying of the main Diesel Tank and its bund.

Options for improving and expanding the retention in these areas, and reducing the associated risk, are included, along with the associated estimated costs.

2. INTRODUCTION Kerry Ingredients (Ireland) Ltd. was found to be in breach of its IPC Licence, Register Number 386, when an incident occurred on 14' March 2005, whereby a leak of whey concentrate from a tank onsite found its way into the Charleville stream. The Environmental Protection Agency issued a notification of non- compliance on 5' April 2005. One condition of that notification was that a full independent risk assessment be conducted at the facility. This report assesses the risks associated with the material storage and transfer arrangements at the facility.

3. 0

SITE DESCRIPTION The Kerry Ingredients (Ireland) L tk premises at Rathgoggin Middle, Charleville processes milk into powdered milk, butter and cheese products. Please refer to Attachment 1 for a layout of the site and its drainage systems. Surface water drains are shown in green and process effluent and foul drains are shown in red and purple.

3.1 Surface water drainage The north of the site is bounded by farmland and farm buildings. A body of water known as the Millrace flows under the site and emerges in the middle of the site. This flows in a northeasterly direction through the site. There are thirteen surface water outfalls from the site to this Millrace: SWEP2-14 inclusive. Of these, five - SWEP2, SWEP3, SWEP4, SWEP5, and SWEPG - are monitored daily by visual inspection and weekly for pH and COD. Two of these (SWEPS and SWEP 13) are ovefflows from water tanks. These outfalls are identified in the risk assessment exercise below in Section 4.4.1 as Catchments 2-14 inclusive.

The site is bounded to the south by the main Charleville-Kilmallock road. Alongside this road runs a body of water known as the Glen River. There are six surface water outfalls from the site to the Glen River. None of these outfalls is monitored. Of these, the run-off from the diesel storage tank near the main site entrance passes through a diesel interceptor prior to its release to the river. The outfalls are numbered for the purposes of the risk assessment exercise in Section 4.4.1 below as Catchments 24, 29, 30, 31, 15 and 16.

Further downstream the Glen River and the Millrace converge to form what is then called the Charleville Stream.

-

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101 112-22-RP-0001 Issue A 26 July 2005

3.2 Process and Foul Drainage Foul drainage from the western side goes to the local authority sewer, and form the eastern side of the site goes to the site's WWTP through the process effluent drainage system. Process and foul drains are both shown in red or purple on the attached site layout, Attachment 1.

The local authority sewer flows underneath the site from the southwestern comer up to the maintenance compound. At the maintenance compound it is joined by another branch of the local authority sewer from the northwestern corner of the site. The sewer then flows down to the road and leads' onwards to the Cork County Council Charleville Municipal Wastewater Treatment Plant. There are eight outfalls from the site to the local authority sewer, none of which is monitored. These outfalls carry a combination of surface water and foul effluent. The outFalls correspond to the following catchments in the risk assessment exercise in Section 4.4.1 as Catchments 17,23, 18, 19, 20, 32, 21 and 22.

The process effluent drainage system carries process effluent from the processing areas and surface water runoff from much of the site, particularly the raw material and chemical storage areas. The process drains were surveyed and some were found to be faulty, i.e. there was the potential for loss of material to ground. A five-year plan was agreed with the Environmental Protection Agency for repairs to the process drains. The plan is in its third year, with the following areas completed to date: Powder (Phase l), Cheestrings, and Processed Cheese. Areas still to be repaired are Powder (Phases 2 and 3), Butter, and Milk Intake.

.

3.3 Wastewater Treatment Pfant The site's wastewater treatment plant is located approximately two miles northeast of the site. Process effluent passes through <a screen at the north of the c

site and then flows under gravity into the WWTP balance tank (capacity 2,453 m3). From the balance tank it enters the dissolved air flotation units where it is adjusted to pH 8.5. It is then transferred back to a sump near the lagoons. From here it enters firstly the anoxic lagoon, then the aeration lagoon, wherein most of the treatment takes place. It is then transferred back to the plant area, where it is dosed with coagulant (ferric sulphate or aluminium sulphate) and phosphorus is removed. The effiuent is then split across two settlement chambers. The solids from the settlement chambers are transferred to the picket fence thickeners and then on to the dewatering building. The liquid effluent passes through the sandfilter and then on to the storage lagoons (six in number, with a total capacity of 600,000 m3) where it is retained until it is released into the Charleville stream at SWEPI. Under the IPC Licence Register Number 386, effluent may only be released to the stream when there is a minimum of six dilutions of effluent by stream water. The picket fence thickeners and the dissolved air flotation devices feed to the decanter in the dewatering building, which brings the solids content up to 8%. This sludge is sent for soil injection. In wintertime the sludge is brought up to 22% solids and lime is added; this sludge is stored until spring and used on tillage ground.

There are ten additional lagoons alongside the WVVTP that have the potential for use as emergency overflow should it be required.

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1

I

Kerry Ingredients (Ireland) Ltd. Environmental Risk Assessment

101 11 2-22-RP-0001 Issue A 26 July 2005

4. RISK ASSESSMENT

4.1 Methodology Reference to the following guidance documentation is normally used for the purposes of conducting an Environmental Risk Assessment:

EPA's IPC Guidance Note on the Storage and Transfer of Materials f0.r Scheduled Activities, 2004.-

U.K Environment Agency R&D Publication 20 on Methodology for the Derivation of Remedial Targets for Soil and Groundwater to Protect Water Resources, 1999.

0 U.K. Department of the Environment, Food & Rural Affairs Guidelines for Environmental Risk Assessment and Management, 2000

The assessment is primarily a desktop exercise, which includes recommendations for. further remedial action considered necessary.

Three components need to be present before a risk can be manifest, namely:

Source =$ Pathway j Receptor

If any of the above is missing, then there is no risk.

4.2 Sub-Division of Site into Catchment Areas The site, including the VWVTP, %as been divided into 28 catchment areas according to the outfalls to the Millrace, the Glen River, the local authority sewer and the site WWTP (Refer to the catchment drawing, Attachment 2). In addition, there are three catchment areas in which oils or fuel are stored, but which have no local drainage; any loss of material would be to ground. The WWTP itself is an additional catchment as chemicals are stored therein; again any loss outside of the storage bunds would be to ground.

.

4.3

Each catchment is then broken down further into source areas, as appropriate, depending on the materials stored therein and the drainage system layout in that catchment area. Source areas are assessed separately for environmental risk. Refer to Table 2 in Appendix I for the complete assessment.

Source - Pathway - Receptor The sources encountered on the site are:

I. Chemicals, mainly used for CIP and in the WWTP;

2. Raw materials; and

3. Fuels and oils.

For each source, the pathway and receptor are defined.

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101 1 12-22-RP-0001 Issue A 26 July 2005

The pathwavs encountered on the site are:

I. Surface water drains;

2. Process effluent drains; and

3. Leakage from process effluent drains requiring repairs.

The receptors encountered on the site are:

1. The Millrace, the stream running underground and emerging at the north of the site;

2. The Glen River, the stream running along the south of the site; ! cs 3. Charleville stream at the VWVTP, after the confluence of the Millrace and

the Glen River;

4. The local authority sewer, which crosses under the site and flows I I ultimately to the Cork County Council Municipal WWTP for Charleville;

and

5. Groundwater.

Water Quality of the Charleville Stream

The Charleville Stream (also known as the GlenSiver) is a tributary of the River Maigue and ib monitored by the EPA for water quality. At the sampling locations both upstream and downstream of the sfte, the water quality is assessed as continuing to be unsatisfactory, with moderately polluted conditions recorded at all three locations (2003 Q-values of 3, 2-3 and 3)' It is not designated as a salmonid watercourse.

' Source: €PA EcologicaI Assessment of Rivers 2003. Sampling locations: 0200, New Line Bridge; 0500, Bridge NW of Ballincolly; 0800, Just upstream of River Maigue confluence.

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101 112-22-RP-0001 Issue A 26 Julv 2005

4.4 Estimation of Risk

4.4. I Storage of materials With reference to Section 5.2.5 of the EPA Guidance Note, the environmental risk is a combination of the likelihood of the event occurring, i.e. the probability of potentially polluting substances being discharged to the environment, and the consequence of the event on the environment. For each source, pathway and receptor on the site, the probability, consequence and risk have been estimated.

‘The complete record of the estimation of risk for each area and source is included as Appendix 1. For simplicity, the risks associated with each source have been extracted into Table 1 below, and ranked in order of decreasing severity.

The individual catchment areas, and their associated risk ratings, are shown on drawinf number 101 112-22-SK-0006, included as attachment 2.

Appendix 1 also contains a complete listing of all materials stored on the site, based on each source location. All materials are assigned a water hazard class (WHC) value, according to the German Umweltbundesamt classification (corresponds to Wassergefahrkfasse, WGK value). As per Section 5.2.7 of the EPA Guidance Note, milk and other food materials stored on site have been assigned a WHC value of 1. This decision of the EPA is based on the fact that these compounds, while not exhibiting an acute toxicity, do present a high pollution load. When the total amount of material onsite is added up and its WHC values taken into consideration, there is more than 500 m3 of WHC 2 material and almost 2,500 m3 of WHC 1 material. The site therefore is a Category D high hazard facility. Particular consideration must be given to sensttive

e. environmental receptors in the cases of overground faciIities of Category D.

Considering the BOD of the whole milk stored on the site in the six whole milk intake tanks: These contain 1600m3 of milk, with a BOD of 120 Kg/m3, i.e. a total of 192,000 Kg of BOD. This also designates the site as a high hazard facility,

Pege 7

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Kerry ingredients (Ireland) Ltd. Environmental Risk Assessment

101 112-22-RP-0001 Issue A 26 July 2005 i

4

29, 30,31

16

1.1

1.5

1.8

c

Raw Materials Millrace High See below

Skimmed Milk Intake Glen Medium See below River

Diesel Tank Filling Area Glen Medium See below River

Milk Intake tanker area Ground Low Repairs to

Niro 2/3 CIP Centre Ground Low Repairs to

Fat tanks Ground Low Repairs to

drains

drains

Table 1 Catchment Source Areas ranked in order of priority of risks

.. i

i

Su)mlam\OtllX2 EMllRONMENTALYlOl ENVlRDMrlENTAL\lOl112~22~AP~l WAdOc Page 8

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101112-22-RP-0001 Issue A 26 Julv 2005

c

Table ‘f continued

Process Cheese

Niro I CIP Centre’

17 Farm Services

23 Run-off from Farm Services

1.3 Niro 2 Store

I .5 Niro 3 Store

1.5 Niro 3

I .6 Niro 2 I .7 FFM

OfficeslCanteenlMar keting Offices

Fats Room

Niro ?/Bagging Line I 1.10 Bagging Line 2

I

1.11 I ProjectsIFirst Aid

1.12 Pilot Plant

2 Drains NW and N of Butter Factory

3 Drains NW of Butter Factory

4 Yard West of Butter Factory/Powder Carpark, Niro 2 Store, Malt Milk, Butter Store

5 Niro 3 and 4 stores buildings

6 Roof run-off from Niro I store and bagging line 2.

7 Roof run-off from diesel generator room

Run-off from carpark and CHP Plant

WWTP

WWTP NearZerc

Municipal Near Zerc

WWTP

Municipal Near Zerc

WWTP 7 Zero

Zero

Zero

.Zero

Zero

I I Zero

t. Zero

- Zero

- Zero

Zero

Zero

fiction- :Required

NIA

NiA

NIP;

NIA

N/A

NIA

NIA

NIA

NiA

NIA

NIA

N/A

N/A

N/A

NIA

i

NIA

N/A

NIA

NIA

N/A

NIA

NIA

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Kerry Ingredients (Ireland) Ltd. . 101 1 12-22-RP-0001 Issue A Environmental Risk Assessment 26 July 2005

Table f continued

10

11 r

12

13 14 15

18 19

20

21 22 c;

24

29

.30

31

32

Roof run-off from CheestringslBrunchetta

Roof and yard run-off from Process Cheese and Cold Stores Roof r u n-off fro mLiquid - Cold Milk Stores

Overflow from Water Tank - Run-off from Farm Services - Gully (south of Marketing - offices)

Cold Stores - Roof run-off from - Intervention Stores and Shipping Offices

Roof run-off from - Intervention Stores

Foul effluent from Security

F.oul effluent from Medical Centre

Run-off from process Cheese yard.

South of Skimmed Milk Intake



Foul effluent from Projects Office

I

Zero N/A

Zero NIA

Zero NIA

Zero NIA

Zero NIA

Zero N/A

Zero NIA

Zero NIA

Zero NIA

Zero N/A

Zero NJA

Zero NIA

,

Page 10 &:\Pmeck\lD111~ ENVWoNMENTAL'4Ot ENVIRONMENTAL\101112-~~.RFWOl WAdZ

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101 11 2-22-RP-0001 Issue A 26 July 2005

Hiqh risk storage areas

Whole Milk Intake Storage tanks

There is 1600 m3 of milk stored in 6 tanks at the milk intake area, with no local containment. (Catchment 2, surface water drains to SWEP2). Whole milk has a BOD5 of 120,000 mg/L, so loss of the contents of a 266.6m3 tank would mean a loss of 32,000 Kg of BOD. Such a loss would have a dramatic short-term effect on the water quality of the Millrace and on downstream. This area was initially considered to be of medium risk following,a risk assessment in line with Section 5.2.6 of the EPA Guidance Note. However, since it contains a large quantity of high BOD material (> 20,000 Kg of BOD) and there is currently the potential for loss of material to the MIIlrace from this area, as per Section 6.3.2 of the Guidance Note it is rated as a HIGH risk area. ,

Furthermore, there is also the potential for spills from tankers unloading in this area to reach the surface water system and flow into the Millrace.

Raw Materials

There are two tanks of 45m3 each that may at any time contain either whey concentrate, liquid malt, or butteroil, and one 50rn3 tank of glucose. A leak from any of these tanks should enter the local process effluent drain. However, during the incident of 14' March 2005, the process drain was blocked and whey concentrate made its way into the surface water drainage system and thence into the Millrace (Catchment 4). Whey has a BOD of 40 Kg/m3, so there was the potential for 1800 Kg of BOD to enter the Millrace.

The BODS of liquid malt and glucose are approximately 900 Kg/m3, so loss of the contents of either tank would mean a loss of up to 45,000 Kg of BOD. However, the very high viscosities of the& materialsz mean that they are likely to solidify on the yard or in the drainage system, allowing the material to be collected and disposed of. Butteroll has a BOD of 1,000 Kg/m3 and is not so viscous, so a catastrophic tank failure could result in the loss of 45,000 Kg of BOD. Much of the material should enter the process drainage system, but given that the process drain is only 100 mm in diameter, it may be inadequate to carry all the leaked material and some material could end up in the surface water drain and make its way into the Millrace, as happened during the incident in March. T h e environmental risk of a leak from these t a n k s is classed as HIGH.

Viscosities: Glucose = 160,000 CP at 20°C; Liquid Malt = 40,000 CP at 25°C.

Page 11 SUinjcc!silOll lZE2 ENVIRONMENTALWI ENVWONMENTAL\101112-ZMP4lp-RPQW1 mAdm

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101 112-22-RP-0001 Issue A 26 July 2005

Medium risk storaqe areas

Skimmed Milk Intake Area

There are nine skimmed milk storage tanks on the site. Six are located together in a level area which drains to the process effluent system, so the environmental risk from these is low. The other three tanks are located in an area with a fall towards the Glen River. The local drains enter the process system. However, in the event of a catastrophic tank failure, some skimmed milk would flow in an easterly direction and enter the process drainage system neafthe Marketing Offices. However, some of the skimmed milk would flow in a southeasterly direction. There are two open-ended pipes through the boundary wall which would allow milk to enter the river. In addition, there are three surface water drains in this area, so it is possible that material would end up in the river throu h these (Catchments 29,30 and 31). Skimmed milk has a BOD of 70 Kglm , so the loss of the contents of a tank of capacity 272 m3 would mean a

. loss of 19,040 Kg of BOD. Such a loss would have a dramatic short-term effect on the water quality of the Glen River and on downstream. The environmental risk of a leak from a skimmed milk tank is classed as medium.

Low risk storage areas

Generally, chemicals on site are stored in tanks or drums or on pallets with local secondary containment, so these sources have a low probability of release into the environment and hence pose a low or near zero risk to the environment. Bunds are inspected and tested every three years, in accordance with IPC Licence Register Number 386.

Similarly, fuets and oils are stored in tanks within bunds or in double-skinned tanks, so again these sources have a low probability of releas6 into the environment and hence pose a low or near zero risk to the environment.

Q

c

4.4.2 Overground pipes'

There are a number of gantries carrying above-ground piping systems on the site - see Site Layout, Attachment 1. These are used for the transfer of raw materials (whole milk, skimmed milk, vegetable oil) around the site. The pipes are of stainless steel construction and trave! over impermeable areas. With reference to Section 5.3.3 of the EPA Guidance Note, in general for piping systems containing food stuffs, retention is not required.

Chemicals are all stored outside of buildings in chemical storage areas and made up to strength in those areas - the diluted materials are then piped to the points of use. The risks associated with loss of material in these areas are covered in Section 4.4.1 above.

There are lines in and out of the diesel tank at the main site entrance, and a line to carry water from the bund to the interceptor. Should a leak from any of these pipes occur, diesel could enter the local surface water drain and make its way into the Glen River (Catchment 16). As diesel has a WHC rating of 2, retention is required (ref. Section 5.3.3 of the EPA Guidance Note). Nonetheless, with reference to Section 7 of the EPA Guidance Note, utilisation of the technical measures outlined in Appendix E of the Guidance Note will reduce and possibly eliminate the requirement for retention.

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1

101 112-22-RP-0001 Issue A 26 July 2005 1


4.4.3 Underground pipes

The only underground transfer pipes on site are the filling and emptying lines to and from the main diesel tank near the site entrance, and the line carrying water from the diesel bund to the interceptor. These travel underground to pass under a roadway. They are of single-walled mild steel construction and are currently not subject to inspection.

The process drains are subjected to inspection as per the IPC Licence Register Number 386. A number of these were shown to be faulty during the last round of inspectionk and a five-year plan for the replacement of all process drains was put in place and agreed with the EPA. This plan is now in its third year.

4.4.4 UnloadingLoading facilities

Raw materials are transferred in or out of road tankers at seven locations on the site. These are:

Vegetable Oil Intake (east of Butter Factory)

0 Cream Loading (south of Butter Factory)

0 Whole Milk Intake (west of Milk Intake)

0 Two x Fat Intakes (one by Fats Room and one by Crystallisation Room)

0 Two x Skimmed Milk Intakes (at the Skimmed Milk silo areas).

Transfers all take place in impervious areas. With reference to Section 5.3.5 of the EPA Guidance Note, retention is not required for the filling and transfer of foodstuffsr-

Transfer of diesel occurs at the main entrance at the diesel pump area. This is done from a road tanker through a fixed overground line into the diesel tank. With reference to Section 5.3.5 of the EPA Guidance Note, retention is required for the filling and emptying of mobile vessels. Should a leak occur during emptying of the tanker, diesel could enter the local surface water drain and make its way into the Glen River (Catchment 16). The environmental risk associated with a leak from a tanker during a filling operation is medium.

SZm~~\lO1112’22 WMIIRONMENIALYIOI ENVIRDNMENTALU Dl 118224lPMX)l WAdOc Page 13

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I


101 112-22-RP-0001 Issue A 26 July 2005

5. PROPOSED REMEDIAL WORKS The following options are proposed as means of reducing the risk associated with the areas requiring attention.

5.1 Whole Milk Intake Storage Area. These tanks present a risk of lass of whole milk to the Millrace should a leak occur. Bunding of the six tanks at the intake was considered but to attain the requisite large retention volume of 400rn3 (Refer to Section 4.4.1) a bund wall of about 2m in height would have to be provided around the tanks. This is considered impractical and would be of no benefit in dealing with the recurring problem In the area whereby spillage and run off from the periphery of the tanker unloading bays is not flowing back into the bays and the process drains as intended, but instead is being carried out onto the external concrete yard and into the surface water system.

In order to control spillage from the tanker unloading bays the provision of a drainage channel immediately to the eastladjacent to the unloading area, connected to the process drainage system, was also considered. This however would be of little benefit in controllinglcontaining spillage from the storage tanks.

Therefore, to cater for both containment and spillage control, it is proposed to transfer the eight road gullies, which drain the yard to the east of the Milk Intake, to a new process sewer running in parallel with the existing surface water drain and connecting to the existing process drain to the southeast of the Butter Factory (see 101 1 12-49-SK-0008). This would catch any contaminated runoff or spillage from the milk intake and would also ensure that any significant spills from the storage tanks would be contained in an area entirely drained to the process drainage system.

The transfer of the yard catchment (1,800m ') to the process drainage system increases the runoff going to process by about 30 Ils for a once-in-!%year storm and up to 20 I/s for a one-year return period.

The estirnated/theoretical capacity of the 350mm diameter effluent pipeline from the factory to the Wastewater Treatment Plant (WWTP) is approximately 500 m3hr or 140 I/s. An analysis of the recent monitoring results of flows in the pipeline (late May/early June) indicate a peak flow of 220 m31hr, equivalent to 61 I/s, during rainfall on May 27". This indicates that there is more than adequate capacity available in the line to accommodate the additional runoff from the area.

The analysis also indicates a peak daily flow to the WWTP of 4,023m3 (885,000 gals) for May 27*. Thus the runoff from the area of I I Om3 over 24 hrs for a once-in-5-year storm will not impose a significant additional hydraulic load on the treatment plant (e 3%).

Since the area is readily drainable to the WWTP, the balance tank at the Plant can be considered as remote containment for the raw milk storage tanks. The balance tank has a design capacity of 2,453m3, with an emergency overflow to the anoxic lagoon. As such, the system has adequate capacity to deal with the 400m3 retention/containment required under the EPA guidance criteria3 in the event of an emergency release.

EPA's IPC Guidance Note on Storage and Transfer of Materials for Scheduled Activities.

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1011 12-22-RP-0001 Issue A 26 July 2005

5.2

i

The gully at the foot of the rainwater downpipe at the south of the Butter Factory should be provided with a solid cover. In addition, the sink waste currently discharging at this location to the external gully should be diverted to the nearby process sewer, as shown on SK-0008. This will ensure that the entire area drains to the process drainage system. The gully at the foot of the piperack in the intake yard should be similarly capped.

One of the yard gullies to the west of the intake currently drains through the tanker bays to the surface water drainage system. This should be diverted to the nearby process drain to ensure that the whole‘ area drains to process.

A

Skimmed Milk Intake Area These tanks pose a risk of loss of skimmed milk to the Glen river should a catastrophic tank failure occur.

Under EPA guidance3, a containment volume of 300m3 is required for the 3 No tanks located to the south of the Boiler House. Provision of a bund wall around the tank plinth was considered but the wall height of over 2m was considered impractical and probably not entirely necessary.

,

@ 5.3

It is therefore proposed to marginally extend the existing kerbed grassed island and to provide a cut-off channel, connected to the process drainage system, to bisect the paved area to the south of the tanks, as shown on 101 112-49-SK- 0008. This should insure that any spillage or leakage in the area is confined to a catchment draining to the process drainage system and is prevented from flowing towards the Glen River.

Since all runoff from the area will be captured by the process drainage system, the balance tank at the WWTP can be cofisidered as remote containment for the storage tanks, as in the case of the Raw Milk Intake above. The required retention volume of 300m3 is comparable to the Raw Milk Intake and as such the W W P has been shown to have adequate capacity to accommodate this emergency load. As the area currently drains to the process network there will be no additional surface water flow to the Treatment Plant associated with this volume.

Raw Materials These tanks pose a risk of loss of material to the Millrace should a leak occur and insufficient drainage capability be available in the local process drain.

The unloading slab adjacent to the tanks (3 No.) is suitable for containing minor spillages but proved inadequate during the incident in March 2005, probably to some degree due to the inadequate pipeline capacity (1 OOmm diameter) to which the gullies are connected.

Consideration was given to bunding the tanks. A containment capacity of 55 m3 (50m3 x 1.1) is required and this could be achieved by the construction of a 750 mm high wall around the perimeter of the tank plinthlslab. However, given the number of pumps and other electrical equipment associated with the tanks, the bunding would require significant relocation of equipment and alteration of pipework. It would also have a significant operational impact.

The alternative is to upgrade the process drainage line serving the area and to provide a cut-off channel to the east of the concrete apron to connect to the new

SW~CtS\tO1112’22 ENVlRONMENTAWl ENVlRONUENTAL\lOl112.P-RP~l rprAdac Page 15

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101 11 2-22-RP-0001 Issue A 26 July 2005

process sewer. This would significantly improve the surface drainage capacity in the area. The two gullies on the apron would also be connected to the newhpgraded process sewer and the gulley to west, currently draining to the surface water system, should also be diverted to the process sewer. As such, with the entire area adjacent to the tanks draining to the process system, the balancing tank at the WWTP would act a5 a remote containrnentlretention facility.

Most of this area currently drains to the process drainage system and there will "therefore be no increase in the surface water volume going to fhe Treatment Plant. A significant area to the west of the tank does however drain to the gully which it is now proposed to connect to the process drain. It is therefore proposed to provide a cut-off drainage channel across the downslope to intercept the run- off from this area and divert it to the surface water system. This should be located at a sufficient elevation up the slope that a containment basin, draining to process, is formed around the tanks to guard against a catastrophic failure.

5.4 Diesel Unloading Area

There is a risk of loss of diesel to the Glen River during filling of the main diesel tank from a road tanker. It is proposed that a forecourt separator be installed before the outfall to the Glen River - this would be capable of retaining any spilfs of diesel. A class 1 separator is typically used where discharge is expected to sensitive waters and where the hydrocarbon pollutant concentration is required to be reduced to 5rng/L or less. To meet this design criteria this separator includes a closure device and a coalescer. A float-controlled closure device is incorporated to ensure that in the event of a major spillage, the pollutant would be contained by the separator. The closure shuts off when the water is displaced by the less dense hydrocarbon pollutants, protecting the outfal1,from gross oil

'contamination.

5.5 Underground lines There is a risk of loss of diesel from the filling and emptying lines to and from the diesel tank or loss of a diesel and water mixture from the line used to empty the diesel storage bund. These lines are underground where they pass under the roadway close to the main site entrance/exit. These lines are presently of single- walled mild steel construction.

It is therefore recommended that these lines be placed in a covered and sealed concrete duct where they cross under the road. A monitoring sump and overflow to the nearby interceptors should also be included in accordance with the EPA guidance3 for new underground piping systems.

In addition., a general pipework inspection is on these lines should be carried out every five years.

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101 112-22-RP-0001 Issue A 26 July 2005

6. RISK MANAGEMENT MEASURES - COST ESTIMATE The following is a breakdown of the estimated costs associated with the scope of works proposed in this report

Whole Milk In fake Area

New 225 mm Diameter diversidn sewer and local mods Skimmed Milk Intake Area

New channel drainage and containment

Raw Materials Storage Area

New channel drainage and containment

Diesel Unloading Area

Forecourt Separator (Class ‘I)

Double-contained diesel line

Subtotal

PreIiminarieslSite Establishment

Contingency

Engineering

Total (excl. VAT)

c

cost (€)

15,000

12,000

14,000

10,000

4,000 55,000

8,000

63,000 7,000

70,000

9.000

79,000

Su)rolenslOl1 T Z E EMIIR0NMENTALW)l ENVlRONMENTAL\101112*~~APMW1 WA.L!CC Page 17

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101 112-22-RP-0001 Issue A 26 July 2005

ESTIMATION OF ENVIRONMENTAL RISK FROM STORAGE AREAS

i I i . .

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v ) . -- c

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1011 12-22-RP-0001 Issue A 26th July 2005

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I

......... ...... . ._ .... . . . . . . . . . . . . . . . . . . . . . . . . ...... ... . ...... .

. , , .~ .. " , .

101 112-22-RP-0001 Issue A 26th July 2005

Kerry ingredients (Ireland) Ltd. @ 6 Environmental Risk Assessment

Catchment Area: I .2

Butter milk, 3 tanks of 20.46 m3 each

Butter oil, 8 tanks of 22 m3 each, of which 4 are currently in use.

Nitric acid :Ii5%), d1.5 n

Stainless steel tanks. No bunding.

Stainless steel tanks in a concrete bund which offers some spill protection. Several pipes pass through the wall of the bund, so it cannot be considered to provide containment for the tanks' contents.

Tank located in small stainless steel bund which offers some spill protection. This bund Is not tested for Integrity.

1. Process drains in this area have been shown to require repairs.

2. A major loss of material from a lank could ultimately enter the process effluent drainage system.

I

1. Groundwater.

2. Site WWTP

High

Low

Negligible

Negligible

Near Zero

Near Zero

Page 21 &:MafrEts\lPI 11 2'22 ENVIRMJtAENTAL@Ol ENVIRONhlENTAL\lO1I12-22.FiPQMll m~Adoc

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EPA Export 25-07-2013:20:37:05

Kerry Ingredients (Ireland) Lld. Environmental Risk Assessment

101112-22-RP-0001 Issue A 261h July 2005

Catchment Area: 1.2, continued.

Butter Factory, including fat oil tanks, continued

Caustic (2.5%), 11.5 m3

Peracetic acid, 25L drums

-

1

2

No bunding around tank.

In chemical storage unit with integral steinless steel bund of capacity 2.56m3. The storage unit is on concrete, with drains leading to the WWTP.

1. Process drains in this area have been shown to require repairs. '

2. A major loss of material from a tank could ultimately enter the process effluent drainage system.

1. Groundwater. 1 High Negligible

Negligible

.

Near Zero

Near Zero

. .... .. . . . -.. -.-._ , b. . . .. I . . , . ..

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. . . . ........ . . . . . . . . . . . . . . . . . . . . . - ..... _ _ . . . 8 . ......

101 112-22-RP-0001 Issue A 26th July 2005

Kerry Ingredients (Ireland) Ltd. 8 @ Environmental Risk Assessment

Catchment Area: 1.2, continued

Butter Factory, including fat oil tanks, continued

Caustic, I m3 I of solution in IBC plus 4 pallets of solid

Cleaning 2 agents, 3 m3

Hydrogen 1 peroxide, 1 m3

Sodfum 2 hypochlorite solution, I m3

Maintenance 2 Jils

In chemical storage unit with integral stainless steel bund of ca acit 1.575 rn .The storage unit is on concrete, with drains leading to the W P .

F Y

Stored in IBC's on concrete, with drains leading to the W P .

IBC held on individual plastic bund. Located on concrete, with drains leading to the WVVTP.

Mild steel bund, capacity 0.653 m .

I. Process drains in this area have been shown to require repairs.

2. A major loss of material from a tank could ultimately enter the process effluent drainage system.

3

I. Groundwater. Medium I

2. S i t e w P I Low

.' .

Negligible

Negligible

.

Near Zero

Near Zero

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101 11 2-22-RP-0001 Issue A 26th July 2005

. . Page 24 ....... .............. a" ... . . SV~ads\lnll12i!22 ENVIAONNENTALVKII ENVI~TAL\l01112-2Z.RPMIOl mA.b

'7 ___^". -----

, . . I

--..-I- I . . . . . . . . . . . . . . . . . .

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2 ___. .~ ~ _ _ _ _ _ _ _ - ~ ~-

. . . . . . . . . . ................... ... .......... . . . . . .

. . . . .

101 I 12-22-RP-0001 Issue A 26Lh July 2005

Kerry Ingredients (Ireland) Ltd. 8 Environmental Risk Assessment

Catchment Area: 1.3

3

Page 25 SV~\lOlll2'22 WVIAONMWTfLWI ENVIRONMENTAL\l01112+2~RP+3Ul IWA&

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101 112-22-RP-0001 Issue A Kerry Ingredients (Ireland) Ltd. Environmental Risk Assessment 26th July 2005


1 Raw Twoianks of Materials 45m each

that may contain either malt, whey concentrate or butter oil

Glucose, 50 m3

lead to the I Mild I Low tanks on a concrete process effluent 2. LOSS to plinth. No local system. ground from

faulty drains bunding. NOTE: in the

Low

case of the incident on 14’h March 2005, the ’

process drain was blocked and whey concentrate entered the surface water system here. (See also Catchment 4.)

i

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EPA Export 25-07-2013:20:37:05

101 112-22-RP-0001 Issue A 26Lh July 2005

Kerry Ingredients (Ireland) Ltd, Environmenlal Risk Assessment

Catchment Area: 1.5

Niro 3 Store

Niro 3

Ntro 2/3 CIP Centre

None I - None 1 -- Bulk Caustic (15%); 60.0 m3

1

-

Stainless steel tank in concrete bund of capacity 79.72 m3. Bund was tested in December 2002 and found to be in good condition.

The drains in this area lead to the process effluent system. They are due to be replaced in 2005 as part of a %year plan. There are no surface water $aim in the area.

..

1. Site VWTP

2. Loss to ground through leakage from old pipework.

Low

Low

Negligible Near Zero

Mild I Low

" .

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EPA Export 25-07-2013:20:37:05

101 11 2-22-RP-0001 Issue A 26th July 2005


<Catchment Area: 1.5, continued

Niro 2/3 CIP Centre, continued

Bulk Nitric 2 Stainless steel Acid or Dims tank in 222 (55% or concrete bund 100%); 18.5 of capacity m3 43.45 m3,

Bund was tested In December 2002 and found to be satisfactory.

Caustic soda 1 Stainless steel plus ComplexB tanks. Some V813, 28.0 rn spill

containment Nitric Acid or 2 offered by low Divos 222 stainless steel (0.5-1.5%), 9 bund, not m3 tested for

Caustic (5%), I 2.3 m3

integrity.

Nitric Acid or 2

6%), 8.2 m Divas 222 $5-

The drains in this area lead to the process effluent system. They are due to be replaced in 2005 as part of a 5-year plan. There are no surface water ’

drains in the area.

I. Site WWTP


Low

Low

Negligible

Mild

” c

Near Zero

Low

.._. ... 1 -.. . .--. --. __ __ --.. ~

----- ....., ..._. . . . . . ...

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-- I ..._. - 1.1 ,... . ~. .~ .. . , . . . . . . .. . ~. . ,

I01 11 2-22-RP-0001 Issue A 26th July 2005

Kerry Ingredients (Ireknd) Lld. @ Environmental Risk Assessment

Catchment Area: 1.6

Niro 2 None '? - .. '. , Zero -

S ~ \ l O l l l 2 ' 2 2 USJIADNMENTALVIO! ENVIRONMENTAL\lOI112-22-RPOWI rwAdDc Page 29

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elwapoyy

dlMM al!S ' 1

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.... -.- ~ _.._ ...... . . ..... . ., -.

. . 3 .

I O 1 I1 2-22-RP-0001 Issue A 26th July 2005

@ R

Kerry Ingredients (Ireland) Ud. 6 Environmental Risk Assessment


purple

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EPA Export 25-07-2013:20:37:05


101 112-22-RP-0001 Issue A 26th July 2005

Vegetable oil; tanks in a 40 m3 small concrete

bund. This FatTank5: ? drains to a Vegetable oil; sump of 80 m3 cagacity 3.36

FatTank6: 1 material can Vegetable oil; be pumped

FatTank8: 1 Vegetable oil; 20 m3

FatTank7: 1 Stainless steel Vegetable oil; tank, no 82 m3 containment.

m , from which

65 m3 out.

lead to process effluent system.

'?

Mild I Low

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EPA Export 25-07-2013:20:37:05

101 112-22-RP-0001 Issue A 26Lh July 2005

Kerry Ingredients (Ireland) Ltd, Environmental Risk Assessment

Catchment Area: 1.9

Niro 1

Bagging Line I

Chemical storage area

None

None

Caustic, 4 x

plus solid material

Hydrogen peroxide, 25L drums

Vitric acid, 25L drums

1

1

.. .

In chemical storage unit with integral steel bund with polyurethane coating. Capacity 1.25m . In chemical storage unit with integral stainless steel bund of capacity 2.5m3.

1. Process drains in this area have been shown to require repairs.

2. A major loss of material from a tank couid ultimately enter the process effluent drainage *

sys tem.

I . Groundwater.

2. Site WWTP

Medium

Low

Negligible

Negligible

Zero, I

Near Zero

Near Zero

Zero I

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EPA Export 25-07-2013:20:37:05

Kerry Ingredients (Ireland) Ltd. 101 112-22-RP-0001 Issue A

26th July 2005 Environmental Risk Assessment

;hemica1 torage area, Lontinued

'otasslurn I iydrogen :arbonate, ;olid, 12 x 25 Kg bags

Distal No. I 1 degreaser, solid, I pallet

Cipton Plus, 3 1 x lrn3 IBC's

Comple3VB 1 1 3 , l rn

peroxide, 25L drums

Hydrogen 1

iunding. IBC in this area could potentially enter the surface water drain at the eastern corner of

On a pallet. No the Mixer I bunding. Building (next to

the safety shower). This

In IBC's, no enters the bunding. process drainage

system. In an IBC, no bunding. 2. Process drains

in this area have In 25L drums, been shown to no bunding. require repairs.

2. Groundwater

I I

.

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EPA Export 25-07-2013:20:37:05

101 1 12-22-RP-0001 Issue A 26th July 2005

Kerry Ingredients (Ireland) Lid. Environmental Risk Assessment

Catchment Area: 1.10

” .

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EPA Export 25-07-2013:20:37:05

Kerry Ingredients (Ireland) Ltd. Environmental Rlsk Assessment

101 11 2-22-RP-0001 Issue A 26Lh July 2005

Catchment Area: I .I I

skimmed Milk ;ilos

CHP Plant

Projects First Aid

skimmed 1 No Milk; 1 tank of containment :8m3, 2 tanks 3f 90m3, 3 tanks of I80 m3 each

Turbine Oil 2

Waste Oil 2

Polyethylene storage unit, 0.25 m3.

Polyethylene storage unit, 0.25 m3.

The process effluent drains In this area have been shown to be in need of repair and are due to be replaced as part of a 5-year plan.

I. Site WWTP


Medium

Medium

1 _ _ _ ~

There are no I 1. Site WWTP 1 High surface water drains in this area, so any leak would lead to the process effluent drain. The drains in this area are due to be replaced as part of a 5-year plan.


High

qegligible

Negligible

Negligible

Negligible

'7 ,

Near Zero

Near Zero

Near Zero

Near Zero

Zero

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.

L

c

GOO?! Alnr W9Z y ............... ... ..... ..................... .......... ........ . . . ...

. . . .

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I

Keny Ingredients (Ireland) Lid. Environmental Risk Assessment

lot 112-22-RP-0001 Issue A 261h July 2005

Catchment Area: 1 .I2

Salt saturator, Sodium 1 Tank situated Drains lead to Softwater chloride . on concrete process effluent. Plant solution, 25 plinth.

m3

I - I I I

Site WWTP High Negligible

I - I -

" .

Near Zero

Zero

..... Page38 . . . @II__ .. -___ ___..I .... . .... . . . . . . . . ___ __.-__,_ ...

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EPA Export 25-07-2013:20:37:05

~ .~ -~

.. . . . . . . . . . . . . ......... ....... ..................... . . . . . . . . . . > .

101 112-22-RP-0001 issue A 26th July 2005

Kerry Ingredients (Ireland) Ltd. e) Environmental Risk Assessment

Catchment Area: 1 .I 3

Cheestrings Caustic-based cleaners, 3 x im3 IBCS

. . . . . . . . .

1 IBC's are located in a chemical storage unit with integral stainless steel bunding.

The local drains lead to the process effluent system. 3

Site M P Medlum Negligible Near Zero

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EPA Export 25-07-2013:20:37:05

7

101 11 2-22-RP-0001 Issue A Kerry Ingredients (Ireland) Ltd. Environmental Risk Assessment

26th July 2005

Catchment Area: 1.14

Process Cheese

Lactol (Caustic Soda); 22.06 m3

Bund of capacity 25.52 rn .Thiswas tested in December 2002 and was found to be in good condition.

area enter the Council's town sewer. Charlevllle

, WWTP

............. . _"...-- . .̂ .. _.-_- .. .... ~ L. ' i. .' ...... ............. _ . . . . ... .

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EPA Export 25-07-2013:20:37:05

Kerry Ingredients (Ireland) Ltd. Environrnenlal Risk Assessment

. ... ..- "

.. .

Q 101112-22-RP-0001 Issue A 26th JUlV 2005

Catchment Area: I .I5

Niro I CIP Bulk Caustic (15%); 60.0 m3

.._

I ..

Stalnless steel tank in a reinforced concrete bund of capacity 69.65 m3, Bund was tested in December 2002 and found to be satisfactory.

The local drains lead to the process effluent system.

1. Site WWTP

2. Loss to ground from faulty drains

. _ .

Low

Low

Negligible

Mild

Near Zero

Low

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EPA Export 25-07-2013:20:37:06

101 112-22-RP-0001 Issue A Kerry Ingredients (Ireland) Ltd. Environmental Risk Assessment

26th July 2005


I Niro I CIP Bulk Nitric Acid (5$%), 18.5 rn .

Stainless steel tank in a reinforced concrete bund with stainless steel lining, of cayacity 25.14 rn . Bund was tested in January 2004 and the bund floor was found to be satisfactory.

The local drains lead to the process effluent system.

1. Site WWTP

2. Loss to ground from faulty drains

Low

Low

Negligible Near Zero

Mild Low

_. Page 42 ..... . . . . . . . . . -.- . . .. ......

__I ....... .. - .' - ---- _,. ...... .__ . . . . . . . .

, *

% W ~ ~ \ l O l l l ~ ENVlRONMENTALWll ENVIRMJMENTAL\lO1112-22~RPM)(Il WAda

... . . . . . . . . . .

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EPA Export 25-07-2013:20:37:06

- __ -- I

-. _ _ -- __ -- . . __ . -- . --.- - .- -.

‘1 ~

101 112-22-RP-OODI Issue A 26th July 2005

Kerry Ingredients (Ireland) Ltd, (D @ Environmental Risk Assessment


Niro Area

CIP Cipton Plusa (2%); 7.8 rn .

Cipton Plus (0.5%), 7.8 m . 3

Nitric acid

7.8 m3. (3.0-4.0%);

Caustic soda plus CompJex

1.3%); 16.0 rn.

VB13 (t.0-

3

Fat Room flash (4-5% zaustic), 7.8 m . 3

Stainless steel tanks surrounded by a stainless steel channel that leads back to the process drain.

Process drains lead back to the site WWTP.

4

I. Site WWTP Medium I 2. Loss to ground from faulty drains Low

Negligible

Mild

. .. . . . . ..

Near Zero

Low

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EPA Export 25-07-2013:20:37:06

Kerry Ingredients (Ireland) Ud. 101 112-22-RP-0001 ISSUB A 261h July 2005

Environmental Risk Assessment

Catchment Area: 2.

Outfall: To the Millrace at SWEP2.

Impermeable area: 6500 m2. Roofed area: 3748m'.

Neighbridge I Milk, 1600m3 and yard east and south of Milk Intake area

Drains northwest and north of Butter Factory

None

6 tanks, no loca? containment. the Millrace.

Small spillages of milk are a common occurrence during unloading, and these sometimes escape the Intake building and end up in the surface water system.

-

High*

' refer to Section 6.3.2 of EPA Guidance Note

Zero

Page 44 S.\P@XIS\~O~ 11W ENVIRWSdENTALYIOl U.MAONMENTAL\l01112-2Z*W~l rcvllda . __ . - ... .............. .

.- .......... --- ai! . . . . . . . . . . . . . . . . . . . .- . . . I_.- ----..'- ; I^ .-- .- . ........ . . . . . .

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EPA Export 25-07-2013:20:37:06

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EPA Export 25-07-2013:20:37:06

101 112-22-RP-0001 Issue A 261h July 2005 Kerry lngredienls (Ireland) Ltd.


Catchment Area: 4. - Outfall: To the Millrace at SWEP4.

Impermeable area: 91 00m2 Roofed area: 6265~1'.

Yard west of Butter factory

Powder carpark

Nlro 2 Store, Malt milk, Butter Store

Raw Materials

done 1 ~

rlone

Vone

Two tanks of 45m3 each that may contain either malt, whey concentrate or butter oil

Gkcose, 50 m

1

- 1

-

I

Stainless steel tanks on a concrete plinth. No local bundlng.

-oca1 drains ead to the process effluent system. In the case of the incident on 14" March 2005, the process drain was blocked and whey concentrate entered the surface water system here.

The Millrace

, .

Medium

. .

. , Moderate

. .

Zero

~

Iero

Cero

ilgh

:risk is Dased on the high BOD of the stored materials)

Page 46 ..............

~ .- S;\p~o&lDI 112E2 MVIRONh(aJTALYIO1 ENVIR(INMMTAL\IOI 112-22.RP.0001 I 0 V A . h

..... ................... .-- -1.. e, _" , ---- ; ' -..-. j - ' ...... ........ . . .

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EPA Export 25-07-2013:20:37:06

Kerry Ingredients (Ireland) Ltd.

Catchment Area: 5.

Outfall: To the Millrace at SWEP5. Impermeable area: Nil

Roofed area: 5349rn’.

Niro 3 and 4 stores buildings

c

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EPA Export 25-07-2013:20:37:06

Kerry lngredlenls (Ireland} Lfd. Environmental Risk Assessment

101 112-22-RP-0001 Issue A 28th July 2005

Catchment Area: 6.

Outfall: To the Millrace at SWEPG. lrnaenneable area: NI1 (grassed) Roofed area: 3765m'.

Roof run-off None from Niro 1 store and Bagging line 2.

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EPA Export 25-07-2013:20:37:06

- ---

Kerry Ingredients (Ireland) Ltd. 6 Environmental Risk Assessment

Catchment Area: 7.

Outfall: To the Millrace at SWEP7. IrnDerrneable area: Nil

Roofed area: 2880m2.

Roof run-off None from diesel generator room.

....... -... ......., " . I .

101 11 2-22-RP-0001 Issue A 26th July 2005

Page 49 '1' ,

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EPA Export 25-07-2013:20:37:06

<:

. . . . .. .

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EPA Export 25-07-2013:20:37:06

" . ._ - - ~ _- _._. - _

' 101 112-22-RP-0001 Issue A 26u1 July 2005


Catchment Area: 9. Outfall: To the Millrace at SWEPS.

lmaermeable area: Nil

Roofed area: Nil.

Water tank None - - - Zero overflow.

A

" .

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EPA Export 25-07-2013:20:37:06

.r '


101 1 12-22-RP-0001 Issue A 26th July 2005

Catchment Area: 10.

Outfall: To the Millrace at SWEPIO. Impermeable area: 1 060m2

Roofed area: 7740m'.

Roof run-off from Cheestrings and Brunchetta.

Roof run-off from Projects Office, - Packaging Stores, Maintenance and Garage.

None

None ..

. .. ... . .. .. - .-. . ... ... , ...

, J I . . . , . a I - .- - . ~

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EPA Export 25-07-2013:20:37:06

. . . - - . -__

@ 101 112-22-RP-0001 Issue A Kerry Ingredients (Ireland) Ltd. @

26th July 2005 Environmental Risk Assessment

Catchment Area: 11.

Outfall: To the Millrace at SWEPI I. ImPermeable area: 300m2

Roofed area: 276411-1~.

B

Roof and yard None run-off from Process Cheese and Cold Stores.

I - I - ?I - I -

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EPA Export 25-07-2013:20:37:06

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EPA Export 25-07-2013:20:37:06

- _I _ _ - . . " - _ -_ - - -

101 112-22-RP-0001 issue A 2nd June 2005

Kerry Ingredients (Ireland) Lid. 8 e Environmental Risk Assessment

Catchment Area: 13.

Outfall: To the Millrace at SWEPI 3.

Impermeable area: Nil Roofed area: 957~1'.

Overflow from None .. - Zero water tank

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EPA Export 25-07-2013:20:37:06


101 112-22-RP-0001 Issue A 2d June 2005

Catchment Area: 14. Outfall: To the Millrace at SWEPl4. Impermeable area: 1469111' Roofed area: Nil

- Page 56

.............. . ---- ,6_. ....

....... ....... -. . . . . _. L... . . . I .

8iP\pmlPtMlOl IlW WVIRONMENTALWI ENVIRONhENTAUlO1112~P~RPODO1 r ~ A d a -_._ _.....- .-.- .̂

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EPA Export 25-07-2013:20:37:06

Keny Ingredients (Ireland) Lld. Environmental Risk Assessment

Marketing Offices

Q 101 112-22-RP-0001 Issue A 2d June 2005

Catchment Area: 15. Outfall: To the Glen River.

Impermeable area: Nil

Roofed area: Nil

Zero

Page 57

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EPA Export 25-07-2013:20:37:06

J

Kerry Ingredients (Ireland) Ltd, Environmental Risk Assessment

101 11 2-22-RP.0001 Issue A 2d June 2005

Catchment Area: 16.

Outfall: To the Glen River. Impermeable area: 3325m3

Roofed area: Nil

Run-off from Diesel re- fuelling area and main entrance

Diesel, 36 m3 Surface water The Glen River drains

Medium I Moderate I Medium The diesel pump is positioned next to a drain to collect any spills. These pass through a diesel interceptor. There is no containment for the contents of a road tanker in this area.

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EPA Export 25-07-2013:20:37:06

. . . . . . . . . . . .... .. . . . . . ...... - .x

. . . . . .

101 11 2-22-RP-0001 Issue A 2" June 2005 Kerry lngredienk (Ireland) Lid. CI Environmental Risk Assessment

Catchment Area: 17. Outfall: To the Local Authority sewer at ASW3 (LASI). ImDerrneable area: 385111' Roofed area: 584m'.

?

Run-off from Farm Services compound.

3

Page 5B S.1pmlPds\101112'22 ENIIIRONMEMALU)[Il ENVIRONMENTAL\101112~2?~FIP9wI WAC&

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EPA Export 25-07-2013:20:37:06

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EPA Export 25-07-2013:20:37:06

- ._ "-. - - __" - -. - -. - -.-

I01 112-22-RP-0001 Issue A 2nd June 2005

Kerry lngredlents (Ireland) Ltd. -Q 8 Environmental Risk Assessment

Catchment Area: 19. Outfall: To the Local Authority sewer at LAS3. Impermeable area: 795511-1'

Roofed area: 2730~1'.

Roof run-off from Intervention Stores and Shipping Offices.

None. 3

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EPA Export 25-07-2013:20:37:06

101 11 2-22-RP-0001 Issue A 2d June 2005

Keny Ingredients (Ireland) Ltd. Environmental Risk Assessment

Catchment Area: 20.

Outfall: To the Local Authority sewer (unlabelled outfall).

Roofed area: 650rn'.

'I

' ImpermeabIe area: 2270rn2

Gasoil, 2 Doubleskinned Surface Water 5,OOOL tank drain, then Local

Authority sewer

Gasoil, 2.75 2 Double-skinned Surface Water rn3. tank drain, then Local

Authority sewer

I " l - I Zero I C ha rleville Low Mild Low Municipal WWTP

Charleville . Low Mild Low Municipal - WWTP

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EPA Export 25-07-2013:20:37:06

1

-- - - __ - - . . - ._ -.-- -

101112-22-RP-0001 Issue A 2nd June 2005

Q Keny Ingredients (Ireland) Ltd. Environmental Risk Assessment

Catchment Area: 21.

Outfall: To the Local Authority sewer at SREPS. Impermeable area: Nil Roofed area: Nil.

I I I I I I I 1

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EPA Export 25-07-2013:20:37:06

Kerry Ingredients (Ireland) Ltd. Environmental Rlsk Assessment

101 112-22-RP-0001 Issue A 2M June 2005

Catchment Area: 22.

Outfall: To the Local Authority sewer at SREPG. Impermeable area: Nil Roofed area: Nil.

from Medical Centre. I I I I I

- Page 64 SZ~~cls\lOll I~ENVWONMENTAlWl WVRONhfENTW10i112.22-RPOWII mvAdoc "- _,C.-._._. .-c --- -- . .

, ;, - , _' .._...-.._ I ' .. I - --.- ----- .... . ... -.

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EPA Export 25-07-2013:20:37:06

. _ - - . - ~~~~

__

.-- - - ,. - - - -"I- --

~ ~~

101 112-22-RP-0001 Issue A Pd June 2005 .' .

-@ @

Kerry Ingredients (Ireland) Ltd. -


Catchment Area: 23. Outfall: To the Local Authority sewer at SREPI. External Paved area: I 950m2

Run-off from Farm Services compound.

Typical agricultural supplies, e.g. silage additives, fertilisers.

2 I None Drains enter the Local Authority sewer.

Charleville Municipal WWTP.

High Negligible Near Zero

Page 65 W m ~ a s \ l O l l lEE2 ENvlRONMEtdTALVJDl ENVIRONh~AL\10111Z-22.RP.M)[ll r ~ A d o f

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EPA Export 25-07-2013:20:37:06

I


101 1 12-22-RP-0001 Issue A 2"" June 2005

Catchment Area: 24.

- Outfall: To the Local Authority sewer (SW21).

Roofed area: Nil

External paved area: 161 4rn2

.. __.. , . .............. Page 66 .. ...

_I . . . .. .... ,., . . ____ ~

-. ".. . , , . , ., . , .. .. - ..A .... .. .... .

S~m]ec!AlOll12\p ENVIRONhlEEol pMRONMUJTAL\lOIllZ-Z.W~t rcvAdoe

-- -.- ....... -

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EPA Export 25-07-2013:20:37:06

..... ... . . . . . . . . ....... ........... ._ .. . . . . . . . . . ............. . . . . . . .

101 I 12-22-RP-0001 Issue A 2M June 2005

Kerry Ingredients (Ireland) Lld. 8 Environmental Risk Assessment

Catchment Area: 25.

Outfall: None. External paved area: Nil (graveled).

Maintenance Waste oil, compound 2.75 m3

Cooling tower and condenser chemicals I Waste oils

This is a I Groundwater. I Low 1 Moderate I Low permeable

2 Double-

skinned tank gravelled area.

storage unit, 0.59 m3

2 Mild steel

2 Mild steel . storage unit, 0.49 m3

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EPA Export 25-07-2013:20:37:06


101 11 2-22-RP-0001 Issue A 2nd June 2005

Catchment Area: 26

- Outfall: None. External paved area: Nil (graveled).

Gasoil; 2.5m3 2 Double- This is a Groundwater. Low Moderate Low Main Generator permeable supply shinned tank gravelled area.

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EPA Export 25-07-2013:20:37:06

. . . . . . . ............... .... __ ---_ ~ ... . . . . -. _ I . I .

, .

Kerry Ingredients (Ireland) Ltd. e 101112-22-RP-0001 Issue A Environmental Risk Assessment 2nd June 2005

Catchment Area: 27.

OuffalI: None. Impermeable area: Nil

Roofed area: Nil

Genera tor at main gate

Diesel lank by main site entrance

Gasoil, 1.25 m .

Road diesel, 466 m3

3

2

Double-skinned tank

Reinforced concrete bund with dlesel- resistant waterproof membrane, 512.60 m3. Tested in 2004 and found to be adequate.

?

4

. . . .

This area is '

gravelled and material lost would enter the ground. :

Groundwater

1

. .

Low I Low Moderate

'7 .

3 -

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EPA Export 25-07-2013:20:37:06

Kerry Ingredients (Ireland) Ud. Environmental Risk Assessment * 2nd June 2005 101 112-22-RP-0001 Issue A

m3. Bund was

the bund will pass . December 2002 and through the gravel found to be floor and enter the

tested in Spills outside of

Catchment Area: 28

- Outfall: None. External paved area: Nil (graveled).

Roofed area: Nil.

,-

I Plant

Sulphuric acid/

Ferric Sulphate/

"Enviropc", 23.46m

I I capacity 17.78 I system. I

- 1 Reinforced

concrete bund with acid resistant lining, of capacity 29.16 m3. Bund was tested in December 2002 and found to be satisfactory. I

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EPA Export 25-07-2013:20:37:06

c

3

Pl!M 1

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EPA Export 25-07-2013:20:37:06

101 112-22-RP-0001 ISSUB A 2nd June 2005 Keny Ingredients (Ireland) Ltd.

Environmental Rlsk Assessment

Catchment Area: 29

- Outfall: The Glen River.

External paved area: 900m2.

Roofed area: Nil.

South of Skimmed Milk Intake, near former entrance to site

Skimmed I Milk; 3 ta;ks of 272 m each

. stainless steel tanks are situated on a tiled plinth. There is no bunding but there is a .

small surrounding channel to collect spills.

catastrophic tank failure, skimmed milk would probably enter this drain and thereby enter the Glen River.

... Page 72

.- -. __ -- ,.. I .

I . .., S3Pm~aS\lOi112W2 ENVIRONMENTAL\Wt ENVIRDNMENTAL\iOI 112.22-RPM)OI rsvAdDc ___ --.-I

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EPA Export 25-07-2013:20:37:06

yoea .U ZLZ 40

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EPA Export 25-07-2013:20:37:07


101 11 2-22-RP-0001 Issue A 2"d June 2005

Catchment Area: 31

Outfall: The Glen River.

External Daved area: 200m'.

Roofed area: Nil.

South of Skimmed Milk Intake, near former entrance to site

Skimmed Milk; 3 t a p of 272 m each

1

-

These stainless steel tanks are situated on a tiled plinth. There is no bundfng but there is a small surrounding channel to collect spills.

In the event of a catastrophic tank failure, skimmed milk would probably enter this drain and thereby enter the Glen River.

The Glen River I LOW Moderate I Medium

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EPA Export 25-07-2013:20:37:07

Kerry Ingredients (Ireland) Lld,

Foul effluent from Projects off ice

8

- - - - - Zero

101 11 2-22-RP-0001 Issue A Znd June 2005 Environmental Risk Assessment

Catchment Area: 32 Outfall: Local authority sewer. External paved area: Nil.

Roofed area: Nil.

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I

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i I I

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EPA Export 25-07-2013:20:37:07

Kerry Ingredients (Ireland) Ltd. 101 11 2-22-RP-0001 Issue A Environmental Risk Assessment 26th July 2005

FOUL & STORMWATER DRAINAGE OVERALL SITE PLAN

DRG. No. 3000-00-GA-005

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EPA Export 25-07-2013:20:37:07

e rn g rn

5 W 0

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\

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EPA Export 25-07-2013:20:37:07

Drain Testing and Repair Programme

Section Repairs Status Processed Cheese Complete

-

In 2003 it was agreed by the Agency that a five year drain upgrade plan would be undertaken and that drain testing would take place after drains were repaired instead of at the three year frequency required under Condition 10.

Test Due Date 2007

The order in which the repairs have taken place has varied from original plan due to changes on the site e.g. All of the Cheestrings and Processed Cheese drains were upgraded in 2003/2004 as part of the Cheestrings expansion.

Cheestrings Niro 1 Niro 3 StdresBatching

Extensive work was carried out in 2005/2006 to eliminate high risk areas as highlighted in the Risk Assessment on the Storage and Transfer of Materials that was not planned for in the original scope of work and this has extended the programme slightly.

Complete 2007 Complete 2008 Scheduled 2007 2007 Complete/Minor Repairs 2009

Milk Intake Separation Effluent Plant

Scheduled 2009 Complete 2007 Scheduled 2008 2008 Complete 2008

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EPA Export 25-07-2013:20:37:07

TMS Consultancy Ltd. 5 Pery Square,

Limerick

Annual Review of

Environmental Liabilities

Risk Assessment

For

Kerry C harleville

March 2006

Finbarr Stapleton TMS # 06059

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EPA Export 25-07-2013:20:37:07

1.0 Introduction

TMS Consultancy Ltd. was requested by Kerry Ingredients,

Charleville, to undertake an annual review of the Environmental

Liabilities of its operations as identified in the Environmental

Liabilities Risk Assessment Report (Report No. GV006000 1 A,

November 2000 as well as updated Report No. 0123 1 of 2001,

Report No. 02122, Report No. 03238 and Report No. 05064).

This review was carried out in accordance with the requirements of

Condition 14.2 of the company’s IPC Licence (Reg. No. 386).

The review was performed on the 06/03/06 by Finbarr Stapleton of

TMS Consultancy Ltd. The review involved a site inspection and

examination of the site records.

The review was facilitated by Teresa Fitzgerald, the Environmental

Officer for Kerry Ingredients, Charleville who provided

information and records and was present during the site inspection.

2.0 Brief Site Description

Activities on the 8 1 -acre Kerry Charleville site (formerly Golden

Vale Food Products Ltd.) at Rathgoggin Middle, Co. Cork

commenced in 1948. The company manufacturers a wide range of

dairy-based products.

TMS # 06059 Rev 0 Page 2 of 11

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Production activities include the following:

0 Milk intake

0 Separation/butter/yellow fat spreads

0 Milk powders

Cheese

Supporting activities such as, site services, administration, canteen,

laboratories, etc. are also present on-site.

Q A number of changes to the plant have occurred during 2005 and

2006 to date as follows:

0 The company has burned Tallow oil during the winter as

Tallow oil is carbon neutral. This operation is carried out in

accordance with Dept. Of Agriculture and EPA

requirements. The Tallow is supplied by Munster Proteins.

0 This allows the company save on the burning of natural gas.

0 A bulk gas tank @Om3) has been installed for storage of gas

on-site. This is below the Seveso Regulations threshold.

0 New regulations have come into force in Jan '06 in relation

to burning of Tallow which will have implications in terms

of licensing of this activity.

0 The company is considering the possibility of ceasing

operations in the Butter factory during 2006. This will

possibly lead to more cream being dispatched fi-om the plant

and therefore more loadinghnloading of bulk tankers at the

site.

TMS # 06059 Rev 0 Page 3 of 1 I

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EPA Export 25-07-2013:20:37:07

3.0 Summary of Findings

3.1 Raw Materials and Management

3.1.1 As indicated in previous reports the main raw materials stored on-

site include the following:

0 Raw and processed milk

Food additives

0 Cleaning chemicals including detergents

0 Fuels

3.1.2 Storage of materials such as food additives is adequate and as

indicated in the 2003 and 2005 reports, significant improvements

have been made in the storage of these materials.

3.1.3 As indicted in previous reviews storage facilities for caustic and

acids have been significantly improved since the Risk Assessment

carried out in November 2000.

3.1.4 All bunds have been integrity tested in accordance with BS8007: 1987 and all have passed. It was again noted during the site

inspection as part of this review that some of the nitric acid

pipeline is still outside the bunded area.

3.1.5 There were no difficulties with the diesel oil bund and as

previously indicated this bund is no longer a cause for concern.

There is no evidence of leakage and the bund has passed integrity

testing.


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3.1.6 Effective control measures for the diesel bund remain in place

including the following:

0 Visual inspections of the bund are carried out on a regular

basis.

0 The oil tank must not be filled to capacity.

0 An allowance must be made for a depth of lOOmm of water

to be left in the bund at all times

3.1.7 There was still evidence of small-scale oil spillage/leakage at the

road diesel delivery pumphouse. However, this area is within the

confines of the diesel interceptor to ensure that oil is not discharged 6

to surface waters.

3.1.8 Plans are in place to ensure that the delivery pipeline from the

pump house to the tank is placed above ground. This project is due

to be commenced before the end of April 2006.

3.1.9 Waste oil tanks in the vicinity of the transport garage are still in

place and the company should consider decommissioning these

tanks.

3.2 Emissions to Atmosphere

The main emission from the plant includes particulate emissions

from the dryers and combustion gases from boilers, CHP plant,

burners and generators.

Odours:

One odour complaint was received in relation to land spreading

of sludge on 01/04/05. Action was taken to address this issue

including retraining of the land spreading contractor personnel

(i.e. Agri-Life).


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. -

e

e

e

0

e

Particulate Emissions from Dryers:

Particulate emissions during 2005 have been in compliance

with the limits outlined in Schedule l(i) of the IPC Licence

(Reg. No. 386).

Combustion Gas Emissions from Boilers:

Emissions from the CHP Plant in 2005 were within the IPC

Licence Limits. The CHP operates under a Greenhouse Gas

Permit.

NOx emissions from the boiler were within the IPC licence

limits during 2005 and 2006 to date.

The Administration block central heating system uses gas oil.

As indicated in the 2003 and subsequent reviews computer

modelling of emissions indicates that emissions will comply

with the proposed ambient air quality limits, which come into

force in 20 10.

The back up generator is no longer used.

3.3 Emissions to Surface Waters

An incident involving a spillage of approximately 10,000 Kgs of

Whey Concentrate from a tank occurred in March 2005. Some of

the spillage went to the effluent treatment plant but some was

discharged to the surface water drains due to a blocked drain. No

obvious contamination of the River occurred but some

contamination of the Charleville Stream was apparent. Effective

action was taken to mitigate any adverse effects. This was reported

to the EPA highlighting the actions taken.

TMS #'06059 Rev 0 Page 6 of 11

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0 A detailed risk assessment on storage and transfer of scheduled

activities was carried out by Project Management. This involved

looking at loading, unloading and bunding. Drain reinstatement

and improvements were an essential requirement of the risk

assessment. Significant modifications were made to the drainage

system near the whey tanks as a result of this risk assessment.

0 Conversion of the drains in the intake area will be completed

before the end of April 2006.

0 Bunding was not deemed to be necessary as the Whey Concentrate

tanks are remotely bunded to the effluent treatment plant.

0 Effluent discharges have been in compliance with the limits set out

in Schedule 2(i) of the IPC Licence.

A new decanter is to be installed in the effluent treatment plant and

this will produce sludge with 20% solids.

Q

3.4 Emissions to Sewers

0 Emissions to sewers were in accordance with the

requirements of Condition 7 of the IPC Licence (Reg. No.

386) during 2005 and 2006 to date.

0 As indicated in previous reviews of the risk assessments

there is no process wastewater discharged to the public

sewer. No difficulties/complaints have been received from

Cork County Council regarding sewer emissions to date.

3.5 Emissions to Ground

The potential liabilities have been significantly reduced due to

correction of containment irregularities on the site (e.g. engineering

measures to correct inadequate bunding, etc.). Groundwater


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EPA Export 25-07-2013:20:37:07

monitoring is performed on a quarterly basis. Results indicate that

there is no evidence of groundwater contamination on-site.

3.6 Noise Emissions

No noise nuisance complaints have been made to Kerry Charleville

over the last number of years.

Noise monitoring has been carried out in October 2005 in

accordance with Condition 9.2 of the IPC Licence (Reg. No. 386).

Results indicate that daytime noise at noise sensitive locations are

within the 55dBA limit specified in Condition 9.1 of the IPC

Licence.

Results of night-time noise monitoring exceeded the 45dBA limit

at a number of noise sensitive locations.

0 The company is looking at projects for reducing noise levels

but these will only provide a reduction of 0.2 dBA at the

boundary of the plant.

Pending this work noise reduction measures on other

sources will have negligible impact.

Kerry Charleville must meet IPPC requirements by

September 2007.

0

3.7 Waste Management

All wastes generated at Kerry Charleville are managed, disposed

of, recovered or recycled in accordance with Condition 8 of the

IPC Licence (Reg. No. 386).


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There have been no significant changes in waste management on-

site during 2005. Waste permits and licences for the waste disposal

contractor are maintained on file.

As outlined in the 2000 Risk Assessment and confirmed in

subsequent annual reviews, there are no major potential liabilities,

which should accrue at Kerry Charleville, as a result of

management of waste.


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EPA Export 25-07-2013:20:37:07

4.0

4.1

4.2

CONCLUSIONS

In general the potential liabilities and possible costs to the

environment are in line with those outlined in the 2000 Risk

Assessment and the updated 2001 to 2003 and 2005 reviews.

There have been significant improvements made in a number of

areas, which have resulted in reduction of potential risks as

follows:

0 Storage facilities for raw materials, chemicals and oils have

been improved and further improvements in drainage and

containment systems are planned.

0 In general, emissions to atmosphere do not pose a significant

threat. Only one odour complaints has been received during

2001 to 2006 to date. This was due to problems with land

spreading of sludge. Training has been carried out to ensure

that Agri Life the land spreading contractor follows the correct

procedures.

0 The emissions of NO, from the boiler no longer exceed the IPC

licence limits.

0 In general, emissions to surface waters have been in

compliance with the requirements of the IPC Licence (Reg. No.

386).

TMS # 06059 Rev 0 Page 10 of 11

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EPA Export 25-07-2013:20:37:07

0 Noise reduction measures have reduced potential liabilities

due to noise nuisance. However, noise levels at certain noise

sensitive locations have been exceeding IPC Licence limits.

Further noise reduction measures will only result in limited

reduction in environmental noise levels.

0 Current waste management practices are considered to be

adequate to address potential environmental liabilities.

0 Potential costs to the environment resulting from the

company’s activities on the Charleville site are likely to be

in the same region as those outlined in the 2000 risk

assessment report allowing for inflation, etc.

TMS # 06059 Rev 0 Page 11 of 11

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EPA Export 25-07-2013:20:37:07

JLT RISK SOLUTIONS Limited

3' January 2006

To Whom It May Concern

6 Crutchad Friars London ECBN 2PH Telephone 020 7528 4000 Dlract Une 020 7558 3438 Facsimfle MO 7558 3400

Dear Sirs

Confirmation of Insurance Cover Our Client: Kerry Group plc and Subsidiary Companles

We act as lnsurance Brokers to the above named Insured and confirm that the insurance summarised below has been effected for a period of 12 months commencing Ist January 200 and expiring 318' December 2006.

Q

Cover : Public and Products Liability

Limit of Indemnity : Public Liabilitv

GBP5,000,000 any one occurrence and unlimited during Period of Insurance

Products Liability

GBP5,000,000 any one occurrence and in the aggregate during Period of Insurance

Territorial Limits : Worldwide

Insurer : Royal & SunAlllance

Policy Number : YMM822919/20

These statements have been made in good faith and are a summary of the insurance cover in force as at the date of this fetter (which insurance remains subject to the full terms and conditions of subscribing insurers' policy), although the Sum Insured may have been lmpaired by incurred claims and therefore may vary from the amount shown. We accept no responsibility whatsoever for any inadvertent or negligent act, error or omission on our part in preparing these statements or for any loss, damage or expense thereby occasioned to any recipient of this letter.

Should the insurance cover be cancelled, assigned or changed in any way during the period of insurance, neither we nor the subscribing insurer@) accept any obligation to notify any recipient of this letter.

Nfl-0

Lloyd's Broker. A mambcr ol lhs Jardins Lloyd Thompson Gmup A company lncorponbd w l L llablllty llmlW by aham.

Rwlrlarnd offla: 6 Crulchsd FdW, London EC3N 2PH. Rngldered In England No. 1536540. Val No. 244 2321 BB AuU~arlaed end rsgufmnd by tho Flnanda) scnrlcas Authorl~y

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EPA Export 25-07-2013:20:37:07

3' January 2006

JLT RISK SOLUTIONS Limited

Page 2

Notwithstanding the issuance of this letter we are and remain solely the agent of our Cllent in this matter and owe no duties to any recipient of this letter.

Yours sincerely

- e Authorised Signatory JLT Risk Solutions Limited

. . .

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EPA Export 25-07-2013:20:37:07

KERRY INGREDIENTS CHARLEVILLE

I.D.No. EP33 Date: 12/12/05

Rev. 06 Page 1 o f 4 Title: Emergency Preparedness and Response

Approved By:

1 .o

2.0

3 .O

4.0

PURPOSE

To minimise the potential for emergency situations that may arise from significant

environmental aspects and outline response in the event of occurrence to minimise

effects on the environment.

SCOPE

Applies to all emergency situations relating to significant environmental aspects.

REFERENCES / ATTACHMENTS

Register of Environmental Aspects

Table 33.1 Potential Accident and Emergency Situations Relating to Significant Environmental Aspects. Business Continuity Plan EP04 Environmental Communications

EP07 Environmental IncidentIRelease Investigation and Reporting

EP08 Environmental Corrective and Preventive Action Procedure

EPl6 Boiler Maintenance

EP27 Minor Chemical Spillage

EP35 CHP Plant Operation and Maintenance

EP37 On Site Emergency Spillage Procedure

EP38 Off Site Emergency Spillage Procedure

EP39 Emergency Procedure in the Event of a Fire

EP40 Emergency Procedure in the Event of a Major Ammonia Discharge

SF41 Emergency Procedure Checklist

DEFINITIONS

None.

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EPA Export 25-07-2013:20:37:07


I.D.No. EP33 Date: 12/12/05

Rev. 06 Title: Emergency Preparedness and Response

Page: 2 of 4

5.0 RESPONSIBILITY

It is the responsibility of the Site Management to ensure this procedure is

implemented.

6.0 PROCEDURE

Potential Emergency Situations

6.1.1 Table 33.1 contains a summary of the potential accident and emergency situations . relating to the significant aspects as identified in the Register of Environmental Aspects. Table 33.1 should be reviewed following any revision of the Register of Environmental Aspects. Q 6.1.2

Emergencv Preparedness

6.2.1 Specialist emergency equipment shall be provided and maintained - this shall include: Dryer Suppression Systems Carbon Monoxide Detectors Fire Detection and Alarm Systems Fire Extinguishers Fire Engine Fire Hydrants Spill Kits Stream Diversion Facility

6.2.2 Emergency Preparedness and Response Training shall be carried out in accordance with EPl5 Environmental Training - this shall include: @ Annual Fire Evacuation Drills

Weekly Fire Crew Training Emergency Procedures Training

6.2.3 Integrity testing shall be carried out in accordance with IPC Licence requirements - this shall include:

Bund Integrity Testing Silo Integrity Testing Drain Surveys

6.2.4 shall be maintained in accordance with EP35 CHP Plant Operation and Maintenance.

Boilers shall be maintained in accordance with EP16 Boiler Maintenance and CHP

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EPA Export 25-07-2013:20:37:07


I.D.No. EP33 Date: 12/12/05

Rev. 06 Page: 3 o f 4 Title: Emergency Preparedness and Response

Emergency Response

6.3.1 In the event of an emergency, the site Business Continuity Plan should be

implemented to provide overall co-ordination of the incident. SF4 1 Emergency

Procedure Checklist to be used.

In the event of a minor chemical spillage, EP27 Minor Chemical Spillage should be

implemented.

In the event of a larger spillage on site, EP37 On Site Emergency Spillage Procedure

should be implemented.

In the event of a spillage off site, EP38 Off Site Emergency Spillage Procedure should

be implemented.

In the event of a fire, EP39 Emergency Procedure in the Event of a Fire should be

implemented.

In the event of a major ammonia discharge, EP40 Emergency Procedure in the Event

of a Major Ammonia Discharge should be implemented.

6.3.2

6.3.3

6.3.4

6.3.5

6.3.6

Emergency Follow Up

6.4.1

6.4.2

Environment and Safety Manager should contact the E.P.A. and other regulatory authorities if deemed necessary as per EP04 Environmental Communications. Senior member of staff on site at time of emergency must complete a SF05 Environmental/Incident Release Investigation Report as per EP07 Environmental IncidedRelease Investigation and Reporting. All available information must be recorded - time/cause/effects etc. of emergency. Incident report to be filed by Environment and Safety Manager.

6.4.3 A communication report should be completed by management andor Environment and Safety Manager and filed with incident report if communication with external parties was necessary. Senior manager must review the incident and initiate corrective/preventive action if necessary as per EP08 Environmental Corrective and Preventive Action Procedure.

@

6.4.4

Emergency Preparedness and Response Procedures Review

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EPA Export 25-07-2013:20:37:07


1.D.No. EP33 Date: 12/12/05

R~~ nh PaPe: 4 of 4 Title: Emergency Preparedness and Response

6.5 A review of relevant emergency preparedness and response procedures will be carried out following any emergency situation and/or on an annual basis

7.0 RECORDS

SF05 Environmental IncidedRelease Investigation Reports and any other relevant documentation are maintained on file for a minimum period of seven years.

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EPA Export 25-07-2013:20:37:07

KERRY ~NGREDIENTS CHARLEVILLE

I.D.No. EP37 Date: 17/07/04

Rev. 03

Approved By:

Title: On Site Emergency Spillage Procedure Page 1 of 2

1 .o

2.0

e 3 .O

4.0

5.0

Q 6.0

6.1

6.2

PURPOSE

To provide the procedure for quick and effective handling of an on site spillage and to

minimise the effects of such on the environment.

SCOPE

Applies to the following emergency situation:

9 On Site Spillage


EP27 Minor Chemical Spillage

EP33 Emergency Preparedness and Response Procedure

EP04 Environmental Communications

DEFINITIONS

None. .

RESPONSIBILITY


implemented.

PROCEDURE

Contact Site Security at 5 176 who should contact senior member of management on- site in area affected to implement procedure.

Contact site brigade andor emergency services if deemed necessary. For chemical spills requiring breathing apparatus/chemical suits Charleville Fire Brigade to be contacted.

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EPA Export 25-07-2013:20:37:07

KERRY INGREDIENTS CHARLEVILLE .

I.D.No. EP37 Date: 17/07/04

Rev. 03 Page: 2 of 2 Title: On Site Emergency Spillage Procedure

6.3

6.4

6.5

6.6

6.7

6.8

6.9

6.10

6.1 1

6.12

6.13

Cordon off the area. Keep people and vehicles away from the spillage.

Put on protective clothing if necessary e.g. if dealing with caustic or acid (refer to the safety statement and Material Safety Data Sheets.)

Quickly identify the source of the leak and shut it off, if possible. Ensure that the spillage is contained in bunds or directed to effluent drains (marked red) as far as possible.

In the case of spillage from a vehicle, move the vehicle to a suitable area if possible.

Absorbent material or other suitable materials should be used to block the spread of the spillage to stormwater drains (marked green) etc.

In the event of spillage reaching storm drains, the stream should be diverted to the effluent plant, provided stream flow permits. Stream can be diverted by transferring hose to main shore and switching on pump in pump house.

Site management/Site Environment and Safety ManagedSenior management should be contacted as deemed necessary. Site Environment and. Safety Manager should implement EP33 Emergency Preparedness and Response Procedure as deemed necessary. Environment and Safety Manager should contact the E.P.A. and other regulatory authorities if deemed necessary as per EP04 Environmental Communications

The effluent plant should be notified of increased load. Contact numbers at Security Hut.

In the event of a spillage affecting neighboring property, the relevant people should be informed as soon as possible.

In the event of spillage contaminating the stream, on site dewatering pumps and outside vacuum tankers to be used as quickly as possible to deal with contaminated water.

Contaminated areas should be cleaned as soon as possible in order to minimize the effect of the spillage.

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EPA Export 25-07-2013:20:37:08


I.D.No. EP38 Date: 17/07/04

Rev. 03 Page 1 o f2 Title: Off Site Emergency Spillage Procedure

Approved By:

1 .o

2.0

3 .O

4.0

5.0

e.- *

6.0

PURPOSE

To provide the procedure for quick and effective handling of an off site spillage and

to minimise the effects of such on the environment.

SCOPE

Applies to the following emergency situation:

Off Site Spillage




DEFINITIONS

None.

RESPONSIBILITY

It is the responsibility of the Transport Manager to ensure this procedure is

implemented.

PROCEDURE

Spillage may occur off site as a result of a traffic accident involving milk tankers.

6.1 Contact the Transport Manager who must ensure that no safety risk occurs and ensure that the emergency procedure is followed.

6.2 Cordon off the area. Keep people and vehicles away from the spillage.

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EPA Export 25-07-2013:20:37:08


I.D.No. EP38 Date: 17/07/04

Rev. 03 Title: Off Site Emergency Spillage Procedure

Page: 2 of 2

6.3

6.4

6.5

6.6

6.7

6.8

6.9

6.10

Quickly identi@ the source of the leak and shut it off, if possible.

Move the vehicle to a suitable area if possible.

Contact the emergency services if deemed necessary.

Contents of vehicle to be transferred to another tanker if possible.

Senior managemenvsite Environment and Safety Manager should be contacted as deemed necessary by Transport Manager. Site Environment and Safety Manager should implement EP33 Emergency Preparedness and Response as deemed necessary. Environment and Safety Manager should contact the E.P.A. and other regulatory authorities if deemed necessary as per EP04 Environmental Communications

In the event of a spillage affecting neighboring property, the relevant people should be informed as soon as possible by Transport Manager.

In the event of spillage contaminating the watercourses, other tanker/vacuum tanker to be used as quickly as possible to deal with contaminated water, access permitting.

Contaminated areas should be cleaned as soon as possible in order to minimize the effect of the spillage.

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EPA Export 25-07-2013:20:37:08

KERRYIINGREDIENTS CHARLEVILLE

1.D.No. EP39 Date: 17/07/04

Rev. 03 Page 1 o f2

Approved By:

Title: Emergency Procedure in the Event of a Fire

1 .o

2.0

Q 3 .O

4.0

5.0

6.0

e,

PURPOSE

To provide the procedure for quick and effective handling of a fire and to minimise

the effects of such on the environment.

SCOPE

Applies to the following emergency situations:

Fire


EP3 3 Emergency Preparedness and Response Procedure

EP37 On Site Emergency Spillage Procedure


DEFINITIONS

None.

RESPONSIBILITY


implemented.

PROCEDURE

On discovering a minor fire person should contact Security at 5 176'and if safe to do so extinguish fire using appropriate fire extinguisher and if necessary fire hose reels provided - electrical apparatus should be switched off first. Security should contact Fire Warden for relevant area and they should ensure that the fire is extinguished.

6.1 Contact Site Security at 5 176 who should contact senior member of management on- site in area affected to implement procedure.

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1.D.No. EP39 Date: 17/07/04

Rev. 03 Title: Emergency Procedure in the Event of a Fire

Page: 2 of 2

6.2

6.3

6.4

6.5

6.6

6.7

6.8

6.9

6.10

Contact site fire brigade and Charleville Fire Brigade, Fire Warden for relevant area and sound fire alarm. Fire alarm can be sounded by contacting Main Reception at 5325 or by break glass at Fire Engine Room.

On hearing the fire alarm all persons operating equipment should stay at their workstations (provided there is no immediate danger) until they are instructed to evacuate by the Fire Warden. All other persons should evacuate the area and go to their assembly points.

When instructed by Fire Warden, operators to shut down all electric motors and machinery if it is safe to do so and proceed to relevant assembly point.

Fire Warden must ensure that : All people in the area have been informed to evacuate and that they have done so. That prior to leaving building - all equipment is shut down and all windows, doors etc., are closed, provided it is safe to do so Check that all people are at the assembly point. Instruct people not to re-enter the building until they are informed to do so.

A nominated person should go to the security gate to direct the local fire brigade to the fire. The fire brigade should be informed of all potential dangers in the area e.g. ammonia, flammable substances, risk of explosions etc.

EP37 On Site Emergency Spillage Procedure should be applied to the firewater as far as possible.

Site management/Site Environment and Safety ManagedSenior management should be contacted as deemed necessary. Site Environment and Safety Manager should implement EP33 Emergency Preparedness and Response Procedure as deemed necessary. Environment and Safety Manager should contact the E.P.A. and other regulatory authorities if deemed necessary as per EP04 Environmental Communications.

The effluent plant should be notified of increased load. Contact numbers at Security Hut.

In the event of a fire affecting neighboring property, the relevant people should be informed as soon

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EPA Export 25-07-2013:20:37:08


I.D.No. EP40 Date: 17/07/04 Title: Emergency Procedure in the Event of a

Major Ammonia Discharge Rev. 03 Page 1 of 2

Approved By:

1 .o

2.0

3 .O

PURPOSE

To provide the procedure for quick and effective handling of a major ammonia

discharge and to minimise the effects of such on the environment.

SCOPE

Applies to the following emergency situations:

Major Ammonia Discharge




4.0 DEFINITIONS

None.

5.0 RESPONSIBILITY


implemented.

6.0 PROCEDURE

6.1 Contact Site Security at 5 176 who should contact senior member of management on- site in area affected to implement procedure.

6.2 On ascertaining that the ammonia discharge is of a significant nature initiate evacuation of the immediate area affected and contacts the electrical maintenance staff on call.

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EPA Export 25-07-2013:20:37:08


I.D.No. EP40 Date: 17/07/04 Title: Emergency Procedure in the Event of a

Major Ammonia Discharge Rev. 03 Page: 2 of 2

6.3

6.4

6.5

6.6

6.7

Only trained maintenance staff/refrigeration contractor should approach the discharge to isolate it using the breathing apparatus provided and only after ascertaining that it is safe to enter area.

Once the discharge has been isolated the on-site fire brigade and Charleville Fire Brigade should be contacted if deemed necessary. The area should be sprayed with water to control the spread of ammonia and the On Site Spillage Procedure followed.

Building should be ventilated to get rid of internal build up of ammonia.

In the event of an ammonia discharge of the magnitude that will effect neighboring houses etc. the Gardai should be informed immediately. Information on the nature of ammonia, first aid measures etc. should be provided from the Material Safety Data Sheet.

Site managemendsite Environment and Safety ManagerBenior management should be contacted as deemed necessary. Site Environment and Safety Manager should implement EP33 Emergency Preparedness and Response Procedure as deemed necessary. Environment and Safety Manager should contact the E.P.A. and other regulatory authorities if deemed necessary as per EP04 Environmental Communications

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EPA Export 25-07-2013:20:37:08


BUSINESS CONTINUITY PLAN

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Business Continuity Plan

Page: 1

Revision: 3 Signature:

Section 1 Introduction Section 2 - The Teams

2.1 Team 2.2 Activation of Team

3.1 BCP Team Contacts 3.2 3.3 Kerry Group Personnel 3.4 Key Contacts - Insurance 3.5 3.6 Emergency Services 3.7 Key Contacts - Services 3.8 Key Contacts - Personnel 3.9 Key Contacts - Customer 3.10 Key Contacts - Suppliers 3.1 1

Section 3 Key General Contacts

Non-Site Based Kerry Foods Contacts

Site Based Personnel (Departmental Managers & Deputy)

Key Contacts - Business Recovery 3.1 1.1 Cross-Sourcing 3.1 1.2 Contract Manufacture 3.1 1.3 Cleaning 3.1 1.4 Construction 3.1 1.5 Equipment Suppliers

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EPA Export 25-07-2013:20:37:08

INbEX (cont)

Page: 2

Business Continuity Plan Revision: 3

6

Date: 2 1 st June 2006

Signature :

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EPA Export 25-07-2013:20:37:08

Appendix 8 Appendix 9

Procedure for Handling Threatening Phone calls relating to Product Kerry Group plc Claims Procedure 2004

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EPA Export 25-07-2013:20:37:08

c

B

--

BUND TEST CERTIFICATE To BS 8007 : 4987 *

Client

Bund Location

Bund Number

Bund Information

Material Stored in Tankfs) ' Tank nominal volume (Largest Tank) Bund Available Containment Volume Bund volume I tank volume

. Bund volume /tank volume as percentage Bund Material Bund Condition Bund Lining

sst Details Date Bund Filled Date of Initial Reading of Water Level Date of Final Reading of Water Level Test Period Initial Water Level Final Water Level (adjusted for rain) Fall in Level Structural Distress Apparent Leaks Rain J Evaporation

Conclusions

Bund Size Structural Integrity Water level test Water leak test

comments Bund is in good CORditiOn.

Kerry tngredients C harleville, Co.Cork.

Process Cheese Services Yard.

No. 1

Lactol, (Caustic Soda) 22.06 cb.m. 25.52 cb.m. I . I6 116 percent ( > 110% required) . Reinforced Concrete. Good (but see note 2 below) None.

25-02-2006 26-02-2006 8.45 a.m. 27-02-2006 8.45 a.m. 24 Hours 151 mm. below reference point Z 52 m.m. below reference point 1 m.m. (< I O mm allowed) None found on visual inspection None found on visual inspection No rain occured, there was no abnormal drying

Adequate Adequate Adequate Adequate

' Test procedures were based on Clause 9.2 of BS 8007 : 1987, but reduced criteria as follows were used: I. Drop in water level : allowed 10 m.m. in 24 hours. 2. Flow from defects : no ascertainabte flow allowed on visual inspection.

Notes I. Lining mentioned in the previous report has been installed, but some minor repairs remain to be carried out i\

Signed : A..

U \

Martin Clifford B.E.

Date : 23-3-6

Bernard Finnegan Ltd., Structural Consulting Engineers, Sunbeam Industrial Estate, Mallow Road, Cork. Telephone 0214301077, Fax 0214301090

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EPA Export 25-07-2013:20:37:08

5UND TEST CERTIFICATE To BS 8007 : 1987

Client

Bund Location

8und Number

Bund Information

Material Stored in Tank@) Tank nominal volume (Largest Tank) Bund Available Containment Volume Bund volume /tank volume Bund volume I tank volume as percentage Bund Material Bund Condition Bund Linlng

Test Details

Date Bund Filled Date of Initial Reading of Water Level Date of Final Reading of Water Level Test Period Initial level reading Final Water Level Fall in Level Structural Distress Apparent Leaks Rain / Evaporation

Conclusions

Bund Sire Structural integrity Water level test Water leak test

Kerry Ingredients, Charlevilk, C 0. Cork.

Niro ICIP Plant (Bulk Caustic)

No, 4

Caustic Soda 63.25 cbm. 69.65 cbm. 1.10 I10 percent ( = 1 10% required) Reinforced Concrete. Very Good. None

13-01-2006 16-01-2006 3.15 p.m. 17-01-2006 4.20 p.m.

25 Hours 2 m.m. below reference point 2 m.m. below reference point 0 m.m. ( < 10 mm allowed per 24 hours) None found on visual inspection 1 very minor weep in concrete wall. Some rain occured (2mm), there was no significant drying


Comments

1 Bund is satisfactory. 2. There is 1 damp patch on the wall but with no visable water flow.

' Test procedures were based on Clause 9.2 of BS 8007 : 1987, but reduced criteria as follows were used: 1. Drop in water level : allowed I O m.m. in 24 hours. 2. Flow from defects : no ascertainable flow allowed on visual inspection. \.

Martin Cllfford 8.E. '3

Date :

Bernard Finnegan Ltd., Structural Consulting Engineers, Sunbeam Industrial Estate, Mallow Road, Cork. Telephone 021-4301077, Fax 0214301090

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EPA Export 25-07-2013:20:37:08

. ._

Bund volume I tank volume as percentage . 112 percent ( > 110% requlred) Bund Material Reinforced Concrete with Stainless Steel Unlng '

Rund Condition. VeryGood '

md LinIng Stainless Steel (to full helght) not sealed to tank

Test Details Date Bund Filled Date of Initial Reading of Water Level Date of Final Readlng of Water Level Test Period '

Initial level reading Finaf Water Level . Measured increase in Level fn Bund Measured increase in level in Rain Gauge Adjusted increase in Level in Bund for Tank due to rain Adjusted Loss In Level fn Bund Adjusted Fall In Level In Bund due to Time Stnrctural Di6tress Apparent Leah Rain / Evaporation

06-0Y-2004 '

07-0 1-2004 3.20 p.m. 08-01-2004 3.00 p.m. 23.66 Hours 94 . m.m. above reference pofn I04 m.m. above reference point 10 m.m.

m.m. 10

18.76 rnm 8.76 m.m. 8.89' m.m. ( 10 mm allowed per 24 houk) None found on visual Inspection' None found on vtsual inspection Heavy showers occurred and were measured'

Bund Size Adequate . Structural Integrity Adequate Water level test Adequate Water leak test Adequate

Comments 1. Bund floor is satisfactory.

Test procedures were based on Clause 0.2 of BS' 8007 : 1987, but reduced criteia a 1. Drop In water level : adwed I O m.m. In h4 hours. 2. Row from dekcb : no ascertafnqble how allowed on vlsual Inspecffon.

Signed : Mke, Mkbaef Crowley B.E.

Date : 7 -dl --ZOO4

L

_.

Bernard Flnnegan Ltd., Structural ConsuIing Engineers, Sunbeam Indusfrtal Estate, Mallow Road, Cork Telephone 0219301077, Fax 0214301090

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EPA Export 25-07-2013:20:37:08


Client

Bund Location

Bund Number

Bund Information

Kerry Ingredients, Charteville, Co.Cork.

Niro 3 CIP Plant (Bulk Acid)

No. 6

Material Stored in Tank@) Tank nominal volume (Largest Tank) Bund Available Containment Volume Bund volume /tank volume Bund volume I tank volume as percentage Bund Material Bund Condition . Bund Lining

Test Details Date Bund Filled Date of initial Reading of Water Level Date of Final Reading of Water Level Test Period Initial fevel reading Final Water Level Fall in Level Structural Distress Apparent Leaks Rain / Evaporation

Nitric Acid 22.44 cb.m. 43.45 cb-m, i .94 194 percent (’> 11 0% required) Reinforced Concrete, Good. , - None ’

. . . . . . ...

13-01-2006 16-01-2006 3.20 p.m. 1 7-01 -2006 4.25 p.m.

25 Hours 0 m.m. above reference point 6 m.m. below reference point 6 m.m. ( 10 mm allowed per 24 hours) None found on visual inspection 3 minor weeps, with no free water. Some rain occured (2mm). there was no significant drying

Conclusions Bund Size Structural Integrity Water level test Water leak test

2omments 1. Bund is satisfactory.


2. On 1 side of t h e bund, the wall below the joint between the wall and the base is damp, but with no visable water flow.

’ Test procedures were based on Clause 9.2 of BS 8007 : 1987, but reduced criteria as follows were used: 1. Drop in water level : allowed 10 m.m. in 24 hours. 2. Flow from defects : no ascertainable flow allowed on visual inspection. \ \

Maitin Clifford B.E.

Date: ( - r3i - 06

Bernard Flnnegan Ltd., Structural Consultlng Engineers, Sunbeam Industrial Estate, Mallow Road, Cork. . Telephone 0214301077, Fax 021-4301090

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EPA Export 25-07-2013:20:37:08

BUND TEST CERTIFICAE TO BS 8007 : 1987 *

Client

Bund Location

Bund Number

Bund Information Material Stored in Tank@) Tank nominal volume (Largest Tank) Bund Available Containment Volume Bund volume / tank volume Bund volume I tank volume as percentage Bund Material Bund Condition Bund Lining

rest Details Date Bund Filled Date of Initial Reading of Water Level Date of Final Reading of Water Level Test Period In%tial level reading Final Water Level Fall in Level Sbuctural Distress Apparent Leaks Rain t Evaporation

Conclusions Bund Size Structuml Integrity Water level test Water leak test

Jmments

1. Bund is in good condition.

Kerry ingredients Charleville, C0.COrk.

Nim 3 C1P Plant (Bulk Caustic)

No. 7

Caustic Soda 70.37 cb.m. 79.72 cbm. 1.13 t $3 percent ( =. 11o%'required) Reinforced Concrete. Very- Good (minor repairs canied out to floor). Part Lower level only.

25-01-05 2601-2005 9-00 a.m. 27-01-2005 9.00 a.m. 24 Hours 27 m.m. above reference point 24 m.m. above reference point 3 m.m. (e IOmm allowed per 24 hours) None found on visual inspection None found on visual inspection No rain occured, there w s no abnormal drying.


2. There are 2 damp patches on the walls but with no visable water flow. 3. Performance In this test is vely similar to the tank's performance in the test dated 14-12-2001.

Test proceedures were based on Clause 9.2 of BS 8007 : 1987, but reduced criteria as follows were used: 1. Drop in water level : allowed 10 m.m. in 24 hours. 2. Flow from joints \ : no ascertainable flow allowed on visual inspection.

Martin Clifford B.E.

Date : 27-01-05

Bernard Finnegan Ltd., StNcturaI Consulting Engineers, Sunbeam Industrial Estate, Mallow Road, Cork Telephone 0214301077, Fax 0214301090

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EPA Export 25-07-2013:20:37:08

8 Feb 05 16:27 B e r n a r d Finnegan

BUND TEST CERTIFICATE To BS8007: T987' .

Cliejnt

Bund Location

Sund Number Bund Information

Material Stored in Tank@) Tank nominal volume (Largest Tank) Bund Available Containment Volume Bund volume I tank volume Bund volume f tank volume as percentage Bund Material Bund' Condition . Bund Lining

Test Details

Date Bund Filled Date of Initial Reading of Water Level Date of Final Reading of Water Level Test Period lnitifiel IeveJ reading Final Water Level Fall in Level stntchlral Distress Apparent Leaks

Ra& I Evaporation

=onclusions Bund Size Structural Integrity Water level test f

Water leak test

:ominents.

K e n y ingredients Charleville, c0.col-k.

At Main Site Enhnce

No. 8 . .

Road Diesel 466.00 cb.m. 512.60 cb-m. 1.10 f10 percent ( > 110% required) Reinfored Concrete: . Good . . Sika diesel resistant waterproof membrane

25-06-2004 01 417-2~104 8.00 p.m. 03-07-2004 10.00 p.m.

50 Hours . 327 m.m. below reference point 334 m.m. below reference point 7 m.m. (e 1Omm allowed per24 hours) None'found on visual inspectian 3 very minor weeps in concrete walls. Soil beside bund at stream was moist ln one area, but was insufficient to sample. Some rain occured (-4 mm), there ws minor drying.

Adequate Adequate . Adequate Adequate

The bund is being maintained with 1OOrnrn of water in the bottom at all times so that in the event of a spillage, the first liquid to escape will be water (diesel floats on water), giving adequate time to safely salvage the diesel fuel.

Test proceedures were ba.sed on Clause 9.2 of BS 8007 : 7 987, but reduced criteria as follows were used:

\ 1. Drop in water level : allowed 10 m.m. IR 24 hours. 2. Row from joints . \ ' '

:. no ascertainable flop' allowed on visual inspection.

Martin Cliord 8.E.

late : 05-07-04

Bernard Finnegan Ltd., Structural Consulting Engineers, Sunb&rn Industrial Estate, Mallow Road, Cork Telephone 021-43010f7. Fax 0214301090

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EPA Export 25-07-2013:20:37:08


Bund Location

Bund Number

Bund Information

Material Stored in Tank(s) Tank nominal volume (Largest Tank) Bund Available Containment Volume Bund volume /tank volume Bund volume /tank volume as percentage Bund Material Bund Condition Bund Lining

Test Details

Date Bund Filled Date of Initial Reading of Water Level Date of Final Reading of Water Level Test Period Initial level reading Final Water Level Fall in Level Structural Distress Apparent Leaks Rain I Evaporation

Conclusions

Bund Size - Structural Integrity

Water level test Water leak test

omments 1. Bund is satisfactory.

Keny Ingredients, Charleviile, Co.Cork.

Waste Water Treatment Plant

No. 9

Caustic 15.30 cb.m. 17.78 cb.m. 1.16

Reinforced Concrete. Very Good. None

' 116 percent ( > I1 0% required)

16-01-2006 16-01-2006 3.55 p.m. 17-01 -2006 4.05 p.m.

24 Hours 31 m.m. below reference point 32 m.m. below reference point 1 m.m. ( c I O mm allowed per 24 hours) None found on visual inspection None found on visual inspection Some rain occured (2mm), there was no significant drying


I

* Test procedures were based on Clause 9.2 of BS 8007 : 1087, but reduced criteria as foflows were used: 1. Drop in water level : allowed 10 m.m. in 24 hours. 2. Flow from defects : no ascertainable flow allowed on visual inspection. 1

Martln Ciifford B.E.


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EPA Export 25-07-2013:20:37:08


Client

Bund Location

Bund Number Bund Information

Material Stored in Tank@) Tank nominal volume (Largest Tank) Bund Available Containment Volume Bund volume / tank volume Bund volume /tank volume as percentage Bund Material Bund Condition. . . Bund Lining.. . I - ..

Test Details Date Bund Filled Date of Initial Reading of Water Level Date of Final Reading of Water Level Test Period Initial level reading Final Water Level Fall In Level Structural Distress Apparent Leaks Rain I Evaporation

Conclusions

Bund Size Structural Integrity Water level test Water leak test

Comments 1. Bund is satisfactory.

Kerry Ingredients, Charleville, Co.Cork.

Waste Water Treatment Plant

No. 10

Bulk AcidlFerric Sulphate 23.46 cbm. 29.16 cb.m. 1.24 124 percent ( > 110% required) Reinforced Concrete. Very Good. - ,

Acid resistant lining

16-01 -2006 r

16-01-2006 3.50 p.m. 17-01 -2006 4.05 p.m.

24 nouE 406 m.m. below reference point 407 m.m. below reference point d m.m. ( < 10 mm allowed per 24 hours) None found on visual inspection 1 very minor weep found on the walls. No flowlng water. Some rain occured (2mm). there was no significant drying


' Test procedures were based on Clause 9.2 of BS 8007 : 1987, but reduced criteria as follows were used: I. Drop in water level : allowed 10 m.m. in 24 hours. 2. Flow from defects : no ascertainable flqw allowed on visual inspection. \

Maitin Clifford BE.


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EPA Export 25-07-2013:20:37:08

- -

I

-* 1

I

-+

\?\ I I I

. . . . F

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EPA Export 25-07-2013:20:37:09

For inspection purposes only. Attachment · 2013. 7. 25. · RISK ASSESSMENT 4.1 Methodology 4.2...

Documents

Transcript of For inspection purposes only. Attachment · 2013. 7. 25. · RISK ASSESSMENT 4.1 Methodology 4.2...