INDEPENDENT CLOSURE AUDIT AND VALIDATION REPORT … · Lufthansa Technik Airmotive: Independent...

INDEPENDENT CLOSURE AUDIT AND VALIDATION REPORT

LUFTHANSA TECHNIK AIRMOTIVE IRELAND

RATHCOOLE

IPPC LICENCE REG REF 275-01

Report Ref 21281

Issued 05th June 2014

Approved by: Dr Imelda Shanahan

Phone: +353-1-4626710

Fax: +353-1-4626714

Web: www.tmsenv.ie

TMS Environment Ltd

53 Broomhill Drive

Tallaght

Dublin 24 Specialists in laboratory analysis, monitoring and

environmental consultancy

t m s environment ltd

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http://www.tmsenv.ie/

Lufthansa Technik Airmotive: Independent Closure Audit & Validation Report TMS Environment Ltd Ref 21281 of 22

CONTENTS

1.0 INTRODUCTION AND SCOPE

2.0 IPPC LICENCE SURRENDER AND ASSOCIATED REQUIREMENTS

3.0 BACKGROUND INFORMATION

4.0 METHODOLOGY

5.0 AUDIT FINDINGS

5.1 Audit and RMP Overview

5.2 Implementation of Decommissioning Plan: Materials

5.3 Implementation of Decommissioning Plan: Equipment and Processes

5.4 Implementation of Decommissioning Plan: Enva Site Decommissioning Report

5.5 Implementation of Decommissioning Plan: Underground structures and conditions

5.6 Implementation of Decommissioning Plan: Other Waste Categories

6.0 ASBESTOS SURVEY, REGISTER AND REPORT

7.0 PCB SURVEY

8.0 RESIDUAL MATTERS FOR ATTENTION AND RECOMMENDATIONS

Appendix I Plant and machinery retained on site for use by future site owner

Appendix II Waste Register File and Disposal Documentation

Appendix IIII Enva Site Decommissioning Report

Appendix IV Sump and Trench Assessment Report

Appendix V Map showing Manholes and Trenches surveyed by CCTV

Appendix VI Asbestos Register and Report

Appendix VII PCB Survey Report

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1.0 INTRODUCTION AND SCOPE

Lufthansa Technik Airmotive were granted an Integrated Pollution Prevention and

Control (IPPC) licence from the EPA in January 1999 (Licence Reg Ref 275-01). The

Licence was amended in 2005 (Technical Amendment A) and in February 2013

(Technical Amendment B). The company advised in November 2013 that it will close

and that they wish to surrender the IPPC Licence. This report was prepared to satisfy

EPA requirements in respect of the Independent Closure Audit and Validation Report

which is required as part of the Licence Surrender Process.

The Independent Closure Audit (ICA) is intended to meet the requirements of the

Licence in respect of independent validation and verification that the

decommissioning works have been completed satisfactorily. The Scope of Work was

agreed with the Agency following submission of a detailed proposal, revised and

finalised on 12th March 2014. The Scope of work is outlined below.

1. Identify and document the decommissioning, rendering safe or removal of any

soil, sub-soils, buildings, plant, equipment, or waste materials or substances that

could result in environmental pollution. This will include:

Waste. Review of Inventory/Register listing all wastes and the removal and

final destination of all wastes. This will include specific consideration for

Asbestos, PCBs and other hazardous wastes which have been in use at the

facility. A specialist subcontractor has been retained for the actual

decontamination works and removal of wastes. The ICA will review all

documentation associated with the works and the site inspections will verify

satisfactory completion of the works. The building will continue in use and it

is therefore not proposed to remove all asbestos – the Asbestos

Management Report will be reviewed and adequacy verified. The ICA report

includes the following:

(i) Confirmation of the areas that contain asbestos. Where there is

potential for asbestos to be present, there shall be full identification,

management and safe removal, if required, by appropriately certified

contractor.

(ii) Confirmation that any items containing polychlorinated biphenyl

(PCB) compounds have been disposed of appropriately.

Underground structures. Review the Register of all underground structures

including tanks, pipelines and sumps [containing or previously containing

fuel, chemicals, slurry, other], with maps, their integrity testing history &

records for same. Review of integrity testing work and verification of

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adequacy. The scope of work shall include the documented verification that

all plant, equipment, tanks, bunds, sumps are fully emptied, cleaned and

verified as such and contents removed appropriately;

2. Assessment of the potential for soil/groundwater contamination.

An investigation has been carried out by a Senior Hydrogeologist to establish

whether the soil / groundwater is contaminated. The Hydrogeological Report and

associated information is presented in a separate report, TMS Environment Ltd

Report Ref 21102. The work includes the following:

Review of existing information;

Prepare a Source Audit / Preliminary Risk Assessment / Preliminary Site

Assessment [Source-Pathway-Receptor], together with a Conceptual Site

Model [CSM].

An assessment of available groundwater monitoring results, whether the

site overlies a groundwater protection zone and the Aquifer Status and

Vulnerability;

Assessment of the historic bioremediation project reports in the vicinity

of the Engine Test Cell;

Consideration of the need for further detailed investigation and / or the

need for further risk assessment.

3. The ICA Report will include a Declaration as to whether or not the condition of

the site is / is not causing, or likely to cause environmental pollution and the site

of the activity is in a satisfactory state and that all environmental liabilities have

been addressed.

4. Identify how environmental liabilities will be dealt with post-closure, and

whether any remediation measures are necessary. The existing RMP and

Financial Provisions reports and information will be reviewed and will be

included in the final report.

5. Proposals for revised sampling, analysis and reporting arrangements after

closure, where necessary, will be formulated and included in the report for

review and agreement by the Agency.

6. The Independent Closure Audit and Report will be conducted in accordance with

all relevant Agency guidance including the EPA Publication Guidance to Licensees

on Surrender, Cessation and Closure of Licensed Sites.

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2.0 IPPC LICENCE SURRENDER AND ASSOCIATED REQUIREMENTS

The Company was granted an IPPC Licence in 1999 and as part of their Licence

requirements they prepared and agreed with the EPA a Residuals Management Plan

(RMP) in January 2009 in accordance with the terms of their Licence. RMP was the

term for a closure plan prior to the IPPC Directive, which introduced the term

Closure, Restoration and Aftercare Management Planning (CRAMP).

Condition 13 of the Licence defines the Agency requirements in respect of both the

formulation of the RMP and the actions to be taken by the Company in

implementing the RMP. Condition 13 is set out below.

Condition 13. Residuals Management

13.1 Following termination, or planned cessation for a period greater than

six months, of use or involvement of all or part of the site in the licensed

activity, the licensee shall decommission, render safe or remove for

disposal/recovery, any soil, subsoils, buildings, plant or equipment, or any

waste, materials or substances or other matter contained therein or

thereon, that may result in environmental pollution.

13.2 Residuals Management Plan:

13.2.1 The licensee shall prepare, to the satisfaction of the Agency, a fully

detailed and costed plan for the decommissioning or closure of the site or

part thereof. This plan shall be submitted to the Agency for agreement

within twelve months of the date of grant of this licence.

13.2.2 The plan shall be reviewed annually and proposed amendments

thereto notified to the Agency for agreement as part of the AER. No

amendments may be implemented without the written agreement of the

Agency.

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

following:

13.3.1 A scope statement for the plan.

13.3.2 The criteria which define the successful decommissioning of the

activity or part thereof, which ensures minimum impact to the environment.

13.3.3 A programme to achieve the stated criteria.

13.3.4 Where relevant, a test programme to demonstrate the successful

implementation of the decommissioning plan.

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

residuals management plan, for all or part of the site as necessary, shall be

submitted to the Agency within three months of execution of the plan. The

licensee shall carry out such tests, investigations or submit certification, as

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requested by the Agency, to confirm that there is no continuing risk to the

environment.

LTAI are now required to implement the RMP for the decommissioning and closure

of the site. The specific requirements of the above Conditions are addressed in this

Audit and Validation report.

3.0 BACKGROUND INFORMATION

LTAI is a wholly owned subsidiary of Lufthansa Technik AG (LHT) which is one of the

world’s largest civil operators in the aircraft engine and component maintenance

industry. The Company operated an engine overhaul and test facility at its facility in

Rathcoole, Co. Dublin from 1980 to 1996 on behalf of Aer Lingus and from 1996 to

2014 after acquiring the company and site. From 1976 to 1980, a similar facility was

operated by Airmotive Ireland. It is a service company which was involved in the

overhaul and maintenance of commercial jet engines from airlines around the world.

The three main engine types overhauled were the JT9D, which is used on the Boeing

747 aircraft, and the CFM 56 engines.

The total area of the site is approximately of 50,000 m2, comprising 19,000 m2 of

buildings and 31,000 m2 of site roads, car parks, paved areas and loading bays. The

main building consists of approximately 16,250 m2 floor area with various

workshops, stores, offices and facilities services. A large portion of the main plant

building was used for the dis-assembly and re-assembly of engines. There is also a

separate Engine Test Cell, which was used to test the engines once repair and re-

assembly were completed. A detailed description of the twenty-two unit processes

carried out in each area of the site is contained in Attachment 9 of the IPC Licence

application.

The Closure Plan envisages that all plant, machinery, tools, supplies will be re-

located to sister companies or sold at Auction; any residual materials will be

scrapped. Some Utilities will be retained on site as it is planned to sell the building

and prospective buyers will require heating and similar facilities. A list of items to be

retained for this purpose is summarised as follows and detailed elsewhere in this

report: boilers, water heaters, generators, air conditioning and refrigeration plant.

4.0 METHODOLOGY

The Implementation Plan for the ICA is summarized as follows.

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Task 1 Review of existing information

TMS Environment Ltd personnel have reviewed the available documentation. This

review sought to ensure that all necessary areas of specific interest in terms of either

historic incidents or the potential for historic or future pollution are identified and

considered in the Audit. The documentation included, but is not limited to the

following:

IPPC Licence Application Submission

IPPC Licence Reg 275-01 as amended

RMP and associated correspondence with EPA

Soil and groundwater investigation reports

Bioremediation Trench report

Groundwater Monitoring reports

Bund Integrity Test Reports

Pipeline and drain test reports

Waste Register

Waste Shipping, Transfer and Disposal Documentation

Asbestos Survey Report

PCB Report

Waste Removal & Decontamination Contractor Implementation Report

Task 2 Site audit and personnel interviews

An audit of the site was completed and interviews with the Manager Facilities &

Accessories and the Environmental Health & Safety Co-ordinator were conducted on

several dates in March – May 2014.

Task 3 Preparation of ICA Report

This report presenting the findings was prepared. The report documents all of the

work carried out. A separate Hydrogeological Report forms part of the overall ICA

Report and it includes the Conceptual Site Model and Source Audit / Preliminary Risk

Assessment / Preliminary Site Assessment required by the EPA. The final Validation

report will also include a verification of satisfactory execution of the required works.

The ICA and preparation of the Validation Report was carried out by the following

personnel:

Dr Imelda Shanahan, C Chem MRSC, FICI Lead Auditor

Craig O’Connor, BSc MSc PGeo EurGeol CGeol FGS Senior Hydrogeologist

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Craig O’Connor is a senior hydrogeologist with over 15 years experience who is the

principal Technical Resource for the ICA. Craig is responsible for the elements of the

audit that deal with the assessment of potential for soil / groundwater

contamination. The Hydrogeological Report and associated information is presented

in a separate report, TMS Environment Ltd Report Ref 21102.

5.0 AUDIT FINDINGS

5.1 Audit and RMP Overview

The Audit was carried out in stages by Dr Imelda Shanahan and Craig

O’Connor. Multiple visits to the site took place to gather information, to

advise on elements of work being undertaken, to review the work

undertaken by the Company and by the Waste Contractors and to verify that

specified works had been completed. Site visits for Audit purposes took place

on the following dates: 23rd January, 5th March, 16th April, 8th, 21st and 28th

May 2014. In addition, information provided by LTAI was reviewed off-site

prior to and / or during completion of the Audit. The following personnel

were interviewed and provided information for the Audit Team:

Manager Facilities & Accessories, Stephen McFadden

Environmental Health & Safety Co-ordinator, Paul Callaghan

Technical Director, Stefan Schmuck

The areas addressed by the RMP and the manner in which they have been

addressed are summarised as follows. A Waste Disposal Contractor, Enva,

was retained to manage the decontamination of equipment, sumps, trenches

etc and the removal of all chemicals, materials and hazardous wastes off site.

KMK Metals Recycling were subcontracted to take the WEEE and metals. That

work was completed during March, April and May 2014. An Auction House

(HGP Auctions) was retained to Auction the contents of the facility and to

ensure that any residual materials not suitable for sale were scrapped in

accordance with the procedure for disposal of obsolete equipment. A

summary of the main procedures followed in the Decommissioning

Programme is presented here and a more detailed discussion is presented in

the following sections of the report.

1. Materials

A List of materials used on site was submitted to the EPA as part of the

Licence Application Process and updated in the RMP. Some materials were

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transferred to LHT Hamburg, some were returned to the suppliers (principally

gases) and the remainder were taken by Enva and disposed of and/or

recovered with credit issued for same. Detailed information is presented in

the following sections of this report.

2. Equipment & Processes

Some major items of equipment were returned to LHT Hamburg for reuse.

Most of the equipment was sold at Auction and any remaining unsold items

were scrapped, or will be scrapped before end July. Any items already sold in

Phase I of the Auction must be removed from the site by 13th June, although

some larger units (eg Kardex Units) will not be removed until end July by

agreement. Any items which had a potential environmental impact will have

been removed by 13th June. A Phase II Auction will take place in late June –

early July and any remaining items after that date will be scrapped. All

equipment was decontaminated, where required, before shipping / disposal,

and records were maintained. Some items of plant (principally heaters, diesel

generators, boilers, air conditioning units and refrigeration plant) were

retained on site for use by a future site owner. A List of the retained plant

and equipment is presented in Appendix I.

3. Environmental Incidents

There have been some environmental incidents at LTAI going back to 1991

which were discussed in Section 9 of the LTAI IPC licence application. Since

receipt of their IPC licence LTAI had one incident in June 1999 involving

discharge of ca. 500 litres of effluent into a trench excavated for the

installation of a new sewer. The incident was reported to the EPA and

managed to ensure that no environmental risk occurred. There were no

other incidents recorded. These matters are discussed in detail in the

Hydrogeological Report (TMS Environment Ltd Report Ref 21102) which

accompanies the ICA Report.

4. Environmental monitoring

Environmental monitoring is carried out in accordance with the conditions

set in the IPC licence and includes routine monitoring of emissions to

groundwater, sewer, surface water and air. The monitoring is designed to

identify any impact associated with the operation of the facility so as to allow

effective remedial action and prevent or minimize environmental pollution.

Monitoring reports were reviewed and considered as part of this Audit.

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5.2 Implementation of Decommissioning Plan: Materials

All materials, component parts and wastes in use at the facility were stored in

the areas indicated on Figure 5.1 Materials Locations as submitted in the

RMP. The information contained in this Drawing was reviewed with LTAI

personnel and confirmed as an accurate representation of the storage areas.

The cyanide store had been removed to an external Chem Store Unit which

was decommissioned after decontamination and sold. The following major

actions have been taken:

Materials and component parts were removed from site for use at

another LHT site, returned to the supplier or have been disposed of or

recovered by a licensed waste disposal contractor.

All wastes on site were removed for recovery / treatment / disposal at

a licensed waste management facility.

All wastes generated in the decontamination programme were

removed for recovery / treatment / disposal at a licensed waste

management facility.

A list of the main materials expected to be disposed of in the event of the

activation of the RMP was presented in Appendix I of the RMP, and Table 5.1

in the RMP gave an estimate of the maximum quantities of consumable

materials, broken down by generic types ,that it was expected would need to

be removed off-site in the event of activation of the plan. The actual

quantities disposed of are also presented in Table 5.1 below for comparison

with the estimates presented in the RMP.

Table 5.1 Quantities of Consumable Materials Removed Off-Site

Type of Material RMP Estimate for

disposal, Tonnes

Actual Amounts

disposed of, Tonnes

Oils 2.8 14

Solvents 3.1 1.7

Adhesives 0.4 0.73

Acids 0.8 37

Alkalis 1.4 51

Paints 0.5 1.9

Fuel 131.7 60

Cyanides 0.2 6.8

Metal Compounds 2.1 14

Gases & Non fuels 14.4 64.5

Total 157.4 251.6

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Residual fuels were taken with all other materials and wastes by Enva and

credits obtained for their recovery while gases were returned to BOC Gases.

The RMP estimate of 157.4 tonnes of materials is lower than that actually

disposed of. The main reasons for the differences are that (a) wash waters

and decontamination rinses were included and (b) there were some higher

stock figures. In addition, a significant quantity of microfiche and disk records

was removed by KMK Metals Recycling for destruction and disposal.

Records are maintained in the detailed Waste File which is described here.

The file contains a Register of Waste (Appendix II) which also contains all of

the associated shipping and transfer documentation and, where available,

the disposal certificates. The Register contains the following information for

each item and shipment:

Waste Transfer Form (WtF) Number

WtF date

Proposal Number

Item

EWC Code

Quantity

Weight

Drum identification Number

Container Type

Disposal Date

TFS Number

Destination

Disposal Method

Some items have not yet been shipped to the final destination or disposed of

as the Waste Contractor (Enva) will be including these with other similar

wastes in a bulk shipment. The Documentation Identifiers will allow the items

to be tracked and Enva are also licenced by the EPA. The Waste File is divided

in to Open and Closed Sections where the Open Section is still waiting for

final disposal documentation. I have reviewed the File and I am satisfied that

the Register is complete and allows for verification that the small number of

remaining actions are completed satisfactorily.

A small amount of waste remains in the Wash Bay in suitable drums. This is

because some items were left with gear oil etc to allow prospective buyers to

see the equipment running. Any remaining fluids are being removed prior to

shipping off site and when the final work is complete Enva will remove the

remaining drums of waste.

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5.3 Implementation of Decommissioning Plan: Equipment & Processes

Some equipment was transferred to other LHT sites after cleaning and

decontamination was completed. The main items transferred were (a) Tools,

(b) Engines (c) Components and (d) X-Ray and other Equipment including the

Shot Blasters. The Radiological Protection Institute of Ireland (RPII) were

contacted by LTAI and advised that they had no concerns about the removal

of this equipment. Enva removed all fluids and oils for disposal prior to the

equipment being prepared for shipping to Germany. The remaining

equipment was Auctioned and any remaining unsold items were or will be

scrapped before end July.

The following sections, in the same order as presented in the RMP, identify

the decommissioning and decontamination stages of the main items of plant

and equipment at the site as appropriate. A summary of the wastes removed

by category is presented in Table 5.2.

1. Wash Bay & Engine Bay

i. All used cleaning chemicals were removed from the Wash Bay and

disposed of by Enva. Stock Cleaning chemicals were taken back by the

supplier.

ii. The Wash Bay sump was decontaminated and integrity tested as

described in Section 5.5. Visual inspection by TMS confirmed

satisfactory completion. The oil water interceptor was emptied and

cleaned. Contents were disposed of by Enva.

iii. All engines had already been removed to storage as work was

completed. Components were removed from the engine bays and

Auctioned.

iv. Waste oil and spent hydrocarbon solvent cans were removed by Enva.

2. Cleaning Shop

i. All chemicals and tank contents (phosphoric and nitric acids, caustics

(sodium hydroxide and potassium permanganate) and rinse tank

contents were disposed of by Enva.

ii. All sixteen 5,800 litre tanks and associated components and pipework

were decontaminated prior sale at Auction and removal off-site. Visual

inspection by TMS confirmed satisfactory completion. Sold items will

be fully removed by 13th June and any residual material from under the

equipment will be collected and disposed of by Enva.

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iii. The Trench under the tanks was decontaminated, pressure-cleaned and

integrity tested as described in Section 5.5.

3. Non-Destructive Testing (NDT)

This inspection line consisted of five testing procedures:

Fluorescent Penetrant Inspection: Post-Emulsified Line,

Fluorescent Penetrant Inspection: Electrostatics Line,

Magnetic Particle Inspection,

Ultrasonic/Eddy Current/X-ray Inspection,

Mini-NDT.

i. All of the chemicals (kerosene, photographic chemicals, silver,

penetrant dyes (Ardrox) and powder)were disposed of by Enva.

ii. All tanks were emptied, cleaned and decontaminated by Enva. Visual

inspection by TMS confirmed satisfactory completion.

iii. Ductwork on the Electrostatics Line was inspected by CCTV to verify

cleanliness.

iv. The NDT line was sold at Auction.

4. Stripping & Electroplating

i. The electroplating shop contains forty one tanks and the Line was sold

at Auction.

ii. All rinse tank contents were disposed of to sewer

iii. All other acid, alkali and cyanide solutions were disposed of by Enva.

iv. Each tank was decontaminated by Enva. The wash water was directed

to the on site waste water treatment plant for treatment prior to

discharge to sewer.

v. Visual inspection by TMS confirmed satisfactory completion.

5. Machine Shop

i. The machine shop contained several machines used for grinding,

milling, turning and machining various metallic parts. All of these

machines were sold at Auction.

ii. All spent coolant was removed from the machine shop and disposed of

by Enva.

iii. There is a residual amount of gearbox oil in some machines which was

left in place to allow buyers see the machines running. Any remaining

oils are being removed and drummed before removal from the site and

the waste will be disposed of by Enva.

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6. Plasma Shop

i. The plasma shop used various metallic and ceramic powders to coat

components. The powders were disposed of by KMK Metals Recycling.

Full details are presented in the Waste File.

ii. The shop and associated air abatement equipment was

decontaminated by Enva to remove any hazardous plasma dusts prior

to sale. All items were sold at Auction.

iii. Visual inspection by TMS confirmed satisfactory completion.

7. Peening

i. The peening process gives rise to dusts which were collected and

disposed of by Enva.

ii. Equipment from this area was sold at Auction.

8. Painting

i. Paints and solvents and thinners were disposed of by Enva.

ii. The painting booths (one dry filter and two dry booths) were

decontaminated by Enva and any residual matter disposed of as waste.

Visual inspection by TMS confirmed satisfactory completion.

iii. The booths were sold at Auction.

iv. Filters were disposed of by Enva.

9. Welding, Minor Repairs, Rubber Shop, Blasting and Airfoil Shop

i. These five areas generate minor quantities of oils, greases, adhesive

tubes, sealants and resins and aluminium oxide. All of these materials

were disposed of by Enva.

ii. The main items of equipment were sold at Auction.

10. Bearing Cleaning & Inspection

i. The aqueous cleaner was emptied and decontaminated and the

contents disposed of by Enva.

ii. The Cleaner was sold at Auction.

11. Electro pneumatic Shop & Pneumatic Components

i. All materials i.e. small quantities of oil and adhesives were disposed of

by Enva.

ii. Machinery and equipment was sold at Auction.

12. Non Hazardous Test Area, Quick Engine Change & Gearbox Shop

i. These areas use small quantities of oils and solvents all of which were

collected and disposed of by Enva.

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ii. The equipment was sold at Auction.

13. Fuel Shop & Hazardous Test Area

i. Both of these areas used hazardous materials i.e. white spirits, sodium

hydroxide, penetrant dyes and calibrating fluid. All of these materials

were disposed of by Enva.

ii. Equipment, including the 3 main Test Rigs, was decontaminated by Enva

and sold at Auction.

14. Engine Test Cell

The engine test cell comprises six areas:

Preparation room,

Control room,

Air intake facility,

Engine test chamber,

Exhaust facilities,

Fuel storage area.

i. The drains from the Engine Test Cell were cleaned out and the contents

disposed of by Enva.

ii. The oil interceptor from the Engine Test Cell was emptied by Enva after

the entire Engine Test Cell had been washed down to remove any waste

oils.

iii. The walls of the exhaust Unit were cleaned to remove carbon deposits

which was disposed of by Enva.

iv. Unused fuel in the two 227 m3 storage tanks was recovered by Enva and

a credit received.

v. The fuel tanks were degassed and decommissioned by Enva and Sold at

Auction.

15. Boilers and Utilities

The boilers and water heaters have been retained for use by any future

site owner. The Wanson Boiler System and Lines was thoroughly

decontaminated by Enva and waste disposed of by Enva. The system is

being left in place but was thoroughly decontaminated as part of the

Decommissioning Plan.

16. Effluent Treatment Plant

The effluent plant was the last major item of plant to be

decommissioned. The plant was used to treat wash water generated in

plant and equipment decontamination. Following completion of the

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decommissioning, all effluent was pumped out of the treatment plant

and disposed of by Enva prior to decommissioning the plant. The

underground structures were integrity tested as described in Section 5.5

Visual inspection by TMS confirmed satisfactory completion.

17. Fire Suppression System

The Fire Suppression System was not formally identified in the RMP but is

addressed under the general heading Equipment and Processes.

Automatic Fire & Integrated Solutions Dublin issued a Certificate for the

removal of the INERGEN/FM200 Fire Suppression Cylinders, including

the larger-scale systems in the Engine Test Cell, from site. A second

INERGEN System in IT will be decommissioned in mid-July after the

system is closed down. The smaller fire extinguishers etc will remain in

place for a future site owner.

18. Medical / Clinical waste

The Company Occupational Health Nurse was responsible for ensuring

that all Clinical and Medical waste from the Medical Centre was disposed

of. Records of all disposals were maintained and three separate Files

were viewed as well as the Medical Centre Rooms. The Centre was closed

in January and all waste had been removed by Sterile Technologies in

December 2013.

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Table 5.2 Summary of Materials Disposed Of by Area

Area Material Quantity Disposed of, tonnes

Wash Bay & Engine Bay Ardrox 1 900 B /Ardrox 185 Waste oils

4.0 3.0

Cleaning Shop Ardrox 185 Ardrox 1873 Ardrox 188

Phosit/Ardrox 6376 Ardrox 6333

Washings & wipes

20.3 6.2

16.5 12.4 2.4 3.3

Non Destructive Testing Fluorescent Penetrants 29.7

Electroplating Shop Nickel Strip Alocrome 1200

Nitric Acid Silver Strike Silver Plate

Nickel Strike Nickel Plate

Hydrochloric Acid Alkali Cleaner Chrome Strip

Wax DeWax

Washing & wipes

1.0 3.2 2.8 3.5 2.6 2.9 2.9 5.4 5.6 4.3 0.2 2.8 7..2

Machine Shop Coolant 7.7

Plasma Shop Metallic Plasma Powders 2.2

Peening Dusts 0.4

Paint Shop Paints Solvents

1.3 1.5

Welding, Minor Repairs, Rubber Shop, Blasting & Airfoil Shop

Oils Adhesives

Aluminium Oxide

0.6 0.7 5.7

Bearing Shop Ardrox 4181L/ Ardrox 185L 2.8

Electro Pneumatic Shop & Pneumatic Components

Oils Adhesives

0.03 0.15

Non hazardous Test Area, Quick Engine Change & Gearbox Shop

Oils Solvents

0.113 0.5

Fuel Shop & Hazardous Test Area White Spirits Alkaline Rust Remover

Penetrant Dyes Calibrating Fluid

0.17 0.05

0 0.8

Engine Test Cell Oil Fuel

1.3 60

Boilers & Utilities Gas/Transformer Oils 11.2

Effluent Plant Effluent 12.2

Total. 251.6

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5.4 Implementation of Decommissioning Plan: Enva Site Decommissioning

Report

Enva were awarded the Contract to decontaminate the site and all tanks and

equipment as well as removal of chemical wastes and hazardous chemicals,

materials and fuels. They completed the work during March – May 2014 and

their decommissioning report is presented in Appendix III. A summary of the

main stages is presented below.

1. Hazardous chemicals from the Cleaning Shop and Plating Shop were collected

and removed for off-site disposal. The tanks were rinsed clean and finally

tank entry was undertaken to wash down all side walls and floors. pH tests

were carried out on the final washings taken from every bath and the

cleaning process completed until the washings were neutralized. The cyanide

baths were decontaminated by using an oxidizing agent to oxidize the

Cyanides to the more stable Cyanate state to aid the decontamination

process. All floors and drains in this section of the building were power hosed

until clean and finally a CCTV survey was undertaken by Enva to demonstrate

that they had been cleaned to the highest standards possible. Photographs

were taken to demonstrate the work undertaken by showing the initial and

cleaned state of the structures.

2. The wet and dry spray Booths were cleaned and all waste and filters removed

for off-site disposal. ATEX-rated equipment was used where required.

3. The NDT Line baths were emptied and thoroughly cleaned to remove traces

of contaminants. Again the trench under the lines was cleaned and a CCTV

survey undertaken to verify cleanliness and the integrity of the drain.

4. The fuel tanks at the Engine Test Cell were emptied, fuel was recovered off-

site and the tanks were cleaned and decontaminated. Carbon deposits on the

Engine Test Cell exhaust were cleaned off and disposed of as waste.

5. Waste Transfer Forms issued by Dublin City Council were completed for all

off-site removal of waste and copies were given to LTAI for their records.

[Appendix II and Waste File]. Most of the waste was treated at the Enva

facility in Shannon but some hazardous wastes eg cyanides were exported

under TFS to Germany for treatment and disposal.

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6. All tanks and lines from the tanks to the waste water treatment plant were

cleaned and a full CCTV survey was undertaken to verify integrity and

cleanliness.

5.5 Implementation of Decommissioning Plan: Underground structures and

conditions

The Hydrogeological Report contains a detailed assessment of the

significance of underground structures and the assessments and tests carried

out. This section of the report describes the work done and outlines steps

taken to verify the work.

1) Geophysical Survey

The main Production Building has a surface area of ca. 19,000m2. The

concrete slab is up to 200mm thick in areas and visual inspection

indicated that the slab is in good condition throughout.

In order to inspect the subsurface condition of the concrete floor slab

beneath the main building, Minerex Geophysics Ltd (Minerex) undertook

a Ground Penetrating Radar (GPR) survey of selected areas within the

building in April 2014. The areas selected for GPR survey were areas

where fuels/chemicals were used or stored in the production process i.e.

Paint Shop, Cleaning Shop, Electroplating Shop, NDT Line, Bearing

Cleaning Room, Fuel Shop Service Areas, Hazardous Test Area and Non-

Hazardous Test Area.

The survey results showed that the concrete slab is c. 200mm thick and in

excellent condition, with no evidence of breaks or internal damage

(Appendix II of the Hydrogeological Report).

There are some gaps in the GPR survey of the slab where fixed equipment

could not be moved; these areas were visually examined for

condition/signs of contamination by the decommissioning contractor

Enva Ireland Ltd (Enva) following equipment cleaning and removal and by

TMS Environment Ltd to verify conditions. There was no evidence of any

damage to the slab and therefore no evidence of a pathway for spillages /

contaminants to break-through the slab to the sub-surface.

2) CCTV Surveys

Enva carried out CCTV surveys of all foul and process drains throughout

the site in April / May 2014. The drains were found to be in good

condition; the PVC alkaline process drain in the main building was

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deformed (but not broken) in three sections which required re-lining.

Structural defects were found in the PVC foul drains at three points within

the plant which were re-lined. There were no leaks and no potential for

environmental pollution was identified. The CCTV Survey reports are

archived for EPA review if required. A Map showing the areas surveyed is

attached in Appendix V.

The previous CCTV report in 2012 identified three areas which required

work. Horizon Environmental carried out two of the repairs and the third

was completed by Rilta (a section of the Acid Line) in May 2013 and

agreed with the EPA.

3) Hydrostatic and Pressure Tests

Enva carried out hydrostatic and pressure tests on all foul and process

drains throughout the site in April 2014. 6 No. process drain sections and

6 No. foul line sections failed the pressure tests indicating leaks. These

sections were re-lined and re-tested and the sections passed the post-

repair pressure tests. All foul and process drains were integrity tested in

August 2013 and passed the tests; the integrity testing report is filed on

site and was reviewed. It is likely that the higher pressure used in the

current tests may have caused weaknesses and these were all identified

and repaired. The drains did not contain any chemicals / effluent having

been thoroughly cleaned and decontaminated before testing so there

was no potential for environmental pollution arising from the tests. The

Survey reports are archived for EPA review if required. A Map showing

the areas surveyed is attached in Appendix V.

4) Sump & Trench Integrity Tests

LTAI personnel undertook integrity tests in all process sumps/trenches in

March / April 2014 following cleaning by Enva. The Sumps / Trenches

inspected were as follows:

Alkaline sump at effluent plant

Acid sump at effluent plant

Main trench at NDT line

Two (no.) sumps at alkaline compound

2 (no.) sumps at Acid compound

2 (no.) sumps at serviceable compound

Trench and Sump at Wash Bay

Trench in Cleaning Shop

Trench in Plating Shop

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The sumps/trenches were first checked visually for signs of damage and

then filled with water for 24 hours and any level drop noted. The

sumps/trenches were found to be in a satisfactory condition and no

damage/leaks were noted or detected. The Assessment Report and the

photographic records of the assessments are attached in Appendix IV. A

Map showing the areas surveyed is attached in Appendix V.

5) Bund Integrity Tests

The Cadmium Recovery Bund was decommissioned by Enva and

scrapped. This work was carried out and reported to the EPA separately

from the main decommissioning programme at the start of 2014. The last

integrity test was carried out in 2011 and no leaks / issues were

identified. All of the bunds not linked to the heating systems (eg Engine

Test Cell etc) were emptied and decontaminated, the tanks were emptied

and decontaminated and the valves have been left open so that rainwater

does not collect.

5.6 Implementation of Decommissioning Plan: Other Waste Categories

All Laptops and PCs were sold at Auction and as noted elsewhere, any items

not sold will be scrapped by end July by the Auction House. Any remaining

WEEE and batteries will be taken by KMK Metals Recycling. Lamps and

fluorescent tubes went to Irish Lamp Recycling. Rags and wipes from the

Decommissioning Works were removed by Enva. Non-hazardous C&D waste

is being collected by Greenstar. The Grease Trap in the Restaurant was

decontaminated and waste disposed of by Enva. These Waste categories are

summarised at the end of the Waste Register (Appendix II).

6.0 ASBESTOS SURVEY, REGISTER AND REPORT

A comprehensive survey of Asbestos present in the facility was carried out by

McAllister Devereux Keating Limited (MDK). The full report and Asbestos Register is

attached in Appendix VI. The report recommended that most of the asbestos be

managed in situ since No specific environmental / health & safety risk was

presented. Two items which the report recommended be disposed of were

collected by Rilta and ultimately disposed of by Buhck in Germany. These were two

stored sheets of gasket material in the Boiler Room and the black step nosing from

two indoor stairwells. The Waste Transfer and Disposal documentation were

reviewed and are retained in the Waste File.

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7.0 PCB SURVEY

A survey of items of plant that potentially contain PCBs was undertaken by LTAI with

assistance from various bodies. The survey report is attached in Appendix VII and

concluded that there were no PCBs left on site. Following a site visit from the EPA,

the conclusions were agreed.

8.0 RESIDUAL MATTERS FOR ATTENTION AND RECOMMENDATIONS

A small number of matters remain to be addressed as noted in this report. For

example, not all of the final disposal documentation for all wastes had been received

at the time of the Audit. As noted in the relevant sections of this report, we are

satisfied that the necessary procedures are in place to ensure that all waste

shipments can be satisfactorily tracked and that the correct procedures have been

followed. We are also satisfied that the decontamination works for all plant,

equipment and machinery were undertaken correctly and that there is no residual

risk of environmental pollution. Any remaining wastes are ebing stored in the correct

drums in a bunded area and will be collected and disposed of by Enva. All of the sold

equipment has not yet been removed from site but we are satisfied that the

decontamination works were effectively executed and that there is no remaining

environmental risk.

Matters related to the ongoing assessment of potential soil and/or groundwater

pollution are addressed separately in the Phase I Hydrogeological Report which has

already been presented to the Agency and in the Phase II Works which are in

progress and will be reported separately.

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INDEPENDENT CLOSURE AUDIT AND VALIDATION REPORT … · Lufthansa Technik Airmotive: Independent...

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