RESIDUAL MANAGEMENT PLAN - EPA · 2016. 1. 27. · This Residuals Management Plan (RMP) was...

ATTACHMENT K January 2016

ATTACHMENT K – RESIDUAL

MANAGEMENT PLAN

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RESIDUALS MANAGEMENT PLAN 01 October 2015

47092933

Prepared for: Saint-Gobain Building Distribution (ROI) Ltd t/a PDM

Prepared by: AECOM

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RESIDUALS MANAGEMENT PLAN October 2015 Page i

REVISION SCHEDULE

Rev Date Details Prepared by Reviewed by Approved by

1 1st October 2015

Final Shawna Cleary

Environmental Scientist

John Linehan

Senior Environmental Scientist

Caroline Donnelly

Principal Environmental Scientist

AECOM Infrastructure & Environment Ireland Limited 4th Floor, Adelphi Plaza, Adelphi Centre, George’s Street Upper, Dun Laoghaire, Co. Dublin, Ireland.

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RESIDUALS MANAGEMENT PLAN October 2015 Page ii

Limitations

AECOM Infrastructure & Environment Ireland Limited (“AECOM”) has prepared this Report for the sole use of Saint-Gobain Building Distribution (ROI) Ltd t/a PDM (“PDM”) in accordance with the Agreement under which our services were performed. No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by AECOM. This Report is confidential and may not be disclosed by the Client or relied upon by any other party without the prior and express written agreement of AECOM. The information contained in this Report is based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested and that such information is accurate. Information obtained by AECOM has not been independently verified by AECOM, unless otherwise stated in the Report. The methodology adopted and the sources of information used by AECOM in providing its services are outlined in this Report. The work described in this Report is based on the conditions encountered and the information available during the said period of time. The scope of this Report and the services are accordingly factually limited by these circumstances. AECOM disclaim any undertaking or obligation to advise any person of any change in any matter affecting the Report, which may come or be brought to AECOM’s attention after the date of the Report. Certain statements made in the Report that are not historical facts may constitute estimates, projections or other forward-looking statements and even though they are based on reasonable assumptions as of the date of the Report, such forward-looking statements by their nature involve risks and uncertainties that could cause actual results to differ materially from the results predicted. AECOM specifically does not guarantee or warrant any estimate or projections contained in this Report. Unless otherwise stated in this Report, the assessments made assume that the sites and facilities will continue to be used for their current purpose without significant changes. Copyright

© This Report is the copyright of AECOM Infrastructure & Environment Ireland Limited, a wholly owned subsidiary of AECOM. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

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RESIDUALS MANAGEMENT PLAN October 2015 Page iii

TABLE OF CONTENTS 1. CLOSURE PLAN SUMMARY .................................................. 1

1.1 Activity Details ......................................................................... 1

1.2 Report Preparation .................................................................. 1

1.3 Comparison with Previous Residuals Management Plans (RMPs) ...................................................................................... 1

1.4 Overview of the Plan ............................................................... 1

1.5 Scoping .................................................................................... 1

1.6 Cost Summary ......................................................................... 1

1.7 Financial Provision ................................................................. 1

1.8 Review ...................................................................................... 2

2. INTRODUCTION ....................................................................... 3

2.1 Site Description ....................................................................... 3

2.2 Summary of Site History ........................................................ 3

2.3 Classes of Licensed Activities ............................................... 4

2.4 Licence Requirements ............................................................ 4

2.5 Key Changes since the Previous Update ............................. 5

2.6 Closure Scenarios Covered in the Plan ................................ 6

2.7 Restoration and Aftercare Management Plan ...................... 6

3. SITE EVALUATION .................................................................. 7

3.1 Site Processes and Activities ................................................ 7

3.2 Emissions and Monitoring from the Site .............................. 7

3.3 Operator Performance ............................................................ 8

3.3.1 Environmental Management System (EMS) ......................... 8

3.3.2 Compliance .............................................................................. 8

3.3.3 Complaints and Incidents ...................................................... 9

3.4 Site Environmental Setting, Pathways and Sensitivity ..... 10

3.4.1 Current Surrounding Land Use ........................................... 10

3.4.2 Topography ............................................................................ 10

3.4.3 Geology .................................................................................. 11

3.4.4 Hydrology ............................................................................... 11

3.4.5 Hydrogeology ........................................................................ 13

3.4.6 Natural Habitats ..................................................................... 14

3.4.7 Sensitive Receptors .............................................................. 14

3.4.8 Nearby Flood Risk Areas ...................................................... 15

3.4.9 Other ....................................................................................... 15

4. STATUS OF SITE UPON DECOMMISSIONING ................... 16

4.1 Bunds, Aboveground Storage Tanks & Below Ground

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RESIDUALS MANAGEMENT PLAN October 2015 Page iv

Storage Tanks ........................................................................ 22

4.1.1 Inspection and Integrity Testing .......................................... 24

4.2 Hazardous or Potentially Polluting Components and Construction Materials ......................................................... 24

4.3 Inventory of Raw Materials and Waste ............................... 24

4.3.1 Raw Materials ........................................................................ 24

4.3.2 Production Related Waste .................................................... 25

4.3.3 Decommissioning Wastes .................................................... 26

5. CLOSURE PLAN .................................................................... 28

5.1 Exclusions from the Closure Plan ....................................... 28

5.2 Criteria for Successful Closure ........................................... 28

5.3 Closure Tasks, Programme and Costing ............................ 28

5.4 Closure Schedule .................................................................. 54

5.5 Update and Review of the Closure Plan ............................. 54

5.6 Closure Plan Validation ........................................................ 54

6. RESTORATION AND AFTERCARE MANAGEMENT PLAN 55

6.1 Introduction ........................................................................... 55

6.2 Site Characterisation and Assessment .............................. 55

6.3 Corrective Action Feasibility and Design ........................... 55

6.3.1 Remedial Options Assessment (ROA) ................................ 55

6.3.2 Design/Implementation Soil and Groundwater Remediation Programme (as appropriate) ................................................ 56

6.4 Decommissioning of the WWTP .......................................... 58

6.5 Restoration and Aftercare Management Plan Costing ...... 59

6.6 Update and Review of the Restoration and Aftercare Plan60

6.7 Validation of the Restoration and Aftercare Plan .............. 60

7. TOTAL COSTS ASSOCIATED WITH THE DMP ................... 61

APPENDIX A – FIGURE 1 SITE LOCATION & FIGURE 2 SITE LAYOUT

APPENDIX B – GANTT CHART

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RESIDUALS MANAGEMENT PLAN October 2015 Page 1

1. CLOSURE PLAN SUMMARY

1.1 Activity Details

Name: Saint-Gobain Building Distribution (ROI) Limited t/a PDM (hereafter referred to as “PDM”)

Address: Oldmilltown, Kill, Co. Kildare

IPPC Licence Register Number: P0325-01

RBME Category: A1 Year: 2015

1.2 Report Preparation

This Residuals Management Plan (RMP) was prepared on behalf of the operator by AECOM Infrastructure & Environment Ltd, 4th Floor Adelphi Plaza, George’s Street Upper, Dun Laoghaire, Co. Dublin.

1.3 Comparison with Previous Residuals Management Plans (RMPs)

Table 1.1 – Summary of Previous RMP Revisions

Year Closure and Restoration/Aftercare

Costs

Financial Provision Expiry of Financial Provision

2014 €1,255,570 Company Guarantee Not Applicable

2013 €594,898 Company Guarantee Not Applicable

1.4 Overview of the Plan

The Residuals Management Plan (RMP) was prepared in accordance with Condition 13 of the PDM IPPC Licence. The methodology for the development of the RMP follows the EPA Guidance on Assessing and Costing Environmental Liabilities (2014) and has been prepared by an independent and appropriately qualified consultant.

1.5 Scoping

Scoping has determined that the site will require a restoration/aftercare management plan. This is detailed in Section 6 below.

1.6 Cost Summary

The total closure costs have been calculated as €3,193,566 including a contingency of 15% (excluding VAT) which can be broken down as follows:

Closure Plan Costs: €1,430,846

Aftercare Plan Costs: €1,762,720

1.7 Financial Provision

PDM have put in place a financial security agreement with the EPA on the 17th April 2013. This agreement outlines a security amount of €2,026,350.

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1.8 Review

This RMP will be reviewed annually and any updates will be notified to the EPA.

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2. INTRODUCTION

2.1 Site Description

PDM is located in Oldmilltown, in the hinterlands of Kill town, Co. Kildare. PDM is a subsidiary of the French group Saint-Gobain. The site is situated approximately 25km south-west of Dublin city and has been in operation since 1968, specialising in the manufacture and pressure impregnation of wood with preservatives.

The site occupies an area of approximately 16 hectares, with adjacent land owned by the ESB on the western perimeter. Surrounding land use is dominated by agricultural activities.

A site location map is shown in Figure 1, Appendix A.

There are 36 people employed at the site. The facility currently operates within the following hours of operation:

− 6am to 8pm, Monday to Friday; − 6am to 4pm, Saturday; and − 9am to 4pm, Sunday

This distribution of homes in the environs of the establishment is presented in Table 2.1 below.

Table 2.1 – Survey of House Locations Near the PDM site

Distance from Notional Centre of Establishment

Approx. Number of Homes

<500m None

500m to 750m Approximately 12 residential properties

750m to 1000m Approximately 15 residential properties and Oldmill Industrial

Estate

1000m to 1250m Approximately 10 residential homes. The outskirts of Kilteel village are

within this range.

2.2 Summary of Site History

The PDM site has been in operation since 1968. The Environmental Protection Agency (the EPA) granted the IPC licence register number P0325-01 to PDM (PDM) on December 23rd, 1998.

In May 2010 PDM submitted documentation in respect of an application to transfer their IPC licence from PDM Limited to Saint Gobain Building Distribution (ROI) Limited trading as PDM. The IPC licence was transferred from PDM Limited to Saint-Gobain Building Distribution (ROI) Limited on the 8th May 2013.

In 2014, the Wood Chipping Facility, covering an area of approximately 0.93 acres and operated by Padraic Thornton Waste Disposal Ltd. t/a Thorntons Recycling of Parkwest Business Park, Dublin

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under waste permit WFP-KE-10-0061-0 was removed from the licence boundary. This was completed following an independent closure audit, completed by AECOM, as requested by the EPA.

A review of the IPC licence was initiated by the EPA in 2011 for the purpose of fulfilling the requirements of the EC Environmental Objectives (Surface Waters) Regulations 2009. PDM prepared and submitted a licence review application pack to the EPA in 2012. The rules surrounding this review process changed due to the transposition into Irish national law on 23 April 2013 of the European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013).

The EPA informed PDM in a notice issued on 12th November 2014 that their licence review application was subject to the EPA (Industrial Emission) (Licensing) Regulations 2013. The notice required PDM to furnish such information as is necessary for the application to comply with Regulation 13(2)(a) of the Regulations and in particular to provide information as set out in the schedule attached to the notice. AECOM provided assistance to PDM in forming a response to the request for further information as set out in the notice and this was submitted to the EPA on 1st May 2015. The EPA have since requested that further information pursuant to Section 90 of the EPA Acts is required in order to progress the licence review. PDM are in the process of compiling this information.

Environmental management of the site is regulated by the conditions outlined in PDM’s IPC Licence Reg. No. P0325-01.

2.3 Classes of Licensed Activities

The company is licensed under the Environmental Protection Agency Act, 1992 to carry out the following activity:

“The treatment or protection of wood involving the use of preservatives with a capacity exceeding 10 tonnes per day.”

2.4 Licence Requirements

Condition 13 of the IPPC licence requires the preparation and submittal to the EPA of a Residuals Management Plan (RMP). The specific requirements are as follows;

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.

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

The original RMP was prepared in August 2000 and has been reviewed annually as part of the AER. These reports were prepared with reference to the EPA Guidance Document entitled “Guidance on Environmental Liabilities Risk Assessment, Residuals Management Plans and Financial Provision, (2006)”.

This report presents a revision of the RMP in accordance with the EPA Guidance Document entitled “Guidance on Assessing and Costing Environmental Liabilities (2014)” (hereafter referred to the “EPA Guidance Document”).

2.5 Key Changes since the Previous Update

The following key changes to the site have been completed since September 2014:

Additional granular activated carbon (GAC) units were installed before surface water monitoring point E to achieve compliance with the site’s emission limit value (ELV) for Total Polycyclic Aromatic Hydrocarbons (PAHs). A total of 10 GAC units are now in place.

Short term measures were implemented in the waste water treatment plant to improve treatment efficiency. These include:

o Installation of baffles to prevent short-circuiting.

o Installation of a biomass recycling pump to improve biological treatment.

The site separator was de-sludged structurally assessing and repaired.

Contaminated sediment (153.86 tonnes) was removed from the drainage ditches leading to surface water monitoring point A and D and removed offsite for appropriate disposal. Following excavation the ditch was re-vegetated and a filter strip was installed adjacent to the ditch to surface water monitoring point A to reduce the concentration of suspended solids.

Creosote Storage Area 1 and 2 bund was cleaned and lined using a polyurea liner.

A silt trap, physical filter and GAC filters (x2) were installed at surface water monitoring point D to aid in compliance with PAH abatement at this monitoring point.

The Diesel Tank (Boiler Backup) was decommissioned and replaced by a double skinned 5,000 L plastic tank.

Three unbunded hydraulic oil storage tanks were replaced with MDPE self-bunded tanks.

A series of soil, groundwater and surface water site investigations were completed by AECOM to improve understanding of the conceptual site model and to target any necessary remedial works.

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2.6 Closure Scenarios Covered in the Plan

According to the EPA Guidance Document the environmental liabilities remaining due to sudden closure can often result in closure costs well in excess of those related to a well- managed closure process, e.g. due to the inability to reduce stock and waste volumes in the run-up to a well-organised and staged closure process as well as the likelihood that decommissioning and decontamination works may require the engagement of third parties rather than trained employees. The guidance document therefore states that closure plans should be costed for the maximum, realistic cost of closing a fully operational activity with immediate effect.

However, it is noted that a sudden closure of the PDM site is not a realistic scenario in this instance.

A decision to decommission all or part of the PDM site would be taken centrally by Saint Gobain under a coordinated review. Any such decision would be announced by Saint Gobain central management sufficiently in advance of implementation. In the event of such a decision, the site Residuals Management Plan (RMP) would be prepared for activation. The actions detailed in the RMP would begin upon cessation of manufacturing and preparation for closure.

It is a valid assumption that any shutdown of the site will be a well-planned and well-resourced process. This implies that the shutdown date will be known well in advance and that both production schedules and raw materials purchasing will be planned with the shutdown already factored in. It also implies that PDM will have the resources in terms of financial inputs and manpower to implement the RMP through to completion.

It is also noted that the RMP has been prepared for a scenario in which implementation of the RMP will result in a decommissioned and decontaminated site suitable for future industrial use. The majority of buildings that have been in contact with raw materials such as creosote and Osmose Naturewood(R) will be removed from site. A small number of buildings such as the finished product shed, fabrication shed and pole dressing shed whilst emptied and cleaned as part of the RMP, will be assumed to remain in place following cessation activities at the site.

Where possible decommissioning and decontamination works will be undertaken by internal trained employees although, where required, specialist third parties will be engaged to undertake certain aspects of the decommissioning process.

The RMP will be reviewed and updated as necessary, on an annual basis as part of the AER. The annual review of the RMP will take any changes in site status into consideration and incorporate current planned activities. In addition, any changes or modifications required on foot of the scheduled closure will be included as required.

2.7 Restoration and Aftercare Management Plan

A restoration and aftercare plan is required for the site and is detailed in Section 6.

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3. SITE EVALUATION

3.1 Site Processes and Activities

Site activities comprise the manufacture and pressure impregnation by creosote and Osmose Naturewood®, of timber products, namely poles, railway sleepers, posts, rails and round fencing. Under direction of the company that owns PDM, Saint Gobain, the Osmose Naturewood® replaced Celcure AC 500 which had previously replaced Tanalith (CCA). Tanlith was replaced in November 2003 as a wood preservative due to restrictions in marketing and use of CCA. The main active ingredient in the Osmose Naturewood is copper which has long been known as an effective wood preservative. The copper is coupled with an organic co-biocide for enhanced performance against copper tolerant fungi and insects.

Site operations may be summarised as follows:

Poles are received onto the site and stored in an open area. Natural seasoning of the poles, approximately 9-12 months, takes place at this stage;

When suitably seasoned (thus allowing proper penetration of the treatment materials), the cambium layer is removed with dressing machines;

The poles are then transferred to the fabrication shed where the poles are fabricated to the required client specification. Proper penetration of the treatment materials requires that moisture content of 26 to 28% achieved. Therefore all poles brought onto the site from suppliers are required to have an appropriate level of moisture content for treatment;

During the treatment stage, poles are pressure treated with creosote on a batch basis in large pressure cylinders. A small proportion of timber products are treated using Osmose Naturewood®;

The treated poles and fencing are then stored on concrete pads on-site for up to 3 to 4 months, prior to delivery to customers. Larger 110kv treated poles are stored on site for no longer than 1 month. Treated fencing is stored in roofed areas, while larger treated poles are stored without cover. All concrete pads drain to a central collection point (Manhole No. 8) before entering the sites effluent treatment system and draining to Effluent Point E.

A site layout plan of the PDM site is shown in Figure 2, Appendix A of this RMP.

3.2 Emissions and Monitoring from the Site

Emissions from the waste water treatment lagoon are subject to emission limit values as set out in Schedule 1 (i) of the Licence. Monitoring is also carried out at a number of surface water emission points. Groundwater monitoring is also carried out. A list of emission and monitoring points is provided in Table 3.1 below. There are three additional off-site monitoring boreholes in the adjacent ESB Pole Yard which are subject to ongoing monitoring.

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Table 3.1 – Licensed Emission Points

ID No. Emission Destination of Emission

Location

Easting Northing

A Surface water monitoring point

Surface water 297967 222916

B Surface water monitoring point

Surface Water 297747 222938

E Outfall from waste water treatment lagoon to tributary drain to Kill River

Surface water – Kill River

297583 222442

MW1

Groundwater monitoring wells Groundwater

298058.84 222866.92

MW2 297822.42 222657.57

MW3 297866.61 222460.04

MW4 297663.29 222351.18

MW5 297727.91 222480.49

MW8 297746.50 222526.85

MW9 297720.45 222503.47

MW10 297707.16 222487.25

MW11 297751.83 222533.83

MW12 297740.75 222498.75

3.3 Operator Performance

3.3.1 Environmental Management System (EMS)

PDM maintains an Environmental Management System in accordance with Condition 2.1 of the IPPC Licence. In compliance with Condition 2.1, each year the site produces an Environmental Management Programme (EMP) which sets out the objectives and targets for the forthcoming year. The programme is reviewed on an annual basis and changes reported to the EPA through the AER submission. The site also maintains ISO 14001 certification.

3.3.2 Compliance

Since the last update of the RMP in September 2014, the EPA has conducted two site inspections of the PDM site for the purposes of taking samples. There has also been a site visit from the EPA relating to the site’s IED licence transfer. No non-compliances were identified for either inspection.

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3.3.3 Complaints and Incidents

A summary of incidents reported since the last RMP are listed in Table 3.2. No environmental complaints were received since the last RMP.

Table 3.2 Incidents at PDM

DATE DETAILS OF INCIDENT

21st October 2014 4th November 2014 11th November 2014 18th November 2014 25th November 2014 2nd December 2014 6th January 2015 13th January 2015 21st January 2015 4th February 2015 18th February 2015 25th February 2015 11th March 2015

Incidents relate to exceedances of ELVs in PAH levels in Emission Point E. Work is on-going at the site to improve site management to reduce these emissions including the measures outlined in Section 2.5. It should be noted that a significant increase in sampling frequency occurred in 2014/2015, which accounts for the increased number of individual exceedances compared to previous years.

7th October 2014 21st October 2014 28th October 2014 11th November 2014 16th December 2014 6th January 2015 13th January 2015 21st January 2015 29th January 2015 4th February 2015 10th February 2015 18th February 2015 4th March 2015 11th March 2015 25th March 2015 8th April 2015 15th April 2015 22nd April 2015 24th April 2015 29th April 2015 6th May 2015 12th May 2015 20th May 2015 28th May 2015 3rd June 2015 10th June 2015 25th June 2015 8th July 2015 19th August 2015 27th August 2015

Incidents relate to releases of PAHs to surface waters at Emission Point A. Improvement works are underway/planned for the site to prevent such releases including improved storage facilities to prevent run-off. It should be noted that a significant increase in sampling frequency occurred in 2014/2015, which accounts for the increased number of individual exceedances compared to previous years.

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Table 3.2 Incidents at PDM

DATE DETAILS OF INCIDENT

2nd September 2014 9th September 2014 23rd September 2014 7th October 2014 21st October 2014 28th October 2014 11th November 2014 16th December 2014 6th January 2015 13th January 2015 29th January 2015 4th February 2015 10th February 2015 25th February 2015 3rd June 2015 8th July 2015

Incidents relate to releases of PAHs to surface waters at Emission Point D. Improvement works are underway/planned for the site to prevent such releases including improved storage facilities to prevent run-off. It should be noted that a significant increase in sampling frequency occurred in 2014/2015, which accounts for the increased number of individual exceedances compared to previous years.

3.4 Site Environmental Setting, Pathways and Sensitivity

3.4.1 Current Surrounding Land Use

A summary of land use within 1km of the Site is as follows:

East: Directly east of the site is agricultural land. Approximately 500m north east of the site are a small number of residential properties.

South: Immediately south of the Site is agricultural land. Beyond this at a distance of approximately 1000 metres to the south east of the site is the village of Kilteel where there are a large number of residential properties.

West: Directly west of the site is an ESB pole storage yard. Beyond this, approximately 250m from the western boundary of the site is agricultural land. Beyond the agricultural land and 700m west of the site is the Painestown River.

North: Directly north of the Site are commercial units and beyond this is the main road that provides access to Kilteel village to the east and the N7 to the west.

3.4.2 Topography

Site topography slopes gently towards the northwest with the site ground elevation is estimated to be approximately 150 metres (m) above Ordnance Datum (Mean Sea Level - Malin Head, Co. Donegal). To the south-east, ground levels increase more steeply up to the village of Kilteel (230 m AOD), and to various higher points in the hills further to the east and south of the site. The National Grid Reference for the site is N 979 228.

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3.4.3 Geology

Geology underlying the site is indicated to comprise greywacke sandstones and shales of the Tipperkevin Formation in the south-western part of the site and Silurian Metasediments and Volcanics consisting of calcareous greywacke, siltstone and shale of the Carrighill Formation of the Silurian Kilcullen Group in the north-western part of the site (Geological Survey of Ireland (GSI) website; (www.gsi.ie); National Draft Generalised Bedrock Map, accessed 24 September 2015).

Previous investigation completed at the PDM site indicates that there is a weathered bedrock layer in the upper 2-3 metres of the bedrock.

Drilling data indicate that the depth to bedrock varies between approximately 5 m bgl at the northern end of the PDM site and 13 m bgl at the southern end of the site.

The overburden soils consist of made ground and till (glacial sediment derived from Lower Palaeozoic rocks or derived from limestone), (Geological Survey of Ireland (GSI) website; (www.gsi.ie); RBD Subsoils, accessed 24 September 2015).

Based on previous investigations, the overburden soils at the site predominantly comprise gravelly clay with some gravel lenses.

3.4.4 Hydrology

A search of the EPA Envision GIS viewer on the EPA website (www.epa.ie, accessed 25 September 2014) revealed a number of streams and rivers in the area surrounding the site:

Killhill Stream located 400 m to the north-northwest;

Newrow Stream located 450 m to the north;

Kilwarden Stream located 420m to the south-west;

Blackchurch River 850 m to the north-northeast, which flows into the Kill East River 1.1km north of the source;

Farmersvale River, which flows into the Blackchurch River 750 m to the north-east; and

Blackhill Stream located 1.2 km to the west.

All the above surface water features flow west to north-west and eventually enter the Painestown River, located 3.4 km west of the site.

The Painestown River flows to the north-west and discharges into the Morrell River, and then subsequently into the River Liffey, located approximately 8 km north-west of PDM.

The river quality of the Painestown River is classified by the EPA as having ‘Poor Status’. There is no water quality data for the streams and rivers located closer to the site.

The Blackchurch River is currently classified as ‘possibly at risk of not achieving good status’ by 2015. Both the Kill East and Painestown Rivers are currently classified as ‘at risk of not achieving good status’ by 2015 under the Water Framework Directive. (EPA website, (www.epa.ie); EPA Maps – Water Quality, accessed 24 September 2014).

An AECOM field scientist completed a walkover of the site and the streams and ditches up and down gradient of the site on 22 October 2014. The result of this walkover and comparison with publicly available maps and previous surveys identified the following drainage features.

Local Area Drainage

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Two unnamed streams originating to the southeast of the site were observed to flow to the northwest up to the site boundary, then along the boundary to the west and eventually joining up with the Kill River to the southwest of the site.

A third un-named stream originating to the southeast of the site flows towards the northern boundary of the site before branching, with one branch leading to the drainage ditch to Monitoring Point A via Monitoring Point ‘Near Oman’ and another running along the northern boundary of the site before joining a fourth un-named stream and eventually joining the Slane River. The branch which leads to ‘Near Oman’ and Monitoring Point A is considered likely to be seasonal, with a wet area (rather than a defined channel) linking the stream to the drainage ditch leading to Monitoring Point A.

Drainage from Monitoring Point A flows initially through a culvert before opening out onto a drainage ditches which follows a tortuous path to the unnamed stream at Bridge 2. From Bridge 2 it flows generally to the northeast eventually flowing in to the Killhill Stream.

Drainage from Monitoring Point D flows via a culvert to a pond on the adjacent ESB pole storage yard. It is understood that the discharge from the pond is culverted to the point referred to as Final Exit. At Final Exit the drainage ditch splits into two channels, one leading towards sample point SW207 and the other to sample point Bridge 2, before the two channels join again at the Killhill Stream.

Drainage from Monitoring Point E flows via land drain to Final Exit and eventually discharges to the Killhill Stream, as per Monitoring Point D above.

A number of springs were noted on publicly available historic maps for the area available from the OSIError! Bookmark not defined., which could be feeding in to the local area drainage (see next row for further details).

Onsite Drainage

Two main drainage ditches are present on the site. These were the drainage ditch leading to Monitoring Point D at the centre of the site and the drainage ditch leading to Monitoring Point A on the northern end of the site. It has been observed that these drains are seasonal and are periodically dry during the summer months.

The drainage ditch to Monitoring Point A consists of two main branches, one flowing generally from north to south and the other east to west, which join together before discharging from the site at Monitoring Point A. A culverted drain connects the drainage ditch to an upgradient pond (Farmer’s Pond) on the eastern boundary of the site. A number of land drains were observed to enter the drainage ditch before Monitoring Point A, including from the adjacent property on the northern end of the site.

From the historic 25” maps available on the OSIError! Bookmark not defined., a spring is noted close to Monitoring Point A.

The drainage ditch to Monitoring Point D is a ‘t’ shaped feature at the centre of the site. Anecdotal evidence suggests that there may be a spring on the eastern end of the drain, as there is generally a flow in this section, even in dry periods.

Two former drainage ditches were located on the southwestern end of the site, between the timber treatment plant and the Waste Water Treatment Plant (WWTP). It is understood that these were once used as part of the surface water drainage system and were connected to the WWTP. It is understood that all connections from the former drainage ditches to the WWTP have been blocked. The drain was observed to be stagnant, but receives overland flow from surrounding areas of the site. It is understood that the drain is pumped periodically into the surface water drainage system via the pump sump.

Springs

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Nine springs were identified on the OSI 25” maps1 of the area and by site staff.

Two springs are located on site: 1 location (potential spring) close to Monitoring Point D as identified by site staff and 1 spring identified on OSI 25” close to Monitoring Point A. 3 springs are noted up hydraulic gradient of the site and 4 down hydraulic gradient.

3.4.5 Hydrogeology

The bedrock underlying the site is classified by the Geological Survey of Ireland as a ‘poor’ aquifer (generally unproductive except for local zones or bedrock which is generally unproductive), with a ‘moderate’ or ‘low’ vulnerability rating.

No gravel aquifer is indicated as underlying the PDM site on the National Draft Gravel Aquifer Map (GSI website, (www.gsi.ie); Groundwater Vulnerability Map of Ireland, accessed 22 September 2015).

In addition, according to the GSI website there is no Source Protection Zone recorded within a 2 km radius of the site.A gravel aquifer is not indicated to be underlying the ESB Pole Yard or the PDM site on the National Draft Gravel Aquifer Map (GSI website, (www.gsi.ie); Groundwater Vulnerability Map of Ireland, accessed 03 January 2014).

In addition, according to the GSI website there is no Source Protection Zone recorded within a 2 km radius of the site.

WFD Status

According to the EPA website (http://gis.epa.ie) the status of the groundwater beneath the site (2007 – 2012) is ‘good’. There is no WFD risk score for the groundwater immediately beneath the site but the surrounding water body is identified as ‘At risk of not achieving good status’. Groundwater beneath the site is ‘protected for drinking water’ under the WFD.

Inferred Groundwater Flow Direction

Based on the topography of the site and the surrounding area, regional groundwater flow direction is likely to be to the west or north-west. In addition, previous site investigations at the PDM site indicate that the inferred groundwater flow direction follows the topography to the west / north-west.

At a site level, groundwater flow may be influenced by local abstraction of groundwater by PDM from one bedrock well (reported to be 500ft (~153 m) in depth) located in the eastern part of the site and a well used on the adjacent Thorntons site. However, this has not been observed during previous assessments of groundwater flow at the site. This well supplies domestic water for the canteen and office and water for the boiler and other miscellaneous uses including vehicle washing.

In addition, since the installation of the groundwater containment system in 2012, pumping at well MW12 near the western site boundary has resulted in a local groundwater gradient towards MW12 in that area of the site.

Abstraction Wells

There are two groundwater abstraction wells on or adjacent to the site:

A groundwater abstraction well associated with PDM is located approximately 100m east (up hydraulic gradient) of the source area, which supplies water to the site offices and facilities.

A groundwater abstraction well associated with the adjacent Thorntons Wood Recycling Facility is located approximately 100m south-east (up hydraulic gradient) of the source area

1 OSI (2015) [Online] Available from www.osi.ie [Accessed 26 August 2015].

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to supply the Thorntons site office and the 10,000L water AST which supplies the machinery sprinkler system.

A search of the GSI well database (GSI website, (www.gsi.ie); accessed 24 September 2014) found five registered groundwater wells located within 1.5km radius of the site. All but one of these wells is located up hydraulic gradient of the site. A summary of the 5 wells is presented below:

A well (locational accuracy to 50m) installed to a depth of 15.5m bgl with an unknown use is located 1 km west of the source area at Porterstown.

A dug well (locational accuracy to 50m) installed to a depth of 3.9m bgl with an unknown use is located 1.28 km south-east of the source area at Kilteel Upper.

A well (locational accuracy to 1km) installed to a depth of 13.1m bgl with an unknown use is potentially located 845 m south-east of the source area at Kilteel. The yield of this well is described as ‘good’.

A well (locational accuracy to 1km) installed to a depth of 9.5m bgl with an unknown use is potentially located 1260 m north of the source area at Quinsborough. The yield of this well is described as ‘poor’ (27.3m3/day).

A well (locational accuracy to 1km) installed to a depth of 91.4m bgl listed as domestic use is potentially located 1480 m south of the source area at Furryhill.

There are no other recorded wells within 1.5 km of the site. However, it is noted that there is no requirement to register wells with the GSI, and, given the rural setting of the surrounding area, it is considered possible that non-registered groundwater supply wells are present.

3.4.6 Natural Habitats

There are no Special Areas of Conservation (SACs) or Special Protected Areas (SPAs) located within a 2km radius of the site. However, there is a Proposed Natural Heritage Site, Kilteel Wood (Site Code 001394) located approximately 850m south-east of the PDM site.

3.4.7 Sensitive Receptors

As seen in Table 2.1 above, there are no residential properties within 500m of the site and approximately 37 residential properties within 1km of the site. The area surrounding the PDM is largely agricultural and/or industrial in nature with low population density.

Sensitive receptors identified within 1km of the site include:

Protected groundwater beneath the site;

Groundwater abstraction wells located at the PDM site, which supplies water to the PDM site offices and facilities;

A groundwater abstraction well associated with the adjacent Thorntons Wood Recycling Facility to supply the Thorntons site office and a 10,000L water AST;

The nearest off-site surface water feature, the Killhill Stream located 400 m west of the site; and

The nearest off site groundwater abstraction well located down hydraulic gradient of the site is 1km west of the site at Porterstown.

It is noted that the site overlies a designated ‘Poor’ aquifer.

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Although, the groundwater abstraction wells associated with the PDM site and the neighbouring Thornton’s Recycling Facility are located up hydraulic gradient of the site, they have been identified as sensitive receptors given their close proximity to the source area.

All remaining off site groundwater wells identified within a 1.5km radius of the site are located up hydraulic gradient of the source area and, as such, are not identified as sensitive receptors.

3.4.8 Nearby Flood Risk Areas

According to the Office of Public Works (OPW) flood risk website (www.floodmaps.ie, accessed 24 September 2015) there are no recurring flood events within 1km of the site.

3.4.9 Other

There are no EPA licenced IPC or Waste facilities located within a 1km radius of the PDM site. The Thorntons Wood Recycling facility located to the south of the site holds a Waste Facility Permit issued by Kildare County Council.

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4. STATUS OF SITE UPON DECOMMISSIONING

The PDM site consists of the main areas outlined in Table 4.1 below. Table 4.1 also indicates the status of these areas upon site closure. Details of the closure tasks to be undertaken within each are provided in Table 5.1 within Section 5 of this RMP.

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Table 4.1 – Buildings, Equipment and Plant

BUILDING/FEATURE DESCRIPTION/MAIN ACTIVITY STATUS OF THE AREA AT COMPLETION OF

DECOMMISSIONING

Raw Timber Storage Shed This shed is used to store raw or untreated timber. The shed is constructed of a number of supporting steel girders with a timber wall on three sides. The roof of this shed is constructed of asbestos cement sheeting.

The asbestos roof will be removed by licenced contractors and disposed of as hazardous waste. The remaining steel and wood will be dismantled and disposed of as non-hazardous waste.

Sleeper Machine Shed This shed stores the unused sleeper processing machine. The shed is constructed of concrete walls with two open ends. The roof of this shed is constructed of asbestos cement sheeting.

The sleeper processing machine will be decontaminated (i.e. lubricating oil removed) and sold as scrap metal. The asbestos roof will be removed by licenced contractors and disposed of as hazardous waste. The remaining steel and concrete walls will dismantled/demolished and disposed of as non-hazardous waste.

Rails Storage shed (Including small lean to structure)

This shed is used to store raw or untreated timber rails. The shed is constructed of a number of supporting steel girders with a timber wall on two sides. The roof of this shed is constructed of asbestos cement sheeting.

The asbestos roof will be removed by licenced contractors and disposed of as hazardous waste. The remaining steel and wood will be dismantled and will be disposed of as non-hazardous waste.

Concrete Pads There are a number of concrete pads located around the site. These are used to store treated poles prior to dispatch to customers. The concrete in these pads are 7-8 inches in depth.

The pads will be excavated and disposed of as either hazardous or non-hazardous waste as appropriate.

Office Building This building is a wooden construction. This building is for administrative functions only.

All domestic type waste will be removed 9e.g. paper, cardboard, etc.) and disposed of as a non-hazardous waste. All office furniture and electrical equipment will also be removed and disposed of appropriately. The empty and clean building will remain in place.

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Canteen The canteen is a wooden building that houses the canteen for employees.

This building will be emptied of all kitchen equipment and canteen waste. The empty and clean building will remain in place.

Kiln The Kiln is used to dry wet untreated wooden rails to obtain a moisture level of 28% or below. Steam from the boilers drives the kiln.

This electrical equipment within this building will be disposed of as WEEE and the empty structure will remain in place.

Separator The separator is a concrete open topped tank with a capacity of 40 tonnes.

Following completion of the soil remediation programme (see Section 6 of this report) the separator will be emptied, cleaned and demolished with all residuals being disposed of appropriately.

Woodchip Storage Shed This shed holds woodchip which is used to feed the boiler.

All woodchip will either be processed through the boiler or disposed of as non-hazardous waste. The empty and clean shed will remain in place.

Boiler House The boiler house holds one boiler which is predominantly fed by woodchip but can also be fed by diesel oil. A back diesel oil tank for this purpose is located adjacent to the boiler house.

The boiler will be cleaned of all residues. Waste residues including contaminated lagging will be disposed of as hazardous waste while waste ash will be disposed of as non-hazardous waste. The fuel in the fuel tank will be returned to the supplier. The fuel tank and transfer lines will also be cleaned and any residues disposed of appropriately. The decontaminate/decommissioned boiler and tank will remain in place.

Diesel storage shed The diesel storage tank is a bunded shed which holds two fuel tanks. One holds white diesel while the other holds gas oil.

The fuel in both fuel tanks will be returned to the suppliers. The tanks, transfer lines and bund will be cleaned, integrity tested and will remain in place. Any repairs required to bund (subject to integrity testing) will be undertaken.

Welding Shed This shed contains various welding equipment and work benches for maintenance work. It also contains three unbunded tanks used to hold engine

The shed will be emptied of any maintenance equipment and the material within the tanks will be returned to the supplier and the tanks will be cleaned.

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oil, hydraulic oil and gear oil. The shed and cleaned tanks will remain in place.

Workshop The workshop is similar to the welding shed and is used to carry out maintenance work. The workshop stores maintenance equipment.

The shed will be emptied of any maintenance equipment which will be sold to interested parties or dealt with as scrap metal or WEEE. The shed will remain in place.

Creosote Storage area for Plant No. 1 and 2

This building contains ten tanks which are used for servicing, storing, venting and pressing in the creosote process.

Creosote within the tanks will be processed and any remaining creosote will be returned to PDMs sister company. The tanks and associated bunds will be cleaned and the materials generated during cleaning will be disposed of as hazardous waste. The tanks will be dismantled and sold as scrap metal. The building will be demolished and contaminated concrete disposed of as hazardous waste. Associated metal (i.e. galvanised roof, support beams, etc.) will be sold as scrap metal.

Creosote Plant No. 1 and 2 This area contains two pressure cylinders within a concrete bund.

The pressure cylinders will be cleaned along with the associated bunds and the materials generated during cleaning will be disposed of as hazardous waste. The cylinders will be dismantled and sold as scrap metal. The concrete bund and floor area will be excavated contaminated concrete disposed of as hazardous waste.

Creosote Plant No. 3 and associated storage area

This area contains one pressure cylinder within a concrete bund and associated bunded storage tanks.

Creosote within the tanks will be processed and any remaining creosote will be returned to PDMs sister company. The tanks and associated bunds will be cleaned and the materials generated during cleaning will be disposed of as hazardous waste. The tanks will be dismantled and sold as scrap metal. The pressure cylinder will be cleaned along with the associated bund and the materials generated during cleaning will be disposed of as hazardous waste. The

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cylinder will be dismantled and sold as scrap metal. The building will be demolished and contaminated concrete disposed of as hazardous waste. Associated metal (i.e. galvanised roof, support beams, etc.) will be sold as scrap metal.

Creosote Plant No. 4 and associated storage area


Creosote within the tanks will be processed and any remaining creosote will be returned to PDMs sister company. The tanks and associated bunds will be cleaned and the materials generated during cleaning will be disposed of as hazardous waste. The tanks will be dismantled and sold as scrap metal. The pressure cylinder will be cleaned along with the associated bund and the materials generated during cleaning will be disposed of as hazardous waste. The cylinder will be dismantled and sold as scrap metal. The building will be demolished and contaminated concrete disposed of as hazardous waste. Associated metal (i.e. galvanised roof, support beams, etc.) will be sold as scrap metal.

Osmose Naturewood(R) plant and associated storage area


Osmose Naturewood(R) within the tanks will be processed and any remaining creosote will be returned to PDMs sister company. The tanks and associated bunds will be cleaned and the materials generated during cleaning will be disposed of as hazardous waste. The tanks will be dismantled and sold as scrap metal. The pressure cylinder will be cleaned along with the associated bund and the materials generated during cleaning will be disposed of as hazardous waste. The cylinder will be dismantled and sold as scrap metal. The building will be demolished and contaminated concrete disposed of as hazardous waste. Associated metal (i.e. galvanised roof, support beams, etc.) will be

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sold as scrap metal.

Waste Water Treatment Plant The WWTP consists of a balance tank, lagoons, reed bed and carbon filtration.

Following completion of the soil remediation programme (see Section 6 of this report) the balance tank will be emptied and demolished. The aeration basins, reed bed and carbon filtration system will only be decommissioned on completion of the groundwater containment system. Sludges will be removed from the aerators and reed beds. The carbon filtration system will be removed from the site and waste carbon disposed of appropriately.

Fabrication Shed This is an open sided shed which is used to process untreated wood prior to treating.

All poles will be processed and any remaining waste wood disposed of. The shed will remain in place.

Pole Dressing Shed This is an open sided shed which is used to store the pole dressing machine. The machine debarks untreated wood.

The pole dressing machine will be emptied of any hydraulic or lubricating oil and will be sold as scrap metal. The shed will remain in place

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4.1 Bunds, Aboveground Storage Tanks & Below Ground Storage Tanks

There are 21 bunds at the PDM site as follows:

Treatment Plant 1 and 2 Bund;

Small Storage Bund No. 1;

Groundwater Containment System Bund;

Offload Drip Tray 1;



Boiler House Chemical Store;

Creosote Storage Area 3;

Celcure AC500 Storage Tank;

Portable Storage Bund at Fencing Sales Shed;

Portable Storage Bund beside Green Tank at Cylinder; and

Portable Storage Bund beside Shed at Cylinder 4.

Boiler House Chemical Store

Treatment Plant No. 3 bund

Treatment Plant No. 4 bund

Diesel Storage Tank

Tanalith Treatment Tank Bund

Tanalith Mixing Tank Bund

Separator

Pump Sump

Balancing Tank.

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Table 4.2 provides a list of bulk aboveground storage tanks located on-site. There are no underground storage tanks present on site.

Table 4.2 – Aboveground Storage Tanks

Area Tank Capacity Contents

Creosote Storage Area for Plant 1 & 2

No.1 Service Tank 50,450 L Creosote

No. 1 Pressing Tank 21,000 L Creosote

No. 2 Service Tank 50,450 L Creosote

No. 2 Pressing Tank 21,000 L: Creosote

No. 1 Service Tank Plant 1&2

53,672 L Creosote

No. 2 Service Tank Plant No. 1&2

53,672 L Creosote

No. 3 Service Tank Plant No. 1&2

53,672 L Creosote

Barrelling Tank 39,133L Creosote

Square Tank 10,909 Creosote

Osmose Naturewood(R) Cylinder Shed

The old Tanalith Tank (no longer in use)

18,000L No longer in use

Square Tank 18,000 L Osmose Naturewood(R)

Mixing Tank 6,000 L Osmose Naturewood(R)

Rainwater Harvest Tank

10,000 L Water

Rainwater Harvest Tank

10,000 L Water

Creosote Storage Area for Plant 3



No. 3 Service/Pressing Tank

33,000 L Creosote

Creosote Storage Area for Plant 4



No. 3 63,000 L Creosote

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Table 4.2 – Aboveground Storage Tanks

Area Tank Capacity Contents

Service/Pressing Tank

Welding Shed

Engine Oil Tank 1,000 L Engine Oil

Hydraulic Oil Tank 1,000 L Hydraulic Oil

Gear Oil Tank 1,000 L Gear Oil

Back-Up Diesel Tank Back-Up Diesel Tank 5,000 L Diesel Oil

Diesel Storage Shed White Diesel Tank 9,000 L White Diesel

Gas Oil Tank 6,000 L Gas Oil

Separator Separator 150 m3 Wastewater

Pump Sump Pump Sump 40 m3 Wastewater

Balance Tank Balance Tank 1,500m3 Wastewater

4.1.1 Inspection and Integrity Testing

All bunds, sumps, tanks and underground pipes are tested over a 3 year cycle in accordance with Condition 9.4.1 of the site’s IPPC licence. Where integrity testing is due at the date of closure, this will be carried out and any repairs carried out as necessary.

4.2 Hazardous or Potentially Polluting Components and Construction Materials

PCBs

PDM was removed from the National PCB Inventory on the 13th December 2013 and is no longer considered a PCB holding as defined by the Waste Management (Hazardous Waste) Regulations, 1998.

Asbestos

The roof of the dis-used soft woods sawmill is constructed of cement bound asbestos sheeting. The total estimated area of the roof is 2,515.5 m2. The roofing material will need to be removed and disposed of in accordance with regulations in place at the time the work is carried out. All asbestos will be removed by authorised contractors for appropriate disposal.

4.3 Inventory of Raw Materials and Waste

4.3.1 Raw Materials

Due to the planned nature of any closure, both the process schedules and inputs of raw materials would be planned with the shutdown already factored in. All contracts relating to the delivery of supplies and materials will be cancelled. All contracts other than those that are concerned with the RMP or related to safety of personnel or the environment will be terminated.

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Creosote remaining after completion of all timber processing will be returned to PDMs sister company Calders and Grandidge. PDM will pay transport costs for this removal and this has been costed in Table 5.1. Remaining Osmose Naturewood(R), due to its high commercial value, will be sold off to competitors in the business. Treated timber remaining on site which cannot be forwarded to customers will be either returned to PDMs sister company Calders and Grandidge or disposed of as waste. The recovered creosote used as brush product is sold by PDM to certified professional users as brushed product. Any remaining product will be sold to users during a close down scenario.

Costs for waste disposal and shipping have been included in Table 5.1.

Table 4.3 provides details of residual Raw Materials quantities estimated to be present on site prior to decommissioning. These quantities are based on a 90% reduction of present day volumes given the circumstances of a planned closure as outlined above.

Table 4.3 – Raw Materials present on site

Type Amount

Creosote 90,700 gallons

Osmose Naturewood(R) 2,200 gallons

Treated poles (from the Creosote Plant) 1,850 m3

Treated timber (from the Osmose Naturewood(R) Plant) 160 m3

Treated Fencing 2,560 m3

Recovered Creosote – Brush Product 560 gallons

4.3.2 Production Related Waste

The site routinely generates production related hazardous and non-hazardous waste i.e. wastes generated during the production process. Non-hazardous waste includes general domestic waste, cardboard/paper, glass and plastic. The site records details of all wastes produced at the site and maintain records of all waste movements from the site, including waste contractors used and final recovery/recycling/incineration/disposal means.

At the time of site closure, there would be certain quantities of these wastes present on-site which were produced as a result of normal site operations. These production wastes would have to be disposed of as part of the closure process. These productions related wastes are detailed in Table 4.4 below. Quantities of these production related wastes expected to be on-site at site closure are based on the types of wastes disposed of during the previous year (2014). The quantity expected to be present is conservatively estimated at 20% of the 2014 waste figure for wastes which have regular removal from the site (i.e. recyclables, municipal waste etc.) and 50% of the 2014 waste total for more infrequently produced wastes. The costs for disposal of these wastes are included in the ‘Production related waste disposal costs’ outlined in Table 5.1.

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Table 4.4 – Production Related Waste Quantities

Description Hazardous/Non-

Hazardous Amount (Tonnes)

Creosote Waste Hazardous 0.5^

Diesel Hazardous 0.24^

Sludge Hazardous 23.4^

PCB Contaminated Waste Hazardous 0.06*

Absorbents Hazardous 1.4^

Light fittings Hazardous 0.06*

Metal waste Non-hazardous 1.24^

Mixed Municipal Waste Non-hazardous 0.52^

Tyres Non-hazardous 0.24^

Septic Tank Sludge Non-hazardous 1.4^

Soil containing dangerous substances Hazardous 42.72^

Biodegradable canteen waste Non-hazardous 0.19^

Aqueous liquids containing dangerous substances

Hazardous 0.43^

Waste paint or varnishes Non-hazardous 1.68^

Contaminated packaging waste Hazardous 0.24*

Boiler dust Non-hazardous 2.28^

Iron and steel waste Non-hazardous 4.56^

Table Notes: ^ 20% of 2014 waste total * 50% of 2014 waste total

4.3.3 Decommissioning Wastes

Decommissioning wastes are wastes which will be generated during the decommissioning project. These wastes would not normally be generated during production periods. They include hazardous and non-hazardous wastes generated as a result of decontaminating activities at the site, e.g. solid and liquid hazardous and non-hazardous waste generated from decontamination and decommissioning of equipment (e.g. chillers, disposal of chemicals, boiler decommissioning, etc.).

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Table 4.5 below provides an estimate of some of the main types of ‘decommissioning wastes’ which would be expected to be generated. Others will also be generated and these wastes and the costs associated with their disposal are detailed in the relevant part of Table 5.1 in Section 5 of this report.

Table 4.5 – Decommissioning Related Waste Quantities

DESCRIPTION HAZARDOUS/NON-HAZARDOUS

AMOUNT

Decommissioning waste from WWTP

Non-hazardous 650 tonnes

Waste treated timber Hazardous 5 tonnes

Waste Creosote and Celcure AC500

Hazardous 16,000 litres

Decommissioning waste from Creosote and Osmose Naturewood(R) plants

Hazardous 3,500 litres

Waste oils from process equipment

Hazardous 700 litres

Contaminated building and construction waste

Hazardous 557 tonnes

Concrete pads Hazardous 3,350 tonnes

Asbestos waste Hazardous 50 tonnes

Boiler decommissioning waste Hazardous 220 litres

Septic tank waste Non-hazardous 7.5 tonnes

Mixed municipal waste Non-hazardous 2.6 tonnes

Waste boiler ash Hazardous 6 tonnes

WEEE Hazardous 1 tonne

Batteries Hazardous 1 tonne

Fluorescent tubes Hazardous 1 tonne

Absorbents filter materials Hazardous 5,000 litres

Tyres Non-hazardous 1 tonne

Scrap metal Non-hazardous 50 tonnes

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5. CLOSURE PLAN

5.1 Exclusions from the Closure Plan

The following items are excluded from the scope of this RMP:

Costs for building demolition for certain buildings not in contact with raw materials (creosote and Osmose Naturewood(R)) and uncontaminated equipment removal: successful decommissioning is determined as being completed when all building, wastes or any other materials that could result in environmental pollution, are removed from the site and recycled, recovered or disposed in accordance with regulations in force at that time. The costs of removing all above and below ground structures have not been included; and

Certain site areas will continue to operate or remain operational after site decommissioning. These include facilities such as groundwater containment, the reed bed and carbon filtration system.

This report is based on the site RMP area layout plan detailed in Figure 2, Appendix A. Required annual reviews of this RMP will include any variations on the layout that may occur.

5.2 Criteria for Successful Closure

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

The decontamination of all process equipment;

Documented and fully costed reports to ensure that all raw materials and finished product have been dispatched from the site;

Documented and fully costed reports on the disposal of hazardous waste including full certification required under law and the company’s IPPC Licence;

Documented and fully costed reports on the disposal of non-hazardous wastes including all certification required under the Waste Management Act and IPPC Licence;

Documentation relating to the proper management and removal of any asbestos containing materials; and

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

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

5.3 Closure Tasks, Programme and Costing

The Closure Plan involves the decommissioning and decontamination of all above and below ground structures – including management of residues arising – at the main site.

The structure of the Closure Plan included in this RMP is based on a logical sequence of events (project milestones) that would occur in the event of a shutdown, similar in logic to an annual maintenance shutdown. However, the end point would be the removal of all materials from the site that could pose a residual threat to the environment. All remaining structures/buildings would be in a steady-state and safe condition.

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Below ground structures, in-ground sumps, drains and transfer lines only in relation to decontamination of internal surface areas i.e. emptying and flush/rinse etc. Issues associated with any necessary removal of structures and assessment of soil/groundwater contamination is dealt with in Restoration and Aftercare Management Plan.

The programme is constructed in a Project Management style format with a number of Stages, each with specific tasks that involve the management of residual waste. The individual stages are in a logical sequence however; some overlap in terms of time-lines is expected.

The individual stages are as follows:

Stage 1: Production Decommissioning, including transfer of residuals to on-site storage;

Stage 2: Removal of Excess Residuals from Stage 1 (including Raw Materials, wastes and Final Product) from site;

Stage 3: Contract cleaning of bulk containment and equipment in contact with process chemicals (including pressure cylinders and storage tanks);

Stage 4: Dismantling and removal of specific buildings and equipment;

Stage 5: Decommissioning of site utilities and non-contaminated equipment;

Stage 6: Removal of non-process related materials and non-hazardous wastes;

Stage 7: Decommissioning of the Wastewater Treatment Plant;

Stage 8: Documentation, Certification, Monitoring and Validation;

Stage 9: Security Arrangements.

Table 5.1 will detail the stages, tasks and costing for a planned closure shutdown scenario.

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Table 5.1 – Closure Stage and Costing

Task Description Quantity Measurement Unit

Unit Rate Cost Source of Unit Rates

Details

STAGE 1: PRODUCTION DECOMMISSIONING INCLUDING TRANSFER OF RESIDUALS TO ON-SITE STORAGE

Stage 1 – Task 1 – Cancellation of Incoming Materials and Decommissioning Timber Preparations

Cancellation of contracts relating to delivery of supplies and materials. Completion of remaining orders

Not applicable Not applicable

Not applicable

Staff costs are

included below

Staff costs provided by

site personnel

Shut down date will be known in advance. All contracts relating to delivery of supplies and materials will be cancelled. All contracts other than those concerned with the RMP or related to safety of personnel and the environment will be terminated. Remaining untreated wood will be prepared through the pole dressing area and cut to length etc. as required. Residual waste from this process would include remaining cut bark and wood chippings which will be disposed of as non-hazardous waste. A cost

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Details

for disposal of waste timber is included in the ‘waste disposal cost’ section of this table.

Stage 1 – Task 2 – Preliminary Decommissioning of Treatment Plants

Decommissioning of Creosote Plant Not applicable Not

applicable Not

applicable

Staff costs are

included below


site personnel

Once all timber orders have been treated, the creosote pressure cylinders will be drained of remaining creosote which will be pumped back to bulk storage. There will be residual creosote remaining in the cylinders and associated vessels which are dealt with in Task 2 below. All condensate, cooling

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circuit water and hydraulic oil will be removed by PDM staff and stored in IBCs for disposal. Costs for disposal of residues are included in the ‘waste disposal cost’ section of this table.

Decommissioning of Osmose Naturewood(R) Plant Not applicable Not

applicable Not

applicable

Staff costs are

included below


site personnel

There is one Osmose Naturewood(R) pressure cylinder. Once all timber orders have been treated, the Osmose Naturewood(R) pressure cylinder will be drained of remaining Osmose Naturewood(R) which will be pumped back to bulk storage. There will be residual Osmose Naturewood(R) remaining in the cylinder and associated vessels which are dealt with in Task 2 below. All condensate and

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hydraulic oil will be removed by PDM staff and stored in IBCs for disposal. Costs for disposal of residues are included in the ‘waste disposal cost’ section of this table.

STAGE 2 – REMOVAL FROM SITE OF EXCESS RESIDUALS FROM STAGE 1 (INCLUDING RAW MATERIALS, WASTE AND FINAL PRODUCT)

Residual Creosote Not applicable Not applicable

Not applicable

Staff costs are

included below


site personnel

All production steps will be completed at this stage with the initial decommissioning of the Creosote plants having taken place. Any remaining unprocessed creosote will remain in bulk storage until it is shipped to a sister company. Costs for transport are included in the ‘waste disposal cost’ section of this table.

Residual Osmose Not applicable Not Not Staff costs Staff costs All production steps will

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Naturewood(R) applicable applicable are included

below

provided by site personnel

be completed at this stage with the initial decommissioning of the Osmose Naturewood(R) plant having taken place. Any remaining unprocessed Celcure will remain in bulk storage. This will be sold to competitors. No transport costs are envisaged as material would be collected by competitors from the PDM site.

Finished product treated with Creosote & Osmose Naturewood(R)


Not applicable

Staff costs included

below


site personnel

Finished treated product will be stored pending shipment to customers or sister company. Any product that cannot be returned to customers or PDMs sister company will be disposed of as waste. Disposal costs for residual finished product have been included in the waste

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section below. Costs for disposal are included in the ‘waste disposal cost’ section of this table.

STAGE 3 – CONTRACT CLEANING OF BULK CONTAINMENT AND EQUIPMENT IN CONTACT WITH PROCESS CHEMICALS

Cleaning of process equipment (pressure cylinders) and bulk containment in contact with process materials

4 Cylinders and 26 Tanks (listed in Table 4.2 with the exception of

the two rainwater tanks and the balance

tank)

Cylinder Tank

€8000 €5000

€32,000 + €130,000 =

€162,000 Rilta

A specialist contractor will be hired in order to carry out the cleaning process. Cleaning will be carried out using high pressure water (for the Osmose piping, buggies and storage). For the creosote process, a combination of high pressure steam and water to remove as much residual creosote from the surfaces of equipment, piping and storage in contact with creosote. The water and creosote/Osmose Naturewood(R) mix resulting from the cylinder and storage

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tank cleaning will be transferred to IBCs for disposal as hazardous waste. Disposal costs are included the ‘waste disposal cost’ section of this .

De-sludging of the Surface Water Separator and Balance Tank


Not applicable

See Section 6.5

Costs provided by Contractor

This may not be undertaken until after the soil remediation process (outlined further in Section 6 is undertaken) is complete. Costs and works associated with decommissioning of the WWTP have been included in Section 6.5.

Cleaning of bunds and pipework 21 Not

applicable Not

applicable

Staff costs included in

‘Other Costs’


site personnel

Following cleaning of the process equipment and bulk containment the bunds and piping will be cleaned. The contents of the bunds and waste residuals

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below from bunds and piping will be disposed of as hazardous waste. Disposal costs are included in the ‘waste disposal cost’ section of this table.

STAGE 4 – DISMANTLING & REMOVAL OF SPECIFIC BUILDINGS & EQUIPMENT

Dismantling of the soft woods sawmills asbestos roof 1 Buildings Not

applicable Not

applicable €30,000 Costs provided

by site personnel

This shed has an asbestos sheeting roof. The roof will be dismantled by a competent contractor licenced to remove and deal with asbestos. Costs for disposal of asbestos have been included in the ‘waste disposal cost’ section of this table. The building will be dismantled and wood, metal and concrete will be disposed of as non-hazardous waste as these buildings only hold

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untreated timber.

Dismantling of all process equipment and bulk containment in contact with process chemicals


Not applicable

Staff costs included

below


site personnel

Following the removal of all residual wastes from the Creosote and Osmose Naturewood ® Plants and the cleaning of all equipment as outlined in stage 3 above it is envisaged that the equipment will be dismantled and removed from the site. The equipment will be disposed of as non-hazardous metal waste. Costs are not expected to be incurred for this removal due to the value of scrap metal.

Dismantling of the Creosote Plant Buildings & Osmose Naturwood Building (Osmose Naturewood(R) Plant) and concrete pads

2 Buildings Not applicable

Not applicable

Waste disposal costs are

included in the Waste

Section below

See Waste Section for

details

Following removal of all storage tanks and process equipment the main creosote plants and Osmose Naturewood plant will be empty and clean.

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However it is considered that there may be some residual creosote and Osmose Naturewood on the concrete floor and walls of these buildings which may not have been removed through cleaning. The concrete pads will also have to be excavated and removed from sites. For this reason a sum for demolition works have been included in the closure process should demolition of these buildings be required and concrete pads removal works. Costs for disposal of construction and demolition waste from these buildings and pads are included in the ‘waste disposal cost’ section of this table.

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STAGE 5 – DECOMMISSIONING OF SITE UTILITIES & NON-CONTAMINATED EQUIPMENT

Boiler House 1 Not applicable

Not applicable

Staff costs included above

Costs provided by site

personnel

The boiler will be decommissioned by PDM employees once all steam requirements have been met. This will include steam requirements for the cleaning of bulk storage and equipment. The boiler will be cleaned of residual ash and lubrication oil. The ash will be placed in skips for landfilling as a non-hazardous waste. There will also be a quantity of oil contaminated lagging from the boiler and other miscellaneous oil contaminated fabrics from maintenance which will be considered a hazardous waste and will therefore be disposed of by a licensed contractor.

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Costs for disposal are included in the ‘waste disposal cost’ section of this table. The remaining boiler parts will be removed from the site as scrap metal.

Administration Buildings & Employees Canteen Not applicable Not

applicable Not

applicable See Waste

Section AECOM

All office equipment will be returned to Saint Gobain (PDMs parent company). The Administration building will be emptied and will remain in place. Electrical equipment (i.e. cookers, white goods) from the canteen will be disposed. A figure for miscellaneous WEEE has been included in the ‘waste disposal cost’ section of this table.

Fuel Storage Not applicable Not applicable

Not applicable

Not applicable


personnel

All fuel can be returned to the supplier at no cost to PDM.

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Cleaning of other equipment including:

− Pole Dressing Equipment − Sleeper Machine − Maintenance Equipment

Various Not applicable

Not applicable

Staff costs included above


site personnel

Any hydraulic oil or lubricating oils will be removed from all other process equipment and maintenance equipment. Costs for disposal of oils are included in the waste section below. All non-contaminated equipment will be sold as scrap metal.

STAGE 6 – REMOVAL OF NON-PROCESS RELATED MATERIAL AND NON-HAZARDOUS WASTES

Disposal of miscellaneous chemicals Not applicable Not

applicable Not

applicable See Waste

Section


personnel

The miscellaneous chemicals associated with the boiler will be placed in sealed containers, labelled and stored awaiting collection. The chemicals will be disposed of as a hazardous waste by a licensed contractor. Costs are included in the ‘waste disposal cost’ section of this table.

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Removal and disposal of septic tank contents 7.5 Tonnes See Waste

Section See Waste

Section


personnel

This figure is based on the 2012 AER when the septic tanks were last cleaned out. Disposal costs included in the ‘waste disposal cost’ section of this table.

Removal of general (non-hazardous) waste 10 Tonnes See Waste

Section See Waste

Section


personnel

This waste will be disposed of in skips to landfill. Disposal costs included in the ‘waste disposal cost’ section of this table.

STAGE 7 – DECOMMISSIONING OF WASTEWATER TREATMENT PLANT

Decommissioning of the WWTP Not applicable Not

applicable Not

applicable See

Section 6.5 Costs provided by Contractor

This may not be undertaken until after the soil remediation process (outlined further in Section 6 is undertaken) is complete. Costs and works associated with decommissioning of the WWTP have been included in Section 6.5.

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STAGE 8 – DOCUMENTATION, CERTIFICATION, MONITORING, VALIDATION AND FINAL AUDIT

Validation audit and document preparation Not applicable Not

applicable Lump Sum €25,000 AECOM

Documentation will be generated to track progress of the RMP throughout the closure process. All residues removed from site will be recorded and final clearance certs will be prepared as required. A final validation report including a cert. of completion will be submitted to the EPA within 3 months of execution of the plan.

Environmental monitoring during Decommissioning Phase

6 Months €4,500 €27,000 AECOM Noise, dust, weekly independent inspections of closure works.

EPA Licence Surrender Fees Not applicable Not applicable Lump Sum €5,000 AECOM Surrender Fees payable

to the EPA.

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STAGE 9 – SECURITY ARRANGEMENTS

On-site security arrangements, fencing, CCTV etc. Not applicable Not

applicable Lump Sum €74,760 PDM Costs

Prior to vacation from the site, PDM will arrange to secure all on-site equipment; this will include any groundwater containment equipment. Security arrangements will also be arranged for the site. Fifteen years security is provided for in this RMP which includes one mobile patrol a day.

OTHER COSTS

PDM Staff Costs 16 Employees Not applicable €300,000 PDM Costs

PDM currently employs 36 people on site. It was estimated through discussion with site personnel that approximately 16 staff members would be kept on after cessation of activities to assist with the decommissioning

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and closure plan for a period for 3 months. All usual costs including average shift premiums, average overtime, pension etc. have been included.

Equipment Hire Not applicable Not applicable

Not applicable €20,000 AECOM

Equipment may be required for various decommissioning procedures. This may include items such as cherry pickers, temporary waste storage containers, forklift hire, scaffolding, temporary lighting etc.

Shipment costs for finished product and raw materials to sister sites


Not applicable €50,000 AECOM

General electrical works on-site including disconnection from electrical switchgear


Not applicable €14,000 PDM Costs

Utility costs during Not applicable Not Lump Sum €25,000 AECOM

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Details

Decommissioning Phase (electricity, fuel, gas etc.)

applicable

WASTE DISPOSAL COSTS

Production Related Hazardous Wastes

Waste Type Quantity Unit Unit Cost Disposal Costs

Source of Unit Cost Details

Creosote Waste 0.5 Tonnes €380 €190 PDM Cost Based on 20% of AER 2014 figures

Diesel 0.24 Tonnes €380 €91.20 PDM Cost Based on 20% of AER 2014 figures

Sludge waste 23.4 Tonnes €380 €8,892 PDM Cost Based on 20% of AER 2014 figures

PCB Contaminated Waste 0.06 Tonnes €380 €22.80 PDM Cost Based on 50% of AER 2014 figures

Absorbents, filter materials, protective clothing etc. 1.4 Tonnes €380 €532 PDM Cost Based on 20% of AER

2014 figures

Soil containing dangerous substances 42.72 Tonnes €380 €16,233.60 PDM Cost Based on 20% of AER

2014 figures

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Light fittings 0.06 Tonnes €380 €22.80 PDM Cost Based on 50% of AER 2014 figures

Aqueous liquids containing dangerous substances 0.43 Tonnes €380 €163.40 PDM Cost Based on 20% of AER

2014 figures

Contaminated packaging waste 0.24 Tonnes €380 €91.20 PDM Cost Based on 50% of AER

2014 figures

Decommissioning Related Hazardous Wastes



Waste Treated Timber (Stage 1, Task 1) 5 Tonnes Lump Sum €2,083 PDM Costs

Cooling Water from Creosote Plant (Stage 1, Task 1) 2,000 Litres €550/Tonne €1,100 PDM Costs

Condensate Water from Osmose Naturewood(R) Plant (Stage 1, Task 1)

500 Litres €550/Tonne €275 PDM Costs

Condensate Water from Creosote Plant (Stage 1, Task 1)

1,000 Litres €550/Tonne €550 PDM Costs

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Lubricating oils from moving parts (Stage 2) 600 Litres €550/Tonne €330 PDM Costs

Residuals Celcure AC & Creosote remaining from cleaning of tanks, bunds and cylinders (Stage 3)

16,000 Litres Lump Sum €7,680 PDM Costs

Contaminated concrete from the Process Buildings (includes the Creosote Plants and Osmose Naturewood(R) Plant) (Stage 4)

557 Tonnes €100/Tonne €55,700 PDM Costs

Based on the square footage of all process areas in contact with creosote and Celcure AC which totals 1,579 square meters.

All Concrete Pads (Stage 4) 3,350 Tonnes €100/Tonne €335,000 PDM Costs

Rilta were contacted to provide a quote for the removal of all concrete pads from the site. It was established that a method could be utilised to remove the top 1-2 inches of the concrete pad which is expected to be the impacted part. This method will be investigated during a close down scenario

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which may allow some portion of the pads to be disposed of as non-hazardous concrete. However for the purposed of the RMP the worst case scenario has been costed and included.

Asbestos roof sheeting (Stage 4) 40 Tonnes Lump Sum €74,000 PDM Costs Quantity estimate based

on an area of 2,515m2).

Mini Portafeed Boiler Acid (Stage 5) 220 Litres €550/Tonne €121 PDM Costs

Clinker Ash from Boiler Shut-down (Stage 5) 6 Tonne Lump Sum €820 PDM Costs

Oil Contaminated Lagging from the Boiler (Stage 5) 100 Kg Lump Sum €65 PDM Costs

Absorbents, filter materials, protective clothing etc. 5,000 Litres Lump Sum €3,550 PDM Costs

WEEE 1 Tonne €550/Tonne €550 PDM Costs Contingency Amount

Batteries 1 Tonne €550/Tonne €550 PDM Costs Contingency Amount

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Fluorescent tubes 1 Tonne €550/Tonne €550 PDM Costs Contingency Amount

Non-Hazardous Wastes (Production and Decommissioning Related)



Metal from the roof of the Process Buildings (Creosote Plants and Celcure Plant) (Stage 4)

100 Tonnes - - AECOM

Costs are not expected to be incurred for this removal due to the value of scrap metal

Sludge from effluent treatment (Stage 6) 7.5 Tonnes - -

Based on 2012 disposal

amount

Thornton Waste Disposal Ltd t/a Thornton Recycling remove and dispose of PDM’s septic tank waste free of charge. Therefore, no costs have been included for disposal of septic tank waste.

Mixed Municipal Waste 3 Tonnes - - PDM Costs

Thornton Waste Disposal Ltd t/a Thornton Recycling remove and dispose of PDMs mixed municipal

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waste free of charge. Therefore no costs have been included for disposal of such waste.

Iron and Steel Waste 4.6 Tonnes €7 €32.20 PDM Costs

Tyres 1 Tonnes Lump Sum €1,100 PDM Costs

Wood chippings from Pole fabrication (Stage 1, Task 1) 1 Tonnes - - PDM Costs

This would be supplied to a local equestrian company who utilise wood chippings as beddings.

Biodegradable Canteen Waste 0.2 Tonnes €7 €1.40 AECOM Cost Estimate

Based on 20% of AER 2014 figures

Waste paint of varnishes 1.7 Tonnes €7 €11.90 PDM Costs Based on 20% of AER 2014 figures

Paper and cardboard waste 1 Tonnes €145 €145 AECOM Cost Estimate Contingency Amount

Contingency amount to cover unaccounted non-hazardous waste arising during the decommissioning process.

10 Tonnes Lump Sum €1,000 AECOM Cost Estimate

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TOTAL CLOSURE PLAN COST €1,244,214

PLUS CONTINGENCY: An additional contingency sum equal to 15% overall the overall total above costs has been included €186,632

TOTAL CLOSURE PLAN COST (including Contingency and VAT) €1,430,845

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5.4 Closure Schedule

Please refer to Appendix B of this RMP (Gantt chart with stages/tasks and timelines)

5.5 Update and Review of the Closure Plan

The summary of costs associated with closure plan within this RMP, as presented above, are estimates only and are based on the information and data available at the time of compilation of the report. It is anticipated that these costs will vary as time progresses and will depend on factors, including the following:

1. Site conditions;

2. Legislative developments; and

3. Inflation.

Taking this into consideration, it is therefore important that the closure plan and associated costs are reviewed and updated to reflect the current site situation. In addition, IPPC licence requirements specify that the RMP report must be reviewed on an annual basis and any proposed amendments to this plan should be notified to the EPA.

5.6 Closure Plan Validation

Throughout implementation of the RMP, documentation will be generated to track progress. All residues removed from site will be recorded and final clearance certificates will be prepared as required under the terms of the IPPC licence and as required under relevant waste management regulations. A closure audit should be undertaken by an external consultant in order to ensure all aspects of the RMP have been implemented. On completion of this a full report on the outcome of the RMP will be prepared and submitted to the EPA.

It is assumed following completion of all decontamination and decommissioning operations on-site, subsequent compilation of all documentation and submission to the EPA that this will be satisfactory to demonstrate successful implementation of the closure plan.

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6. RESTORATION AND AFTERCARE MANAGEMENT PLAN

6.1 Introduction

Following site closure, and decontamination and removal of key site facilities, it is proposed that a comprehensive intrusive investigation be carried out, followed by remedial options assessment and remedial options implementation. The works will be completed in accordance with EPA Guidance on the Management of Contaminated Land and Groundwater at EPA Licensed Sites. The works will follow the below outline scope:

Stage 1 – Site Characterisation and Assessment

Stage 2 – Corrective Action Feasibility and Design

Stage 3 – Corrective Action Implementation and Aftercare

Risk based decision making will be used to quantitatively evaluate the appropriate levels of residual soil contamination that can be left in place, assuming continued use of the site for industrial purposes.

It is assumed that under a closure scenario, there will already be sufficient groundwater monitoring wells to broadly characterise groundwater quality under the site

Soil and groundwater residuals management at the PDM site represents a medium to long term undertaking that will extend well beyond plant/equipment decommissioning and decontamination. As such, the proposed programme of works has been scoped and costed separately within the overall RMP.

6.2 Site Characterisation and Assessment

Having completed decontamination and removal of the main site facilities, the central and southern area of the site will be available for intrusive soil investigation. There will be much improved access for drilling equipment at that stage, in key potential source areas such as the creosote storage tank area and under the treatment vessels. Furthermore, establishing soil and groundwater quality below potential source areas is best undertaken once all plant decontamination has taken place so as to establish a post-closure baseline.

The investigation will target soil and groundwater quality, particularly in key potential source areas, with a view to identifying areas that may represent an on-going source of groundwater contamination or that may represent an unacceptable risk to future users of the site.

A site specific risk assessment will be completed based on the data obtained during the investigation to enable definition of remedial targets, taking into account the potential risk to groundwater and to future site users from the subsurface contamination.

The estimated time to complete the soil investigation, including reporting, is 5 weeks. The estimated cost to complete the study is €35,000.

6.3 Corrective Action Feasibility and Design

6.3.1 Remedial Options Assessment (ROA)

Following characterisation an assessment of the potential remedial options will be completed to identify and evaluate remedial options for addressing creosote contamination in soil and, groundwater at the site and to provide recommendations for a remedial strategy. It is noted that works to characterise the site and to provide a robust site conceptual model are ongoing and that the remedial options evaluated in this report will require re-assessment following further investigation at site closure.

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The objective of the remedial options assessment (ROA) will be to identify the feasible options that will mitigate the potential risks to human health and controlled waters by contamination in soil and groundwater.

Each remedial approach will be evaluated assessed relative to each other using site-specific assessment criteria as follows:

Overall Scheme Implementation Costs

Effectiveness

Expected Remediation Time

Durability

Availability of Technology

Practicability and Ease of Implementation

Permitting and Licensing Requirements

Health and Safety Management

Stakeholder Acceptability

Environmental Impact

It is considered likely that the following remedial options could be feasible given the current understanding of the site and the contaminants of concern.

Soil Remediation Options

1. Selective excavation and offsite disposal

2. Selective excavation and onsite treatment

3. Containment

4. Containment with selective off-site disposal

5. Containment with on-site treatment

Groundwater Remediation Options

1. Hydraulic containment

2. Augmented hydraulic containment

3. Surfactant flushing with enhanced bioremediation

4. Vacuum assisted product removal

5. Steam enhanced remediation

6. Thermally enhanced remediation

6.3.2 Design/Implementation Soil and Groundwater Remediation Programme (as appropriate)

A remediation plan will be developed for the site based on the ROA prepared during the previous phase of works and feasibility studies/pilot testing will be complete prior to full implementation.

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In the absence of a remedial options assessment and in order to develop a reasonable estimate of the cost of remediation, ballpark costs for each of the potential remedial options presented in Section 6.3.1 considering the current understanding of the site are presented below. It is noted that a remedial options assessment has been recommended for the site and is expected be completed before the end of 2015.

Soil Remediation Options

1. Selective excavation and offsite disposal - €250,000 to €350,000

2. Selective excavation and onsite treatment - €200,000 to €250,000

3. Containment - €150,000 to €200,000

4. Containment with selective off-site disposal - €400,000 to €450,000

5. Containment with on-site treatment - €400,000 to €450,000

Groundwater Remediation Options

1. Hydraulic containment - €8,400 annually to operate in perpetuity.

2. Augmented hydraulic containment - €250,000 to €400,000

3. Surfactant flushing with enhanced bioremediation - €700,000 to €800,000

4. Vacuum assisted product removal - €750,000 to €900,000

5. Steam enhanced remediation - €900,000 to €1,500,000

6. Thermally enhanced remediation - €1,000,000 to €1,500,000

Based on the above ballpark costs, the likely effectiveness of the option and acceptability to stakeholders the following options are considered likely for the site post closure –

Soil Remediation – Selective excavation and onsite treatment.

An area of 500m2 in total with contamination to a depth of 1m representing a volume of 500m3 of soil has been assumed based on the current understanding of the site.

The works would involve localised breaking out of hardstanding, excavation and on-site treatment, using a combination of bioremediation (in a purposefully constructed biopile) and stabilisation of more recalcitrant PAHs and metals, and include replacement and reinstatement of the void using ‘clean’ backfill and landscaping of the treated soil. This would likely require three to six months for completion allowing for design, permitting, ground clearance and validation.

A total cost in the order of €200,000 to € 250,000 is estimated for such purposes, including all preliminary works, design, tendering, on–site supervision and verification

Groundwater Remediation – Surfactant flushing with enhanced bioremediation.

The applicability of a surfactant would be determined not only by the nature of the dense non-aqueous phase liquid (DNAPL) but also by the form of bedrock present.

The feasibility of using a surfactant would need to be investigated initially by desk study followed by a bench-scale test to assess the efficacy of shortlisted reagents. Assuming that an appropriate surfactant was identified (i.e. which met environmental as well as technical effectiveness criteria), the scope of this option is likely to be similar to that of a hydraulic containment system, but with the installation of three additional wells hydraulically up gradient of, or just within, the NAPL zone to act as injection wells for the delivery of the surfactant. Following treatment of the abstracted water, a

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portion of the treated effluent would be re-injected via these wells following addition of the surfactant. This would serve to mobilise the residual DNAPL, which would be captured by the abstraction wells and treated accordingly prior to re-injection.

Once as much mass of contamination had been recovered as reasonably practicable, a polishing phase could then be implemented involving application (injection) of a Terminal Electron Acceptor (TEA), such as nitrate or sulphate, to promote biodegradation of the residual contamination.

Alternatively, in-situ chemical oxidation (ISCO) using a chemical oxidant, such as persulphate, could be used, though this would again require assessment against the geological conditions. In both cases, a final polish would be achieved through monitored natural attenuation

Due to the uncertainty in the volume of NAPL remaining and the ability of the surfactant to effectively mobilise it, time scales are uncertain, though a two to three year period is considered typical followed by a similar length of time for bioremediation and natural attenuation

The costs associated with this option are estimated to be the order of €700,000 to €.800,000 to include all preliminary works, design, tendering, on–site supervision of injection/abstraction well installation and commissioning, operational costs, groundwater monitoring and verification

It is noted that a complete and robust evaluation will need to be prepared following site closure including pilot testing to ensure that the selected options are feasible.

Given the above the estimated cost to implement the soil and groundwater treatment plan is between €900,000 and €1,050,000. The timescales are uncertain given the aforementioned uncertainty but is likely to be about 6 years.

6.4 Decommissioning of the WWTP

Unless required during the remediation works it is envisaged that the WWTP will be decommissioned during site closure. Should it be required during the remediation works the cost of operation and maintenance per year is estimated at €11,000.

Decommissioning of the WWTP will involve contract cleaning of the separator and balance tank and disposal of any sludge’s. The balance tank, separator and pump sump will be demolished and sent as the concrete structure disposed of as hazardous waste. A cost for cleaning of these tanks is included under stage three of the closure process. The estimated costs for disposal of wastes generated include:

Balance tank and pump sump, estimated 370 tonnes of sludge, €67,000

Separator, estimated 172 tonnes of sludge, €31,000

Contaminated concrete from the balance tank, 95 tonnes, €9,500

Contaminated concrete from the pump sump, 10 tonnes, €1,000

Contaminated concrete from the separator, 22 tonnes, €2,200

The principle steps in decommissioning of the aerators, reedbed and carbon filtration unit are:

Aeration basins will continue operating for a period of up to a month or as deemed necessary through monitoring and laboratory analysis. This will induce endogenous respiration in the aeration basin biomass, eliminating any residual toxic carbonaceous substrate and reducing biomass levels;

Aerators in both basins will be switched off and any remaining biomass allowed to settle out;

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The supernatant in the lagoons will be tested for PAH concentrations. Where the PAH concentrations have been determined as being less than the site’s emission limit value (ELV), the supernatant in the lagoons will be pumped to the final discharge point at sample point E;

Where the supernatant exceeds the site’s ELV, it will be pumped for subsequent treatment prior to discharge, e.g. through the reed beds and/or the carbon filters;

The remaining biomass will be removed to a suction tanker and transported, to a local sewerage treatment plant for de-watering;

All equipment associated with the aeration basins will be removed and sold to interested third parties or sold as scrap;

The empty aeration basins will be in-filled and the influent surface water diverted to the final discharge point;

The pumping equipment and reeds from the reed beds will be removed and any potentially contaminated sludge’s which may have settled in the bottom of the Reeds Bed. Biomass from the Reed bed will be disposed of as hazardous waste;

The carbon filtration unit will be disconnected and thoroughly cleaned and returned to the supplier; and

Waste carbon will be disposed of as hazardous waste subject to agreement with the EPA.

The main cost elements of the Reed Beds decommissioning will be:

− Reed bed sludge & biomass disposal – estimated at €85,500

− Aerator sludge disposal – estimated at €114,000

− Carbon disposal, estimated 8 tons, €5,000

− Decommissioning of Pumps and any other associated equipment - €12,300

Contractor costs for decommissioning of the reedbeds and aerators are €29,300

This gives a total estimate of €356,800 to decommission the WWTP.

6.5 Restoration and Aftercare Management Plan Costing

The budget required for the restoration and aftercare management plan is outlined in Table 6.1 below;

Table 6.1 – Summary of Restoration and Aftercare Plan

Description Costs

Post Closure Soil Investigation €35,000

Implementation of Soil and Groundwater Remediation Programme

€1,050,000

Disposal of Stockpiles Boiler Ash €25,000

Operation of the WWTP (6 years) €66,000

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WWTP Decommissioning €356,800

Restoration & Aftercare Management Plan Costs

€1,532,800

Plus 15% Contingency €229,920

Total Restoration & Aftercare Management Plan Costs

€1,762,720

6.6 Update and Review of the Restoration and Aftercare Plan

The programme and summary of costs associated with restoration and aftercare plan within this RMP, as presented above, are estimates only and are based on the information and data available at the time of compilation of the report. It is anticipated that both the programme and the associated costs could vary as time progresses and will depend on factors, including the following:

Site conditions (e.g. an incident involving a release to soils and groundwater);

Legislative developments; and

Inflation.

Taking this into consideration therefore, it is important that the restoration and aftercare plan and associated costs are reviewed and updated to reflect the current site situation. In addition, IE licence requirements specify the RMP report must be reviewed on an annual basis as part of the AER.

6.7 Validation of the Restoration and Aftercare Plan

It is assumed following completion of all decontamination and decommissioning operations onsite, subsequent compilation of all documentation (as previously detailed in Section 5.2) and submission to the EPA and relevant authorities, that this will be satisfactory to demonstrate successful implementation of the decommissioning plan. Furthermore, in relation to the successful implementation of the LTP, it is also assumed that any ongoing soil/groundwater remediation and/or monitoring programmes will be accompanied by associated monitoring data. This monitoring data, which will demonstrate any contaminant levels and/or ongoing performance of treatment systems, will be submitted to the EPA and relevant authorities and will demonstrate the completion of the programme. A certificate of completion will be issued on completion of the RMP.

It is therefore assumed that this documentation and communications with the EPA and relevant authorities will be sufficient to demonstrate successful decommissioning of the RMP and a test programme will not be required.

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7. TOTAL COSTS ASSOCIATED WITH THE DMP

This section summarises the costs presented in Sections 5 and 6 of this report. The summary is presented in Table 7.1 and includes all costs identified during the analysis of the short term and long term programmes.

Table 7.1 – Summary of RMP Costs

Description Costs

Closure Plan Costs (including 15% contingency) €1,430,846

Restoration & Aftercare Management Plan Costs (including 15% contingency)

€1,762,720

RMP TOTAL €3,193,566

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RESIDUALS MANAGEMENT PLAN October 2015

APPENDIX A – Site Location and Site Layout Figures

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1:50,000Drg No:SCALE

SML

North

CLIENT

PROJECT

DRAWING TITLE

Nov 2015

0

SAINT GOBAIN T/A PDM

JL CD

IED APPLICATION

47092933/IED/00001 SITE LOCATION (1:50,000 SCALE)

KILDARE

Ordnance Survey Ireland Licence No. EN 0001915©Ordnance Survey Ireland/Government of Ireland

0 km 3 km

DRAWN ILLUSTRATED CHECKED APPROVED DATE

REV.

4th Floor, Adelphi Plaza, Adelphi Centre, George’s Street Upper, Dun Laoghaire, Co. Dublin, Ireland. T +353 (0)1 238 3100 F +353 (0)1 238 3199 www.aecom.com

1 km 2 km

PDM SITE LOCATION

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WWTP

No Flow(Former drain to WWTP)

Former Blowdown Pit IBC Storage Bund

Seperator

Sample Point D

Firewater Retention Pond

Thorntons

Pump Sump

Balancing Tank

Canteen Kiln Office

AEC 3

Pond

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Groundwater Containment System BundHydraulic / Engine / Waste Oil Storage Tanks

Diesel Tank (Boiler Back-Up)Boiler Chemical Storage Bund

Diesel Tank Bund

Small Storage Bund No.1

Off Loading Drip Tray 1

Creosote Storage Area 1 & 2 Bund

Treatment Plant No.1 & 2 Bund

Portable Bund (beside shed at cylinder 4)

Small Storage Bund No.2

Offloading Drip Tray 3

Treatment Plant No.4 and Creosote Storage Bund

Creosote Storage Area 3 Bund

Tanalith / Treatment Tank Bund

Portable Bund (beside green tank at cylinder 4)Portable Bund (at Fencing Sales Shed)

Treatment Plant No.3 Bund

Offloading Drip Tray 2

Osmose / Tanalith Mixing Bund

Licence Point E

Monitoring Point A

Monitoring Point B

Peeler Building

Fencing Sales Building

Storage Building

Building

Saw MillBuilding

Wood Treatment Plant and Creosote Storage

Concrete Pads - Treated Timber Storage

Buildings

Blow Down Pit

WWTP

Legend:

App'd:

Design:

Chk'd:

Scale:

CAD:

Date:

Title:Project:

App'dRev DetailDate

Made Chk'd

Drawing No.

Status:

Rev:Stat.

Client:NOTES:

T +353 (0)1 238 3100,

F +353 (0)1 238 3199

www.aecom.com

4th Floor, Adelphi Plaza, Adelphi Centre,

George's Street Upper, Dun Laoghaire,

Co. Dublin, Ireland.

SAINT_GOBAIN_T/A_PDM

DESIGN SML

JL CD

NOV2015 1:2500

0PRELIMINARY

47092933IED00002

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APPENDIX B – Gantt Chart

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ID Stage W1 W2 W3 W4 W5 W6 W7 W8 W9 W 10 W11 W12

1 Production Decommissioning, including transfer of residuals to on-site storage

2 Removal of Excess Residuals from Stage 1 (including Raw Materials, wastes and

Final Product) from site

3 Contract cleaning of bulk containment and

equipment in contact with process chemicals

4 Dismantling and removal of specific

buildings and equipment

5 Decommissioning of site utilities and non-

contaminated equipment

6 Removal of non-process related materials

and non-hazardous wastes

7 Decommissioning of the Wastewater

Treatment Plant

8 Documentation, Certification, Monitoring

and Validation

9 Security Arrangements

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ABOUT AECOM In a complex and unpredictable world, where growingdemands have to be met with finite resources, AECOMbrings experience gained from improving quality of lifein hundreds of places. We bring together economists, planners, engineers,designers and project managers to work on projects atevery scale. We engineer energy efficient buildings andwe build new links between cities. We design newcommunities and regenerate existing ones. We are thefirst whole environments business, going beyondbuildings and infrastructure. Our Europe teams form an important part of ourworldwide network of nearly 100,000 staff in 150countries. Through 360 ingenuity, we developpioneering solutions that help our clients tosee further and go further. www.aecom.com Follow us on Twitter: @aecom

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RESIDUAL MANAGEMENT PLAN - EPA · 2016. 1. 27. · This Residuals Management Plan (RMP) was...

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