INDEPENDENT CLOSURE AUDIT AND VALIDATION REPORT
LUFTHANSA TECHNIK AIRMOTIVE IRELAND
RATHCOOLE
IPPC LICENCE REG REF 275-01
Report Ref 21281
Issued 05th June 2014
Approved by: Dr Imelda Shanahan
Phone: +353-1-4626710
Fax: +353-1-4626714
Web: www.tmsenv.ie
TMS Environment Ltd
53 Broomhill Drive
Tallaght
Dublin 24 Specialists in laboratory analysis, monitoring and
environmental consultancy
t m s environment ltd
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CONTENTS
1.0 INTRODUCTION AND SCOPE
2.0 IPPC LICENCE SURRENDER AND ASSOCIATED REQUIREMENTS
3.0 BACKGROUND INFORMATION
4.0 METHODOLOGY
5.0 AUDIT FINDINGS
5.1 Audit and RMP Overview
5.2 Implementation of Decommissioning Plan: Materials
5.3 Implementation of Decommissioning Plan: Equipment and Processes
5.4 Implementation of Decommissioning Plan: Enva Site Decommissioning Report
5.5 Implementation of Decommissioning Plan: Underground structures and conditions
5.6 Implementation of Decommissioning Plan: Other Waste Categories
6.0 ASBESTOS SURVEY, REGISTER AND REPORT
7.0 PCB SURVEY
8.0 RESIDUAL MATTERS FOR ATTENTION AND RECOMMENDATIONS
Appendix I Plant and machinery retained on site for use by future site owner
Appendix II Waste Register File and Disposal Documentation
Appendix IIII Enva Site Decommissioning Report
Appendix IV Sump and Trench Assessment Report
Appendix V Map showing Manholes and Trenches surveyed by CCTV
Appendix VI Asbestos Register and Report
Appendix VII PCB Survey Report
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1.0 INTRODUCTION AND SCOPE
Lufthansa Technik Airmotive were granted an Integrated Pollution Prevention and
Control (IPPC) licence from the EPA in January 1999 (Licence Reg Ref 275-01). The
Licence was amended in 2005 (Technical Amendment A) and in February 2013
(Technical Amendment B). The company advised in November 2013 that it will close
and that they wish to surrender the IPPC Licence. This report was prepared to satisfy
EPA requirements in respect of the Independent Closure Audit and Validation Report
which is required as part of the Licence Surrender Process.
The Independent Closure Audit (ICA) is intended to meet the requirements of the
Licence in respect of independent validation and verification that the
decommissioning works have been completed satisfactorily. The Scope of Work was
agreed with the Agency following submission of a detailed proposal, revised and
finalised on 12th March 2014. The Scope of work is outlined below.
1. Identify and document the decommissioning, rendering safe or removal of any
soil, sub-soils, buildings, plant, equipment, or waste materials or substances that
could result in environmental pollution. This will include:
Waste. Review of Inventory/Register listing all wastes and the removal and
final destination of all wastes. This will include specific consideration for
Asbestos, PCBs and other hazardous wastes which have been in use at the
facility. A specialist subcontractor has been retained for the actual
decontamination works and removal of wastes. The ICA will review all
documentation associated with the works and the site inspections will verify
satisfactory completion of the works. The building will continue in use and it
is therefore not proposed to remove all asbestos – the Asbestos
Management Report will be reviewed and adequacy verified. The ICA report
includes the following:
(i) Confirmation of the areas that contain asbestos. Where there is
potential for asbestos to be present, there shall be full identification,
management and safe removal, if required, by appropriately certified
contractor.
(ii) Confirmation that any items containing polychlorinated biphenyl
(PCB) compounds have been disposed of appropriately.
Underground structures. Review the Register of all underground structures
including tanks, pipelines and sumps [containing or previously containing
fuel, chemicals, slurry, other], with maps, their integrity testing history &
records for same. Review of integrity testing work and verification of
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adequacy. The scope of work shall include the documented verification that
all plant, equipment, tanks, bunds, sumps are fully emptied, cleaned and
verified as such and contents removed appropriately;
2. Assessment of the potential for soil/groundwater contamination.
An investigation has been carried out by a Senior Hydrogeologist to establish
whether the soil / groundwater is contaminated. The Hydrogeological Report and
associated information is presented in a separate report, TMS Environment Ltd
Report Ref 21102. The work includes the following:
Review of existing information;
Prepare a Source Audit / Preliminary Risk Assessment / Preliminary Site
Assessment [Source-Pathway-Receptor], together with a Conceptual Site
Model [CSM].
An assessment of available groundwater monitoring results, whether the
site overlies a groundwater protection zone and the Aquifer Status and
Vulnerability;
Assessment of the historic bioremediation project reports in the vicinity
of the Engine Test Cell;
Consideration of the need for further detailed investigation and / or the
need for further risk assessment.
3. The ICA Report will include a Declaration as to whether or not the condition of
the site is / is not causing, or likely to cause environmental pollution and the site
of the activity is in a satisfactory state and that all environmental liabilities have
been addressed.
4. Identify how environmental liabilities will be dealt with post-closure, and
whether any remediation measures are necessary. The existing RMP and
Financial Provisions reports and information will be reviewed and will be
included in the final report.
5. Proposals for revised sampling, analysis and reporting arrangements after
closure, where necessary, will be formulated and included in the report for
review and agreement by the Agency.
6. The Independent Closure Audit and Report will be conducted in accordance with
all relevant Agency guidance including the EPA Publication Guidance to Licensees
on Surrender, Cessation and Closure of Licensed Sites.
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2.0 IPPC LICENCE SURRENDER AND ASSOCIATED REQUIREMENTS
The Company was granted an IPPC Licence in 1999 and as part of their Licence
requirements they prepared and agreed with the EPA a Residuals Management Plan
(RMP) in January 2009 in accordance with the terms of their Licence. RMP was the
term for a closure plan prior to the IPPC Directive, which introduced the term
Closure, Restoration and Aftercare Management Planning (CRAMP).
Condition 13 of the Licence defines the Agency requirements in respect of both the
formulation of the RMP and the actions to be taken by the Company in
implementing the RMP. Condition 13 is set out below.
Condition 13. Residuals Management
13.1 Following termination, or planned cessation for a period greater than
six months, of use or involvement of all or part of the site in the licensed
activity, the licensee shall decommission, render safe or remove for
disposal/recovery, any soil, subsoils, buildings, plant or equipment, or any
waste, materials or substances or other matter contained therein or
thereon, that may result in environmental pollution.
13.2 Residuals Management Plan:
13.2.1 The licensee shall prepare, to the satisfaction of the Agency, a fully
detailed and costed plan for the decommissioning or closure of the site or
part thereof. This plan shall be submitted to the Agency for agreement
within twelve months of the date of grant of this licence.
13.2.2 The plan shall be reviewed annually and proposed amendments
thereto notified to the Agency for agreement as part of the AER. No
amendments may be implemented without the written agreement of the
Agency.
13.3 The Residuals Management Plan shall include as a minimum, the
following:
13.3.1 A scope statement for the plan.
13.3.2 The criteria which define the successful decommissioning of the
activity or part thereof, which ensures minimum impact to the environment.
13.3.3 A programme to achieve the stated criteria.
13.3.4 Where relevant, a test programme to demonstrate the successful
implementation of the decommissioning plan.
13.4 A final validation report to include a certificate of completion for the
residuals management plan, for all or part of the site as necessary, shall be
submitted to the Agency within three months of execution of the plan. The
licensee shall carry out such tests, investigations or submit certification, as
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requested by the Agency, to confirm that there is no continuing risk to the
environment.
LTAI are now required to implement the RMP for the decommissioning and closure
of the site. The specific requirements of the above Conditions are addressed in this
Audit and Validation report.
3.0 BACKGROUND INFORMATION
LTAI is a wholly owned subsidiary of Lufthansa Technik AG (LHT) which is one of the
world’s largest civil operators in the aircraft engine and component maintenance
industry. The Company operated an engine overhaul and test facility at its facility in
Rathcoole, Co. Dublin from 1980 to 1996 on behalf of Aer Lingus and from 1996 to
2014 after acquiring the company and site. From 1976 to 1980, a similar facility was
operated by Airmotive Ireland. It is a service company which was involved in the
overhaul and maintenance of commercial jet engines from airlines around the world.
The three main engine types overhauled were the JT9D, which is used on the Boeing
747 aircraft, and the CFM 56 engines.
The total area of the site is approximately of 50,000 m2, comprising 19,000 m2 of
buildings and 31,000 m2 of site roads, car parks, paved areas and loading bays. The
main building consists of approximately 16,250 m2 floor area with various
workshops, stores, offices and facilities services. A large portion of the main plant
building was used for the dis-assembly and re-assembly of engines. There is also a
separate Engine Test Cell, which was used to test the engines once repair and re-
assembly were completed. A detailed description of the twenty-two unit processes
carried out in each area of the site is contained in Attachment 9 of the IPC Licence
application.
The Closure Plan envisages that all plant, machinery, tools, supplies will be re-
located to sister companies or sold at Auction; any residual materials will be
scrapped. Some Utilities will be retained on site as it is planned to sell the building
and prospective buyers will require heating and similar facilities. A list of items to be
retained for this purpose is summarised as follows and detailed elsewhere in this
report: boilers, water heaters, generators, air conditioning and refrigeration plant.
4.0 METHODOLOGY
The Implementation Plan for the ICA is summarized as follows.
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Task 1 Review of existing information
TMS Environment Ltd personnel have reviewed the available documentation. This
review sought to ensure that all necessary areas of specific interest in terms of either
historic incidents or the potential for historic or future pollution are identified and
considered in the Audit. The documentation included, but is not limited to the
following:
IPPC Licence Application Submission
IPPC Licence Reg 275-01 as amended
RMP and associated correspondence with EPA
Soil and groundwater investigation reports
Bioremediation Trench report
Groundwater Monitoring reports
Bund Integrity Test Reports
Pipeline and drain test reports
Waste Register
Waste Shipping, Transfer and Disposal Documentation
Asbestos Survey Report
PCB Report
Waste Removal & Decontamination Contractor Implementation Report
Task 2 Site audit and personnel interviews
An audit of the site was completed and interviews with the Manager Facilities &
Accessories and the Environmental Health & Safety Co-ordinator were conducted on
several dates in March – May 2014.
Task 3 Preparation of ICA Report
This report presenting the findings was prepared. The report documents all of the
work carried out. A separate Hydrogeological Report forms part of the overall ICA
Report and it includes the Conceptual Site Model and Source Audit / Preliminary Risk
Assessment / Preliminary Site Assessment required by the EPA. The final Validation
report will also include a verification of satisfactory execution of the required works.
The ICA and preparation of the Validation Report was carried out by the following
personnel:
Dr Imelda Shanahan, C Chem MRSC, FICI Lead Auditor
Craig O’Connor, BSc MSc PGeo EurGeol CGeol FGS Senior Hydrogeologist
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Craig O’Connor is a senior hydrogeologist with over 15 years experience who is the
principal Technical Resource for the ICA. Craig is responsible for the elements of the
audit that deal with the assessment of potential for soil / groundwater
contamination. The Hydrogeological Report and associated information is presented
in a separate report, TMS Environment Ltd Report Ref 21102.
5.0 AUDIT FINDINGS
5.1 Audit and RMP Overview
The Audit was carried out in stages by Dr Imelda Shanahan and Craig
O’Connor. Multiple visits to the site took place to gather information, to
advise on elements of work being undertaken, to review the work
undertaken by the Company and by the Waste Contractors and to verify that
specified works had been completed. Site visits for Audit purposes took place
on the following dates: 23rd January, 5th March, 16th April, 8th, 21st and 28th
May 2014. In addition, information provided by LTAI was reviewed off-site
prior to and / or during completion of the Audit. The following personnel
were interviewed and provided information for the Audit Team:
Manager Facilities & Accessories, Stephen McFadden
Environmental Health & Safety Co-ordinator, Paul Callaghan
Technical Director, Stefan Schmuck
The areas addressed by the RMP and the manner in which they have been
addressed are summarised as follows. A Waste Disposal Contractor, Enva,
was retained to manage the decontamination of equipment, sumps, trenches
etc and the removal of all chemicals, materials and hazardous wastes off site.
KMK Metals Recycling were subcontracted to take the WEEE and metals. That
work was completed during March, April and May 2014. An Auction House
(HGP Auctions) was retained to Auction the contents of the facility and to
ensure that any residual materials not suitable for sale were scrapped in
accordance with the procedure for disposal of obsolete equipment. A
summary of the main procedures followed in the Decommissioning
Programme is presented here and a more detailed discussion is presented in
the following sections of the report.
1. Materials
A List of materials used on site was submitted to the EPA as part of the
Licence Application Process and updated in the RMP. Some materials were
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transferred to LHT Hamburg, some were returned to the suppliers (principally
gases) and the remainder were taken by Enva and disposed of and/or
recovered with credit issued for same. Detailed information is presented in
the following sections of this report.
2. Equipment & Processes
Some major items of equipment were returned to LHT Hamburg for reuse.
Most of the equipment was sold at Auction and any remaining unsold items
were scrapped, or will be scrapped before end July. Any items already sold in
Phase I of the Auction must be removed from the site by 13th June, although
some larger units (eg Kardex Units) will not be removed until end July by
agreement. Any items which had a potential environmental impact will have
been removed by 13th June. A Phase II Auction will take place in late June –
early July and any remaining items after that date will be scrapped. All
equipment was decontaminated, where required, before shipping / disposal,
and records were maintained. Some items of plant (principally heaters, diesel
generators, boilers, air conditioning units and refrigeration plant) were
retained on site for use by a future site owner. A List of the retained plant
and equipment is presented in Appendix I.
3. Environmental Incidents
There have been some environmental incidents at LTAI going back to 1991
which were discussed in Section 9 of the LTAI IPC licence application. Since
receipt of their IPC licence LTAI had one incident in June 1999 involving
discharge of ca. 500 litres of effluent into a trench excavated for the
installation of a new sewer. The incident was reported to the EPA and
managed to ensure that no environmental risk occurred. There were no
other incidents recorded. These matters are discussed in detail in the
Hydrogeological Report (TMS Environment Ltd Report Ref 21102) which
accompanies the ICA Report.
4. Environmental monitoring
Environmental monitoring is carried out in accordance with the conditions
set in the IPC licence and includes routine monitoring of emissions to
groundwater, sewer, surface water and air. The monitoring is designed to
identify any impact associated with the operation of the facility so as to allow
effective remedial action and prevent or minimize environmental pollution.
Monitoring reports were reviewed and considered as part of this Audit.
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5.2 Implementation of Decommissioning Plan: Materials
All materials, component parts and wastes in use at the facility were stored in
the areas indicated on Figure 5.1 Materials Locations as submitted in the
RMP. The information contained in this Drawing was reviewed with LTAI
personnel and confirmed as an accurate representation of the storage areas.
The cyanide store had been removed to an external Chem Store Unit which
was decommissioned after decontamination and sold. The following major
actions have been taken:
Materials and component parts were removed from site for use at
another LHT site, returned to the supplier or have been disposed of or
recovered by a licensed waste disposal contractor.
All wastes on site were removed for recovery / treatment / disposal at
a licensed waste management facility.
All wastes generated in the decontamination programme were
removed for recovery / treatment / disposal at a licensed waste
management facility.
A list of the main materials expected to be disposed of in the event of the
activation of the RMP was presented in Appendix I of the RMP, and Table 5.1
in the RMP gave an estimate of the maximum quantities of consumable
materials, broken down by generic types ,that it was expected would need to
be removed off-site in the event of activation of the plan. The actual
quantities disposed of are also presented in Table 5.1 below for comparison
with the estimates presented in the RMP.
Table 5.1 Quantities of Consumable Materials Removed Off-Site
Type of Material RMP Estimate for
disposal, Tonnes
Actual Amounts
disposed of, Tonnes
Oils 2.8 14
Solvents 3.1 1.7
Adhesives 0.4 0.73
Acids 0.8 37
Alkalis 1.4 51
Paints 0.5 1.9
Fuel 131.7 60
Cyanides 0.2 6.8
Metal Compounds 2.1 14
Gases & Non fuels 14.4 64.5
Total 157.4 251.6
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Residual fuels were taken with all other materials and wastes by Enva and
credits obtained for their recovery while gases were returned to BOC Gases.
The RMP estimate of 157.4 tonnes of materials is lower than that actually
disposed of. The main reasons for the differences are that (a) wash waters
and decontamination rinses were included and (b) there were some higher
stock figures. In addition, a significant quantity of microfiche and disk records
was removed by KMK Metals Recycling for destruction and disposal.
Records are maintained in the detailed Waste File which is described here.
The file contains a Register of Waste (Appendix II) which also contains all of
the associated shipping and transfer documentation and, where available,
the disposal certificates. The Register contains the following information for
each item and shipment:
Waste Transfer Form (WtF) Number
WtF date
Proposal Number
Item
EWC Code
Quantity
Weight
Drum identification Number
Container Type
Disposal Date
TFS Number
Destination
Disposal Method
Some items have not yet been shipped to the final destination or disposed of
as the Waste Contractor (Enva) will be including these with other similar
wastes in a bulk shipment. The Documentation Identifiers will allow the items
to be tracked and Enva are also licenced by the EPA. The Waste File is divided
in to Open and Closed Sections where the Open Section is still waiting for
final disposal documentation. I have reviewed the File and I am satisfied that
the Register is complete and allows for verification that the small number of
remaining actions are completed satisfactorily.
A small amount of waste remains in the Wash Bay in suitable drums. This is
because some items were left with gear oil etc to allow prospective buyers to
see the equipment running. Any remaining fluids are being removed prior to
shipping off site and when the final work is complete Enva will remove the
remaining drums of waste.
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5.3 Implementation of Decommissioning Plan: Equipment & Processes
Some equipment was transferred to other LHT sites after cleaning and
decontamination was completed. The main items transferred were (a) Tools,
(b) Engines (c) Components and (d) X-Ray and other Equipment including the
Shot Blasters. The Radiological Protection Institute of Ireland (RPII) were
contacted by LTAI and advised that they had no concerns about the removal
of this equipment. Enva removed all fluids and oils for disposal prior to the
equipment being prepared for shipping to Germany. The remaining
equipment was Auctioned and any remaining unsold items were or will be
scrapped before end July.
The following sections, in the same order as presented in the RMP, identify
the decommissioning and decontamination stages of the main items of plant
and equipment at the site as appropriate. A summary of the wastes removed
by category is presented in Table 5.2.
1. Wash Bay & Engine Bay
i. All used cleaning chemicals were removed from the Wash Bay and
disposed of by Enva. Stock Cleaning chemicals were taken back by the
supplier.
ii. The Wash Bay sump was decontaminated and integrity tested as
described in Section 5.5. Visual inspection by TMS confirmed
satisfactory completion. The oil water interceptor was emptied and
cleaned. Contents were disposed of by Enva.
iii. All engines had already been removed to storage as work was
completed. Components were removed from the engine bays and
Auctioned.
iv. Waste oil and spent hydrocarbon solvent cans were removed by Enva.
2. Cleaning Shop
i. All chemicals and tank contents (phosphoric and nitric acids, caustics
(sodium hydroxide and potassium permanganate) and rinse tank
contents were disposed of by Enva.
ii. All sixteen 5,800 litre tanks and associated components and pipework
were decontaminated prior sale at Auction and removal off-site. Visual
inspection by TMS confirmed satisfactory completion. Sold items will
be fully removed by 13th June and any residual material from under the
equipment will be collected and disposed of by Enva.
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iii. The Trench under the tanks was decontaminated, pressure-cleaned and
integrity tested as described in Section 5.5.
3. Non-Destructive Testing (NDT)
This inspection line consisted of five testing procedures:
Fluorescent Penetrant Inspection: Post-Emulsified Line,
Fluorescent Penetrant Inspection: Electrostatics Line,
Magnetic Particle Inspection,
Ultrasonic/Eddy Current/X-ray Inspection,
Mini-NDT.
i. All of the chemicals (kerosene, photographic chemicals, silver,
penetrant dyes (Ardrox) and powder)were disposed of by Enva.
ii. All tanks were emptied, cleaned and decontaminated by Enva. Visual
inspection by TMS confirmed satisfactory completion.
iii. Ductwork on the Electrostatics Line was inspected by CCTV to verify
cleanliness.
iv. The NDT line was sold at Auction.
4. Stripping & Electroplating
i. The electroplating shop contains forty one tanks and the Line was sold
at Auction.
ii. All rinse tank contents were disposed of to sewer
iii. All other acid, alkali and cyanide solutions were disposed of by Enva.
iv. Each tank was decontaminated by Enva. The wash water was directed
to the on site waste water treatment plant for treatment prior to
discharge to sewer.
v. Visual inspection by TMS confirmed satisfactory completion.
5. Machine Shop
i. The machine shop contained several machines used for grinding,
milling, turning and machining various metallic parts. All of these
machines were sold at Auction.
ii. All spent coolant was removed from the machine shop and disposed of
by Enva.
iii. There is a residual amount of gearbox oil in some machines which was
left in place to allow buyers see the machines running. Any remaining
oils are being removed and drummed before removal from the site and
the waste will be disposed of by Enva.
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6. Plasma Shop
i. The plasma shop used various metallic and ceramic powders to coat
components. The powders were disposed of by KMK Metals Recycling.
Full details are presented in the Waste File.
ii. The shop and associated air abatement equipment was
decontaminated by Enva to remove any hazardous plasma dusts prior
to sale. All items were sold at Auction.
iii. Visual inspection by TMS confirmed satisfactory completion.
7. Peening
i. The peening process gives rise to dusts which were collected and
disposed of by Enva.
ii. Equipment from this area was sold at Auction.
8. Painting
i. Paints and solvents and thinners were disposed of by Enva.
ii. The painting booths (one dry filter and two dry booths) were
decontaminated by Enva and any residual matter disposed of as waste.
Visual inspection by TMS confirmed satisfactory completion.
iii. The booths were sold at Auction.
iv. Filters were disposed of by Enva.
9. Welding, Minor Repairs, Rubber Shop, Blasting and Airfoil Shop
i. These five areas generate minor quantities of oils, greases, adhesive
tubes, sealants and resins and aluminium oxide. All of these materials
were disposed of by Enva.
ii. The main items of equipment were sold at Auction.
10. Bearing Cleaning & Inspection
i. The aqueous cleaner was emptied and decontaminated and the
contents disposed of by Enva.
ii. The Cleaner was sold at Auction.
11. Electro pneumatic Shop & Pneumatic Components
i. All materials i.e. small quantities of oil and adhesives were disposed of
by Enva.
ii. Machinery and equipment was sold at Auction.
12. Non Hazardous Test Area, Quick Engine Change & Gearbox Shop
i. These areas use small quantities of oils and solvents all of which were
collected and disposed of by Enva.
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ii. The equipment was sold at Auction.
13. Fuel Shop & Hazardous Test Area
i. Both of these areas used hazardous materials i.e. white spirits, sodium
hydroxide, penetrant dyes and calibrating fluid. All of these materials
were disposed of by Enva.
ii. Equipment, including the 3 main Test Rigs, was decontaminated by Enva
and sold at Auction.
14. Engine Test Cell
The engine test cell comprises six areas:
Preparation room,
Control room,
Air intake facility,
Engine test chamber,
Exhaust facilities,
Fuel storage area.
i. The drains from the Engine Test Cell were cleaned out and the contents
disposed of by Enva.
ii. The oil interceptor from the Engine Test Cell was emptied by Enva after
the entire Engine Test Cell had been washed down to remove any waste
oils.
iii. The walls of the exhaust Unit were cleaned to remove carbon deposits
which was disposed of by Enva.
iv. Unused fuel in the two 227 m3 storage tanks was recovered by Enva and
a credit received.
v. The fuel tanks were degassed and decommissioned by Enva and Sold at
Auction.
15. Boilers and Utilities
The boilers and water heaters have been retained for use by any future
site owner. The Wanson Boiler System and Lines was thoroughly
decontaminated by Enva and waste disposed of by Enva. The system is
being left in place but was thoroughly decontaminated as part of the
Decommissioning Plan.
16. Effluent Treatment Plant
The effluent plant was the last major item of plant to be
decommissioned. The plant was used to treat wash water generated in
plant and equipment decontamination. Following completion of the
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decommissioning, all effluent was pumped out of the treatment plant
and disposed of by Enva prior to decommissioning the plant. The
underground structures were integrity tested as described in Section 5.5
Visual inspection by TMS confirmed satisfactory completion.
17. Fire Suppression System
The Fire Suppression System was not formally identified in the RMP but is
addressed under the general heading Equipment and Processes.
Automatic Fire & Integrated Solutions Dublin issued a Certificate for the
removal of the INERGEN/FM200 Fire Suppression Cylinders, including
the larger-scale systems in the Engine Test Cell, from site. A second
INERGEN System in IT will be decommissioned in mid-July after the
system is closed down. The smaller fire extinguishers etc will remain in
place for a future site owner.
18. Medical / Clinical waste
The Company Occupational Health Nurse was responsible for ensuring
that all Clinical and Medical waste from the Medical Centre was disposed
of. Records of all disposals were maintained and three separate Files
were viewed as well as the Medical Centre Rooms. The Centre was closed
in January and all waste had been removed by Sterile Technologies in
December 2013.
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Table 5.2 Summary of Materials Disposed Of by Area
Area Material Quantity Disposed of, tonnes
Wash Bay & Engine Bay Ardrox 1 900 B /Ardrox 185 Waste oils
4.0 3.0
Cleaning Shop Ardrox 185 Ardrox 1873 Ardrox 188
Phosit/Ardrox 6376 Ardrox 6333
Washings & wipes
20.3 6.2
16.5 12.4 2.4 3.3
Non Destructive Testing Fluorescent Penetrants 29.7
Electroplating Shop Nickel Strip Alocrome 1200
Nitric Acid Silver Strike Silver Plate
Nickel Strike Nickel Plate
Hydrochloric Acid Alkali Cleaner Chrome Strip
Wax DeWax
Washing & wipes
1.0 3.2 2.8 3.5 2.6 2.9 2.9 5.4 5.6 4.3 0.2 2.8 7..2
Machine Shop Coolant 7.7
Plasma Shop Metallic Plasma Powders 2.2
Peening Dusts 0.4
Paint Shop Paints Solvents
1.3 1.5
Welding, Minor Repairs, Rubber Shop, Blasting & Airfoil Shop
Oils Adhesives
Aluminium Oxide
0.6 0.7 5.7
Bearing Shop Ardrox 4181L/ Ardrox 185L 2.8
Electro Pneumatic Shop & Pneumatic Components
Oils Adhesives
0.03 0.15
Non hazardous Test Area, Quick Engine Change & Gearbox Shop
Oils Solvents
0.113 0.5
Fuel Shop & Hazardous Test Area White Spirits Alkaline Rust Remover
Penetrant Dyes Calibrating Fluid
0.17 0.05
0 0.8
Engine Test Cell Oil Fuel
1.3 60
Boilers & Utilities Gas/Transformer Oils 11.2
Effluent Plant Effluent 12.2
Total. 251.6
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5.4 Implementation of Decommissioning Plan: Enva Site Decommissioning
Report
Enva were awarded the Contract to decontaminate the site and all tanks and
equipment as well as removal of chemical wastes and hazardous chemicals,
materials and fuels. They completed the work during March – May 2014 and
their decommissioning report is presented in Appendix III. A summary of the
main stages is presented below.
1. Hazardous chemicals from the Cleaning Shop and Plating Shop were collected
and removed for off-site disposal. The tanks were rinsed clean and finally
tank entry was undertaken to wash down all side walls and floors. pH tests
were carried out on the final washings taken from every bath and the
cleaning process completed until the washings were neutralized. The cyanide
baths were decontaminated by using an oxidizing agent to oxidize the
Cyanides to the more stable Cyanate state to aid the decontamination
process. All floors and drains in this section of the building were power hosed
until clean and finally a CCTV survey was undertaken by Enva to demonstrate
that they had been cleaned to the highest standards possible. Photographs
were taken to demonstrate the work undertaken by showing the initial and
cleaned state of the structures.
2. The wet and dry spray Booths were cleaned and all waste and filters removed
for off-site disposal. ATEX-rated equipment was used where required.
3. The NDT Line baths were emptied and thoroughly cleaned to remove traces
of contaminants. Again the trench under the lines was cleaned and a CCTV
survey undertaken to verify cleanliness and the integrity of the drain.
4. The fuel tanks at the Engine Test Cell were emptied, fuel was recovered off-
site and the tanks were cleaned and decontaminated. Carbon deposits on the
Engine Test Cell exhaust were cleaned off and disposed of as waste.
5. Waste Transfer Forms issued by Dublin City Council were completed for all
off-site removal of waste and copies were given to LTAI for their records.
[Appendix II and Waste File]. Most of the waste was treated at the Enva
facility in Shannon but some hazardous wastes eg cyanides were exported
under TFS to Germany for treatment and disposal.
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6. All tanks and lines from the tanks to the waste water treatment plant were
cleaned and a full CCTV survey was undertaken to verify integrity and
cleanliness.
5.5 Implementation of Decommissioning Plan: Underground structures and
conditions
The Hydrogeological Report contains a detailed assessment of the
significance of underground structures and the assessments and tests carried
out. This section of the report describes the work done and outlines steps
taken to verify the work.
1) Geophysical Survey
The main Production Building has a surface area of ca. 19,000m2. The
concrete slab is up to 200mm thick in areas and visual inspection
indicated that the slab is in good condition throughout.
In order to inspect the subsurface condition of the concrete floor slab
beneath the main building, Minerex Geophysics Ltd (Minerex) undertook
a Ground Penetrating Radar (GPR) survey of selected areas within the
building in April 2014. The areas selected for GPR survey were areas
where fuels/chemicals were used or stored in the production process i.e.
Paint Shop, Cleaning Shop, Electroplating Shop, NDT Line, Bearing
Cleaning Room, Fuel Shop Service Areas, Hazardous Test Area and Non-
Hazardous Test Area.
The survey results showed that the concrete slab is c. 200mm thick and in
excellent condition, with no evidence of breaks or internal damage
(Appendix II of the Hydrogeological Report).
There are some gaps in the GPR survey of the slab where fixed equipment
could not be moved; these areas were visually examined for
condition/signs of contamination by the decommissioning contractor
Enva Ireland Ltd (Enva) following equipment cleaning and removal and by
TMS Environment Ltd to verify conditions. There was no evidence of any
damage to the slab and therefore no evidence of a pathway for spillages /
contaminants to break-through the slab to the sub-surface.
2) CCTV Surveys
Enva carried out CCTV surveys of all foul and process drains throughout
the site in April / May 2014. The drains were found to be in good
condition; the PVC alkaline process drain in the main building was
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deformed (but not broken) in three sections which required re-lining.
Structural defects were found in the PVC foul drains at three points within
the plant which were re-lined. There were no leaks and no potential for
environmental pollution was identified. The CCTV Survey reports are
archived for EPA review if required. A Map showing the areas surveyed is
attached in Appendix V.
The previous CCTV report in 2012 identified three areas which required
work. Horizon Environmental carried out two of the repairs and the third
was completed by Rilta (a section of the Acid Line) in May 2013 and
agreed with the EPA.
3) Hydrostatic and Pressure Tests
Enva carried out hydrostatic and pressure tests on all foul and process
drains throughout the site in April 2014. 6 No. process drain sections and
6 No. foul line sections failed the pressure tests indicating leaks. These
sections were re-lined and re-tested and the sections passed the post-
repair pressure tests. All foul and process drains were integrity tested in
August 2013 and passed the tests; the integrity testing report is filed on
site and was reviewed. It is likely that the higher pressure used in the
current tests may have caused weaknesses and these were all identified
and repaired. The drains did not contain any chemicals / effluent having
been thoroughly cleaned and decontaminated before testing so there
was no potential for environmental pollution arising from the tests. The
Survey reports are archived for EPA review if required. A Map showing
the areas surveyed is attached in Appendix V.
4) Sump & Trench Integrity Tests
LTAI personnel undertook integrity tests in all process sumps/trenches in
March / April 2014 following cleaning by Enva. The Sumps / Trenches
inspected were as follows:
Alkaline sump at effluent plant
Acid sump at effluent plant
Main trench at NDT line
Two (no.) sumps at alkaline compound
2 (no.) sumps at Acid compound
2 (no.) sumps at serviceable compound
Trench and Sump at Wash Bay
Trench in Cleaning Shop
Trench in Plating Shop
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The sumps/trenches were first checked visually for signs of damage and
then filled with water for 24 hours and any level drop noted. The
sumps/trenches were found to be in a satisfactory condition and no
damage/leaks were noted or detected. The Assessment Report and the
photographic records of the assessments are attached in Appendix IV. A
Map showing the areas surveyed is attached in Appendix V.
5) Bund Integrity Tests
The Cadmium Recovery Bund was decommissioned by Enva and
scrapped. This work was carried out and reported to the EPA separately
from the main decommissioning programme at the start of 2014. The last
integrity test was carried out in 2011 and no leaks / issues were
identified. All of the bunds not linked to the heating systems (eg Engine
Test Cell etc) were emptied and decontaminated, the tanks were emptied
and decontaminated and the valves have been left open so that rainwater
does not collect.
5.6 Implementation of Decommissioning Plan: Other Waste Categories
All Laptops and PCs were sold at Auction and as noted elsewhere, any items
not sold will be scrapped by end July by the Auction House. Any remaining
WEEE and batteries will be taken by KMK Metals Recycling. Lamps and
fluorescent tubes went to Irish Lamp Recycling. Rags and wipes from the
Decommissioning Works were removed by Enva. Non-hazardous C&D waste
is being collected by Greenstar. The Grease Trap in the Restaurant was
decontaminated and waste disposed of by Enva. These Waste categories are
summarised at the end of the Waste Register (Appendix II).
6.0 ASBESTOS SURVEY, REGISTER AND REPORT
A comprehensive survey of Asbestos present in the facility was carried out by
McAllister Devereux Keating Limited (MDK). The full report and Asbestos Register is
attached in Appendix VI. The report recommended that most of the asbestos be
managed in situ since No specific environmental / health & safety risk was
presented. Two items which the report recommended be disposed of were
collected by Rilta and ultimately disposed of by Buhck in Germany. These were two
stored sheets of gasket material in the Boiler Room and the black step nosing from
two indoor stairwells. The Waste Transfer and Disposal documentation were
reviewed and are retained in the Waste File.
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7.0 PCB SURVEY
A survey of items of plant that potentially contain PCBs was undertaken by LTAI with
assistance from various bodies. The survey report is attached in Appendix VII and
concluded that there were no PCBs left on site. Following a site visit from the EPA,
the conclusions were agreed.
8.0 RESIDUAL MATTERS FOR ATTENTION AND RECOMMENDATIONS
A small number of matters remain to be addressed as noted in this report. For
example, not all of the final disposal documentation for all wastes had been received
at the time of the Audit. As noted in the relevant sections of this report, we are
satisfied that the necessary procedures are in place to ensure that all waste
shipments can be satisfactorily tracked and that the correct procedures have been
followed. We are also satisfied that the decontamination works for all plant,
equipment and machinery were undertaken correctly and that there is no residual
risk of environmental pollution. Any remaining wastes are ebing stored in the correct
drums in a bunded area and will be collected and disposed of by Enva. All of the sold
equipment has not yet been removed from site but we are satisfied that the
decontamination works were effectively executed and that there is no remaining
environmental risk.
Matters related to the ongoing assessment of potential soil and/or groundwater
pollution are addressed separately in the Phase I Hydrogeological Report which has
already been presented to the Agency and in the Phase II Works which are in
progress and will be reported separately.
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