Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report September 2009 Final. Issue No / CKOT0005

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1 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report September 2009 Final Issue No / CKOT0005 Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF

2 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report Project Title: Eastman Chemicals, Grannagh, Co. Kilkenny Report Title: Annual Environmental Report Project No: Report Ref: Status: Client Contact Name: Client Company Name: Issued By: CKOT0005 Final Daan Touw Eastman Chemicals Luxembourg SARL URS Ireland Euro Business Park Little Island Cork Ireland Tel: Fax: Document Production / Approval Record Issue No: 1 Name Signature Date Position Prepared by Edel O'Hannelly 17/09/09 Senior Hydrogeologist Checked by Kevin Forde 17/09/09 Technical Director Approved by Kevin Forde 17/09/09 Technical Director Document Revision Record Issue No Date Details of Revisions 1 17/09/09 Original issue Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Final CKOT0005

3 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Final CKOT0005

4 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report CONTENTS Section Page No 1. INTRODUCTION Description of Activities at the Site Company Organisation for Environmental Management SUMMARY INFORMATION MANAGEMENT OF THE ACTIVITY Environmental Objectives & Targets Environmental Management Programme Pollution Emission Register LICENCE-SPECIFIC REPORTS Quarterly Groundwater and Surface Water Monitoring in OTHER REPORTS ELECTRONIC AER SUBMISSION LIMITATIONS COPYRIGHT FIGURE APPENDIX A - GROUNDWATER RESULTS VS TIME (Q Q4 2008) APPENDIX B - GROUNDWATER RESULTS VS TIME (MW2S & MW2D; ) APPENDIX C - ELECTRONIC AER SUBMISSION 2008 Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page i Final CKOT0005

5 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report INTRODUCTION Name & Location of Site: Eastman Chemicals Luxembourg SARL Grannagh, Co. Kilkenny. GPS Coordinates: 1143N, 2567E IPC Licence Register No. P IPC Class: 5.7, 11.1 Number of staff: 0 NACE Codes: D G Description of Activities at the Site Lawter International Luxembourg SARL established a chemical production facility on the site in Eastman acquired the site from Lawter in The facility manufactured phenolic resin and alcohol solubles for use in printing inks until 2004, when production ceased. The facility had a production capacity of 16,000-18,000 tonnes/annum. The primary raw material used on site was rosin, a naturally occurring compound that was sourced from pine trees. In the production process, rosin was reacted with various chemical reagents to produce a range of intermediate products used in the manufacture of printing inks. Owing to the presence of an incinerator on the site and also the nature of the manufacturing processes, environmental management at the site was regulated by an IPPC licence. The original IPPC licence was issued by the Environmental Protection Agency ( the Agency ) in A revised licence (Register No. P002-02) was issued by the Agency in Production at the site ceased in April 2004, and decommissioning of plant and equipment began soon after. A site inspection was undertaken by the Agency in June The Agency issued a site inspection report which requested that a soil quality investigation be undertaken in certain areas of the site and also that a drain survey be undertaken. This work was completed, and, based on the information obtained from this and earlier work, a Remedial Action Plan (RAP) was developed. The RAP was submitted to the Agency in September 2004, and was implemented between October and December Following completion of the remedial works, the Agency undertook a site inspection and assessed the documentation submitted to them by Eastman in relation to the remedial works (Agency report dated 18 August 2005). A Licence Exit Report was subsequently issued to Eastman by the Agency on 06 September URS has completed quarterly groundwater and surface water monitoring at the site since the second quarter of 2004 (Q2 2004), in accordance with Condition and Schedule Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 1 Final CKOT0005

6 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report (i) of the site s IPC licence. The objectives of the quarterly monitoring rounds (which are on-going) are to assess the environmental quality of groundwater and surface waters at the site and to evaluate temporal trends in contaminant concentrations. Other than the above quarterly monitoring, there were no licence-related activities at the site during The site is no longer in the possession of Eastman and wad bought by local businessmen john Brennan and David Flynn, who were granted planning permission by Kilkenny County Council to redevelop the site as light industrial and commercial units in November 2008, though no redevelopment of the site is understood to have occurred by the time of writing. Eastman retain responsability for contamination issues predating the site sale and for maintenance of the site IPPC licence. 1.2 Company Organisation for Environmental Management Eastman Management: As the site has been closed and sold, there are no Eastman personnel at the site. Environmental management of the site is the responsibility of Mr. Daan Touw (Manager of Health, Safety & Environment for Eastman in Europe), who is based in The Netherlands. Mr. Daan Touw, EMEA HSES Manager Eastman Chemical B.V. Fascinatio Boulevard VA Capelle aan den Ijssel The Netherlands Phone Fax Site Personnel: The facility is no longer operating and there are no Eastman personnel at the site. Environmental Consultants: Eastman has retained the services of URS Ireland Limited as Environmental Consultants. URS have completed quarterly groundwater and surface water monitoring at the site since Q2 2004, completed AERs for 2007 and 2008 and report directly to Daan Touw in The Netherlands. URS Ireland Ltd. Euro Business Park Little Island Cork, Ireland Phone: +353 (0) Fax: +353 (0) Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 2 Final CKOT0005

7 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report SUMMARY INFORMATION There was no activity by Eastman on the site in 2008 apart from quarterly groundwater and surface water monitoring conducted on their behalf by URS, consequently there were no emissions to air, waste waters or sewer arising from the licensed activity during the reporting period. No waste was produced by Eastman at the facility in There was no energy or water consumption by Eastman in There were no environmental incidents or complaints in The two surface water monitoring points, SW1 and SW2 are located at the site boundary, water passing both monitoring points drains into the River Suir. Data from SW1 & SW2 has been used to complete Section 4.2 of the AER Returns Worksheet. Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 3 Final CKOT0005

8 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report MANAGEMENT OF THE ACTIVITY 3.1 Environmental Objectives & Targets Since the licensed activities ceased in 2004, the primary environmental objective at the site has been to reduce organic compounds in soil and groundwater underlying the site to a level that does not pose a risk to the wider environment. This objective was the driver behind the remedial work completed late 2004 and is considered to be achieved. A site-specific risk assessment was undertaken by D.A. Richardson & Associates in 2004 during development of the RAP, which considered the potential environmental and human health risks associated with the pre-remediation levels of volatile organic contamination (PCE, cdce and VC) in soil and groundwater at the site. The risk assessment drew the following conclusions: Based on the results of the risk assessment, there are currently no areas of the site where either soil or groundwater presents an unacceptable risk. While tetrachloroethene in soil does exceed two of its risk-based target levels, those pathways (subsurface soil to indoor air, and the excavation scenario) are not presently complete. Remedial works during site decommissioning in late 2004 removed areas of impacted soil identified as having potential to act as on-going sources of groundwater impact. Based on the work completed by URS at the site (i.e. soil investigations, monitoring and validation of the remedial works in 2004, and quarterly monitoring since Q2 2004), it is considered unlikely that any residual sources of groundwater impact remain that warrant remedial action. This, together with the findings of the 2004 risk assessment, suggests that sufficient remediation has been done to ensure that the site does not pose a risk to the wider environment. Notwithstanding the above, elevated concentrations of certain organic compounds remain in groundwater in some areas of the site, principally downgradient of the former cooling tower area. These elevated concentrations suggest residual groundwater impacts close to areas of soil contamination that were removed in In the absence of significant residual areas of subsurface impact, groundwater quality under the site is expected to improve over time through the processes of natural attenuation. Evidence that these processes are active is discussed in Section Environmental Management Programme The environmental management programme was suspended following closure of the facility in April Pollution Emission Register A PER has not been maintained at the site since it closed in April Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 4 Final CKOT0005

9 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report LICENCE-SPECIFIC REPORTS 4.1 Quarterly Groundwater and Surface Water Monitoring in 2008 The objective of quarterly monitoring is to assess environmental quality of groundwater and surface waters at the site and to evaluate temporal and spatial trends in contaminant concentrations in both groundwater and surface water. Monitoring of six on-site groundwater wells (MW1D, MW2D, MW2S, MW3D, MW5D and MW6D) was undertaken during March, June, August and November In March 2008 and August 2008, groundwater samples were also collected from an abstraction well located on the adjoining Dawn Meats facility (known as GW01). The locations of the on-site monitoring wells are shown on Figure 1. Surface water samples were collected from two on-site locations (SW1 and SW2) during each of the quarterly monitoring rounds. Sampling point SW1 is situated at the discharge point of the Puroflo system, which is located at the southern boundary of the site close to the River Suir. Sampling point SW2 is situated close to the southern site boundary within an open drain that runs along the western site boundary and discharges into the River Suir. The locations of these two sampling points are shown on Figure Volatile Organic Compounds Consistent with past results, chlorinated volatile organic compounds (VOCs) were detected in groundwater at a number of locations in the central area of the site during the reporting period, and also at the two surface water sampling points. The highest concentrations were typically observed in groundwater from monitoring well MW6D. VOCs were not detected in groundwater from the up-gradient well (MW1D) during the reporting period. A number of VOCs were detected at trace level concentrations (<10 µg/l) in groundwater from the down-gradient well (MW3D). Groundwater and surface water analytical results have been compared with the Dutch Intervention Values 1 (DIVs). The DIVs have no legal standing in Ireland but are frequently used as a screening tool and are commonly accepted as guidelines above which a more detailed assessment or remedial action may be required. The following compounds were detected above their respective DIVs during the reporting period: Tetrachloroethene (PCE) was detected above its DIV of 40 µg/l in groundwater from MW6D (all four quarters), MW2D (Q1 and Q4) and SW1 (Q2, Q3 and Q4). 1 Dutch Ministry of Housing, Spatial Planning and Environment. (2000) Dutch Intervention Values. Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 5 Final CKOT0005

10 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report cis-1,2-dichloroethene (cdce) was detected above its DVI of 20 µg/l in groundwater from MW2S (all four quarters), MW5D (Q2), MW6D (all four quarters), SW1 (all four quarters) and SW2 (Q2). Vinyl chloride (VC) was detected above its DIV of 5 µg/l at one sampling location during 2008, SW1 (Q2). Trichloroethene (TCE) was detected at most locations, but did not exceed its DIV of 500 µg/l. The maximum TCE concentration detected during the reporting period was 24.5 µg/l in well MW6D. Graphs showing reported concentrations of individual VOCs, as well as electrical conductivity (EC), and chemical oxygen demand (COD), are included in Appendix A for the period Q through Q Longer-term temporal trends for monitoring wells MW2S and MW2D are included in Appendix B. Trends PCE and cdce concentrations in the data for 2008, compared with 2007, are presented below. The discussion focuses on groundwater monitoring wells MW2D, MW2S MW5D and MW6D, and surface water sampling point SW1, as these are the locations where concentrations of PCE and cdce exceeded DIVs during the reporting period. PCE Concentrations at MW2D and MW6D continued to be variable during Seasonal fluctuation is evident in the data from 2005 onwards for PCE in MW6D in Appendix B, with peak concentrations being observed in the Q2 (June) or Q3 (September) samples each year. PCE concentrations in groundwater from well MW6D continue to be above the DIV. For well MW2D peak PCE concentrations above the DIV were observed in Q1 and Q4 2008, the general pattern has been for annual peak concentrations to occur in Q3 or Q4 each year since 2005, however the PCE peaks in 2007 and 2008 were considerably lower than in At surface water monitoring point SW1, PCE concentrations increased in each quarter from Q2 through to Q Concentrations of PCE at wells MW2S, MW3D, MW5D and SW2 remained below the DIV throughout 2008, consistent with the trend shown in previous years. cdce Declining cdce concentration trends are evident at most sampling locations. An elevated concentration was observed at SW01 in Q2 2008, but the concentration dropped back in both Q3 and Q Seasonal fluctuations are evident in the cdce data for MW6D, with peak concentrations generally being observed in the Q2 (June) or Q3 (September) samples each year since An increasing trend for cdce at MW6D was noticeable from 2004 to June 2007 result. However, cdce results for MW6D throughout 2008 indicate a reduction in cdce concentrations relative to 2007 results. The two wells where VOC concentrations have historically been greatest are shallow well MW2S and bedrock well MW6D, both located on the western side of the former process building and downgradient of the former cooling tower area soil contamination hotspot. Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 6 Final CKOT0005

11 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report There has been a marked improvement in groundwater quality in shallow well MW2S since the remedial work (shallow soil excavation) was completed at the site in 2004, as evidenced by declining VOC and COD concentrations. VOC concentrations at MW6D appear to be fluctuating seasonally, however an overall slight declining trend is evident at this location. The absence of VOCs at elevated concentrations in groundwater from MW3D indicates that any plume of VOCs extending down-gradient from the vicinity of MW6D is relatively localised, and that VOCs in groundwater under the site do not pose a risk to water quality in the River Suir, as concluded by the 2004 risk assessment. There is evidence that natural attenuation is occurring in the bedrock aquifer in the southern portion of the site. Comparing data between the wells in the central area of the site with data for the down-gradient well MW3D indicates: Slightly reducing conditions are evident at MW3D, whereas mildly oxidising conditions are evident in the central area of the site; COD is elevated at MW3D relative to the remainder of the site; Manganese is elevated at MW3D relative to the rest of the site, consistent with the low or absent dissolved oxygen concentrations. MW3D is located downgradient of the former Waste Water Treatment Plant (WWTP), from which in-ground tanks and contaminated soils were removed in The data obtained from surface water sampling points SW1 and SW2 indicate that VOCs are discharging off-site at low concentrations via storm drain pathways. The concentrations of VOCs in these discharges have typically been low during the reporting period (total VOC concentrations typically less than 200 µg/l), and the storm drain flow rates are minor when compared with the flow rate of the River Suir. It is unlikely that the compounds detected at SW1 and SW2 are detectable in the River Suir due to the effects of dilution Semi-Volatile Organic Compounds SVOCs on the standard calibrated suite of compounds reported by the contract analytical laboratory were generally below detection limits in the groundwater and surface water samples analysed during the reporting period. Exceptions were trace (<10 µg/l) concentrations of: Naphthalene, at MW1D and MW2D in Q2 2008; Nitrobenzene, at MW1D in Q4 2008; 3&4-Methylphenol, at MW2D and SW1 in Q4 2008; and 2,4-Dimethylphenol, at MW3D in Q Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 7 Final CKOT0005

12 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report A number of SVOCs were reported as tentatively identified compounds (TICs) in the groundwater samples from wells MW2S and MW3D in all four quarterly monitoring rounds. Trace concentrations (<15 µg/l) of SVOC TICs were also reported in samples MW1D, MW2D, SW1 and SW2 in Q4 2008; MW5D in Q3 and Q4 2008; and MW6D in Q1, Q2 and Q As in previous years, the SVOCs reported as TICs in MW2S and MW3D were predominantly alkyl phenolic compounds. The SVOC TIC reported at highest estimated concentration was phenol, 3-(1,1-dimethylethyl) in MW3D in Q (518 µg/l). These compounds are thought likely to be related to the former processing of resins at the facility. The highest SVOC TIC concentrations reported in 2008 were lower than the highest concentrations reported in 2007 (when p-tert-butylphenol was detected in MW3D at 669 µg/l) and lower again than those reported in 2006 (when in MW2S p-tertbutylphenol had been tentatively identified at a concentration of 1,010 µg/l in Q3). The data indicate the presence of groundwater impact in the vicinity of MW2S and MW3D that is attributable to past operations at the site. MW2S is a shallow well located close to the identified former cooling tower source area of SVOC impact, which was removed during site decommissioning. MW3D lies down gradient of the WWTP source area of SVOC impact, which was also removed during site decommissioning, and is close to the down-gradient boundary of the site. It is possible that the observed concentrations of SVOC TICs are attributable to mobilisation of contaminants into groundwater during the remedial work completed at the site during The observed concentrations are declining over time as a result of the processes of natural attenuation Electrical Conductivity Electrical conductivity (EC) within the bedrock wells is relatively stable for the reporting period (typically between 500 and 750 µs/cm), and the variability of readings between wells during any particular monitoring round was low. Historically, the EC of groundwater in the shallow well MW2S has been markedly higher (greater than 2,000 µs/cm during 2003) than in the bedrock wells. EC readings for well MW2S have been lower in 2007 and 2008, ranging between 855 µs/cm and 1120 µs/cm Chemical Oxygen Demand A declining trend in COD values has been evident in groundwater from MW2S since 2004 (COD 330 mg/l in Q4 2004). Throughout 2007 and 2008, the COD concentration at MW2D has ranged from 23 mg/l (Q1 2007) to 74 mg/l (Q1 2008). Overall, COD values remain highest in groundwater from MW3D, with seasonal fluctuations evident in COD in this well. In previous years the highest COD values were typically detected in Q3 or Q4 of each year, however in 2008 the highest COD concentration was in Q2 2008, 323 mg/l. Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 8 Final CKOT0005

13 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report COD concentrations in MW1D, MW2D, MW5D and MW6D were below the laboratory method detection limit in all four quarterly monitoring rounds. Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 9 Final CKOT0005

14 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report OTHER REPORTS A risk assessment of the potential environmental impact of the tentatively identified alkyl phenol compounds intermittently detected in groundwater a surface water at the site was requested by the Agency in 2008 and was delivered in 2009, outside the reporting period of this AER. Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 10 Final CKOT0005

15 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report ELECTRONIC AER SUBMISSION The Data Input sheets of the 2008 AER electronic workbook submission are included as Appendix C. This data was uploaded in.xml format to the EPA website on 17 September Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 11 Final CKOT0005

16 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report LIMITATIONS URS Ireland Limited (URS) has prepared this Report for the sole use of Eastman Chemicals Luxembourg SARL 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 us. This Report may not be relied upon by any other party without the prior and express written agreement of URS. 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 change. The conclusions and recommendations contained in this Report are 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. Information obtained from third parties has not been independently verified by URS, unless otherwise stated in the Report. Where field investigations have been carried out, these have been restricted to a level of detail required to achieve the stated objectives of the services. The results of any measurements taken may vary spatially or with time and further confirmatory measurements should be made after any significant delay in using this Report. 8. COPYRIGHT This Report is the copyright of URS Ireland Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited. Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Page 12 Final CKOT0005

17 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report Figure Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Final CKOT0005

18 Road Grass MW1D Water Storage Tanks Offices & Factory Floor Electrical Shed Incinerator Shed Nitrogen Tanks MW2D MW2S Incinerator Factory Agricultural land Dawn Meats Facility (GW01) MW6D Factory Loading Bay MW5D SW02 Grass Puroflo Septic Tank MW3D Puroflo Outfall SW01 River Suir CLIENT EASTMAN CHEMICALS LTD. ENVIRONMENTAL CONSULTANTS Key MW1D Deep Groundwater Monitoring Well Location MW2S Shallow Groundwater Monitoring Well Location PROJECT LOCATION GRANNAGH, CO.KILKENNY SW01 Surface Water Monitoring Well Location Buildings Storage tanks DRAWING TITLE FIGURE 1 - SITE LAYOUT PLAN SHOWING MONITORING POINTS. DRAWN SCALE SML NTS TRACED Job No. CHECKED APPROVED MF KF DATE Aug 2009 REV. A

19 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report Appendix A - Groundwater Results vs Time (Q Q4 2008) Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Final CKOT0005

20 Appendix A - Groundwater data for Key Paramenters , former Eastman site Grannagh, Co. Kilkenny (Concentrations in mg/l, elevations in metres above Site Datum) PCE Mar-04 Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov-08 MW2D MW2S MW3D MW5D MW6D SW SW c-dce Mar-04 Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov-08 MW2D MW2S MW3D < MW5D MW6D SW SW TCE Mar-04 Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov-08 MW2D <1 4.6 MW2S MW3D < MW5D MW6D SW VC Mar-04 Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov-08 MW2S <1 <1 MW3D < SW SW <1 <1 ELECTRICAL CONDUCTIVITY Mar-04 Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov-08 MW1D MW2D MW2S MW3D MW5D MW6D COD Mar-04 Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov-08 MW1D < <20 <20 <20 MW2D <20 33 <20 <20 <20 MW2S MW3D MW5D <20 - <20 20 <20 <20 <20 MW6D <20 30 <20 <20 <20 SW <20 <20 <20 <20 SW02 <20 <20 <20 GW Elevation Mar-04 Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov-08 MW1D MW2D MW2S MW3D MW5D MW6D Page 1 of 8

21 Appendix A Eastman Chemicals, Grannagh Tetrachloroethene (PCE) vs Time (Wells where PCE not detected are not shown) MW2D MW2S PCE (µg/l) MW3D MW5D MW6D SW01 SW Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Nov-06 Apr-07 Sep-07 Feb-08 Jul-08 Dec-08 Date URS Ireland Ltd Appendix A.xls

22 Appendix A Eastman Chemicals, Grannagh Trichloroethene vs Time (Wells where TCE not detected are not shown) TCE (µg/l) MW2D MW2S MW3D MW5D MW6D SW Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Nov-06 Apr-07 Sep-07 Feb-08 Jul-08 Dec-08 Date URS Ireland Ltd Appendix A.xls

23 Appendix A Eastman Chemicals, Grannagh cis-1,2 Dichloroethene vs Time (Wells where c-dce not detected are not shown) MW2D c-dce (µg/l) MW2S MW3D MW5D MW6D SW01 SW Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Date Nov-06 Apr-07 Sep-07 Feb-08 Jul-08 Dec-08 URS Ireland Ltd Appendix A.xls

24 Appendix A Eastman Chemicals, Grannagh Vinyl Chloride vs Time (Wells where VC not detected are not shown) VC (µg/l) 15 MW2S MW3D SW01 SW Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Nov-06 Apr-07 Sep-07 Feb-08 Jul-08 Dec-08 Date URS Ireland Ltd Appendix A.xls

25 Appendix A Eastman Chemicals, Grannagh Electrical Conductivity vs Time Conductivity (µs/cm) MW1D MW2D MW2S MW3D MW5D MW6D Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Nov-06 Apr-07 Sep-07 Feb-08 Jul-08 Dec-08 Date URS Ireland Ltd Appendix A.xls

26 Appendix A Eastman Chemicals, Grannagh Chemical Oxygen Demand vs Time COD (mg/l) MW1D MW2D MW2S MW3D MW5D MW6D SW Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Nov-06 Apr-07 Sep-07 Feb-08 Jul-08 Dec-08 Date URS Ireland Ltd Appendix A.xls

27 Eastman Chemicals, Grannagh Groundwater Elevation vs Time Groundwater Elevation (m asd) MW1D MW2D MW2S MW3D MW5D MW6D 2 0 Jan-04 Jul-04 Dec-04 Jun-05 Dec-05 Jun-06 Nov-06 May-07 Nov-07 May-08 Oct-08 Date

28 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report Appendix B - Groundwater Results vs Time (MW2S & MW2D; ) Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Final CKOT0005

29 Appendix B - Summary of Groundwater data since June 1996, former Eastman site Grannagh, Co. Kilkenny (Concentrations in µg/l, elevations in metres above Ordnance Datum (Malin)) PCE Sampling Location Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Mar-03 Jun-03 Sep-03 Dec-03 Mar-04 Jun-04 Sep-04 Dec-04 MW2D MW2S cdce Sampling Location Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Mar-03 Jun-03 Sep-03 Dec-03 Mar-04 Jun-04 Sep-04 Dec-04 MW2D MW2S TCE Sampling Location Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Mar-03 Jun-03 Sep-03 Dec-03 Mar-04 Jun-04 Sep-04 Dec-04 MW2D MW2S EC Sampling Location Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Mar-03 Jun-03 Sep-03 Dec-03 Mar-04 Jun-04 Sep-04 Dec-04 MW2D MW2S COD Sampling Location Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Mar-03 Jun-03 Sep-03 Dec-03 Mar-04 Jun-04 Sep-04 Dec-04 MW2D MW2S GW Elevation Sampling Location Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Mar-03 Jun-03 Sep-03 Dec-03 Mar-04 Jun-04 Sep-04 Dec-04 MW2D MW2S Page 1 of 10

30 Appendix B - Summary of Groundwater data since June 1996, former Eastman site Grannagh, Co. Kilkenny (Concentrations in µg/l, elevations in metres above Ordnance Datum (Malin)) Sampling Location MW2D MW2S PCE Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov Sampling Location MW2D MW2S c-dce Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov Sampling Location MW2D MW2S TCE Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov < Sampling Location MW2D MW2S CONDUCTIVITY Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov Sampling Location MW2D MW2S COD Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov <20 <20 < Sampling Location MW2D MW2S GW Elevation Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 Jun-06 Sep-06 Dec-06 Mar-07 Jun-07 Sep-07 Dec-07 Mar-08 Jun-08 Sep-08 Nov Page 2 of 10

31 Appendix B Eastman Chemicals, Grannagh Tetrachloroethene (PCE) vs Time Wells MW2S and MW2D PCE (µg/l) MW2D MW2S 50 0 Jan-96 Feb-97 Mar-98 Apr-99 Jun-00 Jul-01 Aug-02 Sep-03 Oct-04 Nov-05 Dec-06 Feb-08 Mar-09 Date URS Ireland Ltd Appendix B.xls

32 Appendix B Eastman Chemicals, Grannagh Trichlorothene (TCE) vs Time Wells MW2S and MW2D TCE (µg/l) MW2D MW2S Jan-96 Feb-97 Mar-98 Apr-99 Jun-00 Jul-01 Aug-02 Sep-03 Oct-04 Nov-05 Dec-06 Feb-08 Mar-09 Date URS Ireland Ltd Appendix B.xls

33 Appendix B Eastman Chemicals, Grannagh cis-1,2 Dichloroethene (cdce) vs Time Well MW2D c-dce (µg/l) 100 MW2D 50 0 Jan-96 Feb-97 Mar-98 Apr-99 Jun-00 Jul-01 Aug-02 Sep-03 Oct-04 Nov-05 Dec-06 Feb-08 Mar-09 Date URS Ireland Ltd Appendix B.xls

34 Appendix B Eastman Chemicals, Grannagh cis-1,2 Dichloroethene (cdce) vs Time Well MW2S 40,000 30,000 c-dce (µg/l) 20,000 MW2S 10,000 0 Jan-96 Feb-97 Mar-98 Apr-99 Jun-00 Jul-01 Aug-02 Sep-03 Oct-04 Nov-05 Dec-06 Feb-08 Mar-09 Date URS Ireland Ltd Appendix B.xls

35 Eastman Chemicals, Grannagh Electrical Conductivity (EC) vs Time Wells MW2S and MW2D 2,500 2,000 Conductivity (µs/cm) 1,500 1,000 MW2D MW2S Aug-02 Sep-03 Oct-04 Nov-05 Dec-06 Feb-08 Mar-09 Date

36 Appendix B Eastman Chemicals, Grannagh Chemical Oxygen Demand vs Time Wells MW2S and MW2D 2,500 2,000 COD (mg/l) 1,500 1,000 MW2D MW2S Aug-02 Sep-03 Oct-04 Nov-05 Dec-06 Feb-08 Mar-09 Date URS Ireland Ltd Appendix B.xls

37 Eastman Chemicals, Grannagh, Co. Kilkenny Annual Environmental Report Appendix C - Electronic AER Submission 2008 Eastman Chemicals\ Eastman Grannagh GW 2008\CKOT0005/EO/KAF 17 September 2009 Final CKOT0005

38 Sheet : Facility ID Activities AER Returns Worksheet 16/9/ :12 PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : 2008 REFERENCE YEAR 2008 AER Returns Worksheet 1. FACILITY IDENTIFICATION Parent Company Name Eastman Chemical Luxemburg S.A.R.L. Facility Name Eastman Chemical Luxemburg S.A.R.L. PRTR Identification Number P0002 Licence Number P Version Waste or IPPC Classes of Activity No. class_name The manufacture of paints, varnishes, resins, inks, dyes, pigments or elastomers where the production capacity exceeds 1,000 litres per week The incineration of hazardous waste. Address 1 Fascinatio Boulevard Address VA Capelle ad Ijssel Address 3 The Netherlands Address 4 Country Ireland Coordinates of Location River Basin District NACE Code 2013 Main Economic Activity Manufacture of other inorganic basic chemicals AER Returns Contact Name Daan Touw AER Returns Contact Address dtouw@eastman.com AER Returns Contact Position Manager Health, Safety and Environment AER Returns Contact Telephone Number +31 (0) AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number +31 (0) Production Volume 0.0 Production Volume Units 0 Number of Installations 0 Number of Operating Hours in Year 0 Number of Employees 0 User Feedback/Comments NONE Web Address - 2. PRTR CLASS ACTIVITIES Activity Number Activity Name 3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002) Is it applicable? No Have you been granted an exemption? If applicable which activity class applies (as per Schedule 2 of the regulations)? Is the reduction scheme compliance route being used? PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : 2008 Page 1 of 1

39 Sheet : Releases to Air AER Returns Worksheet 16/9/ : RELEASES TO AIR PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : /09/ : SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS RELEASES TO AIR POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO AIR POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence) RELEASES TO AIR POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year Additional Data Requested from Landfill operators * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below: Landfill: Eastman Chemical Luxemburg S.A.R.L. Please enter summary data on the quantities of methane flared and / or utilised Method Used Designation or Description Facility Total Capacity m3 per hour additional_pollutant_no T (Total) kg/year M/C/E Method Code Total estimated methane generation (as per site model) 0.0 N/A Methane flared (Total Flaring Capacity) Methane utilised in engine/s (Total Utilising Capacity) Net methane emission (as reported in Section A above) 0.0 N/A PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : 2008 Page 1 of 1

40 Sheet : Releases to Waters AER Returns Worksheet 16/9/ : RELEASES TO WATERS PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : /09/ : SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this RELEASES TO WATERS POLLUTANT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO WATERS POLLUTANT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year (rainfall (ref. Met Eireann annual rainfall data for Oak Park Kilkenny 2008)*site area)) x average concentration at emission point SW1 detected in Q1- Q (UKAS accredited laboratory 52 Tetrachloroethylene (PER) E Estimate analysis) Trichloroethylene E Estimate As above Vinyl chloride E Estimate As above * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO WATERS POLLUTANT QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year cis-1,2-dichloroethene E Estimate As Above * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : 2008 Page 1 of 1

41 Sheet : Releases to Wastewater or Sewer AER Returns Worksheet 16/9/ : RELEASES TO WASTEWATER OR SEWER PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_ /09/ : SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button Page 1 of 1

42 Sheet : Releases to Land AER Returns Worksheet 16/9/ : RELEASES TO LAND PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : /09/ : SECTION A : PRTR POLLUTANTS RELEASES TO LAND POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO LAND POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : 2008 Page 1 of 1

43 Sheet : Treatment Transfers of Waste AER Returns Worksheet 16/9/ :21 5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : /09/ : Method Used Name and Address of Final Licence / Permit No. of Final Transfer Destination European Waste Code Hazardous Quantity T/Year Description of Waste Waste Treatment Operation M/C/E Method Used Location of Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) * Select a row by double-clicking the Description of Waste then click the delete button PRTR# : P0002 Facility Name : Eastman Chemical Luxemburg S.A.R.L. Filename : P0002_2008 Draft1.xls Return Year : 2008 Page 1 of 1