Annual Environmental Report 2008, PDM Ltd, Oldmilltown, Kill, Co. Kildare. 24 th March Issue No 1

Transcription

1 Annual Environmental Report 2008, PDM Ltd, Oldmilltown, Kill, Co. Kildare. 24 th March 2009 Issue No 1

2 CONTENTS Section Page No 1. INTRODUCTION General Site & Process Description Site Description Process Description MANAGEMENT OF THE ACTIVITY Environmental Management System PDM Management Structure Schedule of Environmental Objectives and Targets Environmental Management Programme Report Environmental Management Programme Proposal Pollution Emission Register Report EMISSIONS TO ATMOSPHERE EMISSIONS TO WATER Effluent Emissions Introduction Summary of Monitoring Results Discussion of Results Toxicity Monitoring Conclusion Emissions to Surface Water Introduction Summary of Surface Water Emission Monitoring Results Discussion of Results Agency Monitoring Groundwater Monitoring Introduction Groundwater Monitoring Results Discussion of Groundwater Quality Testing and Inspection of Underground Tanks & Pipelines and Bund Integrity Bund Testing Pipeline and Underground Tank Testing and Inspection WASTE Introduction Summary of Waste Statistics NOISE Introduction PDM Ltd i Final

3 CONTENTS Section Page No 7. RESOURCE CONSUMPTION Introduction Electricity Usage Diesel Usage Woodchip Usage Light Fuel Oil Consumption Water Consumption Discussion ENVIRONMENTAL INCIDENTS AND COMPLAINTS Complaints Incidents REVIEW OF RESIDUALS MANAGEMENT PLAN ENVIRONMENTAL LIABILITIES INSURANCE COVER Appendix A PDM Limited Environmental Policy Appendix B Glossary of Terms Appendix C Fugitive Emission Study Appendix D PRTR PDM Ltd ii Final

4 1. INTRODUCTION 1.1. General The following Annual Environmental Report (AER) is prepared for the PDM Limited facility, Oldmilltown, Kill, Co. Kildare in accordance with the conditions of the operating IPPC licence, which states: Condition The licensee shall submit to the Agency, eighteen months from the date of grant of this licence, and each calendar year thereafter, an AER which shall be to the satisfaction of the Agency. This report shall include as a minimum the information specified in Schedule 5 Recording & Reporting to the Agency and shall be prepared in accordance with any relevant guidelines issued by the Agency. The Environmental Protection Agency (hereafter referred as the Agency ) granted the IPPC licence register number 325 (New licence number PO325-01) to PDM Limited ( PDM ) on December 23rd, 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. This AER has been prepared in accordance with EPA guidelines Site & Process Description Site Description PDM is located in Oldmilltown, in the hinterlands of Kill town, in Co. Kildare. PDM is a subsidiary of the French group Saint-Gobain, who were listed in 2003 by Fortune Magazine as the world s 155 th largest company. The site is situated approximately 25km south-west of Dublin city and has been in operation for 40 years, specialising in the manufacture and pressure impregnation of wood with preservative. There is circa 32 people employed at the production plant by the company. The site occupies an area of approximately 16 hectares, with adjacent land owned by the ESB on the western perimeter, and surrounding land use is dominated by agricultural activities. There is a network of open surface water drains occurring across and around the site. The drains tend to follow boundary lines, however regionally surface water flows in a north-west direction reflecting topography. Surface water from the site and the surrounding area discharges to Painestown River, which subsequently PDM Ltd 1 Final

5 discharges to the Morrell River, and finally to the River Liffey located 8 km north-west of PDM Process Description 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. The Osmose Naturewood replaced Tanalith (CCA) in November 2003 as a wood preservative due to recent restrictions in marketing and use of CCA. Site operations may be summarised as follows: Poles are received onto the site. 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 inner bark is removed with dressing machines. The poles are then transferred to the fabrication shed where the poles are fabricated to the required client specification. This is followed by a treatment stage where the poles are pressure treated with creosote or Osmose Naturewood on a batch basis in large pressure cylinders. The treated poles are then stored on concrete pads on-site, prior to delivery to customers. In relation to other timber products, timber is received onto the site and stored in a designated area. Depending on the timber type and moisture content of the timber, drying in kilns may be required at this stage. When the moisture content is correct (i.e. 26%) thus allowing proper penetration of the treatment materials, the timber is pressure treated with creosote or Osmose Naturewood on a batch basis in large pressure cylinders. The treated timber products are then stored in sheds on concrete pads on-site, prior to delivery to customers. *In 2003 the Company changed over plant operations from the use of Tanalith to the new preservative Osmose Naturewood. This was a directive from St. Gobain. 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. 2. MANAGEMENT OF THE ACTIVITY 2.1. Environmental Management System An Environmental Management System (EMS), required under Condition 2.1 of the License, facilitates the management of the environmental impacts of the PDM s activities. The EMS currently includes the following elements: The Environmental Policy; A Schedule of Objectives and Targets; The Environmental Management Programme; PDM Ltd 2 Final

6 The Pollution Emission Register; Programmes relevant to documentation, corrective action, awareness and training, responsibilities and communications. The Environmental Quality Policy is the fundamental building block for the EMS. It serves as the foundation for the rest of the system. This policy sets out the principles, which govern PDMs approach to environmental management. PDM Limited also is accredited to I.S. EN ISO 9001:2000 and ISO and gets audited twice per annum. A copy of the ISO certificate is presented in Appendix A PDM Management Structure The management structure at the PDM facility is detailed in Figure overleaf Schedule of Environmental Objectives and Targets The Schedule of Objectives and Targets submitted as part of the 2007 AER is presented as Table in this report. This table combined with the discussion on individual projects in Section 2.4 of the AER forms the Environmental Management Programme Report for the calendar year The status column in Table has been updated to reflect project progress in Environmental Management Programme Report PDM are required in accordance with Condition of the IPPC licence, to submit an Environmental Management Programme Report, as part of the AER for the reporting period January 2008 to December The EMP report is detailed in the following sections. Refer to Table during the following discussion. Key projects are described. PDM Ltd 3 Final

7 Figure PDM Limited Organisation Chart MANAGING DIRECTOR BRENDAN GIBBONS Financial Director PJ SNEYD Environmental/Quality Manager Catherine O Sullivan Fencing Sales Manager MICHAEL BROGAN WAGES CLERK/PURCHASES Agnes Barry DEBTORS CONTROLLER Nelia Gilligan - AUDITOR -COS - AUDITOR -MB - AUDITOR- PS - AUDITOR- DR - AUDITOR- DK - AUDITOR-MB - AUDITOR-DG - AUDITOR-DG FOREMAN LIAM KELLY - 3 FENCING SALES - 3 PLANT OPERATORS - 1 MAINTENANCE/WWTP - 4 POLES FABRICATORS - 2 POLE DRESSERS - 3 VOLVO DRIVERS - 1 STOCK CONTROLLER SECURITY TRANSPORT CO- ORDINATOR/SALES Tracey Kelly 4 LORRY DRIVERS - F F TEAM -DB - F F TEAM -MB - F F TEAM - JR - F F TEAM - JH - F F TEAM LD - FF TEAM - TH RECEPTIONIST Elayne Thorpe SALES ADMINISTRATOR Claire O Neill PDM Ltd 4 Final

8 Table Schedule of Objectives and Targets for Calendar Year 2008 (presented in 2007 AER) EMP No. Objective Targets Planned Completion Date OB1 Reedbed To arrange a minor clean up of the reedbed. Remove some old reeds and replace with new ones. March 08 Completed March 08 OB2 Stream To organise the collection and disposal of contaminated waste from the rest of the stream and from under all the bunds. August 08 Completed Sept 08 OB3 Review Of Licence To submit to the EPA a revised proposal in regard to the conditions of our IPPC Licence taken into account OCM s report sent to PDM. April 08 On-going OB4 Surface and Ground To complete the implementation of the Groundwater Monitoring Network as Water Protection agreed by the EPA in Dec 08 On going OB5 Interceptor To carry out the integrity test of this bund. May 08 Completed August 08 OB6 Underground Tanks Undertake a programme of testing and inspection of underground tanks and Pipelines and pipelines. May 08 Completed Aug 08 OB7 Waste Water Complete an evaluation of the treatment system to determine its current Treatment Plant loading, design capacity performance and effluent quality. July 08 Completed in July OB8 Fugitive Emissions To carry out more fugitive emissions monitoring and submit findings to the EPA. June 08 Status Completed - Submitted Report in Jan 09 OB9 Boiler Emissions Submit to the EPA a report on the emissions of the boiler. March 08 Completed OB10 Labelling of Timber Introduce a tracking system indicating the batch number and date each timber bale was treated. April 08 Completed May 08 OB11 Storage of Timber Segregate treated and untreated wood waste and assign a code to same. April 08 Completed April 08 OB12 Concrete Pads To clean individual concrete pads once that particular pad becomes empty. On-going On-going PDM Ltd 5 Final

9 OBJECTIVE OB1: CLEAN-UP OF REED BED Overall Target: To arrange a minor clean up of the reedbed. Remove some old reeds and replace with new ones. Scheduled Benefits: Improve the environmental performance of the company; Improved WWTP performance Comply with the requirements of the operating IPPC licence; Minimise risk of emission limit values (ELV) non-compliances Project Summary: In May 2007 Mr. Noel Connaughton from Sligo Institute of Technology examined the reedbed and stated that no modification to the reedbed was required at present. Summary of Work Completed in the Previous EMP: During 2008 a minor clean up of the Reedbed was undertaken. This involved the removal of some old reeds and replacement of same with new ones. Summary of Work to Do in the Forthcoming EMP: General maintenance and upkeep of the reedbed. OBJECTIVE OB2: CLEAN-UP OF STREAM AND BUNDS Overall Target: To organise the collection and disposal of contaminated waste from the remainder of the stream and from under all the bunds. Scheduled Benefits: Implement good housekeeping; Improve the environmental performance of the company; Prevent Soil and Groundwater Contamination. Project Summary: Michael Punch & Partners carried out a report on tank bunds in June 2005 and Jan 2007 as a result of both of these reports it was recommended that there should be removal of contaminated water from the bunds at plant 1 & PDM Ltd 6 Final

10 2. This contaminated water from the bunds at plant 1 & 2 was removed and disposed of appropriately. Cleaning of the stream has been taken place on an ongoing basis over the last two years. Summary of Work Completed in the Previous EMP: PDM have now completed the cleaning of the stream and the removal of the sediment. This took place over two days in September Three full containers were used and a total of 56 tonne were removed. Also removed by Indaver from our site following our maintenance programme was 20 IBC s which were full of waste creosote oil and litres barrels from our standard housekeeping programme. PDM are now in the process of planting some reeds in this stream. Summary of Work to Do in the Forthcoming EMP: Not applicable. OBJECTIVE 0B3: REVIEW OF LICENCE Overall Target: To submit to the EPA a revised proposal in regard to the conditions of our IPPC Licence taking into account O Callaghan, Moran & Associates audit report of the facility sent to PDM. Scheduled Benefits: Reassess emission limit values; Reassess particular sampling as agreed with EPA on present licence; Improve the environmental performance and management within the company. Project Summary PDM plan to submit licence review by the end of Summary of Work Completed in the Previous EMP: A letter was sent to the EPA (June 15 th 2007) requesting a review of our existing licence. They replied in early July stating that on the basis of the information provided to them that a review was necessary and that an application for a review should be submitted to the Agency in Accordance with Section 09 of the EPA Acts 1992 and Possible amendments to the Biocidal Products Directive are pending from the European parliament for the use of Cresote in timber treatment. On announcement of changes to the Directive PDM will pursue with the licence review to include any amendments. Summary of Work to Do in the Forthcoming EMP: PDM Ltd 7 Final

11 Review will be completed during OBJECTIVE OB4: SURFACE AND GROUND WATER PROTECTION Overall Target: To implement the Groundwater Monitoring Network and the groundwater Remedial Strategy as agreed by the EPA in January Scheduled Benefits: Problems with water quality are likely to be highlighted sooner; Increased confidence in water quality data as increased data bank; Minimise on-going off-site migration of PAH contaminated groundwater in the vicinity of the production area. Project Summary: An ongoing objective of the PDM facility is to ensure all effluent and emissions arising onsite and surface and groundwater are monitored and treated appropriately so that the risk of emission limit value (ELV) noncompliances are minimised as a result. As a result of a report submitted to the EPA by PDM on 21 December 2005 Groundwater Monitoring and Review of Remedial Strategy certain recommendations were made such as the decommissioning of MW07 due to contamination with Creosote, the fitting of well caps to all wells and the installation of a hydraulic containment system be put in place. This report was updated by a report submitted in December Review of Remedial Strategy. Recommendations in this report included providing improved secondary containment at the Cresote storage tank filling points, hydraulic testing of the treatment plant bunds and regular inspections, cleaning of drains in the treated timber storage areas and the replacement of MW07 with MW08 and monitoring be carried out at this point on a quarterly basis. Summary of Work Completed in the Previous EMP: In December 2007, PDM submitted an updated proposal to the EPA for the installation of the hydraulic containment system to reduce the potential for off-site migration of PAH contaminated groundwater in the vicinity of MW8. The EPA have proposed a trial period of 1-month (EPA Letter, dated 01/02/2008) and completion of a report on the findings. The report should include, as per the EPA letter, a detailed remediation strategy for the existing contamination and a detailed risk assessment on the potential impacts of a full-scale remediation strategy. The letter also reminded PDM of an EPA letter 13/01/06 requiring PDM to carry out a risk assessment addressing all contamination arising from the site. As part of this Hydraulic Containment strategy, two additional groundwater monitoring wells (MW11 and MW12) were installed by URS PDM Ltd 8 Final

12 in April Hydraulic testing of MW12 was carried out in June 2008, which found MW12 to be a suitable abstraction well for the hydraulic containment system. PDM has requested URS to undertake the final design of the hydraulic containment system. It is intended that the containment system will become operational in Summary of Work to Do in the Forthcoming EMP: The company will continue to analyse water discharge and submit records to the EPA and ensure compliance with the operating IPPC licence. PDM will also continue to implement the recommendations of the Review of Remedial Strategy Report submitted in December OBJECTIVE OB5: INTERCEPTOR Overall Target: To carry out the integrity test of the interceptor. Scheduled Benefits: Comply with the requirements of the operating IPPC licence; To ensure the integrity of all bunded structures onsite; Maintain a high standard of housekeeping on site; Summary of Work Completed in the Previous EMP: The interceptor was subject to integrity testing during the annual plant on the week commencing the 11 th August No issues with the integrity of the interceptor were identified. A report on the results of this integrity test were forwarded to the EPA. Summary of Work to Do in the Forthcoming EMP: Not applicable. OBJECTIVE OB6: UNDERGROUND TANKS AND PIPELINES Overall Target: Undertake a programme of testing and inspection of underground tanks (USTs) and pipelines. Scheduled Benefits: Comply with the requirements of the operating IPPC licence; To ensure the integrity of all USTs and pipelines structures onsite; PDM Ltd 9 Final

13 Maintain a high standard of housekeeping on site; Project Summary: Undertake a programme of testing and inspection of underground tanks (USTs) and pipelines as required under condition of their IPPC licence. Summary of Work Completed in the Previous EMP: Punch & Co carried out integrity testing on the waste storage bund. Hydrostatic testing was completed on all bunds. The waste creosote bund was repaired along with the bund inside the diesel tank. All pipelines were surveillance tested by Meehan Technology during Summary of Work to Do in the Forthcoming EMP: Not applicable. OBJECTIVE OB7: WASTEWATER TREATMENT PLANT Overall Target: Complete an evaluation of the treatment system to determine its current loading, design capacity performance and effluent quality. Scheduled Benefits: Improve the environmental performance of the company; Improved WWTP performance; Comply with the requirements of the operating IPPC licence; Minimise risk of emission limit values (ELV) non-compliances; Summary of Work Completed in the Previous EMP: Samples were taken upstream of the waste water treatment plant and analysed against samples from the discharge point from the waste water treatment plant. All samples were within IPPC licence limits and it was concluded that the waste water treatment plant is working well. Summary of Work to Do in the Forthcoming EMP: Not applicable. OBJECTIVE OB8: FUGITIVE EMISSIONS Overall Target: To carry out more fugitive emissions monitoring and submit findings to the EPA. PDM Ltd 10 Final

14 Scheduled Benefits: Reduce the quantity of fugitive emissions arising from the facility. Improve the environmental performance of the company. Comply with the requirements of the operating IPC licence. Project Summary: An ongoing objective of the PDM facility is to ensure all fugitive emissions arising on-site are minimised. One area of the site identified as a potential source of fugitive emissions is the storage of creosote in the on-site storage tanks. In early 2002, PDM commissioned URS Ireland Limited to undertake a fugitive emissions study at the creosote plants. The results from this study, detailed in Appendix (iii) to the AER 2002, indicate an estimated 23 kg/a of fugitive emissions to atmosphere of creosote. Given the reasonably constant annual creosote consumption, it is assumed that the fugitive emissions are equivalent each year. An additional study was completed in 2005 aimed at verifying the findings of the 2002 report, which was based on computer modelling (TANKS4 software and manual flash calculation), with actual monitoring data. The 2005 report measured losses far less than was predicted in the 2002 study. Summary of Work Completed in the Previous EMP: Several recommendations were made in the 2005 report, including the recommendation to monitor all operational stages to improve the accuracy of the estimate of total fugitive emissions from the production processes at PDM and noting limitations in the sampling carried out in Also taken into account for this assessment were minor changes in the venting process which have occurred since 2005, i.e., the 2 storage tank vents on Plant 1 & 2 were combined and linked to the vapour receiving tank. As a result of this, a comprehensive sampling programme was developed and executed in As a result the annual fugitive emissions from production processes and related activities at PDM of the primary PAH compounds, phenols and BTEX compounds have been characterised and quantified, and recommendations from the 2005 Fugitives Study have been satisfied, to the extent practicable. The percent fugitive losses of input for each compound has been estimated as follows: <1% for PAH s; <1% for phenols; and <12% for BTEX. It has been determined that the fugitive emissions generated due to the operations involving creosote at the site are low in relation to the Solvent Regulations (2002) limit of 45% of solvent input for Wood Impregnation activities. PDM Ltd 11 Final

15 Summary of Work to Do in the Forthcoming EMP: Given the low emission fugitive quantity estimates, no further action has been identified at this point. OBJECTIVE OB9: BOILER EMISSIONS Overall Target: Continue to carry out internal audits and have Saint Gobain carry out an external environment audit. Scheduled Benefits: Maintain high efficiency of the boiler; Identify issues at early stage; Promotes a proactive approach to environmental management within the company. Summary of Work Completed in the Previous EMP: In March 2008 a report was submitted to the EPA on the emissions from the boiler which was carried out by Bord Na Mona on January 31 st It was noted that due to the presence of burning embers in the emission stream, Bord Na Mona recommends that further particulate testing on the stack be carried out using he ESEPA approved method 5 isokinetic sampler which is based on the monitoring principles set out in the European Standard EN A revised monitoring programme was undertaken in July 2008 and the report was forwarded to the EPA. Summary of Work to Do in the Forthcoming EMP: Not Applicable. OBJECTIVE OB10: LABELLING OF TIMBER Overall Target: Introduce a tracking system indicating the batch number and date each timber bale was treated. Scheduled Benefits: Ensures correct storage requirements are followed Reduces potential for soil and groundwater contamination Summary of Work Completed in the Previous EMP: PDM Ltd 12 Final

16 A tracking system is in place on product that has been treated. All bundles of treated timber are labelled with the dimensions and the date of the treatment Summary of Work to Do in the Forthcoming EMP: Maintain tracking system. OBJECTIVE OB11: STORAGE OF TIMBER Overall Target: Segregate treated and untreated wood waste and assign a code to same. Scheduled Benefits: Ensures that treated waste wood is not removed from the site unless through the appropriate waste streams Summary of Work Completed in the Previous EMP: Treated and untreated wood waste is segregated in different areas ensuring any waste wood is disposed of correctly Summary of Work to Do in the Forthcoming EMP: Maintain segregation areas. OBJECTIVE OB12: CONCRETE PADS Overall Target: To clean individual concrete pads once that particular pad becomes empty. Scheduled Benefits: Reduce run off to surface water drain; Reduce odour; Prevent soil and groundwater contamination; Identify faults on pads which require repair; Summary of Work Completed in the Previous EMP: Concrete pads are cleaned as each new batch of timber is removed from the area. Summary of Work to Do in the Forthcoming EMP: Ongoing housekeeping within the concrete pad area. PDM Ltd 13 Final

17 2.5. Environmental Management Programme Proposal A revised Table of Environmental Objectives and Targets is presented in Table It is proposed that Table 2.5.1, in conjunction with the paragraphs Summary of Work to Do in the Forthcoming EMP paragraphs detailed in Section 2.4, will form the Environmental Management Programme for PDM Ltd 14 Final

18 Table Proposed Schedule of Objectives and Targets for Calendar Year 2009 EMP No. OB1 Objective Targets Person Responsible Completion Date Purchasing Re-examine the opportunities of sourcing product from more sustainability sources Catherine O Sullivan/MD Dec 09 OB2 Stream To place reeds in the stream that is now no longer in use. Catherine O Sullivan/Tom Feb 09 OB3 OB4 Review Of Licence Surface and Ground Water Protection To submit to the EPA a revised proposal in regard to the conditions of our IPC Licence taken into account OCM s report sent to PDM To complete the implementation of the Groundwater Monitoring Network as agreed by the EPA in Catherine O Sullivan/URS April 09 URS Dec 09 OB5 Boiler Emissions Carry out another test on the boiler emissions. Catherine O Sullivan March 09 OB6 OB7 OB8 OB9 OB10 OB11 Fugitive Emissions Concrete Yard Training Concrete Pads Groundwater MW5 Audits To submit findings to the EPA on the work carried out by URS on the fugitive Emissions Assess the integrity of the concrete in the drag out areas and make the necessary repairs. Define our training needs with each individual who is directly involved with the environment. To clean individual concrete pads once that particular pad becomes empty. URS/C O Sullivan Jan 09 Catherine O Sullivan Feb 09 Catherine O Sullivan Nov 09 Tom Horan/Liam Kelly On-going Provide a cap for the MW5 monitoring borehole. Tom Horan Jan 09 Carry out at least 3 external audits on those who we sub contract work out to regarding the environment. Catherine O Sullivan Sept 09 PDM Ltd 15 Final

19 2.6. Pollution Emission Register Report The Pollutant and Emission Register (PER) has been succeeded by the Pollutant Releases and Transfer Register (PRTR). Relevant substances on the PRTR will be reported via an EPA web-based system. The completed PRTR worksheet is included in appendix D of this report. PDM Ltd 17 Final

20 3. EMISSIONS TO ATMOSPHERE Condition 5.2 of the IPPC licence Reg. No. P requires the company to submit a summary report of emissions to atmosphere including fugitive emissions. The URS report on fugitive emissions is included in Appendix C. In accordance with the conditions of the operating licence, PDM are not required to monitor emissions to atmosphere. PDM Ltd 18 Final

21 4. EMISSIONS TO WATER 4.1. Effluent Emissions Introduction The PDM facility controls and monitors one licensed effluent emission, emissions point reference no.: E, which discharges directly to the Kill river. This receiving water is situated in close proximity to the PDM site. Condition 6.1, in conjunction with Schedule 1 of the IPPC licence, governs the monitoring and control of final effluent emissions from the wastewater treatment plant to receiving waters. Schedule 1(i) of IPPC licence Reg. No. PO specifies the maximum volume of effluent to be discharged in any one day at 2500m 3, and an hourly discharge licensed at 125 m 3. At the facility, contaminated surface waters may be diverted to a pump sump and balance tank, which channels the surface water to a two-stage aerated lagoon system. Treated water is then polished in a twin-reed bed system. Polished surface water is subsequently discharged, with uncontaminated surface water to the Kill River Summary of Monitoring Results Schedule 1(iii) of the operating IPPC licence requires the company to monitor the final effluent discharge for a range of parameters. All data summarised herein, relates to the period January 1 st 2007 to December 31 st 2007 inclusive, and has been compiled from Emission Monitoring Registers (EMRs), as submitted to the Agency on a monthly basis. Table 4.1 presents the percentage compliance with the relevant parameter. The percentage compliance has been calculated using the following formula: % Compliance = Number of Compliant Samples x 100 Number of Samples 1 PDM Ltd 19 Final

22 Table 4.1: Summary of Monitoring Results for January 2008 to December 2008 Parameter Emission Limit Value (ELV) Average Measured Value 2004 Average Measured Value 2005 Average Measured Value 2006 Average Measured Value 2007 Average Measured Value 2008 Required Monitoring Frequency 2008 % Compliance (2008) Flow m 3 /d m 3 /d 61 m 3 /d m 3 /d m 3 /d 30m 3 /day Weekly % Temperature 2 25 C Continuous - ph Continuous - COD 100 mg/l mg/l mg/l mg/l 39.5 mg/l 37.3mg/l Weekly 100% BOD 25 mg/l < 2.0 mg/l 3.25 mg/l 2.0 mg/l 2.25 mg/l 2.25mg/l Quarterly 100% Suspended Solids 30 mg/l mg/l mg/l mg/l mg/l 10.47mg/l Weekly 100% Phenols 1 mg/l mg/l mg/l mg/l mg/l <0.1mg/l Monthly 100% PAH (Total) mg/l mg/l mg/l mg/l mg/l 0.002mg/l Monthly 8.3% Chromium (Total) 0.5 mg/l mg/l mg/l mg/l mg/l 0.003mg/l Biannually 100% Arsenic 0.5 mg/l mg/l mg/l mg/l mg/l 0.001mg/l Biannually 100% Organic Screen Annually - Toxicity As Required - 1 Average flow was obtained from daily flow readings. 2 Temperature and ph monitoring results were not recorded by PDM as the effluent is composed solely of surface water run-off. PDM has outlined the reasoning behind this decision in correspondence with the Agency. 3 PDM are required to carry out an organic screen on the effluent on an annual basis subject to the agreement of the Agency. PDM have corresponded with the Agency with regard to this matter but are awaiting a response from the Agency. 4 PDM have been in correspondence with the EPA regarding high levels of PAH s in effluent emission. Cleaning of the congested reedbed in April 06 led to slight decrease in PAH levels and further cleaning was carried out in 2008 PDM Ltd 20 Final

23 Table 4.2: Summary of Mass Emissions * Parameter Mass Emissions 2003 Mass Emissions 2004 Mass Emissions 2005 Mass Emissions 2006 Mass Emissions 2007 Mass Emissions 2008 Flow 25,095 m 3 29,960 m 3 22,265 m 3 27,106 m 3 21,943 m 3 21,900 m 3 COD kg kg kg kg 867 kg 817 kg BOD 50.2 kg** 59.9 kg** 72.4 kg** 54.2 kg** 49.4 kg** 49 kg** Suspended Solids kg kg kg kg kg 229 kg Phenols 5.5 kg** 12.9 kg** <0.1 kg** 1.2 kg** 2.08 kg** 2.19 kg** PAH (Total) 1.8 kg** 0.1 kg** 0.9 kg** 0.1 kg** <0.1 kg** <0.1 kg** Chromium (Total) 0.1 kg** 0.2 kg** 0.1 kg** <0.1 kg** <0.1 kg** <0.1 kg** Arsenic 0.2 kg** 0.2 kg** 0.1 kg** 0.1 kg** 0.1 kg** 0.1 kg** * - Mass Emissions were calculated knowing daily parameter concentrations and average effluent flow rates. ** The mass emissions are significantly less than the stated figure, due to the non detectable limits for analysis results. PDM Ltd 21 Final

24 Discussion of Results The overall monitoring results as set out in Tables 4.1 and 4.2 show that all of the parameters, with the exception of PAH, were well below the limits set out in the license. PDM has experienced an ongoing problem of consistently achieving the very high standard of mg/l. The 2008 average result of mg/l is in line with 2007 results and represents a slight improvement compared to 2006 (average value mg/l) and 2005 (0.004 mg/l). The renovation of part of the reed bed in early 2007 and cleaning works carried out in 2008 is likely to have contributed to this improved result. The segregation of effluent and surface water drains has resulted in a situation where the effluent volume, at around 60 m 3 /d, is very much less than the value in the permit (2500m 3 /d). At request of the EPA, new glass sample bottles were used in the composite sample (replacing the older plastic bottle which was considered a potential source of inaccuracy). This does not appear to have significantly effected the results obtained in 2008 and would indicate that previous years results were therefore not impacted significantly by the use of the plastic container Toxicity Monitoring In accordance with requirements of the IPPC licence, in particular condition 6.6 requires the company to determine the acute toxicity of the undiluted final effluent to at least four aquatic species from different trophic levels. PDM carried out toxicity testing on samples of the treated effluent discharged from the on-site treatment plant (emission point E ) in the second half of 2004, the result of which was submitted in the 2005 AER. These results indicated that the treated effluent is of low toxicity to the receiving waters. PDM are required to undertake this toxicity testing only once as per IPPC Licence requirements, hence toxicity testing was not required to be carried out in Conclusion The treatment plant has proved very effective in reducing the concentration of a wide range of contaminants. For PAH also it gives a very large reduction but not always to the required level of mg/l. However, because the daily volume is very much less than the allowed volume the total quantity of PAHs emitted in 2008 was only about one quarter of the load permitted in the license. The PAH issue and the appropriateness of its standard is currently being reassessed and this review will be submitted as part of our upcoming application for an IPPC license to be submitted in PDM Ltd 22 Final

25 4.2. Emissions to Surface Water Introduction In accordance with Condition 9.1 of the operating IPPC licence, monitoring of surface water discharges is conducted at monitoring point locations A, B, and D (Monitoring at Point G was suspended in Feb 2003). These emissions points are detailed in the company s IPPC licence application. Monitoring of surface water discharge from the site at the above 3 locations is conducted to ensure that site operations do not adversely impact on surface waters. Furthermore, the company is required to conduct a daily visual inspection of the surface water emission points. Following correspondence with the EPA (14/2/03), monitoring for PAHs s at A, B, D: was reduced to quarterly. Monitoring at Point G was suspended, as there is no flow at this point Summary of Surface Water Emission Monitoring Results All results of surface water discharge monitoring are detailed in Table 4.3 Table 4.3. Summary of Surface Water Monitoring Results Parameter Average Measured Value (A) Average Measured Value (B) Average Measured Value (D) PAH (total) mg/l mg/l mg/l PAH (total) mg/l mg/l mg/l PAH (total) mg/l mg/l mg/l PAH (total) mg/l mg/l mg/l PAH (total) mg/l mg/l mg/l Chromium (total) 2008 <0.002 mg/l mg/l mg/l Chromium (total) 2007 < mg/l < mg/l < mg/l Chromium (total) 2006 < mg/l < mg/l < mg/l Chromium (total) mg/l mg/l <0.002 mg/l Chromium (total) 2004 <0.002 mg/l <0.002 mg/l <0.002 mg/l Arsenic mg/l mg/l mg/l Arsenic mg/l mg/l mg/l Arsenic 2006 < mg/l < mg/l < mg/l Arsenic mg/l mg/l <0.001 mg/l Arsenic 2004 <0.002 mg/l mg/l mg/l Note 1: In the measurements quoted above, if a result quoted was the limit for detection for the given parameter, the limit of detection value was taken as the actual value for that date. Therefore, the values quoted may overestimate the actual emitted Note 2: The requirement for monitoring surface water for COD, and Phenols was lifted in February The requirement to monitor for suspended solids was lifted in PDM Ltd 23 Final

26 Discussion of Results The results of surface water monitoring for 2008 are similar to results reported for previous years Agency Monitoring The EPA conducted monitoring of the treated effluent emissions at Emission Point Reference No. E on the 17 th January 2008 and 26 th August The EPA also conducted monitoring of the surface water emissions at Emission point A, B and D on the 17 th January 2008 and 26 th August The results of the monitoring undertaken at Emission Point E are shown in Table 4.4 below. Table 4.4 Results of EPA Monitoring on Emission Point E Parameter EPA Result EPA Result ELV Limit 17/01/ /08/2008 ph units >6 and <9 BOD 2 mg/l <2 mg/l 25 mg/l COD 33 mg/l 35 mg/l <100 mg/l TSS 20 mg/l 20 mg/l <30 mg/l Arsenic 10 ug/l 19 ug/l <500 ug/l Chromium 3 ug/l 5 ug/l <500 ug/l Surface water discharges were analysed for a range of organics. The results of the surface water monitoring undertaken at Emission Points A, B and D were below the limits of detection for all parameters tested for both rounds of sampling undertaken by the EPA. It is noted from Table 4.4 that all results obtained were compliant with the conditions of the operating IPPC license. No groundwater monitoring was conducted onsite during Groundwater Monitoring Introduction Condition of the operating IPPC licence, requires groundwater monitoring on an annual basis at the site. The groundwater monitoring locations have been agreed with the Agency. In accordance with Schedule 4 of the IPPC licence, groundwater must be monitored for phenols, PAH s and PDM Ltd 24 Final

27 VOC s. A revision was agreed with the Agency for a requirement to monitor quarterly for PAH s Groundwater Monitoring Results Results for groundwater monitoring conducted during the monitoring period January to December 2008, are reported in Tables 4.5 and 4.6. The results indicate that there has been a significant decrease in the PAH concentrations in MW 1 through MW 7 since Results for both MW 8, 9 and 10 are consistent with those from Discussion of Groundwater Quality The following points summarise the current status of groundwater related issues at the site: The EPA requested a programme of management of contamination on site in September 2005 in line with a URS report on sediment and groundwater report dated April URS indicated that access to the ESB land to assess off-site migration of contamination, if any, is a very important factor in this work. However, access to the E.S.B land was not granted in Meanwhile, the EPA requested PDM to start assessing on-site issues in more detail. A proposal was submitted to the EPA for their approval proposing to assess current groundwater quality in the vicinity of the timber treatment area, and also to survey the condition of groundwater monitoring wells close to the treatment area. The proposal submitted to the EPA on October 17 th 2005 was agreed by the Agency subject to two conditions being addressed: 1. An assessment of the adequacy of monitoring wells on-site for representative groundwater monitoring and proposals for changes where required should be carried out. 2. PDM should take the necessary measures to obtain information by way of investigation if it is not possible to obtain information from the ESB. The schedule of works required in No 1 above should adequately address off site migration of contamination. URS carried out the scope of work outlined in the October 2005 proposal. The key conclusions from that report (December 2005) were: o There is an area of impacted groundwater in the vicinity of the production area at the site. There are indications of free-phase creosote being present in the bedrock in the vicinity of wells MW05 and MW07. o Although measures to prevent further losses of creosote to ground have been installed in treated timber storage areas since 2000, it is likely that groundwater contaminated with creosote continues to migrate off-site towards the west. PDM Ltd 25 Final

28 o It was recommended to put in place a hydraulic containment system that can be used to minimise on-going off-site migration of PAH contaminated groundwater in the vicinity of the production area. It would not be designed to recover contaminated groundwater that has already migrated beyond the down-gradient site boundary. The final design of this system is currently underway and it is expected to be installed in 2009 (see details further down). The above report submitted to the EPA on 21 st December 2005 was agreed by the Agency subject to a number of conditions being addressed: 1. The recommendations detailed throughout the report are implemented; 2. MW07 is replaced for groundwater quality monitoring purposes; 3. The feasibility of recovery of free phase creosote/sources of contamination is addressed and reported to the Agency; 4. Comment on whether the contamination on-site has been fully characterised; 5. A conceptual site model is developed for the site; 6. Comment on whether the works carried out on-site since 2000 are sufficient to prevent any further contamination of soil and groundwater providing recommendations where required; 7. Comment on whether additional monitoring wells are required to ensure that an adequate monitoring well network is in place providing recommendations where required; 8. Comment on whether the monitoring programme is adequate providing recommendations where required; and, 9. Works should also include: o Addressing the drainage ditch which showed evidence of contamination; o Addressing the plume of contamination that has migrated off-site; o Carry out a risk assessment to address all contamination arising from the site; o Assess the impact of the contamination on-site on the effluent discharge providing proposals for measures necessary to ensure that effluent discharges are below emission limit values set out in Schedule 1(i) Treated Effluent Emissions of the IPPC licence; and, o A database of all monitoring results is established to contain all previous and future results. PDM Ltd 26 Final

29 In response to these conditions, in January 2006 PDM submitted the following proposed schedule of works to be undertaken at the PDM facility. o Task 1: Review of Potential Sources; Development of Conceptual Site Model - This involves a detailed inspection of the site to be undertaken by URS to determine whether all potential contamination sources on the site have been identified and their potential impacts assessed. This will include a review of the results of previous investigations carried out on the site, and discussions with PDM site management with regard to both current and past operations at the site. URS will be asked to recommend infrastructure improvements in any areas where a risk of further contamination is identified. - Following on from the above source assessment, the conceptual site model will be reviewed and updated. This will consider potential source-pathway-receptor linkages and will highlight any linkages that require further assessment. - This report entitled Review of Remedial Strategy 2006 was completed and submitted to the EPA in December 2006 (further details below). o Task 2: Groundwater Monitoring Network & Monitoring Programme - In conjunction with Task 1, URS reviewed the adequacy of the groundwater monitoring network at the site, and the adequacy of the current groundwater monitoring programme. o Task 3: Remediation of Drainage Ditch - The drainage ditch in question lies close to the northern site boundary in the vicinity of MW5. - Contaminated sediment have been fully removed from this drain in stages over the past three years (i.e. since 2005). The contaminated sediments removed have been disposed of off-site by Cara Environmental Services. The contaminated sediments are underlain by low permeability clay soils, and as such, the potential for these sediments to contaminate the surrounding environment is very low. - PDM intend to plant the ditch with Reeds during o Task 4: Implementation of a Groundwater Remedial Strategy - Details of this are provided below. o Task 5: Risk Assessment of Off-Site Migration of Contamination PDM Ltd 27 Final

30 - URS will undertake a risk assessment of any contamination that appears to have migrated off-site. A request for information was sent by the EPA in January 2006 to an Environmental Specialist at the ESB. In this letter the EPA requested that the ESB provide the Agency with any reports, monitoring results and hydrological information from their site which is located down gradient of the PDM facility at Oldmilltown, Kill, Co. Kildare. In order to assist PDM with establishing the nature and extent of contamination migration off-site. This information was sent via to URS Ireland from the ESB in March During 2006, URS carried out the scope of works submitted to the EPA in January The key conclusions from this are outlined in the report Review of Remedial Strategy These are outlined below: - Cresote storage tank fill points consideration should be given to providing improved secondary containment at the creosote storage tank filling points, sufficient to contain major loss of creosote (i.e. failure of a hose during tank filling). - Bunding under treatment vessels hydraulic testing of the treatment plant bunds should be performed to confirm their integrity. This was carried in August 2007 and the integrity of the bunds was confirmed. - During the site inspection, some of the drains in the treated timber storage areas were blocked. It was recommended that these should be inspected regularly and cleaned as required. - The groundwater monitoring network and the current monitoring programme are considered adequate; however as MW7 has been decommissioned, it is recommended that its replacement well, MW8, be monitored on a quarterly basis in its place. MW9 and MW10 should be added to the list of wells at the site that are monitored annually. - Given the use of Celcure AC 500 at the site, it is recommended that the samples from wells in the treatment area be analysed on an annual basis for a key indicator of this product (e.g. Copper) as well as speciated PAHs. - With regard to the three newly-installed monitoring wells (MW8, MW9 and MW10), analysis of samples from these three wells indicates that only MW8 needs to be converted to a remedial abstraction well. Groundwater Sampling began at MW8, MW9 and MW10 in Q2, In December 2007, PDM submitted an updated proposal to the EPA for the installation of the hydraulic containment system to reduce the potential for off-site migration of PAH contaminated groundwater in the vicinity of MW8. The EPA have proposed a trial period of 1-month (EPA PDM Ltd 28 Final

31 Letter, dated 01/02/2008) and completion of a report on the findings. The report should include, as per the EPA letter, a detailed remediation strategy for the existing contamination and a detailed risk assessment on the potential impacts of a full-scale remediation strategy. The letter also reminded PDM of an EPA letter 13/01/06 requiring PDM to carry out a risk assessment addressing all contamination arising from the site. As part of this Hydraulic Containment strategy, two additional groundwater monitoring wells (MW11 and MW12) were installed by URS in April Hydraulic testing of MW12 was carried out in June 2008, which found MW12 to be a suitable abstraction well for the hydraulic containment system. PDM has requested URS to undertake the final design of the hydraulic containment system. It is intended that the containment system will become operational in PDM Ltd 29 Final

32 Table 4.5: Groundwater monitoring results 2004 through 2008 Wells MW1 to MW 12 Parameter - PAH (total) (mg/l) MW 1 MW 2 MW 3 MW 4 MW 5 MW 7 MW 8 MW 9 MW 10 MW 11 MW 12 VOC Well Head-space January 2008 < <0.001 < ** < January ** January 2006 < < < < < January <0.2 < (*) January (*) April ** April 2007 < < < < ** < April April April July ** July ** < July < July July October ** < < October ** October (**) < October October (*) unreliable result (**) MW 7 decommissioned PDM Ltd 30 Final

33 4.5. Testing and Inspection of Underground Tanks & Pipelines and Bund Integrity Bund Testing The site holds an IPPC licence (Licence No. PO325-01) and under this licence, PDM ltd. is required to perform integrity testing of all bunded structures on the site. The licence requires that: The integrity and water tightness of all the bunding structures and their resistance to penetration by water or other materials stored therein shall be tested and demonstrated by the licensee to the satisfaction of the Agency In January 2008, Punch & Co were contracted to conduct hydrostatic bund testing on 3 bunds at the site. One of these, the waste creosote bund, failed the test (i.e. a significant drop in water level). This was repaired in April 2008 and has being retested and the results showed no significant drop in water in any of the bunds and compliance with IPPC Licence requirements. During the August 2008 plant shutdown, the main separator at the site, the plant no. 4 bund and the drip trays for the creosote fill points were all tested for integrity. All were found to be in with IPPC Licence requirements Pipeline and Underground Tank Testing and Inspection In accordance with Condition of the operating licence, the company is required to implement a programme to ensure the integrity testing and inspection of underground tanks and pipelines is carried out once every three years. The previous assessment took place in August 2005 and therefore testing of all pipeline and underground tanks was required during The assessment programme was completed in August 2008 by technical experts Meehan Underground Survey and Technology Ltd. (*M.U.S.T). The assessment report was submitted to the EPA in Q PDM Ltd 31 Final

34 5. WASTE 5.1. Introduction Waste generated at the site is primarily non-hazardous in nature, comprising typically of wood-chips and general waste. Quantities arising on-site for the period January to December 2008 are presented in Tables 5.1 to 5.4. Wood-chips generated by the site activities are re-used by local equestrian groups for bedding etc. while treated wood waste is also used by local equestrian groups for mainly show-jumping. During 2009, PDM also disposed of some steel resulting from on-site maintenance work. Small amounts of waste creosote and also materials contaminated with Tanalith were disposed of as hazardous waste Summary of Waste Statistics A summary of wastes generated on-site for the period January 2008 to December 2009 inclusive is summarised in Tables 5.1 to 5.4. Licence and permit details are presented in Table 5.5. PDM Ltd 32 Final

35 Table 5.1. Annual Hazardous Waste Year Waste Material EWC Code Source t On-Site Treatment Waste Management Option On-Site Recovery Off-Site Recovery On-Site Disposal Off-Site Disposal Method t Method t Method t Method t 2008 Creosote * Production 30 None None None None D Table 5.2 Hazardous Waste sent off-site for Recovery/Disposal T Description and Nature of Waste 1. Broker 2. Haulage Contractor Recovery Contractor Disposal Contractor 30 Waste Creosote 1. Cedar 2. J P Ryan - Cedar Resource Management PDM Ltd 33 Final

36 Table 5.3 Annual Non-Hazardous Waste Waste Management Option Year Waste Material EWC Code Source T On-Site Treatment On-Site Recovery Off-Site Recovery On-Site Disposal Off-Site Disposal Method t Method t Method t Method t 2008 Metal Maintenance 0.5 None R General waste Canteen, office etc 18 None None None None D Table 5.4 Non-Hazardous Waste sent off-site for Recovery/Disposal Reporting Period Waste Material EWC Code T Description and Nature of Waste 1. Broker 2. Haulage Contractor Recovery Contractor Disposal Contractor January to December 2008 General waste Canteen, office 1.Thortons (Jan. to Dec.) - Kyletalesha Landfill PDM Ltd 34 Final

37 Table 5.5 Waste Permit Details INDAVER AES Waste Rehab Recycling Returnbatt Thorntons Recycling Centre Ltd Cedar Resource Management Limited Crossmore Transport Limited Waste Collection Permit WCP/KE/20C/05c WCP/KE/051C/05b - WCP/KE/045C/06b WCP/KE/042C/05b WCP/KE/044C/02b WCP/KE/013C/02b Waste Permit - - WPR WP 02/2002 Waste Licence W W /2002 W W Kommunekemi a/s, Denmark Waste License Permit HCE/DS/LSA Kyletalesha Landfill EPA License W PDM Ltd 35 Final

38 6. NOISE 6.1. Introduction On the 14/2/03 PDM received notification from the EPA that the requirement to carry out annual noise monitoring surveys has been suspended. This is as a consequence of there being a body of noise monitoring available at that point, in addition to there being no complaints pertaining to noise at that point. 7. RESOURCE CONSUMPTION 7.1. Introduction The utilisation of energy at PDM consists of diesel, wood-chips and electricity usage. The primary consumer of energy on-site is the process equipment, kilns and on-site boiler. Other resource consumption includes groundwater extracted from an on-site well, which is used for all site water needs. Light fuel oil is also used periodically as a back-up fuel for the boilers. The period considered for this AER is that from January 2008 to December Electricity Usage Electricity usage at the facility is demonstrated in Figure 7.1. Overall electivity usage has decreased slightly on the previous years figures. Figure 7.1 Electricity Usage ( ) MWH January to December ' January to December '04 January to December ' January to December ' January to December ' January to December '08 Electricity Usage PDM Ltd 36 Final

39 7.3. Diesel Usage The usage of diesel at the facility for the 12-month reporting period is presented in Figure 7.2. Diesel usage for 2008 has decreased by 510 litres since ,000 Figure 7.2 Diesel Usage ( ) Diesel Usage 110, , ,263 Litres 105, ,000 99, ,601 95,000 91,626 91,270 90,760 90,000 January - December 2002 January - December 2004 January - December 2006 January - December Woodchip Usage Quantities of wood chip utilised in the on-site boiler, for the period January to December 2008 detailed in Figure 7.3. Wood Chip usage during 2008 has increased slightly over the same as the previous year. Figure 7.3 Woodchip Usage ( ) Tonnes January - December January - December January - December January - December January - December 2008 PDM Ltd 37 Final

40 7.5. Light Fuel Oil Consumption The backup fuel for the boiler is light fuel oil, therefore use is dependent on boiler operation and typically intermittent and unpredictable. The light fuel oil usage for the AER 2008 monitoring period at the PDM facility is presented in Figure 7.4. This includes for light fuel oil usage in the on-site vehicles. There has been an significant decrease since Figure 7.4 Light Fuel Usage ( ) 250, , , ,005 Litres 150, , ,306 85, , ,672 50,000 0 January - December 2008 January - December 2007 January - December 2006 January - December 2005 January - December 2004 January - December ,000 January - December Water Consumption Water consumption at PDM is divided into two main groups: Utilities Domestic, production and washing processes The on-site groundwater well supplies the PDM site. This includes the provision of domestic water for the canteen and office and plus water for the boiler and other miscellaneous uses including vehicle washing. Water abstracted from the well has been metered since June 2002, and for the period January to December 2008 a total of 451m 3 was metered out of the ground water well for the canteen Discussion In order to get an overview on resource consumption and to define patterns in resource use, Efficiency Indices may be considered. It is noted that such indices can be calculated for differing time periods and yet compared with PDM Ltd 38 Final

41 one another since the measurement is based on production over that period. An example for electricity is as follows: Efficiency Index = Electricity Consumption (GJ)/tonnes raw materials used. For PDM, a more appropriate measure of production is the total volume of wood treated over the period of time in question. For the 12 month period January 2008 to December 2008, the quantity of product produced was 41,988 m 3. An example calculation is as follows (for electricity January to December 2008): Electricity consumed: GJ (MWh x 3.6) Product produced: 41,988 m 3 Therefore, Efficiency Index = /41,988 = GJ/m 3 Table Summary Indices of Resource Efficiency. Index Electricity usage (GJ/m 3 ) Light fuel oil usage (L/m 3 ) Diesel usage (L/m 3 ) Woodchip usage (t/m 3 ) Production volume in 2008 (41,988m 3 ) was consistent with that in 2007 (42,002 m 3 ). The Electricity Index has gone down indicating a more efficient use of this energy source over 2008 when it is considered that a similar quantity of wood was treated. The Diesel index and Woodchip index remained unchanged to 2007 consistent with similar quantities of wood treated at the site over this two year period. PDM Ltd 39 Final

42 8. ENVIRONMENTAL INCIDENTS AND COMPLAINTS 8.1. Complaints For the monitoring period January 1 st to December 31 st, 2007 there was no complaints received directly by the company from local residences. The EPA received one compliant from a nearby residences relating to odour which they believed was as a result of activities carried out at the PDM facility. The complainant reported that they were regularly impacted by persistent odour. The EPA forwarded details of the complaint to PDM. PDM responded to both the EPA and the complainant on the matter detailing that it was the opinion of PDM that the odour was not from the PDM facility but from another source in the area. Further to this, the EPA issued the complainant odour logs on which the complainant can track/record the details when the complainant experiences odour nuisance at their residence. There were no further complaints received by either the EPA or PDM in relation to odour during Incidents There were no reported spills at the facility, or any other incidents of environmental concern for the monitoring period of this AER. PDM Ltd 40 Final

43 9. REVIEW OF RESIDUALS MANAGEMENT PLAN PDM originally submitted an RMP to the Agency in August Since 2000 costs have been updated on an annual basis to take account for inflation. During 2008, the RMP was amended at the request of the EPA. The revised RMP was requested by the EPA in a letter to PDM dated the 28 th May The update was concerned the revision of the Section entitled Restoration and Aftercare Management Plan Management of any Potential Long Term Residual Soil and Groundwater Contamination. The RMP and the associated revisions were prepared by external consultants, URS Ireland Ltd., and employed the most Recent EPA Guidance Document entitled Guidance on Environmental Liabilities Risk Assessment, Residuals Management Plans and Financial Provision, copyright The RMP was reviewed in March 2009 by URS. Revisions proposed to the plan in 2009 relate to the groundwater containment and remediation programme and costs associated with decommissioning to more accurately reflect current market conditions in The cost table below is Table 9.1 of the RMP report dated 24 th March 2009, and includes all costs identified during the analysis of the Short Term and Long Term Programmes of the RMP. No other changes are proposed to the RMP. Table 9.1 Summary of RMP Costs ITEM DESCRIPTION COST ( ) STP 1 STP Residuals disposal (See Table 7.5) 112,264 STP 2 STP 3 STP4 LTP1 LTP 2 LTP.3 LTP.4 Project Management STP Specialised contractors Decommissioning of the WWTP SUB TOTAL STP (approximate) Groundwater containment and remediation (*) Soil investigation Soil remediation (**) Sediment assessment and removal Reed Bed decommissioning SUB TOTAL LTP (approximate) 17,157 27,772 16, , ,000 32, ,000 20,000 3, ,932 RMP TOTAL (approximate) 594,898 (*) A period of system operation of 15 years has currently been allowed for. The hydraulic containment approach is yet to be discussed with the EPA and is subject to their approval. (**) Should the on-site remediation of soil prove not to be successful, the estimated cost for offsite soil disposal and site re-instatement is 470,000. PDM Ltd 41 Final

44 In conclusion, in the unlikely event of site closure, it has been estimated that approximately 594,000 would be required to bring the site to an environmentally safe condition. 10. ENVIRONMENTAL LIABILITIES INSURANCE COVER As part of the requirements of IPPC Licence PDM Ltd. are required by the EPA to undertake an Environmental Liability Risk Assessment (ELRA). The ELRA was prepared by external consultants, URS Ireland Ltd., and employed the most Recent EPA Guidance Document entitled Guidance on Environmental Liabilities Risk Assessment, Residuals Management Plans and Financial Provision, copyright PDM originally submitted an ELRA to the Agency in September This has been updated as required as part of the site Annual Environmental Report (AER) submitted to the Agency annually. In 2007, a revised ELRA was prepared for the site in accordance with the most recent guidelines published by the Agency. The revised ELRA was requested by the EPA during an audit in November URS assessed a number of identified environmental risks in terms of probability of occurrence and severity in accordance with the EPA Guidance Document. A worst-case financial scenario of approximately 1,685,000 was determined using the guidelines in the EPA Guidance Document. URS undertook a review of the ELRA in March Revisions proposed to the assessment in 2009 relate to the costs determined in the previous assessment. This is proposed in order to more accurately reflect current market conditions in It is considered that a revised worst-case financial scenario of approximately 1,432,250 is appropriate. No other changes are proposed to the ELRA. Financial provisions at PDM Ltd are summarised in Table 10.1 below. Table 10.1 Assessment of PDM Financial Provision Risk Type Immediate, sudden and unforeseen discharge consequent upon an accident. Gradual unforeseen discharge consequent upon failure of control systems. Closure Restoration and Aftercare Liabilities Existing PDM Financial Provision Current Insurance policies maintained by the site. Funding to be provided by in-house funds or funds available from Parent Company Saint- Gobain. Parent Company Guarantee. Comment Excess of 450,000 for each and every claim. These are excluded from current insurance cover at the site. See separate Residuals Management Plan prepared specifically for this. PDM Ltd 42 Final

45 Based on the assessment of the current financial provisions in place, it is considered that PDM have sufficient insurance cover to provide for any liabilities resulting from immediate, sudden and unforeseen discharge consequent upon an accident. Any liabilities resulting from gradual unforeseen discharge consequent upon failure of control systems, if not covered via the existing insurance policies fro the site will be funded internally via funds released from both PDM or their parent company Saint- Gobain. PDM Ltd 43 Final

46 Appendix A - PDMs Environmental Policy & ISO Certificate

47 ENVIRONMENTAL POLICY 2004 PDM Limited is the only registered supplier in the Republic of Ireland of pressure treated creosoted timber for the utility services and fencing sector within Ireland. Our main objective is to meet our customers needs in all aspects of our activities, products and services in this very specialized area. We strive both to be a good employer and to have concern for environmental and community interests wherever we operate. We recognise that it is our responsibility to reduce the environmental impact that our organisation creates through a process of continual improvement. We seek to do this by: 1) Liaising with our suppliers and our customers to promote the best possible environmental practice. 2) Reducing our energy consumption, and the wise use of all energy required to operate successfully. 3) Reducing waste levels, and to promote the recycling of materials used where appropriate. 4) Reducing, or avoiding, pollution of land, water and air. 5) Observing, and where possible, exceeding the standards set by relevant environmental legislation or other requirements. 6) Encouraging, through induction, instruction and training, the development of good environmental practices by our employees at all levels. 7) Regularly reviewing our progress against the above strategic objectives, and adjusting future targets and actions in the light of these reviews. This environmental policy is communicated to employees and other interested parties, reviewed on an annual basis (every November) and available to the public. Signed Brendan Gibbons Managing Director Signed Catherine O Sullivan Operations Manager Directors B J Gibbons (Managing), W F Buys (Brit.), P Hindle (Brit), C J Kenward (Brit.) PJ Sneyd ACMA PDM Limited, Oldmilltown, Kill, Co. Kildare. Telephone: Fax Registered in Eire No

48

49 Appendix B - Glossary of Terms Glossary of Terms AER BOD COD DB ETP ELV EMP EWC IPPC PER ppm OFG WWTP Annual Environmental Report Biochemical Oxygen Demand Chemical Oxygen Demand Decibels (A weighted) Effluent Treatment Plant Emission Limit Value Environmental Management Programme European Waste Catalogue (94/3/EEC) Integrated Pollution Control Pollution Emission Register Parts Per Million Oils, Fats & Grease Waste Water Treatment Plant

50 Appendix C Fugitive Emissions Report

51 Appendix C Fugitive Emissions Study

52 Fugitive Emissions Assessment PDM Ltd. 19 February 2009 Final Issue No Fugitive Study 2009 Draft Report Final

53 Fugitive Emissions Assessment PDM Ltd. Project Title: Fugitive Emissions Assessment Project No: Status: Client Contact Name: Client Company Name: Issued By: Final Catherine O'Sullivan PDM Ltd. URS Ireland Ltd Iveagh Court Harcourt Rd. Dublin 2 Document Production / Approval Record Issue No: 2 Name Signature Date Position Prepared by Irene Baker 19/02/2009 Environmental Consultant Checked by Danny Ward 19/02/2009 Senior Environmental Engineer Approved by Peter Hassett 19/02/2009 Department Head, Transactions and Compliance Document Revision Record Issue No Date Details of Revisions 1 07/01/2009 Original issue 2 19/02/2009 Updated Table 4.1 Fugitive Study 2008 Report Final 2009 Final

54 Fugitive Emissions Assessment PDM Ltd. LIMITATION URS Ireland Limited has prepared this Report for the sole use of PDM Ltd. 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. 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. Fugitive Study 2008 Report Final 2009 Final

55 Fugitive Emissions Assessment PDM Ltd. CONTENTS Section Page No 1. INTRODUCTION Background Scope of work FUGITIVES EMISSIONS ESTIMATION METHODOLOGY Fugitive emission sources at PDM Compounds Monitoring & Analysis Methods RESULTS Emissions from Process Stages Emissions from Storage and Service tanks (both plants) Emissions from Tanker Unloading (both plants) Emissions from Treated Timber Summary of Results DISCUSSION CONCLUSION Appendix A - Appendix B - Figures Results Fugitive Study 2008 Report Final 19 Feb 2009 Page i Final

56 Fugitive Emissions Assessment PDM Ltd. 1. INTRODUCTION 1.1. Background URS Ireland Ltd (URS) was commissioned by PDM Ltd to undertake a fugitive emissions assessment of the production processes in Kill, Co. Kildare. The objective of the assessment was, to the extent practicable, to characterise and quantify the fugitive emissions from the various stages of the production process. URS completed two previous fugitive estimation studies for PDM in April 2002 and in April The 2002 study modelled fugitive emissions from the creosote storage and process tanks at the PDM facility. This was undertaken using US EPA Software, TANKS 4.0 (version 4.09b) and a manual flash calculation. Breathing Losses (losses due to changes in atmospheric conditions, and other factors) were modelled, as were Working Losses (losses due to the input and extraction of creosote from the tanks). The sum of these losses gives the Total Fugitive Emission from the creosote tanks. Due to the limitations of the estimation software the report recommended that a simple monitoring study be completed to further assess the fugitive emissions for each of the production plants. A monitoring exercise was then undertaken in The 2005 study monitored the specific events of filling and emptying of the creosote tanks and provided an initial estimate of the mass emissions of primary poly aromatic hydrocarbon (PAH) compounds emitted. Several recommendations were made in the 2005 report, including the recommendation to monitor all operational stages to improve the accuracy of the estimate of total fugitive emissions from the production processes at PDM and noting limitations in the sampling carried out in Also taken into account for this assessment were minor changes in the venting process which have occurred since 2005, i.e., the 2 storage tank vents on Plant 1 & 2 were combined and linked to the vapour receiving tank. As a result of this, a comprehensive sampling programme was developed and executed for this monitoring assessment as outlined below Scope of work URS carried out this project in accordance with URS proposal no , dated 24 th July The scope of the fugitive emissions assessment is as follows: Task 1 - Site Visit URS visited the site on the14 th July 2008 in order to: Familiarise project personnel with site operations; Identify all operational stages that could result in fugitive emission releases; Fugitive Study 2008 Report Final 19 Feb 2009 Page 1 Final

57 Fugitive Emissions Assessment PDM Ltd. To locate the most suitable sampling points on tanks and vessels containing creosote; Identify any stages have been adequately monitored/assessed in 2002/2005 and therefore do not require additional monitoring; Source any data required for updating the computer model TANKS4 used for estimation of fugitive emissions in 2002; and Discussions with site personnel regarding the monitoring methodology, in particular, the practicality of monitoring each stage separately. Task 2 - Preparation of Monitoring Protocol Upon completion of the initial site visit, URS prepared an outline assessment methodology and process flow diagram which was then forwarded to PDM in order to clarify and obtain agreement from PDM on the locations, methods and timing for emissions monitoring/sampling programme. Task 3 - Modeling, Data Interpretation and Reporting URS completed the monitoring of the potential fugitive emissions at PDM as outlined in Section 2.0 of this report, Estimation Methodology. The resulting monitoring data was filtered, interpreted and converted into kg/a of fugitive losses as outlined in Section 3.0 of this report, Results. A discussion of results and recommendations arising from the study is outlined in Section 4.0 of this report, Discussion. Fugitive Study 2008 Report Final 19 Feb 2009 Page 2 Final

58 Fugitive Emissions Assessment PDM Ltd. 2. FUGITIVES EMISSIONS ESTIMATION METHODOLOGY 2.1. Fugitive emission sources at PDM There are 2 wood treatment plants at PDM Plant 1/2 and Plant 3/4. Both plants consist of 2 timber treatment lines. On each line, timber poles are treated with the preservative creosote in a large pressure cylinder. In addition to the pressure cylinders, both plants contain creosote reception tanks, storage tanks, service, press tanks and vapour receiver tanks. Schematics of the tank layout in Plant 1/2 and Plant 3/4 are presented in Figures 1 and 2 of this report, respectively. The majority of emissions created during the process are vented to vapour receiver tanks. Vents from the following vapour receiver tanks have been identified as sources of fugitive emissions at PDM Ltd. Plant 1/2 Vapour Receiver Tank (labelled on site as storage tank No. 3) receiver tank for vapours during various stages as follows: filling of storage/service tanks; filling and emptying of the cylinder; and, background i.e. continuous emissions from storage/service tanks. Plant 1/2 Vacuum Vapour Receiver Tank - a receiver tank for vapours during the following stages: preparation for vacuum phase (pressure release); and, vacuum phase. Plant 3/4 Vapour Receiver Tank (external) - a receiver tank for vapours during all stages of the process. As well as the sources outlined above, the following additional sources of fugitive emissions at PDM include: losses from the creosote receiving tank during creosote unloading located in Plant 1/2 (estimated based on sampling at the Vapour Receiver Tank Plant 3/4 during a creosote delivery); opening of the cylinder to remove treated timber; emissions from treated timber after removal from the cylinder Compounds Creosote consists of many different chemical constituents. The main class of chemicals present in creosote are polyaromatic hydrocarbons (PAHs), approximately 99%, based on supplier information. About 20% of the total expected PAH concentration is expected Fugitive Study 2008 Report Final 19 Feb 2009 Page 3 Final

59 Fugitive Emissions Assessment PDM Ltd. to be Napthalene. As it would be prohibitively expensive to monitor for all PAHs in the fugitive emissions vapour stream, the 10 PAH compounds present in the highest quantity in each vapour sample collected were quantitatively identified as part of the monitoring study. Sampling for BTEX compounds (Benzene, Toluene, Ethylbenzene and Xylenes) and phenols was also undertaken as creosote supplier information indicates that up to 1 % of the vapour composition can constitute these compounds Monitoring & Analysis Methods Sampling of fugitive emissions was carried out on Thursday 11 th September Monitoring was performed on Line 1 of Plant 1/2 and Line 4 of Plant 3/4. (Sampling is not required on the other 2 lines as Line 1 is identical to Line 2, and Line 3 is identical to Line 4). Sampling locations and stages are outlined in Table 2.1 below. Samples were collected by drawing the vapour stream through sorbent filled sampling tubes using an SKC Universal Sampling Pump. The sampling pump was calibrated to a flow rate of approximately 50 millilitres per minute (this low flow rate was used to reduce the likelihood of sample breakthrough on the tubes which was observed during the 2005 study). The tubes were supplied by Gradko International Ltd in the UK (a UKAS accredited laboratory who also carried out the analysis of the tubes). The sorbent material used to trap the PAH compounds was Carbograph 1TD, as recommended by Gradko. Separate sampling tubes, with Chromosorb 106 as a sorbent, were used to collect BTEX and phenol compounds, as recommended by Gradko. A sealing cap on one end of the sampling tube was removed and replaced with a diffusion filter. The vapour stream was drawn into this end of the sampling tube as it exited the vent. The other end of the tube was attached to the sampling pump. Sampling tubes in series were used for stages where breakthrough was thought to be possible due to the high concentration of compounds expected. This was a recommendation from the 2005 study where problems of sample breakthrough were encountered. Sampling tubes were exposed for an appropriate length of time depending on the duration of the stage being monitored (see Table 2.1 below). A Rotating Vane Anemometer was used to measure volumetric flow rate of gases exiting through vents where the flow could not be calculated based on the quantity of creosote imputed/air displaced. The only instance where the flow could not be calculated based on the quantity of creosote imputed/air displaced was for the background emissions which are a result of continuous heating of the service/storage tanks (see Sections 3.2). The anemometer was selected as a flow monitoring device over the standard pitot tube method due to the unacceptably short vent length noting that there is a minimum vent length required for adequate pitot tube monitoring. Fugitive Study 2008 Report Final 19 Feb 2009 Page 4 Final

60 Fugitive Emissions Assessment PDM Ltd. Table 2.1: Sampling programme for fugitive monitoring assessment Sample No. Location Start Time Duration of sampling Note 1 Relevant Plant Stages Process Stages (Line 1) 1 Vapour Receiver Tank 3 Vapour Receiver Tank 4 Vacuum Vapour Receiver Tank 5 Vacuum Vapour Receiver Tank 6 Cylinder Opening/Timber stored externally (Line 4) 8 Vapour Receiver Tank 9 Vapour Receiver Tank 11 Vapour Receiver Tank 12 Vapour Receiver Tank Background Breathing Losses 2 Line 1 Vapour Receiver Tank 10 Line 4 Vapour Receiver Tank Tanker Unloading 7 Vapour Receiver Tank (Line 4 only) Control 09:30 24 mins Cylinder Filling: Filling of cylinder 1 with creosote 10:56 17 mins Cylinder Emptying of creosote back into service tanks mins Pressure Release in preparation for vacuuming mins Vacuum: Cylinder 1 under vacuum (duration of emission was 17 mins) mins Cylinder Opening to remove treated timber/treated timber temporarily stored in yard prior to storage. 15:15 15 mins Cylinder Filling: Filling of cylinder 4 with creosote 16:11 17 mins Cylinder Emptying of creosote into service tanks. 16:54 6 mins Pressure Release in preparation for vacuuming (duration of emission was 24 mins) Note mins Vacuum: Cylinder 4 under vacuum (duration of emission was 13 mins) 10:15 10 mins Background losses: emissions from heating of creosote in the service tanks. 16:40 10 mins Background losses: Emission from heating of creosote in the service tanks mins Tanker Unloading into the Storage Tank 13 Blank Brought to site but remained unopened and was sent for analysis to allow blank correction of the above sampled tubes Note 1 Duration of sample equates to the duration of the emission unless other wise indicated. Note 2 This stage began at 16:40, however emissions were noted escaping through open vents on top of the service tanks. The sample taken at the vapour receiver tank during this time has been used as a background sample. The service tanks vents were subsequently closed and the emissions exited through the vapour receiver tank where a second sample was taken, representing emissions during pressure release. Fugitive Study 2008 Report Final 19 Feb 2009 Page 5 Final

61 Fugitive Emissions Assessment PDM Ltd. After completion of sampling the tubes were sealed, labelled and sent to the Gradko Laboratory for analysis. Analysis of the tubes for the top 10 PAH compounds, BTEX compounds and phenols was carried out using the technique of Gas Chromatography Mass-Spectrometry. The results from the diffusion tube sampling are presented in the following section of this report. Fugitive Study 2008 Report Final 19 Feb 2009 Page 6 Final

62 Fugitive Emissions Assessment PDM Ltd. 3. RESULTS The sampling tubes analysis results from Gradko were expressed in µg/m 3 concentration for the different compounds. The results are presented for process stages, tanker unloading, background breathing losses and treated timber Emissions from Process Stages The following assumptions were made when estimating the fugitive emissions for various process stages: The approximate volumetric flows from the tank vents during filling and emptying of the cylinder are estimated based on the known quantity of creosote loaded into the cylinder i.e. 40m 3 of creosote loaded into Line 1 equates to 40m 3 of air displaced, 66m 3 of creosote loaded into Line 4 equates to 66m 3 of air displaced; The volume of air displaced during the vacuum preparation stage (pressure release from 2 bar to 1 bar) of the process equates to the amount of air released as a result of lowering the pressure inside the cylinder from 2bar to 1bar (i.e. volume of void space in cylinder is 40 m 3. At a pressure of 2 bar this equates to 80m 3 of air inside the cylinder. To lower the pressure inside the cylinder to 1 bar, 40m 3 of air must be released). For line 4 this equates to 66 m 3. The maximum volume of air that can be displaced during the vacuum stage of the process equates to the air space in the cylinder, i.e. 40 m 3 for Line 1 and 66 m 3 for Line 4. It is noted that this is a maximum figure as the vacuum stage will not result in the removal of all air from the cylinder, these volumes are taken as a worst case for both lines; The volume of air displaced during cylinder opening is assumed to be equal to the volume of the cylinder minus the volume of the timber, i.e. 40 m 3 for Line 1 and 66 m 3 for Line 4. Again, this is a conservative estimate given that some of this vapour is likely to remain inside the cylinder and is then isolated from outside the cylinder when the cylinder door is again shut when the treated wood is removed. A detailed calculation spreadsheet, including a breakdown of the monitored compounds for each stage, is provided in Appendix A. Summary monitoring results for the individual stages, per batch of treated wood, of are presented in Table 3.1 (Line 1 of Plant 1/ 2) and Table 3.2 (Line 4 of Plant 3/ 4). Fugitive Study 2008 Report Final 19 Feb 2009 Page 7 Final

63 Fugitive Emissions Assessment PDM Ltd. Table 3.1 Process Stages Fugitive Emissions (kg/batch) - Line 1 of Plant 1/2 Plant No. 1 Stages Note 1 Compound Cylinder Filling Empyting Back Pressure Release Vacuum Cylinder Opening TOTAL Sum of Top 10 PAHs BTEX Compounds Phenols Note 1 Stages are based on sample no s 1, 3, 4, 5 and 6 respectively as outlined in Table 2.1 Table 3.2 Process Stage Fugitive Emissions (kg/batch) - Line 4 of Plant 3/4 Plant No. 4 Stages Note 1 Compound Cylinder Filling Empyting Back Pressure Release Vacuum Cylinder Opening Note 2 TOTAL Sum of Top 10 PAHs BTEX Compounds Phenols Note 1 Stages are based on sample no s 8, 9, 11, 12 and 6 respectively as outlined in Table 2.1 Note 2 Monitoring results for the cylinder opening stage of Line 1 have been used to quantify emissions for cylinder opening from Line 4 as cylinder opening for Line 4 was not monitored on the day of sampling. Utilising the results from the tables above, estimates of annual fugitive emissions from the production processes at PDM were calculated. The following information was utilised when estimating annual emissions: There are, on average 4 batches of wood treated per day in Plant 1/2 (2 each per Line 1 and Line 2) and 4 batches of wood treated per day in Plant 3/4 (2 each per Line 3 and Line 4); Emission estimates represented in Table 3.1 above are assumed to be representative for all batches of timber processed; and, The site operates 250 operating days per year. Given the above assumptions, the annual estimates of mass of fugitive emissions for the process stages is presented in Table 3.3. Fugitive Study 2008 Report Final 19 Feb 2009 Page 8 Final

64 Fugitive Emissions Assessment PDM Ltd. Table 3.3 Summary of Process Stage Fugitive Emissions (kg/batch & kg/year) Note 1 Compound Plant 1/2 Plant 3/4 kg/batch kg/year kg/batch kg/year Sum of the Top 10 PAH s BTEX Compounds Phenols Note 1: Background losses and losses from tanker unloading are excluded from the above figures. Separate calculations for these are shown below Emissions from Storage and Service tanks (both plants) The background fugitive emissions were calculated based on the following: Background emissions occur approximately 6 hours per day from both plants, 250 days per year; Background flow rates were recorded using an anemometer. Results for Sample No. 2 (background emissions for Line 1) were used to calculate background emissions for both plants, as a volumetric flow rate was not retrieved for Sample No. 10 (background emissions for Line 4) due an error with the anemometer. Table 3.4 Fugitive emissions from storage/service tanks (kg/day & kg/yr) Compound kg/day kg/year Sum of Top 10 PAH s BTEX Compounds Emissions from Tanker Unloading (both plants) Tanker Unloading was monitored for Line 4 only (Sample No. 7) and this result has been used to calculated total fugitive emission generated during creosote deliveries for both plants. The fugitive emissions generated during delivery of creosote were calculated based on the following: The approximate volume of air displaced through the tank vents during filling of the creosote storage tanks from a road tanker equates to the known volume of creosote delivered, i.e. 24.3m 3 ; and Fugitive Study 2008 Report Final 19 Feb 2009 Page 9 Final

65 Fugitive Emissions Assessment PDM Ltd. The annual quantity of creosote delivered to the site (both plants) is approximately 4,370 m 3 (based on 2007 figures). Table 3.5 Fugitive Emissions from tanker unloading (kg/delivery & kg/yr) Compound kg/delivery kg/year Sum of Top 10 PAHs BTEX Compounds Phenols Emissions from Treated Timber In order to determine the annual expected fugitive emissions from the treated timber (stored on site) an emission factor has been sourced from a 1994 model 1 which was based on detailed measurement data and modelling on creosote treated poles. From that model, an average (from initial removal to storage for 150 days) emission factor can be calculated and is approximately 1.39 g/m 2 outer rack exposed wood surface area of Napthalene, for southern California. By applying an average temperature factor 0.35 over the year (prepared by the authors for a temperate climate in the U.S), then the emission factor is 1.39 g/m 2 x 0.35 = 0.48 g/m 2. The modelling authors noted that Napthalene represents the vast majority of treated wood storage fugitives given the high vapour pressure of naphthalene compared with other creosote components. URS has estimated, (based on known annual production figures and approximate amount of poles on each batch) that approximately 109,780 m 2 of outer surface area of wood is exposed on the PDM site per annum. Applying the emission factor of 0.48 g/m 2, provides an estimate of approximately 52.7 kg/yr Naphthalene emissions as fugitives from the storage of treated wood per annum. Emission factors are not available for BTEX or phenols for treated wood and therefore these compounds have been excluded from this section Summary of Results A summary of the estimated fugitive emissions at PDM (based on data for the year 2007), details of which are presented in Sections 3.1 to 3.4 above, is presented in Table Prepared by the American Wood Preservers Institute on black creosote treated timber poles. Fugitive Study 2008 Report Final 19 Feb 2009 Page 10 Final

66 Fugitive Emissions Assessment PDM Ltd. Table 3.6 Summary of Total Estimated Fugitive Emissions at PDM (kg/yr) Fugitive Emission PAH s (Top 10) Phenols BTEX Source Process Stages Background Tanker Unloading Treated Timber 52.7* - - TOTAL (kg/yr) * Represents Napthalene only as explained in Section 3.4 above. Fugitive Study 2008 Report Final 19 Feb 2009 Page 11 Final

67 Fugitive Emissions Assessment PDM Ltd. 4. DISCUSSION The total estimate of fugitive emissions (kg/yr) as a percentage of compound input (based on the year 2007), is presented in Table 4.1. Table 4.1 Total Estimated Fugitive Emissions as a percentage of Input. Compound % of compound in creosote Note 1 Input Quantity (kg/yr) Note 2 Fugitive Losses (kg/yr) Note 3 % of Input PAH s (Top 10) ,641, BTEX , Phenols , TOTAL 4,675, Note 1 Based on the composition of creosote as provided by the creosote suppliers, Koppers UK Ltd. Note 2 Based on total creosote input for 2007, i.e., 4,370m 3 or 4,675,900kg (specific gravity=1.07 as per MSDS). Note 3 Based on the total emissions from the all sources of fugitive emissions as outlined in Table 3.5. From Table 4.1 above it can be seen that the fugitive losses for each of the compound groups PAH s, BTEX and phenols, is low relative to the input quantity of each compound group, i.e. <1% for PAH s and phenols, and <12% for BTEX (due to the relatively high volatility of BTEX compounds). Furthermore, these percentages are low in relation to the Solvent Regulations (2002) limit of 45% of solvent input for Wood Impregnation activities. Fugitive Study 2008 Report Final 19 Feb 2009 Page 12 Final

68 Fugitive Emissions Assessment PDM Ltd. 5. CONCLUSION The annual fugitive emissions from production processes and related activities at PDM of the primary PAH compounds, phenols and BTEX compounds have been characterised and quantified, and recommendations from the 2005 Fugitives Study have been satisfied, to the extent practicable. The percent fugitive losses of input for each compound group has been estimated as follows: <1% for PAH s; <1% for phenols; and <12% for BTEX. The total fugitive emissions have been estimated at kg/yr, which represents % of the total creosote input for the year Hence, it has been determined that the fugitive emissions generated due to the operations involving creosote at the site are low in relation to the Solvent Regulations (2002) limit of 45% of solvent input for Wood Impregnation activities. Fugitive Study 2008 Report Final 19 Feb 2009 Page 13 Final

69 Fugitive Emissions Assessment PDM Ltd. Appendix A - Figures Fugitive Study 2008 Report Final 19 Feb 2009

70 Creosote Plants 1 & 2 Diagram Vent to atm Press Tanks Tanker 1. 1 Reception Tank Storage Tanks Service Tanks Cylinders 8. Timber Poles Vent to atm Vapour Reciever Tank Vent to atm Vacuum Vapour Receiver Tank LEGEND 1. Tanker Unloading 2. Reception Tank feeds storage Tanks (Background) 3. Storage Tanks top up service tanks/service tanks 4. Cylinder Filled from Service Tanks 5. Creosote Emptied back 6. Pressure Release (Preparation for vaccuum) 7. Vacuum applied 8. Cylinder opened to remove timber poles Vapour Emissions Cresosote Path

71 Creosote Plants 3 & 4 Diagram Vent to atm (release during Vacuum Tanker 1. Receptio 2. n/storage Tank Service/P ress Tanks Cylinders 7. Timber Poles 5. Vent to atm 6. Exteranl Vapour Reciever Tank Timber Poles Liquor to external settle tank LEGEND 1. Tanker Unloading 2. Reception/Storage Tank feeds Service/Press Tanks (Background) 3. Cylinder Filled from Service Tanks 4. Creosote Emptied back 5. Pressure Release (Preparation for vacuum) 6. Vaccuum applies 7. Cylinder opened to remove timber poles Vapour Emissions Cresosote Path

72 Fugitive Emissions Assessment PDM Ltd. Appendix B - Results Fugitive Study 2008 Report Final 19 Feb 2009

73 Client PDM Ltd. Project Fugitives Emissions Study Location Kill, Co. Kildare Job Number Sample Type Air Date 11/09/2008 Plant 1/2 - Line 1 Sample ID Units Blank Cylinder Filling Background (Note 1) Empyting Back Pressure Release Vacuum Cylinder Opening Duration of Sample min Duration of Stage min Volume m Volumetric Flow Rate m3/sec Parameter ug/m3 kg ug/m3 kg ug/m3 kg ug/m3 kg ug/m3 kg ug/m3 kg PAHs Naphthalene ug/m Naphthalene, 1 - methyl ug/m Naphthalene, 2 - methyl ug/m Naphthalene, 1,5 - dimethyl ug/m Naphthalene, 1,6 - dimethyl ug/m Naphthalene, 1,7 - dimethyl ug/m Naphthalene, 2,3 - dimethyl ug/m Naphthalene, 2,6 - dimethyl ug/m Naphthalene, 2,7 - dimethyl ug/m Acenaphthylene ug/m Acenaphthene ug/m Fluorene ug/m Phenanthrene ug/m Fluoranthene ug/m Pyrene ug/m Biphenyl ug/m H Flourene, 1-methyl ug/m BTEX and Phenols Benzene ug/m Toluene ug/m Ethylbenzene and p xylene o Xylene ug/m Phenol ug/m Phenol, 4 methyl ug/m Phenol 2,3 dimethyl ug/m Phenol 3,4 dimethyl ug/m TOTAL (Stages Results Summary excl. Background) Total PAH Total BTEX Total Phenols Plant 3/4 - Line 4 Sample ID Blank Tanker Unloading Cylinder Filling Empyting Back Pressure Release Vacuum Cylinder Opening Duration of Sample min Duration of Stage min Volume m Parameter Units ug/m3 kg ug/m3 kg ug/m3 kg ug/m3 kg ug/m3 kg ug/m3 kg PAHs Naphthalene ug/m Naphthalene, 1 - methyl ug/m Naphthalene, 2 - methyl ug/m Naphthalene, 1,2 - dimethyl ug/m Naphthalene, 1,3 - dimethyl ug/m Naphthalene, 1,4 - dimethyl ug/m Naphthalene, 1,5 - dimethyl ug/m Naphthalene, 1,6 - dimethyl ug/m Naphthalene, 1,7 - dimethyl ug/m Naphthalene, 2,3 - dimethyl ug/m Naphthalene, 2,6 - dimethyl ug/m Naphthalene, 2,7 - dimethyl ug/m Acenaphthylene ug/m Acenaphthene ug/m Fluorene ug/m Phenanthrene ug/m Anthracene ug/m Fluoranthene ug/m Pyrene ug/m Biphenyl ug/m BTEX and Phenols Benzene ug/m Toluene ug/m Ethylbenzene ug/m o Xylene ug/m p Xylene ug/m Phenol ug/m Phenol, 3 methyl ug/m Phenol, 4 methyl ug/m Phenol 2,3 dimethyl ug/m TOTAL (Stages excl. Results Summary Tanker Unloading) Total PAH ug/m Total BTEX ug/m Total Phenols ug/m Note 1 Relates to both Plant 1/2 and Plant 3/4 and are presented as estimated fugitive emissions for 1 day (assuming 6 hours/day for both plants, i.e. 720 mins)

74 Appendix D - PRTR

75 PRTR# : P0325 Facility Name : P.D.M. Limited Filename : EPA Returns 2008(dw working).xls Return Year : /03/ :29 REFERENCE YEAR FACILITY IDENTIFICATION Parent Company Name P.D.M. Limited Facility Name P.D.M. Limited PRTR Identification Number P0325 Licence Number P AER Returns Worksheet Waste or IPPC Classes of Activity No. class_name The treatment or protection of wood involving the use of preservatives with a capacity exceeding 10 tonnes per day. Address 1 Oldmilltown Address 2 Kill Address 3 Co. Kildare Address 4 Version Country Ireland Coordinates of Location River Basin District NACE Code 161 Main Economic Activity Sawmilling and planing of wood AER Returns Contact Name Catherine OSullivan AER Returns Contact Address Catherine.OSullivan@pdm.ie AER Returns Contact Position Assistant to M.D.Env & Quality Mngr AER Returns Contact Telephone Number AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number Production Volume 0.0 Production Volume Units Number of Installations 1 Number of Operating Hours in Year 2080 Number of Employees 32 User Feedback/Comments 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? No If applicable which activity class applies (as per Schedule 2 of the regulations)? Is the reduction scheme compliance route being used?