Annual Environmental Report For Period January 2009 December 2009

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1 Annual Environmental Report For Period January 2009 December 2009 Licence Register No. P Page 1 of 29

2 Table of Contents Section Contents Page 1. Introduction 3 2. Report Structure 5 3. Summary Information Management of the Activity Licence Specific Reports 28 Page 2 of 29

3 Section 1 Introduction Page 3 of 29

4 Section 1 Introduction This Annual Environmental Report (AER) for relates to the environmental performance and achievements of the company in the period 1 st January 2009 to 31 st December The report has been compiled in accordance with condition 11.8 of Integrated Pollution Prevention & Control licence number P and EPA guidance notes for AER s. Brian Kelly Manufacturing Systems Manager 29 th March 2010 Page 4 of 29

5 Section 2 Report Structure Page 5 of 29

6 Section 2 Report Structure Section Contents Page_ Section 1 Introduction 3 Section 2 Report Structure Licence Number 2.2 Name and location of site 2.3 Description of activities on site 2.4 Company Environmental Policy 2.5 Company Organisation Chart for Environmental Management Section 3 Summary Information Monitoring Data Emissions to waters Emissions to atmosphere Waste management 3.2 Agency Monitoring and Enforcement 3.3 Energy and Water Consumption Energy consumption Water consumption 3.4 Environmental Incidents and Complaints 3.5 AER/PRTR Summary Data Table Section 4 Management of the Activity Introduction 4.2 Schedule of Environmental Objectives and Targets 4.3 Environmental Management Programme Report 4.4 Environmental Management Programme Section 5 Licence Specific Reports Noise Monitoring Report 5.2 Groundwater Monitoring Report 5.3 Environmental Management Plan 5.4 Statement Environmental Liabilities 5.5 Environmental Iron Assessment of Milbrook Stream Page 6 of 29

7 Section 2 Report Structure 2.1 Licence Number - I.P.C Licence Registration Number P Name and Location of Site -, Birr, Co. Offaly. 2.3 Description of the activities on site: The product is basically made of 2 no main component parts: - Ductile Iron Cover. - Fabricated Frame. (for alternatives) Details of the manufacturing process are outlined below. Raw Materials The furnace charge (raw material) at is characterised by the use of virgin or clean metals along with foundry returns. Ductile iron is manufactured from pig iron, scrap steel and foundry returns. Various ferro alloys such as silicon, magnesium and copper are added to treat the iron. Foundry returns are a mixture of the runners from castings and off spec products which are recycled. All foundry returns are self generated at the foundry. Scrap steel is made up principally of baled trimmings from new uncoated car panels and off-cuts from engineering shops. One tonne of molten iron is made of approximately 57% steel scrap, 21% pig iron, 16% returns and 6% ferro alloys. Ferro alloys are used to treat the iron and the addition rate is determined by analysis of each batch during production. Melting of Raw Materials The current melting equipment consists of two 2-tonne capacity electric induction furnaces. The metal is heated to a temperature of approximately 1500 C. It is then poured from the furnace to a ladle which is used to transport the iron within the foundry. A series of metallurgical tests is carried out on the molten metal prior to pouring of the molten metal. Page 7 of 29

8 Electric melting furnaces represent the cleanest melting technology used in the foundry industry. The other main melting system used by foundries in Cupola melting which is associated with significantly greater environmental emissions. Pouring A ladle is used to transfer molten metal from the furnace to the casting line. This ladle is moved by gantry crane and the molten metal is discharged into the mould. Magnesium is added directly to the ladle just before molten iron is poured from the furnace. The magnesium is a catalyst for a structural change in the molten metal from flake graphite to Sphereoidal graphite/ductile iron. Casting The molten metal is poured from the ladle into moulds which are made from sand, bentonite clay, coal dust and water. This moulding sand is termed greensand. The metal is poured from the ladle into the moulds which are moving on a casting trolley. The casting trolleys move the moulds from the mould preparation machine through the casting area where they are cast and back to a knockout area. During the transfer of the moulds from the casting area to the knockout area, the molten metal cools and a product is formed. Knock-out The mould containing the casting is transferred to a knockout machine where the sand mould and product casting are pushed from the moulding flash. The used sand is collected on a rubber belt conveyor after falling through the knockout machine and conveyed back to the sand preparation plant for re-use. The now empty moulding flask is returned to the mould preparation area where it is again prepared for a further casting. The casting is moved to the finishing / assembly area where it is finished and assembled. Painting All castings manufactured are coated with black bitumen primer. Sand preparation and mould making Coal dust and clay are currently delivered to site in bags and stored in the courtyard. Sand is delivered in bulk. Page 8 of 29

9 All the above materials are blended in a mixing mill which takes a proportion of each material from storage hoppers and mixes the material with greensand returned from the knock-out machine. Water is added to the mill and the blended material is conveyed by conveyor to the moulding machine where it is used to fill the moulding flasks in preparation for casting. The blend of moulding material is carefully monitored by carrying out a series of control tests in the laboratory. Moulding The mould flask, after the knock-out machine is moved into a moulding flask station prior to the mould preparation machine. Here the moulding flask is split into two parts. Each half is returned to the mould preparation machine where it is placed over an aluminium tooling pattern. Blended moulding sand is dropped into the moulding flask covering the tooling plate where it is compressed using air onto the pattern. Each moulding flask takes an impression of the tool and is then rotated where it can be inspected for quality. Cores may be added at this time. After exiting the mould preparation area the first half of the moulding flask is turned over and placed on top of the second flask. The completed mould is then placed in line onto the casting trolley at the start of the casting line where it awaits delivery of molten metal from the furnace. FRAME MANUFACTURE Raw Materials The raw material consists of 46 X 46 x 3mm angle (min) iron to BS1449 and is attained from various suppliers. Certificates of conformity are requested from suppliers for the material. Fabrication All frames are fabricated in jigs. The angle iron section is placed into the jig where it is clamped prior to welding. Galvanising All fabricated frames are dispatched for galvanising where they are galvanised in accordance with the customer specification. Certificates of conformity to the galvanise specification are provided by the galvaniser. Page 9 of 29

10 2.4 Company Environmental Policy Environmental Policy is committed to conducting all its activities such that they have a minimal effect on the environment. All levels of management are committed to implementing and maintaining an environmental management system in compliance with BS EN ISO 14001:2004. The company s key objectives are :- (i) (ii) (iii) (iv) (v) (vi) (vii) To commitment to compliance with the spirit as well as the letter of environmental legislation and approved codes of practice. The company will co-operate fully and maintain open relationships with all regulatory authorities. To develop procedures for the continuous assessment of the environmental impacts of our products and processes thus demonstrating our commitment to continual improvement and prevention of pollution. To develop procedures to set and review objective targets for the reduction of the company s significant environmental effects. To pro-actively seek waste reduction and recycling measure. To seek continual improvement in the efficient use of energy and natural resources. To train and educate all employees in the skills and understanding necessary to minimise any risk to the environment from the company s activities. To make available to our employees and the public this policy and information concerning the environmental performance of the company as detailed in EMP/23. Page 10 of 29

11 2.5 Company Organisation Chart for Environmental Management Managing Director Sales Department Administration Department Technical Department Production Department Sales Manager Administration Director Environmental Management Co-Ordinator Product Design Engineer Production Director Sales Representitive Sales Co-Ordinator Transport Staff Debtor Clerk Receptionist Secretary Production Personnel Maintenance Personnel Cavanagh Foundry defines and documents the responsibility authority and interrelationships of all key personnel who manage, perform and verify work affecting the environment. Key personnel are informed of their responsibilities in order to facilitate an effective environmental management system. The Environmental Management Co-Ordinator (Manufacturing Systems Manager) reports to the Managing Director with whom overall responsibility for environmental issues rest. Page 11 of 29

12 Section 3 Summary Information Page 12 of 29

13 Section 3 Summary Information Surface Water Emissions Summary Table 1: Summary Table for Surface Water Emissions at SW1 and SW6: Emission Reference Number SW1 Emission Reference Number SW6 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 TOC mg/l Total Copper mg/l Total Iron mg/l Xylene mg/l Page 13 of 29

14 3.1.2 Emissions to Atmosphere Table 2 : Summary Table for Emissions to Atmosphere (Mass Emissions (kg) & Average Emissions (mg/m 3 ): EMISSION POINT REFERENCE PARAMETER MASS EMISSIONS 2009 (kg) LICENCED MASS MASS MASS MASS MASS MASS EMISSIONS EMISSIONS EMISSIONS EMISSIONS EMISSIONS EMISSIONS 2009 (kg) 2008 (kg) 2007 (kg) 2006 (kg) 2005 (kg) 2004 (kg) A2-1 FURNACE EXTRACTOR A2-2 DRY BAG FILTER A2-3 SURFACE COATING VENT A2-4 SHOT BLASTER A3-4 SHOT BLASTER EMISSION POINT Total Particulates Total Particulates TA Luft Organics Class II Total Particulates Total Particulates AVERAGE PARAMETER EMISSIONS LICENCED EMISSIONS EMISSIONS EMISSIONS EMISSIONS EMISSIONS EMISSIONS REFERENCE 2009(mg/m 3 ) 2009(mg/m 3 ) 2008(mg/m 3 ) 2007(mg/m 3 ) 2006(mg/m 3 ) 2005(mg/m 3 ) 2002(mg/m 3 ) A2-1 FURNACE EXTRACTOR A2-2 DRY BAG FILTER A2-3 SURFACE COATING VENT A2-4 SHOT BLASTER A3-4 SHOT BLASTER Total Particulates Total Particulates TA Luft Organics Class II Total Particulates Total Particulates Page 14 of 29

15 QUARTERLY FURNACE STACK AIR EMMISION RESULTS (A2-1) EMISSIONS mg/nm Emission Result Emission Limit 5 0 Q1 '02 Q2 '02 Q3 '02 Q4 '02 Q1 '03 Q2 '03 Q3 '03 Q4 '03 Q1 '04 Q2 '04 Q3 '04 Q4 '04 Q1 '05 Emission Result Emission Limit Q2 '05 Q3 '05 Q4 '05 Q1 '06 Monitoring Period Q2 '06 Q3 '06 Q4 '06 Q1 '07 Q2 '07 Q3 '07 Q4 '07 Q1 '08 Q2 '08 Q3 '08 Q4 '08 Q2 '09 Q4 '09 Page 15 of 29

16 QUARTERLYSAND PLANT PARTICULATE AIR EMISSION RESULTS (A2-2) Emissions mg/nm Q1 '02 Q2 '02 Q3 '02 Q4 '02 Q1 '03 Q2 '03 Q3 '03 Q4 '03 Q1 '04 Q2 '04 Q3 '04 Q4 '04 Q1 '05 Emission Result Emission Limit Q2 '05 Q3 '05 Q4 '05 Q1 '06 Monitoring Period Q2 '06 Q3 '06 Q4 '06 Q1 '07 Q2 '07 Q3 '07 Q4 '07 Q1 '08 Q2 '08 Q3 '08 Q4 '08 Q2 '09 Q2 '09 Page 16 of 29

17 350 QUARTERLY SURFACE COATING VENT EMISSIONS RESULTS (A2-3) Emmisions mg/nm Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q2 Q4 '02 '02 '02 '02 '03 '03 '03 '03 '04 '04 '04 '04 '05 '05 '05 '05 '06 '06 '06 '06 '07 '07 '07 '07 '08 '08 '08 '08 '09 '09 Emission Result Emission Limit Monitoring Period Page 17 of 29

18 Biannual Air Emission Monitoring Results A2-4 Donaldson Shotblaster Emissions Mg/m3 6 4 Emission Result Emission Limit 2 0 Q2 '09 Q4 '09 Period Page 18 of 29

19 Biannual Air Emission Monitoring Results A3-4 Sission Shotblaster Emissions mg/m3 6 4 Emission Result Emission Limit 2 0 Q2 '09 Q4 '09 Period Page 19 of 29

20 3.1.3 Waste Management Table 3: Summary Table of Wastes Generated at in the Period European Waste Catalogue Code Hazardous (Yes/No) Description of Waste Quantity /t No Cardboard 1.71 R No Used Greensand R No Used Greensand R No Empty Steel Barrels 4.91 R4 Disposal/ Recovery Code Location of Disposal/ Recovery AES Ltd, Co. Laois. Hinch Plant Hire, Nyra, Mountmellick, Co. Laois. Roscommon County Council Landfill, Ballaghaderreen, Co. Roscommon. Hammond Lane Metal Company Ltd. Ringsend, Dublin 4. Name of Waste Disposal Recovery Contractor & Waste Collection Permit No. AES Ltd, Naas, Co. Kildare. Permit 053(2)/OY/351/06 (Issued by Offaly County Council) Hinch Plant Hire, Mountmellick, Co. Laois. Permit WCP-OY (Issued by Offaly County Council) Hinch Plant Hire, Mountmellick, Co. Laois. Permit WCP-OY (Issued by Offaly County Council) Hammond Lane Metal Company Ltd. Permit 050(2)/OY/540/07 (Issued by Offaly County Council) No General Refuse D No Packaging Material (other than Cardboard) R4 Offaly County Council Landfill, Derryclure, Tullamore, Co. Offaly. Hammond Lane Metal Company Ltd. Ringsend, Dublin 4. AES Ltd, Naas, Co. Kildare. Permit 053(2)/OY/351/06 (Issued by Offaly County Council) Hammond Lane Metal Company Ltd. Permit 050(2)/OY/540/07 (Issued by Offaly County Council) Page 20 of 29

21 European Waste Catalogue Code Hazardous (Yes/No) Description of Waste Quantity /t No Broken Pallets / Timber Waste R No Spent Linings and Refractories 6.12 R No Furnace Slag R No Foundry Returns R4 Disposal/ Recovery Code Location of Disposal/ Recovery CJ Sheeran Ltd, Mountrath, Co. Laois. Hinch Plant Hire, Nyra, Mountmellick, Co. Laois. Hinch Plant Hire, Nyra, Mountmellick, Co. Laois. Co. Offaly. Name of Waste Disposal Recovery Contractor & Waste Collection Permit No. CJ Sheeran, Co. Laois. Permit 189(2)/OY/467/06 (Issued by Offaly County Council) Hinch Plant Hire, Mountmellick, Co. Laois. Permit WCP-OY (Issued by Offaly County Council) Hinch Plant Hire, Mountmellick, Co. Laois. Permit WCP-OY (Issued by Offaly County Council), Co. Offaly Yes Waste Oils 0 R Yes Fluorescent Tubes 0 R13 Enva Ireland Ltd, Portlaoise, Co. Laois Irish Lamp Recycling, Co. Kildare. Enva Ireland, Co. Laois. Permit 033(2)/OY/281/05 (issued by Offaly County Council) Irish Lamp Recycling, Co. Kildare. 035/OY/80/03 (issued by Offaly County Council) Page 21 of 29

22 3.2 Agency Monitoring and Enforcement There have been no notable differences between Agency monitoring and Cavanagh Foundry Ltd self-monitoring. Agency staff visited the facility during 2009 as detailed below: Agency visit to obtain surface water discharge samples from SW1 and SW Agency site inspection undertaken by Inspector Agency visit to obtain surface water discharge samples from SW1 and SW6. Pertaining to above site visits undertaken by Agency No issues or non-compliances were raised. 3.3 Energy and Water Consumption Energy Consumption Summary Table 4: Summary of Fuel Usage 2008 FUEL USAGE Electricity (MW/h) 4613 LPG Gas (litres) Light Fuel Oils (litres) Water Consumption Table 5: Summary of Water Usage 2008 WATER SOURCE USAGE m 3 On-site Ground Water 1447 On-site Surface Water 0 Municipal Supply 0 Page 22 of 29

23 3.4 Environmental Incidents and Complaints Environmental Incidents None Environmental Complaints None. 3.5 AER/PRTR Emission Data Return Worksheet AER emissions data return worksheets were uploaded to EPA website as required. Printed copies of uploaded information is detailed in Section 5.3. Page 23 of 29

24 Section 4 Management of the Activity Page 24 of 29

25 4.1 Introduction Environmental Objectives and Targets have been determined by incorporating IPPC licence, ISO and business environmental initiative requirements. 4.2 Schedule of Environmental Objectives and Targets In accordance with the facilities IPPC licence and ISO requirements an Environmental Management Programme operates on an ongoing basis within the business. This EMP has been updated to reflect additional business environmental targets and objectives. Table 8: Summary Table of Environmental Objectives and Targets for 2009 ENVIRONMENTAL OBJECTIVES Construct ancillary building to make provision for internal water based painting system. Install dry bag filtration abatement Equipment at A2-1. Install Class I full retention oil/silt Interceptor in rear yard area. Conduct Iron impact assessment of Milbrook stream. Discharge laboratory washings from soak pit to foul sewer/ ENVIRONMENTAL TARGETS Elimination of solvents associated with existi painting process. 80% reduction in total particulate discharge levels from furnaces (A2-1). Upgrade existing provisions to mitigate risks associated with unlikely event of oil/ petroleum spillage in yard. Ensure no detrimental impact from iron discharge on Milbrook stream. Remove discharge from GW to foul sewer Treatment plant. Relating to objectives and targets outlined above 4.3 below details a summarised account of progress in Page 25 of 29

26 4.3 Environmental Management Programme Report Construct ancillary building to make provision for internal water based painting system. Construction of Ancillary building was completed in August To facilitate operational process requirements it was decided to make provision for conversion to water based paint within existing external painting facility. Solvent based paint was replaced in one of the two paint tanks in October The 2 nd paint tank is being used to deplete existing stocks of solvent based paint which are expected to have been utilised by end of April At this time the 2 nd paint tank will be recommissioned using water based paint. No further solvent based paint will be purchased for painting of castings Install dry bag filtration abatement Equipment at A2-1. Installation of abatement equipment at furnace discharge stacks is currently scheduled for installation by end of The nature of installation requires no production to be taking place. Consequently, installation will take place during a shutdown period Install Class I full retention oil/silt Interceptor in rear yard area. Installation of Class 1 full retention oil/silt interceptor in rear yard was completed during Conduct Iron impact assessment of Milbrook stream. An external Environmental Consultancy company were engaged to conduct an Iron impact assessment of the Milbrook stream in February The results of this report found that the company complies with legislative requirements and that iron levels in surface water discharges did not adversely impact on milbrook stream. Full report is detailed in Section Discharge laboratory washings from soak pit to foul sewer During 2009 laboratory washings were re routed from old soakpit to foul sewer. Page 26 of 29

27 4.4 Environmental Management Programme 2010 In accordance with the facilities IPPC licence and ISO requirements an Environmental Management Programme operates on an ongoing basis within the business. This EMP has been updated to reflect additional business environmental targets and objectives for Table 9: Summary Table of Environmental Objectives and Targets for 2010 ENVIRONMENTAL OBJECTIVES Full conversion to water based painting. Install particulate filtration abatement Equipment at A2-1. Install particulate filtration abatement Equipment at A3-4. ENVIRONMENTAL TARGETS Elimination of solvents associated with existi painting process. 50% reduction in total particulate discharge levels from furnaces (A2-1). 30% reduction in total particulate discharge levels from furnaces (A3-4). 4.5 Decomissioning Management Plan/Residuals Management Plan/Environmental Liabilities Bord na Mona Report No. T370-ERMP previously submitted to the agency pertaining to Residual Management Plan (DMP) for the site was reviewed and deemed to remain applicable in it s current format As per condition an annual statement is included in section 5.4 which indicates the measures taken at the site in relation to the prevention of environmental damage and the financial provisions in place in relation to the underwriting of costs for any remedial actions. Page 27 of 29

28 Section 5 Licence Specific Reports Page 28 of 29

29 Section 5.1 Noise Monitoring Report Page 29 of 29

30 Section 5.2 Groundwater Monitoring Report Page 30 of 29

31 Section 5.3 AER Return Sheets Page 31 of 29

32 Section 5.4 Environmental Liabilities Statement Page 32 of 29

33 Statement of Measures in relation to Prevention of Environmental Damage and Remedial Actions (Environmental Liabilities) is equipped with a high level of environmental protection. Ongoing care for the environment is demonstrated by the ongoing upgrading of environmental protection systems/practices, and the notable reduction of plant emissions to the environment over the years. is a component site of EJ Group who are one of the largest manufactures of carriageway furniture in the world with headquarter in Michigan, USA. The Cavanagh Foundry site is a cost centre within the EJ Group and is therefore centrally funded from headquarters. The site operates to an agreed budget which is set in advance and which is intended to cover projected expenditure related to site operations for that financial year. A decision to decommission all or parts of Cavanagh Foundry site would be taken centrally by EJ Group under a coordinated review. Any such decision would be announced by EJ Group management which includes manager from Cavanagh Foundry facility. Any such decision would be announced sufficiently in advance to allow adequate opportunity to transfer production to other group facilities, to address legal and regulatory requirements and to complete decommissioning activities in full where required. Any closure decision would therefore be taken significantly in advance of implementation. Page 33 of 29

34 Section 5.5 Environmental Iron Assessment of Milbrook Stream Page 34 of 29