ANNUAL ENVIRONMENTAL REPORT THE HAMMOND LANE METAL COMPANY LTD. IED Licence P
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1 ANNUAL ENVIRONMENTAL REPORT for THE HAMMOND LANE METAL COMPANY LTD IED Licence P
2 Table of Contents 1. INTRODUCTION Facility Details Licenced Waste Activities Waste Management Record EMISSIONS FROM THE INSTALLATION PRTR Emissions Reporting RESOURCE AND ENERGY CONSUMPTION Energy Consumption COMPLAINTS AND INCIDENTS SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGETS ENVIRONMENTAL MANAGEMENT PROGRAMME NOISE MONITORING REPORT SUMMARY AMBIENT MONITORING SUMMARY TANK AND PIPELINE ASSESSMENT REPORT ENERGY EFFICIENCY AUDIT REPORT SUMMARY RAW MATERIALS USE EFFICIENCY PROGRESS IN WATER CONSUMPTION EFFICIENCY RECYCLING AND RECOVERY RATES FOR WEEE, ELVs, PACKAGING AND SHREDDER OUTPUT INFRASTRUCTURAL WORKS FINANCIAL PROVISION MANAGEMENT AND STAFFING STRUCTURE PUBLIC INFORMATION PROGRAMME
3 18. CLOSURE, RESTORATION AND AFTERCARE MANAGEMENT PLAN (CRAMP) ENVIRONMENTAL LIABILITIES COMPLIANCE WITH GROUNDWATER REGULATIONS PRTR Emissions Reporting
4 1. INTRODUCTION Hammond Lane Metal Company Ltd. (Hammond Lane) operates its Metals Recycling Facility in Ringaskiddy, Co. Cork, under an Industrial Emissions Licence (P ) issued by the Environmental Protection Agency (Agency). The site was developed from a greenfield site in It has been operating as a metal recycling facility since then. Prior to that, it was a grassland site used for grazing livestock. The EPA issued Industrial Emissions Licence P on the 28/11/16. Prior to this date, Hammond Lane operated under a waste permit issued by Cork County Council. Hammond Lane s site occupies approximately 0.96 hectares and is located on the L2545; the road extending east from Ringaskiddy towards Haulbowline. Infrastructure on the site includes a car park, administration offices, two weighbridges, two workshops/maintenance areas and a waste processing area. The site is bordered by woodland to the west, south and east, and by grassland to the north. 1.1 Facility Details Licence Registration Number: - P Name: - Location: - The Hammond Lane Metal Company Ltd. Ringaskiddy, Co. Cork Reporting Period: - 1 st January 31 st December Licenced Waste Activities The licensed activities carried out on site are classified below in accordance with the First Schedule of the Environmental Protection Agency Act (as amended) 1992: Class 11.1: The recovery or disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required Class 11.4 (b): Recovery, or a mix of recovery and disposal, of non-hazardous waste with a capacity exceeding 75 tonnes per day involving one or more of the following activities, (other than activities to which the Urban Waste Water Treatment Regulations 2001 (S.I. No. 254 of 2001) apply): i. biological treatment; ii. pre-treatment of waste for incineration or co-incineration; iii. treatment of slags and ashes; iv. treatment in shredders of metal waste, including waste electrical and electronic equipment and end-of-life vehicles and their components. 4
5 1.3 Waste Management Record Commodity LoW Code Weight (t) ASR (Automotive Shredder Residue) ,581 Non-Ferrous Metals Batteries EMISSIONS FROM THE INSTALLATION The following emissions are monitored at the installation: Emission Stormwater Groundwater Dust Soil Air Emissions from the Shredding Process Noise Monitoring Frequency Weekly Quarterly Quarterly Every 3 years Quarterly Annually Monitoring is ongoing, and exceedances are reported to the Agency via the EDEN system. Further information on exceedances are covered in the incidents summary below. 2.1 PRTR Emissions Reporting For the PRTR, emissions figures were estimated. The PRTR requires a total weight (kg) per year to be provided for each pollutant released to water, air and land. Hammond Lane does not have a flow rate monitor, so an estimate for the amount of stormwater discharging from the site had to be made. Based on experience from another site, this author applied an average of 2,000 L/day. From the data available, an average concentration for each pollutant was calculated and extrapolated to give a total weight in kg for one year. 3. RESOURCE AND ENERGY CONSUMPTION 3.1 Energy Consumption 2016 Type Consumption and Unit Electricity 160, Diesel 74,557 Litres 5
6 4. COMPLAINTS AND INCIDENTS 2016 A complaint was received on 30/01/17 pertaining to an explosion onsite. The management have explained that occasionally crushed end-of-life vehicles (ELVs) or bales of mixed metals enter the facility containing undetected gas cylinders inside. When these enter the shredder, the sudden release of pressurised gas causes a loud bang. Hammond Lane has since liaised with the complainant, the producer of the waste and the Agency about the matter, and at the time of writing, the issue was considered resolved. There was one recent incident relating to above-limit levels of suspended solids in stormwater discharge. Upon investigation, it was found that this was due to the infiltration of seawater into a stormwater attenuation tank. The reason for this occurring was deemed to be the malfunction of an offsite valve that did not belong to Hammond Lane. A full incident report was submitted to the Agency on 10/02/17. Hammond Lane promptly installed a nonreturn valve on the outflow pipe, which is expected to prevent further influx of seawater. A baffle was also installed to ensure the retention of solids inside the tank. 6
7 5. SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGETS 2017 Ref No. Environmental Objective Date for completion Person Responsible Measurement 01 Meet with customers more to ensure the best quality steel is delivered to site Ongoing CM, MB Monitored by V Boyle 02 Monitor energy consumption figures from 2017 onwards (ie: gas, oil, water, electricity) to improve energy efficiency in the future. Ongoing CM, JC V Boyle Monitored by V Boyle 04 Monitor water demand and the volume of trade effluent discharges from 2017 onwards to improve utilisation in the future. Ongoing CM, JC, V Boyle Monitored by V Boyle 05 Monitor progress on discharge licence for 2017 Ongoing CM, TC V Boyle Monitored by V Boyle 06 Upgrade of concrete works in yard- (commencing May 2017 for completion September 2017) Sept 2017 CM, JC V Boyle Monitored by V Boyle 07 Carry out a waste characterisation study of mixed metal loads in order to generate the data required for national statistical May 2017 CM /TC VB reporting under ELV directive 08 - PCB Management Plan implement procedures in compliance with the requirements of the Council Directive 96/59/EC on PDBS May 2017 CM, VB 09 - Air emission report to be carried out April 2017 April 2017 CM 10 - Training for air con removal in depo unit March 207 March 2017 CM 11 - Energy Efficiency report to be carried - March 2017 March 2017 CM 12 Training on IED and EMS requirements March 2017 CM 13 Achieve 95% recycling/recovery target for ELVs within 2 years % % % Ongoing CM, VB 7
8 6. ENVIRONMENTAL MANAGEMENT PROGRAMME This is currently being prepared by Cuthbert Environmental as part of the Environmental Management System (EMS), which is due for submission in May. 7. NOISE MONITORING REPORT SUMMARY Noise monitoring is conducted onsite annually and relevant reports are submitted to the Agency. The reports indicate that there was no significant noise production during the monitoring period in AMBIENT MONITORING SUMMARY This test (air emissions from the shredding process) was not carried out in Hammond Lane s licence was only issued in mid-november, and this testing was not required under the previous permit. 9. TANK AND PIPELINE ASSESSMENT REPORT A tank and pipeline integrity assessment was not carried out in It is scheduled to be carried out in ENERGY EFFICIENCY AUDIT REPORT SUMMARY This audit was not carried out in It was not required under the previous permit, and it is scheduled to be carried out in RAW MATERIALS USE EFFICIENCY These figures were not available for PROGRESS IN WATER CONSUMPTION EFFICIENCY As per Hammond Lane s schedule of environmental objectives and targets (2017), this issue will be monitored in the coming year. 13. RECYCLING AND RECOVERY RATES FOR WEEE, ELVs, PACKAGING AND SHREDDER OUTPUT Commodity Recovery Rate (%) WEEE 80 ELVs 90 Shredder Output INFRASTRUCTURAL WORKS No infrastructural works were carried out in In the first half of 2017, a fixed radiation detection unit will be installed as per licence condition This will be used in conjunction with hand-held detection devices to measure radiation levels of incoming material. 8
9 15. FINANCIAL PROVISION Cuthbert Environmental is preparing updates to the CRAMP and ELRA. Once these are submitted to the Agency and approved, financial provision instruments will be proposed to cover known and unknown liabilities. 16. MANAGEMENT AND STAFFING STRUCTURE Hammond Lane generally has 7 employees. This may fluctuate as temporary staff come and go. 1. Gregg Hodnett, Manager 2. Bart Millard, Office Manager 3. Darren Hodnett, Charge Hand 4. Philip Smith, Fitter 5. Trevor Hodnett, Shredclet- Operator 6. Denis Sheehan, Crane Driver 7. Arthur Mulcahy, Crane Driver 17. PUBLIC INFORMATION PROGRAMME Hammond Lane is fully-committed to providing the public, neighbouring residences and businesses with information relating to the environmental performance of the facility if requested. The facility has a designated meeting room which can be used for the public if they wish to review various reports, etc. All information in respect to the operation of the facility is maintained onsite and can be viewed upon request. Hammond Lane endeavours to provide information to the public in both a timely and accurate manner. 18. CLOSURE, RESTORATION AND AFTERCARE MANAGEMENT PLAN (CRAMP) As mentioned, Cuthbert Environmental is currently preparing the CRAMP for Hammond Lane. 19. ENVIRONMENTAL LIABILITIES Cuthbert Environmental is currently preparing an Environmental Liabilities Risk Assessment for Hammond Lane. Liabilities, as well as measures to minimise them, will be assessed in this report. 20. COMPLIANCE WITH GROUNDWATER REGULATIONS From the data available, it appears Hammond Lane was compliant with European Community Environmental Objectives (Groundwater) Regulations 2010 as amended. 9
10 20.1 PRTR Emissions Reporting Groundwater is monitored quarterly. The facility is completely self-contained on hardstand, and does not discharge directly to groundwater. Hammond Lane does not have the means to measure the quantity of leakage from pipes, tanks etc. into the soil, which would only occur on rare occasions due to damage or wear and tear. Furthermore, groundwater testing is conducted using boreholes around the site, which provides access to the water table but cannot directly sample direct discharges from the facility. Thus, it is impossible to provide an accurate estimate of pollutants released to groundwater on such a large scale (kg per year). When groundwater samples are analysed, it is impossible to differentiate accurately between background pollutant concentrations and those created by the facility. Any estimates made at this point would be speculative. 10
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