Guideline Template for Groundwater Monitoring Report for the Environmental Protection Agency (April 2016) (P )

Transcription

1 LICENCE REFERENCE No. RISK ASSESSMENT METHODOLOGY STAGE & STEP REPORT VERSION P Stage 1 FINAL Guideline Template for Groundwater Monitoring Report for the Environmental Protection Agency (April 2016) ()

2 Project Title: Licence No. Project No: Contract No. Groundwater Monitoring Report IE1145 N/A Report Ref: IE1145-Report-1631-Rev 1.1 Status: Client: Client Details: Issued By: FINAL c/o Andrew O Meara, Environmental Manager Redmondstown, Clonmel, Co. Tipperary. Document Production / Approval Record Prepared by (consultant) IE Consulting, Campus Innovation Centre, Green Road, Carlow. Name Signature Date Position % Input Á. Mc Elhinney 14/4/16 Project Hydrogeologist 95% Approved by (consultant) J. Keohane 14/4/16 Senior Hydrogeologist 5% Site Approval by Andrew O Meara Andrew O Meara 14/4/16 Environmental Manager N/A 2 11/04/16 IE1145 Report Version 1.0

3 LIMITATION The site information obtained for desk-based component of the assessment was based primarily on the following data sources: Groundwater monitoring data provided by ; Information provided by of groundwater sampling and laboratory analysis procedures; Previous site investigation reports; Site information from IPPC Licence application documents. 3 11/04/16 IE1145 Report Version 1.0

4 TABLE OF CONTENTS Section Page No EXECUTIVE SUMMARY... I 1. INTRODUCTION PROJECT CONTRACTUAL BASIS AND PERSONNEL INVOLVED BACKGROUND INFORMATION PROJECT OBJECTIVES SCOPE OF WORKS RATIONALE & STRATEGY GROUNDWATER SAMPLING AND MONITORING LABORATORY ANALYSES RESULTS AND DISCUSSION OF MONITORING PROGRAMME SITE HYDROGEOLOGY AND GROUNDWATER FLOW GROUNDWATER RESULTS POTENTIAL POLLUTANT LINKAGES SUMMARY, CONCLUSIONS AND RECOMMENDATIONS SUMMARY AND CONCLUSIONS RECOMMENDED WAY FORWARD FIGURES Figure 1 Figure 2 Figure 3 Figure 4 Site Location Overall Site Layout Detail of Site Layout Plan Groundwater Monitoring Well Locations Figure 5 Groundwater Contour Map (05/12/2013) Figure 6 Groundwater Contour Map (25/06/2014) Figure 7 Groundwater Contour Map (18/12/2014) Figure 8 Figure General Indicator Parameter Concentrations 2015 Heavy Metal Parameter Concentrations i 11/04/16 IE1145 Report Version 1.0

5 TABLE OF CONTENTS TABLES Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Target Activities for New Additional Monitoring Boreholes (AGW7 and AGW8) Summary of Site Groundwater Monitoring Point Installations Site Development from Historic Maps and Aerial Photographs Overview of Site Planning History Site Manufacturing Process Overview Summary of Potential Contamination Sources Site Environmental Setting Locations and Rationale of Site Groundwater Monitoring Points Table 9 Quarterly Static Water Level Measurements for 2014 Table 10 Table 11 Table 12 Table 13 APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Groundwater Level Fluctuation Data for the Period Historical Trends in ( ) for Key Parameters Site Potential Pollution Linkages Target Activities for Proposed Additional Monitoring Boreholes Borehole Logs for On-Site Monitoring Points Flow Charts for Manufacturing and Wastewater Processes Geological Survey of Ireland Webmapping ALS Laboratory Accreditation Certificates of Analysis Tabulated Groundwater Analysis Results Graphs of Parameter Exceedances ii 11/04/16 IE1145 Report Version 1.0

6 EXECUTIVE SUMMARY was first granted an Integrated Pollution Prevention Control (IPPC) licence by the Environmental Protection Agency (EPA) on the 16 th April 1996 (Reg. No. P ) for the manufacturing of fibreboard installations, with a production capacity equal to, or exceeding, 25,000 tonnes of product per year. The licence was reviewed on the 30 th of November 2001 (Reg. No. ).The facility was developed on a green field site previously set aside for agricultural purposes. A total of six monitoring boreholes (AGW1-AGW6) were installed as part of a groundwater monitoring network to provide information on the state of the groundwater environment beneath the site. Since the commencement of operations in 1983, some materials have been deposited in a landfill to the north-west of the plant, adjacent to the log storage area. The landfill was built on existing ground, sloping to the east, and comprises an area of approximately 1 ha. The Contaminants of Potential Concern (CoPC s) and the parameters that would indicate an issue with the groundwater beneath the site are as follows: phenols, ammonium, formaldehyde, diesel range organics, petrol range organics, mineral oil, heavy metals, elevated ph, sodium, chloride and orthophosphate. The main objectives of this report were to review the groundwater quality for the 2015 period and identify any increasing or decreasing trends in CoPC s and to assess the suitability of the current groundwater monitoring network to adequately define the groundwater conditions beneath the site. The overall increasing trends in nickel and nitrate in the upgradient borehole, MW1, suggest that groundwater flowing into the site has been contaminated from activities upgradient of the landfill. The increasing trends in chloride, ammonia and heavy metals in LF1 suggest that the landfill may be impacting on downgradient groundwater quality. The existing groundwater monitoring network meets the original objective i.e. to provide information on the state of the groundwater environment beneath the site and to intercept groundwater flow upgradient and downgradient of the site. Two additional monitoring boreholes (AGW7 and AGW8) were installed at the site, in locations agreed with the agency in January These boreholes have not been sampled to date but will be included in all future monitoring rounds. i 16/3/16 IE1145 Report Version 1.0

7 Conceptual Site Model Old Monitoring Borehole Names MW1 MW2 MW3 MW4 LF1 LF2 New Monitoring Borehole Names AGW3 AGW4 AGW5 AGW6 AGW1 AGW2 i 16/3/16 IE1145 Report Version 1.0

8 EPA Contaminated Land & Groundwater Risk Assessment Methodology Report Reference Report Date Status STAGE 1: SITE CHARACTERISATION & ASSESSMENT 1.1 PRELIMINARY SITE ASSESSMENT GES Report No.E Final 1.2 DETAILED SITE ASSESSMENT GES Report No. 98/29/ Final 1.3 QUANTITATIVE RISK ASSESSMENT OUTLINE CORRECTIVE ACTION STRATEGY FEASIBILITY STUDY & OUTLINE DESIGN DETAILED DESIGN 2.4 FINAL STRATEGY & IMPLEMENTATION PLAN 3.1 ENABLING WORKS 3.2 CORRECTIVE ACTION IMPLEMENTATION &VERIFICATION ii 16/3/16 IE1145 Report Version 1.0

9 3.3 AFTERCARE iii 16/3/16 IE1145 Report Version 1.0

10 1. INTRODUCTION 1.1. PROJECT CONTRACTUAL BASIS AND PERSONNEL INVOLVED IE Consulting were engaged by to undertake an assessment of the 2015 groundwater monitoring data for the facility at Redmondstown, Clonmel, Co. Tipperary (Figure 1) as per a proposal dated 24 th February 2015 (Reference AW/IE090/1609). The consultants involved in the project are listed below: Áine Mc Elhinney BSc. (Hons) Geology, MSc. Applied Environmental Science - 6 years experience. Jer Keohane BSc. Geology, MSc. FCIWEM, MIEI - with 31 years experience BACKGROUND INFORMATION Site Overview was first granted an Integrated Pollution Prevention Control (IPPC) licence by the Environmental Protection Agency (EPA) on the 16 th April 1996 (Reg. No. P ) for the manufacturing of fibreboard installations, with a production capacity equal to, or exceeding, 25,000 tonnes of product per year. The licence was subsequently reviewed on two occasions (Reg. No. and P ). The most recent licence review (Reg. No. P ) is currently in process. The entire site layout within the EPA licence boundary is presented in Figure 2 and a closer map showing the layout of the plant is presented in Figure 3. Groundwater Monitoring Network In May 1995, as part of the original application to the EPA for an IPPC licence, GES (an associate company of IE Consulting) was requested by to assist in developing a groundwater monitoring network (Report No. E ). A total of four groundwater monitoring boreholes MW1, MW2, MW3 and MW4 were installed as part of the network (Figure 4) to provide information on the state of the groundwater environment beneath the site. (These boreholes were subsequently renamed AGW3, AGW4, AGW5 and AGW6 in 2015 following updated EPA licensing nomenclature). The boreholes were located so as to be spatially representative of the site and to intercept groundwater flow upgradient and downgradient of the site. Two additional monitoring boreholes (AGW7 and AGW8) were installed at the site, in locations agreed with the agency in January These boreholes have not been sampled to date but will be included and discussed in all future monitoring rounds. A summary table of the proposed target site activities for each of the new boreholes is presented below: 1 20/4/15

11 Borehole ID Upgradient Target Activities AGW7 AGW8 Fuel, chemical and raw material storage areas, chip yard, boiler house. Energy plant, warehouse and shipping, septic tank and percolation area, raw material storage area. Table 1. Target Activities for New Additional Monitoring Boreholes (AGW7 and AGW8) Landfill Monitoring Since the commencement of operations in 1983, some materials have been deposited in a landfill to the north-west of the plant, adjacent to the log storage area (Figure 4). The landfill was built on existing ground, sloping to the east, and comprises an area of approximately 1 ha. The materials deposited at the landfill are described as being mainly wood based i.e. fibre, sander dust (containing ~ 6-8% ammonium polyphosphate) and reject board (unsuitable for recycling). Since 1986, settled sludge from the surface water settlement lagoons was also landfilled (containing ~1% ammonium polyphosphate and small quantities of urea formaldehyde resin). In addition, considerable quantities of excavated clean soil were deposited in the landfill in 1994 during site construction works. In late , GES were retained by to evaluate the impact of the site landfill on the environment. This involved the drilling of a borehole (LF1 - now renamed AGW1) east of the site landfill to monitor groundwater downgradient of it. In addition, four shallow gas monitoring points (TP1-TP4) were installed within the landfill to monitor gas emissions from the landfill (Figure 4). In late 1997, GES were requested to locate a suitable position for an additional groundwater monitoring borehole (LF2 now renamed AGW2) downgradient of the landfill to further investigate the findings of the monitoring results from the first borehole (LF1/AGW1). A report prepared by GES on 16/07/98 (Report No. 98/29/01) detailed a qualitative risk assessment and impact appraisal of the on-site landfill. The investigation indicated elevated concentrations of ammonia downgradient of the landfill. However, a water balance assessment, together with an assessment of monitoring data, indicated adequate available dilution and attenuation downgradient of the landfill, which resulted in no significant off-site movement of contaminants. It was recommended in GES Report No. 98/29/01 that the boreholes be sampled on a monthly basis for at least twelve months to establish a groundwater quality database. Regular monitoring has been undertaken on a quarterly basis since June 1999, with the most recent analysis results from 2015 discussed as part of this report. A summary of the information available for the six groundwater monitoring boreholes is presented in Table 2 below. The logs for the boreholes are presented in Appendix A. 2 20/4/15

12 Well Details AGW1 (formerly LF1) AGW2 (formerly LF2) AGW3 (formerly MW1) AGW4 (formerly MW2) AGW5 (formerly MW3) AGW6 (formerly MW4) AGW7 AGW8 Year of Installation National Grid Coordinates E N E N E N E N E N E N E N E N Drilled Well Depth (m) Internal diameter (m) Screen Length (m) Depth to Bedrock (m) Drilling Log Summary Measured Well Depth (m) m: *Not recorded on log CLAY and STONES 6-18m: Brown, silty CLAY m: Brown, silty SAND and GRAVEL m: Red, hard, consolidated CLAY m: Weathered DOLOMITE and CLAY m: Weathered DOLOMITE m: Pale grey DOLOMITE 0-2 m: CLAY and STONES 4-14 m: Pale coloured, hard DOLOMITE m: Red coloured, weathered, DOLOMITE and silty veins. 0-4 m: Gravelly CLAY 4-34 m: LIMESTONE with DOLOMITE bands 0-6 m: Loose, very clayey/silty, fine SAND 8-10 m: GRAVEL m: LIMESTONE 0-12 m: Loose, very sandy CLAY, with silty fine SAND m: LIMESTONE 0-16 m: Stiff, orange, sandy/gravelly CLAY m: LIMESTONE Fill MADE GROUND Grey brown firm CLAY Orange brown sandy CLAY Light brown SAND with fine gravel Varying weathered/comp etent DOLOMITE (See log Appendix x for full details) Fill MADE GROUND Sandy gravelly CLAY Gravelly SAND LIMESTONE DOLOMITE LIMESTONE Table 2. Summary Details for Groundwater Monitoring Boreholes 3 20/4/15

13 Site Development History The facility was developed on a green field site previously set aside for agricultural purposes. An overview of the site development and planning history, as noted on historical maps, aerial photography and planning files, is presented in Tables 3 and 4 below. Year Source Record of Site Development inch map Green field site inch map Green field site Aerial photograph Facility comprised two large main buildings along with additional smaller structures, car park and storage areas 2000 Aerial photograph Additional structure near western boundary of site Aerial photograph Additional structure near eastern & southern boundary of site. Extension to structure directly south of eastern main factory building 2013 Aerial photograph No visible change Table 3. Review of Site Development from Historic Maps & Aerial Photographs 4 20/4/15

14 Planning File No. Date of Grant of Planning Permission Development Description P /07/81 Manufacture of medium density fibreboard (MDF) from native Irish forest thinning. P /10/81 Site development. P /10/81 Site development works west of line for MDF plant. P /01/82 Construction of warehouse. P /08/82 Construction of medium density fibreboard plant. P /10/82 Construction of a new 110 kv electrical sub-station. P /10/85 Storage and utilisation of anhydrous ammonia. P /02/87 Erection of two storey office and lab extension to plant. P /03/89 Relocation of weighbridge, road re-alignment, chain link fence P /01/90 Demolition of farm house /10/95 Replacement of existing fibre dryer /08/11 Installation of new plant structures within existing facility and construction of two extensions to this facility with a floor area of circa 360 m 2. FS /02/12 Two extensions /05/12 Construction of a new chip storage area consisting of a store 450 m 2 and an external concrete apron. Table 4. Overview of Site Planning History The production lines at the facility are used for the manufacturing of MDF boards. The two production lines operate in parallel. Both lines share the same chip processing facility and similar finishing facilities further downstream. A flow chart showing the manufacturing and wastewater processes, as developed by, are presented in Appendix B. A summary of the MDF manufacturing process is presented in Table 5 below. Process Process/Activity Product/Bi-product Use Log and chip handling *Wood debarking *Log chipping *Wood bark *Wood chip *On-site fuel source *MDF product Refining *Pre-steaming of chips *High pressure steaming *Excess water removal *Excess water *Wastewater treatment plant *MDF product *Refining by grinding chips to fibres *Addition of resin and additives solutions Dryers *Direct/indirect heating of fibres *Dried fibre by boiler flue gases and steam Forming and Pressing *Fibres are passed through forming head and compressed to required thickness, cut and cooled *Wood fibre mats Finishing *Sanding and grading of boards *Final products *Sander dust and board cut-offs Table 5. Site Manufacturing Process Overview The site manufacturing processes are supported by the following activities and service: *Distribution/shipment *On-site fuel source 5 20/4/15

15 On-site wastewater treatment plant treats sanitary effluent and process effluent (mainly wood chip squeezing water); Two on-site septic tanks and percolation areas; Surface water interceptor settling ponds; Maintenance area; Bulk and drum chemical storage; Laboratory facilities; Administration offices; Engineering services; Fire water storage ponds. The energy requirements are provided by the following: Recovery of waste wood biomass in two boilers and the on-site Energy Plant; Electricity; Natural gas; Liquified Petroleum Gas (LPG); Diesel fuel. A summary of the potential contaminant sources relating to site processes and service activities is presented in Table 6 below. The locations of these sources within the site boundary are shown on Figure /4/15

16 Raw materials Fuels / Heating Utilities Wastewater Treatment Chemicals Maintenance Materials Laboratory Chemicals Contaminants of Potential Concern (CoPCs) Resin for adhesion (Urea Formaldehyde, Melamine Urea Formaldehyde) Waxes (Paraffin and Montan) Urea Fire retardants(e.g. Ammonium Polyphosphate) Colorants (water based) Wood biomass Liquified Petroleum Gas (LPG) Thermal fluid for heat transfer Gas Oil (Diesel Oil) Hydrochloric Acid Sodium Hydroxide Sodium Chloride (salt) Betz products (Biocides, Corrosion Inhibitors, Scale) Aluminium chloride (flocculant) Polymers (for sludge Dewatering) Polymers (coagulant) Anti Foams Nutrifeed (nutrient) Sodium Hypochlorite 15% Hydrated Lime Oils (lubricating, hydraulic) Degreaser Toluene, Acetone, COD reagent, Acids, Bases Table 6. Summary of Potential Contamination Sources Based on the above review of the site activities the Contaminants of Potential Concern (COPCs) and the parameters that would indicate an issue with the groundwater beneath the site are as follows: Phenols; Ammonium; Formaldehyde; Diesel range organics; Petrol range organics; Mineral oils; Heavy metals; Elevated ph; Sodium; Chloride; Orthophosphate * not analysed in /4/15

17 Environmental Setting An overview of the relevant information on rainfall, topography, land use, hydrology, and hydrogeology pertaining to the site is discussed below. Topography (Figure 1) Regionally, the topography is dominated by the Comeragh Mountains to the south and Slievenamon to the north-east. Locally, the land slopes from north-west to south-east towards the Anner River from a local high point elevation of 60 m OD west of the site. The ground elevation in the vicinity of the site is c. 25 m OD. The original land surface sloped from c. 45 m OD at the north-western corner of the site to approximately 22 m OD at the eastern side of the site. However, this original topography was modified to create a level site. Hydrology (Figure 2) The site is located in the River Suir Valley. The River Suir flows eastwards c. 1 km south of the site. The Anner River, a tributary of the River Suir, flows in a southerly direction, approximately 100 m east of the site. The confluence of the Anner River with the River Suir is approximately 1 km downstream of the site. Topsoil On the Teagasc soils map the site itself is classified as Made Ground. The soils surrounding the site are mainly mapped as deep well-drained acidic mineral soils (AminDW), comprising Acid Brown Earths or Brown Podzolics with smaller areas of deep poorly drained mineral soil derived from mainly acidic parent materials (AminPD). Alluvial deposits (AlluvMIN) associated with the Anner River are mapped to the east of the site. Subsoils Teagasc subsoil mapping indicates the area of the site is classified as MADE GROUND. The subsoils in the surrounding area are mapped as Till derived chiefly from Namurian Ricks (TNSSs) (shale and sandstone till). The GSI s recharge map classifies the till as being moderately permeable. Alluvial deposits (A) are mapped along the Anner River channel to the east of the site. Site-specific information on subsoils is available from drilling of the eight groundwater monitoring boreholes (see summary of borehole logs in Table 2). Subsoils encountered comprised mainly sandy/gravelly CLAY. In AGW4 in the northeastern area of the site the subsoils comprised 10 m of SAND/GRAVEL over bedrock. In AGW1, immediately east of the landfill, a thick band of SAND/GRAVEL was encountered from m. Small pockets of gravel such as this are common along the Anner River (GES Report 98/29/01). In addition, subsoil information was available from a geotechnical investigation undertaken in 1981 to assess ground conditions for the plant foundations. The site investigation comprised 21 No. boreholes to depths ranging from m bgl. The original report or logs were not available for review as part of this report, but the subsoils encountered were summarised as comprising mainly gravelly CLAY or SILT/CLAY overlying 2-3 m of dense, fine to medium grained GRAVEL transitioning into weathered bedrock (GES Report 98/29/01). 8 20/4/15

18 Depth to Bedrock The depth to bedrock beneath the site is highly variable. Based on the information obtained from the borehole logs the depth to bedrock ranges from 2.7 m to 27 m below ground level. Groundwater Vulnerability (Map 2, Appendix C) The groundwater beneath the main factory site is mapped as Moderate (M) vulnerability with areas of High (H) vulnerability extending to the west. An area of Extreme (E/X) vulnerability coincide with the mapped topographic high west of the site. Bedrock & Structural Geology (Map 3 and Map 4, Appendix C) The site is mapped as underlain by the Waulsortian Limestones, described as massive un-bedded lime-mudstones containing original cavities filled with calcareous cement. This bedrock is characterised by zones of intense fracture cleavage. Typically, the upper 2-3 m is loose and weathered. The closest regional fault is mapped at approximately 1,350 m east of the site. The regional faults trend predominantly in a north-south direction and also an east-west direction. In a regional geological context, the site is mapped within a heavily faulted east-west aligned structure, namely the Carrick-on-Suir Syncline. Although the bedrock underlying the site is not mapped as WAdo (Waulsortian dolomititised) site specific drilling records indicate the site is underlain by dolomitised limestones (AGW1, AGW2, AGW3, AGW7 & AGW8). Dolomitisation has the effect of increasing the porosity and thus permeability of limestone. The variable depth to bedrock recorded is indicative of a mature karst bedrock landscape. Aquifer Classification (Map 4, Appendix C) The bedrock formation is classified as a Regionally Important Aquifer dominated by diffuse flow (Rk d ). Groundwater flow is through karstified conduits, developed as a result of solutional widening of calcite-filled cleavage planes, original cavities, fissures and fractures, especially fault zones. Groundwater Body (Map 4, Appendix C) The site is located in the Clonmel groundwater body (GWB), the key characteristics of which have been identified by the Geological Survey of Ireland (GSI) as follows: Transmissivity values for the Carrick-on-Suir Syncline limestones are given as 100-2,000 m 2 /d; Most recharge takes place through the till subsoil deposits and may receive indirect recharge from the north and south from the Lower Palaeozoic mountains; Most of the groundwater moves relatively rapidly along short flow paths and discharges into the streams which cross the aquifers; Hydraulic gradients in the Waulsortian Limestone are typically low ( ); Flow in the karstified systems tends to be conduit flow along the fault zones. There are considerable variations in the hydrogeological conditions in this aquifer unit, owing to the wide range in elevation of the outcrop areas and its karstic nature; Conditions in the main limestone aquifers are predominantly unconfined, as the water table is generally less than 10 m from the surface; 9 20/4/15

19 The annual water table fluctuation is probably less than 5 m in the better aquifers. The groundwater body is categorised as having good status but is classified as at risk of failing to meet the 2015 Water Framework Directive (WFD) objectives. Groundwater Recharge (Map 5, Appendix C) According to the average recharge beneath the site is 136 mm/yr, probably due to the developed nature of the site. The average recharge in the area surrounding the site is 407 mm/yr, based on the hydrogeological setting (Rk d aquifer; moderate groundwater vulnerability, moderate permeability subsoil and overlain by well-drained soil). The recharge coefficient for the surrounding area is taken as 60 % of the effective rainfall (679 mm/yr) /4/15

20 1.3. PROJECT OBJECTIVES The objectives for the 2015 groundwater monitoring report are as follows: To review the groundwater quality for the 2015 period; To identify any increasing or decreasing trends in Contaminants of Potential Concern (CoPC) and contamination indicator parameters; To assess the overall groundwater quality in the context of Conceptual Site Model (CSM); To provide up-to-date groundwater contour maps of the site based on topographic surveying and water level measurements etc.; To assess the suitability of the current groundwater monitoring network to adequately define the groundwater conditions beneath the site SCOPE OF WORKS RATIONALE & STRATEGY The sampling locations for the 2015 groundwater monitoring are presented in Figure 4. The rationale for the chosen monitoring point locations was discussed in Section 1.2 and is summarised in Table 7 below. AGW3 (MW1) AGW4 (MW2) AGW1 (LF1) AGW2 (LF2) AGW5 (MW3) AGW6 (MW4) Overall upgradient monitoring point for the site Downgradient of landfill close the Anner River Downgradient of landfill Downgradient of landfill (to confirm monitoring results in AGW2 (LF1) Overall downgradient of northern section of facility Overall downgradient of southern section of facility Table 7. Locations & Rationale for Site Groundwater Monitoring Points AGW3 (MW1) was installed to provide information on overall background water quality. The monitoring boreholes AGW1 (LF1) and AGW2 (LF2) were specifically installed to target the landfill. The monitoring boreholes, AGW4 (MW2), AGW5 (MW3) and AGW6 (MW4), were installed to monitor the groundwater flowing towards the Anner River from the main site. The parameters included in the groundwater monitoring programme are those set out in Schedule 4(ii) of the EPA IPPC licence. These parameters are: ph; Trace organics (as per USEPA Method 524.4); Major anions; Major cations; Individual heavy metals; 11 20/4/15

21 Ammonia GROUNDWATER SAMPLING AND MONITORING Water Level Monitoring The static groundwater level in each borehole is recorded by personnel as part of the quarterly groundwater monitoring programme (as per Schedule 4(ii) of the IPPC licence). The water levels are recorded prior to purging and sample collection. The top of the steel casing is used as a reference point for measurements in all boreholes. The groundwater levels recorded in 2015 are presented in Table 8 below. Date AGW3 (MW1) AGW3 Reduced Water Level (mod) AGW4 (MW2) Depth to Water Table (m below top of steel casing) AGW4 Reduced Water Level (mod) AGW5 (MW3) AGW5 Reduced Water Level (mod) AGW6 (MW4) AGW6 Reduced Water Level (mod) AGW1 (LF1) AGW1 Reduced Water Level (mod) AGW2 (LF2) AGW2 Reduced Water Level (mod) 31/03/ /04/ /06/ /09/ Table 8. Quarterly Static Water Level Measurements for 2015 The water level data presented above indicate that the depth to the water table is highly variable, ranging from ~28 m (LF1) below the top of casing to closer to ground level (MW1). This reflects the sloping topography of the site towards the Anner River. The groundwater level fluctuation data for the 2006 to 2015 period, as shown in Table 9 below, indicates that the water level fluctuations in the site boreholes is less than 6 m, which coincides well with the expected characteristics of the groundwater body, as discussed in Table 6 above. Borehole Fluctuation* (m) MW MW MW MW LF LF Table 9. Groundwater Level Fluctuations 2015 *This table shows the difference between the maximum and minimum groundwater levels measured at each borehole throughout each year Collection of Wellhead Parameters No unstable hydrochemical parameters are currently recorded during purging and sampling. However, the sampling protocol for the site has been updated to include the proposed measurement of the following field parameters: temperature, ph, electrical conductivity /4/15

22 Sampling Techniques and Protocols Sampling of the six boreholes is carried out by personnel based on an updated site sampling protocol. A 50 mm diameter mobile submersible sampling pump is used for purging and sampling. The pump is decontaminated with Decon 90 and rinsed with clean water prior to the commencement of sampling and between boreholes in order to prevent cross-contamination. The following steps are carried out for sampling: Pump Decontamination; Record water level; Well volume calculation; Remove three well volumes; Collect sample. Sample Containers/Bottles The 2015 samples were analysed by ALS Laboratory in Clonmel, Co. Tipperary. According to the laboratory, the following sampling containers were used for the collected samples: Plastic HDPE (high density polyethylene) containers; Glass vials for semi-volatile and volatile parameters. Filtering/Preservation Protocols According to ALS Laboratory, all samples are acidified on receipt in Prague for metal and major cations. Sampling Events: A total of 4No. quarterly groundwater samples were taken from each of the on-site monitoring boreholes on the dates set out in Table 8 above. Sample Handling Protocols Samples were collected by ALS Laboratory and transported in cool boxes to Clonmel or delivered to the laboratory by personnel on the day of sampling. On receipt of samples in the laboratory in Clonmel and prior to transfer, storage is by refrigeration on which temperature monitoring is performed daily. Samples are packed the next morning with cool blocks in boxes and transported by courier to the sister laboratory (ALS Prague) for next day delivery with DHL. All information on samples sent is communicated to ALS Prague from the laboratory in Clonmel and 13 20/4/15

23 sample receipt confirmations are ed when the samples are received in Prague LABORATORY ANALYSES All 2015 samples were analysed by ALS laboratories in Clonmel, which is located approximately 3 km south-west of the site. Samples are either collected by ALS or delivered to ALS by Medite personnel. None of the parameters were subcontracted in However, the majority of parameters analysed were carried out in ALS Prague (see Appendix D for laboratory accreditation). The certificates of analysis for the 2015 data are presented in Appendix E. The parameter groups for the samples analysed are presented in Section above. All tabulated results from the 2015 groundwater analyses are presented in Appendix F. The graphs of parameter exceedances are presented in Appendix G. The analysis results were compared with the following legislation and guidance sources: European Communities Environmental Objectives (Groundwater) Regulations 2010 (S.I. No. 9 of 2010); Environmental Protection Agency (EPA) Interim Guideline Values (IGVs). Where a result exceeded more than one standard/guideline, then the result was highlighted against the lower (more stringent) standard. 2. RESULTS AND DISCUSSION OF MONITORING PROGRAMME 2.1. SITE HYDROGEOLOGY AND GROUNDWATER FLOW Site Groundwater Flow Regime Further to a request for additional information by the EPA concerning the landfill monitoring programme (Appendix H), the following works were undertaken in December 2013 to confirm the groundwater flow regime beneath the site: GPS topographical survey of groundwater boreholes MW1, MW2, MW3, MW4, LF1 and LF2. National grid based x and y co-ordinates for each borehole and the topographical level to the top of each borehole related to Ordnance Datum and to an accuracy of +/ m were obtained; The groundwater boreholes were positioned on a GIS based vector map; One round of groundwater level measurements was undertaken on 5 th December 2013 at all borehole locations using a dip meter with an accuracy of +/-0.001m; Groundwater levels at all boreholes were calculated related to Ordnance Datum; A groundwater contour map was developed based on the groundwater levels at each borehole location. The resulting groundwater contour map is presented in Figure 5 from which the following observations and interpretations were made in relation to the groundwater flow regime beneath the site: The groundwater flow gradient beneath the site is low, at 0.001, which is reflective of both 14 20/4/15

24 the karstified nature of the bedrock and the proximity of the site to the Anner River; The overall groundwater flow direction is towards the Anner River. However, based on the contour map generated from the groundwater monitoring points, there appears to be a zone of preferential groundwater flow along the northern to north-eastern section of the site. This may be reflective of a zone of higher bedrock permeability compared to the surrounding bedrock e.g. dolomitisation as noted in the LF1 borehole log; The groundwater flow direction suggests that the MW2 is upgradient of the landfill and the main site activities; MW3 and MW4 boreholes are representative of the overall downgradient quality from the main site area; The groundwater quality data beneath the main factory site is limited to MW3 and MW4 monitoring points (AGW7 and AGW8 will provide additional information on groundwater quality beneath the main factory site in 2016). Following on from the 2013 groundwater level monitoring, IE Consulting carried out two additional groundwater level monitoring rounds using a dipper with an accuracy of +/ m. The groundwater contour maps for the water level measurements taken on 25 th June 2014 and on 18 th December 2014 are presented in Figures 6 and 7, respectively. The groundwater contour maps confirm that the groundwater flow direction is variable, with the inferred groundwater flow direction to the south-east, south/south-east and south as indicated in Figures 5-7. Following the installation of the additional groundwater monitoring boreholes (AGW7 and AGW8) in January 2016, and collation of 4 groundwater level monitoring rounds using a dipper with an accuracy of +/ m an updated groundwater contour map will be prepared for the site. Site Hydrogeology Beneath the site, groundwater flow is in the Waulsortian Limestones, described as massive, unbedded lime-mudstones containing cavities filled with calcareous cement and dolomitised limestone. The bedrock is classified as a regionally important aquifer (Rk d ), which indicates that groundwater flows through karstified conduits. The presence of dolomitised limestone beneath the site is evident from the LF1 borehole in which the bedrock was described as completely dolomitised (and new monitoring borehole data, see Table 2). The underlying bedrock forms part of the Clonmel Groundwater Body (GWB). Based on Initial Characterisation Report monitoring is currently being undertaken by the EPA on the Clonmel GWB. The groundwater levels beneath the site range from c. 28 m below ground level in the north-western section of the site to close to ground level near the Anner River. The groundwater gradient beneath the site is 0.001, which is considered a low gradient. The groundwater flow paths are considered to be horizontal beneath the site. However, vertical flow paths are likely to exist closer to the Anner River, where groundwater discharges to the river /4/15

25 2.2. GROUNDWATER RESULTS Introduction A total of 4No. samples were taken from each of the 6No. on-site monitoring wells during the 2014 monitoring period (see Appendix E). The groundwater monitoring trends for key parameters are discussed below (see Appendix F). In relation to the concentrations of the analytes reported by the laboratory (Appendix E), the following should be noted: Ammonia/ammonium The parameter was analysed and reported as mg/l NH 3 -N for all 2013 sampling rounds and for the Q1 and Q2 sampling rounds in 2014 and, as such, could not be compared to the legislation and guidelines, although a comparison was made between 2013 and 2014 results. Results for the Q3 and Q4 sampling rounds in 2014 and 2015 were analysed and reported as the concentration of ammonium (mg/l NH 4 + ), which can be compared to the EPA IGV for ammonium. These results were converted to concentrations of ammonium as N (mg/l NH 4 - N) so that they could be compared to results from 2000 to 2012 and to the Groundwater Regulations TV. Total metals/dissolved metals Heavy metals were analysed and reported as concentrations of total metal only in Q1 of Subsequent sampling rounds in 2014 (Q2, Q3 and Q4) were analysed for both total metal and concentrations of dissolved metal. All sampling rounds in 2015 were analysed for both total metal and concentrations of dissolved metal. Alkalinity, Orthophosphate and Potassium These parameters were not analysed during 2015 due to an oversight by the laboratory. The groundwater results are discussed below in terms of the exceedances of the Groundwater Regulations and the EPA IGV, in the overall context of the confirmed site groundwater flow direction (Figure 5): Upgradient of site AGW5 (MW1), (AGW4) MW2 Downgradient of site (AGW5) MW3, (AGW6) MW4 Downgradient of landfill (AGW1) LF1, (AGW2) LF2 The spatial concentrations of general indicator parameters and of heavy metals are presented in Figure 8 and Figure 9, respectively. AGW3 (formerly known as MW1) AGW3 is considered to be the upgradient borehole for the site and the groundwater contour map (Figure 5) supports this fact. No sample was taken from AGW3 during Q3 as the borehole was dry. Chloride concentrations ranged from 16.8 mg/l to 33.6 mg/l. Concentrations of Chloride exceeded the lower groundwater TV for the Q4 quarterly monitoring round of /4/15

26 Calcium concentrations ranged from 182 mg/l to 398 mg/l, exceeding the EPA IGV in samples Q1 and Q2. The sample from Q1 was particularly high at 398 mg/l. However, high calcium concentrations are also characteristic of the limestone bedrock beneath the site and surrounding area. Calcium concentrations display a decreasing trend during monitoring in Total petroleum hydrocarbons (TPH) was detected at a level of 0.18 mg/l in the sample from Q1 and Q4 respectively, which is above the EPA IGV. Hydrocarbon concentrations from Q2 and Q4 were below the LOD. There is no groundwater TV for TPH. AGW4 (formerly known as MW2) Based on the updated groundwater map, AGW4 is considered to be upgradient of the site and generally has good groundwater quality. Dissolved arsenic was detected at a level of mg/l in the sample from Q which exceeds the groundwater TV of mg/l. Total petroleum hydrocarbons (TPH) was detected at a level of 0.10 mg/l and 0.11 mg/l in samples from Q2 and Q4 respectively, which is above the EPA IGV. Hydrocarbon concentrations from Q1 and Q3 were below the LOD. There is no groundwater TV for TPH. AGW5 (formerly known as MW3) AGW5 is situated between the factory and the river, and is downgradient of the northern section of the factory site. Ammonium (NH 4 ) exceeded the threshold value (TV) in Q3 of Ammonia as NH 3 -N also exceeded the TV in Q3 of Chloride exceeded the lower groundwater TV in Q4 of Total petroleum hydrocarbons was detected at a level of 1.57 mg/l, which is above the EPA IGV of 0.01 mg/l, in the sample from Q4. The other three available samples were below the LOD. AGW6 (formerly known as MW4) AGW6 is situated at the south-eastern corner of the site, south of MW3. The groundwater contour map indicates that MW4 is downgradient of the southern section of the factory site. There were no exceedances of either the EPA IGV or the groundwater TV during AGW1 (formerly known as LF1) LF1 is situated downgradient of the on-site landfill. Groundwater quality is compromised at this location. Ammonium (NH 4 ) exceeded the lower Threshold Value (TV) during all monitoring rounds, ranging from 0.21 mg/l to 0.57 mg/l. Concentrations of ammonia as NH 3 -N also exceeded the lower Threshold Value (TV) during all monitoring rounds, ranging from 0.16 mg/l to 0.44 mg/l /4/15

27 Dissolved cadmium exceeded the corresponding groundwater TV and EPA IGV in Q1, Q2 and Q3 in Concentrations of dissolved cadmium ranged between <0.004 mg/l and mg/l. Cadmium concentrations increased during Q1, Q2 and Q Cadmium concentrations subsequently decreased significantly during Q Calcium concentrations exceeded the EPA IGV on all sampling occasions, ranging in concentration between 208 mg/l and 224 mg/l. Calcium concentrations displayed an upward trend during Chloride concentrations exceeded the lower groundwater TV during all monitoring rounds, ranging from 24.9 mg/l to 29 mg/l. Choride concentrations displayed an upward trend in 2015 with the sample from Q4 recording a slight decrease. Dissolved nickel concentrations exceeded the groundwater TV in Q1, Q2 and Q3 in The results ranged between mg/l to mg/l. Nickel concentrations decreased in each quarter during Total petroleum hydrocarbons were detected at a level of 0.12 mg/l, which is above the EPA IGV of 0.01 mg/l, in the sample from Q The other three available samples were below the LOD. Dissolved zinc exceeded the EPA IGV during Q1, Q2 and Q Zinc concentrations increased during Q1, Q2 and Q Zinc concentrations subsequently decreased significantly during Q AGW2 (formerly known as LF2) AGW2 is situated further downgradient from the landfill; located approximately 70m downgradient of AGW1 and closer to the factory. Groundwater quality is also somewhat compromised at this location. Ammonium (NH 4 ) exceeded the lower Threshold Value (TV) during all monitoring rounds, ranging from 0.23 mg/l to 5.43 mg/l. Concentrations of ammonia as NH 3 -N also exceeded the lower Threshold Value (TV) during all monitoring rounds, ranging from 0.16 mg/l to 0.44 mg/l. Chloride concentrations ranged from 23 mg/l to 26.1 mg/l and exceeded the lower groundwater TV during the Q3 monitoring round in Calcium concentrations exceeded the EPA IGV on all sampling occasions, ranging in concentration between 203 mg/l and 235 mg/l. Dissolved nickel concentrations exceeded the groundwater TV on all four sampling rounds in The results ranged between mg/l and mg/l. Nitrate concentrations as NO 3 ranged between 38.5 mg/l and 40.5 mg/l for the 2015 groundwater monitoring rounds. The sample from Q2 and Q4 rounds also exceeded the groundwater TV. Nitrate concentrations as N ranged between 8.96 mg/l and 9.14 mg/l during the 2015 groundwater monitoring rounds. The sample from Q2 and Q4 rounds also exceeded the groundwater TV. An overview of the trends ( ) for historical key parameters is presented in Table 10 below (see Appendix F for graphs) /4/15

28 Parameter Upgradient AGW3 (MW1) AGW4 (MW2) Downgradient of Site AGW5 (MW3) AGW6 (MW4) Downgradient of Landfill MW5 MW6 (LF1) (LF2) Chloride overall from 2000 since 2010 overall from 2000 overall from 2000 /~ overall from 2000 overall from 2000 since 2005 Nitrate Nickel overall from 2000 overall since 2000 Slight overall overall since 2013 overall since overall from 2000 overall from 2000 since Q overall since 2008 Note: Zinc Calcium Ammonia ~ ~ - ~ ~ Orthophosphate * Not analysed ~ ~ ~ ~ ~ ~ during 2015 Cadmium Potassium Increasing trend Decreasing trend ~ No discernible increasing or decreasing trend - Not graphed (no exceedances of limits) Table 10. Trends for Historical Key Parameters ( ) The parameter trends indicate an overall background increase in nitrate from upgradient activities. The data indicates an overall increasing trend in nickel, nitrate and calcium in boreholes both upgradient and downgradient of the landfill. The overall increasing trends in ammonia, calcium, cadmium, chloride, nickel and zinc in LF1 suggest that the landfill may be impacting on downgradient groundwater quality. It should be noted that a significant decrease in nickel, zinc and cadmium was recorded during Q in LF1. Total Petroleum Hydrocarbons (TPH) were detected in 2015 in MW2, MW3 and LF1 at concentrations above the EPA IGV, although all other hydrocarbon parameters were recorded as below the limit of detection, so the potential source of this TPH contamination is unclear POTENTIAL POLLUTANT LINKAGES The primary potential pollution linkage identified based on a review of the 2015 groundwater monitoring results is summarised in Table 11 below /4/15

29 Source Pathway Receptor *Landfill leachate *Vertical infiltration through soils and subsoils. *Bedrock aquifer *Anner River *Horizontal movement through the sand and gravel lenses on site *Horizontal movement through fractured bedrock aquifer. Table 11. Site Potential Pollution Linkage 20 20/4/15

30 3. SUMMARY, CONCLUSIONS AND RECOMMENDATIONS 3.1. SUMMARY AND CONCLUSIONS The overall increasing trends in nickel and nitrate in the upgradient borehole, MW1, suggest that groundwater flowing into the site has been contaminated from activities upgradient of the landfill. The increasing trends in chloride, ammonia and heavy metals in LF1 suggest that the landfill may be impacting on downgradient groundwater quality. The existing groundwater monitoring network meets the original objective i.e. to provide information on the state of the groundwater environment beneath the site and to intercept groundwater flow upgradient and downgradient of the site. Two new groundwater monitoring boreholes (AGW7 and AGW8) were installed in January 2016 within the main factory site in order to further augment the existing groundwater monitoring network. These monitoring points will provide additional groundwater monitoring data close to the current site activities. The locations of the 2No. additional monitoring boreholes are show in Appendix I. The inclusion of these new monitoring boreholes in the network and the subsequent water level monitoring will enable better confirmation of groundwater flow beneath the site RECOMMENDED WAY FORWARD Based on this assessment, the following actions are recommendations: Groundwater Monitoring Network The two additional monitoring boreholes within the main factory site area will be incorporated into the existing site groundwater monitoring network and sampled on a quarterly basis. Groundwater Flow Direction The water levels in all boreholes including the additional monitoring borehole will continue to be measured on a quarterly basis using a dipmeter with an accuracy of +/-0.001m in order to confirm the direction/variability of groundwater flow beneath the main site. Groundwater Sampling Procedure/Protocol Include the monitoring of unstable hydrochemical parameters (ph, Electrical Conductivity, Temperature) during purging. Groundwater Monitoring Parameters Include Total Petroleum Hydrocarbons, Mineral Oil, Diesel Range Organics and Petrol Range Organics in the parameter list on an on-going basis to assess the potential source of TPH detected in the 2015 monitoring rounds. Reduce the Limit of Detection (LOD) for Total Petroleum Hydrocarbons (TPH) to <0.01 mg/l so that a comparison can be made with the corresponding EPA IGV. Continue to analyse Ammonia as NH 4 -N for future sampling rounds to enable comparison of data with the Groundwater Regulations. Continue to analyse total and dissolved heavy metals /4/15

31 Landfill Assessment Submit a proposal to the EPA to undertake an up-to-date risk assessment on the on-site landfill based on the on-going increasing Chloride, Ammonia and Cadmium concentrations in LF1. Timeframe: End 2016 oo00oo Respectfully submitted On behalf of IE Consulting Sign Here (Lead Consultant) 22 20/4/15

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