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2 Quinn-therm Environment Manua Environm&ita Management System Manua DRAFT EPA Export :17:40:11

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4 Quinn-therm Environment Manua INDEX CONTENTS Section Tite 1.0 Introduction 2.0 Scope 3.0 Definitions Genera Requirements 4.2 Environmenta Statement Poicy Environmenta Management System Requirements Panning Environmenta Aspects Lega and other requirements Objectives and Targets Environmenta Management Programme 22 Page Impementation and Operation Structure and Responsibiity Training, awareness and competence Communication Environmenta Management System Documentation Document Contro Operationa Contro Emergency Preparedness and Response B.O.Nei Page 3 16/06104 EPA Export :17:40:12

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6 Quinn-therm Environment Manua Introduction The purpose of the Environmenta Management System (EMS) is to ensure that the Quinn group Therm (PU) Division (referred to in this document henceforth as Therm (PU) commit to a poicy of compiance with a appicabe egisation and reguations and, beyond that, commit to continuous improvement in environmenta performance. Therm (PU) have deveoped a customised Environmenta Management System, which is essentiay a continuous improvement mode that compies with the foowing principe eements: Environmenta poicy Environmenta panning 0 Operationa contro (incuding impimentation & operations) Inspection and correction Management review The IS is a series of standards being deveoped by the Internationa Organisation for Standardisation in order to provide guidance and structure for managing environmenta impacts. IS is the Environmenta Management Systems (EMS) Specification. Therm (PU) wi reinforced its position to become an environmenta eader by introducing this Management System which was deveoped using the guideine in the IS Standard. Companies certified to IS must integrate activities such as environmenta panning, programme impementation and performance measurement into their day -to - day business activities. Finay, the standard requires that the EMS be scrutinised by a third party auditor (NSAI or BSI) in order to be recommended for registration. It is intended that a the Divisions in the Quinn Group wi operate under a common Environmenta Management System with the exception of Quinn Gass who are aready certified by Northern Ireand BSI. There are severa advantages to a singe IS certification Group wide: This minimises time and resources using ony one certification body, one set of certification audits, one set of higher eve documentation e.g. manuas, ega registers, etc. B.O.Nei Page 5 16/06104 EPA Export :17:40:12

7 Quinn-therm Environment Manua Tite: 1 Introduction Approved by: 1 Brendan O Nei Quinn Group HSE manager 1 Page 6 of 80 Since this EMS is a new deveopment, it is designed using existing knowedge and information from a the Divisions but adapting it for maximum simpicity. The EMS uses common formats, tempates and documentation across the Divisions aowing for easier interchange of information, keeping records and formatting of reporting information. A Group wide EMS does not reduce ownership of the system by the individua Divisions. The common eements across the Divisions are managed centray by HSE and the operationa parts of the system is deveoped, impemented and revised as appropriate by the Divisiona managers or their deegates. This aows the Divisions more freedom to concentrate on the aspects that specificay affect them. For Therm (PU), a Heath & Safety,Environmenta (HSE) Officer, suppies the deveopment, support and co-ordination of the therm (PU) specific HSE system. In terms of IS , this means the management of the specific operationa aspects (such as deveoping Therm (PU) procedures, record keeping, training, etc.). The certification of Therm (PU) as an IS Division wi be achieved in two parts due to the timescaes invoved.firsty deveopment of a usabe and practica Environmenta management system with a necessary procedures and training.secondy the impementation of this system to a members of Staff at a eves. B.O.Nei Page 6 16/06/04 EPA Export :17:40:12

8 Quinn-therm Environment Manua SCOPE 1.1 Scope This manua provides an overview of Therm (PU) s Environmenta Management System. The Environmenta Management System appies to those environmenta aspects, which the organisation can contro and over which it can be expected to have an infuence. A number of procedures have been incorporated into the Manua. 1.2 Fied Of Appication This manua describes the core eements of the management system and their interaction. It is intended to provide direction to reated documentation and other information sources. It can be a reference source for the foowing purposes: For reference by independent certifying or verifying bodies when performing audits, For reference by interna personne when auditing, To provide information on the company s environmenta management system for interested empoyees and Visitors, To introduce new empoyees to the environmenta contro systems pertaining at Therm (PU). B.O.Nei Page /04 EPA Export :17:40:12

9 a;... _ :,^, QE2% ig Therm (PU) Environment Manua EMS.PUOOO Tite: Quinn-therm EMS Manua Approved by: Brendan O Nei Quinn group HSE manager Page 8 of 80 Can be used as a too for presenting an overview of the Environmenta Management System to third parties, As an aid in reviewing and updating procedures and activities in a controed way, in response to changing circumstances. To provide information on Therm (PU) s commitment to the environment for interested customers. DESCRIPTION OF ACTIVITIES & SITE HISTORY 1. Introduction A II,71 Om* manufacturing faciity for the production of rigid Poyurethane insuation board, is being constructed for the operation of a Poyisocyanurate (PIR) foam manufacturing faciity incusive of a main production area, aboratory faciities, chemica bending and storage areas, underground pentane storage tank, truck spray cage, office, toiets, car parking faciities, smoking hut, and compete encosure of site with suitabe security fencing with aestheticay finished entrance For the reaisation of the idea of using a twin-bet-machine for the production of PUR sandwich eements by processing pentane instead of chorinated fuorocarbon it has been necessary to change parts of the equipment. In particuar a safety concept must be eaborated in order to avoid any dangerous situation arising from exposive mixtures between air and pentane. In the introduction beow we point out the changes in the new revised and improved safety concept. 2. Procedure Production of PUR sandwich eements with * PUR high-resistance foam as supporting core * profied sheet stee facing on both sides on twin-bet-machines: These finshed Construction eements are manufactored in a continuous process and find use as buiding components for was, roofs and gates as we as in the industria sector. Continuous operations Process + profiing the facings B.O.Nei Page 8 16/06/04 EPA Export :17:40:12

10 Therm (PU) Environment Manua + preparing / equaizing the temperature of the facings + feeding in the poyurethane high-resistance foam + cutting up to effective ength + piing up, packing 2.1 Project Background Quinn Group have been manufacturing Expanded Poystyrene (EPS) insuation boards at their existing faciity sited in Granard, Co. Longford for the past 10 years. Over this period they have gained considerabe experience of the insuation market and have captured a considerabe share of the overa market. Given industry requirements and various treaty s requiring the phasing out of CFCs in ine with the Montrea Protoco and Seveso guideines, together with the impications which the new buiding reguations wi have on the insuation market, Quinn Group decided that it was of paramount importance to the Quinn Lite division of the Group to progress their pans for a PIR manufacturing faciity to ensure their viabiity in a changing and demanding market pace. The proposed deveopment wi be ocated on a 40,000m2 site in the Td., of Rakeean, Bayconne, Co. Cavan. The deveopment wi take pace over a three month period, providing the-appication is treated favouraby the panning authorities. The proposed faciity wi manufacture PIR cosed-ce rigid aminate insuation foam board with fexibe facings for use in was, roofs and foors of industria, commercia and domestic buidings. The finished product wi have one of the owest thermai conductivity vaues of a insuation materias avaiabe in this country and wi comfortaby satisfy revised buiding reguations governing this area of the construction business which require improved therma conductivity vaues for rigid insuants. B.O.Nei Page EPA Export :17:40:12

11 Therm (PU) Environment Manua EMS.PUOOO Tite: Quinn-therm EMS Manua Approved by: Brendan O Nei Quinn group HSE manager Page 10 of Background to PIR process Rigid Urethane Foam technoogy was deveoped in the 1960s by Bayer chemica company and has been deveoped to the widest end use and compatibiity by the rigid urethane industry over the ast four decades. The 1970 oi crises was the major catayst in concentrating R&D deveopment on PU insuation technoogy. Since then, these products have come to dominate the insuation market and have undergone a period of rapid growth, principay due to;- 1) The products superior insuation properties. a The widest compatibiity with associated buiding components and atest industry buiding designs and reguations. Features which make Rigid Urethane Foam unique. 1) Lowest K-Vaue 2) Compatibiity / Versatiity The ow K Vaue is as a direct resut of the tota encapsuation of the bowing agent within the cosed ces of the foam core. The bowing agent composition and the therma properties of that gas is vita to fina insuation performance. In short the gas must have. 1) A moecuar size arge enough to remain trapped within the ces. 2) Must have the owest possibe therma conductivity. 3) Must have a boiing point, which is compatibe with the exothermic reaction of the rigid urethane foam. B.O.Neii Page 10 16/06/04 EPA Export :17:40:12

12 Therm (PU) Environment Manua During the products initia deveopment and subsequent in service use for the first 30 years, the bowing agent which fitted a the above criteria was FREON II. This materia possessed a the required properties and therefore the products and systems incuding their insuants quicky became first choice where high eves of insuation were required. In the ate 1980 s it was estabished that the industry woud have to eiminate CFC containing materias from it s production processes and the poyurethane industry was required to step up efforts to deveop and suppy ceaner aternatives for rigid foams. Foowing the Montrea Protoco a phase out pan was put in pace. Time aowance was made for the phase out of CFC products for the foowing reasons. 0 the bowing agent was totay encapsuated in the foam core and ii) in recognition of the products contribution to energy conservation and therefore ong-term aternative. the need to deveop a suitabe and sustainabe Between 1991 and 1994 trias were carried out in conjunction with the major chemica companies. Assistance was aso received from Brufma (British Rigid Urethane Foam Manufacturers Association) on ong term ageing tests, to quaify the aternatives. This was particuary reevant to the industry as the products are designed to provide a eve of insuation performance for the ifetime of the buiding where they are instaed. The initia route was to phase out CFCs in ine with the Montrea Protoco and at some time ensure the eve of energy conservation these products was maintained. provided by B.O.Nei Page 11 16/06/04 EPA Export :17:40:12

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14 Therm (PU) Environment Manua 2.5 Site Location The proposed faciity is to be ocated aong the R205 main Bayconne to Derryin road. The site is ocated approximatey 1 km to the north of Bayconne and 7 km to the south of Derryin, Co. Fermanagh. The site entrance wi be approximatey opposite the access road for the Sean Quinn Group Scotchtown Cement Works. The area in and around the Cement Pant is designated as an industria compex, however the site area itsef woud be most ikey designated as Mixed Use. Quinn Group recenty received panning permission for a 36,00Om* storage warehouse and ground works have aready commenced. The proposed faciity wi be sited to the south and adjoining this warehouse on ands in the ownership of Quinn Group. 3. Product PUR sandwich eements used as roof and wa eements in the industria sector combine the foowing advantages of both, the sheet stee facings +. mutipe ways of architectonic design by various coours and profies +. performing static functions depending on the chosen materia and profie +. resistance against mechanica stress +. high-quaity corrosion reduction and the PUR high-resistance foam, +. superior heat insuation +. superior adhesive and crushing strength +. ow apparent density +. ow weight, easy instaation +. foam thickness up to 200 mm + resuting in a mutipurpose buiding component that can be instaed easiy, fast and without any probem and that is industriay pre-fabricated corresponding to the customers requirements. Quinn Therm (PU) is a member of the Quinn group of companies. B.O.Nei Page EPA Export :17:40:12

15 I >Y a i Therm QYZ!6 (PU) Environment Manua EMSPUOOOI Tite: Quinn-therm EMS Manua Approved by: Brendan O Nei Quinn group HSE manager Page 14 of 80 Definitions Continua Improvement The process of enhancing the environmenta management system to achieve improvements in overa environmenta performance in ine with the organisations environmenta poicy. Environment The surroundings in which an organisation operates, incuding air, water, and, natura resources, fora, fauna, humans and their interreation. Surroundings in this context extend from within an organisation to the goba system. Environmenta Aspects An eement of an organisations activities, products or services that can interact with the environment. A significant aspect is one that has or coud have a significant environmenta impact. Environmenta Impact Any change to the environment, whether adverse or beneficia, whoy or partiay resuting from an organisations activity, products or services. Environmenta Manaqement System The part of the overa management system that incudes organisationa structure, panning activities, responsibiities, practices, procedures, processes and resources for deveoping, impementing, achieving, reviewing and maintaining the environmenta poicy. B.O.Nei Page /04 EPA Export :17:40:12

16 :..: /,..,,.: j.. Therm (PU) Environment Manua EMSPUOOOI Page 15 of 80 Environmenta Manacement Svstem Audit A systematic and documented verification process for objectivey obtaining and evauating evidence to determine whether the organisations Environmenta Management System (EMS) conforms to the EMS audit criteria and for communication of the resuts of this process to management. Environmenta Obiective An overa environmenta goa, arising from the environmenta poicy, that an organisation sets itsef to achieve, and which is quantified where possibe. Environmenta Performance This is the measurabe resut of the EMS, reated to an organisation s contro of its environmenta aspects, based on its environmenta poicy, objectives and targets. Environmenta Poicy A pubicy avaiabe statement by top management, of an organisations intentions and principes, in reation to its environmenta performance. Environmenta Target A detaied performance requirement quantified where practicabe, that must be met in order to achieve the environmenta objectives. Interested party Individua or group concerned with or affected by the environmenta performance of an organisation. These may incude empoyees, statutory bodies, oca communities, customers and the genera pubic. B.O.Nei Page EPA Export :17:40:12

17 ? j I.,_ Therm (PU) Environment Manua 42 qgg; EMS.PUOOO Tite: Quinn-therm EMS Manua Approved by: Brendan O Nei Quinn group HSE manager 1 Page 16 of 80 f Prevention of poution Use of processes, practices, materias or products that avoid, reduce or contro poution. These may incude recycing, treatment, process changes, contro mechanisms, efficient use of resources and materia substitution. Emeraencv Pan A document which defines the emergency action to be taken in the event of an incident or potentia incident at a faciity, in order to protect company personne, the genera popuation and the environment. Description of EMS documentation 1.0 Purpose and scope The purpose of this section is to describe the extent and makeup of the EMS documentation and provide a convenient overview of it. 2.0 Extent of documentation Documentation for the EMS consists of the foowing texts. EMS system manua (this manua), (TEMS). Procedures manuas (TEPM) Register of environmenta aspects VW Register of environmenta reguations, (LR Legisation Register ). Environmenta management programme (TEMP) Monitoring and measurement records (TER Therm (PU) Env, records) 3.0 Environmenta Management System manua (TEMS) The EMS manua provides a comprehensive overview of the environmenta management system. It outines the various mechanisms that Therm (PU) empoys to maintain conformance with standard requirements. It describes B.O.Nei Page 16 16/06104 EPA Export :17:40:12

18 Therm (PU) Environment Manua reated documentation empoyed by Therm (PU) in support of IS requirements and indicates where this can be ocated. 4.0 Procedures manua (TEPM) The procedures manua defines the operating procedures for the system and, where appropriate, wi incude more detaied work instructions for specific tasks. 5.0 Register of Environmenta Aspects ( AR) The Register of Environmenta Aspects detais, evauates and categorises the environmenta aspects of company activities that it can contro and over which it can be expected to have an infuence. 6.0 Register of Environmenta Reguations (LR) The Register of Environmenta Reguations records a egisative, reguatory and other poicy requirements and codes, which are appicabe to the environmenta aspects of the company s activities, products and services. 7.0 Environmenta Management Programme (TEMP) The Environmenta Management Programme describes projects and pans for bringing about environmenta improvements to achieve defined objectives and targets. 8.0 Monitoring and measurement records (TER) These provide data on emissions and resource usage etc. which faciitates the organisation in evauating the impacts its activities are having on the B.O.Nei Page /04 EPA Export :17:40:12

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20 Therm (PU) Environment Manua 1.0 Purpose Environment, Heath and Safety Poicy outines the company s commitment to the heath and safety of a it s empoyees and its commitment to the protection of the environment. The poicy is avaiabe to the pubic and a interested parties on request. It is aso avaiabe to a empoyees and wi be dispayed in prominent ocations around the pant. 2.0 Responsibiity Senior management of Therm (PU) is responsibe for ensuring the Environment, Heath and Safety Poicy is appropriatey defined, documented and impemented. It wi be reviewed annuay at the Management Review and updated accordingy. 3.0 Poicy Management demonstrates their commitment to good environment and safety practices through the formuation of the company s Environment, Heath and Safety Poicy Statement. The statement is documented and signed by the Divisiona Genera Manager and the Divisions Director. The Environmenta, Heath and Safety Poicy Statement takes account of the nature, scae and environmenta impacts of the company s activities, products and services. It states a commitment to continua improvement and prevention of poution. It aso commits to compy with a reevant environmenta egisation and reguations and with Quinn group Corporate Poicies. The poicy provides the framework for setting and reviewing environmenta objectives and targets for improving environmenta performance. The poicy is communicated to a empoyees and is made avaiabe to the pubic. The poicy is reviewed annuay or when deemed necessary by management to ensure that it remains reevant to Therm (PU) operations. It is revised and reissued in accordance with changing circumstances. B.O.Nei Page /04 EPA Export :17:40:13

21 Therm (PU) Environment Manua THERM (PU) DIVISION ENVIRONMENTAL POLICY / STATEMENT The Therm (PU) Division is committed to: giving the protection of the environment and the heath and safety of its empoyees, customers and neighbours priority over economic considerations. ensuring that a Therm (PU) operations, services and products are at a minimum in fu compiance with appicabe ega requirements and Corporate standards. conducting a Therm (PU) operations and services in a manner that safeguards heath, prevents poution and conserves vauabe resources and materias. providing a resources necessary to continuousy improve workpace safety and environmenta protection. estabishing environmenta heath and safety improvement objectives and targets and reguary review progress against designated goas. communicating this documented poicy, responsibiities and ega requirements to a Therm (PU) empoyees, suppiers and contractors and make this poicy avaiabe to the pubic. ( Therm (PU) Divison Manager) Date B.O.Nei Page /04 EPA Export :17:40:13

22 . x., _!. I. i..-,- _,.. :,.:,. :/: Therm (PU) Environment Manua Environments1 Aspects IS0 Reference: Purpose The purpose of the Register of Environmenta Aspects is to reguary examine the aspects of Therm (PU) s activities, processes and products and their associated impacts over which the Division can be expected to have an infuence. 2.0 Responsibiity It is the responsibiity of the Group HSE Manager to ensure that the Register of Environmenta Aspects is appropriatey structured and reguary reviewed. It is the responsibiity of the Therm (PU) HSE Officer to keep the Register of Environmenta Aspects up to date. HSE is responsibe for identifying, assessing and quantifying the environmenta affects with each of the Divisions management. 3.0 Register of Environmenta Aspects The purpose of the Register of Environmenta Aspects is to identify and document the environmenta aspects of Therm (PU) s activities, products and services that it can contro and over which it can be expected to have an infuence. This is to determine those aspects, which have or can have a significant impact on the environment. The environmenta objectives and targets of Therm (PU) wi be based on those aspects, which are evauated to have or can have the most significant impact on the environment. The register is divided into sections - each section reevant to each individua Divisiona (i.e.cement pant therm (PU) etc.) Each section of the Environmenta Aspects Register wi incude the foowing subsections: B.O.Nei Page ~04 EPA Export :17:40:13

23 Therm (PU) Environment Manua An introduction and description of the processes and systems empoyed within the individua Divisiona Centre. Process fow charts of the reevant processes. Summary tabes of the significant environmenta aspects. Evauation sheets for each environmenta aspect. Risk assessments of potentia / emergency / unforeseen events and occurrences. Therm (PU) utiises a procedure for the identification of Environmenta Aspects and for cacuating the significance of those aspects. The procedure wi consider activities, which can have a beneficia or adverse impact on the environment under both norma and abnorma operating conditions. For a Therm (PU) s activities, the foowing environmenta aspects sha be reviewed: Atmospheric emissions Aqueous emissions Hazardous waste generation Non-hazardous waste generation Contamination of and Use of natura resources Nuisance effects 3.1 Definitions Environment: Surroundings in which an organisation operates, incuding air, water, and, natura resources, fora, fauna, humans and their interreation. Environmenta Aspects: Eements of an organisations activities, products or services which can interact with the environment. B.O.Nei Page 22 16/06/04 EPA Export :17:40:13

24 Therm (PU) Environment Manua Tite: Quinn-therm EMS Manua Approved by: Brendan O Nei Quinn group HSE manager EMS.PUOOO Page 23 of 80 Environmenta Impact: Any change to the environment, whether adverse or beneficia, whoy or partiay resuting from an organisations activities, products or services. 3.2 Procedure s Therm (PU) wi identify the environmenta aspects of its activities, products or services over which it can contro and which it can be expected to have an infuence. Having identified a environmenta aspects, HSE can then determine the aspects, which are most ikey to have significant impacts on the environment. The identification of environmenta stages: aspects comprises of seven main HSE carries out an initia survey of each process area to identify the different production methoogy I activities in each area. The Therm (PU) HSE Officer wi instruct Area managers / Supervisors to create fow charts for each activity / process, identifying inputs / outputs and waste streams under norma and abnorma operating conditions. Supervisors in conjunction with HSE then buid upon the identified areas of environmenta burden by competing an environmenta risk assessment. HSE coate the environmenta data for the Divisions and quantify the different burdens where possibe. HSE evauate the reated environmenta effect produced by the burden and compie an Environmenta Evauation Sheet for the pant as a whoe. HSE inspect the site to assess the environmenta significance of visua and noise effects arising from activities arising outside the Pant, e.g. skip areas, outside storage faciities, etc. Considering a the environmenta effects arising from the Pant, HSE and the reevant ine managers wi score each burden against four criteria. The resuts are tabuated and the environmenta effects with the highest tota the most significant. B.O.Nei Page 23 16/06/04 EPA Export :17:40:13

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26 Therm (PU) Environment Manua Severity of Environmenta Impact (Se) 5. Severe - extensive damage to widespread environment Limited - Locaised nuisance probem Priority Rating (Px) Impact Significance Priority Required Action (Is) PI Immediate countermeasure P2 Urgent countermeasure must be impemented P3 Medium term action required 81-1 P4 No action required - continue to assess 4.0 Review of Register of Environmenta Aspects The Register is reguary reviewed and updated to remain reevant to possibe changes in processes of Therm (PU) and any subsequent environmenta aspects. When updating the Register of Environmenta Aspects a reevant data is considered. This may incude: Any spis on the site Environmenta incidents and near misses Breaches of reevant Environmenta Legisation Compaints / concerns of Therm (PU) operations Emissions information and monitoring resuts for discharges to air, water and noise eves. B.O.Nei Page 25 16/06/04 EPA Export :17:40:13

27 Therm (PU) Environment Manua Lega and other Requirements IS0 Reference O Purpose To record a egisative reguatory and other poicy requirements and codes to which Therm (PU) subscribes, appicabe to the environmenta aspects of the Division s activities, products and services. 2.0 Responsibiity It is the responsibiity of the HSE Officer to estabish, maintain, evauate and update the Register of Environmenta Reguations. However if necessary the assistance of an externa direction ( Group HSE Manager) wi be sought. 3.0 Register of Reguations The register is divided into a number of categories that incude: Genera Environmenta Legisation Emissions to Air Emissions to Water Waste Noise Panning and Deveopment Heath and Safety Recycing In each of these categories reevant Irish and European egisation is incuded as we as codes of practice and panning permissions. The Faciities Engineer maintains a panning permissions on fie as part of the Safety Fie for the buiding. B.O.Nei Page 27 16/06/04 EPA Export :17:40:13

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29 Therm (PU) Environment Manua Objectives and Targets IS0 Reference j Purpose To estabish and maintain documented environmenta objectives and targets at a reevant eves within Therm (PU), with a view to minimising and, where possibe, eiminating adverse impacts on the environment. The objectives and targets wi be consistent with the Environment Poicy. 2.0 Responsibiity The Pant Manager I Production Engineer is responsibe for ensuring that the Environmenta objectives and targets are consistent with the Environment Poicy and reevant to the operations of Therm (PU). The HSE Officer is responsibe for compiing draft objectives and targets and for ensuring that a approved objectives and targets are periodicay reviewed and updated. 3.0 Setting Objectives and Targets Objectives and targets wi be identified foowing the review of the Environmenta Legisative and Affects Register and after the annua Management Review. The objectives and targets estabished are considered in reation to: Lega and other requirements Significant environmenta aspects Technoogica options Financia, operationa and business requirements Views of interested parties Changes in poicy foowing Management Review Changes in HSE corporate poicy Environmenta incidents and near misses B.O.Nei Page 29 16/06/04 EPA Export :17:40:13

30 Therm (PU) Environment Manua EMS.PUOOO Tite: Quinn-therm EMS Manua I 1 Approved by: 1 Brendan O Nei Quinn group HSE manager 1 Page 30 of 80 Introduction of new production processes Objectives and targets reate to both the Therm (PU) Division as a whoe and to individua Pant areas. 4.0 Review of Objectives and Targets Objectives and Targets are set within the timescae of one year and for each year thereafter foowing the annua Management review. The objectives are prioritised according to the significance of their environmenta aspects and appropriate timescaes are appied to each target. Objectives and targets compiance are tracked on a roing basis through reguar Einvironmenta meetings periodic Divisiona review meetings and HSE Management reviews. Objectives and targets that are not achieved within the designated timescaes set wi be ogged in the Corrective Action Log and tracked for progress toward compiance (ref. Nonconformance and corrective and preventive action IS (4.6)). Therm (PU) senior management is committed to the achievement of designated objectives and targets by the provisions of funding for compiance and through invovement in the Pant HSE Management. 5.0 Reated Documents Corrective Actions Check Sheet Corrective Action Log Non-conformance and corrective and preventive Action Monthy Meeting Minutes ( > ( 1 ( >> ( 1 B.O.Nei Page 30 16/06/04 EPA Export :17:40:13

31 . j :;: - ; r _. :; 8, i :-,,.,,,. ~- Therm (PU) Environment Manua Tite: EMS.PUOOO Quinn-therm EMS Manua Approved by: Brendan O Nei Quinn group HSE manager Page 31 of 80 Environmenta Management Programme IS0 Reference: O Purpose To estabish and maintain an Environmenta Management Programme for Therm (PU), to ensure that set objectives and targets are achieved. 2.0 Responsibiity The HSE Officer is responsibe for co-orciinating the compiation and impementation of an Environmenta Management Programme that wi achieve the objectives and targets of Therm (PU). 3.0 Compiing the Environmenta Management Programme For each objective and reafed fargef, a defai/ed pan for achieving the objective wi be esfabished and documenfed. If wi incude fhe designation of responsibiity for achieving objectives and targets at each reevanf function and eve of Therm (PU) management Programmes wi be amended where reevant to incude new deveopments and new or modified activities, products or services. This wi ensure that the environmenta management system remains reevant to such projects and deveopments. Targets dates wi be aocated to each objective and, where possibe and reevant, the objective wi be quantified. The means by which objectives and associated targets wi be achieved wi form the Environmenta Management Programme (TEMP). B.O.Nei Page 31 16/06104 EPA Export :17:40:13

32 Therm (PU) Environment Manua 4.0 Reviewing the Environmenta Management Programme Progress towards achieving objectives and targets wi be reguary reviewed by the HSE Officer foowing the interna auditing procedure. The forum for addressing environmenta operations consists of: issues appicabe to Therm (PU) Monthy meetings of the Management team (can be combined with H&S Monthy meetings) and HSE Officer,Group HSE Manager &Group Environmenta Engineer to incude discussion on environment management programmes in the various other group faciities & pants. Reguar reporting between the HSE Officer and the Group HSE Manager on issues raised Monthy meetings. HSE Forum meetings between the Group HSE Manager and other Divisiona managers to incude review of objectives and targets. Objectives and targets aready achieved wi be ogged in the minutes of the Management Review Meeting. A documented Environmenta Management Programme wi be maintained by the Therm (PU) HSE Officer. 5.0 Reated Documents Environmenta Management Programme 0 Monthy Meeting Minutes 0 HSE Meeting Minutes 0 Environmenta Objectives and Targets 0 1 Prepared by: Brendan O Nei 1 Version No Issue date: EPA Export :17:40:13

33 .,.j ; 4P Therm (PU) Environment Manua efz!s!f TEMS.CO001 ) Tite: Approved by: \ Brendan U Ne% Quinn Group HSE manager 1 Page 34 of 81 EMS responsibiities. 1.O Purpose To define, document and communicate the roes, responsibiities and authority of the key personne who manage and perform work that affects the environment. 2.0 Responsibiities A basic principe of the Environmenta Management System at Therm (PU) is that a empoyees of the company, at every eve, have a responsibiity to appy the principes of the Environmenta Management System and the Environmenta Poicy whie performing their work. Management is responsibe for the provision of the resources of time and money to aow the impementation and contro of the Environmenta Management System. The Therm (PU) HSE Officer, as the appointed management representative has the overa responsibiity for the impementation and maintenance of the Environmenta Management System in conjunction with the group HSE division The specific responsibiities of key personne who manage and perform work that impacts the environment are documents as foows. 1 Prepared by: Brendan O Nei 1 Version No Issue date: I EPA Export :17:40:13

34 :,.,. I.,L? : ^,-,, :I. Therm (PU) Environment Manua RESPONSIBILITIES OF THE THERM (PU) DIVISIONAL MANAGER To ensure that the Company HSE Poicy is effective and that it is impemented throughout a Therm (PU)s divisions,pant. To ensure that adequate resource of time, personne and finance are avaiabe for effective impementation of the HSE Poicy and the EMS through the Divisiona managers/ supervisors. To ensure that management decisions, where appicabe, take into account the HSE performance of the company. To ensure that arrangements are in pace to make empoyees aware of their HSE responsibiities. To ensure that environment and safety incidents, occurrences and near misses are investigated and that action is taken to prevent their recurrence. To recognise HSE performance as part of management priorities. To ensure that HSE system review is carried out as required. 1 issue date: EPA Export :17:40:14

35 .,:.I ; 42 Therm (PU) Environment TEMSXOQOI Tite: Environmenta Management Responsibiities 1 Approved by: 1 Brendan O Nei Quinn Group HSE manager [ Page 36 of 81 RESPONSIBILITIES OF THE QUINN GROUP HSE MANAGER Acting as Management Representative, to ensure that the EMS requirements are estabished, impemented and maintained in accordance with best practice. To ensure that advice, guidance and instruction on a EH&S matters is provided to management, empoyees, contractors and visitors on site. To ensure that adequate records are maintained and updated to demonstrate conformance with the EMS requirements. To ensure that an Environmenta Management Programme is deveoped, with appropriate objectives and targets, taking into consideration the HSE Poicy Statement, ega requirements, significant environmenta aspects and the company s business requirements. To report to Management on the performance of the EMS and aert them when corrective action is needed. To provide adequate interna auditing of the EMS so that conformance to documented requirements is monitored and maintained. To maintain interna and externa communication on matters reating to EH&S. To devise safety and environmenta improvement programmes and estabish appropriate objectives and targets in support of the commitment to continuous improvement. To ensure that a sufficient Emergency Preparedness and Response procedure is in pace and that reevant personne have received training as required. 1 Prepared by: Brendan O Nei 1 Version No Issue date: EPA Export :17:40:14

36 Therm (PU) Environment Manua RESPONSIBILITIES OF THE THERM (PU1 HSE OFFICER To maintain and progress the environment and safety management system in accordance with the requirements of the IS standard and the Division s Safety Statement. To provide information, advice, guidance and instruction on environment and safety matters to management, empoyees, contractors and visitors on site. 0 To maintain and keep updated, appropriate records to ensure compiance with requirements and demonstrate conformance with the EMS. To co-ordinate the compiation and impementation of an Environmenta Management Programme that wi achieve the company s objectives and targets. To assist with and faciitate the investigation and recording of environment and safety incidents and accidents in accordance with the EMS. To monitor the company s performance in the impementation of the EMS and communicate progress to the Group Group HSE Manager & Divisiona Manager. To provide interna auditing of the EMS as per the defined schedue in order to estabish that conformance to its requirements is maintained. To ensure that corrective actions are subsequenty impemented to address any deviations identified during auditing. a To assembe periodic HSE data reports required by management and the corporation. To estabish, maintain, evauate and update the Register of Environmenta Legisation. To ensure that a documentation and data is controed in accordance with Therm (PU)procedures. To estabish and maintain measurement and recording systems for waste disposa, refurbish and recyced materias. to manage community and interna reations at Therm (PU) and aso address dissemination of information on HSE aspects. To source, approve and empoy quaified waste recyce and disposa contractors to remove waste from site in accordance with company procedures. 1 Prepared by: Brendan O Nei 1 Version No Issue date: EPA Export :17:40:14

37 Therm (PU) Environment Manua TEMS.C0001 Tite: 1 Environmenta Management Responsibiities 1 Approved by: 1 Brendan O Nei Quinn Group HSE manager 1 Page33 of8z To estabish and maintain measurement and recording systems for waste disposa and recyced materias. To promote the Therm (PU) Divisions poicies of reduce, reuse and recycte. To co-ordinate the introduction of new chemicas to the site with the assistance of the Divisiona Management & Supervision. To ensure compiance with the Emergency Preparedness and Response procedure and that a members of the Emergency Response Team receive training as appropriate. To ensure that projects defined in the Environmenta Management Programme are impemented and that it s objectives and targets are met. To ensure that a waste, both hazardous and non-hazardous is controed, stored and disposed of in accordance with company procedures. To ensure that ony approved disposa contractors are empoyed to dispose of waste on behaf of the company. To ensure that a maintenance programme is in pace for pant and equipment that impacts environment and safety aspects sitewide. To have utiity usage monitored and to initiate conservation measures. To take corrective action on any faciity area deviations from environmenta or safety operating procedures. To notify the Group Group HSE Manager of any safety or environment incidents as soon as they occur. 1 Prepared by: Brendan O Nei 1 Version No Issue date: EPA Export :17:40:14

38 Therm (PU) Environment Manua TEMSCOOOI To impement the faciities reated projects defined in the Environmenta Management Programme and achieve the objectives and targets defined therein. To contro and monitor contractors working on site and ensure that they conform to EH&S procedures and practices. To ensure that a contractors are aware of Therm (PU) EH&S poicy. To contro, store and dispose of a wastes, hazardous and non-hazardous in accordance with company procedures. To maintain and operate a maintenance programme for pant and equipment which is critica for achieving defined environment and safety performance. standards and document same. To ensure that caibration of instrumentation and contro systems for environment and safety equipment operation is performed on schedue and that the work is documented. To estabish and maintain measurement and recording systems for utiity usage, refrigerant gases and traffic movements To impement corrective actions arising from audit reports. 1 Version No Issue date: EPA Export :17:40:14

39 ,3 ( 2,. : 4P Therm (PU) Environment TEMSCOOOI Tite: 1 Environmenta Management Responsibiities 1 Approved by: 1 Brendan OWei Quinn Group HSE manager 1 Page40of81 RESPONSIBtTES OF THERM IPU) DIVSfUNS EMPLOYEES To take reasonabe care for their own safety, heath and wefare and that of others who may be affected by their acts or omissions. To co-operate with their empoyer in reation to compiance with statutory requirements and corporate poicies and procedures. To report without deay any defects in workpace pans, equipment or systems of work. To report any HSE incidents regardess how minor so that appropriate corrective action may be taken. To pursue a poicy of persona continuous improvement in workpace safety and poution prevention. To conduct a Therm (PU) operations in a manner that safeguards heath, protects the environment, conserves vauabe materias and resources and minimises risk of asset oses. To co-operate in promoting waste avoidance through reduce and reuse and maximise recycing by segregation of waste. To participate fuy in training programmes and co-operate with a measures taken to secure a successfu EH&S system. 1 Prepared by: Brendan O Nei 1 Version No Issue date: EPA Export :17:40:14

40 Therm (PU) Environment Manua TEMSCOOOI Tite: 1 Environmenta Management Responsibiities Approved by: 1 Brendan O Nei Quinn Group HSE manager Page 41 of 81 Training, Awareness and Competence IS0 Reference: Purpose To estabish and maintain procedures to identify the training needs of a personne invoved in work activities that may have a significant impact on the environment. To ensure that there is an awareness of the importance of the compiance with Therm (PU),environmenta objectives and targets and with the requirements of ISO The procedures wi ensure that empoyees at a eves within Therm (PU) are aware of the actua or potentia environmenta impacts of their work activities and the benefits of improved persona performance for the environment. 2.0 Responsibiity Human Resources are responsibe for ensuring that a empoyees receive appropriate training on safety and environmenta aspects of operations at Therm (PU). They are aso responsibe for managing the training programme overa, providing appropriate training materias and resources and ensuring that training is impemented in accordance with agreed schedues. Team Leaders, Supervisors and Training co-ordinators are responsibe for ensuring that their groups received prescribed training as defined by the training matrix. 3.0 Training, Awareness and Competence A Therm (PU) empoyees receive a comprehensive programme which incudes HSE training. induction training Training materias are provided by the group HSE Management Supervisory Staff as needed. and the 1 Prepared by: Brendan O Nei 1 Version No Issue date: EPA Export :17:40:14

41 Therm (PU) Environment Manua TEMSXOOOI Tite: ( Environmenta Management Responsibiities 1 Approved by: 1 Brendan O Nei Quinn Group HSE manager 1 Page 42 of 81 The HR Divisiona supervision are responsibe for the impementation of a corporate training on the Therm (PU) sites ie. a training that need to be given to the whoe Therm (PU) Division Specific HSE training wi be administered by the HSE Officer or Group HSE department. An annua HSE programme is compied for a empoyees. The subject matter of the programme wi be reviewed and updated on a reguar basis by the Group HSE Manager. Environmenta training materias and the schedue of environmenta training for the year are maintained by the Therm (PU) HSE Officer.. Training effectiveness and is evauated through questionnaires via the group HSE department and evauated by the Human Resources Department. Records of training received are documented and fied. 4.0 Reated Documents. HSE induction materia 0 Procedure for Environmenta Training 0 Training Matrix 0 Training Schedue 0 Training Records Ref: Human Resources 1 Prepared by: Brendan O Nei 1 Version No Issue date: EPA Export :17:40:14

42 . :,,. I.. _. Therm (PU) Environment Manua TEMS.COOO Tite: 1 Environmenta Management Responsibiities Approved by: 1 Brendan O Nei Quinn Group HSE manager Page 43 of 81 Communication IS0 Reference: Purpose To estabish and maintain procedures for interna communications on environmenta issues and the Environmenta Management System between a eves and functions within Therm (PU). Procedures wi aso be in pace for receiving, documenting and responding to reevant communications from externa interested parties. 2.0 Responsibiities The Group HSE Manager is responsibe for ensuring that this procedure is impemented. The HSE Officer is responsibe for ensuring that a communications are up to date and current. The HSE Officer is aso responsibe for ensuring that a environmenta issues and concerns are propery communicated through the proper channes to the reevant parties. 3.0 Communication Therm (PU) s Environment Poicy Statement is posted at prominent ocations throughout the faciity to ensure that its contents are famiiar to as many empoyees and visitors to the faciity as possibe. These copies wi be repaced by revised versions as practicabe. The HSE Officer is responsibe for management of interna communications within the Therm (PU) site. The HSE Officer wi aso manage the dissemination of information on environmenta aspects and issues. B.O.Nei Page 43 16iO6104 EPA Export :17:40:14

43 <f.. i j : Therm (PU) Environment Manua &I, a,ue!r TEMS.COOO Tite: Environmenta Management Responsibiities Approved by: Brendan O Nei Quinn Group HSE manager ] Page 44 of 81 The Quinn group devotes a section of its intranet site to providing a considerabe body of information on HSE topics. Empoyees have access to this to keep up to date and informed on environmenta aspects. Quinn Group s in-house magazine is pubished periodicay and is used to inform empoyees and the oca community of the status of the Environmenta Management System at Therm (PU). Poster and notice board campaigns highight genera and specific environmenta issues to the empoyees. Information incudes items such as the environmenta poicy statement, waste statistics, energy usage statistics and any artices of interest to Therm (PU). Communication meetings incuding Environmenta issues from each of the Business area wi be hed reguary. Environmenta issues and concerns are communicated to senior management through minutes and discussion from these meetings and senior management issues arising through the Group HSE Meeting.The minutes from Management environmenta meetings are pubished and distributed prompty and made avaiabe on notice boards. Communications from externa parties may incude compaints, suggestions or queries on environmenta issues raised by interested parties. Such communications are diverted to the pubic reations department that dea with a Therm (PU) externa communications incuding press reeases, pubic statements, etc. On matters of compaints, these wi be communicated to the HSE department who wi furnish them with any additiona information required. Detais of a communications and requests from externa parties documented and forwarded to the HSE Officer for storage as records as an externa communication fie. B.O.Nei Page /04 EPA Export :17:40:14

44 Therm (PU) Environment Manua TEMS.COOO Tite: Environmenta Management Responsibiities Approved by: Brendan O Nei Quinn Group HSE manager Page 45 of Reated Documents EPA Export :17:40:14

45 -.. I IiP,. Therm (PU) Environment Manua a!i!!er TEMSCOOOI Tite: Environmenta Management Responsibiities Approved by: Brendan O Nei Quinn Group HSE manager Page 46 of 81 Documentation ISQ Reference: EMS Documentation This manua documents and describes the eements of the Environmenta Management System. 2.0 Extent of documentation Documentation for the EMS consists of the foowing texts. EMS system manua (this manua) (TEM) Procedures manuas / matrix (TPM) Register of environmenta aspects (AR) Register of environmenta reguations (CLR) Environmenta management programme (TEMP) Monitoring and measurement records (TER) 2.1 Environmenta Management System manua (TEMS) The EMS manua provides a comprehensive overview of the environmenta management system. It outines the various mechanisms that the company empoys to maintain conformance with standard requirements. It describes reated documentation empoyed by the company in support of IS requirements and indicates where this can be ocated. 2.2 Procedures manua (TPM) The procedure manua defines the operating procedures for the system and, where appropriate, wi incude more detaied work instructions for specific tasks. 2.3 Register of Environmenta Aspects (AR) The Register of Environmenta Aspects detais, evauates and categorises the environmenta aspects of company activities that it can contro and over which it can be expected to have an infuence. B.O.Nei Page 46 16/06/04 EPA Export :17:40:14