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ANNUAL ENVIRONMENTAL REPORT
2009
for
Licence No. P0795-01
Cadbury Ireland Limited
Rathmore,
Co. Kerry
P0-795-01|Cadbury Rathmore AER 2009
P a g e | 1
CONTENTS
1 INTRODUCTION
1.1 Licensee Details 2
1.2 Description of Site Activities 2
1.3 Company Environmental Policy (Overview) 2
1.4 Company Environmental Management Structure 3
1.5 Company Environmental Management Organisational Chart 3
2 SUMMARY INFORMATION
2.1 Self Monitoring Data 4
2.2 Agency Monitoring and Enforcement 7
2.3 Energy & Water Consumption 7
2.3 Environmental Incidents and Complaints 8
2.4 AER Summary Data table 8
3 MANAGEMENT OF THE ACTIVITY
3.1 Schedule of Environmental Objectives & Targets 8
3.2 Environmental Management Programme Report (for 2009) 10
3.3 Environmental Management Programme Proposal (for 2010) 16
3.4 Other Significant Environmental Aspects, Audits etc 21
4. LICENCE-SPECIFIC REPORTS
4.1 Noise Monitoring report summary 22
4.2 Tank and pipeline testing and inspection report 22 4.3 Report on the assessment of the efficiency of use of raw materials in processes and the reduction of waste generated 22 4.4 Report on progress made and proposals being developed to minimise water demand and the volume of trade effluent discharge 23 4.5 Environmental Liabilities Risk Assessment (ELRA) Review 23
APPENDICES
Appendix A: AER Summary Data Tables
TABLES
Table 1 Summary Table for Emissions to Water 4 Table 2 Summary of Non-Compliances for Emissions to Water 5 Table 3a Summary Table for Mass Emissions to Atmosphere 5
Table 3b Summary Table of Pollutant Average Concentrations 5
Table 4 Summary of Non-Compliances for Emissions to Atmosphere 5
Table 5 Summary information of waste arisings 6
Table 6 Summary information of waste streams 6
Table 7 Summary of EPA v Self Monitoring Data _________________________________ 7
Table 8 Energy Consumption 7
Table 9 Water Consumption 7
Table 10 Schedule of Environmental Objectives & Targets 9
Table 11 Summary 2009 EMP 11
Table 12 Environmental Management Programme (EMP) 2010 17
Table 13 Summary of Project Schedule 21
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1 INTRODUCTION 1.1 Licensee Details License Register Number: P0795-01 Licensee: Cadbury Ireland Limited Location of Installation Shinnagh, Rathmore, County Kerry
1.2 Description of Site Activities
The Cadbury Ireland Ltd, Rathmore installation manufactures milk chocolate crumb which is an intermediate
product utilised in the production of milk chocolate. Production of milk chocolate crumb involves pasteurisation
and evaporation of milk followed by the addition of sugar to form Sweetened Concentrated Milk (SCM). Butteroil
may also be added depending on the recipe and required fat concentrations. Liquid cocoa mass is then added to
form a paste. Raw and in-process materials are stored in tanks and silos on site. Off-specification product may also
be reworked into the process at this stage. The paste is then cooked and fed to an air drier or one of three vacuum
driers, prior to cooling. The resulting crumb is then weighed and packed into 1,150 kg bulk bags, or sent to the bulk
storage silos on site. There is also a milling process which may be employed to reduce the particle size of the
crumb where required. The control of the entire process is highly automated.
Cadbury Ireland Ltd Rathmore facility comprises of a main processing facility with associated buildings, storage structures and wastewater treatment plant.
1.3 Company Environmental Policy
Key policy objectives are as follows:
We will: 1. Strive to prevent pollution and minimise the environmental impacts of our operation, working with our
supply chain and business partners to reduce our collective environmental footprint and protect the ecosystems that provide our raw materials.
2. Guarantee that our customers and consumers come first by actively listening to and understanding their expectations of our brands.
3. Reinforce our commitment to sustainability and safeguard the reputation of Cadbury through regular engagement with internal and external stakeholders.
4. Maintain a zero waste culture that consistently embraces environmental sustainability where everyone understands their responsibilities and accountabilities.
5. Operate audited environmental management systems that continually improve our processes to deliver this policy and any associated standards and ensure compliance with prevailing legislation.
6. Assign clear management accountability for setting, monitoring performance against and meeting measurable targets for environmental performance.
7. Communicate openly and regularly in line with international good reporting practice
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8. Place continuous improvement at the heart of our performance through assessment of the environmental
performance of new and existing products and processes.
9. Create a passion for sustainability where success and achievement are recognised, communicated and celebrated.
10. Review and update this policy and any associated standards regularly ensuring that it continues to reflect our values and the expectations of key stakeholders.
1.4 Company Environmental Management Structure
Cadbury Ireland Ltd, Rathmore has a structured management approach to the operation of the business in terms
of product quality, process control, environment and safety.
The Head of Manufacturing has the overall responsibility for environmental management and control at the
Rathmore Installation.
The Quality and Environment (Q&E) Manager, as designated Environmental Representative, has responsibility
for day-to-day environmental management at the Rathmore Installation.
Shift Managers are responsible for ensuring day-to-day environmental requirements are met.
All staff at the facility have are responsible to ensure the environmental requirements are met.
1.5 Cadbury Rathmore Environmental Management Organisational Chart
Head of Manufacturing
Production and
maintenance
personnel
Laboratory &
Security Personnel
Quality & Environment (QE) Manager
WWTP Personnel
Production Shift
Managers
Site Leadership
Team
External
Contractors
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2 SUMMARY INFORMATION
The information presented here is for the calendar year 1st
January 2009 to 31st
December 2009.
2.1 Self Monitoring Data
2.1.1 Emissions to Water
Cadbury Ireland Rathmore is licensed for emissions to water. There is one emission point from the wastewater
treatment plant (SW1), discharging treated effluent to the River Blackwater. This emission point has been
monitored and analysed in accordance with requirements of Schedules B2 and C2.2 of the facilities IPPC Licence.
There are two licensed storm water emission points (SW2 and SW3) that indirectly discharge on-site storm water
to the River Blackwater. There are no license limits applied to these emission points however water quality is
assessed on a daily basis and analysed weekly in accordance with Schedule C2.3 and for additional parameters
stipulated in the Agency’s Site Inspection Report of February 2008.
Up until June 2009 water analysis was largely carried out in house at the on-site micro and chemistry laboratory by
fully trained and competent personnel. Parameters not tested on-site were sent to an independent external
laboratory for analysis. In June 2009, Cadbury Rathmore committed to comprehensive laboratory validation
programme. From June 2009 to December 2009 all self monitoring water emission samples were sent to an
independent external laboratory for testing while validation was in process.
There were five incidents of non-compliance associated with emission limit values for emissions to water during
2009. All were reported to the Agency and appropriate incidence investigation and corrective action was
undertaken.
Table 1: Summary Table for Emissions to Water
PARAMETER FINAL EFFLUENT DISCHARGE PT SW1
(2007)
FINAL EFFLUENT DISCHARGE PT SW1
(2008)
FINAL EFFLUENT DISCHARGE PT SW1
(2009)
EMISSION LIMIT VALUE
Volume 483.8 m3 512.2 m
3 483.4 m
3 900 m
3
Temp 10.89 10.9 14.6 25 maximum
pH 8.3 8.2 8.5 6 – 9
BOD 11.08 mg/l 17.14 mg/l 6.33 mg/l 40 mg/l
COD 73.98 mg/l 63.39 mg/l 42.7 mg/l 125 mg/l
Suspended Solids 27.66 mg /l 21.85 mg/l 17.75mg/l 50 mg/l
Total Nitrogen 3.33 mg/l 6.42 mg/l 8.45 mg/l 15 mg/l
Total Ammonia 0.17 mg/l 0.33 mg/l 0.4 mg/l 10 mg/l
Detergents 0.03 mg/l 0.02 mg/l 0.01mg/l 2 mg/l
Oils, Fats, Greases <10 mg/l <10 mg/l <10 mg/l 10 mg/l
Orthophosphate 2.13 kg / day 1.70 kg/day 0.33 kg/day 1.08kg/day *
Total Phosphorus 2.34 kg / day 1.95 kg /day 0.43 kg /day 1.17kg/day **
Toxicity n/a <2.2 n/a 5 TU
Note: This emission data is based upon the averaged monitoring data available for the facility. * Limit of 5.06 kg/day for orthophosphate applied before 5/12/08 ** Limit of 5.5 kg/day for total phosphorus applied before 5/12/08 *** Nitrate nitrogen as N
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Table 2: Summary of Non-Compliances for Emissions to Waters
DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION
10 April 2009 Reportable exceedence of ELV for orthophosphate
Known increased plant loading – specific cause unknown
In advance of known increase demand on system increase ferric dosing
15 April 2009 Reportable exceedence of ELV for phosphorous and orthophosphate
Excessive CIP in advance of boiler shutdown and poor control of holding tank levels resulting in by-pass of phosphorous treatment system
Level probe installed on balance tank to ensure tank levels are kept within a manageable range and reoccurrence of by-pass prevented
20 April 2009 Reportable exceedence of ELV for nitrogen
Cause undermined following investigation
Continuing investigation into origins of nitrogen
29 July 2009 Reportable exceedence of ELV for nitrogen
Cause undermined following investigation
Continuing investigation into origins of nitrogen
11 December 2009 Reportable exceedence of ELV for nitrogen
Run-off control barrier damaged during construction activities resulting in contamination of WWTP stone bed system
Run-off control barrier replaced. Protocol established for more rigorous monitoring of all further construction activities.
2.1.2 Emissions to Air
Licensed emissions to the atmosphere are in the form of combustion emissions. There have been no changes to
the type of fuel used (heavy fuel oil) to date. Air emissions monitoring from the combustion process are carried
out twice annually to licence requirements by independent contractors. There were no exceedences of licence
emission limit values for emissions to air.
Table 3a: Summary Table for Mass Emissions to Atmosphere
PARAMETER MASS EMISSION (2007)
MASS EMISSION (2008)
MASS EMISSION (2009)
Oxides of Sulphur 67419 kg / year 51997 kg/year 45654 kg/year
Nitrogen Oxides 29972 kg/year 30331 kg/year 29772 kg/year
Table 3b Summary Table of Pollutant Average Concentrations
CONCENTRATION May (2009)
CONCENTRATION November (2009)
EMISSION
LIMIT VALUE Boiler A1-1 Boiler A1-2 Boiler A1-1 Boiler A1-2
Oxides of Sulphur 1099 mg/m3 1159 mg/m
3 1141 mg/m
3 1108 mg/m
3 1700 mg/m
3
Nitrogen Oxides 698 mg/m3 800 mg/m
3 800 mg/m
3 651 mg/m
3 900 mg/m
3
NOTE: Mass emission figures for each year (as reported in the electronic AER) have been calculated from average
concentrations as measured against quantity of heavy fuel oil consumed. Average concentrations are measured are also
provided for comparison with the Emission Limit Values as given in the licence.
Table 4: Summary of Non-Compliances for Emissions to Atmosphere
DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION
There were no non-compliances associated with emissions to air
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2.1.3 Waste Arisings
Cadbury Ireland Rathmore is licensed to monitor waste sludge arising from the on-site wastewater treatment plant
facility. Sludge is tested annually and results are submitted to the Agency. A summary of all waste streams and
the management of waste arisings is presented in Tables 5 and 6 below.
Table 5: Summary information of waste arising
ITEM TONNES/ANNUM 2007
TONNES/ANNUM 2008
TONNES/ANNUM 2009
Total quantity of waste produced in calendar year
- Total quantity of waste disposed of on-site
- Total quantity of waste disposed of off-site
- Total quantity of waste recovered on-site
- Total quantity of waste recovered off-site
387.27 t
None
61.76 t
None
325.51 t
2195.86 t
None
1821.48 t
None
374.38 t
791.601t
None
303.325t
None
488.276t
Quantity of non-hazardous waste produced in calendar year
- quantity of non-hazardous waste disposed of on-site
- quantity of non-hazardous waste disposed of off-site
- quantity of non-hazardous waste recovered on-site
- quantity of non-hazardous waste recovered off-site
365.96 t
None
61.76 t
None
304.20 t
1727.72 t
None
1493.42 t
None
234.3 t
695.84t
None
284.88t
None
410.96
Quantity of hazardous waste produced in calendar year
- quantity of hazardous waste disposed of on-site
- quantity of hazardous waste disposed of off-site
- quantity of hazardous waste recovered on-site
- quantity of hazardous waste recovered off-site
21.31 t
None
None
None
21.31 t
468.14 t
None
328.06 t
None
140.08 t
95.761t
None
18.445t
None
77.316t
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Table 6: Summary information of waste streams
EWC CODE DESCRIPTION OF WASTE HAZ YES/NO
QUANTITY (T/A) 2008
QUANTITY (T/A) 2009
METHOD OF
DISPOSAL/RECOVERY
WASTE SOURCE WASTE TYPE
02 05 02 wastes from the dairy products industry
sludges from on-site effluent treatment
No 236 323.18 R10
02 05 01 Wastes from the dairy products industry
Materials unsuitable for consumption or processing
No n/a 4.32 R10
13 07 01 wastes of liquid fuels - fuel oil and diesel Yes n/a 10.76 R1
13 07 03 wastes of liquid fuels - other fuels (including mixtures) Yes n/a 48.26 R1
13 08 02 oil wastes not otherwise specified
other emulsions Yes n/a 9.22 R1
15 01 01 packaging (including separately collected municipal packaging waste)
paper and cardboard packaging No 4 6.24 R3
15 01 06 packaging (including separately collected municipal packaging waste)
mixed packaging No n/a 18.18 R13
15 01 10 packaging (including separately collected municipal packaging waste)
packaging containing residues of or contaminated by dangerous substances
YES n/a 0.06 R4/R5
15 02 02 absorbents, filter materials, wiping cloths and protective clothing
absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances
Yes 4 5.665 R1/D10
16 05 06 gases in pressure containers and discarded chemicals
laboratory chemicals, consisting of or containing dangerous substances, including mixtures of laboratory chemicals
Yes 0.05 0.044 D9
17 02 01 wood, glass and plastic wood No n/a 3.74 R3
17 04 07 metals (including their alloys)
Mixed metals No 14.3 59.04 R4
17 05 03 soil (including excavated soil from contaminated sites), stones and dredging spoil
soil and stones containing dangerous substances
Yes 324 2.9 R5
17 06 05 Insulation materials and asbestos-containing construction materials
construction materials containing asbestos
Yes n/a 17.64 D1
17 09 04 other construction and demolition waste
mixed construction and demolition
wastes other than those mentioned
in 17 09 01, 17 0902 and 17 09 03.
No n/a 221.16 D1
20 01 21 Municipal wastes -separately collected fractions
fluorescent tubes and other mercury-containing waste
Yes 0.0136 t 0.191 R5 / R4
20 03 01 Other municipal wastes
mixed municipal waste No 59 57.54 D1
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2.2 Agency Monitoring and Enforcement
2.2.1 Site Inspection
The EPA audited the site on one occasion in 2009. This was a schedule visit undertaken on 23 April 2009. One
non-compliance and several observations were noted on the day of inspection. Corrective action was undertaken
and all audit findings were appropriately addressed to the satisfaction of the Agency.
2.2.2 Emissions Monitoring The EPA collected samples from the final effluent discharge point SW1 for analysis on two separate occasions
during 2009. The collection dates were 1 April 2009 and 29 September 2009. There were notable differences
between self monitoring data and that of the Agency but there were no exceedences of emission limit values. The
most considerable differences between the recorded results are highlighted in Table 7.
Table 7: Summary of EPA Analysis v Self Monitoring Data
Parameter Self Monitoring Agency Emission Limit Value
BOD (1 April 2009) 5.5 25.5 40 mg/l Suspended Solids (1 April 2009) 50 37.2 50 mg/l COD (29 Sept 2009) 21.5 12 125 mg/l
2.3 Energy & Water Consumption Summary
2.3.1 Energy Consumption
Energy usage on site associated with production is largely fuel combusted in boilers to produce steam for the
thermal requirements of the site and electricity supplied to site, primarily for motive power. In addition to the
direct requirements of the manufacturing process energy is consumed on site for ancillary requirements such as
supply of well water, waste water treatment, tanker cleaning, loading and unloading of delivery vehicles,
compressed air production etc. Cadbury Ireland Rathmore used Heavy Fuel Oil as the main combustion fuel in
2009. Electricity used on site was obtained from the national grid. Water is sourced both from on-site wells and
municipal supply. Diesel usage is for the emergency generator. LPG usage is for the fork truck fleet and for
heating of some process lines during annual shut-down. Overall energy use fell in 2009 compared to 2008. A
focus on energy efficiency projects together with changes in the boiler system has helped the decrease in energy
usage on site.
Table 8: Energy Consumption Summary
ITEM 2007 2008 2009
Heavy Fuel Oil 3,892.67 tonnes 3,667.1 tonnes 3,457.94tonnes
Diesel 0.23 tonnes 0.23 tonnes 0.23 tonnes
LPG 8.9 tonnes 9.32 tonnes 7.85 tonnes
Electricity 6,925,255 kWh 6,449,854 kWh 6,424,000 kWh
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2.3.2 Water Consumption
The majority Municipal water is supplied by Kerry County Council. There has been a significant reduction in the
volume of municipal water used on-site in 2009 compared to volumes used in 2008. This is principally due to
improvements made to increase the efficiency of abstraction from on-site wells thus reducing the requirement for
additional supply. Overall water usage on site fell by 4% in 2009 compared to 2008 figures as a result of on-site
water conservation initiatives undertaken during the year.
Table 9 Water Consumption Summary
ITEM 2007 2008 2009
On-site ground water 135,638 m3 122,550 m
3 114,613 m
3
Municipal Supply 1497 m3 1017 m
3 403 m
3
2.4 Environmental Incidents and Complaints
There were no reportable incidences at the site during 2009.
No complaints were received during the year 2009.
2.5 AER Summary Data Tables
See Appendix A
3. MANAGEMENT OF THE ACTIVITY
3.1 Schedule of Environmental Objectives & Targets
The schedule of Environmental Objectives and Targets for Cadbury Rathmore was developed in 2008 to address a
five year period up to 2012. Environmental Targets and Objectives took into account compliance with all
conditions and schedules of the IPPC licence and the company’s financial, operational and business requirements.
The schedule shows that a total of 13 project areas were considered and that 39 schemes/actions had been
programmed for completion before 2012.
The schedule of Objectives and Targets was reviewed in December 2008 as part of the 2008 AER. The 5-year
Programme was reviewed and revised forward to incorporate a Programme for the next 5 years; Year 2 (2009) to
Year 6 (2013). The schedule of Objectives and Targets has again been reviewed in December 2009. Revisions to
this schedule principally relate to the reprioritizing of targets and review of timeframes for achieving targets.
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TABLE 10 Schedule of Environmental Objectives & Targets (Revised for period 2010 - 2014)
PROJECT OBJECTIVES TARGETS
Stormwater
Management
Improve storm water discharge quality to
ensure no soil, surface water or
groundwater contamination as a result of
stormwater discharges from the site
Improvements in stormwater quality through improvements to on-site collection
and filtrations system by 2012
Water Resource
Management
Improve water conservation Maintain or improve on the 4% reduction on 2008 volumes of water use per tonne of finished product
Wastewater
Management
Improve wastewater quality discharge to
ensure no soil, surface water or
groundwater contamination as a result of
wastewater discharges from the site
Improvements in wastewater treatment system by December 2010
Improvements in process water/foul drains by 2012
Emissions to waters from the wastewater treatment plant shall not exceed emission limit values outline in table B.2.2 of Schedule B of the facilities IPPC licence
No substance shall be discharged in a manner or at a concentration that following initial dilution causes tainting of fish or shellfish
Energy Use Reduce Installations Energy consumption
+ Increase the use of renewable energy
to improve energy efficiency
All findings and recommendations of the 2008 Energy Audit survey to be implemented and\or achieved by 2013
Power Generation Reduce Installations use of conventional
power generation
Evaluate the options of running the boilers on alternative renewable fuels by
2012.
Fuel & Chemical
Storage
No soil, surface water or groundwater
contamination as a result of fuel or
chemical storage on-site
All tanks, containers and drum storage areas shall be rendered impervious to
the materials stored therein according to the 2009 Tank Testing Schedule.
All drainage from bunded areas to be diverted for collection and safe disposal
via remote bunding by end 2010.
Waste
Management
Reduce hazardous and non-hazardous
waste and improve recovery, reuse and
recycling of waste material
Reduce the environmental impact of the
Installations waste
a) Waste Generation: Reduce the volume of waste generated at the Installation
b) Waste Handling: No soil, surface water or groundwater contamination as a result of waste collection or disposal
c) Waste Storage: No soil, surface water or groundwater contamination as a result of waste storage
Develop schedule for improvements by March 2010 (schedule will include
quantifiable objectives).
All routes for recycling to be investigated with a view to recycling 100% of
recyclable material by January 2011
Waste Generation – set target for reducing the volume of non-recyclable waste
generated at the Installation by end 2010.
Waste Handling – Waste sent-off site for recovery or disposal shall be
transported only by authorised waste contractors ( Licensed or permitted). - All
waste to be disposed of at a licensed or permitted facility
Waste Storage – Waste shall be stored in designated areas protected against
spillage and leachate run-off
Air Emissions Operations & activities at the facility shall
not result in the release of significant
levels of pollutants to the atmosphere
Emissions to the atmosphere from the installation shall not exceed emission limit
values set out in the IPPC licence
Emission of oxides of sulphur shall not exceed 1700mg/m3
Emissions of nitrogen oxides (as NO2) shall not exceed 900mg/m3
No emissions of offensive odours outside the boundaries of the premises.
Noise Emissions Noise generated on-site shall not impact
the amenity of neighbouring properties
Noise from the installation shall not give rise to sound pressure levels (Leq, T)
,measured at sensitive locations of the installation which exceed the limit value(s)
of 55dB(A) for Daytime noise and 45dB(A) for night-time noise
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Table 10ctd Cadbury Rathmore - Schedule Of Environmental Objectives & Targets (Revised for period 2009 - 2014)
PROJECT OBJECTIVES TARGETS
Fugitive Emissions Reduce fugitive emissions plant wide to
ensure no soil, surface water or
groundwater contamination as a result of
fugitive emissions from the site
Establish the losses from all on-site activities through fugitive emissions by 2012.
Develop a schedule for improvements (including quantifiable targets) by 2014.
Goods
Consumption
Reduce the facilities overall raw materials
resource consumption per tonne of
finished product
Material processing: Reduce, where possible, the losses of food materials in all
processes; while being mindful of possible food safety limitations. Target – that
annual ingredient losses (specifically raw crumb materials of milk, sugar, coca
mass and butter oi)l do not exceed 0.5%
Facility &
Equipment
Maintenance
Improve process control (equipment &
management) to reduce waste and
Improve maintenance and calibration of
control and monitoring equipment
to ensure adequate control of plant &
equipment so the hazardous breakdown
is prevented
Investigate downtime on all on-line monitoring equipment and reduce to less
than 5% by 2014
Environmental
Management
System
Make provisions for management of the
activity on a planned basis having regard
to the desirability of ongoing assessment,
recording and reporting of matters
affecting the environment
Existing management system and reporting structure to be continually reviewed
and updated as required
3.2 Environmental Management Programme Report 2009
The following table provides a summary on the programme of works undertaken in accordance with the 2009
environmental management programme (EMP). The summary gives an overview of the success in meeting the
planned targets for 2009.
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Table 11 SUMMARY of ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009
PROJECT TARGETS PROGRAMME/ACTION
REQUIRED
ACHIEVEMENTS V
TARGETS / ACTION
PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Storm Water Management
- Silt trap and oil
separator on
stormwater
discharges
- All pump sumps
storage tanks, or
other treatment plant
chambers from which
spillages of
environmentally
significant materials
might occur shall be
fitted with high liquid
level alarms
- Contaminated
stormwaters currently
discharging to the
ground at the eastern
side of the
installation, discharge
to the Blackwater via
a silt trap and oil
separator
- Suitable monitoring
and diversion
mechanism on the
discharge to ensure
that contaminated
stormwater is
diverted to the on-site
WWTP
- Complete installation of bypass separator on SW2 (Western outfall)
Bypass separator
installed on SW2
n/a n/a
Stormwater drainage systems upgrading – including monitoring + diversion of contaminated stormwater (Phase 1) to include 220m3 monitoring tank
Stormwater Phase 1B –
Monitoring & Diversion
System completed in
August 2009
Delays due to
weather and
difficulties
associated with
working in live
WWTP
n/a
Storm water drainage systems upgrading, including monitoring + diversion of storm water (Phase 2) to include 2000m3 holding tank /firewater retention tank
Stormwater Phase 1C –
Stormwater/Firewater
Tank commenced
November 2009
Delay in completion
of Phase 1B resulted
in delay to start of
Phase 1C.
Due for Completion
in May 2010
Fit high liquid level alarms at emergency tank and divert tanks
Included in Phosphate
Removal Contract. Not
Complete.
Delay in completion
of Phase 1B resulted
in delay to start of
this contract
To be completed in
early 2010.
2 no. full retention separators to be installed on SW3 (primary storm water outfall)
2 no. Full Retention
Separators installed and
commissioned on SW3
n/a n/a
TOC and Hydrocarbon monitors to be installed
TOC and Hydrocarbon
monitors installed and
commissioned
n/a n/a
undertake limited additional testing and survey based on gaps identified in review Continue with upgrading of pipework
Gaps in drainage survey
& testing not complete
Included in Phase
2A Drainage
Contract, which is
due to commence in
early 2010
To be completed
early 2010
Routine monitoring of storm water discharges
Routine monitoring of
stormwater has
commenced
n/a n/a
Ground water sampling and analysis twice per year
Groundwater sampling
has commenced
n/a n/a
Fit storm water holding / firewater retention tank with connection points to allow for reuse of water in a fire event
Not achieved Decision taken at
planning stage that
reuse of firewater is
not appropriate. All
firewater shall be
returned to the
WWTP for
treatment
n/a
Remediation of existing stormwater soakaway at eastern boundary
Existing stormwater
soakaway remediated in
January 2009
n/a n/a
Construct new stormwater outfall as part of upgrading works
New stormwater outfall
completed as part of
Phase 1B
n/a n/a
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Table 11 ctd SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009
PROJECT TARGETS PROGRAMME/ACTION
REQUIRED
ACHIEVEMENTS V TARGETS /
ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE ACTION
Wastewater Management
Complete WWTP upgrade by December 2009 Phosphorus removal
equipment shall be
installed at the
WWTP. Refer to
Wastewater
Treatment Plant
Assessment for
details.
Foul sewers shall be
remediated as part of
ongoing works.
Monitoring of pH,
flow and temperature
shall be maintained at
the outfall.
TOC monitor and divert mechanism shall be installed at the treated effluent outfall. Refer to Proposals for Stormwater Management report for details.
Install Phosphorus removal equipment at WWTP
Temporary phosphorus removal
system installed at DAF Unit in
January 2009. Permanent system
to be installed in early 2010
Delays in
completion of
Phase 1B resulted
in delay to start of
Phosphate
removal Contract
Permanent system to be
installed and
commissioned by March
2010.
Install TOC monitor, divert mechanism and diversion chamber at treated effluent outfall
TOC monitor and divert system
completed August 2009
n\a n\a
Bunding of Tanks + Divert the drain from River
Diversion of drain from river not
completed.
Bunding of tanks - groundwater
monitoring in place to verify
integrity of underground tanks.
Included in
Stormwater Phase
1C
To be completed early
2010
Remediation of Existing balance tanks (Replacement option)
Remediation of existing balance
tank not complete
These works
cannot
commence until
proposed
stormwater /
firewater tank is
in place.
Remediation of Balance
Tank to be carried out in
second half of 2010.
Dispose of sludge build-up from balance tanks
Not achieved Disposal of sludge
to be completed
as part of
remediation of
balance tank
To be carried out in second
half of 2010
Review sludge levels with phosphorous removal equipment installed
Review of sludge levels not
complete
See above Review of sludge levels to
commence in 2010
Survey + Improve WWTP safety + access
Access survey is not complete. Improvements to
WWTP safety &
access are
ongoing as part of
the new
construction
works in Phase 1B
and 1C.
Survey of access to existing
WWTP to be carried out
early 2010.
Continue with upgrading of process/foul drains
1 no. connection/upgrade to
process drain completed in July
2009.
n/a n/a
Routine monitoring at outfall
Routine monitoring at outfall is in
place
n/a n/a
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Table 11 ctd - SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009
PROJECT TARGETS PROGRAMME/ACTION
REQUIRED
ACHIEVEMENTS V TARGETS /
ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE ACTION
Water Resource Management
Opportunities for
reducing the volume
of on-site water usage
to be identified by
March 2010. Schedule
for improvements to
be devised by October
2010.
Carry out an audit to identify
opportunities for reduction in
the quantity of water used on-
site
Audit undertaken and some
action undertaken
n/a None required
Further investigations into recycling and reuse initiatives options Investigate options for
recycling / reuse of grey water.
The potential for recycling
and reuse options of grey
water in domestic systems
(eg Harvesting of roof water)
was considered but not
investigated.
n/a Further investigations
into this to be
progressed in 2010.
Fit stormwater holding /
firewater retention tank
with connection points to
allow for reuse of water in a
fire event
Not undertaken The proposal to fit the
stormwater holding tank/
firewater retention tank
with connection points to
allow for reuse of water in
a fire event was re
assessed and it was
determined that it would
not be best practice to
reuse firewater in a fire
event
None required
Energy Use
Implement finding of steam trap survey by December 2009 Increase the boiler TDS level on the boilers from 3,000 to 3,500 ppm.
Schedule to be developed by August 2009 through normal in house maintenance, planning and scheduling procedures.
Achieved n/a n/a
Review on basis of concerns
raised by water treatment
company that this target may
not be achievable. Review
additional opportunities for
energy use reduction and
efficiency
Achieved A review of the
recommendation to
increase the boiler TDS
levels from 3,000 to 3,500
ppm determined that this
was not
feasible/achievable
n/a
Power generation
Establish targets for
use of clean energy
technologies
Investigate if any new or emerging possibilities for clean energy in 2009
Achieved n/a n/a
Waste Management
Establish set targets
for waste reduction Identify areas where waste can be reduced
Achieved n/a Implement schemes
as identified.
Identify areas where recyclable materials can be used (eg returnable containers, supplier packaging etc)
Achieved n/a Implement schemes
as identified.
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Table 11 - SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009
PROJECT TARGETS PROGRAMME/ACTION
REQUIRED
ACHIEVEMENTS V
TARGETS / ACTION
PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE ACTION
Fuel & Chemical Storage
i) - All tanks/drum storage to be bunded locally or remotely to a volume of not less than 110% capacity of the largest tank
- Minor remediation as outlined in HFO
assessment report to be carried out
- Caustic + Nitric bunds to be tested
- Assessment of self bunded tanks to be carried out
ii) Investigate the possibility of using spill tray at HFO bund to overcome difficulties of positioning gauge within the bunded area
iii) Establish plan for drainage from bunded areas to be diverted for collection and safe disposal
Review requirements for spill kits
+ replace where necessary
Commence works for
local/remote bunding of tanks
+ drums
In progress n/a Continue as planned
commence containment works
for inlets, outlets, vent pipes,
valves and gauges
In processs n/a Continue as planned
Establish schedule for
assessment /integrity testing of
bunds and tanks
Achieved n/a Undertake
assessments as per
schedule
Continue with weekly
inspection and include spill kits
Satisfactory to date –
ongoing
n/a Continue as planned
Air Emissions Emissions to the atmosphere from the installation shall not exceed emission limit values set out in the IPPC licence
Carry out stack emission
monitoring surveys (April +
Sept)
Continue monitoring through daily logs
Achieved n/a n/a
Noise Emissions
Noise from the installation shall
not give rise to sound pressure
levels (Leq, T) ,measured at
sensitive locations of the
installation which exceed the
limit value(s) of 55dB(A) for
Daytime noise and 45dB(A) for
night-time noise
- Carry out boundary noise
survey
- Review Noise Sensitive Locations in proximity to the site
Achieved Noise emissions
at employee
carpark require
investigation
Investigate and
implement necessary
noise control
measures
Fugitive Emissions
Complete the identification of
fugitive emissions from the
facility
Examine the need for catchment
system to collect any leaks from
flanges and valves of overground
pipes.
As per targets Ongoing. Desktop study
was undertaken in 2009
to determine potential
sources of on-site fugitive
emissions
Priority was
afforded to
addressing
known areas of
fugitive emission
Continue with fugitive
emission survey in
2010
Facility & Equipment Maintenance
Establish a comprehensive
programme for planning,
scheduling and tracking
preventative maintenance
activities that provides a
systematic way of ensuring they
are not neglected
Continue with maintenance programme. Review + update if necessary
Achieved n/a Continue with this
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Table 11 - SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009
PROJECT TARGETS PROGRAMME/ACTION
REQUIRED
ACHIEVEMENTS V
TARGETS / ACTION
PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Goods Consumption
Take all measures required to ensure
no inadvertent losses of ingredients
to drain (e.g. while unloading milk
tankers to silos)
Review unloading systems to ensure
all ingredients captured in system
Monitor ingredients in vs finished
goods out. Monitor effectiveness of
other measures detailed below
Rathmore system is generally set up
to recover within process rather than
loss – but there are a couple of
existing areas where there is no
recovery step built in. All new
equipment to incorporate recovery
step. Manual recovery of material to
take place as far as possible
otherwise
Aim to evaporate all milk on day of
delivery.
Monitor and record condition of any
stored milk in silos.
Monitor condition of all reclaim /
rework in production area
Finalise and approve all
materials procedures
Ongoing This is being
carried out on a
priority basis
Continue as
scheduled
Conduct a root cause
analysis of spills during
2009 that will be
incorporated into a new
training program and
conducting the following
training
- Spill prevention
awareness training for
all plant personnel
- In-depth spill
prevention training for
all raw material handling
personnel
- Spill control training
for all production
personnel (as part of site
Emergency Response
procedure)
All achieved with
exception of training for
some external delivery
personnel
n/a Outstanding
spill prevention
training for raw
material
handling
personnel to be
prioritised in
2010.
Environmental Management System
Management + Reporting Structure Review annually +
update as necessary
Achieved n/a Continue as
planned
Schedule of Environmental
Objectives + Targets
Review annually +
update as necessary
Achieved n/a Continue as
planned
Environmental Management
Programme
Review annually &
update as necessary
Achieved n/a Continue as
planned
Documentation Review annually +
update as necessary
Achieved n/a Continue as
planned
Data Management system Review annually +
update as necessary
Achieved n/a Continue as
planned
Corrective Action Review annually +
update as necessary
Achieved n/a Continue as
planned
Awareness + Training Review annually + update as necessary
Continue with site wide IPPC awareness training throughout 2009
Complete training of Mass Tanker drivers
Achieved
Not achieved
n/a
n/a
Continue as
planned
To be
prioritised
during 2010
Communication Programme Review annually +
update as necessary
Achieved n/a Continue as
planned
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Table 11 - SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009
PROJECT TARGETS PROGRAMME/ACTION
REQUIRED
ACHIEVEMENTS V
TARGETS / ACTION
PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Environmental
Management
System ctd
Efficient Process Control Continue with Regional
KPI initiative;
Environmental
Governance pack to
address KPI’s in 2009
Achieved n/a Continue as
planned
Accident Prevention Review existing accident prevention procedures
Carry out safety audits to ensure that best practices are maintained
Carry out prompt
emergency repair to
damaged and distressed
plant + equipment
Achieved n/a Continue as
planned
Emergency Response Review annually +
update as necessary
Achieved n/a Continue as
planned
Reports i)AER to be submitted to Agency by 31 March
ii) PRTR to be submitted to Agency by 31 March
Achieved n/a Continue as
planned
3.3 Environmental Management Programme Proposal 2010
The targets and action programmes for the year are set out on an annual basis at the first Environmental
Management Meeting of the year. The environmental management plan (EMP) for 2010 proposes the
programmes and actions set out in Table 12 below to be undertaken in the coming year.
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Table 12 CADBURY RATHMORE - ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME
Stormwater
Management
In line with overall
objectives to improve
storm water discharge
quality and overall
target that these
improvements are
achieved by 2012 the
following targets and
actions are proposed
for 2010
100% of gaps in drainage
survey to be completed
Undertake additional testing and survey
based on gaps identified in previous survey
Contractor
By June 2010
All critical areas
identified as part of the
stormwater drainage
systems upgrading on
site to be completed
Further upgrading of storm water and
process water drains
Contractor
By December
2010
All identified stormwater
monitoring and control
mechanisms to be
installed
(i) Complete installation of 2000m3 holding
tank/firewater retention
Contractor By Sept 2010
(ii) All identified pumps, sumps, storage
tanks or treatment plant chambers from
which spillages of environmentally
significant materials might occur to be
fitted with high liquid level alarms
Contractor By Sept 2010
Water Resource
Management
In line with overall
objective to improve
water conservation
and overall revised
target to maintain or
improve on the 4%
reduction on 2008
volumes of water use
the following targets
and actions are
proposed for 2010
Continue with
identification of
opportunities for
reducing the volume of
on-site water usage
(i) Carry out site wide water balance to drive
future water reduction programmes
Contractor By end 2010
(ii) Analyse water meter data and review
water usage targets
Contractor and
Facility QE Manager
By end 2010
(iii) continue with site in house awareness
training on water usage and water
conservation
Facility QE Manager Ongoing
during 2010
Wastewater
management
In line with overall
objectives to improve
wastewater quality
discharges and overall
target that this is to be
achieved by 2012 the
following targets and
actions are proposed
during 2010
Planned WWTP
upgrading works for
2010 to be completed
(i) Further upgrading of foul water drains Contractor Ongoing
during 2010
(ii) Continue with WWTP safety + access
improvements
Contractor Ongoing
during 2010
(iii) Permanent phosphorus removal system
to be completed
Contractor By May 2010
(iv) Commence bunding of divert drain from
river with a view to be completed by
early 2011
Contractor By end 2010 /
2011
(v) Review sludge levels with phosphorus
removal equipment installed
Contractor By end 2010
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Table 12 ctd - ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME
Energy Use In line with overall
objectives to reduce
the facilities energy
consumption the
following targets and
actions are proposed
during 2010
Findings and
recommendations
of the 2008 Energy
Audit Survey set out
for 2010 to be
achieved
(i) Investigate whether a duct can be
installed for the air supply to the boiler air
intake from the top of the boiler house
Contractor and
Production Manager
by June 2010
(ii) Investigate the option of recuperating
the waste heat from the discharge stream
from dryer 0
Contractor and
Facility Production
Manager
by September
2010
(iii) Investigate whether heat can be
recovered from water going to evaporator
start up/shut down tank, preheat milk to
condenser (Heat Exchanger)
Contractor and
Facility Production
Manager
by December
2010
(iv) Investigate the sequence of operation of
the milling operation so as to utilise the
energy spent as efficiently as possible
Contractor and
Facility Production
Manager
by March
2010
(v) Investigate the feasibility of recovering
the discharge air from the pneumatic
actuators on closure
Contractor and
Facility Production
Manager
by September
2010
(vi) Investigate the possibility of installing a
VSD (reducing impeller trim) on the
distribution pump of Cooling Tower No. 2
Contractor and
Facility Production
Manager
by June 2010
(vii) Investigate the feasibility of reinstating
the steam coil on the heavy fuel oil storage
tank so as to replace the equivalent
electrical counterpart
Contractor and
Facility Production
Manager
by September
2010
(viii) Evaluate whether the operational
pressure of the standby boiler can be
reduced
Contractor and
Facility Production
Manager
by March
2010
Waste
Management
In line with overall
objective to reduce
hazardous and non-
hazardous waste and
improve recovery,
reuse and recycling of
waste materials the
following targets and
actions are proposed
during 2010
100% of identified
recyclable waste to
be recycled
(i) Continue with reducing the volume of
waste going to landfill
Facility QE Manager Ongoing
during 2010
(ii) Investigate and implement improved
kitchen waste segregation
Facility QE Manager By Sept 2010
(iii) Continue with waste management
training
Facility QE Manager Ongoing
during 2010
(iv) Review reducing 2009 volumes of
wastewater using COD and TOC monitoring
Contractor and
Facility QE Manager
Ongoing
during 2010
(v) Review targets for waste reduction +
reuse
Facility QE Manager By end 2010
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Table 12 ctd ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME
Fuel & Chemical
Storage
In line with overall
objectives to ensure there
is no contamination as a
result of fuel or chemical
storage on site the
following targets and
actions are proposed
during 2010
All presently
identified
potential risk
area to be
addressed
i) Continue with containment works for inlets,
outlets, vent pipes, valves and gauges
Contractor Ongoing
during 2010
(ii) Review spill kit requirements
Facility QE Manager
Ongoing
during 2010
Air Emission In line with overall
objectives that operations
and activities at the facility
shall not result in releases
of significant pollutants to
the atmosphere the
following targets and
actions are proposed
during 2010
Emissions to
the atmosphere
shall not exceed
emission limit
values set out in
the IPPC
licences
Monitoring as per licence requirements Contractor May 2010
&
October 2010
Noise Emissions In line with overall
objectives that noise
emissions shall not impact
the amenity of
neighbouring properties
the following targets and
actions are proposed
during 2010
Noise emissions
associated with
employee
carpark gate to
be mitigated
(i) Install appropriate noise control measures
at employee carpark gate
Contractor By May 2010
(ii) Continue with annual noise survey
Contractor By September
2010
Fugitive
Emissions
In line with overall
objectives to reduce risk of
contamination as a result
of fugitive emissions the
following targets and
action are proposed during
2010
Continue with
identification of
fugitive
emissions
(i) Prepare a schedule/plan for investigating
fugitive emissions
Facility QE Manager By June 2010
Facility
Equipment and
Maintenance
In line with overall
objectives to improve
process control the
following targets and
actions are proposed
during 2010
All key plant
and equipment
for control of
emissions to be
included in
SAPs
Continue with maintenance programme.
Review + update if necessary
Facility
Maintenance
Manager
Ongoing
during 2010
Goods
consumption
In line with overall
objectives to reduce the
facilities overall raw
materials resource
consumption per tonne of
finished product the
following targets and
action programmes are
proposed during 2010
Maintain 99%
recovery of
ingredients in
verses finished
goods.
(i) Outstanding spill prevention training for
raw material handling personnel to be
prioritised in 2010.
Facility QE Manager By May 2010
(ii) Establish improvements to reduce losses in
the production plant
Facility Production
Manager
By October
2010
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Table 12 ctd ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME
Environmental
Management
System
In line with overall
objectives to make
provisions for the
management of facility
activities on a planned
basis having regard to the
desirability of ongoing
assessment, recording and
reporting of matters
affecting the environment
the following targets and
actions are proposed
during 2010
Management +
Reporting
Structure
Schedule of
environmental
Objectives and
Targets
Environmental
Management
Programme
Documentation
Data
Management
System
Corrective Action
Awareness and
Training
Communication
Programme
Efficient Process
Control
Accident
Prevention
Emergency
Response
Reports
Continue annual review of procedures and
update as necessary
Facility QE Manager By December
2010
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Table 13 Summary of 2010 Project Schedule
Project Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec
Storm Water Management √ √ √ √ √ √ √ √ √ √ √ √
Water Resource management √ √ √ √ √ √ √ √ √ √ √ √
Wastewater Management √ √ √ √ √ √ √ √ √ √ √ √
Energy Use √ √ √ √ √ √ √ √ √ √ √ √
Power generation √
Waste Management √ √ √ √ √ √ √ √ √ √ √ √
Fuel & Chemical Storage √ √ √ √ √ √
Air Emissions √ √
Noise Emissions √
Fugitive Emissions √
Facility & Equipment Maintenance √
Goods Consumption √ √ √
EMS √ √ √ √ √ √ √ √ √ √ √ √
3.4 Other Significant Environmental Aspects, Audits etc
3.4.1 ISO 14001 EMS Audit
In 2009, Cadbury’s Rathmore ISO 14001-certified EMS underwent an annual audit for its conformance with the
standard and was recommended for continued registration following this evaluation. This audit was undertaken
by the NSAI in October 2009.
3.4.2 Internal Audit
An audit was undertaken of the Environmental Management System in October by Cadbury Personnel. This audit
did not highlight any significant new issues.
3.4.3 Management Environmental Meetings
Key internal environmental meetings are held by management at Cadbury Rathmore three times per year. There
are a number of unscheduled meetings as needed. The first meeting of the year reviewed the previous year and
established the programme of works for the coming year. Subsequent meetings updated the schedule of works
for the year and included the following projects:
i) Oil tank refurbishment and new pumping and heating set
ii) Next stage of roofing project
iii) Cooling tower for evaporator 1
iv) Next phase IPPC licence compliance agenda
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4. LICENCE-SPECIFIC REPORTS
4.1 Noise Monitoring report summary Dixon Brosnan undertook a noise survey in November 2009 and included a day time and night-time survey.
Overall noise levels recorded were satisfactory. The daytime 55db and night time 45db noise limits specified in
licence P0795-01 were not exceeded. Recommendations: It was noted during the night-time survey that noise
emission from the gate motors to the employee car park were audible at monitoring location N2 the south
western most corner of the site and there was recommendations made that these emission need to be addressed.
Noise Sensitive Locations were reviewed and on recommendation of the Agency an unoccupied cottage/dwelling
house situated immediately south of the facility was omitted from the 2009 survey as it was deemed to be
unrepresentative NSL.
4.2 Tank and pipeline testing and inspection report A visual inspection of all tanks and bunds on site at Cadbury Rathmore was undertaken during 2009. In total, 26
tanks and associated bunds were inspected. All tanks are to be visually re-inspected every three years. A
schedule for further testing and inspection was also prepared and submitted to the Agency. The Heavy Fuel Oil
tank was internally inspected in December 2009 and was passed as satisfactory. Five tanks have been schedule for
internal testing during the year 2010.
A review of the CCTV survey and water tightness testing which was carried out as part of Phase 1 of the IPPC
Works was carried out in 2009 and a Drainage Review Report was submitted to the Agency. The report included
the following data:
(a) Schedule for Integrity Testing of Outstanding Pipelines (b) Schedule for Review and Repair of Relevant Pipelines (c) Drains Marked ‘Not in Use’ (d) Testing of Drains Marked ‘Not in Use’ (e) Decommissioning of Drains
The report has revealed that 70% of the drainage systems have been tested. The gaps in the survey and testing
shall be closed out as planned under Phase 2A during 2010.
4.3 Report on the assessment of the efficiency of use of raw materials in processes and the reduction of waste generated
There have been large improvements made on waste management activities and training over the past year.
Significant advances in the identification of areas where waste could be reduced have been made. Significant
improvements in the disposal of organic waste were planned during 2009 for implementation during 2010. 100%
of waste crumb product is to be composted (off-site), diverting a significant volume of waste from landfill. In
terms of packaging waste, 100% of mini bulk sacks are now also diverted from landfill and recycled. Improvements
in waste segregation has also occurred. Up to 90% of scrap timber that would have been included within general
waste skips destined for landfill is now sent for recycling
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4.4 Report on progress made and proposals being developed to minimise water demand and the volume of
trade effluent discharge As part of the EMP for 2009 and general site programme, there was a focus on addressing water leaks on site.
Improved controls were installed on hoses and faucets. This reduced the consumption of raw water. Data
indicates that there has been a 4% reduction on 2008 figures in the volume of process water used. Onsite data
also indicates that there has been an 8% reduction on 2008 figures in the volume of wastewater discharged from
the site. There are ongoing initiatives for 2010 to implement improvements in water consumption and volumes of
wastewater generated.
4.5 Environmental Liabilities Risk Assessment (ELRA) Review An ELRA report, carried out by independent consultants relating to potential environmental liabilities was
submitted to the Agency in 2008. This report will be reviewed every three years and updates documented in the
AER as required in the licence.
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APPENDIX A| AER SUMMARY DATA TABLES