ANNUAL ENVIRONMENTAL REPORT Licensee Cadbury Ireland

ANNUAL ENVIRONMENTAL REPORT Licence Register Number P0795-01 Licensee Cadbury Ireland Limited Location of Installation Shinnagh,

Rathmore, County Kerry

Report for (year) 2008

Emissions from the installation: There have been some changes in emission points from the site since the initial granting of the licence in December 2007 as follows:

Emissions to Air: The boiler stack that was in place at the time the licence was issued has now been dismantled and replaced with a new stack. The original boilers are no longer in use and two new boilers have been commissioned in their place. The initial proposal for the replacement work submitted to the Agency was dated 27th March 2008 with additional information being requested by the Agency on 10th April. Final approval subject to compliance with the licence was issued on 12th June. There have been no changes to the fuel used (heavy fuel oil) to date. Emissions are measured approximately every 6 months by an external consultancy firm as described in Condition 4.2 of the licence with the annual figures (as reported in the AER spreadsheet incorporated in this document as Appendix 1) calculated on the basis of concentration at time of measurement and volume of heavy fuel oil used during the year. The full report is retained by the site Quality & Environment Manager and is controlled as an externally generated document. Emissions to Water (Surface Water discharge point SW1): The location of the discharge point to the receiving waters (the River Blackwater) is being changed in conjunction with the introduction of the divert system on the outflow. The acute toxicity of the undiluted final effluent as discharged at SW1 has been verified as being non-toxic in compliance with Condition 6.12 with results submitted to the Agency on 12 June 2008. A flow dependent sampler is in place at the nominated discharge point with testing taking place either in the on-site laboratory or in an external facility. The monitoring results for the year are reported in the AER spreadsheet (Appendix 1 of this report). Emissions to Water (Storm Water discharge point SW2): The current storm water discharge SW2 is being upgraded to include a silt trap and oil separator in compliance with Condition 3.8 of the licence. Drainage systems on site are being upgraded so that discharges from this point in the future will consist solely of the influent stream (flowing from the western side of the site) and the run-off from the employee car park. Emissions to Water (Storm Water discharge point SW3): Storm water discharge SW3 is being developed so that the storm waters which have been discharging to ground (a stone soakaway) on the eastern side of the site will be passing through a silt trap and oil separator. Monitoring and diversion mechanisms will also be installed on this system. The only part of the site which will be not be draining through this new discharge point once the current drainage work is completed will be the employee car park.

Emissions to land: There are no process emissions to land. As required by Condition 6.14 of the licence, a hydrogeological investigation of the site has been carried out. Three groundwater monitoring points have been identified upstream of the site (using the existing wells) with two new monitoring points created downstream of the site within the area of the WWTP. This report was submitted to the Agency on 12th February and is awaiting final approval. As a result of this recommendations of this report, biannual monitoring of groundwater will be carried out on site. Waste management record: Waste management records for the site for 2008 are included in the AER spreadsheet which comprises Appendix 1 of this report. Resource consumption summary: 2008 2007 Process water usage 122,550 m3 from wells 135, 638 m3 from wells Heavy fuel oil usage 3,667.1 tonnes 3,892.67 tonnes Diesel usage 0.23 tonnes 0.23 tonnes Gas usage 9.324 tonnes 8.9 tonnes Complaints summary No complaints of an environmental nature related to the operation of the facility have been received since the IPPC licence was issued in December 2007 Schedule of Environmental Objectives and Targets The Schedule of Environmental Objectives and Targets is included in Appendix 2, with Table 1 listing the specific Schedule for 2009. Environmental Management Programme (report for 2008) The 2008 report on the Environmental Management Programme for the site forms Appendix 3 of this report. Environmental Management Programme (proposal for 2009) The Environmental Management Programme for the site for the years 2009 – 2013 is described in Table 2 of Appendix 2 as it forms part of the overall Schedule of Environmental Objectives and Targets. Pollution Release and Transfer Register (report for 2008) All category specific PRTR pollutants are reported within the AER spreadsheet which forms Appendix 1 of this report. Pollution Release and Transfer Register (proposal for 2009) It is proposed to continue following all relevant guidelines as issued by the Agency, including the requirement to submit details electronically.

Noise monitoring report summary Condition 6.15 of the licence requires that a noise survey of the site operations be carried out annually. Monitoring was undertaken at six monitoring stations in the vicinity of the site, which were selected as representing noise sensitive locations in the local area. Where audible, emissions from the site were continuous and steady, and there were no occurrences of clearly audible tonal components (which would have resulted in a breach of schedule B4). Daytime noise levels as measured at all six stations were within the limit of 55dB as specified in the licence. Nighttime levels were lower than the 45dB at five out of the six monitoring stations, but exceeded this at the sixth point at which measurements took place (an unoccupied cottage). The definition of the latter as a noise sensitive location is being reviewed and it is likely that a more suitable NSL in the same area will be identified for the 2009 survey. Additional information was requested following the initial submission of the report on 3rd December, with the Agency issuing final approval of the report on 6th March. The full report is retained by the site Quality & Environment Manager and is controlled as an externally generated document. Ambient monitoring report summary No ambient monitoring is to be carried out as part of this licence. Tank and pipeline testing and inspection report Details of the tank and pipeline testing reports are included as Appendix 4 of this report. Reported incidents summary Date Reported incident 25/01/08 Hydraulic fluid spillage from compactor 10/03/08 Hydraulic fluid spillage from cocoa mass tanker 29/04/08 Heavy fuel oil spillage from pipeline 25/06/08 Non-reporting of incidents of (1) No flow rate recorded at SW1 as

probe detached on 2/03/08 (2) discharge at SW1 shown as in excess of ELV on 3 dates in May and (3) discharge at SW1 shown as in excess of ELV on 5 dates in June

11/07/08 ELVs for COD and TSS exceeded at SW1 1/08/08 ELV for flow to river exceeded at SW1 (heavy rainfall) 5/09/08 ELV for COD exceeded at SW1 6/09/08 ELV for COD exceeded at SW1 11/12/08 pH of discharge to river (continuous monitoring), COD, TSS and

BOD ELVs all exceeded at SW1 (14/01/09) Non-reporting by fax of incident of 11/12/08 Energy Efficiency audit report summary Condition 7.1 of the licence requires that an audit of energy efficiency of the site be carried out within one year of date of grant of the licence. This report was submitted to the Agency on 3rd December with final approval issued on 6th March 2009. Recommendations arising from the audit have been incorporated into the Schedule of Environmental Objectives and Targets for 2009. The full report is retained by the site

Quality & Environment Manager and is controlled as an externally generated document. Report on the assessment of the efficiency of use of raw materials in processes and the reduction in waste generated The report indicates that ingredient losses for 2008 amounted to 0.62% when the ingredient input figure is compared with the finished product output. Report on progress made and proposals being developed to minimise water demand and the volume of trade effluent discharge Process water used and wastewater discharged are regarded as Key Process Indicators for the site with quantities used per tonne of crumb monitored on a monthly basis for the last number of years. One initiative that was implemented at the end of 2008 was the installation of locks on hoses inside the factory. Hoses can therefore only be operated with the knowledge of management. The environmental awareness program scheduled to run during the first part of 2009 also raises awareness of the importance of saving resources such as water. Some discussions have been held to date with chemical suppliers which may lead to further opportunities for water reduction in CIP processes in the future (while still being mindful of food safety requirements). Review of residuals management plan The residuals management plan has been submitted to the Agency and is currently awaiting approval of costings (last communication dated 19/309) Statement of measures in relation to prevention of environmental damage and remedial actions (Environmental Liabilities) IPPC Licence P0795-01 includes a condition on Environmental Liabilities (12.2.1) which states; “The licensee shall as part of the AER provide an annual statement as to the measures taken or adopted at the site in relation to the prevention of environmental damage, and the financial provisions in place in relation to the underwriting of costs for remedial actions following anticipated events (including closure) or accidents/incidents, as may be associated with the carrying on of the activity.” The following measures are implemented on site in relation to preventing environmental damage.

• A full site specific ELRA has been carried out which identified mitigation measures at the facility and site.

• The RMP and costing have been prepared and submitted to the Agency and are awaiting approval. A Parent Company Guarantee will be drafted pending approval of the RMP costs by the Agency.

• IPPC annual contribution • Site wide training; IPPC and environmental awareness training is being rolled

out across the site. Approximately 50% of all staff have received training and the remainder are scheduled for 2009.

• Spill kits and containment booms are positioned throughout the site and are clearly signed.

• Weekly inspections are carried out of holding areas, bunds and spill kits.

• The Rathmore site is accredited to the 14001 standard and maintains an Environmental Management System (EMS) which complies to the standard and is audited regularly and revised for continual improvement. Revisions of the EMS have incorporated IPPCL requirements.

• Corporate Compliance Audits are also carried out and Cadbury has a Purple goes Green initiative.

• Regional Environmental Meetings rotate around different sites where environmental staff meet to discuss and share experience from their sites.

• Cadbury Ireland Ltd. maintain a high level of insurance to cover any unplanned pollution event or incident.

Environmental Liabilities Risk Assessment Review A full site specific ELRA has been submitted to the Agency and is currently awaiting approval. (02/03/09).

Appendix 1: AER spreadsheet

Facility ID & Activities

| PRTR# : P0795 | Facility Name : Cadbury Ireland Limited | Filename : Sheet1.xls | Return Year : 2008 | 4904

Version 1.1.01REFERENCE YEAR 2008

1. FACILITY IDENTIFICATIONParent Company Name Cadbury Ireland Limited

Facility Name Cadbury Ireland LimitedPRTR Identification Number P0795

Licence Number P0795-01

Waste or IPPC Classes of ActivityNo. class_name

7.2.1

The treatment and processing of milk, the quantity of milk received being greater than 200 tonnes per day (average value on a yearly basis).

Address 1 ShinnaghAddress 2 RathmoreAddress 3 County KerryAddress 4

Country IrelandCoordinates of Location 11800928

River Basin DistrictNACE Code 105

Main Economic Activity Manufacture of dairy productsAER Returns Contact Name Jocelyn Cathalin

AER Returns Contact Email Address [email protected] Returns Contact Position Quality & Environment Manager

AER Returns Contact Telephone Number 064-58004AER Returns Contact Mobile Phone Number 087 9059792

AER Returns Contact Fax Number 064-58368Production Volume 0.0

Production Volume UnitsNumber of Installations 1

Number of Operating Hours in Year 0Number of Employees 0

User Feedback/CommentsWeb Address

2. PRTR CLASS ACTIVITIESActivity Number Activity Name8c Treatment and processing of milk

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)Is it applicable?

Have you been granted an exemption ?If applicable which activity class applies (as per

Schedule 2 of the regulations) ?Is the reduction scheme compliance route being

used ?

AER Returns Worksheet

Page 1

Releases to Air

4.1 RELEASES TO AIR | PRTR# : | Facility Name : * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button | Filename : Sheet2.xls | Return Year : Nitroge 03/04/2009 17:278 12 20 20 28 28 6 7 6 6 6

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 T (Total) KG/YearA (Accidental) KG/Year

F (Fugitive) KG/Year

0.0 0.0 0.0 0.0 0.0

08 Nitrogen oxides (NOx/NO2) M ALTKane May Quintox KM9160 flue gas analyser 25998.5 25998.5 51997.0 0.0 0.0

11 Sulphur oxides (SOx/SO2) M BS EN 14791:2005 15165.5 15165.5 30331.0 0.0 0.086 Particulate matter (PM10) M ISO 9096 9311.0 9311.0 18622.0 0.0 0.0

02 Carbon monoxide (CO) M ALTKane May Quintox KM9160 flue gas analyser 1400.0 1400.0 2800.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


Additional Data Requested from Landfill operators

Landfill:* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

Please enter summary data on the quantities of methane flared and / or utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method CodeDesignation or

DescriptionFacility Total Capacity m3

per hourTotal estimated methane generation (as pe

site model) 0.0 N/AMethane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)Net methane emission (as reported in Sectio

A above) 0.0 N/A

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Method Used

RELEASES TO AIRPOLLUTANT METHOD

Method Used


Method Used


Method Used

Page 1

Releases to Waters

4.2 RELEASES TO WATERS | PRTR# : | Facility Name : | Filename : Sheet3.xls | Return Year : Total nitrogen | 03/04/2009 17:278 11 19 20 28 35 6 8 6 6 6

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility

QUANTITYSW1

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 T (Total) KG/Year

A (Accidental) KG/Year


0.0 0.0 0.0 0.0 0.0 0.012 Total nitrogen M ALT ETG03 (Ganimede) 1128.35 0.0 0.0 1128.35 0.0 0.0

13 Total phosphorus M ALT

HACH method adapted from Standard Methods for the Examination of Water and Wastewater 672.95 0.0 0.0 672.95 0.0 0.0

0.0 0.0 0.0 0.0 0.0 0.0* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.00.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

QUANTITYSW1

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 T (Total) KG/Year

A (Accidental) KG/Year


0.0 0.0 0.0 0.0 0.0 0.0

303 BOD M OTH

Oxygen Sensitive Electrode used to measure changes in dissolved oxygen content of material over 5 day incubation period 1776.25 0.0 0.0 1776.25 0.0 0.0

306 COD M CRM

HACH method adapted from J Water Pollution Control Federation 1964 10185.41 0.0 0.0 10185.41 0.0 0.0

238 Ammonia (as N) M ALT

Nessler method adapted from Standard Methods for the Examination of Water and Wastewater 58.32 0.0 0.0 58.32 0.0 0.0

314 Fats, Oils and Greases M ALTET 0834 Based on APHA 2005:5520:D 1.0 0.0 0.0 1.0 0.0 0.0

332 Ortho-phosphate (as PO4) M ALT

HACH method adapted from Standard Methods for the examination of water and wastewater 597.27 0.0 0.0 597.27 0.0 0.0

240 Suspended Solids M ALT Gravimetric methods 3559.82 0.0 0.0 3559.82 0.0 0.00.0 0.0 0.0 0.0 0.0 0.0


RELEASES TO WATERSPOLLUTANT

Method Used


Method Used


Method Used

Page 1

Releases to Wastewater or Sewer

4.3 RELEASES TO WASTEWATER OR SEWER | PRTR# : | Facility Name : | Filename : Sheet4.xls | Return Year : * Select a row by double-clicking on 03/04/2009 17:278 8 16 16 6 6 6 6

SECTION A : PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWERPOLLUTANT METHOD

Method Used

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWERPOLLUTANT METHOD

Method Used

Page 1

Releases to Land

4.4 RELEASES TO LAND | PRTR# : | Facility Name : | Filename : Sheet5.xls | Return Year : | 03/04/2009 17:278 9 17 17 6 6 6 6

SECTION A : PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.00.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.0


RELEASES TO LANDPOLLUTANT METHOD

Method Used

RELEASES TO LANDPOLLUTANT METHOD

Method Used

Page 1

Treatment & Transfers of Waste

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : 17 05 03 | Facility Name : 05 01 05 | Filename : Sheet6.xls | Return Year : 13 05 03 | 03/04/2009 17:275 24

Transfer Destination European Waste Code HazardousQuantity T/Year Description of Waste

Waste Treatment Operation M/C/E Method Used

Location of Treatment

Name and Licence / Permit No. of Recoverer / Disposer /

BrokerAddress of Recoverer /

Disposer / Broker

Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS

WASTE ONLY)

Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS

WASTE ONLY)

Within the Country 02 05 02 No 194.0 Sludges from on site effluent treatment R10 M Weighed Offsite in Ireland

McGill Environmental Services CK(S) 302/06 (waste collection permit holder Munster Waste WCP LK/008/08(d))

Ballinvoher, Castletownroche, Co.Cork

Within the Country 20 03 01 No 59.0Mixed muncipal waste (general compactor and yard skip) D1 M Weighed Offsite in Ireland

Killarney Waste Disposal W0217-01 (waste collection permit WCP LK/072/07(d))

Aughnacureen, Killarney, Co. Kerry

Within the Country 16 07 08 Yes 12.0 Waste oil R9 M Weighed Offsite in Ireland

Lehane Environmental & Industrial Services Limited (waste collection permit WCP/LK/066/06c)

Unit 5, Wallingstown Industrial Estate, Little Island, Cork

Rilta Environmental , Rathcoole, Co. Dublin 192-2

Within the Country 15 01 01 No 4.0Cardboard removed from site in dedicated cardboard compactor R3 M Weighed Offsite in Ireland

Killarney Waste Disposal W0217-01 (waste collection permit WCP LK/072/07(d))

Aughnacureen, Killarney, Co. Kerry

Within the Country 13 05 03 Yes 12.0 Interceptor Waste R9 M Weighed Offsite in Ireland




Within the Country 02 05 02 No 42.0 Sludges from on site effluent treatment R10 M Weighed Offsite in Ireland

Waddock Composting WP 01/02 (waste collection permit Lehane WCP LK/066/06c) Killamaster, Co. Carlow

To Other Countries 15 02 02 Yes 4.0 Oil containing absorbents, cloths, filters D10 E Volume Calculation Abroad


Unit 5, Wallingstown Industrial Estate, Little Island, Cork ATM Netherlands 03 / 7623

Within the Country 20 01 35 Yes 0.07 WEEE R4 M Weighed Offsite in Ireland



KMK Metals Recycling Ltd, Cappincur Industrial Estate, Co. Offaly 113-03

Within the Country 05 01 05 Yes 116.0 Hydrocarbon oil R9 M Weighed Offsite in Ireland




To Other Countries 17 05 03 Yes 324.0 Potentially contaminated soil D8 M Weighed Abroad


Unit 5, Wallingstown Industrial Estate, Little Island, Cork U Nord, Brenen, Germany 2006 / 008

Within the Country 17 04 05 No 14.3 Scrap metal R4 M Weighed Offsite in Ireland

Cork Metal Company CK (S) 204 /05 (waste collection permit WCP LK/024/05c) Dublin Hill, Cork

Within the Country 20 01 21 Yes 0.0136 Fluorescent lamp tubes R5 C Weighed Offsite in IrelandIrish Lamp Recycling Company WCP LK/057/06c

Blackpark, Kilkenny Road, Athy, Co.Kildare

Irish Lamp Recycling Company 02 2000B

Within the Country 20 01 35 Yes 0.0136 WEEE R5 C Weighed Offsite in IrelandIrish Lamp Recycling Company WCP LK/057/06c



Within the Country 20 01 33 Yes 0.0136 Battery R4 C Weighed Offsite in IrelandIrish Lamp Recycling Company WCP LK/057/06c



Within the Country 06 04 04 Yes 0.0136 Mercury R4 C Weighed Offsite in IrelandIrish Lamp Recycling Company WCP LK/057/06c



Within the Country 20 01 35 Yes 0.0136 Fittings R5 C Weighed Offsite in IrelandIrish Lamp Recycling Company WCP LK/057/06c



Within the Country 18 01 03 Yes 0.01 Waste from healthcare checks D9 E Volume Calculation Offsite in Ireland

Healthcare Waste Management Services WCP/LK/049/08d

The Royal Mews, 10 Dublin Street, Carlow

Eco-Safe Systems, Unit A, Allied Industrial Estate, Kylemore Road, Ballyfermot, Dublin 10 54-2

Method Used

Page 1

Treatment & Transfers of Waste

Within the Country 16 05 06 Yes 0.05COD vials and other unused laboratory chemicals D9 E Volume Calculation Offsite in Ireland

Johnston Logistics Limited WCP LK/056/07(c)

Blackchurch, Rathcoole, Co. Dublin

Shannon Environmental Services Ltd, Smithstown Industrial Estate, Shannon, Co. Clare 41 -1

Within the Country 17 09 04 No 120.04 Mixed construction waste D1 M Weighed Offsite in Ireland

Vincent Reen WP 07/16 (waste collection permit for Nigel O'Connor WCP LK/504/07b)

Old Chapel, Rathmore, Co.Kerry

Within the Country 17 09 04 No 1314.38 Mixed construction waste D1 M Weighed Offsite in Ireland

Vincent Reen WP 07/16 (waste collection permit for Michael Quirke WCP LK /177/07c)

Old Chapel, Rathmore, Co.Kerry

* Select a row by double-clicking the Description of Waste then click the delete button

Page 2

Appendix 2: Schedule of Environmental Objectives and Targets

Schedule of Environmental Objectives + Targets – Cadbury Ireland Rathmore, Co. Kerry (P0795‐01) ____________________________________________________________________________________

Page 1 of 5

SCHEDULE OF ENVIRONMENTAL OBJECTIVES + TARGETS

for period

2009 ‐ 2013

Licence Reg No P0795‐01

Licensee Cadbury Ireland Rathmore

Location of Installation Rathmore, Co. Kerry

Project No. Rev Date Prepared By Status

12448-6006 B March 2009 MWP + Cadburys Rathmore Controlled


Page 2 of 5

CONTENTS

1. INTRODUCTION 2. SCOPE

3. FORMAT 4. DISCUSSION 5. LIMITATIONS

APPENDICES

TABLE 1 ‐ ENVIRONMENTAL OBJECTIVES + TARGETS

TABLE 2 – ENVIRONMENTAL MANAGEMENT PROGRAMME 2008 ‐ 2012


Page 3 of 5

1. INTRODUCTION This document has been prepared to satisfy Condition No’s 2.2.2.2 and 2.2.2.3 of Cadbury Ireland

Rathmore IPPC License (P0795‐01), and includes the first annual review. The document outlines

Cadburys Rathmore environmental objectives and targets and the Environmental Management

Programme (EMP) which defines the actions and a time schedule for achieving these objectives and

targets.

2. SCOPE 2.1 Environmental Objectives: Cadbury Ireland Rathmore environmental objectives are based on:

statutory obligations, and in particular IPPC licence requirements

an extensive corporate level environment policy; and

a facility specific environmental management system.

2.2 Environmental Targets: The proposed targets are specific tasks which have been identified as being

necessary for the achievement of environmental objectives. These targets will be reviewed and

updated periodically to ensure they appropriately address environmental goals.

2.3 Environmental Management Programme (EMP): The EMP outlined in this document, which sets

out the schedule of how and when objectives and targets will be achieved, has been established

through extensive assessment of the identified environmental aspects of the facility’s operation and

management. The proposed plan sets out the priorities and actions to be pursued over the next five

years to achieve environmental goals.


Page 4 of 5

3. FORMAT

The Schedule of Environmental Objectives and Targets is presented in 2 No. tables as follows:

Table 1 ‐ Environmental Objectives and Targets. This table outlines

The environmental aspects to be addressed

The environmental objective relative to the aspect

The targets which detail performance requirements to achieve environmental objectives

Specific schemes / actions necessary to meet environmental targets

Priority of action

Table 2 ‐ Environmental Management Programme. This table follows on from Table 1 and outlines

the schedule and responsibility for achieving environmental actions and targets outlined in Table 1.

4. DISCUSSION Environmental Objectives were divided into two main categories, namely:

i) Operational Objectives‐ which incorporates twelve broad categories of operational aspects

identified as having potential to influence the environmental performance of the facility

ii) Management Objectives – which incorporates the twelve categories of aspects associated with

the facilities environmental management system


Page 5 of 5

4.1 Operational Objectives:

The actions and time frames proposed for achievement of Operational Objectives have been

determined based on the Schedule of Environmental Objectives and Targets developed for Year 1 (2008)

through to Year 5 (2012).

The 5‐year Programme has been reviewed and revised forward to incorporate a Programme for the next

5 years; Year 2 (2009) to Year 6 (2013).

Many of the operational objectives identified in Year 1 are due to be completed in Year 2 (2009).

Given the significant financial costs involved, the proposed programme affords some priority to those

actions with most potential to reduce environmental impacts within the main target categories, namely

storm water and wastewater management issues.

4.2 Management Objectives:

Cadbury Ireland Rathmore currently has an Environmental Management System (EMS) in place which is

accredited to ISO14001. The EMS has been reviewed and minor modifications are ongoing to

incorporate the requirements of the IPPC Licence.

Many site procedures have been updated, including the Monitoring Procedure, Corrective and

Preventive Action Procedure and Communication Procedure. The EMS will be further reviewed and

updated throughout Year 2 (2009) and the following years in keeping with principles of Continual

Improvement.

5. LIMITATIONS

Targets for achieving objectives which had a considerable amount of large engineering works have been

extended in part due to adverse weather conditions.

Page 1 of 9

Table 1 Environmental Objectives and Targets ‐ Cadbury Ireland Ltd, Rathmore, Co. Kerry

OPERATIONAL REQUIREMENTS ASPECT OBJECTIVE TARGETS ACTION PRIORITY

Storm Water Management

No soil, surface water or groundwater contamination as a result of storm water discharges from the site

Maintain a silt trap and oil separator on storm water discharges

All pump sumps storage tanks, lagoons or other treatment plant chambers from which spillage of environmentally significant materials might occur shall be fitted with high liquid level alarms

The provision of a catchment system to collect any leaks from flange and valves of all over‐ground pipes to be examined

Ensure that contaminated storm waters currently discharging to ground at the eastern side of the installation, discharge to the River Blackwater via a silt trap and oil separator

Install suitable monitoring and a diversion mechanism on the discharge to ensure that contaminated storm water is diverted to the on‐site WWTP

Monitor ground water biannually

2 no. full retention separators shall be installed on SW3 (primary storm water outfall from the site). 1 no. bypass separator shall be fitted on SW2 (western outfall).

High liquid level alarms shall be fitted at the emergency tank and divert tanks.

Storm water drainage system to be upgraded to include monitoring and diversion of contaminated storm water.

New storm water outfall shall be constructed as part of the upgrade works.

Storm water upgrade works shall include monitoring and divert mechanisms. TOC and hydrocarbon monitors shall be installed.

Kerry drains to undertake limited additional testing and survey based on gaps identified in review

Continue with existing storm water pipelines remediation/ upgrading

Organise for sampling and analysis of ground water twice per year

HIGH

HIGH

HIGH

MEDIUM

HIGH

HIGH

HIGH

MEDIUM

Water Resource management

Encourage water conservation

Targets to be established for reduction in water consumption

Recycling/ Reuse: Storm water holding / firewater retention tank shall be fitted with connection points to allow for reuse of water in a fire event.

Continue with water project on site

Further investigations into recycling and reuse initiative options

MEDIUM

Page 2 of 9

Table 1 continued Environmental Objectives and Targets


Wastewater Management

No soil, surface water or groundwater contamination as a result of wastewater discharges from the site No substance shall be discharged in a manner or at a concentration that following initial dilution causes tainting of fish or shellfish

In order to protect the quality of a water body, 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

Continuous monitoring: ‐ No flow shall exceed the specified limit ‐ No pH shall deviate from the specified range ‐ No temperature value shall exceed the limit value Composite Sampling: ‐ No pH shall deviate from the specified range ‐ Other than pH + flow, 8 of 10 consecutive

composite results shall not exceed the emission limit value.

‐ No individual result shall exceed 1.2 times the emission limit value

Discrete sampling: ‐ Other than pH + temperature, no grab sample

value shall exceed 1.2 times the emission limit value

Permanent phosphorus removal

equipment to be installed at the WWTP. Review sludge level with phosphorus removal equipment

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 Storm water Management report for details.

HIGH

MEDIUM

HIGH

HIGH

Energy Use a) Reduce Installations Energy Consumption

b) Increase the use of renewable energy

Increase the boiler TDS level on the boilers from 3,000 to 3,500 ppm by end 2009.

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

MEDIUM

Power generation

Reduce Installations use of conventional power generation

Incorporate clean energy technologies options for power generation

Investigate if any new or emerging possibilities for clean energy in 2009.

MEDIUM

Page 3 of 9

Page 4 of 9

Table 1 continued ‐ Environmental Objectives and Targets


Waste Management

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

a) Increase volume of recyclable material of total waste produced. Quantifiable target to be set.

b) ‐ 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

c) Waste shall be stored in designated areas protected against spillage and leachate run‐off

Establish set targets for waste reduction

Identify areas where recyclable materials can be increased

MEDIUM

Fuel & Chemical Storage

No soil, surface water or groundwater contamination as a result of fuel + chemical stored on‐site

i) All tanks, containers and drum storage areas shall be rendered impervious to the materials stored therein

ii) All inlets, outlets, vent pipes, valves and gauges to be stored within the bunded area

iii) All drainage from bunded areas to be diverted for collection and safe disposal

iv) Adequate supply of containment booms and/or suitable absorbent material to contain and absorb any spillage

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

iv) Review requirements for spill kits + replace where necessary

MEDIUM

Page 5 of 9


OPERATIONAL REQUIREMENTS

ASPECT OBJECTIVE TARGETS ACTION PRIORITY

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.

Continuous monitoring:

‐ No 24 hour mean value shall exceed the emission limit value

‐ 97% of all 30 minute mean values taken continuously over an annual period shall not exceed 1.2 times the emission limit value

‐ No 30 minute mean value shall exceed twice the emission limit value

Non‐continuous Monitoring

‐ For flow, no hourly or daily mean value shall exceed the relevant limit value

‐ For all other parameters, no 30 minute mean value shall exceed the emission limit value

Bi‐annual monitoring of stack emissions to be carried out to ensure targets are being complied with

MEDIUM

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

Annual noise survey to be carried out to ensure targets are met

Review Noise Sensitive Locations in proximity to the site

MEDIUM

Fugitive Emissions

No soil, surface water or groundwater contamination as a result of fugitive emission from the site

Complete the identification of fugitive emissions from the facility by June 2009

Implement any actions identified in the fugitive emissions reduction programme

MEDIUM

Page 6 of 9



ASPECT OBJECTIVE TARGETS ACTION PRIORITY

Material Handling: Minimise preventable losses of all materials through handling procedures

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

MEDIUM ‐ Ongoing review

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 do not exceed 0.5%

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

MEDIUM ‐ Ongoing review and optimisation

Goods consumption (specifically crumb raw materials of (1) milk (2) sugar (3) cocoa mass (4) butter oil)

Reduce the facilities overall raw material resource consumption per tonne of finished product

Material storage: Minimise preventable losses of all relevant (potentially sensitive) materials while in storage. Milk in silos and reclaim/rework in process tanks have potential to deteriorate hence becoming unfit for use and then must be disposed of – thus not only resulting in loss of valuable raw materials but also extra loading onto the site effluent plant.

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

MEDIUM Ongoing. Twice daily Every shift

Facility + Equipment Maintenance

Adequate control of plant + equipment so that hazardous breakdown is prevented

Ensure maintenance programme in SAP includes all key equipment that is central to meeting targets / monitoring systems by June 2009.

Continue with maintenance programme. Review + update if necessary

HIGH

Page 7 of 9


ENVIRONMENTAL MANAGEMENT SYSTEM REQUIREMENTS

ASPECT OBJECTIVE TARGET ACTION PRIORITY

Management + Reporting Structure

Make provision 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 + reporting structure to be reviewed and updated by December 2008

Responsibilities in relation to quality, environment, health + safety and general operating procedures are outlined

Review annually + update as necessary

MEDIUM

Schedule of Environmental Objectives + Targets

As above Establish schedule of environmental objectives + targets by June 2008


HIGH

Environmental Management Programme

As above Established 5 year environmental management programme by June 2008


HIGH

Documentation As above Existing environmental management documentation system to be reviewed by December 2008


MEDIUM

Data Management system

As above Establish a data management system for collation, achieving, assessing and graphically presenting environmental monitoring data by June 2008


HIGH

Corrective Action

As above Existing corrective action procedure to be reviewed by December 2008


MEDIUM

Page 8 of 9




Awareness + Training

Increase the environmental awareness of employees

All employees are familiar with the Group’s environmental policy by December 2008.


Continue with site wide IPPC awareness training throughout 2009. Complete training of Mass Tanker drivers.

MEDIUM

Communication Programme

Communicate environmental performance with interested parties

Ensure interested parties + members of the public can obtain information concerning the environmental performance of the installation

Notice board of contact details for environmental queries has been installed. This is included in the communication procedure.

LOW

Efficient Process Control

Adequate control of processes under all modes of operation

Establish a programme for the control of processes and monitoring of process control performance

Continue with Regional KPI initiative; Environmental Governance pack to address KPIs in 2009.

MEDIUM

Accident Prevention

Provide for the protection of the environment by preventing accidents

Ensure no major accidents occur

Reduce the number of minor accidental events with environmental and/or health & safety consequences

Establish specific remedial measures at problem locations where measures are targeted to reduce particular types of commonly occurring accidents.

Maintain compliance with health and safety codes;

Review existing accident prevention procedures

Carry out safety audits to ensure that best practices are maintained

Review accident data annually as a basis for output monitoring and determining future local safety schemes + programmes. Review schemes a suitable period after implementation and take action as necessary. Carry out prompt emergency repair to damaged and distressed plant + equipment

MEDIUM

Page 9 of 9




Emergency Response

Provide for the protection of the environment by mitigating potential consequences of unplanned events

Prevention of escalation of the emergency

Protection of natural and physical resources

Develop and improve staff capabilities to respond effectively to environmental emergencies

Review existing emergency response programme to include the following:

Policies and procedures,

Response plans,

Operational guidelines,

Technical guidance on emergency response

MEDIUM

Reporting Report on the environmental performance of the facility to interested parties

Prepare + submit to the Agency an Annual Environmental Report (AER)

Prepare Pollution Release and Transfer Register (PRTR) annually

MEDIUM

Page 1 of 8

TABLE 2: ENVIRONMENTAL MANAGEMENT PROGRAMME – 2009 ‐ 2013


ACTION ASPECT YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY


Complete installation of bypass separator on SW2 (Western outfall)

Storm water drainage systems upgrading‐, including monitoring + diversion of storm water (Phase 2) to include 2000m3 holding tank /firewater retention tank

Fit high liquid level alarms at emergency tank and divert tanks

2 no. full retention separators to be installed on SW3 (primary storm water outfall)

TOC and Hydrocarbon monitors to be installed

Kerry drains to undertake limited additional testing and survey based on gaps identified in review

Continue with upgrading of pipework

Routine monitoring of storm water discharges

Ground water sampling and analysis twice per year













MWP ‐ External Engineering Consultant to implement + oversee infrastructural works

Cadbury Quality and Environment Manager to carry out routine monitoring

Page 2 of 8

OPERATIONAL REQUIREMENTS ACTION ASPECT

YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY

Water Resource management

Establish targets for reducing the quantity of fresh water used on site

Fit storm water holding / firewater retention tank with connection points to allow for reuse of water in a fire event

Continue with water projects on site

Further investigations into recycling and re‐use initiative options

Review of targets


Review of targets


Review of targets


Review of targets

Cadbury Quality and Environment Manager to commission audit


Install TOC monitor, divert mechanism and diversion chamber

Bunding of Tanks + Divert drain from River

Remediation of Existing balance tanks (Replacement option)

Dispose of sludge build‐up from balance tanks

Review sludge levels with phosphorous removal equipment installed

Survey + Improve WWTP safety + access

Continue with upgrading of process/foul drains

Routine monitoring at outfall

Continue with WWTP safety + access improvements



Installation of Activated sludge plant (Phase 1)










MWP ‐ External Engineering Consultant to implement + oversee infrastructural works

Cadbury Quality and Environment Manager to carry out routine monitoring

Page 3 of 8


ACTION ASPECT

YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY

Energy Use Review targets for energy use reduction

Increase the boiler TDS level on the boilers from 3,000 to 3,500 ppm.

Review targets for energy use reduction in 2010.

Review targets for energy use reduction




Power generation Investigate if any new or emerging possibilities for clean energy in 2009.

Establish targets for use of clean energy technologies

Review targets Review targets Review targets Review targets Cadbury Quality and Environment Manager to commission audit

Waste Management

Establish set targets for waste reduction

Identify areas where recyclable materials can be increased

Review targets for waste reduction + reuse






Commence works for local / remote bunding of tanks + drums

Commence containment works for inlets, outlets, vent pipes, valves and gauges

Establish schedule for assessment /integrity testing of bunds + tanks

Continue with weekly inspection and include spill kits

Continue with containment works for inlets, outlets, vent pipes, valves and gauges

Review spill kit requirements

Commence scheduled assessment /integrity testing of bunds + tanks

Review spill kit requirements

Review spill kit requirement

Review spill kit requirement

MWP + Metlab

Page 4 of 8


ACTION ASPECT

YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY

Air Emissions Carry out stack emission monitoring surveys (April + Sept)

Continue ongoing monitoring through daily logs

Carry out stack emission monitoring surveys (April + Sept)




Cadbury Quality and Environment Manager to commission monitoring events

Noise Emissions Carry out boundary noise survey

Review Noise Sensitive Locations in proximity to the site

Carry out boundary noise survey




Cadbury Quality and Environment Manager to commission monitoring events

Fugitive Emissions

Complete the identification of fugitive emissions from the facility by June 2009

Implement any actions identified in fugitive emissions reduction programme

Review annually Review annually Review annually Review annually Cadbury Quality and Environment Manager to commission this work

Page 5 of 8


ACTION ASPECT YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY

Goods Consumption

Finalise and approve all materials procedures

Review + update material handling procedures to minimise losses

Review + update material processing procedures to minimise losses

Review + update material storage procedures to minimise losses










Cadbury Quality and Environment Manager

Facility & Equipment Maintenance


Continue with maintenance programme Review + update if necessary




Cadbury Quality and Environment Manager + Health + Safety Officer

Page 6 of 8

ENVIRONMENTAL MANAGEMENT SYSTEMS REQUIREMENTS

ACTION ASPECT

YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY

Management + Reporting Structure













Cadbury Quality and Environment Manager and support from MWP







Cadbury Quality and Environment Manager and support from MWP

Documentation Review annually + update as necessary













Page 7 of 8


ACTION ASPECT

YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY

Corrective Action Review annually + update as necessary








Continue with site wide IPPC awareness training throughout 2009

Complete training of Mass Tanker drivers






Communication Programme








Continue with Regional KPI initiative; Environmental Governance pack to address KPIs in 2009.






Page 8 of 8


ACTION ASPECT

YEAR 2 2009

YEAR 3 2010

YEAR 4 2011

YEAR 5 2012

YEAR 6 2013

RESPONSIBILITY

Accident Prevention



Carry out prompt emergency repair to damaged and distressed plant + equipment














Emergency Response







Reports AER to be submitted to Agency by 31 March

PRTR to be submitted to Agency by 31 March

AER to be submitted to Agency by 31 March









Appendix 3: Environmental Management System report (2008)

REVIEW of ENVIRONMENTAL MANAGMENT PROGRAMME

Review for AER

2008

Licence Reg No P0795‐01

Licensee Cadbury Ireland Rathmore

Location of Installation Rathmore, Co. Kerry

Project No. Rev Date Prepared By Status

12448-6025 D March 2009 H. Dalton Controlled

ENVIRONMENTAL MANAGEMENT PROGRAMME – 2009 REVIEW


Aspect YEAR 1 ‐ 2008 STATUS / COMMENT

i) Kerry drains to complete pressure testing and survey of underground pipework

Initial survey completed, and reviewed by Malachy Walsh and Partners (MWP) engineers. Further limited survey has been requested based on review.

ii) Continue with upgrading of pipework New contract in 2009

iii) Assess need for Firewater Retention facility Completed

iv) Fit high liquid level alarms at the WWTP balance tank, emergency tank and divert tanks

Some already exist on main holding tank and remainder as part of the phosphorous contract

v) 2 no. full retention separators to be installed on SW3 (primary storm water outfall)

To be completed by April 2009

vi) Storm water drainage systems upgrading ‐ including monitoring + diversion of contaminated storm water {Phase 1) to include 220m3

monitoring tank

Storm Water contract; To be completed by April 2009

vii) Construct new storm water outfall as part of upgrading works Storm Water contract; To be completed by April 2009

viii) TOC and Hydrocarbon monitors to be installed Quote received from Gilroys; To be completed by April 2009

ix) Remediation of existing storm water soakaway at eastern boundary Completed in Phase 1A. May require review after Phase 1B.


x) Routine monitoring 1st sample sent for monthly external QC. Results under review and to be compared with internal results.

Page 2 of 8



i) Carry out audit to identify opportunities for reduction in the quantity of water used on‐site

Water project is ongoing at the site. Hoses are now locked off in the factory. Water Resource

management

ii) Check for leaks Hygiene audits ongoing at the moment.

i) Install Phosphorus removal equipment at WWTP Temporary removal equipment on site currently and permanent solution to be installed

ii) Install TOC monitor + divert mechanism at treated effluent outfall

Quote received from Gilroys. Quote approved, order placed

iii) Continue with upgrading of process/foul drains Works ongoing. Review of drain survey resulted in gaps Drain survey; Works to follow


iv) Routine monitoring at outfall Monitoring procedure in place. Audit to be scheduled in 2009

i) Carry out audit to identify opportunities for energy use reduction + efficiency

Audit carried out and report completed. Summary Report sent to EPA Energy Use

ii) Establish targets based on audit for energy use reduction Targets reviewed and 2009 target included in the next Schedule of Objectives and Targets

Power generation

i) Investigate possibilities for use of clean energy technologies Airtricity currently supplying electricity (95% renewable)

Waste Management

Carry out audit to identity areas where waste can be reduced Waste folder compiled by JC. All permits and licences contained within. Ongoing management of records

Page 3 of 8



i) Establish plan for drainage from bunded areas to be diverted for collection and safe disposal

Recommendations to be implemented in next Phase of work

ii) Provide spill kits / containments booms at all fuel + chemical storage areas

Inventory to be included in SAP system. Kits are in place with signage. Training on IPPC includes spill kits and daily inspections also include kits.

iii) Assess integrity of Heavy Fuel Oil Bund (Completed) Recommendations to be implemented in next Phase of work

iv) Assess integrity of Nitrite and Caustic bunds Metlab report complete. Bunds in good condition.


v) Investigate options for suitable containments of spills / leaks at inlets, outlets, vent pipes, valves and gauges

Raw Material Intake Assessment carried out. PK to review spill trays etc.

i) Install + commission new boilers Boilers up and running; daily logs are completed

ii) Decommission old boilers Stack removal complete, old boilers are decommissioned on site.

Air Emissions

iii) Carry out stack emission monitoring On SAP and will be scheduled going forward

(Monitoring of new boilers carried out; within limits)

Noise Emissions i) Carry out boundary noise survey Dixon Brosnan conducted noise survey. Report submitted to EPA Dec 4th. Noise sensitive locations to be reviewed

Page 4 of 8



i)Establish programme for identification + reduction of fugitive emissions from the facility by December 2008

Identification to be completed ‐ Ongoing Fugitive Emissions

ii) Interim action ‐ examine the need for catchment system to collect any leaks from flanges and valves of overground pipes.

Included in the Raw Materials Intake Assessment (remote bunding – part of Storm Water contract)

i) Review Material Handling procedures Ongoing; Developing a Table

ii) Review Material Processing procedures Ongoing

Goods Consumption

iii) Review Material Storage procedures Ongoing; May develop a table with a map.

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

In place with SAP. Maintenance Procedure has been updated to reflect current management within SAP.

Page 5 of 8

Environmental Management Programme 2008‐Continued



Amend the existing documented management structure to include all personnel associated with the installation.

Structure updated and reflects current organisation. Management + Reporting Structure

Responsibilities in relation to the quality, the environment, health + safety and general operating procedures to be outlined

Job descriptions detailing responsibilities in Environmental Manual


Identify all environmental aspects associated with site activities and establish means for control.

COMPLETED FOR 2008 – reviewed & updated for 2009

Year 2 to 6 identified as 2009 ‐ 2013


Prioritise objectives + targets and set deadlines for achieving compliance with environmental targets

COMPLETED FOR 2008 –reviewed & updated for 2009

Year 2 to 6 identified as 2009 ‐ 2013

Documentation Establish procedure outlining the environmental management documentation system

Documentation Procedure has been revised and approved. Will be audited in 2009.


Document the procedure for the data management system Data managed per procedures and records; ongoing

Page 6 of 8



Corrective Action

Amend and update the existing corrective action procedure to take account of IPPC licence requirements

Procedure approved and in use


Review training and document all environmental training undertaken by employees

Training Assessment Records developed. Ongoing; further records to be developed. Enviro training of new staff and staff on new projects. IPPC awareness training has been rolled out on site. Approximately 50% of staff are trained.

i) Write standard operating procedure for communication programme

SOP written and approved Communication Programme

ii) Notice board of contact details for environmental queries has been installed.

The notice board is installed at the entrance

Establish a programme for the control of processes and monitoring of process control performance Ongoing. There is a Regional KPI initiative in Cadbury; Environmental

Governance pack to address KPIs will be developed and distributed in 2009.

Existing key process indicators to be reviewed by December 2008 Ongoing. There is a Regional KPI initiative in Cadbury; Environmental Governance pack to address KPIs will be developed and distributed in 2009.


Methods for measuring + controlling KPIs to be established by December 2008 Ongoing. There is a Regional KPI initiative in Cadbury; Environmental

Governance pack to address KPIs will be developed and distributed in 2009.

Page 7 of 8



i) Review existing accident prevention procedures Ongoing

ii) Carry out safety audits to ensure that best practices are maintained

Ongoing

Accident Prevention

iii) Carry out prompt emergency repair to damaged and distressed plant + equipment

Ongoing

Emergency Response

Review existing emergency response programme Review is ongoing; amalgamating documents from Safety Systems also

i)AER to be submitted to Agency by 31 March COMPLETED

ii) PRTR to be submitted to Agency by 31 March COMPLETED

iii) Residuals Management to be submitted to the Agency by 5 June COMPLETED /awaiting approval

iv) Environmental Liabilities Risk Assessment to be completed by 5 December

COMPLETED /awaiting approval

Reports

v) Hydro geological Site investigation to be completed by 5 December

COMPLETED /awaiting approval

Note:

This is a review of the 2008 EMP. The EMP has been revised for 2009 ‐2013 and this facilitates the continuation of the management of the targets and actions.

Page 8 of 8

Appendix 4: Tanks and pipelines testing reports

12448 – Cadbury IPPC Licence Implementation

Infrastructure Testing

Summary Report

March 2009

Consulting Engineers: Client:Malachy Walsh & Partners Cadbury Ireland Ltd.Reenpoint ShinnaghBlennerville RathmoreTralee Co. KerryCo. Kerry

Document Amendment Record

Project No Rev Date Prepared Reviewed Approved Status

12448 6032-A March 2009 P. Kelly H. Dalton M. O’Sullivan Current

Infrastructure Testing Summary Report 1


Table of Contents

1.0 Introduction........................................................................................................................................1

2.0 Testing...............................................................................................................................................1

2.1 Heavy Fuel Oil Bund .....................................................................................................................1

2.2 Nitric and Caustic Bunds...............................................................................................................1

2.3 Testing of Underground Pipes ......................................................................................................1

2.4 Testing of Tanks & Containers......................................................................................................2

Appendix A – Test Certificates for Nitric Acid Bund and Caustic Soda Bund

Appendix B – Results of Water Tightness Tests on Underground Pipelines



1.0 Introduction This report summarises the tank and pipeline testing that has been carried out to date to satisfy Condition 6.10 of IPPC Licence No. P0795-01. Testing is ongoing and this report will be updated as testing progresses.

Condition No. 6.10

The integrity and water tightness of all underground pipes, tanks, bunding structures and containers and their resistance to penetration by water or other materials carried or stored therein shall be tested and demonstrated by the licensee. This testing shall be carried out by the licensee at least once every three years and reported to the Agency on each occasion. This testing shall be carried out in accordance with any guidance published by the Agency. A written record of all integrity tests and any maintenance or remedial work arising from them shall be maintained by the licensee.

2.0 Testing

2.1 Heavy Fuel Oil Bund A detailed inspection was carried out by Malachy Walsh and Partners as described in our report titled “Structural Assessment of Heavy Fuel Oil Bund”. The conclusion of the report was that the bund is fit for its design purpose and that only minor remedial work is necessary to ensure that it can deliver on its design intent, i.e. pipe penetrations shall be properly sealed. Remedial works to the bund are to be carried out this week. A summary report of the visual re-test shall be submitted to the Agency next week.

2.2 Nitric and Caustic Bunds As advised in our correspondence of 20th June 2008, Bodycote Metlab were contracted to test the nitric acid and caustic soda bunds. The tests, which involved (a) visual inspection, (b) dye penetrant inspection of welds and (c) ultrasonic test of thickness of steel lining were carried out in August 2008. Both bunds were found to be in good order. The results of these tests are enclosed in Appendix A.

2.3 Testing of Underground Pipes Kerry Drains Services have carried out a CCTV survey and water tightness testing of the foul and surface water drainage on site. The survey was carried out in May and June 2008. The drainage systems were tested by means of water tightness tests in accordance with Appendix G of “IPC Guidance Note on Storage and Transfer of Materials for Scheduled Activities”. The CCTV survey and water tightness test reports were completed in July 2008.

The following is a summary of the results of the water tightness testing:

Drainage System Lines Passed Lines Failed Lines for Review

Foul Drains 56 runs 12 runs 6 runs

Storm Drains 38 runs 16 runs 8 runs



The results sheets for the water tightness tests are enclosed in Appendix B. Malachy Walsh and Partners have a copy of the CCTV survey. This can be submitted to the Agency if required.

Malachy Walsh and Partners are currently assessing the survey of the drainage system and are preparing a programme of works for remedial works. Part of this assessment includes identifying any gaps in the initial CCTV survey and water tightness tests. It is intended that remedial works to the drainage systems will commence in June of this year, as part of Phase III of the IPPC Licence Implementation Works.

2.4 Testing of Tanks & Containers There are 3 no. underground tanks at the WWTP site. These include the east and west divert tanks and the primary settlement tank. These tanks will be monitored through the use of localised groundwater monitoring as recommended in Appendix G of ‘Guidance Note on Storage and Transfer of Materials for Scheduled Activities’. Two new groundwater monitoring boreholes have been installed down gradient of the wastewater treatment plant as part of the Hydrogeological Assessment of the site. These boreholes will permit monitoring of the underground tanks. This is in line with our discussions with the Agency which occurred in a meeting on 25th June 2008.

The Hydrogeology Report, January 2009, which was prepared by TEC Ltd. shows that there was no contamination in soil or groundwater samples at the wastewater treatment plant and recommended that no additional remediation is required. Bi-annual groundwater monitoring will be carried out in line with the report recommendations.



Appendix A – Test Certificates for Nitric Acid Bund and Caustic Soda Bund



Appendix B – Results of Water Tightness Tests on Underground Pipelines


BODYCOTE METLAB

Unit 6 Airways Technology Park, Ballygarvan, Cork. T: (021) 4311614 F: (021) 4311714 email: [email protected] Bodycote Metlab - registered in Ireland (No. 84894) - Bodycote Metlab is the trading name of Metlab (Int) Limited

Report No: C 6667-8 Client: Cadburys

Job No: C 10874

Date: 7/08/2008 Address: Rathmore,

Co.Kerry

Ultrasonic & Dye penetrant Inspection

Report Page: 1 OF 2

Location of test: Rathmore NDT Specification: EN 1714 & EN 571 Client Ref: Nitric acid tank bund Material: Carbon steel Weld Process TIG

Surface finish: Smooth Component: Primary welds & shell plates Capacity: Not supplied Heat Treatment: N/A

Calibration Block: A4 & sensitivity block Scan Surface: Acceptable Couplant: Ultrasonic Gel Flaw Detector: Sonatest sitescan

Probe Type: WK CD 10 Serial No: 18288

Probes Angle 0° Probes MHz 5MHz Twin

Ref dB 56db Scan dB 72db

Compression probe Scan level : 2ND Back wall echo to full screen height Shear wave probe Scan level: DAC + 14db

Summary: Bodycote Metlab was requested by Mr. Liam O’Flynn of Cadburys to conduct an inspection survey on the Nitric acid storage

tank bund located at the rear of the plant on the 7th of August 2008.

Please note that access was restricted to one side of the bund due to the tank location.

Inspection details:

An ultrasonic thickness measurement survey was carried out on the floor and wall plates to check for any variations in wall

thicknesses that may suggest corrosion activity is present.

A dye penetrant inspection was carried out on all the primary welds mainly concentrating on ‘T-Joints’ and any seam welds

which would be susceptible to leaking or cracking from expansion etc.

Results:

UTM- Over 150 readings were taken throughout the bund; these were all consistent and ranged between 3.1mm & 3.2mm.

DPI- No significant weld defects were found at the time of inspection.

Visual- No obvious signs of leaking or product staining were observed.

Procedure/Technique Ref: P(UT) EN 1 P(DPI) EN 3 Acceptance Standard: Report findings Test Restrictions: Isolated areas of scale (product) on certain sections of floor plate Technician Bodycote Metlab Approval Client approval

Name: (Cert no :) Signature: Date:

Colin Geary PCN II No 208984 13-08-2008

Name: (Position) Signature: Date:

John Coughlan Operations Manager 13-08-2008

Name: Signature Date

Form No: NDT 008 Rev 03

The results are only applicable to the items tested. This test report shall not be reproduced except in full without written approval of the laboratory.

BODYCOTE METLAB


Page 2 of 2

55% Nitric acid concentrate

Thickness measurements & Dye penetrant was carried out on seam welds



BODYCOTE METLAB


Report No: C 6668-8 Client: Cadburys

Job No: C 10874

Date: 7/08/2008 Address: Rathmore,

Co.Kerry

Ultrasonic & Dye penetrant Inspection

Report Page: 1 OF 2

Location of test: Rathmore NDT Specification: EN 1714 & EN 571 Client Ref: Caustic soda liquor tank bund Material: Carbon steel Weld Process TIG

Surface finish: Smooth Component: Primary welds & shell plates Capacity: Not supplied Heat Treatment: N/A

Calibration Block: A4 & sensitivity block Scan Surface: Acceptable Couplant: Ultrasonic Gel Flaw Detector: Sonatest sitescan

Probe Type: WK CD 10 Serial No: 18288

Probes Angle 0° Probes MHz 5MHz Twin

Ref dB 56db Scan dB 72db

Compression probe Scan level : 2ND Back wall echo to full screen height Shear wave probe Scan level: DAC + 14db

Summary: Bodycote Metlab was requested by Mr. Liam O’Flynn of Cadburys to conduct an inspection survey on the Caustic soda liquor

storage tank bund located at the rear of the plant on the 7th of August 2008.

Inspection details:

An ultrasonic thickness measurement survey was carried out on the floor and wall plates to check for any variations in wall

thicknesses that may suggest corrosion activity is present.

A dye penetrant inspection was carried out on all the primary welds mainly concentrating on ‘T-Joints’ and any seam welds

which would be susceptible to leaking or cracking from expansion etc, and also where floor buckling was occurring.

Results: UTM- Over 300 readings were taken throughout the bund; these were all consistent and ranged between 3.0mm & 3.2mm.

DPI- No significant weld defects were found at the time of inspection.

Visual- No obvious signs of leaking or product staining were observed.

Procedure/Technique Ref: P(UT) EN 1 P(DPI) EN 3 Acceptance Standard: Report findings Test Restrictions: Technician Bodycote Metlab Approval Client approval

Name: (Cert no :) Signature: Date:

Colin Geary PCN II No 208984 13-08-2008

Name: (Position) Signature: Date:

John Coughlan Operations Manager 13-08-2008

Name: Signature Date



BODYCOTE METLAB


Page 2 of 2

The results are only applicable to the items tested. This test report shall not be reproduced except in full without written approval of the l

Rear end of bund


aboratory.

Documents

ANNUAL ENVIRONMENTAL REPORT Licensee Cadbury Ireland