Annual Environmental Report of CROWN Packaging Ireland ...CROWN Packaging Ireland Ltd – Annual Environmental Report 2008 Page 2 CONTENTS Page No. Section 1: Overview 1.1 Introduction

Licence Register Number: P0098-01 Licensee: CROWN Packaging Ireland Limited Location of Activity: Woodstock Industrial Estate Athy Co. Kildare Attention: IPC Enforcement Administration Licencing and Control Division Environmental Protection Agency P.O. Box 3000 Johnstown Castle Estate Co. Wexford Prepared by: Dermot O’Callaghan Technical/ Environmental Manager CROWN Packaging Ireland Ltd Athy Co. Kildare. Date: April 2009

Annual Environmental Report of CROWN Packaging Ireland Limited Compliance with the Requirements of the IPC Licence

CROWN Packaging Ireland Ltd – Annual Environmental Report 2008

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CONTENTS Page No.

Section 1: Overview

1.1 Introduction 4

1.2 Site Description 5

1.3 Local Environmental Conditions 6

1.4 Main Units / Products 7

1.5 Economic Contribution 8

Section 2: Data

2.1 Summary Data 9

2.1.1 Emission Data 10-11 2.1.2 Energy and Water Usage 12 2.1.3 Environmental Incidents and Complaints 13 2.1.4 Other Significant Environmental Assessments 14-15 2.2 Pollution Emissions Transfers Register 16

Section 3: Environmental Management System

3.1 Environmental Management System 17

3.2 Environmental Management Organisation 18

3.3 Environmental Training and Education 19

3.4 Environmental EPA Site Inspection and Site Audit 20

3.5 Environmental Management Programme for 2006 21

3.5.1 Policy Statement 22 Section 4: Other Reports

4.1 Bund Programme and Bund Testing 23

4.1.1 Bunding of Diesel Storage Tank 23 4.1.2 Bunding of Flam Store 23 4.1.3 Pumping out of Integrated Flam Store Bund and

Fire Water Retention Facility Reports 24

4.2 Summary details of the Surrender Application for

License P0098-01 25-27


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APPENDICES Appendix 01 Verification of acceptance of AER/PRTR Emissions data

Appendix 02 Training Records 2008

Appendix 03 Environmental Management Programme 2008

Appendix 04 Bund Integrity Assessment of the Flamstore Bund

Appendix 05 Pumping out of the Flam Store Bund and Fire Water Retention Facility Reports

SECTION 1

OVERVIEW


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1.1 Introduction In accordance with schedule 4 (i) of IPPC licence reference number P0098-01, the

following is the Annual Environmental Report for the year 2008 at CROWN Packaging

Ireland Ltd, Athy, Co. Kildare. It is considered that the company continues to make

significant improvements in the management of its environmental affairs and the

protection of the local environment in which it operates.

The Environmental Management Team on site are committed to implementing ongoing

improvements programme at the facility. The Environmental Management System

(EMS) implemented at the facility has been upgraded to international standards and was

recommended for ISO 14001 accredidation by SGS on the 09th of March 2009.

Through ongoing training all associates at the facility are involved in this improvement

programme. The continuous improvement requirement of the IPPC process is fully

embraced by the Environmental Management Team. Crown Packaging Ireland Ltd are

also in the process of surrendering IPPC licence P0098-01, and demonstrate their

commitment to ongoing environmental awareness and improvement by achieving ISO

accreditation of their Environmental Management System.


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1.2 Site Description

CROWN Packaging Ireland Ltd is situated in the Woodstock Industrial Estate, which

is located within a rural setting on the outskirts of Athy, Co. Kildare. The plant was

built in 1974 and occupies an area of approximately 5,000 square metres.

The land area is approximately 45,000 square metres.

The plant is under the administration of Athy Urban District Council.


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1.3 Local Environmental Conditions

Certain conditions were agreed with the Athy Urban District Council when planning

permission was first granted. These conditions were imposed to ensure the protection

of the local environment and are in all cases being diligently enforced by the

company.

These conditions include the following:

1.3.1 ‘The developers shall not permit any surface or storm water to pass, whether

directly or indirectly, to the council’s foul sewer. The developers shall not

permit discharge into the council’s sewers or drains, directly or indirectly, any

substances whatsoever whether chemical, dye, grease, solvent or volatile

corrosive material which whether by itself or in conjunction with anything

already in such sewer or drain might be or become a source of danger or injury

to the sewer or drainage system or part thereof or which at the out fall of the

drainage system might be a nuisance, annoyance, danger or injury to any

person, property and right of easement’.

1.3.2 ‘No effluent, other than domestic sewerage, shall be discharged into the public

sewer without the agreement of Athy Urban District Council. Before Athy

UDC agrees to accept any such effluent, it will be necessary for the developer

to submit details including volume and analysis of effluent and report of same

to the Institute for Industrial Research & Standards and Athy Urban District

Council will require that the developer meet the conditions laid down by them

before such effluent is accepted into the public sewer’.

1.3.3 ‘The developers shall not operate in the said factory building any noxious,

offensive or injurious process, shall not use the premises or permit them to be

used so as to be a nuisance or annoyance whether by smell discharge, deposit,

dust, smoke, fumes, noise, vibration, electrical interference or otherwise to

adjoining owners or occupiers or to the public or so as to impair the amenities

of the locality’.


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1.4 Main Units / Products.

The operation manufactures three-piece cans for whole milk powder and dry baby

food.

Tinplate is the major raw material in which most of the requirements are purchased

from the UK. The tinplate is purchased plain and shipped to lithography companies in

the UK for printing and then shipped to Athy for processing. Other raw materials

used include – Aluminium and Tinplate Easy Open Ends, Penny Lever Assemblies,

Copper Wire, Aluminium Foil and Lacquers.

The can production process begins with the cutting of the tinplate sheets into blanks to

the exact size of the circumference and height of the required can. The can body

blanks are fed into the bodymaker, formed into a cylinder and the two unlacquered

edges of the blanks are welded together to form a leak-proof side seam. Lacquer is

then applied to the weld area to protect against rusting. The body is then flanged and

if necessary beaded for additional strength. The flanged body is then conveyed to a

seamer where the maker’s end or assembly is seamed in position, creating a leakproof

joint with the help of a compound.

The can is then conveyed to a packing machine, which packs the cans onto a pallet.

Each layer of cans is separated by a layer of cardboard. Each pallet of cans is

strapped and stretch wrapped prior to despatch.

Normal working hours are 8.00am to 12 midnight Monday to Thursday and 8.00am to

10.000pm on Fridays. If demand exceeds capacity during these hours, overtime work

is introduced as required. All products and methodologies are detailed in Question 9

of IPPC Licence Application 098.


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1.5 Economic Contribution

This company was established in Athy in 1974 by Borden Inc. A change in ownership

was effected in July 1999. The workforce includes managers, administrative staff and

plant operatives. The majority of associates live in the immediate locality, and this

has a substantial positive economic impact on the area.

Goods and services are sourced as much as possible from local businesses and

enterprises, e.g., security, haulage, stationery etc. This provides additional

employment in the businesses supplying these goods and services. This further

contributes to the wellbeing of the local economy.

Thus, this company has become an important contributor to the local economy and an

important part of the fabric of local industry in Athy.

SECTION 2

DATA


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2.1 Summary Data This section outlines all summary data derived from the ongoing monitoring

programme at CROWN Packaging Ireland as per the requirements of IPPC Licence –

Ref No. P0098-01


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2.1.1 Emission Data

Tables 2.1 –2.4 below give the results of monitoring for the following emissions:

• Emissions to water & sewers • Solid waste emissions – hazardous • Solid waste emissions – non hazardous 2.1.1.1 Emissions to Water / Sewers

TABLE 2.1

Results of Biannual Monitoring Analysis on Surface Water Samples from Jan 1st to

Dec 31st 2008

Date Emission Point Ref. COD mgl-1 pH units

16/06/08 SW1 <10 7.9

14/11/08 SW1 <10 7.7


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2.1.1.2 Solid Waste Emissions (Hazardous)

TABLE 2.2 Hazardous Waste Generated on Site from Jan 1st to Dec 31st 2008

Waste Category Quantity ( t/yr) Recycled/ removed by Address of Final Recovery/disposal site Fluorescent Tubes and Bulbs 0.05 Contec Technology Ltd Mercury Recycling, Mercury House, 17 Commerce Way, Trafford

Pk, Mancs M171HW Waste Thinners 0.205 Safetykleen, Ireland Ltd, ENVA, Clonminam Industrial Estate,Portlaoise, Co. Laoise Electrical and Electronic waste 0.544 KMK Metals Recycling Cappincur Industrial Estate, Daingean Rd, Tullamore, Co. Offaly 2.1.1.3 Solid Waste Emissions (Non-Hazardous)

TABLE 2.3 Non-Hazardous Waste Generated on Site from Jan 1st to Dec 31st 2008

Waste Category Quantity ( t/yr) Recycled/ removed by Address of Final Recovery/disposal site Mixed Municipal 2.74 AES AES Portlaoise, Kyletalisha, Portlaoise, Co. Laoise

Copper Wire 159.4 La Farga La Farga, 08509 Les Masies de Voltrega, Barcelona, Spain

Cardboard/Paper 23.31 AES AES Tullamore, Cappincur, Tullamore, Co Offaly Plastic 7.13 AES AES Tullamore, Cappincur, Tullamore, Co Offaly Waste Timber 87.94 AES AES Tullamore, Cappincur, Tullamore, Co Offaly Waste Tinplate 320.68 AES AES Portlaoise, Kyletalisha, Portlaoise, Co. Laoise


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2.1.2 Energy and Water usage

Summary data for energy and water usage at CROWN Packaging is detailed in Table

2.4 below.

TABLE 2.4

Energy and Water Usage on Site for 2007 and 2008

Units 2007 2008

Electricity Kilowatt Hours 1,020,000 1,180,000

LPG Litres 22,481 11,083

Diesel Litres 66,544 57,000

Water Litres 2,631,000 6,500,000


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2.1.3 Environmental Incidents and Complaints

All environmental incidents and complaints are recorded in the incidents and

complaints register (EMF014), which is held in the Technical Environmental

Managers office.

There were no environmental incidents reported for the reporting period

between the 1st of January 2008 and the 31st of December 2008.

Environmental Incidents are controlled under procedure EMP 004 and form EMF

018. EMP 004 is the procedure for notifying the agency in event of an environmental

incident - which outlines the mechanisms for the response to and reporting of

incidents. EMF 018 is the log sheet that details the incident.

Environmental Queries or Complaints are controlled under procedure EMP 003 and

forms EMF 004, EMF 005, EMF 006 and EMF 007. EMP 003 is the procedure for

handling environmental incidents and complaints. EMF 004, EMF 005, EMF 006 and

EMF 007 are the inquiry call log, the complaint call log, the inquiry visit log and the

complaint visit log respectively.

No environmental queries or complaints were received for the reporting period

between the 1st of January 2008 and the 31st of December 2008.


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2.1.4 Other Significant Environmental Assessments

Other significant environmental assesments carried out at CROWN Packaging under

the 2008 monitoring programme were:

Visual Analysis of Storm Water.

2.1.4.1 Visual Inspection and Analysis of Storm Water

In compliance with schedule 3 (i) of our IPPC Licence, monthly visual inspection of

the storm water was conducted. This inspection was controlled by the Environmental

Procedure EMP 002 (Procedure for Visual Monitoring of Storm Emissions) and the

Environmental Management Record Sheet EMF 012 (Visual Water Inspection Record

Sheet). These results are documented in table 2.5 below.

Table 2.5

Water Effluent Analysis 2008

Date Sample Appearance Odour Action

28/01/08 Clear None None













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The results of the bi-annual pH and COD analysis of the surface water are

documented in Table 2.6 below

Table2.6 Bi-annual Surface Water Monitoring Results Parameter Monitoring event 1

(18/06/08) Monitoring event 2 (14/11/08)

COD <10 mg/l <10 mg/l pH 7.9 pH units 7.7 pH units


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2.2 Pollution Emissions Transfer Register A Pollution Emissions Register (PRTR) is an electronic register of potentially harmful

pollutant releases or transfers, from the site. The annual publication of the PRTR will

provide the public with comprehensive information on the use, control, transfer and

release of pollutants in industry and create a powerful motivation for waste reduction.

The electronic PRTR submission has been compiled and uploaded onto the EPA

website, verification of acceptance of the upload and a copy of the report has been

included in Appendix 1 of this document.

SECTION 3

ENVIRONMENTAL MANAGEMENT SYSTEM


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3.1 Environmental Management System

In compliance with IPPC License Ref Number P0098-01 (Condition 2 – 2.5.1) an

Environmental Management System has been established at CROWN Packaging Ltd.

All documents, procedures, forms and record sheets are controlled by revision

numbers, stamped master copy and stored in the Environmental Management filing

cabinet in the Main Office. The Environmental Management System for the site was

upgraded in 2008 and was recommended for ISO 14001 accreditation on the 09th of

March 2009 following an accreditation audit by an eternal auditor from SGS.

The following documentation is controlled:

I. Environmental Management Forms

II. Environmental Management Procedures


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3.2 Environmental Management Organisation The Environmental Management Programme is co-ordinated by the Environmental

Management Team (EMT) as represented in Table 3.1 below.

TABLE 3.1 Name

Job Title

Responsibilities

A. Devlin

General Manager

Overall management responsibility

D.O’ Callaghan

Technical / Environmental Manager

Overall Technical and Environmental responsibility

J. Dalton

Operations Manager

Day-to-day responsibility for manufacturing related environmental issues

Michael Peters / Barry Wright

Engineer

Energy conservation


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3.3 Environmental Training and Education

In compliance with IPPC Licence Reference Number 098 (Condition No. 2.7), an

Environmental Training Programme has been established.

This section details the programme including procedures to control Environmental

Awareness and Training.

These procedures ensure that there is awareness throughout the organization at all

levels, of:

• The importance of compliance with the Licence

• The potential environmental effects of work activities and potential consequences

of departure from specified operating procedures

• Individual roles and responsibilities in achieving compliance with the Licence

• Environmental benefits of improved performance

CROWN Packaging Ltd has established procedures for identifying environmental

training needs and for providing appropriate training for all personnel whose work can

have significant effect upon the environment.

The environmental training plan for 2008 is recorded on Form EMF017. This is

included in Appendix 2.


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3.4 Environmental EPA Site Inspection and Site Audit Site Inspection The EPA carried out an un-announced site inspection on 14/04/08. The

Agency considered that the site is being well managed from an environmental

perspective. No non conformances with the license were noted.

There were two observations noted during the visit:

1. The licensable activity ceased on the 19/12/05. The observation required

the licensee to inform the agency if it intended to apply to surrender its

license and to carry out an independent exit audit of the site.

Following a communication from Crown Packaging dated the 12/06/09

proceedings were initiated to surrender License P0098-01. An

independent exit audit was conducted by Bord na Mona Environmental

Ltd and the report was submitted to the Agency in November 2008. An

exit audit of the facility was conducted by the EPA on the 11/03/09 (Ref

P0098-01 /gc16.doc).

2. The annual maintenance record for 2007/2008 was not available for

inspection on the day of the audit. The person in charge of the maintenance

contract was not on site on the day of the site audit. The maintenance

record in question was submitted to the agency in communication dated

the 12/06/08. Documentation observations regarding the diesel tank

inspection record were corrected and records were also submitted in the

communication dated the 12/06/08.


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3.5 Environmental Management Programme (EMP) for 2008

In accordance with Schedule 4 (i) of IPPC Licence 098, the Environmental

Management Team developed an Environmental Management Programme (EMP) for

2008. The purpose of the EMP is to ensure that the objectives and targets are

supported by a realistic programme that is implemented throughout the organization.

This programme of objectives and targets set for 2008 has been attached in Appendix

3. Progress made on the objectives and targets in the reporting period has been

detailed in the column labeled Comments/Progress made in 2008.

Objectives and targets are set annual and going forward shall be managed through the

ISO 14001 accredited Environmental Management System. Objectives and Targets

have been set for 2009. They ensure that progress is made in the areas of

environmental awareness, waste management, energy consumption, emissions from

the site. There is also an objective to complete the surrender of license P0098-01. The

system shall be independently audited to ensure progress towards set objectives and

targets and to ensure continual improvement with respect to the environmental

performance of the site.


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3.5.1 Environmental Policy Statement The following is the Environmental Policy Statement of CROWN Packaging Ltd.

CROWN PACKAGING LTD

ENVIRONMENTAL POLICY

CROWN Packaging is committed to environmental excellence throughout our

operation, both to live up to our social responsibilities and as a means to build the

value of our business. Excellence means integrating environmental planning and

execution into all business activities, complying with the law, conserving natural

resources, responsibly managing environmental risks, and working collaboratively

with others in addressing issues and opportunities.

It is the policy of CROWN Packaging to conduct its business of manufacturing and

distributing tinplate packaging in such a manner that its activities minimise or

eliminate any potential adverse effects to the environment.

An appropriate Environmental Management System has been developed and

maintained to assure the effective implementation of the Environmental Management

Policy.

The Environmental Management Policy and the requirements of the Environmental

Management System are issued under the authority of the General Manager. All

associates will familiarise themselves and comply with this policy and its principles as

they apply to their specific job function.

SECTION 4

OTHER REPORTS

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4.1 Bund Programme and Bund Testing This section of the report presents the bunding inspection programme implemented at

CROWN Packaging as part of its ongoing environmental strategy.

4.1.1 Bunding of the Diesel Storage Tank Crown Packaging has a documented procedure associated with the inspection of the

diesel storage tank (EMP 015) and the Diesel Storage Inspection Record Sheets (EMF

008). The procedure ensures that the tank, bund and associated pipe work are visually

inspected for integrity at three month intervals. It also ensures that the bundman

interstitial alarm is operational. During 2008 the checks were conducted on the

following dates: 13/03/08, 09/06/08, 23/09/08, and 03/12/08. No issues were

observed during the checks and the tanks were deemed to have no physical damage,

no chemical deterioration and no liquid in the bund. There was no evidence of spills

in the surrounding area and the Bundman interstitial alarm was tested and was

operating correctly on all occasions.

4.1.2 Bunding of Flam Store

The procedures associated with the testing and inspection of the flam store bund

(EMP012) (EMP 014) and the flam store bund/fire water retention facility testing and

inspection record sheets (EMF010) (EMF 009). A visual inspection of the flamstore

bund is conducted on a biannual basis by the technical manager. In 2008 these checks

were conducted on the 09/06/08 and on the 03/12/08. No issues were observed with

respect to cracking, mechanical damage, chemical attack damage, or any other

deterioration. The flamstore bund was also integrity tested for liquid tightness for

seven days in accordance with BS8007:1987, Clause9.2 (Appendix 1). The report has

been included in Appendix 4 of this report

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4.1.3 Pumping out of the Flam Store Bund and Fire Water Retention Facility Reports

This section of the report presents the record sheet (EMF 011) associated with the

pumping out of the integrated flam store bund and firewater retention facility at

CROWN Packaging - see Appendix 5. The procedure associated with the pumping

out of the flam store bund (EMP 013) is included as Appendix 5

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4.2 Summary details of the Surrender Application for License P0098-01

Crown Packaging was granted an IPC license reference number P0098-01 in 1996

which was granted for Class 12.2.2 activities, i.e.

The manufacture or use of coating materials in processes with a capacity to make or

use at least 10 tonnes per year of organic solvents, and powder coating manufacture

with a capacity to produce at least 50 tonnes per year.

The licensable activity ceased on the 19/12/05. However the facility continues to

manufactures three-piece cans for the whole milk powder and dry baby food

industries. Previously, up until 19th of December 2005, the company operated a press

department at the facility which used a solvent based compound for the manufacture

of various types of ends for the three-piece cans. As a result of the introduction of the

VOC regulations this process line was decommissioned and the manufacture of these

ends was transferred to a sister plant in the UK. As a direct result the usage of organic

solvents ceased completely and the company no longer met the criteria for requiring

an IPPC licence as set out in the Environmental Protection Agency Acts 1992-2003.

The EPA conducted an inspection of the site on the 14/04/08. The inspector noted the

following observation:

“The licensee is required to inform the Agency if it intends to apply to surrender its

license on receipt of this site report, In any event, an independent closure audit is

required to be carried out by a suitable qualified person with demonstrated experience

in contaminated land”

Following the EPA inspection on the 14/04/08, the decision was taken by Crown

Packaging management that the ceased activity would not be resumed and that IPPC

licence P0098-01 would no longer be required. The application for surrender of

licence was initiated.

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Bord na Móna Environmental Ltd. was commissioned by Crown Packaging Ireland

Ltd to undertake an independent exit audit of their facility at Athy, Co. Kildare.

The impetus of this audit was to identify the decommissioning, rendering safe or

removal for disposal/recovery of any soil, sub-soils, buildings, plant or equipment, or

any waste materials or substances or any other matter contained therein or thereon,

that are associated with the licensed activity that may result in environmental

pollution. The audit was carried out on the 30th of September and entailed review of

documentation, site visit and interviews with relevant site personnel.

On the day of the audit it was noted that the manufacturing equipment, wastes and

raw materials associated with the licensable activity had been completely

decommissioned and removed from the site.

Based on the audit observations the decommissioning process of the licensable

activity were addressed. Crown Packaging has operated their facility under the strict

guidance of their Environmental Management System and in accordance with IPC

License P0098-01. In addition the have been recommended for ISO 14001

accreditation of their EMS. Crown Packaging is committed to continually monitor and

improve on the environmental performance of the site following the surrender of their

IPC License.

Based on the finding of the exit audit, it is considered that there are no remaining

environmental liabilities associated with the Press Department remaining at the

facility. The independent exit audit report was submitted to the Agency in November

2008.

An exit audit of the facility was conducted by the EPA on the 11/03/09 (Ref P0098-01

/gc16.doc). Special attention was paid to any wastes, chemicals, equipment and any

other materials remaining on-site, the flamstore bund, two double skinned tanks, the

former press department and the current surface water monitoring point. A review of

the following documentation was conducted:

• Waste Records

• Noise Survey Report

• Flamstore Integrity Test Report

• Surface Water Visual Inspection Log

• Surface Water Monitoring (2006/207/2008)

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• Oil Separator Maintenance Records (2007/2008)

• Diesel Tank Inspection Records

• Flamstore Bund Inspection Record

• PBC Survey Report

All documentation reviewed during the audit was deemed to be satisfactory. Crown

Packaging was commended on the progress made to date (16/03/09) and for their

commitment to comply with IPPC Licence P0098-01. The inspector noted that the

facility was in a satisfactory state and is not likely to cause environmental pollution.

The surrender of the licence can proceed contingent upon the satisfactory resolution

of the observation raised in the audit report.

The Observation required the preparation of and the submission of an AER for 2008

including the following information:

• Surface Water monitoring results

• Waste emissions

• Energy and water consumptions

• Summary of environmental incidents and complaints

• Progress on 2008 objectives and targets

• Pollutant Release and Transfer Register (PRTR) reporting for 2008.

This report has been prepared and shall be submitted to the Agency.

APPENDIX 01

APPENDIX 02


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CROWN PACKAGING IRELAND LIMITED, 2008

ANNUAL ENVIRONMENTAL TRAINING PLAN Page 1 of 1

ATHY,

CO.KILDARE.

DEPARTMENT: All Departments/Environmental

IDENTIFICATION OF TRAINING NEEDS/ OBJECTIVES TRAINING PLAN IMPLEMENTATION

Name/ Training Job Title Training Objective Method of Training / Course Title Completion Completion Training Training Comments

Category Date Date Mandays Record

All employees Environmental Awareness Internal Course by External Specialist 31-Dec-08 25/07/2008 y

All employees Use of the spill kits Internal Course by External Specialist 31-Dec-08 Not

completed

Technical Dept ISO 14001 In house by External Specialist 31-Dec-08 10/07/2008 y

20/11/2008 y

New employees Induction Training In house 31-Dec-08 Ongoing Y

Technical Dept AER Electronic Reporting External 31/12/2008 23/01/2008 y

SIGNED: Dermot O'Callaghan TITLE: Technical / Environmental Mgr DATE: 23/03/2009

SIGNED: TITLE: DATE: EMF017/R02

APPENDIX 03 Environmental Management

Programme for 2008


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Table 4.1 Air Emissions Activity / Emission Target

Target Date Objective Responsibility

Comments/Progress made in 2008

Boiler Emissions

Reduction of boiler emissions Ongoing

1) Management of ongoing boiler service Site Engineer Ongoing

programme

2) Minimise emissions by reducing Site Engineer Ongoing

energy consumption

Emergency Situations

Manage and reduce impact of emissions Ongoing

Training for CROWN Packaging associates on the

Tech./Environmental Manager

Ongoing programme of induction training for

as a result of accident or emergency emergency plan new employees

Implementation of ISO 14001

Procedural control of Environmental Dec-08

Implementation of ISO 14001 system


Recommended for ISO 14001 accreditation following

Issues SGS audit of 09/03/09

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Table 4.2 Water Emissions Activity / Emission Target

Target Date Objective Responsibility

Comments/Progress made in 2008

Storm Water

To monitor storm water in accordance with Ongoing

Maintain ongoing monitoring program including

Tech./Environmental Manager Ongoing

IPC licence. monthly visual analysis








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Table 4.3 Waste Activity / Emission Target

Target Date Objective Responsibility Comments/Progress made in 2008

Shipment of Waste

Maintain waste register Ongoing

Maintain a hazardous waste register


Maintain a non-hazardous waste register


Recycling

Maximise recycling of waste materials Ongoing

1) Review current recycling practices

Tech./Environmental Manager Maintain on going programme of recycling

2) Implement any improvements identified


Waste Production

Minimise volume of waste produced Ongoing

1) Review current waste production Operations Manager

Ongoing programme to reduce scrap levels as part of the company's KPI objectives

2) Implement any improvements identified Operations Manager








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Table 4.4 Energy Activity / Emission Target

Target Date Objective Responsibility Comments/Progress made in 2008

Energy Consumption

Reduce the energy requirements at Ongoing

Maintain training and awareness programme to Site Engineer

Crown Packaging Ireland Ltd.

inform and involve the Crown Packaging Ireland

associates in an energy conservation strategy, e.g., lighting, heating etc.


Procedural control of Environmental Issues Dec-08



Recommended for ISO 14001 accreditation following SGS audit of 09/03/09

APPENDIX 04

For the Attention of: Prepared by: Mr. Dermot O’Callaghan Mr. Peter Coogan

Crown Packaging Ireland Ltd. Monitoring Team Leader

Woodstock Industrial Estate

Athy Co. Kildare Reviewed by: Ms. Natalie Duncan

Environmental Scientist

Ref: ECS3215 - January 09

BUND INTEGRITY ASSESSMENT

AT

CROWN PACKAGING

WOODSTOCK INDUSTRIAL ESTATE,

ATHY,

CO. KILDARE.

Crown Packaging Ireland Ltd ECS3215

Bord na Móna Technical Services Crown Packaging Bund Assessment January 2009

CONTENTS

1.0 Executive Summary

2.0 Scope

3.0 Survey Methodology

3.1 Monitoring Requirements

3.2 Assessment Techniques

3.3 Determination of fill level.

3.4 Reporting

3.5 Rain Gauge

4.0 Discussion

Appendix 1. Determination of required fill level Daily Log and Photographic Evidence

Appendix 2. Graph of Rainfall



1.0 Executive Summary

Bord na Móna was commissioned by Crown Packaging Ireland Ltd to carry out Bund testing

at their facility in Athy, Co. Kildare. The survey was performed between 19/01/09 and

26/01/09. The bunded areas included in this study were referenced as follows:

1. Oil/Chemical Storage Bund

The above bunded area were tested for liquid tightness for seven days in accordance with B.S.

8007:1987 sections 9 (24 Hr Stabilisation period) and was found to be in compliance with the

test.

Signed:_____________________ _____________________ Peter Coogan Natalie Duncan

Monitoring Team Leader Environmental Scientist



2.0 Scope

Bord na Móna Technical Services was contracted by Crown Packaging Ireland Ltd to carry

out Bund testing at their facility in Athy, Co. Kildare. The scope of the survey is limited to the

following:

a. Identification and Inspection of the bunded area.

b. Test the bunded area for ‘liquid tightness’ as specified in section nine of B.S. 8007: 1987

as required for seven days.

c. Reporting and interpretation of the assessment results.

3.0 Survey Methodology

3.1 Monitoring requirements

As part of the ongoing assessment of the bunded areas on site as required by

IPPC licence No. P0098-01, Condition 8.3.2, this test was performed to

determine the integrity of the bund. The bund tested was referenced as

follows:

Bund I.D.

1 . Oil / Chemical Storage Bund

3.2 Assessment Techniques

The bunded area was allowed to fill with rain water to the fill level, marked and allowed to

stabilise for 24 hours on the 19th of January 2009. After stabilisation, the level of the liquid

surface was recorded by means of a photograph at 24-hour intervals for the test period of

seven days.

3.3 Determination of required fill level.

The required retention volume for each bund was determined prior to commencing filling.

Details of the bund are available in appendix 1.

3.4 Reporting

Daily photographic evidence for the bunded area is reported in Appendix 1.



3.5 Rain Gauge

An ISCO 675 rain gauge was installed within the bund area. The ISCO 675

logging rain gauge uses a tipping bucket design for accurate rainfall

measurement. The rain gauge has a built-in logger which records date, time

and rainfall data. Rain Gauge graphs and photographs are shown in Appendix 2

4.0 Discussion

The criteria used for testing of bunds, tanks and sumps are as follows:

1. A bund containing one vessel should have a nominal capacity of 110 % of the vessel’s

maximum capacity.

2. A bund containing more than one vessel should have a nominal capacity of 110% of the

largest vessel or 25% of the total capacity of all the vessels, which ever is the greater.

3. Sumps, built with double skins (i.e. an inner and outer layer) should have no water in

between the two layers.

The bunded areas, as detailed in previous sections, were allowed stabilise for 24 hours and

tested. During this 7-day test period the total permissible dip in level (allowing for

evaporation) should not exceed 1/500th of the average water depth of the full bund in all

cases.



APPENDIX 1



BUND TESTING REPORT CLIENT: Crown Packaging Ireland Ltd BUND LOCATION: Bund 1 – Oil/Chemical Storage Bund SURVEY DATES: 19/01/09 -26/01/09 PERSONNEL: Peter Coogan - Bord na Móna

DAILY LOG

DATE WATER LEVEL

EVAPORATION /24hr

PHOTO I.D. PERSONNEL

19/01/09 Fill/ Stabilisation 440 mm +/- 1mm No PC 20/01/09 Stabilisation/Test 460 mm +/- 1mm Yes PC 21/01/09 Test 465 mm +/- 1mm Yes PC 22/01/09 Test 482 mm +/- 1mm No DC 23/01/09 Test 505 mm +/- 1mm Yes DC 24/01/09 Test 520 mm +/- 1mm No DC 25/01/09 Test 543 mm +/- 1mm No DC 26/01/09 Test 590 mm +/- 1mm Yes PC

Total Area of Bund - 18.6 x 12m Water Catchment Area – 2 x 11.5m

DATE Rainfall (mm) Calculated Increase in Catchment Area Based on

Rainfall (mm/day) 19/01/09 1.9 18.4 20/01/09 0.6 5.82 21/01/09 1.8 17.46 22/01/09 2.3 22.31 23/01/09 1.6 15.52 24/01/09 2.5 24.25 25/01/09 4.1 39.77 26/01/09 0.3 2.91

I. COMMENTS

This bund (Bund 1) was tested for Seven days in accordance to B.S. 8007: 1987

(Design of concrete structures for the retaining aqueous liquids: Section Nine -

inspection and testing of the structure).

Conformance to B.S. 8007: 1987 Section 9 (24 Hr Stabilising Period) Compliant

Photo ID: Bund 1 - Day 1 (20/01/09)

Photo ID: Bund 1 - Day 2 (21/01/2009)



Photo ID: Bund 1 - Day 4 (23/01/2009)

Photo ID: Bund 1 - Day 7 (26/01/2009)



Bund Area

Collection Tank in Bunded (Catchment Area)



APPENDIX 2



Graph Representing Rain Fall



ISCO 675 Rain Gauge

APPENDIX 05


Page 33

Crown Packaging Ireland Ltd Work Instructions Manual

Procedure Number Re

vision

Page

EWI 6.0 0 1 of 1 Procedure Pump out of flam store bund / fire water retention facility Purpose To ensure that the pumping out of the flame store bund does not cause

pollution of the storm water drains Responsibility Technical Department References EWIF 6.1 Flamestore bund fire Water Retention facility pump out

1. The above bund will be pumped out as required.

2. The Technical Manager or person designated by the Technical Manager shall carry out the pumping out of the flame store bund.

3. The water in the bund will be initially inspected for signs of chemical contamination.

4. If no signs of contamination are evident the bund water may be pumped into the storm water drain

having first recorded.

5. The depth of water in the bund shall be documented prior to pumping.

6. The results are recorded on the Flam Store Bund/Fire Water Retention Facility Pump Out Sheet EWIF 6.1.

7. These results are submitted annually to the EPA as part of the Annual Environmental Report.

8. A controlled hard copy of this record sheet is stored in the Technical / Environmental Managers Office.

9. If there are any signs of chemical contamination of the water, the Environmental Management Team

will initiate an investigation as per non-conformance, corrective &preventive action procedure EP 8.0.

Documents

Annual Environmental Report of CROWN Packaging Ireland ...CROWN Packaging Ireland Ltd – Annual Environmental Report 2008 Page 2 CONTENTS Page No. Section 1: Overview 1.1 Introduction