Attachment K Residuals Management Plan Consent of ... · 15th December 2014 For inspection ... We disclaim any responsibility to the client and others in respect of any matters outside

Attachment K

Residuals Management Plan

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Decommissioning Management Plan

for Merck Millipore Limited

Final

15th December 2014

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Document Control

Status Draft Final Draft FinalDate 12/6/2014 15/8/2014 15/12/2014Version # 1 2 4

Approved

This report has been prepared by Environet Consulting Ireland Ltd, with all appropriate care and diligence withinthe terms of the Contract with the client. This Contract incorporates our Terms and Conditions and takes accountof the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of works.

This report is confidential to the client and we accept no responsibility to third parties to whom this report, or anypart thereof, is made known. Such parties rely on the report at their own risk.

Dungarvan Business CentreFairlaneShandonDungarvanCo. WaterfordIrelandTel: 058-51155Fax: 058-51231Email: [email protected]

www.environet.ie

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TABLE OF CONTENTS

1 EXECUTIVE SUMMARY..........................................................................5

1.1 Activity Details .............................................................................................................5

1.2 Report Preparation ......................................................................................................5

1.3 Comparison with Previous Plans...............................................................................5

1.4 Overview of the Plan ...................................................................................................6

1.5 Scoping.........................................................................................................................6

1.6 Cost Summary .............................................................................................................6

1.7 Financial Provision......................................................................................................6

1.8 Review ..........................................................................................................................6

2 INTRODUCTION ......................................................................................7

2.1 Site Description ...........................................................................................................7

2.2 Site History...................................................................................................................7

2.3 Classes of Activity Licensed ......................................................................................8

2.4 Licence Requirements ................................................................................................8

3 SITE EVALUATION .................................................................................9

3.1 Operator Performance ................................................................................................9

3.2 Environmental Pathways and Sensitivity .............................................................. 10

3.3 Processes.................................................................................................................. 103.3.1 Biotools Department (Clean Rooms 1, 2 and 3) .................................................... 103.3.2 Membrane Manufacture ......................................................................................... 113.3.3 Chromatography Media Manufacture [Controlled Pore Glass (CPG)]................... 143.3.4 Emissions from CPG Processes ............................................................................ 143.3.5 Wastewater Treatment Plant.................................................................................. 14

3.4 Inventory of Main Buildings & Infrastructure ........................................................ 15

3.5 Inventory of Annual Waste Arisings....................................................................... 18

4 CLOSURE TASKS AND PROGRAMMES.............................................21

5 CRITERIA FOR SUCCESSFUL CLOSURE...........................................22

6 CLOSURE PLAN VALIDATION............................................................. 23

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7 CLOSURE PLAN COSTING ..................................................................24

8 CLOSURE PLAN UPDATE AND REVIEW............................................27

9 RESTORATION/AFTERCARE MANAGEMENT PLAN......................... 28

10 FINANCIAL PROVISION ....................................................................29

Appendix A – Financial ProvisionAppendix B – Site LocationAppendix C – Site Layout PlanAppendix D – Groundwater Monitoring Report - ERM

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1 Executive Summary

1.1 Activity Details

Name: Merck Millipore LimitedAddress: Tullagreen, Carrigtwohill, Co. CorkIE Licence Number: P0571-03Activities Licensed: 12.2.1 The surface treatment of substances,

objects or products using organic solvents, inparticular for dressing, printing, coating,degreasing, waterproofing, sizing, painting,cleaning or impregnating, with a consumptioncapacity of more than 150 kg per hour or morethan 200 tonnes per year.

11.2 (e) Disposal or recovery of hazardous wastewith a capacity exceeding 10 tonnes per dayinvolving solvent reclamation or regeneration

RBME Category: A2

1.2 Report Preparation

This report was prepared on behalf of the operator by Environet Solutions.

Environet SolutionsDungarvan Business CentreDungarvanCo. Waterford

1.3 Comparison with Previous Plans

This will be the third Decommissioning Management Plan (DMP) for the site.

Year Cost Financial Instrument Expiry of FinancialInstrument

2010 €900,000 Parent CompanyGuarantee

No time limit

2011 €900,000 Parent CompanyGuarantee

No time limit

2014 €1,400,000 Parent CompanyGuarantee

No time limit

Table 1: Decommissioning Management Plan History

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1.4 Overview of the Plan

This DMP was prepared in accordance with the EPA document ‘Guidance onAssessing and Costing Environmental Liabilities’, 2014. Mr. Gerard Kelly ofEnvironet visited the site on 9th April 2014. A site tour was undertaken in thecompany of Mr. Ross Daly, EHS Engineer.

1.5 Scoping

Based on all available documentation it has been determined that the site hasno potential long term environmental liabilities (see recent GroundwaterMonitoring Report from consultants ERM in Appendix D). Therefore a cleanclosure is envisioned for the site and neither restoration nor aftercaremanagement are expected to be required post closure.

1.6 Cost Summary

The total cost associated with the closure, restoration and aftercaremanagement of the facility has been estimated to be €1,400,000.

1.7 Financial Provision

Merck Millipore has provided a letter of guarantee to cover the liabilitiesidentified in this report. This letter is included in Appendix A.

Table 2 below details the financial instrument to be put in place.

Type Description Source/Methodof

Quantification

Amount ofProvision

FinancialInstrument

Knownliabilitiesassociatedwith theclosure of thesite

As detailedin this DMP

As detailed inTable 8 of thisreport

€1.4 M Merck MilliporeLimited CompanyGuarantee.

Table 2: Financial Instrument

1.8 Review

This closure and restoration/aftercare plan will be reviewed annually and anyupdates will be notified to the EPA.

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2 Introduction

2.1 Site Description

The site is situated approximately 1 km west of the centre of Carrigtwohill, Co.Cork, a town with a population of approximately 6,000. The site has an area ofapproximately 38 hectares.

The facility employs 600 colleagues. Many of the main processes operate ona 24 hour shift basis, 7 days per week.

A Site Location Map is included in Appendix B and a Site Layout Map isincluded in Appendix C.

2.2 Site History

Table 3 gives an overview of many of the main activities and events at the sitesince 1972.

Date History1987 Development of Greenfield site.

1988 Filter Cutting and Millex start-up (production buildingOP1-Biotools)

1990 Steritest start-up (Biotools)

1990 Construction of Casting Plant (IC1 DuraporeProcess)

1999 Hi-Flow membrane manufacturing plant start-up(production building Aircast) plus additionalanalytical devices clean rooms.

2002 IPPC licence P0571-02 obtained

2007 Installation of New Analytical Clean Room,expansion of Aircast (MW2 process) and thermaloxidisers start up

2008 Further expansion of Aircast with J1 Process andIC2 expansion plus tech transfer of Controlled PoreGlass Manufacturing Process.

2009 Application for review of IPPC licence P0571-02

2010 IPPC licence P0571-03 obtained2012 Process Drain Upgrade Completed

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Date History2013 Major Upgrade to Wastewater Treatment Plant

Completed

Table 3: Site Operational History

2.3 Classes of Activity Licensed

Merck Millipore has an IE licence (P0571-03) issued by the EPA on 9th March2010 for the following activities;

12.2.1 The surface treatment of substances, objects or products usingorganic solvents, in particular for dressing, printing, coating,degreasing, waterproofing, sizing, painting, cleaning or impregnating,with a consumption capacity of more than 150 kg per hour or more than200 tonnes per year.

11.2 (e) Disposal or recovery of hazardous waste with a capacityexceeding 10 tonnes per day involving solvent reclamation orregeneration.

2.4 Licence Requirements

The preparation of the Decommissioning Management Plan (DMP) is arequirement under the IE licence;

‘10.1 Following termination, or planned cessation for a period greaterthan six months, of use or involvement of all or part of the site in thelicensed activity, the licensee shall, to the satisfaction of the Agency,decommission, render safe or remove for disposal/recovery, any soil,subsoils, buildings, plant or equipment, or any waste, materials orsubstances or other matter contained therein or thereon, that mayresult in environmental pollution.

10.2 Decommissioning Management Plan (DMP)

10.2.1 The licensee shall prepare, to the satisfaction of theAgency, a fully detailed and costed plan for thedecommissioning or closure of the site or part thereof.

10.2.2 The plan shall be reviewed annually and proposedamendments thereto notified to the Agency for agreement aspart of the AER. No amendments may be implemented withoutthe agreement of the Agency.

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10.2.3 The licensee shall have regard to the EnvironmentalProtection Agency Guidance on Environmental Liability RiskAssessment, Decommissioning Management Plans andFinancial Provision when implementing Condition 10.2.1 above.

10.3 The Decommissioning Management Plan shall include as aminimum, the following:-

(i) a scope statement for the plan;(ii) the criteria which define the successful decommissioning ofthe activity or part thereof, which ensures minimum impact onthe environment;(iii) a programme to achieve the stated criteria;(iv) where relevant, a test programme to demonstrate thesuccessful implementation of the decommissioning plan;(v) details of the costings for the plan and the financialprovisions to underwrite those costs.

10.4 A final validation report to include a certificate of completion forthe Decommissioning Management Plan, for all or part of the site asnecessary, shall be submitted to the Agency within three months ofexecution of the plan. The licensee shall carry out such tests,investigations or submit certification, as requested by the Agency, toconfirm that there is no continuing risk to the environment.’

3 Site Evaluation

3.1 Operator Performance

Environet has reviewed the site’s compliance with its IE licence in 2013. Therewas one non-compliance due to an exceedances of the Total VOC limit atemission point A1-8 due to a cold spot in the oxidation bed.

The most recent audit carried out by the EPA was on 20th February 2014resulting in a number of observations but no non-compliances.

The site received three complaints during 2013 relating to muddy waters dueto construction activity, a chemical mist descending on a car and somecomplaints that were not related to site activities. All complaints were closedout and were proved to be unrelated to site activities.

In general Environet Solutions found the site to be very well managed andhighly compliant with the requirements of its IE licence.

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3.2 Environmental Pathways and Sensitivity

The bedrock geology in the area consists of Wallsortian Mudbank, and palegrey massive limestone. Groundwater vulnerability is classified as High (on ascale of Low, Moderate, High, Extreme) and the aquifer is RegionallyImportant with fissured bedrock. In general groundwater flows from north tosouth beneath the site, but is considered a perched water table in parts of site.

The site discharges treated process effluent to County Council Sewer.Surface waters are continuously monitored and discharged to the Slatty RiverEstuary which in turn feeds into the Great Island Channel, part of CorkHarbour.

The nearest area of ecological importance is the Great Island Channel justsouth of the site, to which uncontaminated surface water is discharged. This isclassified as a Special Area of Conservation (SAC), a Special Protection Area(SPA) and a proposed Natural Heritage Area (pNHA).

3.3 Processes

The main processes currently undertaken on the Millipore site fall into threecategories:

Assembly of Analytical Devices i.e. Biotools Department Membrane Manufacture (IC1, Aircast, IC2,) Controlled Pore Glass (CPG) manufacture

3.3.1 Biotools Department (Clean Rooms 1, 2 and 3)

In this 6,100 m2 building plastic parts are injection moulded and assembled asdevices in a number of assembly areas with various types of Milliporemembranes to produce a range of medical and pharmaceutical filtrationdevices.

Departments within the assembly plant building include:

Millex 25 Moulding Millex 33 Stericup Centrifugal/ Amicon Millicell Multiscreen Filter cutting Warehouse and shipping

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3.3.2 Membrane ManufactureMembrane manufacturing operations typically run 24 hours a day – 7 days aweek. It currently comprises of three main manufacturing area plus anadditional area (SMF) which will come online in 2016. Within each area arespecialised membrane manufacturing machines as outlined hereunder:

3.3.2.1 IC1 Process (VMF1 and VMF4 Machines)In 1989, a separate facility (IC1) of 2,000 m2 was constructed to house themembrane manufacturing facility. Durapore membranes are thin plasticmembranes used in a variety of medical, pharmaceutical and beveragefiltration processes. Membrane manufacturing consists of mixing a specialistsoluble resin with solvent to form a casting lacquer which prepared in batch inthe area mixroom.

After mixing, the lacquer is cast onto a plastic film which carries the lacquerthrough a solvent bath where the membrane forms. The membrane is thenseparated from the carrier and rinsed in a series of water rinses, dried, andwound into rolls. This process is called Immersion Casting where twomachines are utilised VMF1 and VMF4.

Wastewater is extracted to sites dedicated WWTP. Process vapours fromeach machine are extracted to the thermal oxidiser system.

To improve the properties of the membrane it is then heat treated in theAnnealing Area, to improve the membranes hydraulic-properties.

3.3.2.2 IC2 Process (Casting and Modification Machines)The IC2 process is designed with the capability to manufacture a range ofboth Durapore (same as IC1) with the addition of Polyethylene SulphideMembrane.

The main process elements of the IC2 process are:

Mix Room - Membrane lacquer is produced within the mix room. Solvents arefed into mix vessels from the tank farm. Various soluble polymers are addedto solvents in the vessels to make the lacquer. The lacquer is then fed toeither the Casting machine.

Casting Machine - The casted lacquer is fed through a formation bathfollowed by a series of extraction tanks and finally through a drumdryer. The membrane is wound onto rollers at the end of the castingmachine. To improve the properties of the membrane it is then heattreated in the annealing area.

Modification Machine - From the annealing area, the membrane isunrolled onto the Modification machine where it is wetted with solvent,washed with ROUF water and then coated with polymer. The monomer

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is then extracted from the membrane through hot and cold waterextraction tanks.

3.3.2.3 Emissions from IC1 and IC2Waste concentrated solvents from IC1 and IC2 processes are recovered forre-use in the two onsite solvent recovery units.

Dilute wastewater streams from each of the manufacturing machines aretreated in the onsite wastewater treatment plant. Final effluent is discharged tothe Carrigtwohill Sewage Treatment works in accordance with therequirements of the IE Licence Reg. No. P0571-03

Solvent process vapours are diverted to the onsite thermal oxidisers (TO1,TO2 and TO3) for destruction. Emissions from the thermal oxidisers meetemission limits as required under the IE licence.

Non-hazardous wastes from the process are segregated for recycling wherepossible and all waste is disposed of / recycled through authorised wastecontractors only. Hazardous waste is segregated and incinerated via licensedfacilities. A full waste management record is maintained on site in accordancewith IE license requirements.

3.3.2.4 AircastAircast consists of four main processing machines.

1. Aircast - K Machine

Hi-Flow membranes offer a basic substrate to which a client’s chemistry canbe applied to generate a wide variety of diagnostic assays which are now acommon feature of modern clinical and product quality assessments. Hi-flowmembranes are manufactured using cellulose resin. The resin is mixed with asolvent blend to form a lacquer solution. The mixture is blended and then castonto a continuous stainless belt.

The support belt carries the casting solution through a series of formation anddrying chambers. Within the chambers solvent evaporates under controlledconditions allowing the cellulose to form a membrane layer.

Once formed it is removed from the stainless belt and passed through a rinsetank. It is then dried, slitted and wound into rolls.

2. Aircast - J1 Machine

J1 membranes are also manufactured using cellulose resin. The resin ismixed with a solvent blend to form a lacquer solution. The lacquer is pumpedfrom the mix room on to the J1 casting machine.

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The belt conveys the lacquer through formation and drying processingsections where the lacquer is converted to a formed micro porous membrane.The membrane is then removed off the belt at controlled tension through anextraction tank where it is washed with a purified water / detergent mix.The membrane is passed onto a drum-dryer where it is dried by heated airimpingement. The film is then inspected prior to passing through aslitter/winder machine where it is edge trimmed and cut into strips and woundinto rolls.

3. Aircast - J2 Process

The J2 Process very much replicates the J1 Process but on smallerproduction scale.

4. Aircast - Microweb2 Process

Microweb 2 (MW2) membranes are manufactured using high-grade celluloseresin. The resin is mixed with a solvent blend to form a casting solution.

MW2 is a vertical air casting process. The lacquer is pumped from the mixroom to the MW2 machine. A lacquer impregnated web then travels throughan air chamber where the lacquer is converted to a formed membrane via aconditioned air flows system. The membrane web is then pulled at controlledtension through a multiple zone extraction tank where it is sprayed withpurified water.

The wetted membrane is carried onto a steam heated dryer where it is dried.The dried membrane web is then pulled over an inspection box into aslitter/winder machine where its edge is trimmed and slitted accordingly tocustomer specifications.

3.3.2.5 Emissions from AircastProcess exhausts from the operations are treated in the thermal oxidisers onsite, where K Machine is mainly connected to A1-7 and all other processmachines connected to A1-8 (though diversion can be made is necessary ifoperational issues occur).

Process wastewater from the Aircast operation is treated by the wastewatertreatment plant where Aircast accounts for a large proportion of the siteseffluent chemical loading.

Non-hazardous wastes from the process are segregated for recycling wherepossible and all waste is disposed/ recycled through authorised wastecontractors only. Hazardous waste is segregated and incinerated via licensedfacilities. A full waste management record is maintained on site in accordancewith IE license requirements.

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3.3.3 Chromatography Media Manufacture [Controlled Pore Glass(CPG)]

Initially glass discs are fired and quenched in a furnace oven. Thereafter theglass discs are ground-down through a rough and finished grinding processand separated into a desired grain size. [Process dust is collected by adedicated dust torit A2-30]. The powdered glass is then transferred into aleach tank where it is washed with acid and neutralised with caustic solution toachieve the necessary pore size. [Process vapours are extracted to a wetscrubber system). The Controlled Pore Glass is then rinsed with purifiedwater and transferred to ProSep manufacturing. Wastewater is neutralisedand discharged to site’s WWTP. Finished products are then shipped to MerckMillipore’s sister site in UK for further processing.

3.3.4 Emissions from CPG ProcessesCPG process does not generate any significant air emissions as there are noorganic solvents used in this process. The two furnaces are fitted with localexhaust ventilation to remove excess heat only from the area - no adverseenvironmental emissions. Any dust generated in the grinding processes arecaptured as near to the source as practicable and the air is cleaned using dustcollectors (A2-30) prior to discharge to atmosphere. Acid fumes are generatedas part of the acid treatment of the glass beads. These are scrubbed in adedicated caustic scrubber.

3.3.5 Wastewater Treatment Plant

Merck Millipore’s wastewater is ultimately derived from process effluent fromsite membrane manufacturing processes (IC1, Aircast and IC2 with someminor volumes from Chromography Media manufacturing. The WWTPunderwent a major infrastructural upgrade and process improvement in 2013.

At present process effluent is discharged to the WWTP to one of three 200m3

Catch Tanks (new) where it is monitored for solvent content and presence ofchlorinated sanitate. Anti-chlorination agents are added accordingly toneutralise chloro-elements, where then the three Catch Tanks are forward fedto the Balance Tank, which combines the contents of the three tanks into auniform consistency. After a period 6-7 days the effluent is then forward fed toone of two Aeration Tanks where activated sludge consisting ofmicroorganisms will consume the effluent .To assist the process pH correctiontakes place as well as the introduction of nitrogen/phosphorous rich nutrients.

The Aeration Tanks are constantly monitored by a series of inline probes todetermine oxygen content and process efficiently. After 12 days the treatedeffluent is forward fed to a new Dissolved Air Floatation process where thebiomass and solids are removed. The treated effluent will discharge via SE1(final emission point) and the biomass is sent to a sludge dewatering plant

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where the water is removed and sludge thickened for disposal (offsite –approved licensed treatment facility, currently Eras Eco ,Youghal, Co. Cork)whilst the water is returned to the WW process . SE1 discharges toCarrigtwohill treatment works operated by the Local Authority.

As part of the upgrade the entire WWTP is contained on hard standingground. The new Catch Tanks are fully bunded. All pipework operatesoverground. All systems are automated with state of the art controls. Alaboratory was constructed for day-to-day testing. Revamp dewatering plantwas installed. All tanks are extracted to an odour control unit where WWvapours are treated by a biobed of seashell which render the vapours inert.

The Merck Millipore wastewater treatment plant operates 24hrs/7days withdaily operator cover and out of hours back-up and emergency call out asrequired.

3.4 Inventory of Main Buildings & Infrastructure

The table below lists the main building located at the facility. During the siteaudit there was no evidence of asbestos containing materials being present inroofing materials or pipe lagging. Site management confirmed that to theirknowledge asbestos containing materials are not present at the site.

Building Construction Activity

Security Office Prefabricated on a concrete floor. Site Security

LaboratoriesSteel frame, externally steel

cladding, internal block walls, steelroof

R&D and QC Laboratories

Offices and CanteenSteel frame, externally steel


Canteen andadministration

Boiler House (2 No. & SiteUtilities)

Steel frame, externally steelcladding, internal block walls, steel

roof

Steam production,power/heat generation

Main Production BuildingsSteel frame, externally steel


Production

Main Warehousing (withinmain building)

Steel frame, externally steelcladding, internal block walls, steel

roof

Minimal warehousing on-site.

Firewater Pump HouseSteel frame, externally steel


Diesel Firewater Pumps

Flammable Materials StoreSteel frame, externally steel


Storage of nitrocellulose

Roll Store and Hydro Room Concrete floor, concrete walls andflat roof. Storage

WWTP laboratory Concrete floor, concrete walls andflat roof. WW analysis

WWTP Sludge DewateringBuilding

Concrete floor, cladded walls androof

Sludge thickeningtechnology

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Building Construction Activity

IC1 Tank Farm MCC Room Concrete floor, concrete walls andflat roof.

Tank Farm Systemcontrols

IC2 Tank Farm MMC Room Concrete floor, concrete walls andflat roof.

Tank Farm Systemcontrols

T7 Transformer MMCRoom

Concrete floor, concrete walls andflat roof.

Transformer Systemcontrols

IC1 Foam Deluge House Concrete floor, cladded walls androof

Fire suppressant foamtank.

Temporary Portocabins x10 Timber frame structures Consultants design teams.

Office overflow.

Table 4: Inventory of Main Buildings

Merck Millipore keeps an inventory of all tanks and bunds on site. Alllaboratory chemicals are stored within designated self-contained flame proofcabinets with the laboratories and are not included in the bund inventory.

# Containment Structure Type Construction MaterialContained

Capacity(m3)

CS001 VMF1 Sump Sump prefabricated

Acetone,MeOH,DMAC 2

CS002 VMF4 Sump Sump prefabricated HPA 2

CS003 VMF 4 Sump Pump Bund Sump prefabricated

Solventwaste /machinewashings 2

CS004 VMF 1 Sump Pump Bund Sump prefabricated

Stormwater/ FirewaterRetention 2

CS005 IC1 Mixroom Sump SumpReinfrorcedconcrete and SS

Mixroomcleaningsolutions 0.143

CS006 Aircast Tank Farm Bund BundReinforcedConcrete

Solventtanks -rainwater 131

CS007 Durapore Tank Farm Bund BundReinforcedconcrete and SS


CS008 IC1 DrumstoreSump/Retention

ReinforcedConcrete

Wastedrums,IBC's, oiletc. 23.1

CS009 IC1 Tanker Loading Bay Loading BayReinforcedConcrete

Tankers ofSolvent -rainwater 32

CS010 Aircast mixroom Pit Sump SumpReinforcedConcrete

Processwaste 0.680

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Capacity(m3)

CS011 Microweb 2 Sump and Tank Sump prefabricatedProcesswaste 2.47

CS012 J1 Sump Sump prefabricatedProcesswaste 3.24

CS013 IC2 Tank Farm Bund BundReinforcedConcrete


CS014 IC2 Loading Bay Loading BayReinforcedConcrete

Tankers ofSolvent -rainwater 31.7

CS015 IC2 DrumstoreSump/Retention

ReinforcedConcrete

Wastedrums,IBC's, oiletc. 10.44

CS016 IC2 Waste Tank Bund BundReinforcedConcrete

Processwaste 151

CS017 IC2 SRU Bund BundReinforcedConcrete

Recoveredsolvent 23

CS018 Cooling Tower Bund - chem store BundHDPE (chemresistant plastic)

Coolingtowerwater 1.35

CS019 Firepond 1RetentionLagoon

Impermeablemembrane overprecast concrete


CS020 Firepond 2RetentionLagoon

Impermeablemembrane overprecast concrete


CS021 T6 Transformer Bundreinforcedconcrete oils 2.8

CS022 T3 Transformer Bundreinforcedconcrete oils 2.4

CS023 Op2 Chiller Bunds Bundreinforcedconcrete Refrigerant 2.0

CS024 Diesel Tank Bund Bundreinforcedconcrete Diesel 1.48

CS025 IC2 Chiller Bund Bundreinforcedconcrete coolants 20

CS026 MW2 Chiller Bund Bundreinforcedconcrete coolants 1.75

CS027 CPG Bund (acid/caustic) Bundreinforcedconcrete

Acids/caustics 35

CS028 CPG Bund Leach Area Bundreinforcedconcrete

Acids/caustics 2300

CS029 IC1 Foam Tank Bund Bundreinforcedconcrete AFFF

CS030 IC1 SRU Bund Bundreinforcedconcrete Solvents

CS032 Interceptor 1 Sump prefabricatedStormwater / oil

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Capacity(m3)

CS033 Interceptor 2 Sump prefabricatedStormwater / oil

CS034 SE2 Sump Sumpreinforcedconcrete

ROUFReject 2

CS035 CHP Condensate Sump Sumpreinforcedconcrete

Boilercondensate

CS036 T4 Transformer Bundreinforcedconcrete Oils 0.85

CS037 T7 Transformer Bundreinforcedconcrete Oils 0.895

Table 5: Inventory of Containment Structures

Site management confirmed that all bunds are tested in accordance with theconditions of the company’s IE licence and are certified by externalcontractors to the current EPA recommendations.

Table 6 below is an estimate of annual raw material usage. In order to arriveat an estimated cost of waste removals it is estimated that approximately 1%of annual usage will need to be removed as part of the DMP process.

Substance Hazardous(Y/N)

AnnualConsumption

1% requiringdisposal

Liquids, gases and solids Y 17,800 t 178 tLiquids, gases and solids N 2,400 t 24 tTOTAL 20,200 t 202 t

Table 6: Inventory of Raw Materials

3.5 Inventory of Annual Waste Arisings

Table 7 below contains a list of all waste materials generated at the site in2013. For the purposes of the DMP we assume that 20% of this material willrequire disposal in a closure scenario.

Waste EWD Code Hazardous(Y/N)

WasteContractor

Quantityproducedt/annum

packaging containingresidues of or contaminatedby dangeroussubstances

15 01 10 Y Veolia 0.521

other organic solvents,washing liquids and motherliquors

07 01 04 Y Veolia 2202.7

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Waste EWD Code Hazardous(Y/N)

WasteContractor

Quantityproducedt/annum

absorbents, filter materials(including oil filters nototherwise specified),wiping cloths, protectiveclothing contaminated bydangerous substances

15 02 02 Y Veolia 195.9

other bases 06 02 05 Y Veolia 7.7

solid wastes containingdangerous substances

07 05 13 Y Veolia 8.4

paint, inks, adhesives andresins containing dangeroussubstances

20 01 27 Y Veolia 0.4

fluorescent tubes and othermercury-containing waste

20 01 21 Y Veolia 0.39

discarded inorganicchemicals consisting of orcontaining dangeroussubstances

16 05 07 Y Veolia 0.42

discarded organic chemicalsconsisting of or containingdangeroussubstances

16 05 08 Y Veolia 4.14

acids 20 01 14 Y Veolia 2.51gases in pressure containers(including halons) containingdangeroussubstances

16 05 04 Y Veolia 0.006

discarded equipmentcontaining hazardouscomponents

16 02 13 Y Veolia 1.65

sludges from on-site effluenttreatment other than thosementioned in 0702 11

07 02 12 N Eras Eco 639.6

wastes containing mercury 06 04 04 Y Veolia 0.027

other hydraulic oils 13 02 08 Y Veolia 4.212

wastes whose collection anddisposal is subject to specialrequirements inorder to prevent infection

18 01 03 Y Veolia 2.29

bulky waste 20 03 07 N Greenstar 275.9

mixed municipal waste 20 03 01 N Greenstar 18.5biodegradable kitchen andcanteen waste

20 01 08 N Greenstar12.82

plastic packaging 15 01 02 N Greenstar57.9

paper and cardboardpackaging

15 01 01 N Greenstar144.8

paper and cardboard 20 01 01 N Greenstar160.5

plastics 20 01 39 N Greenstar 215wooden packaging 15 01 03 N Greenstar

58.9metals 20 01 40 N Greenstar 40.27glass packaging 15 01 07 N Greenstar

1.62

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Table 7: Annual Waste Arisings

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4 Closure Tasks and Programmes

This section focuses on the closure aspects for the activity. The closure planincludes the decommissioning and decontamination of all of the structuresand the management and safe removal of any residuals arising as a result ofdecommissioning.

The purpose of the closure process is to ensure that the site no longer posesa risk of environment pollution and is considered to be environmentally inert.

It is not envisaged that any of the plant and/or equipment will have to bedemolished. These elements, once decommissioned and decontaminated, willbe tested to ensure there is no risk of environmental pollution remaining. Thefollowing steps will be carried out in sequential order to achieve closure of theproduction area of the site:

Decontamination and decommissioning of production buildings usingstandard clean in place (CIP) procedures. All wash waters dischargedto WWTP for treatment. All residual waste and materials removed towaste storage areas.

Emptying of warehouses and decontamination of warehouse buildings.Material returned to supplier, where possible, or labelled anddispatched to waste storage areas.

Emptying, decontamination and decommissioning of tanks. Noresiduals to remain in tanks or pipelines. Residuals to be treated on-site or recovered/disposed off-site at appropriate facilities. Shutdown,decontaminate and decommission boilers. Residual fuels to beremoved from tanks and pipelines.

Removal of all residual waste to waste storage areas. Clear and clean all office and administration areas. WEEE to be

removed by suitably permitted operator. All other wastes to bedispatched to waste storage areas.

It is expected that the above operations will take approximately 26weeks. Tasks and timings are detailed in Section 7 of this report.

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5 Criteria for Successful Closure

The following criteria have been established to set the benchmark for thesuccessful closure of the site:

All plant will be safely decontaminated using standard procedures andtrained personnel.

All waste will be handled, packaged, temporarily stored, recoveredand/or disposed of in a manner which complies with regulatoryrequirements and best practice.

All relevant records relating to movement, transfer or disposal of wastewill be managed and retained throughout the closure process and willbe available for review by the EPA.

No soil within the site boundary will be contaminated to a level thatposes a risk to human health or neighbouring properties.

Access to monitoring locations will be maintained at all times during theclosure process.

The site will remain in compliance with its IPC licence during theclosure process and until the date of licence surrender.

That any remaining issues are closed out in a timely manner followingthe EPA site closure audit

That the site is left in an environmentally inert state; That sufficient funds are available to cover the full cost of closure.

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6 Closure Plan Validation

Once the closure plan has been implemented the licensee will arrange for anIndependent Closure Audit (ICA) to be carried out by an independent thirdparty consultant. The qualification and experience of the independent auditorwill be provided and agreed with the EPA prior to the ICA commencing. Thescope of the audit will be agreed in advance with the EPA and, followingapproval, the chosen independent auditor will complete the validation audit.The completed Validation Audit report will be submitted to the EPA forapproval.

The EPA may then elect to carry out a final closure audit to verify compliance.

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7 Closure Plan Costing

Closure plan costing is presented in Table 5 below:

Task Description Quantity Unit1 Unit Rate(€)

Cost (€) Source

Decommissioning & Removal from Service ofBuildings/Areas

IC1 Area 10 day 1,800 18,000 MMAircast Area 10 day 1,800 18,000 MMIC2 Area 10 day 1,800 18,000 MMCPG Area 10 day 1,800 18,000 MMAssembly Area 5 day 1,800 9,000 MMSolvent Recovery 5 day 1,800 9,000 MMInjection Moulding 5 day 1,800 9,000 MMAir Abatement Equipment 10 day 1,800 18,000 MMBoiler House 5 day 1,800 9,000 MMSite Drainage Cleaning 10 day 3,500 35,000 MMWastewater Treatment PlantDecommissioning and Cleaning

15 day 1,800 27,000 MM

Decommissioning & Removal from Service ofStorage Tanks

54 Solvent Tanks 15 day 1,800 27,000 Master EngMisc. Chemical & Storage Tanks 5 day 1,800 9,000 Master Eng

Hazardous & Non-Hazardous Waste Removal Sludge from Wastewater Treatment Plant2,440 m3 of activated sludge at MLSS of8,000 mg/l = 20 t dry solids to remove.Assuming sludge is at 10% dry solids thensludge to be removed = 20 x 10 = 200 t

200 t 130 26,000 Veolia

WEEE Removal 40 t 100 4,000 VeoliaResidual waste from decontaminationPhase

50 t 100 5,000 Veolia

Sludge removal from firewater pond 40 t 100 4,000 Veolia

1 Assuming 1 supervisor and 3 operatives on contract.

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Task Description Quantity Unit1 Unit Rate(€)

Cost (€) Source

Assume 20% of annual hazardous wasterequired disposal at closure

112 t 300 33,600 Veolia

Assume 20% of annual non-hazardouswaste arising require disposal at closure

214 t 100 21,400 Veolia

Assume 1% of hazardous raw materialsand product need to be disposed of ashazardous waste (Table 6)

178 t 300 53,400 Veolia

Assume 1% of non-hazardous rawmaterials and product needs to bedisposed of as non-hazardous waste

24 t 100 2,400 Veolia

Environmental Monitoring Wastewater Monitoring (Daily) 60 sample 50 3,000 ExovaValidation Audit Consultant 3 day 900 2,700 EnvironetManagement Costs Utilities (assuming production has ceased) 6 month 40,000 240,000 MM

Security 6 month 9,500 57,000 MMManagement 6 month 60,000 360,000 MMInsurance 6 month 20,000 120,000 MM

SUB-TOTAL 1,156,500Plus 20% Contingency 213,000TOTAL 1,369,500

Table 8: Closure Plan Costing

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The schedule for site closure and remediation works is summarised below:

Table 9: Gantt Chart

Action Wk 2 Wk 4 Wk 6 Wk 8 Wk 10 Wk 12 Wk 14 Wk 16 Wk 18 Wk 20 Wk 22 Wk 24 Wk 26Notify EPA and Cork County Councilof intent to cease productionCease productionDecontaminate any plant/equipmentArrange for all waste to be taken off-site and recycled/disposed in anappropriate mannerArrange for sale/recycling of plant/equipmentArrange for sale/disposal of anyproduct or raw materials located at thesite at the time of closureInternal Closure Validation auditcarried out by or on behalf of MerckMilliporeExternal closure audit by the EPAClosure Validation Certification issuedby the EPA to indicate formalacceptance of the closure of the site.Surrender the IE Licence to the EPA

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8 Closure Plan Update and Review

As per the IE licence:

‘10.2.2 The plan shall be reviewed annually and proposed amendmentsthereto notified to the Agency for agreement as part of the AER. Noamendments may be implemented without the agreement of the Agency.’

Merck Millipore confirms its intention to review the DMP annually and toinform the EPA of any changes thereto.

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9 Restoration/Aftercare Management Plan

As the most recent Groundwater Monitoring Report by consultants ERM hasconcluded that there are no significant groundwater contamination issues atthe site it has been decided that the site will opt for a ‘Clean Closure’.Therefore other than the requirement to continue to monitor wastewater andsurface water emissions until the licence is surrendered and the managementcosts associated with the site, there are not expected to be any othersignificant aftercare costs.

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10 Financial Provision

Please find the Company Guarantee attached in Appendix A.

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Appendix A – Financial Provision

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Appendix B – Site Location

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Project Decommissioning ManagementPlan

Client Merck MilliporeDrawing Name Site Location ‘Discovery Series’

MapVersion 1Date 12-06-2014

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Appendix C – Site Layout Plan

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Appendix D – ERM Groundwater MonitoringReport

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The world’s leading sustainability consultancy

IPPC Licence Annual Groundwater Monitoring Report, 2013

Client: Merck Millipore Ireland Limited

Draft Report August 2013 www.erm.com

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Environmental Resources Management Limited Incorporated in the United Kingdom with registration number 1014622 Registered Office: 2nd Floor, Exchequer Crt, 33 St Mary Axe, London, EC3A 8AA

Merck Millipore Ireland Limited

IPPC Licence Annual Groundwater Monitoring Report, 2013

August 2013

Reference 0211582

Prepared by: Brian Rouse

This report has been prepared by Environmental Resources Management, the trading name of ERM Environmental Resources Management Ireland Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

For and on behalf of Environmental Resources Management Approved by: Simon Tillotson

Signed: Position: Partner Date: 27th August 2013

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CONTENTS

1 INTRODUCTION 1

1.1 PREAMBLE 1 1.2 REPORT FORMAT 1

2 SITE SETTING 2

2.1 SITE DESCRIPTION 2 2.2 SURROUNDING LAND USE 2 2.3 ENVIRONMENTAL SETTING 2

3 FIELDWORK METHODOLOGIES ADOPTED 4

3.1 SAMPLING LOCATIONS AND PROCEDURE 4 3.2 FIELD OBSERVATIONS 4

4 ANALYTICAL RESULTS 6

4.1 ANALYTICAL SUITE 6 4.2 ASSESSMENT OF ANALYTICAL RESULTS 6

5 CONCLUSIONS AND RECOMMENDATIONS 9

5.1 CONCLUSIONS 9 5.2 RECOMMENDATIONS 9

ANNEX A GENERIC QUANTITATIVE RISK ASSESSMENT TABLES ANNEX B CERTIFICATES OF LABORATORY CHEMICAL ANALYSIS FIGURES SITE LOCATION PLAN BOREHOLE LOCATION PLAN GROUNDWATER FLOW DIAGRAM

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ENVIRONMENTAL RESSOURCES MANAGEMENT MERCK MILLIPORE IRELAND LIMITED

1

1 INTRODUCTION

1.1 PREAMBLE

Environmental Resources Management Limited (ERM) was commissioned by Merck Millipore Ireland Ltd. (Millipore), to undertake annual monitoring works at the Carrigtohill Facility (‘the Site’), located at Carrigtohill, County Cork, Republic of Ireland, identified on Figure 1. The purpose of the annual monitoring is to satisfy the monitoring requirements of the Environment Protection Agency (EPA) Integration Pollution Prevention Control (IPPC) Licence (Licence No. P0571-02). The licence requires five groundwater monitoring wells (AGW1-3, AGW5 and AGW6) are sampled on an annual basis. The five monitoring wells designated for sampling are identified on Figure 2. This report provides the results of the 2013 IPPC licence annual monitoring round undertaken on 7 August 2013.

1.2 REPORT FORMAT

The remainder of this report has been structured as follows: Section 2 summarises the environmental setting of the Site;

Section 3 describes the field methodologies employed during the fieldwork

programme, the Site-specific ground conditions encountered, observations and measurements made during the investigation;

Section 4 details the analytical results and an interpretation of these results;

and Section 5 presents the conclusions of the assessment and the

recommendations based on the conclusions of this monitoring event. In addition, the following Annexes are attached to the report: Figures Site Location Plan Borehole Location Plan Groundwater Flow Direction Annex A Generic Quantitative Risk Assessment Tables Annex B Certificates of Laboratory Chemical Analysis

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2

2 SITE SETTING

2.1 SITE DESCRIPTION

The Site is located within a predominantly rural setting in County Cork approximately 1 km west of Carrigtoohill and 10 km east of Cork city centre. A site location plan is provided as Figure 1. The Site occupies an area of approximately 38 hectares. The Site topography generally falls from the north east to south west with a maximum elevation of 6.038 m Above Ordinance Datum (AOB) to north east and a minimum elevation of 0.765 m AOD in the south west. The majority of the Site is occupied by a single large building in the northern and central areas of the Site. The area in the south west of the Site is used for fire water retention ponds, and the area in the south east is used as playing fields. In the north east corner of the Site is the on-site wastewater treatment facility. The remaining areas of the Site are landscaped, apart from the two car parking areas, to the east and west, which are covered with tarmac and gravel. The Site is currently occupied by the Millipore facility which was purpose built for Millipore in 1987, for the production of filtration devices and membrane films; prior to this the Site was undeveloped agricultural land.

2.2 SURROUNDING LAND USE

The surrounding land use is predominantly agricultural, with the closest farm located adjacent to the southern boundary of the site.

2.3 ENVIRONMENTAL SETTING

2.3.1 Superficial & Solid Geology

Published information identifies that the Site is underlain by superficial deposits consisting of Glacial Till, comprising of light brown soft sandy gritty clay, which are further underlain by alluvial deposits compromising of sands and gravels. The underlying solid geology comprises of the Dinantian pure unbedded limestone. Previous site investigation work identified slightly gravelly silt to clay. The clay and silt were dry, friable, yet firm, gravel within the clay was well rounded fine to coarse and included cobbles. The sand content also varied between boreholes.

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3

The clay was underlain by a series of sand and gravel drift deposits, ranging from sandy silty gravels to clayey sands. The sands and gravels were encountered between 4.2 and 5 m bgl in the middle of the Site, to the west the gravels were encountered around 2.5 m bgl and to the north eastern boundary the gravels were similarly encountered at 2.5 m bgl. The sands and gravels were generally brown in colour, with gravels being well rounded.

2.3.2 Hydrogeology

The underlying alluvium has been classified as a Locally Important Sand/Gravel Aquifer. Groundwater flow direction has been calculated to be in a south west direction towards Slatty Water and subsequently Lough Mahon, the upper reaches of the estuarine waters of Cork Harbour. The groundwater body beneath the site is believed to be in hydraulic conductivity with the Slatty Water. The underlying bedrock has been classified by the GSI online mapping tool as a regionally important karstified aquifer. There are no known groundwater abstractions down gradient of the site, however, there is potential for there to be unregistered private supply abstractions within the area.

2.3.3 Hydrology

The closest surface water feature is Slatty Water, which is located 200 m west of the Site. The Slatty water represents the upper reaches of estuarine waters of Lough Mahon and Cork harbour, the main body of which is located southwest of the site. The Slatty Water and Lough Mahon are classified by the EPA as a Transitional and Coastal Water body and have a water quality “Intermediate” rating. This is the second highest of four quality ratings, after “Unpolluted”. There are no known recorded surface water abstractions within 1 km of the Site.

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4

3 FIELDWORK METHODOLOGIES ADOPTED

The site works were undertaken by ERM on 7 August 2013.

3.1 SAMPLING LOCATIONS AND PROCEDURE

The five monitoring wells AGW1, AGW2, AGW 3, AGW5 and AGW6 designated for sampling are presented in Figure 2. The groundwater encountered within each of the boreholes was purged using a peristaltic pump and sampled using low flow sampling techniques. The groundwater samples were submitted to Jones Environmental Forensics Laboratories (Jones), for analysis. Sample bottles, once filled and labelled, were transferred to insulated sample cool boxes and freezer blocks were added to the sample containers to reduce the loss of volatile materials. General sampling and decontamination procedures used in the course of the sampling were designed to allow the collection of representative samples and to minimise the potential for cross-contamination between samples. In addition, a rigorous programme of field QA/QC was implemented including sample labelling and chain-of-custody documentation. During sample collection, relevant information such as field observations was logged in the field book before transferring the samples to laboratory-prepared sample bottles. In the course of sampling, especially for samples destined for volatile analysis, care was taken to fill groundwater sample bottles completely to minimise remaining headspace. Care was also taken to minimise the aeration of samples during transfer to the bottles. As part of the overall sampling QA/QC package, sample tags and 'Chain-of-Custody' travel documents were filled out for each sample. This allowed tracking of the samples from acquisition through to analysis. These forms were enclosed in the sample coolers shipped to the laboratory. During sampling and decontamination activities, disposable nitrile gloves were worn to prevent transfer of contaminants from other sources.

3.2 FIELD OBSERVATIONS

Each of the five boreholes sampled contained water. At none of the locations did groundwater display visual or olfactory evidence of hydrocarbon or VOC contamination.

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5

Field Screening Results The results of field screening, using a YSI multiparameter handheld direct reading field instrument, are summarised in Table 3.1.

Table 3.1 YSI Testin

Borehole Screening Criteria

AGW1 AGW2 AGW3 AGW5 AGW6

Parameter (Units) Temperature (oC) 25 14.4 13.7 14.5 15.7 12.8 Conductivity (μs/cm) 1,000 575 523 545 336 445 Dissolved Oxygen (DO %)

No abnormal change

8.3 62.5 43.2 43.7 4.3

pH >6.5 to <9.5 6.72 6.79 6.83 6.97 6.67 pH mv Not applicable 1.4 -4.2 -9.3 -16.7 2.3 Redox Potential (ORP)

Not applicable -24.5 73.5 75.1 51.4 -44.5

The groundwater was purged using a “low flow” technique. The purged water was screened using an YSI multiparameter meter and the groundwater sampled when the readings stabilised. Groundwater flow at the site has previously been inferred from measurement of groundwater elevations to be in a south westerly direction, see Figure 3.

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6

4 ANALYTICAL RESULTS

4.1 ANALYTICAL SUITE

Groundwater samples were submitted to Jones, a UKAS accredited laboratory. The IPPC wells samples (AGW series) were scheduled for the following analytical suite: Metals Suite (arsenic, cadmium, chromium, lead, mercury, selenium,

boron, copper, nickel, zinc; Total Ammonia; Nitrate (as N); Orthophosphate; Chloride; Fluoride; Sodium; Magnesium; Potassium; Calcium; Mineral Oil; and Organic solvents. The analytical results are discussed in detail in Section 4.2 and are presented in Annex A. The laboratory analytical certificates are included in Annex B.

4.2 ASSESSMENT OF ANALYTICAL RESULTS

4.2.1 Rationale

The assessment of the analytical results has been carried out with reference to the guidance and methods specified by the Irish Environmental Protection Agency in their Technical Advice to Third Parties on the Protection of Groundwater in Ireland, Interim Report. In assessing whether pollution of groundwater has, or is likely to occur, it is common practice to compare against Interim Guideline Values (IGVs) defined within this guidance.

4.2.2 IPPC Groundwater Well Sampling Results

The groundwater analytical results were assessed against the relevant IGVs, The only exceedences of these IGVs are summarised in Table 4.1 below.

Table 4.1 Exceedences of IGVs

Compound IGV Criteria mg/l AGW1 AGW2 AG3 AGW5 AGW6 Chloride 30.0 42.4 36 - - 38.2 Potassium 5 10.1 - - - 16.6 Note: IGV Criteria – Interim Guideline Value - = did not exceed IGV

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7

Chloride Chloride concentrations for the 2013 monitoring event are consistent across the Site. The concentrations range between 22.1mg/l and 42.4mg/l with only three of the samples marginally exceeding the IGV. The concentrations are also consistent with time, with the exception of AGW5, as demonstrated by the graphs below (Plates 4.2a and 4.2b) demonstrating monitoring results over a five year period beginning in 2009.

Plate 4.2a Chloride Concentration Trends with Time at Sampling Points AGW1, AGW2, AGW3and AGW6

The chloride results at AGW5 demonstrated a spike in 2010 but have had a consistently decreasing trend since that spike and have subsequently dropped below the EPA IGV in 2013 (see Plate 4.2b).

EPA IGV

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8

Plate 4.2b Chloride Concentration Trends with Time at Sampling Point AGW5

Potassium The potassium concentrations are plotted in Plate 4.2c below and the 2013 results are consistent with previous monitoring rounds for each sampling location. AGW1 and AGW6 exceed the IGV, with the highest concentration of 16.6 mg/l detected at AGW6. The concentrations are not necessarily the direct result of site related activity but may be due to localised geological conditions.

Plate 4.2c Potassium Concentration Trends with Time at All Sampling Points

EPA IGV

EPA IGV

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9

5 CONCLUSIONS AND RECOMMENDATIONS

5.1 CONCLUSIONS

The majority of analytes were either below their respective laboratory detection limit or the screening criteria. Chloride and potassium were detected at concentrations above their respective IGV screening criteria. However, where exceedences occur, these exceedences are in general only marginally above their respective screening criteria or indicative of conditions within the surrounding area. It should also be noted that the receptor of concern, the Slatty Water and subsequently Lough Mahon, is located 200 m west of the Site and is saline. Lough Mahon is classified by the EPA Envision online mapping tool as having an “intermediate” water quality rating and has a “1a - At risk of not achieving good status” Water Framework Directive Risk Score status. It is therefore considered the groundwater from the site is unlikely to represent a significant risk or impact to the Slatty Water given the existing condition of the Slatty Water, the low concentrations detected on site and the attenuation of concentrations within the groundwater body between the site and the Slatty Water.

5.2 RECOMMENDATIONS

Given the majority of analytes are either below their respective laboratory detection limit or the screening criteria and that the exceedences are only marginally greater than the screening criteria, no further works are required. However, the chloride and potassium results should be reassessed as part of the 2014 IPPC licence sampling event.

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CLIENT: SIZE: TITLE:

DATE: 21/05/2010

DRAWN: MTC

CHECKED: BR

APPROVED:

PROJECT: 0114243

SCALE: As Scale BarDRAWING: REV:

Millipore Ireland BV A4 Figure 1: Site Location Plan Carrigtwohill, Co Cork, Ireland

CorkLocationPlan.mxd 0SOURCE: Reproduced from Ordnance Survey digital map data. © Crowncopyright, All rights reserved. 2007 License number 0100031673.PROJECTION: TM65 Irish Grid

File:

0114

243M

illipore

GIS_

MTC_

BR\C

orkLo

catio

nPlan

.mxd

ERM11th Floor5 Exchange QuayManchester, M5 3EFTel: 0161 958 8800Fax: 0161 958 88880 25

Kilometres

© ERM This print is confidential and is supplied on the understanding that it will be used only as a record to identify or inspect parts, concepts or designs and that it is not disclosed to other persons or to be used for construction purposes without permission.

SITE LOCATION

Carrigtwohill

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BH04BH04

BH01BH01

BH05BH05BH03BH03

BH02BH02

AGW2AGW2

BH02BH02

BH05BH05

BH03BH03

BH01BH01

Pit 1RPit 1R

Pit 1bPit 1b

Pit 1LPit 1L

SumpSump

Enlarged View of Sump AreaEnlarged View of Sump Area

Please See Enlarged View of Sump Area

Please See Enlarged View of Sump Area

SB15SB15

SB11SB11SB21SB21

SB2SB2

SB5SB5

SB14SB14

SB4SB4

SB7SB7SB8SB8

SB18SB18

AGW1AGW1

AGW6AGW6

AGW2AGW2

AGW3AGW3

AGW5AGW5

ERM Installed Borehole

BH04BH04

BH02BH02

BH05BH05 BH03BH03

BH01BH01

Fire Retention Pond

Fire Retention Pond

Fire Retention Pond

Fire Retention Pond

Car ParkCar Park

Durapore CastingDurapore Casting

OfficesOffices

OfficesOffices

WarehouseWarehouse

Existing Car ParkExisting Car Park

Contractors CompoundContractors Compound

Wastewater Treatment PlantWastewater Treatment Plant

Proposed Solvent Tank Farm


Proposed Thermal Oxidiser


Hi FlowHi Flow

Manchester Office11th Floor5 Exchange QuayManchester, M5 3EFTelephone: +44 (0) 161 958 8800Facsimile: +44 (0) 161 958 8888


SOURCE:

CHECKED: BR

APPROVED:

PROJECT: 0114243

SCALE: Not to Scale

REV:

0114243_1 - 04.02.10 0

DATE: 04.02.10

DRAWN: MTC

DRAWING:

SIZE:

A3

CLIENT:

Millipore Ireland BV

TITLE:

Figure 2: Site Layout, Monitoring Well & Sample Location Plan

Carrigtwohill, Co Cork, Ireland

KEY:

Site boundary

ERM installed monitoring wells

IPPC monitoring wells

Remaining monitoring / remediation boreholes

Additional soil sample location

Text to be place here

Text to be place here

Reproduced from Ordnance Survey digital map data. © Crown copyright, All rights reserved. 2009 License number 0100031673

0 6

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N

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BH04BH04

BH01BH01

BH05BH05BH03BH03

BH02BH02

AGW1AGW1

AGW6AGW6

AGW2AGW2

AGW3AGW3

AGW5AGW5

ERM Installed Borehole

BH04BH04

BH02BH02

BH05BH05 BH03BH03

BH01BH01

2mAOD2mAOD

1mAOD1mAOD

0mAOD0mAOD

SB15SB15

SB11SB11SB21SB21

SB2SB2

SB5SB5

SB18SB18

SB14SB14

SB4SB4

SB7SB7SB8SB8

Fire Retention Pond

Fire Retention Pond

Fire Retention Pond

Fire Retention Pond

Car ParkCar Park

Durapore CastingDurapore Casting

OfficesOffices

OfficesOffices

WarehouseWarehouse

Existing Car ParkExisting Car Park

Contractors CompoundContractors Compound

Wastewater Treatment PlantWastewater Treatment Plant





Hi FlowHi Flow

Manchester Office11th Floor5 Exchange QuayManchester, M5 3EFTelephone: +44 (0) 161 958 8800Facsimile: +44 (0) 161 958 8888


SOURCE:

CHECKED: BR

APPROVED:

PROJECT: 0114243

SCALE: Not to Scale

REV:

0114243_2 - 04.02.10 0

DATE: 21.05.10

DRAWN: MTC

DRAWING:

SIZE:

A3

CLIENT:

Millipore Ireland BV

TITLE:

Figure 3: Inferred Groundwater Flow Direction

Carrigtwohill, Co Cork, Ireland

KEY:

Site boundary

ERM installed monitoring wells

IPPC monitoring wells

Remaining monitoring / remediation boreholes

Groundwater contour mAOD (metres above ordnance Datum

Inferred direction of flow

Reproduced from Ordnance Survey digital map data. © Crown copyright, All rights reserved. 2009 License number 0100031673

0 6

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Annex A

Generic Quantitative Risk Assessment Tables

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IPPC Groundwater Analytical Results 2012

Screening Criteria

MetalsArsenic mg/l 0.01 n.d. n.d. n.d. n.d. n.d.Boron mg/l 1.00 0.021 0.022 0.022 0.056 0.204Cadmium mg/l 0.005 n.d. n.d. n.d. n.d. n.d.Chromium mg/l 0.03 n.d. n.d. n.d. n.d. n.d.Copper mg/l 0.030 n.d. n.d. n.d. n.d. n.d.Lead mg/l 0.01 n.d. n.d. n.d. n.d. n.d.Mercury mg/l 0.001 n.d. n.d. n.d. n.d. n.d.Nickel mg/l 0.02 n.d. n.d. n.d. n.d. n.d.Selenium mg/l n.v. n.d. n.d. n.d. n.d. n.d.Zinc mg/l 0.10 n.d. n.d. 0.004 n.d. n.d.

InorganicspH (Field Measurement) >6.5-<9.5 6.72 6.79 6.83 6.97 6.67Ammonia (calculated from ammoniacal nitrogen) mg/l 0.15 0.0005 n.d. n.d. n.d. 0.00005

Nitrate as N# mg/l 25.00 n.d. 5.07 2.42 5.29 n.d.

Ortho phosphate as PO4# mg/l 0.03 n.d. n.d. n.d. n.d. n.d.

Sulphate# mg/l 200.00 11.59 15.46 14.64 22.58 7.48

Chloride# mg/l 30.00 42.4 36 27.2 22.1 38.2Fluoride mg/l 1.00 n.d. n.d. n.d. n.d. n.d.

Calcium - dissolved# mg/l 200.00 72.9 73.6 90.6 39.4 9.5

Magnesium - dissolved# mg/l 50.00 7.8 8.7 5.2 5.6 17.2

Potassium - dissolved# mg/l 5.00 10.1 4.4 0.9 2.1 16.6

Sodium - dissolved# mg/l 150.00 17.8 19.8 16 20.9 42.2

No VOCs Detected

No Mineral Oil Detected

No SVOCs Detected

No Phenols Detected

No PAHs Detected

No Phthalates Detected

Note:n.d - not detected above laboratory detection limitn.a. - not available

EPA IGV - Environmental Protection Agency Interim Guidline Valuesabove detection limitexceeds screening criteria

AnalyteConcentration

EPA IGVUnits

AGW1 AGW2 AGW3 AGW5 AGW6

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Annex B

Certificates of Laboratory Chemical Analysis

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EPA Export 11-09-2015:23:39:31

Unit 3 Deeside Point

Zone 3

Deeside Industrial Park

Deeside

ERM

No.4225

Attention :

Date :

Your reference :

Our reference :

Location :

Date samples received :

Status :

Issue :

Bob Millward BSc FRSC

Principal Chemist

1

Jones Environmental Laboratory

CH5 2UA

Tel: +44 (0) 1244 833780

Fax: +44 (0) 1244 833781

Brian Rouse

The Capel Building

Mary's Abbey

Dublin

Ireland

Five samples were received for analysis on 9th August, 2013. Please find attached our Test Report which should be read with notes at the end of

the report and should include all sections if reproduced. Interpretations and opinions are outside the scope of any accreditation, and all results

relate only to samples supplied.

All analysis is carried out on as received samples and reported on a dry weight basis unless stated otherwise. Results are not surrogate corrected.

Paul Lee-Boden BSc

Project Manager

20th August, 2013

0211582

MILLIPORE

9th August, 2013

Final report

Compiled By:

Test Report 13/7298 Batch 1

QF-PM 3.1.1 v14Please include all sections of this report if it is reproduced

All solid results are expressed on a dry weight basis unless stated otherwise. 1 of 9

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Client Name: Report : Liquid

Reference:

Location:

Contact: Liquids/products: V=40ml vial, G=glass bottle, P=plastic bottle

JE Job No.: 13/7298 H=H2SO4, Z=ZnAc, N=NaOH, HN=HN03

J E Sample No. 1-6 7-12 13-18 19-24 25-30

Sample ID AGW1070813GW AGW2070813GW AGW3070813GW AGW5070813GW AGW6070813GW

Depth

COC No / misc

Containers V H HN P G V H HN P G V H HN P G V H HN P G V H HN P G

Sample Date 07/08/2013 07/08/2013 07/08/2013 07/08/2013 07/08/2013

Sample Type Ground Water Ground Water Ground Water Ground Water Ground Water

Batch Number 1 1 1 1 1

Date of Receipt 09/08/2013 09/08/2013 09/08/2013 09/08/2013 09/08/2013

Metals

Dissolved Arsenic # <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 ug/l TM30/PM14

Dissolved Cadmium # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM30/PM14

Total Dissolved Chromium # <1.5 <1.5 <1.5 <1.5 <1.5 <1.5 ug/l TM30/PM14

Dissolved Copper # <7 <7 <7 <7 <7 <7 ug/l TM30/PM14

Dissolved Lead # <5 <5 <5 <5 <5 <5 ug/l TM30/PM14

Dissolved Mercury # <1 <1 <1 <1 <1 <1 ug/l TM30/PM14

Dissolved Nickel # <2 <2 <2 <2 <2 <2 ug/l TM30/PM14

Dissolved Selenium # <3 <3 <3 <3 <3 <3 ug/l TM30/PM14

Dissolved Zinc # <3 <3 4 <3 <3 <3 ug/l TM30/PM14

Dissolved Boron 21 22 22 56 204 <12 ug/l TM30/PM14

Dissolved Calcium # 72.9 73.6 90.6 39.4 9.5 <0.2 mg/l TM30/PM14

Dissolved Magnesium # 7.8 8.7 5.2 5.6 17.2 <0.1 mg/l TM30/PM14

Dissolved Potassium # 10.1 4.4 0.9 2.1 16.6 <0.1 mg/l TM30/PM14

Dissolved Sodium # 17.8 19.8 16.0 20.9 42.2 <0.1 mg/l TM30/PM14

VOC TICs ND ND ND ND ND None TM15/PM10

SVOC TICs ND ND ND ND ND None TM16/PM30

Mineral Oil # <10 <10 <10 <10 <10 <10 ug/l TM5/PM30

Fluoride <0.3 <0.3 <0.3 <0.3 <0.3 <0.3 mg/l TM27/PM0

Sulphate # 11.59 15.46 14.64 22.58 7.48 <0.05 mg/l TM38/PM0

Chloride # 42.4 36.0 27.2 22.1 38.2 <0.3 mg/l TM38/PM0

Ortho Phosphate as PO4 # <0.06 <0.06 <0.06 <0.06 <0.06 <0.06 mg/l TM38/PM0

Nitrate as N # <0.05 5.07 2.42 5.29 <0.05 <0.05 mg/l TM38/PM0

Ammoniacal Nitrogen as NH3 # 0.35 <0.03 <0.03 <0.03 0.05 <0.03 mg/l TM38/PM0

Electrical Conductivity @25C # 552 541 554 344 429 <2 uS/cm TM76/PM0

MILLIPORE

Brian Rouse

Please see attached notes for all

abbreviations and acronyms

LOD UnitsMethod

No.


ERM

0211582



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EPA Export 11-09-2015:23:39:31

Client Name: SVOC Report : Liquid

Reference:

Location:

Contact:

JE Job No.: 13/7298

J E Sample No. 1-6 7-12 13-18 19-24 25-30


Depth

COC No / misc


Sample Date 07/08/2013 07/08/2013 07/08/2013 07/08/2013 07/08/2013



Date of Receipt 09/08/2013 09/08/2013 09/08/2013 09/08/2013 09/08/2013

SVOC MS

Phenols

4-Chloro-3-methylphenol # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

2-Chlorophenol # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

2-Methylphenol # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

4-Methylphenol <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

2,4-Dichlorophenol # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

2,4-Dimethylphenol <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

2-Nitrophenol # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

4-Nitrophenol <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Pentachlorophenol <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Phenol <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

2,4,5-Trichlorophenol # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

2,4,6-Trichlorophenol <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

PAHs

Acenaphthene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Acenaphthylene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Anthracene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Benzo(a)anthracene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Benzo(bk)fluoranthene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Benzo(a)pyrene <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Benzo(ghi)perylene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

2-Chloronaphthalene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Chrysene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Dibenzo(ah)anthracene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Fluoranthene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Fluorene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Indeno(123cd)pyrene <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

2-Methylnaphthalene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Naphthalene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Phenanthrene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Pyrene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Phthalates

Bis(2-ethylhexyl) phthalate <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Butylbenzyl phthalate <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Diethyl phthalate # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Dimethyl phthalate <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Di-n-butyl phthalate # <1.5 <1.5 <1.5 <1.5 <1.5 <1.5 ug/l TM16/PM30

Di-n-Octyl phthalate <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Amines

N-nitrosodi-n-propylamine # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Anilines

4-Chloroaniline <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

2-Nitroaniline <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

3-Nitroaniline <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

4-Nitroaniline # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

MILLIPORE

Brian Rouse



LOD UnitsMethod

No.


ERM

0211582



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EPA Export 11-09-2015:23:39:31

Client Name: SVOC Report : Liquid

Reference:

Location:

Contact:

JE Job No.: 13/7298

J E Sample No. 1-6 7-12 13-18 19-24 25-30


Depth

COC No / misc


Sample Date 07/08/2013 07/08/2013 07/08/2013 07/08/2013 07/08/2013



Date of Receipt 09/08/2013 09/08/2013 09/08/2013 09/08/2013 09/08/2013

SVOC MS

Other SVOCs

Azobenzene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Bis(2-chloroethoxy)methane # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Carbazole # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Dibenzofuran # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

2,4-Dinitrotoluene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

2,6-Dinitrotoluene <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Hexachlorobutadiene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Hexachlorocyclopentadiene <10 <10 <10 <10 <10 <10 ug/l TM16/PM30

Isophorone # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM16/PM30

Nitrobenzene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Bis(2-chloroethyl)ether # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

4-Bromophenylphenylether # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

4-Chlorophenylphenylether # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Hexachloroethane # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

Hexachlorobenzene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

1,2,4-Trichlorobenzene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30

1,2-Dichlorobenzene # <1 <1 <1 <1 <1 <1 ug/l TM16/PM30



LOD UnitsMethod

No.


ERM

0211582

MILLIPORE

Brian Rouse





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EPA Export 11-09-2015:23:39:31

Client Name: VOC Report : Liquid

Reference:

Location:

Contact:

JE Job No.: 13/7298

J E Sample No. 1-6 7-12 13-18 19-24 25-30


Depth

COC No / misc


Sample Date 07/08/2013 07/08/2013 07/08/2013 07/08/2013 07/08/2013



Date of Receipt 09/08/2013 09/08/2013 09/08/2013 09/08/2013 09/08/2013

VOC MS

BTEX

Benzene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM15/PM10

Toluene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM15/PM10

Ethylbenzene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM15/PM10

p/m-Xylene # <1 <1 <1 <1 <1 <1 ug/l TM15/PM10

o-Xylene # <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/l TM15/PM10

Chloroethenes

Tetrachloroethene (PCE) # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Trichloroethene (TCE) # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

1,1-Dichloroethene (1,1 DCE) # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

cis-1-2-Dichloroethene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

trans-1-2-Dichloroethene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Vinyl Chloride <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 ug/l TM15/PM10

Chloroethanes

1,1,1,2-Tetrachloroethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

1,1,2,2-Tetrachloroethane <4 <4 <4 <4 <4 <4 ug/l TM15/PM10

1,1,1-Trichloroethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

1,1,2-Trichloroethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

1,1-Dichloroethane # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

1,2-Dichloroethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Chloroethane # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Chlorobenzenes

1,2,3-Trichlorobenzene <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

1,2,4-Trichlorobenzene <3 <3 <3 <3 <3 <3 ug/l TM15/PM10




Chlorobenzene # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Chloromethanes

Carbon tetrachloride # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Chloroform # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Dichloromethane (DCM) # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Chloromethane # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Chloropropanes

1,2,3-Trichloropropane # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

1,2-Dichloropropane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

2,2-Dichloropropane <1 <1 <1 <1 <1 <1 ug/l TM15/PM10

1,3-Dichloropropane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Chloropropenes

1,1-Dichloropropene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

cis-1-3-Dichloropropene <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

trans-1-3-Dichloropropene <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

MILLIPORE

Brian Rouse



LOD UnitsMethod

No.


ERM

0211582



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Client Name: VOC Report : Liquid

Reference:

Location:

Contact:

JE Job No.: 13/7298

J E Sample No. 1-6 7-12 13-18 19-24 25-30


Depth

COC No / misc


Sample Date 07/08/2013 07/08/2013 07/08/2013 07/08/2013 07/08/2013



Date of Receipt 09/08/2013 09/08/2013 09/08/2013 09/08/2013 09/08/2013

VOC MS

Other VOCs

Bromobenzene # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Bromochloromethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Bromodichloromethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Bromoform # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Bromomethane <1 <1 <1 <1 <1 <1 ug/l TM15/PM10

n-Butylbenzene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

sec-Butylbenzene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

tert-Butylbenzene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

2-Chlorotoluene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

4-Chlorotoluene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Isopropylbenzene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

1,2-Dibromo-3-chloropropane <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Dibromochloromethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

1,2-Dibromoethane # <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Dibromomethane # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Dichlorodifluoromethane <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

4-Isopropyltoluene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Propylbenzene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Styrene <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Trichlorofluoromethane # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

1,2,4-Trimethylbenzene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

1,3,5-Trimethylbenzene # <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Methyl Tertiary Butyl Ether # <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 ug/l TM15/PM10

Hexachlorobutadiene <3 <3 <3 <3 <3 <3 ug/l TM15/PM10

Naphthalene <2 <2 <2 <2 <2 <2 ug/l TM15/PM10

Surrogate Recovery Toluene D8 99 96 98 94 98 <0 % TM15/PM10

Surrogate Recovery 4-Bromofluorobenzene 109 108 108 101 108 <0 % TM15/PM10

LOD UnitsMethod

No.


ERM

0211582

MILLIPORE

Brian Rouse





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JE Job No.:

SOILS

DEVIATING SAMPLES

SURROGATES

NOTE

Surrogate compounds are added during the preparation process to monitor recovery of analytes. However low recovery in soils is often due to peat,

clay or other organic rich matrices. For waters this can be due to oxidants, surfactants, organic rich sediments or remediation fluids. Acceptable

limits for most organic methods are 70 - 130% and for VOCs are 50 - 150%. When surrogate recoveries are outside the performance criteria but

the associated AQC passes this is assumed to be due to matrix effect. Results are not surrogate corrected.

Data is only accredited when all the requirements of our Quality System have been met. In certain circumstances where the requirements have not

been met, the laboratory may issue the data in an interim report but will remove the accreditation, in this instance results should be considered

indicative only. Where possible samples will be re-extracted and a final report issued with accredited results. Please do not hesitate to contact the

laboratory if further details are required of the circumstances which have led to the removal of accreditation.

It is assumed that you have taken representative samples on site and require analysis on a representative subsample. Stones will generally be

included unless we are requested to remove them.

UKAS accreditation applies to surface water and groundwater and one other matrix which is analysis specific, any other liquids are outside our

scope of accreditation

As surface waters require different sample preparation to groundwaters the laboratory must be informed of the water type when submitting samples.

Samples must be received in a condition appropriate to the requested analyses. All samples should be submitted to the laboratory in suitable

containers with sufficient ice packs to sustain an appropriate temperature for the requested analysis. If this is not the case you will be informed and

any test results that may be compromised highlighted on your deviating samples report.

Where appropriate please make sure that our detection limits are suitable for your needs, if they are not, please notify us immediately.

Please note we are not a Drinking Water Inspectorate (DWI) Approved Laboratory . It is important that detection limits are carefully considered

when requesting water analysis.

If you have not already done so, please send us a purchase order if this is required by your company.

All analysis is reported on a dry weight basis unless stated otherwise. Results are not surrogate corrected. Samples are dried at 35°C ±5°C unless

otherwise stated. Moisture content for CEN Leachate tests are dried at 105°C ±5°C.

Where Mineral Oil or Fats, Oils and Grease is quoted, this refers to Total Aliphatics C10-C40.

Where a CEN 10:1 ZERO Headspace VOC test has been carried out, a 10:1 ratio of water to wet (as received) soil has been used.

NOTES TO ACCOMPANY ALL SCHEDULES AND REPORTS

Please note we are only MCERTS accredited for sand, loam and clay and any other matrix is outside our scope of accreditation.

Where Mineral Oil or Fats, Oils and Grease is quoted, this refers to Total Aliphatics C10-C40.

13/7298

WATERS

Where an MCERTS report has been requested, you will be notified within 48 hours of any samples that have been identified as being outside our

MCERTS scope. As validation has been performed on clay, sand and loam, only samples that are predominantly these matrices, or combinations

of them will be within our MCERTS scope. If samples are not one of a combination of the above matrices they will not be marked as MCERTS

accredited.

All samples will be discarded one month after the date of reporting, unless we are instructed to the contrary. If we are instructed to keep samples, a

storage charge of £1 (1.5 Euros) per sample per month will be applied until we are asked to dispose of them.



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JE Job No.:

#

B

DR

M

NA

NAD

ND

NDP

SS

SV

W

+

++

*

CO

OC

NFD

Analysis subcontracted to a Jones Environmental approved laboratory.

Calibrated against a single substance.

No Determination Possible

ABBREVIATIONS and ACRONYMS USED

No Asbestos Detected.

None Detected (usually refers to VOC and/SVOC TICs).

UKAS accredited.

No Fibres Detected

Result outside calibration range, results should be considered as indicative only and are not accredited.

Results expressed on as received basis.

Surrogate recovery outside performance criteria. This may be due to a matrix effect.

Dilution required.

Indicates analyte found in associated method blank.

Not applicable

MCERTS accredited.

AQC failure, accreditation has been removed from this result, if appropriate, see 'Note' on previous page.

Outside Calibration Range

Suspected carry over

13/7298



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Method Code Appendix

JE Job No 13/7298

Test Method No. Description

Prep Method

No. (if

appropriate)

Description UKAS

MCERTS

(soils

only)

Analysis done on As

Received (AR) or Air

Dried (AD)

Reported on dry

weight basis

TM5 EPH by GC-FID, modified USEPA 8015 PM30 Magnetic stirrer extraction Yes

TM15 VOC - Target by GC-MS, modified USEPA 8260 PM10 VOC GC-MS

TM15 VOC - Target by GC-MS, modified USEPA 8260 PM10 VOC GC-MS Yes

TM16 SVOC - Target by GC-MS, modified USEPA 8270 PM30 Magnetic stirrer extraction

TM16 SVOC - Target by GC-MS, modified USEPA 8270 PM30 Magnetic stirrer extraction Yes

TM27 SO4,Cl,NO3,NO2,F,PO4 by Dionex PM0 No Preparation

TM30 Metals by ICP-OES PM14 Metals by ICP (Waters)

TM30 Metals by ICP-OES PM14 Metals by ICP (Waters) Yes

TM38 SO4,Cl,NO3,NO2,F,PO4, Amm N2,ThioCN, Hex Cr by Aquakem PM0 No Preparation Yes

TM76 Electrical Conductivity by Metrohm PM0 No Preparation Yes


QF-PM 3.1.10 v12 Please include all sections of this report if it is reproduced 9 of 9

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ERM consulting services worldwide www.erm.com

ERM has over 140 offices across the following countries and territories worldwide Argentina New Zealand Australia Panama Belgium Peru Brazil Poland Canada Portugal China Puerto Rico Colombia Romania France Russia Germany Singapore Hong Kong South Africa Hungary South Korea India Spain Indonesia Sweden Ireland Taiwan Italy Thailand Japan United Arab Emirates Kazakhstan UK Malaysia US Mexico Vietnam The Netherlands ERM’s Dublin Office Suite 508, The Capel Building Mary;s Abbey, Dublin 7 T: +353 1 814 7700 F: +353 1 814 7777 www.erm.com

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Attachment L

Statutory Requirements

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2

1 Statutory Requirements

The following describes how the facility will comply with the requirements asspecified in Section L of the IE Application Form. The questions in theapplication form are in italics below.

Indicate how the requirements of Section 83(5)(a)(i) to (v) and (vii) to (x)of the EPA Act 1992, as amended, shall be met, having regard, whereappropriate, to any relevant specification issued by the Agency undersection 5 (3) of the Act and the reasons for the selection of thearrangements proposed. Namely;

83(5)(a)(i) any emissions from the activity will not result in thecontravention of any relevant air quality standard specified undersection 50 of the Air Pollution Act 1987, and will comply with anyrelevant emission limit value specified under section 51 of the AirPollution Act 1987.

The facility will not lead to a contravention of the above ambient air qualitystandards and emissions limit values specified above will be complied with.An Air Dispersion Modelling Report has been provided in Attachment I andconfirms compliance with statutory emission limit values and ambient airstandards.

83(5)(a)(ii) any emissions from the activity will comply with, or will notresult in the contravention of, any relevant quality standard for waters,trade effluents and sewage effluents and standards in relation totreatment of such effluents prescribed under section 26 of the LocalGovernment (Water Pollution) Act 1977.

The facility will comply with the above legislation. Process effluent is sent toCarrigtwohill WWTP following tertiary treatment on-site. Emissions are incompliance with the emission limit values specified in the IE Licence. Clean,uncontaminated storm water is discharged, via an oil/silt interceptor to SlattyWaters which discharges to Lough Mahon, part of Cork Harbour. Millipore hasalso installed online TOC and pH analysers which closes a penstock valve inthe event that TOC or pH analysis is above the background level agreed withthe EPA. Surface water is then held onsite in the firewater retention pond.

83(5)(a)(iii) any emissions from the activity or any premises, plant,methods, processes, operating procedures or other factors which affectsuch emissions will comply with, or will not result in the contraventionof, any relevant standard including any standard for an environmental

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3

medium prescribed under regulations made under the EuropeanCommunities Act 1972, or under any other enactment,

The facility will not lead to a contravention of any relevant standard prescribedunder the European Communities Act 1972, or under any other enactment.There are no predicted significant impacts associated with the proposedfacility.

83(5)(a)(iv) any noise from the activity will comply with and will notresult in the contravention of, any regulation under section 106.

As detailed in Section I.7 of this application noise from the activity will complywith, or will not result in the contravention of, any regulations under section106.

83(5)(a)(v) any emissions from the activity will not cause significantenvironmental pollution.

Emission from the activity will not cause significant environmental pollution. Afull assessment of environmental impacts have been detailed in Section I ofthe application.

83(5)(a)(vii) having regard to Part III of the Act of 1996, production ofwaste in the carrying on of the activity will be prevented or minimised or,where waste is produced, it will be recovered or, where that is nottechnically or economically possible, disposed of in a manner which willprevent or minimise any impact on the environment,

The facility will comply with the provisions of the Act of 1996. This will beachieved through the implementation of BAT and waste management bestpractice.

83(5)(a)(viii) energy will be used efficiently in the carrying on of theactivity.

Energy efficiency is a critical part of design considerations and ongoingoperations at the facility. Refer to Attachment G.2 of this application.

83(5)(a)(ix) necessary measures will be taken to prevent accidents in thecarrying on of the activity and, where an accident occurs, to limit itsconsequences for the environment and, in so far as it does have suchconsequences, to remedy those consequences.

All measures are taken to prevent and limit the severity of accidents at thefacility. Refer to Attachment J of this application.

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4

83(5)(a)(x) necessary measures will be taken upon the permanentcessation of the activity (including such a cessation resulting from theabandonment of the activity) to avoid any risk of environmental pollutionand return the site of the activity to a satisfactory state.

Residuals management costs have been estimated and the site will bereturned to an environmentally inert state in the event of closure. Refer toAttachment K of this application.

Indicate whether or not the activity is carried out, or may be carried out,or is located such that it is liable to have an adverse effect on –

(a) a site placed on a list in accordance with Part 3 of S.I. 477 of 2011, or

(b) a site where consultation has been initiated in accordance withArticle 5 of the EU Habitats Directive (92/43/EEC).

Undertake a screening for Appropriate Assessment and state whetherthe activity, individually or in combination with other plans or projects,is likely to have a significant effect on a European Site(s), in view of bestscientific knowledge and the conservation objectives of the site(s).Where it cannot be excluded, on the basis of objective scientificinformation, following screening for Appropriate Assessment, that anactivity, either individually or in combination with other plans orprojects, will have a significant effect on a European Site, provide aNatura Impact Statement, as defined in Regulation 2(1) of the EuropeanCommunities (Birds and Natural Habitats) Regulations (S.I. No. 477 of2011). Where based on the screening it is considered that anAppropriate Assessment is not required, provide a reasoned response.

The proposed site is not protected under cSAC, SPA, NHA or pNHAdesignation. The closest protected site is the Slatty Waters to which the sitedischarges uncontaminated surface waters. The Slatty Waters is designatedas an SAC and SPA. It is not expected that the activity will have any impacton this area.

Indicate whether or not the activity is liable to have an adverse effect onwater quality in light of the European Communities EnvironmentalObjectives (Surface Water) Regulations 2009 (S.I. No. 272 of 2009).

The activity is not expected to have any adverse impact on surface waterquality. Process effluent is treated onsite prior to discharge in compliance withemission limit values to Carrigtwohill municipal wastewater treatment plant.Only uncontaminated surface water is discharged directly to the Slatty Waters.

Indicate whether or not the activity is liable to have an adverse effect onwater quality in light of the European Communities EnvironmentalObjectives (Ground Water) Regulations 2010 (S.I. No. 9 of 2010).

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5

There are no direct discharges to ground from the activity.

Indicate whether any of the substances specified in the Schedule of theEPA (Industrial Emissions)(Licensing) 2013, S.I. No. 137 of 2013, aredischarged by the activity to the relevant medium.

The following substances will be emitted to atmosphere in accordance withappropriate emission limit values:

Oxides of nitrogen and other nitrogen compounds. Carbon monoxide. Volatile organic compounds. Dust including fine particulate matter.

The following substance will be emitted to sewer in accordance withappropriate emission limit values:

Materials in suspension. Substances which contribute to eutrophication (in particular, nitrates

and phosphates). Substances which have an unfavourable influence on the oxygen

balance (and can be measured using parameters such as BOD, COD,etc.).

Indicate if the best environmental practices are in place for control ofdiffuse emissions from the installation as set out in the followinglegislation:

(a) a BAT Conclusions Implementing Decision published by the EC.

Best Available Techniques are in place at the facility. Please refer toAttachment I.8

(b) a specification prepared by the Agency in accordance withSection 5 of the Environmental Protection Agency Act 1992 asamended;

Best Available Techniques are in place at the facility. Please refer toAttachment I.8

(c) the Urban Waste Water Treatment Regulations 2001 (S.I. No. 254of 2001) as amended by the Urban Waste Water Treatment(Amendment) Regulations 2004 (S.I. No. 440 of 2004) or any futureamendment thereof;

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6

While not directly applicable treated effluent from the facility is discharged tothe Carrigtwohill municipal wastewater treatment plant. However it isconsidered that this will have no significant impact on the municipal plant dueto the level of treatment provided on site.

(d) the European Communities (Good Agricultural Practice forProtection of Waters) Regulations 20 (S.I. No. 610 of 2010) or anyfuture amendment thereof;

Not applicable.

(e) the Local Government (Water Pollution) Act, 1977 (Control ofCadmium Discharges) Regulations 1985 (S.I. No. 294 of 1985);

Not applicable.

(f) the Local Government (Water Pollution) Act, 1977 (Control ofHexachlorocyclohexane and Mercury Discharges) Regulations1986 (S.I. No. 55 of 1986);

Not applicable.

(g) the Local Government (Water Pollution) Acts, 1977 and 1990(Control of Carbon Tetrachloride, DDT and PentachlorophenolDischarges) Regulations 1994 (S.I. No. 43 of 1994); and,

Not applicable

(h) measures or controls identified in a pollution reduction plan forthe river basin district prepared in accordance with Part V of theEC Environmental Objectives (Surface Waters) Regulations 2009S.I. No. 272 of 2009 for the reduction of pollution by prioritysubstances or the ceasing or phasing out of emissions,discharges and losses of priority hazardous substances.

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Documents

Attachment K Residuals Management Plan Consent of ... · 15th December 2014 For inspection ... We disclaim any responsibility to the client and others in respect of any matters outside