KMK METALS RECYCLING LTD., MOATE ROAD, KILBEGGAN, CO. … · 2019. 1. 4. · MOATE ROAD, KILBEGGAN, CO. WESTMEATH. REMEDIAL CORRECTIVE ACTION VALIDATION REPORT Newry Office Innovation

KMK METALS RECYCLING LTD.,

MOATE ROAD, KILBEGGAN,

CO. WESTMEATH.

REMEDIAL CORRECTIVE ACTION VALIDATION REPORT

Newry Office Innovation Centre 1 RDC House Green Road

WIN Business Park Carlow

Newry

BT35 6PH Tel: 059 91 33084

Fax: 059 91 40499 Tel: 048 302 57974 Email: [email protected]

JRP Integrated Engineering Ltd

Registered Office: Innovation Centre, Green Road, Carlow

Company Registration No. 519448

Directors: P McShane BEng(Hons) MIEI J Keohane BSc MSc C.Geol FCIWEM MIEI RR Matthews BSc CEng FICE

Associate: E Fitzpatrick BSc, MSc, PGeo N O’Malley BEng (Hons) MIEI S Furlong MIPA

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IE Consulting Excavation RCA Validation Report

KMK Metals Recycling Ltd 20‐12‐18

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Document Control Sheet

Project Title KMK Kilbeggan Environmental Remediation

Report Title

Remedial Corrective Action Validation Report

Report Reference IE1616-3024

Version A

Issue Date 20th December 2018

Document Production / Approval Record

Name

Signature

Date

Position

% Input

Prepared by

(consultant)

Conor Lee

BSc MSc

20/12/2018 Hydrogeologist

90%

Approved by

(consultant)

Jer Keohane

BSc MSc CGeol FCIWEM

20/12/2018 Technical

Director

10%

Status

Report Status

First Draft

Distribution

Organisation

Contact

Format

Copies

KMK Metals Recycling Ltd

QED Engineering Ltd

EPA

Olivia Brennan

PDF copy 1

Copyright © IE Consulting 2018

This report or its contents must not be reproduced for any purpose without written permission.

It is to be used only for the purpose for which it is supplied

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KMK Metals Recycling Ltd i 20‐12‐18

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TABLE OF CONTENTS

FIGURES

Figure 1 Regional Location Map (Drawing No IE1616‐01‐A)

Figure 2 Window Sample & Groundwater Well locations (Drawing No IE1616‐02‐A)

Figure 3 July Sampling Locations (Drawing No IE1616‐03‐A)

Figure 4 September Sampling Locations (Drawing No IE1616‐04‐A)

Figure 5 September Sampling Locations (Drawing No IE1616‐05‐A)

DRAWINGS

Drawing 1 Groundwater Contour Map (water levels is m AOD)

TABLES

Table 1 Detection of Mineral Oils & Hydrocarbons in WS‐4

Table 2 Site History from 1974 to Present

Table 3 Validation soil sample results (24th July 2018)

Table 4 Validation soil sample results (24 September 2018) Table 5 Volume of Material and Waste Excavated during the July and September 2018

excavations (IE Data)

APPENDICES

Appendix A Figures

Appendix B Borehole Logs Appendix C Soil Sampling Results Appendix D Photos Appendix E Laboratory Cerrtificates of Analyses Appendix F LQM/CIEH Suitable for Use Levels (S4ULs) for Petroleum Hydrocarbons for the

commercial land use at 1%, 2.5% and 6% soil organic matter (SOM) Appendix G Haulage and Waste Disposal Tickets

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KMK Metals Recycling Ltd 1 20‐12‐18

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1. INTRODUCTION

1.1. Project Contractual Basis & Parties Involved

IE Consulting was requested by KMK Metals Recycling Ltd. to generate a Remedial Corrective Action

Validation Report with respect to the Total Petroleum Hydrocarbons (TPH) soil contamination

identified at the KMK Metals Recycling Plant, Kilbeggan, Co. Westmeath (Figure IE1616‐01 in

Appendix A).

This Remedial Corrective Action Validation Report utilises site data compiled during soil excavation

and laboratory soil analyses to support the validation of the recent remedial corrective active works.

1.2. General Introduction

On 20th September 2017, four percussive window sample boreholes were drilled to a maximum

depth of 4 m bgl at the site (i.e. WS1, WS2, WS3 and WS4). Soil sampling was undertaken at the four

window sampling locations (Figure IE1616‐02 in Appendix A). One bulk sample was collected per

window sampling location. Samples were representative of depths of between 0.6 m and 3.0 m bgl.

The samples were couriered to Chemtest Limited Laboratory in Newmarket, U.K for laboratory

analysis. They were analysed for the RILTA suite of parameters which includes leachate, soil and

WAC analysis and is an approved EPA list of parameters.

Visual and olfactory evidence of possible contamination was observed at one location, WS‐4. A

hydrocarbon odour and a slight sheen were noted on the soil core between 0.6 and 2.0 m depth.

1.3. History of the Site

The site history is described below in Table 2.

Company Years Active Activity

Powerscreen Ltd. 1974 ‐ 2006 Manufacturing screening & crushing equipment.

Coen Holdings Ltd. 2006 ‐ 2011 Manufacturing architrave & skirting & some storage of wood.

KMK Metals Recycling ltd 2015 ‐ Present Metal & WEEE recycling

Table 2 Site History from 1974 to Present

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1.4. Generic Assessment Criteria

The soil analysis results taken on the 20th September 2017 were compared to the LQM/CIEH

Commercial guidelines as summarised below. The LQM/CIEH Guidelines 2nd edition was published

in 2009 as a set of generic assessment criteria values and was updated to reflect the significant

changes in human health risk assessment technical guidance (such as the replacement of CLR9 and

10 with SR2 and SR3) and policy since the release of the first edition in 2006.

The 2nd edition includes Generic Assessment Criteria (GAC) for an extended range of 81 substances

including:

• Metals (including beryllium, boron, copper and zinc)

• Total petroleum hydrocarbon fractions (aromatic and aliphatic)

• Polyaromatic hydrocarbons (USEPA 16)

• Chlorinated solvents

• Chlorobenzenes

• Pesticides

• Others

For each substance, GAC have been derived for a range of generic land uses and Soil Organic Matter

contents and all toxicological and physical‐chemical data inputs used in the derivation of the GAC are

presented and discussed in the publication. In the absence of specific Irish values, these values are

generally accepted by the EPA.

1.5. Site Investigations

Table 1 Detection of Mineral Oils & Hydrocarbons in WS‐4

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Total Petroleum Hydrocarbons (1,500 mg/kg) were detected in WS‐4‐1. WS‐4‐1 was sampled

between 0.6 and 1.4 mbgl, indicating shallow soil contamination at this depth.

Laboratory analyses has demonstrated that the three other window sample locations, WS ‐1‐1, WS‐

2‐1 and WS‐3‐1 were free from Total Petroleum Hydrocarbons.

Monitoring well GW3 was drilled downgradient of WS‐4, along the eastern site boundary. Borehole

logs are presented in Appendix C. During drilling, there was no visual or olfactory evidence of any

mineral oils or hydrocarbons in the subsoil. As a result no soil samples were taken from this

borehole, but the observations would suggest that the contamination has not migrated far from the

vicinity of WS‐4 and is most likely contained in a small localised area around WS‐4.

1.6. Report Outline

This report describes corrective action remedial works undertaken at the site between July and

September 2018 and outlines the positive outcome of remedial validation of the remaining soils.

This report presents analytical data obtained from analysis of residual soils located at the base and

walls of the excavation area. The soil has been sampled, analysed and the results interpreted against

the LQM/CIEH Suitable for Use Levels (S4Uls) generic assessment criteria for commercial land use.

Soil sampling results are attached in Appendix B of this report.

Conor Lee of IE Consulting was present on‐site during the remedial corrective action works.

1.7. Project Objectives

The remedial work comprised excavation of contaminated soil from the area around WS‐4. Though

the TPH levels in the soil did not exceed the generic assessment criteria, this corrective action work

would limit the potential vertical and lateral migration of hydrocarbons off the site.

The remedial validation work will help demonstrate that the excavation area is not or will not pose

an unacceptable risk to the overburden aquifer with respect to TPH’s (See section 1.8).

1.8. Conceptual Site Model

During window sampling, water was encountered at shallow depths (0.12 – 1.8 mbgl). During

borehole drilling, minor water strikes were encountered in the overburden in GW2 and GW3 in the

east and southeast of the site (Figure 1, below). Borehole logs are presented in Appendix B. In all

three wells, the main water strikes occurred in the weathered bedrock. Two weeks after well

installation, when dipped, the water level in the wells was very shallow (0.82 – 1.48 mbgl). As the

wells were screened in the bedrock, this would suggest that the aquifer is confined or at least semi‐

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confined. Based on groundwater levels and survey levels obtained on 23rd October 2017, it would

appear that water is flowing in a southeasterly direction, towards the River Brosna (Drawing 1,

below). There appears to be perched groundwater in the shallow subsurface at the site. Layers of

gravelly soil were found which contain water starting at depths of between 3.8 – 5.0 mbgl. It is not

known if these gravel bands are in lateral continuity across the site or if they exist as separate

pockets of gravel at the site that are not in hydraulic continuity. This perched water is separated

from the water in the bedrock by clay confining layers.

Drawing 1 Groundwater Contour Map (water levels is m AOD)

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2.0 Detailed Scope of Works

The remedial excavation work involved the following scope of works;

The site works were undertaken on 11 May 2018. A mechanical excavator excavated around the

area around WS‐4. Near WS‐4 there is a drain running between the building in KMK and the building

in the site adjacent to the site (Figure IE1616‐05 in Appendix A). This drain was lined with cemented

blocks and its base was concrete. It was filled with rounded gravel (Photo 1 in Appendix D).

This drain was 1.1 m wide and runs from the KMK building to past the site boundary to the east.

Workers on site stated that this drain originally contained pipes which transported hydraulic oil

between the two buildings. Upon excavation of around this drain, it became apparent that this drain

was a source of hydrocarbon contamination, with both olfactory and visual evidence of

hydrocarbons. The contamination appeared to be seeping from the base of the drain, where the

block walls met the concrete base at c. 0.66 mbgl (Photo 2 in Appendix D).

A four metre long trench was excavated along the external drain walls, on the north and south side,

and it became apparent that this contamination ran along the length of the base of the drain. It was

decided by KMK and the Hydrogeologist from IE Consulting that the way forward would be to

excavate out the drain between the factory wall and the site boundary, a length of 14.4 m, and any

contaminated soil from below the drain, and to the north, south, east and west of where the drain

was. This was decided because it was evident that the drain was the source of the contamination,

and removing it and any surrounding contamination in the soil would remove the TPH in the soil in

this area of the site.

Excavation of the drain and contaminated soils was undertaken on 24th July 2018. A 7 tonne

excavator used a jackhammer to break up the reinforced concrete at the surface, and the walls and

base of the drain (Photo 3 & 4 in Appendix D). A bucket was then used by the excavator to remove

the concrete and block rubble (Photo 5 in Appendix D).

The excavator then scraped off any visual evidence of residual contamination from the walls of the

exaction and from the pit. The final depth of the excavation ranged from approximately 0.99 to 1.12

mbgl. The removed soil and rubble was removed by Enva to their Portlaoise depot as hazardous

waste (EWC code 17 05 03). The excavation stopped at the site boundary, but the drain continues

into the adjacent site. At the end of the excavation there was visual and olfactory evidence of

hydrocarbons seeping from the drain in the adjacent site into the excavated pit (Photo 6 in Appendix

D).

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It was decided that partition would be put against the drain at the site boundary and then the drain

would be filled in with cement the other side of the partition (Photo 7). This would prevent the

potential migration of hydrocarbons from the adjacent site back into the KMK site. This means that

there is most likely residual contamination in the adjacent site, owned by Irish Water Jet Profiles Ltd.

Four soil validation samples (SS‐1 to SS‐4) were taken from inside the excavated pit (Figure IE1616‐

03 in Appendix A) and analysed for the following parameters:

Moisture

Total Organic Carbon

Mineral Oil

Aliphatic TPH >C5‐C6








Total Aliphatic Hydrocarbons

Aromatic TPH >C5‐C7








Total Aromatic Hydrocarbons

Total Petroleum Hydrocarbons

Benzene

Toluene

Ethylbenzene

m & p‐Xylene

o‐Xylene

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Laboratory certificates of analysis are presented in Appendix C. The results of the sampling are shown in Table 3, below. TPH’s were detected at SS‐1 (3,800 mg/kg) and SS‐4 (11,000 mg/kg), which were taken from the western wall and the base of the excavation, respectively. These values are below the LQM/CIEH Suitable for Use Levels for the commercial land use, which use 28,000 mg/kg as an acceptable value for TPH concentration in soil. But 11,000 mg/kg is still a high enough concentration that more remedial action was needed. The LQM/CIEH commercial land use scenario generic assessment criteria limit values are provided in Appendix D.

Table 3 Validation soil sample results (24th July 2018)

As there was TPH detected in the samples at relatively high concentrations, subsequent excavation

of residual contamination and soil sampling was undertaken on 24th September 2018. Between

sampling rounds, the pit was covered with tarpaulin to prevent any surface water ingress into the pit

during times of rain.

The objective of the second round of soil analyses was to verify the successful remediation of the

residual contaminated soil. The proposed remedial target values were set at the laboratory limit of

detection (LOD). During the second excavation, the base of the hole was deepened to a depth of

2.55 mbgl from 1.12 mbgl. The four walls of the excavation were scraped back (Photo 7 in Appendix

SS-1 SS-2 SS-3 SS-4Determ inand Units LODMoisture % 0.020 15 14 17 17Total Organic Carbon % 0.20 0.25 1.3 0.23 0.38Mineral Oil mg/kg 10 3200 < 10 < 10 8200Aliphatic TPH >C5-C6 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C6-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C8-C10 mg/kg 1.0 9.1 < 1.0 < 1.0 7.3Aliphatic TPH >C10-C12 mg/kg 1.0 95 < 1.0 < 1.0 110Aliphatic TPH >C12-C16 mg/kg 1.0 740 < 1.0 < 1.0 1700Aliphatic TPH >C16-C21 mg/kg 1.0 880 < 1.0 < 1.0 2100Aliphatic TPH >C21-C35 mg/kg 1.0 1500 < 1.0 < 1.0 4100Aliphatic TPH >C35-C44 mg/kg 1.0 36 < 1.0 < 1.0 220Total Aliphatic Hydrocarbons mg/kg 5.0 3200 < 5.0 < 5.0 8200Aromatic TPH >C5-C7 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C7-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C8-C10 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C10-C12 mg/kg 1.0 16 < 1.0 < 1.0 49Aromatic TPH >C12-C16 mg/kg 1.0 200 < 1.0 < 1.0 820Aromatic TPH >C16-C21 mg/kg 1.0 140 < 1.0 < 1.0 580Aromatic TPH >C21-C35 mg/kg 1.0 270 < 1.0 < 1.0 760Aromatic TPH >C35-C44 mg/kg 1.0 < 1.0 < 1.0 < 1.0 160Total Aromatic Hydrocarbons mg/kg 5.0 620 < 5.0 < 5.0 2400Total Petroleum Hydrocarbons mg/kg 10.0 3800 < 10 < 10 11000Benzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0Toluene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0Ethylbenzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0m & p-Xylene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0o-Xylene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Sample Location:

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D) and the soil was stockpiled, where it was to be removed by Enva to their Portlaoise depot as

hazardous waste (EWC code 17 05 03).

Five soil samples were taken, one from each wall and one from the base of the excavation (Figure

IE1616‐03 in Appendix A). They were analysed for the Rilta Suite. Table 4 below highlights that TPH’s

were not detected above the laboratory LOD in any of the validation soil samples.

Table 4 Validation soil sample results (24 September 2018)

As part of the reinstatement process, the excavated trench was filled with clean soil and stones

obtained from a stockpile located at the western part of the site. Full reinstatement of the concrete

surface will occur in the near future when the entire concrete surface will be resurfaced.

S1 S2 S3 S4 S5Determ inand Units LODMoisture % 0.020 12 17 16 22 17Total Organic Carbon % 0.20 0.30 < 0.20 < 0.20 0.42 < 0.20Mineral Oil mg/kg 10 < 10 < 10 < 10 < 10 < 10Aliphatic TPH >C5-C6 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C6-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C8-C10 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C10-C12 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C12-C16 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C16-C21 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C21-C35 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C35-C44 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Total Aliphatic Hydrocarbons mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0Aromatic TPH >C5-C7 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C7-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C8-C10 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C10-C12 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C12-C16 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C16-C21 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C21-C35 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C35-C44 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Total Aromatic Hydrocarbons mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0Total Petroleum Hydrocarbons mg/kg 10.0 < 10 < 10 < 10 < 10 < 10Benzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Toluene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Ethylbenzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0m & p-Xylene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0o-Xylene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

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3.0 System Performance – Soil Excavation and Contaminated Soil Stockpiling

3.1. Remedial Target Values

The excavation area site investigations demonstrate that the soil within the excavated area

consisted of Made Ground (Sandy CLAY), sandy SILT with cobbles and firm brown SILT.

IE Consulting propose that the Laboratory LOD’s are utilised as remedial target values.

LQM/CIEH Commercial Land Use scenario suitable for use levels are the most applicable to the site.

The LQM/CIEH commercial land use scenario generic assessment criteria limit values are provided in

Appendix D.

The commercial land use scenario generic assessment criteria remedial target values were achieved

in both rounds of soil sampling and during window sampling, with no hydrocarbons above the

laboratory LOD being detected in the second round of soil sampling.

3.2. Successful Remedial Corrective Action

The corrective action programme is considered to be successful based on the following justification;

The former hydrocarbon contaminated area no longer contains volumes of total

petroleum hydrocarbons over the laboratory LOD.

The successful corrective action programme has resulted in the excavation of approximately 140 m3

of material. This included reinforced concrete, contaminated concrete blocks and concrete slab,

contaminated soil and clean soil. This material was removed by Enva and brought to their Portlaoise

Depot. Table 5 below shows the description and volume of material removed during the July and

September excavations. The haulage and waste disposal tickets are presented in Appendix F.

Year Type EWC Approximate Quantity M3

July 2018 Soil and concrete Waste ‐ Hazardous 17 05 03140 m3

Sept 2018 Soil Waste ‐ Hazardous 17 05 03

Table 5 Volume of Material and Waste Excavated during the July and September 2018 excavations (IE Data)




No long‐term monitoring and aftercare management plan is required for the area. There is no

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downgradient shallow groundwater monitoring location at the site. GW3 is downgradient of the

remediated area but it is screened between depths of between 14.7 and 24.0 mbgl. Therefore, it is

not in hydraulic continuity with the layers that contained the hydrocarbon contamination. KMK have

applied to the EPA for an Industrial Emissions (IE) Licence, Reg No. P1076‐01, for the Kilbeggan site.

This application is being processed by the EPA so is not issued yet. It is expected that this licence,

when issued, will also have a condition for annual groundwater monitoring. This, however, would

not be for the specific purpose of monitoring hydrocarbon contamination in relation the remediated

area at the site.

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4.0 Monitoring Results

The remedial action plan did not require any additional soil or groundwater monitoring during the

remedial excavations. There is no soil or groundwater monitoring planned for downgradient of the

remediated area. As part of the reinstatement process, the excavated trench was filled with clean

soil and stones obtained from a stockpile located at the western part of the site. Full reinstatement

of the concrete surface will occur in the near future when the entire concrete surface will be

resurfaced.

As the results from the second round of sampling returned hydrocarbon values all below the

laboratory LOD, we believe that this is satisfactory evidence that the contamination has been

removed from the area.

4.1. Generalised Groundwater Quality Review – Bedrock

There are three groundwater monitoring wells screened in the bedrock at the site (GW1, GW2 and

GW3). GW2 is downgradient of the remediated area. However, as described in Section 1.7, the

bedrock aquifer is not in hydraulic continuity with the shallow soil, and therefore GW2 is not a

suitable monitoring point to determine whether any hydrocarbons have migrated downgradient in

the shallow soil. There was no visual or olfactory evidence of hydrocarbon contamination on the

southern wall of the excavated pit, and no hydrocarbons were detected above laboratory LOD in the

sample taken from the southern wall (S2) in the second sampling round. This would suggest the

hydrocarbons did not migrate further than the excavated area.

4.2. Surface Water Quality Review

There are no current surface water monitoring points or compliance points located downgradient of

the former excavation area.

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5.0 Verification –Soil Analyses of Excavation Area

5.1. Excavation Area

The excavation area around the drain was 14.4m in length. In the western side of the pit it was 4.5 m

wide and in the centre and eastern side it was 3.5 m wide. After the second round of excavating the

pit base was 2.55 m bgl. The pit consisted of:

0 – 0.16 m bgl: Reinforced concrete

0.16 – 0.30 m bgl: MADE GROUND – Brown sandy clay with cobbles.

0.30 – 2.4 mbgl: Brown gravelly sandy SILT with occasional cobbles.

2.4 – 2.55: Brown firm SILT.

5.1.1. Validation Soil Analyses – TPH

There were no incidences where TPH was detected above the various soil generic assessment

criteria remedial target values. Specifically, the LQM/CIEH S4Uls commercial limit values at 1% soil

organic matter were not exceeded by any of the validation soil samples in either of the sampling

rounds, or in the original window samples at WS‐4. While in the first excavation and sampling event

in July, there were some hydrocarbons detected above the laboratory LOD, the second sampling

event in August returned all hydrocarbon values below the laboratory LOD.

5.1.2. Overall Quality Summary

The soils remaining in the walls and in the base of the excavated pit contain un‐contaminated soil

and stones. These soils have been validated by sampling and accredited laboratory soil analyses.

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IE1616

Draft 1‐0

6.0 Reinstatement




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IE1616

Draft 1‐0

7.0. AFTERCARE AND POTENTIAL IMPACT OF THE REMEDIATED AREA

As all five samples from the second round of soil sampling showed hydrocarbons to be below the

laboratory LOD, it is expected that the remediation area will have a negligible impact on soil quality

in its vicinity.

7.1. Medium Term Monitoring

There is no intention for medium term monitoring of soil or groundwater downgradient of the

remediated area to occur.

7.2. Long Term Monitoring

There is no intention for long term monitoring of soil or groundwater downgradient of the

remediated area to occur.

7.3. Aftercare of Former Remediated Area

No aftercare management of the remedial excavations is required.

7.4. Final Cap – No Requirement

A concrete cap will be placed on the reinstated pit when the entire site is being resurfaced.

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IE1616

Draft 1‐0

8.0 Liaison with the Regulator and Third Parties

This report will be submitted to the Agency by KMK Metals Recycling Limited. The adjacent

landowners Irish Jet Profiles Ltd should be notified that there may be residual contamination in the

section of drain running onto their property.

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IE1616

Draft 1‐0

9.0 Conclusions and Recommendations

1. Remedial works were successfully completed at the excavation area and validated by site

investigations and soil sampling;

2. The objectives of the corrective action programme were completed effectively and the corrective

action will negate the potential risk of hydrocarbons to migrate off site;

3. An aftercare management programme is not currently deemed necessary for the remediated

area;

4. It is recommended that surface water and groundwater monitoring is undertaken as per the EPA

licence.

Respectfully submitted

On behalf of IE Consulting

Conor Lee

Jer Keohane

Hydrogeologist

B.Sc. MSc

Project Manager

MSc BSc CGeol MIEI

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Appendix A

Figures

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Project Title:

Project Address:

Client:

Drawing Title:

Drg. Scale: Date: Dwg No: Job No: Revision: Dwg. By:

IE Consulting, Innovation Centre, Green Road, Carlow Ph: 059 913 3084 Fax: 059 914 0459 Email: [email protected]

Site Boundary

Kilbeggan

M6

To Tullamore


KMK, Moate Road, Kilbeggan, Co. Westmeath

KMK Metals Recycling Ltd.

Figure 1: Regional Location Map

NTS 5/12/2018 IE1616‐01 IE1616 A CL

R446 Road

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Project Title:

Project Address:

Client:

Drawing Title:






Figure 2: Window Sample & Groundwater Well Location

NTS 5/12/2018 IE1616‐02 IE1616 A CL

EPA Licence Boundary

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Project Title:

Project Address:

Client:

Drawing Title:






Figure 3: July Sampling Locations (Plan View)

NTS 5/12/2018 IE1616‐03 IE1616 A CL

SS‐2 (North Wall)

SS‐3 (South Wall)

SS‐1 (West Wall) SS‐4 (Base)

14.4 m

3.5 m 4.5 m

KMK Build

ing

Adjacen

t Site Excavated Drain

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Project Title:

Project Address:

Client:

Drawing Title:






Figure 4: September Sampling Locations (Plan View)

NTS 5/12/2018 IE1616‐04 IE1616 A CL

S1 (North Wall)

S2 (South Wall)

S3 (West Wall) S4 (Base)

14.4 m

3.5 m 4.5 m

KMK Build

ing

Adjacen

t Site

S5 (East Wall)

Excavated Drain

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Drain

KMK Building

Adjacent Site Building

Project Title:

Project Address:

Client:

Drawing Title:






Figure 5: Drain Location

NTS 5/12/2018 IE1616‐05 IE1616 A CL

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Appendix B

Borehole Logs

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EPA Export 04-01-2019:03:33:43

Air Rotary 3/10/2017 KMK Kilbeggan

KMK Metals 67.735 E 632676 N 735875

Continued on Next Page

Stephan Petersen Drilling. Drawn by CL.

160 mm

20.0 mbgl IE1464

Site: Date: Method:

Client: maOD of GL:: Coordinates: Diameter mm:

Description of Strata Legend Depth Installation Installation Details

Borehole Log

GW1

Sheet 1 of 2

‐0.5

‐1.5

‐2.5

‐3.5

‐4.5

‐5.5

‐6.5

‐7.5

‐8.5

‐9.5

‐10.5

‐11.5

‐12.5

‐1.0

‐2.0

‐3.0

‐4.0

‐5.0

‐6.0

‐7.0

‐8.0

‐10.0

‐11.0

‐12.0

‐13.0

‐9.0

‐0.44

‐3.0

Concrete

Grey sandy gravelly FILL. Gravel coarse grained. Lots of cobbles. Sand medium to coarse grained. Gravel and cobbles angular to sub angular.

Water strike @ 10.8 mbgl at the Interface.

Light grey weathered LIMESTONE. Some quartz veining and orange staining.

Drilled & Logged By: Drill Depth: Job No.:

Flush Cover at Ground Level Standpipe Casing: 0‐11.3 mbgl. 50mm ø ID. Standpipe Screen: 11.3‐20 mbgl. 50mm ø ID. Concrete: 0‐0.5 mbgl. Grout: 0.5‐10.8 mbgl. Sand: 10.8 – 11.1 mbgl. Gravel Pack: 11.1‐20.0 mbgl. Geotextile Sock: 11.3‐20.0. mbgl. End Cap @ base.

Fill

Limestone

‐0.62

Dark grey sandy gravelly very soft SILT. Sand medium to coarse grained. Gravel fine grained. Gravel subangular to subrounded. Wet. Becomes very wet at 4.0m. Gravel band at 5.50m.

‐8.3

Dark brown stiff sandy gravelly CLAY. Gravel subrounded. Sand medium grained. Dry. At 9.0 m, gravel % decreases and sand % increases and becomes medium to coarse grained.

‐10.8

Major Water strike @ 12.3 mbgl at the Interface.

Concrete ‐0.90

Light brown/grey sandy gravelly clayey FILL. Sand medium to coarse grained. Gravel subangular to subrounded. Some yellow lenses.

‐1.30

Brown very sandy CLAY. Sand fine to medium grained. Some yellow lenses. Damp.

No return

Light grey competent LIMESTONE. Some orange staining.

‐12.3

Light grey weathered LIMESTONE. Some orange staining.

Dipped groundwater level at 0.81 mbgl No evidence of contamination

Clay

Silt

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KMK Metals ????? 160mm

20.0 mbgl IE1464

Site: Date: Method:



Borehole Log

GW1

Sheet 2 of 2

‐13.5

‐14.5

‐15.5

‐16.5

‐17.5

‐18.5

‐19.5

‐20.5

‐21.5

‐22.5

‐23.5

‐24.5

‐25.5

‐14.0

‐15.0

‐16.0

‐17.0

‐18.0

‐19.0

‐20.0

‐21.0

‐22.0

‐23.0

‐24.0

‐25.0

‐26.0


‐15.2

Flush Cover at Ground Level Standpipe Casing: 0‐5.5 mbgl. 50mm ø ID. Standpipe Screen: 5.5‐17 mbgl. 50mm ø ID. Concrete: 0‐0.5 mbgl. Grout: 0‐5.0 mbgl. Sand: 5.0 – 5.3 mbgl. Gravel Pack: 5.3‐17.0 mbgl. Geotextile Sock: 5.5‐17. mbgl. End Cap @ base.

E??????? N?????????

Dark grey Competent Limestone

‐17.0

‐17.2 Weathered Zone

End of Hole 20 mbgl

Dipped groundwater level at 0.81 mbgl No evidence of contamination Stephan Petersen Drilling.

Drawn by CL.

Fill

Limestone

Concrete

Clay

Silt

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KMK Metals 67.74 E 632732 N 735797



160 mm

24.0 mbgl IE1464

Site: Date: Method:



Borehole Log

GW2

Sheet 1 of 2

‐0.5

‐1.5

‐2.5

‐3.5

‐4.5

‐5.5

‐6.5

‐7.5

‐8.5

‐9.5

‐10.5

‐11.5

‐12.5

‐1.0

‐2.0

‐3.0

‐4.0

‐5.0

‐6.0

‐7.0

‐8.0

‐10.0

‐11.0

‐12.0

‐13.0

‐9.0

‐0.22

‐4.0


Grey, very sandy gravelly soft CLAY. Sand coarse grained. Gravel subangular to subrounded. Decrease in % of sand from 12m. Increase in % of clay and sand from 13m. Stifness increases from 13.5m.


Flush Cover at Ground Level Standpipe Casing: 0‐14.8 mbgl. 50mm ø ID. Standpipe Screen: 14.8‐24.0 mbgl. 50mm ø ID. Concrete: 0‐0.5 mbgl. Grout: 0.5‐14.3 mbgl. Sand: 14.3 – 14.6 mbgl. Gravel Pack: 14.6‐24.0 mbgl. Geotextile Sock: 14.8‐24.0. mbgl. End Cap @ base.

Fill

Limestone

‐7.9 Brown sandy gravelly CLAY. Sand medium to coarse grained. Gravel angular to subrounded. Damp.

‐9.0

Concrete

‐1.15


Clay

Silt

Grey sandy gravelly clayey FILL. Sand medium to coarse grained. Gravel angular to subangular.

‐0.15

Brown slightly sandy gravelly clayey FILL. Clay firm. Sand medium grained. Some grey lenses. Damp.

‐5.0 Brown sandy clayey GRAVEL bands throughout the silt. Gravel angular to subrounded. Sand coarse grained

‐11.2

Gravel

Boulders


Concrete

‐2.3 Brown sandy BOULDERS. Sand medium to coarse. Wet.

‐2.6

Soft sandy gravelly CLAY. Sand medium to coarse grained. Wet.

Dark brown/grey very soft sandy clayey SILT. Sand medium to coarse grained. Wet.

Wet grey sandy GRAVEL. Sand coarse grained. Gravel subrounded to subangular. Increased % of clay from 10m.

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24.0 mbgl IE1464

Site: Date: Method:



Borehole Log

GW2

Sheet 2 of 2

‐13.5

‐14.5

‐15.5

‐16.5

‐17.5

‐18.5

‐19.5

‐20.5

‐21.5

‐22.5

‐23.5

‐24.5

‐25.5

‐14.0

‐15.0

‐16.0

‐17.0

‐18.0

‐19.0

‐20.0

‐21.0

‐22.0

‐23.0

‐24.0

‐25.0

‐26.0


‐14.3

E??????? N?????????

Dark grey weathered LIMESTONE. Some orange staining. Some quartz veins. Brown clay infill.

End of Hole 24 mbgl

No evidence of contamination Stephan Petersen Drilling.

Drawn by CL.

Clay infill becomes yellow colour.

Clay infill becomes tan brown colour.

Clay infill becomes dark brown colour.

Fill

Limestone

Concrete

Clay

Silt

Gravel

Boulders


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KMK Metals 67.71 E 632704 N 735728



160 mm

24.0 mbgl IE1464

Site: Date: Method:



Borehole Log

GW3

Sheet 1 of 2

‐0.5

‐1.5

‐2.5

‐3.5

‐4.5

‐5.5

‐6.5

‐7.5

‐8.5

‐9.5

‐10.5

‐11.5

‐12.5

‐1.0

‐2.0

‐3.0

‐4.0

‐5.0

‐6.0

‐7.0

‐8.0

‐10.0

‐11.0

‐12.0

‐13.0

‐9.0

‐0.47

‐3.8

Concrete

Light brown gravelly sandy clayey FILL. Sand medium to coarse grained. Gravel subangular to subrounded. Occasional cobbles.


Dark grey angular to subrounded gravel. Very wet. Inceasing % sand from 14m. Sand medium to carse grained.



Fill

Limestone

Dark grey limestone BOULDERS. Quartz veining. Wet.

‐8.0

Dark grey firm sandy CLAY. Sand medium to coarse grained. Gravel % increases from 9.0m.

‐10.0

Concrete

‐1.09

‐12.3


Clay

Silt

Grey sandy gravelly FILL. Sand coarse grained. Gravel angular to subangular. ‐0.22

Golden brown sandy GRAVEL. Sand medium to coarse grained. Gravel fine to medium grained. Damp. Becomes less sandy and more gravelly at 2.0m.

‐4.8 Brown soft sandy gravelly CLAY. Sand medium to coarse grained. Gravel subrounded to subangular. Wet.

Brown very soft sandy SILT. Sand medium to coarse grained. Occasional fine gravel. Very wet.

‐11.0

Gravel

Boulders Water strike @ 3.8 mbgl at the Interface.


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EPA Export 04-01-2019:03:33:44



20.0 mbgl IE1464

Site: Date: Method:



Borehole Log

GW3

Sheet 2 of 2

‐13.5

‐14.5

‐15.5

‐16.5

‐17.5

‐18.5

‐19.5

‐20.5

‐21.5

‐22.5

‐23.5

‐24.5

‐25.5

‐14.0

‐15.0

‐16.0

‐17.0

‐18.0

‐19.0

‐20.0

‐21.0

‐22.0

‐23.0

‐24.0

‐25.0

‐26.0


‐14.2

E??????? N?????????

Dark grey weathered LIMESTONE. Some orange staining. Brown clay infill throughout.

‐17.0

‐17.2 Clay infill becomes dark brown colour.

End of Hole 24 mbgl

Dipped groundwater level at 0.81 mbgl No evidence of contamination Stephan Petersen Drilling.

Drawn by CL.

Clay infill becomes yellow/brown colour.

Clay infill becomes cream colour.

Dark grey competent LIMESTONE. Some orange staining.

Fill

Limestone

Concrete

Clay

Silt

Gravel

Boulders


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EPA Export 04-01-2019:03:33:44

Appendix C

Soil Sampling Results

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EPA Export 04-01-2019:03:33:44

Client: QED Engineering 18-22172 18-22172 18-22172 18-22172 18-29454 18-29454 18-29454 18-29454 18-29454Quotation No.: Q18-11861 660243 660244 660245 660246 695576 695577 695578 695579 695580Order No.: SS-1 SS-2 SS-3 SS-4 1 2 3 4 5

1 2 3 4 S1 S2 S3 S4 S5SOIL SOIL SOIL SOIL SOIL SOIL SOIL SOIL SOIL

Determinand Accred. SOP Units LODMoisture N 2030 % 0.020 15 14 17 17 12 17 16 22 17Total Organic Carbon U 2625 % 0.20 0.25 1.3 0.23 0.38 0.30 < 0.20 < 0.20 0.42 < 0.20Mineral Oil N 2670 mg/kg 10 3200 < 10 < 10 8200 < 10 < 10 < 10 < 10 < 10Aliphatic TPH >C5-C6 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C6-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C8-C10 U 2680 mg/kg 1.0 9.1 < 1.0 < 1.0 7.3 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C10-C12 U 2680 mg/kg 1.0 95 < 1.0 < 1.0 110 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C12-C16 U 2680 mg/kg 1.0 740 < 1.0 < 1.0 1700 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C16-C21 U 2680 mg/kg 1.0 880 < 1.0 < 1.0 2100 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C21-C35 U 2680 mg/kg 1.0 1500 < 1.0 < 1.0 4100 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic TPH >C35-C44 N 2680 mg/kg 1.0 36 < 1.0 < 1.0 220 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Total Aliphatic Hydrocarbons N 2680 mg/kg 5.0 3200 < 5.0 < 5.0 8200 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0Aromatic TPH >C5-C7 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C7-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C10-C12 U 2680 mg/kg 1.0 16 < 1.0 < 1.0 49 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C12-C16 U 2680 mg/kg 1.0 200 < 1.0 < 1.0 820 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C16-C21 U 2680 mg/kg 1.0 140 < 1.0 < 1.0 580 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C21-C35 U 2680 mg/kg 1.0 270 < 1.0 < 1.0 760 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic TPH >C35-C44 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 160 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Total Aromatic Hydrocarbons N 2680 mg/kg 5.0 620 < 5.0 < 5.0 2400 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0Total Petroleum Hydrocarbons N 2680 mg/kg 10.0 3800 < 10 < 10 11000 < 10 < 10 < 10 < 10 < 10Benzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Toluene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Ethylbenzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0m & p-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0o-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Sample Type:Date Sampled: 24-Jul-2018 24-Sep-2018

Project: IE1616 KMK Kilbeggan

Chemtest Job No.:Chemtest Sample ID.:

Client Sample Ref.:Client Sample ID.:

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Appendix D

Photos

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EPA Export 04-01-2019:03:33:44

Photo 1 Drain running between KMK Building and Adjacent Site

Photo 2 Hydrocarbon contamination on exterior drain wall outlined in red

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Photo 3 Jack Hammer breaking up the drain walls

Photo 4 Jack Hammer breaking up reinforced concrete hardstanding

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Photo 5 Excavator removing rubble and soil from void

Photo 6 Open drain at boundary between KMK site and adjacent site.

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Photo 7 Partition in drain at boundary between KMK site and adjacent site

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EPA Export 04-01-2019:03:33:44

Appendix E

Laboratory Certificates of Analysis

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EPA Export 04-01-2019:03:33:44

Chemtest Ltd.

Depot Road

Newmarket

CB8 0AL

Tel: 01638 606070

Email: [email protected]

Report No.: 18-22172-1

Initial Date of Issue: 09-Aug-2018

Client QED Engineering

Client Address: M-TEK Building 1

Armagh Road

Monaghan

Ireland

Contact(s): Patricia Murtagh

Project IE1464 KMK Kilbeggan

Quotation No.: Q18-11861 Date Received: 26-Jul-2018

Order No.: Date Instructed: 26-Jul-2018

No. of Samples: 4

Turnaround (Wkdays): 5 Results Due: 01-Aug-2018

Date Approved: 01-Aug-2018

Approved By:

Details: Martin Dyer, Laboratory Manager

Final Report

Page 1 of 4

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EPA Export 04-01-2019:03:33:44

Results - Soil

Client: QED Engineering 18-22172 18-22172 18-22172 18-22172

Quotation No.: Q18-11861 660243 660244 660245 660246

Order No.: SS-1 SS-2 SS-3 SS-4

1 2 3 4

SOIL SOIL SOIL SOIL

24-Jul-2018 24-Jul-2018 24-Jul-2018 24-Jul-2018

Determinand Accred. SOP Units LOD

Moisture N 2030 % 0.020 15 14 17 17

Total Organic Carbon U 2625 % 0.20 0.25 1.3 0.23 0.38

Mineral Oil N 2670 mg/kg 10 3200 < 10 < 10 8200

Aliphatic TPH >C5-C6 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Aliphatic TPH >C6-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Aliphatic TPH >C8-C10 U 2680 mg/kg 1.0 9.1 < 1.0 < 1.0 7.3

Aliphatic TPH >C10-C12 U 2680 mg/kg 1.0 95 < 1.0 < 1.0 110




Aliphatic TPH >C35-C44 N 2680 mg/kg 1.0 36 < 1.0 < 1.0 220

Total Aliphatic Hydrocarbons N 2680 mg/kg 5.0 3200 < 5.0 < 5.0 8200

Aromatic TPH >C5-C7 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Aromatic TPH >C7-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Aromatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Aromatic TPH >C10-C12 U 2680 mg/kg 1.0 16 < 1.0 < 1.0 49




Aromatic TPH >C35-C44 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 160

Total Aromatic Hydrocarbons N 2680 mg/kg 5.0 620 < 5.0 < 5.0 2400

Total Petroleum Hydrocarbons N 2680 mg/kg 10.0 3800 < 10 < 10 11000

Benzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Toluene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Ethylbenzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

m & p-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0

o-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0


Chemtest Job No.:

Chemtest Sample ID.:

Client Sample Ref.:

Client Sample ID.:

Sample Type:

Date Sampled:

Page 2 of 4

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EPA Export 04-01-2019:03:33:44

Test Methods

SOP Title Parameters included Method summary

2030

Moisture and Stone Content of

Soils(Requirement of

MCERTS)

Moisture content

Determination of moisture content of soil as a

percentage of its as received mass obtained at

<37°C.

2625 Total Organic Carbon in Soils Total organic Carbon (TOC)

Determined by high temperature combustion

under oxygen, using an Eltra elemental

analyser.

2670Total Petroleum Hydrocarbons

(TPH) in Soils by GC-FID

TPH (C6–C40); optional carbon banding, e.g. 3-

band – GRO, DRO & LRO*TPH C8–C40Dichloromethane extraction / GC-FID

2680 TPH A/A Split

Aliphatics: >C5–C6, >C6–C8,>C8–C10,

>C10–C12, >C12–C16, >C16–C21, >C21–

C35, >C35– C44Aromatics: >C5–C7, >C7–C8,

>C8– C10, >C10–C12, >C12–C16, >C16– C21,

>C21– C35, >C35– C44

Dichloromethane extraction / GCxGC FID

detection

2760

Volatile Organic Compounds

(VOCs) in Soils by Headspace

GC-MS

Volatile organic compounds, including BTEX

and halogenated Aliphatic/Aromatics.(cf.

USEPA Method 8260)*please refer to UKAS

schedule

Automated headspace gas chromatographic

(GC) analysis of a soil sample, as received,

with mass spectrometric (MS) detection of

volatile organic compounds.

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EPA Export 04-01-2019:03:33:44

Report Information

Key

U UKAS accredited

M MCERTS and UKAS accredited

N Unaccredited

S This analysis has been subcontracted to a UKAS accredited laboratory that is accredited for this analysis

SN This analysis has been subcontracted to a UKAS accredited laboratory that is not accredited for this analysis

T This analysis has been subcontracted to an unaccredited laboratory

I/S Insufficient Sample

U/S Unsuitable Sample

N/E not evaluated

< "less than"

> "greater than"

Comments or interpretations are beyond the scope of UKAS accreditation

The results relate only to the items tested

Uncertainty of measurement for the determinands tested are available upon request

None of the results in this report have been recovery corrected

All results are expressed on a dry weight basis

The following tests were analysed on samples as received and the results subsequently corrected to a dry

weight basis TPH, BTEX, VOCs, SVOCs, PCBs, Phenols

For all other tests the samples were dried at < 37°C prior to analysis

All Asbestos testing is performed at the indicated laboratory

Issue numbers are sequential starting with 1 all subsequent reports are incremented by 1

Sample Deviation Codes

A - Date of sampling not supplied

B - Sample age exceeds stability time (sampling to extraction)

C - Sample not received in appropriate containers

D - Broken Container

E - Insufficient Sample (Applies to LOI in Trommel Fines Only)

Sample Retention and Disposal

All soil samples will be retained for a period of 45 days from the date of receipt

All water samples will be retained for 14 days from the date of receipt

Charges may apply to extended sample storage

If you require extended retention of samples, please email your requirements to:

[email protected]

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EPA Export 04-01-2019:03:33:44

mailto:[email protected]

Chemtest Ltd.

Depot Road

Newmarket

CB8 0AL

Tel: 01638 606070

Email: [email protected]

Report No.: 18-29454-1

Initial Date of Issue: 02-Oct-2018

Client QED Engineering

Client Address: M-TEK Building 1

Armagh Road

Monaghan

Ireland

Contact(s): Patricia Murtagh

Project IE1616 KMK Kilbeggan

Quotation No.: Q18-11861 Date Received: 26-Sep-2018

Order No.: Date Instructed: 26-Sep-2018

No. of Samples: 5

Turnaround (Wkdays): 5 Results Due: 02-Oct-2018

Date Approved: 02-Oct-2018

Approved By:

Details: Robert Monk, Technical Manager

Final Report

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EPA Export 04-01-2019:03:33:44

Results - Soil

Client: QED Engineering 18-29454 18-29454 18-29454 18-29454 18-29454

Quotation No.: Q18-11861 695576 695577 695578 695579 695580

1 2 3 4 5

S1 S2 S3 S4 S5

SOIL SOIL SOIL SOIL SOIL

0.90 1.30 1.20 0.00 1.40

24-Sep-2018 24-Sep-2018 24-Sep-2018 24-Sep-2018 24-Sep-2018

Determinand Accred. SOP Units LOD

Moisture N 2030 % 0.020 12 17 16 22 17

Total Organic Carbon U 2625 % 0.20 0.30 < 0.20 < 0.20 0.42 < 0.20

Mineral Oil N 2670 mg/kg 10 < 10 < 10 < 10 < 10 < 10

Aliphatic TPH >C5-C6 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0


Aliphatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0






Total Aliphatic Hydrocarbons N 2680 mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0

Aromatic TPH >C5-C7 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0


Aromatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0






Total Aromatic Hydrocarbons N 2680 mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0

Total Petroleum Hydrocarbons N 2680 mg/kg 10.0 < 10 < 10 < 10 < 10 < 10

Benzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Toluene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Ethylbenzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

m & p-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

o-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0


Top Depth (m):

Chemtest Job No.:

Chemtest Sample ID.:

Client Sample ID.:

Sample Type:

Date Sampled:

Sample Location:

Page 2 of 4

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EPA Export 04-01-2019:03:33:44

Test Methods

SOP Title Parameters included Method summary

2030

Moisture and Stone Content of

Soils(Requirement of

MCERTS)

Moisture content

Determination of moisture content of soil as a

percentage of its as received mass obtained at

<37°C.

2625 Total Organic Carbon in Soils Total organic Carbon (TOC)

Determined by high temperature combustion

under oxygen, using an Eltra elemental

analyser.

2670Total Petroleum Hydrocarbons

(TPH) in Soils by GC-FID

TPH (C6–C40); optional carbon banding, e.g. 3-

band – GRO, DRO & LRO*TPH C8–C40Dichloromethane extraction / GC-FID

2680 TPH A/A Split

Aliphatics: >C5–C6, >C6–C8,>C8–C10,

>C10–C12, >C12–C16, >C16–C21, >C21–

C35, >C35– C44Aromatics: >C5–C7, >C7–C8,

>C8– C10, >C10–C12, >C12–C16, >C16– C21,

>C21– C35, >C35– C44

Dichloromethane extraction / GCxGC FID

detection

2760

Volatile Organic Compounds

(VOCs) in Soils by Headspace

GC-MS

Volatile organic compounds, including BTEX

and halogenated Aliphatic/Aromatics.(cf.

USEPA Method 8260)*please refer to UKAS

schedule

Automated headspace gas chromatographic

(GC) analysis of a soil sample, as received,

with mass spectrometric (MS) detection of

volatile organic compounds.

Page 3 of 4

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EPA Export 04-01-2019:03:33:44

Report Information

Key

U UKAS accredited

M MCERTS and UKAS accredited

N Unaccredited

S This analysis has been subcontracted to a UKAS accredited laboratory that is accredited for this analysis

SN This analysis has been subcontracted to a UKAS accredited laboratory that is not accredited for this analysis

T This analysis has been subcontracted to an unaccredited laboratory

I/S Insufficient Sample

U/S Unsuitable Sample

N/E not evaluated

< "less than"

> "greater than"

Comments or interpretations are beyond the scope of UKAS accreditation

The results relate only to the items tested

Uncertainty of measurement for the determinands tested are available upon request

None of the results in this report have been recovery corrected

All results are expressed on a dry weight basis

The following tests were analysed on samples as received and the results subsequently corrected to a dry

weight basis TPH, BTEX, VOCs, SVOCs, PCBs, Phenols

For all other tests the samples were dried at < 37°C prior to analysis

All Asbestos testing is performed at the indicated laboratory

Issue numbers are sequential starting with 1 all subsequent reports are incremented by 1

Sample Deviation Codes

A - Date of sampling not supplied

B - Sample age exceeds stability time (sampling to extraction)

C - Sample not received in appropriate containers

D - Broken Container

E - Insufficient Sample (Applies to LOI in Trommel Fines Only)

Sample Retention and Disposal

All soil samples will be retained for a period of 45 days from the date of receipt

All water samples will be retained for 14 days from the date of receipt

Charges may apply to extended sample storage

If you require extended retention of samples, please email your requirements to:

[email protected]

Page 4 of 4

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EPA Export 04-01-2019:03:33:44

mailto:[email protected]

Appendix F

LQM/CIEH Suitable for Use Levels (S4ULs) for

Petroleum Hydrocarbons for the commercial land use

at 1%, 2.5% and 6% soil organic matter (SOM)

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Commercial land use

1% SOM 2.5% SOM 6% SOM

Aliphatic EC 5‐6 3200 5900 12000

Aliphatic EC > 6‐8 7800 17000 40000

Aliphatic EC > 8‐10 2000 4800 11000

Aliphatic EC > 10‐12 9700 23000 47000

Aliphatic EC > 12‐16 59000 82000 90000

Aliphatic EC > 16‐35 1600000 1700000 1800000

Aliphatic EC > 35‐44 1600000 1700000 1800000

Aromatic EC 5‐7 (benzene) 26000 46000 86000

Aromatic EC > 7‐8 (toluene) 56000 110000 180000

Aromatic EC > 8‐10 3500 8100 17000

Aromatic EC > 10‐12 16000 28000 34000

Aromatic EC > 12‐16 36000 37000 38000

Aromatic EC > 16‐21 28000 28000 28000

Aromatic EC > 21‐35 28000 28000 28000

Aromatic EC > 35‐44 28000 28000 28000

Aliphatic + Aromatic EC > 44‐70 28000 28000 28000

LQM/CIEH S4ULs for Petroleum Hydrocarbons (mg kg‐1 DW)

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Appendix G

Haulage and Waste Disposal Tickets

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EPA Export 04-01-2019:03:33:45

0001337229INVOICE

PORTLAOISE - CORK - SHANNON - DUBLIN

Enva Ireland Limited, Clonminam Ind Est, Portlaoise, Co Laois, R32 XD95, 057 8678600

Page 1 of 1

KMK001

30


Killbeggan

EUR

Our Order No. 0007102872

Account No.

VAT Exempt No.

Date

Currency

Cr Terms Days

Delivery Method

WTF RefCappincur Ind. Estate

Daingean Road

Tullamore

Co. Offaly

31-Jul-2018


IE 4534857 E

Customer POINVOICE NAME & ADDRESS

DELIVERY ADDRESS

Total PriceTotal VatVAT %Total NettUnit PriceInv QtyProduct DescriptionProduct codeItem

1 P1.HAULAGE Collection and Transport of

Contaminated Soil

5.00 200.00 1,000.00 23.00 230.00 1,230.00

1,230.00

230.00

1,000.00

Invoice Total EUR

Total VAT

Sub-totalVAT Summary

Total Nett VAT % Total Vat Total Price 1,000.00 23.00 230.00 1,230.00

30-Aug-2018Payment Due By

Enva Ireland Limited

Registered No: 317186 VAT No: IE 6337186AClonminam Industrial Estate, Portlaoise, Co. Laois, Ireland

Tel: 057 8678600 - Fax 057 8678699 - Email: [email protected] -

www.enva.com

Title of the goods does not pass until payment is received in full but risk in the goods shall

pass to the Buyer upon delivery.

All goods are supplied in accordance with our standard terms and conditions of sale -

see http://enva.com/termsandconditions

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EPA Export 04-01-2019:03:33:45

0001337218INVOICE

PORTLAOISE - CORK - SHANNON - DUBLIN

Enva Ireland Limited, Clonminam Ind Est, Portlaoise, Co Laois, R32 XD95, 057 8678600

Page 1 of 1

KMK001

30


Killbeggan

EUR

Our Order No. 0007102872

Account No.

VAT Exempt No.

Date

Currency

Cr Terms Days

Delivery Method

WTF RefCappincur Ind. Estate

Daingean Road

Tullamore

Co. Offaly

31-Jul-2018


IE 4534857 E

Customer POINVOICE NAME & ADDRESS

DELIVERY ADDRESS

Total PriceTotal VatVAT %Total NettUnit PriceInv QtyProduct DescriptionProduct codeItem

1 P1.SOIL Treatment and collection of

contaminated soil of 8244T @

€60.00p/t.

82.44 60.00 4,946.40 13.50 667.76 5,614.16

5,614.16

667.76

4,946.40

Invoice Total EUR

Total VAT

Sub-totalVAT Summary

Total Nett VAT % Total Vat Total Price 4,946.40 13.50 667.76 5,614.16

30-Aug-2018Payment Due By

Enva Ireland Limited

Registered No: 317186 VAT No: IE 6337186AClonminam Industrial Estate, Portlaoise, Co. Laois, Ireland

Tel: 057 8678600 - Fax 057 8678699 - Email: [email protected] -

www.enva.com

Title of the goods does not pass until payment is received in full but risk in the goods shall

pass to the Buyer upon delivery.

All goods are supplied in accordance with our standard terms and conditions of sale -

see http://enva.com/termsandconditions

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EPA Export 04-01-2019:03:33:46

Documents

KMK METALS RECYCLING LTD., MOATE ROAD, KILBEGGAN, CO. … · 2019. 1. 4. · MOATE ROAD, KILBEGGAN, CO. WESTMEATH. REMEDIAL CORRECTIVE ACTION VALIDATION REPORT Newry Office Innovation