annual environmental report · cadbury ireland ltd rathmore facility comprises of a main processing...

ANNUAL ENVIRONMENTAL REPORT

2009

for

Licence No. P0795-01

Cadbury Ireland Limited

Rathmore,

Co. Kerry

P0-795-01|Cadbury Rathmore AER 2009

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CONTENTS

1 INTRODUCTION

1.1 Licensee Details 2

1.2 Description of Site Activities 2

1.3 Company Environmental Policy (Overview) 2

1.4 Company Environmental Management Structure 3

1.5 Company Environmental Management Organisational Chart 3

2 SUMMARY INFORMATION

2.1 Self Monitoring Data 4

2.2 Agency Monitoring and Enforcement 7

2.3 Energy & Water Consumption 7

2.3 Environmental Incidents and Complaints 8

2.4 AER Summary Data table 8

3 MANAGEMENT OF THE ACTIVITY

3.1 Schedule of Environmental Objectives & Targets 8

3.2 Environmental Management Programme Report (for 2009) 10

3.3 Environmental Management Programme Proposal (for 2010) 16

3.4 Other Significant Environmental Aspects, Audits etc 21

4. LICENCE-SPECIFIC REPORTS

4.1 Noise Monitoring report summary 22

4.2 Tank and pipeline testing and inspection report 22 4.3 Report on the assessment of the efficiency of use of raw materials in processes and the reduction of waste generated 22 4.4 Report on progress made and proposals being developed to minimise water demand and the volume of trade effluent discharge 23 4.5 Environmental Liabilities Risk Assessment (ELRA) Review 23

APPENDICES

Appendix A: AER Summary Data Tables

TABLES

Table 1 Summary Table for Emissions to Water 4 Table 2 Summary of Non-Compliances for Emissions to Water 5 Table 3a Summary Table for Mass Emissions to Atmosphere 5

Table 3b Summary Table of Pollutant Average Concentrations 5

Table 4 Summary of Non-Compliances for Emissions to Atmosphere 5

Table 5 Summary information of waste arisings 6

Table 6 Summary information of waste streams 6

Table 7 Summary of EPA v Self Monitoring Data _________________________________ 7

Table 8 Energy Consumption 7

Table 9 Water Consumption 7

Table 10 Schedule of Environmental Objectives & Targets 9

Table 11 Summary 2009 EMP 11

Table 12 Environmental Management Programme (EMP) 2010 17

Table 13 Summary of Project Schedule 21


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1 INTRODUCTION 1.1 Licensee Details License Register Number: P0795-01 Licensee: Cadbury Ireland Limited Location of Installation Shinnagh, Rathmore, County Kerry

1.2 Description of Site Activities

The Cadbury Ireland Ltd, Rathmore installation manufactures milk chocolate crumb which is an intermediate

product utilised in the production of milk chocolate. Production of milk chocolate crumb involves pasteurisation

and evaporation of milk followed by the addition of sugar to form Sweetened Concentrated Milk (SCM). Butteroil

may also be added depending on the recipe and required fat concentrations. Liquid cocoa mass is then added to

form a paste. Raw and in-process materials are stored in tanks and silos on site. Off-specification product may also

be reworked into the process at this stage. The paste is then cooked and fed to an air drier or one of three vacuum

driers, prior to cooling. The resulting crumb is then weighed and packed into 1,150 kg bulk bags, or sent to the bulk

storage silos on site. There is also a milling process which may be employed to reduce the particle size of the

crumb where required. The control of the entire process is highly automated.

Cadbury Ireland Ltd Rathmore facility comprises of a main processing facility with associated buildings, storage structures and wastewater treatment plant.

1.3 Company Environmental Policy

Key policy objectives are as follows:

We will: 1. Strive to prevent pollution and minimise the environmental impacts of our operation, working with our

supply chain and business partners to reduce our collective environmental footprint and protect the ecosystems that provide our raw materials.

2. Guarantee that our customers and consumers come first by actively listening to and understanding their expectations of our brands.

3. Reinforce our commitment to sustainability and safeguard the reputation of Cadbury through regular engagement with internal and external stakeholders.

4. Maintain a zero waste culture that consistently embraces environmental sustainability where everyone understands their responsibilities and accountabilities.

5. Operate audited environmental management systems that continually improve our processes to deliver this policy and any associated standards and ensure compliance with prevailing legislation.

6. Assign clear management accountability for setting, monitoring performance against and meeting measurable targets for environmental performance.

7. Communicate openly and regularly in line with international good reporting practice


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8. Place continuous improvement at the heart of our performance through assessment of the environmental

performance of new and existing products and processes.

9. Create a passion for sustainability where success and achievement are recognised, communicated and celebrated.

10. Review and update this policy and any associated standards regularly ensuring that it continues to reflect our values and the expectations of key stakeholders.

1.4 Company Environmental Management Structure

Cadbury Ireland Ltd, Rathmore has a structured management approach to the operation of the business in terms

of product quality, process control, environment and safety.

The Head of Manufacturing has the overall responsibility for environmental management and control at the

Rathmore Installation.

The Quality and Environment (Q&E) Manager, as designated Environmental Representative, has responsibility

for day-to-day environmental management at the Rathmore Installation.

Shift Managers are responsible for ensuring day-to-day environmental requirements are met.

All staff at the facility have are responsible to ensure the environmental requirements are met.

1.5 Cadbury Rathmore Environmental Management Organisational Chart

Head of Manufacturing

Production and

maintenance

personnel

Laboratory &

Security Personnel

Quality & Environment (QE) Manager

WWTP Personnel

Production Shift

Managers

Site Leadership

Team

External

Contractors


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2 SUMMARY INFORMATION

The information presented here is for the calendar year 1st

January 2009 to 31st

December 2009.

2.1 Self Monitoring Data

2.1.1 Emissions to Water

Cadbury Ireland Rathmore is licensed for emissions to water. There is one emission point from the wastewater

treatment plant (SW1), discharging treated effluent to the River Blackwater. This emission point has been

monitored and analysed in accordance with requirements of Schedules B2 and C2.2 of the facilities IPPC Licence.

There are two licensed storm water emission points (SW2 and SW3) that indirectly discharge on-site storm water

to the River Blackwater. There are no license limits applied to these emission points however water quality is

assessed on a daily basis and analysed weekly in accordance with Schedule C2.3 and for additional parameters

stipulated in the Agency’s Site Inspection Report of February 2008.

Up until June 2009 water analysis was largely carried out in house at the on-site micro and chemistry laboratory by

fully trained and competent personnel. Parameters not tested on-site were sent to an independent external

laboratory for analysis. In June 2009, Cadbury Rathmore committed to comprehensive laboratory validation

programme. From June 2009 to December 2009 all self monitoring water emission samples were sent to an

independent external laboratory for testing while validation was in process.

There were five incidents of non-compliance associated with emission limit values for emissions to water during

2009. All were reported to the Agency and appropriate incidence investigation and corrective action was

undertaken.

Table 1: Summary Table for Emissions to Water

PARAMETER FINAL EFFLUENT DISCHARGE PT SW1

(2007)

FINAL EFFLUENT DISCHARGE PT SW1

(2008)

FINAL EFFLUENT DISCHARGE PT SW1

(2009)

EMISSION LIMIT VALUE

Volume 483.8 m3 512.2 m

3 483.4 m

3 900 m

3

Temp 10.89 10.9 14.6 25 maximum

pH 8.3 8.2 8.5 6 – 9

BOD 11.08 mg/l 17.14 mg/l 6.33 mg/l 40 mg/l

COD 73.98 mg/l 63.39 mg/l 42.7 mg/l 125 mg/l

Suspended Solids 27.66 mg /l 21.85 mg/l 17.75mg/l 50 mg/l

Total Nitrogen 3.33 mg/l 6.42 mg/l 8.45 mg/l 15 mg/l

Total Ammonia 0.17 mg/l 0.33 mg/l 0.4 mg/l 10 mg/l

Detergents 0.03 mg/l 0.02 mg/l 0.01mg/l 2 mg/l

Oils, Fats, Greases <10 mg/l <10 mg/l <10 mg/l 10 mg/l

Orthophosphate 2.13 kg / day 1.70 kg/day 0.33 kg/day 1.08kg/day *

Total Phosphorus 2.34 kg / day 1.95 kg /day 0.43 kg /day 1.17kg/day **

Toxicity n/a <2.2 n/a 5 TU

Note: This emission data is based upon the averaged monitoring data available for the facility. * Limit of 5.06 kg/day for orthophosphate applied before 5/12/08 ** Limit of 5.5 kg/day for total phosphorus applied before 5/12/08 *** Nitrate nitrogen as N


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Table 2: Summary of Non-Compliances for Emissions to Waters

DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION

10 April 2009 Reportable exceedence of ELV for orthophosphate

Known increased plant loading – specific cause unknown

In advance of known increase demand on system increase ferric dosing

15 April 2009 Reportable exceedence of ELV for phosphorous and orthophosphate

Excessive CIP in advance of boiler shutdown and poor control of holding tank levels resulting in by-pass of phosphorous treatment system

Level probe installed on balance tank to ensure tank levels are kept within a manageable range and reoccurrence of by-pass prevented

20 April 2009 Reportable exceedence of ELV for nitrogen

Cause undermined following investigation

Continuing investigation into origins of nitrogen

29 July 2009 Reportable exceedence of ELV for nitrogen

Cause undermined following investigation

Continuing investigation into origins of nitrogen

11 December 2009 Reportable exceedence of ELV for nitrogen

Run-off control barrier damaged during construction activities resulting in contamination of WWTP stone bed system

Run-off control barrier replaced. Protocol established for more rigorous monitoring of all further construction activities.

2.1.2 Emissions to Air

Licensed emissions to the atmosphere are in the form of combustion emissions. There have been no changes to

the type of fuel used (heavy fuel oil) to date. Air emissions monitoring from the combustion process are carried

out twice annually to licence requirements by independent contractors. There were no exceedences of licence

emission limit values for emissions to air.

Table 3a: Summary Table for Mass Emissions to Atmosphere

PARAMETER MASS EMISSION (2007)

MASS EMISSION (2008)

MASS EMISSION (2009)

Oxides of Sulphur 67419 kg / year 51997 kg/year 45654 kg/year

Nitrogen Oxides 29972 kg/year 30331 kg/year 29772 kg/year

Table 3b Summary Table of Pollutant Average Concentrations

CONCENTRATION May (2009)

CONCENTRATION November (2009)

EMISSION

LIMIT VALUE Boiler A1-1 Boiler A1-2 Boiler A1-1 Boiler A1-2

Oxides of Sulphur 1099 mg/m3 1159 mg/m

3 1141 mg/m

3 1108 mg/m

3 1700 mg/m

3

Nitrogen Oxides 698 mg/m3 800 mg/m

3 800 mg/m

3 651 mg/m

3 900 mg/m

3

NOTE: Mass emission figures for each year (as reported in the electronic AER) have been calculated from average

concentrations as measured against quantity of heavy fuel oil consumed. Average concentrations are measured are also

provided for comparison with the Emission Limit Values as given in the licence.

Table 4: Summary of Non-Compliances for Emissions to Atmosphere

DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION

There were no non-compliances associated with emissions to air


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2.1.3 Waste Arisings

Cadbury Ireland Rathmore is licensed to monitor waste sludge arising from the on-site wastewater treatment plant

facility. Sludge is tested annually and results are submitted to the Agency. A summary of all waste streams and

the management of waste arisings is presented in Tables 5 and 6 below.

Table 5: Summary information of waste arising

ITEM TONNES/ANNUM 2007

TONNES/ANNUM 2008

TONNES/ANNUM 2009

Total quantity of waste produced in calendar year

- Total quantity of waste disposed of on-site

- Total quantity of waste disposed of off-site

- Total quantity of waste recovered on-site

- Total quantity of waste recovered off-site

387.27 t

None

61.76 t

None

325.51 t

2195.86 t

None

1821.48 t

None

374.38 t

791.601t

None

303.325t

None

488.276t

Quantity of non-hazardous waste produced in calendar year

- quantity of non-hazardous waste disposed of on-site

- quantity of non-hazardous waste disposed of off-site

- quantity of non-hazardous waste recovered on-site

- quantity of non-hazardous waste recovered off-site

365.96 t

None

61.76 t

None

304.20 t

1727.72 t

None

1493.42 t

None

234.3 t

695.84t

None

284.88t

None

410.96

Quantity of hazardous waste produced in calendar year

- quantity of hazardous waste disposed of on-site

- quantity of hazardous waste disposed of off-site

- quantity of hazardous waste recovered on-site

- quantity of hazardous waste recovered off-site

21.31 t

None

None

None

21.31 t

468.14 t

None

328.06 t

None

140.08 t

95.761t

None

18.445t

None

77.316t


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Table 6: Summary information of waste streams

EWC CODE DESCRIPTION OF WASTE HAZ YES/NO

QUANTITY (T/A) 2008

QUANTITY (T/A) 2009

METHOD OF

DISPOSAL/RECOVERY

WASTE SOURCE WASTE TYPE

02 05 02 wastes from the dairy products industry

sludges from on-site effluent treatment

No 236 323.18 R10

02 05 01 Wastes from the dairy products industry

Materials unsuitable for consumption or processing

No n/a 4.32 R10

13 07 01 wastes of liquid fuels - fuel oil and diesel Yes n/a 10.76 R1

13 07 03 wastes of liquid fuels - other fuels (including mixtures) Yes n/a 48.26 R1

13 08 02 oil wastes not otherwise specified

other emulsions Yes n/a 9.22 R1

15 01 01 packaging (including separately collected municipal packaging waste)

paper and cardboard packaging No 4 6.24 R3


mixed packaging No n/a 18.18 R13


packaging containing residues of or contaminated by dangerous substances

YES n/a 0.06 R4/R5

15 02 02 absorbents, filter materials, wiping cloths and protective clothing

absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances

Yes 4 5.665 R1/D10

16 05 06 gases in pressure containers and discarded chemicals

laboratory chemicals, consisting of or containing dangerous substances, including mixtures of laboratory chemicals

Yes 0.05 0.044 D9

17 02 01 wood, glass and plastic wood No n/a 3.74 R3

17 04 07 metals (including their alloys)

Mixed metals No 14.3 59.04 R4

17 05 03 soil (including excavated soil from contaminated sites), stones and dredging spoil

soil and stones containing dangerous substances

Yes 324 2.9 R5

17 06 05 Insulation materials and asbestos-containing construction materials

construction materials containing asbestos

Yes n/a 17.64 D1

17 09 04 other construction and demolition waste

mixed construction and demolition

wastes other than those mentioned

in 17 09 01, 17 0902 and 17 09 03.

No n/a 221.16 D1

20 01 21 Municipal wastes -separately collected fractions

fluorescent tubes and other mercury-containing waste

Yes 0.0136 t 0.191 R5 / R4

20 03 01 Other municipal wastes

mixed municipal waste No 59 57.54 D1


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2.2 Agency Monitoring and Enforcement

2.2.1 Site Inspection

The EPA audited the site on one occasion in 2009. This was a schedule visit undertaken on 23 April 2009. One

non-compliance and several observations were noted on the day of inspection. Corrective action was undertaken

and all audit findings were appropriately addressed to the satisfaction of the Agency.

2.2.2 Emissions Monitoring The EPA collected samples from the final effluent discharge point SW1 for analysis on two separate occasions

during 2009. The collection dates were 1 April 2009 and 29 September 2009. There were notable differences

between self monitoring data and that of the Agency but there were no exceedences of emission limit values. The

most considerable differences between the recorded results are highlighted in Table 7.

Table 7: Summary of EPA Analysis v Self Monitoring Data

Parameter Self Monitoring Agency Emission Limit Value

BOD (1 April 2009) 5.5 25.5 40 mg/l Suspended Solids (1 April 2009) 50 37.2 50 mg/l COD (29 Sept 2009) 21.5 12 125 mg/l

2.3 Energy & Water Consumption Summary

2.3.1 Energy Consumption

Energy usage on site associated with production is largely fuel combusted in boilers to produce steam for the

thermal requirements of the site and electricity supplied to site, primarily for motive power. In addition to the

direct requirements of the manufacturing process energy is consumed on site for ancillary requirements such as

supply of well water, waste water treatment, tanker cleaning, loading and unloading of delivery vehicles,

compressed air production etc. Cadbury Ireland Rathmore used Heavy Fuel Oil as the main combustion fuel in

2009. Electricity used on site was obtained from the national grid. Water is sourced both from on-site wells and

municipal supply. Diesel usage is for the emergency generator. LPG usage is for the fork truck fleet and for

heating of some process lines during annual shut-down. Overall energy use fell in 2009 compared to 2008. A

focus on energy efficiency projects together with changes in the boiler system has helped the decrease in energy

usage on site.

Table 8: Energy Consumption Summary

ITEM 2007 2008 2009

Heavy Fuel Oil 3,892.67 tonnes 3,667.1 tonnes 3,457.94tonnes

Diesel 0.23 tonnes 0.23 tonnes 0.23 tonnes

LPG 8.9 tonnes 9.32 tonnes 7.85 tonnes

Electricity 6,925,255 kWh 6,449,854 kWh 6,424,000 kWh


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2.3.2 Water Consumption

The majority Municipal water is supplied by Kerry County Council. There has been a significant reduction in the

volume of municipal water used on-site in 2009 compared to volumes used in 2008. This is principally due to

improvements made to increase the efficiency of abstraction from on-site wells thus reducing the requirement for

additional supply. Overall water usage on site fell by 4% in 2009 compared to 2008 figures as a result of on-site

water conservation initiatives undertaken during the year.

Table 9 Water Consumption Summary

ITEM 2007 2008 2009

On-site ground water 135,638 m3 122,550 m

3 114,613 m

3

Municipal Supply 1497 m3 1017 m

3 403 m

3

2.4 Environmental Incidents and Complaints

There were no reportable incidences at the site during 2009.

No complaints were received during the year 2009.

2.5 AER Summary Data Tables

See Appendix A

3. MANAGEMENT OF THE ACTIVITY

3.1 Schedule of Environmental Objectives & Targets

The schedule of Environmental Objectives and Targets for Cadbury Rathmore was developed in 2008 to address a

five year period up to 2012. Environmental Targets and Objectives took into account compliance with all

conditions and schedules of the IPPC licence and the company’s financial, operational and business requirements.

The schedule shows that a total of 13 project areas were considered and that 39 schemes/actions had been

programmed for completion before 2012.

The schedule of Objectives and Targets was reviewed in December 2008 as part of the 2008 AER. The 5-year

Programme was reviewed and revised forward to incorporate a Programme for the next 5 years; Year 2 (2009) to

Year 6 (2013). The schedule of Objectives and Targets has again been reviewed in December 2009. Revisions to

this schedule principally relate to the reprioritizing of targets and review of timeframes for achieving targets.


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TABLE 10 Schedule of Environmental Objectives & Targets (Revised for period 2010 - 2014)

PROJECT OBJECTIVES TARGETS

Stormwater

Management

Improve storm water discharge quality to

ensure no soil, surface water or

groundwater contamination as a result of

stormwater discharges from the site

Improvements in stormwater quality through improvements to on-site collection

and filtrations system by 2012

Water Resource

Management

Improve water conservation Maintain or improve on the 4% reduction on 2008 volumes of water use per tonne of finished product

Wastewater

Management

Improve wastewater quality discharge to



wastewater discharges from the site

Improvements in wastewater treatment system by December 2010

Improvements in process water/foul drains by 2012

Emissions to waters from the wastewater treatment plant shall not exceed emission limit values outline in table B.2.2 of Schedule B of the facilities IPPC licence

No substance shall be discharged in a manner or at a concentration that following initial dilution causes tainting of fish or shellfish

Energy Use Reduce Installations Energy consumption

+ Increase the use of renewable energy

to improve energy efficiency

All findings and recommendations of the 2008 Energy Audit survey to be implemented and\or achieved by 2013

Power Generation Reduce Installations use of conventional

power generation

Evaluate the options of running the boilers on alternative renewable fuels by

2012.

Fuel & Chemical

Storage

No soil, surface water or groundwater

contamination as a result of fuel or

chemical storage on-site

All tanks, containers and drum storage areas shall be rendered impervious to

the materials stored therein according to the 2009 Tank Testing Schedule.

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

via remote bunding by end 2010.

Waste

Management

Reduce hazardous and non-hazardous

waste and improve recovery, reuse and

recycling of waste material

Reduce the environmental impact of the

Installations waste

a) Waste Generation: Reduce the volume of waste generated at the Installation

b) Waste Handling: No soil, surface water or groundwater contamination as a result of waste collection or disposal

c) Waste Storage: No soil, surface water or groundwater contamination as a result of waste storage

Develop schedule for improvements by March 2010 (schedule will include

quantifiable objectives).

All routes for recycling to be investigated with a view to recycling 100% of

recyclable material by January 2011

Waste Generation – set target for reducing the volume of non-recyclable waste

generated at the Installation by end 2010.

Waste Handling – Waste sent-off site for recovery or disposal shall be

transported only by authorised waste contractors ( Licensed or permitted). - All

waste to be disposed of at a licensed or permitted facility

Waste Storage – Waste shall be stored in designated areas protected against

spillage and leachate run-off

Air Emissions Operations & activities at the facility shall

not result in the release of significant

levels of pollutants to the atmosphere

Emissions to the atmosphere from the installation shall not exceed emission limit

values set out in the IPPC licence

Emission of oxides of sulphur shall not exceed 1700mg/m3

Emissions of nitrogen oxides (as NO2) shall not exceed 900mg/m3

No emissions of offensive odours outside the boundaries of the premises.

Noise Emissions Noise generated on-site shall not impact

the amenity of neighbouring properties

Noise from the installation shall not give rise to sound pressure levels (Leq, T)

,measured at sensitive locations of the installation which exceed the limit value(s)

of 55dB(A) for Daytime noise and 45dB(A) for night-time noise


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Table 10ctd Cadbury Rathmore - Schedule Of Environmental Objectives & Targets (Revised for period 2009 - 2014)

PROJECT OBJECTIVES TARGETS

Fugitive Emissions Reduce fugitive emissions plant wide to



fugitive emissions from the site

Establish the losses from all on-site activities through fugitive emissions by 2012.

Develop a schedule for improvements (including quantifiable targets) by 2014.

Goods

Consumption

Reduce the facilities overall raw materials

resource consumption per tonne of

finished product

Material processing: Reduce, where possible, the losses of food materials in all

processes; while being mindful of possible food safety limitations. Target – that

annual ingredient losses (specifically raw crumb materials of milk, sugar, coca

mass and butter oi)l do not exceed 0.5%

Facility &

Equipment

Maintenance

Improve process control (equipment &

management) to reduce waste and

Improve maintenance and calibration of

control and monitoring equipment

to ensure adequate control of plant &

equipment so the hazardous breakdown

is prevented

Investigate downtime on all on-line monitoring equipment and reduce to less

than 5% by 2014

Environmental

Management

System

Make provisions for management of the

activity on a planned basis having regard

to the desirability of ongoing assessment,

recording and reporting of matters

affecting the environment

Existing management system and reporting structure to be continually reviewed

and updated as required

3.2 Environmental Management Programme Report 2009

The following table provides a summary on the programme of works undertaken in accordance with the 2009

environmental management programme (EMP). The summary gives an overview of the success in meeting the

planned targets for 2009.


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Table 11 SUMMARY of ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009

PROJECT TARGETS PROGRAMME/ACTION

REQUIRED

ACHIEVEMENTS V

TARGETS / ACTION

PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Storm Water Management

- Silt trap and oil

separator on

stormwater

discharges

- All pump sumps

storage tanks, or

other treatment plant

chambers from which

spillages of

environmentally

significant materials

might occur shall be

fitted with high liquid

level alarms

- Contaminated

stormwaters currently

discharging to the

ground at the eastern

side of the

installation, discharge

to the Blackwater via

a silt trap and oil

separator

- Suitable monitoring

and diversion

mechanism on the

discharge to ensure

that contaminated

stormwater is

diverted to the on-site

WWTP

- Complete installation of bypass separator on SW2 (Western outfall)

Bypass separator

installed on SW2

n/a n/a

Stormwater drainage systems upgrading – including monitoring + diversion of contaminated stormwater (Phase 1) to include 220m3 monitoring tank

Stormwater Phase 1B –

Monitoring & Diversion

System completed in

August 2009

Delays due to

weather and

difficulties

associated with

working in live

WWTP

n/a

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

Stormwater Phase 1C –

Stormwater/Firewater

Tank commenced

November 2009

Delay in completion

of Phase 1B resulted

in delay to start of

Phase 1C.

Due for Completion

in May 2010

Fit high liquid level alarms at emergency tank and divert tanks

Included in Phosphate

Removal Contract. Not

Complete.

Delay in completion

of Phase 1B resulted


this contract

To be completed in

early 2010.

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

2 no. Full Retention

Separators installed and

commissioned on SW3

n/a n/a

TOC and Hydrocarbon monitors to be installed

TOC and Hydrocarbon

monitors installed and

commissioned

n/a n/a

undertake limited additional testing and survey based on gaps identified in review Continue with upgrading of pipework

Gaps in drainage survey

& testing not complete

Included in Phase

2A Drainage

Contract, which is

due to commence in

early 2010

To be completed

early 2010

Routine monitoring of storm water discharges

Routine monitoring of

stormwater has

commenced

n/a n/a

Ground water sampling and analysis twice per year

Groundwater sampling

has commenced

n/a n/a

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

Not achieved Decision taken at

planning stage that

reuse of firewater is

not appropriate. All

firewater shall be

returned to the

WWTP for

treatment

n/a

Remediation of existing stormwater soakaway at eastern boundary

Existing stormwater

soakaway remediated in

January 2009

n/a n/a

Construct new stormwater outfall as part of upgrading works

New stormwater outfall

completed as part of

Phase 1B

n/a n/a


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Table 11 ctd SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009


REQUIRED

ACHIEVEMENTS V TARGETS /

ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE ACTION

Wastewater Management

Complete WWTP upgrade by December 2009 Phosphorus removal

equipment shall be

installed at the

WWTP. Refer to

Wastewater

Treatment Plant

Assessment for

details.

Foul sewers shall be

remediated as part of

ongoing works.

Monitoring of pH,

flow and temperature

shall be maintained at

the outfall.

TOC monitor and divert mechanism shall be installed at the treated effluent outfall. Refer to Proposals for Stormwater Management report for details.

Install Phosphorus removal equipment at WWTP

Temporary phosphorus removal

system installed at DAF Unit in

January 2009. Permanent system

to be installed in early 2010

Delays in

completion of

Phase 1B resulted


Phosphate

removal Contract

Permanent system to be

installed and

commissioned by March

2010.

Install TOC monitor, divert mechanism and diversion chamber at treated effluent outfall

TOC monitor and divert system

completed August 2009

n\a n\a

Bunding of Tanks + Divert the drain from River

Diversion of drain from river not

completed.

Bunding of tanks - groundwater

monitoring in place to verify

integrity of underground tanks.

Included in

Stormwater Phase

1C

To be completed early

2010

Remediation of Existing balance tanks (Replacement option)

Remediation of existing balance

tank not complete

These works

cannot

commence until

proposed

stormwater /

firewater tank is

in place.

Remediation of Balance

Tank to be carried out in

second half of 2010.

Dispose of sludge build-up from balance tanks

Not achieved Disposal of sludge

to be completed

as part of

remediation of

balance tank

To be carried out in second

half of 2010

Review sludge levels with phosphorous removal equipment installed

Review of sludge levels not

complete

See above Review of sludge levels to

commence in 2010

Survey + Improve WWTP safety + access

Access survey is not complete. Improvements to

WWTP safety &

access are

ongoing as part of

the new

construction

works in Phase 1B

and 1C.

Survey of access to existing

WWTP to be carried out

early 2010.

Continue with upgrading of process/foul drains

1 no. connection/upgrade to

process drain completed in July

2009.

n/a n/a

Routine monitoring at outfall

Routine monitoring at outfall is in

place

n/a n/a


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Table 11 ctd - SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009


REQUIRED

ACHIEVEMENTS V TARGETS /

ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE ACTION

Water Resource Management

Opportunities for

reducing the volume

of on-site water usage

to be identified by

March 2010. Schedule

for improvements to

be devised by October

2010.

Carry out an audit to identify

opportunities for reduction in

the quantity of water used on-

site

Audit undertaken and some

action undertaken

n/a None required

Further investigations into recycling and reuse initiatives options Investigate options for

recycling / reuse of grey water.

The potential for recycling

and reuse options of grey

water in domestic systems

(eg Harvesting of roof water)

was considered but not

investigated.

n/a Further investigations

into this to be

progressed in 2010.

Fit stormwater holding /

firewater retention tank

with connection points to

allow for reuse of water in a

fire event

Not undertaken The proposal to fit the

stormwater holding tank/

firewater retention tank

with connection points to

allow for reuse of water in

a fire event was re

assessed and it was

determined that it would

not be best practice to

reuse firewater in a fire

event

None required

Energy Use

Implement finding of steam trap survey by December 2009 Increase the boiler TDS level on the boilers from 3,000 to 3,500 ppm.

Schedule to be developed by August 2009 through normal in house maintenance, planning and scheduling procedures.

Achieved n/a n/a

Review on basis of concerns

raised by water treatment

company that this target may

not be achievable. Review

additional opportunities for

energy use reduction and

efficiency

Achieved A review of the

recommendation to

increase the boiler TDS

levels from 3,000 to 3,500

ppm determined that this

was not

feasible/achievable

n/a

Power generation

Establish targets for

use of clean energy

technologies

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

Achieved n/a n/a

Waste Management

Establish set targets

for waste reduction Identify areas where waste can be reduced

Achieved n/a Implement schemes

as identified.

Identify areas where recyclable materials can be used (eg returnable containers, supplier packaging etc)

Achieved n/a Implement schemes

as identified.


P a g e | 15

Table 11 - SUMMARY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2009


REQUIRED

ACHIEVEMENTS V

TARGETS / ACTION

PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE ACTION

Fuel & Chemical Storage

i) - All tanks/drum storage to be bunded locally or remotely to a volume of not less than 110% capacity of the largest tank

- Minor remediation as outlined in HFO

assessment report to be carried out

- Caustic + Nitric bunds to be tested

- Assessment of self bunded tanks to be carried out

ii) Investigate the possibility of using spill tray at HFO bund to overcome difficulties of positioning gauge within the bunded area

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

Review requirements for spill kits

+ replace where necessary

Commence works for

local/remote bunding of tanks

+ drums

In progress n/a Continue as planned

commence containment works

for inlets, outlets, vent pipes,

valves and gauges

In processs n/a Continue as planned

Establish schedule for

assessment /integrity testing of

bunds and tanks

Achieved n/a Undertake

assessments as per

schedule

Continue with weekly

inspection and include spill kits

Satisfactory to date –

ongoing

n/a Continue as planned

Air Emissions Emissions to the atmosphere from the installation shall not exceed emission limit values set out in the IPPC licence

Carry out stack emission

monitoring surveys (April +

Sept)

Continue monitoring through daily logs

Achieved n/a n/a

Noise Emissions

Noise from the installation shall

not give rise to sound pressure

levels (Leq, T) ,measured at

sensitive locations of the

installation which exceed the

limit value(s) of 55dB(A) for

Daytime noise and 45dB(A) for

night-time noise

- Carry out boundary noise

survey

- Review Noise Sensitive Locations in proximity to the site

Achieved Noise emissions

at employee

carpark require

investigation

Investigate and

implement necessary

noise control

measures

Fugitive Emissions

Complete the identification of

fugitive emissions from the

facility

Examine the need for catchment

system to collect any leaks from

flanges and valves of overground

pipes.

As per targets Ongoing. Desktop study

was undertaken in 2009

to determine potential

sources of on-site fugitive

emissions

Priority was

afforded to

addressing

known areas of

fugitive emission

Continue with fugitive

emission survey in

2010

Facility & Equipment Maintenance

Establish a comprehensive

programme for planning,

scheduling and tracking

preventative maintenance

activities that provides a

systematic way of ensuring they

are not neglected

Continue with maintenance programme. Review + update if necessary

Achieved n/a Continue with this


P a g e | 16



REQUIRED

ACHIEVEMENTS V

TARGETS / ACTION

PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Goods Consumption

Take all measures required to ensure

no inadvertent losses of ingredients

to drain (e.g. while unloading milk

tankers to silos)

Review unloading systems to ensure

all ingredients captured in system

Monitor ingredients in vs finished

goods out. Monitor effectiveness of

other measures detailed below

Rathmore system is generally set up

to recover within process rather than

loss – but there are a couple of

existing areas where there is no

recovery step built in. All new

equipment to incorporate recovery

step. Manual recovery of material to

take place as far as possible

otherwise

Aim to evaporate all milk on day of

delivery.

Monitor and record condition of any

stored milk in silos.

Monitor condition of all reclaim /

rework in production area

Finalise and approve all

materials procedures

Ongoing This is being

carried out on a

priority basis

Continue as

scheduled

Conduct a root cause

analysis of spills during

2009 that will be

incorporated into a new

training program and

conducting the following

training

- Spill prevention

awareness training for

all plant personnel

- In-depth spill

prevention training for

all raw material handling

personnel

- Spill control training

for all production

personnel (as part of site

Emergency Response

procedure)

All achieved with

exception of training for

some external delivery

personnel

n/a Outstanding

spill prevention

training for raw

material

handling

personnel to be

prioritised in

2010.

Environmental Management System

Management + Reporting Structure Review annually +

update as necessary

Achieved n/a Continue as

planned

Schedule of Environmental

Objectives + Targets

Review annually +

update as necessary


planned

Environmental Management

Programme

Review annually &

update as necessary


planned

Documentation Review annually +

update as necessary


planned

Data Management system Review annually +

update as necessary


planned

Corrective Action Review annually +

update as necessary


planned

Awareness + Training Review annually + update as necessary

Continue with site wide IPPC awareness training throughout 2009

Complete training of Mass Tanker drivers

Achieved

Not achieved

n/a

n/a

Continue as

planned

To be

prioritised

during 2010

Communication Programme Review annually +

update as necessary


planned


P a g e | 17



REQUIRED

ACHIEVEMENTS V

TARGETS / ACTION

PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Environmental

Management

System ctd

Efficient Process Control Continue with Regional

KPI initiative;

Environmental

Governance pack to

address KPI’s in 2009


planned

Accident Prevention Review existing accident prevention procedures

Carry out safety audits to ensure that best practices are maintained

Carry out prompt

emergency repair to

damaged and distressed

plant + equipment


planned

Emergency Response Review annually +

update as necessary


planned

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

ii) PRTR to be submitted to Agency by 31 March


planned

3.3 Environmental Management Programme Proposal 2010

The targets and action programmes for the year are set out on an annual basis at the first Environmental

Management Meeting of the year. The environmental management plan (EMP) for 2010 proposes the

programmes and actions set out in Table 12 below to be undertaken in the coming year.


P a g e | 18

Table 12 CADBURY RATHMORE - ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010

PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME

Stormwater

Management

In line with overall

objectives to improve

storm water discharge

quality and overall

target that these

improvements are

achieved by 2012 the

following targets and

actions are proposed

for 2010

100% of gaps in drainage

survey to be completed

Undertake additional testing and survey

based on gaps identified in previous survey

Contractor

By June 2010

All critical areas

identified as part of the

stormwater drainage

systems upgrading on

site to be completed

Further upgrading of storm water and

process water drains

Contractor

By December

2010

All identified stormwater

monitoring and control

mechanisms to be

installed

(i) Complete installation of 2000m3 holding

tank/firewater retention

Contractor By Sept 2010

(ii) All identified pumps, sumps, storage

tanks or treatment plant chambers from

which spillages of environmentally

significant materials might occur to be

fitted with high liquid level alarms

Contractor By Sept 2010

Water Resource

Management


objective to improve

water conservation

and overall revised

target to maintain or

improve on the 4%

reduction on 2008

volumes of water use

the following targets

and actions are

proposed for 2010

Continue with

identification of

opportunities for

reducing the volume of

on-site water usage

(i) Carry out site wide water balance to drive

future water reduction programmes

Contractor By end 2010

(ii) Analyse water meter data and review

water usage targets

Contractor and

Facility QE Manager

By end 2010

(iii) continue with site in house awareness

training on water usage and water

conservation

Facility QE Manager Ongoing

during 2010

Wastewater

management



wastewater quality

discharges and overall

target that this is to be

achieved by 2012 the



during 2010

Planned WWTP

upgrading works for

2010 to be completed

(i) Further upgrading of foul water drains Contractor Ongoing

during 2010

(ii) Continue with WWTP safety + access

improvements

Contractor Ongoing

during 2010

(iii) Permanent phosphorus removal system

to be completed

Contractor By May 2010

(iv) Commence bunding of divert drain from

river with a view to be completed by

early 2011

Contractor By end 2010 /

2011

(v) Review sludge levels with phosphorus

removal equipment installed

Contractor By end 2010


P a g e | 19

Table 12 ctd - ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010


Energy Use In line with overall

objectives to reduce

the facilities energy

consumption the



during 2010

Findings and

recommendations

of the 2008 Energy

Audit Survey set out

for 2010 to be

achieved

(i) Investigate whether a duct can be

installed for the air supply to the boiler air

intake from the top of the boiler house

Contractor and

Production Manager

by June 2010

(ii) Investigate the option of recuperating

the waste heat from the discharge stream

from dryer 0

Contractor and

Facility Production

Manager

by September

2010

(iii) Investigate whether heat can be

recovered from water going to evaporator

start up/shut down tank, preheat milk to

condenser (Heat Exchanger)

Contractor and

Facility Production

Manager

by December

2010

(iv) Investigate the sequence of operation of

the milling operation so as to utilise the

energy spent as efficiently as possible

Contractor and

Facility Production

Manager

by March

2010

(v) Investigate the feasibility of recovering

the discharge air from the pneumatic

actuators on closure

Contractor and

Facility Production

Manager

by September

2010

(vi) Investigate the possibility of installing a

VSD (reducing impeller trim) on the

distribution pump of Cooling Tower No. 2

Contractor and

Facility Production

Manager

by June 2010

(vii) Investigate the feasibility of reinstating

the steam coil on the heavy fuel oil storage

tank so as to replace the equivalent

electrical counterpart

Contractor and

Facility Production

Manager

by September

2010

(viii) Evaluate whether the operational

pressure of the standby boiler can be

reduced

Contractor and

Facility Production

Manager

by March

2010

Waste

Management


objective to reduce

hazardous and non-

hazardous waste and

improve recovery,

reuse and recycling of

waste materials the



during 2010

100% of identified

recyclable waste to

be recycled

(i) Continue with reducing the volume of

waste going to landfill


during 2010

(ii) Investigate and implement improved

kitchen waste segregation

Facility QE Manager By Sept 2010

(iii) Continue with waste management

training


during 2010

(iv) Review reducing 2009 volumes of

wastewater using COD and TOC monitoring

Contractor and

Facility QE Manager

Ongoing

during 2010

(v) Review targets for waste reduction +

reuse

Facility QE Manager By end 2010


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Table 12 ctd ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010


Fuel & Chemical

Storage


objectives to ensure there

is no contamination as a

result of fuel or chemical

storage on site the



during 2010

All presently

identified

potential risk

area to be

addressed

i) Continue with containment works for inlets,

outlets, vent pipes, valves and gauges

Contractor Ongoing

during 2010

(ii) Review spill kit requirements

Facility QE Manager

Ongoing

during 2010

Air Emission In line with overall

objectives that operations

and activities at the facility

shall not result in releases

of significant pollutants to

the atmosphere the



during 2010

Emissions to

the atmosphere

shall not exceed

emission limit

values set out in

the IPPC

licences

Monitoring as per licence requirements Contractor May 2010

&

October 2010

Noise Emissions In line with overall

objectives that noise

emissions shall not impact

the amenity of

neighbouring properties

the following targets and


during 2010

Noise emissions

associated with

employee

carpark gate to

be mitigated

(i) Install appropriate noise control measures

at employee carpark gate

Contractor By May 2010

(ii) Continue with annual noise survey

Contractor By September

2010

Fugitive

Emissions


objectives to reduce risk of

contamination as a result

of fugitive emissions the


action are proposed during

2010

Continue with

identification of

fugitive

emissions

(i) Prepare a schedule/plan for investigating

fugitive emissions

Facility QE Manager By June 2010

Facility

Equipment and

Maintenance



process control the



during 2010

All key plant

and equipment

for control of

emissions to be

included in

SAPs

Continue with maintenance programme.

Review + update if necessary

Facility

Maintenance

Manager

Ongoing

during 2010

Goods

consumption


objectives to reduce the

facilities overall raw

materials resource

consumption per tonne of

finished product the


action programmes are

proposed during 2010

Maintain 99%

recovery of

ingredients in

verses finished

goods.

(i) Outstanding spill prevention training for

raw material handling personnel to be

prioritised in 2010.

Facility QE Manager By May 2010

(ii) Establish improvements to reduce losses in

the production plant

Facility Production

Manager

By October

2010


P a g e | 21

Table 12 ctd ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010


Environmental

Management

System


objectives to make

provisions for the

management of facility

activities on a planned

basis having regard to the

desirability of ongoing

assessment, recording and

reporting of matters

affecting the environment

the following targets and


during 2010

Management +

Reporting

Structure

Schedule of

environmental

Objectives and

Targets

Environmental

Management

Programme

Documentation

Data

Management

System

Corrective Action

Awareness and

Training

Communication

Programme

Efficient Process

Control

Accident

Prevention

Emergency

Response

Reports

Continue annual review of procedures and

update as necessary

Facility QE Manager By December

2010


P a g e | 22

Table 13 Summary of 2010 Project Schedule

Project Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec

Storm Water Management √ √ √ √ √ √ √ √ √ √ √ √

Water Resource management √ √ √ √ √ √ √ √ √ √ √ √

Wastewater Management √ √ √ √ √ √ √ √ √ √ √ √

Energy Use √ √ √ √ √ √ √ √ √ √ √ √

Power generation √

Waste Management √ √ √ √ √ √ √ √ √ √ √ √

Fuel & Chemical Storage √ √ √ √ √ √

Air Emissions √ √

Noise Emissions √

Fugitive Emissions √

Facility & Equipment Maintenance √

Goods Consumption √ √ √

EMS √ √ √ √ √ √ √ √ √ √ √ √

3.4 Other Significant Environmental Aspects, Audits etc

3.4.1 ISO 14001 EMS Audit

In 2009, Cadbury’s Rathmore ISO 14001-certified EMS underwent an annual audit for its conformance with the

standard and was recommended for continued registration following this evaluation. This audit was undertaken

by the NSAI in October 2009.

3.4.2 Internal Audit

An audit was undertaken of the Environmental Management System in October by Cadbury Personnel. This audit

did not highlight any significant new issues.

3.4.3 Management Environmental Meetings

Key internal environmental meetings are held by management at Cadbury Rathmore three times per year. There

are a number of unscheduled meetings as needed. The first meeting of the year reviewed the previous year and

established the programme of works for the coming year. Subsequent meetings updated the schedule of works

for the year and included the following projects:

i) Oil tank refurbishment and new pumping and heating set

ii) Next stage of roofing project

iii) Cooling tower for evaporator 1

iv) Next phase IPPC licence compliance agenda


P a g e | 23

4. LICENCE-SPECIFIC REPORTS

4.1 Noise Monitoring report summary Dixon Brosnan undertook a noise survey in November 2009 and included a day time and night-time survey.

Overall noise levels recorded were satisfactory. The daytime 55db and night time 45db noise limits specified in

licence P0795-01 were not exceeded. Recommendations: It was noted during the night-time survey that noise

emission from the gate motors to the employee car park were audible at monitoring location N2 the south

western most corner of the site and there was recommendations made that these emission need to be addressed.

Noise Sensitive Locations were reviewed and on recommendation of the Agency an unoccupied cottage/dwelling

house situated immediately south of the facility was omitted from the 2009 survey as it was deemed to be

unrepresentative NSL.

4.2 Tank and pipeline testing and inspection report A visual inspection of all tanks and bunds on site at Cadbury Rathmore was undertaken during 2009. In total, 26

tanks and associated bunds were inspected. All tanks are to be visually re-inspected every three years. A

schedule for further testing and inspection was also prepared and submitted to the Agency. The Heavy Fuel Oil

tank was internally inspected in December 2009 and was passed as satisfactory. Five tanks have been schedule for

internal testing during the year 2010.

A review of the CCTV survey and water tightness testing which was carried out as part of Phase 1 of the IPPC

Works was carried out in 2009 and a Drainage Review Report was submitted to the Agency. The report included

the following data:

(a) Schedule for Integrity Testing of Outstanding Pipelines (b) Schedule for Review and Repair of Relevant Pipelines (c) Drains Marked ‘Not in Use’ (d) Testing of Drains Marked ‘Not in Use’ (e) Decommissioning of Drains

The report has revealed that 70% of the drainage systems have been tested. The gaps in the survey and testing

shall be closed out as planned under Phase 2A during 2010.

4.3 Report on the assessment of the efficiency of use of raw materials in processes and the reduction of waste generated

There have been large improvements made on waste management activities and training over the past year.

Significant advances in the identification of areas where waste could be reduced have been made. Significant

improvements in the disposal of organic waste were planned during 2009 for implementation during 2010. 100%

of waste crumb product is to be composted (off-site), diverting a significant volume of waste from landfill. In

terms of packaging waste, 100% of mini bulk sacks are now also diverted from landfill and recycled. Improvements

in waste segregation has also occurred. Up to 90% of scrap timber that would have been included within general

waste skips destined for landfill is now sent for recycling


P a g e | 24

4.4 Report on progress made and proposals being developed to minimise water demand and the volume of

trade effluent discharge As part of the EMP for 2009 and general site programme, there was a focus on addressing water leaks on site.

Improved controls were installed on hoses and faucets. This reduced the consumption of raw water. Data

indicates that there has been a 4% reduction on 2008 figures in the volume of process water used. Onsite data

also indicates that there has been an 8% reduction on 2008 figures in the volume of wastewater discharged from

the site. There are ongoing initiatives for 2010 to implement improvements in water consumption and volumes of

wastewater generated.

4.5 Environmental Liabilities Risk Assessment (ELRA) Review An ELRA report, carried out by independent consultants relating to potential environmental liabilities was

submitted to the Agency in 2008. This report will be reviewed every three years and updates documented in the

AER as required in the licence.


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APPENDIX A| AER SUMMARY DATA TABLES

annual environmental report · cadbury ireland ltd rathmore facility comprises of a main processing...

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