Attachment 4.8.3 Baseline Report IEL Review P0005-02 Application ID LA001617 MSD Ireland (Brinny) Project reference: PR-25391 Project number: 60563354 19 July 2018 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 20-11-2018:04:05:08
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Attachment 4.8.3 Baseline Report · produce a baseline report. MSD Brinny appointed AECOM Ireland Limited (AECOM) to assist in the preparation of their IEL review application including
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Attachment 4.8.3 Baseline ReportIEL Review P0005-02Application ID LA001617
Where any conclusions and recommendations contained in this Report are based upon informationprovided by others, it has been assumed that all relevant information has been provided by thoseparties and that such information is accurate. Any such information obtained by AECOM has not beenindependently verified by AECOM, unless otherwise stated in the Report. AECOM accepts no liabilityfor any inaccurate conclusions, assumptions or actions taken resulting from any inaccurateinformation supplied to AECOM from others.
The methodology adopted and the sources of information used by AECOM in providing its servicesare outlined in this Report. The work described in this Report was undertaken between May 2018 andJuly 2018 and is based on the conditions encountered and the information available during the saidperiod of time. The scope of this Report and the services are accordingly factually limited by thesecircumstances. AECOM disclaim any undertaking or obligation to advise any person of any change inany matter affecting the Report, which may come or be brought to AECOM’s attention after the date ofthe Report.
9.3 Stage 3 – Assessment of Site Specific Pollution Possibility ........................................... 189.4 Stage 4 – Site History .................................................................................................. 189.5 Stage 5 – Environmental Setting .................................................................................. 189.6 Stage 6 – Site Characterisation .................................................................................... 189.7 Stage 7 – Site Investigation .......................................................................................... 18
Appendix A Figures .......................................................................................................................... 19Appendix B Relevant Hazardous Substances Tables ....................................................................... 20Appendix C Site Investigation Data .................................................................................................. 21Appendix A FiguresFigure 1 Site Location PlanFigure 2 Site Layout PlanFigure 3 Well LocationsFigure 4 Cross SectionFigure 5 Shallow Aquifer Contour Plan – April 2018Figure 6 Deep Aquifer Contour Plan – April 2018
Appendix B Relevant Hazardous Substances TablesTable 1 Relevant Hazardous Substances (Stage 1 and 2)Table 2 Relevant Hazardous Substances (Stage 3)
Appendix C Site Investigation DataTable 1 Well InventoryTable 2 IEL Sampling ScheduleTable 3 IEL Well Historic Data
1.1 Project BackgroundMSD Ireland Brinny (MSD Brinny) operate a site in Innishannon, Co. Cork (the site), under IndustrialEmissions Licence (IEL) P0005-02, granted by the Environmental Protection Agency (EPA). Under theterms of this licence, the site is licensed for the use of a chemical or biological process for theproduction of basic pharmaceutical products. Under current licensed site operations, the biologicsbuildings on-site are configured for the fermentation process necessary to produce a singlepharmaceutical product. It is planned to reconfigure the internal structure of these buildings to permitmulti-product fermentation processes. This planned change in site operations has obliged the site toundertake a review of the site’s IEL. As part of the IEL review application MSD Brinny are obliged toproduce a baseline report. MSD Brinny appointed AECOM Ireland Limited (AECOM) to assist in thepreparation of their IEL review application including the production of this Baseline Report.
1.2 Baseline AssessmentWhen the European Union Directive on Industrial Emissions1 came into force, it became necessaryfor licensees to prepare a baseline report with regard to soil and groundwater contamination whenactivity on the site involves the use, production or release of relevant hazardous substances, undereither of the following scenarios:
· When applying for an IEL to operate a new installation; and,
· When revising the permit for an existing licensed installation.
Under the Industrial Emissions Directive, a Relevant Hazardous Substance is a raw material, product,intermediary, by-product, emission or waste which, as a result of their hazardousness, mobility,persistence and biodegradability (as well as other characteristics), is capable of contaminating soil orgroundwater.
1.3 Project ObjectiveThe main objective of the project is to complete a baseline assessment for the site in support of thecurrent licence review application.
1.4 Scope of WorkThe aim of baseline assessment is to generate a report which, on cessation of the licensed activity,will allow for direct comparison to determine if contamination has been added in the course of thelicensed activity since the baseline was established. Therefore, the baseline report needs to be ascomprehensive as possible.
The Official Journal of the European Union has issued guidance2 on the stages to be completed andthe scope of content for baseline reports. In total there are eight stages to be completed, as listedbelow:
· Stage 1 – Identification of hazardous substances used;
· Stage 2 – Identification of relevant hazardous substances used;
· Stage 3 – Assessment of the site specific pollution possibility;
· Stage 4 – Site history;
· Stage 5 – Environmental setting;
· Stage 6 – Site characterisation;
1 Industrial Emissions Directive, Directive 2010/75/EU2 European Commission Guidance concerning baseline reports under Article 22(2) of Directive 2010/75/EU on industrialemissions (2014)
2. Identification of Hazardous Substances (Stage 1)The first stage in preparing a baseline assessment is to identify every hazardous substance that iscurrently used, produced or released at the site.
MSD Brinny has collated a comprehensive inventory of substances used and stored on site (seeAttachment 4-6-2 as an example). AECOM were supplied with a list of substances used and storedon site.
Substances were classified as hazardous if:
· They were identified as ‘Hazardous’ by the EPA Document Classification of Hazardous and Non-Hazardous Substances in Groundwater (2010)3; and,
· If they have a relevant environmental hazard statement on the European Chemicals Agencywebsite4.
A list of the hazardous substances identified on site are listed in Appendix B Table 1.
3. Identification of ‘Relevant Hazardous Substances’(Stage 2)
Stage 2 screens the hazardous substances identified following stage 1 for potential pollution risk dueto their chemical or physical properties.
This risk-based assessment screens the list of substances given in Appendix B Table 1 inconsideration of:
· The physical state of substances used and stored on site, e.g. solids and gases can be removedfrom the list as part of the screening process; and,
· The overall quantity used on site. The EU Guidance states that “where very small quantities areused, produced or released on the site of the installation then the possibility of contamination islikely to be insignificant for the purpose of producing a baseline report”.
An annual usage of >250 L (or >250 kg) was used as the threshold above which substances used onsite were considered in this assessment. Those substances that are used/stored in small quantitieson site have not been considered, for example substances used in laboratories, canteen or medicalcentre on site.
Five Relevant Hazardous Substances were identified in stage 2:
4. Assessment of Site Specific Pollution Possibility(Stage 3)
In stage 3, the hazardous substances which were taken forward from stage 2 were considered in thecontext of the site to determine whether circumstances exist which may result in the release of asubstance in sufficient quantities to pose a pollution risk. Specific issues include:
· The quantity of each hazardous substance or groups of similar hazardous substances;
· How and where hazardous substances are stored and used on site;
· How the hazardous substances are transported around the installation; and,
· In case of existing installations, the measures that have been adopted to ensure that it isimpossible in practice for contamination of soil or groundwater to take place (including thepresence and integrity of containment mechanisms, condition of site drainage etc.)
MSD Brinny provided AECOM with details of the storage locations and containment measures for thehazardous chemicals. The storage and usage locations of the relevant hazardous substances arepresented in Figure 2.
For the current list of on-site relevant hazardous substances which were not screened out in stage 2,AECOM assessed both the storage arrangement of each chemical substance, together with theassociated containment measures. At MSD Brinny, the storage and handling of process materials areundertaken in accordance with the EPA Guidance Document “IPC Guidance Note on Storage andTransfer of Materials for Scheduled Activities”, EPA 20045. Details on current site containment wereobtained from MSD’s documented site procedures and a review of site bund reports. Brief details ofthe storage arrangements of the current on-site hazardous chemical substances and associatedcontainment measures for each of the hazardous substances are provided in Appendix B Table 2.
Bunded liquid chemicals or liquid chemicals that are not stored in bulk storage tanks and possesssecondary and tertiary containment facilities were also screened out of the list of chemicals to beassessed.
Based on the information provided by MSD Brinny to AECOM, it is expected that, as a result ofcurrent site storage, containment and handling practices, the likelihood of possible contamination ofsoils and groundwater from the current on-site hazardous substances is low.
4.1 Diesel and Light Fuel OilDiesel (sulphur free gas oil) and light fuel oil (LFO) were considered together due to their similarproperties. They are liquid at room temperature and have the potential to contaminate soil and/orgroundwater if lost to ground. Diesel and LFO are stored in five bulk above ground storage tanks(AST) on site. The bulk diesel tanks are contained within bunds, which are integrity tested on a threeyear cycle. None of the relevant bunds are noted as having failed integrity testing.
Diesel and LFO are transported across site through above ground pipelines. The site has a number ofinterceptors in case of spillage on roadways or around filling points, to reduce the potential forhydrocarbons to enter the storm water drainage system at the site. In addition in the event of a spillcontaminated liquid entering the storm water system, it will be automatically diverted to a retentionlagoon (see section 6.5). However it was noted in the MSD Brinny Overhead Pipeline RiskAssessment 2016 (AECOM) that diesel is transported over areas of unmade ground withoutsecondary containment. Following the completion of this report a survey was conducted by Metlabwho confirmed that there were no flanges on the diesel pipework above unmade ground.
As diesel is stored within secondary containment and MSD Brinny have documented procedures onmaterial use and storage, the risk of diesel entering soil and/or groundwater is considered low.
However as diesel is stored in bulk and is transported over sections of made ground diesel is aconsidered a Relevant Hazardous Substance.
4.2 Sodium HypochloriteSodium hypochlorite is a liquid at ambient temperature and stored within bunds which are integritytested. None of the relevant bunds are noted as having failed integrity testing. Sodium hypochlorite isnot stored in bulk which significantly reduces the risk of a large scale release.
Due to the provision of secondary and tertiary containment and as sodium hypochlorite is not storedin bulk the risk of sodium hypochlorite entering soil and/or groundwater is considered very low andhas been screened out as a Relevant Hazardous Substance.
4.3 Ammonia Hydroxide SolutionThe storage of ammonia hydroxide solution in quantities greater than 250 litres will be introduced aspart of the planned change to the site Biologics operations. Ammonia hydroxide solution is a liquid atambient temperature and will be stored in a newly installed ChemStore near the WwTP which will beintegrity tested. Ammonia hydroxide is not stored in bulk which significantly reduces the risk of alarge scale release.
Due to the provision of secondary and tertiary containment and as ammonia hydroxide is not stored inbulk the risk of ammonia hydroxide entering soil and/or groundwater is considered very low and hasbeen screened out as a Relevant Hazardous Substance.
4.4 Hydrogen PeroxideHydrogen Peroxide is a liquid at ambient temperature and is stored in ChemStores in the mainWarehouse which are integrity tested. None of the relevant bunds are noted as having failed integritytesting. Hydrogen peroxide is not stored in bulk which significantly reduces the risk of a large scalerelease.
Due to the provision of secondary and tertiary containment and as hydrogen peroxide is not stored inbulk the risk of hydrogen peroxide entering soil and/or groundwater is considered very low and hasbeen screened out as a Relevant Hazardous Substance.
4.5 Environ Vesphene® SE Phenolic DisinfectantAll of the remaining relevant hazardous substances (p-(1,1-dimethylpropyl)phenol, biphenyl-2-ol,clorofene and potassium hydroxide) are constituents of Environ Vesphene® SE, a germicidaldetergent. While the cumulative volume used on the site inventory is >250 L, Environ Vesphene® SEis contained in bottles and sachets, which individually contain small volumes.
Therefore, the risk of and its constituents entering soil and/or groundwater is considered very low andhas been screened out as a Relevant Hazardous Substance.
5.1 Historic Land UseIn 1973 an antibiotic manufacturing facility was built by Chemibiotic (Ireland) Ltd. After termination ofthis activity Schering Plough purchased the site in 1980 and commenced operations at the site. In2009 Schering Plough merged with MSD. In September 2016 the company name was transferred toMSD International GmbH, trading as MSD Ireland (Brinny). Since operations began the facility hasproduced a range of biotechnology derived pharmaceutical products.
Prior to the construction of the Chemibiotic facility the site use was agricultural.
5.2 Historic Losses to GroundA site data review was conducted in 20156 to assess historic groundwater sampling data and trends.This data review and historic reports identify four distinct events which resulted in losses to ground.They are:
· Diesel in 2001;
· Ethylene glycol in 2003;
· Diesel in 2004; and,
· Ethylene glycol 2006.
5.2.1 Diesel Spill 2001A site investigation completed in 2001 details the remediation of a diesel spill. Approximately 24 m3 ofcontaminated soil was excavated and moved off site. Sampling as part of the site investigation (seesection 8.2) did not identify elevated hydrocarbon concentrations following the completion of theexcavation.
5.2.2 Ethylene Glycol Spill, 2003In August 2003, a site investigation was undertaken (see section 8.2 ) following a spill of ethyleneglycol coolant close to Building 18. The investigation concluded that the ethylene glycol biodegradedin the environment and did not pose a threat to the environment.
5.2.3 Diesel Spill, 2004In June 2004, a small diesel leak occurred on a pipeline that connected a decommissioned generatorwith an AST located west of the purification building. An area of 1 m x 1 m was excavated down to adepth of 1.1 m below ground level (bgl). The excavated soil, from which a hydrocarbon odour wasnoted, was stockpiled. A soil sample was taken from the base of the excavation and analysed forhydrocarbons, no hydrocarbons were detected.
Following the diesel spills in 2001 and 2004 additional control measures were put in place to reducethe likelihood of future incidents including the installation of oil interceptors in the drainage networkand the introduction of a permit system and documented procedures for diesel deliveries.
5.2.4 Ethylene Glycol Spill, 2006In August 2006, the TOC alarm in the storm water drain was activated. Storm water was then divertedto the tertiary containment lagoon. A glycol spray was observed from the automatic air vent on theglycol loop in an open area south of the laboratory building. 5,000 litres of water containing an 11.7%glycol mix was lost (see Figure 2). Following the loss, a series of groundwater sampling rounds wereconducted, no ethylene glycol was detected.
6 AECOM (2015) 47092942 / CKRP0004 Issue 2 Final - MSD Brinny 2014 IEL Groundwater Data Review
A qualitative risk assessment was undertaken and it was concluded that the zone of groundwatercontribution (ZOC) to the on-site production wells could encompass the spill area - see section 8.5.
Ethylene glycol is miscible in water, tends not to sorb to soil and is readily biodegraded. Therefore, itis unlikely that ethylene glycol lost to ground in 2006 would persist in soil and groundwater beneaththe site.
Ethylene glycol has been routinely analysed since 2009, and was most recently sampled for in April2018. Ethylene glycol has not been detected in groundwater from any well since routine monitoringbegan in 2009. Therefore MSD Brinny is proposing (Attachment 9.1) not to include ethylene glycol infuture groundwater monitoring rounds.
6.1 Site Setting and TopographyThe site is situated at an elevation of between 20 m and 30 m above Ordnance Datum (OD) and landacross the site slopes gently to the south-west toward the valley of the River Brinny, with a steepslope along the western site boundary.
6.2 HydrologyThe River Brinny flows past the western and southern site boundary, with an old mill race flowing atthe base of the steep slope along the western and southern site boundary. The mill race joins theRiver Brinny south of the site.
The River Sall, which flows from west to east, also joins the River Brinny to the south of the site, justup-stream of Brinny Bridge; and the River Brinny continues to flow south-eastwards, joining the RiverBandon 2.5 km down-stream. Surface water quality in the section of the River Brinny adjacent to thesite (EPA reference Brinny_020) is classified as High7.
6.3 GeologyThe site is underlain by made ground on glacial till derived from Devonian/Carboniferous sandstoneand shales. Available drilling records for the site indicate that the shallow overburden compositionvaries from soft, silty clay to gravel, with the deeper overburden consisting of sand and gravel. Thebedrock beneath is Carboniferous sandstones, mudstones and dolomites.The generalised geological sequence is:
· 5 – ~10 m bgl: sandy, gravelly, clay and silt (aquitard);
· ~10 m - ~22 m bgl: sand and gravel (with discontinuous silt and clay zones) (aquifer); and,
· Below ~22 m bgl: mudstone, sandstone and dolomite (bedrock aquifer).
6.4 Site Hydrogeology and Groundwater FlowPrevious investigations (see section 8) at the site have classified the overburden into a shallowperched gravel aquifer and deeper sand and gravel aquifer, which are separated by a lowerpermeability aquitard. The deeper gravel unit is classed as a ‘Locally Important Aquifer (Lg)’ while thebedrock aquifer is classed as ‘Locally Important Aquifer (LI) – Bedrock which is moderately productiveonly in Local Zones’.8
Under natural gradient conditions, groundwater would be expected to mirror the topographic gradientand flow across the site to the west/south-west. Shallow groundwater in the perched aquifer generallyappears to do this, and groundwater seepages from the base of the slope are seen. These seepagesdischarge to the mill race. Continuous groundwater abstraction from the deeper sand and gravelaquifer does not appear to affect the direction of groundwater flow in the shallow perched aquifer.
Groundwater in the deeper sand and gravel aquifer is confined by the aquitard, with the verticalhydraulic gradient downwards between the two gravel aquifers.
7 www.catchments.ie – accessed 20 June 20188 www.gsi.ie – accessed 20 June 2018
Groundwater abstraction from the deeper gravel is understood to alternate between three productionwells on an approximate 8-hour rotation, groundwater level monitoring conducted in 20179 indicatedthat pumping is not continuous during an 8-hour period.
As seen with the dip round data for April 2018 (Appendix A Figure 6), groundwater flow will convergeon whichever well is actively pumping at any given time. Over the course of a day, the focus ofgroundwater flow in the deeper gravel changes depending on which production well is operational.Under natural gradient conditions, it is expected that groundwater in the deeper gravel woulddischarge to the River Brinny.
Water levels in well MW-1D have been monitored since November 2007 and have not shown anylong term changes in groundwater level as a result of changes to the abstractions regime at the siteduring that time, suggesting that the zone of contribution to the site’s abstraction wells does notextend to the north-eastern edge of the site.
6.5 Surface Runoff Drainage SystemsStorm water run-off is directed to surface water drains which discharge to the River Brinny via anumber of oil/water interceptors (Class I and Class II) and then to a Total Organic Carbon(TOC)/pH/Temperature monitoring chamber (SW2).
In the event of a chemical release the surface water drainage system is set up to re-route the stormwater to the onsite retention pond if TOC/pH/Temperature levels exceed specific limits. The retentionpond is linked to the MSD Brinny operating site storm water system via a 900 mm undergroundconcrete pipeline. In the same trench there is a 100 mm polyethylene pipeline that facilitates thepumping of contaminated water back to the main site wastewater treatment plant (WwTP).
Site process wastewater and sanitary wastewater is directed to the on-site WwTP where physical,chemical and biological treatment is provided. The treated effluent from the WwTP is dischargedunder EPA license into the Bandon River estuary approximately 700 m north of Kilmacsimon via anapproximately 9 km long pipeline.
6.6 EcologyThere are no direct hydrogeological links between the MSD Brinny site and any Special Areas ofConservation or Special Protection Areas. However, there are three proposed Natural Heritage Areas(pNHA) downstream of the site; these are the Bandon Valley above Innishannon (pNHA 001740),Bandon Valley below Innishannon (pNHA 01515) and James Fort (pNHA 001060).
6.7 Surrounding Land useMost current land use in the surrounding area is agricultural, other than a sandstone quarrydevelopment (Kilmore Concrete Ltd) and modular building supplier (Spacecab Limited), bothapproximately 200 m west of the site. There are no other EPA licensed facilities located within a 2 kmradius of the facility.
In addition to a number of supply wells in the general area, the site itself abstracts groundwater for allproduction and supply purposes on site from three on-site wells. Groundwater is abstractedpredominantly from the sand and gravel aquifer, but some production wells extend into the deeperbedrock.
9 AECOM (2017) 60533059 Issue 2 Final - MSD Ireland (Brinny) Response to EPA RFI Zone of Contribution Estimate
7. Site Characterisation (Stage 6)Potential pollutant linkages are considered viable where there is a source of contamination on sitewhich can migrate via a defined pathway to identified receptors. Receptors can be eitherenvironmental or human, and located either within or outside the site boundary.
7.1 SourcesFrom a review of the site history (see section 4), it appears that losses to ground from distinct eventsare limited to:
· Diesel in 2001;
· Ethylene glycol in 2003;
· Diesel in 2004; and,
· Ethylene glycol in 2006.
7.2 PathwaysLosses to ground would migrate vertically downwards to the shallow perched aquifer. Contaminantsin perched groundwater would then migrate with groundwater flow down hydraulic gradient.
It appears that perched groundwater flows to the south-west toward the mill race; indeed, seepages of shallow groundwater from the base of the slope between the site and the mill race have beenobserved historically. The mill race flows from north-west to south-east and joins the River Brinnyfurther to the south-east of the site just upstream of Brinny Bridge.
Although the vertical hydraulic gradient between the two aquifer units is downward across the lowerpermeability aquitard, it is considered unlikely that diesel, ethylene glycol or inorganics (major ions)would have impacted/impact the deeper gravel aquifer, as the aquitard provides protection andseparates the two aquifer units. The primary groundwater flow path through the perched aquiferwould likely follow the horizontal hydraulic gradient.
It is also noted that the three active production wells on site abstract groundwater from the deepergravel aquifer. It is expected that, under active pumping conditions, the vertically downward hydraulicgradient across the aquitard would increase close to the active pumping well, which would locallyincrease leakage of groundwater from the perched aquifer to the deeper gravel aquifer.
Under natural gradient conditions, the direction of groundwater flow in the deeper gravel aquifer isexpected to be to the south or south-west, i.e. toward the River Brinny. However, active pumpingalters this, with each production well becoming the focus for groundwater flow when actively pumping.The three active production wells are located in the centre of the site:
· To the north of the purification building (654);
· To the north-east of the services building (651); and,
· Immediately east of the operations building (653).
The source protection plan completed in 2004 concluded that the zone of contribution to the threeproduction wells extended beyond the site boundary, and was elongated to the north-east.
The zone of contribution was reassessed in early 2017 and an area of ~2.2 km2 was conservativelydelineated, extending from the River Brinny in the west to a local highpoint at Old Chapel CrossRoads in the north-east.
7.3 ReceptorsThe site uses groundwater for all water supply requirements on site. The three active production wellson site abstract groundwater, principally from the deeper gravel aquifer, but with a proportion of water
also likely to come from deeper bedrock. As noted above, there is a vertically downward hydraulicgradient between the two sand and gravel aquifer units, which is likely to increase in the vicinity of anactively pumping well; however, the aquitard is considered to provide a protective hydraulic barrierbetween the two aquifer units.
Therefore, the receptors of groundwater from production wells (i.e. site staff using the water forpotable supply) are not considered likely to be at risk from potential groundwater contamination in theshallow aquifer zone. It is understood that groundwater from the abstraction wells is sampled on aquarterly basis and analysed for a suite of drinking water parameters. No issue with the potable waterquality has been reported since monitoring began.
The consumption of groundwater from groundwater wells is not considered to be a potential risk to off-site receptors.
The mill race, into which shallow groundwater from the perched aquifer discharges, joins the RiverBrinny to the south-east of the site at a location, which appears to be, directly up-gradient of thesurface water quality monitoring point at Brinny Bridge. Surface water quality at Bridge West ofRockfort House is classified as High Status (Q4-Q5), this is a slightly higher quality classification thanthe Q4 status which is registered for the upstream monitoring point at Bridge near BallinacurraHouse10. Therefore, water quality in the River Brinny improves slightly as it flows by the site,indicating that site operations are not having an adverse impact on surface water quality.
7.4 SummaryReported groundwater data ranges in April 2018 were within ranges previously reported (seeAppendix C Table 3) and do not indicate a deterioration in groundwater quality. There is no evidenceof impact to the adjacent surface water courses; in fact, the quality of water in the River Brinny actually increases down-stream of the site. It is understood that water from the on-site productionwells meets the standards for potable supply. A cross section of the site is presented in Appendix AFigure 4.
8. Site Investigation (Stage 7)
8.1 RationalSufficient data has been gathered from several phases of historic site investigations to characterisethe site. These have been conducted for various reasons, including:
· Groundwater resource assessment through the installation of trial and abstraction wells;
· Geotechnical investigations related to construction works on site; and,
· Installation of monitoring wells in the assessment of potential sources of contamination.
From available data, it appears that contamination issues on site have been localised and/or of shortduration.
As discussed in Section 1.1, this Baseline Report has been prepared to supplement an IE LicenceApplication which MSD Brinny are making for a revision of their existing IE Licence (P0005-02) due tochanging manufacturing operations within the MSD Brinny existing Biologics Buildings.
Due to changes in operations at MSD Brinny additional substances will be used. These additionalsubstances are
· Ethanol;
· Ammonium hydroxide;
· Potassium phosphate;
10 https://gis.epa.ie/EPAMaps/ - accessed 29 June 2018
These additional substances are not classified as relevant hazardous substances with the exceptionof Ammonium Hydroxide. However Ammonium Hydroxide has been screened out as a relevanthazardous substances as discussed in Section 4.3 of this report. Furthermore under the proposednew process, there will be no change in chemical handling practices or chemical storage practices.
Additionally:
· The site history and environmental setting are well understood and documented;
· Site investigation and monitoring data are available, not only for the IE Licensed monitoringwells, but also for additional monitoring and site investigation points across the site; and,
· The existing groundwater monitoring suite includes data relevant to the new substances to beused on site
Therefore a site investigation is not warranted in support of this Baseline Report.
8.2 2002 Site InvestigationA site investigation was conducted in 2001 close to the generator building located to the west of thesite. The site investigation was conducted following the remediation of an oil spill close to thegenerator building (see section 5.2.1).
Three boreholes (GMW1 to GMW3) were drilled to between 7.0 m and 7.2 m bgl. The wells werescreened within the silty sand unit. Soil and groundwater samples were taken and analysed for asuite of hydrocarbon parameters. In addition a vapour survey was conducted inside the generatorbuilding. No elevated hydrocarbon concentrations were detected indicating that the remediation wassuccessful.
8.3 2003 Site InvestigationA site investigation was conducted in 2003 close to the fermenter building located to the south of thesite. The site investigation was conducted following the loss of ethylene glycol (see section 5.2.2).
A zone of contribution for the three onsite production wells was completed in 2003 which indicatedthat the spill occurred within the zone of contribution of well 653.
Initially a series of five boreholes (GMW4S/D, GMW5S/D and GMW6) were installed. The four pairedwells were screened within the interbedded sands, silts clays and gravels. The single installation wellGMW6 was installed within the deeper gravel aquifer. Groundwater from the five wells andgroundwater seepages at the base of the embankment to the west of the site adjacent to the mill racewere sampled for ethylene glycol. No ethylene glycol was detected in any of the groundwatersamples.
An additional five boreholes (GMW7 to GMW11) were installed to a depth of 8 m bgl in close proximityto Building 18 in late 2003. Nineteen soil samples were analysed for ethylene glycol. Ethylene glycolwas only detected above the method detection limit (MDL) in one sample (2.8 m bgl from boreholeGMW10) at a concentration of 35 mg/kg.
Monthly groundwater sampling took place in the five newly installed wells. Ethylene glycol wasdetected above the MDL in GMW10 and intermittently in GMW11.
A total of 75 surface water samples were taken following the spill. Ethylene glycol remained below theMDL in all samples tested.
The report concluded that ethylene glycol will readily biodegrade under both aerobic and anaerobicgroundwater conditions. The 2004 site investigation report concluded that:
“The remaining low levels which are well below the concentrations identified as posing a risk theenvironment, would be expected to be biodegraded and be assimilated in the environment in duecourse”11
Ethylene glycol has not been detected in groundwater from any of the onsite wells since testing for itresumed in 2009.
8.4 2004 Source Protection Area AssessmentFollowing on from the 2001 diesel spill and 2003 ethylene glycol spill it was recommended that aSource Protection Area assessment take place. Initially a zone of contribution for the three onsiteproduction wells was completed in 200312. Drilling records of the existing wells were used to definethe extents of the shallow and deep aquifers beneath the site. It was noted that groundwater flowwould be altered by the three onsite wells which would draw water radially in towards the activepumping well. A downward hydraulic gradient was identified through the low permeability aquitardseparating the two aquifers.
8.5 2006 Water Level SurveyIn 2006 a water level survey13 was conducted for selected wells on site to assist in the development ofa conceptual site model.
The monitoring wells used for the survey were surveyed to an arbitrary site datum to allowcomparisons of water levels and geological logs.
The survey confirmed that the lower aquifer is confined by the aquitard identified in previous siteinvestigations. Groundwater in deeper wells was found to be flowing radially towards the three on siteproduction wells. However, groundwater in the shallower wells flowed in a south easterly directiontowards the mill race where seepages of groundwater have been identified in the past. Theinvestigation concluded that groundwater in the deeper aquifer was of “high to moderate vulnerabilitydue to the presence of the overlying low permeability aquitard.”
However AECOM would classify the deeper aquifer as having a medium vulnerability due to thepresence of the aquitard.
8.6 2009 Geotechnical InvestigationA geotechnical assessment was conducted in 2009 to facilitate the extension of Building No. 19. Fourboreholes BH01 – BH04 were drilled to depths ranging from 8.0 m to 16.1 m bgl. A series of in-situand ex-situ geotechnical tests were conducted.
8.7 2012 IPC Well ReplacementIn 2012 due to the expansion of one of the existing on site structures, the original MW3S and MW3Dwere decommissioned. Two new wells were installed using the names MW-3S and MW-3D as closeas possible to original well locations. MW-3S was screened between 4 m bgl and 9 m bgl. No waterstrikes were noted. MW-3D was screened from 12.5 m to 13.8 m within the deeper sand and gravelaquifer. There was no evidence of contamination during drilling.
8.8 2017 Zone of Contribution EstimateAt the request of the EPA an updated zone of contribution (ZOC) report was produced in June 2017for the three on site production wells. Six data loggers were installed in wells across site to measurethe effect of pumping on site. The report concluded that a conservative estimate for the ZOC is 2.2
km2. The report concluded that there is no indication of long term declining water levels caused bythe current groundwater extraction regime.
8.9 IEL Groundwater SamplingUnder the terms of the site’s IEL, the site is required to conduct groundwater monitoring on a biannualbasis from seven wells: MW-1S, MW-1D, MW-2S, MW-3S, MW-3D, MW-4S and MW-4D (Condition 6and Schedule C.6 of the licence). The location of onsite monitoring wells are presented in Appendix AFigure 3
Groundwater samples are analysed for a suite of parameters as presented in Appendix C Table 2.
8.9.1 IEL Groundwater trendsGroundwater trends for the IEL wells are presented in Appendix C Table 3.
8.9.1.1 Diesel and LFOTotal petroleum hydrocarbons (TPHs) which would incorporate both diesel and LFO were below thelaboratory MDL in all samples taken since 2016. TPHs were not included in groundwater analyticalsuites at the MSD Brinny site prior to May 2016, however, constituents of diesel and LFO such astrimethylbenzene and napthalene were analysed for as part of volatile organic compound (VOC) andpolycyclic aromatic hydrocarbons (PAH) analysis suite, which were conducted annually for allsampled wells. VOC and PAH concentrations were low to below the MDL in every monitoring roundand do not indicate diesel or LFO contamination.
8.9.1.2 InorganicsSodium hypochlorite, ammonia hydroxide and hydrogen peroxide are inorganic materials. However,sodium hypochlorite, ammonia hydroxide and hydrogen peroxide cannot be readily analysed directlyby commercial laboratories.
Groundwater is analysed biannually for a comprehensive suite of major ions and metals. The currentmajor ion suite is considered sufficient to monitor ambient groundwater quality, while at the same timeincludes constituents of sodium hypochlorite (sodium and chloride are analysed for biannually) andammonia hydroxide (ammonia is analysed for biannually).
Both sodium and chloride are generally detected at low concentrations below relevant assessmentcriteria in groundwater well MW-3S and MW3-D which are located downgradient of the sodiumhypochlorite storage area.
9. Production of Baseline Report (Stage 8)Stage 8 of the baseline report summarises the information gathered in Stages 1- 7 of the report.
9.1 Stage 1 - Identification of Hazardous SubstancesIn stage one an inventory of raw materials, products, intermediaries, by-products, emissions andwastes which was provided by MSD was screened to identify hazardous substances used on site.
9.2 Stage 2 – Identification of ‘Relevant Hazardous Substances’Hazardous substances identified during stage 1 were screened to identify ‘Relevant HazardousSubstances’.
Five substances were carried through the stage 2 screening process:
· Diesel and light fuel oil;
· Ammonia hydroxide solution
· Sodium hypochlorite;
· Hydrogen peroxide; and,
· Environ Vesphene® SE phenolic disinfectant.
9.3 Stage 3 – Assessment of Site Specific Pollution PossibilityThe relevant hazardous substances identified in Stage 2 were assessed based on their:
· Storage and usage location;
· Usage quantity;
· Storage and transport methods; and,
· Review of secondary containment systems and procedures.
Following the completion of the screening process in stage 3 one relevant hazardous substance wasidentified: Diesel and LFO.
9.4 Stage 4 – Site HistoryThe site history including information of historical incidents which resulted in the loss to ground ofsubstances.
9.5 Stage 5 – Environmental SettingThe existing environment, including, topology, geology, hydrogeology, land use and drainage systemsare assessed.
9.6 Stage 6 – Site CharacterisationA cross section was produced from existing data from historical site investigation. The cross section ispresented in Appendix A Figure 4.
9.7 Stage 7 – Site InvestigationA site investigation was not needed as sufficient information is available from historic siteinvestigations to characterise the site.
Gas cylinder StoreBuilding 22 Technical Operations, Laboratories & Freezer Operations
Engineering Project Office
Building 5 Office and Engineering Store
Material Storage
Material StorageMaterial Storage
Material Storage
Material Storage
Light Fuel Oil AST
Light Fuel Oil AST
Light Fuel Oil AST
Light Fuel Oil AST
Waste StorageWaste Storage
Waste Storage
Engineering Store
Bulk Gas N2 Storage
Bulk Gas O2 Storage
Bulk Gas N2 Storage
Ammonia Hydroxide Solution Storage
Drawing Number Rev
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INFORMATIONMSD BRINNYBASELINE ASSESSMENT FIGURE 2 SITE LAYOUT
7 - WYG, 2012: The Relocation of Groundwater Monitoring Boreholes MW3S & MW3D due to Site Expansion Works, # CE08805
11 - WYG, 2010 IPPC Licence Application
12 - Geological Survey of Ireland website, www.gsi.ie
1 - KT Cullen, 1982: Report on the Possible Effect on Local Groundwater Levels due to Increased Abstractions at Chemibitoic (Irl.) Ltd., Brinny, Co. Cork
2 - KT Cullen, 1992: Groundwater Monitoring Well Installation and Sampling, Schering-Plough, Brinny, Innishannon, Co. Cork FINAL Metres to site datum, as originally reported
Top of well casing elevations as re-surveyed in 2006
Metres below ground level
Metres below casing top
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EPA Export 20-11-2018:04:05:09
Prepared by: BMC
Checked by: EOHAppendix C Table 2 - Analytical Schedule