R&A Bailey IPPC Licence No. P0807-01 Annual Environmental ... · R&A Bailey Annual Environmental Report 2009 1 INTRODUCTION R&A Bailey & Company, Nangor House, Nangor Road, Western

R&A Bailey IPPC Licence No. P0807-01

Annual Environmental Report 2009

R&A Bailey Annual Environmental Report 2009

CONTENTS

1. INTRODUCTION 4 1.1 Description of Site Activities 4 1.2 R&A Bailey Site Environmental Policy 5 1.3 R&A Bailey Organisational Chart for Environmental Management 6

2. EMISSIONS FROM INSTALLATION 7 2.1 Water Emissions Monitoring Data 7 2.2 Air Emissions Monitoring 9

3. WASTE DATA 10

4. ENERGY & WATER CONSUMPTION 10

5. ENVIRONMENTAL COMPLAINTS & INCIDENCES 11 5.1 Complaints 11 5.2 Incidences 11

6. ENVIRONMENTAL MANAGEMENT PROGRAMME 11 6.1 2009 – Review of Schedule of Objectives and Targets 11 6.2 2010 – Proposal for Objectives and Targets 12

7. POLLUTANT RELEASE AND TRANSFER REGISTER 19

8. NOISE SURVEY 19 8.1 Summary of Results 19

9. AMBIENT MONITORING 20

10. TANK & PIPELINE TESTING AND INSPECTION REPORT 20

11. ENERGY EFFICIENCY AUDIT 20

12. EFFICIENCY OF USE OF RAW MATERIALS 20

13. WATER DEMAND AND EFFLUENT MINIMISATION 21

14. RESIDUALS MANAGEMENT PLAN & ELRA 21

2


APPENDIX A Waste Data Register

ATTACHMENT 1 Noise Report

ATTACHMENT 2 CRAMP Report

3


1 INTRODUCTION R&A Bailey & Company, Nangor House, Nangor Road, Western Industrial Estate, Dublin 12 was granted an IPPC Licence by the EPA on the 11th of May 2007 – Licence No. P0807-01. In accordance with Condition 11.8 of the licence R&A Bailey is required to submit an Annual Environmental Report by the 31st March each year detailing environmental performance of the site for the previous year. This document is R&A Bailey’s second AER and relates to the environmental performance of the site from 31st December 2008 to the licence to 31st December 2009. This report is based on the AER requirements set out in Schedule D of the licence and EPA Guidance Note for: Annual Environmental Report.

1.1 Description of Site Activities R&A Bailey & Company is a cream liqueur manufacturing plant, located on an approximately 9.3 hectare site at Nangor Road, Dublin 12. The facility produces Baileys cream liqueur, in addition to Sheridan’s (a coffee layered liqueur) and Smirnoff Vodka. Over 200 people are employed.

The site operations are broken down into the following sections:

1. Cream blend Plant (includes Sheridan’s White)

2. Maltodextrin

3. Sugar Syrup

4. Baileys Production (Plant 1, Plant 2)

5. Sheridan’s Black

6. Smirnoff Vodka

7. Bottling

8. Warehouse and Dispatch

9. Environmental Systems

10. Utilities

11. Laboratory and Office Activities

The site’s IPPC Licence has been granted under the following activity class:

Treatments or processes for the production of food products from animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day

4


1.2 R&A Bailey Site Environmental Policy

5


1.3 R&A Bailey Organisational Chart for Compliance

A

Risk &

Evelyn Conlon

Risk & Sustainability Manager- Environment

Alastair Aitken

Risk & Sustainabi

Manager- Safety

QC

Q

John Miller

Site Manager

idan O’Donnell

Sustainability Manager

lity

Shift Co-Ord x 2

C Techs x 8

Paul McMahon

Risk & Sustainability

Manager - Quality

Angela Kenn

Quality Assura

Co-ord.

6

Donald Perry

Risk & Sustainability Manager- C&E

y

nce


2 EMISSIONS FROM INSTALLATION

2.1 Water Emissions Monitoring Data

2.1.1 Emissions to Storm Water (SW1, SW2, SW3 & SW4) There are four storm water emission points to the Camac River from the R&A Baileys site – SW1, SW2, SW3 and SW4. During 2009 surface water emission points were monitored on a weekly basis. The average measurements are presented in Table 2.1.1. Work is currently being undertaken to establish more accurate surface water emission points. This work is due for completion in May 2010.

Table 2.1.1: Storm Water Emissions to the Camac River Dec 2008-Dec 2009

Parameters Measurements

Average Unit

pH 8.1

COD 8.2 (mg/l)

Conductivity 504 (µS/cm)

2.1.2 Emissions to Sewer (SE1) There is one emission point to sewer from the site’s Effluent Treatment Plant. At the treatment plant the site’s effluent is pH-neutralised using acid and caustic dosing and then released to the sewer system. The monitoring results for 2009 are presented in Table 2.1.2.

The temperature and pH of the sewer emissions are monitored continuously online. The maximum temperature monitored is recorded in Table 2.1.2. The online pH measurement is linked to an automatic control system, which diverts the effluent back into the balancing tank if the pH is outside specification thus avoiding pH exceedences.

Volume: There were no IPPC Licence exceedances relating to effluent volume emission limits for the period from 31st December 2008 to 31st December 2009.

7


COD & BOD, Suspended Solids, Sulphates, Phosphates, Detergents, Oils, Fats & Greases: There were zero exceedances in 2009.

Historically licence exceedances occurred as a result of ingredient releases to drain. A number of initiatives have been undertaken in 2009 to prevent this for occurring.

– Increased awareness and training in the area of process releases to drain has led to heightened awareness of the importance of communicating releases to the facilities team.

– A new cream loss minimisation process is ongoing in Plant two.

– A TOC meter has been installed at the effluent treatment plant. This gives clearer visibility of the impact the process plant is having on the effluent plant. This TOC is now automated to recirculation if levels run above 3000mg/Cl/l.

– A weekly monitoring and losses meeting takes place to address any issues in process while overall awareness of losses has been heightened.

– Recording of any product releases and communication procedure in the event of product release.

Note: BOD is tested once a week. To determine the mean weekly, monthly and annual loads (see Table 2.1.2) this data was supplemented with daily calculation of BOD based on the daily COD measured values (BOD=0.5COD) as per Note 3 of Schedule C.3.2 of the site’s IPPC Licence.

8


Table 2.1.2: Sewer Water Emissions (SE1) River 31st Dec 2008-31st Dec 2009

Measurement

Limit Parameters

SE1

Volume Daily Max. (m3) 581 600

Volume Annual Daily Mean (m3) 99

Temp (C) <35 42

pH 6-10 6-10

COD Daily Load Max (kg/day) 8419 * 8000

COD Mean Weekly Load Max (kg/day) 2759 6000

COD Mean Monthly Load Max (kg/day) 1749 5700

COD Mean Annual Load (kg/day) 891 5400

BOD Daily Load Max (kg/day) 4210 * 4000

BOD Mean Weekly Load Max (kg/day) 1379 3000

BOD Mean Monthly Load Max (kg/day) 874.35 2850

BOD Mean Annual Load (kg/day) 445.67 2700

SS Daily Load Max (kg/day) 1713 2000

SS Mean Weekly Load Max (kg/day) 610 1500

SS Mean Monthly Load Max (kg/day) 226.24 1250

SS Mean Annual Load (kg/day) 138 1000

Sulphates Conc. Max (mg/l) 540 600

Sulphates Daily Load Max (kg/day) 268.36

Phosphates Conc. Max (mg/l) 9.1 100

Phosphates Daily Load Max (kg/day) 2.6 60

Detergents as MBAS Conc. Max (mg/l) 1.6 100

Detergents as MBAS Daily Load Max (kg/day) 0.379 60

OFG Daily Load Max (kg/day) 533 600

OFG Mean Annual Load (kg/day) 21.45 400

* Condition 44.1.2 (ii) applies; ‘For parameters other than pH and flow, eight out of ten consecutive composite results, based on flow proportional composite sampling, shall not exceed the emission limit value. No individual result similarly calculated shall exceed 1.2 times the emission limit value’

9


2.2 Air Emissions Monitoring There are no air emissions of significance from the site however in line with the IPPC licence requirements the combustion efficiencies of the site boilers (emissions points A1.1 & A1.2) are tested annually. The test results from 2009 are detailed in Table 2.2.

Table 2.2: Boiler Combustion Efficiencies March 2009

Parameter A1-1 A1-2

Efficiency (%) 81.45 82.62

3 WASTE DATA Annual waste data for 2009 is detailed in Appendix A. Records for hazardous waste shipments sent off-site are held on site and are available for viewing. Table A.1 is based on the sample waste register provided by the EPA in January 2008.

On 22nd December 2008, R & A Bailey Ltd. became registered as a manufacture of feed with the Department of Agriculture (Registration Number IED236586). This allows for the option of sending aged & out of spec product for agricultural feed purposes in the future.

4 ENERGY & WATER CONSUMPTION The annual energy and water consumption are summarised in Tables 4.1 and 4.2 respectively.

Table 4.1: Energy Consumption Jan-Dec 2009

Item Quantity

Electricity 5,021,865 (KWh)

Natural Gas 7,905,608 (KWh)

Diesel 2076 (litres)

10


Table 4.2: Mains Water Consumption 2009 Month Mains Water (m3)

Jan 8097

Feb 6375

Mar 5843

April 6023

May 5798

June 6128

July 8945

August 12537

September 12192

October 12594

November 12008

December 6922

Total 103462

Note: Site water usage is sourced exclusively from the mains water supply. There is no on-site surface or ground water abstraction.

5 ENVIRONMENTAL COMPLAINTS & INCIDENCES

5.1 Complaints There were no environmental complaints made to the R&A Bailey site in 2009

5.2 Incidences

There were no reportable incidents in 2009.

6 ENVIRONMENTAL MANAGEMENT PROGRAMME

6.1 2010 – Review of Schedule of Objectives and Targets As part of the Environmental Management Programme for the site six objectives to improve environmental performance were developed in 2009. These are summarised in the following section.

11

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008

6.2 2010 – Proposal for Objectives and Targets Following on from the progress on the 2009 Objectives and Targets these have been amended to ensure continued improvement in 2010. The new Objectives and Targets for 2010 are detailed in the following sections.

Table 6.2.1: 2010 Objective 1 – Reduction of Effluent Load to Sewer Action No.

Annual Actions Target for Completion

Responsible Person

1.2 Target production loss reduction and BOD/COD load minimisation. Target yet to be decided.

31/12/2010 Operations Manager

1.3 Target zero effluent-related non-compliances with IPPC licence. Determine feasibility of diverting out of spec TOC into recirculation at the Effluent plant.

31/12/2010 Facilities manager

Table 6.2.2: 2010 Objective 2 – Reduction of Energy Use Action No. Annual Actions Target for

Completion Responsible Person

2.3 Aim to reduce energy usage per litre of product below YTD - exact target yet be to fixed

31/12/2010 Environmental Manager

Table 6.2.3: 2010 Objective 3 – Reduction of Waste to Landfill Action No. Annual Actions Target for


3.1 Improve waste segregation and labelling on site to increase level of recycling.

31/12/2010 Risk managerEnvironment

3.2 Undertake risk assessment of hazardous waste areas on site.


12


Table 6.2.4: 2010 Objective 4 – Minimise risk associated with the Storage and Handling of Chemicals Action No. Annual Actions Target for


4.1 Review placement of spill kits on site and place local spill kits at higher risk areas.


4.2 Brief all operators on spill kit use and preventing pollution on site.


4.3 Full emergency response training for security and key members of staff and review site emergency response plan in relation to environmental risk on site.


Table 6.2.5: 2010 Objective 5 – IPPC Licence Compliance Action No. Annual Actions Target for


5.1 Complete surface water drainage system and access to surface water monitoring points.

31/12/2010 Engineering Manager

5.2 Install automated slam shut valves on surface water points.

31/12/2010 Engineering Manager

Table 6.2.6: 2010 Objective 6 – Water Minimisation Action No. Annual Actions Target for


6.1 Achieve water KPI – Figure per litre produced target yet to be decided. 2015 – 30% reduction to be achieved.


6.2 Update water minimisation strategy plans on an ongoing basis and continue to meet on a fortnightly basis.


13


Action No. Annual Actions Target for Completion

Responsible Person

6.3 Continue CIP project to reduce overall times of CIP’s on site.

31/12/2010 Process and water team

6.3 2009 – Review of 2009 Objectives and Targets

Table 6.3.1: 2009 Objective 1 – Reduction of Effluent Load to Sewer Action No.

Annual Actions Target for Completion

Responsible Person

Status

1.1 Update Site Characterisation and Effluent Minimisation Plan.

30/06/09 EnvironmentManager

Complete

1.3 Target zero effluent-related non-compliances with IPPC licence. Determine feasibility of diverting out of spec BOD/COD effluent to prevent BOD/COD non-compliances.

30/06/09 EnvironmentManager

0 exceedances achieved & significant improvements made.

Table 6.3.2: 2009 Objective 2 – Reduction of Energy Use Action No. Annual Actions Target

for Completion

Responsible Person

Status

2.1 Implement EN16001 and outline Energy Reduction Plan.


Complete - Now certified to EN16001

14



Responsible Person

Status

2.2 Implement revised Energy Reduction Plan 31/12/09 Environmental Manager

Complete - Now certified to EN16001

2.3 Aim to reduce energy usage on site by 3% 30/06/09 Environmental Manager

On track to meet F10 target.

Table 6.3.3: 2009 Objective 3 – Reduction of Waste to Landfill Action No. Annual Actions Target for


Status

3.1 Target ‘zero waste to landfill’ for year ending 2009 30/06/09 Environmental Manager

0 waste to landfill achieved

3.2 Undertake assessment on-site waste minimisation possibilities in order to reduce waste being sent for recycle


Complete. Further measures identified

Table 6.3.4: 2009 Objective 4 – Minimise risk associated with the Storage and Handling of Chemicals Action No. Annual Actions Target for


Status

15



Responsible Person

Status

4.1 Complete Containment and bunding project 31/03/09

Risk manger Environment

Complete. Site drainage project undertaken. New firewater retention tank on site.

Table 6.3.5: 2009 Objective 5 – IPPC Licence Compliance Action No. Annual Actions Target for

Completion

Responsible

Person

Status

5.1 Review site emergency response plan to include new slam shut valves on site.

31/05/2010 EnvironmentalManager

Ongoing

5.5 Carry out refresher ERP training with relevant site personnel

30/06/08 EnvironmentalManager/H&S Manager

To be completed May 2010

5.6 Review site environmental training requirements for 2009 and provide appropriate training


Complete –All employees briefed during safety day. Other specific training ongoing.

16


Table 6.3.6: 2009 Objective 6 – Water Minimisation Action No. Annual Actions Target for


Status

6.1 Maintain water efficiencies on site. 30/06/2011 Environmental Manager

Targets are measured from July 1st to June 30th each year.

6.2 Complete a site water balance and monitoring data to ensure comprehensive site water usage is available


Complete

6.3 Update water minimisation assessment

Identify best practice and possible engineering solutions

30/09/09

Environmental Manager

Complete & ongoing

6.4 Update water usage minimisation strategy plan 31/12/09 Environmental Manager

Complete & ongoing

17


7 POLLUTANT RELEASE AND TRANSFER REGISTER This will be submitted online as per EPA instructions and guidelines.

8 NOISE SURVEY An environmental noise survey was carried out by Kearney & Associates Ltd. on behalf of R&A Bailey & Company in November 2009. The survey was carried out in order to determine the impact of on-site noise sources on noise levels at the site boundaries and nearest noise sensitive location. The full report is included as Attachment 1 of this AER.

8.1 Summary of Results Noise levels were measured at five site boundary locations. LAeq levels at these locations ranged from 55-63dBA during the day and 52-56dBA at night. At most locations the predominant noise both during the day and at night resulted from off-site traffic however on-site equipment and truck movements did contribute to site boundary noise levels. The nearest noise sensitive location to the site is an apartment building off Park West Avenue, which is approximately 500m from the R&A Bailey site. Noise levels at this location both during the day and at night were predominated by local traffic and activity. Noise from the Baileys site was not audible at this location.

From the tonal analysis undertaken on the measured data it was concluded that tonal noise identified at two boundary locations may have been due to on-site equipment. No tonal noise was identified at the noise sensitive location.

Road traffic on Nangor Road and Park West Avenue is the main source of noise in the immediate vicinity of the Diageo Baileys Nangor Road plant. Noise from Diageo Baileys plant was not audible over the general environmental noise arising from traffic.

It is important to note that the Baileys site is located in a built-up, industrial-zoned area, surrounded by roads and other industry and no noise complaints have been received during the operating history of the site. Based on the noise monitoring results it is concluded that the noise levels generated on-site are acceptable in the context of the site location in an industrial estate.

19


9 AMBIENT MONITORING As per Schedule C.6 of the R&A Bailey IPPC License no ambient monitoring is required at the site.

10 TANK & PIPELINE TESTING AND INSPECTION REPORT It is required in accordance with Condition 6.8 of the R&A Bailey IPPC Licence that a Tank & Pipeline Testing and Inspection assessment is carried out within 12 months of the grant of the licence. In accordance with this R&A Bailey undertook an inspection and survey of the drains on site and was submitted as part of the 2008 AER.

11 ENERGY EFFICIENCY AUDIT Sustainable Energy Ireland (SEI) carried out an IS393 Gap Analysis Audit for R&A Baileys in February 2007 to assess the site’s readiness to satisfy the requirements of IS393/EN16001 and build an effective Energy Management System. In early 2008 R&A Bailey signed up to the SEI Agreements programme and thereby committed to achieving IS393/EN16001 accreditation within 3 years. A copy of the audit was provided in the 2007 AER.

The September 2008, DBGS established an energy aspects register. This is available to view on site. Following this review R&A Bailey have identified the significant energy aspects of the site and have developed an Energy Reduction Plan, which was implemented as part of achieving EN16001 energy management system, which was awarded in September 2009.

12 EFFICIENCY OF USE OF RAW MATERIALS The 2009 efficiency of use of raw materials assessment has been based on alcohol usage, Cream, Malto and Sugar as summarised in Table 12.1. The alcohol, cream, malto and sugar calculation was based on incoming alcohol raw material vs alcohol out in product.

Table 12.1: Raw Material Efficiency Use

Parameter % Loss

Alcohol 1.42

Cream 0.82

Malto 2.02

Sugar 1.96

20


13 WATER DEMAND AND EFFLUENT MINIMISATION Diageo Baileys Global Supply Dublin has reduced their water on site by 21% since H2 2006. A number of projects are currently in place or planned to minimise site water usage and thereby also reduce the volume of water discharging from the site as trade effluent. These projects are summarised as follows:

1. Leak detection – weekly monitoring of water use, reviewing at un-metered water on a weekly basis. A water team meet on a fortnightly basis to discuss this loss along with any leaks identified in the plant.

2. Reduction in Water used in plant CIPs – an potential saving of water during CIPs has been identified. Trials are on-going to validate (with respect to quality) reduced CIP water usage during bottling tank CIPs. It is expected that CIP water usage for bottling tank CIPs can be reduced further on last year’s reduction.

3. Recycle of product bottle rinse-water – the feasibility of reusing bottle rinse water is ongoing and is currently being considered in Baileys. A trial will be planned for 2010 in the Belfast site and if successful will be trialled in Dublin also.

14 RESIDUALS MANAGEMENT PLAN & ELRA R&A Bailey completed a CRAMP report in January 2009. This report will be reviewed and updated annually and submitted to the EPA. As part of the site’s Annual Environmental Report, in accordance with Condition 10.2 of the IPPC Licence, Register P0004-03 this report can be found in appendix A, attachment2.

21


APPENDIX A

WASTE DATA REGISTER


Licensee's Description of Waste(s) to be Dispatched

EWC Waste origin Facility Waste to be Dispatched to

Type of Facility to be dispatched to (e.g. landfill, recovery facility etc)

approximate Tonnage Per month

Total To2008

Mixed Municipal Waste 20 03 01 Canteen/Production Bord na Mona, Drehid waste managent facility, Co. Kildare.

SFR 67.9 814.2

Process Waste 20 03 01 Waste Flavours Bord na Mona, Drehid waste managent facility, Co. Kildare.

SFR 1.9 23.31

Cardboard 15 01 01 Waste Cardboard Panda Waste, Ballymount, Dublin Recovery 5.2 62.15

Cardboard /layerpads & boxes 15 01 01 Cardboard Boxes Irish Packaging recycling

(formally sumrfit Ireland) Recovery 7.1 85.5

Glass Packaging 15 01 07 Bottling/Decant Rehab Glass, Ballymount Recovery 27.856 334.27

Mixed Dry Recyclables 20 01 99 General Site and Office Dry Recyclable Waste (paper, cans, plastic bottles etc.)

Thorntons Recycling Centre, Killeen Road, Ballyfermot, Dublin 10.

Recovery 5.967 71.6

Chemical Waste 06 02 05 / 06 01 01 Crystal Caustic/Sulphuric bund water

College Proteins, College Road, Nobber, Co. Meath Rendered/Destroyed 0.088 1.05

Municipal Plastic Waste 20 01 39 Plastic Packaging Waste

Shabra Recycling Limited, Killycard Industrial Estate, Bree Castleblaney, Co. Monaghan

Recovery 2.618 31.42


Municipal Biodegradable Waste 20 01 08 Kitchen Waste O'Toole Composting,

Ballintrane, Co. Carlow Recovery as Compost 2.122 25.46

Scrap Metal - light iron and steel 17 04 07, 20 01 40 Fabrication Waste

National Recycling, Station Road, Clondalkin, Dublin 22

Recovery 0.500 6

Timber 15 01 03 Pallet Waste Neiphin trading ltd. Recovery 8.000 96

Waste from Production of Beverages 02 07 04 Off-spec product College Proteins, College

Road, Nobber, Co. Meath Rendered/Destroyed 9.483 113.8

Waste from Edible Oils 02 03 99 Waste Cooking Oil College Proteins, College Road, Nobber, Co. Meath Rendered/Destroyed 0.033 0.4

Interceptor Sludge/Oily water/Waste not other Specified

130899/13 05 03*/130506 Cleaning of Site's interceptors

Rilta Environmental, Greenogue Business Park, Rathcoole, Co. Dublin

Recovery of Oil 11.812 141.74

Electrical Waste / Flourescent Tubes

16 02 14/ 16 02 13*/ 20 01 21*

Obsolete Elec Equipment/Used Lamps

FMW Recycling, Unit 1 IDA Industrial Estate, Balbriggan Co. Dublin

Recovery 0.004 0.05

Medical Waste (First aid station waste) 18 01 03*, 18 02 02* First Aid Station

Transafe Limited, 430 Beech Road, Western Industrial Estate, Naas Road, Dublin 12

Thermal Treatment 0.002 0.027


ATTACHMENT 1

2009 NOISE REPORT


Diageo, Environmental Noise Survey.

Nangor House, Nangor Road, Dublin 12.

DG 2901EN Evelyn J. Conlon 5/11/2009.


CONTENTS

1. Introduction 3

2. Summary 4

3. Conclusions 5

4. Results 6

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 1. Introduction. Ms Evelyn J. Conlon of Diageo, Nangor House, Nangor Road, Dublin 12 requested the assistance of Kearney & Associates Limited in carrying out an environmental noise survey at their plant. This work was carried out on the 2nd of November 2009.

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 2. Summary Traffic on the M50 and on Nangor Road and Park West Avenue is the main source of noise in the immediate vicinity of the Diageo Bailey’s Nangor Road plant. Noise from Diageo Bailey’s plant was not audible over the general environmental noise arising from traffic.

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 3. Conclusions. (1) Environmental noise at the nearest noise sensitive location to the Diageo plant on

Nangor Road is dominated by local road traffic noise particularly from the adjacent M50.

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 4. Results The site layout of the Diageo, Nangor Road, Dublin 12 plant is described in Figure 1. Daytime and night time noise monitoring was carried out at the Diageo facility on Nangor Road and at the noise sensitive location (NSL) marked AN6 on Figure 1 on the 2nd of November 2009. Noise measurements were made at five site boundary points and at the noise sensitive location as detailed in Table 1. “AN” denotes the environmental noise monitoring location.

Table 1 Description of Noise Measurement Points. Noise Measurement Description Point

AN1 South/West corner of site-at corner Nangor Rd/Park West Ave.

AN2 West corner of site-Park West Ave. Intersects Grand Canal.

AN3 North corner of site across from loading bay.

AN4 Boundary fence between Bailey’s and Toyota facility-east of site.

AN5 Eastern entrance to Bailey’s near Cammock River.

AN6 Nearest Noise Sensitive Location-outside Crescent Apts. Off Park

West Ave. Roundabout (Nat. Grid. Co-Ords. E308281, N232357)

Weather conditions may have both positive and negative effects on the propagation of noise. A positive wind vector or a temperature inversion may give an increase in noise level at a distance from the source. A negative wind vector may reduce the received noise level. These effects tend to become more significant at relatively long

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 distances from the noise source. When wind speeds rise above ten knots (five metres per second), locally generated wind noise can have a significant masking effect, often rendering a low-level noise source inaudible. In order to eliminate, in so far as is possible, variable wind and weather factors, noise measurements were confined to periods when weather conditions on and around the site were judged to have no significant effect on noise propagation. Table 2 Daytime Noise Measurements taken on the 2nd November 2009. Location (see Fig 1)

Time LAeq LA90 Noise Sources

AN1 1003 61.8 60.5 Heavy traffic noise Nangor Road and M50

AN2 1015 57.2 56 Heavy traffic noise Nangor Road and M50

AN3 1027 56.6 55.5 Traffic noise M50 and Park West Avenue

AN4 1041 61.2 60 Heavy traffic noise Nangor Road/M50 AN5 1055 64.8 62.7 Heavy traffic noise Nangor Road/M50

and stream noise (running water) AN6 1118 67 65.5 Apartment traffic and traffic noise from

M50 and Park West Avenue AN1 1330 61.4 59.5 Heavy traffic noise Nangor Road, some

on site traffic noise from trucks AN2 1345 59.1 57.5 Heavy traffic noise M50/Nangor Road;

some on site forklift (reversing) noise AN3 1359 56.2 55 Traffic noise M50 & Park West Avenue

and trucks moving on Cemex site next door

AN4 1417 59.2 58.5 Traffic noise from Toyota site and Nangor Road

AN5 1427 59.8 57.2 Traffic noise from Nangor Road and stream noise

AN6 1446 65 64 Traffic noise M50 and Park West Avenue and apartment noise

AN1 1614 61.4 59.5 Heavy traffic noise Nangor Road and M50

AN2 1627 60.5 59.5 Heavy traffic noise M50, Nangor Road and reversing forklift on site, site noise from pumps

AN3 1639 56.7 56 Traffic noise M50 & Park West Avenue, trucks moving on next door


Cemex site AN4 1657 57.6 56.5 Traffic noise Nangor Road , revering

truck AN5 1714 65.9 64 Heavy traffic noise Nangor Road and

running water noise from stream AN6 1735 65.9 54.5 Traffic noise M50 and Park West

Avenue Where possible the audible sources of plant noise and that from other audible sources are identified. Noise levels were measured using a CEL Integrating Sound Level Meter type CEL 480. Wind conditions were light on the day of measurement with occasional gusts of wind. Light rainfall occurred at about 6.30 pm but ceased at approximately 8.00 pm. Measurements of noise levels were made during day time and night time on the 2nd of November 2009. These measurements are shown in Tables 2 & 3. The preferred parameter for estimating environmental noise is the LAeq, and this is shown in Table 1 for the measurements made. When interfering noise from traffic occurs the LAeq would overestimate noise from the factory and in this case the LA90 is used to estimate factory noise. Table 3 Nighttime Noise Measurements taken on the 2nd November 2009. Location (see Fig 1)

Time LAeq LA90 Noise Sources

AN1 1940 59.8 58 Steady traffic noise M50/Nangor Road AN2 1951 58.5 57.5 Traffic noise M50/Park West, pumps

noise AN3 2009 53.7 53 Noise from Park West Avenue, M50 AN4 2023 54.5 53.5 Noise from Nangor Road/M50 AN5 2034 60.4 59.8 Stream noise and traffic noise from

Nangor Road/M50 AN6 2052 64.6 62 Traffic noise M50 and Park West

Avenue AN1 2221 60.9 58 Traffic noise Nangor Road/M50 AN2 2233 57.1 56 Traffic noise M50/Park West AN3 2246 63.6 51.5 Traffic noise from M50 and West Park

Avenue AN4 2258 55.7 53 Off site road traffic noise

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 AN5 2314 57.9 56 Traffic noise M50/Nangor Road, River

noise. AN6 2337 62 60 Traffic noise M50/West Park Avenue

and apartment noise The Environmental Protection Agency normally recommends noise limits of 55 dB(A) at daytime and 45 dB(A) at nightime at noise sensitive locations with no clearly off site audible tonal or impulsive content. A margin of 2 dB is allowed in interpreting noise limit exceedences. Environmental noise arising at measurement points was dominated by traffic noise with Nangor Road being particularly busy at all times. The M50 was a constant source of traffic noise in the background at every measurement point. Environmental noise at the nearby noise sensitive location-Crescent Apartments- was dominated at all times by the continuous traffic at the nearby M50. Traffic noise never ceased completely even late at night. No off site tonal noise was noted but it may not have been practicable to detect a tonal noise output due to the persistent traffic noise at all times during the survey.


ATTACHMENT 2

CRAMP REPORT



Contents

1. EXECUTIVE SUMMARY 4 2. INTRODUCTION 6 2.1 Facility and Licence Details 6 2.2 Facility Closure Scenarios covered in this Plan 6 3. RISK CLASSIFICATION 9 3.1 Screening and Operational Risk Assessment 9 4. SITE EVALUATION 11 4.1 Facility Operations & Materials: Raw materials, Intermediates, Products Handling 11 4.2 Site Inventory 15 4.3 Facility Compliance Status 17 4.4 Waste Materials generated on site 17 5. CLOSURE CONSIDERATIONS 18 5.1 Clean Closure Declaration 18 5.2 Plant & Equipment Decontamination Requirements 18 5.3 Plant Disposal & Recovery 18 5.4 Waste Disposal & Recovery 18 5.5 Soil Removal 18 6. IMPLEMENTATION OF CLOSURE PLAN 19 6.1 Cessation of Production/Construction and Run-down of Stock 19 6.2 Removal of Residual Material and Waste 19 6.3 Cleaning/Decontamination of Plant and Equipment 20 6.4 Removal of Contractor’s Facilities/Equipment 20 6.5 Demolition 20 6.6 Validation Plan/Due Diligence 21 6.7 Transfer or Surrender of Licence 21 6.8 Other Areas 21 7. CRITERIA FOR SUCCESSFUL CLOSURE 22 7.1 Statutory Authority Notifications 22 7.2 Full or Partial Closure Considerations 22 7.3 Review with Agency 22 8. CLOSURE PLAN VALIDATION 23 8.1 Closure Validation Audit 23 8.2 Divestitures and Exiting Leases 23 8.3 Closure Validation Audit Report 24 9. RESIDUALS AND AFTERCARE MANAGEMENT 24 10. CLOSURE PLAN COSTING 25 10.1 Decommissioning Costs 25 10.2 Facility Staffing and Security 27 10.3 Closure Validation Audit (Environmental Due Diligence) 27 10.4 Total Cost of CRAMP 27 10.5 Funding of CRAMP 29 11. CLOSURE PLAN UPDATE AND REVIEW 30 11.1 Proposed Frequency of Review 30 11.2 Proposed Scope of Review 30


1. EXECUTIVE SUMMARY Diageo Baileys Global Supply (DBGS), a subsidiary of Diageo plc, is a cream liqueur manufacturing plant, located on an approximately 9.3 ha site at Nangor Road, Dublin 12. The facility produces Baileys cream liqueur, Sheridan’s liqueur and Smirnoff Vodka. Over 300 people are employed on the site.

Approximately 20% of the 9.3 ha site consists of buildings which house DBGS’s production, office, laboratory, warehousing and utility facilities.

DBGS was granted an IPPC Licence by the EPA on the 11th of May 2007 – Licence No. P0807-01. This Closure, Restoration, Aftercare Management Plan (CRAMP) is prepared in order to furnish the information required by Condition 10.3 of DBGS’s Integrated Pollution Prevention Control (IPPC) Licence. This Residual Management Plan is based on the Environmental Protection Agency’s (EPA) Guidance on Environmental Liabilities, Risk Assessment, Residual Management Plans and Financial Provision (2006).

An initial screening and operational risk assessment of the facility indicates that the facility lies in the low risk category (Category 1).

The scope of this plan addresses the key issues, which will occur in an orderly closure of all the site activities on a phased basis over an estimated time period of 6 months. The basis of the plan is to ensure that, upon completion of the plan, the facility would be in a suitable state for future industrial use and its condition would not pose a risk to public health and safety or to the environment. All decommissioning of materials, equipment and buildings onsite will be carried out to any legislative standards in place at the time, to best environmental practice standards, and in to satisfaction of the EPA. DBGS will submit results of all tests and investigations as necessary to confirm that there is no continuing risk to the environment.

A DBGS’s EHS engineer or another suitably qualified person will supervise all contractors and suppliers involved in plant decommissioning. External contractors required for cleaning, waste disposal or recycling activities will be fully approved and licensed.

In the event of a spillage, leak or fire during decommissioning, DBGS’s Emergency Response Plan will be fully implemented in order to minimise the risk to health and the environment.

Cost estimates have been prepared for each element of the closure plan. The costs are primarily related to the cleaning, decontamination, decommissioning of equipment, divestiture/disposal of obsolete equipment and wastes and the provision of staff and security during the implementation of the Closure Plan and the conduct of an environmental due diligence audit.

As per the site’s Decommissioning Plan, the demolition of 40% of the buildings has been included. This assumes that the remaining 60% will be retained for other potential usage on site. The total cost of implementation of the plan is estimated to be in the order of €2.36 m (considering 10% contingency). In the case that the demolition of the buildings is not to be carried out, the total cost will be in the order of €1.95 m.


DBGS confirms that the Diageo plc has more than adequate resources from operations to fund the CRAMP. In addition, the value of the facility itself as a fixed asset worth in excess of €56m will far outweigh any closure and decommissioning costs.

2. INTRODUCTION

2.1 Facility and Licence Details Diageo plc is the largest multinational beer, wine and spirits company in the world. Its subsidiary, Diageo Baileys Global Supply (DBGS), operates a cream liqueur manufacturing plant on a ~9.3 ha site at Nangor House, Nangor Road, Western Estate, Dublin 12. The DBGS facility produces Baileys cream liqueur, Sheridan’s liqueur, and Smirnoff Vodka. The site location is shown in Figure 2.1. The site’s IPPC Licence, Reg. No. P0807-01, has been granted under the following activity class 7.8.0: Treatments or processes for the purposes of the production of food products from - (a) animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day, (b) vegetable raw materials with a finished product production capacity greater than 300 tonnes per day (average value on a quarterly basis).

PM Group was retained to prepare a Closure, Restoration and Aftercare Management Plan or “CRAMP” (previously known as a Residuals Management Plan or RMP) in accordance with the EPA’s Guidance on Environmental Liabilities, Risk Assessment, Residual Management Plans and Financial Provision (2006), in order to satisfy condition 10.3 of its IPPC Licence.

“10.3 The Residuals Management Plan shall include as a minimum, the following:-

(i) A scope statement for the plan

(ii) The criteria which define the successful decommissioning of the activity or part thereof, which ensures minimum impact on the environment

(iii) A programme to achieve the stated criteria.

(iv) Where relevant, a test programme to demonstrate the successful implementation of the decommissioning plan.

(v) Details of the costings for the plan and the financial provisions to underwrite those costs.”

An initial screening and operational risk assessment indicated that the facility lies in the low risk category (Category 1) (see Section 3.1).

2.2 Facility Closure Scenarios covered in this Plan To develop a fully detailed and costed CRAMP, it is necessary to present a number of assumptions regarding the mode and management of a hypothetical site shut down.

Site closure is considered to include:

• Cessation of the IPPC licensed activity under Article 90 of EPA Act, 1992 as amended by the POE (Protection of the Environment) Act 2003;

• Voluntary or involuntary liquidation of the company or organisation holding the IPPC licence which results in the cessation of the activity;


• Transfer of ownership under Article 91 of EPA Act, 1992 as amended by the POE (Protection of the Environment) Act 2003;

• Site closure as a result of corporate rationalisation or relocation;

• Mothballing of plant/site.

The criteria that will determine the successful implementation of this plan will include:

1. Adequate planning for cessation of activities.

2. Adequate manpower and financial resources to execute the site closure programme.

3. Adequate aftercare of the facility prior to determining its long term future.

DBGS operates a strict environmental policy. Therefore, it is firstly assumed that any shutdown of the site will be a well-planned and well-resourced event. This implies that the shutdown date will be known well in advance and that both production schedules and raw materials purchasing will be planned with the shutdown already factored in. All decommissioning of materials, equipment and buildings onsite will be carried out to any legislative standards in place at the time, to best environmental practice standards, and in to satisfaction of the EPA. It is estimated that the duration of decommissioning and decontamination would be 6 months. Environmental monitoring would continue while the plan is in operation and for a period following the completion of the plan to be determined by the EPA and/or local authority.

DBGS will have the resources in terms of both financial inputs and manpower to implement the CRAMP through to completion, with no requirement for external financing or manpower other than for expert advice. DBGS intends to utilise existing staff resources to form a team to manage and execute the plan, supplemented where appropriate by outside resources. This Residuals Management Team would be responsible for managing and executing the complete plan. Outside contractors required for cleaning, waste disposal, incineration or recycling activities would be fully approved and licensed.

3. RISK CLASSIFICATION PM performed an initial Screening and Operational Risk Assessment on the facility to establish whether it was a low, medium or high risk facility. Depending on the resulting classification, the EPA Guidance Document gives direction on how to prepare the CRAMP.

3.1 Screening and Operational Risk Assessment The Initial Screening and Operational Risk Assessment carried out established that the plant is a low risk facility (Category 1). The risk assessment is shown in Table 3.1 below.


Table 3.1: Initial Screening and Operational Risk Assessment

Complexity1

Licensed Activity Class Band (G1-G5) Score

Class 7.8.0 Food and drink. “Treatments or processes for the purposes of the production of food products from –

(a) animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day,

(b) vegetable raw materials with a finished product production capacity greater than 300 tonnes per day (average value on a quarterly basis).”

G2 2

Environmental Sensitivity

Environmental Attribute Sub-Matrix Score Score

Human Occupation:

- 50-250m

3

Groundwater Protection:

Locally Important Aquifer

Vulnerability: High3

1

2

Sensitivity of receiving waters:

Class C4

1

Air Quality and Topography:

Relatively Simple terrain5

0

Protected ecological sites:

Directly boundering proposed NHA site6

2

Sensitive agricultural receptors: >150m from site boundary

7 0

Total = 9

Environmental Sensitivity Classification Moderate

2

Compliance Record

Licensed facility with minor non-compliances 1

Overall Risk Score (Complexity x Environmental Sensitivity) x Compliance Record)

2x2x1 4

Risk Category: Low Risk Category 1


1 Based on IPPC and Waste Activities Complexity Look-Up Tables.

2 DBGS Site is located in an Industrial state.

3 Locally Important Aquifer- Source GSI: http://193.178.1.182/website/Introduction_to_Groundwater_WebMapping.htm

4 EPA River Quality Map for Ireland, the River Carmac is classed as Q3, moderate polluted status which is classed at C - Source EPA:

http://www.epa.ie/rivermap/report/surveillance.html. 5 DBGS is situated on relatively flat terrain

6 DBGS is border by the Grand Canal which is a proposed NHA, Source NPWS: http://www.npws.ie/en/MapsData

7 There is no farming activity within 150m of DBGS.

4. SITE EVALUATION

4.1 Facility Operations & Materials A layout of the DBGS site is shown in Fig. 4.1. The site can be divided into twelve main areas as shown:

1. Bottling Hall

2. Dispatch/Warehouse

3. Process Building

4. Offices

5. Vodka Plant

6. Whiskey/Spirit Store

7. Blend Room

8. Powder Store

9. Bulk Intake Area (Cream & Alcohol)

10. Ethanol Intake Area

11. Boiler House

12. Sugar & Caustic Storage The materials used on site comprise product ingredients & process materials, packaging, cleaning, boiler & effluent plant chemicals, laboratory & engineering chemicals & materials, and fuel. In addition water is a major consumable in all areas of the site.


Figure 4.1 – Site Location Map

4.1.1 Raw materials The main raw ingredients used at the facility are listed below – the natures of the components are not divulged for reasons of business protection from competitors.

Material Physical State Packaging Type Location

Liquid A (Smirnoff component) Liquid Bulk tank Smirnoff plant

Liquid B Liquid Bulk tank Spirit Store

Liquid C (pasteurized) Liquid Insulated chilled bulk tank

Process Plant

Liquid E Liquid Bulk tank Process Intake Area

Extender Liquid Drums Charcoal store adjacent to the Smirnoff plant

Flavours & Colours Liquid Bulk tank or drums Process plant or Chemstore drum store

Solid F Solid 500 kg or 800 kg bags Powder storeroom

Solid G Solid 25 kg bags Pallet store

Solid H Solid Bulk tank Process plant intake area

Solid K Solid Bulk tank or 800 kg bags Process intake area

Solid L Solid 25 kg bags Powder store

Filter Aid Solid 25 kg bags Powder room

Charcoal Solid Bags Charcoal store adjacent to the Smirnoff plant


Flavour blend Liquid Bulk tank Process plant

Solid K solution Liquid Bulk tank Process plant

Intermediate Smirnoff Liquid Bulk tank Smirnoff plant

4.1.3 Final products – Liquids The main products manufactured at the facility are as follows:

Material Physical State Packaging Type Location

Baileys Liquid Bulk tank/bottles Process plant/

bottling lines/

Warehouse

Sheridan’s Liquid Bulk tank/bottles Process plant/

bottling lines/

Warehouse

Value brands Liquid Bulk tank/bottles Process plant/

bottling lines/

Warehouse

Smirnoff Liquid Bulk tank/bottles Smirnoff plant/

bottling lines/

Warehouse

Once bottled and packed the product is palletized and conveyed to the warehouse where it is removed by forklift trucks for storage and shipment.

4.1.4 Other materials a) Packaging Materials

• Plastic and glass bottles

• Bottle caps and seals

• Tamper seals

• Ink

• Adhesives

• Cardboard and plastic packaging.

a) Cleaning chemicals

A variety of cleaning products are used on site including general cleaning agents and specific cleaning agents for stainless steel tanks, drains and glass.

c) Boiler and effluent plant chemicals


Chemicals are required for boiler water treatment prior to steam production. Acid and hydroxide are required for pH neutralization of effluent in the effluent in the effluent plant.

d) Laboratory chemicals and materials

Chemicals are required in the site laboratories as reagents for quality control testing. In addition materials such as glassware and utensils are also consumed.

e) Engineering materials

In the engineering department the main consumables are spare parts, lubricants, welding gas and refrigeration fluids.

f) Energy/Fuel

The main fuel used on site is natural gas which is piped into the facility. The gas is primarily use to fuel the steam boilers. Energy is also consumed in the form of electricity which is supplied to the site via the national grid. Electricity is used on site to power all the equipment and provide lighting and heating.

Some diesel is also used on site as fuel for on-site shunting vehicles and for running the emergency generator. The generator is only used to power the sprinkler system in the event of loss of electrical power during a fire. In addition to emergency situations the generator is also run for 30 mins every week for maintenance and testing purposes.

4.2 Site Inventory Current materials and maximum storage quantities are shown in Table 4.1.

4.3 Facility Compliance Status The site is generally compliant with its IPPC Licence conditions. The site operates an Environmental Management System (EMS), of which regular internal environmental audits are a key element.

4.3.1 2007 Non-compliance During 2007, only one reportable non-compliance with the licence occurred: a trickle emission of diesel from storm water emission point was discovered. In accordance with the site Emergency Response Plan, security was alerted and river booms were put in place in two locations on the Camac and the emission point was closed using a portable bung device. Investigation of the incident determined that interceptor was not functioning correctly and was allowing hydrocarbons to be released to the river. Remediation work was carried out on the interceptor. It was pumped out several times, with over 30,000 L being removed over 3 days. A full service of the interceptor was also carried out by the manufacturer, including a filter change. Cleaning and inspection of the site interceptors is now scheduled to take place every six months as per the manufacturer’s recommendations.

In addition as part the overall investigation, a comprehensive drainage survey was undertaken. In general, the underground survey proved the existing system to be in good structural condition with only a minor number of issues that require attention. DBGS has undertaken to have these issues addressed and also to review commissioning requirements of the interceptor level alarm system by the end of January 2009. The interceptor alarm system has been set up on the preventative maintenance (PM) system for annual maintenance.

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 4.4 Waste Materials generated on site

The waste materials generated on site comprise the following:

• Off-spec product, sent for beneficial reuse as animal feed;

• Waste oil, sent for appropriate recovery;

• Segregated fractions of recyclable packaging materials (glass, cardboard and plastic);

• Small quantities of miscellaneous other materials.

All waste is removed off-site for recycling, recovery or disposal and is handled by appropriately licensed waste contractors.

5. CLOSURE CONSIDERATIONS DBGS has a Decommissioning Plan in place to be followed in the event of planned or unplanned closure or divestiture of the site.

5.1 Clean Closure Declaration Upon cessation of operations and subsequent decommissioning at the facility, it is anticipated that there will be no remaining environmental liabilities, i.e. clean closure is expected.

5.2 Plant & Equipment Decontamination Requirements All plant and equipment will be decontaminated to ensure the removal of any hazardous materials. Equipment will be verified either analytically or through a visual inspection, as appropriate.

5.3 Plant Disposal & Recovery Plant may be removed for use at other locations, left in place as part of the asset to be disposed of, or scrapped, based on risk assessment and cost benefit analysis.

5.4 Waste Disposal & Recovery All wastes, both non-hazardous and hazardous, will be sent for appropriate recycling, recovery, treatment or dispose at suitable licensed facilities, as per the conditions of the IPPC licence.

5.5 Soil Removal The facility is not obliged under its IPPC licence to conduct regular soil monitoring, as the processes conducted on site have little potential for the contamination of soil. Under DBGS current IPPC licence biannual monitoring of groundwater takes place and will indicate if any contamination of soil has occurred or if testing is required. There is no known incidence or history of groundwater contamination at the site.

6. IMPLEMENTATION OF CLOSURE PLAN Particular actions are listed below for specific areas of the facility as part of the CRAMP. In general, care and attention will be given during the implementation of the plan to ensure that the potential risks associated with the plan are avoided. In the event of a spillage, leak or fire during decommissioning, DBGS’s Emergency Response Plan will be fully implemented in order to minimise the risk to health and the environment. It is anticipated that the closure plan would take 6 months to implement.

The main actions to be taken during decommissioning will consist of:

R&A Bailey IPPC Licence No. P0807-01 Annual Environmental Report 2008 6.1 Cessation of Production/Construction and Run-down of Stock

• Cessation of all production other than completion of work in progress.

• Virgin raw materials will be returned to suppliers where possible.

• Cessation of any construction project work on site so that the site is left in a safe and orderly condition. Contractors will be required to decommission any construction compounds and remove all construction equipment, construction materials and waste, storage units and temporary offices from the site at the completion of construction projects.

6.2 Removal of Residual Material and Waste

• All products will be sent for suitable re-use, recovery, treatment or disposal.

• The removal and authorised disposal of all waste materials (including any potentially harmful materials). Raw materials, intermediates and products will be run down to minimum stock levels as part of the shutdown sequence. The small remaining amounts will be sent back to the supplier, which is the preferred method of disposal. If this is not possible, the materials will be sent for offsite disposal using an appropriate method as per the IPPC licence. Asbestos was not used as a construction material anywhere in the site. Any hazardous waste arising from the plant and utilities areas will be removed from site and disposed of to a suitably licensed facility.

• Hazardous waste such as waste oils, solid waste, fluorescent tubes and other hazardous waste requiring disposal/recovery shall be sent to an agreed waste disposal/recovery site. This will be carried out by licensed waste contractors.

• All waste transported off site shall be transported in accordance with good environmental practice and appropriate national European legislation.

• Non-hazardous waste including canteen, office, process solid waste, insulation from boilers and other waste requiring disposal/recovery shall be sent to an agreed waste/disposal recovery site. This will be carried out by licensed waste contractors.

6.3 Cleaning/Decontamination of Plant and Equipment

• The removal and cleaning of all materials from production equipment, pipelines and storage vessels. Site cleaning procedures, using clean-in-place, steam-in-place, clean-out-of-place, and steam-out-of-place would generally be sufficient for these operations. Additional specific procedures would be developed if required, particularly for high-containment areas. The state of cleanliness would be verified either analytically or through a visual inspection.

• Shutting off unnecessary services to the building. Heating and ventilation capability would be maintained.

• Maintenance of key instrumentation and computer systems required for on-going monitoring of the status of the equipment; the remaining instrumentation to be disconnected and rendered safe.


• Cleaning and decontamination of all floor drains and sumps.

• Underground pipework and pipelines will be removed to the boundary fence and also taken off-site. All sumps and pipe cavities will be rendered safe through gravel filling.

• All laboratory instrumentation shall be decommissioned and cleaned on site. It shall then be sold to another facility for further use.

• Any unopened laboratory reagents and chemicals shall be returned to the suppliers. Any remaining laboratory reagents and chemical shall be disposed via an authorised hazardous waste disposal contractor.

• A Diageo engineer or another suitable qualified person will supervise all contractors and suppliers involved in plant decommissioning.

6.4 Removal of Contractor’s Facilities/Equipment

• All remaining specialised equipment will be sent for suitable re-use or sold to an interested party. Obsolete equipment will be recycled where possible or otherwise disposed of by a licensed contractor.

• Disbandment of contract personnel, facilities and equipment.

• Termination of all non-essential maintenance and other contracts.

• Removal from site any temporary offices or storage areas.

6.5 Demolition

• With the exception of any buildings that may remain on site to be used for environmentally benign purposes, all other structures and plant will be removed to grade level and taken off-site per the DBGS site’s Decommissioning Plan.

6.6 Validation Plan/Due Diligence

• A testing/monitoring plan will be developed for a period of time in agreement with the EPA to demonstrate the successful implementation of the decommissioning plan and to ensure there is no residual contamination from the site.

• Validation by an external consultant to ensure the plant is decommissioned in a safe and environmentally sound manner resulting in no residual risk to the environment.

6.7 Transfer or Surrender of Licence

• The transfer or surrender of the IPPC Licence to the satisfaction of the EPA.

• All IPPC related documentation will be maintained on file at a designated location for a minimum of 7 years post closure of the facility. Where a transfer of the IPPC Licence takes place, the associated IPPC documentation will reside with the new Licensee.


6.8 Other Areas The following other actions would be required to ensure the implementation of the CRAMP on a site-wide basis:

• Continuation of ongoing monitoring programmes to insure the integrity of the groundwater and surface waters on site.

• Rationalisation of the site electricity supply. This would involve removing transformers from service, allowing remaining site operations to run from one transformer. Oils would be removed from redundant transformers.

• Testing of soils and groundwater at the time of decommissioning would be performed and remediation carried out, if necessary.

• Retention of all necessary fire alarms and fire protection systems.

• Retention of standard security patrols, CCTV monitoring and defined site access procedures.

• Removal of all items that may contain mercury (for example fluorescent lights) or any other controlled compounds for recycling or disposal if necessary.

7. CRITERIA FOR SUCCESSFUL CLOSURE Successful clean closure will be expected to be achieved when it can be demonstrated through an Environmental Due Diligence Audit that there are no remaining environmental liabilities at the site. In practice this will require demonstration that the following criteria have been met:

• Continued compliance with IPPC requirements;

• All plant was safely decontaminated using standard procedures and authorised contractors;

• All wastes were handled, packaged, temporarily stored and disposed of or recovered in a manner which complies with regulatory requirements;

• All relevant records relating to waste and materials movement and transfer or disposal were managed and retained throughout the closure process;

• No soil or groundwater contamination at the site. This will be verified using monitoring data and a soil/groundwater assessment at the time of closure (if required);

• The Environmental Management System remained in place and was actively implemented during the closure period;

• The asset is suitable for use as a commercial development site, as demonstrated by an environmental due diligence assessment.

7.1 Statutory Authority Notifications The EPA and local authority will be notified of DBGS’s intentions to full or partially decommission the facility. The Health and Safety Authority will also be notified and also any demolition works will be regulated under the Construction Regulations.

7.2 Full or Partial Closure Considerations


Any partial closure of the facility will be dealt with as a change of activity, as long as the licensable activity remains on the site.

7.3 Review with Agency The planned future use of the site and the updated Closure Plan will be reviewed by DBGS in conjunction with the EPA.

8. CLOSURE PLAN VALIDATION

8.1 Closure Validation Audit Condition 10.4 of the IPPC licence requires that “A final validation report to include a certificate of completion for the residuals management plan, for all or part of the site as necessary, shall be submitted to the Agency within three months of execution of the plan. The licensee shall carry out such tests, investigations or submit certification, as requested by the Agency, to confirm that there is no continuing risk to the environment.”

The scope of due diligence audit will be based on the size and complexity of the subject transaction, facility, and the property. The following measures will be taken into account when executing the due diligence audit:

• An environmental consulting firm will be retained to conduct the due diligence audit under the direction of DBGS.

• The due diligence audit will follow a phased approach, designed to provide more in-depth information with each successive phase.

• Ample time will be allowed to complete all phases, including any required fieldwork and associated analytical testing.

• Where required, the scope of environmental assessments will comply with applicable standards, such as the ASTM Standard Practice for Environmental Assessment.

A due diligence report will be prepared which includes a summary and a detailed explanation of issues, grouped as follows:

• Environmental liabilities, past and present;

• Regulatory non-compliance issues along with a ranking of their severity and implications;

• Major environmental risks;

• Approximate cost estimate to bring closure to these issues.

Such an environmental due diligence audit would take approximately 10 weeks to execute and would cost in the region of €15,000 (2009 costs). These costs include for soil and groundwater sample collection and analysis.

8.2 Divestitures and Exiting Leases When divesting of facilities or real estate properties, an environmental assessment shall be conducted to identify all environmental liabilities and establish a Site Exit Report on the environmental conditions of the property at the time of transfer. These conditions shall be documented and communicated to the purchaser representatives.


If environmental contamination is discovered, the decision to remediate conditions shall be agreed upon with the purchaser shall be reflected in the agreement of sale.

If long-term (greater than two years) environmental warranty is given to purchaser, the scope of environmental assessment shall be accordingly expanded to allow for the establishment of a much more comprehensive

baseline. In all such cases, at a minimum, sewer integrity testing shall be added to the scope of the environmental assessment, unless testing had been recently completed.

8.3 Closure Validation Audit Report For an IPPC licence to be transferred or surrendered there must be a consultation process with the EPA. Normally, the EPA conducts a post-closure audit of the site and thereafter the EPA must be satisfied that the facility is fully compliant with its licence conditions at the time of closure in order to facilitate the formal surrender or transfer of a licence. DBGS will implement any closure plan in consultation with the Agency, towards satisfying the authority that no residual risk will remain.

9. RESIDUALS AND AFTERCARE MANAGEMENT

There is no known history of contamination of soil or groundwater by the facility. There is currently no known environmental pollution that would require long term monitoring or aftercare. Hence this CRAMP does not propose any ongoing monitoring post-closure or decommissioning of the DGBS site.

10. CLOSURE PLAN COSTING

10.1 Decommissioning Costs The costs associated with decommissioning are generally related to the disposal and recycling of equipment and the use of external resources to implement the CRAMP. In certain instances, costs may be recouped through the sale of equipment or materials.

It is expected that external resources will be required in order to implement the CRAMP in full. A list of these resources and associated costs (at 2009 prices) is shown in Table 10.1 below.

The following assumptions were made in estimating the likely costs involved:

• The processes and operations at the facility do not give rise to any reasonable probability that site remediation in the form of groundwater or soil cleanup would be a likely requirement.

• The site would be left in a clean condition, i.e. decontaminated and certified as being free of any chemical hazard. All buildings would be retained. All bulk materials and process intermediates and products would be removed.

• No liabilities would be incurred due to activities of contractors storing and disposing of materials removed from the DBGS site, as DBGS will continue to apply its current waste management principles.

• No civil liability would be incurred as a result of third parties alleging environmental damage arising from the operational phase or closure.

• The maximum asset value of the facility would be maintained, but no action would be taken to prepare the site for a trade sale as a going concern or otherwise.


• Normal practice would be applied to minimise ongoing liabilities and to fulfil insurance requirements.

• It is assumed that the planning authority would not take any action to prevent site dereliction, as the existing facilities would be maintained in a condition suitable for future beneficial use. The planning authority will be notified of the plans to decommission and will be consulted in relation to the isolation of facilities and services on site.

• In addition, no factors have been identified that would indicate an unusual liability for the site in comparison with other process industry sites.

Table 10.1: Breakdown of estimated cost of Decommissioning of Facility

Production area Cost (€)

Cost for tank cleaning Transportation cost to send raw an intermediate material back to supplier/sister site

96,768

Disposal cost for unwanted raw materials 6,182 Disposal cost of unsold vessels/equipment 2,000 Dismantling and Transportation cost of equipment to buyer/sister site 35,200 Subtotal 212,950

Utilities area Cost (€) Cleaning and maintenance 8,800 Subtotal 8,800

Laboratory Cost (€) Cleaning and decontamination of Laboratory/instruments 8,800 Dismantling of other equipment and general cleaning and maintenance 8,800 Removal of all opened chemical containers and out-of date chemicals for recycling or for disposal by a licensed contractor

600

Subtotal 18,200 Offices Cost (€)

Cleaning and maintenance 8,800 Subtotal 8,800

Dispatch/Warehouse Cost (€) Cleaning and maintenance 8,800 Subtotal 8,800

Waste Cost (€) Solid and liquid waste for incineration 2,475 Solid and liquid waste recycled/recovered 56,100 Subtotal 58,575

Other Cost (€)

Buildings demolition (40% of site buildings) 372,000

Liquidator 120,000

Subtotal 1,912,000


10.2 Facility Staffing and Security A number of staff members would be required to remain on site for a period of 6 months to successfully implement the Residuals Management Plan. These are estimated as follows:

Management 2 Security 4 Laboratory 3 Administration 2 Engineering & other staff 14

The total cost of continuing to employ these staff members is expected to be in the region of €1.32million.

On completion of the clearance of the site, the asset will be sold; pending sale the site will be supervised by Security. Depending on the commercial arrangements appropriate at the time, this responsibility may by undertaken by a liquidator. The cost of this supervision is likely to be no more than €120,000 at 2009 prices.

10.3 Closure Validation Audit (Environmental Due Diligence) An Environmental Due Diligence Audit will be required to be conducted to ensure that all liabilities associated with the site are identified prior to divestiture. This will cost approximately €15,000.

10.4 Total Cost of CRAMP The total cost associated with executing a Residuals Management Plan at the DBGS site is estimated to be in the region of €2.36 million, broken down as follows in Table 10.2.


Table 10.2: Estimated Cost of execution of CRAMP

Production area Cost (€)Cost for tank cleaning 72,800Transportation cost to send raw an intermediate material back to supplier/sister site

96,768

Disposal cost for unwanted raw materials 6,182Disposal cost of unsold vessels/equipment 2,000Dismantling and Transportation cost of equipment to buyer/sister site

35,200

Subtotal 212,950Utilities area Cleaning and maintenance 8,800Subtotal 8,800Laboratory Cleaning and decontamination of Laboratory/instruments 8,800Dismantling of other equipment and general cleaning and maintenance

8,800

Removal of all opened chemical containers and out-of date chemicals for recycling or for disposal by a licensed contractor

600

Subtotal 18,200Offices Cleaning and maintenance 8,800Subtotal 8,800Dispatch/Warehouse Cleaning and maintenance 8,800Subtotal 8,800Waste Solid and liquid waste for incineration 2,475Solid and liquid waste recycled/recovered 56,100Subtotal 58,575Other Buildings demolition 372,000Staff and Security 1,320,000Closure Validation Audit (Environmental Due Diligence) 15,000Liquidator 120,000Subtotal 1,827,000Final Subtotal (including demolition of 40% of the site buildings)

2,143,125

Contingency 10% 214,313Total (including demolition of 40% of the site buildings) 2,357,438Final Subtotal (excluding demolition of 40% of the site buildings)

1,771,125

Contingency 10% 177,113Total (excluding demolition of 40% of the site buildings) 1,948,238


the CRAMP will cost in the order of €2.36 m. Without demolition of the buildings the total cost will be in the order of €1.95 m.

10.5 Funding of CRAMP DBGS confirms that the company has more than adequate resources from operations to fund the CRAMP as set out above.

Further details on the financial status of DBGS can be found in the 2007 Annual Report, available at the following web address:

http://www.diageo.com

In addition, the value of the developed 9.3 acre site itself as a fixed asset will far outweigh any remediation cost.

11. CLOSURE PLAN UPDATE AND REVIEW

11.1 Proposed Frequency of Review This CRAMP will be reviewed and updated annually and submitted to the EPA as part of the site’s Annual Environmental Report, in accordance with Condition 10.2 of the IPPC Licence, Register Number P0004-03.

11.2 Proposed Scope of Review The scope of the annual review of the RMP will cover the following at a minimum:

• Review in accordance with the facility’s IPPC Licence conditions;

• Review any incidents that may result in soil or groundwater contamination;

• Review changes in underground structures; and

• Review scope of decontamination and decommissioning required.







R&A Bailey IPPC Licence No. P0807-01 Annual Environmental ... · R&A Bailey Annual Environmental Report 2009 1 INTRODUCTION R&A Bailey & Company, Nangor House, Nangor Road, Western

Documents