arrabawn co-operative society: production upgrade(sodium metabisulphite) 7681-57-4 10034-089-5 200l...

Arrabawn Co-operativeSociety: Production UpgradeBaseline and Condition Report

14 June 2018

Arrabawn Co-operative Society

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1 11 Ahttps://mottmac.sharepoint.com/teams/pj-a483/do/Documents/Licence ReviewApplication/4. Activity and Capacity/Attachment 4.8 Baseline and Condition Report.docxMott MacDonald

Mott MacDonaldSouth BlockRockfieldDundrumDublin 16 D16 R6V0Ireland

T +353 (0)1 2916 700mottmac.com

Arrabawn Co-operativeSocietyStafford StreetNenaghCounty Tipperary

Arrabawn Co-operativeSociety: Production UpgradeBaseline and Condition Report

14 June 2018

Directors: C O’Donovan BE MBA CEngMIET (Managing), J T Murphy BEHDipMM CEng FIEI CMCILT (DeputyManaging), D Herlihy BE MSc CEng, KHowells BSc MBA CEng MICE MCIWEM(British), F McGivern BSc DipEnvEngCEng MIEIInnealtoirí Comhairleach (ConsultingEngineers)Company Secretary: Ian Kilty BA (Hons)ACARegistered in Ireland no. 53280. MottMacDonald Ireland Limited is a member ofthe Mott MacDonald Group

Arrabawn Co-operative Society

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Mott MacDonald | Arrabawn Co-operative Society: Production UpgradeBaseline and Condition Report

1 | 11 | A | 14 June 2018

Issue and Revision Record

Revision Date Originator Checker Approver DescriptionA 5th June

2018J Baxter M McCarthy P Kelly Licence Review Issue

Document reference: 1 | 11 | A

Information class: Standard

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or beingused for any other purpose, or containing any error or omission which is due to an error or omission in data suppliedto us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to otherparties without consent from us and from the party which commissioned it.

This Re por t has be en p rep are d solely for use by t he p arty w hich c om mission ed it (the 'Client') i n co nnecti on wit h the cap tione d p roject . It s hould not be used for any oth er p urp ose. N o p erso n ot her tha n th e Client or any party who has expr essly a gre ed t er ms of relia nce wit h us (the 'Recipie nt(s )') m ay r ely on the cont ent, info rma tion or any view s exp ress ed in the R epo rt. This R epo rt is co nfide ntial and c ont ains p rop riet ary in tellect ual p rop erty and we ac cept no duty of ca re, resp onsibility or li ability t o any oth er recipi ent o f this R epo rt. N o re pre sent ation , wa rran ty o r un dert aking , exp ress or i mplie d, is made an d no res ponsi bility or liability is acce pted by us to any p arty oth er t han the Cli ent or a ny Reci pient (s), as t o the accu racy or c om plete ness of th e info rm ation cont aine d in t his Rep ort. Fo r t he av oida nce o f do ubt t his Re port do es no t in any way pu rpo rt to includ e a ny leg al, ins ura nce or fin ancial advic e or opini on.

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Mott MacDonald | Arrabawn Co-operative Society: Production UpgradeBaseline and Condition Report

1 | 11 | A | 14 June 2018

1 Introduction 11.1 Background 11.2 Site Description 1

1.2.1 Offices 11.2.2 Milk Processing Facility 11.2.3 Wastewater Treatment Plant 2

1.3 Activities and Licence Details 31.4 Planning Status 3

2 Stage 1: Identifying Hazardous Substances 42.1 Current Site Activities 42.2 List of Hazardous Substances Stored on Site 4

3 Stage 2: Identifying Relevant Hazardous Substances 7

4 Stage 3: Site-Specific Pollution Possibility 13

5 Conclusion 26

A. Site Condition 27A.1 Geology and Soils 27A.2 Hydrogeology 27A.3 Geological Heritage Areas 29A.4 Geohazards 30A.5 Radon 30

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Mott MacDonald | Arrabawn Co-operative Society: Production Upgrade 1Baseline and Condition Report

1 | 11 | A | 14 June 2018

1 Introduction

1.1 BackgroundBaseline Reports are required in accordance with Article 22 of the Industrial Emissions Directive(2010/75/EU), where an activity involving the use, production or release of relevant hazardoussubstances has the possibility of contaminating soil and groundwater.

This Baseline Report has been completed for the Arrabawn Co-operative Society (hereafterreferred to as Arrabawn) dairy processing plant located in Nenagh, Co. Tipperary. The reporthas been prepared in support of an application to review Industrial Emissions Licence P0791-02.

The preparation of this Baseline Report was informed by the following information sources:

● Inventory of materials/substances (i.e. type, volume etc) information provided by Arrabawn;● Bund Integrity Assessment Report (2017) prepared by Panther Environmental Solutions

Limited;● Silo and Tank Inspection Report (2017) prepared by PlateTek Engineering Limited;● Ground Investigation Report (2014) prepared by Priority Geotechnical.

It is intended that this report will form the basis for a comparison of the pre-condition of thereceiving environment with the condition upon definitive cessation of the facility’s operation.

The pre-existing condition of the site is characterised in Appendix A.

1.2 Site DescriptionArrabawn’s milk processing plant is located in Stafford Street in Nenagh, County Tipperary. Itsoperations are divided between three sites, located in close proximity to each other, as follows:

● Arrabawn offices;● Arrabawn milk processing facility; and● Arrabawn wastewater treatment plant.

Both the offices and the milk processing facility are located on Stafford Street. The wastewatertreatment plant (WWTP) is located approximately 120 metres to the south of the milk processingplant. Adjacent land uses to Arrabawn’s various site locations include residential andcommercial properties as well as agricultural pasture land.

1.2.1 Offices

Arrabawn’s office facilities are located on Stafford Street, and serve as the head office for arange of personnel working in production, quality, environment, purchasing, sales, marketing,human resources, research & development, finance and administration.

1.2.2 Milk Processing Facility

The milk processing facility is also located on Stafford Street and comprises the following mainbuildings, plant and equipment:

● Car Park;● Weighbridge;

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● CIP Room;● Liquid Milk Cold Store;● Laboratory;● Process Building consisting of;

– Butter Room;– Churning Room;– Dry Store;– Canteen & Locker Room;

● Warehouse and Dryer Plant Building consisting of:– Refrigeration Store;– Boiler House;– Evaporator Room;– Powder Store;– Compressor Room;– Separator Room;– Bagging Off Room;– Tower No.1;– Tower No.2;

● Casein Process Building;● Compound Store;● General Store;● Oil Bund;● Water Tank;● Milk Intake Area;● Covered Loading Bay;● Chemical Storage Bund; and● Dry Goods Store.

1.2.3 Wastewater Treatment Plant

The WWTP is located approximately 120 metres to the south of the milk processing plantconsists of the following key plant and equipment:

● Dissolved Air Floatation (DAF) Unit;● Dairy Balance Tower;● Chemical DAF;● Biotower;● Casein Balance Tank;● Aeration Tanks No.1 and 2;● Sludge thickening and Dewatering Tank;● Inter-stage Settlement Tank;● Anoxic Tank;● Aeration Tank; No 3.;

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1 | 11 | A | 14 June 2018

● Settlement Tank;● Tertiary DAF; and● Drum Filter.

1.3 Activities and Licence DetailsArrabawn requires an Industrial Emissions Licence from the Environmental Protection Agency(EPA) as its operations fall into the categories of industrial activity referred to by the FirstSchedule of the Environmental Protection Agency Act 1992, as amended. Section 7.2.1 of theFirst Schedule of the Act states that an Industrial Emissions Licence is required for:

Treatment and processing of milk only, the quantity of milk received being greater than 200tonnes per day (average value on an annual basis).

Arrabawn’s operations have been licenced by the Agency since 2009; firstly, under licenceP0709-01 and since 2012 under licence P0791-02. This license sets out in detail the conditionsunder which the facility is managed and operated.

1.4 Planning StatusA planning application for the proposed development, which is subject to the licence reviewapplication to the EPA has been submitted to Tipperary County Council. An EnvironmentalImpact Assessment Report (EIAR) was submitted with this application. Once planningpermission has been granted, notification of same will be immediately provided to the Agency.

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2 Stage 1: Identifying Hazardous Substances

2.1 Current Site ActivitiesA milk processing plant has been in operation at this location in Nenagh since it was originallyfounded by Nenagh C-operative in 1913. Over the years, the plant has been expanded by theaddition of various plant, equipment and infrastructure. In 1974, the first dryer was installed andthe second dryer was installed in 1979. The casein processing plant was installed in 1988. Thebutter plant was modernised and upgraded in 1993. Whey production started in 1997. In 2002,Nenagh Co-operative merged with Mid West Farmers Co-operative to form Arrabawn Co-operative Society.

2.2 List of Hazardous Substances Stored on SiteTable 1 lists the hazardous substances which are directly associated with the operation of thedairy processing plant.

Table 1: Arrabawn (Production Upgrade): List of Hazardous Substances to be Stored onSite

Material/Substance

CAS Number AmountStored(tonnes)

TypicalAnnualUsage(tonnes)

Nature of use

1. AluminiumSulphate Ferric

10028.22.5 48.6 720 Treatment ofpotable water aswell as processwater, wastewater,sewage, andindustrial effluents

2. SodiumHypochlorite14%

7681-52-9 2 6 Disinfecting,oxidising, andbleaching agent

3. Lactic Permeate40%

502.15 24 48.4 Food Ingredient

4. Nitric Acid 7697-37-2 48 450 Industrial cleaningagent for food anddairy equipment;CIP

5. Caustic Liqour30%

1310-73-2 30 1300 Industrial cleaningagent; effluenttreatment, pHadjustment andtreatment

6. PotassiumHydroxide

1310-58-3 30 800 Neutraliser Whey

7. HydrochloricAcid

7647-01-0 37 1000 Proteinmanufacturing:demineralizingwhey, usedextensively incasein

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8. Maintenance Oil 2.5 10 Various machineoils formaintenance

9. Amertrol 1123(tetrapotassiumpyrophosphate)

7320-34-5 200L 600L Scale inhibitor inboiler watertreatment

10. Amersite(sodiummetabisulphite)

7681-57-410034-089-5

200L 600L Corrosion inhibitorin boiler watertreatment

11. Butomat NCCleaningChemical

7681-52-9 1 11 Industrial cleaningagent

12. SD 100 Antifoam N/A 0.25 0.375 Control foamgeneration ingeneral chemicalprocessingapplications suchas industrialcleaning and wastewater treatment

13. Ferric Nitrate Iron (III) Nitrate(10421-48-4, 233-899-5)Water (7732-18-5)

3 20 Cleaning agent

14. Lactol 1310-73-2 5 199.65 Clean-in-place(CIP): interiorsurfaces of pipes,vessels, processequipment, filtersand associatedfittings

15. Cellfloc C5 N/A 2 21 Wastewatertreatment agent

16. Cellfloc C19 75150-29-768213-23-064742-46-7

3 30 Wastewatertreatment agent

17. MicroseedLf2518

67-56-1 1 7.1 Wastewatertreatment agent

18. Microseed G 50L < 1 Wastewatertreatment agent

19. Refined GranularSalt

7647-14-5 24 207.5 Water treatmentand softeningagent

20. Performax PM3601

26099-09-21233879-59-85995-42-6

150L 300L Cooling towerwater treatmentagent

21. Alkfoam S 111-76-261789-40-067-63-01310-73-23088-31-1

0.15 0.50 Industrial detergent(washing) agent

22. Dryfloc 7995 64742-47-877-92-968002-97-168551-12-2

1 4.2 Wastewatertreatment

23. Memacid (nitricacid, phosphoricacid)

7697-37-27664-38-2

2 9m3 CIP of membranefiltration process

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24. Memalk(potassiumhydroxide)

1310-58-3 2 21m3 CIP of membranefiltration process

25. Memplus N/A 2 6m3 CIP of membranefiltration process

26. Memzyme 9014-01-1 0.05 2 CIP of membranefiltration process

27. Memplex 1310-73-2 1 4 CIP of membranefiltration process

28. Memlip N/A 0.05 0.05 CIP of membranefiltration process

29. SuperSol N/A 0.10 1 All-purposedegreaser/cleaningagent

30. Chloro-foamND3

67.66.3 0.15 0.3 Disinfectantfoamer

31. AMC-70(acetylatedmethyl cellulose)

9004-67-5 1 6 Cleaning chemicalfor truck wash

32. Amphotrol-FB5 139734-65-9 0.5 2.5 Industrial detergentand sanitisingagent

33. Amphotrol TE N/A 0.05 0.25 Industrial detergentand sanitisingagent

34. P3 Stabicip HX(Ethylenediamine tetraacetate,Sodiumhydroxide)

64-02-81310-73-2

2 10 Industrial cleaningagent

35. Biosperse 250 10377-60-355965-84-9, 2682-20-47786-30-3

100L 300L Control of bacteria,fungi, and algae inindustrialrecirculatingcooling watersystems

36. Biosperse 535 55566-30-8 100L 300L Control of bacteria,fungi, and algae inindustrialrecirculatingcooling watersystems

37. Cellfloc A12 39290-78-342751-79-1

21 400 Flocculant for DAF

38. Cellfloc A10 10043-01-3 21 200 Flocculant for DAF

39. Sulphuric acid98%

7664-93-9 25m3 75m3 pH adjustment inthe effluent plant

40. Peracetic acid15%

64-19-77722-84-179-21-0

3m3 3m3 Sterilant

41. Milk & Milkproducts

N/A 3500 323000 Raw Material

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3 Stage 2: Identifying Relevant Hazardous Substances

Table 2 identifies the potential pollution risk of each hazardous substance, identified in theprevious section. This information is used to determine whether or not the substance has thepotential to cause pollution to soils or groundwater.

Table 2: Arrabawn (Production Upgrade): Relevant Hazardous SubstancesMaterial/Substance

AmountStored(tonnes)

Nature of use Potential to CausePollution to Soils orGroundwater in theAbsence of Control /Storage Attenuation

1. Aluminium Sulphate Ferric 48.6 Treatment ofpotable water aswell as processwater,wastewater,sewage, andindustrialeffluents

Low -The product is an inorganicsubstance/preparation. Duringhydrolysation, a precipitate isformed of metal hydroxide in thepH-range 5 to 7. Due to thisreaction the pH in the waterphase decreases.

2. Sodium Hypochlorite 14% 2 Disinfecting,oxidising, andbleaching agent

HighH400 – Very toxic to aquatic life.P273 - Avoid release to theenvironment. 6.2. Environmentalprecautions.Spillages or uncontrolleddischarges into watercoursesmust be IMMEDIATELY alertedto the Environmental Agency orother appropriateregulatory body.

3. Lactic Permeate 40% 24 Food Ingredient Low – High volumes in watercan cause eutrophication andlowering of pH.

4. Nitric Acid 48 Industrialcleaning agentfor food anddairy equipment;CIP

High - Being a strong mineralacid, nitric acid will causeimmediate scorching ofvegetation: in water courses theresulting depression ofpH may be fatal to aquatic.GENERAL: Vegetation contactedwith undiluted Nitric Acid will bedestroyed by corrosive action. Inrivers lakes, etc. Nitric Acid willcause a lowering of pH whichmay prove fatal to aquatic lifeforms.MOBILITY: Highly mobile due tohigh water solubility. Therefore,rapidly diluted in water coursesand leached from soils, althoughlow pH in soils may requirerectifying by lime additions.Discharge into the environmentshould be avoided Nitric Acid isharmful to aquatic life even inlow concentrations due to its acid

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nature. Neutralisation isgenerally required prior todischarge.Nitric Acid can cause damage tovegetation. Inhibition ofdegradation activity in activatedsludge is not to be anticipatedduring correct introduction of lowconcentrations. Not consideredto bio-accumulate.

5. Caustic Liqour 30% 30 Industrialcleaning agent;effluenttreatment, pHadjustment andtreatment

High - Concentrations greaterthan 10ppm, or with a pH valueequal or greater than 10 can beacutely toxic to aquatic life,especially in fresh water.Concentrations sufficient torender effluent alkaline maycause damage to effluenttreatment organisms.

6. Potassium Hydroxide 30 Neutraliser Whey High - This material is alkalineand may raise the pH of surfacewaters with low bufferingcapacity. Releases should bereported, if required, toappropriate agencies. Thismaterial is alkaline and mayraise the pH of surface waterswith low buffering capacity. Thismaterial has exhibited moderatetoxicity to aquatic organisms.Biodegradation: This material willdisassociate into ionic form in theaquatic environment.Natural carbon dioxide will slowlyneutralise this material. Groundwater pollutant.

7. Hydrochloric Acid 37 Proteinmanufacturing:demineralizingwhey, usedextensively incasein

High - Major discharge mayhave a negative effect in a waterenvironment due to local pHreduction. Consists mainly ofnon-organic material which is notbiodegradable. Prevent spillageentering a watercourse or sewer,contaminating soil or vegetation.If this is not possible notifyappropriate authoritiesimmediately.

8. Maintenance OilOilM 2.5 Various machineoils formaintenance

Moderate - Spills may form afilm on water surfaces causingphysical damage to organisms.Oxygen transfer could also beimpaired. Low solubility andfloats and is expected to migratefrom water to land. Expected topartition to sediments.

9. Amertrol 1123(tetrapotassiumpyrophosphate)

200L Scale inhibitor inboiler watertreatment

No data available – should betreated as hazardous waste.

10. Amersite (sodiummetabisulphite)

200L Corrosioninhibitor in boilerwater treatment

No data available – should betreated as hazardous waste.

11. Butomat NC CleaningChemical

1 Industrialcleaning agent

High - Concentrations greaterthan 10 ppm, especially in freshwater or a pH value equal to orgreater than 10.5 may be fatal tofish and other aquatic organisms.

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Can cause damage to aquaticplants.

12. SD 100 Antifoam 0.25 Control foamgeneration ingeneral chemicalprocessingapplications suchas industrialcleaning andwaste watertreatment

Low – food grade antifoam –>80% biodegradable. Will notbioaccumulate.

13. Ferric Nitrate 3 Cleaning agent Low - The product can hydrolyseand form a precipitate of ironhydroxide when diluted beyond aparticular level. The solubility ofthe product is dependent on itspH value.

14. Lactol 5 Clean-in-place(CIP): interiorsurfaces ofpipes, vessels,processequipment, filtersand associatedfittings

High - Do not allow ANYenvironmental contamination.Concentrations greater than 10ppm, especially in fresh water ora pH value equal to or greaterthan 10.5 may be fatal to fishand other aquatic organisms.Can cause damage to aquaticplants. The product is notbioaccumulating. Sodiumhydroxide degrades readily byreaction with the natural carbondioxide in the air.

15. Cellfloc C5 2 Wastewatertreatment agent

Low - Readily biodegradable



17. Microseed Lf2518 1 Wastewatertreatment agent

High - Do not allow ANYenvironmental contamination. Ifspillage or contaminatedwashings cause contamination ofwater courses, drains orvegetation inform relevantauthorities. Concentrationsgreater than 10 ppm, especiallyin fresh water or a pH valueequal to or greater than 10.5may be fatal to fish and otheraquatic organisms. Can causedamage to aquatic plants. Theproduct is not bioaccumulating.

18. Microseed G 50L Wastewatertreatment agent

High - Do not discharge intodrains or rivers. Contain thespillage using bunding. Harmfulto aquatic organisms, may causelong term adverse effects in theaquaticenvironment.

19. Refined Granular Salt 24 Water treatmentand softeningagent

Low

20. Performax PM 3601 150L Cooling towerwater treatmentagent

High - Do not allow ANYenvironmental contamination. Donot flush into surface water orsanitary sewer system. Thisproduct is miscible with water.May spread in water systems.

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21. Alkfoam S 0.15 Industrialdetergent(washing) agent

Moderate - corrosive

22. Dryfloc 7995 1 Wastewatertreatment


23. Memacid (nitric acid,phosphoric acid)

2 CIP ofmembranefiltration process

Moderate - Large dischargesmay contribute to theacidification of water and beharmful to aquatic life.

24. Memalk (potassiumhydroxide)


High - Concentrations greaterthan 10ppm, or with a pH valueequal or greater than 10 can beacutely toxic to aquatic life,especially in freshWater.

25. Memplus 2 CIP ofmembranefiltration process

Low – No data available forpreparation

26. Memzyme 0.05 CIP ofmembranefiltration process

High - Keep away from drains orthe aquatic ecosystem. Reactionwith most common metalsliberates toxic oxides of nitrogenand hydrogen. Large dischargesmay contribute to theacidification of water and beharmful to aquatic life.Eutrophicating substance. Canbe harmful to organisms that livein the water. Avoid discharge tosurface waters. Soluble in water.High mobility in soil. There isevidence of slow degradation insoil and water. Inhibition ofdegradation activity in activatedsludge is not to be anticipatedduring correct introduction of lowconcentrations.

27. Memplex 1 CIP ofmembranefiltration process

High - Prevent soil and waterpollution. Prevent spreading insewers. Concentrations greaterthan 10ppm, or with a pH valueequal or greater than 10 can beacutely toxic to aquatic life,especially in fresh water Datarelates to concentrate. Theproduct has high mobility in soil.Low potential for absorption insoil. Ground water pollutant.

28. Memlip 0.05 CIP ofmembranefiltration process

High - Spillages or uncontrolleddischarges into watercoursesmust be IMMEDIATELY alertedto the Environmental Agency orother appropriateregulatory body. Absorbs theatmospheric CO2. PotassiumHydroxide degrades readily byreaction with the natural CarbonDioxide in the air. Heat releaseresulting in increased fire orexplosion risk. The product hashigh mobility in soil. Has lowpotential for bioaccumulation andis soluble in water.

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29. SuperSol 0.10 All-purposedegreaser/cleaning agent

Low - No special environmentalprecautions required

30. Chloro-foam ND3 0.15 Disinfectantfoamer

High - Do not allow ANYenvironmental contamination. Donot flush into surface water orsanitary sewer system. If theproduct contaminates rivers andlakes or drains, inform respectiveauthorities. Concentrationsgreater than 10 ppm, especiallyin fresh water or a pH valueequal to or greater than 10.5may be fatal to fish and otheraquatic organisms. Can causedamage to aquatic plants. Noexperimental data available forpreparation. Water,soil/sediments: Considerablesolubility and mobility.Soil/sediments: Mobile, soluble,ionisation/neutralisation. Air:chemicaldegradation.

31. AMC-70 (acetylated methylcellulose)

1 Cleaningchemical fortruck wash

Low - Not regarded asdangerous for the environment

32. Amphotrol-FB5 0.5 Industrialdetergent andsanitising agent

Low – no data available

33. Amphotrol TE 0.05 Industrialdetergent andsanitising agent

Moderate - Do not dischargeinto drains, water courses oronto the ground. Spillages oruncontrolled discharges intowatercourses must beIMMEDIATELY alerted to theEnvironmental Agency or otherappropriate regulatory body. Theproduct has high mobility in soil.Potash liquid has low volatility.Concentrations >10ppm or with apH value equal or greater than10 can be acutely toxic toaquatic life especially in freshwater.

34. P3 Stabicip HX(Ethylenediaminetetraacetate, Sodiumhydroxide)


Moderate - Do not dischargeinto drains/surfacewaters/groundwater. Notregarded as dangerous for theenvironment.

35. Biosperse 250 100L Control ofbacteria, fungi,and algae inindustrialrecirculatingcooling watersystems

High - Toxic to aquatic life withlong lasting effects.

36. Biosperse 535 100L Control ofbacteria, fungi,and algae inindustrialrecirculatingcooling watersystems

High - Very toxic to aquaticorganisms, may cause long-termadverse effects in the aquaticenvironment.

37. Cellfloc A12 21 Flocculant forDAF

Low - Not regarded asdangerous to the environment.

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Moderate – Because of the lowpH of this product, it would beexpected to produce significantecotoxicity upon exposure toaquatic organisms and aquaticsystems. The product canhydrolyse and form a precipitateof iron hydroxide when dilutedbeyond a particular level. Thesolubility of theproduct is dependent on its pHvalue.

39. Sulphuric acid 98% 25m3 pH adjustment inthe effluent plant

High - Forms corrosive mixtureswith water even if diluted.Harmful effect due to pH shift.Endangers drinking-watersupplies if allowed to enter soil orwater. Discharge into theenvironment must be avoided.

A historic spill incident involvingsulphuric acid within the WWTPoccurred in July 2017 whichresulted in a loss of approx. 700to 1,500 litres. Corrective actionwas immediately taken byArrabawn; specifically, aremedial programme of workwas devised by BREL, approvedby Arrabawn and the EPA,utilising a ‘Source-Removal’approach to clean-up the spillareas, and a post-validationlaboratory report confirmed noadverse or sustained impacts tosoil, surface water, orgroundwater.

40. Peracetic acid 15% 3m3 Sterilant Moderate - Toxic for aquaticorganisms. Nevertheless, hazardfor the environment is limited dueto product properties: nobioaccumulation, considerableabiotic and biotic degradability,weak persistence of degradationproducts.

41. Milk & Milk products 3500 Raw Materials High – Large volumes have thepotential to cause fish kills due tohigh BOD

42. Effluent 45.38m3 Waste Moderate – untreated effluent/sludge has the potential to causeeutrophication and low O2 levels

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4 Stage 3: Site-Specific Pollution Possibility

As previously stated, the existing Arrabawn milk processing facility is located on Stafford Streetin Nenagh, County Tipperary. Its operations are divided between three sites, located in closeproximity to each other, as follows: Arrabawn offices, Arrabawn milk processing facility, and theArrabawn wastewater treatment plant. The dairy processing plant area predominantly consistsof hardstanding and small area of greenfield land along its north-eastern periphery. The WWTPis also situated on hardstanding. No other known historical activities have been undertaken onthe site and there is no evidence of contaminated soils or groundwater. It should be noted thatbetween the 19th and 24th of February 2014, Priority Geotechnical conducted a groundinvestigation (GI) at the site of the new Evaporator Building which is located centrally within themain processing facility. The GI comprised of two boreholes (BH01 and BH02) which werebored to a depth of 3.5m below existing ground level (bgl) to 3.9m bgl. Additionally, two rotaryboreholes (RC01, and RC02) were undertaken to depths of 9.0m bgl to 9.3m bgl. A total ofseven bulk disturbed samples, six small disturbed samples, and one undisturbed sample weretaken as well as rotary cores being obtained. Following laboratory analysis, it was determinedthat the underlying geology consisted of Calp, dark grey black limestone, and shale whilesubsoil mapping indicated glacial till derived from limestone (TLs), made-ground, and alluvialdeposits. Of significant note, analysis of findings did not identify any evidence of containmentswithin the on-site soil samples or in groundwater.

In relation to the substances stored on site, it should be noted that each of the substancesbrought forward from Stage 2 have been reviewed in the context of the site to determinewhether circumstances exist which may result in the release of the substance in sufficientquantities to represent a pollution risk, either as a result of a single emission or as a result ofaccumulation from multiple emissions. The review concluded that there is no significantpossibility for contamination of soil or groundwater based on the review of the Bund IntegrityAssessment Report (20170 prepared by Panther Environmental Solutions Limited and the Siloand Tank Inspection Report (2017) prepared by PlateTek Engineering Limited, both of whichhave been previously submitted to the Environmental Protection Agency as part of theimplementation of Licence P0791-02. Both of these reports identified minor corrective actionswhich have been implemented by Arrabawn. Arrabawn is committed to ensuring that regularinspections and updates to these reports are provided to the Agency to ensure that no defectsarise which might present a risk of there being a significant pollution risk to soils or groundwater.

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Table 3: Assessment of Site-Specific Pollution Possibility

Material/Substance

AmountStored

(tonnes)

Nature of Use Location Containment Mechanisms SignificantPossibility of

Pollution1. Aluminium

SulphateFerric

48.6 Treatment ofpotable water aswell as processwater,wastewater,sewage, andindustrialeffluents

Milk ProcessingFacility / WWTP

Within the Milk Processing Facility, aluminiumsulphate ferric is held within a locked bundcharacterised as having steel cladding fixed to abox section steel framework. The base of the bundwas relined with fiberglass matting, pack epoxyresin, and hardener and chemical resistant paintduring October 2017 in order to repair leakage insection one.Within the WWTP, three bunds of variouscompositions are utilised:● a locked bund with steel cladding fixed to a box

section steel framework;● a plastic double yellow bund type medium

density Polyethylene "one-piece" construction;● concrete base with concrete walls internally

coated with a solvent-free polyurethane. Thepolyurethane was brush applied to a filmthickness of approx. 1.5mm to provide a water-tight seal which is considered suitable for thistype of wall structure. The coating was alsoapplied to the joints between the wall andconcrete floor.

These bunds were visually assessed during a bundintegrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress or major corrosion.

No

2. SodiumHypochlorite14%

2 Disinfecting,oxidising, andbleaching agent

Milk ProcessingFacility

Within the Milk Processing Facility, SodiumHypochlorite is held within a locked bundcharacterised as having steel cladding fixed to abox section steel framework. The base of the bundwas relined with fiberglass matting, pack epoxyresin, and hardener and chemical resistant paintduring October 2017 in order to repair leakage insection one.The Sodium Hypochlorite is transferred from IBC toa 1200L tank that is contained within a concretebund that is lined. This bund was visually assessed

No

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Material/Substance

AmountStored

(tonnes)


Pollutionduring a bund integrity inspection by PantherEnvironmental Solutions (2017), and showed noevidence of leakage, seepage, distress, majorcorrosion

3. LacticPermeate40%

24 Food Ingredient Milk ProcessingFacility

Lactic Permeate 40% is within a locked store with abund that was visually assessed during a bundintegrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion orweld failure.

No

4. Nitric Acid 48 Industrialcleaning agentfor food anddairy equipment;CIP


Nitric Acid is stored in two bunds: 1) enclosure with220mm thick concrete block wall, plastic coatedwalls and floors in order to facilitate a water-tightseal, and a steel reinforcement bracket, and 2)enclosure with 145mm thick concrete block walland plastic-coated walls and floors in order tofacilitate a water-tight seal.Upon original inspection of the 145m concrete wallenclosure, it was determined that a section of thebund was unsound due to the presence of anunsealed outlet pipe in the base of the bund,seepage from sealed redundant holes, unsealedredundant holes, and protruding outlet valves overthe edge of the bund. Repair works included:sealing of all redundant holes in the walls of thebund sections and new valves fitted to bund outletpipes to prevent the accidental release of thecontained chemicals.These bunds are now considered structurallysound by Panther Environmental Solutions (2017),and show no evidence of leakage, seepage,distress, major corrosion.

No

5. CausticLiqour 30%

30 Industrialcleaning agent;effluenttreatment, pHadjustment andtreatment

Milk ProcessingFacility / WWTP

Caustic Soda is held within four bunds of varyingcomposition at the Milk Processing Facility.● Enclosure with 220mm thick concrete block wall,

plastic coated walls and floors in order tofacilitate a water-tight seal, and a steelreinforcement bracket;

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Material/Substance

AmountStored

(tonnes)


Pollution● Enclosure with 145mm thick concrete block wall

and plastic-coated walls and floors in order tofacilitate a water-tight seal;

● Enclosure with 200mm thick concrete block walland plastic-coated walls and floors in order tofacilitate a water-tight seal;

● Plastic double yellow bund type medium densityPolyethylene "one-piece" construction.

Upon original inspection of the 145m concrete wallenclosure, it was determined that a section of thebund was unsound due to the presence of anunsealed outlet pipe in the base of the bund.Within the Milk Processing Facility, caustic liquor isheld in a plastic double yellow bund type mediumdensity Polyethylene "one-piece" construction. Atthe WWTP, a plastic single yellow bund typemedium density Polyethylene "one-piece"construction is utilised for containment.These bunds were visually assessed during a bundintegrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress or major corrosion.

6. PotassiumHydroxide

30 Neutraliser Whey Milk ProcessingFacility

Potassium hydroxide is held within a 200mm thickreinforced concrete enclosure with the floor andinternal walls coated with plastic to provide awater-tight seal. The bund is separated through themiddle by a plastic lined concrete partial wall(1.73m high).Upon original inspection, a section of the bund wasdetermined to be unsound as water was presentbetween the plastic and the concrete base inaddition to multiple minor punctures in the plasticfloor liner. Subsequent repair alterations includedtreatment of the liner with epoxy paint and repairsto the physical structure of the bund.This bund is now considered structurally sound byPanther Environmental Solutions (2017), andshows no evidence of leakage, seepage, distress,major corrosion.

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Material/Substance

AmountStored

(tonnes)


Pollution7. Hydrochloric

Acid37 Protein

manufacturing:demineralizingwhey, usedextensively incasein


Hydrochloric acid is held within a 200mm thickreinforced concrete enclosure with the floor andinternal walls coated with plastic to provide awater-tight seal. The bund is separated through themiddle by a plastic lined concrete partial wall(1.73m high).Upon original inspection, a section of the bund wasdetermined to be unsound as water was presentbetween the plastic and the concrete base inaddition to multiple minor punctures in the plasticfloor liner. Subsequent repair alterations includedtreatment of the liner with epoxy paint and repairsto the physical structure of the bund.This bund is now considered structurally sound byPanther Environmental Solutions (2017), andshows no evidence of leakage, seepage, distress,major corrosion.

No

8. MaintenanceOil

2.5 Various machineoils formaintenance


Oil is stored in a secure room on spill pallets.Waste maintenance oil are contained within amedium density polyethylene structure tankcontained within a similar shaped medium densitypolyethylene bund type tank.This bund was visually assessed during a bundintegrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion.

No

9. Amertrol1123(tetrapotassiumpyrophosphate)

200L Scale inhibitor inboiler watertreatment


Amertrol 1123 is held in a plastic high-densityPolyethylene "one-piece" construction IBC typebund (installed within 2017). This bund was visuallyassessed during a bund integrity inspection byPanther Environmental Solutions (2017), andshowed no evidence of leakage, seepage, distress,major corrosion.

No

10. Amersite(sodiummetabisulphite)

200L Corrosioninhibitor in boilerwater treatment


Amersite is held in a plastic high-densityPolyethylene "one-piece" construction. This bundwas visually assessed during a bund integrityinspection by Panther Environmental Solutions(2017), and showed no evidence of leakage,seepage, distress, major corrosion.

No

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Material/Substance

AmountStored

(tonnes)


Pollution11. Butomat NC

CleaningChemical



Within the Milk Processing Facility, Butomat NC isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.The IBC that is in use is held in a plastic doubleyellow bund type medium density Polyethylene"one-piece" construction. This bund was visuallyassessed during a bund integrity inspection byPanther Environmental Solutions (2017), andshowed no evidence of leakage, seepage, distress,major corrosion.

No

12. SD 100Antifoam

0.25 Control foamgeneration ingeneral chemicalprocessingapplications suchas industrialcleaning andwaste watertreatment

WWTP / MilkProcessingFacility

Within the Milk Processing Facility, SD 200 is heldwithin a locked bund characterised as having steelcladding fixed to a box section steel framework.The base of the bund was relined with fiberglassmatting, pack epoxy resin, and hardener andchemical resistant paint during October 2017 inorder to repair leakage in section one.The SD200 Antifoam IBC in use is held in a plasticdouble yellow bund type medium densityPolyethylene "one-piece" construction. This bundwas visually assessed during a bund integrityinspection by Panther Environmental Solutions(2017), and showed no evidence of leakage,seepage, distress, major corrosion. The 25L drumsthat are in use are stored on a spill pallet.

No

13. Ferric Nitrate 3 Cleaning agent WWTP Ferric nitrate is held in a plastic single yellow bundtype medium density Polyethylene "one-piece"construction. This bund was visually assessedduring a bund integrity inspection by PantherEnvironmental Solutions (2017), and showed noevidence of leakage, seepage, distress, majorcorrosion.

No

14. Lactol 5 Clean-in-place(CIP): interiorsurfaces ofpipes, vessels,


Within the Milk Processing Facility, Lactol is heldwithin a locked bund characterised as having steelcladding fixed to a box section steel framework.The base of the bund was relined with fiberglass

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Material/Substance

AmountStored

(tonnes)


Pollutionprocessequipment, filtersand associatedfittings

matting, pack epoxy resin, and hardener andchemical resistant paint during October 2017 inorder to repair leakage in section one.The IBCs are used in a number of locations andare held in plastic double yellow bund type mediumdensity Polyethylene "one-piece" construction.These bunds were visually assessed during a bundintegrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion.


WWTP Within the WWTP, Cellfloc C5 is held within alocked bund characterised as having steel claddingfixed to a box section steel framework.The IBC in use is held in plastic double yellowbund type medium density Polyethylene "one-piece" construction. These bunds were visuallyassessed during a bund integrity inspection byPanther Environmental Solutions (2017), andshowed no evidence of leakage, seepage, distress,major corrosion.

No


WWTP Within the WWTP, Cellfloc C19 is held within alocked bund characterised as having steel claddingfixed to a box section steel framework.When in use the IBC is stored above a centrifugecentrate steel holding tank constructed withconcrete block walls.

No

17. MicroseedLf2518

1 Wastewatertreatment agent

WWTP Within the WWTP, Microseed Lf2518 is held withina locked bund characterised as having steelcladding fixed to a box section steel framework.The IBC in use is held in plastic double yellowbund type medium density Polyethylene "one-piece" construction. These bunds were visuallyassessed during a bund integrity inspection byPanther Environmental Solutions (2017), andshowed no evidence of leakage, seepage, distress,major corrosion.

No

18. Microseed G 50L Wastewatertreatment agent

WWTP Within the WWTP, Microseed G C19 is held withina locked bund characterised as having steelcladding fixed to a box section steel framework.

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Material/Substance

AmountStored

(tonnes)


PollutionThe IBC in use is held in plastic double yellowbund type medium density Polyethylene "one-piece" construction. These bunds were visuallyassessed during a bund integrity inspection byPanther Environmental Solutions (2017), andshowed no evidence of leakage, seepage, distress,major corrosion.

19. RefinedGranular Salt

24 Water treatmentand softeningagent


Refined Granular Salt is stored in a securedcompound area. Any spills are swept upimmediately.

No

20. PerformaxPM 3601

150L Cooling towerwater treatmentagent


Performax is stored in a 150L plastic tank that iscontained in a plastic bund with a capacity of 175L.

No

21. Alkfoam S 0.15 Industrialdetergent(washing) agent


Within the Milk Processing Facility, Alkfoam S isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.The Alkfoam S 25L drum that is in use is stored ona spill pallet.

No

22. Dryfloc 7995 1 Wastewatertreatment

WWTP Within the WWTP, Dryfloc 7995 is held within alocked bund characterised as having steel claddingfixed to a box section steel framework.The IBC in use is held in plastic double yellowbund type medium density Polyethylene "one-piece" construction. These bunds were visuallyassessed during a bund integrity inspection byPanther Environmental Solutions (2017), andshowed no evidence of leakage, seepage, distress,major corrosion.

No

23. Memacid(nitric acid,phosphoricacid)



Within the Milk Processing Facility, Memacid isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.

No

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Material/Substance

AmountStored

(tonnes)


PollutionThe Memacid is transferred from IBC to a 1200Ltank that is contained within a concrete bund that islined. This bund was visually assessed during abund integrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion.

24. Memalk(potassiumhydroxide)



Within the Milk Processing Facility, Memalk is heldwithin a locked bund characterised as having steelcladding fixed to a box section steel framework.The base of the bund was relined with fiberglassmatting, pack epoxy resin, and hardener andchemical resistant paint during October 2017 inorder to repair leakage in section one.The Memalk is transferred from IBC to a 1200Ltank that is contained within a concrete bund that islined. This bund was visually assessed during abund integrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion.

No

25. Memplus 2 CIP ofmembranefiltration process


Within the Milk Processing Facility, Memplus isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.The Memplus is transferred from IBC to a 1200Ltank that is contained within a concrete bund that islined. This bund was visually assessed during abund integrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion.

No

26. Memzyme 0.05 CIP ofmembranefiltration process


Within the Milk Processing Facility, Memzyme isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.

No

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Material/Substance

AmountStored

(tonnes)


PollutionThe 25L drum of Memzyme is maintained on a spillpallet when in use.

27. Memplex 1 CIP ofmembranefiltration process


Within the Milk Processing Facility, Memplex isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.The Memplex is transferred from IBC to a 1200Ltank that is contained within a concrete bund that islined. This bund was visually assessed during abund integrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion.

No

28. Memlip 0.05 CIP ofmembranefiltration process


Within the Milk Processing Facility, Memlip is heldwithin a locked bund characterised as having steelcladding fixed to a box section steel framework.The base of the bund was relined with fiberglassmatting, pack epoxy resin, and hardener andchemical resistant paint during October 2017 inorder to repair leakage in section one.The 25L drum of Memlip is maintained on a spillpallet when in use.

No

29. SuperSol 0.10 All-purposedegreaser/cleaning agent


Within the Milk Processing Facility, SuperSol isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.The SuperSol 25L drum that is in use is stored ona spill pallet.

No

30. Chloro-foamND3

0.15 Disinfectantfoamer


Within the Milk Processing Facility, Chloro-foam isheld within a locked bund characterised as havingsteel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardener

No

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Material/Substance

AmountStored

(tonnes)


Pollutionand chemical resistant paint during October 2017in order to repair leakage in section one.The 25L drum of Chloro-foam is maintained on aspill pallet when in use.

31. AMC-70(acetylatedmethylcellulose)

1 Cleaningchemical fortruck wash


Within the Milk Processing Facility AMC-70 is heldwithin a locked bund characterised as having steelcladding fixed to a box section steel framework.The base of the bund was relined with fiberglassmatting, pack epoxy resin, and hardener andchemical resistant paint during October 2017 inorder to repair leakage in section one.The IBC of AMC -70 that is in use is maintained inthe truck wash area. All liquid from this area iscaptured in the truck wash sump and sent to theWWTP.

No

32. Amphotrol-FB5

0.5 Industrialdetergent andsanitising agent


Within the Milk Processing Facility, Amphotrol-FB5is held within a locked bund characterised ashaving steel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.The 25L drums of Amphotrol-FB5 in use aremaintained in spill cabinets in various locations.

No

33. AmphotrolTE

0.05 Industrialdetergent andsanitising agent


Within the Milk Processing Facility, Amphotrol TEis held within a locked bund characterised ashaving steel cladding fixed to a box section steelframework. The base of the bund was relined withfiberglass matting, pack epoxy resin, and hardenerand chemical resistant paint during October 2017in order to repair leakage in section one.The 25L drum of Amphotrol TE in use ismaintained on a spill pallet.

No

34. P3 StabicipHX(Ethylenediaminetetraacetate,



Within the Milk Processing Facility, Stabicip is heldwithin a locked bund characterised as having steelcladding fixed to a box section steel framework.The base of the bund was relined with fiberglassmatting, pack epoxy resin, and hardener and

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Material/Substance

AmountStored

(tonnes)


PollutionSodiumhydroxide)

chemical resistant paint during October 2017 inorder to repair leakage in section one.The IBC of Stbicip in use is held within a smallerlocked bund characterised as having steel claddingfixed to a box section steel framework.

35. Biosperse250

100L Control ofbacteria, fungi,and algae inindustrialrecirculatingcooling watersystems


Biosperse 250 is stored in a 100L plastic tank thatis contained in a plastic bund with a capacity of110L.

No

36. Biosperse535

100L Control ofbacteria, fungi,and algae inindustrialrecirculatingcooling watersystems


Biosperse 535 is stored in a 100L plastic tank thatis contained in a plastic bund with a capacity of110L.

No


WWTP Cellfloc A12 is stored in a purpose-built silo withintegrated bund that was installed in 2017.

No


WWTP Cellfloc A10 is stored in a purpose-built silo withintegrated bund that was installed in 2017.

No

39. Sulphuricacid 98%

25m3 pH adjustment WWTP Sulphuric acid is stored in a purpose-built silo withintegrated bund that was installed in 2017 followinga spill incident in July 2017 as previously describedin Table 2 (Item 39).

The walls of the bund are coated internally with asolvent-free polyurethane which was brush appliedto a film thickness of approx 1.5mm to provide awater-tight seal. This coating was also applied tothe joints between the wall and concrete floor. Thebund was filled to 630 mm in depth with water and,following the 6 hour test period, there was no dropin water level. Therefore, it was concluded that thebund is watertight. This wall is found to be of soundstructure and shows no significant evidence ofconcrete deterioration, cracking or spalling.

No

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Material/Substance

AmountStored

(tonnes)


Pollution40. Peracetic

acid 15%3m3 Sterilant Milk Processing

FacilityPeracetic Acid is held in a plastic double yellowbund type medium density Polyethylene "one-piece" construction. This bund was visuallyassessed during a bund integrity inspection byPanther Environmental Solutions (2017), andshowed no evidence of leakage, seepage, distress,major corrosion.

No

41. Milk & Milkproducts

3500 Raw Material Milk ProcessingFacility

Milk is contained in ten individual silos. Tanks areprotected with steel bollards and high kerbs.PlateTek engineering conducted an examination ofall operating silos (2017) in order to check forinternal defects and sub-defects. Where adefect/sub-defect was identified, appropriate repairmeasures were used by PlateTek to remedy thefault. All silos which exhibited defects/sub-defectswere re-tested and passed.

No

42. Effluent 45.38m3 Waste Milk ProcessingFacility

Production effluent is held in an enclosureconstructed of a concrete block wall on a concretefloor, and reinforced with a steel strapping andgirders. The walls and floor are coated with plasticto provide a water-tight seal.This bund was visually assessed during a bundintegrity inspection by Panther EnvironmentalSolutions (2017), and showed no evidence ofleakage, seepage, distress, major corrosion.

No

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5 Conclusion

This Baseline Report has been completed for the Arrabawn production upgrade works inaccordance with Article 22 of the Industrial Emissions Directive (2010/75/EU).

It is noted that no evidence of contaminated soils or groundwater was identified in an historicalground investigation undertaken at a central location within the site. It is also noted that neitherthe Bund Integrity Assessment Report (2017) or the Silo and Tank Inspection Report (2017)identified any evidence of significant contamination. Both of these reports have been previouslysubmitted to the Environmental Protection Agency as part of the implementation of LicenceP0791-02. Arrabawn is committed to ensuring that regular inspections and updates to thesereports are provided to the Agency to ensure that no defects arise which might present a risk ofthere being a significant pollution risk to soils or groundwater.

In relation to the substances to be stored on site, it is concluded that there is no significantpossibility for contamination of soil or groundwater, arising from the activities to be carried out atthe Arrabawn dairy processing facility and WWTP.

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A. Site Condition

A.1 Geology and SoilsDrift GeologyThe North Tipperary Landscape Character Assessment 2006 (NTLCA) states that glacialdeposition rather than erosion was the primary influence on drift geology within North Tipperaryand the wider county; specifically, glacial deposition led to deposits of boulders, pebbles, sand,and mud throughout the region’s topsoil.

The most commonly occurring soil type within North Tipperary, including Nenagh and theArrabawn site, is grey brown podzol. Geologically, this soil is derived from glacial till composedof limestone which subsequently composes the majority of the region’s bedrock geology asfurther described below.

In specific regard to the Arrabawn site, the EPA Mapping of subsoils and Teagasc onlinedatabase classified the existing Arrabawn dairy processing facility and entranceway on man-made hardstanding (urban) and the existing WWTP on undifferentiated alluvium subsoils.

Bedrock GeologyThe Geological Survey of Ireland (GSI) quaternary geological databases and maps indicate thatthe Arrabawn site is situated on Carboniferous dark limestone and shale of the Lucan Formationwhich is further described as,

“Dark-grey to black, fine-grained, occasionally cherty, micritic limestones that weather paler,usually to pale grey. There are rare dark coarser grained calcarenitic limestones, sometimesgraded, and interbedded dark-grey calcar”.

This analysis is supported by the findings from Priority Geotechnicals Ground Investigation(refer Appendix A.6) which found that the underlying geology (of the Evaporator building)consisted of Calp, dark grey black limestone and shale. In addition to this, the groundinvestigation characterised ground conditions as:

● Medium dense gravel fill was present to depth 1.5m bgl;● ‘Soft to firm’ slightly sandy, slightly gravelly clay to a depth 3.4m bgl. Furthermore, the clay

was assessed as two layers: a soft upper layer and a stiffer lower layer;● Dense, slightly silty, sandy gravel with cobble and boulder content to a depth 5.6m bgl;● Limestone (‘moderately strong to strong’ based on point load indices) was present below this

depth (5.6m bgl). More specifically, a review of the rock properties, strength, fracture spacingand condition (based on the geomechanics rock mass rating system [Bienawaski, 1989])indicated Class III- II, fair to good limestone; and

● No evidence of contaminated soils or groundwater.

A.2 HydrogeologyThe bedrock underlying the study area is classified by the GSI which rates the aquifers ofIreland according to their productivity and their vulnerability as follows:

● Regionally important aquifers: good (100 to 400 m3/day) to excellent (>400m3/day)productivity;

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● Locally important aquifers: moderate (40 to 100 m3/day) productivity; and● Poor aquifers: poor (<40 m3/day) productivity

Aquifer ClassificationGSI mapping indicates that the bedrock aquifers underlying the study area correspond to thebedrock formations classified by the GSI as: -

● L1 - ‘locally important’ bedrock aquifer which is generally moderately productive only in localzones

Aquifer Vulnerability

Overburden geology defines the vulnerability of an aquifer. The GSI use a matrix comprisingfour groundwater vulnerability categories to classify aquifer vulnerability:

● Extreme;● High;● Moderate; and● Low.

The categories are based on subsoil type and the thickness of overburden which provides somereduction for contaminants migrating toward the groundwater table from the surface or nearsub-surface. Where the surface is less than 3m thick, the aquifer is considered significantlyvulnerable as the potential for contamination to reach the aquifer is extremely high. On the otherhand, where the overburden is greater than 10m thick and has a low permeability, thevulnerability is considered low. These guidelines are reproduced below:

Table 2: Vulnerability Mapping Guidelines

VulnerabilityRating

Hydrogeological ConditionsSubsoil Permeability (Type) and Thickness Unsaturated

ZoneKarst

FeaturesHigh

permeability(sand/gravel)

Moderatepermeability

(e.g. sandysubsoil)

Lowpermeability(e.g. clayey

subsoil, clay,peat)

sand/gravelaquifers only

<30m radius

Extreme (E) 0 -3.0m 0 – 3.0m 0 – 3.0m 0 –3.0m --

Extreme (E)

High (H) >3.0m 3.0 – 10.0m 3.0 – 5.0m >3.0mN/A

High (H)

Moderate (M) N/A >10.0m 5.0 – 10.0m N/AN/A

Moderate (M)

Low (L) N/A N/A >10.0m N/AN/A

Low (L)

1. Note: N/A = not applicable2. Precise permeability values cannot be given at present.3. Release point of contaminants is assumed to be 1-2m below ground surface

Based on the consideration of the criteria for classifying groundwater vulnerability, GSI web-mapping has largely classified the Arrabawn site area as having ‘High’ groundwatervulnerability.

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Groundwater WellsThere are no Source Protection Areas on, or in the immediate vicinity of Arrabawn according tothe GSI national database. There are, however, a significantly large number of wells locatedwithin 2km of the general development area. As such, wells located within 1km of the sites havebeen identified in Table 3.

Table 3: Groundwater Wells within 2km of ArrabawnGSI Name Well Type Drill Date Depth (m) Yield (m3d) Approx.

distance fromproposed site

1717SEW032 Borehole 11/04/1975 45.7 - 113m

1717SEW004 Borehole 01/10/1964 52.5 65.5 175m

1717SEW006 Borehole 01/06/1983 79.5 364 136m

1717SEW003 Borehole 01/01/1936 38.7 - 238m

1717SEW001 Dug Well 30/12/1899 7 19.6(abstraction)

275m

1717SEW140 Dug Well 30/12/1899 2 - 380m

1717SEW142 Dug Well 30/12/1899 2.3 - 656m

1717SEW141 Dug Well 30/12/1899 2 - 853m

1717SEW148 Dug Well 30/12/1899 2.2 - 1km

1717SEW159 Borehole 16/10/1990 32 382 890m

1717SEW002 Borehole 30/12/1899 33.5 21.8(abstraction)

770m

1717SEW005 Borehole 24/04/1972 37.5 26.2(abstraction)

827m

1717SEW139 Borehole 30/12/1899 2.1 - 936m

1717SEW126 Dug Well 30/12/1899 2 - 884m

1717SEW153 Dug Well 30/12/1899 1.2 - 1km

1717SEW155 Dug Well 30/12/1899 2.3 - 1km

A.3 Geological Heritage AreasA Geological Heritage Area is one which contains geological or geomorphological featuresconsidered to be of national interest and recommended for Natural Heritage Area (NHA)designation by the GSI under the Wildlife (Amendment) Act 2000.

Desk-based research utilising GSI databases indicated that there are no NHAs (or proposals forNHAs) within one kilometre of the proposed development sites; specifically, the most proximateNHA to the proposed development are as follows:

Table 4: Geological Heritage Areas within the General Vicinity of the Proposed SiteSite Name Summary Description Approx. distance from the

proposed development siteKillaloe The most extensive slate quarries

in Ireland9.7km

Silvermines – Ballynoe – Willee Ballygown - hemimorphite - bestexample in Ireland

8km

Lisduff Quary Lower Carboniferous stratigraphy 8.4km

Silvermines - Ballynoe - Willee Mineralisation of Pb-Zn inCourceyan limestones

8.9km

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A.4 GeohazardsA review of the GSI National Landslide Database for Ireland found no recorded landslides in thearea.

Geohazards are in essence, natural Earth processes that pose a risk to human life. They canrange from naturally occurring radioactive gases such as radon to geological hazards such aslandslides, bog-bursts, coastal erosion or subsidence to hydro-meteorological hazards likefloods and high tides.

A.5 RadonRadon gas is a naturally occurring radioactive gas, originating from the decay of uranium onrocks and soils. It is a colourless, odourless and tasteless gas and its presence can only bemeasured using specialist equipment. Radon dissipates readily in open air and is notconsidered harmful. However, in enclosed spaces, such as a building, radon can accumulate tounacceptably high concentrations. Radon is measured in Becquerel’s per cubic metre of air(Bq/m³).

In Ireland, the Environmental Protection Agency (EPA) is the national organisation whichprovides advice on and regulates radon in workplaces. Exposure to natural radon levels in theworkplace is governed by the Radiological Protection Act 1991 (Ionising Radon Order 2000)and the Radiological Protection (Miscellaneous Provisions) Act 2014.

A reference level for radon in workplaces of 400 Bq/m³ averaged over a period of three monthsis specified in the Act. In accordance with the Safety, Health and Welfare at Work Act 2005 (asamended), employers are required to identify hazards in the workplace, assess the risk to healthand safety from these hazards and put in place measures to eliminate or reduce the risk. Inaccordance with this requirement the Health and Safety Authority require radon measurementsto be carried out in all indoor workplaces in High Radon Areas over three consecutive months. Ifradon levels in the workplace are found to exceed the reference level of 400 Bq/m³ the EPAmust be notified immediately and appropriate measures, such as remedial works, implementedto mitigate the risk.

Information on radon levels around the proposed development site was obtained from thenational radon map illustrated on the EPA website (http://www.epa.ie/radiation/radon/). Radonmapping on this website illustrates 10km x 10km grid squares which show the estimatedpercentage of homes above the reference level for radon. The radon measurements illustratedon this map for Nenagh, Co. Tipperary indicate that the proposed development sites are notwithin a High Radon Area; specifically, it is estimated that only 1% to 5% of dwellings arepredicted to have radon levels greater than 200 Bq/m3.

A.6 Historical Site investigationA Ground Investigation was undertaken by Priority Geotechnical between the 19th and 24thFebruary 2014 with the purpose of informing the final foundation design for the EvaporatorBuilding extension. Whilst this was a localised ground investigation within the Arrabawn site; itsresults are relevant as they provide a snapshot of the likely ground condition, in particular inrelation to the location of the casein building extension1.

1 Notwithstanding this it should be noted that a new ground investigation will be undertaken in advance of construction works associatedwith the casein building extension.

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The ground investigation employed Dando 2000 light cable percussion rig with 200mm diametercasing and Deltabase 520 rotary drilling rig plant and was carried out in general accordancewith BS 5930 (1999) Code of Practice for Site Investigation.

Two number boreholes (BH01 and BH02) were bored to a depth of 3.5m below existing groundlevel (bgl) to 3.9m bgl. Additionally, two number rotary boreholes (RC01, and RC02) wereundertaken to depths of 9.0m bgl to 9.3m bgl. Within these two boreholes and two rotaryboreholes, twelve standard penetration tests and standard penetration test (SPT) values werecarried out. A total of seven bulk disturbed samples, six small disturbed samples, and oneundisturbed sample were taken as well as rotary core being obtained. The location of all groundinvestigations is provided in Figure 1.

Figure 1: Exploratory Location Plan

All bulk disturbed samples and rotary core were transported to the Priority Geotechnicallaboratory in Midleton, County Cork and were examined, logged and prepared for scheduledtesting. Testing was carried out in accordance with Part 9 of BS1377 (1990), Methods of test forsoils for civil engineering purposes and the ISRM suggested methods for rock characterisation,testing and monitoring.

A.7 Current Land and Soils Reporting to EPABund Integrity Assessment Report (2017)Panther Environmental Limited conducted an on-site Bund Integrity assessment on the 20th ofApril 2017 for 26 no. bunds within the Arrabawn dairy processing plant. There is a large numberand type of chemicals stored on site; however, volumes stored are relatively small with thelargest single tank stored on site being Hydrochloric Acid (50m3). Visual and hydraulic testingwas undertaken in general accordance with the following standards and technical publications: -

● BS8007:1987 – Design of Concrete Structures for Containing Aqueous Liquids.● CIRIA Report 163 – Construction of Bunds for Oil Storage Tanks.● EPA’s Guidance Note on the Storage and Transfer of Materials for Scheduled Activities.

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Of the 26 no. bunds that were inspected, three bunds were identified as requiring minor repairsdue do structural faults (i.e. outlet valves protruding over the edge of the bund), presence ofunsealed outlet pipes, and seepage from sealed and unsealed holes and punctures. In October2017, subsequent repairs were carried out which included:● The base of the Bund 1 was relined with fiberglass matting, 2 – Pack epoxy resin and

hardener, and chemical resistant paint in order to improve structural integrity (watertight);● Redundant holes in the walls of Bund 5A were adequately sealed using an appropriate

render. Valves were fitted to bund outlet pipes to prevent the accidental release of thecontained chemicals; and

● Repairs to the plastic liner of Bund 6 included treatment with epoxy paint, and was found tobe water-tight, with the repairs robust to physical stress.

Following repairs, all bunds within the facility were assessed as being structurally fit for purpose,e.g. were impervious to the materials contained therein, and showed no evidence of leakage,seepage, distress or major corrosion.

Silo and Tank Inspection Report (2017)PlateTek Engineering conducted a Silo and Tank Inspection on February 16th, 2017 on 25 no.structures in order to examine the internal surface area of the vessel for defects and sub-defects. Defects which were identified during the inspections were subsequently repaired andre-tested under the same procedures; subsequently, all structures passed the test and weredetermined to be structurally fit for purpose.

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