outline corrective action summary

Outline Corrective ActionSummaryTechnical Note

Saint-Gobain Building Distribution (ROI) Ltd. T/A PDM Ltd.

Project number: 60534258/M001.008

20 October 2017

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Outline Corrective Action Summary Saint-Gobain Building Distribution (ROI) Ltd.T/A PDM Ltd.


Prepared for: Saint-Gobain Building Distribution (ROI) Ltd. T/A PDM Ltd.60534258 Outline Corrective Action Summary (Issue1).docx

AECOM

Quality informationPrepared by Checked by Approved by

Matteo ViganottiSenior Environmental Consultant

David MullanAssociate Environmental Scientist

David MullanAssociate Environmental Scientist

Revision HistoryRevision Revision date Details Authorized Name Position

Issue 1 22/10/2017 Final 22/10/2017 Matteo Viganotti PM

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AECOM

Prepared for:Saint-Gobain Building Distribution (ROI) Ltd. T/A PDM Ltd.Oldmilltown,Kill,Co. Kildare

Prepared by:Matteo ViganottiSenior Environmental ConsultantT: +353-(0)1-238-3100M: +353-(0)87-939-2074E: [email protected]

AECOM Ireland Limited4th FloorAdelphi PlazaGeorges Street UpperCo. DublinIreland

T: +353 1 238 3100aecom.com

© 2017 AECOM Ireland Limited. All Rights Reserved.

This document has been prepared by AECOM Ireland Limited (“AECOM”) for sole use of our client (the “Client”)in accordance with generally accepted consultancy principles, the budget for fees and the terms of referenceagreed between AECOM and the Client. Any information provided by third parties and referred to herein has notbeen checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may relyupon this document without the prior and express written agreement of AECOM.

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AECOM

Table of Contents1. Introduction ............................................................................................................................................ 1

1.1 Background ................................................................................................................................. 11.2 Scope ......................................................................................................................................... 11.3 Report Structure .......................................................................................................................... 1

2. Licence Pt A Catchment ......................................................................................................................... 22.1 Soil Contamination Hot-Spot (S1) ................................................................................................ 22.1.1 Remedial Action .......................................................................................................................... 22.1.2 Progress ..................................................................................................................................... 32.2 Sediment Contamination in Farmer’s Pond (S2) ........................................................................... 32.2.1 Remedial Action .......................................................................................................................... 32.2.2 Progress ..................................................................................................................................... 32.3 Stormwater Management Measures (S3 and S4).......................................................................... 32.3.1 Progress ..................................................................................................................................... 4

3. Licence Pt E Catchment ......................................................................................................................... 43.1 Soil Contamination Hot-Spot (S1) ................................................................................................ 63.1.1 Remedial Action .......................................................................................................................... 63.1.2 Progress ..................................................................................................................................... 63.2 Maintenance of the Exiting Drainage Pipework (S5)...................................................................... 63.2.1 Remedial Action .......................................................................................................................... 63.2.2 Progress ..................................................................................................................................... 63.3 Low Level Soil Contamination (S4 and S7) ................................................................................... 63.3.1 Remedial Action .......................................................................................................................... 63.3.2 Progress ..................................................................................................................................... 73.4 Resurfacing of Critical Areas (P2 to P5)........................................................................................ 73.4.1 Remedial Action .......................................................................................................................... 73.4.2 Progress ..................................................................................................................................... 73.5 Upgrading of Site Drainage Infrastructure (P2 to P8) .................................................................... 73.5.1 Remedial Action .......................................................................................................................... 73.5.2 Progress ..................................................................................................................................... 73.6 Upgrading of the Wastewater Treatment Plant (P2 to P8) ............................................................. 83.6.1 Remedial Action .......................................................................................................................... 83.6.2 Progress ..................................................................................................................................... 8

Appendix A Site Location Map ........................................................................................................................... 9Appendix B Licence Pt A Conceptual Site Model (CSM) ................................................................................... 10Appendix C Licence Pt A Corrective Action Drawings ....................................................................................... 11Appendix D Licence Pt E Conceptual Site Model (CSM)................................................................................... 12Appendix E Licence Pt E Corrective Action Drawings ....................................................................................... 13

TablesTable 1 Viable Source-Pathway-Receptor linkages. ............................................................................................ 2Table 2 Viable Source-Pathway-Receptor linkages. ............................................................................................ 4

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AECOM1

1. IntroductionAECOM Ireland Limited (hereafter referred to as “AECOM”) is pleased to present Saint Gobain BuildingDistribution (ROI) Ltd., trading as PDM Limited (hereafter referred to as “PDM”), with this Technical Notesummarising the outline corrective action plan currently being implemented to address non-compliance issues attheir site in Oldmilltown, Kill, Co. Kildare (the site). A location map of the site is provided in Appendix A.

1.1 Background

PDM has operated under an Industrial Pollution Control Licence (Reg. No. P0325-01), as issued by theEnvironmental Protection Agency (EPA), since 1998. A review of this licence was initiated by the EPA in 2011 forthe purpose of fulfilling the requirements of the EC Environmental Objectives (Surface Waters) regulations 2009.PDM prepared and submitted a licence review application pack to the EPA in 2012. The rules surrounding thisreview process changed due to the transposition into Irish national law on 23rd April 2013 of the European Union(Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013).The EPA informed PDM in a notice issued on 12th November 2014 that their licence review application wassubject to the EPA (Industrial Emission) (Licensing) Regulations 2013. The notice required PDM to furnish suchinformation as is necessary for the application to comply with Regulation 13(2)(a) of the Regulations, and inparticular to provide information as set out in the schedule attached to the notice. AECOM provided assistanceto PDM in forming a response to the request for further information as set out in the notice, and this wassubmitted to the EPA on 1st May 2015.The EPA informed PDM in a notice issued on 24th June 2015 that further information pursuant to Section 90 ofthe EPA Acts was required in order to progress the licence review. A meeting was held between PDM and theEPA on 10th September 2015 during which the EPA requested that PDM complete relevant sections of theIndustrial Emissions Activities Licence Application Form, in order to facilitate the provision of information to theEPA in order to progress the licence review. PDM completed the relevant sections of the Industrial EmissionsActivities Licence Application Form and electronically submitted the information to the EPA on 20th November2015.PDM are currently in the process of implementing environmental upgrade works across the site in response toCompliance Investigations CI000164, CI000165 and CI000320. It was agreed during a meeting between PDM,the EPA and AECOM in June 2016 that any further information requests would not be made until Quarter 2 2017,once PDM had commissioned the infrastructural changes proposed for the site as part of the site environmentalupgrade works.During a meeting at the PDM site on 24th May 2017 the EPA requested further information under Section 90 ofthe EPA Act as amended. This was submitted to the EPA on the 6th September 20171. On the 29th September2017, following the review of the documentation provided the EPA requested by email the following additionalinformation:1. Details of the 2016 Outline Corrective Action Plans for emission point A and E and an update on the

progress against same.2. Monitoring results for emission point A and E for the last 6 months including a breakdown of the 16 PAHs

and alkalinity readings.

1.2 Scope

This Technical Note addresses Item 1 above and provides a summary of the 2016 Outline Corrective ActionPlans2,3 (CAP) prepared for the Licence Pt A and Licence Pt E catchment. These were developed to addressexceedances recorded in discharges to surface water. Where relevant, amendments to the Outline Plans thatoccurred during detailed design development are also reported. Current progress in relation to theimplementation of the corrective actions is also discussed.This document should be read in conjunction with the documents and information submitted to the EPA asdiscussed above.

1.3 Report Structure

This report is organised in the following three (3) sections:

1 AECOM (2017), Response to EPA Request for Information dated 05/09/172 AECOM (2016), Outline Corrective Action Plan for Licence Pt A. Issue 13 AECOM (2016), Outline Corrective Action Plan for Licence Pt E. Issue 1

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1. Introduction;2. Licence Pt A Catchment;3. Licence Pt E Catchment.Sections 2 and Section 3 include a description of the identified viable Source-Pathway-Receptor (S-P-R)linkages. For each viable S-P-R linkage the proposed action to mitigate or eliminate impacts is outlined. Asummary of current progress is provided for each action.

2. Licence Pt A CatchmentTable 1 below summarises the viable S-P-R linkages considered to be present within the Licence Pt A catchment.These were determined on the basis of the Conceptual Site Model (CSM) developed for the site. A location mapillustrating the viable S-P-R linkages is provided in Appendix B.

Table 1 Viable Source-Pathway-Receptor linkages.Key Sources Potential Pathway Potential Receptors

Hot spot soil contamination in theformer reject pole storage area (S1)

Contact with or ingestion ofcontaminated soil or dust (P1). Workers on site (R1).

Erosion and transport as an adsorbedphase on suspended particles or bydissolution into overland stormwaterflow to Ditch 2 and emission at LicencePt A (P2).

Kill River, Killhill River andPainestown River (R2)

Contaminated sediment in FarmersPond (S2).

Remobilisation of sediment duringrainfall and transport as an adsorbedphase on suspended particles or bydissolution into stormwater flow to Ditch2 and emission at Licence Pt A (P2).

Low level contaminated soil acrossthe subject area (including soilstockpiles) (S3).

Erosion and transport as an adsorbedphase on suspended particles or bydissolution into the water column inoverland stormwater flow to drainageditches and emission at Licence Pt A(P2).

Treated product storage areas (S4).Wind-blown contamination andincidental splashing into adjacent Ditch2 and onward to Licence Pt A (P3).

The proposed outline strategy to address the S-P-R linkages identified above can be divided into two parts.1. Source reduction measures associated with hot spot soil contamination giving rise to associated human

health risk in the former Rejected Poles storage area (S1) and low level contaminated sediment in FarmersPond (S2).

2. Stormwater management measures associated with low level soil contamination (PAHs) across the subjectarea (S3) and storage of treated timber adjacent to Ditch 2 (S4).

Drawings detailing the proposed remedial actions for the Licence Pt A catchment are provided in Appendix C.

2.1 Soil Contamination Hot-Spot (S1)

2.1.1 Remedial Action

Two options were considered to address the hot spot soil contamination reported in the former Reject Polesstorage area:1. Excavation and disposal of contaminated soil; and2. Containment / encapsulation of contaminated soil.

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Of the two options considered, excavation and disposal scored the highest results in the remedial optionsassessment (83 compared to 80). Additionally, a high level of protection of surface water and a higher level ofprotection of groundwater would be provided by the excavation option in the general context of the site.The recommended remediation option was to excavate and dispose of an estimated area of 1,250m2 in total, withcontamination to a depth of 0.4m, representing a volume of 500m3 of soil. The area was to be re-instated withclean materials for future use as storage area for untreated timber stock.

2.1.2 Progress

These remediation works have been completed.

2.2 Sediment Contamination in Farmer’s Pond (S2)


Given the relatively small volume of sediment estimated in the pond, it was proposed to excavate and dispose ofit appropriately offsite. The estimated volume of mildly contaminated material to be excavated was 25m 3.However, since the preparation of the Outline CAP further assessment of the mild sediment contamination wascarried out4. This indicated that negligible impacts on identified receptor would be expected and therefore nofurther action was recommended. It is noted that in the context of the drainage re-design outlined below it wasproposed that the outfall from the Farmers Pond is diverted through a sealed pipe so that it no longer interactswith the storm water infrastructure of the site.

2.2.2 Progress

The Farmer’s Pond diversion works have been completed.

2.3 Stormwater Management Measures (S3 and S4)

Stormwater management measures were proposed to address sources S3 (low level soil contamination acrossthe subject area) and S4 (storage of treated timber adjacent to Ditch 2).

It was proposed to install a management train of sustainable urban drainage systems (SuDS) elements. SuDSare proposed as they will use less energy and resources; will maximize the opportunities from storm watermanagement; and will provide benefits for water quality (reduce contaminants), water quantity (reduce theamount of water discharged offsite), biodiversity and potentially an amenity.

It was proposed that the SuDS treatment design will be in line with good practice, as set out in the CIRIA SuDSManual 20155. The SuDS manual summarises good practice for SuDS treatment design as follows:

· Manage surface water runoff close to source.· Treat surface water runoff on the surface.· Treat surface water runoff to remove a range of contaminants.· Minimise risk of sediment remobilisation.· Minimise impacts from accidental spills.The outline objectives were as follows:

· Water quality – reduce contaminants in stormwater at Licence Pt A to acceptable levels.· Water quantity – reduce peaks in discharge by containing events <5mm (similar to greenfield conditions)

and attenuating, treating and controlling the discharge of larger events.· Biodiversity – provide localized improvement of biodiversity by creating more vegetated areas of grassland

and/or trees.· Amenity – provide the potential for amenity use of vegetated areas for onsite workers.The proposed measures, their benefits and rationale for their implementation are presented below and illustratedin the design plans presented in Appendix C. The following elements form part of the proposed plan:

Pervious Pavement

4 AECOM (2016) PDM Off-site Impacts Assessment dated 18/08/20165 CIRIA (2015) The SuDS Manual. Ref: CIRIA C753. London.

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It was proposed to install pervious pavement (soil stabilisation) to cover all track access and raw timber storagebays in the subject area. The pervious pavement will reduce the risk of erosion of low level contaminatedsediment reported across the subject area. The pervious pavement will intercept rainfall where it falls in thesubject area and reduce the frequency and volume of runoff. It will also provide treatment benefits in terms offiltration, adsorption, biodegradation and sedimentation for any contaminants which pass through it. It is notedthat to limit the generation of dust and sediment was proposed to construct two (2) asphalt road spurs to accessthe storage bays.

Filter Drains

It was proposed to install a system of filter drains in the subject area. Filter drains are shallow trenches filled withgravel that provide temporary subsurface storage, attenuation, conveyance and filtration of surface water. Filterdrains also encourage adsorption and biodegradation processes.

Swales

It was proposed to replace existing Ditch 2 with a shallow swale and buffer zone between the swale and thetreated timber storage area (S3). The buffer zone is discussed further below. The proposed swale is a shallowflat bottomed vegetated open channel which is designed to convey, treat and attenuate surface water runoff.Swales facilitate sedimentation, filtration through the root zone and soil matrix, evapotranspiration and infiltration.Additionally, where sediment is exposed to UV light photolysis and volatilisation can also breakdown PAHs.

Vegetated Buffer Zone

To mitigate against wind-blown contamination or incidental spills from the treated timber storage area (S4) it wasproposed to infill the existing ditch (replaced by swale above) and to create a vegetated buffer zone between thetreated timber storage area and the swale. The buffer zone will reduce the potential for contamination of runoff inthe subject area; increase infiltration and evapotranspiration; provide treatment in terms of phytoremediation forany contaminants that fall on the area; and improve local biodiversity. It should also allow for the visibleidentification of any contaminants that fall on the surface.

Wet Pond

All water conveyed through the new swale and Ditch 3 will enter the proposed wet pond. The wet pond willprovide for sedimentation, attenuation and treatment of runoff. The outflow will be controlled and water levelscan increase following rainfall events. Vegetation in the pond will enhance treatment and biodiversity. It wasproposed to line the pond due to the high perched water table anticipated beneath the subject area. Futureproofing elements include the installation of ducting (power) and the provision of a pumping chamber to allow forwater treatment prior to discharge should this be necessary (eg. following an accidental spill).

2.3.1 Progress

Construction of the stormwater management measures has been completed and the system is currently goingthrough a commissioning phase.

3. Licence Pt E CatchmentTable 2 below summarises the viable S-P-R linkages considered to be present within the Licence Pt A catchment.These were determined on the basis of the Conceptual Site Model (CSM) developed for the site. A location mapillustrating the viable S-P-R linkages is provided in Appendix D.

Table 2 Viable Source-Pathway-Receptor linkages.Key Sources Potential Pathway Potential Receptors

Hot Spot of contaminatedsediment in Drainage Ditch 4.(S1)

Outdoor ingestion of soil and fugitivedust from contaminated shallow soiland outdoor dermal contact with soil.(P1)

Workers at the site considering acontinued commercial end use. (R1)

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Key Sources Potential Pathway Potential Receptors

Creosote Storage andTreatment Areas, Main SiteSeparator. (S2)

Flow to surface water drainagenetwork via gullies and separator.Emission at Licence Pt E via WWTP.(P2)

Kill River, Killhill River andPainestown River. (R2)

Kill River, Killhill River andPainestown River. (R2)

Overland flow directly offsite bypassingsurface water drains and surface waterdrainage network. (P3)

Treated product storage areas.(S3).

Flow to surface water drainagenetwork via gullies. Emission atLicence Pt E via WWTP. (P4)


Overland flow or overflow (MH8) todrainage ditches leading to Ditch 1during periods of high rainfall.Emission at Licence Pt E via WWTP.(P5)

Exposed contaminated (lowlevel) soil across the site (S4).

Overland flow to Drainage Ditches 1and 4 during periods of high rainfall.Emission at Licence Pt E via WWTP.(P6)

Overland flow to surface waterdrainage network via gullies. Emissionat Licence Pt E via WWTP. (P7)


Hot Spot of contaminatedsediment in Drainage Ditch 4(S1) and contaminatedsediment in the drainagenetwork (S5).

Flow through the surface waterdrainage network. Emission at LicencePt E via WWTP. (P8)

S5 Only - Overland flow or overflow(MH8) to drainage ditches leading toDitch 1 during periods of high rainfall.Emission at Licence Pt E via WWTP.(P5)

The proposed outline strategy to address the S-P-R linkages identified above can be divided into three parts.1. Source reduction measures, including maintenance and dredging works to remove contaminated sediment

(S1 and S5);2. Stormwater and Surface Water management and infrastructure improvement measures associated with

treatment areas (S2 and P3) and areas dedicated to the storage of treated timber (S3 and P5) includinglandscaping and road/storage surface upgrade works to reduce erosion impacts from low level soilcontamination (PAHs) across the subject area’s exposed surfaces (S4 and P7); and

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3. Upgrade of the WwTP to improve treatment and compliance at Licence Pt. E (P2 and P4 to P8).Drawings detailing the proposed remedial actions for the Licence Pt E catchment are provided in Appendix E. Itis noted that the drawings are provided for illustration purposes only. It should be noted that unforeseencircumstances during construction might result in amendments to the plan presented herein.

3.1 Soil Contamination Hot-Spot (S1)


Three options were considered to address the hot spot soil contamination reported in Drainage Ditch 4:· Excavation and disposal of contaminated soil;· Selective excavation and containment / encapsulation of residual contaminated soil; and· Containment / encapsulation of contaminated soil.During optioneering, the highest score was obtained for the containment and selected excavation and disposaloption (94), involving the removal of a nominal 36m3 of soil and the installation of an impermeable hard standingand/or suitable lining design.The second highest score (90) was obtained for the excavation and disposal option. The works would involve theexcavation and disposal to a licensed waste facility of a nominal 36m3 of soil. Reinstatement would becompleted using ‘clean’ backfill available on site to the extent of infilling the full volume of the former drain. Thiswas the recommended for the remedial works implemented in the context of upgrade works relating to thesurface drainage infrastructure which include the full decommissioning of the drainage ditch.

3.1.2 Progress

Works are currently being progressed on site as part of the site infrastructure upgrade works. At the time ofwriting, the remedial works have been completed but infilling of Drainage Ditch 4 is not expected to be completeduntil later in the project. The infrastructure upgrade works are expected to be completed by June 2018.

3.2 Maintenance of the Exiting Drainage Pipework (S5)


It was initially proposed to carry out cleaning and sediment removal from the existing drainage pipework toprevent mobilisation of potentially contaminated deposits that might have accumulated within3. However, duringdesign development and following further assessment the reuse of existing drainage infrastructure wasconsidered unviable with few exceptions. Therefore most of the existing drainage will be decommissioned.

3.2.2 Progress

Works are currently being progressed on site as part of the site infrastructure upgrade works. The infrastructureupgrade works are expected to be completed by June 2018.

3.3 Low Level Soil Contamination (S4 and S7)


To prevent or limit the migration of contaminants from exposed soils showing low levels of contamination, it isproposed to implement the following mitigation measures:· Pervious pavements: it is proposed to install pervious pavement surfaces (soil stabilisation) in those areas

impinged by site traffic and operations (such as the fabrication timber storage). The pervious pavement willreduce the risk of erosion of low level contaminated sediment reported across the subject area. Thepervious pavement will intercept rainfall where it falls in the subject area and reduce the frequency andvolume of runoff. It will also provide treatment benefits in terms of filtration, adsorption, biodegradation andsedimentation for any contaminants which pass through it.

· Vegetated areas: it is proposed to complete landscaping and greening works in those areas not impingedby operational activities. The vegetated areas will reduce the potential for contamination of runoff in thesubject area; increase infiltration and evapotranspiration; provide treatment in terms of phytoremediation for

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any contaminants that fall on the area; and improve local biodiversity. It should also allow for the visibleidentification of any contaminants that fall on the surface.

· Impermeable pavement: it is proposed to construct a number of roads and service areas (includingrefuelling and creosote delivery pads) that will be covered with impermeable surfaces. These will preventrun-off from coming in to contact with the soil. Run-off from these areas will be collected in to the drainagesystem.

3.3.2 Progress


3.4 Resurfacing of Critical Areas (P2 to P5)


It is proposed to carry out resurfacing works at the creosote storage and timber treatment areas. While theconsequent positive impacts would be mostly relating to possible groundwater infiltration, resurfacing of theseareas (in conjunction with the drainage remedial works illustrated below) will limit the risk of uncontrolled,potentially contaminated discharges over ground. It is noted that the refurbishment plan for the Drag Out Areawill include an upgrade to the sidings of the rails for Treatment Units 3 and 4. This will allow loading of a newcharge of timber immediately after the previous charge is extracted from the vessel, which will have positiveenvironmental effects by limiting the time that the vessel remains open. It will also limit the temperature loss inthe vessel between charges providing energy efficiency advantages.

3.4.2 Progress


3.5 Upgrading of Site Drainage Infrastructure (P2 to P8)


An extensive plan of works is proposed to upgrade the drainage infrastructure on the site. The works will reducethe risks of system overflow and consequent uncontrolled discharges (over ground, via Drainage Ditch 4 and viaDrainage Ditch 1), as well as improving the control of flows and water quality reaching the WwTP. The proposedworks will include:· Upgrading of the site drainage infrastructure (interceptors, gullies, sumps, pipework etc.) to include:

─ Separation of surface water and roof run-off collection systems;─ Zoning of the site drainage to control and limit accidental spill events.

· Upgrading of the current collector drains for the collection of flow of roof run-off and surface water from hardstanding areas (concrete pads and surfaces, roads, etc.).

· Upgrading of the pumping and attenuation infrastructure controlling water flows from the collector drain tothe WwTP. The objective of the proposed storm water attenuation and balancing plan is to provideattenuation and balancing storage for pass forward to either the existing WwTP for treatment or if shown tobe sufficiently clean to discharge directly at a new storm water emissions Monitoring Point. Provisions forthe potential separate discharge (untreated) of roof run-off are also included in the proposed design. It isnoted that the overall capacity of the system will be substantially increased.

The proposed new Pumping Station and Balance Tank will be instrumented and will provide online and manualcontrols to allow shut off and containment in the event of an incident on site (such as a fire or spillage) as well asautomated controls in case of mechanical failures in the system.

3.5.2 Progress


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3.6 Upgrading of the Wastewater Treatment Plant (P2 to P8)


It was initially proposed to refurbish and upgrade the existing Wastewater Treatment Plant (WwTP)3. However,during detailed design development and inconsideration of the sustained compliance at Licence Pt E (sinceMarch 2016) it is now proposed to review the optioneering carried out for the WwTP. It is noted that theimproved compliance is deemed to be associated with improved environmental and operational practices beingimplemented at the site.

3.6.2 Progress

The review of the optioneering will be carried out following a pilot testing period to be completed after theconstruction works are complete. The pilot testing will aim to assess the performance of the existinginfrastructure under the new loading conditions and influent characteristics. Future proofing is however includedin the proposed design for the new Balance Tank to allow for the connection of additional treatment units fortemporary and/or long term augmentation of the treatment train. It is noted that should the current systemperform satisfactorily it would provide a low carbon and sustainable treatment solution for the site.

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Appendix A Site Location Map

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Appendix B Licence Pt A Conceptual Site Model (CSM)

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Appendix C Licence Pt A Corrective Action Drawings

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Appendix D Licence Pt E Conceptual Site Model (CSM)

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Appendix E Licence Pt E Corrective Action DrawingsNOTE: Drawings are provided for illustration purposes only. Unforeseen circumstances during construction mightresult in amendments to the plan presented here.

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