production operations cessation · 2015-12-10 · atlas aluminium ltd. – production operations...

Production Operations Cessation

Independent Closure Audit Validation Report

October 2015

Prepared for: Atlas Aluminium Ltd. Project No. 47092887

IRELAND

Atlas Aluminium Ltd. – Production Operations Cessation – Independent Closure Audit Validation Report

OCTOBER 2015

i

Issue Date Details Prepared by Checked by Approved by

1 16 February 2015

Draft Report

Áine Kirrane

Environmental scientist

Peter Hassett

Principal Consultant

Peter Hassett

Technical Director

2 02 October 2015

Final Áine Kirrane

Environmental scientist

Peter Hassett

Principal Consultant

Peter Hassett

Technical Director

Signed

AECOM Infrastructure & Environment Ireland Limited (incorporating former URS Ireland Limited) 4th Floor, Adelphi Plaza, Adelphi Centre, George’s Street Upper, Dun Laoghaire, Co. Dublin, Ireland.

www.aecom.com


OCTOBER 2015

ii

Limitations

AECOM Infrastructure & Environment Ireland Limited, formerly URS Ireland Limited (“URS”) has prepared this Report for the sole use of Atlas Aluminium Ltd. (“Client”) in accordance with the Agreement under which our services were performed (reference proposal number P862850, dated 03 December 2014). No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by URS. This Report is confidential and may not be disclosed by the Client nor relied upon by any other party without the prior and express written agreement of URS.

The conclusions and recommendations contained in this Report are based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested and that such information is accurate. Information obtained by URS has not been independently verified by URS, unless otherwise stated in the Report.

The methodology adopted and the sources of information used by URS in providing its services are outlined in this Report. The work described in this Report was undertaken between [insert date] and [insert date] and is based on the conditions encountered and the information available during the said period of time. The scope of this Report and the services are accordingly factually limited by these circumstances.

Where assessments of works or costs identified in this Report are made, such assessments are based upon the information available at the time and where appropriate are subject to further investigations or information which may become available.

URS disclaim any undertaking or obligation to advise any person of any change in any matter affecting the Report, which may come or be brought to URS’ attention after the date of the Report.

Certain statements made in the Report that are not historical facts may constitute estimates, projections or other forward-looking statements and even though they are based on reasonable assumptions as of the date of the Report, such forward-looking statements by their nature involve risks and uncertainties that could cause actual results to differ materially from the results predicted. URS specifically does not guarantee or warrant any estimate or projections contained in this Report.

Copyright

© This Report is the copyright of AECOM Infrastructure & Environment Ireland Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.


OCTOBER 2015

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TABLE OF CONTENTS 1. INTRODUCTION ................................................................ 1

1.1 Objectives .......................................................................... 1 1.2 Scope of work .................................................................... 1

2. SITE DESCRIPTION AND STATUS .................................. 1

3. DECOMMISSIONING ACTIVITIES ................................... 4

4. RECOMMENDATIONS AND CONCLUSION .................. 10

4.1 Recommendations ........................................................... 10 4.2 Conclusion ....................................................................... 10

APPENDIX A FIGURES

APPENDIX B PHOTO LOG


OCTOBER 2015

1

1. INTRODUCTION

URS is pleased to present this Independent Closure Audit (ICA) validation report on the former Atlas Aluminium Ltd. facility, a former aluminium foundry operating at Atlas Avenue, Dock Road, Limerick (the site).

The site currently holds an Integrated Pollution Control (IPC) Licence (P0436-01) relating to its former manufacturing activities which Atlas Aluminium plans to surrender. Manufacturing operations at the site ceased in December 2007 and associated plant and equipment has since been removed from the site.

1.1 Objectives

The objective of this project was for URS to provide Atlas Aluminium with an ICA and subsequent validation report of the site relating to cessation of Atlas Aluminium activities on the site and in accordance with EPA Guidance to Licensees on Surrender, Cessation and Closure of Licensed Sites. This report may be used to assist Atlas Aluminium in IPPC licence surrender.

1.2 Scope of work

The scope of work involved the following tasks:

Initial contact and discussion with site management;

Contact with the EPA in October 2014 to obtain information and expectations on the site closure audit in addition to contact with the Polychlorinated Biphenyl (PCB) unit in the EPA regarding the site status regarding PCB’s;

Assessment of available information regarding the site and IPC licence P0436-01. Records including:

o Geosyntic Consultants, Environmental Site Assessment, Atlas Aluminium, Dock Road, Limerick – September 2013

o EPA, Licence Audit Report – February 2011 and correspondence between the EPA and Atlas Aluminium Ltd.

o URS, ‘Hydrogeological Investigation of the Soak Pit Area – March 2002

o URS, Residuals Management Plan – April 2002

A site visit by Mr. Peter Hassett and Ms. Áine Kirrane of URS on 19th December 2014; and

Independent Closure Validation report preparation.

A photo log from the URS site visit is presented in Appendix B.


OCTOBER 2015

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2. SITE DESCRIPTION AND STATUS

Particulars regarding the site description and status are presented in Table 1.

Table 1: Site Description and Status

Subject Description

Location

Address: Atlas Avenue, Dock Road, Limerick.

The site is located at Grid Reference 157180; 156750 at the southern bank of the River Shannon Estuary.

The River Shannon is located approximately 20m to the north of the site boundary.

The site location is marked in Figure 1, Appendix A

Licence status Licensed by the Environmental Protection Agency, IPC Licence reference no. P0436-01.

Ownership status The site is currently owned under Freehold by Atlas Aluminium Limited


OCTOBER 2015

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Facility Description

The site consists of:

a large factory building located in the centre to southeastern portion of the site with all production equipment removed;

two sheds located northeast and northwest of the main factory building;

a car park to the north of the main building;

an ESB substation;

a disused compressor house (compressors removed);

subsurface drainage infrastructure including an interceptor, soakaway and settling tank;

the remains of an old groundwater pump to the south of the factory; and

an area of overgrown scrub vegetation occupying the western portion of the site.

A site layout is provided as Figure 2, Appendix A.

The locale surrounding the site is largely commercial in nature.

North - The River Shannon flows close to the northern site boundary;

South - commercial and warehouse units along Dock Road

East – commercial premises

West - A timber treatment licensed facility (James McMahon Ltd – Licence Register No. P0329-01)


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Operations

Recent:

Atlas Aluminium operations on the site ceased in December 2007.

The site was locked and unused during 2009 and 2010.

All equipment including air scrubbers and air extraction ducting were removed from the site in the first half of 2008 as part of cessation activities. Site management informed URS that the equipment was largely auctioned off via a single auction house (Halcon, UK) who in turn managed the sale of equipment to various operations internationally for re-use. There are overall records of sale available but not a detailed listing of equipment sold or removed.

A fire causing damage to an office in the main factory building occurred at the site possibly in 2010 according to the site representative although this date has not been confirmed. Site management indicated to URS that most of the records relating to environmental management from that point onward were destroyed in the fire as they had been held on site.

Clean-up and removal of waste from the site with a view to site closure was initiated in 2011 with the last collection by Rilta Environmental occurring in May of that year according to the site representative.

The site is currently derelict and has been subject to frequent vandalism.

Historical:

Atlas Aluminium operated an aluminium and zinc pressure die casting facility at the site from 1985 to 2007. A licence was granted by the EPA on 20 November 2000 (licence number P0436-01) for ‘”the production, recovery or processing of non-ferrous metals, their compounds or other alloys including aluminium and zinc, by thermal means in installations with a batch capacity exceeding 0.5 tonnes”.

Prior to 1985 the site was owned by the IDA and housed various tenants.

The site is believed to have been a plating factory during (or prior to) 1960s. However, URS could not obtain records on this operational period. When Atlas Aluminium was in operation on the site, in addition to extending the facility with a new foundry floor, URS understands that Atlas Aluminium built a new floor over the original plating facility floor.


OCTOBER 2015

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3. DECOMMISSIONING ACTIVITIES

Particulars regarding the site decommissioning activities, including recommendations, are presented in Table 2.

Table 2: Site Decommissioning Activities

Subject Description

Licence Decommissioning Requirements

Condition 13.4 of IPC licence P0462-01 requires:

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

Atlas Aluminium prepared a Residuals Management Plan in 2002 in response to a licence P0436-01 Condition 13.4 requirement

Chemical Management & Containment

Atlas Aluminium removed chemical and fuels from the site during the original decommissioning work in 2008 and again in 2011 (miscellaneous small volumes of chemical waste). URS were informed that many chemicals were returned to suppliers.

During the site visit by URS in December 2014, a small number of gas cylinders, empty boiler treatment chemical drums and water treatment cylinders of the type used for water softening or ion exchange (although contents not known) were observed by the URS auditors in the shed northwest of the site. URS were advised that water treatment cylinders were never used. This area was not bunded and containers as observed were placed directly in contact with the floor.


OCTOBER 2015

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Waste Management

The following are notes and observations from the December 2014 URS site visit, interviews with site management and a review of records:

Atlas Aluminium initiated clean-up and removal of remaining waste at the site in January 2011. The site representative informed URS that wastes including wood, general refuse, rubble, plastic and paper waste were removed from the site by Green Star (formerly Ipodec). A number of invoices linked to the clean-up were reviewed by URS on the day of the URS site visit in December 2014 which detail type and amount of waste removed.

Site management also informed URS that Rilta Environmental (formerly Sita) were the only hazardous waste contractors at the site and removed waste oil, IBCs including those previously identified in the western corner of the yard, cleaned the interceptor and removed interceptor fluid from the site. Green Star and Rilta under their former names are authorised waste contractors in accordance with condition 7.2 of IPC licence P0462-01.

Documentation of waste movements subsequent to 2009 is not currently available and at least some is presumed to have been destroyed by the fire which occurred at the site.

The site representative contacted both Greenstar and Rilta during the URS site visit in December 2014 to request copies of disposal certs and records. At the date of preparation of this report, URS has not received these records for review. Rilta verbally confirmed to the site representative that their last collection from the site was in May 2011.

Depositions of mixed rubbish and wastes were observed by URS in December 2014 at various points across the site including in the sheds northeast and northwest of the site, on the first floor in the factory building and in the yard area outside the factory. Although the debris depositions appeared to be generally non-hazardous in nature, URS did observe therein occasional items such as fluorescent light fittings and spray canisters that may be considered hazardous waste. Debris is present from the office fire occurring at the site but is not thought to pose an environmental concern. A waste oil drum was observed west of the main building full with rainwater and likely to be contaminated with oil. The waste pile in the shed to the northwest of the factory consisted of oil filters, aluminium dust, floor sweepings, contaminated ‘oil dry’, old oil filters, fire blankets, old files and general rubbish. Some of this waste, for example, the contaminated oil dry and the oil filters, is considered hazardous waste. The building floor in this area was oily and it is anticipated that due to the poor condition of the structure including missing brickwork and slope of the building towards the west that localised contamination with oil product is likely present on unmade ground west of this building. The extent of this contamination, if any, could not be confirmed as the ground in this area was overgrown with vegetation.


OCTOBER 2015

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Wastewater/ Drainage

The following is noted:

Process effluent, consisting mainly of cooling water lightly contaminated with oils and metal fines (zinc and aluminium), was drained directly from production machine plinths to an interceptor system located to the west of the production building. One of the processes separately discharged to a separate settling tank to remove aluminium metal filings. Clarified water from the holding tank when operational was periodically pumped to the interceptor system.

Production machine concrete plinth drainage channels, and interceptor system and associated effluent drains as were power hosed and flushed by Atlas as part of decommissioning works in 2011. During the URS site visit in December 2014, whilst visible channels and pipes appeared to be in good condition and clean, small pockets of oily sludge were observed in some channels in the Zinc Foundry and Old Foundry sections of the factory building.

UPVC drains present between old and new floors were flushed out but no camera survey was carried out during this operation.

Water is currently present in the interceptor and a slight sheen was observed but it otherwise appears clean. The interceptor is likely to remain full due to the collection of rainwater entering the building. The interceptor has not been integrity tested but is holding water.

The settling tank was last cleaned out in 2007 by Atlas Aluminium according to the site representative. Rust was observed by URS on the inside of the tank during the December 2014 inspection but otherwise it appears clean.


OCTOBER 2015

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Building Condition

The following is noted (mainly as observed by URS during the December 2014 site visit):

Evidence of vandalism and disrepair were observed at the site.

The main factory building production floors appeared clean overall with drainage channels observed mostly clean and free of sludge. The door to the smelter room is welded shut and there is no access. URS has been informed that there is no equipment in this room and no channels or effluent emitting from this room but that the room contain small amounts of general debris. Access to a ‘lean too’ type building was also unavailable. This area was previously used to store metal but is now empty aside from a caged metal store.

URS observed some pools of water present on the floor of the main factory building indicating that rainwater is entering the building. The rainwater was generally uncontaminated although URS did observe one patch of contaminated rain water in the ‘New Foundry’ part of the building where the original floor was not completely cleaned. However, the contaminated rain water area is limited and well contained within the building.

The shed located to the northeast of the main factory building is burnt out and contains general rubble but is not believed to pose an environmental threat. It was previously used for storage of boxes and training purposes.

The shed to the northwest of the site is badly damaged with missing brickwork at the base of the walls and metal sheeting has been interfered with to create gaps. This building was previously used as an IBC store and for raw metal and stock storage. Rainwater is entering the building and an oily sheen is present on the floor possibly exuding from a mixed waste pile.

No access is available to the ESB substation. The compressor house is welded shut but URS has been informed that the structure is now empty.

The concrete floor in the area of the building that originally housed the transformers (reportedly two of them) and high voltage capacitance and switchgear was largely covered in a mix of oil contaminated sand and an oil residue. URS was informed that this was due to vandalism to remove metals from the transformers. None of the oil containing electrical equipment was present on the day of the URS inspection.


OCTOBER 2015

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Emissions to Air

During operations, emissions to air comprised mainly of:

Combustion emissions from two furnaces in the main production building; and

A wet dust extractor located beside the main production building.

However there are currently no licensed emission points in operation although emission stacks are still present.

Asbestos Containing Materials (ACMs)

The factory building was re-roofed in 1985 (replacing what was originally an ACM cement roof). Site management is not aware of any ACM sources remaining at the site. No ACMs were observed by URS on the day of the 2014 site visit.

Polychlorinated Biphenyls (PCBs)

In January 2011, the EPA undertook an inspection of the facility for PCB containing equipment. The following is noted from the inspection report (reference PCB0178-01):

Four items of equipment were identified as potentially containing PCBs, two transformers and two oil filled circuit breakers; and The EPA requested site management to verify the PCB status of the oil within the equipment noted via testing to an approved

PCB test method and also to undertake a more detailed survey for other potential PCB containing equipment (light fittings, etc).

On contacting the EPA, URS was informed that the Atlas Aluminium site at Dock Road is entered as a ‘nil holding’ on the EPA register of PCB holdings (i.e., no PCB containing equipment present). However, site management informed URS during this closure process that actions requested by the EPA in the above bullet points were not made. Therefore, it is not currently known what the PCB status is of the spilled oil noted by URS in the transformer room and therefore no proof available as to the ‘nil holding’ PCB status.

Ozone Depleting Substances (ODS) and Fluorinated Gases (F-Gas)

As all process equipment has been removed from the site there are unlikely to be any sources of ODS or F-Gas present at the site.


OCTOBER 2015

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Soil & Groundwater Quality

In 2002 URS carried out a hydrogeological investigation at the site in order to comply with condition 9.2 of the IPC licence and to assess whether the on-site oil-water interceptor or any other site activity has impacted on groundwater. Four monitoring wells were installed and soil and groundwater samples analysed.

The site was found to be underlain by Made Ground to depths of at least 4 mbgl comprising of top soil and fill material including materials resembling coal slack used to reclaim the site prior to the construction of the IDA facilities. Significant levels of diesel range organics (DRO) were identified in soil samples although levels detected in groundwater were much lower reflecting the immobile nature of the middle to higher range hydrocarbons identified. Of the 12 metals analysed for only copper was identified at levels exceeding the Dutch Intervention Value (DIV). These results indicate that contamination at the site is likely associated with the coal slack beneath the site and not the result of activities at the site.

In 2013 Geosyntec Consultants carried out an environmental site assessment on behalf of the EPA in relation to the surrender of the IPC licence to assess whether soil or groundwater at the site had been adversely affected by the previous site operations necessitating corrective actions. This investigation included collection of and analysis of 8 samples of made ground and groundwater samples from four installed monitoring wells.

The geology encountered during this investigation was similar to that of the previous investigation. Made ground was encountered to a maximum depth of 4.3 mbgl and consisted of coal, slack, glass and brick fragments, cobbles and ash. Groundwater flow direction was indicated to flow from south to north towards the River Shannon.

Heavier range hydrocarbons were detected in made ground samples taken from close to the interceptor, consistent with the results of the earlier investigation. Elevated PAH and metal concentrations detected are thought likely to be linked to the source of the fill material rather than site activities apart from a single elevated zinc result detected close to the surface which may be process related. Groundwater samples analysed did not contain elevated concentrations of contaminants of potential concern linked to former site operations. TPH results were below detection limits in all samples and individual PAHs were detected in two groundwater samples at levels exceeding respective surface water EQSs. Zinc was detected in trace amounts at all 4 monitoring wells and aluminium was detected in one well at trace level.

While there is evidence of residual soil contamination in the southern area of the site with relatively immobile longer chain hydrocarbons there is no indication from this report of a residual soil or groundwater contamination issue linked to licensed activities at the site requiring corrective action. While the elevated metal concentrations in soil appear immobile and related to the coal-ash based fill material used at the site, there would be a requirement to evaluate the site in terms of waste disposal of excavated soil if the site were to be redeveloped.


10 October 2015

4. RECOMMENDATIONS AND CONCLUSION

4.1 Recommendations

Significant decommissioning work was undertaken at the site, greatly reducing the risk of environmental pollution.

Nonetheless, URS makes the following recommendations to progress site cessation activities.

1. Remove remaining accumulations of waste debris. This will require some waste segregation to separate out hazardous waste from non-hazardous waste;

2. Obtain samples of the transformer/circuit breaker oil that has spilled in the transformer room and get analysed for PCB content;

3. Clear overgrowth immediately along the western boundary of the North West shed (refer to Figure 2) and determine if there has been any oil based contamination to unmade ground in that area. Two to three (less than 1m) hand auger samples to obtain soil samples for analyses of oil based hydrocarbons should suffice;

4. Based on PCB sample results, determine a plan to remove oil and oil contaminated materials from the transformer room and to adequately decontaminate remaining impacted transformer room infrastructure (e.g., floors, etc);

5. Remove oil impacted water from the waste oil storage tank as hazardous waste/oil waste and either remove the waste oil storage tank or seal the tank such that further rainwater cannot get into the tank;

6. Clean up remaining minor pockets of oily/metal residue observed in some of the old machine areas in the production areas;

7. Gain access to the old smelter room and determine if there is potentially hazardous waste depositions in the room that, if present, also will need to be removed;

8. Regarding the elevated metals detected at the site, any redevelopment would require proper waste disposal of excavated soils and management of the human exposure during site works.

4.2 Conclusion

Based on information contained in Tables 1 & 2 of this report, and until at least the above recommended tasks are undertaken, URS cannot conclude the following:

1. The condition of the site is not causing, or is likely to cause, environmental pollution; and

2. The site of the activity is in a satisfactory state.


October 2015

APPENDIX A FIGURES

SITELOCATION

1:50,000 Job No. SCALE

SML

North

CLIENT

PROJECT

DRAWING TITLEO OCT 2015

0

AK PH/DUB

47092887

LIMERICK

Ordnance Survey Ireland Licence No. EN 0001915©Ordnance Survey Ireland/Government of Ireland0 km 1 km 2 km 3 km

DRAWN ILLUSTRATED CHECKED APPROVED DATE

REV.FIGURE 1 _ SITE LOCATION

ATLAS ALUMINIUM LTD

PRODUCTION OPERATIONS CESSATION –INDEPENDENT CLOSURE AUDIT VALIDATION REPORT

ATLAS AVENUE, DOCK ROAD, LIMERICK 410/411 Q HOUSE, 76 FURZE ROAD, SANDYFORD, DUBLIN 18.TEL: +353 (1) 2933200 FAX: +353 (1) 2933201

Settling tank(process water)

MW202

0 50m

Approximate Scale

MW203

MW201

MW204

Interceptor

Soakaway

KEY:

SITE BOUNDARY

BUILDING AREA

MONITORING WELL LOCATION(OCTOBER 2013)

APPROXIMATE LOCATION OF BOREHOLES UTILISED BY URS

MW203

BH105

River Shannon

Car park

Atlas Avenue

Atlas Avenue

BH105

BH103

BH104

BH101

BH102

ESB Substationand disusedcompressor house

Old Foundry

Smelter

Room

NewFoundry

“lean

too”

Shed

(containing rubble)

Shed -damaged brickwork

/ vandalised

MainFactoryBuilding

1:50,000 Job No. SCALE

SML

North

CLIENT

PROJECT

DRAWING TITLE

OCT 2015

0

AK PH/DUB

47092887

DRAWN ILLUSTRATED CHECKED APPROVED DATE

REV.FIGURE 2 _ SITE LAYOUT

ATLAS ALUMINIUM LTD

PRODUCTION OPERATIONS CESSATION –INDEPENDENT CLOSURE AUDIT VALIDATION REPORT

ATLAS AVENUE, DOCK ROAD, LIMERICK 410/411 Q HOUSE, 76 FURZE ROAD, SANDYFORD, DUBLIN 18.TEL: +353 (1) 2933200 FAX: +353 (1) 2933201


October 2015

APPENDIX B PHOTO LOG

PHOTOGRAPHIC LOG

Client Name:

Atlas Aluminium Ltd.

Site Location: Atlas Avenue, dock Road, Limerick Project No.

47092887

Photo No.

1

Date:

19/12/2014

Description:

Main factory building as

viewed from northeast of

site

Photo No.

2

Date:

19/12/2014

Description:

Interior of shed in

northeast of site. Badly

damaged with fire with

resulting rubble.

PHOTOGRAPHIC LOG

Client Name:



47092887

Photo No.

3

Date:

19/12/2014

Description:

Exterior view of shed in

northwest of the site with

overgrown vegetation to

the west

Photo No.

4

Date:

19/12/2014

Description:

Waste pile in shed in

northwest of the site.

Contains mix of hazardous

and non-hazardous waste.

Hazardous waste mainly

discarded oil filters and

contaminated ‘oil-dry’.

PHOTOGRAPHIC LOG

Client Name:



47092887

Photo No.

5

Date:

19/12/2014

Description:

Damage to brickwork in

shed in northwest of the

site along western wall.

Photo No.

6

Date:

19/12/2014

Description:

Evidence of vandalism in

shed in northwest of the

site at northern wall.

PHOTOGRAPHIC LOG

Client Name:



47092887

Photo No.

7

Date:

19/12/2014

Description:

Gas cylinders, empty

chemical drums and

water treatment cylinders

in shed in northwest of

the site

Photo No.

8

Date:

19/12/2014

Description:

‘Compressor House’

located south of the main

factory building

PHOTOGRAPHIC LOG

Client Name:



47092887

Photo No.

9

Date:

19/12/2014

Description:

Interceptor cover – south

of the main factory

building

Photo No.

10

Date:

19/12/2014

Description:

Main factory interior with

rainwater present on

factory floor and evidence

of vandalism

PHOTOGRAPHIC LOG

Client Name:

Atlas aluminium Ltd.


47092887

Photo No.

11

Date:

19/12/2014

Description:

Example of oil

contaminated floor in

former transformer room.

Miscellaneous wastes also

indicated stained with oil.

Photo No.

12

Date:

19/12/2014

Description:

Drainage channel with

evidence of fire

PHOTOGRAPHIC LOG

Client Name:

Atlas aluminium Ltd.


47092887

Photo No.

13

Date:

19/12/2014

Description:

Waste pile upstairs in

main factory building.

Some light ballasts and

empty spray cans evident.

Photo No.

14

Date:

19/12/2014

Description:

View of fire damaged

office from main factory

building

production operations cessation · 2015-12-10 · atlas aluminium ltd. – production operations...

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