attachment 4-8-2 soil & groundwater baseline screening ... · this report has been prepared in...
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Attachment 4-8-2
Soil & Groundwater Baseline Screening
Assessment Report
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Prepared by IE Consulting
Innovation Centre, Green Road, Carlow
Tel:- 059 91 33084 Fax:- 059 91 40499
Baseline Assessment Report
Baseline Screening Exercise
Baush & Lomb, Waterford June 2019
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Document Control Sheet
Project Title Baseline Assessment – Bausch & Lomb, Waterford.
Report Title
Baseline Screening Report, Stages 1–3.
Report Reference IE1808-3218
Version Rev. 5.
Issue Date 11/06/2019
Document Production / Approval Record
Name
Signature
Date
Position
% Input
Reviewed by (consultant)
Eoin Fitzpatrick BSc MSc
(Contaminated Land)
11/06/19
Contaminated Land &
Remediation Scientist
20
Prepared by
Kevin Murphy BSc, MSc
(Hydrogeology)
11/06/19 Project Hydrogeologist
80
Status
Report Status
ISSUE
Distribution
Organisation
Contact
Format
Copies
Environet Consulting Ireland Limited
Alan Setter Electronic (PDF) 1
Copyright © IE Consulting 2019
This report or its contents must not be reproduced for any purpose without written permission. It is to be used only for the purpose for which it is supplied
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Table of Contents 1. Introduction ............................................................................................................................................. 1
1.1 Requirement for a Baseline Report .............................................................................................. 1
2. STAGE 1 - Site Activities & Identification of Hazardous Substances ........................................... 3
2.1 Current Use ....................................................................................................................................... 3
2.2 Historical Land Use ......................................................................................................................... 4
2.3 Identification of Hazardous Substances Screening Process .................................................. 4
3. STAGE 2 – Identification of Relevant Hazardous Substances ..................................................... 8
3.1 Relevant Hazardous Substances ................................................................................................. 8
4. STAGE 3 – Assessment of the Site Specific Pollution Possibility .............................................. 11
4.1 Storage, usage, containment measures, potential pollution risks ................................. 11
4.2 Soil & Groundwater Contamination Hazards ........................................................................... 12
4.3 Conclusion ...................................................................................................................................... 14
List of Tables Table 1; Hazardous substances dealt with inside the installation boundary [Ref. 7]. ................... 6 Table 2; Relevant Hazardous Substances [Ref. 7]. .............................................................................. 9
Appendix
Appendix A Hazardous Material Stores – Drawing No. OS.14.Hazardous - 1.12.
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1. Introduction
This report has been prepared for Environet Consulting Ireland Ltd on behalf of Bausch & Lomb Ireland. The existing facility is located at unit no. 424/425, Cork Road Industrial Estate, Cork Road, Waterford which manufactures contact lenses. Bausch & Lomb plan to develop an additional manufacturing facility on lands located to the North East/East of their current manufacturing plant and to submit an EPA Licence Application.
This report has been prepared in line with the European Guidance concerning baseline reports under Article 22(2) of Directive 2010/75/EU on Industrial Emissions (IE) [Ref. 1]. This report will form part of the IE Licence Application to the Environmental Protection Agency (EPA) for the existing facility, and the proposed extension. The purpose of this report is to meet the requirements of the 2010 Article 22(2) of the Industrial Emissions Directive (2010/75/EU) and to determine whether or not a baseline assessment report is required.
1.1 Requirement for a Baseline Report
The Industrial Emissions Directive (2010/75/EU) or ‘IED’ entered into force within the European Union on 6 January 2011. The IED is a recast of 7 pieces of legislation including the Integrated Pollution Prevention and Control Directive (2008/1/EC), the Waste Incineration Directive (2000/76/EC) and five other directives.
For industrial activities regulated by the IED, such as the activity carried out by Bausch & Lomb, Article 22(2) of Chapter II of the IED states that:
“Where the activity involves the use, production or release of relevant hazardous substances and having regard to the possibility of soil and groundwater contamination at the site of the installation, the operator shall prepare and submit to the competent authority a baseline report before starting operation of an installation or before a permit for an installation is updated for the first time after 7 January 2013’’ [Ref. 2].
‘’The baseline report shall contain the information necessary to determine the state of soil and groundwater contamination so as to make a quantified comparison with the state upon definitive cessation of activities provided for under paragraph 3’’ [Ref. 2].
The baseline report shall contain at least the following information:
(a) Information on the present use and, where available on past uses of the site [Ref. 2];
(b) Where available, existing information on soil and groundwater measurements that reflect the state at the time the report is drawn up or, alternatively, new soil and groundwater measurements having regard to the possibility of soil and groundwater contamination by
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those hazardous substances to be used, produced or released by the installation concerned [Ref. 2].
Where information produced pursuant to other national or Union law fulfils the requirements of this paragraph that information may be included in, or attached to, the submitted baseline report” [Ref. 2].
The European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013) and the resulting amendments to the Environmental Protection Agency Act 1992 give effect to Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control).
The Commission has established guidance on the content of the baseline report in the form of European Guidance concerning baseline reports under Article 22(2) of Directive 2010/75/EU on Industrial Emissions. This guidance sets out eight stages, which are summarised as follows:
Stage 1 – 3: To decide whether a baseline report is required;
Stage 4 – 7: To determine how a baseline report has to be prepared;
Stage 8: To determine the content of the baseline report.
This report deals with the initial phase of works: Stage 1 – 3. Where, during stages 1-3 it is demonstrated on the basis of the available information that a baseline report is not required; there is no need to progress to the later stages. A record of such a demonstration should be made and held by the competent authority, including the reasons for such a decision [Ref. 1].
Section 2 outlines the hazardous substances currently used at the facility. Section 3 describes those which are relevant to the facility. The potential for site specific soil and groundwater contamination resulting from the use of hazardous substances is addressed in Section 4.
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2. STAGE 1 - Site Activities & Identification of Hazardous Substances
2.1 Current Use
The Bausch & Lomb site is a multi-function complex which includes contact lenses, research and development as well as surgical support operations [Ref. 3]. Overall, the main focus is on manufacturing contact lenses [Ref. 3]. Approximately 1,100 people are employed onsite [Ref. 3]. The site to the North East of the existing manufacturing facility is planned to be developed for an extension of the existing plant. The land to the North East is green field and gently sloping, with some areas of soft ground and is not currently farmed, as shown in Figure 1, below.
Figure 1; Present day site layout (OSi).
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2.2 Historical Land Use
Bausch & Lomb have been operating on the site since 1980 [Ref 3]. Prior to 1980, Ordnance Survey Ireland (OSi) Historical Mapping shows the site lying between the town lands of Lismore and Skibbreeen. Field boundaries are delineated with 110 Kv power lines mapped to the south of the site by the 1930s and land use is predominantly agricultural [Ref. 4].
There was a farm yard associated with Lismore House, located to the North of the existing facility [Ref 4]. Following a site walk over and discussions with Bausch & Lomb site engineers, Lismore House fell in to disrepair and was abandoned in the late twentieth century. At present, there are some remains of Lismore House, the most notable the tree lined entrance and concrete paved roadway, which once led to the house and farmyard. The OSi Cassini 6 inch raster mapping dated 1830s to 1930s for the area is shown in Figure 2, as shown below.
Figure 2; OSi Cassini 6 inch raster mapping dated 1830s to 1930s for the present day Bausch & Lomb site (OSi).
2.3 Identification of Hazardous Substances Screening Process
The first step in the baseline screening process is to identify which hazardous substances are used, produced or released at the installation and subsequently produce an inventory of the hazardous substances within the site.
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The inventory was complied with data supplied by Bausch & Lomb, Waterford [Ref. 7]. The inventory of hazardous substances, which are dealt with inside the boundary of the site is presented in Table 1.
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Table 1; Hazardous substances dealt with inside the installation boundary [Ref. 7].
Substance Code
Material/ Substance CAS Number Danger Category Amount Stored
(Tonnes)
Annual Usage
(Tonnes) Unit Nature of Use Hazard Statement
1 Erythritol 149-32-6 N/A 0.012 0.01 Tonnes Research &
Development N/A
2 Potassium Chloride 7447-40-7 N/A 0.009 0.01 Tonnes Research &
Development N/A
3 Sodium Phosphate Monobasic 10049-21-5 N/A 0.01 0.01 Tonnes Research &
Development N/A
4 IMVT Reactive Blue 246 121888-69-5 N/A 0.002 0.01 Tonnes Production N/A
5 TBE Monomer 128840-36-8 Skin Irr. 2; Skin. Sens. 1; Eye Irr. 2; STOT SE 3; Aquatic
Chronic 4 0.3 2.04 Tonnes Production
H315, H317, H319, H335, H413
6 Poly Hema Co NVP 29612-57-5 N/A 0.025 0.06 Tonnes Production H303, H333, H315
8 Vazo 64 78-67-1
Self-reactive substances (Type C) Acute Tox. 4 (inhalation);
Acute Tox. 4 (oral); Aquatic Chronic 3
0.16 0.24 Tonnes Production H242, H302, H332, H412
9 Low Acid Hema 868-77-9 Skin Irrit. 2; Eye Irrit. 2; Skin Sens. 1; 4 14.40 Tonnes Production H315, H319, H317
10 Glycerol 56-81-5 N/A 1.2 4.19 Tonnes Production -
11 Ethylene glycol dimethacrylate 97-90-5 Skin Sens. 1; STOT SE 3, Xi 0.05 0.20 Tonnes Production H317, H335
12 UV Blocker 96478-09-0 Acute Tox. 4; Skin Irrit. 2; Eye Irrit. 2; STOT SE 3 0.16 4.00 Tonnes Production H312, H315, H319, H335
13 Allyl methacrylate, AMA 95-05-9 Flam. Liq. 3; Acute Tox. 4 (oral); Acute Tox. 3 (dermal); Acute Tox. 2 (inhalation); STOT RE 2; Aquatic Acute 1;
Aquatic Chronic 3 0.05 0.20 Tonnes Production
H226, H302, H311, H330, H373, H400, H412
14 Hema VC (monomer) 145497-35-4 Skin Irrit. 2; Eye Irrit. 2; STOT SE 3 0.004 0.01 Tonnes Production H315, H319, H335
15 Poloxamine 9003-11-6 N/A 2.825 7.00 Tonnes Production N/A
17 NVP, 1-Vinyl-2-pyrrolidinone 88-12-0 Acute Tox. 4; Eye Dam. 1; Carc. 2; STOT SE 3; STOT RE 2 9.6 29.00 Tonnes Production H302, H332, H312, H318,
H351, H335, H373
18 IPA 67-63-0 Flam. Liq. 2; Eye Irrit. 2; STOT SE 3 1.2 2.40 Tonnes Production H225, H319, H336
19 Propylene Glycol 57-55-6 N/A 1.2 3.50 Tonnes Production N/A
20 Boric Acid 10043-35-3 Repr. 1B 0.6 13.30 Tonnes Production H360FD
21 Di Sodium Tetraborate 1330-43-4 Eye Irrit. 2; Repr. 1B 0.625 1.90 Tonnes Production H319, H360FD
23 Hydrochloric acid 7647-01-0 Met. Corr. 1; Skin Corr. 1B; STOT SE 3 0.01 0.02 Tonnes Production H290, H314, H318, H335
24 Polyvinyl alcohol, PVA 9002-89-5 N/A 0.075 0.15 Tonnes Production N/A
27 Sodium Hydroxide 1310-73-2 Skin Corr. 1A 0.006 0.04 Tonnes Production H290, H314
28 Bi-Napthol 18531-99-2 Eye Irrit. 2 0.0002 0.0005 Tonnes H319
29 Di(ethylene glycol) diacrylate 4074-88-8 Acute Tox. 3; Skin Irrit. 2; Eye Dam. 1; Skin Sens. 1 0.005 0.01 Tonnes Production H301+H311, H315, H317,
H318
30 HEA, 2-Hydroxyethyl acrylate 818-61-1 Acute Tox. 4; Acute Tox. 3; Skin Corr. 1B; Skin Sens. 1;
Aquatic Acute 1 0.006 0.02 Tonnes Production
H302, H311, H314, H317, H400
31 Ethyl-L-Lactate 687-47-8 Flam. Liq. 3; Eye Dam. 1; STOT SE 3 0.075 0.18 Tonnes Production H226, H318, H335
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Substance Code
Material/ Substance CAS Number Danger Category Amount Stored
(Tonnes)
Annual Usage
(Tonnes) Unit Nature of Use Hazard Statement
32 BME 99%, 2-Mercaptoethanol 60-24-2 Acute Tox. 3; Acute Tox. 2; Skin Irrit. 2; Eye Dam. 1; Skin Sens. 1; STOT RE 2; Aquatic Acute 1; Aquatic Chronic 1,
M-Factor - Aquatic Acute: 1 0.002 0.002 Tonnes Production
H301, H331, H310, H315, H318, H317, H373, H400,
H410
33 IPA Wipes 67-63-0 Flam. Liq. 2; Eye Irrit. 2; STOT SE 3 0.217 0.87 Tonnes Production H225, H319, H336
34 Spiriclens 64-17-5 Flam. Liq. 2; Eye Irrit. 2 0.03 0.08 Tonnes Production H225, H319
35 Resin N/A May cause eye, skin and respiratory tract irritation. 724 3875.00 Tonnes Production H320, H315, H335
36 Hydraulic Oil N/A N/A 0.892 2.00 Tonnes Production N/A
37
NALCO® 2584 - Sodium Hydroxide (Caustic) 30-50% - Potassium Hydroxide (potash) 10-20%
1310-73-2 1310-58-3
Skin Corr. 1A; Eye Dam. 1 0.52 0.26 Tonnes Boiler Treatment pH
control H290, H314
40 NALCO® 77211 - Sodium Bisulfite 30-50% - Cobalt Sulfate 0.01-0.1%
7631-90-5 10124-43-3
Acute Tox. 4 0.44 0.98 Tonnes Oxygen scavenger H302
41 Mobil Pegasus 705 Oil N/A N/A 3 3.00 Tonnes Facilities N/A
42 Monoethylene Glycol 107-21-1 Acute Tox. 4 (oral); STOT RE 2 0.5 1000.00 Tonnes Coolant H302, H373
43 IPA 67-63-0 Flam. Liq. 2; Eye Irrit. 2; STOT SE 3 356 3000.00 Tonnes Production H225, H319, H336
44 Diesel 68476-34 Flam. Liq. 3; Acute Tox. 4; Skin Irrit. 2; Skin Cor. 2; STOT
RE 2; Carc 1B; Aquatic Chronic 2 26 15.00 Tonnes Facilities
H226, H350, H332, H304, H315, H373, H411
45 LPG - Liquefied Petroleum Gas 68476-85-7 Flam Gas 1; Press. Gas 1.64 2.89 Tonnes Facilities H220, H280
46 Nitrogen 7727-37-9 N/A 0.08 7000.00 Tonnes Facilities N/A NOTES Carc. – Cacogenic; Corr. – Corrosive; Flam. – Flammable; Irr. – Irritation; Liq. – Liquid; Sens. - Sensitive; Press. – Pressurised; R&D – Research and Development; Tox. – Toxic.
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3. STAGE 2 – Identification of Relevant Hazardous Substances
3.1 Relevant Hazardous Substances
Stage two of the assessment requires the identification of relevant hazardous substances used onsite that have the potential to contaminate soil or groundwater [Ref.1].
‘Relevant hazardous substances’ are those substances or mixtures defined within Article 3 of the 2008 Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP Regulation) which, as a result of their hazardousness, mobility, persistence and biodegradability (as well as other characteristics), are capable of contaminating soil or groundwater and are used, produced and/or released by the installation’ [Ref 5].
A review of the 2008 Regulation (EC) No 1272/2008 Article 3 on the Classification, Labelling and Packaging of Substances and Mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 was undertaken.
The substances outlined in Table 2, below, have been identified from Stage 1 as being relevant hazardous substances which are used, or released at the facility. The likelihood of the release of these substances into the environment, taking into account the volumes, potential environmental effects, location and the containment measures in place is discussed in Section 4.
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Table 2; Relevant Hazardous Substances [Ref. 7].
Substance Code
Material/ Substance
CAS Number Danger
Category Amount Stored
(Tonnes)
Annual Usage
(Tonnes)
Unit Stored Internally or Externally?
Storage Location
within Facility
Method of Storage
Method of Handling/
Transportation
Contamination Containment Mechanism
Nature of Use
Hazard Statement
5 TBE Monomer 128840-36-8 Skin Irr. 2; Skin. Sens. 1; Eye Irr. 2; STOT SE 3; Aquatic Chronic 4
0.3 2.04 Tonnes Internally Cold Room 1 l Bottles Manual Bunded Room Production H315, H317, H319, H335,
H413 8 Vazo 64 78-67-1 Self-reactive substances
(Type C) Acute Tox. 4 (inhalation);
Acute Tox. 4 (oral); Aquatic Chronic 3
0.16 0.24 Tonnes Internally Fire Vault Cardboard Drum -
25kg
Manual Bunded Room Production H242, H302, H332, H412
9 Low Acid Hema 868-77-9 Skin Irrit. 2; Eye Irrit. 2; Skin Sens. 1
4 14.40 Tonnes Internally Cold Room 200 l Drum Pallet Truck Bunded Room Production H315, H319, H317
11 Ethylene glycol dimethacrylate
97-90-5 Skin Sens. 1; STOT SE 3, Xi 0.05 0.20 Tonnes Internally Cold Room 25 l Drum Pallet Truck Bunded Room Production H317, H335
12 UV Blocker 96478-09-0 Acute Tox. 4; Skin Irrit. 2; Eye Irrit. 2; STOT SE 3
0.16 4.00 Tonnes Internally Ambient Room
1 kg Plastic Manual Bunded Room Production H312, H315, H319, H335
13 Allyl methacrylate, AMA
95-05-9 Flam. Liq. 3; Acute Tox. 4 (oral); Acute Tox. 3 (dermal); Acute Tox. 2 (inhalation); STOT RE 2;
Aquatic Acute 1; Aquatic Chronic 3
0.05 0.20 Tonnes Internally Cold Room 25 l Drum Pallet Truck Bunded Room Production H226, H302, H311, H330, H373, H400,
H412
14 Hema VC (monomer)
145497-35-4 Skin Irrit. 2; Eye Irrit. 2; STOT SE 3
0.004 0.01 Tonnes Internally Cold Room 1 l Glass Bottle
Manual Bunded Room Production H315, H319, H335
17 NVP, 1-Vinyl-2-pyrrolidinone
88-12-0 Acute Tox. 4; Eye Dam. 1; Carc. 2; STOT SE 3; STOT RE 2
9.6 29.00 Tonnes Internally Ambient Room
200 l Drum Pallet Truck Bunded Room Production H302, H332, H312, H318, H351, H335,
H373 18 IPA 67-63-0 Flam. Liq. 2; Eye Irrit. 2; STOT SE
3 1.2 2.40 Tonnes Externally Fire Vault 200 l Drum Pallet Truck Bunded Room Production H225, H319,
H336 20 Boric Acid 10043-35-3 Repr. 1B 0.6 13.30 Tonnes Internally LLC 25 kg Bags Pallet Truck N/A Production H360FD
21 Di Sodium Tetraborate
1330-43-4 Eye Irrit. 2; Repr. 1B 0.625 1.90 Tonnes Internally LLC 25 kg Bags Pallet Truck N/A Production H319, H360FD
23 Hydrochloric acid 7647-01-0 Met. Corr. 1; Skin Corr. 1B; STOT SE 3
0.01 0.02 Tonnes Internally Chemistry Lab
1 l Bottle Manual Bunded cabinet Production H290, H314, H318, H335
27 Sodium Hydroxide 1310-73-2 Skin Corr. 1A 0.006 0.04 Tonnes Internally Ambient Room
1 l Plastic Manual Bunded cabinet Production H290, H314
28 Bi-Napthol 18531-99-2 Eye Irrit. 2 0.0002 0.0005 Tonnes Internally Ambient Room
100 g bottle
Manual Bunded cabinet Production H319
29 Di(ethylene glycol) diacrylate
4074-88-8 Acute Tox. 3; Skin Irrit. 2; Eye Dam. 1; Skin Sens. 1
0.005 0.01 Tonnes Internally Cold Room 100 ml Bottle
Manual Bunded Room Production H301+H311, H315, H317,
H318 30 HEA, 2-
Hydroxyethyl acrylate
818-61-1 Acute Tox. 4; Acute Tox. 3; Skin Corr. 1B; Skin Sens. 1; Aquatic
Acute 1
0.006 0.02 Tonnes Internally Cold Room 250 ml Bottle
Manual Bunded Room Production H302, H311, H314, H317,
H400 31 Ethyl-L-Lactate 687-47-8 Flam. Liq. 3; Eye Dam. 1; STOT
SE 3 0.075 0.18 Tonnes Internally Ambient
Room 1 l Plastic Manual Bunded Room Production H226, H318,
H335
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Substance Code
Material/ Substance
CAS Number Danger
Category Amount Stored
(Tonnes)
Annual Usage
(Tonnes)
Unit Stored Internally or Externally?
Storage Location
within Facility
Method of Storage
Method of Handling/
Transportation
Contamination Containment Mechanism
Nature of Use
Hazard Statement
32 BME 99%, 2-Mercaptoethanol
60-24-2 Acute Tox. 3; Acute Tox. 2; Skin Irrit. 2; Eye Dam. 1; Skin Sens. 1;
STOT RE 2; Aquatic Acute 1; Aquatic Chronic 1, M-Factor -
Aquatic Acute: 1
0.002 0.002 Tonnes Internally Ambient Room
1 l bottle Manual Bunded Room Production H301, H331, H310, H315, H318, H317, H373, H400,
H410 33 IPA Wipes 67-63-0 Flam. Liq. 2; Eye Irrit. 2; STOT SE
3 0.217 0.87 Tonnes Internally Engineering
Stores Container Pallet Truck Chemical Shed
- Bunded Production H225, H319,
H336 34 Spiriclens 64-17-5 Flam. Liq. 2; Eye Irrit. 2 0.03 0.08 Tonnes Internally Engineering
Stores 500ml Bottle
Pallet Truck Chemical Shed - Bunded
Production H225, H319
37 NALCO® 2584 - Sodium Hydroxide (Caustic) 30-50% - Potassium Hydroxide (potash) 10-20%
1310-73-2 1310-58-3
Skin Corr. 1A; Eye Dam. 1 0.52 0.26 Tonnes Externally Facilities Store
440 l Forklift Chemical Shed - Bunded
Boiler Treatment pH control
H290, H314
40 NALCO® 77211 - Sodium Bisulfite 30-50% - Cobalt Sulfate 0.01-0.1%
7631-90-5 10124-43-3
Acute Tox. 4 0.44 0.98 Tonnes Externally Facilities Store
440 l Forklift Chemical Shed - Bunded
Oxygen scavenger
H302
42 Monoethylene Glycol
107-21-1 Acute Tox. 4 (oral); STOT RE 2 0.5 1000.00 Tonnes Internally Ambient Room
1 l bottle Manual Bunded Cabinet
Coolant H302, H373
43 IPA 67-63-0 Flam. Liq. 2; Eye Irrit. 2; STOT SE 3
356 3000.00 Tonnes Externally Bulk tanks Bulk tanks Sealed pipeline, bunded
loading area.
Bunded Room Production H225, H319, H336
44 Diesel 68476-34 Flam. Liq. 3; Acute Tox. 4; Skin Irrit. 2; Skin Cor. 2; STOT RE 2; Carc 1B; Aquatic Chronic 2
26 15.00 Tonnes Externally Bulk tanks Bulk tanks Sealed pipeline,
infrequent deliveries <1
per year
Bunded Room Facilities H226, H350, H332, H304, H315, H373,
H411
45 LPG 68476-85-7 Flam Gas 1; Press. Gas 1.64 2.89 Tonnes Externally Bulk tanks Bulk tanks Sealed pipeline,
infrequent deliveries <4
per year
N/A. Gas at atmospheric
pressure
Facilities H220, H280
46 Nitrogen 7727-37-9 Pressurised Gas 0.08 7000.00 Tonnes Externally Bulk tanks Bulk tanks Sealed pipeline N/A. Gas at atmospheric
pressure
Facilities H280
NOTES Carc. – Cacogenic; Corr. – Corrosive; Flam. – Flammable; Irr. – Irritation; Liq. – Liquid; Sens. - Sensitive; Press. – Pressurised; R&D – Research and Development; Tox. – Toxic.
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4. STAGE 3 – Assessment of the Site Specific Pollution Possibility
4.1 Storage, usage, containment measures, potential pollution risks
The following information in relation to each of the hazardous substances in question is outlined in Table 2, Section 3.1 Relevant Hazardous Substances:
• Storage location; • Storage method; • Method of handling/transport; • Containment mechanism; • Use on site.
Considering the above information, in the context of potential land and groundwater pollution, the following can be concluded:
1. All the storage methods/locations have a containment mechanism i.e. a bund [Ref. 6/Ref. 7]. This reduces/limits the potential risk of pollution to the land or groundwater from a spillage, but does not eliminate the risk.
2. IPA, LPG, Diesel and pressurised Nitrogen Gas are transported in sealed pipelines [Ref.6/Ref. 7]. This does not prevent pollution, but when transporting hazardous materials sealed pipelines pose a low risk of contamination to soils and groundwater.
The only hazardous chemical’s stored onsite without a containment mechanism are Boric Acid (13.3 Tonnes) and Di Sodium Tetraborate (1.9 Tonnes) [Ref. 7]. These are stored in a 25 kg bags internally onsite [Ref. 7]. This is a potential contamination risk, considering the volume of the material stored on site, as outlined in Table 2. There is the potential for contamination to the land and groundwater when Boric Acid and Di Sodium Tetraborate are transported to the site, off loaded from trucks/vans and handled on site. Contamination may result from accidents, broken bags, broken pallets and punctures to the plastic bags which could potentially cause localised contamination.
Furthermore, it is possible that localised contamination may enter the drainage network through gullies and pose a contamination risk to surface waters. Investigation of the storage protocols and containment structures was not possible, as access was not permitted for IE Consulting personnel to enter the buildings on site.
The location of the above storage points across the Bausch & Lomb facility are outlined in Drawing No. OS.14.Hazardous-1.12, contained in Appendix A.
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4.2 Soil & Groundwater Contamination Hazards
There is no historical soil or groundwater baseline data available, prior to the development of the current site infrastructure. Limited information for the existing facility is available for the site, prior to licencing.
Access inside the plant was not permitted by Bausch & Lomb for IE Consulting Personnel. However, Bausch & Lomb provided information to Environent Consulting to suggest the storage facilities and general site maintenance is to a high standard [Ref. 9]. It is understood, that the site does not contain any materials which can degrade concrete [Ref. 6].
The loading/unloading areas, yards and external hard standing areas are inspected on a monthly basis [Ref. 9]. The structures and site surfacing are in good condition, according to Bausch & Lomb [Ref. 9]. There is no evidence of major cracks or damage to hard standing or loading/unloading areas across the site [Ref. 9]. Hair line cracks are evident in some areas [Ref.9].
The integrity of all bunds is tested every three years by a certified contractor [Ref. 9]. Bausch & Lomb maintain a register of all bund testing completed, and certificates of testing are available upon request [Ref .9]. The last round of bund integrity testing was completed in May 2017, and Bausch & Lomb confirmed that all bunds passed the testing [Ref. 10]. There were no recommendations or follow up works required as a result of the 2017 bund integrity tests [Ref. 10].
Drainage routes and service corridors were not surveyed by IE Consulting Personnel, due to access restrictions. No commentary was received from Environent Consulting in relation to pollution prevention measures for spills entering the sites drainage network.
As per the guidance concerning baseline reports under the 2010 Article 22(2) of Directive 2010/75/EU, the following circumstances under which emissions may occur are required to be investigated: planned emissions, routine operations, and accidents/incidents [Ref. 2].
Planned Emissions – Bausch & Lomb currently have no discharges to groundwater or to soil [Ref. 6]. However, in the event of a spillage or unplanned emission it is possible that contamination may enter the drainage network conveying surface water runoff from the site. Thus, this potentially may result in contamination of soils and groundwater resources.
Routine Operations - Overall the site is maintained to a high standard [Ref. 6/Ref. 9]. There is no evidence of major cracks or damage to hard standing areas which would form a pathway to the soil/groundwater during loading/unloading hazardous of materials [Ref. 6]. Hair line cracks are evident in some areas which pose a minor risk [Ref.9]. Loading and unloading of materials takes place in designated areas only [Ref.6].
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The main materials delivered to the site are liquid nitrogen, which is kept at a low temperature and liquefied petroleum gas [Ref. 6/Ref. 7]. Nitrogen is also produced on site in the nitrogen plant [Ref. 11]. When liquid nitrogen and liquefied petroleum gas are released to air, they will transition into the gaseous phase. Thus, these will have a minimal impact on the land and groundwater.
Diesel is stored onsite for use during emergencies to power back-up generators [Ref. 6]. Diesel tanks are bunded and all bunds have their integrity tested every three years by a certified contractor [Ref. 9]. The location of the storage areas across the Bausch & Lomb facility are outlined in Drawing No. OS.14.Hazardous-1.12, contained in Appendix A.
Accident/Incidents - In late December 2004, an oil (diesel) leak occurred from an underground pipeline [Ref. 8]. Approximately 200 tonnes of soil/fill surrounding the pipeline was excavated between 1.0 and 1.5 meters below ground level (mbgl). A sump at one end of the pipeline was reported to have had 1,200 litres of oil removed from it [Ref. 8.] The location of the diesel leak is not outlined in the report undertaken by URS Ireland Limited in 2005.
Soil samples were collected from the base and sides of the excavation along with one water sample [Ref.8]. The mineral oil results for the soils indicated that heavily contaminated soils within the area had been removed [Ref. 8]. During the sampling campaign pockets of moderately contaminated fill remained close to the actual site of the leak. In order to minimise the residual impact, Bausch & Lomb continued to excavate the contaminated granular fill from within the excavation [Ref.8].
The Dutch Intervention Values (DIV) were applied as a screening tool to assess the severity of the soil and groundwater contamination. This was due to the absence of statutory soil assessment criteria in Ireland [Ref. 8]. The DIV for mineral oil in soil in 2005 was 5,000 mg/kg, with a corresponding 600 µg/L in groundwater. Neither threshold had been exceeded by the analytical results for the soil and water samples collected [Ref. 8].
The contamination was restricted to the granular fill overlying the natural clay subsoils through the area [Ref. 8]. All samples of the basal clays were free of hydrocarbon contamination. In addition, the clays were considered to be an effective barrier to the downward migration of diesel contamination into the deep bedrock aquifer [Ref. 8]. In conclusion, all soil and water samples collected were found, when analysed, to have mineral oil concentrations below the relevant contamination assessment criteria [Ref. 8].
Contaminated water was removed from the sump though pumping [Ref. 8]. It is the opinion, of the contaminated land consultant (URS), that all heavily impacted soils were removed and backfilled with clean, granular fill material [Ref.8].
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4.3 Conclusion
The following can be concluded from the Baseline Screening Process:
1. The preliminary conceptual model is that the entire site is underlain by between 5 to 25 m of clay. Clay has a low hydraulic conductivity, and thus will act as an impermeable, somewhat protective barrier to contamination entering the groundwater. However, soils are highly vulnerable to contamination from surface activities and storage areas as they are the first receptor.
2. This can be summarized as outlined below:
Sources: Storage of hazardous substances, fuels, Boric Acid/ Di Sodium Tetraborate stored without containment mechanisms etc.
Pathway: Direct ingress through hair line cracks in concrete, spills during unloading, broken pipes, accidents, containment mechanism failure, entry through drainage system on site etc.
Receptor: Soils (high risk) and groundwater (medium risk – partially protected by the overlying clay deposit).
3. Hazardous materials are stored and handled on site. 4. Bausch & Lomb carry out monthly audits of yards, external hard standing areas and
loading/unloading areas to check for potential contamination pathways to soil/groundwater and to ensure the site is maintained to a high standard. All bunds have their integrity tested every three years by a certified contractor.
5. There is no baseline data or site specific information in relation to the status of the land and groundwater underlying the site.
6. Storage methods/locations such as bunded rooms, bunded cabinets and bunded tanks are used on site. This reduces/limits the risk of pollution to the land and groundwater from a spillage, but does not eliminate the risk.
7. IPA, LPG, Diesel and pressurised Nitrogen Gas are transported in sealed pipelines. These do not prevent pollution, but when transporting hazardous materials sealed pipelines pose a low risk of pollution to soils and groundwater.
8. The only hazardous chemical’s stored onsite without a containment mechanism are Boric Acid and Di Sodium Tetraborate. These hazardous substances pose a risk to the land and groundwater underlying the site.
9. In the event of an unplanned emission, there is a risk that soil and groundwater may become contaminated. There is also a risk from routine operations that contamination may occur, through accidental spills, drips or broken packaging during unloading.
10. Potential pathways include surface runoff and contamination entering the drainage network or through hairline cracks in the yards, external hard standing areas and loading/unloading areas.
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11. The diesel spill of 2004 is understood to have been remediated by the excavation of contaminated soils [Ref. 8]. Given the impermeable nature of the clay underlying the site, IE Consulting understands that the diesel spill had a low impact on the groundwater underlying the site.
12. In the context of the cumulative volume of hazardous material stored on site, the absence of contaminant mechanisms for Boric Acid and Di Sodium Tetraborate and the 2004 diesel fuel spill, it is recommended that Stages 4 to 8 of the Baseline Assessment be completed.
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References
Ref. 1. Communication from the Commission: European Commission Guidance concerning baseline reports under Article 22(2) of Directive 2010/75/EU on industrial emissions 2014/C 136/03.
Ref. 2. DIRECTIVE 2010/75/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 24 November 2010 on industrial emissions (integrated pollution prevention and control) (Recast) (Text with EEA relevance).
Ref. 3. IDA (Industrial Development Authority) – Invest in the South East, Business in the South East: Bausch & Lomb in Waterford. Accessed 14/05/2019.
Ref. 4. OSi (Ordnance Survey Ireland) – Geohive. Accessed: 14/05/2019.
Ref. 5. Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006. Accessed: 14/05/2019.
Ref. 6. Commentary from Environet Consulting Ireland Limited. 09/05/2019.
Ref. 7. Hazardous Material Information, Data and Comments, supplied by Bausch & Lomb.
Ref. 8. URS Ireland Limited - Report Ref. 45078 Bausch & Lomb, Re: Soil Validation Sampling, 11th March 2005.
Ref. 9. Commentary from Bausch & Lomb (Waterford, Ireland) Environment Health & Safety Office (EHS), in response to queries by Environet Consulting Ireland Limited. 24/05/2019.
Ref. 10. Commentary from Bausch & Lomb (Waterford, Ireland) Environment Health & Safety Office (EHS), in response to queries by Environet Consulting Ireland Limited. 06/06/2019.
Ref. 11. Commentary from Environet Consulting Ireland Limited. 11/06/2019.
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Prepared by IE Consulting
Innovation Centre, Green Road, Carlow
Tel:- 059 91 33084 Fax:- 059 91 40499
Email:- [email protected] www.iece.ie
APPENDIX A
Hazardous Material Stores Drawing No. OS.14.Hazardous-1.12
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GD
13
0B
RWP
COL
COL
COL
COL
COL
COL
COL
COL
COL
Col.
LIFT
Roller S
hutter Door
L57
Ramp
HOIST
RWP
RWP
RWP
RWP
HOIST
COL
Col.
Col.Col.Col.Col.
UP
RWG
UP
RWP
8
7
6
5
4
3
2
1
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0
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7
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5
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6
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BU
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S2130m
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2500m
m C
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WID
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2500m
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WID
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200
2500m
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WID
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m C
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WID
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200
2500m
m C
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WID
TH
2500m
m C
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AR
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EN
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WID
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2130m
m B
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WE
EN
BU
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S2130m
m B
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WE
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BU
FF
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S2130m
m B
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WE
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BU
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S
15
15
Parking
Parking
Parking
T
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M
P
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A
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C
A
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A
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A
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A
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K
Ram
p
Ram
p
Ramp
SLOW
SLOW
EXIT
VISITORS PARKING ONLY
EX
IT
NO
NO
E
XIT
SLO
W
SLO
W
SLO
W
EXIT
NO
NO EXIT
ENTRY
ENTRY
NO
EXIT
SLO
W
SET DOWN ONLY
N
O
P
AR
KIN
G
LO
AD
IN
G
GD42CRoller Shutter Door
GD42BGD42A
GD
42D
GD
42
E
Roller Shutter Door
Roller S
hutter Door
BD
BDBDBDBDBDBD
BD
BD
BD
BD
BD
BD
BD
BD
BD
BD
BD
BDBD
BD BD
BD
BD
BD
BD
BD BD BD BD BD BD BD BD
SP
SP
SP
SPRINKLER
DIESEL
TANK
BIN
BIN
94sqM
OVERALL SITEBOILER HOUSE 3
OS-00132sqM
OVERALL SITEWELDING ROOM
OS-002
109sqM
OVERALL SITECOMPRESSOR ROOM
OS-003
61sqM
OVERALL SITEDRYER ROOM
OS-004
31sqM
OVERALL SITESPRINKLER PUMPHOUSE
PUMP NO.1 (DUTY)DIESEL PUMPSET
OS-00530sqM
OVERALL SITESPRINKLER PUMPHOUSEPUMP NO.2 (STAND-BY)
ELECTRIC PUMPSETOS-006
75sqM
OVERALL SITECHEMICAL STORE
OS-007
91sqM
OVERALL SITEPORTABLE OFFICE
ROOM
OS-009
U
P
45
123
G
Y
G
Y
G
Y
G
Y
G
Y
G
Y
BD
AJ
FH
FH
LP
LP
LP
LP
LP
LP
LP
LPLP
LP
LP
SP
SP
SP
SP
SP
T
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P
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A
R
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C
A
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K
Ramp
Planting
Grass
Grass
Top of kerbwith levels taken
Bottom of kerbwith levels taken
Bottom of kerbwith levels taken
Top of kerbwith levels taken
Steps
Steps
Average 2.5m high hedging
Average 2.5m high hedging
Average 3m high hedging
Ramp
FH
15
LP
15
N
O
P
AR
KIN
G
LO
AD
IN
G
Aco Drain
Generator
FH
LP
Ramp
Diesel Tank
BD
BDBD
BD
110.
Parking
ParkingParking
SM
SM
UP
3967
MOTORCYCLE
PARKING
UP
ACCESS RAMP
STOP
160.
150.
148.
MH
MOTORCYCLE
PARKING
147.
140.
130.
120.
100.
90.
80.
70.
50.
10.
UP
120
50
35
L02
L01
300
585,18
653,7
1
2
UP
UP
7
5
4
3
2
1
6
L02
UP
7
5
4
3
2
1
6
UP
UP
LEGEND
NOTES
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