srtechnics - epa · 2013. 7. 26. · sr technics ireland limited md112, oshei engineering/...

SRTechnics Office of Environmental Enforcement EPA Regional Inspectorate, McCumiskey House Richview, Clonskeagh Road, Dublin 14

01 March 2010

Dear Sir/ Madam,

SR Technics Ireland Limited MD112, OSHEI Engineering/ Planning/ Sales Office, 1st Floor, Hangar 5, Dublin Airport,

SR Technics Ref: EnvIPPCSURR041 O.epa( Rev2) Mobile: 086 857 22 66 €-Mail: [email protected]

PO480-02 SR Technics Ireland Limited Submission of amended IPPC Boundary Drawings N/A N/A

As you are aware SR Technics is in the last phase of closing its Dublin Airport Facility.

As Licensed Activities are no longer carried being carried on in parts of our facility we are now requesting the Agency’s permission to reduce the area covered by the Licence by removing certain buildings from the scope of the above Licence and reducing the site boundary.

All buildings on site have already been surrendered to Dublin Airport Authority (DAA) but SR Technics still retains responsibility under the Licence for work carried on there.

URS Ireland Limited has carried out a closure audit on Hangar 3 and they have certified that they are satisfied that the Hangar 3 area is in a condition which poses no threat to persons or to the environment.

I am requesting from the Agency that the boundary of the SR Technics IPPC Licence (PO480-02) as defined in Condition 1.3 (Drawing Reference ‘IPPCBOUNDARY Revl’) be amended through a Technical Amendment to facilitate the removal of Hangar 3 and its associated offices and workshops from the scope of the SR Technics IPPC Licence. The revised boundary drawing reference ‘IPPCBOUNDARY Rev2’ shows the proposed IPPC Licence boundary minus Hangar 3 and its associated workshops.

Copies of the URS Closure Audit and proposed alternative reduced facility footprint were sent to the Agency in previous correspondence reference EnvIPPCSURR041 O.epa.

If you require any further clarity on any of the above please feel free to contact me.

Yours sincerely,

Sean Lawlor I - 2 MAR 2010

Tel: + 353 1 812 6000, Fax +353 1 888 8889 Directors: James Stuart, CEO (British), Helmut Himmelreich (German), Stephanie Kennett (British)

www.srtechnics.com Registered in Ireland as a private company limited by shares, number 268659

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mailto:[email protected]

http://www.srtechnics.com

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HANGAR 3 mr mr

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FINAL NOTES STATUS

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IPPCL Surrender Support

Hangar 3 Closure Audit - Validation Report

15 February 201 0 Final

Issue No 2 4934071 7 I

-A-= .

Environmental Protection Agency

0FPTC.E OF ENVIRONMENTAL ENFORCEMENT

RI CHVIEW

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOlKKIKK

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IPPCL Surrender Support Hangar 3 Closure Audit - Validation Report

1

2

Project Title:

Report Title:

Project No:

Report Ref:

Status:

Client Contact Name:

Client Company Name:

Issued By:

15 February 201 0

15 February 201 0

Original issue

SR Technics comments

IPPCL Surrender Support

Hangar 3 Closure Audit - Validation Report

4934071 7

Final

Sean Lawlor

SR Technics

URS Ireland Ltd lveagh Court 6-8 Harcourt Road Dublin 2 Ireland Tel: + 353 (0) 1 415 5100 Fax: + 353 (0) 1 415 5101 www.iirseurope.com

Document Production I Approval Record

Issue No: 2

Prepared by

Checked by

Approved by

..

Name

Klara Kovacic

Danny Ward

Peter Hassett

Document Revision Record

Signature Date

15 February 201 0

15 February 201 0

15 February 201 0

Position

Environmental Consultant

Environmental Consultant

Department Head, Transactions & compliance

I IssueNo I Date I Details of Revisions I

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOI/KWKK 15 February 2010

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http://www.iirseurope.com


CERTIFICATE OF COMPLETION

This is to certify that URS Ireland Limited considers that the requirements of.Condition 10 (Decommissioning) of IPPC Licence PO480-02 were completed to the extent practicable at the date of preparation of this report subject to the following comments:

SR Technics should complete any outstanding actions listed in section 2.10 of this Validation Report and provide any outstanding information to the EPA as detailed in this Validation Report or as otherwise requested by the EPA.

Signed,

Peter Hassett,

For,

URS Ireland Limited,

Date:

1 5Ih February 201 0

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOI/KWKK 15 February2010

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IPPCL Surrender Support Hangar 3 Closure Audit . Validation Report

CONTENTS

Section Page No

LIMITATIONS ................................................................................................................................ 1

COPYRIGHT ................................................................................................................................. 1

1 . 1.1 1.2 1.3

2 . 2.1 2.2 2.3 2.4 2.5

2.6 2.7 2.8 2.9 2.10

3 .

INTRODUCTION .............................................................................................................. 1

Scope of Work .................................................................................................................. 2 Background ...................................................................................................................... 3 Hanagar 3 IPPC licence surrender .................................................................................. 3

FINDINGS ........................................................................................................................ 4

Overview .......................................................................................................................... 4 Soil and groundwater contamination ................................................................................ 5 Equipment Decommissioning and Removal from Site ..................................................... 8 Decommissioning of Bunds, Tanks and Pipelines ......................................................... 10 Presence of Poly Chlorinated Biphenyls (PCB) and Ozone Depleting Substances (ODS) ......................................................................................................... 11 Presence of asbestos ..................................................................................................... 11 Removal of waste ........................................................................................................... 12 Removal of Product and Raw Materials ......................................................................... 12 Decommissioning of Site Utilities ................................................................................... 13 Summary of issues and recommended actions ............................................................. 13

CONCLUSION ............................................................................................................... 14

APPENDIX A . FIGURES

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IPPCL Surrender Support URS Hangar 3 Closure Audit - Validation Report ,

LIMITATIONS

URS Ireland Limited (URS) has prepared this Report for the sole use of SR Technics in accordance with the Agreement under which our services were performed. No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by us. This Report may not be relied upon by any other party without the prior and express written agreement of URS. Unless otherwise stated in this Report, the assessments made assume that the sites and facilities will continue to be used for their current purpose without significant change. 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. Information obtained from third parties has not been independently verified by URS, unless otherwise stated in the Report.

COPYRIGHT

0 This Report is the copyright of URS Ireland Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOl/KKIKK 15 February 2010

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1. INTRODUCTION

SR Technics Ireland Ltd. (SR Technics) contracted URS Ireland Ltd. (URS) to complete a closure audit of Hangar 3 and the adjacent offices and workshops encompassing the footprint of Hangar 3 (see Figure 1) in order to surrender that part of the SR Technics site from their current IPPC Licence No. PO480-02.

SR Technics was granted an IPC Licence (Register Number PO480-01) by the Environmental Protection Agency (hereafter referred to as the 'Agency') on the 31" August 1999 for the use of coating materials in processes with a capacity to use at least 10 tonnes per year of organic solvents, and electroplating operations.

Licence register number PO480-01 was reviewed and replaced by the revised licence Reg. No. PO480-02 on the 25Ih September 2006 for:

: - The manufacture or use of coating materials in processes with the capacity to make or use at least 10 tonnes of per year of organic solvents, and powder coating manufacture with a capacity to produce at least 50 tonnes per year not included in paragraph 12.2.1

: - The surface treatment of metals and plastic materials using an electrolytic or chemical process where the volume of the treatment vats exceeds 30 m3

The requirement to complete a closure audit and prepare a validation report follows discussions between SR Technics and the EPA after SR Technics' announcement to cease operations. Specifically, the EPA requested that such an audit be carried out in a letter to SR Technics dated 12'h February 2010 (reference: EPA Letter Ref: P0480- 02/gc03ts).

The requirement to complete a validation report is also contained in Condition 10.4 of the IPPC licence which states:

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,

URS has prepared this validation report on the basis of and taking into account:

Specific EPA requirements as outlined in correspondence from the EPA to SR Technics (reference: EPA Letter Ref: P0480-02/gc03ts);

Assessment of all available information provided by SR Technics relating to the decommissioning process; and,

A site visit by Ms. Klara Kovacic, URS Environmental Consultant, on 05'h February 2010.

SR Technics Ireland Ltd449340717 SR Technics Hangar 3 IPPC\DURPOOOI/KWKK 15 February 2010

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The following site personnel provided key information and accompanied URS during the audit:

Mr. Sean Lawlor, Environmental Manager, SR Technics; and

0 Mr. Niall Farrell, Facilities Manager, SR Technics.

Relevant documentation provided by Mr. Sean Lawlor was reviewed during and after the site visit. Other reports prepared by URS for SR Technics were also reviewed.

1 .I Scope of Work

The following scope of work comprised this closure audit and validation report assessment:

Task 1 : Review of existing information;

Task 2: Site audit and personnel interviews;

Task 3: Reporting.

Task 1 : Review of Existing Information and Data

This task involved the collation and assessment of relevant documentation. The following reports and records were obtained and reviewed prior to the site visit:

Residuals Management Plan (dated March 2007), prepared by URS;

0 Bund Integrity Testing (dated O!jth February 2007), prepared by URS;

Soil and groundwater investigation reports prepared by URS during 2010;

0 The sites tanks and bund list; and

0 IPPC Licence No. PO480-02.

Task 2: Site Audit and Personnel Interviews

A one day site inspection was conducted. This site visit by Ms. Klara Kovacic was completed on 5'h February 201 0.

The tasks carried out during this site included:

0 Interview with Mr. Sean Lawlor;

0 Review of additional documentation;

Site inspection (only Hangar 3 and adjacent office and workshops were audited); and

Follow-up document review after the site tour.

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During the site inspection, the following areas of the site were visited:

Hangar 3, including the offices on the hangar floor;

External east yard with diesel and detergent tanks, Karcher workshop, and 40 ft. paint storage container;

Ground level paint workshops adjacent to the south side of Hangar 3;

Ground level offices adjacent to the west side of Hangar 3;

Ground level cleaning and sand blasting workshop;

First floor electrical workshop, offices, training rooms and general workshops.

Task 3: Reporting

This report provides detailed observations made during the site audit and presents assessment of issues and recommendations.

1.2 Background

In 2004, SR Technics acquired FLS Aerospace Ireland Limited, an aircraft maintenance company who operated from a facility at the north side of Dublin Airport. SR Technics operations on the site included aircraft maintenance, washing, painting, electroplating, servicing of auxiliary power units, sheet metal fabrication and repair.

The SR Technics site and all buildings on the site including Hangars 1-6, garage, workshops, and offices were passed to Dublin Airport Authority (DAA) as part of the closure agreement.

SR Technics ceased all operations at the Dublin Airport site in March 2009. Since then, SR Technics has been carrying out decommissioning, cleaning and environmental restoration activities.

At the time of writing of this report, SR Technics had returned all of the buildings on the entire site, including Hangar 3 and adjacent offices and workshops, to DAA, who have subsequently leased some of the buildings to other companies. The EPA were notified of this leasing of the buildings by SR Technics via letter on the 26'h June 2009 and the 14'h August 2009. DAA are also in the process of renovating some of the offices and workshops.

1.3 Hanagar 3 IPPC licence surrender

Hangar 3 was used for large airframe painting and it is equipped with an air extraction system to facilitate airframe painting. Air is drawn downwards through vents located in the hangar floor, and extracted through ducts to IPPC licensed emission points A1 & A2.

The workshops adjacent to Hangar 3 were used for painting of specific aircraft components and electrical repairs.


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2.

2.1

SR Technics wishes to surrender Hangar 3 and the adjacent offices and workshops including associated monitoring points (Al, A2, A35, A36, A37, NS1 and NS6) from their current IPPC Licence No. PO480-02 as outlined in Figure 1. An outline of the revised footprint of the area which would still be covered by the revised IPPC Licence (PO480-02) is provided in Figure 3. SR Technics is requesting that, with the agreement of the Agency (through a ‘Technical Amendment’) that this now becomes the site area covered by SR Technics’ IPPC Licence PO480-02.

This change to SR Techincs’ IPPC Licence is required in order to facilitate the aircraft spray painting operations which Eirtech Aviation Ltd. (Eirtech) wish to carry out. Eirtech will lease Hangar 3 from DAA.

The boundaries of Hangar 3 and the adjacent offices and workshops that are the subject of this report are presented in Figures 1 and 2 in Appendix A of this report.

Eirtech plan to lease only Hangar 3, excluding the offices and workshops located adjacent to the south side of Hangar 3. Eirtech will use several offices that are located inside Hangar 3, on the east side of the ground level.

Eirtech will use Hangar 3 for the same activities, namely aircraft painting, as did SR Technics.

FINDINGS

Overview

At the time of the closure audit on 5‘h February 201 0, all decommissioning work in Hangar 3 and adjacent offices and workshops was completed. All production had ceased and the majority of production equipment removed. Only a skeleton staff remained to ensure smooth interface with contractors carrying out final decommissioning activities. All materials and wastes related to production had been removed. Cleaning to remove operations related residuals had been carried out throughout Hangar 3 and adjacent offices and workshops.

All utilities on site - electricity, water, heating, pressurised air - were in operation due to the fact that DAA has taken over the site and was occasionally carrying out some small aircraft repairs and also some refurbishment of some off ices and workshops. According to the information provided by Mr. Sean Lawlor, aircraft repairs carried out by DAA in Hangar 3 are limited to small electrical repairs, tyre replacement, etc. URS observed during the site audit that office refurbishment carried out by DAA are currently limited to wall painting, pipe insulation, and false ceiling repairs.

Overall it was clear that extensive decommissioning work had been completed and that the result was a thoroughly decommissioned site.

The following subsections outline the important aspects of the decommissioning process and its subsequent validation by URS. Specifically the following aspects of the decommissioning process are discussed:

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Potential On-site Contamination;

Production Equipment Decommissioning and Removal from Site;

0 Decommissioning of Bunds, Tanks and Pipelines;

Presence of PCB’s;

Presence of Asbestos;

Removal of Wastes;

Removal of Product and Raw Materials:

Decommissioning of Site Utilities; and,

Other Issues.

2.2 Soil and groundwater contamination

During 2009 and 2010, URS completed a number of environmental assessments at the entire SR Technics site. These assessments addressed the following impacts:

Hvdrocarbons

URS completed an investigation of soil and groundwater quality in the vicinity of the fuel pumps in the Garage Area and provided an assessment of the severity and extent of soil contamination in URS report ‘Garage Area Investigation - Interim Advice’ dated 27 November 2009.

Further, URS completed an investigation of soil and groundwater quality in the vicinity of historically impacted groundwater well GWO11. The assessment is provided in URS report ‘Hydrocarbon Area Investigation’ dated 11 January 201 0. URS notes that groundwater well GWOOl is located downgradient in relation to groundwater flow from hangar 3 and therefore findings related to the investigation around GWOl1 do not have any material impact on the status of soil and groundwater beneath hangar 3.

Trichloroethene (TCE)

URS completed a TCE source area investigation to assess the source of historically impacted shallow and deep groundwater close to Hangar 1. Details of this assessment are provided in URS report ‘Trichloroethene (TCE) Source Area Investigation’, dated 8Ih February 201 0.

Metals

URS completed a groundwater investigation of historical lead (detected in groundwater in the area adjacent to the site boundary) and nickel (detected in well GW016) at the site.

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The assessment is provided in URS report ‘Groundwater Assessment’ dated February 201 0.

The main conclusions of these reports are:

Hydrocarbon contamination in the Garage area of the site:

Moderate levels of hydrocarbon contamination were detected but were considered likely to be restricted to the fill materials.

The Hydrocarbon investigation around well GWOI 1 :

The hydrocarbon impact detected in well GWOII is considered unlikely to be extensive and unlikely to pose a risk to human health (assuming continued industrial/ commercial use of the site) or controlled waters.

The impact detected is considered likely to be associated with intermittent spillages of hydrocarbon fuels in the area and is considered likely to naturally attenuate in line with observed historical trends assuming the use of the area for fuelling is discontinued.

Trichloroethene (TCE)

TCE contamination occurs between Hangar 1 and Hangar 2 (as shown in Figure 3). In terms of TCE the impacted shallow soils and deep and shallow groundwater sampled during this investigation are not considered to pose a risk to human health assuming continued industrial or commercial use of the site.

The impacted shallow soil and groundwater are considered not to be extensive beyond Hangar 1 and the Inflammable Goods Store and are considered unlikely to pose a risk to controlled waters.

The extent of impacted deep groundwater is not clear

The presence of the breakdown products of TCE (including DCE, VC ethene, ethane and methane) in groundwater samples during this site investigation indicates that the conditions for natural biodegradation of TCE have been present in the past or are present in the subsurface.

Other compounds, including 1 , I -dichloroethane (DCA), naphthalene and other hydrocarbon related compounds were also detected in soil and groundwater (shallow and deep). DCA is not a breakdown product of TCE and was used and stored on-site. These compounds are also likely related to sources within Hangar 1 and the Inflammable Goods Store. The migration mechanisms outlined above for TCE are probably common, however, some more detailed work in isolating these sources will be required. Some further delineation of the DCA plume may also be required, as it was detected in GW022, beyond which no downgradient well exists.

Lead

SR Technics Ireland Ltd-49340717 SR Technics Hangar 3 IPPC\DURPOOOI/KWKK 15 February 2010

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IPPCL Surrender Support Hanaar 3 Closure Audit - Validation Report

The historical detections of lead across the site are considered likely to be associated with the shallow fill material observed across the site and unlikely to be related to any process or activity identified on the site.

Assuming continued industrial/commercial use of the site, the concentrations detected are considered unlikely to pose a risk to current or future site users (or con trolled waters.

Nickel

The most plausible source of nickel impact identified is the series of interceptors located in close proximity to well GWOl6 and their associated pipework.

Assuming continued industrial/commerciaI use of the site, the concentrations of nickel detected in fill and shallow groundwater across the site are considered unlikely to pose a risk to current or future site users

The elevated levels of nickel detected in gioundwater are considered unlikely to pose a risk to controlled waters.

With reference to the previous investigations completed at the site URS has drawn the following conclusions with respect to soil and groundwater beneath Hangar 3. It should be noted that no soil and groundwater sampling was completed immediately beneath or downgradient of Hangar 3 and these conclusions assume that conditions observed during previous investigations completed across the site are representative of the area around Hangar 3.

The TCE impact detected in shallow soil and groundwater onsite is located up hydraulic gradient of Hangar 3. However, the detected impact is considered not to be extensive and is unlikely to impact shallow soil and groundwater at Hangar 3.

The extent of TCE impact in deep groundwater around Hangar 3 is unclear.

DCA was detected in well GW022 up hydraulic gradient of Hangar 3. Since no wells are located downgradient of this location the extent of DCA impact is unclear.

The hydrocarbon impact detected on site at well GWO11 and the Garage Area was located down hydraulic gradient of Hangar 3 and is therefore considered unlikely to pose a risk to soil and groundwater beneath this hangar.

The nickel impact detected in well GW016 was located down hydraulic gradient of Hangar 3 and is therefore considered unlikely to pose a risk to soil and groundwater beneath this hangar.

The concentrations of lead detected in groundwater across the site are considered unlikely to pose a risk to current or future site users of Hangar 3 (assuming continued industriakommercial use of the site) or controlled waters beneath the hangar.


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2.3 Equipment Decommissioning and Removal from Site

The site does not maintain an equipment register. All equipment from the site was either sold off or disposed of as waste. No sales documentation was available for review. As the equipment was removed from the entire site, it is not practicable to distinguish the waste records that refer to the equipment from Hangar 3 and the adjacent offices and works hops.

Hangar 3

According to the SR Technics representatives, the only removable equipment in Hangar 3 was scaffolding and mobile steps. Scaffolding was leased and after the operations were ceased, SR Technics returned the scaffolding to the company it was leased from.

The remaining removable equipment in Hangar 3 are fire extinguishers. However, fire extinguishers are considered part of the building and are owned by DAA, therefore fire extinguishers remained in situ. Given the nature of the site and the fact that some small aircraft repairs are taking still place, it is considered necessary to have the fire extinguishers in place. Also, one spill kit (containing sand) was observed in Hangar 3, which is also considered necessary in case of a fuel spill from an aircraft.

Other equipment observed in Hangar 3 is fixed to the walls or ceiling and owned by DAA. This equipment includes:

6 large heating units (labelled A.H.U. 1 to 6) located on platforms on east and west walls of Hangar 3; and

Approximately 45 gas heating units suspended from the ceiling of Hanger 3.

URS observed an electrical switchroom which contains a number of electrical switching panels which were all in operation.

URS observed large amount of scaffolding and 6 mobile metal steps on the floor of Hangar 3. SR Technics representatives informed URS that these scaffolding and mobile steps are owned by Eirtech, who obtained permission from DAA and SR Technics to store this equipment in Hangar 3.

Ground floor offices

All ground floor offices, located on the east and the west side of Hangar 3, were observed to be empty of all equipment, including furniture, office materials, raw materials, or waste. The only remaining pieces of equipment observed were two metal chassis for computer network equipment, owned by DAA, and expected to be used by Eirtech for their office operations.

Karcher workshop and 40 foot container

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Outside the eastern wall of Hangar 3 (as shown on Figure 2), there is a Karcher workshop, 40 foot container and two bunded overground tanks’.

The Karcher workshop contains Kartcher brand power cleaning equipment and a boiler used for heating water. This equipment is fixed to the wall and the floor of the workshop, and it is owned by DAA. The equipment is operational and will presumably be used by Eirtec h .

The 40 foot container was used for storage of specialist aircraft paint and associated thinners and sealants. The container was observed to be empty of all materials.

Painting workshop

A water wall used for removal of paint solids from the overspray is fixed to the ceiling and floor and still in situ in this workshop. The system is cleaned and does not contain any residual material.. In addition, there is a conveyor metal track attached tc the ceiling which was used to hang painted aircraft parts. This track is also free of any ,residual materials.

Cleaning workshop

This workshop contains 9 tanks which were filled with various chemical agents used for cleaning, degreasing, and paint stripping of various aircraft parts. These tanks are located on a platform, and below this platform is a bund and a sump. SR Technics representatives informed URS that all the tanks were emptied, professionally cleaned and decontaminated. URS reviewed an invoice from Enva for providing two staff to clean these tanks and for provision of cleaning detergent (dated 08‘h July 2009).

At the time of the site audit, URS observed residual liquid at the bottom of two tanks. SR Technics representatives informed URS that this liquid is clean water, and source of it are leaking pipes and roof.

Following the audit, SR Technics informed URS that the bund and the sump were not yet cleaned and decontaminated.

In addition, URS observed some potentially contaminated hoses and potentially contaminated scrap metal in the cleaning workshop. URS advised the site representatives that these materials should be disposed of in environmentally sound manner as part of the final cleaning of the workshop. The site representatives informed URS that final cleaning will be completed by the end of February 2010.

Following the site audit, URS advised the site representatives that the bund and the sump should be cleaned and decontaminated..

’ Tanks and bunds are discussed in Section 2.4.

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URS observed sand blasting equipment and a water deioniser in the cleaning workshop. This equipment is owned by DAA, therefore it could not be removed by SR Technics.

Cylinder workshop, sheet metal workshop and stores

The cylinder workshop, sheet metal workshop, generator test area and stores were observed to be empty of all equipment. The only equipment that was still in situ were several small wall mounted electrical circuit breakers, owned by DAA.

Boiler room

Boilers in the boiler room are used for heating and were observed to be in operation at the time of the site audit. This equipment was owned and currently maintained by DAA.

Generator test room

This room was inaccessible during the site visit. The site representatives informed URS that the only equipment in this room are several operational and several decommissioned electrical panels used for testing of aircraft parts. This equipment is owned by DAA.

First floor offices and workshops

Several off ices, avionics workshop and stores, training workshops, locker rooms, electrical workshop and several other rooms are located on the first floor above the painting workshop, sheet metal workshop and store areas. First floor offices and workshops are fully decommissioned and empty of any equipment, furniture, process materials or wastes. URS observed evidence of some renovation works, namely wall painting and pipe insulation, currently being carried out by DAA.

2.4 Decommissioning of Bunds, Tanks and Pipelines

There are two above ground storage tanks and bunds associated with Hangar 3. These tanks and bunds are located adjacent to 40 foot storage container and cleaning workshop (as indicated on Figure 2).

One of the observed above ground tanks is used for storage of diesel used for heating. This tank was partially full at the time of the site audit. The tank is bunded and rain water observed in the bund. This bund was integrity tested in 2007 and was found to be water tight (URS report ‘Bund Integrity Testing’ dated Osth February 2007).

The other tank was used as detergent tank in the past and was empty for several years. This tank was also bunded and there was rain water observed in the bund. This bund was integrity tested in 2007 and was found to be water tight (URS report ‘Bund Integrity Testing’ dated Osth February 2007).

Both tanks are the property of DAA. Fuel in the diesel tank was used by DAA for of workshops and water.

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOI/KK/KK 15 February 2010

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There are drainage lines and a sump in Hangar 3. SR Technics representatives informed URS that the sump was emptied. URS examined documentation (an invoice and a C1 form) showing that 10,000 litres of oily water were removed from Hangar 3 sump.

SR Technics representatives informed URS that drainage and the sump was not cleaned and decontaminated. However, URS considers that this is not necessary due to the following:

Hangar 3 will at no point be closed and completely unused; and

Eirtech will use Hangar 3 for the same activities as SR Technics.

SR Technics completed a drainage integrity survey for the entire site in 2005. The survey was carried out by Horizon Environmental Ltd., and it included drainage in Hangar 3. No defects on drainage in Hangar 3 were detected in 2005 survey.

2.5 Presence of Poly Chlorinated Biphenyls (PCB) and Ozone Depleting Substances (ODS)

SR Technics staff reported that there are no Ozone Depleting Substances in Hangar 3 or adjacent offices and workshops. No refrigeration equipment is present in these areas and all observed fire extinguishers were carbon dioxide based.

SR Technics staff reported that there are no known PCBs in Hangar 3 or adjacent offices and workshops. During the audit, URS observed the following potentially PCB containing equipment:

Fluorescent lights; and

Circuit breakers.

However, this equipment was located in the areas that were built in 1992, the fluorescent light fittings were changed over the past several years and all circuit breakers were either electronic or air insulated, therefore URS concluded that there are no PCBs in Hangar 3 or adjacent offices and workshops.

2.6 Presence of asbestos

The site completed a comprehensive asbestos survey in 2003 and maintains an asbestos register. URS reviewed the site’s asbestos register prepared by Kearney and Associates Ltd., dated 20Ih January 2003. The asbestos register contains the following relevant information:

Heaters in the cleaning workshop and the painting workshop are assumed to have asbestos backing. This assumption is based on the asbestos testing completed on the similar heaters in Hangar 2. These heaters have backing with cardboard on one side and a green material resembling PVC on the other side. A sample was analysed for asbestos and found that it contains chrysotile (white) asbestos.

~~

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOI/KK/KK 15 February 2010

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According to the site representatives, the heaters are in a good state of repair, therefore the asbestos in the heaters does not present a risk to human health and there is no need to remove it.

2.7 Removal of waste

Substantial quantities of waste were generated during the decommissioning phase that required off-site removal. This waste includes various paints, oils, adhesives, sealants, lubricants, chemicals, specialist aircraft maintenance equipment, electrical and mechanical tools, WEEE, office materials, etc. The site used Enva Ireland Ltd. (Enva) as the waste management contractor. Enva hold all required waste management licences.

The following specific points are noted with regard to the management of waste at SR Technics during the decommissioning process:

At the time of the closure audit, almost all wastes had been removed from Hangar 3 and adjacent offices and workshops.

All waste from Hangar 3 and adjacent offices and workshops was stored and removed together with other waste from the entire SR Technics site, therefore it is impracticable to determine exact quantities and types of waste removed from the part of the site that is subject of this report.

URS spot checked waste documentation generated during the decommissioning process for the entire SR Technics site. The documentation and record keeping was found to be satisfactory. Records included waste volumes/tonnages, the specific hazardous waste documentation i.e. C1 forms and TFS forms recording movement of waste and certificates of destruction and final destination. At the time of the site audit, some documents of final disposal had yet to be received from waste brokers.

It was observed that minor amounts of hazardous waste, were present at site during the site audit, namely two half-full 5-litre oil container and some scrap metal in front of the Kartcher workshop, some potentially contaminated hoses and scrap metal from the cleaning workshop. SR Technics representatives informed URS that all waste will be removed from the area as part of the final closure of Hangar 3.

2.8 Removal of Product and Raw Materials

SR Technics is a service company, so there was no final products on the site. The aircrafts that were serviced at the time of ceasing operations were sent to SR Technics’ sites in the UK and Germany.

Raw materials on site consisted of aircraft parts and paints, lubricants, sealants, thinners, oils, fuel, metal. All aircraft parts were sent to the other SR Technics sites and the remaining materials were mostly disposed of as waste.

At the time of the site audit the only remaining raw materials observed by URS in the workshops adjacent to Hangar 3 were:

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOl/KKKK 15 February2010

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one 200 litre drum of oil outside the Karcher workshop; and

two 200 litre drums partially filled with sand blasting material in the cleaning workshop.

URS advised the site representatives that oil containers, oil drum and scrap metal should be disposed of in environmentally sound manner, and the site representatives informed URS that these materials will be removed from the area as part of the final closure of Hangar 3.

2.9 Decommissioning of Site Utilities

During the site audit, URS observed that all utilities were connected:

Heating; and

Pressurised air.

Water; including drinking water, and water hoses required for aircraft servicing;

Electricity, including lights and electrical leads for powering aircraft;

This is due to the fact that DAA currently run limited operations on the site. There is no plan to decommission any of the site utilities as there is continuing activity on the site by DAA.

Summary of issues and recommended actions

The table bellow presents a summary of the issues identified during the site audit and recommended actions to address these issues.

2.1 0

Issue

Small amount of residual materials present on site: two 5-litre half-empty containers of machine oil were present in the Karcher workshop and one 200 litre drum of oil outside the Karcher workshop; some scrap metal outside the Karcher workshop;

two 200 litre drums partially filled with sand blasting material in the cleaning workshop.

Two bunds (for diesel and detergent tanks) filled with rain water.

~~~ ~

Bund and sump in the cleaning workshop were not yet cleaned and decontaminated.

~ ~~~

Small amount of potentially contaminated hosing and metal had yet to be removed from the cleaning workshop.

Recommended action

Disposal of all residual materials in environmentally sound manner.

Emptying the bunds.

Clean and decontaminate the bund and the sump.

Disposal of all potentially contaminated materials in environmentally sound manner.

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\DURPOOOI/KWKK 15 Februaly 2010

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URS IPPCL Surrender Support Hangar 3 Closure Audit - Validation Reoort

3.

During the site audit, URS informed SR Technics representatives of the issues listed in the table above and recommended that all actions listed in the table above be completed. SR Technics representatives agreed that these actions will be completed within one week of date of site survey.

URS does not consider any of the above issues to be significant.

CONCLUSION

Based on the site audit completed on 05Ih February 2010 and information subsequently provided to URS by Mr. Sean Lawlor, Hangar 3 and the adjacent offices and workshops appear to be adequately decommissioned according to the site’s Residuals Management Plan and the conditions of SR Technics’ IPPC Licence (PO480-02).

SR Technics Ireland Ltd-\49340717 SR Technics Hangar 3 IPPC\OURPOOOI/KWKK 15 February 2010

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URS IPPCL Surrender Support Hangar 3 Closure Audit - Validation ReDort

Appendix A = Figures


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16

SR TECHNICS

HANGAR 3 IPPC LICENCE SURRENDER

CIGURE 2 - HANGAR 3 AND ADJACENT OFFICES AND WORKSHOPS

I AREAS I I I GROUND FLOOR

I I I GENTS TOILET

I 2 I SHEETMETAL WORKSHOP

I 3 I SUB STORES

I 4 I CLEANING SHOP

I 5 I KARCHER PLANTROOM

I 6 I WANSON PLANTROOM

I 7 I PLANTROOM

B I OFFICES I 9 I FACILITIES WORKSHOP I

I LO I CYLINDER SHOP

I I1 I PAINT STORES

12 1 GENERATOR PLANTROOM I 13 I PAINT SHOP I

FINAL SANS

I E N V I R O N M E N T A L C O N S U L T A N T S

URS lveagh Court, 6-8 Harcourt Rood, Dublin2

TEL +353 1 4155100 FAX +353 1 4155101

49340717

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srtechnics - epa · 2013. 7. 26. · sr technics ireland limited md112, oshei engineering/...

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