ANNUAL ENVIRONMENTAL REPORT 2018 - KMK€¦ · KMK Tullamore Annual Environmental Report 2018 Filename: 190320 501.00323.00004 Rev0 KMK Tullamore AER 2018 SLR Ref No: 501.00323.00004

ANNUAL ENVIRONMENTAL

REPORT 2018

KMK Metals Recycling Ltd

Cappincur Industrial Estate

Daingean Road

Tullamore

Co. Offaly

Waste Licence No W0113 - 04

SLR Ref: 501.00323.00004

Version No: Rev0

March 2019

KMK Tullamore

Annual Environmental Report 2018

Filename: 190320 501.00323.00004 Rev0 KMK Tullamore AER 2018

SLR Ref No: 501.00323.00004

March 2019

BASIS OF REPORT

This document has been prepared by SLR Consulting Limited with reasonable skill, care and diligence, and taking account of the

manpower, timescales and resources devoted to it by agreement with KMK Metals Recycling Ltd (the Client) as part or all of the

services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any

purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party

have executed a reliance agreement or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied

by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information

set out in this report remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on

any elements which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole

document and any documents referenced explicitly herein and should then only be used within the context of the appointment.

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CONTENTS

REPORTING PERIOD ......................................................................................................... 1 1.0

EMISSIONS FROM THE FACILITY ....................................................................................... 1 2.0

2.1 Dust ........................................................................................................................................... 1

2.2 Stack Emission Point Monitoring .............................................................................................. 3

2.3 Noise ......................................................................................................................................... 4

2.4 Wastewater and Storm Water Emissions.................................................................................. 9

2.4.1 Interpretation of 2018 results ....................................................................................................................................... 18

2.5 Groundwater ........................................................................................................................... 20

2.6 Drinking water......................................................................................................................... 21

WASTE ACTIVITIES CARRIED OUT AT THE FACILITY .......................................................... 23 3.0

QUANTITY AND COMPOSITION OF WASTE RECOVERED, RECEIVED AND DISPOSED OF DURING 4.0

THE REPORTING PERIOD INCLUDING EWC CODES ........................................................... 24

WASTE MANAGEMENT RECORD .................................................................................... 24 5.0

5.1 Waste Received in 2018 .......................................................................................................... 24

5.2 Waste Despatched from the Facility for Recovery in 2018 ..................................................... 24

WASTE RECOVERY RECORD ............................................................................................ 25 6.0

RESOURCE CONSUMPTION SUMMARY ........................................................................... 26 7.0

REVIEW OF NUISANCE CONTROLS .................................................................................. 26 8.0

SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGETS AND ENVIRONMENTAL 9.0

MANAGEMENT PROGRAMME ....................................................................................... 27

POLLUTANT RELEASE AND TRANSFER REGISTER ............................................................. 29 10.0

NOISE MONITORING REPORT SUMMARY ....................................................................... 29 11.0

NOISE MONITORING REPORT SUMMARY ....................................................................... 29 12.0

TANK AND PIPELINE TESTING AND INSPECTION REPORT ................................................. 29 13.0

13.1 Bund Assessment ................................................................................................................... 29

13.2 Pipeline Inspections and Testing ............................................................................................ 29

REPORTED INCIDENTS SUMMARY .................................................................................. 30 14.0

COMPLAINTS SURVEY .................................................................................................... 34 15.0

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ENERGY EFFICIENCY AUDIT REPORT SUMMARY .............................................................. 34 16.0

VOLUME OF TRADE EFFLUENT/LEACHATE AND/OR CONTAMINATED STORMWATER PRODUCED 17.0

AND VOLUME TRANSPORTED OFF-SITE .......................................................................... 34

REPORT ON THE ASSESSMENT OF THE EFFICIENCY OF USE OF RAW MATERIALS IN PROCESSES 18.0

AND REDUCTION IN WASTE GENERATED ........................................................................ 35

REPORT ON PROGRESS MADE AND PROPOSALS BEING DEVELOPED TO MINIMISE WATER 19.0

DEMAND AND THE VOLUME OF TRADE EFFLUENT DISCHARGE ....................................... 35

DEVELOPMENT / INFRASTRUCTURAL WORKS SUMMARY (COMPLETED IN PREVIOUS YEAR OR 20.0

PREPARED FOR CURRENT YEAR) ..................................................................................... 35

REPORT ON THE FINANCIAL PROVISION MADE UNDER THIS LICENCE, MANAGEMENT AND 21.0

STAFFING STRUCTURE OF THE FACILITY, AND A PROGRAMME FOR PUBLIC INFORMATION35

21.1 Programme for Public Information ......................................................................................... 36

21.2 Staffing Structure ................................................................................................................... 37

REVIEW OF DECOMMISSIONING PLAN ........................................................................... 37 22.0

ENVIRONMENTAL LIABILITIES RISK ASSESSMENT ............................................................ 38 23.0

DEVELOPMENT WORKS ................................................................................................. 38 24.0

24.1 Development Works in 2018 .................................................................................................. 38

OTHER ITEMS ................................................................................................................ 38 25.0

DOCUMENT REFERENCES

TABLES

Table 2-1 Dust monitoring licence requirements................................................................................. 1

Table 2-2 Licence Requirements for Stack Monitoring ........................................................................ 3

Table 2-3 Stack Monitoring 2018 ......................................................................................................... 3

Table 2-4 Summary of Noise Monitoring Licence Requirements ......................................................... 4

Table 2-5 Summary of Noise Monitoring Results ................................................................................. 6

Table 2-6 Attenuation of Noise over Distance for point source emissions e.g. industrial sources ..... 8

Table 2-7 Wastewater monitoring licence requirements .................................................................... 9

Table 2-8 Storm water monitoring licence requirements .................................................................... 9

Table 2-9 Wastewater and storm water monitoring dates ................................................................ 10

Table 2-10 Groundwater monitoring licence requirements .............................................................. 20

Table 2-11 Groundwater quality results 2018 ................................................................................... 20

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Table 2-12 Drinking water monitoring licence requirements ............................................................ 21

Table 2-13 Drinking Water (DW1 and DW2) Results – 17th

December 2018 ..................................... 22

Table 5-1 Summary of waste received 2018 ...................................................................................... 24

Table 7-1 Breakdown of Energy Consumption for the Year ............................................................... 26

Table 9-1 Environmental Objectives and Targets 2018 ..................................................................... 27

Table 14-1 Incidents Report Table during 2018 ................................................................................. 31

FIGURES

Figure 2-1 Dust Deposition results ....................................................................................................... 2

Figure 2-2 Annual Noise Monitoring Locations 2018 ........................................................................... 5

Figure 21-1 KMK Metals Recycling Ltd Organisational Chart ............................................................. 37

APPENDICES

Appendix 01: Annual Noise Monitoring Report 2018 ........................................................................ 38

Appendix 02: Waste Received in 2018 ............................................................................................... 39

Appendix 03: Mitigation Measures .................................................................................................... 41

Appendix 04: Environmental Occurrences Register……………………………………………………………………44

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Reporting Period 1.0

The reporting period for this Annual Environmental Report is 1st January 2018 to 31st of December 2018.

Emissions from the Facility 2.0

A summary and interpretation of all emissions monitoring carried out at the facility during 2018 is discussed in

detail below:

2.12.12.12.1 DustDustDustDust The full Ambient Dust Monitoring Reports were submitted separately to the EPA. A summary of the reports is

provided below.

Dust deposition monitoring was carried out at the site from the 6th

September 2018 to the 5th

October 2018 by

Q.E.D. Engineering Ltd, in accordance with Waste Licence Requirements (Table 2-1).

Table 2-1

Dust monitoring licence requirements

Location Parameter (mg/m2/d) Monitoring frequency Analysis method/ technique

A2-1, A2-2,

A2-3, A2-4

Total Dust Deposition

Metal content Note3

AnnuallyNote1

AnnuallyNote4

Bergerhoff GaugeNote2

Standard method

Note 1: During the period May to September, or otherwise specified in writing by the Agency.

Note 2: Standard VDI 2119 (Measurement of dustfall, Determination of dustfall using Bergerhoff Instrument (Standard Method) German Engineering Institute). Any

modifications to eliminate interference due to algae growth in the gauge should be reported to the Agency.

Note 3: Analysis to include the following metals: Al, As, Cd, Cr, Cu, Fe, Hg, Ni, Pb and Zn.

Note 4: Biannually in the first twelve months following grant of licence.

Weather conditions can have a notable impact upon dust creation and entrainment in the air and these have to

be taken into account when assessing dust monitoring results.

The summary of dust deposition results are presented in Figure 2-1, below. Figure 2-1 shows the location of

each of the stations and total dust deposition results.

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Figure 2-1

Dust deposition results

Total Dust Deposition levels at monitoring location A2-1 were above the EPA limit value of 350 mg/m3/day.

Dust monitoring location A2-1, which is situated in the E yard area on the northern boundary adjacent to the

car park sees a significant amount of traffic, skip drop offs and the transporting of WEEE components to

storage areas.

In addition to the existing regime of sweeping up and controlling visible debris, increased dampening during

dry weather shall ensure that the ambient dusts at this location improve to within licence limits. Site

management will monitor weather conditions and adjust the dust mitigation procedures in place in line with

forecasted weather events. Mobile sweeper options are also being investigated to assist with dust removal. It

is important to note that due to the nature of dust deposition, dust generation from neighbouring sites in the

industrial estate may be accounted for in these results. There are no dwellings or other sensitive locations in

the immediate vicinity of the site, therefore dust generation and deposition from the KMK Metals Recycling

Site should not be problematic or cause nuisance to any sensitive locations.

All other dust monitoring locations at KMK Metals Recycling Ltd. were below the EPA limit value for total dust

deposition of 350 mg/m3/day.

In addition to Total Dust Deposition, metals are also analysed during this dust monitoring event.

There are no Emission Limit Values specified for the metals content in the licence. Trigger limit values have

been developed using ambient dust analysis data from 2015 to 2017. The trigger warning value set for

Cadmium was breached at A2-1. Trigger action values set for Cadmium, Chromium, Copper and Lead were

breached at A2-3 and trigger action values set for Chromium, Copper and Arsenic were breached at A2-4. No

trigger limit values were breached at A2-2. However, these monitoring locations were below the EPA limit

value of 350 mg/m3/day.

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2.22.22.22.2 Stack Emission Point MonitoringStack Emission Point MonitoringStack Emission Point MonitoringStack Emission Point Monitoring The Waste Licence requirements for stack emission monitoring are presented in Table 2 below.

Table 2-2

Licence Requirements for Stack Monitoring

Location Parameter Monitoring frequency Analysis method/ technique

A2-5 Total particulates and metals including

Al, As, Cd, Cr, Cu, Fe, Hg, Ni, Pb and Zn

Quarterly Standard method

Monitoring of A2-5 was performed over four separate monitoring events during 2018: Q1, Q2, Q3 and Q4.

The plant was in use during monitoring, and the samples were taken as discharged from the emission stack

after treatment by the bag house filter unit.

The individual monitoring reports were submitted separately to the EPA. A summary of the reports is provided

below (Table 2-3) in terms of dates and total particulate results obtained.

Table 2-3

Stack Monitoring 2018

Date Company Ref Result (mg/m3) Limit Value (mg/m

3)

08/02/2018 Glenside

Environmental

Q1 0.4 10

17/05/2018 Q2

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2.32.32.32.3 NoiseNoiseNoiseNoise The waste licence (W0113-04) requirements for the noise monitoring programme is referred to in Condition

6.11 and are presented in Table 2-4.

Table 2-4

Summary of Noise Monitoring Licence Requirements

Stations and Grid Ref Parameter Monitoring

frequency

Analysis method/ technique

NE001: 635847 725118

NE002: 635959 725004

NE003: 635870 724963

NE004: 635772 725046

L(A)eq [30 minutes],

L(A)10 [30 minutes],

L(A)90 [30 minutes] and

1/3 Octave Band Analysis

Annually Standard Method Note1

Note 1: International Standards Organisation, ISO 1996 Acoustics – Description and Measurement of Environmental Noise. Parts 1,2 & 3.

Furthermore it is stated ‘The survey programme shall be undertaken in accordance with the methodology

specified in the ‘Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to

Scheduled Activities (NG4)’ as published by the Agency.’

Condition 6.11.2 states: ‘The licensee shall implement any noise attenuation measures as required by the

Agency, having regard to the principles of BAT, to ensure compliance with the noise limits specified in this

licence.’

Schedule B3 Noise Emissions tabulates the following

Daytime dB LAr,T

note2

(30minutes)

Evening time dB LAr,T

note2

(30minutes)

Night-time dB dB LAr,T

note2

(15-30minutes)

55 50 45

Note 1: there shall be no clearly audible tonal component or impulsive component in the noise emission from the activity at any noise-sensitive location.

Note 2: LAr,T is defined as the Related Noise Level, equal to the L(A)eq during a specified time interval (T), plus specified adjustments for tonal character and/or impulsiveness

of the sound.

Hence the following parameters were measured and reported: L(A)eq[30 minute], L(A)10[30 minute],

L(A)90[30 minute] and 1/3 Octave Band analysis.

To ensure that all monitoring positions could be adequately monitored, and based upon normal best practice

for noise measurements, as issued by the EPA, the night time measurement was a 15 minute period at each

location.

The monitoring locations were thus as follows:

• NE001: Car park at fence boundary – northern boundary

• NE002: Eastern boundary, inside C yard

• NE003: Rear of the facility buildings – Southern boundary

• NE004: Adjacent the working yard area – Western boundary

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Noise level monitoring was undertaken on the 5th

and 6th

August 2018. Daytime noise monitoring took place

between 10:45 – 14:00, evening monitoring took place between 20:35 – 21:30 and night time monitoring took

place on between 01:45 – 02:50. Each monitoring location is identified on the map shown in Figure 2-2 below.

Weather conditions during daytime monitoring were calm, cool and sunny with scattered rain showers.

Figure 2-2: Noise Monitoring Locations 2018

The summary of the noise measurement results is included in the noise monitoring survey (Appendix 01).

These are summarised and compared to the licence limits below in Table 2-5.

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Table 2-5

Summary of Noise Monitoring Results

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Noise sources from the facility, audible at the site boundaries have been identified as:

• Vehicles entering/leaving the site

• Unloading and loading of trucks with waste materials and processed materials using fork lift trucks,

JCB etc

• Tipping of WEEE under cover in the Hanger building

• Reversing alarms from forklift trucks

• WEEE processing operations within buildings.

• Personnel entering/leaving buildings, car park area

NE001 located on the northern boundary had an average LAeq reading of 58dBA during the day. The difference

of 11dBA between the average LA10 reading of 59dBA and the average LA90 reading of 48dBA indicates the

presence of intermittent noise at this location, caused by on-site and off-site traffic and the handling of WEEE

on-site.

This location had an average LAeq reading of 56dBA during the evening. The difference of 10dBA between the

average LA10 reading of 57dBA and the average LA90 reading of 47dBA indicates the presence of intermittent

noise at this location, caused by vehicle movement in E yard and by road traffic noise from the by-pass and the

main Ballinagar road.

This location had an average LAeq reading of 39dBA during the night. The difference of 9dBA between the


noise at this location, caused by road traffic noise from the by-pass and the main Ballinagar road.

No impulsive or tonal noise from the factory was audible at this location.

NE002 located at the eastern boundary of the site had an average LAeq reading of 64dBA during the day. The

difference of 14dBA between the average LA10 reading of 69dBA and the average LA90 reading of 55dBA

indicates the presence of intermittent noise at this location, caused by the movement of material by forklift 5

metres from this monitoring location, radio music and from general WEEE handling and dismantling.



noise at this location, again caused by a forklift moving material and from WEEE handling inside D-Hanger.



noise at this location, caused by road traffic noise from the by-pass and the main Ballinagar road.


NE003 located at the southern boundary behind the D-Hanger building had an average LAeq reading of 77dBA

during the day. The difference of 3dBA between the average LA10 reading of 78dBA and the average LA90

reading of 75dBA indicates the presence of some intermittent noise at this location, caused by the processing

and handling of WEEE in DHanger and from road traffic on the by-pass.



noise at this location, again caused by road traffic on the by-pass.


average LA10 reading of 51dBA and the average LA90 reading of 34dBA indicates the presence of a lot of

intermittent noise at this location, caused by road traffic noise from the by-pass.

Tonal noise in the high frequency band was detected from an extraction unit near this location during day and

evening time surveys.

No impulsive noise was audible at this location.

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NE004 located on the western boundary of the site had an average LAeq reading of 67dBA during the day. The

difference of 10dBA between the average LA10 reading of 69dBA and the average LA90 reading of 59dBA

indicates a lot of intermittent noise at this location, caused by the processing and handling of WEEE in D-

Hanger, and road traffic noise from the by-pass and the main Ballinagar road.


average LA10 reading of 53dBA and the average LA90 reading of 51dBA indicates consistent noise levels at this

location, caused by on site activities and road traffic on the by-pass.


average LA10 reading of 51dBA and the average LA90 reading of 34dBA indicates the presence of a lot of

intermittent noise at this location, caused by a church bell ringing and road traffic noise from the by-pass and

the main Ballinagar road.


In general, the exceedances at boundary locations are not likely to be experienced at any noise sensitive

location near the site due to noise dissipation over increasing distances and mitigation as a result of buildings

acting as noise reduction barriers (the closest dwelling house to the facility is located 200m from the northern

boundary of the site). For point sources it is known that a doubling of the distance away from the source

results in a 6 dBA fall in noise level. An example of this is shown in the following table:

Table 2-6

Attenuation of Noise over Distance for point source emissions e.g. industrial sources

The 1/3 Octave Noise Readings taken at Boundary Noise Locations and subjective determinations made on the

site during monitoring show that there was tonal noise at NE003 during the day and evening time survey due

to high frequency noise being emitted from an extraction unit in operation near the location. This location is on

the southern boundary of the site which is furthest from the nearest dwelling house, 200m from the northern

boundary. There was no tonal noise detected at NE0001 on the northern boundary of the site during day or

evening time surveys. Consequently, tonal noise from NE003 is not likely to be experienced at any noise

sensitive location near the site.

There was no impulsive noise from the factory audible at the boundary noise locations.

In conclusion:

• Annual environmental noise monitoring occurred at KMK on 5th

and 6th

August 2018.

• The level of noise at the site boundary of the facility is relatively high during day and evening times,

with all noise readings at boundary noise locations exceeded the licence requirements for daytime

and evening time noise levels.

• Night-time noise readings at boundary noise locations NE001 and NE002 were below the licence

requirements.

• Night time boundary noise locations NE003 and NE004 were above the license requirements

because of traffic noise from the by-pass and a church bell ringing. No site noise was audible.

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• The exceedances at boundary locations are not likely to be experienced at any noise sensitive

location near the site due to noise dissipation over increasing distances and mitigation as a result

of buildings acting as noise reduction barriers.

• Tonal noise was measured at NE003 during the daytime and evening time survey. The tonal noise

is not likely to be experienced at any noise sensitive location near the site.

2.42.42.42.4 WastewaterWastewaterWastewaterWastewater and and and and SSSStorm torm torm torm WWWWaterateraterater EEEEmissionsmissionsmissionsmissions The requirements for the sanitary effluent water discharge monitoring are as follows:

Table 2-7

Wastewater monitoring licence requirements


F Flow Continuous On-line flow meter with

recorder

F BOD, suspended solids, total dissolved

solids, nitrates (as N), ammonia (as N),

total phosphorous (as P), chloride, iron,

pH

Quarterly* Standard methods

* monthly samples were taken when parameters were elevated

Similarly, the waste licence requirements for storm water monitoring are as follows:

Table 2-8

Storm water monitoring licence requirements


DX

E

Visual inspection Daily Examine for colour and

odour

DX

E

pH, COD, ammonia (as N), conductivity,

total suspended solids, mineral oils,

metals (Al, As, Cr, Cu, Fe, Hg, Ni, Pb, Zn)

Quarterly* Standard methods

* monthly samples were taken when parameters were elevated

The sampling dates are shown in Table 2-9 below, the locations are marked ‘yes’ if a sample was taken. All

samples were tested at ALS Life Sciences Ltd.

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Table 2-9

Wastewater and storm water monitoring dates

Date F DX E

26/01/18 Yes No No

28/02/18 Yes No No

26/03/18 No Yes Yes

25/04/18 Yes Yes Yes

24/05/18 May sample taken on 31/05/18 Yes Yes

28/06/18 Yes No No

31/07/18 No Yes Yes

22/08/18 No Yes Yes


31/10/18 October sample taken on 10/10/18 Yes Yes


11/12/18 No Yes Yes

The laboratory results from 2014 to December 2018 are shown in the tables below.

Suspended

Solids (mg/L)

Total

Dissolved

Solids (mg/L)

Nitrates (as N)

(mg/L)pH (pH units)

Ortho P as P

(mg/L)Iron (mg/L)

Chloride

(mg/L)

Year Quarter Sampling Date Result Licence Limit Result Result Result Result Licence Limit Result Licence Limit Result Result Result Result

2014 - Q1 31/03/2014 2 5 6 2180 105.77 1.27 1 5.075 1

2014 - Q2 29/05/2014 1 5 2.5 3110 378 4.28 1 6.5 1

2014 - Q3 25/09/2014 1 5 5 1020 57.7 0.379 1 2.6 1

2014 - Q4 19/11/2014 2 5 5 845 82.59 1.7 1 2.7 1

2015 - Q1 16/02/2015 2.32 5 45.5 1060 76.7 2.34 1 0.847 1 7.51

2015 - Q2 03/04/2015 1 5 2.5 2270 69.2 1.24 1 1.36 1 7.67

2015 - Q3 10/11/2015 1 5 2 601 38.7 0.0446 1 2.02 1 7.84 1.84

2015 - Q4 25/11/2015 1 5 2 2870 69.4 0.046 1 1.59 1 7.79 1.41

2016 - Q1 (1) 27/01/2016 1 5 2 1890 71.9 2.02 1 0.939 1 7.43 0.866

2016 - Q1 (2) 27/02/2016 1 5 2 949 74.4 0.0171 1 1.49 1 7.8

2016 - Q2 10/05/2016 1 5 6 1480 85.5 1.02 1 1.85 1 7.49

2016 - Q3 08/09/2016 1 5 2 1670 45 0.0341 1 1.74 1 7.71

2016 - Q4 23/11/2016 1 5 2 2350 74.5 0.116 1 3.5 1 7.72

2017 - Q1 08/03/2017 1 5 2 649 54.7 0.0889 1 0.918 1 7.62

2017 - Q2 28/06/2017 1 5 2 625 54.4 0.0435 1 0.791 1 8.03

2017 - Q3 04/09/2017 1 5 2 2460 78.2 0.081 1 1.38 1 7.81

2017 - Q4 07/12/2017 1 5 6.35 577 171 4.84 1 0.965 1 7.34 0.162 7.34

2018 - January 26/01/2018 1.67 5 5.9 459 106 0.724 1 0.758 1 7.46 0.019 7.46

2018 - February 28/02/2018 2.56 5 19.5 844 315 0.979 1 0.201 1 7.53 0.0201 137

2018 - April 25/04/2018 1 5 11.9 576 25.9 2.07 1 0.112 1 7.39 0.0786 78.1

2018 - May 31/05/2018 2.09 5 16.7 846 25.9 0.0477 1 0.18 1 7.39 0.019 125

2018 - June 28/06/2018 1 5 11.2 852 376 0.0436 1 0.06 1 6.99 0.0249 137

2018 - Q3 10/10/2018 1 5 2 776 376 0.0465 1 4.58 1 7.53 0.019 89.1

2018- Q4 30/11/2018 1 5 15.8 739 78 0.163 1 2.31 1 5.68

Ammonia (as N) (mg/L)Total Phosphorus (as P)

(mg/L)

2016

2015

2014

Biochemical Oxygen

Demand (mg/L)

BOLD BLACK text indicates an exceedence of a licence limit applicable at the time

An underline indicates that a "

Sampling Period Sampling Date Result Licence Limit Result Warning Value Action Value ResultWarning Value

Lower

Warning Value

Upper

Action Value

Lower

Action Value

UpperResult Warning Value Action Value

SW EQS

Values 2009Result Warning Value Action Value

2015 - Q3 10/11/2015 20 35 0.619 1.405 1.731 8.71 1.24 3.05 4.763 0.065 60.1 130 155

2015 - Q4 07/12/2015 43.5 35 0.395 1.405 1.731 7.95 0.112 3.05 4.763 0.065 39.1 130 155

2016 - Q1 10/02/2016 10.5 35 0.184 0.985 1.238 7.94 0.159 2.33 3.06 0.065 19.4 61.9 80.1

2016 - Q2 30/06/2016 2 35 0.199 0.985 1.238 7.01 0.295 2.33 3.06 0.065 19.6 61.9 80.1

2016 - Q3 03/10/2016 11 35 0.509 0.985 1.238 7.71 1.9 2.33 3.06 0.065 50 61.9 80.1

2016 - Q4 23/11/2016 2 35 0.551 0.985 1.238 8.1 1.24 2.33 3.06 0.065 32.2 61.9 80.1

2017 - Q1 08/03/2017 4.1 35 0.163 0.985 1.238 7.32 0.278 2.33 3.06 0.065 17.1 61.9 80.1

2017 - Q2 26/04/2017 6.9 35 0.391 0.985 1.238 7.38 1.01 2.33 3.06 0.065 37.2 61.9 80.1

2017 - Q3 04/09/2017 9.95 35 0.652 0.985 1.238 7.76 0.961 2.33 3.06 0.065 55.6 61.9 80.1

2017 - Q4 07/12/2017 48.2 35 0.817 0.709 0.876 7.68 0.886 2.01 2.63 0.065 89.3 63.34 77.84

2018 - Q1 26/03/2018 20.2 35 0.455 0.709 0.876 8.04 2.01 2.63 0.065 38.1 63.34 77.84

2018 - April 25/04/2018 112 35 0.709 0.771 0.961 7.29 0.101 1.603 2.071 0.065 293 66.42 82.585

2018 - May 24/05/2018 72.7 35 0.523 0.771 0.961 7.93 0.128 1.603 2.071 0.065 53.2 66.42 82.585

2018 - July 31/07/2018 64.7 35 0.457 0.771 0.961 7.69 0.365 1.603 2.071 0.065 90.8 66.42 82.585

2018 - August 22/08/2018 22.7 35 0.807 0.771 0.961 7.44 3.46 1.603 2.071 0.065 97.6 66.42 82.585

2018 - September 28/09/2018 125 35 0.381 0.771 0.961 7.72 0.092 1.603 2.071 0.065 35.7 66.42 82.585

2018 - October 31/10/2018 148 35 0.889 0.771 0.961 7.48 0.821 1.603 2.071 0.065 141 66.42 82.585

2018 - November 30/11/2018 48.2 35 0.399 0.904 1.112 7.74 6.96 8.51 6.57 8.9 0.147 1.179 1.547 0.065 48.1 66.206 79.87

2018 - December 11/12/2018 76.1 35 0.47 0.904 1.112 7.56 6.96 8.51 6.57 8.9 0.244 1.179 1.547 0.065 82.1 66.206 79.87

Storm Water (DX) Sampling

HIGHLIGHTED text indicates newly proposed Trigger Level Values (November 2018)

indicates an additional exceedance of the SW EQS Values 2009


Result Warning Value Action Value Result Warning Value Action ValueSW EQS


SW EQS


SW EQS Values

2009Result Warning Value Action Value

SW EQS Values

2009

0.143 0.562 1.043 1.83 1.9 3 25 31.5 270 431 100 1.33 10.00 17.00 32 15.6 26.00 42.00 20

0.0404 0.562 1.043 0.879 1.9 3 25 115 270 431 100 1.79 10.00 17.00 32 6.07 26.00 42.00 20

0.0778 0.562 1.043 0.12 1.9 3 25 105 270 431 100 0.859 10.00 17.00 32 2.98 26.00 42.00 20

0.144 0.562 1.043 0.28 1.9 3 25 116 270 431 100 1.15 10.00 17.00 32 8.51 26.00 42.00 20

0.379 0.562 1.043 0.837 1.9 3 25 25.1 270 431 100 1.37 10.00 17.00 32 11 26.00 42.00 20

0.322 0.562 1.043 0.779 1.9 3 25 35.7 270 431 100 1.2 10.00 17.00 32 8.54 26.00 42.00 20

0.0393 0.562 1.043 1.13 1.9 3 25 236 270 431 100 1.2 10.00 17.00 32 6.03 26.00 42.00 20

0.605 0.562 1.043 0.766 1.9 3 25 6.82 270 431 100 1.2 10.00 17.00 32 10 26.00 42.00 20

0.194 0.562 1.043 1.06 1.9 3 25 5.61 270 431 100 1 10.00 17.00 32 8.22 26.00 42.00 20

0.0327 0.593 0.781 1.92 1.8 2.3 25 10.1 225 296 100 1 1.80 2.00 32 13.6 15.70 19.30 20

0.019 0.593 0.781 1.08 1.8 2.3 25 97 225 296 100 1.87 1.80 2.00 32 8.87 15.70 19.30 20

0.0972 0.451 0.596 0.912 2.343 2.954 25 138 84.822 109.819 100 1 2.77 3.50 32 12.4 16.02 19.93 20

0.0823 0.451 0.596 0.7 2.343 2.954 25 478 84.822 109.819 100 1.22 2.77 3.50 32 14 16.02 19.93 20

0.0737 0.451 0.596 0.854 2.343 2.954 25 36.7 84.822 109.819 100 1 2.77 3.50 32 11.4 16.02 19.93 20

0.519 0.451 0.596 1.06 2.343 2.954 25 10.7 84.822 109.819 100 1 2.77 3.50 32 12 16.02 19.93 20

0.261 0.451 0.596 1.38 2.343 2.954 25 56 84.822 109.819 100 1 2.77 3.50 32 7.39 16.02 19.93 20

0.636 0.451 0.596 1.01 2.343 2.954 25 55.7 84.822 109.819 100 1 2.77 3.50 32 20.9 16.02 19.93 20

0.0289 0.484 0.644 0.685 1.871 2.326 25 64.4 74.794 96.029 100 4.33 1.769 2.047 32 4.92 16.129 19.589 20

0.0988 0.484 0.644 0.561 1.871 2.326 25 54.2 74.794 96.029 100 35.3 1.769 2.047 32 8.73 16.129 19.589 20

Iron (mg/L) Chromium (µg/L)Zinc (µg/L)Arsenic (µg/L) Nickel (µg/L)

Result Warning Value Action Value Result Warning Value Action ValueSW EQS


SW EQS Values


SW EQS Values

2009Result Licence Limit

190 208 304 10.7 18.6 25.8 5 17.8 47 209 7.2 0.01 0.33 0.5 0.07 1 2

35.8 208 304 10.4 18.6 25.8 5 4.73 47 209 7.2 0.01 0.33 0.5 0.07 1 2

29.3 208 304 8.17 30 39 5 18 11.8 15.6 7.2 0.0436 0.0615 0.0796 0.07 1 2

21.3 208 304 1.36 30 39 5 4.39 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

22.6 208 304 0.85 30 39 5 2.96 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

32 208 304 2.68 30 39 5 4.89 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

9.76 208 304 5.03 30 39 5 6.27 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

18.3 208 304 0.85 30 39 5 0.946 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

69.8 208 304 2.84 30 39 5 2.75 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

25.9 155.66 211.05 2.1 12.9 16.9 5 1.07 19.9 26 7.2 0.01 0.036 0.048 0.07 1 2

48.3 155.66 211.05 8.07 12.9 16.9 5 2.45 19.9 26 7.2 0.01 0.036 0.048 0.07 1 2

65.5 180.511 236.628 11.8 22.405 29.646 5 7.15 8.7 11.2 7.2 0.01 0.09 0.125 0.07 5 2

41.2 180.511 236.628 26.4 22.405 29.646 5 7.97 8.7 11.2 7.2 0.01 0.09 0.125 0.07 5.31 2

70.3 180.511 236.628 4.12 22.405 29.646 5 14.9 8.7 11.2 7.2 0.01 0.09 0.125 0.07 1.65 2

79.8 180.511 236.628 1.84 22.405 29.646 5 1.23 8.7 11.2 7.2 0.01 0.09 0.125 0.07 3.13 2

68 180.511 236.628 7.75 22.405 29.646 5 12.4 8.7 11.2 7.2 0.01 0.09 0.125 0.07 1 2

21.5 180.511 236.628 5.55 22.405 29.646 5 9.79 8.7 11.2 7.2 0.025 0.09 0.125 0.07 5 2

111 138.529 182.472 17.8 10.873 14.253 5 5.06 5.463 6.817 7.2 0.0133 0.031 0.039 0.07 1 2

126 138.529 182.472 11.3 10.873 14.253 5 6.37 5.463 6.817 7.2 0.01 0.031 0.039 0.07 1.31 2

Mineral Oil (mg/L)Aluminium (µg/L) Copper (µg/L) Mercury (µg/L)Lead (µg/L)

Sampling Period Sampling Date Result Licence Limit Result Warning Value Action Value ResultWarning Value

Lower

Warning Value

Upper

Action Value

Lower

Action Value

UpperResult Warning Value Action Value

SW EQS Values


2014 - Q1 31/03/2014 8 35 0.146 8.4 0.473 0.065 11

2014 - Q2 29/05/2014 3.5 35 0.246 8.88 0.988 0.065 32.4

2014 - Q3 25/09/2014 6 35 0.124 7.8 0.337 0.065 19

2014 - Q4 19/11/2014 5 35 0.263 9.2 0.97 0.065 22

2015 - Q1 16/02/2015 2 35 0.266 7.72 0.471 0.065 21.2

2015 - Q2 03/06/2015 2 35 0.184 1.405 1.731 8.8 0.373 3.05 4.763 0.065 20.9 130 155

2015 - Q3 10/11/2015 11.5 35 0.352 1.405 1.731 7.54 0.936 3.05 4.763 0.065 64.6 130 155

2015 - Q4 07/12/2015 112 35 0.12 1.405 1.731 8.17 0.216 3.05 4.763 0.065 78.5 130 155

2016 - Q1 (1) 10/02/2016 9 35 0.393 0.985 1.238 7.98 0.698 2.33 3.06 0.065 34.8 61.9 80.1

2016 - Q1 (2) 24/02/2016 10 35 0.363 0.985 1.238 8.43 1.01 2.33 3.06 0.065 29.7 61.9 80.1

2016 - Q2 (1) 30/06/2016 4.5 35 1.13 0.985 1.238 8.62 56.2 2.33 3.06 0.065 34.9 61.9 80.1

2016 - Q2 (2) 15/08/2016 35 0.985 1.238 0.025 2.33 3.06 0.065 61.9 80.1

2016 - Q3 03/10/2016 3.5 35 0.37 0.985 1.238 8.62 1.12 2.33 3.06 0.065 25.9 61.9 80.1

2016 - Q4 (1) 23/11/2016 11 35 0.575 0.985 1.238 8.13 2.23 2.33 3.06 0.065 66.8 61.9 80.1

2016 - Q4 (2) 09/12/2016 35 0.985 1.238 2.33 3.06 0.065 61.9 80.1

2017 - Q1 08/03/2017 7.45 35 0.336 0.985 1.238 8 0.93 2.33 3.06 0.065 31.6 61.9 80.1

2017 - Q2 26/04/2017 5.15 35 0.358 0.985 1.238 7.72 1.08 2.33 3.06 0.065 48.7 61.9 80.1

2017 - Q3 04/09/2017 3.35 35 0.749 0.985 1.238 7.91 0.213 2.33 3.06 0.065 32.6 61.9 80.1

2017 - Q4 07/12/2017 16.4 35 0.567 0.827 1.067 7.41 1.06 1.814 2.326 0.065 30.7 69.64 87.49

2018 - Q1 26/03/2018 8.8 35 0.584 0.827 1.067 8.07 1.814 2.326 0.065 13.6 69.64 87.49

2018 - April 25/04/2018 21 35 0.651 0.771 0.961 7.4 1.32 1.603 2.071 0.065 30.3 66.42 82.585

2018 - May 24/05/2018 5.75 35 0.219 0.771 0.961 7.96 0.241 1.603 2.071 0.065 25.9 66.42 82.585

2018 - July 31/07/2018 2.75 35 0.185 0.771 0.961 7.67 0.305 1.603 2.071 0.065 22.7 66.42 82.585

2018 - August 22/08/2018 3.05 35 0.165 0.771 0.961 7.4 0.307 1.603 2.071 0.065 28.9 66.42 82.585

2018 - September 12/10/2018 6.3 35 0.424 0.771 0.961 8.32 1.87 1.603 2.071 0.065 19.7 66.42 82.585

2018- October 31/10/2018 3.65 35 0.239 0.771 0.961 7.47 0.74 1.603 2.071 0.065 24.4 66.42 82.585

2018 - November 30/11/2018 13 35 0.454 0.855 1.084 7.51 7.10 9.08 6.61 9.57 0.646 1.836 2.349 0.065 29.5 65.687 82.254

2018 - December 11/12/2018 7.5 35 0.402 0.855 1.084 7.36 7.10 9.08 6.61 9.57 0.748 1.836 2.349 0.065 24.9 65.687 82.254

Ammonia (as N) (mg/L) Chemical Oxygen Demand (mg/L)


Result Warning Value Action Value Result Warning Value Action ValueSW EQS Values


SW EQS Values


SW EQS Values


SW EQS Values

2009

0.1195 0.731 25 21.88 100 0.68 32 2.299 20

0.253 2.6 25 86.6 100 2.1 32 7.03 20

0.11 0.6 25 187.5 100 1 32 3.6 20

0.67 3.1 25 250 100 1 32 11 20

0.0379 0.555 25 37.8 100 0.506 32 5.89 20

0.107 0.562 1.043 1.6 1.9 3 25 11.1 270 431 100 0.913 10 17 32 2.79 26 42 20

0.225 0.562 1.043 1.23 1.9 3 25 202 270 431 100 1.84 10 17 32 13.5 26 42 20

0.0765 0.562 1.043 0.262 1.9 3 25 45.9 270 431 100 0.883 10 17 32 3.57 26 42 20

0.157 0.562 1.043 0.904 1.9 3 25 431 270 431 100 1.3 10 17 32 13.6 26 42 20

0.325 0.562 1.043 2.26 1.9 3 25 123 270 431 100 4.72 10 17 32 9.15 26 42 20

0.0339 0.562 1.043 0.989 1.9 3 25 562 270 431 100 0.879 10 17 32 45.6 26 42 20

0.562 1.043 1.9 3 25 41.9 270 431 100 10 17 32 26 42 20

0.0584 0.562 1.043 1.83 1.9 3 25 47.5 270 431 100 1.2 10 17 32 6.32 26 42 20

0.278 0.562 1.043 1.64 1.9 3 25 117 270 431 100 1.2 10 17 32 16 26 42 20

0.562 1.043 1.9 3 25 270 431 100 10 17 32 26 42 20

0.103 0.562 1.043 1.73 1.9 3 25 177 270 431 100 1.2 10 17 32 10.3 26 42 20

0.0465 0.562 1.043 1.2 1.9 3 25 42.6 270 431 100 1.2 10 17 32 10.6 26 42 20

0.247 0.562 1.043 2.24 1.9 3 25 10.7 270 431 100 1 10 17 32 5.71 26 42 20

3.69 0.493 0.653 19.5 2.89 3.66 25 52.3 248.42 322.92 100 1 3.33 4.3 32 6.1 16.78 21.04 20

0.019 0.493 0.653 5.89 2.89 3.66 25 16.8 248.42 322.92 100 1 3.33 4.3 32 2.6 16.78 21.04 20

8.41 0.451 0.596 22.4 2.343 2.954 25 13.8 84.822 109.819 100 1 2.765 3.499 32 3.69 16.016 19.925 20

0.288 0.451 0.596 1.89 2.343 2.954 25 114 84.822 109.819 100 1 2.765 3.499 32 4.11 16.016 19.925 20

0.188 0.451 0.596 1.86 2.343 2.954 25 38 84.822 109.819 100 1 2.765 3.499 32 3.79 16.016 19.925 20

0.118 0.451 0.596 1.63 2.343 2.954 25 47.6 84.822 109.819 100 1 2.765 3.499 32 3.23 16.016 19.925 20

3.24 0.451 0.596 16.6 2.343 2.954 25 85.6 84.822 109.819 100 1 2.765 3.499 32 3.74 16.016 19.925 20

0.208 0.451 0.596 1.64 2.343 2.954 25 97 84.822 109.819 100 1 2.765 3.499 32 4 16.016 19.925 20

5.87 0.476 0.626 18.8 2.981 3.721 25 52 78.877 99.821 100 1 2.86 3.668 32 3.41 14.735 18.716 20

5.39 0.476 0.626 16.2 2.981 3.721 25 111 78.877 99.821 100 1 2.86 3.668 32 5.26 14.735 18.716 20

Arsenic (µg/L)Iron (mg/L) Zinc (µg/L) Nickel (µg/L)Chromium (µg/L)

Result Warning Value Action Value Result Warning Value Action ValueSW EQS Values


SW EQS Values


SW EQS Values

2009Result Licence Limit

110.6 5 3.881 7.2 0.2 0.07 0.06526 2

210 5 9.52 7.2 0.0245 0.07 1 2

78.8 13 5 16.4 7.2 0.02 0.07 0.482 2

200 8 5 12.7 7.2 0.02 0.07 0.107 2

78.2 8.41 5 3.81 7.2 0.01 0.07 1 2

173 208 304 5.53 18.6 25.8 5 2.32 47 209 7.2 0.01 0.33 0.5 0.07 1 2

64.1 208 304 33.4 18.6 25.8 5 38.2 47 209 7.2 0.0368 0.33 0.5 0.07 1.78 2

89.1 208 304 10.9 18.6 25.8 5 20.9 47 209 7.2 0.01 0.33 0.5 0.07 8.95 2

71.9 208 304 8.03 30 39 5 5.14 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

169 208 304 7.05 30 39 5 9.39 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

174 208 304 88.2 30 39 5 2.99 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1.14 2

208 304 11.5 30 39 5 11.8 15.6 7.2 0.0615 0.0796 0.07 2

278 208 304 7.17 30 39 5 3.15 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

354 208 304 45.8 30 39 5 19.9 11.8 15.6 7.2 0.022 0.0615 0.0796 0.07 1 2

208 304 30 39 5 18.8 11.8 15.6 7.2 0.0615 0.0796 0.07 2

73.8 208 304 22.3 30 39 5 13.6 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1.04 2

103 208 304 15 30 39 5 4.31 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

2.72 208 304 1.81 30 39 5 0.2 11.8 15.6 7.2 0.01 0.0615 0.0796 0.07 1 2

5.62 226.33 278.12 0.532 27.87 35.54 5 0.224 10 12.5 7.2 0.01 0.121 0.168 0.07 1 2

10 226.33 278.12 0.3 27.87 35.54 5 0.2 10 12.5 7.2 0.01 0.121 0.168 0.07 1 2

16 180.511 236.628 2.14 22.405 29.646 5 0.568 8.7 11.2 7.2 0.01 0.09 0.125 0.07 1 2

58.2 180.511 236.628 15.6 22.405 29.646 5 16.1 8.7 11.2 7.2 0.0101 0.09 0.125 0.07 1 2

54.4 180.511 236.628 6.18 22.405 29.646 5 4.52 8.7 11.2 7.2 0.0101 0.09 0.125 0.07 1 2

44.5 180.511 236.628 14.3 22.405 29.646 5 6.98 8.7 11.2 7.2 0.0104 0.09 0.125 0.07 1 2

30.4 180.511 236.628 3.88 22.405 29.646 5 1.92 8.7 11.2 7.2 0.01 0.09 0.125 0.07 1 2

14.8 180.511 236.628 7.74 22.405 29.646 5 3.66 8.7 11.2 7.2 0.0259 0.09 0.125 0.07 1 2

29.7 213.788 278.708 0.784 11.687 15.179 5 1.41 5.181 6.670 7.2 0.01 0.029 0.036 0.07 1 2

32.4 213.788 278.708 3.91 11.687 15.179 5 3.92 5.181 6.670 7.2 0.01 0.029 0.036 0.07 1 2

Mineral Oil (mg/L)Aluminium (µg/L) Copper (µg/L) Lead (µg/L) Mercury (µg/L)

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2.4.1 Interpretation of 2018 results

Location F

Total phosphorous as P has exceeded licence emission limits in October and November 2018. The licence

emission limit is 1mg/l, the highest reading was recorded in October with a concentration of 4.58mg/l.

All other parameters are below licence emission limits for every sample taken in 2018.

Location DX

The parameters exceeding licence emission limits, trigger warning/ action values, and/ or surface water EQS

values varies from month to month:

• Suspended solids exceeded the licence emission limit of 35mg/l seven out of the nine samples taken;

• Conductivity exceeded trigger warning values in two samples;

• Ammonia exceeded the trigger action value in one sample;

• COD exceeded trigger action value in five samples;

• Iron exceeded trigger warning value in one sample and trigger action value in one sample

• Zinc exceeded EQS and trigger action value in two samples;

• Chromium exceeded trigger warning value in one sample, trigger action value in two, and EQS in one;

• Nickel exceeded trigger action value and EQS in one sample;

• Copper exceeded EQS in seven samples, trigger warning value in one and trigger action value in one;

• Lead exceeded trigger warning value in two samples, trigger action value in two and EQS in four; and

• Mineral oil exceeded licence emission limit of 2mg/l in two samples.

Some parameters had no exceedances in 2018: pH, arsenic, aluminium and mercury.

Location E

The parameters exceeding licence emission limits, trigger warning/ action values, and/ or surface water EQS

values varies from month to month:

• Ammonia exceeds the trigger warning value in one sample;

• Iron exceeds trigger action value in four samples;

• Arsenic exceeds trigger action value in five samples;

• Zinc exceeds EQS in two samples, trigger warning value in two and trigger action value in two;

• Copper exceeds EQS in four samples; and

• Lead exceeds EQS and trigger action value in one sample.

Some parameters had no exceedances in 2018: total suspended solids, conductivity, pH, COD, chromium,

nickel, aluminium, mercury and mineral oil.

KMK Tullamore



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Page 19

Mitigation measures

KMK Metals Recycling Ltd actively investigated the above exceedances throughout 2018 and will continue to

do so in 2019.

The procedure to be carried out in the event of any trigger level values exceedances is outlined in the IMS

Operational Procedure version 02, reference IMS Reference 313-PRO-IMS. In addition to these procedures,

additional mitigation measures have been carried out. Details of measures undertaken are presented in

Appendix 03, and include replacement of interceptor filters, implementation of a new drain cleaning checklist

and monthly jetting and desludging of interceptors and the drainage network. The implementation of these

measures is discussed in relation to individual parameters below:

Wastewater F Parameters

Phosphorous

Following an EPA Incident notification issued on 11th

January 2019, discharge point F will be monitored monthly

until otherwise instructed by the agency. A weekly schedule of servicing and sample analysis has been arranged

with Molloy’s until system compliance is continually demonstrated.

Storm Water DX and E Parameters

Suspended Solids

A reading of 76.1mg/l has been reported in December 2018. Additional mitigation measures outlined

including jetting and desludging, covering drains and altering the dampening procedure have been carried out

earlier this year which resulted in the suspended solids reducing to 72.7mg/l in May 2018. October 2018

samples were taken without the additional filters, resulting in a high reading of 148mg/l. Since the October

2018 samples, the Ultra Drain Guard filters have been refitted onto the outlet pipe and the filters will remain in

place for future sampling. November 2018 results showed this filter reducing suspended solids and it had been

expected that future suspended solids results will continue to reduce due to these filters, however an increase

has occurred in December 2018. This increase could be due to weather conditions and increased rainfall during

the winter months. It is noted that from 2015 there has been an exceedance in suspended solids in December.

The filter has now been replaced.

Following the 2019 results, a review will be carried out on the impact of the filter and any further mitigation

measures required.

COD

A review is carried out on the impact of the filter and any further mitigation measures required.

Metals

A review is carried out on the impact of the filter.

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Page 20

2.52.52.52.5 GroundwaterGroundwaterGroundwaterGroundwater

KMK Metals Recycling Ltd has two wells GW1 and GW2, both of which are tapped on-site. There is another

well, GW03, off-site located north-east of the main entrance. GW03 is in the private ownership of the

industrial estate, and is located approximately 50m upgradient of the KMK facility. July 2018 samples were

tested at ALS Life Sciences Ltd, December 2018 samples were tested at TMS Environment Ltd.

Groundwater monitoring was carried out in accordance with parameters listed in Schedule C.7 of waste licence

W0113-04 and the hazardous substances identified in the Groundwater Monitoring Risk Assessment Report

2014.

Table 2-10

Groundwater monitoring licence requirements

Wells Parameters Monitoring

frequency

Analysis method/

technique

GW1, GW2, GW3 pH, conductivity, total nitrogen, aluminium, arsenic,

chromium, copper, iron, lead, mercury, nickel, zinc,

faecal coliforms, total coliforms, VOCs

Bi-annually Standard

methods

The groundwater quality can be seen in Table 2-11 below.

In July 2018 arsenic in wells GW2 and GW3 exceeded the groundwater regulations (SI No 66 of 2016), all other

parameters were below assessment criteria. All VOCs were below detection limits.

In December 2018 arsenic in well GW2 exceeded the groundwater regulations, all other parameters were

below assessment criteria. All VOCs were below detection limits.

Table 2-11

Groundwater quality results 2018

Parameter Unit GW1 July GW1

Dec

GW2

July

GW2

Dec

GW3

July

GW3

Dec SI No 366 of

2016

(GW Regs)

pH pH Units 7.62 7.52 7.74 7.57 7.64 8.1 -

Conductivity µS/cm @

20°C

498 500 579 541 494 202 800-1875

Total Nitrogen mg/l

KMK Tullamore



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Page 21

Parameter Unit GW1 July GW1

Dec

GW2

July

GW2

Dec

GW3

July

GW3

Dec SI No 366 of

2016

(GW Regs)

Lead mg/l

KMK Tullamore



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Table 2-13

Drinking Water (DW1 and DW2) Results – 17th

December 2018

Parameter Unit DW1 DW2

Limit (Drinking Water)

Regulations 2014 (SI No. 122

of 2014)

Alkalinity mg/l CaCO3 40 28.5 -

pH pH Units 6.32 6.55 6.5-9.5

Ortho Phosphate mg/l P 0.02 0.02 -

True Colour mg/l PtCo

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Waste Activities Carried Out at the Facility 3.0

The principal class of activity is:

Class 13 of the Fourth Schedule (Waste Recovery Activities) of the Waste Management Act (1996): Storage of

waste intended for submission to any activity referred to in a preceding paragraph of this Schedule, other than

temporary storage, pending collection, on the premises where such waste is produced.

Non Technical Description: Temporary storage and processing of waste materials at the facility prior to

removal off site for further metals recovery at an alternative facility.

Consequently, other activities carried out on site include:

Class 3 of the Fourth Schedule (Waste Recovery Activities) of the Waste Management Act (1996): Recycling or

reclamation of metals and metal compounds.

Non Technical Description: Collection, acceptance and processing of metallic wastes (hazardous and non

hazardous including electronic and electrical wastes and liquids containing dissolved metals) as part of waste

loads arriving at the facility prior to removal off site for recycling or recovery.

Class 4 of the Fourth Schedule (Waste Recovery Activities) of the Waste Management Act (1996): Recycling or

reclamation of other inorganic materials.

Non Technical Description: Acceptance of plastic components and packaging as part of incoming waste loads.

Class 6 of the Fourth Schedule (Waste Recovery Activities) of the Waste Management Act (1996): Recovery of

components used for pollution abatement.

Non Technical Description: Acceptance of auto catalysts, filters etc.

Class 7 of the Fourth Schedule (Waste Recovery Activities) of the Waste Management Act (1996): Recovery of

components from catalysts.

Non Technical Description: Recovery of metals from catalysts in manufacturing processes (this applies to liquids

and solids)

Class 11 of the Fourth Schedule (Waste Recovery Activities) of the Waste Management Act (1996): Use of waste

obtained from any activity referred to in a preceding paragraph of this schedule.

Non Technical Description: Re-use of some waste materials e.g. metal drums, IBCs, cardboard boxes and

textile IBC bulk bags as waste receptacles.

Class 12 of the Fourth Schedule (Waste Recovery Activities) of the Waste Management Act (1996): Exchange of

waste for submission to any activity referred to in a preceding paragraph of this schedule.

Non Technical Description: Trading activities in waste management.

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Quantity and Composition of Waste Recovered, Received and 4.0

Disposed of During the Reporting Period including EWC Codes

This specific and detailed information is presented in Appendix 02 of this report.

Waste Management Record 5.0

5.15.15.15.1 Waste Received in 2018Waste Received in 2018Waste Received in 2018Waste Received in 2018 Waste is received in the KMK facility from the following sources: civic amenity sites, commercial customers,

industrial customers, gate customers, and transfer station waste management sites. A summary of all waste

received during 2018 is given below.

Table 5-1

Summary of waste received 2018

Finalised incomings Sum of material weight (tonnes)

Civic amenity site 9631.19

Commercial 17713.7

Industrial 1089.656

KMK gate customer 106.237

Transfer station 560.079

Waste industry 2211.311

Total 31,312.173

A full breakdown of waste types and quantities accepted for 2018 is included in Appendix 02 attached to this

AER.

The total quantity received was 31,312 tonnes for 2018.

5.25.25.25.2 Waste DWaste DWaste DWaste Deeeespatched from the Facility forspatched from the Facility forspatched from the Facility forspatched from the Facility for Recovery in 2018Recovery in 2018Recovery in 2018Recovery in 2018

The total quantity of waste despatched from the facility in 2018 was 31,019.102 tonnes. A summary of all

waste despatched during 2017 is included in Appendix 02 attached to this AER.

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Waste Recovery Record 6.0

All waste accepted at KMK is treated for recovery and recycling. There is a ‘no waste to landfill’ policy on-site.

KMK also acknowledges and complies with the most recent WEEE Regulations whereby recovery targets are

calculated and achieved. See letter statement below.

In addition, KMK has achieved compliance with EN50625 WEEE Treatment Standard / the WEEELABEX

Standard, which prescribes methods for conducting Batch Tests and for the subsequent Calculating Recycling

and Recovery Targets.

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Resource Consumption Summary 7.0

Electricity, green diesel and kerosene are used at the facility. The following tables summarise the electricity

and fuel consumption at the facility from 2017 to 2018 inclusive and for comparison purposes.

Table 7-1

Breakdown of Energy Consumption for the Year

Energy Type Consumption in kWh*

2017 % of total 2018 % of total

Electricity 630,600 32 746,007 36

Kerosene 54,378.88 3 53,141 3

Diesel 1,281,788.11 65. 1,278,309 62

Total 1,966,766.99 2,077,458

*Energy conversion factors: kerosene 9.821 kWh/L, diesel 10.169 kWh/L

In summary, the following trends are noted:

• There is an increase in electricity consumption from 2017 to 2018.

• Kerosene is used for the heating of office space. The levels of kerosene used in 2018 are slightly

lower than in 2017.

• Similar diesel consumption in 2018 was due to the same operation times as 2017 where the LHA

Baler was running from 06:00 – 22:00 during most days. Diesel consumption in 2018 was slightly

lower than in 2017.

Review of Nuisance Controls 8.0

The types of nuisances which could be expected at a Waste Management Facility in general are litter, vermin,

birds, flies, mud, dust and odours.

Due to the dry solid and non-food related origin of materials recycled at KMK, the activities carried out onsite

are not conducive to flies, birds, odours, and vermin - there are however canteens onsite, and associated

businesses nearby, therefore KMK employs a pest control company to ensure rodents are controlled.

All waste processing activities are carried out within buildings; all materials prior to processing are not able to

create a windblown nuisance (as they are solid / intact and too large to be blown), and all fractions generated

by the activities of KMK are stored under cover.

All site surfaces are concreted for minimisation of dirt/dust onsite, however dust is entrained or deposited

onsite and controls are in place in the form of yard dampening as necessary - as often as twice per day in

summer time, plus KMK uses a road sweeper on smooth floor surfaces for example in the WEEE Plant. Dust

monitoring around the boundaries of the KMK site during the 2018 monitoring event showed that one

monitoring location exceeded the EPA recommendation limit of 350mg/m2/day. All remaining dust deposition

results were below the EPA recommendation limit of 350mg/m2/day.

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Schedule of Environmental Objectives and Targets and 9.0

Environmental Management Programme

The schedule of Objectives and Targets / Environmental Management Programme for 2018 and their current

status is included below in Table 9-1 as part of the company IMS. Most of the scheduled objectives and targets

were achieved in 2018; some were carried forward and where this is the case a note is made to that effect in

‘Status’.

A schedule of objectives and targets / EMP proposed for year ending 2019 is currently being finalised by KMK.

Table 9-1

Environmental Objectives and Targets 2018

2 Environment

No. Aspect Objectives Target Time

Frame Responsibility Status

2.1 Environmental

Aspects

Review and documentation

of KMK’s Environmental

Aspects

Inclusion of KMK Kilbeggan and

review of KMK Tullamore Aspects May 2018 OB Complete

2.2 ISO Standard

Achieve certification to the

ISO 14001:2015 and

9001:2015 standards

following NSAI Audit in May

Certification to ISO 14001:2015

and 9001:2015 June 2018 OB Complete

2.3 Monitoring

Reports

Graphing of all Internal

Monitoring Report data

To track KMK’s internal

monitoring performance

September

2018 OB Complete

1. General



1.1 Waste to

Energy Audit

Improved compliance with

the waste management

hierarchy.

Improve downstream treatment

choice for waste materials

currently sent for waste to

energy.

May 2018 KMK

Management Incomplete

1.2 KMK Systems

Update

Amalgamation of existing

systems with the DPMS

and Smart RFID for

enhanced reporting and

asset management.

An amalgamated DPMS and

Smart RFID system that have

been updated to ensure higher

levels of accuracy and efficiency.

July 2018 KMK

Management Ongoing

1.3 IED Licence

Application

Development of the

Kilbeggan facility as an IED

licenced site.

Obtain an EPA IED Licence for the

Kilbeggan facility.

October

2018

KMK

Management Ongoing

1.4

KMK

Kilbeggan

Operations

Further development of

process activities at KMK

Kilbeggan.

Compliant flat screen, re-use and

fines treatment at KMK Kilbeggan

with achievement of the

requirements of the PAS

141:2011 Standard.

December

2018

KMK

Management Ongoing

1.5 SOPs Preparation of SOPs for

key office functions.

Documented step-by-step

procedures for the completion of

various key office functions.

December

2018

KMK

Management

KMK Office

Staff

Ongoing

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2.4 Surface Water

Quality

Reduction in surface water

monitoring result

exceedances

Less exceedances in surface water

monitoring results compared to

2017 and overall improvement in

surface water quality

December

2018

KMK

Management

OB

Ongoing

2.5 Energy Implementation of drafted

Energy Management Plan

Prevention of excess energy

wastage and reduction in energy

costs

December

2018

KMK

Management

OB

Ongoing

4 Quality



4.1 Cage

Quality

To improve cage quality and

tracking

Improved cage quality to the

satisfaction of customers and

effective cage tracking

July 2018

KMK

Management

KM

Ongoing

4.2 Battery

Manual

Review and update of the

KMK Battery Manual

Suitably detailed Battery Manual

for documentation of all battery

activities

July 2018 OB Ongoing

4.3

Customer

Satisfaction

Surveys

Creation and distribution of

further customer

satisfaction surveys

To distribute more customer

satisfaction surveys in 2018

compared to 2017

December

2018

KM

HW

Incomplete

3 Occupational Health & Safety


Frame

Responsibili

ty Status

3.1

Risk

Assessment

s

To incorporate process

audits into Risk Assessment

review and completion

To ensure Risk Assessments are

effectively prepared and audit

process activities during review and

completion.

May 2018 MF Incomplete

3.2 Business

Contingency

Implementation of drafted

Business Continuity and

Disaster Preparedness Plan

Preparedness for any adverse,

unexpected or emergency

situations at KMK

August

2018

MF

OB

Ongoing

3.3 Accidents Accident Prevention

Less than 15 non-reportable

accidents and less than 5

reportable accidents.

December

2018 MF

Not met but

improvements

made

3.4 Near Misses Increased Near Miss

Reporting

Reporting of at least 10 near misses

in 2018

December

2018 MF

Not met but

improvements

made

3.5 ISO

Standard

Implementation of ISO

45001:2018 requirements

To meet the new ISO standard

requirements for future NSAI

Certification

December

2018

MF

OB

Ongoing

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4.4 Complaints Reduction in complaints

received

Less than 5 complaints from

customers on KMK

products/services

December

2018 KM Not met

4.5

De-

Pollution

Target

Monitoring

Improved de-pollution

target monitoring results

Quarterly reports distributed to

management on results and

progress

December

2018

KMK

Management

OB

Ongoing

Pollutant Release and Transfer Register 10.0

There is no requirement to include a PRTR report as part of the 2018 AER.

Noise Monitoring Report Summary 11.0

A summary of the noise monitoring for 2018 is presented in Section 2.3 of this AER, as well as Table 2-5. The

full noise monitoring report is included in Appendix 01.

Noise Monitoring Report Summary 12.0

A summary of the ambient dust monitoring for 2018 on-site is presented in Section 2.1.

Tank and Pipeline Testing and Inspection Report 13.0

13.113.113.113.1 Bund AssessmentBund AssessmentBund AssessmentBund Assessment A full assessment of the bunds storage structures was completed between September 2016 and February 2017.

The full report was submitted separately to the EPA.

The bund assessment is a triennial assessment, and therefore will be required again in 2019.

13.213.213.213.2 Pipeline Inspections and TestingPipeline Inspections and TestingPipeline Inspections and TestingPipeline Inspections and Testing Integrity Testing of Storm and Foul underground lines and a CCTV survey of the E Network was carried out in

2017 and a number of repairs were recommended. .

Repairs were completed between 16/04/201 - 01/05/2018 by Carroll Design and Surveying, and all inspected

pipes were subsequently found to be in an acceptable structural condition (report exert below).

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Reported Incidents Summary 14.0

There were 12 Category 1 reportable incidents during 2018 at the facility, and the details are summarised in

Table 14-1 below. A series of mitigation measures have been put in place in 2018 as outlined in Appendix 03.

It is further intended to apply for planning permission to for a proposed extension to the roofs in the D4 and E

yards, as well as the Hangar Building. Covering these areas will significantly reduce external storage of material

and will reduce loading to surface water runoff.

A full set of environmental occurrences for 2018, including both Category 1 incidents and non compliances, is

presented in Appendix 04.

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Table 14-1

Incidents Report Table during 2018

EDEN Ref no Incident

reported

date

Incident cause/ description Summary of actions throughout the

course of this incident history

Incident

status

INCI015682 12/12/18 Phosphorous concentration exceeded the

emission limit value in several samples. The

Waste Water Treatment System was not

working effectively during the month of

September and October due to technical

issues with the FeCl dosing unit.

Concentration on 10/10/18 - 4.58mg/l,

04/12/18 – 2.31mg/l, 12/12/18 – 4.7mg/l.

ELV: 1mg/l. Providers (Molloy Precast

Products Ltd) have since serviced the unit.

02/11/18 - Providers of the WWTS

(Molloy Precast Products Ltd) have

since serviced the unit

18/12/18 - Providers will be called out

again for further assessment.

Closed

INCI015454 02/11/18 ELV for Environmental dust deposition

exceeded at monitoring location A2-1

(450.7mg/m2/day).

Update on 12/12/18:

Based on the updated report uploaded

through licensee return LR038121 (as

amended) the following trigger level values

were exceeded:

A2-1

Warning Value Exceedance:

Cadmium 0.0061 mg/m2/day

Possible Action Value Exceedance:

Chromium

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reported

date



Incident

status

INCI014987 10/08/18 ELV breached for Suspended solids (35mg/l)

at DX. Result: 64.7mg/l.

10/08/18 - Desludging of surface water

lines commissioned.

17/08/18 - Ensure silt traps are

maintained.

Open

INCI014507 05/06/18 Exceedances in proposed trigger level

values for Copper:26.4ug/l and Zinc:478ug/l

in storm water discharge DX and for

Lead:16.1ug/l and Zinc:114ug/l in storm

water discharge E.

Reason Invalidated: An incident (INCI04494)

was recorded earlier in May, the incident is

in relation to recurring contamination of DX

and E SW emission points. The original

incident will be kept open and

investigations relating to this incident will

be uploaded to it after discussion with LM

(18/06/2018).

05/06/18 - New interceptor filters have

been sourced from the supplier and will

be installed at DX and E prior to June

samples being taken. Following

correspondence with the EPA, the DX

sampling point will now be located at

the surface water discharge point next

to the land drain to allow for a flow

sample to be taken.

08/06/18 - A turnaround time for the

results of sampling of 5 days has been

arranged with the laboratory.

A second laboratory that specialises in

contaminated water will receive the

same samples as ALS Laboratories this

month in order to compare results and

ensure there are no discrepancies

following an improbably high result for

zinc in DX reported in May by ALS

Laboratories.

Invalid

INCI014506 05/06/18 Emission limit value breaches in suspended

solids and Mineral Oil at surface water

monitoring location DX. (Suspended Solids:

72.7mg/l, Mineral Oil 5.31mg/l).

05/06/18 – New interceptor filters have

been sourced from the supplier and will

be installed at DX and E prior to June

samples being taken. Following

correspondence with the EPA, the DX

sampling point will now be located at

the surface water discharge point next

to the land drain to allow for a flow

sample to be taken.

08/06/18 - A turnaround time for the

results of sampling of 5 days has been

arranged with the laboratory.

A second laboratory specialises in

contaminated water will receive the

same samples as ALS Laboratories this

month in order to compare results and

ensure there are no discrepancies

following an improbably high result for

zinc in DX reported in May by ALS

Laboratories.

Open-Cl

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reported

date



Incident

status

INCI014494 31/05/18 Breach of trigger values in storm water

samples at sampling location DX (COD

293mg/l and Zinc 138 ug/l) and at sampling

location E (Iron; 8.41mg/l and Arsenic

22.4ug/l).

03/09/18 –

August Lab result 180825-94

ELV Breach for Mineral Oil 3.13mg/l

Trigger Action Breach for Ammonia

3.46mg/l and COD 97.6 mg/l

Trigger Warning Breach for Conductivity

0.807mS/cm

12/10/18 –

September Lab Result 18002-35

ELV Breach for Suspended solids 125mg/l in

discharge DX and trigger action limit breach

for lead 12.4mg/l in DX.

Trigger Action Breach at discharge E for

Arsenic 16.6mg/l and Iron 3.24mg/l

Trigger Warning Breach for Ammonia

1.87mg/l and Zinc 85.6mg/l

25/05/18 – Immediate investigation

into the source of the elevated

parameters. Surface water networks to

be re sampled, filters ordered for both

interceptors and both drainage

networks where desludged.

31/05/18 – monthly monitoring to

continue.

Open-Cl

INCI014493 31/05/18 Ammonia levels Elevated above ELV in Foul

water sample (2.07mg/l).

Sample was taken between servicing of the

system which began on the 23rd of April

and was completed on the 26th of April.

31/05/18 – Sample to be taken in may

when plant adjustments and

maintenance is complete.

29/06/18 – monthly monitoring.

Closed

INCI014492 31/05/18 Suspended Solids elevated above Emission

Limit value Values in DX stormwater

(Suspended Solids: 112mg/l).

Sample was taken from stagnant water

from the bottom of the sampling chamber.

Sediment within the chamber is often

disturbed whilst sampling. This is believed

to be the reason for elevated suspended

solids at this sampling location.

28/05/18 - Further sampling carried out

in May. Sample to be taken from outlet

pipe od DX where it enters the land

drain to the west of the site instead of

stagnant water from the DX chamber.

30/05/18 - Ensure yard is kept

continuously clean.

Closed

INCI013604 02/01/18 Breach of ELV at storm water discharge

point DX.

Sample was taken from stagnant water in

final discharge chamber. No flow of surface

water was being discharged off site.

02/01/18 - Future samples should be

taken from the discharge flow.

02/01/18 - The preventative action will

be dependent on the effectiveness of

the corrective action as previously

described.

Closed

INCI013602 02/01/18 Breach of trigger action limit values at E-

Storm water discharge. Arsenic result -

19.5ug/l (Trigger Action Value - 3.66ug/l)

and Iron result - 3.69ug/l (Trigger Action

Value - 0.693ug/l).

02/01/18 – Investigation is to be carried

out on site by KMK Metals Recycling to

identify the problem.

05/01/18 - The preventative action will

be dependent on the effectiveness of

the corrective action.

Closed

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reported

date



Incident

status

INCI013600 02/01/18 Breach of ELV at F discharge outlet from

recently installed FeCl WWTP; Ammonia as

N result - 4.84mg/l.

Update 31/05/18 - It is believed that extra

Ammonia arising from secondary treatment

is being delivered to the Tertiary Treatment

Sand Filter and is putting a strain on its

ability to convert the Ammonia at present

temperature levels. A major factor in

treating Ammonia is the temperature levels.

The temperatures are low at the moment

and the Nitrifying bacteria tend to perform

less well below 12°C. The Tertiary

Treatment Sand Filter is by necessity built at

ground level in a long narrow tank and will

always be subject temperature variations.

Modifications to increase the aeration were

made to the Secondary Treatment Unit on

22nd of December 2017 by Molloys. These

modifications are designed to increase the

Nitrification, Ammonia reduction, process in

the SBR secondary treatment. The dormant

Christmas holiday period needs to be

discounted in relation to the biology

adjustment. The full effects of the increased

aeration will take a few weeks to be fully

realised.

02/01/18 - Molloys (WWTS provider)

will make adjustments to the program

on the newly installed FeCl dosing unit.

Monthly analysis of F will continue in

January 2018 when Molloys have made

the appropriate adjustments to the

Waste water treatment system.

12/01/18 - F Samples taken on the

12/01/18 for analysis to determine the

effectiveness of the dosing

adjustments.

31/05/18 - Mollys (WWTS provider) will

continue to monitor progress with their

own laboratory testing regime and

make adjustments as required to

improve the biological treatment

process and reduce Ammonia

concentrations to below the ELV.

Closed

All incidents will continue to be addressed in a timely manner and reported using the EDEN online reporting portal system, as adopted by the

EPA, and in accordance with Guidance and Waste Licence requirements on same.

Complaints Survey 15.0

No complaints were received at KMK during 2018.

Energy Efficiency Audit Report Summary 16.0

Please refer to Section 7.0 of this report for energy usage data and information.

Volume of Trade Effluent/Leachate and/or Contaminated 17.0

Stormwater Produced and Volume Transported Off-Site

There is no trade effluent or leachate produced at KMK.

In terms of stormwater, this is discharged off-site via DX and E outlets. The site interceptors are routinely

emptied and maintained throughout the year. Water removed during emptying is transported off site by

Ellsport Ltd., Derrybeg, Co. Offaly (WCP Permit Number: NWCPO-12-10654-02). The following off site disposals

occurred during 2018:

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Table 17-1

Storm Water Transport Off-Site

No. of Collection

Events

Reference EWC Description Quantity (kg)

17 DX &E

Networks 13 05 08*

Interceptor associated

drains contents, jetting &

washing cleanings and silt

removal

Estimated Total:

70,000 L

Report on the Assessment of the Efficiency of Use of Raw 18.0

Materials in Processes and Reduction in Waste Generated

The raw materials used at KMK for the recycling process are metallic and WEEE waste inputs. Please refer to

6.0 previously for information relating to the recovery efficiency of KMK’s activities.

KMK does not landfill; all residual wastes are sent for recycling (for example Timber Waste and Dry Recyclables)

or energy recovery (only those wastes which are not clean / dry recyclables and which are unsuitable for

recycling).

Report on Progress Made and Proposals being Developed to 19.0

Minimise Water Demand and the Volume of Trade Effluent

Discharge

This section is not applicable to KMK as there is no trade effluent discharge from the facility in 2018.

Development / Infrastructural Works Summary (Completed in 20.0

Previous Year or Prepared for Current Year)

Any relevant such works are already presented in Section 9.0 of this report.

Report on the Financial Provision made under this Licence, 21.0

Management and Staffing Structure of the Facility, and a

Programme for Public Information

KMK confirms that adequate financial provisions are in place for all proposed environmental improvements

Documents

ANNUAL ENVIRONMENTAL REPORT 2018 - KMK€¦ · KMK Tullamore Annual Environmental Report 2018 Filename: 190320 501.00323.00004 Rev0 KMK Tullamore AER 2018 SLR Ref No: 501.00323.00004