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ANNUAL ENVIRONMENTAL REPORT
2010
for
Licence No. P0795-01
Cadbury Ireland Limited
Rathmore,
Co. Kerry
P0-795-01|Cadbury Rathmore Annual Environmental Report (AER) 2010
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CONTENTS
1 INTRODUCTION ......................................................................................................................... 3
1.1 Licensee Details.................................................................................................................. 3
1.2 Description of Site Activities ............................................................................................... 3
1.3 Company Environmental Policy .......................................................................................... 3
2 SUMMARY INFORMATION ........................................................................................................ 5
2.1 Self Monitoring Data .......................................................................................................... 5
2.1.1 Emissions to Water ..................................................................................................... 5
2.1.2 Emissions to Air .......................................................................................................... 6
2.1.3 Waste Arisings ............................................................................................................ 7
2.2 Agency Monitoring and Enforcement ................................................................................. 9
2.2.1 Site Inspection ............................................................................................................ 9
2.2.2 Site Audits .................................................................................................................. 9
2.2.3 Agency Emissions Monitoring ..................................................................................... 9
2.3 Energy & Water Consumption Summary ............................................................................ 9
2.3.1 Energy Consumption .................................................................................................. 9
2.3.2 Water Consumption ................................................................................................. 10
2.4 Environmental Incidents and Complaints ......................................................................... 10
2.5 AER Summary Data Tables................................................................................................ 10
3 MANAGEMENT OF THE ACTIVITY ............................................................................................ 10
3.1 Schedule of Environmental Objectives & Targets .............................................................. 10
3.2 Environmental Management Programme Report 2010 ..................................................... 12
3.3 Environmental Management Programme Proposal 2011 .................................................. 19
3.4 Other Significant Environmental Aspects, Audits etc ........................................................ 23
3.4.1 ISO 14001 EMS Audit ................................................................................................ 23
3.4.2 Internal Audit ........................................................................................................... 23
3.4.3 Management Environmental Meetings ..................................................................... 23
4 LICENCE-SPECIFIC REPORTS ..................................................................................................... 23
4.1 Noise Monitoring report summary ................................................................................... 23
APPENDICES
Appendix A: AER Summary Data Tables
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TABLES
Table 1: Summary Table of Emissions to Water ........................................................................................... 5
Table 2 Summary of Non-Compliances for Emissions to Waters ................................................................. 6
Table 3 Summary Table for Mass Emissions to Atmosphere ....................................................................... 6
Table 4 Summary Table of Pollutant Average Concentrations ..................................................................... 6
Table 5: Summary of Non-Compliances for Emissions to Atmosphere.......................................................... 6
Table 6: Summary information of waste arising ........................................................................................... 7
Table 7 Summary information of waste streams......................................................................................... 7
Table 8 Summary of EPA Analysis v Self Monitoring Data ........................................................................... 9
Table 9 Energy Consumption Summary .................................................................................................... 10
Table 10 Water Consumption Summary .................................................................................................... 10
Table 11 Schedule of Environmental Objectives & Targets (Revised for 2011) ............................................ 11
Table 12 Review of 2010 Environmental Management Programme (EMP) ................................................ 13
Table 13 2011 Environmental Management Programme (EMP) ................................................................ 19
Table 14 Summary of 2011 Project Schedule ............................................................................................ 23
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1 INTRODUCTION
1.1 Licensee Details
License Register Number: P0795-01
Licensee: Cadbury Ireland Limited
Location of Installation Shinnagh, Rathmore, County Kerry
1.2 Description of Site Activities
The Cadbury Ireland Ltd, Rathmore installation manufactures milk chocolate crumb which is an intermediate
product utilised in the production of milk chocolate. Production of milk chocolate crumb involves
pasteurisation and evaporation of milk followed by the addition of sugar to form Sweetened Concentrated
Milk (SCM). Butteroil may also be added depending on the recipe and required fat concentrations. Liquid
cocoa mass is then added to form a paste. Raw and in-process materials are stored in tanks and silos on site.
Off-specification product may also be reworked into the process at this stage. The paste is then cooked and fed
to an air drier or one of three vacuum driers, prior to cooling. The resulting crumb is then weighed and packed
into 1,150 kg bulk bags, or sent to the bulk storage silos on site. There is also a milling process which may be
employed to reduce the particle size of the crumb where required. The control of the entire process is highly
automated.
Cadbury Ireland Ltd Rathmore facility comprises of a main processing facility with associated buildings, storage structures and wastewater treatment plant.
1.3 Company Environmental Policy
Key policy objectives are as follows:
We will: 1. Strive to prevent pollution and minimise the environmental impacts of our operation, working with
our supply chain and business partners to reduce our collective environmental footprint and protect the ecosystems that provide our raw materials.
2. Guarantee that our customers and consumers come first by actively listening to and understanding their expectations of our brands.
3. Reinforce our commitment to sustainability and safeguard the reputation of Cadbury through regular engagement with internal and external stakeholders.
4. Maintain a zero waste culture that consistently embraces environmental sustainability where everyone understands their responsibilities and accountabilities.
5. Operate audited environmental management systems that continually improve our processes to deliver this policy and any associated standards and ensure compliance with prevailing legislation.
6. Assign clear management accountability for setting, monitoring performance against and meeting measurable targets for environmental performance.
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7. Communicate openly and regularly in line with international good reporting practice
8. Place continuous improvement at the heart of our performance through assessment of the
environmental performance of new and existing products and processes.
9. Create a passion for sustainability where success and achievement are recognised, communicated and celebrated.
10. Review and update this policy and any associated standards regularly ensuring that it continues to reflect our values and the expectations of key stakeholders.
1.4 Company Environmental Management Structure
Cadbury Ireland Ltd, Rathmore has a structured management approach to the operation of the business in
terms of product quality, process control, environment and safety.
The Head of Manufacturing has the overall responsibility for environmental management and control at the Rathmore Installation.
The Quality and Environment (Q&E) Manager, as designated Environmental Representative, has responsibility for day-to-day environmental management at the Rathmore Installation.
Shift Managers are responsible for ensuring day-to-day environmental requirements are met.
All staff at the facility have are responsible to ensure the environmental requirements are met.
1.5 Cadbury Rathmore Environmental Management Organisational Chart
Head of Manufacturing
Production and
maintenance
personnel
Laboratory &
Security Personnel
Quality & Environment (QE) Manager
WWTP Personnel
Production Shift
Managers
Site Leadership
Team
External
Contractors
Quality, Environment and Health & Safety
(QEHS) Manager
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2 SUMMARY INFORMATION
The information presented here is for the calendar year 1st
January 2010 to 31st
December 2010.
2.1 Self Monitoring Data
2.1.1 Emissions to Water
Cadbury Ireland Rathmore is licensed for emissions to water. There is one emission point from the wastewater
treatment plant (SW1), discharging treated effluent to the River Blackwater. This emission point has been
monitored and analysed in accordance with requirements of Schedules B2 and C2.2 of the facilities IPPC
Licence.
There are two licensed storm water emission points (SW2 and SW3) that indirectly discharge on-site storm
water to the River Blackwater. There are no license limits applied to these emission points however water
quality is assessed on a daily basis and analysed weekly in accordance with Schedule C2.3 and for additional
parameters stipulated in the Agency’s Site Inspection Report of February 2008.
From January to September 2010 water analysis was undertaken by an independent external laboratory.
During this time Cadbury Rathmore was undertaking a comprehensive laboratory validation programme. From
September 2010 to December 2010 (having completed the analytical validation programme) water analysis
was carried out in-house at the on-site micro and chemistry laboratory by fully trained and competent
personnel.
There were three incidents of non-compliance associated with emission limit values for emissions to water
during 2010. All were reported to the Agency and appropriate incidence investigation and corrective action
was undertaken.
Table 1: Summary Table of Emissions to Water
PARAMETER FINAL EFFLUENT DISCHARGE PT SW1
(2009)
FINAL EFFLUENT DISCHARGE PT SW1
(2010)
EMISSION LIMIT VALUE
Volume 483.4 m3 484m3 900 m3
Temp 14.6 14.7 25 maximum
pH 8.5 8.5 6 – 9
BOD 6.33 mg/l 6.66 mg/l 40 mg/l
COD 42.7 mg/l 41.7 mg/l 125 mg/l
Suspended Solids 17.75mg/l 15.77 mg/l 50 mg/l
Total Nitrogen 8.45 mg/l 8.45 mg/l 15 mg/l
Total Ammonia 0.4 mg/l 0.22 mg/l 10 mg/l
Detergents 0.01mg/l 0.04 mg/l 2 mg/l
Oils, Fats, Greases <10 mg/l <10 mg/l 10 mg/l
Orthophosphate 0.33 kg/day 0.46kg/day 1.08kg/day
Total Phosphorus 0.43 kg /day 0.58 1.17kg/day
Toxicity n/a n\a 5 TU
Note: This emission data is based upon the averaged monitoring data available for the facility.
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Table 2 Summary of Non-Compliances for Emissions to Waters
DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION
12 January 2010 Reportable exceedence of ELV for flow rate.
Fault detected with flow meter when system in divert
Maintaining calibration status of flow meter. Ongoing review of system with flow meter supplier.
14 January 2010 Reportable exceedence of ELV for Suspended Solids
Unknown. Cause undermined following investigation. Facility not in operation (sampling event undertaken during annual Christmas shut down).
Review of recorded results preceding and subsequent indicates this concentration out of trend. No corrective action taken
12 May 2010 Reportable exceedence of ELV for nitrogen
Cause undermined following investigation
Continuing investigation into origins of nitrogen
2.1.2 Emissions to Air
Licensed emissions to the atmosphere are in the form of combustion emissions. There have been no changes
to the type of fuel used (heavy fuel oil) to date. Air emissions monitoring from the combustion process are
carried out twice annually to licence requirements by independent contractors. There were no exceedences of
licence emission limit values for emissions to air. As the facility also reports under the Emissions Trading
Scheme, mass emissions of carbon dioxide are also being reported within the PRTR. Mass emissions of
particulates are also being reported within this table for comparison purposes as they have also been
reported within the PRTR for the last couple of years
Table 3 Summary Table for Mass Emissions to Atmosphere
PARAMETER MASS EMISSION (2008)
MASS EMISSION (2009)
MASS EMISSION (2010)
Oxides of Sulphur 51,997 kg/year 45,654 kg/year 44,757 kg/year
Nitrogen Oxides 30,331 kg/year 29,772 kg/year 23,095 kg/year
Carbon Dioxide 11,498 tonnes/year 10,842 tonnes/year 9,396 tonnes /year
Particulates 18,622 kg/year 11,738 kg/year 10,094 kg/year
Table 4 Summary Table of Pollutant Average Concentrations
CONCENTRATION May (2010)
CONCENTRATION November (2010)
EMISSION
LIMIT VALUE Boiler A1-1 Boiler A1-2 Boiler A1-1 Boiler A1-2
Oxides of Sulphur 1084 mg/m3 1098 mg/m3 1559 mg/m3 1529 mg/m3 1700 mg/m3
Nitrogen Oxides 695 mg/m3 682 mg/m3 646 mg/m3 570 mg/m3 900 mg/m3
NOTE: Mass emission figures for each year (as reported in the electronic AER) have been calculated from
average concentrations as measured against quantity of heavy fuel oil consumed. Average
concentrations are measured are also provided for comparison with the Emission Limit Values as given
in the licence.
Table 5: Summary of Non-Compliances for Emissions to Atmosphere
DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION
There were no non-compliances associated with emissions to air
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2.1.3 Waste Arisings
Cadbury Ireland Rathmore is licensed to monitor waste sludge arising from the on-site wastewater treatment
plant facility. Sludge is tested annually and results are submitted to the Agency. A summary of all waste
streams and the management of waste arisings is presented in Tables 5 and 6 below.
Table 6: Summary information of waste arising
ITEM TONNES/ANNUM 2009
TONNES/ANNUM 2010
Total quantity of waste produced in calendar year
- Total quantity of waste disposed of on-site
- Total quantity of waste disposed of off-site
- Total quantity of waste recovered on-site
- Total quantity of waste recovered off-site
791.601t
None
303.325t
None
488.276t
559.239t
None
116.76t
None
442.479t
Quantity of non-hazardous waste produced in calendar year
- quantity of non-hazardous waste disposed of on-site
- quantity of non-hazardous waste disposed of off-site
- quantity of non-hazardous waste recovered on-site
- quantity of non-hazardous waste recovered off-site
695.84t
None
284.88t
None
410.96
548.56t
None
106.3t
None
442.26t
Quantity of hazardous waste produced in calendar year
- quantity of hazardous waste disposed of on-site
- quantity of hazardous waste disposed of off-site
- quantity of hazardous waste recovered on-site
- quantity of hazardous waste recovered off-site
95.761t
None
18.445t
None
77.316t
10.679t
None
10.46t
None
0.219t
Table 7 Summary information of waste streams
EWC CODE
DESCRIPTION OF WASTE HAZ YES/NO
QUANTITY (T/A) 2009
QUANTITY (T/A) 2010
METHOD OF DISPOSAL/ RECOVERY
WASTE SOURCE WASTE TYPE
02 05 02 wastes from the dairy products industry
sludges from on-site effluent treatment
No 323.18 231.7 R10
02 05 01 Wastes from the dairy products industry
Materials unsuitable for consumption or processing
No 4.32 0 R10
13 07 01 wastes of liquid fuels - fuel oil and diesel Yes 10.76 0 R1 13 07 03 wastes of liquid fuels - other fuels (including
mixtures) Yes 48.26 0 R1
13 08 02 oil wastes not otherwise specified
other emulsions Yes 9.22 0 R1
15 01 01 packaging (incl.separately collected municipal packaging waste)
paper and cardboard packaging
No 6.24 0 R3
15 01 06 packaging (including separately collected municipal packaging waste)
mixed packaging No 18.18 9.58 R13
15 01 10 packaging (including separately collected municipal packaging waste)
packaging containing residues of or contaminated by dangerous substances
YES 0.06 0 R4/R5
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Table 7 ctd Summary information of waste streams
EWC CODE
DESCRIPTION OF WASTE HAZ YES/NO
QUANTITY (T/A) 2009
QUANTITY (T/A) 2010
METHOD OF DISPOSAL/ RECOVERY
WASTE SOURCE WASTE TYPE
15 02 02 absorbents, filter materials, wiping cloths and protective clothing
absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances
Yes 5.665 0.155 R1
15 02 03 absorbents, filter materials, wiping cloths and protective clothing
absorbents, filter materials, wiping cloths and protective clothing other than those mentioned in 15 02 02
No 0 0.2 R12
16 05 06 gases in pressure containers and discarded chemicals
laboratory chemicals, consisting of or containing dangerous substances, including mixtures of laboratory chemicals
Yes 0.044 0.08 D9
17 01 07 Rubble mixture of concrete, bricks, tiles and ceramics other than those
53.22
17 02 01 wood, glass and plastic wood No 3.74 0 R3
17 04 05 metal iron and steel No 169.02
17 04 07 metals (including their alloys)
Mixed metals No 59.04 0 R4
17 05 03 soil (including excavated soil from contaminated sites), stones and dredging spoil
soil and stones containing dangerous substances
Yes 2.9 0 R5
17 06 05 Insulation materials and asbestos-containing construction materials
construction materials containing asbestos
Yes 17.64 10.38 D1
17 09 04 other construction and demolition waste
mixed construction and
demolition wastes other
than those mentioned in 17
09 01, 17 0902 and 17 09
03.
No 221.16 0 D1
19 12 01 wastes from the mechanical treatment of waste (for example sorting, crushing, compacting, pelletising) paper and cardboard
paper 1.26
20 01 08 biodegradable kitchen and canteen waste
Crumb compost 16.88
20 01 21 Municipal wastes -separately collected fractions
fluorescent tubes and other mercury-containing waste
Yes 0.191 0.064 R5 / R4
20 01 38 wood other than that mentioned in 20 01 37
timber 13.62
20 03 01 Other municipal wastes mixed municipal waste No 57.54 49.28 D1
20 03 07 Mixed municipal waste bulky waste 3.8
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2.2 Agency Monitoring and Enforcement
2.2.1 Site Inspection
The EPA inspected the site on one occasion in 2010. This was an unannounced inspection undertaken on 27
May 2010. Three (3) non-compliance and eight observations were noted on the day of inspection. Corrective
action was undertaken in relation to all inspection findings.
2.2.2 Site Audits
The EPA audited the site on one occasion in 2010. This was a scheduled audit undertaken on 23 July 2010. No
(0) non-compliance and eight observations were noted on the day of audit. Corrective action was undertaken
in relation to all audit findings.
2.2.3 Agency Emissions Monitoring
The EPA collected samples from the final effluent discharge point SW1 for analysis on four(4) occasions during
2010. The collection dates were 3 February 2010, 11 May 2010, 16 September 2010 and 14 December 2010.
Table 8 below shows the results of self monitoring with results recorded by the Agency. The cells highlighted
in orange indicate the significant differences between self monitoring results and that of the Agency. With the
exception of the Total Nitrogen concentration recorded for the 16th September 2010, the reported self
monitoring results were higher than that of the Agencys results.
Table 8 Summary of EPA Analysis v Self Monitoring Data
Parameter 3 February
2010
11 May
2010
16 September
2010
14 December
2010
Agency Self
Monitoring
Agency Self
Monitoring
Agency Self
Monitoring
Agency Self
Monitoring
pH 7.8 8.9 8.7 8.5 8.4 8.5 8.5 8.6
BOD mg/l 3.0 2.8 4.0 6
COD mg/l 74 80 12 22 <10 14.5 46 40
Total Suspended Solids mg/l 9.6 21 10 9 16 12 11 16
Ammonia mg/l 0.05 0.03
Total Phosphorus kg/day 0.52 0.53
Soluble Phosphorus kg/day 0.49 0.48
Total Nitrogen mg/l 1.43 4.3 16.1 15.1
2.3 Energy & Water Consumption Summary
2.3.1 Energy Consumption
Energy usage on site associated with production is largely fuel combusted in boilers to produce steam for the
thermal requirements of the site and electricity supplied to site, primarily for motive power. In addition to the
direct requirements of the manufacturing process energy is consumed on site for ancillary requirements such
as supply of well water, waste water treatment, tanker cleaning, loading and unloading of delivery vehicles,
compressed air production etc. Cadbury Ireland Rathmore used Heavy Fuel Oil as the main combustion fuel in
2010. Electricity used on site was obtained from the national grid. Water is sourced both from on-site wells
and municipal supply. Diesel usage is for the emergency generator. LPG usage is for the fork truck fleet and
for heating of some process lines during annual shut-down. Overall energy use continued to fall in 2010
compared to 2009. A focus on energy efficiency projects together with changes in the boiler system has
helped the decrease in energy usage on site.
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Table 9 Energy Consumption Summary
ITEM 2008 2009 2010
Heavy Fuel Oil (tonnes) 3,667.1 3,457.94 2,995.4
Diesel (tonnes) 0.23 0.23 1.05
LPG (tonnes) 9.32 7.85 9.5
Electricity (kWh) 6,449,854 6,424,000 5,290,175
2.3.2 Water Consumption
Water sources for the site include municipal water supplied by Kerry County Council and 2 No. on-site
groundwater borewells. The consumption of water by the activity during 2010 was 110,969m3.
Table 10 Water Consumption Summary
ITEM 2008 2009 2010
On-site ground water (m3) 122,550 114,613 110,307
Municipal Supply (m3) 1017 959 note 1 662 Note 1 This volume has been amended from that reported in the 2009 AER (of 403 m2). Clerical error in reporting.
2.4 Environmental Incidents and Complaints
During the reporting period, there were three (3) non-compliant emissions to water. These incidents were
reported to the Agency and have been discussed in Sections 2.1.1 of this report. There were no further
Incidents.
One (1) noise complaints was received during the year 2010. A neighbour phoned the facility around 11pm on
7th October 2010 about a ringing alarm. The alarm in question was the low level alarm system associated with
the firewater sump. The issue was addressed immediately and the alarm ceased 30 mins later.
2.5 AER Summary Data Tables
See Appendix A
3 MANAGEMENT OF THE ACTIVITY
3.1 Schedule of Environmental Objectives & Targets
The schedule of Environmental Objectives and Targets for Cadbury Rathmore was developed in 2008 to
address a five year period up to 2012. Environmental Targets and Objectives took into account compliance
with all conditions and schedules of the IPPC licence and the company’s financial, operational and business
requirements. The schedule shows that a total of 13 project areas were considered and that 39
schemes/actions had been programmed for completion before 2012.
The schedule of Objectives and Targets was reviewed in December 2008 as part of the 2008 AER. The 5-year
Programme was reviewed and revised forward to incorporate a Programme for the next 5 years; Year 2 (2009)
to Year 6 (2013). The schedule of Objectives and Targets has again been reviewed in December 2010.
Revisions to this schedule principally relate to the reprioritizing of targets and review of timeframes for
achieving targets.
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Table 11 SCHEDULE OF ENVIRONMENTAL OBJECTIVES & TARGETS (Revised + Update for 2011) – Part 1 of 2
PROJECT OBJECTIVES TARGETS
Stormwater
Management
Improve storm water discharge quality to
ensure no soil, surface water or
groundwater contamination as a result of
stormwater discharges from the site
Improvements in stormwater quality through improvements to on-site collection
and filtrations system by 2012
Water Resource
Management
Improve water conservation Maintain water usage at 3 m3
(+/- 10%) per tonne of finished product.
Wastewater
Management
Improve wastewater quality discharge to
ensure no soil, surface water or
groundwater contamination as a result of
wastewater discharges from the site
Emissions to waters from the wastewater treatment plant shall not exceed emission limit values outline in table B.2.2 of Schedule B of the facilities IPPC licence
No substance shall be discharged in a manner or at a concentration that following initial dilution causes tainting of fish or shellfish
Energy Use Reduce Installations Energy consumption
+ Increase the use of renewable energy
to improve energy efficiency
All findings and recommendations of the 2008 Energy Audit survey to be implemented and\or achieved by 2013
Power Generation Reduce Installations use of conventional
power generation
Evaluate the options of running the boilers on alternative renewable fuels by
2012
Fuel & Chemical
Storage
No soil, surface water or groundwater
contamination as a result of fuel or
chemical storage on-site
All tanks, containers and drum storage areas shall be rendered impervious to
the materials stored therein according to the 2009 Tank Testing Schedule.
Drainage from caustic and nitrite delivery areas to be diverted for collection
and safe disposal by end 2011.
Waste
Management
Reduce hazardous and non-hazardous
waste and improve recovery, reuse and
recycling of waste material
Reduce the environmental impact of the
Installations waste
a) Waste Generation: Reduce the volume of waste generated at the Installation
b) Waste Handling: No soil, surface water or groundwater contamination as a result of waste collection or disposal
c) Waste Storage: No soil, surface water or groundwater contamination as a result of waste storage
Waste generation: Reduce quantity of material to landfill by 10% on 2010
quantities in 2011. Investigate whether target can be set for reduction of sludge
volume by end of 2012.
Waste handling: Waste sent off site for recovery or disposal shall be transported
only by authorised waste contractors (Licensed or permitted). All waste to be
disposed of at a licensed or permitted facility.
Waste Storage: Waste shall be stored in designated areas protected against
spillage and leachate run-off
Air Emissions Operations & activities at the facility shall
not result in the release of significant
levels of pollutants to the atmosphere
Emissions to the atmosphere from the installation shall not exceed emission limit
values set out in the IPPC licence
Emission of oxides of sulphur shall not exceed 1700mg/m3
Emissions of nitrogen oxides (as NO2) shall not exceed 900mg/m3
No emissions of offensive odours outside the boundaries of the premises.
Noise Emissions Noise generated on-site shall not impact
the amenity of neighbouring properties
Noise from the installation shall not give rise to sound pressure levels (Leq, T)
,measured at sensitive locations of the installation which exceed the limit value(s)
of 55dB(A) for Daytime noise and 45dB(A) for night-time noise
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Table 11 SCHEDULE OF ENVIRONMENTAL OBJECTIVES & TARGETS (Revised + Update for 2011) – Part 2 of 2
PROJECT OBJECTIVES TARGETS
Fugitive Emissions Reduce fugitive emissions plant wide to
ensure no soil, surface water or
groundwater contamination as a result of
fugitive emissions from the site
Establish the losses from all on-site activities through fugitive emissions by 2012.
Develop a schedule for improvements (including quantifiable targets) by 2014.
Goods
Consumption
Reduce the facilities overall raw materials
resource consumption per tonne of
finished product
Material processing: Reduce, where possible, the losses of food materials in all
processes; while being mindful of possible food safety limitations. Target – that
annual ingredient losses (specifically raw crumb materials of milk, sugar, coca
mass and butter oi)l do not exceed 0.5%
Facility &
Equipment
Maintenance
Improve process control (equipment &
management) to reduce waste and
Improve maintenance and calibration of
control and monitoring equipment
to ensure adequate control of plant &
equipment so the hazardous breakdown
is prevented
Investigate downtime on all on-line monitoring equipment and reduce to less
than 5% by 2014
Environmental
Management
System
Make provisions for management of the
activity on a planned basis having regard
to the desirability of ongoing assessment,
recording and reporting of matters
affecting the environment
Existing management system and reporting structure to be continually reviewed
and updated as required
3.2 Environmental Management Programme Report 2010
Table 12 provides a summary on the programme of works undertaken in accordance with the 2010
environmental management programme (EMP). The summary gives an overview of the success in meeting the
planned targets for 2010.
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Table 12 Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 1 of 6
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED TIME ACHIEVEMENTS V TARGETS /
ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Stormwater
Management
In line with overall
objectives to improve
storm water discharge
quality and overall
target that these
improvements are
achieved by 2012
100% of gaps in drainage
survey to be completed
Undertake additional testing and survey
based on gaps identified in previous survey
By June 2010 Additional surveying and testing carried
out in June / July 2010.
All gaps in survey
could not be closed
out due to
restrictions on
access.
Remedial action
required to provide
access. Scheduled for
June 2011.
All critical areas
identified as part of the
stormwater drainage
systems upgrading on
site to be completed
Further upgrading of storm water and
process water drains
By December
2010
Stormwater drainage upgrade works
are ongoing.
Delays due to cold
weather in
December and
January.
Works due to be
completed by 2010 to be
closed out by March
2011
All identified stormwater
monitoring and control
mechanisms to be
installed
(i) Complete installation of 2000m3 holding
tank/firewater retention
By Sept 2010 Stormwater / Firewater Tank complete
and operational.
N/A N/A
(ii) All identified pumps, sumps, storage
tanks or treatment plant chambers from
which spillages of environmentally
significant materials might occur to be
fitted with high liquid level alarms
By Sept 2010 All tanks fitted with high level alarms. N/A N/A.
Water Resource
Management
In line with overall
objective to improve
water conservation
and overall revised
target to maintain or
improve on the 4%
reduction on 2008
volumes of water use
Continue with
identification of
opportunities for
reducing the volume of
on-site water usage
(i) Carry out site wide water balance to drive By end 2010 Water balance carried out as planned .
Review of the data acquired was not
undertaken
N/A Undertake review during
2011.
(ii) Analyse water meter data and review
water usage targets
By end 2010 Water meters in place. Data not
analysed
N/A Data to be analysed
during 2011.
(iii) continue with site in house awareness
training on water usage and water
conservation
Ongoing
during 2010
Informal training given to key
personnel.
N/A N/A
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Table 12 ctd Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 2 of 6
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED TIME ACHIEVEMENTS V TARGETS
/ ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Wastewater
management
In line with overall
objectives to improve
wastewater quality
discharges and overall
target that this is to be
achieved by 2012
Planned WWTP
upgrading works for
2010 to be completed
(i) Further upgrading of foul water drains Ongoing
during 2010
Current phase of process water
upgrade works complete.
N/A N/A
(ii) Continue with WWTP safety + access
improvements
Ongoing
during 2010
Footpaths, steps and handrails
installed in 2010. Extra works
planned for 2011.
N/A N/A
(iii) Permanent phosphorus removal system
to be completed
By May 2010 Phosphate removal system is in
place and operational.
N/A N/A
(iv) Commence bunding of divert drain from
river with a view to be completed by
early 2011
By end 2010 /
2011
Balance Tank and Emergency Tank
bund divert drain complete.
N/A N/A
(v) Review sludge levels with phosphorus
removal equipment installed
By end 2010 Levels reviewed as planned. Downturn in production
would have impacted sludge
volumes thus affecting
correlation with phosphorus
removal system
To be reviewed
again in 2011
Energy Use In line with overall
objectives to reduce
the facilities energy
consumption
Findings and
recommendations of the
2008 Energy Audit
Survey set out for 2010
to be achieved
(i) Investigate whether a duct can be
installed for the air supply to the boiler air
intake from the top of the boiler house
by June 2010 Investigation undertaken as
planned
Opportunity investigated
with the burner
manufacturer and found that
this is not a feasible option
due to the overall boiler
house temperature and
burner design
n/a
(ii) Investigate the option of recuperating
the waste heat from the discharge stream
from dryer 0
by September
2010
Investigation carried out as
planned
n/a This is now added to
list of sites energy
saving options and
is to be assessed
against business
guidelines for
capital funding
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Table 12 ctd Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 3 of 6
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED TIME ACHIEVEMENTS V TARGETS /
ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Energy Use ctd In line with overall
objectives to reduce
the facilities energy
consumption
Findings and
recommendations of the
2008 Energy Audit
Survey set out for 2010
to be achieved
(iii) Investigate whether heat can be
recovered from water going to evaporator
start up/shut down tank, preheat milk to
condenser (Heat Exchanger)
by December
2010
Investigation carried out as planned n\a This is now added to list
of sites energy saving
options and is to be
assessed against
business guidelines for
capital funding
(iv) Investigate the sequence of operation of
the milling operation so as to utilise the
energy spent as efficiently as possible
by March
2010
Investigation carried out as planned Shorter plant run
time due to product
demand has
reduced the savings
opportunity
significantly
n/a
(v) Investigate the feasibility of recovering
the discharge air from the pneumatic
actuators on closure
by September
2010
Investigation carried out as planned n\a This is now added to list
of sites energy saving
options and is to be
assessed against
business guidelines for
capital funding
(vi) Investigate the possibility of installing a
VSD (reducing impeller trim) on the
distribution pump of Cooling Tower No. 2
by June 2010 Investigation carried out as planned n/a VSDs are now installed
(vii) Investigate the feasibility of reinstating
the steam coil on the heavy fuel oil storage
tank so as to replace the equivalent
electrical counterpart
by September
2010
Investigation carried out as planned n/a Steam heater now
installed
(viii) Evaluate whether the operational
pressure of the standby boiler can be
reduced
by March
2010
Investigation carried out as planned Results showed that
savings were not as
attractive due to the
efficient design of
the burners
Opportunities to run on
reduced pressure during
periods of low
production demand will
for part of ongoing
energy efficiency
evaluation
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Table 12 ctd Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 4 of 6
PROJECT REASON TARGETS PROGRAMME/ACTION
REQUIRED
TIME ACHIEVEMENTS V TARGETS /
ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Waste
Management
In line with overall
objective to reduce
hazardous and non-
hazardous waste and
improve recovery, reuse
and recycling of waste
materials
100% of identified
recyclable waste to
be recycled
(i) Continue with reducing the
volume of waste going to landfill
Ongoing during
2010
Achieved as planned. N/A N/A
(ii) Investigate and implement
improved kitchen waste
segregation
By Sept 2010 Investigation carried out as planned.
Limited implementation of findings.
Limited outlets for
collection and disposal
of segregated materials
available.
Continue investigations
– new system must be in
place by end June 2011.
(iii) Continue with waste
management training
Ongoing during
2010
Achieved as planned N/A N/A
(iv) Review reducing 2009 volumes
of wastewater using COD and TOC
monitoring
Ongoing during
2010
Limits for stormwater now set to ensure
that no unnecesaary stormwater is sent
through the WWTP.
N/A Submit limits to Agency
for approval
(v) Review targets for waste
reduction + reuse
By end 2010 Achieved as planned N/A N/A
Fuel & Chemical
Storage
In line with overall
objectives to ensure there
is no contamination as a
result of fuel or chemical
storage on site
All presently
identified potential
risk area to be
addressed
i) Continue with containment works
for inlets, outlets, vent pipes, valves
and gauges
Ongoing during
2010
Suitable containment solution for
intake gauge at Heavy Fuel Oil (HFO)
Bund determined.
HFO intake gauge
Containment works not
implement – financial
reasons
These works to be
undertaken in 2011
Insufficient control
measure identified by
Agency during site
inspection of 27 May
2010 at Nitric and
Caustic delivery area
Appropriate control
measures investigated
and proposals sent to
the Agency for approval.
Control measures to be
implemented 3rd
Quarter 2011
Interim action – delivery
personnel given further
training and instruction.
(ii) Review spill kit requirements Ongoing during
2010
Action achieved. All necessary spill kits
in place
n/a n/a
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Table 12 ctd Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 5 of 6
PROJECT REASON TARGETS PROGRAMME/
ACTION REQUIRED
TIME ACHIEVEMENTS V TARGETS /
ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Air Emission In line with overall objectives
that operations and activities
at the facility shall not result in
releases of significant
pollutants to the atmosphere
Emissions to the
atmosphere shall
not exceed emission
limit values set out
in the IPPC licences
Monitoring as per licence
requirements
May 2010
&
October 2010
Action achieved. Monitoring undertaken
as planned
n/a n/a
Noise Emissions In line with overall objectives
that noise emissions shall not
impact the amenity of
neighbouring properties
Noise emissions
associated with
employee carpark
gate to be mitigated
(i) Install appropriate noise control
measures at employee carpark gate
By May 2010 Action achieved. New gear box and pads
installed on the electronic gate to the
employee carpark
n/a n/a
(ii) Continue with annual noise survey By September
2010
Action achieved. Monitoring undertaken as
planned
n/a n/a
Fugitive
Emissions
In line with overall objectives
to reduce risk of contamination
as a result of fugitive emissions
Continue with
identification of
fugitive emissions
(i) Prepare a schedule/plan for
investigating fugitive emissions
By June 2010 Action achieved. Plan established in
accordance with Leak detection standard EN
378 (Refrigerating Systems and Heat pump –
safety and environmental requirements)
and Regulation (EC) No 2037/2000 on
controlled substances
n/a n/a
Facility
Equipment and
Maintenance
In line with overall objectives
to improve process control
All key plant and
equipment for
control of emissions
to be included in
SAPs
Continue with maintenance
programme. Review + update if
necessary
Ongoing
during 2010
Achieved as planned
N/A N/A
Goods
consumption
In line with overall objectives
to reduce the facilities overall
raw materials resource
consumption per tonne of
finished product
Maintain 99%
recovery of
ingredients in verses
finished goods.
(i) Outstanding spill prevention
training for raw material handling
personnel to be prioritised in 2010.
By May 2010 Action achieved. Training provided as
planned
n/a n/a
(ii) Establish improvements to reduce
losses in the production plant
By October
2010
Action achieved. Customer transport
packaging which had previously been
identified by Cadbury as a key area of
product losses, has been replaced with a
suitable alternative.
n/a n/a
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Table 12 ctd Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 6 of 6
PROJECT REASON TARGETS PROGRAMME/
ACTION REQUIRED
TIME ACHIEVEMENTS V TARGETS /
ACTION PROGRAMMES
DIFFICULTIES
ENCOUNTERED
CORRECTIVE
ACTION
Environmental
Management
System
In line with overall
objectives to make
provisions for the
management of facility
activities on a planned
basis having regard to the
desirability of ongoing
assessment, recording and
reporting of matters
affecting the environment
Management +
Reporting Structure
Schedule of
environmental
Objectives and Targets
Environmental
Management
Programme
Documentation
Data Management
System
Corrective Action
Awareness and
Training
Communication
Programme
Efficient Process
Control
Accident Prevention
Emergency Response
Reports
Continue annual review of
procedures and update as necessary
By December
2010
Action achieved. All areas of the
environmental management system
audited, reviewed and updated as necessary
n/a n/a
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3.3 Environmental Management Programme Proposal 2011
The targets and action programmes for the year are set out on an annual basis at the first Environmental
Management Meeting of the year. The environmental management plan (EMP) for 2011 proposes the
programmes and actions set out in Table 13 below to be undertaken in the coming year.
Table 13 CADBURY RATHMORE – 2011 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 1 of 4
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME
Stormwater
Management
In line with overall
objectives to
improve storm
water discharge
quality and overall
target that these
improvements are
achieved by 2012
the following
targets and actions
are proposed for
2011
Close out on the
upgrading works
scheduled for to be
completed in 2010 by
March 2011
Pipelines S01-S85, S85-S21, S24-S86,
S86-S87, S87-S12, S12-S12a to be
installed
Contractor March 2011
Upgrade defective
stormwater pipelines
identify at northern
end of site.
Pipelines to be upgraded: S01-S29, S29-
S30, S31-S32 and S32-S33
Contractor Oct 2011
Complete survey on
outstanding drains
Remedial action required to provide
access to facilitate close out on
drainage survey
Contractor June 2011
Install forecourt type
oil interceptor at HFO
delivery area
New concrete plinth and drainage
channel to be constructed and
connected to new oil interceptor
Contractor Oct 2011
Water
Resource
Management
In line with overall
objective to
improve water
conservation the
following targets
and actions are
proposed for 2011
Identify future water
reduction
programmes
Undertake review of the water balance
data acquired during 2010
QE Manager Dec 2011
Review water usage
targets
Undertake review of the water meter
data acquired during 2010
QE Manager Dec 2011
Wastewater
management
In line with overall
objectives to
improve
wastewater quality
discharges and
overall target that
this is to be
achieved by 2012
the following
targets and actions
are proposed
during 2011
Upgrade of raw
effluent Balance Tank
Refurbish glass lined steel structure of
Balance Tank, improve access to tank,
upgrade aeration system.
Contractor July 2011
Investigate impacts of
phosphorus removal
system on sludge
volumes
Review sludge levels with phosphorus
removal equipment installed
QE Manager Sept 2011
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Table 13ctd CADBURY RATHMORE – 2011 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 2 of 4
PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME
Energy Use In line with overall
objectives to reduce
the facilities energy
consumption the
following targets
and actions are
proposed during
2011
Waste heat from the
discharge stream
from dryer 0
Option for recuperating the waste heat
from the discharge stream from dryer 0
to be assessed against business
guidelines for capital funding
Facility
Production
Manager
End 2011
Evaporator Heat
Exchanger / heat
recovery system
Identified site energy saving options
associated with investigation into
recovered heat from water going to
evaporator start up/shut down tank,
preheat milk to condenser (Heat
Exchanger) to be assessed against
business guidelines for capital funding
Facility
Production
Manager
End 2011
Discharged air from
the pneumatic
actuators
Options for recovering the discharge
air from the pneumatic actuators on
closure to be assessed against business
guidelines for capital funding
Facility
Production
Manager
End 2011
Operational pressure
of the standby boiler
Opportunities to run on reduced
pressure during periods of low
production demand to be further
investigated as part of ongoing energy
efficiency evaluation
Facility
Production
Manager
End 2011
Waste
Management
In line with overall
objective to reduce
hazardous and non-
hazardous waste
and improve
recovery, reuse and
recycling of waste
materials the
following targets
and actions are
proposed during
2011
Improve segregation
of kitchen waste
Appropriate waste receptacles to be
provided for Kitchen waste.
Collection outlet for food waste to be
established
QE Manager June 2011
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Table 12 CADBURY RATHMORE – 2011 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 3 of 4
PROJECT REASON TARGETS PROGRAMME/ACTION
REQUIRED
RESPONSIBILITY TIME
Fuel &
Chemical
Storage
In line with overall
objectives to ensure
there is no
contamination as a
result of fuel or
chemical storage on
site the following
targets and actions
are proposed during
2011
Drainage from caustic
and nitrite delivery
areas to be diverted
for collection and safe
disposal
Improve delivery bay for caustic and
nitric delivery vehicles. New
concrete plinth and drainage channel
to be constructed and connected to
process water drainage system
Contractor end 2011.
Condensate from
heavy fuel oil
pumping and heating
set to be connected
to appropriate drain
Connection to be made to existing
drainage in area. Condensate to be
directed through existing oil
interceptor.
Contractor Aug 2011
Install forecourt type
oil interceptor at HFO
delivery area
New concrete plinth and drainage
channel to be constructed and
connected to new oil interceptor
Contractor Oct 2011
Air Emission In line with overall
objectives that
operations and
activities at the
facility shall not result
in releases of
significant pollutants
to the atmosphere
the following targets
and actions are
proposed during 2011
Emissions to the
atmosphere shall not
exceed emission limit
values set out in the
IPPC licences
Monitoring as per licence
requirements
Contractor May 2011
&
October
2011
Noise
Emissions
In line with overall
objectives that noise
emissions shall not
impact the amenity of
neighbouring
properties the
following targets and
actions are proposed
during 2011
Noise levels at site
boundaries shall not
exceed limit values
set out in the IPPC
licences
Continue with annual noise survey
Contractor By
September
2011
Fugitive
Emissions
In line with overall
objectives to reduce risk
of contamination as a
result of fugitive
emissions the following
targets and action are
proposed during 2011
Routine monitoring of
the identified sources of
fugitive emissions
- Continue with monitoring of stormwater
discharges
- Continue with maintenance contract for
ODS monitoring
- Implement maintenance contract for
ODS monitoring for identified laboratory
equipment
QE Manager +
Facilities Manager
Ongoing
through 2011
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Table 13 CADBURY RATHMORE – 2011 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 4 of 4
PROJECT REASON TARGETS PROGRAMME/ACTION
REQUIRED
RESPONSIBILITY TIME
Facility
Equipment and
Maintenance
In line with overall
objectives to
improve process
control the
following targets
and actions are
proposed during
2011
Equipment maintenance
programme
Review + update if necessary Facility
Maintenance
Manager
Ongoing
during 2011
Goods
consumption
In line with overall
objectives to reduce
the facilities overall
raw materials
resource
consumption per
tonne of finished
product the
following targets
and action
programmes are
proposed during
2011
Maintain 99% recovery of
ingredients in verse
finished goods.
- Continue with spill prevention
training as required.
- Continue with investigating
improvements to reduce losses
in the production plant.
Facility QE
Manager
Facility QE
Manager
End 2011
End 2011
Environmental
Management
System
In line with overall
objectives to make
provisions for the
management of
facility activities on
a planned basis
having regard to the
desirability of
ongoing
assessment,
recording and
reporting of
matters affecting
the environment
the following
targets and actions
are proposed
during 2011
Management + Reporting Structure Schedule of environmental Objectives and Targets Environmental Management Programme Documentation Data Management System Corrective Action Awareness and Training Communication Programme Efficient Process Control Accident Prevention Emergency Response Reports
Continue annual review of procedures and update as necessary Prepare site ELRA
Facility QE Manager Contractor
By December 2011 By December 2011
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Table 14 Summary of 2011 Project Schedule
Project Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec
Storm Water Management √ √ √ √ √ √ √ √ √ √ √ √
Water Resource management √ √ √ √ √ √ √ √ √ √ √ √
Wastewater Management √ √ √ √ √ √ √ √ √ √ √ √
Energy Use √ √ √ √ √ √ √ √ √ √ √ √
Power generation √
Waste Management √ √ √ √ √ √ √ √ √ √ √ √
Fuel & Chemical Storage √ √ √ √ √ √
Air Emissions √ √
Noise Emissions √
Fugitive Emissions √
Facility & Equipment Maintenance √
Goods Consumption √ √ √
EMS √ √ √ √ √ √ √ √ √ √ √ √
3.4 Other Significant Environmental Aspects, Audits etc
3.4.1 ISO 14001 EMS Audit
In 2010, Cadbury’s Rathmore ISO 14001-certified EMS underwent an annual audit for its conformance with the
standard and was recommended for continued registration following this evaluation. No non-conformances
were noted during this audit which was undertaken by the NSAI.
3.4.2 Internal Audit
An audit of the Environmental Management System was undertaken during the period May - June by Cadbury
Personnel and external Environmental Consultants Malachy Walsh and Partners. This audit did not highlight
any significant new issues.
3.4.3 Management Environmental Meetings
Key internal environmental meetings are held by management at Cadbury Rathmore three times per year.
There are a number of unscheduled meetings as needed. The first meeting of the year reviewed the previous
year and established the programme of works for the coming year. Subsequent meetings updated the
schedule of works for the year.
4 LICENCE-SPECIFIC REPORTS
4.1 Noise Monitoring report summary
Dixon Brosnan undertook a noise survey in September 2010 and included a day time and night-time survey.
Overall noise levels recorded were satisfactory. The daytime 55db and night time 45db noise limits specified in
licence P0795-01 were not exceeded.
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APPENDIX A| AER SUMMARY DATA TABLES