Annual Environmental Report for Calendar Year 2012Annual Environmental Report for Calendar Year 2012...

Annual Environmental Report for Calendar Year 2012 True Temper Limited, trading as Ames True Temper, Whites Cross, Cork. IPPC Licence Reg. No. P0615-01

True Temper Limited, Whites Cross, Cork. IPC Licence Reg.No. P0615-01 __________________________________________________________________________________________________

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Contents Section Page No. 1. Introduction 1

1.1 General 1 1.2 Licensee Details 1 1.3 Site Description 1

1.3.1 Local Environmental Conditions 1 1.3.2 Products, Processes and Facilities 1 1.3.3 Recent Developments 3 2. Management of the Activity 4 2.1 Environmental Management System 4 2.2 Management Organisation 4 2.3 Schedule of Environmental Objectives and Targets 4 2.4 Environmental Management Programme (EMP) Report 4 2.4.1 EMP Report 8 2.5 Environmental Management Programme Proposal 15 2.6 Pollution Emission Register Report 17 2.6.1 General 17 3. Emissions to Atmosphere 18 3.1 General 18 3.2 Summary of Compliance / Non-Compliance 18 4. Emissions to Water 20 4.1 General 20 4.2 Summary of Surface Water Emission Monitoring Results 20 4.3 Groundwater Monitoring 22 4.3.1 Groundwater Monitoring Results 22 4.3.2 Groundwater Monitoring of Foul Effluent Emissions 24 4.3.3 Drinking Water 27 4.4 Testing and Inspection of Underground Tanks and Pipelines And Bund Integrity Testing 27 5. Waste and Waste Management 28 5.1 Introduction 28 5.2 Summary of Waste Statistics 28 6. Noise 29 6.1 Introduction 29

True Temper Limited, Whites Cross, Cork. IPC Licence Reg.No. P0615-01 __________________________________________________________________________________________________

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Contents Section Page No. 7. Resource Consumption 30 7.1 Introduction 30 7.2 Electricity Usage 30 7.3 Diesel Usage 31 7.4 LPG Usage 32

7.5 Water Consumption 33 7.6 Energy Efficiency Indices 33

8. Environmental Incidents and Complaints 34

8.1 Complaints 34 8.2 Incidents 34

9. Review of Residuals Management Plan 34 10. Environmental Liabilities Risk Assessment 34 11. Conclusion 35 Appendix 1 Site Location Map Appendix 2 Site Layout Plan Appendix 3 ISO 9001 Certificate Appendix 4 Organisational Structure Appendix 5 PRTR (Pollutant Release and Transfer Register) Emissions Data Appendix 6 Glossary of Terms

True Temper Limited, Whites Cross, Cork. IPC Licence Reg.No. P0615-01 ______________________________________________________________________________

___________________________________________________________________________ Annual Environmental Report (AER) 2012 1

1. Introduction 1.1 General

This Annual Environmental Report is prepared for True Temper Limited, Whites Cross, Cork, in accordance with Condition 2.9.2 of its operating Integrated Pollution Prevention and Control (IPPC) Licence Register No. P0615-01 and details the environmental performance at the site for the period January to December 2012.

1.2 Licensee Details

Name and Address: True Temper Limited, trading as Ames True

Temper, Whites Cross, Cork. Licence Reg.No. P0615-01 Date of grant of Licence: June 10th 2003. National Grid Reference: E1695 N0778

Class Description: Class 3.2.2: “The processing of iron and steel in forges, drawing plants and rolling mills where the production area exceeds 500 square metres, not included in paragraph 3.2.1”.

1.3 Site Description

1.3.1 Local Environmental Conditions

True Temper Ltd. occupies a 10 acre site and is located in Whites Cross, Cork approximately five kilometres north of Ballyvolane parish located north of Cork City at an elevation of 130m above sea level – See Appendix 1 Site Location Map. The topography of the site slopes gently down towards the southwest, towards an unnamed stream/drainage ditch that flows along the southern site boundary. The surrounding land use is predominantly agricultural and there are no schools or hospitals located in the vicinity of the site. The nearest occupied residences to the True Temper facility are situated several hundred metres to the south, southeast and southwest and west of the site. There is a residential property located to the northeast of the site. There is a facility “Inform Nutrition” located directly to the northeast of the True Temper Ltd. site that manufactures animal nutritional products. The nearest river to the site is the Glashaboy river which is upgradient of the site and situated approximately 1.7 km northwest. The small unnamed stream/drainage ditch that runs along the southern boundary of the site ultimately discharges to the Glennamought river, approximately 2 km southwest of the site.

1.3.2 Products, Processes and Facilities

True Temper Limited is a wholly owned subsidiary of US based Corporation Ames



True Temper, Camp Hill, Pa., the leading lawn and garden non-powered tool business in the U.S. The company is located at Whites Cross in Cork and employs 17 people as of December 2012. The primary products that used to be manufactured at the True Temper site (up to 2009/2010) included lawn and garden, agricultural and contractor non-powered hand tools comprising of forged spades and shovels (both solid-socket and open-socket configurations), forks, rakes and garden hoes. The company also market and distribute an extended product range which includes snow tools, cutting tools and striking tools. The activities/processes that were previously undertaken at the True Temper site can be summarised into six operations, namely, 1. Forging of steel for shovel blades, forks, rakes and hoes 2. Shotblasting and blade tumbling 3. Powder painting 4. Handle processing 5. Assembly and Packaging of finished products 6. Warehousing and distribution. The True Temper site, which is owned by the company, consists of three main blocks (comprising 75,000 square feet facility) which is divided into the following areas:

Building 1: Administration Offices including limited canteen facility. Building 2: Assembly/Warehouse building which includes wood handle

processing, assembly and packaging of finished products, electrostatic power spray painting, Pyrolysis Oven (for cleaning of paint racks), storage and distribution of finished products, goods inward loading bay, engineering office.

Building 3: Forge building The principal ancillary facilities located on the site are the Utility areas comprising of Compressed air generation, Diesel (gas oil) storage, Liquid Petroleum Gas (LPG) storage and an Electricity Supply Board (ESB) substation and an electric power low-tension switch room. The site also includes a wood dust/woodchip extraction system where the waste shavings and chippings are fed to an on-site 300kW Biomass burner.

The site comprises of support facilities including a hydrant ring main and Hydrant firewater reservoir, a Sprinkler system including a Sprinkler water reservoir, a drinking water reservoir supplied from own on-site well and a foul effluent treatment system. See Appendix 2 – Site Layout Plan. The Maintenance workshop and associated machinery and equipment, previously located in Building 2, were permanently removed in 2011 to facilitate more floor space for product storage and distribution.



1.3.3 Recent Developments

As outlined in the True Temper Ltd. Annual Environmental Reports of 2009, 2010 and 2011, the company undertook significant organisational restructuring in 2009 due to changing needs of the business resulting in the closure of the Forge Shovel Mill operation and the subsequent cessation of the limited amount of remaining forging activity of open-back shovels and finish forming of fork heads in late 2010/early 2011. In parallel with this, there was a significant reduction in the remaining manufacturing-related operating activities/processes which continued through to, and during 2012. These organisational changes resulted in the switching off and “mothballing” of the remaining machinery and equipment relating to the Forging operations and activities. For this equipment and machinery, all on-board lubrication oil reservoirs and sumps were drained of residual oil. This organisational restructuring resulted in a 38% reduction in the total workforce from 52 persons in January 2009 to 32 persons in December 2009. There were further redundancies in 2010 resulting in a total workforce of 17 persons as of December 2010. As of December 2012 the total workforce was 17. This figure includes 8 administration personnel. The only manufacturing/preparation undertaken in 2012 comprised a very limited amount of the following activities and processes:

1. Shotblasting (of residual stock) 2. Powder painting 3. Wood handle preparation – handle end preparation only. 4. Product Assembly and Packaging. The limited amount of remaining Forging activity of open-back shovels and finish forming steel fork heads from WIP inventory ceased at the site in late 2010/early 2011. True Temper Ltd. plan to continue in the restructured business at the same facility (without the forge operations and activities) with the focus on existing sales, marketing, warehousing and distribution of agricultural, contractor and lawn & garden non-powered tools, snow tools, cutting tools and striking tools.

There will be a very limited amount of the following activities in the short term:

1. Painting of product

2. Wood handle preparation

3. Shot blasting metal parts

4. Product assembly and packaging. In light of the above developments and in particular the cessation of the Forge Shovel Mill operations, True Temper Ltd. initiated the process of surrendering their IPPC licence in November 2011 by requesting a Closure Audit proposal from an



independent environmental consultant. True Temper Ltd. commissioned this independent consultant to carry out an Independent Closure Audit (ICA) for the facility. An Audit of the facility was carried out in June 2012 with a follow up ICA report submitted to the Agency in August 2012. The findings of the audit were provided in this ICA report, outlining potential environmental impacts and highlighting corresponding corrective actions. The bulk of these corrective actions were undertaken in the final quarter of 2012. This is work in progress and a final grant of surrender of the True Temper Ltd. IPPC licence from the Environmental Protection Agency is expected in the first half of 2013.

2. Management of the Activity

2.1 Environmental Management System

An Environmental Management System (EMS) is required under Condition 2.1 of its operating IPPC licence facilitates the management of environmental activities at the True Temper site. The EMS currently includes the following elements: 1. Environmental Policy 2. Schedule of Objectives and Targets 3. Environmental Management Programme 4. European Pollutant Release and Transfer Register 5. Programmes relevant to documentation, corrective action, awareness and

training, responsibilities and communications. True Temper is also accredited to I.S. EN ISO 9001:2008 and is audited by the NSAI bi-annually. A copy of the ISO 9001:2008 Certificate is presented in Appendix 3.

2.2 Management Organisation

The organisational structure at True Temper Ltd. (trading as Ames True Temper) is presented in Appendix 4 – Organisational Chart as of December 2012.

2.3 Schedule of Environmental Objectives and Targets

The schedule of Environmental Objectives and Targets submitted as part of the 2011 Annual Environmental Report (AER) is presented in Table 2.3.1 of this report. This table in conjunction with the discussion on individual projects in Section 2.4 of the AER, forms the Environmental Management Programme report for the calendar year 2012. The status column in Table 2.3.1 has been updated to reflect project progress in 2012.

2.4 Environmental Management Programme Report

Condition 2.3 of the True Temper Ltd. IPPC licence requires the submission of an Environmental Management Programme (EMP) report, as part of the AER for the



reporting period January to December 2012. The EMP report (Section 2.4.1) is detailed in the discussion following Table 2.3.1 (Schedule of Environmental Objectives and Targets for Calendar Year 2012).

True Temper Ltd. completed the following site infrastructure and environmental improvement projects in 2012: 1. Installation of uPVC double-glazed windows and doors in the Office

Administration building. 2. Insulation of perimeter cavity wall Office Administration building. 3. Insulation of ceiling area in Administration Office building. 4. Installation of uPVC double-glazed windows in the Warehouse packing area. 5. Lubrication oil store structure dismantled and removed by a licensed

hazardous waste contractor.



Table 2.3.1 – Schedule of Environmental Objectives and Targets for Calendar Year 2012 (presented in 2011 AER) EMP No.

Objective Targets Status

OB1

No potential pollution substance or matter shall be permitted to discharge to off-site waters, off-site storm drains or to groundwater under the site.

Decommission and make environmentally inert main diesel (gas oil) storage/supply area. Decommission and remove above-ground oil:water separator.

Complete. Complete.

OB3

Identify all opportunities for energy use reduction and efficiency

Examine night-time electricity usage with a view to reducing energy use.

Not complete

OB4

Recycling of waste material off-site

Compliance with the 2007 Waste Management Packaging Regulations – self-comply or join Repak.

Complete

OB9

Secondary containment improvements

Decommission 10,000 litre diesel AST. Remove associated pumps / pipework, and existing dispensing nozzle. Remove and dispose 2,500 litre waste oil storage tank. Clean and make environmentally inert existing diesel storage bunded area. Decommission existing 2x lubrication oil storage tanks. Clean and make environmentally inert existing lubrication oil storage bunded area.

Complete Complete Complete Complete Complete

OB11

Underground Storage Tank/Groundwater Monitoring results

Conduct on-going monitoring of groundwater wells to assess

Complete and on-



EMP No.

Objective Targets Status

the affects if any the removal of the UST had on the quality of groundwater.

going.

OB12

Testing of Underground pipework

Decommission trade-effluent water settling tanks and decommission trade effluent cooling water storage tank.

Complete

OB13

Groundwater monitoring of final effluent from wastewater treatment plant.

Continue bi-annual (on-going) monitoring of GW9 and investigate fluctuations in analytical results.

Complete and on-going



2.4.1 EMP Report

OBJECTIVE OB1: No Polluting substance or matter shall be permitted to discharge to Off-site waters, Off-site storm drains, to Ground or to Groundwater under the site. Overall Target: No polluting substance shall be permitted to discharge to:

Off-site waters

Off-site storm drains

Ground

Groundwater

Scheduled Benefits:

To operate organisation in an environmentally friendly manner.

Comply with the requirements of the operating IPPC licence.

Stage Project Area Time Scale Responsibility

1 Decommission and make environmentally inert main diesel (gas oil) storage/supply area. Decommission and remove above-ground oil:water separator.

April 2012 Engineering

Project Summary: An on-going objective of True Temper is to reduce pollutants discharging to off-site waters, ground and groundwater to meet or be significantly under the emission limit values set out in the IPPC licence. Summary of work completed in the previous EMP: Groundwater monitoring is carried out biannually on specified groundwater monitoring wells on site (GW4, GW6, GW7, GW8 and GW9). Surface water monitoring is also carried out at the site storm water outflow at monitoring point SW1. These results help to identify any trends in the groundwater status and thus inform ongoing (management and mitigation) measures that may be required. It was planned to decommission and make environmentally inert the existing main diesel (gas oil) storage/supply or bunded area including the 10,000 litre capacity diesel storage tank (AST). These tasks were completed in 2012. As a result of this, there was no further requirement for the existing (above ground) oil:water



separator/interceptor which was also decommissioned and removed from site by a local interceptor hire company.

Summary of work to do in the forthcoming 2013 EMP:

This objective is now considered complete.

OBJECTIVE OB3: Identify all opportunities for energy use reduction and efficiency. Overall Target: Identify all opportunities for energy use reduction and efficiency.

Scheduled Benefits:

Encourage and promote energy use reduction.

Identify energy saving solutions that are associated with process and utility plant

Quantify energy savings

Comply with the requirements of the operating IPC licence.


1 Examine night-time electricity usage with a view to reducing energy use.

July 2012 Engineering

Project Summary: An objective for True Temper is to identify all opportunities for energy use reduction. Summary of work completed in the previous EMP: This objective has not been completed.





OBJECTIVE OB4: Recycling of waste materials off-site . Overall Target: Ensure continued proper management of facility waste streams.

Scheduled Benefits:

Encourage and promote waste minimisation and recycling.

Improve the environmental performance of the company.

Comply with the requirements of the operating IPC licence.


1 Review compliance with the 2007 Waste Management Packaging regulations – self-comply or join Repak.

Sep. 2012 Engineering

Project Summary: An objective of True Temper is to continuously review means of recycling materials where possible. Summary of work completed in the previous EMP: Compliance with the 2007 Waste Packaging Regulations was reviewed with the quantity of packaging waste produced/supplied by the company onto the Irish Market assessed and calculated. True Temper have joined Repak.


This objective is considered complete.

OBJECTIVE OB9: Secondary containment improvements. Overall Target: Structural improvements and modifications to:

Ensure integrity of bunds on-site

Ensure an environmentally clean operation

Carry out bund integrity testing as required by True Temper operating IPC licence.



Scheduled Benefits:

Reduce site environmental risk/impact


Comply with the requirements of the operating IPPC licence.


1 Decommission 10,000 litre diesel storage tank (AST).


2 Remove and dispose 2,500 litre waste oil storage tank.


3 Clean and make environmentally inert existing diesel storage bunded area.


4 Decommission existing 2x lubrication oil storage tanks.

May 2012 Engineering

5 Clean and make environmentally inert existing lubrication oil storage bunded area.

May 2012 Engineering

Project Summary: Eliminate the environmental impact of potential bund leakage and fuel/oil spills. Summary of work completed in the previous EMP: The existing 10,000 litre capacity diesel/gas oil storage tank (AST) was internally cleaned and decommissioned. AST was emptied and cleaned by a licensed hazardous waste disposal/recovery contractor. The existing 2,500 litre capacity waste oil storage tank, located in the diesel storage bunded area was removed and taken off site through a sale/purchase agreement with an interested third party for continued use.

The existing lubrication oil storage tanks located in the lubrication oil storage bunded area were decommissioned and taken off site through a sale/purchase agreement with an interested third party for continued use. The diesel storage bunded area was cleaned and made environmentally inert – see also OB1. The lubrication oil storage bunded area was also cleaned and decommissioned. Both bunded areas were emptied and cleaned by a licensed hazardous waste disposal/recovery contractor





OBJECTIVE OB11: Underground Storage Tank / Groundwater monitoring results Overall Target: Conduct on-going monitoring of groundwater wells to assess the affects if any the removal of the UST had on the quality of groundwater. Scheduled Benefits:

Comply with the requirements of the operating IPC licence to carry out groundwater monitoring bi-annually.


1 Conduct on-going monitoring of groundwater wells to assess the affects if any the removal of the UST had on the quality of groundwater.

December 2012 (on-going)

Engineering

Project Summary: True Temper conducts groundwater monitoring bi-annually as requested by its IPPC licence. This monitoring will help determine the quality of groundwater since the UST has been removed.

Summary of work completed in the previous EMP: True Temper conducted two monitoring rounds of groundwater monitoring points GW4, GW6, GW7 and GW8 as per Condition 9.2.5 of the company’s IPC licence in 2012.

Summary of work to do in the forthcoming 2013 EMP: True Temper will continue to conduct groundwater monitoring biannually as requested by the IPC licence.



OBJECTIVE OB12: Testing of Underground pipework

Overall Target: Carry out testing of underground pipework, tanks, oil interceptors and all underground effluent and sewer pipes. Scheduled Benefits:

Comply with the requirements of the operating IPPC licence to undertake a programme of testing and inspection of underground tanks and pipelines.



1 Decommission trade-effluent water settling tanks and decommission trade effluent cooling water storage tank.

Sep. 2012 Engineering

Project Summary: The limited amount of remaining Forging activity of open-back shovels and finish forming steel fork heads from WIP inventory ceased at the site in late 2010/early 2011. As a result, True Temper is planning to decommission its trade effluent cooling water system. Summary of work completed in the previous EMP:

The trade effluent sub-surface cooling water tanks and the 90 m3 trade effluent cooling water storage tank were decommissioned in 2012. All tanks were emptied and cleaned by a licensed hazardous waste disposal/recovery contractor.





OBJECTIVE OB13: Groundwater monitoring of final effluent from wastewater treatment plant Overall Target: Set out a programme for groundwater monitoring (GW9) of the final effluent disposed through the percolation area from the Puraflo wastewater treatment system. Agree Emission Limit Values (ELV’s) with the EPA.

Scheduled Benefits:

Establish good environmental practice by regularly monitoring final effluent.

Ensure satisfactory operation and proper performance of Puraflo foul effluent treatment system.



1 Continue bi-annual monitoring of GW9 and investigate fluctuations in analytical results.

December 2011.

Engineering

Project Summary: True Temper monitored GW9 on a bi-annual basis to monitor the operation of the site foul effluent/waste water treatment system.

Summary of work completed in the previous EMP: True Temper set up a programme in 2007 for groundwater monitoring of the final effluent disposed through the percolation area from the wastewater treatment system, through monitoring groundwater well GW9. True Temper conducted two monitoring rounds of groundwater monitoring point GW9 in 2012.

Summary of work to do in the forthcoming 2013 EMP: True Temper will continue bi-annual monitoring of GW9 and assessment of analytical results.



.

2.5 Environmental Management Programme Proposal

A revised Table of Environmental Objectives and Targets is presented in Table 2.5.1 - It is proposed that Table 2.5.1 in conjunction with the paragraphs “Summary of Work to Do in the forthcoming 2013 EMP” as detailed in Section 2.4.1 will form the Environmental Management Programme (EMP) for 2013. As previously outlined in Section 1.3.3 of this report, True Temper Ltd. initiated the process of surrendering their IPPC licence in November 2011. True Temper Ltd. commissioned an independent consultant to carry out an Independent Closure Audit (ICA) for the facility. An Audit of the facility was carried out in June 2012 with a follow up ICA report submitted to the Agency in August 2012. The findings of the ICA were provided in this report, outlining potential environmental impacts and highlighting corresponding corrective actions. The bulk of these corrective actions were undertaken in the final quarter of 2012. This is work in progress and a final grant of surrender of the True Temper Ltd. IPPC licence from the Environmental Protection Agency is expected in the first half of 2013. Part of the EMP for 2013 will be completing the IPPC licence surrender process including the various tasks and corrective actions to be completed and closed off.



Table 2.5.1 – Proposed Schedule of Environmental Objectives and Targets for Calendar Year 2013 EMP No.

Objective Targets Completion Date

OB3

Identify all opportunities for energy use reduction and efficiency


July 2013

OB11

Underground Storage Tank/Groundwater Monitoring results

Conduct on-going monitoring of groundwater wells to assess the affects if any the removal of the UST had on the quality of groundwater.


OB13

Groundwater monitoring of final effluent from wastewater treatment plant.

Continue bi-annual (on-going) monitoring of GW9 to assess the operation of the site foul effluent treatment system.


OB15

Determine quality of site drinking.

Sample and analyse existing water supply for compliance to EU directives and Irish guidelines on drinking water standards.

October 2013



2.6 Pollution Emission Register Report 2.6.1 General

True Temper are required under Condition 2.4.1 of their IPPC Licence, to submit a Pollution Emissions Register proposal (PER) for the processing facility (processing of steel in forges), located at Whites Cross, Cork. The specific requirements of Condition 2.4 are detailed as follows:

Condition 2.4 Pollution Emission Register (PER) 2.4.1 The substances to be included in the PER shall be agreed with the

Agency each year by reference to the list specified in the AER guidance note. The PER shall be prepared in accordance with any relevant guidelines issued by the Agency and shall be submitted as part of the AER.

2.4.2 The licensee shall, not later than six months from the date of grant of this

licence and thereafter as part of the AER, agree with the Agency the list of substances to be included in the PER, and the methodology to be used in their determination.

The objective of the PER is to ensure that the destination of major pollutants is tracked. The chemicals to be included in the PER are based on a review of all materials used at the site and the materials contained in Annex II of the E-PRTR Regulation. True Temper plan to report substances which are listed in Annex II of the PRTR Regulation and used on site for 2012 through the EPA web-based system which allows licensees to report emissions and waste transfers off site more easily and in a readily available format. This report will be submitted electronically to the EPA under the PRTR Emissions data XML Return file. A copy of this file will be included in this 2012 Annual Environmental Report – See Appendix 5.



3. Emissions to Atmosphere 3.1 General

Condition 5.3 of the True Temper operating IPC Licence requires that monitoring and analyses of each emission shall be carried out as specified in Schedule 1(iii) Monitoring of Emissions of the licence. A report on the results of this monitoring shall be submitted to the EPA on an annual basis. Condition 5.4 of the operating IPC Licence requires True Temper to submit a summary report of emissions to atmosphere including fugitive emissions as part of the Annual Environmental Report (AER). Emissions to atmosphere from the True Temper facility occur from individual furnaces, ovens, boilers, the welding maintenance area and from the powder paint system. A total of 16 point sources of emissions to atmosphere are located at the True Temper facility, consisting mostly of minor emission points as defined by the Agency. Due to the recent organisational restructuring at the True Temper facility the vast majority of these minor emission points are now redundant. The two main point sources of emissions which have been assigned Emission Limit Values (ELV’s) by the EPA and which form part of the emissions monitoring schedule of the True Temper operating IPPC licence are: 1. Tempering Oven Afterburner (Emission Point Ref. A1-2) located in the

Forge Shovel Mill and 2. Pyrolysis Oven Afterburner (Emission Point Ref. A1-6) located in the

Assembly/Warehouse building.

3.2 Summary of compliance / non-compliance

Condition 5.3 of the True Temper operating IPPC licence requires that monitoring and analyses of each emission shall be carried out as specified in Schedule 1(iii) Monitoring of Emissions of this licence. A report on the results of this monitoring shall be submitted to the EPA as follows: 1. Bi-annual basis (Emission Point Ref. A1-2) – Combustion flue gases and

TOC(as C). 2. Annual basis (Emission Point Ref. A1-6) – Combustion flue gases and

TOC(as C). Note that TOC (asC) for A1-6 is not specified in the True Temper IPC licence – this was requested as additional monitoring by the sites EPA OEE inspector in November 2007.



A1-2: As outlined in Section 1.3.3 the True Temper Ltd. Forge Shovel Mill ceased operating from 17th July 2009. This particular process consisted of Solid socket shovel manufacture – reference Section 9.1 of True Temper Ltd. IPPC Licence Application Form, sub heading “Shovel Manufacture”.

This change resulted in the shutdown and elimination of Emission Point Ref. No. A 1-2 from June 2009, reference schedules 1(i), 1(ii) and 1(iii) of True Temper Ltd. IPPC licence Reg. No. P0615-01.

Prior to the cessation of this particular manufacturing process, True Temper Ltd. introduced a new heat treatment process for solid socket shovels and spades at the beginning of March 2009 – reference Boron Steel Project. The new process would eliminate the use and environmental impact of the existing oil quench and Tempering Oven facility (Emission Point Reference No. A1-2) in favour of water quenching through the introduction of an alternative steel Boron, for shovel blade manufacture.

The existing oil quench and tempering oven heat treatment process (Emission Point Reference No. A1-2) was utilised on a part-time basis only from March 2009 to consume existing steel inventory until June 2009 when it was eliminated from the Solid socket shovel manufacturing process – Forge Shovel Mill. However, as previously mentioned, the Forge Shovel Mill ceased operating from 17th July 2009. The last round of monitoring for Emission Point Reference No. A1-2 was carried out on 29th January 2009 and reported to the Agency under correspondence dated 31st March 2009. A1-6: Monitoring of Emission Point Reference No. A1-6 was last undertaken on the 22nd September 2011 and the corresponding analytical results were reported in the 2011 AER. This Oven was used for periodic removal of the build-up of residual paint on the product paint racks. The oven was only periodically in use for approximately 80 hours in total over CY2011.

As outlined in Section 1.3.3, there was a very limited amount of powder painting undertaken in 2012. This resulted is zero requirement for the use of the Pyrolysis Oven in 2012, (with corresponding Emission Point Ref. No. A1-6). It is envisaged that there will be no further requirement for the use of the Pyrolysis Oven going forward into 2013 and beyond. There was no emissions to atmosphere monitoring undertaken at A1-6 in 2012.



4. Emissions to Water 4.1 General

There were previously two emission points to surface waters (to a stream that runs along the southern boundary of the site), reference SW1 and SW2. SW1 was previously used to discharge a combination of process trade effluent water and surface water runoff. However, since the installation of a trade effluent/cooling water system in September 2003, only surface water is discharged to SW1 unless there is a batch discharge required from the trade effluent/cooling water storage tank. Batch discharges may still occur, however, the trade effluent/cooling water system is very efficient at recycling water and to date no batch discharges were required. The previous system for treatment of foul effluent sewage was by of septic tank, which overflowed to a soakaway. The soakaway was drained using land drainage to SW2. However, this has now been superceded by the installation of a Bord Na Mona “Puraflo” foul effluent treatment system and associated percolation area in January 2005. The outflow is monitored by a groundwater monitoring point GW9. Therefore SW2 no longer exists as a discharge point. Monitoring of site surface water discharges is conducted at monitoring point location SW1 as per Condition 9.1 of the True Temper operating IPC licence. Schedule 2(ii) Effluent Treatment Control requires that the oil/water separators and the holding tank be visually inspected weekly. True Temper carry out weekly inspections of the trade effluent/cooling water system and of the surface water discharge SW1. However, as outlined in last years Annual Environmental Report and in Section 1.3.3 of this report, True Temper undertook significant organisational restructuring in 2009 due to changing needs of the business resulting in the closure of the Forge Shovel Mill operation. Following this, the remaining limited amount of forging activity of open-back shovel manufacture and finish forming of fork heads ceased in late 2010/early 2011. This cessation effectively eliminated the remaining requirement for the trade effluent/cooling water system. The trade effluent sub-surface cooling water tanks and the 90 m3 trade effluent cooling water storage tank were decommissioned in 2012. All tanks were emptied and cleaned by a licensed hazardous waste disposal/recovery contractor.

4.2 Summary of surface water emission monitoring results.

Schedule 2(iii) Monitoring of Emissions to Water requires that the following parameters be monitored prior to each batch discharge to SW1: Flow, pH, BOD, Suspended Solids, DRO, Copper, Zinc, other metals.



When the Forge activity was operational, process/trade effluent cooling water was recycled through a trade effluent/water cooling system and during its usage there was never a requirement for batch discharging from the trade effluent/cooling water storage tank to SW1.Therefore, SW1 only discharges surface water. True Temper has voluntarily included monitoring of SW1 as part of its bi-annual groundwater suite of monitoring to maintain good environmental practice and performance. Two monitoring rounds were scheduled for SW1 by True Temper Ltd. in 2012, the first round in July and the second in December. The second round of sampling was undertaken on the 3rd January 2013 – delayed due to laboratory sampling service availability. Analytical results for both rounds are discussed below:

Biological Oxygen Demand (BOD) – BOD was not detected above the

laboratory Limit of Quantification (LOQ) of <1 mg/L for both rounds. The IPPC licence ELV for BOD is 5mg/L.

Suspended Solids (SS) – SS was not detected above the LOQ (<5 mg/L) for the July round and was measured at 10 mg/L for the January round, which is below the IPPC licence ELV for SS of 25 mg/l.

Diesel Range Organics (DRO) – no DRO’s were detected in the surface water sample above the laboratory LOQ (<10 μg/L) in the July round and was measured at 11.4 ug/L for the January round. The IPPC licence ELV for DRO’s is 1000 μg/L.

MO – MO was detected at 35.1 ug/L (LOQ 10 μg/L) in the July round and was measured at 88.7 ug/L for the January round. There is no IPPC licence ELV assigned for MO

PRO – no PRO’s were detected above the laboratory (LOQ <10 μg/L) in the July round and was measured at 16.1 ug/L for the January round. There is no IPPC licence ELV assigned for PRO.

TPH – TPH was detected at 35.1 ug/L (LOQ 10 μg/L) in the July round and was measured at 116.2 ug/L for the January round. There is no IPPC licence ELV assigned for TPH.

pH values measured from the surface water samples from both rounds were in the range 7.0 to 7.1, all of which are within the IPPC licence ELV for pH of between 6-9.



Metals – In the January round, no copper was detected above the laboratory LOQ of <0.003 mg/L while in the July round, Copper was detected at 0.007 mg/L. The IPPC licence ELV for Copper is 0.005 mg/L.

Metals – In the January round, Zinc was detected at 18.9μg /L while in the July round Zinc was detected at 15.1μg /L. The IPPC licence ELV for Zinc is 30 μg /L.

4.3 Groundwater monitoring

Condition 9.2.5 of the operating IPPC licence, requires that groundwater monitoring points GW4, GW6, GW7 and GW8 shall be sampled and analysed in accordance with Schedule 4(i) Groundwater Monitoring and be monitored bi-annually for Diesel Range Organics (DRO’s) and Volatile Organic Compounds (VOC’s). Two monitoring rounds were scheduled for all of the Groundwater wells by True Temper Ltd. in 2012, the first round in July and the second in December. The second round of sampling was undertaken on the 3rd January 2013 – delayed due to laboratory sampling service availability.

4.3.1 Groundwater monitoring results GW6, GW7 and GW8

Groundwater monitoring points GW6, GW7 and GW8 were sampled in July 2012 and January 2013 as per Condition 9.2.5 of the True Temper operating IPPC licence. All samples were analysed for the parameters set out in Schedule 4(i) Groundwater Monitoring of the IPC licence as well as for Petrol Range Organics (PRO’s), Mineral oil (MO) and Total Petroleum Hydrocarbons (TPH). Note that there are no ELV’s specified for any of the parameters in Schedule 4(i) or for the additional parameters PRO, MO and TPH. Analytical results for both sampling rounds for GW6, GW7 and GW8 are discussed below:

o Diesel Range Organics – No DRO were detected in the groundwater

samples above the laboratory Limit of Quantification (LOQ) of <10 μg/L) in either monitoring round.

o Volatile Organic Compounds – No VOC’s were detected above the

laboratory Limit of Quantification (LOQ) in either monitoring round.

o Petrol Range Organics – No PRO were detected in the groundwater samples above the laboratory Limit of Quantification (LOQ) of



<10 μg/L in either monitoring round except for the GW6 January round which measured 14.1 μg/L.

o MO - No MO were detected in the groundwater samples above the

laboratory Limit of Quantification (LOQ) of <10 μg/L in either monitoring round except for the GW6 January round which measured 147.8 μg/L.

o TPH - No TPH were detected in the groundwater samples above the

laboratory Limit of Quantification (LOQ) of <10 μg/L in either monitoring round except for the GW6 January round which measured 161.9 μg/L.

GW4 Groundwater monitoring point GW4 was sampled in July 2012 and January 2013 as per Condition 9.2.5 of the True Temper operating IPC licence. All samples were analysed for the parameters set out in Schedule 4(i) Groundwater Monitoring of the IPPC licence as well as for Petrol Range Organics (PRO’s), Mineral oil (MO) and Total Petroleum Hydrocarbons (TPH). Note that there are no ELV’s specified for any of the parameters in Schedule 4(i) or for the additional parameters PRO, MO and TPH.

Analytical results for both sampling rounds are discussed below:

o Diesel Range Organics – DRO were detected in the July monitoring

round – 2147.6 μg/L and in the January monitoring round 1783.1 μg/L. (2011 monitoring rounds – July 1440 ug/L: December 1320 ug/L).

o Volatile Organic Compounds – No VOC’s were detected above the laboratory Limit of Quantification (LOQ) in either monitoring round, except for the following:

Parameter (ug/L) July ‘12 January ‘13

Hexachlorobutadiene 8.0 65.7

Xylene - o 676.4 <0.5

Toulene <0.5 118.4

Tetrachloroethene <0.1 11.8

P Isopropyltoulene 21.5 <0.5

Naphthalene 59 118.3

1,2,4-trichlorobenzene <0.5 59.2

1,2,3-trichlorobenzene <0.5 69

Note that in a February 2010 monitoring assessment carried out by independent environmental consultants, the following compounds were detected above the laboratory detection limits in GW4: Toulene,



Ethyl Benzene, m & p Xylene, o-Xylene, Isopropyl Benzene, 135 Trimethylbenzene, 124 Trimethylbenzene and Napththalene. These compounds are indicative of weathered petrol associated with the former petrol tank (UST) in this area. Reference: “Groundwater Review Report” 49341826/CKRP0001 dated 16 March 2010. The True Tempering monitoring results from July 2012 and January 2013 generally concur with the results of the Environmental consultants assessment.

o PRO concentration - PRO were detected in the July 2012 monitoring

round, 24214 μg/L and in the January 2013 monitoring round, 27,265 μg/L. Note that in a February 2010 monitoring assessment carried out by independent environmental consultants, the PRO concentration was 31,398μg/L. These compounds are indicative of weathered petrol associated with the former petrol tank (UST) in this area. Reference: “Groundwater Review Report” 49341826/CKRP0001 dated 16 March 2010. PRO concentrations in the July 2010 and December 2010 monitoring rounds were 12750μg/L and 13800μg/L respectively and in the July 2011 and December 2011 6230 ug/L and 11,000 ug/L respectively.


laboratory Limit of Quantification (LOQ) of <10 μg/L in either monitoring round.

o TPH - TPH were detected in the July 2012 monitoring round

26,361 μg/L and in the January 2013 monitoring round 29,049 μg/L. 4.3.2 Groundwater monitoring of Foul Effluent Emissions

The previous system for treatment of Foul Effluent sewage was by way of septic tank which then flowed to percolation area/soakaway. The soakaway was drained using a land drainage system to an outflow point designated SW2. However, this has now been superseded by the installation in January 2005 of a Bord Na Mona “Puraflo” foul effluent treatment system and associated percolation area. The outflow is monitored by a groundwater monitoring point GW9, which is located down gradient of the site “Puraflo” Foul Effluent Treatment system. This monitoring point was installed at the request of the Environmental Protection Agency to monitor groundwater down-gradient of the “Puraflo” percolation area. The request post dated the issuing of the True Temper IPPC licence, and there are no official Emission Limit Values (ELV’s) attached to the parameters measured. Where applicable, True Temper insert for comparison the ELV’s for



those parameters assigned to SW1, reference Schedule 2(i) as per the True Temper IPPC licence.

As outlined in a Site Inspection Report by the Environmental Protection Agency dated 23rd November 2005, in addition to the groundwater monitoring parameters set out in Schedule 4(i) of the licence, ATT were also requested to monitor GW9 groundwater for the following parameters:

PRO’s, Major Ions and BOD, pH, Total Coliforms, Faecal Coliforms, aluminium, boron, cadmium, chromium, cobalt, iron, lead, manganese, molybdenum, mercury, nickel. In addition True Temper monitors GW9 for Major ions, BOD, COD, Potassium, Sodium, Copper and Zinc. Groundwater monitoring point GW9 was sampled by True Temper Ltd. in July 2012 and January 2013.

Analytical results for both sampling rounds are discussed below:

o Diesel Range Organics – No DRO were detected above the

laboratory Limit of Quantification (LOQ <10 ug/L) in either monitoring round.

o Volatile Organic Compounds – No VOC’s were detected above the

laboratory Limit of Quantification (LOQ) for each respective compound in any of the monitoring rounds except for the January round where the compounds 1,2,3-trichlorobenzene and Hexachlorobutadiene were measured at 0.6 μg/L each with LOQ of 0.5 μg/L each.

o Petrol Range Organics – No PRO were detected in the groundwater

sample above the laboratory Limit of Quantification (LOQ <10 ug/L) in the July monitoring round. PRO sample concentration was measured at 64.7 ug/L in the January monitoring round.


laboratory Limit of Quantification (LOQ) of <10 μg/L in the July round and measured 11.5 ug/L in the January round.

o TPH - No TPH were detected in the groundwater samples above the

laboratory Limit of Quantification (LOQ) of <10 μg/L in the July monitoring round and measured 76.2 ug/L in the January round.

o Major Ions – GW9 was analysed for chloride, fluoride, nitrate, nitrite,

orthophosphate, ammoniacal nitrogen and total kjeldahl nitrogen. The results were compared against the Draft Interim Guideline Values



(IGV’s) issued by the EPA. Elevated concentrations of these parameters would commonly be associated with sewage effluent.

The review of results indicate that concentrations of chloride, fluoride, nitrate and ammoniacal nitrogen are generally below their draft IGV thresholds except for the January monitoring round which detected chloride at a concentration of 35.2mg/L against draft IGV concentration of 30mg/L.

Concentrations of nitrite and orthophosphate exceeded their respective Draft IGV’s on both of the July and January monitoring rounds. No Total Kjeldahl Nitrogen was detected in the groundwater samples above the laboratory Limit of Quantification (LOQ) of <1 mg/L (Note that there is no threshold IGV given for total kjeldahl nitrogen).

o Metals – GW9 was analysed for potassium, sodium, boron,

aluminium, cadmium, chromium, cobalt, copper, iron, lead, manganese, molybdenum, mercury, nickel and zinc. The results were compared against the Draft Interim Guideline Values (IGV’s) issued by the EPA. The review of results indicate that concentrations of all metals are below their Draft IGV’s except for concentrations of Manganese in the July monitoring round 464.3μg/L and in the January round at a concentration of 382 ug/L compared to its Draft IGV of 50 ug/L.

Concentrations of iron in July, 377.5 μg/L and in January, 258.0 μg/L exceeded its draft IGV of 200 μg/L.

Elevated concentrations of iron and manganese are generally encountered in groundwater that has low dissolved oxygen levels and low to negative redox potential that is, reducing groundwater conditions. These parameters are not monitored, however, reducing groundwater conditions would typically be expected down-gradient of discharge from a sewage treatment system. The threshold values for iron and manganese are not based on toxicity but rather their organoleptic properties, as elevated concentrations of iron and manganese can lead to discolouration and staining.

o Biological Oxygen Demand – BOD was detected below the limit of

quantification (LOQ <1 mg/L) in both monitoring rounds.

o Total Coliforms and Faecal Coliforms (E.coli) – In the July 2012 monitoring round, total coliforms were detected at 18 mpn/100mls and Faecal coliforms (E.coli) were not detected - (0 mpn/100mls). In the January monitoring round, total coliforms were detected at 14 mpn/100mls and Faecal coliforms (E.coli) were detected at 1 mpn/100mls. (Draft IGV’s for both parameters is 0 mpn/100ml).



However, total coliforms can be present not only as a result of sewage effluent but are also present naturally in the subsurface forming part of the soil fauna.

Elevated total coliforms were previously detected in up-gradient production well BH02 and were attributed to agricultural activity up-gradient of the site and were a factor in this well being taken out of service. This indicates that background concentrations of elevated coliforms may, at least in part be linked to off-site sources. Faecal Coliforms (E.coli) were not detected in the July monitoring round and were detected in the January monitoring round at a concentration of 1 mpn/100ml. E.coli. are found in human or animal waste and so their presence is directly related to sewage effluent discharge.

o Chemical Oxygen Demand (COD) – COD results for GW9 ranged

from 521 mg/L in the July 2012 round of monitoring, to 150 mg/L in the January 2013 round. There is no corresponding Draft IGV for COD.

4.3.3 Drinking Water

Drinking Water was last sampled and analysed in July 2011 from a tap outlet by an external Environmental Laboratory Service company. The results indicated that the drinking water quality generally meets the 2007 Drinking Water regulations. The pH value was outside the lower end of the typical range (6.5 - 9.5) for Irish groundwater conditions at 5.8. This below-neutral pH reading is typical of a non-carbonate aquifer like the fine to medium grained sandstone encountered at True Temper. This slightly acidic groundwater condition may promote dissolution of metals from acquifer material (rock/soil). The water supply from on-site well BH02 has been switched off since May 2008 (See 2008 AER Section 4.3.3) and the plant now operates on groundwater supply from BH01 which is adequate and satisfactory for its present requirements.

4.4 Testing and Inspection of Underground Tanks and Pipelines and Bund Integrity Testing No bund or pipeline testing was undertaken in 2012. Note that since 2009/2010 the majority of the pipelines and tanks/interceptors on the test schedule had been taken out of service due to restructuring of the True Temper Ltd. business and operations. The diesel storage bunded area was cleaned and made environmentally inert and decommissioned. The lubrication oil storage bunded



area was also cleaned and decommissioned. Both bunded areas were emptied and cleaned by a licensed hazardous waste disposal/recovery contractor. The trade effluent sub-surface cooling water tanks and the 90 m3 trade effluent cooling water storage tank were cleaned and decommissioned in 2012. All tanks were emptied and cleaned by a licensed hazardous waste disposal/recovery contractor.

5.0 Waste and Waste Management 5.1 Introduction The waste generated on site at True Temper is primarily non-hazardous in nature,

comprising of scrap metal, timber/wood, wooden pallets, cardboard, paper, mixed packaging, plastic packaging and general waste. Hazardous waste generated, consists of small quantities of waste oil and oil contaminated waste solids cloths and absorbents. As previously outlined in this report, due to the restructuring and downgrading of the True Temper manufacturing operations, hazardous waste is significantly reduced.

Wood processing waste (wood chips and shavings) is disposed of on-site at True

Temper and used as a fuel source for an on-site 300kw wood chip biomass burner.

All waste is collected and disposed/recovered by licensed waste management

contractors.

5.2 Summary of Waste Statistics A summary of wastes generated on-site for the period January to December 2012

inclusive is presented in the PRTR (Pollutant Release and Transfer Register) Emissions Data XML Return file/workbook – See Appendix 5 to view copy of Workbook with page heading “Onsite Treatment and Offsite Transfers of Waste”.



6.0 Noise 6.1 Introduction

The predominant land use in the surrounding area to the True Temper facility is agricultural. The True Temper site operates during the daytime but is not operational during night-time. Section 8.1 of the True Temper operating IPC licence outlines the sound pressure limits (Leq, 15 mins) to be complied with (daytime 55 dB(A), night-time 45 dB(A)), and stipulates that activities on site may not give rise to noise levels off site which exceed these limits by more than 2 dB(A). In addition, no clearly audible tonal component or impulsive component is permitted in the noise emission from the activity at any noise sensitive location. The three designated noise sensitive locations are: N1 adjacent to the boundary of the nearest noise sensitive location to the

south of the True Temper site. N2 located at the entrance driveway to the nearest noise sensitive location to

the south-east of the True Temper site. N3 located to the north-east of the site at a point close to the boundary of a

noise sensitive property. True Temper Ltd. did not receive any complaints about noise levels in 2012. There is no requirement under its IPPC licence to monitor noise levels on the True Temper site.



7.0 Resource Consumption 7.1 Introduction

A comprehensive Energy Audit was carried out by Systems Optimisation Ltd. in March 2006. The data used in this section is based on information obtained from the energy audit. The utilisation of energy at True Temper can be broken down as follows:

Electrical energy – lighting, motive power (motors, fans) and various industrial appliances (compressor, pumps, etc.)

Liquified Petroleum Gas (LPG) – thermal energy – Paint curing oven and Warehouse heating system.

Diesel (Gas oil) – thermal energy – Office heating system.

Compressed Air – manufacturing and maintenance.

Other resource consumption includes groundwater extracted from two on-site wells, BH01 and BH02, which is used for all site water needs. In May 2008, well BH02 was disconnected as previously mentioned in Section 4.3.3 of this report and the site has been supplied satisfactorily by BH01 for all of its water requirements since then.

7.2 Electricity Usage

Annual electricity usage in KWh at the True Temper facility from 2002 to 2012 is illustrated in Figure 7.2

Fig.7.2 - Electricity consumption 2002 to 2012

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

676920

592206 528600

499690

496246475420

438900399533

282182

134957

102692

0

100000

200000

300000

400000

500000

600000

700000

800000

KW

h



There has been a declining rate in electricity usage since 2003 as indicated in Figure 7.2 and generally reflects the decline in manufacturing activity and the company organisational restructuring since 2009.

7.3 Diesel Usage Diesel (Gas oil) usage in litres at True Temper facility from 2002 to 2012 is

illustrated in Figure 7.3

Figure 7.3 - Diesel (Gas oil) usage 2002 to 2012

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

136500

74211

192000

199000 196000

155600

175950

135900

77566

155882563

0

50000

100000

150000

200000

250000

Lit

res

Diesel consumption at the True Temper facility has significantly further reduced in 2012 principally because of the elimination of the existing diesel-fired boiler heating system in the Warehouse building. The office administration building still utilises a diesel-fired heating system.



7.4 Liquid Petroleum Gas (LPG) Usage

Liquid Petroleum Gas (LPG) usage at the True Temper facility from 2002 to 2012 is illustrated in Figure 7.4

Figure 7.4 - Liquid Petroleum Gas (LPG) usage 2002 to 2012

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

2585511358

46887

192102

400000451550469410

513132567456

561740

584014

0

100000

200000

300000

400000

500000

600000

700000

Lit

res

LPG usage has reduced significantly since 2008 principally because of the introduction of the Boron Steel Project in March 2009, which eliminated the full- time requirement for the LPG-fired heat-treatment Tempering Oven process and the closure of the Forge shovel mill operation in July 2009. Usage has also reduced due to the continued decline in manufacturing volume and the company organisational restructuring since 2009. In 2012 there was very limited use of the powder painting and curing oven operation. The Pyrolysis Oven was not used in 2012. The increase in consumption over that in 2011 is attributed to the introduction of an LPG-fired radiant tube (infra red) heating system in the Warehouse building in October 2011, replacing the existing diesel-fired boiler heating system.



7.5 Water consumption

Water consumption at the True Temper facility is was previously utilised for Production and Domestic requirements, but is now only utilised for domestic requirements – administration office canteen, washing and WC facilities and main supply for Hydrant and Sprinkler fire suppression facilities. The on-site groundwater well BH01 supplies the True Temper site water requirements. Water abstracted from the well is not metred but it has been estimated that for the period January to December 2012 a total of approximately 90m3 was used.

7.6 Energy Efficiency Indices

Due to the cessation of shovel, spade and fork manufacturing in 2012, the energy efficiency indices calculated as per previous Annual Environmental Reports will not be undertaken for the 2012 report.



8. Environmental Incidents and Complaints 8.1 Complaints

There were no complaints received for the reporting period January to December 2012.

8.2 Incidents

There were no environmental incidents during the reporting period January to December 2012.

9. Review of Residuals Management Plan (RMP) True Temper Ltd. last updated their RMP for the site in November 2008. The

review brought the document in line with the EPA Guidance Document entitled “Guidance on Environmental Liability Risk Assessment, Residuals Management Plans and Financial Provisions”. There have been no changes at the facility in 2012 that would have a negative impact on the RMP.

10. Environmental Liabilities Risk Assessment

True Temper Ltd. has reviewed the current version of the ELRA for the site, which was first completed in 2005. The review brings the document in line with the EPA Guidance document entitled “Guidance on Environmental Liability Risk Assessment, Residuals Management Plans and Financial Provisions”. There have been no changes at the facility in 2012 that would have a negative impact on the current version of the ELRA.

True Temper has Environmental Liability Insurance cover in place.



11. Conclusion

True Temper Ltd. is pleased to present this Annual Environmental Report for calendar year 2012. As outlined in Section 1.3.3, the company undertook significant organisational restructuring in 2009 due to changing needs of the business resulting in the closure of the Forge Shovel Mill operation and the subsequent cessation of the limited amount of remaining forging activity of open-back shovels and finish forming of fork heads in early 2011. In parallel with this, there was a significant reduction in the remaining manufacturing-related operating activities/processes which continued through to, and during 2012. True Temper Ltd. initiated the process of surrendering their IPPC licence in November 2011 by requesting a Closure Audit proposal from an independent consultant. True Temper Ltd. commissioned this independent consultant to carry out an Independent Closure Audit (ICA) for the facility. An Audit of the facility was carried out in June 2012 with a follow up ICA report submitted to the Agency in August 2012. The findings of the audit were provided in this ICA report, outlining potential environmental impacts and highlighting corresponding corrective actions. The bulk of these corrective actions were undertaken in the final quarter of 2012. This is work in progress and a final grant of surrender of the True Temper Ltd. IPPC licence from the Environmental Protection Agency is expected in the first half of 2013.


______________________________________________________________________________ Annual Environmental Report (AER) 2010

Appendix 1 - Site Location Map

Surveyed 1841

Revised 1931

Levelled 1932

Scale:- 1:10,560Sc6la:- 1:10,560

Record PLACE Map

0 100 20O 400 600 800 1,000 Metres1 " " " " , ! l t l l .

h569414.577875

@6 inchcK063

L i c e n c e P e r m i t N o .

A R 0 0 7 8 4 0 6

Produced by National Map Seruices,The Court House Chambers,27129 Washington Street,Cork City, Co. CorkOn behaliof Ordnance Suryey lreland,Phoenix Park, Dublin 8.

Sdraionn atdirgeadh neamhUdaraithe coipcheartShuirbh6ireacht Ordan6istireann agusRialtas na hEireann.Unauthorised reprcduction infringes ordnaneSuruey Ireland and Govemment of lrelandcopyright.

Gach cead cosnamh. Ni ceadmhach aon chuidden fhoilseachan seo a ch6ipe6il, a atdhgeadh n6a tharchur in aon fhokm ne ar aon bhealach gancead i scribhinn roimh re 6 Uineiri an ch6ipchiri.All rjghts reserued. No part ofthis publication maybe copied, reproduced or transmitted in any formor by any means without the priorwrittenpemission of the @pyright owneE.

@ Suirbh6ireacht Ordanais Eireann. 2006@ Ordnance Surudv lreland. 2006'i,

It \

Plot Rei No. 1076017_1Plot Date 24-JAN-2006

0 350 700 2,100 2,800 3,500 Feet

SuNeyedRevisedLevelled

19972002 Rural PLACE Map

0 50 100 150 200 t etresl r , , r ' r r l l l l1 " " " ' l l l l

0 150 300 450 600 Feet

1:250O6291-A

L i c e n c e p e r m i t N o .

A R 0 0 7 8 4 0 6

;t:Sl,.),;3."uii, ,c14tJD

Produced by National l\4ap Seruices,The Court House Chambe6,27129 Washington Street,Cork City, Co. CorkOn behalf of Ordnance Suryey lreland,Phoenix Park, oublin 8.

Sdraionn atdirgeadh neamhudaraith€ c6ipcheartShuirbhdireacht ordan6isf ireann agusRialtas na hEireann.unauthorised reprcduction infringes OrdnanceSuruey lreland and Govemment of lrelandcopyright.

Gach cead msnamh. Ni ceadmhach aon chuidden fhoilseachan seo a ch6ipe6il, a at6irgeadh n6a tharchur in aon fhoirm na ar aon bhealach gancead i scribhinn roimh re 6 0in6iri an ch6ipchirt.All rights reserued. No part of this publication maybe copied, reproduced or transmitted in any fomor by any means without the prior writtenpermission of the mpyrightowneB.

Scale:- 1:2,500Sc6 la : - ' 1 : 2 ,500

Plot Ref. No. '1076017_1_1

Plot Date 24-JAN-2006

569414.577870

l-ffi:



Appendix 2 - Site Layout Plan



Appendix 3 – ISO 9001 Certificate



Appendix 4 – Organisational Chart /

Management Structure

OOrrggaanniissaattiioonnaall CChhaarrtt --AAmmeess TTrruuee TTeemmppeerr,, IIrreellaanndd AAss ooff 2266//1122//1122

IRELAND Sales Merchandisers

Gary Coyle Seamus Treacy Gabriel Leslie

Purchasing Officer Una McCarthy

Customer Service Administrators Trish O’Sullivan

Marzena Molumby

HR Executive Debra O Sullivan

(covering maternity leave for Joanne Fitzgerald)

Assembly/Dispatch Operatives x 6

(1 temp)

Financial Director Sean O’Mahony Managing Director

Credit Controller Evonne Kidney

Receptionist/ AP Administrator Clare Twohig

Marketing Executive

UK Sales Representative

Sales & Marketing Director Niall Nugent

Sales Manager Manager TBA

Garant Jean Gaudreault ATT



Appendix 5 – PRTR (Pollutant Release and Transfer Register) Emissions Data

| PRTR# : P0615 | Facility Name : True Temper Limited | Filename : P0615_2012 (1).xls | Return Year : 2012 | 3477 13/06/2013 11:25

Guidance to completing the PRTR workbook

Version 1.1.16

REFERENCE YEAR 2012

1. FACILITY IDENTIFICATIONParent Company Name True Temper Limited

Facility Name True Temper LimitedPRTR Identification Number P0615

Licence Number P0615-01

Waste or IPPC Classes of ActivityNo. class_name

3.2.2

The processing of iron and steel in forges, drawing plants and rolling mills where the production area exceeds 500 square metres, not included in paragraph 3.2.1.

Address 1 True Temper LtdAddress 2 Whites CrossAddress 3 CorkAddress 4

CorkCountry Ireland

Coordinates of Location -8.44430 51.9520River Basin District IESW

NACE Code 2445Main Economic Activity Other non-ferrous metal production

AER Returns Contact Name Tom ButlerAER Returns Contact Email Address [email protected]

AER Returns Contact Position Engineering and EHS consultantAER Returns Contact Telephone Number 0214 302433

AER Returns Contact Mobile Phone Number 086 8155 357AER Returns Contact Fax Number 0214 304621

Production Volume 0.0Production Volume Units

Number of Installations 1Number of Operating Hours in Year 1980

Number of Employees 17User Feedback/Comments

Web Address www.amestruetemper.com

2. PRTR CLASS ACTIVITIESActivity Number Activity Name50.1 General

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)Is it applicable? No

Have you been granted an exemption ?If applicable which activity class applies (as per

Schedule 2 of the regulations) ?Is the reduction scheme compliance route being

used ?

4. WASTE IMPORTED/ACCEPTED ONTO SITE Guidance on waste imported/accepted onto siteDo you import/accept waste onto your site for on-

site treatment (either recovery or disposal activities) ? No

This question is only applicable if you are an IPPC or Quarry site

AER Returns Workbook

4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : P0615 | Facility Name : True Temper Limited | Filename : P0615_2012 (1).xls | Return Year : 2012 | 13/06/2013 11:25

8 8 16 20 28 28 6 6 6 8 6 6 20

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Yea F (Fugitive) KG/Year0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITYA1-6 (Oven not used in

2012)

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 T (Total) KG/YearA (Accidental) KG/Year

F (Fugitive) KG/Year

02 Carbon monoxide (CO) E ESTIMATE 0.0 0.0 0.0 0.0 0.0 0.003 Carbon dioxide (CO2) E ESTIMATE 0.0 0.0 0.0 0.0 0.0 0.007 Non-methane volatile organic compounds (NMVOC) E ESTIMATE 0.0 0.0 0.0 0.0 0.0 0.008 Nitrogen oxides (NOx/NO2) E ESTIMATE 0.0 0.0 0.0 0.0 0.0 0.011 Sulphur oxides (SOx/SO2) E ESTIMATE 0.0 0.0 0.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)Please enter all quantities in this section in KGs

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Yea F (Fugitive) KG/Year0.0 0.0 0.0 0.0


Additional Data Requested from Landfill operators

Landfill: True Temper Limited

Please enter summary data on the quantities of methane flared and / or utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method CodeDesignation or

DescriptionFacility Total Capacity m3

per hourTotal estimated methane generation (as per sit

model) 0.0 N/AMethane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)Net methane emission (as reported in Section A

above) 0.0 N/A

RELEASES TO AIRPOLLUTANT METHOD

Method Used

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Method Used

Method UsedPOLLUTANT

RELEASES TO AIR

RELEASES TO AIRMETHOD

POLLUTANT METHOD

Method Used

4.2 RELEASES TO WATERS Link to previous years emissions data | PRTR# : P0615 | Facility Name : True Temper Limited | Filename : P0615_2012 (1).xls | Return Year : 2012 | 13/06/2013 11:26

8 9 17 24 32 43 6 6 6 6 6 6 43SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility

Please enter all quantities in this section in KGsQUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.00.0 0.0 0.0 0.0


SECTION B : REMAINING PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year20 Copper and compounds (as Cu) M ESTIMATE 0.186 0.186 0.0 0.018 Cadmium and compounds (as Cd) M ESTIMATE 0.007 0.007 0.0 0.019 Chromium and compounds (as Cr) M ESTIMATE 0.037 0.037 0.0 0.023 Lead and compounds (as Pb) M ESTIMATE 0.013 0.013 0.0 0.021 Mercury and compounds (as Hg) M ESTIMATE 0.001 0.001 0.0 0.022 Nickel and compounds (as Ni) M ESTIMATE 0.048 0.048 0.0 0.076 Total organic carbon (TOC) (as total C or COD/3) M ESTIMATE 112.0 112.0 0.0 0.024 Zinc and compounds (as Zn) M ESTIMATE 0.633 0.633 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)Please enter all quantities in this section in KGs

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0

303 BOD M ESTIMATE 37.21 37.21 0.0 0.0374 Boron M ESTIMATE 0.744 0.744 0.0 0.0355 Aluminium M ESTIMATE 0.551 0.551 0.0 0.0357 Iron M ESTIMATE 2.714 2.714 0.0 0.0321 Manganese (as Mn) M ESTIMATE 0.846 0.846 0.0 0.0368 Molybdenum M ESTIMATE 0.037 0.037 0.0 0.0341 Sodium M ESTIMATE 738.59 738.59 0.0 0.0240 Suspended Solids M ESTIMATE 279.063 279.063 0.0 0.0338 Potassium M ESTIMATE 91.16 91.16 0.0 0.0356 Cobalt M ESTIMATE 0.037 0.037 0.0 0.0309 Diesel range organics M ESTIMATE 0.398 0.398 0.0 0.0


RELEASES TO WATERS

Method Used

RELEASES TO WATERS

RELEASES TO WATERS

Method Used

POLLUTANTMethod Used

POLLUTANT

POLLUTANT

4.3 RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data | PRTR# : P0615 | Facility Name : True Temper Limited | Filename : P0615_2012 (1).xls | Return Yea 13/06/2013 11:27

8 8 16 16 6 6 6 6 1SECTION A : PRTR POLLUTANTS


No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your LicencePlease enter all quantities in this section in KGs

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

Method Used

Method Used

POLLUTANT METHOD

POLLUTANT METHOD

4.4 RELEASES TO LAND Link to previous years emissions data | PRTR# : P0615 | Facility Name : True Temper Limited | Filename : P0615_2012 (1).xls | Return Year : 2012 | 13/06/2013 11:27

8 8 16 16 6 6 6 6SECTION A : PRTR POLLUTANTS


No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)Please enter all quantities in this section in KGs

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.0


POLLUTANT METHODMethod Used

RELEASES TO LAND

RELEASES TO LAND

POLLUTANT METHODMethod Used

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0615 | Facility Name : True Temper Limited | Filename : P0615_2012 (1).xls | Return Year : 2012 | 13/06/2013 11:27

5 19 Please enter all quantities on this sheet in Tonnes 0

Quantity (Tonnes per

Year)

Haz Waste : Name and Licence/Permit No of Next DestinationFacility Non Haz Waste:

Name and Licence/Permit No of Recover/Disposer

Haz Waste : Address of Next Destination Facility

Non Haz Waste: Address of Recover/Disposer

Name and License / Permit No. and Address of Final Recoverer / Disposer

(HAZARDOUS WASTE ONLY)

Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Transfer DestinationEuropean Waste

Code Hazardous Quantity T/Year Description of Waste

Waste Treatment Operation M/C/E Method Used

Location of Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

To Other Countries 17 04 05 No 11.0 iron and steel R4 M Weighed Abroad

Cork Metal Co.Ltd.,WFP-CK-10-0067-01 A1 / WCP LK 08 589 01

Dublin Hill ,Cork.,".",".",Ireland

Within the Country 13 05 07 Yes 2.64 oily water from oil/water separators D9 M Weighed Offsite in Ireland

Lehane Environmental and Ind.Services,WCP-CK-08-0574-02

Unit 5 ,Wallingstown Ind.Estate ,Little Island ,Co.Cork.,Ireland

Rilta Environmental Ltd.,192-3,Block 402,Grants Drive,Greenouge Business Pk.,Rathcoole Co.Dublin.,Ireland

Block 402,Grants Drive,Greenouge Business Pk.,Rathcoole Co.Dublin.,Ireland

Within the Country 13 05 07 Yes 10.8 oily water from oil/water separators R13 M Weighed Offsite in IrelandEnva Ireland Ltd.,WCP-DC-08-1116-01 / WO184-1

Clonminam Ind.Estate ,Portlaoise ,Co.Laoise,".",Ireland

Enva Ireland Ltd.,WCP-DC-08-1116-01,Clonminam Ind.Estate,Portlaoise,Co.Laois,".",Ireland

Clonminam Ind.Estate,Portlaoise,Co.Laois,".",Ireland

Within the Country 13 07 03 Yes 8.38 other fuels (including mixtures) R13 M Weighed Offsite in IrelandEnva Ireland Ltd.,WCP-DC-08-1116-01 / WO184-1


Enva Ireland Ltd.,WCP-DC-08-1116-01,Clonminam Ind.Estate,Portlaoise,Co.Laois,".",Ireland


Within the Country 17 05 04 No 4.98soil and stones other than those mentioned in 17 05 03 R13 M Weighed Offsite in Ireland

Enva Ireland Ltd.,WCP-DC-08-1116-01 / WO184-1


Within the Country 13 07 01 Yes 2.12 fuel oil and diesel R13 M Weighed Offsite in IrelandEnva Ireland Ltd.,WCP-DC-08-1116-01 / WO184-1


Enva Ireland Ltd.,WCP-DC-08-1116-01 / WO184-1,Clonminam Ind.Estate,Portlaoise,Co.Laois,".",Ireland


To Other Countries 17 06 05 Yes 0.5construction materials containing asbestos (18) D15 M Weighed Abroad

Oxigen Commercial Ltd.,WCP-DC-08-1106-02

Merrywell Industrial Est. ,Ballymount Road Lower ,Dublin 22.,.,Ireland

Buhck GmbH & Co.KG,eg0019,Sudring 38 ,21465 Wentorf ,.,.,Germany

Sudring 38 ,21465 Wentorf ,.,.,Germany

Within the Country 19 12 09 No 15.24 minerals (for example sand, stones) D1 M Weighed Offsite in Ireland

Greenstar Recycling (Munster) Ltd. ,WO136-02 / WCP-CK-10-0771-03

Sarsfields Court Ind.Est ,Glanmire ,Cork.,".",Ireland

Within the Country 20 03 07 No 14.42 bulky waste D1 M Weighed Offsite in Ireland



Within the Country 20 01 01 No 0.72 paper and cardboard R13 M Weighed Offsite in Ireland



Within the Country 15 01 06 No 0.31 mixed packaging R13 M Weighed Offsite in Ireland



Within the Country 17 02 01 No 3.0 wood R13 M Weighed Offsite in Ireland



Within the Country 15 01 03 No 2.54 wooden packaging R13 M Weighed Offsite in Ireland



Within the Country 20 01 38 No 2.34 wood other than that mentioned in 20 01 37 R13 M Weighed Offsite in Ireland



* Select a row by double-clicking the Description of Waste then click the delete button

Link to previous years waste dataLink to previous years waste summary data & percentage change

Method Used



Appendix 6 – Glossary of Terms AER Annual Environmental Report

AST Above Ground Storage Tank

BATNEEC Best Available Technology Not Entailing Excessive Cost

BOD Biochemical Oxygen Demand

COD Chemical Oxygen Demand

CO Carbon Monoxide

DB Decibels (A weighted)

DRO Diesel range Organics

ELV Emission Limit Value

EMP Environmental Management Programme

EPA Environmental Protection Agency

EWC European Waste Catalogue (94/3/EEC)

IPC Integrated Prevention and Pollution Control

LOD Limit Of Detection

LOQ Limit of Quantification

MO Mineral oil

PER Pollution Emission Register

ppm Parts Per Million

PRO Petrol Range Organics

PRTR Pollution and Release Transfer Register

SW1 Surface Discharge 1

TOC Total Organic Carbon

TPH Total Petroleum Hydrocarbons

VOC Volatile Organic Compound

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