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Annual Environmental Report for Calendar Year 2010 True Temper Limited, trading as Ames True Temper, Whites Cross, Cork. IPC 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 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 21 2.6 Pollution Emission Register Report 25 2.6.1 General 25 3. Emissions to Atmosphere 26 3.1 General 26 3.2 Summary of Compliance / Non-Compliance 26 4. Emissions to Water 28 4.1 General 28 4.2 Summary of Surface Water Emission Monitoring Results 28 4.3 Groundwater Monitoring 29 4.3.1 Groundwater Monitoring Results 30 4.3.2 Groundwater Monitoring of Foul Effluent Emissions 31 4.3.3 Foul Effluent Water Quality 34 4.3.4 Drinking Water 35 4.4 Testing and Inspection of Underground Tanks and Pipelines And Bund Integrity Testing 35 5. Waste and Waste Management 36 5.1 Introduction 36 5.2 Summary of Waste Statistics 36 6. Noise 43 6.1 Introduction 43 7. Resource Consumption 44 7.1 Introduction 44 7.2 Electricity Usage 44 7.3 Diesel Usage 45 7.4 LPG Usage 46

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

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Contents Section Page No.

7.5 Water Consumption 46 7.6 Energy Efficiency Indices 46

8. Environmental Incidents and Complaints 47

8.1 Complaints 47 8.2 Incidents 47

9. Review of Residuals Management Plan 47 10. Environmental Liabilities Risk Assessment 48 Appendix 1 Site Location Map Appendix 2 Site Layout Plan Appendix 3 ISO Certificate Appendix 4 Organisational Structure Appendix 5 Glossary of Terms Appendix 6 Pyrolysis Oven incident Appendix 7 Report oily soil sampling

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

______________________________________________________________________________ Annual Environmental Report (AER) 2010 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 Control (IPC) Licence Register No. P0615-01 and details the environmental performance at the site for the period January to December 2010.

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 6th 2003. National Grid Reference: E1695 N0778

Class Description: Class 7.2.1: “The processing of iron and steel in forges, drawing plants and rolling mills where the production area exceeds 500 square metres”.

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 2010. The primary products manufactured include lawn and garden, agricultural and contractor non-powered 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, Wheelbarrows, garden carts, hose reels, cutting tools, striking tools and flower pots. The activities/processes undertaken at the True Temper site can be summarised into six operations, namely, 1. Forging of steel blades and heads 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 are divided into the following areas: Building 1: Administration Offices 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 including loading bay, a maintenance workshop, engineering offices and a canteen.

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. As outlined in last years Annual Environmental 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. This 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. Note that this closure of the Forge Shovel Mill operation has resulted in the switching off and “mothballing” of all associated machinery and equipment relating to the Shovel Mill section only. This situation remained in 2010 and is likely to remain for the foreseeable future. The only manufacturing undertaken in 2010 comprised a very limited amount of the following activities: 1. Hollowback shovel and Fork/Rake manufacture 2. Shotblasting 3. Powder painting 4. Handle processing 5. Assembly and Packaging of finished products. True Temper Ltd. also took out of service their main workforce canteen facility and relocated remaining workforce to office canteen facility. Warehousing and distribution of finished products will continue as the main core activity at the True Temper facility. True Temper Ltd. considered surrendering their IPC licence in 2010 in light of the above developments and in particular the cessation of the Forge Shovel Mill operation. It is envisaged that licence surrender will be initiated in 2011.



2. Management of the Activity 2.1 Environmental Management System

An Environmental Management System (EMS) is required under Condition 2.1 of its operating IPC 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 management structure at True Temper Ltd. (trading as Ames True Temper) is presented in Appendix 4 – Organisational Chart as of January 2010 and Organisational Chart as of December 2010.

2.3 Schedule of Environmental Objectives and Targets

The schedule of Environmental Objectives and Targets submitted as part of the 2009 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 2010. The status column in Table 2.3.1 has been updated to reflect project progress in 2010.

2.4 Environmental Management Programme Report Condition 2.3 of the True Temper Ltd. IPC licence requires the submission of an Environmental Management Programme (EMP) report, as part of the AER for the reporting period January to December 2010. 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 2010).

True Temper Ltd. completed the following site infrastructure and environmental improvement projects in 2010: 1. Repair / Relining of ESB Transformer room roof. 2. Upgrade of Facility intruder alarm system.



Table 2.3.1 – Schedule of Environmental Objectives and Targets for Calendar Year 2010 (presented in 2009 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.

Install a new oil:water interceptor to replace temporary hired interceptor. Set up monitoring schedule for waste water released from overground oil:water separator.

Not complete - deferred Not complete

OB3

Identify all opportunities for energy use reduction and efficiency

Conduct feasibility study for upgrading the existing space heating system used for the Assembly/Distribution Building (Building 2) with a more efficient and economical alternative.

Eliminate compressed air leaks.

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

Complete 90% complete Not complete

OB4

Recycling of waste material off-site

Review compliance with the 2007 Waste Management Packaging Regulations.

Undertake analysis of waste ash from Pyrolysis Oven operation.

Complete Not complete

OB9

Secondary containment improvements

Clean, make environmentally inert and decommission “older” bunded area.

Provide spill protection for diesel fuel dispensing nozzle and

Not complete



EMP No.


for main diesel fill point. Provide spill protection for main diesel re-fill point

Install new Trade Effluent cooling water storage tank of smaller capacity.

Set up test schedule for bund leakage detection double-skin storage tanks.

Not complete Complete Not complete-deferred. Complete

OB10

ISO 14001

Assess the viability of ISO 14001 certification in 2010 in light of prevailing economic and financial circumstances.

Complete

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. Carry out independent assessment of GW4 monitoring data with particular regard to petrol range hydrocarbon and volatile organic compound data and its impact on site groundwater.

Complete (on-going) Complete

OB12

Testing of Underground pipework

Carry out testing on underground pipework, tanks, oil interceptors and all underground effluent and sewer pipes.

Not complete

OB13

Groundwater monitoring of final effluent from wastewater treatment plant

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

Complete (ongoing)



EMP No.


Conduct independent assessment of GW9 monitoring results to determine the efficiency of the foul effluent treatment system.

Complete

OB14

Audits

Train internal Auditors on conducting environmental audits. Set up a programme of regular internal audits using these trained auditors.

Not complete Not complete

OB15

Water supply

To take more samples and do more monitoring to determine quality of water from wells.

Not complete

OB18

Firewater retention

Monitor compliance and effectiveness of fire risk management programme

Complete (on-going)

OB20

PCB’s

Review fluorescent lighting ballasts to ascertain whether there are any on-site that contain PCB’s.

Not complete

OB21

Updated Environmental Procedures

Review and update all remaining procedures for environmental operations and provide training for personnel to implement procedures.

Complete



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 IPC licence.

Stage Project Area Time Scale Responsibility 1 Install a new oil:water interceptor to

replace temporary hired interceptor Sep. 2010 Engineering

2 Set up monitoring schedule for waste water released from over-ground oil:water separator.

May 2010 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 IPC 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. Accumulated water from the diesel fuel storage bunded area was discharged through the below ground interceptor. True Temper are currently using an above ground oil:water separator/interceptor following observation of a crack in the floor of the third chamber of the existing below ground oil:water interceptor. It was planned to install a new below ground interceptor by September 2010, however the project was deferred due to financial constraints. Also it is envisaged that



diesel storage /supply in this area may no longer be a requirement in 2011 due to further company restructuring of operations, hence there may be no requirement for an oil:water separator, new or existing (overground) going forward in 2011. A monitoring schedule for waste water released from the over-ground oil:water separator has not yet been set up. Waste water emission point SW1 (from site) is monitored bi-annually as part of the facility operating IPC licence and was additionally monitored by the Environmental Protection Agency on two separate occasions in 2010.Monitoring results for Diesel range Organics (DRO) were well below the licence ELV on all occasions.

Summary of work to do in the forthcoming 2011 EMP: It is envisaged that further restructuring operations at True Temper Ltd. will result in diminishing diesel (gas oil) fuel requirements going forward. Based on this, the diesel storage in this area will no longer be a requirement, hence True Temper plan to defer installation of a new oil:water interceptor in 2011 and will monitor the situation going forward. Biannual monitoring of groundwater and surface water discharge will continue as required by the True Temper operating IPC licence. Decommission and make environmentally inert main diesel storage/supply area by July 2011.

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.

Stage Project Area Time Scale Responsibility 1 Conduct feasibility study for upgrading

the existing space heating system used for the Assembly/Distribution building (Building 2) with a more efficient and economical alternative.

Sep.2010 Engineering



2 Eliminate compressed air leaks. Sep.2010 Engineering 3 Examine night-time electricity usage with

a view to reducing energy use. July 2010 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: An investigative study was undertaken to determine the options available to introduce a more energy efficient heating system for the Assembly/Distribution building as an alternative to the existing diesel (gas oil) fired boiler heating system. The proposed project (gas-fired radiant heating option) is included in the Capital expenditure programme for FY2011. Approximately 90% of compressed air leaks have been eliminated predominantly due to the shutdown of the Forge manufacturing facility.

Summary of work to do in the forthcoming 2011 EMP: Implement upgraded and more energy efficient heating system in the Assembly/Distribution building as per Capital expenditure programme for FY2011, and with corresponding elimination of requirement of diesel (gas oil) fuel. Examine night-time electricity usage with a view to reducing energy use. Eliminate remaining compressed air leaks.

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

Stage Project Area Time Scale Responsibility 1 Review compliance with the 2007 Waste

Management Packaging regulations June 2010 Engineering



2 Undertake analysis of Waste ash from Pyrolysis Oven.


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 quantity of packaging waste produced/supplied by the company onto the Irish Market. True Temper will need to self-comply or join Repak. Summary of work to do in the forthcoming 2011 EMP:

Undertake analysis of waste ash from Pyrolysis Oven operation. Company will need to self-comply or join Repak to comply with the 2007 Waste Packaging Regulations. 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 • Improve the environmental performance of the company. • Comply with the requirements of the operating IPC licence.

Stage Project Area Time Scale Responsibility 1 Clean, make environmentally inert and

decommission “older” bunded area. June 2010 Engineering

2 Provide spill protection for diesel fuel dispensing nozzle and for main diesel fill point.




3 Provide spill protection for main diesel re-fill point.


4 Install new Trade Effluent cooling water storage tank of smaller capacity.

Aug. 2010 Engineering

5 Set up test schedule for bund leakage detection double-skin storage tanks.

July 2010 Engineering

Project Summary: Eliminate environmental impact of bund leakage and fuel spills. Summary of work completed in the previous EMP: Spill protection for diesel (gas oil) refill/replenishing point.

Summary of work to do in the forthcoming 2011 EMP:

As previously outlined, due to the restructuring and downsizing of the True Temper manufacturing operations and due to diminishing diesel (gas oil) fuel and lubrication oil requirements by True Temper Ltd. going forward, it is envisaged that diesel storage /supply and lubrication oil storage/supply in the existing bunded storage areas may no longer be a requirement in 2011, will which result in the following:

• decommissioning of the double-skin 10,000 litre capacity diesel AST, hence there will be no requirement for implementation of test schedule for bund testing (leakage detection) double-skin storage tanks.

• Decommissioning of 2,500 litre waste oil storage tank.

• Clean and make environmentally inert recently upgraded diesel

storage/supply bunded area.

• Clean, make environmentally inert and decommission “older” diesel storage bunded area.

• Provide spill protection for fuel dispensing nozzle.

• Decommissioning of two lubrication oil storage tanks.

• Clean and make environmentally inert existing lubrication oil storage

bunded area.

• Install new Trade Effluent cooling water storage tank of smaller capacity – See Objective 12 re: decommissioning of existing Trade Effluent cooling water storage tank and elimination of requirement for new tank.



OBJECTIVE OB10: ISO 14001 Overall Target: To obtain accreditation for ISO 14001.

Scheduled Benefits:

• ISO 14001 is an internationally recognised standard that would further improve the image of the company.

• Improve the environmental performance of the company. • Could potentially result in making the company more efficient and

profitable. Stage Project Area Time Scale Responsibility 1 Assess the viability of ISO 14001

certification in 2010 in light of prevailing economic and financial circumstances.

October 2010 Engineering

Project Summary: True Temper is planning to conduct a pre-audit of their current EMS against the requirements of the ISO 14001 standard to highlight where they need to make improvements to their system. Summary of work completed in the previous EMP: Due to further redundancies in 2010 and the reallocation of remaining resources, this task was deferred. Summary of work to do in the forthcoming 2011 EMP: True Temper will assess the viability of ISO 14001 certification in 2011 in light of current resource availability and financial circumstances. 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. Stage Project Area Time Scale Responsibility 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 2010 (on-going)

Engineering

2 Carry out independent assessment of GW4 monitoring data with particular regard to petrol range hydrocarbon and volatile organic compound data and its impact on site groundwater.

March 2010 Engineering

Project Summary: True Temper conducts groundwater monitoring bi-annually as requested by its IPC 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 2010. An independent assessment of GW4 monitoring data with particular regard to petrol range hydrocarbon and volatile organic compound data and its impact on site groundwater was carried out by environmental consultants on behalf of True Temper Ltd. The results of this assessment were issued to the Agency.

Summary of work to do in the forthcoming 2011 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 IPC licence to

undertake a programme of testing and inspection of underground tanks and pipelines.

• Improve the environmental performance of the company. Stage Project Area Time Scale Responsibility 1 Carry out testing of underground

pipework, tanks, oil interceptors and all underground effluent and sewer pipes.

November 2010 Engineering

Project Summary: True Temper is planning to carry out hydraulic testing on tanks and oil interceptors, while underground pipelines will be pressure tested by an approved contractor. Summary of work completed in the previous EMP: No additional work other than that reported in the 2007 AER was conducted in 2010. Note that since 2007 the majority of the pipelines and tanks/interceptors on the test schedule have been taken out of service due to restructuring of the True Temper Ltd. business and operations.

Summary of work to do in the forthcoming 2011 EMP: Test underground pipework still in service by June 2011 – foul effluent/sewer pipeline. Decommission trade-effluent water settling tanks and decommission trade effluent cooling water storage tank.

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. • Improve the environmental performance of the company.

Stage Project Area Time Scale Responsibility 1 Continue bi-annual monitoring of GW9

and investigate fluctuations in analytical results.

December 2010.

Engineering

2 Conduct independent assessment of GW9 monitoring results to determine the efficiency of the foul effluent treatment system.

March 2010. Engineering

Project Summary: True Temper have previously monitored GW9 but are planning to set a programme for monitoring the quality of the final effluent from the wastewater treatment plant that treats domestic wastewater (washroom facilities/canteen) on site on an annual basis.

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 2010. An independent assessment of GW9 to determine the efficiency of the foul effluent treatment system and to assess the impact if any on site groundwater was carried out by environmental consultants on behalf of True Temper Ltd. The results of this assessment were issued to the Agency.

Summary of work to do in the forthcoming 2011 EMP: True Temper will continue bi-annual monitoring of GW9 and assessment of analytical results.



OBJECTIVE OB14: Environmental Audits Overall Target: Train internal Auditors on conducting environmental audits. Scheduled Benefits:

• Establish good environmental practice. • Improve the environmental performance of the company.

Stage Project Area Time Scale Responsibility 1 Train internal Auditors on conducting

environmental audits. Sep 2010 Engineering

2 Set up programme of regular internal audits using these trained auditors

Sep 2010 Engineering

Project Summary: True Temper are planning to put procedures in place to carry out regular internal environmental auditing programmes so that standards can be set and improvements made to support the overall environmental performance of the company.

Summary of work completed in the previous EMP: True Temper had planned to train two auditors in 2010, however due to further redundancies in 2010 and reallocation of remaining resources, this task was not completed.

Summary of work to do in the forthcoming 2011 EMP: As previously mentioned in this report, True Temper Ltd. is considering surrendering their IPC licence in 2011 in light of recent restructuring developments in their business and will put on hold the training of internal auditors. This objective will be removed from the proposed 2011 Schedule of Environmental Objectives and Targets. In the interim, auditing will be managed and conducted by the True Temper Ltd. Engineering and EHS consultant.



OBJECTIVE OB15: Water supply Overall Target: Take further water samples and carry out further monitoring to determine the quality of water from the water supply wells. Scheduled Benefits:

• Establish good environmental practice. • Improve quality of water supplied on site

Stage Project Area Time Scale Responsibility 1 To take more samples and do more

monitoring to determine quality of water from wells.

July 2010. Engineering Manager

Project Summary: True Temper plan to take samples from the existing on-site water supply wells and send them for analysis. The results will indicate the quality of the site drinking water and if the water meets existing EU directives and Irish guidelines on drinking water standards.

Summary of work completed in the previous EMP: True Temper obtains all of its water requirements including its drinking water from two on-site wells BH-01 and BH-02 located on the northern site boundary. BH-02 has been disconnected since May 2008 because of coliform contamination. The site is satisfactorily supplied by BH-01. However, no further samples were taken from either well in 2010.

Summary of work to do in the forthcoming 2011 EMP: True Temper plan to sample both wells by July 2011.



OBJECTIVE OB18: Firewater retention Overall Target: Implement firewater risk management programme. Scheduled Benefits:

• Establish good environmental practice. • Reduce the environmental risk rating of Building 2 –

Assembly/Warehouse building. Stage Project Area Time Scale Responsibility 1 Monitor compliance and effectiveness of

fire risk management programme. December 2010 (on-going).

Engineering

Project Summary: True Temper engaged the services of a consultant to conduct a firewater risk assessment of its facility at Whites Cross. The assessment was prepared with due regard to the EPA’s “Guidance Note to Industry on the requirements for Firewater Retention Facilities”, currently in draft form (1995). A specific risk assessment was prepared as part of the overall project and included the environmental risk posed by fire occurring at the site. A risk assessment (as defined in the EPA Guidance Notes) can be defined as an assessment of the risk that an industrial facility poses to the environment during a fire that brings firewater into contact with operations or substances that would cause significant pollution. Summary of work completed in the previous EMP: True Temper has completed a Fire Risk Management Programme.

Summary of work to do in the forthcoming 2011 EMP: This objective is now considered complete. However, the programme will be monitored for compliance and effectiveness during 2011.



OBJECTIVE OB20: Polychlorinated Bi-phenyls (PCB’s) Overall Target: Review fluorescent lighting ballasts to ascertain whether there are any on-site that contain PCB’s. Scheduled Benefits:

• Establish good environmental practice. • Comply with legislative requirements.

Stage Project Area Time Scale Responsibility 1 Review fluorescent lighting ballasts to

ascertain whether there are any on-site that contain PCB’s. .

Sep 2010. Engineering

Project Summary: There is a legal requirement on holders of PCB’s greater than 5 litres to dispose of the PCB holding by a licensed hazardous waste disposal contractor by the end of 2010. Summary of work completed in the previous EMP: It is unlikely that any of the fluorescent lighting ballasts contain any PCB’s, however True Temper has yet to complete this task.

Summary of work to do in the forthcoming 2011 EMP: True Temper plan to have this task completed by September 2011.

OBJECTIVE OB21: Update Environmental Procedures Overall Target: Ensure that Environmental procedures are updated and relevant and that staff have received appropriate training on specific procedures.



Scheduled Benefits:

• Establish good environmental practice. • Reduce the environmental risk. • Environmentally aware staff.

Stage Project Area Time Scale Responsibility 1 Review and update all procedures for

environmental operations and provide training for personnel to implement procedures. .

July 2010. Engineering

Project Summary: True Temper plans to review all their procedures with environmental significance and will provide training to staff on all updated procedures. Summary of work completed in the previous EMP: The majority of environmental procedures applicable to the site were completed in 2010 and appropriate training given to those responsible. However this will be monitored on an on-going basis when procedures will need review and updating and appropriate training required.

Summary of work to do in the forthcoming 2011 EMP: This objective is now considered complete.

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 2011 EMP” detailed in Section 2.4.1 will form the Environmental Management Programme (EMP) for 2011.



Table 2.5.1 – Proposed Schedule of Environmental Objectives and Targets for Calendar Year 2011 EMP No.

Objective Targets Completion Date

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.

July 2011

OB3

Identify all opportunities for energy use reduction and efficiency

Implement upgraded and more energy efficient heating system in the Assembly/Distribution building.

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

Eliminate remaining compressed air leaks.

September 2011 September 2011 August 2011

OB4

Recycling of waste material off-site

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

Undertake analysis of waste ash from Pyrolysis Oven operation.

July 2011 June 2011

OB9

Secondary containment improvements

Clean, make environmentally inert and decommission “older” bunded area.

Provide spill protection for diesel fuel dispensing nozzle. Decommission 10,000 litre diesel storage tank

August 2011 June 2011 August 2011



EMP No.


Secondary containment improvements (cont’d)

Decommission 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.

August 2011 August 2011 August 2011 August 2011

OB10

ISO 14001

Assess the viability of ISO 14001 certification in 2011 in light of resource availability and financial circumstances.

October 2011

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.


OB12

Testing of Underground pipework

Carry out testing on remaining underground pipework, tanks, oil interceptors and all underground effluent and sewer pipes. Decommission trade-effluent water settling tanks and decommission trade effluent cooling water storage tank.

June 2011 September 2011

OB13

Groundwater monitoring of final effluent from wastewater treatment plant.

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


OB15

Water supply

To take more samples and do more monitoring to determine quality of water from wells.

July 2011



EMP No.


OB20

PCB’s

Review fluorescent lighting ballasts to ascertain whether there are any on-site that contain PCB’s.

September 2011



2.6 Pollution Emission Register Report 2.6.1 General

True Temper are required under Condition 2.4.1 of their IPC 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 2010 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 to the EPA independently of this AER.



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. The two main point sources of emissions which have been assigned Emission Limit Values (ELV’s) by the EPA and which are referenced in the operating IPC 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 IPC 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.



True Temper Ltd. wishes to note in this Annual Environmental Report that due to changing needs of their business, one of its main manufacturing processes in its Steel Forging facility – the 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. IPC Licence Application Form, sub heading “Shovel Manufacture”.

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

Prior to 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 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. Monitoring of Emission Point Reference No. A1-6 was not carried out in 2010 and is overdue. However, as previously mentioned in this report, True Temper Ltd. manufacturing is being phased out and as a result there was a very limited requirement for the powder coating/painting activity in 2010 which resulted in diminished requirement (activity/use) for the Pyrolysis Oven, Emission Point Reference No. A1-6. The oven was only periodically in use for approximately 160 hours over CY2010. With regard to the True Temper AER/PRTR Electronic Reporting Workbook (AER Returns Worksheet/Spreadsheet) reporting emissions and waste transfers, that for the purposes of calculation for 4.1 “Releases to Air”, we have used as a very conservative estimate, 50% of 2009 operating hours which equates to a “calculation figure” of 360 operating hours for 2010 and the corresponding values recorded for 2009 monitoring.



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 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. This closure effectively eliminated the requirement for the trade effluent/cooling water system except for very limited use in fork manufacture in 2010.

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. However, as previously stated, process/trade effluent cooling water is recycled through a trade effluent/water cooling system and to date there has been no requirement for batch discharging from the trade effluent/cooling water storage tank. 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 carried out by True Temper Ltd. at SW1 in 2010, the first round in July and the second in December. Two further rounds of monitoring at SW1 were carried out by the EPA in February and September as a part of a monitoring visit. Analytical results for all four rounds are discussed below:

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

laboratory detection limit (<2 mg/L) for the True Temper July and December rounds, while the February and September rounds (EPA) were 1.4 and 19.0 mg/L respectively. The IPC licence ELV for BOD is 5mg/L.

• Suspended Solids (SS) – SS was not detected above the laboratory detection

limit for all rounds (<5 mg/L) which is below the IPC licence ELV for SS of 25 mg/l.

• Diesel Range Organics (DRO) – no DRO’s were detected in the surface water

sample above the method detection limit in both the True Temper July and December monitoring rounds and the EPA February monitoring round (<10 µg/L). The EPA September round of monitoring detected DRO at 200 µg/L. The IPC licence ELV for DRO’s is 1000 µg/L.

• pH values measured from the surface water samples from all four rounds

were in the range was 7.00 to 7.80, all of which are within the IPC licence ELV for pH of between 6-9.

• Metals – Copper was not detected above the laboratory detection limit (<5

µg/L) in the February (EPA) monitoring round. In the True Temper July monitoring round, Copper was detected at 10µg/L while in the September (EPA) monitoring round Copper was detected at 12µg/L. In the True Temper December monitoring round, Copper was detected at 5µg/L. The IPC licence ELV for Copper is 5µg/L.

• Metals – Zinc was detected at 31µg/L in the February (EPA) monitoring round.

In the True Temper July monitoring round, Zinc was detected at 25.5µg/L while in the September (EPA) monitoring round Zinc was detected at 38µg/L. In the True Temper December monitoring round, Zinc was detected at 24.1µg/L. The IPC licence ELV for Zinc is 30µg/L.

4.3 Groundwater monitoring

Condition 9.2.5 of the operating IPC 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).

4.3.1 Groundwater monitoring results GW6, GW7 and GW8

Groundwater monitoring points GW6, GW7 and GW8 were sampled in July and December 2010 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 IPC licence as well as for Petrol Range Organics (PRO’s). Note that there are no ELV’s specified for any of the parameters in Schedule 4(i). Analytical results for both sampling rounds are discussed below:

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

samples above the method detection limit (<10 µg/L) in either monitoring round.

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

method detection limit in either monitoring round.

o Petrol Range Organics – No PRO were detected in the groundwater samples above the method detection limit (<10 µg/L) in either monitoring round.

GW4 Groundwater monitoring point GW4 was sampled in July and December 2010 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 IPC licence as well as for Petrol Range Organics (PRO’s). Note that there are no ELV’s specified for any of the parameters in Schedule 4(i). An extra round of monitoring was carried out in February 2010 as part of an external environmental consultants assessment and report of groundwater monitoring data for wells GW4 and GW9 following a request from the Environmental Protection Agency. This report was forwarded to the Agency in March 2010 – Report title “Groundwater Review Report” Reference: 49341826/CKRP0001 dated 16 March 2010. This report also fulfils Objective 11 from the 2010 Environmental Management Programme to “Carry out independent assessment of GW4 monitoring data with particular regard to petrol range



hydrocarbon and volatile organic compound data and its impact on site groundwater”.

Analytical results for all groundwater samples (three rounds) are discussed below:

o Diesel Range Organics – No DRO were detected in the True Temper

July monitoring round above the method detection limit (<10 µg/L). DRO were detected at 2140µg/L in the True Temper December monitoring round. No DRO were measured in the consultant’s assessment in February 2010.


method detection limit in either monitoring round.

o Petrol Range Organics – In the February monitoring assessment carried out by the 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. In the True Temper July and December monitoring rounds, the following compounds were detected above the laboratory detection limits in GW4: m & p Xylene, o-Xylene, 135 Trimethylbenzene and Napththalene. These compounds are indicative of weathered petrol associated with the former petrol tank (UST) in this area.

o PRO concentration - In the February monitoring assessment carried

out by the environmental consultants, the PRO concentration was 31398µg/L. PRO concentrations in the True Temper July and December monitoring rounds were 12750µg/L and 13800µg/L respectively.

The True Tempering monitoring results from July and December 2010 generally concur with the results of the Environmental consultants assessment.

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 IPC 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 ATT’s IPC 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 and December 2010. An extra round of monitoring was carried out in February 2010 at GW9 for PRO and VOC concentrations only as part of an external environmental consultants assessment and report of groundwater monitoring data for wells GW4 and GW9 following a request from the Environmental Protection Agency. This report was forwarded to the Agency in March 2010 – Report title “Groundwater Review Report” Reference: 49341826/CKRP0001 dated 16 March 2010. This report also fulfils Objective 13 from the 2010 Environmental Management Programme (Schedule of Environmental Objectives and targets) to “Conduct independent assessment of GW9 monitoring results to determine the efficiency of the foul effluent “Puraflo” treatment system”. Analytical results for all three rounds are discussed below:

o Diesel Range Organics – No DRO were detected in the True Temper

July and December monitoring rounds above the method detection limit (<10µg/L). No DRO were measured in the consultant’s assessment in February 2010.


method detection limit in any of the monitoring rounds.



o Petrol Range Organics – No PRO were detected in the groundwater samples above the method detection limit in the True Temper July and December monitoring rounds (<10µg/L ). No PRO were detected in the groundwater sample above the method detection limit in the consultant’s assessment February monitoring round (<100µg/L ).

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, and nitrate are generally below their draft IGV thresholds except for the True Temper December monitoring round which detected chloride at a concentration of 55mg/L against draft IGV concentration of 30mg/L.

Concentrations of nitrite, orthophosphate and ammoniacal nitrogen exceeded their respective Draft IGV’s on one or both of the True Temper July and December monitoring rounds. (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 (381.1µg/L compared to its Draft IGV of 50µg/L) and for both iron and manganese in the December round of monitoring, detected at concentrations of 349µg/L and 265.3µg/L respectively, compared to their Draft IGV’s of 200µg/L and 50µg/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 presence of ammonia in groundwater, as detected at GW9, confirms reducing groundwater conditions, as ammonia would react with any dissolved oxygen and be converted to nitrate. 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

detection (<2 mg/L) in both True Temper monitoring rounds.

o Total Coliforms and Faecal Coliforms (E.coli) – In the July monitoring round, total coliforms were detected at 8330 mpn/100mls and Faecal coliforms (E.coli) were detected at 630 mpn/100mls. In the December monitoring round total coliforms were detected at 0 mpn/100mls and Faecal coliforms (E.coli) were detected at 0 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 detected in the July monitoring round at 630 mpn/100ml and were not detected in the December monitoring round. 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 59 mg/L in the July round of monitoring, to 197 mg/L in the December round. There is no corresponding Draft IGV for COD.

4.3.3 Foul Effluent Water Quality Historical note: Objective 13 of the True Temper Schedule of Objectives and Targets for 2009 had a target to “Undertake analysis of the effluent before and after peat bed module treatment to determine the efficiency of the “Puraflo” system and the quality of final effluent as discharged to the percolation area”. In October 2009 samples of effluent entering the foul effluent treatment system (“Puraflo”) peat bed modules (inflow) and exiting the “Puraflo” peat bed modules (outflow) were collected for analysis. A noticeable reduction was observed in the concentrations of several parameters between the Inflow and Outflow samples analysed. Analytical results are discussed below:



o Ammoniacal nitrogen reduced from 14 mg/L to 0.08 mg/L with a corresponding increase in nitrate from <0.12 mg/L (as nitrogen) to 5.5 mg/L (as nitrogen), indicating that ammonia in the effluent has been oxidized to nitrate as it flows through the treatment system.

o Orthophosphate decreases by 50% from 5.0 mg/L to 2.5 mg/L.

o Biological oxygen demand fell from 28 mg/L (exceeding comparable

ELV of 5 mg/L for SW1) to below the reporting limit (<2 mg/L).

o E.coli. fell from a colony count of 17329 mpn/100ml to 4106 mpn/100ml, a reduction of over 75%.

o COD also fell from 75 mg/L to 16 mg/L. (There is no Draft IGV or

comparable ELV for COD)

o Suspended Solids fell from 26 mg/L (exceeding comparable ELV of 25 mg/L for SW1) to 6 mg/L.

Based on the results for the Inflow and Outflow samples taken in October 2009 and the treatment system specification as reported by Bord Na Mona, the “Puraflo” foul effluent treatment system is working within specified ranges. Please also refer to Report title “Groundwater Review Report” Reference: 49341826/CKRP0001 dated 16 March 2010 issued to the Agency in March 2010. This report also fulfils Objective 13 from the 2010 Environmental Management Programme (Schedule of Environmental Objectives and targets) to “Conduct independent assessment of GW9 monitoring results to determine the efficiency of the foul effluent “Puraflo” treatment system”.

4.3.4 Drinking Water

There were no samples taken from either drinking water supply wells BH01 and BH02 in 2010. The supply from BH02 has been switched off since May 2008 (See 2008 AER Section 4.3.3) and the plant now operates on supply from BH01 which is adequate and satisfactory for its present requirements. True Temper will analyse Drinking Water in 2011 as per Objective 15 of its “Schedule of Objectives and Targets for 2011”.

4.4 Testing and Inspection of Underground Tanks and Pipelines and Bund Integrity Testing No additional work other than that reported in the 2007 AER was conducted in 2010. Note that since 2007 the majority of the pipelines and tanks/interceptors on



the test schedule have been taken out of service due to restructuring of the True Temper Ltd. business and operations – See Objectives 9 and 12 of 2011 EMP.

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 eliminated/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 2010

inclusive is presented in Tables 5.1 to 5.4



Table 5.1 Annual Hazardous Waste for Calendar Year 2010 Waste Management Option Waste Material EWC

Code Source Qty

(t) On-sitetreatment

On-site recovery Off-site recovery On-site disposal Off-site disposalMethod (t) Method (t) Method (t) Method (t)

Waste oil

13 02 08*

Production

0

None

None

0

None

0

None

0

None

0

Diesel/Water mix tank cleaning

13 07 03*

Cleaning/decomm-issioning diesel storage tanks

0

None

None

0

None

0

None

0

None

0

Tank cleaning

16 07 08*

Cleaning/decomm-issioning oil quench storage tank

0

None

None

0

None

0

None

0

None

0



Table 5.2 Annual Non-Hazardous Waste for Calendar Year 2010 Waste Management Option Waste Material EWC

Code Source Qty

(t) On-sitetreatment

On-site recovery Off-site recovery On-site disposal Off-site disposalMethod (t) Method (t) Method (t) Method (t)

Oil contaminated solids & absorbs

15 02 03

Production

0

None

None

0

None

0

None

0

None

0

De-watered waste

20 03 04

Septic tank sludge

0

None

None

0

None

0

None

0

None

0

Empty packaging

15 01 04

Used oil drums

0

None

None

0

None

0

None

0

None

0

Scrap metal

12 01 99

Production

79.28

None

None

0

R4

79.28

None

0

None

0

Wood / Timber

19 12 07

Production

9.58

None

None

0

R13

9.58

None

0

None

0

Mill scale from steel forging

20 03 01

Production

0

None

None

0

None

0

None

0

None

0

Cardboard/Paper

20 01 01

Production / Office Packaging from incoming goods.

0.56

None

None

0

R13

0.56

None

0

None

0

Mixed Packaging (recyclables)

15 01 06

Production/ Office/ Canteen

0.74

None

None

0

R13

0.74

None

0

None

0

General Waste

20 03 07


19.14

None

None

0

None

0

None

0

D1

19.14

Process wood chips /shavings

03 01 05

Production

100

None

None

0

None

0

D10

100

None

0



Table 5.3 Annual Hazardous Waste sent off-site for Recovery/Disposal for Calendar Year 2009 Waste Material EWC

Code Source Qty

(t) Description and nature of waste

Broker

Recovery Contractor

Disposal Contractor

Haulage contractor Waste oil

13 02 08*

Production

0

Waste oil


13 07 03*

Cleaning/decomm-issioning diesel storage tanks

0


Tank cleaning

16 07 08*

Cleaning/decomm-issioning oil quench storage tank

0

Quench oil/water mix



Table 5.4 Annual Non-Hazardous Waste sent off-site for Recovery/Disposal for Calendar Year 2009 Waste Material EWC

Code Source Qty

(t) Description and nature of waste

Broker

Recovery Contractor Disposal Contractor

Haulage contractor Oil contaminated solids & absorbs

15 02 03

Production

0

Oil contaminated waste solids & absorbs

De-watered waste

20 03 04

Septic tank sludge

0

De-watered waste

Empty packaging

15 01 04

Used oil drums

0

Used oil drums

Scrap metal

12 01 99

Production

79.28

Scrap metal

Cork Metal Co. Ltd.

1. Cork Metal Co. Ltd. 2. Arcelormittal Espana, Asturais, Spain.

-

Wood / Timber

19 12 07

Production

13.12

Wood / Timber

Greenstar Ltd.

1. CTO/Cork City Council 2. Cork Recycling Co.

-


20 03 01

Production

0


Cardboard/Paper

20 01 01

Production / Packaging from incoming goods/ Office.

0.56

Cardboard/Paper

Greenstar Ltd.

1. Greenstar MRF, Sarsfields Court. 2. Greenstar MRF Glyntown.

-



Waste Material EWC Code

Source Qty (t)

Description and nature of waste

Broker

Recovery Contractor Disposal Contractor

Haulage contractor Mixed Packaging (recyclables)

15 01 06


0.42

Mixed Packaging (recyclables)

Greenstar Ltd.

1. Greenstar MRF, Sarsfields Court. 2. Greenstar MRF Glyntown.

-

General Waste

20 03 07


19.14

General Waste

Greenstar Ltd.

1. Greenstar MRF, Sarsfields Court. -

-Greenstar MRF, Cork. -Knockharley Landfill

Process wood chips & shavings

03 01 05

Production

100

Process wood chips and shavings

N/A

-

-



Table 5.5 Waste Collection, Permit and Licence details Contractor Waste Collection Permit Waste Permit Waste Licence

Cork Metal Co. Ltd.

wcp-lk-08-589-01

CK(S) 491/07

Arcelormittal Espana, Asturais, Spain.

es a81046856

Greenstar Ltd.

CK WMC 323/05 (Cork) CK WMC 42/01 (Glyntown)

CK(S) 263/05 (Cork Recycling) WFP-CK-10-0047-02 (Glyntown)

W0136-02 (Greenstar Cork) W0146-02 (Knockharley Landfill)



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. For the monitoring period January to December 2010 inclusive, the only environmental complaint received by the company related to noise from a number of false alarm activations of the intruder alarm sounder during night-time hours from an adjacent neighbour. Upon receipt of the complaint the company acted promptly to resolve this issue. True Temper Ltd. did not receive any other complaints about noise levels in 2010. There is no requirement under its IPC 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 – furnaces and ovens.

• Diesel (Gas oil) – thermal energy – furnaces, factory and office heating

system, forklift.

• 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 4.3.4 of this report and the site has been supplied satisfactorily by BH01 for all of its water requirements since then.

7.2 Electricity Usage

Electricity usage in KWh at the True Temper facility is illustrated in Figure 7.2

Figure 7.2 - Electricity Usage 2002 to 2010

2005 2006 2007 2008 2009 20102002 2003 2004

676,920

592,206 528,600

499,690

496,246 475,420438,900 399,533

282,182

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

KW

h

There has been a declining rate in electricity usage since 2003 as indicated in Figure 7.2 and generally reflects the restructuring/downsizing of the overall manufacturing operation.



7.3 Diesel Usage Diesel (Gas oil) usage in litres at True Temper facility is illustrated in Figure 7.3

Figure 7.3 - Diesel (Gas oil) Usage 2002 to 2010

2002 2003 2004 2005 2006 2007 2008 2009 2010

7421177566

136500135900

175950

155600

196000199000

192000

0

50,000

100,000

150,000

200,000

250,000Li

tres

Diesel usage has declined significantly since 2008 (approximately 46% decrease) principally because of the elimination of the Diesel driven Compressor through the introduction of a new more energy efficient electric driven variable speed compressor and the continued restructuring/downsizing of the forge manufacturing operation/facility.



7.4 Liquid Petroleum Gas (LPG) Usage

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

Figure 7.4 - Liquid Petroleum Gas (LPG) Usage 2002 to 2010

2002 2003 2004 2005 2006 2007 2008 2009 2010

584,014

561,740

567,456

513,132

469,410 400,000451,550

192,102

46,8870

100,000

200,000

300,000

400,000

500,000

600,000

700,000Li

tres

LPG usage has declined significantly since 2008 principally because of the closure of the Forge shovel mill operation in July 2009, the introduction of the Boron Steel Project in March 2009, which eliminated the full-time requirement for the heat-treatment Tempering Oven process and the continued restructuring/downsizing of the overall manufacturing facility in 2010.

7.5 Water consumption

Water consumption at True Temper is utilised for Production and Domestic requirements. 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 2010 that a total of 480m3 approximately was used, taking into account the continued restructuring/downsizing of the Forge Shovel Mill manufacturing operation.

7.6 Energy Efficiency Indices

Due to the significant decline in shovel and spade manufacturing in 2010 the energy efficiency indices calculated as per previous Annual Environmental Reports will not be undertaken for the 2010 report.



8. Environmental Incidents and Complaints 8.1 Complaints

As previously outlined under Section 6.0 “Noise”, for the monitoring period January to December 2010 inclusive, the only environmental complaint received by the company related to a number of false alarm activations of the intruder alarm sounder during night-time hours from an adjacent neighbour. Upon receipt of the complaint the company acted promptly to resolve this issue.

8.2 Incidents

There was one reported incident to the Agency for the monitoring period January to December 2010 and this related to a fire in the flue of the Pyrolysis Oven (Emission Ref. point A1-6). The fire was promptly brought under control by the site fire/emergency response crew. A summary report of the reported incident is contained in Appendix 6 of this report. An small area of ground subsidence was noted by True Temper staff in the roadway between the Forge and Assembly site buildings, just north of the ESB electricity transformer room in March 2010. Within the excavation, an oily odour was noted by site workers investigating the subsidence from soil loated close to a storm water manhole. The Agency was notified of this discovery and environmental consultants investigated the issue and collected soil samples for assessment and analysis. One of the concluding recommendations of the environmental consultants suggested that in the absence of a clear or imminent risk of heavy hydrocarbon material impacting human health or the wider environment (which there did not appear to be at that time), then this material may be safely left in situ. True temper staff removed the majority of this oily soil and placed in storage for proper disposal. Appendix 7 contains a report on this issue and subsequent soil sampling results from the environmental consultants. There were no other reported incidents for this reporting period.

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 2010 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 2010 that would have a negative impact on the current version of the ELRA.

True Temper has Environmental Liability Insurance cover in place and has advised the Agency of the particulars relating to this insurance cover.


______________________________________________________________________________ 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 Charts /

Management Structure

OOrrggaanniissaattiioonnaall CChhaarrtt --AAmmeess TTrruuee TTeemmppeerr,, IIrreellaanndd AAss ooff 3311sstt JJaannuuaarryy 22001100

IRELAND Sales Merchandisers

Barrie Deehan Gary Coyle

Seamus Treacy Gabriel Leslie Purchasing Officer

Una McCarthy

Customer Service Administrator Trish O Sullivan

HR Executive Joanne Fitzgerald

Customer Service Administrator Carrie Wilson

Forge/Assembly Foreman

Con Murphy Operatives x 14

Financial Director Sean O’Mahony

Managing Director Tom O’Connor

Credit Controller Evonne Kidney

Receptionist/ AP Administrator Clare Twohig

Merchandising Supervisor Mairead McKenny

UK Key Account Executive

Mark Hewett

UK Sales Representative

Wendy Wilkinson

Sales & Marketing Director

OOrrggaanniissaattiioonnaall CChhaarrtt --AAmmeess TTrruuee TTeemmppeerr,, IIrreellaanndd aass ooff 2266tthh DDeecceemmbbeerr 22001100

IRELAND Sales Merchandisers

Gary Coyle Seamus Treacy Gabriel Leslie

Purchasing Officer Una McCarthy

Customer Service Administrators Marie Dobbyn Carrie Wilson

HR Executive Sandra Walsh

Assembly/Dispatch Operatives x 4

Financial Director Sean O’Mahony Managing Director

Tom O’Connor

Credit Controller Evonne Kidney

Receptionist/ AP Administrator Clare Twohig

Marketing Executive

UK Sales Representative

Wendy Wilkinson

Sales & Marketing Director

Merchandising Supervisor Mairead McKenny

Garant Jean Gaudreault ATT

Duane Greenly



Appendix 5 – Glossary of Terms



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 Polution Control

LOD Limit Of Detection

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

VOC Volatile Organic Compound



Appendix 6 – Pyrolysis Oven Incident

Incident at True Temper Ltd. involving Pyrolysis Oven Date and time of incident: 12th April 2010 at 12.20 pm approx. Summary details of the occurrence: The Pyrolysis Oven located in the Assembly building is used as a cleaning furnace

designed to remove cured electrostatic applied polyester powder coatings from steel

hanging racks.The Oven was switched on at approximately 08.00 hours. Heavy

smoke was observed emanating from the Pyrolysis Oven flue by the Assembly

supervisor at approximately 12.15 hours. The direction of the smoke was

approximately north-west and appeared to dissipate as it was carried across the site.

Flame was also observed emanating from the flue. The LPG gas supply to the Oven

was immediately switched off and the electrical power supply to the furnace controls

was also switched off.

The plant fire alarm was raised and the plant fire crew implmented their emergency

response procedure. This included activation of the Fire alarm and evacuation of all

employees to designated assembly areas outside the building. The fire alarm signal

automatically notified the Alarm monitoring company. The Plant Fire Crew chief

considered it not necessary to call the Fire Brigade. The Flue was accessed from the

Assembly building roof and two dry powder extinguishers were discharged into the

flue to terminate the fire. The flue is set back approximately 2 metres from the

northern side wall of the Assembly building and protrudes approximately 1.6 metres

above roof level.

The external surface of the stainless steel flue was cooled using hydrant water for

approximately four to five minutes at a reduced flow rate so as not to put an

unnecessary side load on the projecting flue. Total hydrant fire water utilised is

estimated to be approximately 4000 litres where after discharge it flowed from the

mineral felt roof surface to adjacent storm water downpipes that run down internally

inside the Assembly building wall and directly into the storm water drain without

contacting any yard hard surface areas. Any residual offshoot hydrant water, which

was minimal, landed on the open hard standing yard area outside the Assembly

building where it entered the storm water guttering.

The fire was under control in approximately 5 minutes. However, there was residual

smoke emanating from the flue which had a heavy appearance for approximately 25

minutes after the start of the fire and gradually became lighter in appearance

vapourising shortly after emission up to one hour after the start of the fire. It is difficult

to estimate the total unburned smoke volume emitted, however based on previous

flow rates recorded during monitoring and the fact the a portion of the smoke was

being burned for a short time due to the nature of the incident, it is estimated that 350

Nm3 of unburned smoke was emitted to atmosphere.

The probable cause of the fire may be related to a combined malfunction of the Oven

over-temperature water spray protection system and a high-limit thermostat which

could potentially cause an increase in Oven and Stack temperature. This system

measures the amount of pyrolysis smoke entering the afterburner chamber by

monitoring the afterburner (stack) temperature. When the evolution of smoke from

the paint racks causes the stack temperature to rise above its preset control point,

water mist is automatically injected into the oven to cool the racks and slow down the

emission rate of the smoke from the racks and to arrest the rising temperature

preventing any parts becoming damaged and preventing the furnace from

overheating. It was found that two of the three water spray emission points were not

operating satisfactorily. The high-limit thermostat function is presently being checked

for correct operation.

Corrective and preventive action:

Both pieces of equipment are included in the corrective action to be taken (inspection

and repair) to return the Oven to a safe and standard operating condition. The flue

internals will be also be checked for any damage and corrective action taken if

required. The over temperature operating system will be thoroughly examined and

corrective action taken where required. The restart of the Oven, after corrective

action has taken place, will be monitored and recorded.

Conclusion:

The on-site Fire crew emergency team implemented the fire emergency procedure

satisfactorily and brought the fire under control in a very short time There were no

complaints from the public in relation to this incident. This particular oven has its

emissions to atmosphere monitored on an annual basis as part of the conditions of

the plants IPC licence. The Oven is used on a periodic basis only throughout the

year.

Tom Butler

Engineering and EHS consultant

True Temper Ltd.

___________________________________________________________________



Appendix 7 – Report oily soil sampling

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