ANNUAL ENVIRONMENTAL REPORT

ANNUAL ENVIRONMENTAL REPORT

2010

for

Licence No. P0795-01

Cadbury Ireland Limited

Rathmore,

Co. Kerry

P0-795-01|Cadbury Rathmore Annual Environmental Report (AER) 2010

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CONTENTS

1 INTRODUCTION ......................................................................................................................... 3

1.1 Licensee Details.................................................................................................................. 3

1.2 Description of Site Activities ............................................................................................... 3

1.3 Company Environmental Policy .......................................................................................... 3

2 SUMMARY INFORMATION ........................................................................................................ 5

2.1 Self Monitoring Data .......................................................................................................... 5

2.1.1 Emissions to Water ..................................................................................................... 5

2.1.2 Emissions to Air .......................................................................................................... 6

2.1.3 Waste Arisings ............................................................................................................ 7

2.2 Agency Monitoring and Enforcement ................................................................................. 9

2.2.1 Site Inspection ............................................................................................................ 9

2.2.2 Site Audits .................................................................................................................. 9

2.2.3 Agency Emissions Monitoring ..................................................................................... 9

2.3 Energy & Water Consumption Summary ............................................................................ 9

2.3.1 Energy Consumption .................................................................................................. 9

2.3.2 Water Consumption ................................................................................................. 10

2.4 Environmental Incidents and Complaints ......................................................................... 10

2.5 AER Summary Data Tables................................................................................................ 10

3 MANAGEMENT OF THE ACTIVITY ............................................................................................ 10

3.1 Schedule of Environmental Objectives & Targets .............................................................. 10

3.2 Environmental Management Programme Report 2010 ..................................................... 12

3.3 Environmental Management Programme Proposal 2011 .................................................. 19

3.4 Other Significant Environmental Aspects, Audits etc ........................................................ 23

3.4.1 ISO 14001 EMS Audit ................................................................................................ 23

3.4.2 Internal Audit ........................................................................................................... 23

3.4.3 Management Environmental Meetings ..................................................................... 23

4 LICENCE-SPECIFIC REPORTS ..................................................................................................... 23

4.1 Noise Monitoring report summary ................................................................................... 23

APPENDICES

Appendix A: AER Summary Data Tables


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TABLES

Table 1: Summary Table of Emissions to Water ........................................................................................... 5

Table 2 Summary of Non-Compliances for Emissions to Waters ................................................................. 6

Table 3 Summary Table for Mass Emissions to Atmosphere ....................................................................... 6

Table 4 Summary Table of Pollutant Average Concentrations ..................................................................... 6

Table 5: Summary of Non-Compliances for Emissions to Atmosphere.......................................................... 6

Table 6: Summary information of waste arising ........................................................................................... 7

Table 7 Summary information of waste streams......................................................................................... 7

Table 8 Summary of EPA Analysis v Self Monitoring Data ........................................................................... 9

Table 9 Energy Consumption Summary .................................................................................................... 10

Table 10 Water Consumption Summary .................................................................................................... 10

Table 11 Schedule of Environmental Objectives & Targets (Revised for 2011) ............................................ 11

Table 12 Review of 2010 Environmental Management Programme (EMP) ................................................ 13

Table 13 2011 Environmental Management Programme (EMP) ................................................................ 19

Table 14 Summary of 2011 Project Schedule ............................................................................................ 23


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1 INTRODUCTION

1.1 Licensee Details

License Register Number: P0795-01

Licensee: Cadbury Ireland Limited

Location of Installation Shinnagh, Rathmore, County Kerry

1.2 Description of Site Activities

The Cadbury Ireland Ltd, Rathmore installation manufactures milk chocolate crumb which is an intermediate

product utilised in the production of milk chocolate. Production of milk chocolate crumb involves

pasteurisation and evaporation of milk followed by the addition of sugar to form Sweetened Concentrated

Milk (SCM). Butteroil may also be added depending on the recipe and required fat concentrations. Liquid

cocoa mass is then added to form a paste. Raw and in-process materials are stored in tanks and silos on site.

Off-specification product may also be reworked into the process at this stage. The paste is then cooked and fed

to an air drier or one of three vacuum driers, prior to cooling. The resulting crumb is then weighed and packed

into 1,150 kg bulk bags, or sent to the bulk storage silos on site. There is also a milling process which may be

employed to reduce the particle size of the crumb where required. The control of the entire process is highly

automated.

Cadbury Ireland Ltd Rathmore facility comprises of a main processing facility with associated buildings, storage structures and wastewater treatment plant.

1.3 Company Environmental Policy

Key policy objectives are as follows:

We will: 1. Strive to prevent pollution and minimise the environmental impacts of our operation, working with

our supply chain and business partners to reduce our collective environmental footprint and protect the ecosystems that provide our raw materials.

2. Guarantee that our customers and consumers come first by actively listening to and understanding their expectations of our brands.

3. Reinforce our commitment to sustainability and safeguard the reputation of Cadbury through regular engagement with internal and external stakeholders.

4. Maintain a zero waste culture that consistently embraces environmental sustainability where everyone understands their responsibilities and accountabilities.

5. Operate audited environmental management systems that continually improve our processes to deliver this policy and any associated standards and ensure compliance with prevailing legislation.

6. Assign clear management accountability for setting, monitoring performance against and meeting measurable targets for environmental performance.


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7. Communicate openly and regularly in line with international good reporting practice

8. Place continuous improvement at the heart of our performance through assessment of the

environmental performance of new and existing products and processes.

9. Create a passion for sustainability where success and achievement are recognised, communicated and celebrated.

10. Review and update this policy and any associated standards regularly ensuring that it continues to reflect our values and the expectations of key stakeholders.

1.4 Company Environmental Management Structure

Cadbury Ireland Ltd, Rathmore has a structured management approach to the operation of the business in

terms of product quality, process control, environment and safety.

The Head of Manufacturing has the overall responsibility for environmental management and control at the Rathmore Installation.

The Quality and Environment (Q&E) Manager, as designated Environmental Representative, has responsibility for day-to-day environmental management at the Rathmore Installation.

Shift Managers are responsible for ensuring day-to-day environmental requirements are met.

All staff at the facility have are responsible to ensure the environmental requirements are met.

1.5 Cadbury Rathmore Environmental Management Organisational Chart

Head of Manufacturing

Production and

maintenance

personnel

Laboratory &

Security Personnel

Quality & Environment (QE) Manager

WWTP Personnel

Production Shift

Managers

Site Leadership

Team

External

Contractors

Quality, Environment and Health & Safety

(QEHS) Manager


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2 SUMMARY INFORMATION

The information presented here is for the calendar year 1st

January 2010 to 31st

December 2010.

2.1 Self Monitoring Data

2.1.1 Emissions to Water

Cadbury Ireland Rathmore is licensed for emissions to water. There is one emission point from the wastewater

treatment plant (SW1), discharging treated effluent to the River Blackwater. This emission point has been

monitored and analysed in accordance with requirements of Schedules B2 and C2.2 of the facilities IPPC

Licence.

There are two licensed storm water emission points (SW2 and SW3) that indirectly discharge on-site storm

water to the River Blackwater. There are no license limits applied to these emission points however water

quality is assessed on a daily basis and analysed weekly in accordance with Schedule C2.3 and for additional

parameters stipulated in the Agency’s Site Inspection Report of February 2008.

From January to September 2010 water analysis was undertaken by an independent external laboratory.

During this time Cadbury Rathmore was undertaking a comprehensive laboratory validation programme. From

September 2010 to December 2010 (having completed the analytical validation programme) water analysis

was carried out in-house at the on-site micro and chemistry laboratory by fully trained and competent

personnel.

There were three incidents of non-compliance associated with emission limit values for emissions to water

during 2010. All were reported to the Agency and appropriate incidence investigation and corrective action

was undertaken.

Table 1: Summary Table of Emissions to Water

PARAMETER FINAL EFFLUENT DISCHARGE PT SW1

(2009)

FINAL EFFLUENT DISCHARGE PT SW1

(2010)

EMISSION LIMIT VALUE

Volume 483.4 m3 484m3 900 m3

Temp 14.6 14.7 25 maximum

pH 8.5 8.5 6 – 9

BOD 6.33 mg/l 6.66 mg/l 40 mg/l

COD 42.7 mg/l 41.7 mg/l 125 mg/l

Suspended Solids 17.75mg/l 15.77 mg/l 50 mg/l

Total Nitrogen 8.45 mg/l 8.45 mg/l 15 mg/l

Total Ammonia 0.4 mg/l 0.22 mg/l 10 mg/l

Detergents 0.01mg/l 0.04 mg/l 2 mg/l

Oils, Fats, Greases <10 mg/l <10 mg/l 10 mg/l

Orthophosphate 0.33 kg/day 0.46kg/day 1.08kg/day

Total Phosphorus 0.43 kg /day 0.58 1.17kg/day

Toxicity n/a n\a 5 TU

Note: This emission data is based upon the averaged monitoring data available for the facility.


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Table 2 Summary of Non-Compliances for Emissions to Waters

DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION

12 January 2010 Reportable exceedence of ELV for flow rate.

Fault detected with flow meter when system in divert

Maintaining calibration status of flow meter. Ongoing review of system with flow meter supplier.

14 January 2010 Reportable exceedence of ELV for Suspended Solids

Unknown. Cause undermined following investigation. Facility not in operation (sampling event undertaken during annual Christmas shut down).

Review of recorded results preceding and subsequent indicates this concentration out of trend. No corrective action taken

12 May 2010 Reportable exceedence of ELV for nitrogen

Cause undermined following investigation

Continuing investigation into origins of nitrogen

2.1.2 Emissions to Air

Licensed emissions to the atmosphere are in the form of combustion emissions. There have been no changes

to the type of fuel used (heavy fuel oil) to date. Air emissions monitoring from the combustion process are

carried out twice annually to licence requirements by independent contractors. There were no exceedences of

licence emission limit values for emissions to air. As the facility also reports under the Emissions Trading

Scheme, mass emissions of carbon dioxide are also being reported within the PRTR. Mass emissions of

particulates are also being reported within this table for comparison purposes as they have also been

reported within the PRTR for the last couple of years

Table 3 Summary Table for Mass Emissions to Atmosphere

PARAMETER MASS EMISSION (2008)

MASS EMISSION (2009)

MASS EMISSION (2010)

Oxides of Sulphur 51,997 kg/year 45,654 kg/year 44,757 kg/year

Nitrogen Oxides 30,331 kg/year 29,772 kg/year 23,095 kg/year

Carbon Dioxide 11,498 tonnes/year 10,842 tonnes/year 9,396 tonnes /year

Particulates 18,622 kg/year 11,738 kg/year 10,094 kg/year

Table 4 Summary Table of Pollutant Average Concentrations

CONCENTRATION May (2010)

CONCENTRATION November (2010)

EMISSION

LIMIT VALUE Boiler A1-1 Boiler A1-2 Boiler A1-1 Boiler A1-2

Oxides of Sulphur 1084 mg/m3 1098 mg/m3 1559 mg/m3 1529 mg/m3 1700 mg/m3

Nitrogen Oxides 695 mg/m3 682 mg/m3 646 mg/m3 570 mg/m3 900 mg/m3

NOTE: Mass emission figures for each year (as reported in the electronic AER) have been calculated from

average concentrations as measured against quantity of heavy fuel oil consumed. Average

concentrations are measured are also provided for comparison with the Emission Limit Values as given

in the licence.

Table 5: Summary of Non-Compliances for Emissions to Atmosphere

DATE NON-COMPLIANCE CAUSE CORRECTIVE ACTION

There were no non-compliances associated with emissions to air


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2.1.3 Waste Arisings

Cadbury Ireland Rathmore is licensed to monitor waste sludge arising from the on-site wastewater treatment

plant facility. Sludge is tested annually and results are submitted to the Agency. A summary of all waste

streams and the management of waste arisings is presented in Tables 5 and 6 below.

Table 6: Summary information of waste arising

ITEM TONNES/ANNUM 2009

TONNES/ANNUM 2010

Total quantity of waste produced in calendar year

- Total quantity of waste disposed of on-site

- Total quantity of waste disposed of off-site

- Total quantity of waste recovered on-site

- Total quantity of waste recovered off-site

791.601t

None

303.325t

None

488.276t

559.239t

None

116.76t

None

442.479t

Quantity of non-hazardous waste produced in calendar year

- quantity of non-hazardous waste disposed of on-site

- quantity of non-hazardous waste disposed of off-site

- quantity of non-hazardous waste recovered on-site

- quantity of non-hazardous waste recovered off-site

695.84t

None

284.88t

None

410.96

548.56t

None

106.3t

None

442.26t

Quantity of hazardous waste produced in calendar year

- quantity of hazardous waste disposed of on-site

- quantity of hazardous waste disposed of off-site

- quantity of hazardous waste recovered on-site

- quantity of hazardous waste recovered off-site

95.761t

None

18.445t

None

77.316t

10.679t

None

10.46t

None

0.219t

Table 7 Summary information of waste streams

EWC CODE

DESCRIPTION OF WASTE HAZ YES/NO

QUANTITY (T/A) 2009

QUANTITY (T/A) 2010

METHOD OF DISPOSAL/ RECOVERY

WASTE SOURCE WASTE TYPE

02 05 02 wastes from the dairy products industry

sludges from on-site effluent treatment

No 323.18 231.7 R10

02 05 01 Wastes from the dairy products industry

Materials unsuitable for consumption or processing

No 4.32 0 R10

13 07 01 wastes of liquid fuels - fuel oil and diesel Yes 10.76 0 R1 13 07 03 wastes of liquid fuels - other fuels (including

mixtures) Yes 48.26 0 R1

13 08 02 oil wastes not otherwise specified

other emulsions Yes 9.22 0 R1

15 01 01 packaging (incl.separately collected municipal packaging waste)

paper and cardboard packaging

No 6.24 0 R3

15 01 06 packaging (including separately collected municipal packaging waste)

mixed packaging No 18.18 9.58 R13

15 01 10 packaging (including separately collected municipal packaging waste)

packaging containing residues of or contaminated by dangerous substances

YES 0.06 0 R4/R5


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Table 7 ctd Summary information of waste streams

EWC CODE

DESCRIPTION OF WASTE HAZ YES/NO

QUANTITY (T/A) 2009

QUANTITY (T/A) 2010

METHOD OF DISPOSAL/ RECOVERY

WASTE SOURCE WASTE TYPE

15 02 02 absorbents, filter materials, wiping cloths and protective clothing

absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances

Yes 5.665 0.155 R1

15 02 03 absorbents, filter materials, wiping cloths and protective clothing

absorbents, filter materials, wiping cloths and protective clothing other than those mentioned in 15 02 02

No 0 0.2 R12

16 05 06 gases in pressure containers and discarded chemicals

laboratory chemicals, consisting of or containing dangerous substances, including mixtures of laboratory chemicals

Yes 0.044 0.08 D9

17 01 07 Rubble mixture of concrete, bricks, tiles and ceramics other than those

53.22

17 02 01 wood, glass and plastic wood No 3.74 0 R3

17 04 05 metal iron and steel No 169.02

17 04 07 metals (including their alloys)

Mixed metals No 59.04 0 R4

17 05 03 soil (including excavated soil from contaminated sites), stones and dredging spoil

soil and stones containing dangerous substances

Yes 2.9 0 R5

17 06 05 Insulation materials and asbestos-containing construction materials

construction materials containing asbestos

Yes 17.64 10.38 D1

17 09 04 other construction and demolition waste

mixed construction and

demolition wastes other

than those mentioned in 17

09 01, 17 0902 and 17 09

03.

No 221.16 0 D1

19 12 01 wastes from the mechanical treatment of waste (for example sorting, crushing, compacting, pelletising) paper and cardboard

paper 1.26

20 01 08 biodegradable kitchen and canteen waste

Crumb compost 16.88

20 01 21 Municipal wastes -separately collected fractions

fluorescent tubes and other mercury-containing waste

Yes 0.191 0.064 R5 / R4

20 01 38 wood other than that mentioned in 20 01 37

timber 13.62

20 03 01 Other municipal wastes mixed municipal waste No 57.54 49.28 D1

20 03 07 Mixed municipal waste bulky waste 3.8


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2.2 Agency Monitoring and Enforcement

2.2.1 Site Inspection

The EPA inspected the site on one occasion in 2010. This was an unannounced inspection undertaken on 27

May 2010. Three (3) non-compliance and eight observations were noted on the day of inspection. Corrective

action was undertaken in relation to all inspection findings.

2.2.2 Site Audits

The EPA audited the site on one occasion in 2010. This was a scheduled audit undertaken on 23 July 2010. No

(0) non-compliance and eight observations were noted on the day of audit. Corrective action was undertaken

in relation to all audit findings.

2.2.3 Agency Emissions Monitoring

The EPA collected samples from the final effluent discharge point SW1 for analysis on four(4) occasions during

2010. The collection dates were 3 February 2010, 11 May 2010, 16 September 2010 and 14 December 2010.

Table 8 below shows the results of self monitoring with results recorded by the Agency. The cells highlighted

in orange indicate the significant differences between self monitoring results and that of the Agency. With the

exception of the Total Nitrogen concentration recorded for the 16th September 2010, the reported self

monitoring results were higher than that of the Agencys results.

Table 8 Summary of EPA Analysis v Self Monitoring Data

Parameter 3 February

2010

11 May

2010

16 September

2010

14 December

2010

Agency Self

Monitoring

Agency Self

Monitoring

Agency Self

Monitoring

Agency Self

Monitoring

pH 7.8 8.9 8.7 8.5 8.4 8.5 8.5 8.6

BOD mg/l 3.0 2.8 4.0 6

COD mg/l 74 80 12 22 <10 14.5 46 40

Total Suspended Solids mg/l 9.6 21 10 9 16 12 11 16

Ammonia mg/l 0.05 0.03

Total Phosphorus kg/day 0.52 0.53

Soluble Phosphorus kg/day 0.49 0.48

Total Nitrogen mg/l 1.43 4.3 16.1 15.1

2.3 Energy & Water Consumption Summary

2.3.1 Energy Consumption

Energy usage on site associated with production is largely fuel combusted in boilers to produce steam for the

thermal requirements of the site and electricity supplied to site, primarily for motive power. In addition to the

direct requirements of the manufacturing process energy is consumed on site for ancillary requirements such

as supply of well water, waste water treatment, tanker cleaning, loading and unloading of delivery vehicles,

compressed air production etc. Cadbury Ireland Rathmore used Heavy Fuel Oil as the main combustion fuel in

2010. Electricity used on site was obtained from the national grid. Water is sourced both from on-site wells

and municipal supply. Diesel usage is for the emergency generator. LPG usage is for the fork truck fleet and

for heating of some process lines during annual shut-down. Overall energy use continued to fall in 2010

compared to 2009. A focus on energy efficiency projects together with changes in the boiler system has

helped the decrease in energy usage on site.


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Table 9 Energy Consumption Summary

ITEM 2008 2009 2010

Heavy Fuel Oil (tonnes) 3,667.1 3,457.94 2,995.4

Diesel (tonnes) 0.23 0.23 1.05

LPG (tonnes) 9.32 7.85 9.5

Electricity (kWh) 6,449,854 6,424,000 5,290,175

2.3.2 Water Consumption

Water sources for the site include municipal water supplied by Kerry County Council and 2 No. on-site

groundwater borewells. The consumption of water by the activity during 2010 was 110,969m3.

Table 10 Water Consumption Summary

ITEM 2008 2009 2010

On-site ground water (m3) 122,550 114,613 110,307

Municipal Supply (m3) 1017 959 note 1 662 Note 1 This volume has been amended from that reported in the 2009 AER (of 403 m2). Clerical error in reporting.

2.4 Environmental Incidents and Complaints

During the reporting period, there were three (3) non-compliant emissions to water. These incidents were

reported to the Agency and have been discussed in Sections 2.1.1 of this report. There were no further

Incidents.

One (1) noise complaints was received during the year 2010. A neighbour phoned the facility around 11pm on

7th October 2010 about a ringing alarm. The alarm in question was the low level alarm system associated with

the firewater sump. The issue was addressed immediately and the alarm ceased 30 mins later.

2.5 AER Summary Data Tables

See Appendix A

3 MANAGEMENT OF THE ACTIVITY

3.1 Schedule of Environmental Objectives & Targets

The schedule of Environmental Objectives and Targets for Cadbury Rathmore was developed in 2008 to

address a five year period up to 2012. Environmental Targets and Objectives took into account compliance

with all conditions and schedules of the IPPC licence and the company’s financial, operational and business

requirements. The schedule shows that a total of 13 project areas were considered and that 39

schemes/actions had been programmed for completion before 2012.

The schedule of Objectives and Targets was reviewed in December 2008 as part of the 2008 AER. The 5-year

Programme was reviewed and revised forward to incorporate a Programme for the next 5 years; Year 2 (2009)

to Year 6 (2013). The schedule of Objectives and Targets has again been reviewed in December 2010.

Revisions to this schedule principally relate to the reprioritizing of targets and review of timeframes for

achieving targets.


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Table 11 SCHEDULE OF ENVIRONMENTAL OBJECTIVES & TARGETS (Revised + Update for 2011) – Part 1 of 2

PROJECT OBJECTIVES TARGETS

Stormwater

Management

Improve storm water discharge quality to

ensure no soil, surface water or

groundwater contamination as a result of

stormwater discharges from the site

Improvements in stormwater quality through improvements to on-site collection

and filtrations system by 2012

Water Resource

Management

Improve water conservation Maintain water usage at 3 m3

(+/- 10%) per tonne of finished product.

Wastewater

Management

Improve wastewater quality discharge to



wastewater discharges from the site

Emissions to waters from the wastewater treatment plant shall not exceed emission limit values outline in table B.2.2 of Schedule B of the facilities IPPC licence

No substance shall be discharged in a manner or at a concentration that following initial dilution causes tainting of fish or shellfish

Energy Use Reduce Installations Energy consumption

+ Increase the use of renewable energy

to improve energy efficiency

All findings and recommendations of the 2008 Energy Audit survey to be implemented and\or achieved by 2013

Power Generation Reduce Installations use of conventional

power generation

Evaluate the options of running the boilers on alternative renewable fuels by

2012

Fuel & Chemical

Storage

No soil, surface water or groundwater

contamination as a result of fuel or

chemical storage on-site

All tanks, containers and drum storage areas shall be rendered impervious to

the materials stored therein according to the 2009 Tank Testing Schedule.

Drainage from caustic and nitrite delivery areas to be diverted for collection

and safe disposal by end 2011.

Waste

Management

Reduce hazardous and non-hazardous

waste and improve recovery, reuse and

recycling of waste material

Reduce the environmental impact of the

Installations waste

a) Waste Generation: Reduce the volume of waste generated at the Installation

b) Waste Handling: No soil, surface water or groundwater contamination as a result of waste collection or disposal

c) Waste Storage: No soil, surface water or groundwater contamination as a result of waste storage

Waste generation: Reduce quantity of material to landfill by 10% on 2010

quantities in 2011. Investigate whether target can be set for reduction of sludge

volume by end of 2012.

Waste handling: Waste sent off site for recovery or disposal shall be transported

only by authorised waste contractors (Licensed or permitted). All waste to be

disposed of at a licensed or permitted facility.

Waste Storage: Waste shall be stored in designated areas protected against

spillage and leachate run-off

Air Emissions Operations & activities at the facility shall

not result in the release of significant

levels of pollutants to the atmosphere

Emissions to the atmosphere from the installation shall not exceed emission limit

values set out in the IPPC licence

Emission of oxides of sulphur shall not exceed 1700mg/m3

Emissions of nitrogen oxides (as NO2) shall not exceed 900mg/m3

No emissions of offensive odours outside the boundaries of the premises.

Noise Emissions Noise generated on-site shall not impact

the amenity of neighbouring properties

Noise from the installation shall not give rise to sound pressure levels (Leq, T)

,measured at sensitive locations of the installation which exceed the limit value(s)

of 55dB(A) for Daytime noise and 45dB(A) for night-time noise


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Table 11 SCHEDULE OF ENVIRONMENTAL OBJECTIVES & TARGETS (Revised + Update for 2011) – Part 2 of 2

PROJECT OBJECTIVES TARGETS

Fugitive Emissions Reduce fugitive emissions plant wide to



fugitive emissions from the site

Establish the losses from all on-site activities through fugitive emissions by 2012.

Develop a schedule for improvements (including quantifiable targets) by 2014.

Goods

Consumption

Reduce the facilities overall raw materials

resource consumption per tonne of

finished product

Material processing: Reduce, where possible, the losses of food materials in all

processes; while being mindful of possible food safety limitations. Target – that

annual ingredient losses (specifically raw crumb materials of milk, sugar, coca

mass and butter oi)l do not exceed 0.5%

Facility &

Equipment

Maintenance

Improve process control (equipment &

management) to reduce waste and

Improve maintenance and calibration of

control and monitoring equipment

to ensure adequate control of plant &

equipment so the hazardous breakdown

is prevented

Investigate downtime on all on-line monitoring equipment and reduce to less

than 5% by 2014

Environmental

Management

System

Make provisions for management of the

activity on a planned basis having regard

to the desirability of ongoing assessment,

recording and reporting of matters

affecting the environment

Existing management system and reporting structure to be continually reviewed

and updated as required

3.2 Environmental Management Programme Report 2010

Table 12 provides a summary on the programme of works undertaken in accordance with the 2010

environmental management programme (EMP). The summary gives an overview of the success in meeting the

planned targets for 2010.


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Table 12 Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 1 of 6

PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED TIME ACHIEVEMENTS V TARGETS /

ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Stormwater

Management

In line with overall

objectives to improve

storm water discharge

quality and overall

target that these

improvements are

achieved by 2012

100% of gaps in drainage

survey to be completed

Undertake additional testing and survey

based on gaps identified in previous survey

By June 2010 Additional surveying and testing carried

out in June / July 2010.

All gaps in survey

could not be closed

out due to

restrictions on

access.

Remedial action

required to provide

access. Scheduled for

June 2011.

All critical areas

identified as part of the

stormwater drainage

systems upgrading on

site to be completed

Further upgrading of storm water and

process water drains

By December

2010

Stormwater drainage upgrade works

are ongoing.

Delays due to cold

weather in

December and

January.

Works due to be

completed by 2010 to be

closed out by March

2011

All identified stormwater

monitoring and control

mechanisms to be

installed

(i) Complete installation of 2000m3 holding

tank/firewater retention

By Sept 2010 Stormwater / Firewater Tank complete

and operational.

N/A N/A

(ii) All identified pumps, sumps, storage

tanks or treatment plant chambers from

which spillages of environmentally

significant materials might occur to be

fitted with high liquid level alarms

By Sept 2010 All tanks fitted with high level alarms. N/A N/A.

Water Resource

Management


objective to improve

water conservation

and overall revised

target to maintain or

improve on the 4%

reduction on 2008

volumes of water use

Continue with

identification of

opportunities for

reducing the volume of

on-site water usage

(i) Carry out site wide water balance to drive By end 2010 Water balance carried out as planned .

Review of the data acquired was not

undertaken

N/A Undertake review during

2011.

(ii) Analyse water meter data and review

water usage targets

By end 2010 Water meters in place. Data not

analysed

N/A Data to be analysed

during 2011.

(iii) continue with site in house awareness

training on water usage and water

conservation

Ongoing

during 2010

Informal training given to key

personnel.

N/A N/A


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Table 12 ctd Review of CADBURY RATHMORE – 2010 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 2 of 6

PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED TIME ACHIEVEMENTS V TARGETS

/ ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Wastewater

management


objectives to improve

wastewater quality

discharges and overall

target that this is to be

achieved by 2012

Planned WWTP

upgrading works for

2010 to be completed

(i) Further upgrading of foul water drains Ongoing

during 2010

Current phase of process water

upgrade works complete.

N/A N/A

(ii) Continue with WWTP safety + access

improvements

Ongoing

during 2010

Footpaths, steps and handrails

installed in 2010. Extra works

planned for 2011.

N/A N/A

(iii) Permanent phosphorus removal system

to be completed

By May 2010 Phosphate removal system is in

place and operational.

N/A N/A

(iv) Commence bunding of divert drain from

river with a view to be completed by

early 2011

By end 2010 /

2011

Balance Tank and Emergency Tank

bund divert drain complete.

N/A N/A

(v) Review sludge levels with phosphorus

removal equipment installed

By end 2010 Levels reviewed as planned. Downturn in production

would have impacted sludge

volumes thus affecting

correlation with phosphorus

removal system

To be reviewed

again in 2011

Energy Use In line with overall

objectives to reduce

the facilities energy

consumption

Findings and

recommendations of the

2008 Energy Audit

Survey set out for 2010

to be achieved

(i) Investigate whether a duct can be

installed for the air supply to the boiler air

intake from the top of the boiler house

by June 2010 Investigation undertaken as

planned

Opportunity investigated

with the burner

manufacturer and found that

this is not a feasible option

due to the overall boiler

house temperature and

burner design

n/a

(ii) Investigate the option of recuperating

the waste heat from the discharge stream

from dryer 0

by September

2010

Investigation carried out as

planned

n/a This is now added to

list of sites energy

saving options and

is to be assessed

against business

guidelines for

capital funding


P a g e | 15


PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED TIME ACHIEVEMENTS V TARGETS /

ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Energy Use ctd In line with overall



consumption

Findings and

recommendations of the

2008 Energy Audit

Survey set out for 2010

to be achieved

(iii) Investigate whether heat can be

recovered from water going to evaporator

start up/shut down tank, preheat milk to

condenser (Heat Exchanger)

by December

2010

Investigation carried out as planned n\a This is now added to list

of sites energy saving

options and is to be

assessed against

business guidelines for

capital funding

(iv) Investigate the sequence of operation of

the milling operation so as to utilise the

energy spent as efficiently as possible

by March

2010

Investigation carried out as planned Shorter plant run

time due to product

demand has

reduced the savings

opportunity

significantly

n/a

(v) Investigate the feasibility of recovering

the discharge air from the pneumatic

actuators on closure

by September

2010

Investigation carried out as planned n\a This is now added to list

of sites energy saving

options and is to be

assessed against

business guidelines for

capital funding

(vi) Investigate the possibility of installing a

VSD (reducing impeller trim) on the

distribution pump of Cooling Tower No. 2

by June 2010 Investigation carried out as planned n/a VSDs are now installed

(vii) Investigate the feasibility of reinstating

the steam coil on the heavy fuel oil storage

tank so as to replace the equivalent

electrical counterpart

by September

2010

Investigation carried out as planned n/a Steam heater now

installed

(viii) Evaluate whether the operational

pressure of the standby boiler can be

reduced

by March

2010

Investigation carried out as planned Results showed that

savings were not as

attractive due to the

efficient design of

the burners

Opportunities to run on

reduced pressure during

periods of low

production demand will

for part of ongoing

energy efficiency

evaluation


P a g e | 16


PROJECT REASON TARGETS PROGRAMME/ACTION

REQUIRED

TIME ACHIEVEMENTS V TARGETS /

ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Waste

Management


objective to reduce

hazardous and non-

hazardous waste and

improve recovery, reuse

and recycling of waste

materials

100% of identified

recyclable waste to

be recycled

(i) Continue with reducing the

volume of waste going to landfill

Ongoing during

2010

Achieved as planned. N/A N/A

(ii) Investigate and implement

improved kitchen waste

segregation

By Sept 2010 Investigation carried out as planned.

Limited implementation of findings.

Limited outlets for

collection and disposal

of segregated materials

available.

Continue investigations

– new system must be in

place by end June 2011.

(iii) Continue with waste

management training

Ongoing during

2010

Achieved as planned N/A N/A

(iv) Review reducing 2009 volumes

of wastewater using COD and TOC

monitoring

Ongoing during

2010

Limits for stormwater now set to ensure

that no unnecesaary stormwater is sent

through the WWTP.

N/A Submit limits to Agency

for approval

(v) Review targets for waste

reduction + reuse

By end 2010 Achieved as planned N/A N/A

Fuel & Chemical

Storage


objectives to ensure there

is no contamination as a

result of fuel or chemical

storage on site

All presently

identified potential

risk area to be

addressed

i) Continue with containment works

for inlets, outlets, vent pipes, valves

and gauges

Ongoing during

2010

Suitable containment solution for

intake gauge at Heavy Fuel Oil (HFO)

Bund determined.

HFO intake gauge

Containment works not

implement – financial

reasons

These works to be

undertaken in 2011

Insufficient control

measure identified by

Agency during site

inspection of 27 May

2010 at Nitric and

Caustic delivery area

Appropriate control

measures investigated

and proposals sent to

the Agency for approval.

Control measures to be

implemented 3rd

Quarter 2011

Interim action – delivery

personnel given further

training and instruction.

(ii) Review spill kit requirements Ongoing during

2010

Action achieved. All necessary spill kits

in place

n/a n/a


P a g e | 17


PROJECT REASON TARGETS PROGRAMME/

ACTION REQUIRED


ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Air Emission In line with overall objectives

that operations and activities

at the facility shall not result in

releases of significant

pollutants to the atmosphere

Emissions to the

atmosphere shall

not exceed emission

limit values set out

in the IPPC licences

Monitoring as per licence

requirements

May 2010

&

October 2010

Action achieved. Monitoring undertaken

as planned

n/a n/a

Noise Emissions In line with overall objectives

that noise emissions shall not

impact the amenity of

neighbouring properties

Noise emissions

associated with

employee carpark

gate to be mitigated

(i) Install appropriate noise control

measures at employee carpark gate

By May 2010 Action achieved. New gear box and pads

installed on the electronic gate to the

employee carpark

n/a n/a

(ii) Continue with annual noise survey By September

2010

Action achieved. Monitoring undertaken as

planned

n/a n/a

Fugitive

Emissions

In line with overall objectives

to reduce risk of contamination

as a result of fugitive emissions

Continue with

identification of

fugitive emissions

(i) Prepare a schedule/plan for

investigating fugitive emissions

By June 2010 Action achieved. Plan established in

accordance with Leak detection standard EN

378 (Refrigerating Systems and Heat pump –

safety and environmental requirements)

and Regulation (EC) No 2037/2000 on

controlled substances

n/a n/a

Facility

Equipment and

Maintenance


to improve process control

All key plant and

equipment for

control of emissions

to be included in

SAPs

Continue with maintenance

programme. Review + update if

necessary

Ongoing

during 2010

Achieved as planned

N/A N/A

Goods

consumption


to reduce the facilities overall

raw materials resource

consumption per tonne of

finished product

Maintain 99%

recovery of

ingredients in verses

finished goods.

(i) Outstanding spill prevention

training for raw material handling

personnel to be prioritised in 2010.

By May 2010 Action achieved. Training provided as

planned

n/a n/a

(ii) Establish improvements to reduce

losses in the production plant

By October

2010

Action achieved. Customer transport

packaging which had previously been

identified by Cadbury as a key area of

product losses, has been replaced with a

suitable alternative.

n/a n/a


P a g e | 18


PROJECT REASON TARGETS PROGRAMME/

ACTION REQUIRED


ACTION PROGRAMMES

DIFFICULTIES

ENCOUNTERED

CORRECTIVE

ACTION

Environmental

Management

System


objectives to make

provisions for the

management of facility

activities on a planned

basis having regard to the

desirability of ongoing

assessment, recording and

reporting of matters

affecting the environment

Management +

Reporting Structure

Schedule of

environmental

Objectives and Targets

Environmental

Management

Programme

Documentation

Data Management

System

Corrective Action

Awareness and

Training

Communication

Programme

Efficient Process

Control

Accident Prevention

Emergency Response

Reports

Continue annual review of

procedures and update as necessary

By December

2010

Action achieved. All areas of the

environmental management system

audited, reviewed and updated as necessary

n/a n/a


Page | 19

3.3 Environmental Management Programme Proposal 2011

The targets and action programmes for the year are set out on an annual basis at the first Environmental

Management Meeting of the year. The environmental management plan (EMP) for 2011 proposes the

programmes and actions set out in Table 13 below to be undertaken in the coming year.

Table 13 CADBURY RATHMORE – 2011 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 1 of 4

PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME

Stormwater

Management


objectives to

improve storm

water discharge

quality and overall

target that these

improvements are

achieved by 2012

the following

targets and actions

are proposed for

2011

Close out on the

upgrading works

scheduled for to be

completed in 2010 by

March 2011

Pipelines S01-S85, S85-S21, S24-S86,

S86-S87, S87-S12, S12-S12a to be

installed

Contractor March 2011

Upgrade defective

stormwater pipelines

identify at northern

end of site.

Pipelines to be upgraded: S01-S29, S29-

S30, S31-S32 and S32-S33

Contractor Oct 2011

Complete survey on

outstanding drains

Remedial action required to provide

access to facilitate close out on

drainage survey

Contractor June 2011

Install forecourt type

oil interceptor at HFO

delivery area

New concrete plinth and drainage

channel to be constructed and

connected to new oil interceptor

Contractor Oct 2011

Water

Resource

Management


objective to

improve water

conservation the

following targets

and actions are

proposed for 2011

Identify future water

reduction

programmes

Undertake review of the water balance

data acquired during 2010

QE Manager Dec 2011

Review water usage

targets

Undertake review of the water meter

data acquired during 2010

QE Manager Dec 2011

Wastewater

management


objectives to

improve

wastewater quality

discharges and

overall target that

this is to be

achieved by 2012

the following

targets and actions

are proposed

during 2011

Upgrade of raw

effluent Balance Tank

Refurbish glass lined steel structure of

Balance Tank, improve access to tank,

upgrade aeration system.

Contractor July 2011

Investigate impacts of

phosphorus removal

system on sludge

volumes

Review sludge levels with phosphorus

removal equipment installed

QE Manager Sept 2011


Page | 20

Table 13ctd CADBURY RATHMORE – 2011 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) – Part 2 of 4

PROJECT REASON TARGETS PROGRAMME/ACTION REQUIRED RESPONSIBILITY TIME

Energy Use In line with overall



consumption the

following targets

and actions are

proposed during

2011

Waste heat from the

discharge stream

from dryer 0

Option for recuperating the waste heat

from the discharge stream from dryer 0

to be assessed against business

guidelines for capital funding

Facility

Production

Manager

End 2011

Evaporator Heat

Exchanger / heat

recovery system

Identified site energy saving options

associated with investigation into

recovered heat from water going to

evaporator start up/shut down tank,

preheat milk to condenser (Heat

Exchanger) to be assessed against

business guidelines for capital funding

Facility

Production

Manager

End 2011

Discharged air from

the pneumatic

actuators

Options for recovering the discharge

air from the pneumatic actuators on

closure to be assessed against business

guidelines for capital funding

Facility

Production

Manager

End 2011

Operational pressure

of the standby boiler

Opportunities to run on reduced

pressure during periods of low

production demand to be further

investigated as part of ongoing energy

efficiency evaluation

Facility

Production

Manager

End 2011

Waste

Management


objective to reduce

hazardous and non-

hazardous waste

and improve

recovery, reuse and

recycling of waste

materials the

following targets

and actions are

proposed during

2011

Improve segregation

of kitchen waste

Appropriate waste receptacles to be

provided for Kitchen waste.

Collection outlet for food waste to be

established

QE Manager June 2011


Page | 21



REQUIRED

RESPONSIBILITY TIME

Fuel &

Chemical

Storage


objectives to ensure

there is no

contamination as a

result of fuel or

chemical storage on

site the following

targets and actions

are proposed during

2011

Drainage from caustic

and nitrite delivery

areas to be diverted

for collection and safe

disposal

Improve delivery bay for caustic and

nitric delivery vehicles. New

concrete plinth and drainage channel

to be constructed and connected to

process water drainage system

Contractor end 2011.

Condensate from

heavy fuel oil

pumping and heating

set to be connected

to appropriate drain

Connection to be made to existing

drainage in area. Condensate to be

directed through existing oil

interceptor.

Contractor Aug 2011

Install forecourt type

oil interceptor at HFO

delivery area

New concrete plinth and drainage

channel to be constructed and

connected to new oil interceptor

Contractor Oct 2011

Air Emission In line with overall

objectives that

operations and

activities at the

facility shall not result

in releases of

significant pollutants

to the atmosphere

the following targets

and actions are

proposed during 2011

Emissions to the

atmosphere shall not

exceed emission limit

values set out in the

IPPC licences

Monitoring as per licence

requirements

Contractor May 2011

&

October

2011

Noise

Emissions


objectives that noise

emissions shall not

impact the amenity of

neighbouring

properties the

following targets and

actions are proposed

during 2011

Noise levels at site

boundaries shall not

exceed limit values

set out in the IPPC

licences

Continue with annual noise survey

Contractor By

September

2011

Fugitive

Emissions


objectives to reduce risk

of contamination as a

result of fugitive

emissions the following

targets and action are

proposed during 2011

Routine monitoring of

the identified sources of

fugitive emissions

- Continue with monitoring of stormwater

discharges

- Continue with maintenance contract for

ODS monitoring

- Implement maintenance contract for

ODS monitoring for identified laboratory

equipment

QE Manager +

Facilities Manager

Ongoing

through 2011


Page | 22



REQUIRED

RESPONSIBILITY TIME

Facility

Equipment and

Maintenance


objectives to

improve process

control the

following targets

and actions are

proposed during

2011

Equipment maintenance

programme

Review + update if necessary Facility

Maintenance

Manager

Ongoing

during 2011

Goods

consumption



the facilities overall

raw materials

resource

consumption per

tonne of finished

product the

following targets

and action

programmes are

proposed during

2011

Maintain 99% recovery of

ingredients in verse

finished goods.

- Continue with spill prevention

training as required.

- Continue with investigating

improvements to reduce losses

in the production plant.

Facility QE

Manager

Facility QE

Manager

End 2011

End 2011

Environmental

Management

System


objectives to make

provisions for the

management of

facility activities on

a planned basis

having regard to the

desirability of

ongoing

assessment,

recording and

reporting of

matters affecting

the environment

the following

targets and actions

are proposed

during 2011

Management + Reporting Structure Schedule of environmental Objectives and Targets Environmental Management Programme Documentation Data Management System Corrective Action Awareness and Training Communication Programme Efficient Process Control Accident Prevention Emergency Response Reports

Continue annual review of procedures and update as necessary Prepare site ELRA

Facility QE Manager Contractor

By December 2011 By December 2011


Page | 23

Table 14 Summary of 2011 Project Schedule

Project Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec

Storm Water Management √ √ √ √ √ √ √ √ √ √ √ √

Water Resource management √ √ √ √ √ √ √ √ √ √ √ √

Wastewater Management √ √ √ √ √ √ √ √ √ √ √ √

Energy Use √ √ √ √ √ √ √ √ √ √ √ √

Power generation √

Waste Management √ √ √ √ √ √ √ √ √ √ √ √

Fuel & Chemical Storage √ √ √ √ √ √

Air Emissions √ √

Noise Emissions √

Fugitive Emissions √

Facility & Equipment Maintenance √

Goods Consumption √ √ √

EMS √ √ √ √ √ √ √ √ √ √ √ √

3.4 Other Significant Environmental Aspects, Audits etc

3.4.1 ISO 14001 EMS Audit

In 2010, Cadbury’s Rathmore ISO 14001-certified EMS underwent an annual audit for its conformance with the

standard and was recommended for continued registration following this evaluation. No non-conformances

were noted during this audit which was undertaken by the NSAI.

3.4.2 Internal Audit

An audit of the Environmental Management System was undertaken during the period May - June by Cadbury

Personnel and external Environmental Consultants Malachy Walsh and Partners. This audit did not highlight

any significant new issues.

3.4.3 Management Environmental Meetings

Key internal environmental meetings are held by management at Cadbury Rathmore three times per year.

There are a number of unscheduled meetings as needed. The first meeting of the year reviewed the previous

year and established the programme of works for the coming year. Subsequent meetings updated the

schedule of works for the year.

4 LICENCE-SPECIFIC REPORTS

4.1 Noise Monitoring report summary

Dixon Brosnan undertook a noise survey in September 2010 and included a day time and night-time survey.

Overall noise levels recorded were satisfactory. The daytime 55db and night time 45db noise limits specified in

licence P0795-01 were not exceeded.


Page | 24

APPENDIX A| AER SUMMARY DATA TABLES

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