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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) i HYDROGEOLOGICAL SITE INVESTIGATION GALWAY METAL COMPANY ORANMORE COUNTY GALWAY Prepared For: - Galway Metal Company Ltd., Oranmore, Co. Galway Prepared By: - O’ Callaghan Moran & Associates, Granary House, Rutland Street, Cork. 17 th August 2009 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 13-09-2016:01:48:03
Transcript
Page 1: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) i

HYDROGEOLOGICAL SITE INVESTIGATION

GALWAY METAL COMPANY

ORANMORE

COUNTY GALWAY

Prepared For: -

Galway Metal Company Ltd.,

Oranmore,

Co. Galway

Prepared By: -

O’ Callaghan Moran & Associates,

Granary House,

Rutland Street,

Cork.

17th

August 2009

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) i

TABLE OF CONTENTS

PAGE

1 INTRODUCTION ........................................................................................... 1

2 SITE DESCRIPTION...................................................................................... 2

2.1 SITE LOCATION AND SURROUNDING LANDUSE ......................................................................2 2.2 SURFACE WATER DRAINAGE .................................................................................................2 2.3 SITE INSPECTION ....................................................................................................................3 2.4 SITE LAYOUT & OPERATION ..................................................................................................3 FIGURE 2.2 SITE LAYOUT & DRAINAGE A3..........................................................................................5 2.5 GEOLOGY AND HYDROGEOLOGY ...........................................................................................6

2.5.1 Soils and Subsoil ..............................................................................................................6 2.5.2 Bedrock.............................................................................................................................6

2.6 HYDROGEOLOGY....................................................................................................................6 2.6.1 Aquifer Classification.......................................................................................................6

2.7 AQUIFER VULNERABILITY .....................................................................................................9 2.7.1 Groundwater Flow Direction............................................................................................9 2.7.2 Nearby Wells ....................................................................................................................9

3 GROUNDWATER QUALITY ASSESSMENT ........................................... 12

3.1 WELL LOCATIONS ................................................................................................................ 12 3.2 METHODOLOGY ................................................................................................................... 12 3.3 GROUNDWATER SAMPLING .................................................................................................. 14 3.4 GROUNDWATER QUALITY .................................................................................................... 15 3.5 DATA INTERPRETATION ....................................................................................................... 19

3.5.1 Hydrocarbons.................................................................................................................. 19 3.5.2 Polycyclic Aromatic Hydrocarbons (PAH) .................................................................... 19 3.5.3 Volatile Organic Compounds (VOCs)............................................................................ 20 3.5.4 Metals and Anions .......................................................................................................... 20

4 SOILS ASSESSMENT .................................................................................. 21

4.1 FIELD SCREENING ................................................................................................................ 21 4.2 SOIL SAMPLING.................................................................................................................... 22 4.3 SOIL QUALITY ...................................................................................................................... 22 4.4 DATA INTERPRETATION ....................................................................................................... 22

4.4.1 Petroleum Hydrocarbons ................................................................................................ 22 4.4.2 Volatile Organic Compounds (VOCs)............................................................................ 23 4.4.3 Metals ............................................................................................................................. 23

5 RISK ASSESSMENT .................................................................................... 28

6 CONCLUSIONS AND RECOMMENDATIONS ........................................ 30

6.1 CONCLUSIONS ...................................................................................................................... 30 6.1.1 Soil.................................................................................................................................. 30 6.1.2 Groundwater ................................................................................................................... 30

6.2 RECOMMENDATIONS ............................................................................................................ 32 6.2.1 Soil.................................................................................................................................. 32 6.2.2 Groundwater ................................................................................................................... 32 6.2.3 Surface Water ................................................................................................................. 33

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) ii

LIST OF APPENDICES

APPENDIX 1 - Borehole Logs

APPENDIX 2 - OCM Sampling Protocol

APPENDIX 3 - Laboratory Results

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1 INTRODUCTION

Galway Metal Company Ltd. (Galway Metal) requested O’ Callaghan Moran &

Associates (OCM) to conduct a hydrogeological assessment of its facility at Oranmore,

County Galway.

Agricultural lands adjoining the Galway Metal facility have been contaminated by

oily water discharges from the site. OCM understand that there have in the past been

problems with leaks in the surface water drains beneath the site and that these leaks

are the most likely source of the oily discharges to the farm land to the east of the

facility and of the impacts in the groundwater system beneath and down hydraulic

gradient of the facility. OCM completed an initial assessment of the impacted farm

land in 2002. At that time, the impacted area was estimated at 250m2.

OCM recommended that the impacted soils be removed, however it is understood

that, due to issues over accessing the lands, the removal works could not be carried

out. It is now intended to proceed with the remediation of the impacted area by the

removal of all of the contaminated soils and a further investigation of the

contaminated area was required to quantify the volume of materials to be removed.

In addition to the removal of the impacted soils, Galway County Council (the

Council) requested that three groundwater monitoring wells be installed down

gradient of the impacted area, with a further five wells to be positioned within and

adjoining the Galway Metal site -two within the site, two in the car park north of the

processing area and one on access road south of the processing area.

The OCM assessment included a desk study to establish the local geological and

hydrogeological conditions and intrusive investigations, including a soil and

groundwater sampling programme. This report presents the findings of the OCM

assessment.

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2 SITE DESCRIPTION

2.1 Site Location and Surrounding Landuse

The site is located in Oranmore approximately 8km to the east of Galway City (Figure

2.1). The site is bounded to the south by Galway Oil Company, which is an oil

distribution centre that stores home heating oil and diesel. To the east are agricultural

lands, a portion of which have been impacted by the oily water run-off. The lands to

the north are lying fallow, but it is understood that these may be developed for

industrial purposes. The lands to the west of the site are occupied by the City Bin

Company Materials Recovery Facility, which operates under a waste licence issued

by the EPA.

2.2 Surface Water Drainage

The surface water drainage details are shown on Figure 2.2. The site slopes gently

from the northwest to the south east and, with the exception of landscaped areas, is

almost completely concrete paved. Surface water run-off from the concrete paving is

collected in the storm drain system that runs beneath the scrap metal processing area.

All run-off is channelled to a number of oil water interceptors located in the southern

section of the site. These interceptors discharge to an unnamed stream to the south of

the site. This stream flows from west to east for approximately 450m and then loops

around and flows west again to Oranmore Bay, which is approximately 1.5km to the

south west of the site.

There is evidence of oil staining at the discharge point of the surface water drainage

system to the stream. This may indicate that the interceptor system is not effectively

retaining hydrocarbons within the interceptors.

Based on previous assessments undertaken by OCM in 2004 the surface water

drainage system was not fully sealed and oily water collected from the yard leaked

from joints along manhole connections into the underlying subsoils. These leaks

ultimately discharged into the farm land to the west which is located at a lower

elevation than the site.

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2.3 Site Inspection

OCM completed a site inspection on 19th

June 2009. The objective of the inspection

was to gain an understanding of site operations and to identify potential sources of the

oil release. It included a visual assessment of the facility’s storm drainage and oil

water interceptor system and the impacted area in the field to the east of the facility.

2.4 Site Layout & Operation

The site layout is shown on Figure 2.2. There is a weighbridge at the site entrance.

Adjacent to the weighbridge is the Main Processing Building. The central section of

the building contains discrete waste processing areas for recycling of non-ferrous,

aluminium, new and reusable steel, paper and glass processing and plastic processing.

The eastern section of the building is occupied by a maintenance garage with offices

in the western part. The building is in good repair and well maintained with roof,

walls and concrete floors in good condition.

The remainder of the facility is occupied by car parking and external materials

storage, handling and processing areas. The main processing area (7993m2) includes

discrete storage areas for cast aluminium, aluminium turnings, stainless steel turnings,

cable and stainless steel storage. This area is provided with a concrete slab, which is

bunded and graded to falls to contain and collect surface water run-off, which is

directed to the interceptor system.

To the north of the building are four plastic tanks and one steel tank, each with an

approximate capacity of 1,600 litres, which are used to store waste oil removed from

the end of life vehicles. The tanks are located in a concrete containment bund, which

appears to be in good condition. These vehicles are depolluted in a designated

concrete paved area.

There are two 7,000 litre oil storage tanks located in a concrete bund along the

northeastern site boundary, which are used store hydraulic oil and fuel oil for the site

vehicles. The bund which appears in good condition.

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SCALE

FIGURE No.Legend

TITLE

CLIENTO' Callaghan Moran & Associates.

environmental management for business

not be used, reproduced or disclosed to anyone without the prior written

permission of O'Callaghan Moran & Associates and shall be returned upon request.

This drawing is the property of O'Callaghan Moran & Associates and shall

Granary House, Rutland Street,

Tel. (021) 4321521 Fax. (021) 4321522

Cork, Ireland.

email : [email protected]

Galway Metal Company

kilometers

0 2.5 5

Site Location

Site Location

2.1

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Page 8: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) 6 of 33

2.5 Geology and Hydrogeology

Information on the local and regional geology and hydrogeology was derived from a

desk study, which included Geological Survey of Ireland (GSI) geology databases;

Teagasc Soil Maps for the region; in-house databases prepared by OCM and the site

investigation undertaken by OCM in June 2009. The latter, which included the

installation of boreholes and groundwater monitoring wells, is described in more

detail in Section 3.

2.5.1 Soils and Subsoil

The subsoils distribution, which is based on the Teagsc maps, is shown on Figure

2.3. The soils across most of the site are classified as Made Ground i.e. fill

material and concrete. The soils in the lands surrounding the site are classified by

as Limestone Till (TLs). The OCM site investigation confirmed the Teagasc

classification. The subsoil appears to be approximately 2m thick beneath the

facility based on the borehole log for BH-8 located in the southeast section of the

site.

2.5.2 Bedrock

The bedrock geology is illustrated on Figure 2.4. The site is underlain by

undifferentiated Visean Limestone. During the monitoring well installation,

bedrock comprising dark grey limestone was encountered at depths ranging from

1.3m in the lands to the east of the site, to 4.3m within the site itself. The variation

in the depth to bedrock is probably due the fact that the site has been raised with

fill material.

2.6 Hydrogeology

2.6.1 Aquifer Classification

The GSI has developed a classification system for aquifers based on the value of

the resource and the hydrogeological characteristics. The bedrock aquifer beneath

the site is characterised by the GSI as a Regionally Important Karstified Aquifer

(Rkc) as shown on Figure 2.5.

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Page 10: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

SCALE

FIGURE No.Legend

TITLE

CLIENTO' Callaghan Moran & Associates.

environmental management for business

not be used, reproduced or disclosed to anyone without the prior written

permission of O'Callaghan Moran & Associates and shall be returned upon request.

This drawing is the property of O'Callaghan Moran & Associates and shall

Granary House, Rutland Street,

Tel. (021) 4321521 Fax. (021) 4321522

Cork, Ireland.

email : [email protected]

Galway Metal Company

0 0.5 1

kilometers

Site Location

Subsoil Classification

Subsoil Classification

TLs - Limestone Till

Made - Made Ground

RckCa - Calcareous Rock

FenPt - Fen Peat

A - Alluvium

Cut - Cutover Peat

Mesc - Esturine Seds

2.3

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2.7 Aquifer Vulnerability

Vulnerability is defined by the GSI as the intrinsic geological and hydrogeological

characteristics that determine the ease with which groundwater may be contaminated

by human activities. Vulnerability categories range from Extreme (E) to High (H) to

Moderate (M) to Low (L) and are dependant on the nature and thickness of subsoils

above the water table.

The GSI vulnerability map indicates that the vulnerability across the site ranges from

high to low (HL). Based on the thickness of the subsoils recorded during the site

investigation, OCM considers the vulnerability to range from extreme (E) to high (H).

The aquifer vulnerability is shown on Figure 2.6.

2.7.1 Groundwater Flow Direction

The water table appears to be confined by the glacial till subsoil beneath the site. The

water level in the bedrock wells indicates levels above the top of bedrock ranging

from 1-2.5 above the top of bedrock. Based on the levels recorded in the on-site wells,

the groundwater flow is from north-west to south-east towards the stream that runs

along the southern site boundary south and it is likely that shallow groundwater

discharges to the stream.

The underlying bedrock is characterised as RkC, which means a Regionally Important

bedrock aquifer with conduit flow. Essentially the rock only allows water through in

large conduits that have been opened up due to dissolution by water moving through

fractures and fissures (karstification). In those parts of the rock that are not karstified,

there is usually little or no groundwater, as the rock is essentially massive and solid.

Groundwater flow in this types of bedrock aquifer is extremely difficult to predict but

will ultimately be expected to follow the regional drainage pattern with groundwater

moving toward the sea to the west of the site. Where contaminants enter the bedrock

they can travel very large distances 2-3km in timescales ranging from hours to weeks.

2.7.2 Nearby Wells

OCM carried out a review of the groundwater well database maintained by the GSI

and the EPA. The closest recorded well to the site is approximately 650m to the south

southwest in Oranmore. The well is described by the GSI as being for agricultural

and domestic use.

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3 GROUNDWATER QUALITY ASSESSMENT

The groundwater quality assessment included the installation of monitoring wells;

measurement of groundwater levels and the collection of representative groundwater

samples for laboratory testing.

3.1 Well Locations

Eight (8 No.) monitoring wells (BH-01 to BH-08) were installed at the locations

shown on Figure 3.1. The number and locations of the wells were as requested by

Galway County Council.

BH-01 and BH-02 were located at points that were considered to be upgradient of the

site. BH-01 is to the west of the Main Building in the south eastern corner of a gravel

covered truck parking area. BH-02 is to the north of the Main Building in a tarmac

paved staff car parking area.

BH-03 was located downgradient of the site at its southern boundary, to the west of

the Galway Oil site. BH-04, 05 and 06 were located on private agricultural lands to

the east of the site, where the oil contamination has occurred. BH-04 is upgradient of

the oil stained area, but downgradient of the site. BH-05 and BH-06 are downgradient

of the impacted area. BH-07 and BH-08 were located within the site along the eastern

site boundary.

3.2 Methodology

The wells were drilled installed using rotary percussion drilling methods between the

19th

of June 2009 and the 1st of July 2009 by Glovers Drilling under the supervision of

an OCM hydrogeologist. The boreholes were logged by OCM in accordance with

BS5930. The borehole logs are presented in Appendix 1.

They boreholes were drilled at 150mm diameter and cased to bedrock to ensure the

hole stayed open. They extended to maximum depths of 10m below ground level.

Bedrock was encountered at between 1.3m and 4.3m. Groundwater was encountered

between 3m and 6.4m.

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O’ Callaghan Moran & Associates.Granary House, Rutland Street,Cork Ireland.Tel. (021) 4321521 Fax. (021) 4321522email : [email protected]

This drawing is the property of O'Callaghan Moran & Associates and shall notbe used, reproduced or disclosed to anyone without the prior written permissionof O'Callaghan Moran & Associates and shall be returned upon request.

FIGURE NUMBER

Scale

Not To Scale

Job Number:

CLIENT

TITLE

DetailsGalway Metal Company 3.1

Groundwater Well Locations

Groundwater Well

Site Boundary

N

09-123-03

BH-01

BH-02

BH-03

BH-07

BH-04

BH-05

BH-06

BH-08

Impacted Area

0m 50m25m 75m

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The monitoring wells are all constructed to monitor groundwater movement within

the bedrock. They were constructed using uPVC 50 mm diameter slotted and solid

standpipe. Solid standpipe was placed from ground level to the top of the rock and

slotted standpipe from the rock to the completion depth.

A gravel filter pack was inserted in the annular space between the boring and the

standpipe to a level of 0.5 m above the slotted section of the standpipe. Above the

gravel filter, the annular space was filled with a bentonite seal. The solid section of

the well pipe was brought above the ground level and fitted with a steel protective

well casing, set in a concrete base. In the operational yard areas the wells were

finished with flush steel covers to avoid damage caused by vehicles. The well

construction details are shown on the borehole logs in Appendix 1.

During drilling, strong hydrocarbon odours and oil sheens were noted in the

groundwater encountered in BH-03 and BH-08. Staining of the ground surface was

noted in the area surrounding BH-01, which may be associated with minor leaks from

the trucks parked in the area.

3.3 Groundwater Sampling

All wells were developed and left to stabilise for a period of more than 48 hours.

Groundwater samples were collected from the wells on the 9th

July 2009. After

completion of groundwater level measurements, the wells were purged to remove the

stagnant water in the well and surrounding gravel pack.

Purging is necessary to ensure that the groundwater parameters measured are

representative of the formation and not the stagnant water in the monitoring well or

surrounding gravel filter. This process is particularly important where contamination

of the groundwater has previously been detected.

Wells BH-01, 02, 04, 05, 06 and 07 were purged using with a 12 volt submersible

pump. The pump was cleaned and new sampling tubing was provided between each

well. Due to the presence of odours and an oily sheen on the groundwater noted

during the drilling of BH-03 and BH-08, these wells were purged using dedicated

plastic bailers to avoid cross continuation of the other wells.

pH, temperature and electrical conductivity were measured in the field and the results

are presented in Table 3.1.

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Table 3.1

Location PH

(pH units)

Temperature

(°C)

Electrical

Conductivity

(µS/cm)

GW Level

(mBGL)

9th

July 2009 9th

July 2009 9th

July 2009 9th

July 2009

BH-1 9.69 12 618 3.89

BH-2 7.32 11.7 754 2.47

BH-3 7.05 14.5 582 1.10

BH-4 6.94 13. 675 0.77

BH-5 6.6 13.9 773 0.55

BH-6 6.62 13 734 0.79

BH-7 6.86 12.7 725 3.2

BH-8 6.92 13.7 693 2.23

All samples were collected in accordance with OCM’s sampling protocol, a copy of

which is included in Appendix 2. The samples were placed in laboratory prepared

containers and stored in coolers prior to shipment to Jones Environmental Forensics,

UK (UKAS Accredited). Chain of custody documentation is included in Appendix 3.

During sampling strong hydrocarbon odours were noted at BH-03 and BH-08 and free

product was found in BH-08. Hydrocarbon odours or visual evidence of

contamination were not detected at of the other wells.

3.4 Groundwater Quality

The samples were analysed for – diesel range Organics (DRO), petrol range organics

(PRO), mineral oils, VOCs, BTEX (benzene, toluene, ethyl benzene, xylene),

Polyaromatic Hydrocarbons (PAHs), pH, arsenic, aluminium, antimony, barium,

cadmium, chromium, copper, iron, mercury, nickel, selenium, lead, zinc, ammonia,

sodium, potassium chloride, sulphate and sulphide.

The laboratory reports are included in Appendix 3 and the results are summarised in

Tables 3.2 to 3.5. The Tables include relevant vlaues specified in the EPA Interim

Guideline Values (IGVs). The IGVs are not statutory guidelines, but have been

published by the EPA to assist in the assessment of impacts on groundwater quality.

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Table 3.2 Groundwater Metals and Inorganics Results - Galway Metal - July 2009

Parameter Units BH-01 BH-02 BH-03* BH-04 BH-05 BH-06 BH-07 BH-08** IGV

Aluminium - dissolved µg/l 243 307 221 243 300 287 286 296 200

Arsenic - dissolved µg/l 3.3 2.7 3.3 3.9 4.4 2.9 <2.5 5.7 10

Antimony - dissolved µg/l <2 <2 <2 <2 <2 <2 <2 <2 -

Barium - dissolved µg/l 47 60 90 30 58 66 29 63 100

Cadmium - dissolved µg/l <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 5

Chromium - dissolved µg/l <1.5 <1.5 <1.5 <1.5 <1.5 <1.5 <1.5 <1.5 30

Copper - dissolved µg/l <7 <7 <7 <7 <7 <7 <7 <7 30

Iron - dissolved µg/l <20 <20 <20 <20 58 31 <20 108 200

Mercury - dissolved µg/l <1 <1 <1 <1 <1 <1 <1 <1 1

Nickel - dissolved µg/l 4 3 7 5 4 <2 3 7 20

Selenium - dissolved µg/l <3 <3 <3 <3 <3 <3 <3 <3 -

Lead - dissolved µg/l <5 <5 <5 <5 <5 <5 <5 <5 10

Zinc - dissolved µg/l 3 5 5 <3 4 <3 9 6 100

Sulphate mg/l 12.48 23.71 32.97 17.53 17.31 3.83 26.06 49.35 200

Chloride mg/l 28.6 24.2 38.9 31.4 27.7 25.3 25.1 53.0 30

Potassium - dissolved mg/l 5.05 1.82 7.30 7.99 5.41 6.51 2.76 23.18 5

Sodium - dissolved mg/l 19.07 13.97 17.50 20.55 18.15 16.26 17.53 37.02 150

Ammoniacal Nitrogen mg/l 2.62 0.03 0.74 1.03 1.02 1.78 0.08 3.14 0.11

Sulphide �g/l <250 <250 <250 <250 <250 <250 <250 <250 -

Table 3.3 Groundwater Organics Results - Galway Metal - July 2009

Parameter Units BH-01 BH-02 BH-03* BH-04 BH-05 BH-06 BH-07 BH-08** IGV

DRO mg/l 0.16 <0.01 40.74 0.19 1.35 1.48 <0.01 302.94 0.01

Mineral Oil mg/l <0.01 <0.01 <0.01 <0.01 0.67 0.74 <0.01 151.47 0.01

PRO (C4-C8) mg/l <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 1.03 0.01

PRO (C8-C12) mg/l <0.1 <0.1 0.37 <0.1 <0.1 <0.1 <0.1 12.83 0.01

PRO (C4-12) mg/l <0.1 <0.1 0.37 <0.1 <0.1 <0.1 <0.1 13.86 0.01

** Sample had to be diluted by a factor of 100 to allow analysis.

** Sample had to be diluted by a factor of 100 to allow analysis.

* Sample had to be diluted by a factor of 25 to allow analysis.

* Sample had to be diluted by a factor of 25 to allow analysis.

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Table 3.4 Groundwater PAH Results - Galway Metal - July 2009

Parameter Units BH-01 BH-02 BH-03* BH-04 BH-05 BH-06 BH-07 BH-08** IGV

Naphthalene �g/l <0.1 <0.1 39.3 <0.1 <0.1 <0.1 <0.1 57 1

Acenaphthylene �g/l <0.08 <0.08 <2 <0.08 <0.08 <0.08 <0.08 <8 -

Acenaphthene �g/l <0.1 <0.1 170.2 <0.1 <0.1 <0.1 <0.1 <10 -

Fluorene �g/l <0.07 <0.07 134 <0.07 <0.07 <0.07 <0.07 19 -

Phenanthrene �g/l <0.07 <0.07 464.1 <0.07 <0.07 <0.07 <0.07 29 -

Anthracene �g/l <0.08 <0.08 <2 <0.08 <0.08 <0.08 <0.08 <8 10000

Fluoranthene �g/l <0.09 <0.09 324.5 <0.09 <0.09 <0.09 <0.09 <10 1

Pyrene �g/l <0.12 <0.12 186 <0.12 <0.12 <0.12 <0.12 <12 -

Benz(a)anthracene �g/l <0.09 <0.09 6 <0.09 <0.09 <0.09 <0.09 <8 -

Chrysene �g/l <0.1 <0.1 4.6 <0.1 <0.1 <0.1 <0.1 <10 -

Benzo(bk)fluoranthene �g/l <0.26 <0.26 <6.5 <0.26 <0.26 <0.26 <0.26 <26 0.50

Benzo(a)pyrene �g/l <0.12 <0.12 <3 <0.12 <0.12 <0.12 <0.12 <12 0.01

Indeno(123cd)pyrene �g/l <0.1 <0.1 <2.5 <0.1 <0.1 <0.1 <0.1 <10 0.05

Dibenzo(ah)anthracene �g/l <0.1 <0.1 <2.5 <0.1 <0.1 <0.1 <0.1 <10 -

Benzo(ghi)perylene �g/l <0.12 <0.12 <3 <0.12 <0.12 <0.12 <0.12 <12 -

* Sample had to be diluted by a factor of 25 to allow analysis.

** Sample had to be diluted by a factor of 100 to allow analysis.

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Dichlorodifluoromethane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Methyl Tertiary Butyl Ether �g/l <2 <2 <2 4 <2 <2 <2 13 30

Chloromethane �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Vinyl Chloride �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Bromomethane �g/l <1 <1 <1 <1 <1 <1 <1 <1 -

Chloroethane �g/l <3 <3 24 6 <3 4 <3 19 -

Trichlorofluoromethane �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

1,1-Dichloroethene �g/l <3 <3 <3 <3 <3 <3 <3 <3 30

Carbon Disulphide �g/l NA NA NA NA NA NA NA NA -

Dichloromethane �g/l <3 <3 <3 <3 <3 <3 <3 <3 10

Trans-1,2-Dichloroethene �g/l <3 <3 <3 <3 <3 <3 <3 <3 30

1,1 - Dichloroethane �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Cis-1,2-Dichloroethene �g/l <3 <3 <3 <3 <3 <3 <3 15 30

2,2 Dichloropropane �g/l <1 <1 <1 <1 <1 <1 <1 <1 -

Bromochloromethane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Chloroform �g/l <3 <3 <3 <3 <3 <3 <3 <3 12

1,1,1-Trichloroethane �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

1,1-Dichloropropene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Carbontetrachloride �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

1,2-Dichloroethane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Benzene �g/l <3 <3 <3 <3 <3 <3 <3 7 1

Trichloroethene �g/l <3 <3 <3 <3 <3 <3 <3 <3 70

1,2-Dichloropropane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Dibromomethane �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Bromodichloromethane �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Cis-1,3-Dichloropropene �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Toluene �g/l <3 <3 <3 <3 <3 <3 <3 495 10

Trans-1,3-Dichloropropene �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

1,1,2-Trichloroethane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Tetrachloroethene �g/l <3 <3 <3 <3 <3 <3 <3 7 40

1,3,-Dichloropropane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Dibromochloromethane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

1,2-Dibromoethane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Chlorobenzene �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

1,1,1,2-Tetrachloroethane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Ethylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 344 10

m/p Xylene �g/l <5 <5 <5 <5 <5 <5 <5 2375 10

o Xylene �g/l <3 <3 <3 <3 <3 <3 <3 1498 10

Styrene �g/l <2 <2 <2 <2 <2 <2 <2 47 -

Bromoform �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

Isopropylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 51 -

1,1,2,2 Tetrachloroethane �g/l <4 <4 <4 <4 <4 <4 <4 <4 -

Bromobenzene �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

1,2,3-Trichloropropane �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Propylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 147 -

2-Chlorotoluene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

1,3,5-Trimethylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 763 -

4-Chlorotoluene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Tert-Butylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

1,2,4-Trimethylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 1732 -

Sec-Butylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 38 -

4-Isopropyltoluene �g/l <3 <3 <3 <3 <3 <3 <3 26 -

1,4- Dichlorobenzene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

1,3-Dichlorobenzene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

n-Butylbenzene �g/l <3 <3 <3 <3 <3 <3 <3 116 -

1,2-Dichlorobenzene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

1,2-Dibromo-3-Chloropropane �g/l <2 <2 <2 <2 <2 <2 <2 <2 -

1,2,4-Trichlorobenzene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Hexachlorobutadiene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

Naphthalene �g/l <2 <2 12 <2 <2 <2 <2 191 1

1,2,3-Trichlorobenzene �g/l <3 <3 <3 <3 <3 <3 <3 <3 -

* Sample had to be diluted by a factor of 25 to allow analysis.

** Sample had to be diluted by a factor of 100 to allow analysis.

NA Denotes parameter results not available

Table 3.5 Groundwater VOC Results - Galway Metal - July 2009

Parameter Unit BH-01 BH-02 BH-03* BH-04 BH-05 BH-06 BH-07 BH-08** IGV

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3.5 Data Interpretation

3.5.1 Hydrocarbons

Hydrocarbons were detected at elevated levels in BH-03 and BH-08, with

lower levels detected in BH-01, which is up hydraulic gradient of the Galway

Metal site, and in BH-04, 05 and 06 in the agricultural lands to the east of the

site.

The hydrocarbons detected in BH-1 may be linked to the oil staining noted at

the ground surface, which are probably associated with minor leaks from

vehicles parked in this area.

The source of the elevated levels detected in BH-08 is Galway Metal site and

may be the result of historical leaks in the storm water drainage system and or

historical discharges to ground prior to the paving of process yard area. The

source of is most likely the leakage of oils from end of life vehicles that may

not have been properly depolluted.

The presence of hydrocarbons, although at relatively low levels, in BH-04, 05

and 06 indicate the presence of a dilute plume migrating off-site to the

southeast.

Given the direction of groundwater flow, from northwest to south east, it is

possible that the off-site sources may be contributing to the elevated levels

detected at BH-03.

3.5.2 Polycyclic Aromatic Hydrocarbons (PAH)

Significant PAHs were detected in BH-03 and BH-08. Due to high

concentrations, the samples had to be diluted in the laboratory in order to

ensure representative analyses. The highest concentrations were detected in

BH-03, with relatively low levels in BH-08. As indicated previously it is

possible that the source of contamination in BH-03 is at least in part

attributable to off-site sources.

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3.5.3 Volatile Organic Compounds (VOCs)

Elevated VOCs were detected in BH-08, with lower levels in BH-03, 04 and

06. The main VOCs detected (benzenes, toluene, ethylbenzene and xylene)

are constituents of petrol while others may be associated with brake fluids or

degreasing agents.

3.5.4 Metals and Anions

Aluminium was the only metal detected above IGV limits. It is present in all

wells at levels slightly above the IGV of 200µg/l. The levels detected ranged

from 221µg/l to 307µg/l. Given the detection in up hydraulic gradient as well

as down hydraulic gradient wells, its presence may be natural occurring and is

not considered to be significant.

Chloride, potassium and ammoniacal nitrogen levels are slightly elevated

primarily in the down hydraulic gradient wells. The slightly elevated

ammoniacal nitrogen and potassium in BH-01, which is upgradient of the

Galway Metal site, indicate an impact on groundwater quality originating form

an off site source.

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4 SOILS ASSESSMENT

The soil investigation included the collection of soil samples from the boreholes

installed on site. Soil samples were not collected from BH-05 or BH-06, as poor

weather conditions (heavy rain and strong winds) at the time of the drilling made it

impossible to collect representative samples of the drill cuttings. It was intended to

collect samples at these locations from trial pits that were to be excavated on the day

following the borehole installation. However OCM were denied access to the lands

on the following day and were therefore not able to collect soil samples.

4.1 Field Screening

The soil samples collected were examined for visual or olfactory evidence of

contamination. Field screening was undertaken on all samples collected to detect the

presence of volatile organic compounds. This was achieved by filling resalable

plastic bags with the soil. A head space was left in the bags and the sample allowed

to sit for ten minutes. A photo ionisation probe (PID) was then inserted into the bag

to detect any volatile organic vapours within the headspace. A summary of the PID

measurements is presented in the borehole logs in Appendix 2.

High PID readings were detected in the soils encountered in BH-03 and BH-08. The

levels in BH-03 ranged from 258 parts per million (ppm) at a depth of 0.25m to 4,500

ppm at a depth of 0.75m. The readings detected at the final soil sample collected

from BH-03 at 2.25m was 2,270ppm. These PID reading are indicative of the

presence of volatile hydrocarbon compounds which were observed during the drilling

programme.

The PID readings for BH-08 ranged from 3,490ppm at a depth of 1.9m to 1,550ppm

at a depth of 3.9m. Low levels of VOCs were detected between 0m and 0.5m of BH-

01, between 1m and 2m in BH-04 and between 1 and 2m in BH-07. The PID

detections correlate well with the presence of volatile hydrocarbons detected in the

subsoils (See Section 4.2) and are not considered to be indicative of the presence of

elevated volatile organic compounds associates with organic solvents.

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4.2 Soil Sampling

Soil samples were taken form the boreholes at either 0.5m or 1m intervals. The

interval was based on the drilling conditions at the time and the amounts of soil being

returned. Where small amounts of soils were being returned samples were collected

every metre and where large amounts of soils were returned samples were collected

every half metre.

All samples were collected in accordance with OCM’s sampling protocol, a copy of

which is included in Appendix 2. The soil samples were placed in laboratory

prepared containers and stored in coolers prior to shipment to Jones Environmental

Forensics, UK (UKAS Accredited). Chain of custody documentation and laboratory

analytical results are included in Appendix 3.

4.3 Soil Quality

The samples were analysed for – diesel range Organics (DRO), petrol range organics

(PRO), mineral oils, VOCs, BTEX (benzene, toluene, ethyl benzene, xylene),

Polyaromatic Hydrocarbons (PAHs), pH, arsenic, aluminium, antimony, barium,

cadmium, chromium, copper, iron, mercury, nickel, selenium, lead, zinc, These are

the contaminants typically associated with scrap metal and vehicle processing.

The laboratory results are summarized on Tables 4.1 to 4.8 and included in full in

Appendix 3. The tables include, for comparative purposes, soil quality ranges

published by the Environmental Protection Agency (EPA), which indicate typical

background levels for a range of parameters, primarily metals, in Irish Soils.

The Table also includes Dutch quality guidelines known as the Dutch List. The latter

are used by many local authorities to assess soil and groundwater contamination and

have two categories, a target level (D) and an intervention level (I). The (D) level is

considered representative of background conditions. The (I) level is one at or above

which remedial action may be considered necessary based on risk assessment.

4.4 Data Interpretation

4.4.1 Petroleum Hydrocarbons

Elevated hydrocarbons were detected in the subsoils in BH-01, BH-03 and

BH-08.

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In BH-01 the top 0.5m of the subsoil is slightly impacted, but beneath this

level no hydrocarbons were detected. The staining at the surface is most likely

the result of minor spills or leaks from vehicles parked in this area.

OCM were denied access to excavate the trial pits on the lands to the east of

the facility where oily discharges from the site have resulted in heavy staining

of the surface. However, based on observations during the installation of BH-

04, 05 and 06, the top soil and possible 20-30cm of subsoil where the oil

discharges have occurred are heavily impacted and will require excavation and

removal.

It should be noted however that the extent of the impacted area appears to be

increasing. This is because oily water seepages continue to discharge from the

site, which is located at c.1.5-2m higher elevation than the land to the east,

into the farmland.

Polycyclic Aromatic Hydrocarbons (PAH)

Low levels of PAH were detected in the subsoils in BH-01 and BH-08. The

levels detected BH-01 are not considered to be significantly elevated. The

PAHs have not appear to have penetrated beyond the top 0.5m beneath the

ground surface. In BH-08 low levels were detected at depth. Their presence

indicate a pathway through the subsoils to the groundwater in this area

however the levels detected do not indicate the presence of a significant source

of PAH contamination in the subsoils beneath the site. The PAHs are most

likely related to leaks in the surface water drainage system running beneath the

processing area.

4.4.2 Volatile Organic Compounds (VOCs)

Low levels of VOCs were detected in the soil.

4.4.3 Metals

Metal levels are not significantly elevated in the subsoils beneath the site.

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Table 4.1 Subsoils Metals - Galway Metal June 2009

0-0.5m 1.5-2m 3.5-4m 0-0.5m 1.5-2m 3-3.5m 0.5-1m 1-1.5m 2-2.5m

Aluminium mg/kg 674.0 1,916 1,348 2,282 2,262 2,864 5,224 29,660 1,985 - - 10,000-80,000

Arsenic mg/kg 1 1.6 1.1 1.8 1.5 1.4 5.5 8.4 1.1 29.0 55.0 1.0-50

Antimony mg/kg <1 <1 <1 <1 <1 <1 2 <1 <1 3 15 0.2-3

Barium mg/kg 10 25 11 17 15 19 92 135 12 160 625 -

Cadmium mg/kg 0.1 0.4 0.5 0.2 0.4 0.4 0.8 2.1 0.4 0.8 12.0 0.1-1

Chromium mg/kg 24.1 5.3 4.9 4.7 5.3 6.7 80.5 62.1 6.5 100 380 5-250

Copper mg/kg 31 6 4 7 4 4 102 63 3 36 190 2-100

Iron mg/kg 3,235 2,120 1,704 3,202 2,037 2,241 31,620 23,610 1,088 - - 10,000-50,000

Mercury mg/kg 0 0.3 0.4 0.4 0.3 0.3 0.3 0.3 0.4 0.3 10 0.03-0.8

Nickel mg/kg 14.4 5.9 6.4 6.2 6.2 6.8 45.3 50.9 5.2 35 210 0.5-100

Selenium mg/kg <1 <1 <1 <1 <1 <1 1 2 <1 0.7 100 0.2-2

Lead mg/kg 33 <5 <5 <5 <5 <5 95 39 <5 85 530 0.2-80

Zinc mg/kg 44 9 8 9 8 9 185 101 7 140 720 10-200

* From Towards Setting Environmental Quality Objectives for Soil Developing a Soil Protection Strategy for Ireland. Irish EPA 2002.

Table 4.2 Subsoils Metals - Galway Metal June 2009

0-1m 1-2m 0.8-1.8 1.8-2.8 2.8-3.8 1.4-2.4 2.4-3.4 3.4-3.6

Aluminium mg/kg 8,301 1,994 4,189 3,666 2,047 4,475 1,275 806 - - 10,000-80,000

Arsenic mg/kg 3.8 1.7 2.6 2.2 1.4 3.1 1.5 1.4 29.0 55.0 1.0-50

Antimony mg/kg <1 <1 <1 <1 <1 <1 <1 <1 3 15 0.2-3

Barium mg/kg 35 13 21 23 14 26 <10 12 160 625 -

Cadmium mg/kg 0.8 0.4 0.8 0.5 0.5 0.6 0.5 0.4 0.8 12.0 0.1-1

Chromium mg/kg 17.9 5.8 9.3 8.6 5.7 9.6 5.7 5.0 100 380 5-250

Copper mg/kg 11 4 6 6 5 8 3 4 36 190 2-100

Iron mg/kg 6,449 2,181 4,356 3,815 2,053 5,159 1,738 1,331 - - 10,000-50,000

Mercury mg/kg 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 10 0.03-0.8

Nickel mg/kg 17.7 6.9 11.6 10.9 7.6 11.5 6.3 7.1 35 210 0.5-100

Selenium mg/kg <1 <1 <1 <1 <1 <1 <1 <1 0.7 100 0.2-2

Lead mg/kg 16 <5 6 <5 <5 9 <5 <5 85 530 0.2-80

Zinc mg/kg 33 9 15 15 10 24 9 8 140 720 10-200

* From Towards Setting Environmental Quality Objectives for Soil Developing a Soil Protection Strategy for Ireland. Irish EPA 2002.

Dutch I-Value EPA Range*Dutch D-ValueBH-01 BH-01

BH-04 BH-04

Parameter Unit

Parameter Unit

BH-03BH-01 BH-02

BH-07

BH-02 BH-03 BH-03BH-02

BH-07 BH-07 BH-08 BH-08 BH-08Dutch D-Value Dutch I-Value EPA Range*

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Table 4.3 Subsoils Organics - Galway Metal June 2009

0-0.5m 1.5-2m 3.5-4m 0-0.5m 1.5-2m 3-3.5m 0.5-1m 1-1.5m 2-2.5m

DRO mg/kg 1,121 <30 <30 <30 <30 96 4,440 1,210 2,128 - -

Mineral Oil mg/kg 560 <30 <30 <30 <30 <30 2,220 605 1,702 50 5000

Table 4.4 Subsoils Organics - Galway Metal June 2009

0-1m 1-2m 0.8-1.8 1.8-2.8 2.8-3.8 1.4-2.4 2.4-3.4 3.4-3.6

DRO mg/kg 104 <30 <30 148 250 3,574 857 438 - -

Mineral Oil mg/kg <30 <30 <30 <30 <30 1,787 428 219 50 5000

Parameter UnitBH-01 BH-01 BH-01 BH-02 BH-02 BH-02 BH-03 BH-03

Dutch D-Value Dutch I-ValueBH-03

Parameter UnitBH-04 BH-04 BH-07 BH-07 BH-07 BH-08 BH-08 BH-08

Dutch D-Value Dutch I-Value

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0-0.5m 1.5-2m 3.5-4m 0-0.5m 1.5-2m 3-3.5m 0.5-1m 1-1.5m 2-2.5m

Naphthalene �g/ kg <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 - -

Acenaphthylene �g/ kg 0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Acenaphthene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Fluorene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Phenanthrene �g/ kg 0.04 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Anthracene �g/ kg 0.05 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Fluoranthene �g/ kg 0.12 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Pyrene �g/ kg 0.13 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 - -

Benz(a)anthracene �g/ kg 0.04 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Chrysene �g/ kg 0.08 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 - -

Benzo(bk)fluoranthene �g/ kg 0.11 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 - -

Benzo(a)pyrene �g/ kg 0.04 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Indeno(123cd)pyrene �g/ kg 0.03 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Dibenzo(ah)anthracene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Benzo(ghi)perylene �g/ kg 0.05 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04

SUM of Ten �g/ kg 0.69 <0.27 <0.27 <0.27 <0.27 <0.27 <0.27 <0.27 <0.27 1 40

ND Denotes parameter not detected

Table 4.5 Subsoil Volatile Organic Compounds Galway Metal February 2009

BH-02Parameter Unit

BH-01 BH-03BH-02BH-01 BH-01 BH-02 Dutch I-

Value

BH-03 BH-03 Dutch D-

Value

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0-1m 1-2m 0.8-1.8 1.8-2.8 2.8-3.8 1.4-2.4 2.4-3.4 3.4-3.6

Naphthalene �g/ kg <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 <0.03 - -

Acenaphthylene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Acenaphthene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 0.36 0.06 <0.02 - -

Fluorene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 0.60 0.12 <0.02 - -

Phenanthrene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 0.74 0.14 <0.02 - -

Anthracene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 0.05 <0.02 <0.02 - -

Fluoranthene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 0.20 0.11 <0.02 - -

Pyrene �g/ kg <0.03 <0.03 <0.03 <0.03 <0.03 0.22 0.10 <0.03 - -

Benz(a)anthracene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 0.06 0.05 <0.02 - -

Chrysene �g/ kg <0.04 <0.04 <0.04 <0.04 <0.04 0.07 0.04 <0.04 - -

Benzo(bk)fluoranthene �g/ kg <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 - -

Benzo(a)pyrene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Indeno(123cd)pyrene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Dibenzo(ah)anthracene �g/ kg <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 - -

Benzo(ghi)perylene �g/ kg <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04

SUM of Ten �g/ kg <0.27 <0.27 <0.27 <0.27 <0.27 0.38 0.20 <0.27 1 40

ND Denotes parameter not detected

Parameter Unit

Table 4.6 Subsoil Volatile Organic Compounds Galway Metal February 2009

BH-07 BH-07 BH-08BH-04 BH-04 BH-07 BH-08Dutch IDutch D

BH-08

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) 28 of 33

5 RISK ASSESSMENT

OCM understand that rainfall running off the scrap metal stock piles results in the

generation of oily water which is collected in the on-site surface water drainage

system and discharges via a series of interceptors to the surface water stream to the

south of the site. There is evidence of oil staining at the discharge point of the surface

water drainage system to the stream. This may indicate that the interceptor system is

not effectively retaining hydrocarbons within the interceptors.

OCM understand that there have in the past been problems with leaks in the surface

water drains beneath the site and that these leaks are the most likely source of the oily

discharges to the farm land to the east of the facility and of the impacts in the

groundwater system beneath and down hydraulic gradient of the facility.

The soil and groundwater results for the area around BH-01 indicate that while there

is staining at the surface and some hydrocarbons present in the top 0.5m, the impact

on the groundwater system is very low.

It is likely that shallow groundwater from beneath the site discharges into the adjacent

surface water course to the south of the site. There is a strong possibility therefore

that the contamination from beneath the site is impacting on the stream to the south of

the site.

Because of the karst nature of the bedrock aquifer it is difficult to predict with any

accuracy where or if contaminated groundwater emanating from the facility could be

impacting in the bedrock aquifer and potentially migrating long distances away from

the site through the karst conduits.

However the fact that oily water from beneath the site is migrating into the farmland

to the east of the site rather than vertically to ground indicates that the subsoil beneath

the facility is of relatively low permeability. The groundwater level data indicates

that the bedrock aquifer may in fact be confined beneath the site by the low

permeability subsoil. Because of its low permeability, infiltrating oil/water beneath

the site is being preferentially diverted laterally to the west along the surface water

pathway. However, at some point in the farm land the discharge appears to be getting

to ground as the extent of the impacted area does not reach a surface water drainage

outlet i.e. the river to the south of the site.

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) 29 of 33

The detection of a weak plume in the down gradient monitoring wells (BH-04, 05 and

06) indicates that oily water is migrating to water table to the east of the facility. The

extent of the impact appears however to be limited and if the discharge can be

eliminated it should be possible to reduce contamination in the groundwater in a

relatively short timeframe.

It is likely that the drainage from the site discharges to the stream to the south of the

site and ultimately both surface and groundwater discharges to the sea to the west of

the facility in the Oranmore area.

Once remedial action is taken to eliminate the discharge of oily water to ground

beneath the site a remediation programme can be developed to eliminate the residual

contamination beneath and down hydraulic gradient of the site. The remediation

programme can be designed following monitoring to assess the extent of impact

remaining post removal of the discharge.

It is likely that the remediation would involve some form of chemical oxidation to

mitigate the hydrocarbon contamination in the subsoil and groundwater. The precise

nature of remedial activity could be established following the assessment of

groundwater hydrochemistry as part of groundwater monitoring programme.

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) 30 of 33

6 CONCLUSIONS AND RECOMMENDATIONS

6.1 Conclusions

6.1.1 Soil

Localised hydrocarbon impacts were detected in BH-03 and 08 down hydraulic

gradient of the site. While the impacts in BH-03 may in part be associated with off-

site sources, based on the groundwater flow direction they are also in part associated

with leaks in the surface water drainage system discharging to ground beneath the

site.

It was not possible to complete the trial pitting investigation in the field to the east of

the facility. However, based on observations during the installation of BH-04, 05 and

06, the top soil and possible 20-30cm of subsoil where the oil discharges have

occurred are heavily impacted and will require excavation and removal. OCM

estimate that an area of approximately 600m2 has been impacted in this area, but this

needs to be confirmed.

Until the oily discharges emanating from the Galway Metal site into the farmland are

eliminated, the removal of the impacted soils is not recommended because the

underlying cleaner subsoils will continue to be impacted.

Oil staining in the vicinity of BH-01 does not appear to be indicative of significant

contamination based on the soil and groundwater results from BH-01.

6.1.2 Groundwater

Hydrocarbon contamination has been detected at elevated levels primarily in

monitoring wells BH-03 and BH-08. Lower levels of hydrocarbon

contamination were detected in BH-01.

Lower levels of hydrocarbon contamination were detected in BH-04, 05 and

06 in the agricultural lands to the east of the site.

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) 31 of 33

The hydrocarbons in BH-1 may be indicative of minor leaks or spills

associated with the trucks parked in the area to the west of the main offices on

site.

Given the direction of groundwater flow across the site from northwest to

south east it is likely that the source of elevated hydrocarbons in BH-03 may

in part originate from adjacent off-site sources.

The elevated hydrocarbons detected in BH-08 are considered to originate from

the Galway Metal site and may be the result of historical leaks in the surface

water drainage system or historical discharges to ground prior to the sealing of

process yard area. The source of the impact is most likely the discharge of

hydrocarbons from crushed vehicles that may not have been depolluted.

It is likely that low permeability subsoil beneath the site has resulted in the

diversion latterly of much of the oily water from beneath the facility to the

farmland east of the site. This low permeability subsoil may be limiting the

impact of hydrocarbon contamination on the bedrock aquifer beneath the site.

The detections in BH-04, 05 and 06 indicate the presence of a dilute plume

migrating away from the surface impacted farm land to the east of the site.

Significant PAHs were detected in BH-03 and BH-08. The highest

concentrations were detected in BH-03 with lower levels in BH-08. It is

possible that the source of contamination in BH-03 is at least in part

attributable to off-site sources.

VOCs were detected primarily in BH-08.

It is likely that the shallow groundwater from beneath the site discharges into

the adjacent surface water course to the south of the site. There is a strong

possibility therefore that the contamination from beneath the site is impacting

on the surface water system down hydraulic gradient of the site to the south

and east.

Because of the karst nature of the bedrock aquifer it is difficult to predict with

any accuracy where or if contaminated groundwater emanating from the

facility could be impacting on the deeper groundwater conduit flow system in

the regionally important bedrock aquifer beneath and down hydraulic gradient

of the facility.

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) 32 of 33

However the presence of low permeability subsoil beneath the site, the

confined aquifer conditions and the monitoring data for BH5 and 6 down

hydraulic gradient of the site indicates that to date off-site impacts in the

bedrock aquifer may be limited.

It is likely that the drainage from the site, both surface and groundwater

ultimately discharges to the sea to the west of the facility in the Oranmore

area.

The recommendations below will only be effective if all sources of

contamination are identified and eliminated. If there are off-site sources of

hydrocarbon contamination the effectiveness of any actions taken now by

Galway Metal will be reduced if off-site source areas are not also addressed.

6.2 Recommendations

6.2.1 Soil

OCM recommend that any ongoing leaks of oily water in the surface water drainage

system be identified and repaired to eliminate the discharge of oily water off-site to

the east of the facility.

OCM recommend that once it is established that all oily water at the facility is being

collected and diverted to interceptor that the impacted area in the farmland be

excavated and removed for appropriate disposal. The excavated area should be

reinstated with clean subsoils and top soils and reseeded.

OCM recommend that ideally all vehicle parking areas should be paved to prevent

discharges of leaks or spills from vehicles to the subsurface.

6.2.2 Groundwater

OCM recommend that following any necessary repairs to the surface water drainage

system that a groundwater monitoring programme incorporating the new monitoring

wells be undertaken quarterly to monitor water quality.

OCM recommend that a remedial action plan be developed so that clean up goals for

the groundwater system can be established and an effective method of remediation

can be designed and implemented.

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS) 33 of 33

6.2.3 Surface Water

OCM recommend that oil interceptor system be assessed to ensure that its integrity is

intact and that it has sufficient capacity to treat oily water prior to discharge to the

surface water course to the south of the facility.

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS)

APPENDIX 1

Borehole Logs

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Page 38: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS)

APPENDIX 2

OCM Sampling Protocol

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C:\SOP\Soil.Doc 1

STANDARD OPERATING PROCEDURE

SOIL SAMPLING

The soil sampling technique described below will be followed to ensure that soil samples are

representative of the environment which they are intended to characterise.

1.0 SAMPLING

(A) Locate the soil sampling station in accordance with the workplan which will specify

the number and type of samples to be taken. Place a wooden stake into the ground

one metre from the sample location and record sample location on the stake.

(B) Record the location in the field logbook and, if possible, photograph the location.

(C) Collect soil samples from the depth specified in the workplan and record the depth in

the field notebook. Describe the colour and texture of each sample and record in

notebook.

(D) Wear appropriate level of protection when taking samples (gloves, safety glasses,

hard hat etc.) as specified in the workplan. Collect soil samples as specified in the

workplan using decontaminated stainless steel trowel, soil corer, or similar device.

Collect discrete soil samples from each station.

(E) If required by the workplan, composite discreet soil samples by placing equal

volumes of soil into the container and mixing thoroughly to a homogenous mixture.

Samples may be hand picked, if necessary, to remove larger materials, such as

leaves, sticks, gravel, rocks etc., if specified in the workplan. Record in notebook

the nature of any materials removed from soil samples.

(F) Deposit each soil sampled into a (clean, pre-washed) container. At the time of

collection, the sample bottle will be filled to the top with soil sample.

(G) Fill out labels with waterproof ink and attach to the sample container. The following

information will be recorded on each sample label: -

Client/Site Name

Date Collected

Time Collected

Analysis

Preservative

Sample Identification Number

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C:\SOP\Soil.Doc 2

(H) Decontaminate sampling equipment as described below unless otherwise specified in

the site workplan. When using stainless steel sampling equipment: -

wash with non-phosphate detergent in potable water,

rinse sequentially in potable water, methanol, acetone, methanol and D1 water

and;

allow to air dry in a containment free area.

(I) Wrap the decontaminated sampling equipment in aluminium foil which has been

decontaminated in accordance with Section H.

2.0 FIELD DOCUMENTATION

Record sample information in the field notebook. Provide a complete description of the

sample location, and a photograph, if necessary. Describe the soil appearance, especially if

the presence of oil or an odour is noted. Document the sample bottle lot numbers in the field

notebook. Record weather conditions at the time of sampling. The Field Team Leader will

initial the logbook entries for correctness.

3.0 FIELD QA/QC SAMPLES

See the separate SOP on Field QA/QC samples for appropriateness and preparation of D1

Water Field Blanks, Cross-contamination Field Blanks, Trip Blanks and Field Duplicate

Samples.

4.0 PACKAGING AND TRANSPORT

Check to be sure that all necessary information is on the sample container label. Complete

the chain-of custody form. Package, label and transport the samples to the testing laboratory

in accordance with requirements for packing, shipping and labelling environmental samples.

END.

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C:\SOP\Gwater.Doc 1

STANDARD OPERATING PROCEDURE

GROUNDWATER SAMPLING

The primary objective of groundwater sampling is to establish groundwater quality and

evaluate whether the potential contaminant sources at a site have impacted the groundwater in

the underlying aquifer. The additional objective is to measure hydraulic gradient, or slope, of

the water table to evaluate the direction of groundwater flow.

The purpose of this procedure is to ensure that representative samples of groundwater are

collected and documented using consistent methods to ensure sample integrity.

1.0 SAMPLING PROCEDURES

1.1 Well Operating and Purging Procedures

All groundwater sampling will be conducted after the installed and developed wells have been

allowed to equilibrate for at least 2 to 3 days. A Field Data Sheet for Well Sampling will be

completed for each well.

Groundwater sampling teams will use to following procedure for approaching, opening,

purging and sampling all wells, unless directed otherwise by a site specific workplan.

1) Prior to placing any equipment into the well, decontaminate the sampling equipment

according to standard decontamination protocol.

2) Ensure you have a working FID/PID, a well key, and a depth-to-water meter.

3) Unlock and open the well cap just enough to insert the probe of the PID/FID. Take and

record a reading. A decision to upgrade PPE may be necessary based on the FID/PID

readings in the breathing zone.

4) Where practical, the surface water column will be visually examined for the presence of

hydrocarbons, if present or suspected, the thickness of the hydrocarbon layer will be

measured using an oil/water interface probe prior to taking the depth-to-water

measurement.

5) Insert the water level probe into the well and measure and record the static water level

to the nearest 0.01 m with respect to the established survey point on top of the well

casing.

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C:\SOP\Gwater.Doc 2

6) Decontaminate the water level probe with DDI water (Do not rinse with any solvents

unless product was encountered).

7) Calculate and record the minimum volume of water to be purged according to the

following conversion factors: -

1 well volume = water column in metres x litres/linear metre

50mm casing = 2.0 LPM

100mm casing = 8.1 LPM

150mm casing = 18.2 LPM

200mm casing = 32.4 LPM

8) Purge the well of at least 3 casing volumes by pumping or bailing with a

decontaminated submersible pump or PVC bailer equipped with a bottom filling check

valve (if the purge volume is low, generally less than 100 litres, the sampling team

might find it more efficient to purge with a bailer than a pump). Use a graduated bucket

to track the amount of water removed from the well. Periodically determine the pH,

temperature and specific conductance of the purged water. Continue purging until the

well has been completely evacuated or until the pH and specific conductance

measurements have stabilised for at least one well volume. Wells that become

dewatered before producing three casing volumes will be sampled as soon as practical

once they recover sufficiently.

9) Dispose of purge water collected in the graduated bucket by pouring onto the ground at

a distance of 50 to 60 metres from the vicinity of the well. If the water is known or

suspected to be significantly contaminated, it may be necessary to store the purge water

in a secure container, such as a drum, pending proper disposal.

10) Be aware and record any unusual occurrence during purging such as cascading (a

shallow water entry zone that trickles into the borehole).

1.2 Field Parameter Measurement

Measurements of field parameters of pH, temperature and electrical conductivity are collected

and organic vapour screening is conducted while the well is purged. To facilitate the

collection of basic field parameters, the field team needs to: -

· Purge three well volumes of water from the well and measure field parameters

for each well volume removed.

· Collection of water samples should take place after stabilisation of the following

parameters: -

- Temperature +/- 1

oC

- pH (meter or paper) +/- 0.2 units

- Specific conductivity +/- 5%

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C:\SOP\Gwater.Doc 3

· If the aforementioned parameters do not stabilise within three purge volumes,

the well will be purged up to a maximum of six borehole volumes unless two

consecutive sets of stabilised parameters are obtained.

· Note any observations in the field logbook.

1.3 Collection of Water Samples

All samples or chemical analysis will be placed in laboratory prepared bottles. The types of

sample containers and preservative required for each type of analysis are described in the

workplan. If required, preservatives will be placed in the sample containers prior to collecting

the samples.

The following procedure will be used to sample a well: -

1) After the well has been purged and allowed to recover, sample the well using a properly

decontaminated or dedicated disposable bailer. Gently lower the bailer into the water

column. Allow the bailer to sink and fill with a minimum of surface disturbance.

2) Slowly raise the bailer out of the well. Do not allow the bailer line to contact the

ground, either by coiling it on a clean plastic sheet or by looping it from arm to arm as

the line is extracted from the well.

3) Samples will be collected for VOCs analysis immediately after purging is complete and

before other samples are collected. Pour the samples slowly into the laboratory

prepared 40 ml glass vial. Overfill each vial slightly to eliminate air bubbles, a convex

meniscus should be present at the top of the vial. Ensure that the Teflon liner of the

septum cap is facing inward and that no bubbles are entrapped. After capping securely,

turn bottle upside-down, tap it against your other hand, and observe sample water for

bubbles. If bubbles are observed, remove the cap, overfill the vial and reseal. Repeat

this step for each vial until the samples with no bubbles are obtained.

4) Place a label on the container and enter the following information: -

Client/Site Name

Date Collected

Time Collected

Analysis

Preservative

Sample Identification Number

5) Record pertinent information in the field logbook and on the Field Data Sheet for Well

Sampling. Complete chain-of-custody form.

6) Place custody seals on the container caps. As soon as possible, place sample containers

in a cooler with ice packs and maintain at 4oC until extraction. Surround the bottles

with appropriate packaging.

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C:\SOP\Gwater.Doc 4

7) Obtain the semi-volatile compound/pesticides/PCBs sample(s) by transferring the water

to a laboratory prepared 1000 ml amber glass bottle with Teflon-lined cap. Fill the

bottle to the bottom of the neck and follow steps 4, 5 and 6 above.

8) Dissolved metals (if necessary) requires the team to filter the sample water through a

.45 micron filter. The water is collected in a 1 litre, unpreserved, plastic or glass bottle

with HNO3 preservative. Filtering must be done within 15 minutes of sample

collection.

9) Obtain the total metals sample by directly transferring the water from the bailer into a

laboratory prepared 1000 ml plastic or glass bottle with HNO3 preservative.

10) Be sure the pH of the metals sampled is less than 2 by pouring off an aliquot in a clean

jar and testing for pH using litmus paper. Dispose of this water and rinse the jar.

11) Collect and prepare Field QA/QC samples in accordance with separate SOP.

12) Be sure to record all data required on the Field Data Sheet or Well Sampling and

appropriate entries into the field logbook.

13) Secure the well cap and replace the locking cover.

14) Decontaminate all sampling equipment according to procedure.

15) Decontaminate submersible pumps as follows: -

Scrub pump and cord in a tub of appropriate detergent and potable water

Pump at least 80 litres of soapy water through pump

Rinse with potable water

Pump at least 80 litres of rinse water through the pump

Rinse with DI water before lowering pump into the next well.

END.

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C: \09\123_HegartyMetal\03_GalwayMetalCompagnyLtd\1230301.Doc August 2009 (SM/BS)

APPENDIX 3

Laboratory Results

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Page 57: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

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Page 58: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

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ectio

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pose

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Page 59: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

For

insp

ectio

n pur

pose

s only

.

Conse

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right

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Page 60: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

For

insp

ectio

n pur

pose

s only

.

Conse

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copy

right

owne

r req

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for a

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EPA Export 13-09-2016:01:48:04

Page 61: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

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r req

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for a

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EPA Export 13-09-2016:01:48:04

Page 62: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

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se.

EPA Export 13-09-2016:01:48:04

Page 63: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

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her u

se.

EPA Export 13-09-2016:01:48:04

Page 64: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

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her u

se.

EPA Export 13-09-2016:01:48:04

Page 65: HYDROGEOLOGICAL SITE INVESTIGATION For inspection … · 2.3. The soils across most of the site are classified as Made Ground i.e. fill material and concrete. The soils in the lands

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 13-09-2016:01:48:04


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