Kmk Metals Recycling Ltd., Moate Road, Kilbeggan, Co

KMK METALS RECYCLING LTD.,

MOATE ROAD, KILBEGGAN, CO. WESTMEATH. REMEDIAL CORRECTIVE ACTION VALIDATION REPORT

For inspection purposes only. Consent of copyright owner required for any other use.

Newry Office Innovation Centre 1 RDC House Green Road WIN Business Park Carlow Newry BT35 6PH Tel: 059 91 33084 Fax: 059 91 40499 Tel: 048 302 57974 Email: [email protected]

JRP Integrated Engineering Ltd

Registered Office: Innovation Centre, Green Road, Carlow

Company Registration No. 519448

Directors: P McShane BEng(Hons) MIEI J Keohane BSc MSc C.Geol FCIWEM MIEI RR Matthews BSc CEng FICE

Associate: E Fitzpatrick BSc, MSc, PGeo N O’Malley BEng (Hons) MIEI S Furlong MIPA EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

Document Control Sheet

Project Title KMK Kilbeggan Environmental Remediation

Report Title Remedial Corrective Action Validation Report

Report Reference IE1616-3024

Version A

Issue Date 20th December 2018

Document Production / Approval Record

% Name Signature Date Position Input

Prepared by Conor Lee Hydrogeologist 20/12/2018 90% (consultant) BSc MSc

Approved by Jer Keohane 20/12/2018 Technical 10%

(consultant) BSc MSc CGeol Director FCIWEM

Status For inspection purposes only. Consent of copyright owner required for any other use.

Report Status First Draft

Distribution

Organisation Contact Format Copies KMK Metals Recycling Ltd Olivia Brennan PDF copy 1 QED Engineering Ltd EPA

KMK Metals Recycling Ltd 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

TABLE OF CONTENTS

FIGURES Figure 1 Regional Location Map (Drawing No IE1616‐01‐A) Figure 2 Window Sample & Groundwater Well locations (Drawing No IE1616‐02‐A) Figure 3 July Sampling Locations (Drawing No IE1616‐03‐A) Figure 4 September Sampling Locations (Drawing No IE1616‐04‐A) Figure 5 September Sampling Locations (Drawing No IE1616‐05‐A)

DRAWINGS

Drawing 1 Groundwater Contour Map (water levels is m AOD)

TABLES Table 1 Detection of Mineral Oils & Hydrocarbons in WS‐4 Table 2 Site History from 1974 to Present Table 3 Validation soil sample results (24th July 2018) Table 4 Validation soil sample results (24 September 2018) Table 5 Volume of Material and Waste Excavated during the July and September 2018 excavations (IE Data)

APPENDICES Appendix A Figures Appendix B Borehole Logs Appendix C Soil Sampling Results For inspection purposes only. Appendix D Photos Consent of copyright owner required for any other use. Appendix E Laboratory Cerrtificates of Analyses Appendix F LQM/CIEH Suitable for Use Levels (S4ULs) for Petroleum Hydrocarbons for the commercial land use at 1%, 2.5% and 6% soil organic matter (SOM) Appendix G Haulage and Waste Disposal Tickets

KMK Metals Recycling Ltd i 20‐12‐18 IE784 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

1. INTRODUCTION

1.1. Project Contractual Basis & Parties Involved

IE Consulting was requested by KMK Metals Recycling Ltd. to generate a Remedial Corrective Action Validation Report with respect to the Total Petroleum Hydrocarbons (TPH) soil contamination identified at the KMK Metals Recycling Plant, Kilbeggan, Co. Westmeath (Figure IE1616‐01 in Appendix A).

This Remedial Corrective Action Validation Report utilises site data compiled during soil excavation and laboratory soil analyses to support the validation of the recent remedial corrective active works.

1.2. General Introduction

On 20th September 2017, four percussive window sample boreholes were drilled to a maximum depth of 4 m bgl at the site (i.e. WS1, WS2, WS3 and WS4). Soil sampling was undertaken at the four window sampling locations (Figure IE1616‐02 in Appendix A). One bulk sample was collected per window sampling location. Samples were representative of depths of between 0.6 m and 3.0 m bgl. The samples were couriered to Chemtest Limited Laboratory in Newmarket, U.K for laboratory analysis. They were analysed for the RILTA suite of parameters which includes leachate, soil and WAC analysis and is an approved EPA list of parameters.

Visual and olfactory evidence of possible contamination was observed at one location, WS‐4. A hydrocarbon odour and a slight sheen were noted on the soil core between 0.6 and 2.0 m depth.

For inspection purposes only. 1.3. History of the Site Consent of copyright owner required for any other use.

The site history is described below in Table 2.

Company Years Active Activity Powerscreen Ltd. 1974 ‐ 2006 Manufacturing screening & crushing equipment. Coen Holdings Ltd. 2006 ‐ 2011 Manufacturing architrave & skirting & some storage of wood. KMK Metals Recycling ltd 2015 ‐ Present Metal & WEEE recycling Table 2 Site History from 1974 to Present

KMK Metals Recycling Ltd 1 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

1.4. Generic Assessment Criteria

The soil analysis results taken on the 20th September 2017 were compared to the LQM/CIEH Commercial guidelines as summarised below. The LQM/CIEH Guidelines 2nd edition was published in 2009 as a set of generic assessment criteria values and was updated to reflect the significant changes in human health risk assessment technical guidance (such as the replacement of CLR9 and 10 with SR2 and SR3) and policy since the release of the first edition in 2006.

The 2nd edition includes Generic Assessment Criteria (GAC) for an extended range of 81 substances including:

• Metals (including beryllium, boron, copper and zinc)

• Total petroleum hydrocarbon fractions (aromatic and aliphatic)

• Polyaromatic hydrocarbons (USEPA 16)

• Chlorinated solvents

• Chlorobenzenes

• Pesticides

• Others

For each substance, GAC have been derived for a range of generic land uses and Soil Organic Matter contents and all toxicological and physical‐chemical data inputs used in the derivation of the GAC are presented and discussed in the publication. In the absence of specific Irish values, these values are For inspection purposes only. generally accepted by the EPA. Consent of copyright owner required for any other use.

1.5. Site Investigations

Table 1 Detection of Mineral Oils & Hydrocarbons in WS‐4

KMK Metals Recycling Ltd 2 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

Total Petroleum Hydrocarbons (1,500 mg/kg) were detected in WS‐4‐1. WS‐4‐1 was sampled between 0.6 and 1.4 mbgl, indicating shallow soil contamination at this depth.

Laboratory analyses has demonstrated that the three other window sample locations, WS ‐1‐1, WS‐ 2‐1 and WS‐3‐1 were free from Total Petroleum Hydrocarbons.

Monitoring well GW3 was drilled downgradient of WS‐4, along the eastern site boundary. Borehole logs are presented in Appendix C. During drilling, there was no visual or olfactory evidence of any mineral oils or hydrocarbons in the subsoil. As a result no soil samples were taken from this borehole, but the observations would suggest that the contamination has not migrated far from the vicinity of WS‐4 and is most likely contained in a small localised area around WS‐4.

1.6. Report Outline

This report describes corrective action remedial works undertaken at the site between July and September 2018 and outlines the positive outcome of remedial validation of the remaining soils.

This report presents analytical data obtained from analysis of residual soils located at the base and walls of the excavation area. The soil has been sampled, analysed and the results interpreted against the LQM/CIEH Suitable for Use Levels (S4Uls) generic assessment criteria for commercial land use.

Soil sampling results are attached in Appendix B of this report.

Conor Lee of IE Consulting was present on‐site during the remedial corrective action works.

1.7. Project Objectives For inspection purposes only. Consent of copyright owner required for any other use. The remedial work comprised excavation of contaminated soil from the area around WS‐4. Though the TPH levels in the soil did not exceed the generic assessment criteria, this corrective action work would limit the potential vertical and lateral migration of hydrocarbons off the site.

The remedial validation work will help demonstrate that the excavation area is not or will not pose an unacceptable risk to the overburden aquifer with respect to TPH’s (See section 1.8).

1.8. Conceptual Site Model

During window sampling, water was encountered at shallow depths (0.12 – 1.8 mbgl). During borehole drilling, minor water strikes were encountered in the overburden in GW2 and GW3 in the east and southeast of the site (Figure 1, below). Borehole logs are presented in Appendix B. In all three wells, the main water strikes occurred in the weathered bedrock. Two weeks after well installation, when dipped, the water level in the wells was very shallow (0.82 – 1.48 mbgl). As the wells were screened in the bedrock, this would suggest that the aquifer is confined or at least semi‐

KMK Metals Recycling Ltd 3 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report confined. Based on groundwater levels and survey levels obtained on 23rd October 2017, it would appear that water is flowing in a southeasterly direction, towards the River Brosna (Drawing 1, below). There appears to be perched groundwater in the shallow subsurface at the site. Layers of gravelly soil were found which contain water starting at depths of between 3.8 – 5.0 mbgl. It is not known if these gravel bands are in lateral continuity across the site or if they exist as separate pockets of gravel at the site that are not in hydraulic continuity. This perched water is separated from the water in the bedrock by clay confining layers.

For inspection purposes only. Consent of copyright owner required for any other use.

Drawing 1 Groundwater Contour Map (water levels is m AOD)

KMK Metals Recycling Ltd 4 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

2.0 Detailed Scope of Works

The remedial excavation work involved the following scope of works;

The site works were undertaken on 11 May 2018. A mechanical excavator excavated around the area around WS‐4. Near WS‐4 there is a drain running between the building in KMK and the building in the site adjacent to the site (Figure IE1616‐05 in Appendix A). This drain was lined with cemented blocks and its base was concrete. It was filled with rounded gravel (Photo 1 in Appendix D).

This drain was 1.1 m wide and runs from the KMK building to past the site boundary to the east. Workers on site stated that this drain originally contained pipes which transported hydraulic oil between the two buildings. Upon excavation of around this drain, it became apparent that this drain was a source of hydrocarbon contamination, with both olfactory and visual evidence of hydrocarbons. The contamination appeared to be seeping from the base of the drain, where the block walls met the concrete base at c. 0.66 mbgl (Photo 2 in Appendix D).

A four metre long trench was excavated along the external drain walls, on the north and south side, and it became apparent that this contamination ran along the length of the base of the drain. It was decided by KMK and the Hydrogeologist from IE Consulting that the way forward would be to excavate out the drain between the factory wall and the site boundary, a length of 14.4 m, and any contaminated soil from below the drain, and to the north, south, east and west of where the drain was. This was decided because it was evident that the drain was the source of the contamination, and removing it and any surrounding contamination in the soil would remove the TPH in the soil in this area of the site. For inspection purposes only. Consent of copyright owner required for any other use. Excavation of the drain and contaminated soils was undertaken on 24th July 2018. A 7 tonne excavator used a jackhammer to break up the reinforced concrete at the surface, and the walls and base of the drain (Photo 3 & 4 in Appendix D). A bucket was then used by the excavator to remove the concrete and block rubble (Photo 5 in Appendix D).

The excavator then scraped off any visual evidence of residual contamination from the walls of the exaction and from the pit. The final depth of the excavation ranged from approximately 0.99 to 1.12 mbgl. The removed soil and rubble was removed by Enva to their Portlaoise depot as hazardous waste (EWC code 17 05 03). The excavation stopped at the site boundary, but the drain continues into the adjacent site. At the end of the excavation there was visual and olfactory evidence of hydrocarbons seeping from the drain in the adjacent site into the excavated pit (Photo 6 in Appendix D).

KMK Metals Recycling Ltd 5 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

It was decided that partition would be put against the drain at the site boundary and then the drain would be filled in with cement the other side of the partition (Photo 7). This would prevent the potential migration of hydrocarbons from the adjacent site back into the KMK site. This means that there is most likely residual contamination in the adjacent site, owned by Irish Water Jet Profiles Ltd.

Four soil validation samples (SS‐1 to SS‐4) were taken from inside the excavated pit (Figure IE1616‐ 03 in Appendix A) and analysed for the following parameters:

 Moisture  Total Organic Carbon  Mineral Oil  Aliphatic TPH >C5‐C6  Aliphatic TPH >C6‐C8  Aliphatic TPH >C8‐C10  Aliphatic TPH >C10‐C12  Aliphatic TPH >C12‐C16  Aliphatic TPH >C16‐C21  Aliphatic TPH >C21‐C35  Aliphatic TPH >C35‐C44  Total Aliphatic Hydrocarbons  Aromatic TPH >C5‐C7  Aromatic TPH >C7‐C8

 Aromatic TPH >C8‐C10 For inspection purposes only. Consent of copyright owner required for any other use.  Aromatic TPH >C10‐C12  Aromatic TPH >C12‐C16  Aromatic TPH >C16‐C21  Aromatic TPH >C21‐C35  Aromatic TPH >C35‐C44  Total Aromatic Hydrocarbons  Total Petroleum Hydrocarbons  Benzene  Toluene  Ethylbenzene  m & p‐Xylene  o‐Xylene

KMK Metals Recycling Ltd 6 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

Laboratory certificates of analysis are presented in Appendix C. The results of the sampling are shown in Table 3, below. TPH’s were detected at SS‐1 (3,800 mg/kg) and SS‐4 (11,000 mg/kg), which were taken from the western wall and the base of the excavation, respectively. These values are below the LQM/CIEH Suitable for Use Levels for the commercial land use, which use 28,000 mg/kg as an acceptable value for TPH concentration in soil. But 11,000 mg/kg is still a high enough concentration that more remedial action was needed. The LQM/CIEH commercial land use scenario generic assessment criteria limit values are provided in Appendix D.

Sample Location: SS-1 SS-2 SS-3 SS-4 De te r m inand Units LOD Moisture % 0.020 15 14 17 17 Total Organic Carbon % 0.20 0.25 1.3 0.23 0.38 Mineral Oil mg/kg 10 3200 < 10 < 10 8200 Aliphatic TPH >C5-C6 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C6-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C8-C10 mg/kg 1.0 9.1 < 1.0 < 1.0 7.3 Aliphatic TPH >C10-C12 mg/kg 1.0 95 < 1.0 < 1.0 110 Aliphatic TPH >C12-C16 mg/kg 1.0 740 < 1.0 < 1.0 1700 Aliphatic TPH >C16-C21 mg/kg 1.0 880 < 1.0 < 1.0 2100 Aliphatic TPH >C21-C35 mg/kg 1.0 1500 < 1.0 < 1.0 4100 Aliphatic TPH >C35-C44 mg/kg 1.0 36 < 1.0 < 1.0 220 Total Aliphatic Hydrocarbons mg/kg 5.0 3200 < 5.0 < 5.0 8200 Aromatic TPH >C5-C7 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C7-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C8-C10 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C10-C12 mg/kg 1.0 16 < 1.0 < 1.0 49 Aromatic TPH >C12-C16 mg/kg 1.0 200 < 1.0 < 1.0 820 Aromatic TPH >C16-C21 mg/kg 1.0 140 < 1.0 < 1.0 580 Aromatic TPH >C21-C35 mg/kg 1.0 270 < 1.0 < 1.0 760 Aromatic TPH >C35-C44 mg/kg 1.0 < 1.0 < 1.0 < 1.0 160 Total Aromatic Hydrocarbons mg/kg 5.0 620 < 5.0 < 5.0 2400 Total Petroleum Hydrocarbons mg/kg 10.0 3800 < 10 < 10 11000 Benzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Toluene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Ethylbenzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 For inspection purposes only. m & p-Xylene µg/kgConsent 1.0 of copyright < 1.0 owner required < 1.0 for any other

As there was TPH detected in the samples at relatively high concentrations, subsequent excavation of residual contamination and soil sampling was undertaken on 24th September 2018. Between sampling rounds, the pit was covered with tarpaulin to prevent any surface water ingress into the pit during times of rain.

The objective of the second round of soil analyses was to verify the successful remediation of the residual contaminated soil. The proposed remedial target values were set at the laboratory limit of detection (LOD). During the second excavation, the base of the hole was deepened to a depth of 2.55 mbgl from 1.12 mbgl. The four walls of the excavation were scraped back (Photo 7 in Appendix

KMK Metals Recycling Ltd 7 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

D) and the soil was stockpiled, where it was to be removed by Enva to their Portlaoise depot as hazardous waste (EWC code 17 05 03).

Five soil samples were taken, one from each wall and one from the base of the excavation (Figure IE1616‐03 in Appendix A). They were analysed for the Rilta Suite. Table 4 below highlights that TPH’s were not detected above the laboratory LOD in any of the validation soil samples.

S1 S2 S3 S4 S5 De te r m inand Units LOD Moisture % 0.020 12 17 16 22 17 Total Organic Carbon % 0.20 0.30 < 0.20 < 0.20 0.42 < 0.20 Mineral Oil mg/kg 10 < 10 < 10 < 10 < 10 < 10 Aliphatic TPH >C5-C6 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C6-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C8-C10 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C10-C12 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C12-C16 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C16-C21 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C21-C35 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C35-C44 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Total Aliphatic Hydrocarbons mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Aromatic TPH >C5-C7 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C7-C8 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C8-C10 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C10-C12 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C12-C16 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C16-C21 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C21-C35 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C35-C44 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Total Aromatic Hydrocarbons mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Total Petroleum Hydrocarbons mg/kg 10.0 < 10 < 10 < 10 < 10 < 10 Benzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Toluene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Ethylbenzene µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 m & p-Xylene µg/kg 1.0 < For 1.0 inspection < 1.0purposes only. < 1.0 < 1.0 < 1.0 o-Xylene µg/kg 1.0Consent of < 1.0copyright owner < 1.0 required < for1.0 any other

Table 4 Validation soil sample results (24 September 2018)

As part of the reinstatement process, the excavated trench was filled with clean soil and stones obtained from a stockpile located at the western part of the site. Full reinstatement of the concrete surface will occur in the near future when the entire concrete surface will be resurfaced.

KMK Metals Recycling Ltd 8 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

3.0 System Performance – Soil Excavation and Contaminated Soil Stockpiling

3.1. Remedial Target Values

The excavation area site investigations demonstrate that the soil within the excavated area consisted of Made Ground (Sandy CLAY), sandy SILT with cobbles and firm brown SILT.

IE Consulting propose that the Laboratory LOD’s are utilised as remedial target values.

LQM/CIEH Commercial Land Use scenario suitable for use levels are the most applicable to the site. The LQM/CIEH commercial land use scenario generic assessment criteria limit values are provided in Appendix D.

The commercial land use scenario generic assessment criteria remedial target values were achieved in both rounds of soil sampling and during window sampling, with no hydrocarbons above the laboratory LOD being detected in the second round of soil sampling.

3.2. Successful Remedial Corrective Action

The corrective action programme is considered to be successful based on the following justification;

 The former hydrocarbon contaminated area no longer contains volumes of total petroleum hydrocarbons over the laboratory LOD.

The successful corrective action programme has resulted in the excavation of approximately 140 m3 of material. This included reinforced concrete, contaminated concrete blocks and concrete slab, contaminated soil and clean soil. This material was removed by Enva and brought to their Portlaoise For inspection purposes only. Consent of copyright owner required for any other use. Depot. Table 5 below shows the description and volume of material removed during the July and September excavations. The haulage and waste disposal tickets are presented in Appendix F.

Year Type EWC Approximate Quantity M3

July 2018 Soil and concrete Waste ‐ Hazardous 17 05 03 140 m3 Sept 2018 Soil Waste ‐ Hazardous 17 05 03 Table 5 Volume of Material and Waste Excavated during the July and September 2018 excavations (IE Data)

No long‐term monitoring and aftercare management plan is required for the area. There is no

KMK Metals Recycling Ltd 9 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report downgradient shallow groundwater monitoring location at the site. GW3 is downgradient of the remediated area but it is screened between depths of between 14.7 and 24.0 mbgl. Therefore, it is not in hydraulic continuity with the layers that contained the hydrocarbon contamination. KMK have applied to the EPA for an Industrial Emissions (IE) Licence, Reg No. P1076‐01, for the Kilbeggan site. This application is being processed by the EPA so is not issued yet. It is expected that this licence, when issued, will also have a condition for annual groundwater monitoring. This, however, would not be for the specific purpose of monitoring hydrocarbon contamination in relation the remediated area at the site.

For inspection purposes only. Consent of copyright owner required for any other use.

KMK Metals Recycling Ltd 10 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

4.0 Monitoring Results The remedial action plan did not require any additional soil or groundwater monitoring during the remedial excavations. There is no soil or groundwater monitoring planned for downgradient of the remediated area. As part of the reinstatement process, the excavated trench was filled with clean soil and stones obtained from a stockpile located at the western part of the site. Full reinstatement of the concrete surface will occur in the near future when the entire concrete surface will be resurfaced.

As the results from the second round of sampling returned hydrocarbon values all below the laboratory LOD, we believe that this is satisfactory evidence that the contamination has been removed from the area.

4.1. Generalised Groundwater Quality Review – Bedrock

There are three groundwater monitoring wells screened in the bedrock at the site (GW1, GW2 and GW3). GW2 is downgradient of the remediated area. However, as described in Section 1.7, the bedrock aquifer is not in hydraulic continuity with the shallow soil, and therefore GW2 is not a suitable monitoring point to determine whether any hydrocarbons have migrated downgradient in the shallow soil. There was no visual or olfactory evidence of hydrocarbon contamination on the southern wall of the excavated pit, and no hydrocarbons were detected above laboratory LOD in the sample taken from the southern wall (S2) in the second sampling round. This would suggest the hydrocarbons did not migrate further than the excavated area.

For inspection purposes only. 4.2. Surface Water Quality Review Consent of copyright owner required for any other use.

There are no current surface water monitoring points or compliance points located downgradient of the former excavation area.

KMK Metals Recycling Ltd 11 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

5.0 Verification –Soil Analyses of Excavation Area

5.1. Excavation Area

The excavation area around the drain was 14.4m in length. In the western side of the pit it was 4.5 m wide and in the centre and eastern side it was 3.5 m wide. After the second round of excavating the pit base was 2.55 m bgl. The pit consisted of:

 0 – 0.16 m bgl: Reinforced concrete

 0.16 – 0.30 m bgl: MADE GROUND – Brown sandy clay with cobbles.

 0.30 – 2.4 mbgl: Brown gravelly sandy SILT with occasional cobbles.

 2.4 – 2.55: Brown firm SILT.

5.1.1. Validation Soil Analyses – TPH There were no incidences where TPH was detected above the various soil generic assessment criteria remedial target values. Specifically, the LQM/CIEH S4Uls commercial limit values at 1% soil organic matter were not exceeded by any of the validation soil samples in either of the sampling rounds, or in the original window samples at WS‐4. While in the first excavation and sampling event in July, there were some hydrocarbons detected above the laboratory LOD, the second sampling event in August returned all hydrocarbon values below the laboratory LOD.

5.1.2. Overall Quality Summary For inspection purposes only. Consent of copyright owner required for any other use.

The soils remaining in the walls and in the base of the excavated pit contain un‐contaminated soil and stones. These soils have been validated by sampling and accredited laboratory soil analyses.

KMK Metals Recycling Ltd 12 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

6.0 Reinstatement

For inspection purposes only. Consent of copyright owner required for any other use.

KMK Metals Recycling Ltd 13 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

7.0. AFTERCARE AND POTENTIAL IMPACT OF THE REMEDIATED AREA

As all five samples from the second round of soil sampling showed hydrocarbons to be below the laboratory LOD, it is expected that the remediation area will have a negligible impact on soil quality in its vicinity.

7.1. Medium Term Monitoring

There is no intention for medium term monitoring of soil or groundwater downgradient of the remediated area to occur.

7.2. Long Term Monitoring

There is no intention for long term monitoring of soil or groundwater downgradient of the remediated area to occur.

7.3. Aftercare of Former Remediated Area

No aftercare management of the remedial excavations is required.

7.4. Final Cap – No Requirement

A concrete cap will be placed on the reinstated pit when the entire site is being resurfaced.

For inspection purposes only. Consent of copyright owner required for any other use.

KMK Metals Recycling Ltd 14 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

8.0 Liaison with the Regulator and Third Parties

This report will be submitted to the Agency by KMK Metals Recycling Limited. The adjacent landowners Irish Jet Profiles Ltd should be notified that there may be residual contamination in the section of drain running onto their property.

For inspection purposes only. Consent of copyright owner required for any other use.

KMK Metals Recycling Ltd 15 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43 IE Consulting Excavation RCA Validation Report

9.0 Conclusions and Recommendations

1. Remedial works were successfully completed at the excavation area and validated by site investigations and soil sampling;

2. The objectives of the corrective action programme were completed effectively and the corrective action will negate the potential risk of hydrocarbons to migrate off site;

3. An aftercare management programme is not currently deemed necessary for the remediated area;

4. It is recommended that surface water and groundwater monitoring is undertaken as per the EPA licence.

Respectfully submitted

On behalf of IE Consulting Conor Lee Jer Keohane

Hydrogeologist Project Manager B.Sc. MSc MSc BSc CGeol MIEI For inspection purposes only. Consent of copyright owner required for any other use.

KMK Metals Recycling Ltd 16 20‐12‐18 IE1616 Draft 1‐0

EPA Export 04-01-2019:03:33:43

Appendix A Figures

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:43 Site Boundary

R446 Road

Kilbeggan

To Tullamore For inspection purposes only. Consent of copyright owner required for any other use.

IE Consulting, Project Title: Remedial Corrective Action Validation Report Innovation Centre, Project Address: KMK, Moate Road, Kilbeggan, Co. Westmeath Green Road, Client: KMK Metals Recycling Ltd. Carlow Drawing Title: Figure 1: Regional Location Map Ph: 059 913 3084 Drg. Scale: Date: Dwg No: Job No: Revision: Dwg. By: Fax: 059 914 0459 Email: [email protected] NTS 5/12/2018 IE1616‐01 IE1616 A CL

EPA Export 04-01-2019:03:33:43 EPA Licence Boundary

For inspection purposes only. Consent of copyright owner required for any other use.

IE Consulting, Project Title: Remedial Corrective Action Validation Report Innovation Centre, Project Address: KMK, Moate Road, Kilbeggan, Co. Westmeath Green Road, Client: KMK Metals Recycling Ltd. Carlow Drawing Title: Figure 2: Window Sample & Groundwater Well Location Ph: 059 913 3084 Drg. Scale: Date: Dwg No: Job No: Revision: Dwg. By: Fax: 059 914 0459 Email: [email protected] NTS 5/12/2018 IE1616‐02 IE1616 A CL

EPA Export 04-01-2019:03:33:43 Excavated Drain Adjacent Site

SS‐2 (North Wall) SS‐1 (West Wall) 4.5 m SS‐4 (Base) 3.5 m SS‐3 (South Wall) KMK Building

14.4 m

For inspection purposes only. Consent of copyright owner required for any other use.

IE Consulting, Project Title: Remedial Corrective Action Validation Report Innovation Centre, Project Address: KMK, Moate Road, Kilbeggan, Co. Westmeath Green Road, Client: KMK Metals Recycling Ltd. Carlow Drawing Title: Figure 3: July Sampling Locations (Plan View) Ph: 059 913 3084 Drg. Scale: Date: Dwg No: Job No: Revision: Dwg. By: Fax: 059 914 0459 Email: [email protected] NTS 5/12/2018 IE1616‐03 IE1616 A CL

EPA Export 04-01-2019:03:33:43 Excavated Drain Adjacent Site

S1 (North Wall) S3 (West S5 (East 3.5 m Wall) 4.5 m S4 (Base) Wall) S2 (South Wall) KMK Building

14.4 m

For inspection purposes only. Consent of copyright owner required for any other use.

IE Consulting, Project Title: Remedial Corrective Action Validation Report Innovation Centre, Project Address: KMK, Moate Road, Kilbeggan, Co. Westmeath Green Road, Client: KMK Metals Recycling Ltd. Carlow Drawing Title: Figure 4: September Sampling Locations (Plan View) Ph: 059 913 3084 Drg. Scale: Date: Dwg No: Job No: Revision: Dwg. By: Fax: 059 914 0459 Email: [email protected] NTS 5/12/2018 IE1616‐04 IE1616 A CL

EPA Export 04-01-2019:03:33:43 KMK Building

Drain Adjacent Site Building

For inspection purposes only. Consent of copyright owner required for any other use.

IE Consulting, Project Title: Remedial Corrective Action Validation Report Innovation Centre, Project Address: KMK, Moate Road, Kilbeggan, Co. Westmeath Green Road, Client: KMK Metals Recycling Ltd. Carlow Drawing Title: Figure 5: Drain Location Ph: 059 913 3084 Drg. Scale: Date: Dwg No: Job No: Revision: Dwg. By: Fax: 059 914 0459 Email: [email protected] NTS 5/12/2018 IE1616‐05 IE1616 A CL

EPA Export 04-01-2019:03:33:43

Appendix B Borehole Logs

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:43 GW1

Borehole Log

Sheet 1 of 2 Method: Date: Site: Air Rotary 3/10/2017 KMK Kilbeggan Diameter mm: Coordinates: maOD of GL:: Client: 160 mm E 632676 N 735875 67.735 KMK Metals Installation Details Installation Depth Description of Strata Legend

Flush Cover at Ground Level Concrete ‐0.44 ‐0.5 Grey sandy gravelly FILL. Gravel coarse grained. Lots of cobbles. Sand medium to coarse grained. Gravel and cobbles ‐0.62 angular to sub angular. Concrete Light brown/grey sandy gravelly clayey FILL. Sand medium to coarse grained. Gravel subangular to subrounded. Some yellow lenses. Standpipe Casing: ‐0.90 ‐1.0 Brown very sandy CLAY. Sand fine to medium grained. Some yellow lenses. 0‐11.3 mbgl. 50mm ø ID. Damp. ‐1.30 ‐1.5 No return Standpipe Screen: Fill 11.3‐20 mbgl. 50mm ø ID. ‐2.0

Concrete: ‐2.5 Clay

0‐0.5 mbgl. ‐3.0 ‐3.0 Dark grey sandy gravelly very soft SILT. ‐3.5 Sand medium to coarse grained. Gravel fine Grout: Silt 0.5‐10.8 mbgl. grained. Gravel subangular to subrounded. ‐4.0 Wet. Becomes very wet at 4.0m. Gravel Sand: band at 5.50m. ‐4.5 Limestone 10.8 – 11.1 mbgl. ‐5.0 Gravel Pack: 11.1‐20.0 mbgl. ‐5.5

‐6.0 Geotextile Sock:

11.3‐20.0. mbgl. ‐6.5

End Cap @ base. ‐7.0

For inspection purposes only. Consent of copyright‐7.5 owner required for any other use.

‐8.0

‐8.3 ‐8.5 Dark brown stiff sandy gravelly CLAY. Gravel

‐9.0 subrounded. Sand medium grained. Dry. At 9.0 m, gravel % decreases and sand % ‐9.5 increases and becomes medium to coarse grained. ‐10.0

‐10.5 Water strike @ 10.8 mbgl at the Interface. ‐10.8 ‐11.0 Light grey weathered LIMESTONE. Some quartz veining and orange staining. ‐11.5

‐12.0 ‐12.3 Major Water strike @ 12.3 mbgl at the Interface. ‐12.5 Light grey competent LIMESTONE. Some orange staining. ‐13.0 Light grey weathered LIMESTONE. Some orange staining. Continued on Next Page

Dipped groundwater level at 0.81 mbgl Drilled & Logged By: Drill Depth: Job No.: No evidence of contamination Stephan Petersen Drilling. Drawn by CL. 20.0 mbgl IE1464

EPA Export 04-01-2019:03:33:43 GW1

Borehole Log

Sheet 2 of 2 Method: Date: Site: Air Rotary 3/10/2017 KMK Kilbeggan Diameter mm: Coordinates: maOD of GL:: Client: 160mm E??????? N????????? ????? KMK Metals Installation Details Installation Depth Description of Strata Legend

Flush Cover at Ground Level ‐13.5 Concrete Standpipe Casing: ‐14.0 0‐5.5 mbgl. 50mm ø ID.

‐14.5 Standpipe Screen: Fill 5.5‐17 mbgl. 50mm ø ID. ‐15.0 ‐15.2 ‐15.5 Dark grey Competent Limestone Concrete: Clay

0‐0.5 mbgl. ‐16.0

Grout: ‐16.5 Silt 0‐5.0 mbgl. ‐17.0 ‐17.0 Weathered Zone Sand: ‐17.2 ‐17.5 Limestone 5.0 – 5.3 mbgl. ‐18.0 Gravel Pack: 5.3‐17.0 mbgl. ‐18.5

‐19.0 Geotextile Sock:

5.5‐17. mbgl. ‐19.5

End Cap @ base. ‐20.0 End of Hole 20 mbgl For inspection purposes only. Consent of copyright‐20.5 owner required for any other use.

‐21.0

‐21.5

‐22.0

‐22.5

‐23.0

‐23.5

‐24.0

‐24.5

‐25.0

‐25.5

‐26.0

Dipped groundwater level at 0.81 mbgl Drilled & Logged By: Drill Depth: Job No.: No evidence of contamination Stephan Petersen Drilling. Drawn by CL. 20.0 mbgl IE1464

EPA Export 04-01-2019:03:33:43 GW2

Borehole Log

Sheet 1 of 2 Method: Date: Site: Air Rotary 5/10/2017 KMK Kilbeggan Diameter mm: Coordinates: maOD of GL:: Client: 160 mm E 632732 N 735797 67.74 KMK Metals Installation Details Installation Depth Description of Strata Legend

Concrete ‐0.15 Flush Cover at Ground Level ‐0.22 Grey sandy gravelly clayey FILL. Sand medium to coarse grained. Gravel angular to subangular. ‐0.5 Brown slightly sandy gravelly clayey FILL. Concrete Standpipe Casing: ‐1.0 Clay firm. Sand medium grained. Some grey 0‐14.8 mbgl. 50mm ø ID. ‐1.15 lenses. Damp. ‐1.5 Standpipe Screen: Fill 14.8‐24.0 mbgl. 50mm ø ID. ‐2.0 ‐2.3 Brown sandy BOULDERS. Sand medium to coarse. Wet. Concrete: ‐2.5 ‐2.6 Soft sandy gravelly CLAY. Sand medium to Boulders 0‐0.5 mbgl. ‐3.0 coarse grained. Wet.

Grout: ‐3.5 0.5‐14.3 mbgl. Clay ‐4.0 ‐4.0 Dark brown/grey very soft sandy clayey Sand: ‐4.5 SILT. Sand medium to coarse grained. Wet. 14.3 – 14.6 mbgl. Silt Water strike @ 5.0 mbgl at the Interface. ‐5.0 ‐5.0 Gravel Pack: Brown sandy clayey GRAVEL bands ‐5.5 throughout the silt. Gravel angular to 14.6‐24.0 mbgl. Gravel subrounded. Sand coarse grained ‐6.0 Geotextile Sock:

14.8‐24.0. mbgl. ‐6.5 Limestone End Cap @ base. ‐7.0

For inspection purposes only. Consent of copyright‐7.5 owner required for any other use.

‐7.9 ‐8.0 Brown sandy gravelly CLAY. Sand medium to coarse grained. Gravel angular to ‐8.5 subrounded. Damp. ‐9.0 ‐9.0 Wet grey sandy GRAVEL. Sand coarse ‐9.5 grained. Gravel subrounded to subangular. Increased % of clay from 10m. ‐10.0 Water strike @ 11.0 mbgl at the Interface.

‐10.5

‐11.0 ‐11.2 Grey, very sandy gravelly soft CLAY. Sand ‐11.5 coarse grained. Gravel subangular to ‐12.0 subrounded. Decrease in % of sand from 12m. Increase in % of clay and sand from ‐12.5 13m. Stifness increases from 13.5m.

‐13.0 Continued on Next Page

Dipped groundwater level at 0.99 mbgl Drilled & Logged By: Drill Depth: Job No.: No evidence of contamination Stephan Petersen Drilling. Drawn by CL. 24.0 mbgl IE1464

EPA Export 04-01-2019:03:33:43 GW2

Borehole Log

Sheet 2 of 2 Method: Date: Site: Air Rotary 5/10/2017 KMK Kilbeggan Diameter mm: Coordinates: maOD of GL:: Client: 160mm E??????? N????????? ????? KMK Metals Installation Details Installation Depth Description of Strata Legend

Flush Cover at Ground Level ‐13.5 Concrete Standpipe Casing: ‐14.0 0‐14.8 mbgl. 50mm ø ID. ‐14.3 ‐14.5 Dark grey weathered LIMESTONE. Some Standpipe Screen: orange staining. Some quartz veins. Brown Fill 14.8‐24.0 mbgl. 50mm ø ID. ‐15.0 clay infill.

‐15.5 Concrete: Boulders 0‐0.5 mbgl. ‐16.0

Grout: ‐16.5 0.5‐14.3 mbgl. Clay ‐17.0

Sand: ‐17.5 14.3 – 14.6 mbgl. Silt ‐18.0 Gravel Pack: ‐18.5 14.6‐24.0 mbgl. Gravel

‐19.0 Geotextile Sock: Clay infill becomes yellow colour. 14.8‐24.0. mbgl. ‐19.5 Limestone End Cap @ base. ‐20.0

For inspection purposes only. Consent of copyright‐20.5 owner required for any other use.

‐21.0 Clay infill becomes tan brown colour. ‐21.5

‐22.0

‐22.5

‐23.0 Clay infill becomes dark brown colour.

‐23.5

‐24.0 End of Hole 24 mbgl

‐24.5

‐25.0

‐25.5

‐26.0

No evidence of contamination Drilled & Logged By: Drill Depth: Job No.: Stephan Petersen Drilling. Drawn by CL. 24.0 mbgl IE1464

EPA Export 04-01-2019:03:33:43 GW3

Borehole Log

Sheet 1 of 2 Method: Date: Site: Air Rotary 4/10/2017 KMK Kilbeggan Diameter mm: Coordinates: maOD of GL:: Client: 160 mm E 632704 N 735728 67.71 KMK Metals Installation Details Installation Depth Description of Strata Legend

Concrete ‐0.22 Flush Cover at Ground Level Grey sandy gravelly FILL. Sand coarse grained. Gravel angular to subangular. ‐0.5 ‐0.47 Light brown gravelly sandy clayey FILL. Sand medium to coarse Concrete Standpipe Casing: grained. Gravel subangular to subrounded. Occasional cobbles. ‐1.0 ‐1.09 0‐14.7 mbgl. 50mm ø ID. Golden brown sandy GRAVEL. Sand medium to ‐1.5 coarse grained. Gravel fine to medium grained. Standpipe Screen: Damp. Becomes less sandy and more gravelly at Fill 14.7‐24.0 mbgl. 50mm ø ID. ‐2.0 2.0m.

‐2.5 Concrete: Gravel 0‐0.5 mbgl. ‐3.0

Grout: ‐3.5 Water strike @ 3.8 mbgl at the Interface. Boulders 0.5‐14.2 mbgl. ‐3.8 ‐4.0 Dark grey limestone BOULDERS. Quartz

Sand: veining. Wet. ‐4.5 Clay 14.2 – 14.5 mbgl. Water strike @ 4.8 mbgl at the Interface. ‐4.8 ‐5.0 Brown soft sandy gravelly CLAY. Sand Gravel Pack: ‐5.5 medium to coarse grained. Gravel 14.5‐24.0 mbgl. subrounded to subangular. Wet. Silt

‐6.0 Geotextile Sock:

14.7‐24.0. mbgl. ‐6.5 Limestone End Cap @ base. ‐7.0

For inspection purposes only. Consent of copyright‐7.5 owner required for any other use.

‐8.0 ‐8.0 Dark grey firm sandy CLAY. Sand medium to ‐8.5 coarse grained. Gravel % increases from 9.0m. ‐9.0

‐9.5

‐10.0 ‐10.0 Brown very soft sandy SILT. Sand medium to ‐10.5 coarse grained. Occasional fine gravel. Very wet. Water strike @ 11.0 mbgl at the Interface. ‐11.0 ‐11.0 Dark grey angular to subrounded gravel. ‐11.5 Very wet. Inceasing % sand from 14m. Sand medium to carse grained. ‐12.0 ‐12.3 ‐12.5

‐13.0 Continued on Next Page

Dipped groundwater level at 0.99 mbgl Drilled & Logged By: Drill Depth: Job No.: No evidence of contamination Stephan Petersen Drilling. Drawn by CL. 24.0 mbgl IE1464

EPA Export 04-01-2019:03:33:44 GW3

Borehole Log

Sheet 2 of 2 Method: Date: Site: Air Rotary 4/10/2017 KMK Kilbeggan Diameter mm: Coordinates: maOD of GL:: Client: 160mm E??????? N????????? ????? KMK Metals Installation Details Installation Depth Description of Strata Legend

Flush Cover at Ground Level ‐13.5 Concrete Standpipe Casing: ‐14.0 0‐14.7 mbgl. 50mm ø ID. ‐14.2 Dark grey weathered LIMESTONE. Some ‐14.5 Standpipe Screen: orange staining. Brown clay infill Fill 14.7‐24.0 mbgl. 50mm ø ID. ‐15.0 throughout.

‐15.5 Concrete: Gravel 0‐0.5 mbgl. ‐16.0

Grout: ‐16.5 Boulders 0.5‐14.2 mbgl. ‐17.0 ‐17.0 ‐17.2 Clay infill becomes dark brown colour. Sand: ‐17.5 14.2 – 14.5 mbgl. Clay ‐18.0 Gravel Pack: ‐18.5 14.5‐24.0 mbgl. Clay infill becomes yellow/brown colour. Silt

‐19.0 Geotextile Sock:

14.7‐24.0. mbgl. ‐19.5 Limestone End Cap @ base. ‐20.0

For inspection purposes only. Consent of copyright‐20.5 owner required for any other use.

‐21.0

‐21.5

‐22.0 Clay infill becomes cream colour.

‐22.5 Dark grey competent LIMESTONE. Some

‐23.0 orange staining.

‐23.5

‐24.0 End of Hole 24 mbgl

‐24.5

‐25.0

‐25.5

‐26.0

Dipped groundwater level at 0.81 mbgl Drilled & Logged By: Drill Depth: Job No.: No evidence of contamination Stephan Petersen Drilling. Drawn by CL. 20.0 mbgl IE1464

EPA Export 04-01-2019:03:33:44

Appendix C Soil Sampling Results

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:44 Project: IE1616 KMK Kilbeggan Client: QED Engineering Chemtest Job No.: 18-22172 18-22172 18-22172 18-22172 18-29454 18-29454 18-29454 18-29454 18-29454 Quotation No.: Q18-11861Chemtest Sample ID.: 660243 660244 660245 660246 695576 695577 695578 695579 695580 Order No.:Client Sample Ref.: SS-1SS-2SS-3SS-412345 Client Sample ID.: 1234 S1S2S3S4S5 Sample Type: SOIL SOIL SOIL SOIL SOIL SOIL SOIL SOIL SOIL Date Sampled: 24-Jul-2018 24-Sep-2018 Determinand Accred. SOP Units LOD Moisture N 2030 % 0.020 15 14 17 17 12 17 16 22 17 Total Organic Carbon U 2625 % 0.20 0.25 1.3 0.23 0.38 0.30 < 0.20 < 0.20 0.42 < 0.20 Mineral Oil N 2670 mg/kg 10 3200 < 10 < 10 8200 < 10 < 10 < 10 < 10 < 10 Aliphatic TPH >C5-C6 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C6-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C8-C10 U 2680 mg/kg 1.0 9.1 < 1.0 < 1.0 7.3 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C10-C12 U 2680 mg/kg 1.0 95 < 1.0 < 1.0 110 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C12-C16 U 2680 mg/kg 1.0 740 < 1.0 < 1.0 1700 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C16-C21 U 2680 mg/kg 1.0 880 < 1.0 < 1.0 2100 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C21-C35 U 2680 mg/kg 1.0 1500 < 1.0 < 1.0 4100 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C35-C44 N 2680 mg/kg 1.0 36 < 1.0 < 1.0 220 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Total Aliphatic Hydrocarbons N 2680 mg/kg 5.0 3200 < 5.0 < 5.0 8200 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Aromatic TPH >C5-C7 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C7-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C10-C12 U 2680 mg/kg 1.0 16 < 1.0 < 1.0 49 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C12-C16 U 2680 mg/kg 1.0 200 < 1.0 < 1.0 820 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C16-C21 U 2680 mg/kg 1.0 140 < 1.0 < 1.0 580 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C21-C35 U 2680 mg/kg 1.0 270 < 1.0 < 1.0 760 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C35-C44 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 160 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Total Aromatic Hydrocarbons N 2680 mg/kg 5.0 620 < 5.0 < 5.0 2400 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Total Petroleum Hydrocarbons N 2680 mg/kg 10.0 3800 < 10 < 10 11000 < 10 < 10 < 10 < 10 < 10 Benzene U 2760 µg/kg 1.0 < 1.0 < 1.0 For inspection < 1.0 purposes only. < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Consent of copyright owner required for any other use. Toluene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Ethylbenzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 m & p-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 o-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

EPA Export 04-01-2019:03:33:44

Appendix D Photos

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:44

Photo 1 Drain running between KMK Building and Adjacent Site

For inspection purposes only. Consent of copyright owner required for any other use.

Photo 2 Hydrocarbon contamination on exterior drain wall outlined in red

EPA Export 04-01-2019:03:33:44

Photo 3 Jack Hammer breaking up the drain walls

For inspection purposes only. Consent of copyright owner required for any other use.

Photo 4 Jack Hammer breaking up reinforced concrete hardstanding

EPA Export 04-01-2019:03:33:44

Photo 5 Excavator removing rubble and soil from void

For inspection purposes only. Consent of copyright owner required for any other use.

Photo 6 Open drain at boundary between KMK site and adjacent site.

EPA Export 04-01-2019:03:33:44

Photo 7 Partition in drain at boundary between KMK site and adjacent site

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:44

Appendix E Laboratory Certificates of Analysis

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:44 Chemtest Ltd. Depot Road Newmarket CB8 0AL Tel: 01638 606070 Final Report Email: [email protected]

Report No.: 18-22172-1

Initial Date of Issue: 09-Aug-2018

Client QED Engineering

Client Address: M-TEK Building 1 Armagh Road Monaghan Ireland

Contact(s): Patricia Murtagh

Project IE1464 KMK Kilbeggan

Quotation No.: Q18-11861 Date Received: 26-Jul-2018

Order No.: Date Instructed: 26-Jul-2018

No. of Samples: 4

Turnaround (Wkdays): 5 Results Due: 01-Aug-2018

Date Approved: 01-Aug-2018

For inspection purposes only. Approved By: Consent of copyright owner required for any other use.

Details: Martin Dyer, Laboratory Manager

Page 1 of 4

EPA Export 04-01-2019:03:33:44 Results - Soil

Project: IE1464 KMK Kilbeggan Client: QED Engineering Chemtest Job No.: 18-22172 18-22172 18-22172 18-22172 Quotation No.: Q18-11861 Chemtest Sample ID.: 660243 660244 660245 660246 Order No.: Client Sample Ref.: SS-1 SS-2 SS-3 SS-4 Client Sample ID.: 1 2 3 4 Sample Type: SOIL SOIL SOIL SOIL Date Sampled: 24-Jul-2018 24-Jul-2018 24-Jul-2018 24-Jul-2018 Determinand Accred. SOP Units LOD Moisture N 2030 % 0.020 15 14 17 17 Total Organic Carbon U 2625 % 0.20 0.25 1.3 0.23 0.38 Mineral Oil N 2670 mg/kg 10 3200 < 10 < 10 8200 Aliphatic TPH >C5-C6 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C6-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C8-C10 U 2680 mg/kg 1.0 9.1 < 1.0 < 1.0 7.3 Aliphatic TPH >C10-C12 U 2680 mg/kg 1.0 95 < 1.0 < 1.0 110 Aliphatic TPH >C12-C16 U 2680 mg/kg 1.0 740 < 1.0 < 1.0 1700 Aliphatic TPH >C16-C21 U 2680 mg/kg 1.0 880 < 1.0 < 1.0 2100 Aliphatic TPH >C21-C35 U 2680 mg/kg 1.0 1500 < 1.0 < 1.0 4100 Aliphatic TPH >C35-C44 N 2680 mg/kg 1.0 36 < 1.0 < 1.0 220 Total Aliphatic Hydrocarbons N 2680 mg/kg 5.0 3200 < 5.0 < 5.0 8200 Aromatic TPH >C5-C7 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C7-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C10-C12 U 2680 mg/kg 1.0 16 < 1.0 < 1.0 49 Aromatic TPH >C12-C16 U 2680 mg/kg 1.0 200 < 1.0 < 1.0 820 Aromatic TPH >C16-C21 U 2680 mg/kg 1.0 140 < 1.0 < 1.0 580 Aromatic TPH >C21-C35 U 2680 mg/kg 1.0 270 < 1.0 < 1.0 760 Aromatic TPH >C35-C44 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 160 Total Aromatic Hydrocarbons N 2680 mg/kg 5.0 620 < 5.0 < 5.0 2400 Total Petroleum Hydrocarbons N 2680 mg/kg 10.0 3800 < 10 < 10 11000 Benzene U 2760 µg/kg 1.0 < 1.0 < 1.0 For inspection< 1.0 purposes

Page 2 of 4 EPA Export 04-01-2019:03:33:44 Test Methods

SOP Title Parameters included Method summary Moisture and Stone Content of Determination of moisture content of soil as a 2030 Soils(Requirement of Moisture content percentage of its as received mass obtained at MCERTS) <37°C. Determined by high temperature combustion 2625 Total Organic Carbon in Soils Total organic Carbon (TOC) under oxygen, using an Eltra elemental analyser.

Total Petroleum Hydrocarbons TPH (C6–C40); optional carbon banding, e.g. 3- 2670 Dichloromethane extraction / GC-FID (TPH) in Soils by GC-FID band – GRO, DRO & LRO*TPH C8–C40

Aliphatics: >C5–C6, >C6–C8,>C8–C10, >C10–C12, >C12–C16, >C16–C21, >C21– Dichloromethane extraction / GCxGC FID 2680 TPH A/A Split C35, >C35– C44Aromatics: >C5–C7, >C7–C8, detection >C8– C10, >C10–C12, >C12–C16, >C16– C21, >C21– C35, >C35– C44

Volatile organic compounds, including BTEX Automated headspace gas chromatographic Volatile Organic Compounds and halogenated Aliphatic/Aromatics.(cf. (GC) analysis of a soil sample, as received, 2760 (VOCs) in Soils by Headspace USEPA Method 8260)*please refer to UKAS with mass spectrometric (MS) detection of GC-MS schedule volatile organic compounds.

For inspection purposes only. Consent of copyright owner required for any other use.

Page 3 of 4

EPA Export 04-01-2019:03:33:44 Report Information

Key U UKAS accredited M MCERTS and UKAS accredited N Unaccredited S This analysis has been subcontracted to a UKAS accredited laboratory that is accredited for this analysis SN This analysis has been subcontracted to a UKAS accredited laboratory that is not accredited for this analysis T This analysis has been subcontracted to an unaccredited laboratory I/S Insufficient Sample U/S Unsuitable Sample N/E not evaluated < "less than" > "greater than"

Comments or interpretations are beyond the scope of UKAS accreditation The results relate only to the items tested Uncertainty of measurement for the determinands tested are available upon request None of the results in this report have been recovery corrected All results are expressed on a dry weight basis The following tests were analysed on samples as received and the results subsequently corrected to a dry weight basis TPH, BTEX, VOCs, SVOCs, PCBs, Phenols For all other tests the samples were dried at < 37°C prior to analysis All Asbestos testing is performed at the indicated laboratory Issue numbers are sequential starting with 1 all subsequent reports are incremented by 1

Sample Deviation Codes A - Date of sampling not supplied B - Sample age exceeds stability time (sampling to extraction) C - Sample not received in appropriate containers D - Broken Container For inspection purposes only. Consent of copyright owner required for any other use. E - Insufficient Sample (Applies to LOI in Trommel Fines Only)

Sample Retention and Disposal All soil samples will be retained for a period of 45 days from the date of receipt All water samples will be retained for 14 days from the date of receipt Charges may apply to extended sample storage

If you require extended retention of samples, please email your requirements to: [email protected]

Page 4 of 4

EPA Export 04-01-2019:03:33:44 Chemtest Ltd. Depot Road Newmarket CB8 0AL Tel: 01638 606070 Final Report Email: [email protected]

Report No.: 18-29454-1

Initial Date of Issue: 02-Oct-2018

Client QED Engineering

Client Address: M-TEK Building 1 Armagh Road Monaghan Ireland

Contact(s): Patricia Murtagh

Project IE1616 KMK Kilbeggan

Quotation No.: Q18-11861 Date Received: 26-Sep-2018

Order No.: Date Instructed: 26-Sep-2018

No. of Samples: 5

Turnaround (Wkdays): 5 Results Due: 02-Oct-2018

Date Approved: 02-Oct-2018

For inspection purposes only. Approved By: Consent of copyright owner required for any other use.

Details: Robert Monk, Technical Manager

Page 1 of 4

EPA Export 04-01-2019:03:33:44 Results - Soil

Project: IE1616 KMK Kilbeggan Client: QED Engineering Chemtest Job No.: 18-29454 18-29454 18-29454 18-29454 18-29454 Quotation No.: Q18-11861 Chemtest Sample ID.: 695576 695577 695578 695579 695580 Client Sample ID.: 1 2 3 4 5 Sample Location: S1 S2 S3 S4 S5 Sample Type: SOIL SOIL SOIL SOIL SOIL Top Depth (m): 0.90 1.30 1.20 0.00 1.40 Date Sampled: 24-Sep-2018 24-Sep-2018 24-Sep-2018 24-Sep-2018 24-Sep-2018 Determinand Accred. SOP Units LOD Moisture N 2030 % 0.020 12 17 16 22 17 Total Organic Carbon U 2625 % 0.20 0.30 < 0.20 < 0.20 0.42 < 0.20 Mineral Oil N 2670 mg/kg 10 < 10 < 10 < 10 < 10 < 10 Aliphatic TPH >C5-C6 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C6-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C10-C12 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C12-C16 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C16-C21 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C21-C35 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aliphatic TPH >C35-C44 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Total Aliphatic Hydrocarbons N 2680 mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Aromatic TPH >C5-C7 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C7-C8 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C8-C10 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C10-C12 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C12-C16 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C16-C21 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C21-C35 U 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Aromatic TPH >C35-C44 N 2680 mg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Total Aromatic Hydrocarbons N 2680 mg/kg 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Total Petroleum Hydrocarbons N 2680 mg/kg 10.0 < 10 < 10 For inspection< 10 purposes only. < 10 < 10 Consent of copyright owner required for any other use. Benzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Toluene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 Ethylbenzene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 m & p-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 o-Xylene U 2760 µg/kg 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

Page 2 of 4 EPA Export 04-01-2019:03:33:44 Test Methods

Total Petroleum Hydrocarbons TPH (C6–C40); optional carbon banding, e.g. 3- 2670 Dichloromethane extraction / GC-FID (TPH) in Soils by GC-FID band – GRO, DRO & LRO*TPH C8–C40

For inspection purposes only. Consent of copyright owner required for any other use.

Page 3 of 4

EPA Export 04-01-2019:03:33:44 Report Information

If you require extended retention of samples, please email your requirements to: [email protected]

Page 4 of 4

EPA Export 04-01-2019:03:33:44

Appendix F LQM/CIEH Suitable for Use Levels (S4ULs) for Petroleum Hydrocarbons for the commercial land use at 1%, 2.5% and 6% soil organic matter (SOM)

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:44 Commercial land use LQM/CIEH S4ULs for Petroleum Hydrocarbons (mg kg‐1 DW) 1% SOM 2.5% SOM 6% SOM Aliphatic EC 5‐6 3200 5900 12000 Aliphatic EC > 6‐8 7800 17000 40000 Aliphatic EC > 8‐10 2000 4800 11000 Aliphatic EC > 10‐12 9700 23000 47000 Aliphatic EC > 12‐16 59000 82000 90000 Aliphatic EC > 16‐35 1600000 1700000 1800000 Aliphatic EC > 35‐44 1600000 1700000 1800000

Aromatic EC 5‐7 (benzene) 26000 46000 86000 Aromatic EC > 7‐8 (toluene) 56000 110000 180000 Aromatic EC > 8‐10 3500 8100 17000 Aromatic EC > 10‐12 16000 28000 34000 Aromatic EC > 12‐16 36000 37000 38000 Aromatic EC > 16‐21 28000 28000 28000 Aromatic EC > 21‐35 28000 28000 28000 Aromatic EC > 35‐44 28000 28000 28000

Aliphatic + Aromatic EC > 44‐70 28000 28000 28000

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:44

Appendix G Haulage and Waste Disposal Tickets

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:44 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:45 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:45 PORTLAOISE - CORK - SHANNON - DUBLIN Page 1 of 1

Enva Ireland Limited, Clonminam Ind Est, Portlaoise, Co Laois, R32 XD95, 057 8678600

INVOICE 0001337229

Date 31-Jul-2018 Our Order No. 0007102872 DELIVERY ADDRESS INVOICE NAME & ADDRESS KMK Metals Recycling Ltd. Customer PO KMK Metals Recycling Ltd. Killbeggan Account No. KMK001 WTF Ref Cappincur Ind. Estate Currency EUR Daingean Road Cr Terms Days 30 Tullamore Co. Offaly Delivery Method VAT Exempt No. IE 4534857 E

Item Product code Product Description Inv Qty Unit Price Total Nett VAT % Total Vat Total Price 1 P1.HAULAGE Collection and Transport of 5.00 200.00 1,000.00 23.00 230.00 1,230.00 Contaminated Soil

VAT Summary Sub-total 1,000.00 Total Nett VAT % Total Vat Total Price Total VAT 230.00 1,000.00 23.00 230.00 1,230.00 Invoice Total EUR 1,230.00

Payment Due By 30-Aug-2018

For inspection purposes only. Consent of copyright owner required for any other use.

Title of the goods does not pass until payment is received in full but risk in the goods shall Enva Ireland Limited pass to the Buyer upon delivery. Registered No: 317186 VAT No: IE 6337186A All goods are supplied in accordance with our standard terms and conditions of sale - Clonminam Industrial Estate, Portlaoise, Co. Laois, Ireland see http://enva.com/termsandconditions Tel: 057 8678600 - Fax 057 8678699 - Email: [email protected] - www.enva.com

EPA Export 04-01-2019:03:33:45 PORTLAOISE - CORK - SHANNON - DUBLIN Page 1 of 1

Enva Ireland Limited, Clonminam Ind Est, Portlaoise, Co Laois, R32 XD95, 057 8678600

INVOICE 0001337218

Item Product code Product Description Inv Qty Unit Price Total Nett VAT % Total Vat Total Price 1 P1.SOIL Treatment and collection of 82.44 60.00 4,946.40 13.50 667.76 5,614.16 contaminated soil of 8244T @ €60.00p/t.

VAT Summary Sub-total 4,946.40 Total Nett VAT % Total Vat Total Price Total VAT 667.76 4,946.40 13.50 667.76 5,614.16 Invoice Total EUR 5,614.16

Payment Due By 30-Aug-2018

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:45 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:46 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 04-01-2019:03:33:46