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The replacement of an Iarnrod Eireann
railway level crossing required the construction
of an embankment within a surface waterway
. ELS worked with the Civil & Structural
Design Engineers to include tender specification
requirements for waste management (including
hazardous wastes) and environmental planning
& control measures in order to minimise
potential damage to sensitive receptors.
During the tender phase, pre-construction
and construction phases of the project,
ELS' main tasks were as follows:
Tender Stage
ELS proposed revisions to the Tender Specification
to include waste management (including hazardous
waste) requirements and environmental damage
preventative measures The waste assessment
included evaluation of soil and sediments
data, waste classification and characterisation,
and quantification of waste arisings.
ELS also designed the surface water monitoring
and validation works programme.
Pre-Construction Stage
ELS undertook an independent review of key
environmental documents prepared by the
appointed Contractor and recommended further
measures as necessary. The key environmental
documents included:
- the Waste Management Plan,
- the Environmental Management Plan
- the Environmental Procedures
- the Surface Water Monitoring Plan
During Construction Stage
The surface water monitoring was independently
evaluated by ELS and recommendations for
further action were made from this review.
ELS liaised with the appointed Contractor
throughout all phases of the construction
works. ELS also reviewed the Contractor's
Method Statement (MS), and ongoing site
control/protection measures.
Finally we provided independent site observation
at key periods throughout the construction
phase.
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This development comprised a mixed-use
residential, retail and commercial development.
The site covered an area of 12,000 m2 and
the development comprised residential units,
retail units, offices and an underground
car-park. The underground car-park consisted
of a double basement which required excavation
over most of the site to a depth of approximately
9 metres.
On behalf of the appointed Building and
Civil Engineering Contractor, ELS classified
material based upon accepted and legislated
waste criteria in accordance with the European
Waste Catalogue (EWC) and Hazardous Waste
List. We also provided interpretation of
vertical and horizontal spatial distribution
of the soil waste material.
ELS undertook a detailed review of environmental
data gathered during the intrusive site
investigation in order to classify the material
to be excavated and removed from the site
according to the relevant waste management
guidelines and regulatory requirements.
Any material to be removed from the site
was subject to requirements under the Waste
Management Acts, 1996 to 2003 and the Landfill
Directive 1999/31/EC and associated regulations,
as well as specific licence or permit requirements
of any proposed receiving facilities/sites.
The waste soil was classified for recovery/disposal
and preliminary material quantities were
assigned to each category. The material
classification required screening of the
soil bulk and leachate laboratory results
against the relevant criteria for each waste
category. Recommendations for additional
soil sample retrieval and analysis were
also outlined.
Based upon the findings of the preliminary
material classification, appropriate environmental
options for re-use, recovery or disposal
of material were outlined by ELS, including:
- identification of suitable receiving
facilities for off-site material transfer,
- provision of data and liaison with facility
representatives,
- review of pertinent permit and licence
details, and
- evaluation/cost benefit analysis of
recovery v's disposal costs
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This project included a subsurface investigation
of land proposed for a bridge replacement
and road realignment scheme. The scope of
work included tasks at the tender, pre-construction
and construction stages as follows:
Tender Stage
ELS provided environmental consultancy
services to the Civil and Structural Design
Engineers in connection with the Longford
Bridge Development at the pre-tender and
construction stages. Our tasks included
review of the Specification with recommendations
for revision in connection with environmental
issues, the design of an environmental subsurface
investigation and report preparation, the
completion of a preliminary qualitative
risk assessment in connection with potential
risk to the environment and site end-users
associated with observed contaminant impact
at the development site, and recommendations
on the basis of the risk assessment to be
considered in the preparation of relevant
amendments to the Tender Specification.
Any material to be removed from the site
was subject to requirements under the Waste
Management Act, 1996; the Landfill Directive
1999/31/EC and associated regulations, as
well as specific licence or permit requirements
of any proposed receiving facilities/sites.
Material to be excavated was classified
by ELS according to the relevant guidelines
and regulatory requirements (e.g. hazardous,
non-hazardous/inert, or low-level contaminated
materials), and preliminary material quantities
were assigned to each category.
Based upon the findings of the proposed
main site investigation and final specifications
for material removal during the proposed
bridge replacement, appropriate environmental
options for re-use, recovery or disposal
of material to be removed from the site
were outlined.
Pre-Construction Stage
During the pre-construction stage, ELS'
provided ongoing consultancy services including:
- Receive and review the final Cross-Section
Drawings detailing the material to be
excavated at the site,
- Review and comment as necessary on the
environmental aspects of the Contractors
Excavation and Dewatering Method Statement,
including the excavation location(s) and
dimensions, the methodology and associated
timeframes for dewatering (if required),
material excavation, handling, segregation,
and stockpiling prior to dispatch,
- Outline recommendations for additional
on-site soil and water sampling and analysis,
as required, and associated sample turnaround,
- Review the water discharge licence and
any associated documentation,
- Independently review the contact details,
permit and/or licence details of all proposed
permitted and licensed receiving site(s)/facility(ies),
including waste acceptance criteria and
procedures
- Review copy(ies) of the Waste Collection
Permit(s) for the haulier(s) proposed
to be engaged for transportation of the
material categories.
- Review the layout and format of the
proposed dispatch dockets and associated
record keeping procedures relative to
each receiving permitted site and licensed
facility to be implemented by the Contractor
during material dispatch.
Construction Stage
Upon commencement of the site construction,
ELS' on-site scope of works included:
- Assist the Contractor and Site Engineer
in setting out the excavation location(s)
and dimension(s) on site,
- Audit the haulers vehicle identification
and Waste Collection Permit details,
- Assist the Contractor and Site Engineer
with regard to on-site procedures and
arrangements for stockpiling, temporary
storage and confirmatory sampling prior
to dispatch to the designated appropriate
licensed facility or permitted site,
- Retrieve random composite soil samples,
schedule the required suite of analysis,
and arrange dispatch to a designated suitably
accredited laboratory,
- Receive laboratory results and classify
the material based on visual observations
and soil sample results,
- Maintain appropriate site records including
visual observations of material excavated,
and the material stockpile and dispatch
procedures undertaken by the Contractor
during ELS' on-site presence,
- Audit samples of the material dispatch
docket and record keeping system as maintained
by the Contractor during the on-site works,
and
- Prepare a final close out report documenting
the material excavation, stockpiling and
dispatch procedures and all associated
works as described above
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A Guidance Document was prepared by
ELS on behalf of a government regulatory
body.
The Guidance Document provided a structured
and reasoned technical outline to assist
with decision making in relation to residential
properties impacted by home-heating oil
contamination event(s). It outlined a methodology
whereby investigations and associated remediation
of impacted residential properties are carried
out in an objective, efficient and transparent
way and where appropriate information is
collected at the relevant stages to underpin
the investigation/remediation process.
The Guidance Document included a checklist
and guidance for best practice associated
with the general approach to the investigation
and remediation (if required) of residential
sites impacted by home-heating oil spill
event(s).
The main elements of the Guidance Document
included:
- Legislation Overview
A brief outline of the relevant legislation
associated with residential oil spills
in Ireland including reference to relevant
water, waste and land legislation.
- Summary of Site Investigation Procedures
This Section provided an overview of current
best practice guidance and standards applicable
to residential oil spills/land contamination.
It also provided an overview to the development
of a conceptual model and the identification
of its components - source, pathway, receptor
and associated pollutant linkages.
- Environmental Risk Assessment
This section provided an overview of the
qualitative and quantitative risk assessment
process. The aim was to assist the Regulatory
Authority to establish whether unacceptable
exposure risk exists at a study site and
if so what further investigation or action
may be needed.
- Options Appraisal
A summary and review procedures for evaluating
feasible remedial options for a site and
determining the most appropriate remediation
strategy was outlined. It included the
basic approaches to reduce or control
risks to receptors, and discussed 'fitness
for purpose' and other elements to be
considered in the selection of the most
appropriate remedial approach, e.g. practicability,
expense.
- Implementation
This section reviewed the main requirements
required for implementing a remediation
strategy, including the development of
the implementation plan or works specification
which should address all aspects of remediation
design, implementation, verification and
reporting, as well as any long-term monitoring
and maintenance that may be required.
It looked at a range of aspects to consider
when formulating the implementation plan
including for example, the requirement
for permits or discharge licenses and
any other approvals necessary to ensure
timely, effective and compliant completion
of the remediation process.
- Verification and Reporting
This section outlined procedures for evaluating
whether the remediation strategy was continuing
to be effective. It also recommended key
reporting requirements to be undertaken
by the Specialist Remediation Contractor
at various stages of the investigative/remedial
works.
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The site operations included construction
of a Town Bypass traversing approximately
7.6 kilometres of rural countryside. Generally
the site works included:
- realignment of local roads,
- construction of link roads and roundabouts,
- construction of various chambers and
ducting works,
- various landscape environmental and
mitigation works,
- culverting and realignment of streams,
- various earthworks,
- diversion of utilities and services,
and
- various ancillary works
ELS provided consultancy services to assist
with surface water protection, pollution
incident control, waste management, and
compliance with National and EU legislation.
Particular elements of the EMP to which
ELS contributed were:
- Soil and groundwater protection,
- Surface water protection,
- Preparation of Environmental Procedures
relating to site activities, including
for example fuel storage, refueling operations,
and servicing of plant,
- Record keeping procedures,
- Training, awareness and competence,
- Monitoring and Measurement, and Audit
Review, and
- Pollution Incident Response Plan (PIRP)
The main elements of the PIRP included:
- Detailing relevant emergency contact
details in the event of a pollution event,
- Outlining emergency procedures, including
preparation of emergency procedures for
posting at key locations across the site,
and
- Preparation of a chemical inventory
for the site
The EMP and supporting documentation were
prepared during the pre-construction phase
and evolved during the project with direct
input by the Main Contractor.
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The site operations included construction
of a Town Bypass traversing approximately
7.6 kilometres of rural countryside. Generally
the site works included:
- realignment of local roads,
- construction of link roads and roundabouts,
- construction of various chambers and
ducting works,
- various landscape environmental and
mitigation works,
- culverting and realignment of streams,
- various earthworks,
- diversion of utilities and services,
and
- various ancillary works
ELS provided consultancy services to assist
with the preparation of the waste management
plan and compliance with National and EU
legislation.
The main elements of the WMP to which ELS
contributed included:
- Quantities and types of arisings,
- Source of waste/material surplus arisings,
- Proposals for minimisation, reuse and
recycling of waste,
- Proposals for waste/material surplus
arisings unsuitable for re-use on site,
- Record keeping procedures,
- Roles and responsibilities
- Training awareness and competence, and
- Waste auditing procedures
The WMP was prepared during the pre-construction
phase and evolved during the project with
direct input by the Main Contractor.
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A Golf & Country Club, Co. (the
Club) was located approximately 1.5 km south
of a Special Protection Area (SPA) and connected
to it by a River. The Club was surrounded
by residential properties, commercial and
industrial and undeveloped pastureland A
release of approximately 5,000 litres of
gas oil diesel occurred from property home
situated adjacent to the Club.
ELS was responsible for undertaking an
investigation of the impacted River/Lake
system within the Club grounds. The sampling
programme was carried out in accordance
with International guidelines. The first
stage of the investigation was to develop
a conceptual model in order to evaluate
the likely behaviour of the oil in the surface
water system and to assist with the design
of a targeted surface water, riverbank and
river-bottom sediment investigation.
Three primary receptor groups identified
by ELS were as follows:
- Controlled waters (sediment and surface
water)
- The Golf Club members; and
- The SPA
An investigation of selected downstream
impacted zones of the River System was designed
and undertaken by ELS. The objectives of
this environmental assessment were to:
- characterise the riverbank sediment,
bottom sediment and surface water quality,
- qualify and quantify baseline conditions
within the unaffected/upstream portions
of the Ward river/lake system within the
Golf Club grounds, and
- propose remedial objectives and target
values for the river/lake system
ELS also evaluated potentially suitable
treatment strategies/remediation alternatives
suitable for the Golf Club in order to achieve
the proposed remedial objectives and target
values within a feasible and agreed time-frame.
Remediation of the oil spill
The remediation strategy considered for
the Club combined physical and in-situ biological
treatment technologies including
- Stage 1 - Physical Methods
- Stage 2 - Chemical/Biological In-Situ
Methods
- Stage 3 - Re-stocking of Aquatic Plants
Following from the above recommendations,
ELS prepared a performance-based 'Remediation
Specification' which was submitted to suitable
specialist remediation Contractors to tender
for the works.
The implementation of the programme was
subject to approval by the Local Authority
in line with the Conditions of the Section
12 notice. The final design and implementation
plan submitted by the selected Contractor
was also subject to final approval by the
Golf Club.
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ELS has assisted the Comite Europeen
des Assurances - Insurers of Europe (CEA),
to enhance the development of sustainable
insurance solutions for prevention an remedying
of environmental damage with particular
emphasis on the Environmental Liability
Directive (2004/35/EC) (the ELD), as well
as other relevant existing and proposed
EU legal instruments.
Work undertaken by ELS on behalf of the
CEA as a member of the Environmental Expert
Task Force has included:
- Research on the methodologies for quantification
of environmental damage with particular
emphasis on the requirements of the Environmental
Liability Directive (2004/35/EC),
- A review of national legal instruments
and insurance products & claims, and
- Development of proposed risk assessment
procedures in connection with environmental
liabilities.
The outcome of the CEA's work includes
publications, seminars presented by ELS
to the insurance and regulatory community
throughout the EU.
Publications available through the CEA
co-authored by ELS include:
- The Environmental Liability Directive,
Enhancing Sustainable Insurance Solutions,
February 2008
- CEA White Paper on Insurability of Environmental
Liability, January 2007
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Objective
To investigate site soil, groundwater
and soil gas conditions from which key source-pathway-receptor
relationships may be identified, i.e. conceptual
model development. Further, assist with
the site risk assessment and evaluation
of viable options for site remediation and
development
Methodology
The investigation methodology for the site
was dependent upon critical site information
(e.g. site layout, access, existing buildings
and utilities, ground conditions, etc.)
and pre- investigation objectives and considerations
(e.g. plans for site development or refurbishment,
proposals for divestiture, acquisition,
leasing, etc.). All such elements were taken
into consideration in advance of the design
and commencement of the site investigation
(SI).
In accordance with BS10175:2001, Investigation
of Potentially Contaminated Sites - Code
of Practice, ELS undertook:
- a site reconnaissance and a fully comprehensive
desktop study based on reference to historical
records, geological and hydrogeological
records, and consultation with relevant
sources
- Development of an initial site conceptual
model
- Design and undertake the intrusive investigation.
This was based upon critical site information
and pre- investigation objectives and
considerations. Elements included:
- sampling of soils, soil leachate, groundwater
and soil gas
- selection of field and laboratory analysis
suites/test parameters
- selection of competent and suitable
accredited laboratory(ies)
- Liaison with stakeholders including
site occupiers, to avoid business disruption
during the SI
- Preparation of a site investigation
specific 'Preliminary Health and Safety
Risk Assessment' for incorporation into
the Health and Safety Statements of the
Client and any investigation sub-contractors
- Review and evaluation of the intrusive
site investigation data, including ground
descriptions/ soil profile logs, analytical
results (soil, soil vapour, leachate,
groundwater and surface water), on-site
monitoring data (piezometer data, gas
monitoring, water field parameters)
Deliverables
- ELS prepared an intrusive Site Investigation
report to broadly include:
- Introduction
- Objectives
- Methodology (i.e. sampling and analysis)
- Observations
- Discussion of analytical Results and
evaluation of the nature and extent of
contamination, if present
- Conclusions and Recommendations
- Annexes
- Data was presented in tabulated format
according to our client's requirements,
including:
- Soil profile log descriptions
- Borehole installation details
- Tabulated and screened analytical results
- We identified existing or potential
environmental liabilities, provided information
for a site specific risk assessment, and
assisted with the development of appropriate
risk management, mitigation and preventative
measures/actions
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ELS' provided environmental consultancy
services, in connection with the characterisation
of waste material discovered along the embankment
of a railway track. The waste material encountered
along the embankment was originally part
of the perimeter of a former disposal site.
The objective of ELS' work was to undertake
an assessment in order to characterise the
material encountered along the embankment
with regard to suitable off-site transfer/disposal
routes and to provide recommendations regarding
the handling, storage and recovery/disposal
of the material.
The assessment addressed the following
objectives:
- provide preliminary information concerning
the nature of material encountered;
- assist with a preliminary classification
of the waste material in accordance with
the waste acceptance criteria pursuant
to Council Decision 2003/33/EC; and
- recommend appropriate measures in respect
of the ongoing storage, handling and recovery/disposal
of the material.
In order to achieve the objectives ELS
undertook the following specific tasks:
- excavate shallow trial pits to provide
a description and classification of the
materials in accordance with the European
Waste Catalogue (EWC);
- collect representative composite soil
samples and submit to a UKAS and MCERT
accredited laboratory for leachate and
bulk soil analysis;
- evaluate the laboratory data and undertake
preliminary classification of the waste
material in accordance with Council Decision
2003/33/EC; and
- evaluate potential recovery/disposal
routes for the material.
The results of the assessment and associated
recommendations were presented in a Preliminary
Site Investigation Report.
The preparation for, frequency and method
of sample collection intended for chemical
analysis, together with their volume, preservation,
handling and recording was carried out in
accordance with BS10175:2001.
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ELS personnel have completed subsurface
investigations at petroleum service stations
and fuel depots located across Ireland on
behalf of the petrochemical industry.
The work was undertaken as part of spill
response, due diligence, pre-purchase and
pre-sale agreements. An intrusive investigation
was undertaken at each of the sites and
consideration was given to local environmental
or commercially sensitive areas, the local
geology and hydrogeology, planning restrictions,
and client needs.
Appropriate remedial action was taken as
appropriate including, tank decommissioning
and removal, excavation and disposal of
contaminated soil, pump and treat, in-situ
bioremediation, air sparging, soil vapour
extraction and off-site recovery disposal.
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ELS have provided environmental expertise
on behalf of loss adjusters, home-owners
and solicitors on a significant number of
residential oil spills located throughout
the country. Input ranged from assessing
extent of damage to soil, foundations, shallow
groundwater, and neighbouring properties,
as well as recommendation for, and implementation
of appropriate remedial measures.
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ELS undertook a review and audit of
an organisations environmental performance
within the ISO14000 structured management
system. The purpose of the review was to
ensure that its performance was in keeping
with its legal and policy requirements in
relation to the environment.
Methodology
In accordance with the ISO 14001 environmental
management system (EMS) model, we assisted
the organisation with both its overall management
and site specific management objectives
as follows:
The definition of their environmental policy
to ensure that it was:
- appropriate to the nature, scale &
environmental impacts of its activities
- committed to continual improvement and
prevention of pollution,
- commited to complying with relevant
environmental legislation and regulations,
- provided a framework for setting and
reviewing environmental objectives and
targets,
- documented, implemented and maintained
and communicated to all employees, and
- available to the public
During the Planning Stage:
We assisted our client to organise, establish
and maintain procedures to identify the
environmental aspects of its activities
which it could control and ensure that any
significant environmental impacts were considered
in the setting of objectives.
We identified and outlined access legal
and other requirements applicable to the
environment.
We assisted our client with the establishment
and maintenance of documented environmental
objectives and targets, consistent with
good environmental policy.
We assisted with the implementation of
environmental management programmes for
achieving the objectives and targets including
designation of responsibility and timeframes
for achievement.
During the Implementation and Operation
Stage we provided advice regarding resource
management in order to ensure that environmental
management system requirements were established,
implemented and maintained in accordance
with the EMS standard.
We also assisted our client with:
- reporting on the environmental performance
of the EMS
- training, awareness and competence within
the organisation
- internal and external communication
- effective document control
- operational control such as stipulating
operating criteria and maintenance activities
- emergency preparedness and response
planning
During the Checking and Corrective Action
stage we outlined measures and assisted
our client to:
- monitor and measure the key characteristics
of the operations and activities
- monitor non-conformances and undertake
corrective and preventative action
- establish and maintain procedures for
the identification, maintenance and disposition
of environmental records
- undertake internal auditing to determine
whether or not the EMS conformed to planned
arrangements for environmental management,
as well as proper implementation and maintenance
for the EMS
- review policy, objectives and other
elements of the EMS in light of changing
circumstances and continual improvement
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ELS offer the capability to evaluate
Light, (Lux) requirements for various work
and associated support areas. Appropriate
lighting solutions based on current legal
and customer requirements can be recommended
to provide the lowest running cost solution.
Consideration of current capital depreciation
allowances available through the Sustainable
Energy Ireland (SEI) are costed.
These include the energy assessment of
lighting systems such as fluorescent, discharge
filaments, LED's and incandescent lighting
systems. The development of a cost efficient
light fixture replacement Microsoft project
plan will be a core deliverable. This will
allow for the most efficient use of labour
and capital over an agreed time line. The
key to such a program is the capital value
in functioning light fixtures which must
be realised.
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ELS can provide recommendations on heating
system efficiencies using various fuel types,
(oil, heavy fuel oil, natural gas, electricity,
biomass). Consideration will be given to
the installation of combined heat and power
(CHP) solutions where appropriate. Such
systems can provide base load electricity
requirements to an organisation where a
heat requirement is also needed.
Infra red building assessment for heat
energy conservation can be undertaken to
provide real feedback regarding any agreed
insulation changes to a buildings envelope.
In the case of buildings constructed with
poor insulation, appropriate and cost effective
insulation programs can be developed and
program managed to ensure that the disruption
to occupants is minimised. All projects
relating to building fabric insulation are
assessed using SEI's Building Energy Rating
(BER) software to calculate projected energy
savings. BER software allows for the introduction
of various insulating materials to calculate
possible benefits. The key to heat conservation
is building fabric integrity. A full project
plan to reduce warm air movement from a
building fabric will be developed on Microsoft
Project and can be fully project managed
by ELS once Technical and Functional Specifications
are agreed between all stakeholders.
The capture of waste heat will be assessed
for the possibility of being recovered and
used in other areas of a building.
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Electrical energy management services
provided by ELS include a full examination
of our clients electrical bill and an assessment
of how best to manage the various tariff's
imposed by the energy provider. For example,
the minimisation of the Maximum Import Capacity
(MIC), the possibility of availing of energy
rebates in the winter months when reducing
energy needs at peak times, and the switching
of power consumption to lower tariff times.
ELS understand that a customers corporate
culture, and staff training is a key element
in achieving a successful energy management
system. The Sustainable Energy Ireland (SEI)
Irish Standard, IS 393 is used by ELS to
assist our clients to develop and maintain
a corporate wide energy management culture.
ELS can undertake the development of appropriate
energy management systems and work with
clients as an in house champion for energy
conservation.
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ELS can undertake an energy assessment
of individual items of plant leading to
tailored energy management solutions. For
example, auto shut down software, installation
of energy saving Variable Speed Drives (VSD's),
and a full investigation of possible accelerated
capital depreciation programs from SEI.
Areas of assessment may include:
- Electrical motor optimisation
- Energy optimisation for machine cycling
- Heater element optimisation/insulation
- Chilled water energy management
- Refrigeration energy management with
appropriate heat recovery systems where
plant size permits
- Compressed air use audit, leak identification
and the development of a remediation plan.
(Compressed air is the costliest means
of developing motive force as it has a
10:1 energy input to output ratio)

RESULT OF ENERGY MANAGEMENT AT CLIENT
SITE
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The Broadmeadow Viaduct is located within
a Special Protection Area (SPA) and a Special
Conservation Area (SAC), both which are
Natura 2000 sites. The sites are furthermore
protected under national legislation as
proposed Natural Heritage Areas (pNHAs).
Following the collapse of the Bridge Pier
No. 04, emergency stabilisation and construction
works were carried out by Jons Civil Engineering
Ltd. (JONS) on behalf of Iarnrod Eireann.
ELS provided environmental consultancy
services on behalf of JONS, with particular
reference to the Environmental Liability
Directive (ELD) 2004/35/EC and the European
Communities (Environmental Liability) Regulations
(S.I. 547 of 2008). To this end, ELS completed
a desktop study of publicly available information
in connection with surface water quality,
protected species and habitats that may
be located upon and within the vicinity
of the site, with particular reference to
aspects of the stabilisation and construction
works.
The objective of ELS' works was also to
identify potential sources of adverse impact
to the environment during the emergency
stabilisation and reconstruction works on
site and outline relevant potential contaminant
source-pathway-receptor (S-P-R) linkages
associated with the site activities, outline
conclusions and recommendation for impact
avoidance, reduction and mitigation.
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ELS undertook a hydrogeological assessment
in relation to the proposed installation
& operation of a groundwater abstraction
well for the Aldi Distribution Centre, Mitchelstown,
Co. Cork.
The objective of ELS' work was to provide
a qualitative assessment of the level of
potential risk posed to the development
site by the proposed groundwater abstraction
and associated lowering of groundwater levels
within the karstified bedrock aquifer at
the site. To this end, ELS assessed the
potential for adverse impacts on potentially
existing subsurface karst features / cavities
and for the development of additional sinkholes
potentially associated with the proposed
lowering of groundwater levels.
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On behalf of a leading commercial lines
international insurer, ELS prepared a specialised
environmental insurance underwriting guideline
in connection with non-pollution environmental
damage exposure risks that fall within the
scope of the Environmental Liability Directive
(ELD) 2004/35/EC.
The principal aim of the underwriting guideline
was to provide summary information to our
Client's team of underwriters which address
the following aspects:
- a background to provide details on the
types of non-pollution related ELD liabilities
and example scenarios as to how they may
occur;
- information regarding the type of potential
losses that may be associated with such
events;
- the types of risk management procedures
that may be considered to prevent the
associated losses, with particular reference
to 'imminent threat' and 'preventative
measures' as per the ELD; and
- the potential extent of the offending
operator's liability within the context
of the ELD remediation requirements (primary,
complementary and compensatory).
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A spillage of approximately 650 litres
of hydrochloric acid (36%) occurred at our
Client's manufacturing site. The date of
the spillage was subsequent to 1 April 2009
transposition date of the Environmental
Liability Directive (ELD) 2004/35/EC.
The spill occurred from the breakage of
a faulty valve connected to the International
Bulk Container (IBC) which contained the
acid. Emergency response measures were immediately
undertaken by the local fire service including
the application of sodium bicarbonate and
sand to control and contain the released
acid.
All of the materials (i.e. sand, residual
foam and sodium bicarbonate) were subsequently
removed and stored into 7 No. 1,000 litre
IBC containers. These containers were stored
at a secure location until collection by
a licensed hauler for transport to an approved
facility.
The principal aim of ELS' completed works
was to assist our Client to comply with
the request by the Local Authority Environment
Division, to carry out an intrusive environmental
assessment to evaluate the potential risk,
if any, to environmental receptors resulting
from the spill event. ELS also assisted
with the classification of the waste and
identification of potentially suitable receiving
facilities for the characterised waste.
With reference to BS10175 'Investigation
of Potentially Contaminated Land' and the
Environment Agency 'Remedial Targets Methodology
Hydrogeological Risk Assessment for Land
Contamination', dated July 2006 ELS carried
out an intrusive site investigation, and
developed a preliminary conceptual site
model (CSM) and preliminary risk assessment.
The methodology was based upon a phased
approach to risk assessment. The tasks undertaken
are summarised as follows:
- development of a preliminary CSM
- undertake a qualitative assessment of
the level of potential risk posed to identified
receptors beneath and in the vicinity
of the site from the spill event. This
will include a review of publicly available
information and shallow soil sampling
in the area of the spill and submit samples
to an accredited laboratory for analysis
(i.e. Level 1 soil zone assessment),
- undertake sampling of the stored waste
materials and submit samples to an accredited
laboratory for analysis of parameters
in accordance with Council Decision of
19 December 2002 establishing criteria
and procedures for the acceptance of waste
at landfills pursuant to Article 16 of
the Landfill Directive,
- prepare a summary report outlining the
preliminary conceptual site model and
qualitative risk assessment and the results
of the sampling and subsequent laboratory
analysis, also provide recommendations
with regard to appropriate transfer/disposal
alternatives and environmental measures
in respect of the ongoing storage, handling
and recovery/disposal of the waste material.
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