British Vita Property UK (2) Limited Phase 1 Environmental ...€¦ · British Vita Property UK (2)...

British Vita Property UK (2) Limited

Phase 1 Environmental Site Assessment Kommerling UK Ltd (formerly CIL), Preston

Project no. 422231CTR12

JUNE 2017

RSK GENERAL NOTES Project No.: 422231CTR12 Title: Phase 1 Environmental Site Assessment of the Kommerling UK Preston site Client: British Vita Property UK (2) Limited Date: June 2017 Office: Helsby Status: Final Rev00

Author Nick Hedges Technical reviewer Dave Allen

Date: 27 June 2017 Date: 27 June 2017

RSK Environment Ltd (RSK) has prepared this report for the sole use of the client, showing reasonable skill and care, for the intended purposes as stated in the agreement under which this work was completed. The report may not be relied upon by any other party without the express agreement of the client and RSK. No other warranty, expressed or implied, is made as to the professional advice included in this report.

Where any data supplied by the client or from other sources have been used, it has been assumed that the information is correct. No responsibility can be accepted by RSK for inaccuracies in the data supplied by any other party. The conclusions and recommendations in this report are based on the assumption that all relevant information has been supplied by those bodies from whom it was requested.

No part of this report may be copied or duplicated without the express permission of RSK and the party for whom it was prepared.

Where field investigations have been carried out, these have been restricted to a level of detail required to achieve the stated objectives of the work.

This work has been undertaken in accordance with the quality management system of RSK Environment Ltd.

British Vita Property UK (2) Limited Phase 1 ESA – Kommerling UK Preston site 422231/12 final rev00

CONTENTS 1 EXECUTIVE SUMMARY .................................................................................................................. 1 2 INTRODUCTION .............................................................................................................................. 3

2.1 Preface ..................................................................................................................................... 3 2.2 Environmental Site Assessment Methodology ......................................................................... 3 2.3 Constraints ............................................................................................................................... 4

3 SITE DESCRIPTIONS AND SETTINGS .......................................................................................... 6 3.1 Site Setting ............................................................................................................................... 6

3.1.1 Topography and Hydrology .......................................................................................... 8 3.1.2 Geology and Hydrogeology .......................................................................................... 9

3.2 Site Operations ......................................................................................................................... 9 3.3 Buildings on Site and Key Infrastructure ................................................................................ 11

4 INTERVIEWS ................................................................................................................................. 13 4.1 Interviews ............................................................................................................................... 13

5 RECORDS REVIEW....................................................................................................................... 14 5.1 Site and Surrounding Area Land Use History ........................................................................ 14 5.2 Regulatory Permits ................................................................................................................. 15

6 ENVIRONMENTAL SITE CONDITIONS........................................................................................ 17 6.1 Ground Risk ............................................................................................................................ 17 6.2 Air Emissions .......................................................................................................................... 19 6.3 Hazardous Materials............................................................................................................... 20

6.3.1 Underground and Above Ground Storage Tanks ....................................................... 20 6.3.2 Storage of Hazardous Materials and Chemicals ........................................................ 22

6.4 Waste Management ............................................................................................................... 22 6.4.1 Non- Hazardous waste ............................................................................................... 22 6.4.2 Hazardous waste ........................................................................................................ 23

6.5 Surface Water and Waste Water Management ..................................................................... 24 6.6 Fire and Emergency Response .............................................................................................. 25 6.7 Deleterious Materials .............................................................................................................. 26

6.7.1 Ozone Depleting and Fluorinated Gases ................................................................... 26 6.7.2 Weeds, Herbicides and Pesticides ............................................................................. 26 6.7.3 Asbestos Containing Building Materials ..................................................................... 26 6.7.4 Polychlorinated Biphenyl (PCB) Electrical Equipment ............................................... 26 6.7.5 Radioactive Materials ................................................................................................. 27

6.8 Nuisance Issues ..................................................................................................................... 27 7 ENVIRONMENTAL MANAGEMENT OVERVIEW ........................................................................ 28

7.1 Management Systems ............................................................................................................ 28 8 CONCLUSIONS ............................................................................................................................. 29 APPENDIX A – FIGURES .................................................................................................................... 31 APPENDIX B – PHOTOGRAPHS ........................................................................................................ 33 APPENDIX C – DOCUMENTATION REVIEWED ................................................................................ 44

British Vita Property UK (2) Limited Phase 1 ESA – Kommerling UK Preston site 422231/12 final rev00

1 EXECUTIVE SUMMARY On behalf of British Vita Property UK (2) Limited, a subsidiary of Vita (Group) Unlimited, RSK Environment Ltd (RSK) performed a Phase 1 environmental site assessment at a site leased and operated by Kommerling UK Limited (part of the international Royal Adhesives and Sealants Group). The site address is 217 Walton Summit Road, Walton Summit Industrial Estate, Preston PR5 8AQ. This report presents relevant information obtained from public and commercial data and from a site visit on 12 June 2017.

The site incorporates a three bay warehouse type building. This comprises a steel portal frame building clad with brick at lower level and painted corrugated steel at higher level. The roof is a mixture of corrugated steel sheet and corrugated asbestos cement sheet.

The 0.8 hectare site was developed from a greenfield site in the late 1970s initially as a chemical storage, blending and distribution warehouse and later as a chemical product manufacturing facility. The same operator has occupied the site throughout this period. The site is located over a major aquifer. British Geological Survey records in the vicinity of the site indicate there is over 6m of boulder clay beneath the site and there is no available evidence of any impact to ground or surface water and no record of any regulatory action.

The tenant, Kommerling UK Ltd, manufactures rubber to metal bonding agents at the site using solvents and other hazardous chemicals and holds an Environmental Permit number EPR/MP3643RT/T001. The site has been closely regulated by the Environment Agency for over 15 years. There has been regular contact with the Environment Agency; the most recent meeting in March 2017 confirmed that no variation to the permit was needed for proposed minor changes to the operations. Based on this Phase 1 assessment, in RSK’s opinion no action is needed by the tenant or landlord to comply with current legislation on soil and groundwater contamination and the site remains suitable for its ongoing industrial use.

Areas of potential concern (AOPC) for ground condition identified in this report include:

• No intrusive soil and groundwater investigation has been carried out at the site since it was developed. Under their Contaminated Land Inspection Strategy, the local authority categorised the site as very high priority in 2015, but they indicated at the time this was simply based on the nature of the activity and there was no action planned. During this assessment the local Environmental Health Officer confirmed that the situation had not changed since 2015, there are currently no plans to investigate the site and that other sites were considered by the council to be higher priority for further investigation. When the subject site permit was issued in 2006 the Environment Agency accepted there was no requirement for intrusive investigation.

• Contamination from previous activities is considered unlikely. Although we understand from discussions with site personnel that there have been occasional spillages, there are no records of contamination of the ground. Overfilling of a process oil tank prior to 2006 overshot the bund and caused a spillage to surface water drains. The Environment Agency was informed and there was no regulatory action against the company. In 2011 the tanks in the affected area were removed together with some underlying concrete to

British Vita Property UK (2) Limited 1 Phase 1 ESA – Kommerling UK Preston site 422231/12 final rev00

prepare foundations for new ventilation and cooling equipment; during these works no visible impact of oil in the soil was recorded so no clean-up was deemed to be required.

• There is a drain grating in the external tank farm area immediately adjacent to the polymer tank bund. There is no written information on this drain point but site personnel believe it is a soakaway. There are no records of any spills in the area and the tank bunds collect rainwater and are reportedly watertight. The operator is in the process of investigating the drainage system to establish the extent of pipework leading to the soakaway and more generally to check the condition of underground sewers and surface water drains. At the time of this assessment there was no further information on the soakaway but interim verbal reporting from the new drainage survey indicated the operator will need to make some minor repairs to other underground pipes. Maintenance of underground pipework is the tenant’s responsibility.

Compliance issues identified in this report include:

• Asbestos is known to be present in a number of areas, including part of the roof. This is not unusual in a site of this age and type. The last documented review and management plan was in 2011 and there is no written system of inspection, although the observed condition was satisfactory. Asbestos management is the responsibility of the tenant and site personnel are presently organising a formal update using an external qualified party which should address this issue.

According to the information supplied by the tenant, these areas of potential concern are being suitably addressed. There is an environmental management system certified by BSI to ISO 14001:2004 and the site is currently making the transition to the latest standard ISO14001:2015. There are no major non-conformances identified in BSI’s most recent surveillance visit.


2 INTRODUCTION 2.1 Preface On behalf of British Vita Property UK (2) Limited, RSK performed a Phase 1 Environmental Site Assessment (ESA) at the site operated by Kommerling UK Limited, hereinafter referred as the subject property or site. The site is located on the Walton Summit Industrial Estate which is 6 km south east of Preston, Lancashire.

The ESA was based on information made available in documentation and through visual observations made during the site visit, information provided by the subject property representative and information in the public domain. The ESA did not include intrusive or destructive surveys.

Units of measurements and area are in SI units unless quoted from third party information.

The objective of the ESA was to identify the extent to which environmental liabilities associated with the subject property may exist.

2.2 Environmental Site Assessment Methodology RSK understands that British Vita Property UK (2) Limited, a subsidiary of Vita (Group) Unlimited, is looking into the possible divestiture of the Preston site freehold. An accurate and full disclosure of environmental aspects is therefore required to support this strategy. RSK has taken the following approach in order that a full and accurate disclosure of the site conditions can be made. The scope of the due diligence assessment has generally followed the accepted practices of ASTM Phase 1 methodology and standards and included the following tasks:

• Task 1 - Data review;

• Task 2 - Site inspection including interviews with site representatives; and

• Task 3 – Reporting

Task 1 Data Review

Background data for the site has been examined, including information in the public domain (geological data, mining reports, historical maps) and any other information provided by the site such as past environmental reports, permitting information and monitoring data.

Task 2 Site inspection and interviews

The site visit was undertaken by Nick Hedges on 12 June 2017 and included a thorough walkover, a review of current operations and practices and an inspection of surrounding areas.

The site inspection was questionnaire-based and included interviews with site representatives:

The site visit and interviews included but were not limited to investigating the following:

• Evidence of past contamination;

• Historical and present use of the site and surrounding area;

• Air emissions;


• Use and storage of hazardous materials;

• Waste management and disposal practices;

• Underground and above-ground bulk storage tanks;

• Surface water and waste water management;

• Polychlorinated biphenyls (PCBs);

• Radioactive materials;

• Surface conditions (e.g. indications of ground contamination and invasive weeds);

• Asbestos and asbestos-containing materials;

• Nuisance issues such as noise and odour; and

• Status of environmental compliance with relevant national and EU legislation.

Task 3 Reporting

This report sets out the findings of the due diligence assessment identifying areas of potential concern (AOPC). This report objectively describes the findings for the facility providing a factual description of the conditions observed.

We classify these as either compliance or ground condition issues as follows:

• Compliance will be for operational or management issues that conflict with the National regulatory regime or that we consider do not reach industry best practice; and

• Ground condition issues will be associated with contamination that is known or suspected to exist under or near the sites.

Photographs are included in Appendix B.

2.3 Constraints

This report describes the results of the ESA and identifies the presence of areas of potential environmental concern (AOPC) at the subject property and within the immediate surrounding area.

In the course of completing the ESA, RSK has attempted to independently assess the potential presence of such problems within the limits of the established scope of work for this project as set forth in Section 2.2 above.

The scope of this ESA, where appropriate, covers legal or regulatory compliance with respect to UK regulations associated with environmental matters.

As with any Phase I ESA, there is a certain degree of dependence upon oral information provided by site representatives, which is not readily verifiable through visual inspection, or supported by any available written documentation. RSK shall not be held responsible for


conditions or consequences arising from relevant facts that were not fully disclosed by site representatives at the time this ESA was performed.

This report and all field data and notes were gathered and/or prepared by RSK in accordance with the agreed scope of the work and generally accepted engineering and scientific practices in effect at the time of the site visit. The statements, conclusions and opinions contained in this report are intended to give approximations of the environmental conditions on site.

This report, including all supporting field data and notes (collectively referred to hereinafter as “information”), was prepared or collected by RSK for the benefit of its client. The information may be released to third parties, who may use and rely upon the information at their discretion. However, any use of or reliance upon the information by a party, other than specifically named above, shall create no rights, obligations, or liabilities on the part of RSK with respect to any such party. The information shall not be used or relied upon by a party that does not agree to be bound by the above statement.


3 SITE DESCRIPTIONS AND SETTINGS 3.1 Site Setting The 0.8 hectare site is located on the Walton Summit Industrial Estate situated approximately 6km south east of Preston in Lancashire, in a triangle bounded by the M6, M61 and M65 motorways. It is one of many businesses on the estate which was developed in the 1970s.

A site aerial photograph and location plan can be found in Appendices A and B respectively.

The subject site is owned by British Vita Property UK (2) Limited, a subsidiary of Vita (Group) Unlimited. The site was re-purchased from Rock Capital in 2015 after a sale and leaseback in 2006.

Neighbouring properties and features include:

• To the north: Walton Summit Road, beyond which is a collection of businesses including Summit Foods; Dean & Wood refrigeration; GAP Plant and Tool Hire; and a large ParcelForce depot.

• To the east: Cocker Road, beyond which is a largely disused warehouse building, H Parkinson Haulage Ltd and Bosal exhaust manufacturers.

• To the south: Newfield Road, beyond which is a Carillion rail maintenance workshop and Leyland Auto Vehicle Care Centre.

• To the west: Walton Summit Truck Centre.

There is a small triangular piece of land immediately to the west of the site. Formerly a local authority car park used by site vehicles, it is now used for vehicle parking by the Walton Summit Truck Centre.

The nearest housing to the site is 400m to the north, on Bluebell Way and 440m west, on Langden Crescent. The nearest motorway is the M6 which runs approximately 400m to the west of the site.


The public domain and Envirocheck report 12755988_1_1 includes the following information on the site.

Site Specific Details – Preston, Kommerling UK Ltd

Address

Kommerling UK Ltd 217 Walton Summit Road Walton Summit Industrial Estate Preston PR5 8AQ

Site Setting (within boundaries of site)

Waste There are no records of former landfills within site boundaries.

Hazardous Substances

There is a recorded planning hazardous substance consent for the site (South Ribble Borough Council, application ref: 0007) for the maximum storage of 348.2 tonnes of toluene di-isocyanate. According to Envirocheck records, the site is registered as a lower tier COMAH site (this is no longer the case, see section 3.2).

Industrial Land Use There are no other records of contemporary trade directory entries other than for Kommerling UK within the site boundary. There are no Fuel Station entries.

Sensitive Land Use The site is not within any sensitive land use area (i.e. Greenbelt, AONB, Local nature reserve, nitrate vulnerable zone, SPA, SAC, Ramsar, SSSI, national park, , etc.).

Permits, Licenses, registrations & Consents held

There are no contaminated land register entries or notices, no discharge consents to controlled waters, no water abstraction licenses and no registered radioactive substances for the site listed in the Envirocheck report. The site is listed as a lower tier COMAH site and as having a Planning Hazardous Substance Consent (ref: 0007). The site currently holds a permit under the permitting regulations (ref: MP3634RT); the main activity being 6.5 B (A)(1) the manufacture of dyestuffs, printing ink and coating materials: using > 100 T organic solvent /12 months and a subsidiary activity of 4.1 (A)(1)(A)(VI) Organic Chemicals; Halogen Containing Compounds E.g. Halocarbons. There are 5 other revoked IPPC/PPC entries. There is an entry for a Part B Process for the site described as Application Not Yet Authorised. Following discussion with the local Environmental Health Officer this is no longer believed to be active.

Enforcement, Prohibition, Prosecutions & Incidents

There are no recorded enforcement, prohibition, prosecution or pollution incidents related to the site.

Surrounding Area detail (<500m beyond site boundary)

Permits, Licenses, registrations & Consents held

There are no contaminated land register entries or notices, no discharge consents to controlled waters, no water abstraction licenses and no registered radioactive substances listed in the Envirocheck report within 500m of the site. There are two active IPPC records, the nearer is Evans Vanodine 282m north west on Brierley Road, an inorganic chemicals and acids activity. Forfarmers UK operates an animal/vegetable/food treatment activity 360m north west.


Site Specific Details – Preston, Kommerling UK Ltd

There are 10 Local Authority Pollution Prevention and Control records of which six are active; Creative Impressions 122m south east operates blending, use etc of bulk cement, Moore Readymix operates a general mineral process 176m south west; Forbo Flooring operates a bitumen & tar process 238 m south west; Bosal has applied for a metal/plastic coating process 340m south east; Garrick Surface Coatings operates metal/plastic and powder coating processes 340m south west; Hydroproof operates a textile and fabric coating process 386m south east.

Enforcement, Prohibition, Prosecutions & Incidents

There are no recorded enforcement and prohibition notices, no local authority pollution prevention and control enforcements, no prosecutions relating to controlled waters and no planning hazardous substances enforcements. There is one entry on the Substantiated Pollution Incident register at 58m north west from the site on 11 January 2002, incident reference 51884. There was a category 2 significant incident to air, a minor category 3 impact on land and no impact on water. The location is on the land now occupied by Gap Tool Hire. There is one prosecution related to illegal burning of waste 162m south west of the site dated 12 June 2002 and with a fine of £500 and costs of £300. There are 24 recorded instances of pollution incidents to controlled waters. The nearest is a category 3 minor incident at an unnamed pond 47m north in June 1993. The latest incidents were a tank failure category 3 incident releasing inorganic chemicals at Woodside Haulage 251 m north on 12 August 1999 and a molasses spill category 2 significant incident 384m north west at a food & beverage manufacturer on Shuttlingfields Lane on 18 October 1999.

Waste

There are no registered, BGS recorded or historical landfill sites within 500m of the site. There are two licensed Waste Management Facilities in the records; a household, commercial and industrial waste transfer station 170 m south of the site which was operated by Recycling Lives Ltd and was surrendered on 9 January 2014 (license 54436); and a metal recycling site operated by Tom Martin & Co 274 m south of the site issued in July 1991 and modified in October 2013 (licence 54054).

Hazardous Substances

There is 1 upper tier COMAH site and 1 planning hazardous substances consent; these are both located at Evans Vanodine International approx 280m to the east of the site. According to their website, the company manufactures a wide range of janitorial and livestock protection chemicals. The Planning Hazardous Substances consent application was made on 13 January 2016. The subject site is within the consultation zone and a local meeting was held in summer 2016.

Industrial Land Use There are 108 contemporary trade directory entries and 1 fuel station entry within 500m of site.

Sensitive Land Use

There are no sensitive land uses within 500m of the site. The Environmental Permit identifies there are no sites designated under the Habitats Directive within 10 km of the site; there are 6 local wild life and 2 ancient woodland sites within 2 km but no further impact assessment is needed for the subject site.

3.1.1 Topography and Hydrology

The site is approximately 57m above sea level. The immediate area is locally flat but the land slopes gently down from the south east to the north west.


The nearest water courses are the River Lostock 750m to the west and the Fowler Brook 600m to the south east. There are some small ponds offsite at approximately 120 m to the north west and drainage at the intersection of Carnfield Place and Walton Summit Road 170 m to the north east.

The site is not at risk of flooding from rivers or sea. There is limited potential for groundwater flooding to occur.

There are no authorised water abstractions within 500m of the site; the nearest abstractions are at Dunbia at Bamber Bridge, 762 m south west of the site.

3.1.2 Geology and Hydrogeology

The published geological maps for the area indicate that the site is underlain by glacial boulder clay. British Geological Society (BGS) borehole records from October 1972 confirm the presence of a significant layer of boulder clay, see Section 6.1.

Underlying the drift deposits is the Sherwood Sandstone Group of Triassic age, which includes rare mudstone horizons. A northeast – southwest trending fault, with the strata being downthrown to the northeast, lies approximately 750m to the south of the site.

The Groundwater Vulnerability Map for the area indicates the drift deposits to be a Non-aquifer (negligibly permeable), and are considered to contain insignificant quantities of groundwater. The underlying Sherwood Sandstone is classified as a Major Aquifer. These are highly permeable formations usually with a known or probable presence of significant fracturing and may be highly productive and able to support large abstractions for public supply and other purposes.

The soils at the subject site are classified as having a high leaching potential which is applied to urban areas and is based on there being fewer observations than elsewhere. Therefore, a worst-case vulnerability classification is assumed, until proven otherwise.

The location is described as an area that might not be affected by coal mining and there is no hazard identified from non-coal mining. The potential for collapsible, landslide running sand ground and shrinking or swelling clay ground stability hazards is very low, and there is no potential for compressible ground or dissolution stability hazards. The subject site is in a lower probability radon area and no radon protective measures are considered necessary in the construction of new buildings or extensions at the site.

There are no BGS recorded mineral sites within 500m of the site.

3.2 Site Operations The Kommerling UK Ltd Preston site specialises in the production of rubber to metal bonding agents, trading under the Cilbond brand name. The site operates in compliance with an Environmental Permit, the details of which are covered in Section 5.2.

The site was initially constructed in the late 1970s for Compounding Ingredients Ltd, who purchased the site. Site activities have remained broadly similar throughout the period to date, and the site management has maintained continuity since first occupying the site when it was developed. Some operations have been discontinued and the operating business has changed name over the years as follows:


• Compounding Ingredients Limited from 1977 to 2002;

• Chemical Innovations Ltd from 2002 to 2015;

• Kommerling UK from 2015 to date.

Kommerling UK is a subsidiary of Royal Adhesives & Sealants, an international group of companies with experience in the development, manufacture and distribution of proprietary, high quality adhesives, bonding agents and sealants for a variety of applications.

The company and site ownership has changed over the years:

• Compounding Ingredients Limited, a company formed in 1959, purchased the premises in the 1970s. The site started operation as a two bay distribution warehouse for imported materials before commencing production of their own products.

• In the late 1990s the third bay was constructed.

• The company changed name in April 2002 to Chemical Innovations Limited (CIL).

• In 2004 British Vita acquired the CIL business including the site.

• In 2006 the site was sold to Rock Capital and leased back to CIL.

• In 2015 the site was re-purchased by Vita Group.

There are approximately 50 employees on site working across the following areas:

• Cilbond manufacturing areas;

• Raw material and finished goods warehouses;

• Quality Control and development laboratories;

• Administrative offices; and

• Maintenance.

Production operates a two shift system, 6am to 2pm and 2pm to 10 pm Monday to Friday.

The Cilbond processes involve the preparation of various solutions of resins, rubbers and polymers in batch vessels and reactors. The process includes the mixing, chopping and milling of solids, and blending with a polymer and rubber solution in solvent – some of the solvent is stripped off by distillation and re-used. The polymers (known as P6 and P8 intermediate polymers) are manufactured on site in batch reactors operating at about 150ºC and heated and cooled using thermal oil.

There are 5 Cilbond production areas, of which four are solvent based products and one is water based. The majority of areas within the factory main building are classified as hazardous areas in accordance with the Dangerous Substances and Explosive Atmospheres Regulations 2002. The external tank farm is also classified as a hazardous area within 1m of the storage tank bunds.

Approximate production levels at the time of the assessment were 40 tonnes per month of polymer and 200 tonnes per month of bonding agent.

Discontinued operations

The site previously manufactured Tyrfil, an expanding rigid product for large vehicle tyres and Monothane and Duothane urethane coatings, all of which involved similar blending type


operations as Cilbond. A significant difference was these processes used isocyanates and the site was registered as a lower tier COMAH facility as it stored toluene di-isocyanate (TDI). These operations have been discontinued since about 2008, TDI is no longer used and the COMAH registration no longer applies. The 2017 Envirocheck report 12755988_1_1 includes a record of a planning hazardous substance consent for the site (ref: 0007) from South Ribble Borough Council for the maximum storage of 348.2 tonnes of toluene di-isocyanate.

Although there is no official documentation recording the cessation of the COMAH registration, the Environment Agency permit variation BU54881H/V003 issued in 2011 (see section 5.2) states the following: “since issue of the PPC permit in 2006, the Tyrfil process, which is a Section 4.1 A(1)(d) listed activity, has been removed. This process was also regulated under the control of major accident hazards (COMAH) due to the use of toluene di-isocyanate (TDI). The removal of this process resulted in the removal of air release point A1 and meant that regulation under COMAH is no longer applicable”.

Site personnel reported that some previous products contained lead such that workforce health surveillance monitoring took place but no more information was available and the operations had ceased prior to 2012.

3.3 Buildings on Site and Key Infrastructure Approximately 80% of the site is covered by the main building, a tarmac car park and hardstanding, mostly of concrete but with some areas of hardcore and gravel. Around 20% of the site remains grassed or vegetated.

The main manufacturing building has been constructed in stages with the first two bays constructed for the company in the late 1970s and the third bay constructed to the west in the 1990s giving a total floor area of 2,604 m2. Photographs of the main building are located within the photo log in Appendix B.

The building contains:

• Raw material and finished goods warehouses;

• Cilbond manufacturing areas (five zones) with electrically heated thermal oil heaters;

• Quality control and development laboratories;

• Administrative offices with three domestic gas central heating boilers; and

• Air handling systems for extraction and treatment of solvent fumes, with make up air heated by natural gas.

Eon provides electric power and natural gas to the site. In 2016 the site used 2275 MWh of electricity and 393 MWh of gas.

United Utilities provides mains water to the site used for process and potable water. In the 2016 Pollution Inventory form, the site reported it used 865 m3 of mains water.

The key infrastructure outside of the main building consists of the following:

• A sprinkler pump house and a pair of 765m3 fire water tanks to the west of the site within a steel palisade fence;


• Purpose built aerosol store adjacent to and attached to the south west corner of the main building;

• A tank farm/storage/services area in the east part of the site protected by a steel palisade fence incorporating;

o A hazardous waste storage area;

o Canopied tanker delivery area/ waste drum storage area;

o Tank farm with bunded solvent and polymer bulk storage tanks;

o Standby generator with bunded diesel tank;

o Outbuilding containing two chillers, two air compressors and electrical switchgear;

o Two 1000 kVA 11kV/433V transformers;

o A drain connection to the sewer for consented discharge of uncontaminated rainwater; and

o An open drain grating over a presumed soakaway.

• A tarmac car park in the north of the site;

• A strip of concrete hardstanding to the south for delivery vehicles;

• The site has a connection to a combined sewer for foul / trade effluent that runs along the front of the building and connects to a United Utilities sewer in Brierley Road; and

• The site has a separate surface water drainage system with a connection to a surface water main running along Walton Summit Road.


4 INTERVIEWS 4.1 Interviews The site inspection was questionnaire-based and included interviews with the following site representatives:

• John Emerson (Operations Manager); and

• Stephen Martin (UK Finance Director)


5 RECORDS REVIEW 5.1 Site and Surrounding Area Land Use History The Envirocheck report 12755988_1_1 includes the following information on OS maps since 1848:

Date of OS map

Details at and in the vicinity of the site

1848 The historical map shows the site to be located in an agricultural area with scattered small ponds, the nearest approximately 40m to the west of the present building

1893 There is an old clay pit 120m to the south east and a contagious diseases hospital (Bradkirk) 100 m to the north. Two farms, Lions Den and the Old Lemon House, lie approximately 110 m from the site, to the north east and south west respectively.

1974 Little change to the immediate area. The M6 has been constructed 350m to the west of the site and the M61 is present 850m to the north east. Housing has been developed 440 m to the west and 500 m to the north.

1981-1984

The Walton Summit Industrial Estate has been developed including the subject property; the building footprint on the site is consistent with a 2 bay building. The present day Carillion and Leyland Autocare buildings to the south and ParcelForce building to the north are shown.

1987-1991

The warehouse building to the east of the site has been developed.

2001 The subject site building footprint has been extended consistent with the addition of the third bay to the west. The M65 has been constructed 650m to the south of the site.

2017 No significant further changes evident on the site or in the vicinity. Old Lemon House building still shown.

Previous environmental assessments have been carried out by ERM in 2004 for Robinson Bradshaw & Hinton, by RSKENSR in 2006 for British Vita and by Environ in 2015 for Royal Adhesives and Sealants.

The ERM report included a site visit and identified some small areas of staining in and around the bulk delivery area containment and on gravel in the outside areas around the air compressors, back-up generator and small diesel tank.

The RSKENSR report was a desktop study which concluded that no complete pollution linkages existed and the site posed a low risk to site users and the surrounding area.

The Environ report summary gave an overview of their findings which refers to two potentially significant contamination matters; past operations of the site which included the use of toluene


di-isocyanate, dichloromethane and trichloroethene; and overfilling of a former Tyrfil oil tank. No significant impairment of environmental media or regulatory non compliance was identified.

5.2 Regulatory Permits The site holds an Environmental permit number EPR/MP3634RT/T001 (previously EPR/BU54881H) under the Environmental Permitting (England & Wales) Regulations 2010, as amended in 2011, 2012 and 2013. Historical records indicate an integrated pollution control permit was issued on 27 March 2002.

Site personnel were able to demonstrate a record of regular communication with the Environment Agency. Apart from email correspondence, the following permit changes have been notified:

The application by Chemical Innovations Limited for the present permit was accepted as duly made on 30 March 2006 and determined by the Environment Agency on 19 December 2006.

The first variation V002 was issued in October 2008 to reflect the removal of the monothane process and modifications to the existing process.

The second variation BU54881H/V003 was issued on 13 December 2011 to reflect expansion of solvent based production. A copy was made available to RSK prior to the site visit.

A further variation V004 was issued on 28 May 2015 to reflect the change in the company registered address.

The permit includes 9 improvement conditions, of which the first 7 were considered completed by the Environment Agency at December 2011. Improvement condition IP9 was confirmed as closed out by Environment Agency Compliance Assessment report reference BU54881H/0192000 dated 29 October 2013. There is no documentation concerning the status of improvement condition IP8, which requires particulate size distribution of the air emissions, however site personnel believe it has been completed. It is possible that the Industrial Emissions Directive, implemented in the UK through the Environmental Permitting (England & Wales) Regulations 2010, could introduce a requirement for soil and groundwater testing at some point in future.

The latest Compliance Assessment Report BU54881H/0254443 was issued by the Environment Agency in December 2015 and recorded a change in the nominated Environment Agency inspector for the site.

Site personnel stated that they met with the Environment Agency most recently in March 2017 to discuss planned changes to the water based production. Although no documentation was issued, site personnel were advised that because there was no new activity and no change to the VOC emissions were anticipated the permit would not require a further variation.

The site provides annual reports to the Environment Agency summarising emissions and the business operations. The most recent one for the calendar year 2016 was reviewed.

Kommerling UK holds a trade effluent discharge consent from United Utilities (see Section 6.5).


Kommerling UK Ltd falls below the thresholds for the Energy Savings Opportunity Scheme and the CRC Energy Efficiency scheme. The site participates in a Climate Change Agreement through the Chemical Industries Association.


6 ENVIRONMENTAL SITE CONDITIONS 6.1 Ground Risk The site was greenfield prior to the construction of the present building in the late 1970s. The site has been in continuous operation since then, initially as a blending and distribution centre for chemical products and later as a chemical manufacturing facility.

An environmental search request was made as part of the Environ 2015 Phase 1 assessment to South Ribble Borough Council. In a letter dated 11 February 2015, the local Environmental Health Officer confirmed the site did not appear on their register of contaminated land. In the same letter he stated that based principally on current use, the site had been ranked as very high priority for further assessment, so further ground investigation cannot be ruled out; however at that time the Council had no immediate plans or a timetable to carry out any further assessment.

The local Environmental Health Officer confirmed in a telephone conversation on 19 June 2017 that there were still no plans or budget to carry out further assessment and added that other sites were of higher priority for assessment when funds became available. He stated that the original rating used a systematic approach based on historical mapping information and the very high ranking resulted from the site operating as a chemical manufacturing facility.

Site personnel are not aware of any records of intrusive investigation at or near the site. The British Geological Society (BGS) carried out borehole surveys in the vicinity of the site during the 1970s for the Central Lancashire Development Corporation, possibly in preparation for the Walton Summit Industrial Estate. BGS borehole records from October 1972 included a borehole on the subject site (BGS reference SD52NE630 at Easting 357430, Northing 425320) which showed a ground level at 56.7m above Ordnance Datum, 0.2m of topsoil; firm, brown, sandy, silty, stoney CLAY down to 2m; and stiff or firm, brown, sandy, silty, BOULDER CLAY to the base of the borehole at 6.1 m.

The site operates according to a revised site protection monitoring programme (SPMP) for permit BU54881H/V003 dated 6 January 2012. This was prepared following the permit variation in 2011. The Application Site Report and original SPMP were not available during this assessment, but the revised SPMP records that (at the time of the 2006 application) the collection of baseline reference data (for soil and groundwater) was not required by the Environment Agency as long as specified works were carried out within 8 months. These specified works were the fitting of high level probes and alarms to the toluene and MEK tanks. Although site personnel do not have documentation to confirm acceptance by the regulator, subsequent variations of the permit in 2008, 2011 and 2015 have not required further investigation.

At the time of the visit, the toluene and MEK tanks were not fitted with probes and alarms but site personnel confirmed that the capital expenditure required to install these had been approved (ID4496) by Kommerling management. It should be noted that the tanks are fully bunded, there are no records of any spillage or overfilling and no evidence of spillage was observed.

The SPMP describes an Infrastructure Monitoring Programme to minimise the risk of pollution. This includes physical measures such as bulk tank alarms, bunding, sumps in production areas, the use of above ground pipework for all raw material transfer from external storage into the factory, provision of spill control kits around the building; management measures such as written


procedures for inspections, hazard and near miss reporting, emergency preparedness and response, an environmental management system subject to internal and external auditing. With the exception of the probes and alarms project described above, these measures appeared to be in place at the time of the site visit.

The production rooms inside the factory are fitted with concrete lined sumps below floor level to capture possible spillage. Site personnel are not aware of any incidents which have led to these sumps being used.

There are no detailed records, but site management stated that prior to 2006 a process oil tank to the rear of the property was overfilled, causing material to be ejected over the bund, onto the concrete hardstanding and into a surface water drain. This was reported to the Environment Agency but was not recorded as a formal incident and no regulatory action was taken. Instead, full clean up of the concrete and drains was undertaken and measures were taken to mitigate any future spills, including the installation of an inflatable bladder system in the drain to allow it to be sealed quickly in the event of spillage. (Note: following a fire in 2010 the bladder system was disabled to allow the installation of the firewater system, however site personnel confirmed that a capital expenditure request ID5112 has been approved to reinstate the system). In 2011 the tanks in the affected area were removed together with some underlying concrete to prepare foundations for new ventilation and cooling equipment; during these works no visible impact of oil in the soil was recorded so no clean-up was deemed to be required.

A fire at the site in 2010 (see Section 6.6) caused damage to the building but there was no release of process liquid or contaminated firewater and no regulatory action. A comprehensive sprinkler system was subsequently installed at the request of the insurance company. The tenant is now investigating the provision of firewater run off protection measures to ensure that, in the event of sprinkler deployment when the factory is unoccupied, the main building is bunded to significantly reduce the risk of run off to ground or surface water drains (see Section 6.6).

Site personnel advised that a recent incident inside the factory in April 2017 led to the puncturing of a P6 polymer 205 litre drum by a metal skid carried by a fork lift truck. Approximately 80 kg of solvent spilt onto the concrete floor, a spill kit was immediately deployed and the material cleaned up with no release from the building. The cause was fully investigated and seven actions were identified and documented in the management system.

During the site tour, a drain grating was observed in the external tank farm area close to the eastern fence and adjacent to the polymer tank bund. Beneath the grating appears to be a sump (estimated 0.6m diameter x 1.5m deep) with an underground drain feeding into it from the south east. This is not presently recorded on site drainage plans. Site personnel reported that the level remains static and there has been no evidence of visual contamination; and that recent discussion with United Utilities personnel indicated it was likely to be a soakaway. There are no records of any spills in the area and the solvent tank bunds regularly fill with rain water and have to be pumped out in accordance with the trade effluent consent, indicating that they are functional. The tenant is in the process of investigating the drainage system (see Section 6.5).

No evidence of spillage beyond de minimis staining was observed during the visit.


6.2 Air Emissions There are various air emission point sources identified from site in the permit and the emission values on three of these points are reported to the Environment Agency on a regular basis, as specified in the permit.

The air emission sources are summarised in the table below:

Emission reference point

Parameter Source Limit Monitoring frequency

A2 Total Class B Volatile Organic Compounds – Expressed as Carbon

Online Activated Carbon Filter from Cilbond 1

5 tonnes per year or 2kg/hour whichever is the lower (expressed as carbon); 75 mg/m3

Annually

Particulates Online Activated Carbon Filter Unit A or B from Cilbond 1

5 mg/m3

Annually

A4 Various Locations

Volatile Organic Compounds

Vents on Bulk Solvent Storage Tanks

No limit set -

A6

Total Class B Volatile Organic Compounds – Expressed as Carbon

Online Activated Carbon Filter from Cilbond 3 & 4


Annually

Particulates Online Activated Carbon Filter Unit A or B from Cilbond 3 & 4

5 mg/m3

Annually

A7

Total Class B Volatile Organic Compounds – Expressed as Carbon

Online Activated Carbon Filter from Cilbond 2 & 5 & flammable store


Annually

Particulates Online Activated Carbon Filter Unit A or B from Cilbond 2 & 5 & flammable store

5 mg/m3 Annually

The Cilbond 2 and 5 production areas have a sophisticated air handling system, installed as part of the upgrade in 2011. This maintains a suitable continuous extraction rate 24 hours a day and continuously monitors the extract air for flammable vapour. In the event of an increase, the system will ramp up the extraction rate.

Activated carbon is used to remove vapours prior to exhaust to atmosphere from all three main emission points A2, A6 and A7. Particulate filters are renewed monthly and carbon filters are renewed every 2 months.

The annual report to the Environment Agency for the latest monitoring in 2016 confirmed that emission values of particulates and Volatile Organic Compounds were below the permitted limits. Total air emissions of 10.2 tonnes toluene and 6.3 tonnes xylene were reported for 2016.


6.3 Hazardous Materials Bulk raw materials include common solvents such as toluene, methyl ethyl ketone and solvent naptha. These flammable materials are stored externally in the tank farm in bulk storage tanks, and are protected by a deluge firewater system which is regularly tested. The tanks have secondary containment in the form of a concrete bund.

Site personnel identified other significant hazardous materials as hexachlorocyclopentadiene (HCCP) and epichlorohydrin (1-chloro-2,3-epoxypropane). The latter two are used in smaller quantities and carefully controlled to minimise risks during material handling. HCCP is classified as fatal if inhaled, is toxic in contact with skin, causes severe skin burns and eye damage, is very toxic to aquatic life, is very toxic to aquatic life with long lasting effects and is harmful if swallowed. Epichlorohydrin is toxic if swallowed, is toxic in contact with skin, causes severe skin burns and eye damage, is toxic if inhaled, may cause cancer, is a flammable liquid and vapour and may cause an allergic skin reaction. Materials are pumped out from drums in a dedicated partitioned area under the control of operators in breathing apparatus and full protective gear and piped to and measured automatically into the reactors.

6.3.1 Underground and Above Ground Storage Tanks

Site representatives confirmed there are no present or historic underground storage tanks (USTs) on site. There are a number of above ground storage tanks on site as detailed in the table:


Item no Tank name Size

(litres) Use Tank construction

Date manufactured

Secondary containment

1 S55 ethyl benzene T103

32,000 Solvent naphtha Stainless steel 2012 Concrete

bund

2 Methyl Ethyl Ketone 911 15,000 MEK Carbon steel,

painted Not known

Concrete bund 3 Xylene T101 20,000 Xylene Carbon steel Not known

4 Toluene 913 30,000 Toluene Stainless steel 1980

5 Polymer tank T104 18,000 P6 intermediate

polymer

Stainless steel with carbon steel supports

1976

Concrete bund


polymer Stainless steel 2011


polymer

Stainless steel with carbon steel support skirt

Not known


polymer Stainless steel 2011

9 Toluene di-isocyanate 20,000 Out of use Stainless

steel Not known Brick bund

10 Diesel 1,000 Generator fuel Polyurethane Not known Steel bund

A written scheme of examination and risk assessment of items 1 to 8 above and related pipework was carried out by British Engineering Services in October 2014. Non destructive testing was carried out on the base of the MEK tank and confirmed that the condition was satisfactory.

Toluene di-isocyanate (TDI) was used for the former Tyrfil manufacturing process. Site personnel confirmed that item 9 in the table, the TDI tank located in a separate brick bund immediately adjacent to the polymer tank bund in the external tank farm area is no longer in use, although there are no records of decontamination. It is likely to have been out of use since 2008. The bund appears to be in reasonable condition. However the tank would need cleaning and inspecting before being brought back into use.

Site personnel report that the bunds fill with rainwater. The bunds are inspected daily and periodically emptied in accordance with written procedures which include visual inspection and


laboratory analysis prior to discharge. Site personnel also report that the annual firewater testing, which includes undertank sprays, has not revealed any leakage from the bunds.

To the west of the site are two large (unbunded) 765m3 firewater tanks constructed in 2011.

6.3.2 Storage of Hazardous Materials and Chemicals

The quantities of the significant hazardous materials and chemicals used at the location are detailed in the following table:

Chemical / material Container type / storage location

Max amount on site at any time (approx)

Quantity used per year (t)

Toluene Bulk storage, external tank farm

Full tank

313

Xylene Bulk storage, external tank farm 364

MEK Bulk storage, external tank farm 340

Solvent Naptha Bulk storage, external tank farm 125

HCCP 205 l double lined drums on racking in the raw material warehouse (summer) or in heated store room (winter)

5-10 t

61

Epichlorohydrin 205 l double lined drums in raw material warehouse 10

Bulk materials are delivered by tanker. Security gates off Newfield Road lead to a purpose built canopied and bunded area, with marked valves and pipework to transfer material to the appropriate tank. Operating instructions require the measurement and recording of tank levels by the warehouse manager both before and after delivery, to reduce the risk of overfilling and to verify the delivery amount.

6.4 Waste Management All wastes generated on site that require offsite disposal are sent using licensed waste contractors. Contractors used include Biffa Waste, Collins Containers, Mulberry Waste and Red Industries.

The site reports annual quantities of waste through the Pollution Inventory (PI) reporting system.

6.4.1 Non- Hazardous waste

From site observation and the 2016 PI report, the site produces the following non-hazardous wastes:


Waste Generating process Amount generated / annum / Storage type

Paper and cardboard Office and factory 5.0t - 2 x 1100 l wheeled bins

Plastics Polythene wrapping Below reporting threshold - 1100 l wheeled bin

General waste Office and factory Below reporting threshold - 1 x 4,600 l and 1 x 1100 l wheeled bin

A total of 31.6 tonnes of non-hazardous waste was reported in the PI form for 2016, of which 8.6 tonnes were transferred for recovery. Non-hazardous waste is stored in wheeled collection bins in a fenced area adjacent to the firewater tanks. There are two general waste bins, two paper & card bins and one plastic waste bin.

6.4.2 Hazardous waste

From 1st April 2016 sites no longer have to register with the Environment Agency as hazardous waste producers. The site has procedures for managing hazardous waste and the warehouse manager maintains a suitable file of consignment notes. Following a routine review of its impacts and aspects register it has recently improved these procedures to include storage of Part E of the consignment note as evidence of receipt by the disposal or transfer point.

The following hazardous wastes are reported in the 2016 PI form;


Disposal company

Frequency of disposal

Solvent and adhesive waste

Solvent based production

75.54t – 205 l drums or IBC Various As required on

demand

Solvent sludges Solvent based production

44.4t – 205 l drums Various As required on

demand

Aqueous sludges Water based production

2.67t – 205 l drums Various As required on

demand

Other solvent Solvent based production 5.0t – 205 l drums Various As required on

demand

Packaging drums with solvent residue

Empty raw material containers

25.7t – empty 205 l drums Various As required on

demand

Other packaging material with solvent residue

Solvent based production 9.16t Various As required on

demand



Disposal company

Frequency of disposal

Solvent wipes Solvent based production 4.5t Various As required on

demand

Discarded organic chemicals All production 1.64t Various As required on

demand

Hazardous waste is stored in 205 litre drums or in 1m3 IBCs. Some hazardous waste is stored in the Finished Goods warehouse, which is designated as a flammable storage area. Some waste is stored in drum or IBC under the canopy area adjacent to the tanker delivery area. Used empty drums are stored adjacent to the canopied area prior to collection and recovery.

A total of 177.21 tonnes of hazardous waste was reported in the 2016 PI form, of which 162.81 t were sent for recovery, for example as solvent derived fuel.

6.5 Surface Water and Waste Water Management The permit states there are no releases to surface water. The only release to sewer is from uncontaminated surface and roof water, uncontaminated bund water, spent cooling tower water, fire system and laboratory water. The site has a trade effluent discharge consent from United Utilities reference 716T5-43 from 12 July 2002. This was updated on 31 October 2016 to reflect the change of name from Chemical Innovations Limited to Kommerling UK Ltd.

The permit has the following conditions:

Maximum volume 20m3/day or 3 litres per second

Cyanides 1mg/l

Separable grease and oil 100mg/l

Sulphates 1,000 mg/l

Sulphides 1mg/l

Toxic metals 10 mg/l

Maximum temperature 43.3C

pH 6-10

Sampling takes place at the discharge of rainwater from the polymer tank bund. Prior to discharge, a visual inspection is made to ensure that no material is floating on the surface. The site laboratory reportedly checks the quality as part of site procedures, and United Utilities take periodic samples.


Results of testing by United Utilities on 8 March 2017 were as follows:

Suspended solids 51 mg/l

pH 7

COD(settled) 30 mg/l

These results do not reflect the consent conditions, so compliance cannot be confirmed, however these values have not instigated any further response from United Utilities to date.

A drainage survey was carried out in 2005 and the site has recently commissioned a new one. Although the formal results were not available at the time of this assessment, it is understood that there are some discontinuities in the underground drains which may cause blockage or leakage if left unrepaired; these will be rectified by minor remedial repairs according to site personnel. Maintenance of underground drainage is understood to be the responsibility of the tenant.

Rainwater from the roof is collected via rainwater goods into a dedicated underground surface water drainage system on site. According to the 2005 drainage survey, this leaves the site at the north west corner of the site and runs in a westerly direction along Walton Summit Road, but site personnel were unable to confirm if it joins the sewer or goes to surface water.

6.6 Fire and Emergency Response There was a fire at the site in 2010 originating in a stirrer motor in the south east corner of the Cilbond 1 production area. Site personnel reported there was no escape of liquids and no explosion, although there was significant damage to cabling and the roofing which shut the production line for 6-7 months. The incident was reported under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) and an investigation by the Health & Safety Executive (HSE) took place but no regulatory action was taken. As part of the insurance agreement a sprinkler system was installed at the site. This extensive system has three separate zones covering the roof void and offices, the warehouse racking, the external tank farm and the production facilities. It is maintained under contract and tested annually.

The site has a number of written emergency procedures covering external and internal spillages, toxic chemical spillage; fire & explosion.

The operator’s parent company is taking a proactive role in environmental protection. Following a corporate audit in 2016, improvements to firewater protection measures were identified as part of the site’s 2017 targets and objectives. A capital expenditure request (ID 5121) has been made for improvements to the building bunding arrangements to retain firewater run-off in the event of sprinkler system discharge.


6.7 Deleterious Materials

6.7.1 Ozone Depleting and Fluorinated Gases

The Operations Manager confirmed that the (ozone depleting hydrochlorofluorocarbon) refrigerant R-22 is no longer used on the site.

The current site inventory includes three chillers to the rear of the building manufactured in 2011 and containing 6kg, 6 kg and 15.8 kg of refrigerant R410A; four chillers in the tank farm area manufactured in 2007 and containing 13.1kg, 10kg, 10 kg and 14.5kg of refrigerant R407C, and a small unit in the server room containing 1.6 kg of R410A.

During the site tour the Operations Manager identified a newly commissioned chiller in the tank farm, this contains 12 kg of R410A and needs to be added to the inventory.

R407C and R410A are common hydrofluorocarbon refrigerants used in place of R-22.

The refrigeration systems are maintained under contract and serviced annually by Eis Kalt who are qualified fluorinated gas maintenance contractors (certificate REF1009752 observed during the site visit) as required by the Fluorinated Gas Regulations.

6.7.2 Weeds, Herbicides and Pesticides

There is no record of invasive weeds such as Japanese Knotweed on the site and none were observed during the site visit.

The site uses a grounds maintenance contractor to mow lawns and apply occasional weedkiller to the area surrounding the tank farm. No related materials are stored on site.

6.7.3 Asbestos Containing Building Materials

An asbestos survey report was produced by Trojan Asbestos Services in 2004. This identifies asbestos is present in certain roller fire doors, asbestos cement roofing and some rainwater goods. This is not unusual for a building of this age and type. Subsequently site personnel have also presumed the presence of asbestos in two firesafes in the building. Site personnel estimate that approximately 35% of the roof is asbestos cement sheeting.

The policy is to leave it in place, to monitor periodically and to remove deteriorated material using licensed contractors. The last formal review of the asbestos management plan took place in November 2011. This confirmed that the asbestos cement rainwater goods were replaced with plastic items in June 2007, although no record of the disposal of this asbestos containing material was available during the site visit. There are visual inspections but these are not documented. Permits to work are issued prior to work on affected areas. Site personnel reported that a periodic review of the asbestos management plan is due and is being organised with a qualified external organisation.

6.7.4 Polychlorinated Biphenyl (PCB) Electrical Equipment

Two transformers were observed on site within the tank farm area. According to the name plates, each one was manufactured in 1998 and rated at 1000 kVA. Signage suggests that the input voltage is 11kV and the output is 433V. The front transformer is labelled Seddon Atkinson and Hunter Print which are believed to be historic third party local businesses (the Walton Summit Truck Centre has an old Seddon Atkinson sign on the side of the building). The rear one is


labelled “Private” and according to the name plate contains 587 litres of oil. Site personnel confirmed the site has a maintenance contract with Electricity North West Limited for both transformers, and that one is owned by Kommerling and one by ENWL. The Operations Manager was informed by ENWL that they routinely test for PCBs at the start of each contract. Together with the date of manufacture it is unlikely there is any significant level of PCB in the transformer oil.

No other potential sources of PCB were observed during the visit.

6.7.5 Radioactive Materials

Site personnel confirmed that to their knowledge no radioactive materials have been used or stored on site.

6.8 Nuisance Issues The Operations Manager confirmed there had been two noise incidents in the five years he has worked at the site.

The first in quarter 3 2012 was a visit from the local authority seeking a source of noise related to a complainant(s) at a housing estate approximately 0.5 km from the site. The site participated in a test to temporarily shut down the ventilation system at certain times while residents logged their perception of the noise with the local council. There was no correlation between the ventilation plant operation and the residents’ noise logs indicating that it was not the reason for the noise complaint. This was effectively closed out in an email communication from the Environment Agency inspector on 13 March 2013 and no further action was required by the site.

The second in May 2014 was a complaint by a local resident who had noticed a high pitched noise when passing the site. This was traced to a faulty intruder alarm on the north east corner of the main building. The alarm was decommissioned and the resident was satisfied that it was the source of the noise he had heard. This was closed out in a Compliance Assessment Report dated 27 June 2014 with a comment from the inspector regarding the proactive approach adopted by the site.

There was an odour of solvents at the boundary fence of the tank farm noted during the site visit but site personnel confirmed there have been no complaints with regard to odour from neighbours.


7 ENVIRONMENTAL MANAGEMENT OVERVIEW

7.1 Management Systems The Environment Agency permit states that appropriate management systems are in place for operation and maintenance of the Installation. The site has a documented environmental management system certified to ISO14001:2004 since 2006. The certification body BSI carries out regular external audits and is working with the site in the transition to ISO 14001:2015. The site employs a management systems coordinator who is responsible for environmental and quality management systems.

The most recent external audit report from BSI was issued on 15 May 2017 and was reviewed during the site visit. This confirmed that all five previous non-conformances had been closed out. It identified two additional minor non-conformances; one relating to late submission of producer responsibility (packaging waste) data, and one for incomplete determination of monitoring and measurement of utilities (electricity, gas and water).

Site personnel anticipate completing the transition to ISO 14001:2014 by the end of 2017, well ahead of the deadline of 31 December 2018.


8 CONCLUSIONS The Kommerling UK Preston site handles significant volumes of hazardous chemicals and is closely regulated under the Environmental Permitting regulations. The main environmental impact is the release of volatile organic compounds to air. Air emissions are treated by carbon adsorption and routinely monitored and reported as a requirement of the permit. The latest results show that levels are within the permitted limits. Although formerly a COMAH registered site, this no longer applies as the process using a regulated chemical (toluene di-isocyanate) has been discontinued.

The site was developed at a greenfield location for a predecessor of the present operator in the late 1970s. The site is located over a major water bearing aquifer. Although no intrusive soil or groundwater investigations have been carried out at the site during its operation BGS borehole records suggest a significant thickness of boulder clay beneath the site. At the time of issuing the Environmental Permit in 2006 the Environment Agency accepted that no baseline ground investigation was required, subject to certain engineering controls such as high level probes and alarms in tanks. Although some of these controls were not in place in the solvent tank farm at the time of this assessment, capital expenditure to install suitable controls has been approved by site management for implementation in the 2017 financial year.

Site staff stated there has been occasional spillage of material at the site, but they are aware of only one incident in the last five years. There are specific written procedures to deal with spillage, spill kits are located around the factory and there is no record of any contamination to ground. All bulk materials are stored in bunded tanks. The most significant spill occurred prior to 2006 and was caused by overfilling of a process oil tank leading to spillage to concrete hardstanding and to surface water drains. The Environment Agency was informed and engineering and procedural changes were made but no regulatory action was taken against the operator. The process tank was removed in 2011. There was no visual evidence of contamination and no clean up was deemed necessary.

A fire at the site in 2010 disrupted production but was localised and did not lead to the release of contaminated liquids. An investigation was carried out by the Health & Safety Executive but no regulatory action was taken.

It is possible that intrusive investigation will be required at some point in the future, either by the Local Authority in line with its Contaminated Land Inspection Strategy, or by the Environment Agency as part of the Industrial Emissions Directive requirements. However there is no evidence of any contamination to ground. Based on this Phase 1 assessment, in RSK’s opinion no action is needed by the tenant or landlord to comply with current legislation on soil and groundwater contamination and the site remains suitable for its ongoing industrial use.

Approximately 35% of the roof covering is asbestos cement sheet and there are some fire doors containing asbestos; this is not unusual for a site of this age and nature. The condition is reportedly satisfactory and the asbestos appears to be managed satisfactorily, although the last documented review of the management plan was in 2011 and the operator is arranging for an update. There is no written system of examination, although visual inspections are carried out, and permits to work issued for affected areas.


The site is certified by BSI to BS14001:2004 and is working on the transition to the new ISO14001:2015 standard. Site observations, discussions and available records all indicate that the site is competently managed from an environmental point of view.


APPENDIX A – FIGURES

Figure 1 General site location

Figure 2 Site location


Figure 3 Site layout

Bunded solvent tanks

Bunded diesel tank

Bunded polymer tanks

Site of former Tyrfil tanks

Bunded TDI tank (not in use)

Mixing vessels and reactors

Firewater tanks Bunded tanker unloading bay


APPENDIX B – PHOTOGRAPHS


Client Name:

Vita (Group) Unlimited

Site Location:

217 Walton Summit, Preston PR5 8AQ

Project No.

422231/12

Photo No. 1

Date: 12.06.17

Direction Photo Taken:

Description: Satellite imagery of site

Client Name:


Site Location:


Project No.

422231/12

Photo No. 2

Date: 12.06.17


Looking South east

Description: Main building taken from car park at front


Client Name:


Site Location:


Project No.

422231/12

Photo No. 3

Date: 12.06.17


Looking North

Description: Bunded tanker delivery area, hazardous waste storage to the right

Client Name:


Site Location:


Project No.

422231/12

Photo No. 4

Date: 12.06.17


Looking North East

Description: Solvent tanks and bund, hazardous waste storage area


Client Name:


Site Location:


Project No.

422231/12

Photo No. 5

Date: 12.06.17


Looking South east

Description: Drain grating in tank farm area

Client Name:


Site Location:


Project No.

422231/12

Photo No. 6

Date: 12.06.17


Looking North

Description: Polymer tank bund (light streaks believed to be efflorescence)


Client Name:


Site Location:


Project No.

422231/12

Photo No. 7

Date: 12.06.17


Looking North

Description: Standby generator diesel storage tank

Client Name:


Site Location:


Project No.

422231/12

Photo No. 8

Date: 12.06.17


Looking North west

Description: Transformers (ENWL in front, site transformer to rear)


Client Name:


Site Location:


Project No.

422231/12

Photo No. 9

Date: 12.06.17


Looking South east from Newfield Road

Description: Air emission points 1 and 2

Client Name:


Site Location:


Project No.

422231/12

Photo No. 10

Date: 12.06.17


Looking South East

Description: Emission point A7, also site of former Tyrfil tanks off Newfield Road


Client Name:


Site Location:


Project No.

422231/12

Photo No. 11

Date: 12.06.17


Looking West

Description: Site of former Tyrfil tanks off Newfield Road

Client Name:


Site Location:


Project No.

422231/12

Photo No. 12

Date: 12.06.17


Looking North

Description: Fire water storage tank with aerosol store in front.


Client Name:


Site Location:


Project No.

422231/12

Photo No. 13

Date: 12.06.17


Looking North west

Description: Walton Summit truck park adjacent. Site boundary to right with empty drum store in front of fire water tank. Surface drain bladder location to left of tank

Client Name:


Site Location:


Project No.

422231/12

Photo No. 14

Date: 12.06.17


Looking North

Description: Non hazardous waste storage area


Client Name:


Site Location:


Project No.

422231/12

Photo No. 15

Date: 12.06.17


Looking South east

Description: Carillion property opposite on Newfield Road

Client Name:


Site Location:


Project No.

422231/12

Photo No. 16

Date: 12.06.17


Looking West

Description: Rear of site looking along Newfield Road


Client Name:


Site Location:


Project No.

422231/12

Photo No. 17

Date: 12.06.17


Looking South east

Description: Cocker Road, site boundary fence to right

Client Name:


Site Location:


Project No.

422231/12

Photo No. 18

Date: 12.06.17


Looking North west

Description: Gap Plant & Tool hire, Dean & Wood refrigeration and Summit Foods properties on Walton Summit road opposite site


Client Name:


Site Location:


Project No.

422231/12

Photo No. 19

Date: 12.06.17


Looking East

Description: ParcelForce warehouse opposite site on Walton Summit Road


APPENDIX C – DOCUMENTATION REVIEWED A list of the documents reviewed follows:

• Envirocheck Report: Datasheet prepared by The Landmark Information Group, ref no. 12755988_1_1 and dated 7th June 2017.

• Use of EA flood risk mapping tool, found at: https://flood-warning-information.service.gov.uk/long-term-flood-risk/risk?address=10033056920

• Notice of Variation and consolidation with introductory note for Chemical Innovations Limited, permit no. EPR/BU54881H /V003 issued by the EA in December 2011.

• Site Protection and Monitoring Programme for PPC/EPR permit ref EPR/BU54881H/V003, 6 January 2012.

• Pollution Inventory Reporting form for permit MP3634RT for the year 2016.

• Kommerling Annual Report for the period 1 Jan 2016 – 31 Dec 2016 for MP3634RT.

• Phase 1 report of Chemical Innovations Limited by Environ for Royal Adhesives and Solvents, 2015 (excerpts from summary and Appendix D only).

• Phase 1 environmental assessment, CIL compounding, Preston, RSKENSR, 8 February 2006.

• Phase 1 Environmental Site Assessment with a Limited Compliance Review of Synair Corporation, Bamber Bridge, Preston, ERM, November 23, 2004.

• Sample analysis report from United Utilities of a sample of trade effluent from Kommerling dated 08/03/2017.


https://flood-warning-information.service.gov.uk/long-term-flood-risk/risk?address=10033056920

https://flood-warning-information.service.gov.uk/long-term-flood-risk/risk?address=10033056920

British Vita Property UK (2) Limited Phase 1 Environmental ...€¦ · British Vita Property UK (2)...

Documents

Transcript of British Vita Property UK (2) Limited Phase 1 Environmental ...€¦ · British Vita Property UK (2)...