Inspectors Report - Environmental Protection Agency

copper oxide and arsenic pentoxide. Protim 210WR is listed as irritating and flammable and isclassified as a List I substance under Directive 76/464/EEC on pollution caused by certainsubstances discharged into the aquatic environment. Tanalith C3310 is listed as toxic andcorrosive and its ingredients have carcinogenic properties - chromium trioxide (R45: may causecancer) and arsenic pentoxide (R49: may cause cancer by inhalation).Emissions to atmosphere:There are no significant emissions to atmosphere from this operation.Process effluent emissions:There are no emissions of process effluent to water or sewer from this operation.Groundwater and Surface Water:This operation does not involve the discharge of any treatment chemicals to lands, watercoursesor aquifers in the vicinity. The treatment units are totally enclosed and bunded and Condition8.4.2 requires that the integrity will be tested. No treatment of timber was undertaken on-siteprior to the installation of these plants. The timber yard is drained by a series of gullies whichfeed into a manhole (SW2). Visual inspection of emissions to SW2 will be carried out daily.This drain joins the main Dublin Corporation sewer under Castleforbes Road.A firewater retention study is required under Condition 8.3.1 as the treatment plants are locatednext to stored timber and the facility is adjacent to the River Liffey.There is a shower unit installed in the shed beside the tanalising plant. The discharge issoaking to ground via a break in the concrete pavement. Condition 8.4.5 requires that thelicensee submit a proposal to the Agency within three months of the date of grant of licence forthe provision of suitable drainage for the shower unit.At present, trucks delivering preservative do not have access to the site and in the case ofdelivery of Protim, the delivery trucks park on Castleforbes Road and the hose is passed intothe site through a hole in the wall. This situation is not acceptable and Condition 8.4.4 requiresthat the licensee submit a proposal to the Agency for the provision of a designated area for theloading and unloading of materials, which shall be protected against spillage and leachate runoff.The timber preservation plants are roofed. This includes the area where the timber is held todrip. Approximately 1 hour after treatment, the timber is moved to an unroofed area.Condition 8.4.3 requires the submission of a proposal to roof all elements of the timberpreservation processes, including the drying areas.NoiseNo noise sensitive locations were identified in the IPC licence application and the site boundarynoise levels ranged from 55 - 69 dB(A) Leq 15 min., day-time. There is no night-time activityat the site. The facility is adjacent to a busy road, leading to Dublin Docks. The character ofthe noise on-site is similar in character to the external road noise, in particular loading trucksand forklifts. The PD stipulates that noise from the activity shall not exceed the new plantBATNEEC levels at any noise sensitive locations.Waste2

Waste consists of packaging wastes (steel bands, plastic wrappings, paper). No hazardouswastes were listed on the IPC licence application as there is no routine hazardous wastegenerated on-site. However, some non-routine hazardous wastes which may arise have beenincluded in Schedule 1(i) Wastes for Disposal/Recovery and require that a hazardous wastedisposal contractor be used.SubmissionsOne submission was received, from the Department of the Marine and Natural Resources, on 3December 1997. This submission requested:1. Total compliance with control technologies and ELV required by BATNEEC.The control technologies relevant to this facility have been included in the PD. As there is noprocess effluent discharge from the site no ELVs have been specified in the PD.2. Prevention of entry of preservative to surface water drains and foul sewers.Prevention of entry of preservative to drainage system will be achieved by the containment ofall process vessels and bunding of storage tanks. All newly treated timber is held on thetracks leading from the treatment vessel for dripping, and this area is bunded. Integrityassessment of all bunds is required in the PD.3. Inclusion of a toxicity monitoring clause for the effluent discharge and full containment ofwastes and raw materials at the time of issue of the licence.Uncontaminated surface water is the only aqueous discharge from the site thus removing therequirement for a toxicity monitoring clause. Full containment of wastes and raw materialsis currently achieved through bunding and roofing of the treatment area.4. Provision to divert any uncontaminated waters from the dripping area.The current process layout precludes exit of preservative contaminated storm water from theprocess area.5. Where the treatment process is operated at a sawmill, and there is the likelihood of largevolumes of sawdust present at the site having the potential to enter waterways, leading tohigh suspended solids or blanketing of the river bed, a suspended solids monitoringregime shall be put in place and a suspended solids limit set down for any surface wateremission prior to discharge to a watercourse.There is no sawmill associated with the site of this activity.RecommendationIt is recommended that the Board of the Agency approve the Proposed Determination assubmitted.Signed_______________________Fiona McCoole3