SLR 1 2th August 2016

Transcription

1 SLR 1 2th August 2016 Office of Environmental Sustainability EPA Headquarters PO Box 3000 Johnstown Castle Estate County Wexford Dear Sir/Madam, Our Ref: Your Ref: PI RE: PROPOSED DETERMINATION OF INDUSTRIAL EMISSIONS LICENCE P The Hammond Lane Metal Company Ltd (HLM) wishes to object under Section 87 (5) of the EPA Act of 1992, as amended, to a number of the Conditions and Schedules in the Proposed Decision (PD) for Industrial Emissions Licence Register Number P for its installation at Pigeon House Road, Ringsend, Dublin 4. This letter has been prepared on behalf of our client HLM and contains the grounds for the objections. The appropriate objection fee ( 253) will accompany this objection. I.7 Waste Acceptance Hours and Hours of Operation 1.7. I The licensee may accept and dispatch waste and scrap metal and operate between the hours of 07:OO and 16:30 Monday to Friday, and between 08:OO and 13:OO on Saturdays. HLM s normal operating hours are from 07:OO to 18:00, Monday to Friday and from 07:OO to 13:OO on Saturdays. As the site is located in an area that is zoned for industrial uses, there is no obvious reason for the earlier restrictions on waste acceptance and dispatch. We therefore request that the hours be extended to match the normal operating hours. In addition, Condition does not allow for exceptional circumstances, where waste may either be accepted or dispatched, or the installation operated outside of normal hours. While it is not expected that this will be a regular occurrence, HLM needs the commercial flexibility to accept and dispatch waste and scrap metals outside of the normal operational hours in exceptional circumstances. Given the site location this will not have any adverse impacts on nearby residents. HLM requests that Condition be amended as follows: Unless otherwise agreed in advance with the Agency, the licensee may accept and dispatch waste and scrap metal and operate between the hours of 07:OO and 18:OO Monday to Friday and 08:OO and 13:OO on Saturday. Condition No smoking shall be allowed within the installation. The prohibition of smoking within the site boundary is contrary to HLM s company policy to provide dedicated smoking areas for employees in parts of the site that do not present a risk SLR Consulting Ireland, 7 Dundrum Business Park, Windy Atbour. Dublin 14, 11-eland www sli-consulting com T: F: Diiectors R CYDOnd, N 0 Mill.T Paul (Mamgmg). N Penhal (British). I Robeits(Bntish) Secietary R O Dowd Registered inlrelandas SLR Emirmmntal Consulting(Ireland) Limited Regeered No VAT No

2 Hammond Lane Metal Co. Ltd 2 Ref: Objection to PD re P th August 2016 of fire outbreak. HLM requests that Condition be amended as follows to bring it in line with company workplace policy; Smoking shall only be allowed in designated external areas of the installation. Condition 3.18 Weighbridge and Wheel Cleaners The requirement for wheel cleanes is not appropriate for the nature of activities at this site. Roads at the facility are clean. Vehicles are currently rutilizina the site and thw dn no? brit-!? dirt on to the road. We therefore request removal of Conditions , and Condition 3.23 Dust/ Odour Control The reference to odour is not applicable given the nature of waste activities on site. The site does not give rise to odour. The licensee is requesting that the reference to odour is removed. Condition Noise We suggest that this should refer to noise sensitive locations, rather than the site boundary to be consistent with Schedule B.4. The facility is located in an area of heavy industry and is not sensitive to noise, so limiting the noise levels to 55dB at the site boundary is not warranted. Condition 5.6 The licensee shall ensure that all or any of the following: Vermin Birds Flies Mud Dust Litter associated with the activity do not result in an impairment of, or an interference with, amenities or the environment etc. The licensee is seeking to remove the reference to birds, mud and flies as these are not appropriate for the nature of the activity on site. Condition The storm water drainage system (i.e., gullies, manholes, any visible drainage conduits and such other aspects as may be agreed) shall be visually inspected weekly, and desludged as necessary. Bunds, silt traps and oil separators shall be inspected weekly and desludged as necessary. All sludge and drainage from these operations shall be collected for safe disposal. The drainage system, bunds, silt traps and oil interceptors shall be properly maintained at all times. The licensee shall maintain a drainage map on site. The drainage map shall be reviewed annually and updated as necessary. The licensee is seeking the reference to manholes to be removed from this condition as it is impractical to lift all site manholes on a weekly basis. The rest of the condition covers the important points. S LR C:\Users\cwalsh\DesMop\Transfer Docurnents\160812~ Objectionto Harnrnond LanePD P CW-RevO.docx

3 Hammond Lane Metal Co. Ltd 3 Ref: Objection to PD re P th August 2016 Condition A visual examination of the storm water discharges shall be carried out daily. A log of such inspections shall be maintained. The licensee is requesting thatthis condition be amended to weekly inspections given that historically there have been no issues on site. It is more practical for the discharge point to be inspected in tandem with the weekly inspection of the drainage system, as required under Condition Condition Run-off fromprocess areas of the installation usedfor the holding, storage and treatment of waste and scrap metal shall be diverted for collection and safe disposal. This condition shall apply from twelve months from the date of grant of this licence. Condition Run-off fromprocess areas of the installation used for the holding, storage and treatment of waste and scrap metal shall not be discharged to the storm water drainage system. This condition shall apply from twelve months from the date of grant of this licence. Condition The licensee shall ensure that: storm waters that have the potential to become contaminated through contact with waste and scrap metal, are physically segregated from and managed separately to, storm waters that do not have the potential to become contaminated through contact with waste and scrap metal. This condition shall apply from twelve months from the date of grant of this licence. The licensee objects to these three conditions. HLM has submitted many years of surface water discharge results and these were assessed by SLR in the licence application. In summary, SLR determined : The surface water discharge results recorded occasional zinc exceedances and very occasional iron exceedances. There were two sulphate exceedances, expected to be as a result of saline intrusion. Copperand aluminium are not elevated. TSS, COD and BOD were also elevated for some rounds. There were no exceedances of the daily loading limits. In the circumstances, we suggest that further monitoring and comparison with trigger levels would be the appropriate course of action, followed by action only if trigger levels are exceeded on a set number of occasions. The requirement for containment, collection and safe disposal of run-off should only apply where it is demonstrated that the facility cannot operate within the appropriate trigger levels agreed with the Agency. Hydrogeological Assessment and Site Investigation of Hammond Lane Metal Company, 4 Pigeon House Road, Ringsend, Dublin 4. Prepared by SLR Consulting. March SLR C:\Users\cwalsh\DesMop\Transfer Documents\160812~ Objection to Hamrnond Lane PD PI CW_RevO.docx

4 Hammond Lane Metal Co. Ltd 4 Ref: Objection to PD re PI th August 2016 Condition 6.16 Noise The licensee is seeking that the reference to vibration be removed as this is more appropriate to mines and quarries or other facilities where explosives are used. Condition The licensee shall ensure that all vehicles delivering waste to and removing waste and materials from the instahtion are q?nrqnrinte/y covered The licensee cannot comply with this condition given that the site operates in many respects like a civic amenity site. Appropriately permitted collectors, along with farmers, householders, etc. can deliver material to the site. HLM will not be in a position to make these customers cover their loads. In any event, they may not have anything to cover the load with. It should also be noted that metal loads do not pose a litter treat. Therefore, while loads should obviously be secured, there is no environmental reason to cover them. Condition 6.18 Dust I Odour Control Odour is not an issue at metal recycling facilities, so the word odour should be removed from the title and Condition should be removed. This condition is more appropriate for facilities handling residual municipal waste or biowaste. Condition 6.20 Vermin and Flies Flies are not an issue at metal recycling facilities, so the word flies should be removed from the title and the reference to fly infestation shou1d also be removed. This condition is more appropriate for facilities handling residual municipal waste or biowaste. Vermin are not attracted to metal, but may be present due to factors other than the materials processed on site, so the licensee incorporates vermin control measures in the site operation. Condition 6.23 Soil Monitoring This condition should be removed. This condition is inappropriate for the site. The site surface is concreted and any investigation re soil sampling will be intrusive and lead to possible pathways for contamination. The groundwater sampling will identify any impacts on the soil if there are any. Condition 8.7 No waste classified as green list waste in accordance with the EU Shipment of Waste Regulations (Council Regulation EEC No. 1013/2006 as may be amended) shall be consigned for recovery without the agreement of the Agency. All the ferrous and non-ferrous metal wastes consignedfrom the installation are classified as green list waste. This condition could be interpreted to mean that HLM must obtain the Agency s prior approval before each and every consignment of ferrous and non -ferrous metal wastes are consigned. HLM considers this is unnecessary andwould lead to delays in shipments pending receipt of the Agency s approval. HLM requests the Agency to clarify the intention of the condition. HLM is open to obtaining Agency approval for the LOW Codes for the green list wastes that can be part of all consignments from the installation. SLR C:\Users\cwalsh\DesMop\Transfer Documents\160812~ ,,0bjectionto HammondLanePD P CW-RevO.docx

5 Condition Scavenging This condition appears inappropriate. The metal on site is valuable and kept securely to prevent theft, so the issue of scavenging does not arise. Condition Waste shall be accepted at the installation only from known waste producers or new waste producers subject to initial waste profiling and basic characterisation off-site. The written records of this off-site waste profiling and basic characterisation shall be retained by the licensee for all active waste producers and for a two year period following termination of licensee/waste producer agreements. As already noted above, HLM accepts metal wastes and End of Life Vehicles (ELVs) from members of the general public who arrive at the installation without any prior notification or contact with HLM. In effect, HLM like all waste metal recycling operators, act as a form of civic amenity areal bring centre, accepting ELVs and small quantities of waste metal from the general public. If HLM cannot continue to provide this service it will be at an extreme commercial disadvantage and Dublin City would lose an important civic amenity. The waste acceptance procedures applied at the installation are rigorous and thorough and include for the acceptance of waste from non-contractual commercial and domestic customers where waste is paid for at the time of delivery. HLM requests that Condition be amended to allowthe acceptance of waste from members of the general public to continue. The proposed amended condition is as follows: "Waste shall be accepted at the installation only from known commercial waste producers, new commercial waste producers subjectto initial waste profiling and basic characterisation off-site and from the general public subject to presentation of proof of name and address and signing of declaration thatthey are the lawful owner of the waste, or have the consent of the lawful owner to sell the waste. Written records of off-site waste profiling and basic characterisation or confirmation of provision of general public proof of name and address and signed customer declaration shall be retained by the licensee for all waste deliveries for a two year period." Condition Any waste deemed unsuitable for processing at the installation and/or in contravention of this licence shall be immediately separated and removed from the installation at the earliest possible time. Temporary storage of such wastes shall be in a designated Waste Quarantine Area. Waste shall he stored under appropriate conditions in the quarantine area to avoid putrefaction, odour generation, the attraction of vermin and any other nuisance or objectionable condition, The licensee is requesting thatthe condition is amended to remove the last line as it refers to impacts from waste types that are not accepted at the site. Condition The licensee shall issue a certificate of destruction in respect of each end-of-life vehicle deposited at the installation for appropriate treatment and recovery. This condition should be amended to refer only to ELVs where a certificate of destruction (COD) has not already issued. Generally, all ELV's accepted by HLM will have had a COD issued by the authorised treatment facility from where the ELV originated. SLR C:\Users\cwalsh\Desktop\Transfer Documents\160812~ ~0bjectionto HammondLanePD P1002- OI-CW_RevO docx

6 Hammond Lane Metal Co. Ltd 6 Ref: Objection to PD re P th August 2016 Condition The licensee shall, within three months of date of grant of this licence, establish, maintain and implement a Waste, Scrap Metal and Materials Storage Plan for all waste stored and held at the installation. The licensee is seeking for the timeframe in this condition to be extended to 9 or 12 months as Condition 9.5 must be addressed before this condition can be fully complied with and that has P 5 month?irne-fr?me Condition Limitations, as may be necessary, on waste and scrap metal storage arrangements to be used to prevent odours arising; The licensee is asking that the above referenced section of Condition be removed as it refers to odour. The nature of the material managed at the site does create a risk of an odour nuisance. Condition 12.1 Agency Charges The proposed annual contribution is 18,543, which we understand is based on the predicted enforcement effort. HLM considers this contribution does not reflect the low risk activity of waste metal shredding and recycling. HLM notes the contribution is significantly in excess of that set by the Agency in other similar licenses, such as WO and it is a multiple of the cost of the existing waste facility permit. HLM requests the Agency to review the predicted level of enforcement that will be required in the context of the site specific conditions, the environmental setting and the annual contributions specified in other recent proposed determinations. Schedule C.l.I. Monitoring of Emissions to Air The air monitoring requirements under Schedule C.l.I are considered to be overly onerous and inappropriate. The level of monitoring requirement should be proportional to the risk of emission / impact from the site. In this instance, as there are no emission limit values (ELVs) for emissions to air from the facility, so the requirement to monitor quarterly seems to be merely data-gathering and is not based on a recognised problem at the site. Furthermore, the location of the monitoring is vague and is not designed to measure emissions to the atmosphere from the site as the monitoring location will be in the middle of the site rather than at site boundaries. If the rationale for this condition is a health issue, it should be regulated by the HSA rather than the EPA. Otherwise, the monitoring should be less frequent and at the site boundary rather than on or near the shredder. Annual monitoring at two site boundary locations, to be agreed in advance with the Agency, would be a more appropriate requirement. C Monitoring of Storm Water Discharges HLM considers the weekly and monthly monitoring frequency for Emission Point Reference SW-1 Storm Water Discharge is overly onerous and does not reflect the risk. Data submitted with the licence application included 21 historical results from 2010 to 2015 and these showed that the daily discharge limits were not breached by the discharge from the site on any occasion. SLR C:\Users\cwalsh\DesMop\Transfer Docurnents\160812~501, ~0bjectionto Harnrnond LanePDP CW-RevO.docx

7 Hammond Lane Metal Co. Ltd 7 Ref: Objection to PD re P th August 2016 As an alternative, HLM requests quarterly monitoring for all the parameters specified in the Schedule apart from visual inspection, where we suggest that weekly inspections would suffice, as mentioned earlier in this submission. C.7 - Soil Monitoring As mentioned earlier, soil monitoring is not practical at the site as it would require breaching the concrete surface that protects soil and groundwater beneath the site. We therefore request that this schedule be removed. Any contamination of soil will be visible in the groundwater monitoring results. C.4 - Noise Monitoring Schedule C.4 requires noise monitoring at 8 locations. We suggest that this is overly onerous and could be reduced. There are 5 boundary locations when 3 or 4 should be adequate and there are 3 locations in the direction of the nearest reside nces, but these are in close proximity to each other and there are many other noise sources closer to these locations. We suggest that 5 locations should be adequate. Yours sincerely SLR Consulting Ireland Conor Walsh Technical Director SLR C:\U?ers\cwalsh\Desktop\Transfer Documents\160812~ Objection to Hammond Lane PD P CW-.RevO.d ocx

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9 From: Sent: To: Subject: Attachments: Importance: Licensing Staff 15 August :40 Liz Leacy FW: New Applicant objection entered for Reg no: P (Reference Number: P ) objection to Hammond Lane PD P pdf High Hi Liz, This was received in the licensing inbox. Regards, Christina From: Christina Monaghan [mailto: -1 Sent: 15 August :04 To: Licensing Staff Subject: New Applicant objection entered for Reg no: P (Reference Number: P ) Importance: High Objection submitted on: Title: First Name: SurName: Organisation Name: Address Line 1: Address Line 2: Address Line 3: County: Post Code: 15/08/ :03 Ms Christina Monaghan The Hammond Lane Metal Company Limited Pigeon House Road Ringsend Dublin 4 Dublin 0000 Objector Type: Oral Hearing: Applicant No This has been scanned by the Symantec Security.cloud service. For more information please visit 1

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