MEMORANDUM. Members of the Board Technical Committee. DATE: 20/02/03 Objection to Proposed Determination for Galco Steel Limited, IPC Reg. No.

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1 MEMORANDUM TO: FROM: Members of the Board Technical Committee DATE: 20/02/03 RE: Objection to Proposed Determination for Galco Steel Limited, IPC Reg. No. 632 Application Details Class of activity: Location of activity: 3.4. The processing of non-ferrous metals by thermal means in installations with a batch capacity exceeding 0.5 tonnes. Ballymount Road, Walkinstown, Dublin 12. Licence application received: 15/02/02 PD issued: 10/10/02 First party objection received: 5/11/02 Sanitary Authority Response 9/12/02 Company The application relates to an existing galvanising plant with a plan to expand the galvanising operation to include a new galvanising plant. Galco Steel Limited were first licenced in 17/12/97, Reg. No There are two main activities in operation at Galco Steel; Hot dip Galvanising and fabrication. The licence is being reviewed to cover the operation of a new galvanising plant onsite. This will generate two new main emissions to atmosphere and generate additional wastewater for treatment. The existing galvanising bath has a maximum steel throughput of 12 tonnes per hour. The new bath has a maximum steel throughput of 5 tonnes per hour. No submissions were received in relation to the application. Consideration of the Objection The Technical Committee, comprising of Ann Marie Donlon (Chair) and Jonathan Derham, has considered all of the issues raised in the Objections and this report details the Committee s comments and recommendations following the examination of the objections together with discussions with the inspector, Annette Prendergast, who also provided comments on the points raised. L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0632\632TCRept.doc Page 1 of 6

2 South Dublin County Council was consulted in relation to an objection concerning aspects of their consent to discharge to sewer under Section 97 of the Environmental Protection Agency Act, The objection relates to the charge for the disposal of trade effluent. There were no third party objections. The applicant makes 6 points of objection. First Party Objection 1. Condition 5.6 The applicant objects to being required to carry out a dioxin emission survey of the bag filters in plant 1 &2, since such a survey has not been required of other licensees in this sector. Comment: The Inspector was asked to comment on the objection and give the background for Condition 5.6. The Inspector reported that this is the first galvanising application since the publication of the BreF note on BAT in the Ferrous Metals Processing Industry and the Proposed Determination was drafted in accordance with it. The inspector reported that the requirement to conduct dioxin monitoring on the air emissions was included as a one off assessment in the PD because dioxin emissions have never been monitored at the facility and due to the potential for grease to remain behind after degreasing. The issue had been highlighted recently in the BreF note (Part C Chapter 3) which states that if, as a result of process upset, the degreasing operation is inefficient, it is possible for oil and grease to enter the Zinc bath and be subject to low temperature combustion. In this case the filter dust may contain up to 10% grease and dioxins may be detected. The BreF document does not specify dioxin monitoring of flue gases, nor does it specify it in the case of filter dust. The possibility of their formation is merely mentioned. The purpose of monitoring for dioxins is twofold; to establish the level of dioxins emitted and check the efficiency of the degreasing operation. A once off dioxin survey of the air emissions corresponds to a short operating time. It is of limited value since such a survey can be engineered to coincide with a replenished degreasing bath i.e. best possible case. The testing of filter dust for dioxins on the other hand means a much longer period of operation would be under examination. Where concerns exist (eg: following a site inspection) in relation to the efficiency and use of the degreasing bath, an enforcement inspector may check lifetime of degreasing solution or the solutions relative activity and promote through the EMP the use of more efficient technologies such as agitation, skimmers etc. The testing of air or filter dust for dioxins to establish degreasing efficiency maybe considered onerous and of limited value as there are no clearly defined thresholds to which the monitoring relates. Importantly, the BreF document notes that dioxins may arise in filter dust but it does not lend it significance by giving typical levels, setting limits and/or requiring monitoring of either air emissions or filter dust. Further reference to L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0632\632TCRept.doc Page 2 of 6

3 dioxins in the BreF Note is made in Part C.5: Best Available Techniques for Batch Galvanising, the following techniques is to be considered BAT: 'Internal or external reuse of collected dust for flux production. As this dust may occasionally contain dioxins at low concentration due to upset conditions in the plant (badly degreased items being galvanized), only recovery processes yielding fluxing agents free of dioxins are BAT'. Where filter dust is sent for recovery of flux, dioxin monitoring shall be a likely prerequisite. According to the inspector the filter dust is currently recycled by GC Evans Ltd in the UK to produce zinc oxide. Dioxin tests are very expensive and to specify such a test so as to determine the efficiency of degreasing operations has not been established as BAT. Accordingly the Technical Committee consider that a requirement to establish dioxin levels is difficult to sustain at this time, and without sufficient basis to be included in the Licence. Recommendation: Delete Condition 5.6. Delete reference to Dioxin emission survey in Schedule 5(i); Once-off Reports. 2. Condition The applicant objects to the monitoring of the surface water by visual examination on a daily basis as the visual inspection of surface water requires 4 man-hours and these inspections have been performed on a weekly basis for the last five years. It is the opinion of the applicant that this timeframe is sufficient to ensure the quality of the discharge to the storm drain. Comment: It was noted and accepted from the inspectors' comment that this is a typing error and the intended frequency was weekly. Schedule 4 (i) requires weekly visual inspection of surface water. For the purpose of reconciling Condition and Schedule 4 (i) it is recommended that the condition should be amended. Recommendation: For the purposes of clarity the condition should be amended to read as follows: A visual examination of the surface water discharge shall be carried out weekly. A log of such inspections shall be maintained. 3. Condition The applicant objects to the carrying out of an investigation into the intermittent source of contamination of BH2 and that a resultant report should contain proposals for the removal of the source and any remediation of the groundwater deemed necessary. The applicants objects to this condition as there is a presumption that there is a 'source' of contamination, the source arises from Galco Steel operation and that remediation is necessary. Galco Steel expects that the investigation requested will ascertain the cause of the results obtained in previous reports. The applicant L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0632\632TCRept.doc Page 3 of 6

4 expects that the condition would reflect this current position and would not impose conditions on the outcome of the investigation. Comment: The inspector was asked to give the background to this condition. The inspector reported that recent monitoring reports submitted on groundwater quality highlight an intermittent source of zinc (maximum mg/l) and manganese (4.78 mg/l) contamination of one of the boreholes onsite. The inspector noted that the borehole upgradient of the site is uncontaminated and the issue requires further investigation. The applicant proposes to investigate the cause of results obtained. Thereby casting doubt on the validity of the results obtained or implying natural occurrences. Manganese can occur at elevated levels under natural conditions. However similar levels were not detected in the upgradient well. Manganese in solution indicates reducing conditions and a possible organic source. Zinc levels are above background levels detected in the upgradient well. The results indicate contamination and therefore a possible source exists. The condition does not infer an outcome on the investigation but it is reasonable to expect that any source of contamination would be removed should it be proven to originate on the licensees' site. Any proposal for the remediation of groundwater is required where deemed necessary, and is not a foregone conclusion. And any requirement for same would have regard to BAT. The Technical Committee does not consider it appropriate that an investigations sole aim is to ascertain the cause of results. Such investigations, inter alia, also provide a context in which to evaluate results. The monitoring results to date, indicate an intermittent source of contamination that clearly arises on the site and warrants a full investigation by a suitably qualified person. The Technical Committee finds the condition to be appropriate to the circumstances. Recommendation: No change 4. Condition The applicant objects to the installation of high liquid alarm levels on all sumps within three months as the timeframe is too stringent. Galco Steel points out that the wastewater treatment plant is currently being upgraded and will not be completed within three months and recommend six months as a more realistic target. In relation to all other sumps the applicant points out that it will take three months to get approval for the purchase of the equipment due to company structure and recommend twelve months as realistic timeframe for completion of installation. Comment: The Technical Committee accepts the applicants' point in relation to the wastewater treatment plant as reasonable and the licensing inspector supported the six-month timeframe. ` The applicant seeks a timeframe of twelve months in relation to all other sumps. The inspector reported that the requirement to fit high liquid level alarms on pump sumps was included in the original licence and should have been implemented within twelve months of the date of grant of that Licence (17/12/97). The applicants' objection raises concerns as to the level of L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0632\632TCRept.doc Page 4 of 6

5 compliance with the requirements of Licence (M284) in relation to the installation of high level alarms. Having considered the foregoing and the time scales involved, the Technical Committee considers a six month time scale as more than sufficient for all sumps on-site. Recommendation: Condition should be amended to read as follows: All pump sumps or other treatment plant chambers from which spillage might occur shall be fitted with high liquid level alarms within six months from the date of grant of this licence. 5. Condition The applicant objects to this condition as the increase to 1.00 per cubic meter (186% increase) is excessive and such an increase unjustified. South Dublin County Council comment: The following are the charges imposed by South Dublin County Council since These charges are set by Managers Order each year: 1997 ( ), 1998 ( ), 1999 ( ), 2000 ( 0.444), 2001 ( ), 2002 ( 1.00). In addition South Dublin County Council attached a copy of the letter sent to Galco Steel Limited in January 2002 notifying them of the charges for that year and the reasons for the increase. Comment: Consideration of this matter is outside the legal remit of the Agency. Recommendation: No change 6. Schedule 3 (iii) Waste Analysis The applicant objects to the frequency of analysis (per consignment) set out in Schedule 3 (iii) as it is considered excessive. The applicant notes that they have undertaken extensive research and development to improve the consistency of both metal sludge's and the spent pickle acid and recommend a frequency of 4 times per year. However the applicant notes that acid content is determined per consignment for the spent pickle acid. Comment: The applicant is objecting to the frequency of metal analysis of the metal sludges (all) and the spent pickle acid. The applicant accepts that the acid content of the spent pickle acid is determined on a consignment basis. The applicant notes that they have undergone extensive research and development to ensure consistency in metal sludges and spent pickle acid but does not provide the evidence in support of the claim. Metal sludges and spent pickle acid are hazardous waste. It is a requirement of national statute that hazardous waste consigned from a site is fully characterised. The Technical Committee regards as appropriate the testing of each consignment of metal sludges and spent pickle acid for heavy metals. Some opportunities exist in statute for the waste producer to agree with the relevant Local Authority, one consignment note for multiple loads. In the case of such L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0632\632TCRept.doc Page 5 of 6

6 agreements (based on consistency of waste, etc.,) waste testing could be relaxed subject to the written approval of the Local Authority. Such variation can be accommodated in the licence under Condition Recommendation: No change Overall Recommendation It is recommended that the Agency grant a licence to the applicant (i) (ii) for the reasons outlined in the proposed determination and subject to the conditions and reasons for same in the Proposed Determination, and (iii) subject to the amendments proposed in this report. Signed Ann Marie Donlon for and on behalf of the Technical Committee L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0632\632TCRept.doc Page 6 of 6