efficiency (ireland) limited48 main street, bray, co. wicklow, ireland. tel 00 353 i 276 1428 fax 00...

i

,

I

IPC Licensing and 'CO PO Box 3000, Johnstown Castle Estat Co. Wexford.

Date: 08/03/2002 LET3 75 -9 Notice under Section 12

Date: 06/02/2002 ...

T. & J. Standish (Roscrea) Limited. IPC Licence No. 320

To Whom It May Concern,

_. - - .MK

Enclosed please find the following reports: 13/3/02 &,J 1

1.

: 2.

I . I 3.

.63 4.

5.

6.

~ . . . . _ ^

Proposal >for a comprehensive investigation of surface water, stream sediment, ground

and groundwater contamination of the site and environs (Doc. No. 395-3)

Report on the determination of the extent of Chromium contamination in the River

Fuarwan and details on the extent of fencing required (Doc. No. 395-2).

Report on the impact of the Chromium discharges on the Fuanvan River biota; water quality and implications for downstream users (Doc. No. 395-4)

Report on the condition of treatment vessels and associated pumps, tanks, bunds and pipelines used to pressurise, carry, store and retain timber preservatives

Proposal for a revised operational programmes for the pressure treatment vessels to

account in particular for the moisture content of the raw wood and to . define the most appropriate final vacuum time. These programmes to be devised in consultation with

the preservative supplier. -

Proposal works to intercept and treat contaminated surface and groundwater

(Doc.No.395-5)

48 Main Street, Bray, Co. Wicklow, Ireland. Tel 00 353.1 276 1428 Fax 00 353 1 276 1561 Email: [email protected] website, www.enviro-consult.com

Registered Office 54 Dame St., Dublin 2, Ireland. Registered Number 243412

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http://www.enviro-consult.com

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1 Environmental Efficiency Coaisultants (Ireland) Limited Cons U 1 till g E 11 gin eers I’

02. The following were noted:

uring that all freshly treated timber will inimum of 48 hours.

Narrow gullies are cut into the concrete apron around the treatment vessels to divert any contaminated rainwater to an underground sump. Any iiquids diverted to this sump are returned to the preservative storage tanks. On the day of the audit one length of this gully was blocked with dirt.

Corrective Action: Tom Standish has agreed to clear these immediately. These drains will be cleared on a daily basis to ensure no further blockages.

@ Preventative Action:

The sumps under treatment tank 1 and 2 contained a mixture of rainwater and preservative.

Corrective Action: The automatic recycling system is based on a float switch system. Tom Standish confirmed that this has been set to a minimum level and if set lower will draw air into the pumping system. These sumps will be checked on a daily basis to emure that the pumping system is working effectively.

Preventative Action:

With the implementation of the above actions it is concluded that there will be no discharge ,@ of polluting matter to waters (Condition 1 of Section 12 Notice). Regards,

Mags Dalton

Environmental Efficiency Consultants (Ireland) Ltd., 48 Main St., Bray, . Co. Wicklow.

Tel.: 00353 1276 1428 Fax: 00353 1 276 1561 Email: [email protected]

48 Main Street, Bray, Co. Wicklow, Ireland. Tel 00 353 I 276 1428 Fax 00 353 1 276 1561 (I Email: [email protected] website, www.enviro-consult.com

Registered Office 54 Dame St., Dublin 2, Ireland. Registered Number 243412

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1 I 4

b. I

I i' d

I p--, Environmental Efficiency Csnsu8tants (Ireland) Limited I '1 I ), Consulting Engineers

I .. *-

ve Investigation of Surface Water

Stream Sediment of the Site and Environs I (@ And 1

I

I 1

I / ' I I 1

: I DOC. NO. 395-3 I ' ! I

I

' I it T & J Standish (Roscrea) Ltd. IPC Licence 320

11 I February 2002 I

11

/ I . 48 Main Street, Bray, Co. Wicklow. Tel 01 276 1428 Fax 01 276 1561

Email [email protected] Registered Office 54 Dame St., Dublin 2. Registered Number 243412

: I i l

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I

This copy is a controlled copy and the recorded holder of this document will be issued t- 5 t I @with amendments when such amendments are made. .y,,”’----Y-- - ”-

-*-,.w---- I

I

Environmental Efficiency Consultants (Ire.) Ltd. 1

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,

1. Introduction

A Notice under Se amended by the LOC

to T. & J. Standish

Notice states:

ater Pollution) Act, 1977, as

endment) Act, 1990 was issued

2002. Condition Three of this

A comprehensiveinvesti carried out of Surface Water, Stream

i P i

Sediment, ground and groundwater contamination of the Site and Environs.

This investigation shall embrace load out and storage aprons, made ground,

solid and drift geology. The scope, detail and programme, including report

structure and reporting schedule, for this investigation must be agreed in

writing by the Agency prior to implementation. Due regard shall be given to

the findings of any previous reports that may be relevant. Any

recommendations arising from a report or reports on this investigation must

be implemented within such a period to be agreed with the Agency. The

design of the investigation should have regard in particular to the ground in,

around, under and down gradient of the preservation plant and treated

timber storage areas.

'Geotechnical and Environmental Services Ltd' are undertaking the proposal for the

und and groundwater investigation. Mr Jer Keohane accompanied a member of P .Lvironmental Efficiency Consultants (Ire.) Lt!. on the 1'' of March 2001 to agree the scope. This proposal will be submitted separately to this document.

This document proposes the methodology, the nature and the extent of the sampling of

surface water and stream sediment from the Fuarwan River. .

2. Scope of Survey

Environmental Efficiency Consultants (Ire) Ltd. propose to collect all samples outlined

below. All water samples will be analysed at Environmental Efficiency Consultants (Ire)

Ltd. for all parameters except Arsenic. Arsenic will be analysed at an UKAS accredited


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I * , * I 1

Document No. 3W3 I

~ T & J Standish (Roscrea) Ltd, I - - laboratory in the UK, as will the stream sediment samples for all parameters outlined in

Part Two. As river sampling has been undertaken on three previous occasions (July 2001, November 2001 & January 2002) it is proposed that results from these analyses be used as baseline data. S d previously. Therefore, it is

proposed that seven s t a date proposed by the

Environmental Protectio

. It is proposed that on

undertaken on a month1

2.1 Part One

onitoring listed below be

I 3;- 14yr .

@rstly, seven samples will be taken from the each of the following locations and analysed

for the following parameters:

The downstream sample location are described as follows:

@ 1. 10 metres DS Erom main drain leaving T. & J. Standish (Roscrea) Ltd. site 2. 100 metres DS fi-om main drain leaving T. & J. Standish (Roscrea) Ltd. site

3. 250 metres DS from main drain leaving T. & J. Standish (Roscrea) Ltd. site

4. 400 metres DS from main drain leaving T. & J. Standish (Roscrea) Ltd. site 5. 600 metres DS from main drain leaving T. & J. Standish (Roscrea) Ltd:site 6. 1000 metres DS from main drain leaving T. & J. Standish (Roscrea) Ltd. site

The determination of these locations is based on previous monitoring undertaken along the River F u m m (I>oouments No. 37512,3796 & 3751’1 1 - dl submitted to the Environmental Protection Agency).

Environmental Efficiencv Consultants (Ire.) Ltd. 3

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IC‘

i

2.2 Part Two I - c t $1

Seven stream sediment sampl&klt&&ken -”+

locations and analysed

I I

Downstream Fuarwan River (6) Cr ‘+ Subcontract

Subcontract

pg/l c u 2+

pg/I cf 6+

Environmental Efficiency has a Good Laboratory Practice (GLP) manual. This is based

on established best practice in the industry. This GLP manual defines the quality system

so that all analysis of samples is traceable to calibration standards, the collection and

analysis method, and the technicians involved. This gives us the confidence to stand by

our results and answer any query the EPA may have.

All methods used will be based on EPA specified methods or ‘Standard Methods for the

Examination of Water and Waste Waster, 20th Edition’ American Public Health

Association or acceptable alternatives based on best practice.

@mples are stored refrigerated at Environmental Efficiency Consultants (Ire) Ltd. for 1.

three months.

3. Reporting

Certificates of analysis will be issued to the EPA and copies sent to T. & J. Standish

(Roscrea) Ltd. when analysis is complete.


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iQ

I I

INSPECTION REPORT

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Tullamore Road, Clonaslee, Co. Laois Tel: 0502-48077, Pax: 0502-48359, Mobile: 087-2575687

Email: pir>efab(ii),oceanfree.net Vat Reg No. IE 4773886 V

- "--'U, _-."

11 February 2002

T & J Standish (Roscrea) Ltd The Leap Castle Roscrea Co. Tipperary

RE: Timber Treatment Plant, Vacuu

Dear Sirs

Having visited the plant I found the system to be worn, and needed to be upgraded both the Vacuum & Pressure systems were worn.

I have obtained a copy of the specification of the treatment of timber, using this process from Hicksons, I propose the following systems be installed.

1. New Vacuum Pump, Pipework, Filtration, Attenuation, & Exhaust Gas

2. New Pressurisation, Filtration Pump Set, & Pipework be installed. 3. Vessel be upgraded, resealed, Safety Valves, & Pipework be Checked, &

Separation System to be installed.

Certified. 4. All the systems components be linked to, & controlled by a PLC.

The PLC once programmed controls the system accurately for each cycle.

-?e< sqer;\)" d W k &, 9 9 4 I tAoo +Ja c3n

Example:

1'' stage Initial Vacuum, Pre-set time.

2"d stage Filing Chamber. o w . @'% Yd stage Pressurisation.

4'h stage Empty Chamber.

gfh stage Final Vacuum.

6'h. Stop.

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I

1. Instruction Manual detailed, & simple to follow for operators. 2. Safety Valves clearly marked and labelled 3. Rotating, & moving parts be guarded. 4. Full training be given to operators of this system. 5. Noise levels - obtain a required decibel level, and come as close to this as

possible. 6. Fit a separator on the exhaust gas from the Vacuum Pump to avoid vapours

been released to the air. 7. Make sure all the leaks round the system are repaired, and any surplus

chemical liquid can flow safely to a holding tank 8. Make sure there a re high, & low level alarm systems installed in the event of

a tank becoming close to overflowing etc, & these alarm can be closely monitored a t all times.

9. All tank, & vessels must be bunded and all bunding regularly checked, & certified.

The above work was completed~o1r-25- 02. X i % * * + , "

av I 1 ./-- Yours faithfully k- * eclan McCann

Director Pipefab Ltd

.

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. . . . . . . . . . . . . . .

.I I

(-- -

rmination of the extent of Chromium contamination in the River

Fuarwan Q

and I

1'1

i/ Details on the extent of fencing required I I I DOC. NO. 395-2

0' For

T & J Standish (Roscrea) Ltd. IPC Licence 320

February 2002

48 Main Street, Bray, Co. Wicklow, Ireland. Tel 00 353 1 276 1428 Fax 00 353 1 276 1561 Email: [email protected] website, www.enviro-consult.com

Registered Office 54 Dame St., D'ublin 2, Ireland. Registered Number 243412

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@

I

This copy is a controlled copy and the recorded holder of this document will be issued with amendments when such amendments are made.

I

3


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I

I i

J 1

. T & J Standish (Woscrea) Ltd. Document No. 395/2 r I. Introduction A Notice under Section 12 of the Local Government (Water Pollution) Act, 1977, as

amended by the Local Government (Water Pollution) Amendment) Act, 1990 was issued

to T. & J. Standish (Roscrea) tdt date~tT3‘~”

Condition 2 of this Notice stat+: .--- k rL

!I b

urface water drainage ‘Isolate and secure all contqminat

systems to prevent access by membe ocL’Inform the owners

or occupiers or, or Local ~ u t h r r i i i - s on which the off site

surface water drainage systems are situated, of the risk posed to human and animal

d t h by existing contamination of these water courses and of the need to

immediately isolate and secure those systems from members of the public and

livestock’.

h \I - --

@

1/ This report aims to detail the process undertaken to determine the extent of contamination

ahd report on the necessary measures undertaken to comply with the above condition. It

2. Methodology

Extensive sampling of the River Fuarwan from a minimum of 100 metres upstream to 1.5

kilometres downstream was undertaken. Readings of Chromium VI concentrations could

he obtained on site by the use of a portable photometer (Macherey - Nagel PF-11). The k p l e s were analysed using a standard m e ~ o d for Chromium VI determination as

defined in the publication Standard Methods for the Examination of Water and

Wastewater’, 20h edition. Obtaining results on the spot allowed the analyst to determine

how far to take samples from the upstream location. Once the readings gave minimum

of five results lower than the maximum acceptable concentration (MAC) limit (50 pgA

Cr) sampling was ceased. See Appendix 1 for map showing s g p l e locations.

The reerulta were mapped cuad colour co-ordinated according to whether they were above

or below the MAC value. From this it was possible to determine the extent of fencing

required to comply with Condition 2 of the Section 12 Notice.


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- . . . . . . . _ I . .

3. Findings

4 ~ ~ t ~ ~ ~ k limit at sample

FR76';I 3. I Chromium VI Concentratiohs-- H _. * ^ -. *-.--TI sL__

. '1 From the results illustrated in Table $ C ~ E I G ~ I @ 4 points 3-5,7 and 8 only. Upstream the concentrations were below the maximum

detectable limit. Beyond 350 metres downstream concentrations drop below the MAC

limit. The results remain below the MAC limit for another 850 metres. See Appendix 1

for colour coding of above and below MAC limits locations. The colour orange denotes

the samples being above 50 pg/l Cr VI and the colour green denotes the samples being

below 50 pg/l Cr VI.

-2

Table of Results of River Fuarwan Sampling

.


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\ e.', _" _- .* % I

4. Discussion & Conclusion \h 1, ."a+ " $,

4.1 Extent of Fencing Required

Condition 2 of the Section 12 Notice states that isolation of all contaminated on-site and

off-site surface water drainage systems to prevent access by members of the public and

livestock is required. Therefore, it is determined that fencing of the River Fuanvan is

required to a distance of 350 metres downstream from the point where the first drain

enters the River Fuarwan.

On inspection of the riverbank and access to the river on the day of the sampling it was

,wcertained by a member of EEC Ltd. that the existing fencing system covers the area

e q u i r e d i.e. 350 metres from first drain. We are given to understand that this land is

under ownership by Tom Standish.

Therefore, it is not necessary to inform any neighbouring landowners of the existing

contamination of the watercourses as it is below the MAC limit when passing through

their lands.

It was noted that one short section of fencing within the 350-metre stretch appeared weak.

It was recommended that this fencing be reinforced to ensure that there is no possibility

of any member of the public or livestock entering the river area. Tom Standish has

aqeed to check the full length of fencing and repair any weakened fencing immediately. 0


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EPA Export 25-07-2013:18:24:00

, 1 4 1. I , 'I' & J Stairdish (Roscreaj Ltd. --- Document Ne. 39522 i

Appendix 1 Map showing sample locations


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1 ; - . ’ Enviroiimental Efficiency Consultants (Ireland) Limited

Coiisultiiig Engineers

I .’ I I-

I , Q

, “

\

Proposal for the”’hvestigation of ground and groundwater contamination

,

for

T & J Standish

Doc Number 395-3a

48 Main Street, Bray, Co. Wicklow, Ireland. Tel 01 276 1428 Fax 01 276 1561 . elnail [email protected] www.enviro-consult.com

Registered Office 54 Dame Street, Dublin 2. Registered Number 243412

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EPA Export 25-07-2013:18:24:00


OF 1.01 Document Lead Sh

Project No. Document Number Client

- ii -:I, * :‘3 FX6”A : :.

I ”{ Document Title I Proposal--for- ‘the 4nvestigatioP- of- ground and groundwater I

contamination 395 395-3a T & J Standish

Issue No. 1.01

Status Date Author Approved Signature Draft 8/3/02 JK RBS

EEC Project Manager Client Project Manager

Bob Sutcliffe Tom Standish

This copy is a controlled copy and the recorded holder of this document will be issued with amendments when such amendments are made. *

* to be deleted as appropriate

Distribution List - note that the issue of uncontrolled copies is not necessary recorded.

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1 1 1

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1. INTRODUCTION

Geotechnical and Environmental Services Limited were requested by Environmental Efficiency Consultants to prepare a proposal for the investigation of ground and groundwater contamination on the premises of T and J Standish Limited, The Leap Castle, Roscrea. Co. Offaly.

The investigation is required to investigate ground and groundwater contamination of the site and the environs.

The investigation is required to embrace load out and storage aprons, made ground, solid and drift Geology.

2. APPRECIATION

Geotechnical and Environmental Services Limited carried out a hydrogeological assessment of the site in 1999 (Report 98/41/01).

The following conclusions were derived

The working area of the site comprises mainly made ground, comprising a mixture of material types.

The Fuarawn River is the main surface water feature and is considered to be the ultimate focus of surface water drainage from the site.

The bedrock is considered to comprise a POOR aquifer (generally unproductive except in ' localised zones)

The depth to the water table on the site was measured at 35.1 m. b.g.1

The depth to rock was expected to be shallow in the immediate vicinity of the sawmill. Closer to the river the thickness of soil/subsoil was expected to be at least 2m -3m thick.

3. PROPOSEDAPPROACH

The following approach to the investigation is proposed.

1. Excavation of 8-10 trial holes. 2. Take sub-soil samples from various depths (at least 2 per hole) 3. Install monitoring points.

.4. Assess existing boreholes and take groundwater samples 5. Submit samples to laboratory for analysis 6. Prepare preliminary investigation report detailing recommendations for follow on work.

It is not suggested that this is an exhaustive investigation, but it is coniidered that this approach will allow flexibility and direction for follow on stages.

The critical aspects are expanded below.

Trial Holes

= T h e trial holes which will be dug over a 1-2 day period will be used to build up a profile of the ground conditions on the site and environs .in the direction of the river. Because the subsoils have a role in the vulnerability of the groundwa'ter it is important to establish these conditions before decisions are made reagarding the siting of boreholes.

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'* + -, tl #

Soil Sampling

Sub-soil spoil from tria"h 8, samples will be taken.

r, colour, and representative

Samples will be taken from the topsoil and from at least one further depth interval to determine a vertical profile of contamination.

Groundwater monitoring

Where groundwater is encountered as part of this investigation (probably only on the lower slopes) monitoring points will be established to enable groundwater levels to be established.

Groundwater Assessment

Groundwater samples will be taken from the established points after one week. The samples will be analysed for the specific contaminants, using dedicated bailers for each point.

The existing on-site boreholes will be assessed in the context of vulnerability and well- I head protection. I

~

Report

A report will be prepared compiling the findings from the investigation. The recommendations may include provision for further investigation/monitoring which will be carried out under an agreed time period.

~

I The report will be prepared following completion of all analyses (approx. 10 days) I

.

The report will include preliminary proposals for the remediation of areas of significant contamination of ground and groundwater.

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I *r #

Ehvironmental Efficiency consultants (Ireland) Limited

‘1 - -- &-vc I , 1 for

Remedial Works to Intercept and Treat Contaminated Surface and Groundwater

*

@

DOC. NO. 395-5

For

T & J Standish (Roscrea) Ltd. IPC Licence 320

February 2002

48 Main Street, Bray, Co. Wicklow. TelO1 276 1428 Fax 01 276 1561 Email [email protected]

Registered Office 54 Dame St., Dublin 2. Registered Number 2434.12

I

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-. - . .a”

i.

-,

* 3'8s J Standish (Roscrea) Ltd. ' Document No. 395/5 r'

2.1.1 Removal of Contamina 1 or Incineration

Contaminated waste 1 Hazardous waste

Special waste -L - -**

2.1.2 Containment of Contaminant (the 'Source')

Encapsulation

0 Slunywalls

o Jet grouting, blankets

o Clay, plastic membrane

o Vitrification

o Cementation @

! Capping

o Inert granules

o Hard standing

2.1.3 Removal of Contaminant (the 'Source')

Biological

I o Anaerobic bacteria o Fungi

o Landfarming, cornposting

5 o Phytoremediation Chemical

o Ionexchange

o Neutralisation

o Oxidation

o Photolysis

o Precipitation

o Reduction

o Carbon absorption

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<

T & J Standish (Roscrea) Ltd. Document No. 39575 . "

Physical

s- o Soil wash

o Drumremoval

o Evaporation __c

o Steam stripping *-_1 r ---* .-.

7. I

o Vacuum air stripping

o Geochemical Fixation

..


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i-

Impact of Chromium Discharges on the Fuarawn River Biota & Water Quality

.

And

Implications for Downstream Users [ I /

DOC. NO. 395-4

For

69 T & J Standish (Roscrea) Ltd.

IPC Licence 320 i

February 2002

48 Main Street, Bray, Co. Wicklow. TelO1 2'76 1428 Fax 0 1 276 1561

Registered Office 54 Dame St., Dublin 2. Registered Number 243412 1 Email [email protected]

-

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. -

............................................................... 4

3.1

3.3 3.4

FINDINGS AT 1 OOM UPSTREAM ............................................................................................ 10

FINDINGS AT 25OM DOWNSTREAM ....................................................................................... 10 FINDINGS AT 8OoM DOWNSTREAM. ...................................................................................... 1 1

3.2

3.5

FINDINGS AT 1 0 ~ DOWNST REAM... ....................................................................................... 10

SUMMARY TABLE OF FINDINGS ............................................................................................ 1 1 4. DISCUSSION AND CONCLUSIONS ........................................................... ........................... 14

4.1 4.2

IMPACT OF CHROMIUM DISCHARGE ON THE FUARWAN RIVER BIOTA AND WATER QUALITY 14 IMPLICATIONS FOR DOWNSTREAM USERS ............................................................................. 16

@ ' TABLE 1

TABLE 2 TABLE 3 TABLE 4

APPENDIX 1

RELATIONSHIP BETWEEN BIOTIC INDEX (Q) AND THE FIVE FAUNAL GROUPS PRESENT ON ERODING SUBSTRATA OR RIFFLES ........................................................................................... 7 TABLE RELATING Q VALUE TO QUALITY CLASS .................................................................... 7 GENERAL CHARACTERISTICS OF THE VARIOUS BIOLOGICAL QUALITY CLASSES .................. 8 .

TABLE OF RIVER SURVEY FINDINGS ..................................................................................... 12 1 , ' FAUNA INDICATOR GROWS A - E ............................................................................. 17

.

3 Environmental Efficiency Consultants (Ire.) Ltd. '

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. . .: . .., . , ... :, . . 1 ,' . . ,- I i [ ,', i r' I '

amended by the Loch14Government (Water Pollution) Amendment) Act, 1990 was issued

to T. & J. Standish (Roscrea) Ltd. dated 13'h February 2002.

Part Four of this Notice states:

Investigate and report on:

The impact of the Chromium discharges on the Fuarawn river biota, water quality and implication for downstream users.

This report aims to detail the methodology of this investigation, the results of the

investigation and discuss the implication for downstream users. I

2. Methodology

2.1 The Biological Assessment of Water Qualify

Biological surveillance is the only means whereby changes to the riverine ecology can be

detected. Biological monitoring procedures for rivers are based principally on the

examination of suitable resident organisms. Most widely used in river quality

investigations are the group of larger and readily visible invertebrate animals, which

@Ionise the substrata of all rivers. These animals are collectively referred to as macro &vertebrates, the main constituents of which &e young aquatic stage of certain insects.

/

The sensitivity and tolerance to pollution shown by different members of this animal group vary considerably from species to species. A characteristic feature of polluted

environments is a reduction in overall community diversity in line within increasing

pollution severity, and also an increase in the density of tolerant species.

Unlike fish, which are mobile, and may avoid polluted areas, the macro invertebrates are

unable to avoid pollution in this way, so that the community has to endure the full range of environmental conditions, which affect its particular habitat. TheL composition of a

Environmental Efficiency Consultants (Ire. 1 Ltd. 4

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>

i w

r’ community from any given

that particular point.

he average water quality at J

c

Example invertebrate indic

8

8

e

@

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0

e

8

Nutrient enrichment - increased ratio of aquatic worms (oligochaetes) to aquatic insects - increased ratio of midges (chironomids) to other aquatic insects - increase of herbivorous mayflies (ephemeropterans) and midges

Low dissolved oxygen - increased ratio of aquatic worms to aquatic insects - increased ratio of midges to other aquatic insects

Contamination by heavy metals - increased ratio of aquatic worms to aquatic insects - increased ratio of midges to other aquatic insects - increased abundance of water bugs and water beetles - increased ratio of predators to herbivores and detrivores

Sedimentation - decrease in mayflies and midges

Low p H - loss of snails, clams, mussels, daphnids, mayflies, midges

Temperature - Releases of heated effluents tend to reduce community richness

(Source: Adamus and Brandt, 1990)

Biological surveys are usually undertaken in the summer-autumn period when flows are

likely to be relatively low and water temperatures highest. Surveys durinithis period are

likely, therefore, to coincide with the worst conditions to be expected in those reaches affected by water inputs. However, in order to complete the requirement of the Section 12

Notice the surveying for this report was restricted to the month of February.

1 T h e samples are usually obtained by a kick sampling teohnique in the rime (faster

flowing) areas of the river or stream. Sampling is carried out for 2 to 5 minutes and is

Environmental Efficiency Consultants (Ire.) L td. 5

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4 I b ’ . . , .-* usually supplemented by a gimilq length of tirpRaent pic ng macro invertebrates from d-a. €ieI$&ventory of the invertebrates the stones. The invertebrate; are the ._ and their relative abundance are recorded. The quality of the water can then be inferred by

comparing this data with that which might be expected from unpolluted habitats.

, c - - I‘

The locations of the sampling sites should be one lOOm upstream of a likely discharge

point, a second taken just downstream fiom main drain leading from T. & J. Standish site

to river, a third taken 250m from the first downstream site, and a fourth sample taken

800m from the first downstream site (total length of river covered equals lkm).

A general site description is recorded which includes relevant factors such as intensity of

@ algal and / or weed development, water turbidity, bottom siltation, nature of the substratum, speed of current and water depth.

Readings of the pH, conductivity and water temperature are also taken on site at each

location. In addition, samples of the river water were taken and Total Chromium and

Chromium VI concentrations analysed for each sample.

Plants and animals do not bio accumulate chromium; therefore, the potential impact of high chromium levels in the environment is acute toxicity to plants and animals.

The biological water quality assessment used for this project uses a system, which relates

@the relative abundance of five key faunal indicator groups of macro invertebrates to water quality. The five arbitrary ‘indicator’ groups’range from ‘Group A’ (Sensitive Forms), to

‘Group B’ (Less Sensitive), to ‘Group C’ (Tolerant), to ‘Group D’ (Very Tolerant), to

‘Group E’ (Most Tolerant). Each group lists a number of species that are specific to that

group e.g. Group A includes Perlidae (stoneflies). See Appendix 1 for list; of species in

indicator groups.

’

The biological information is then condensed into a readily understandable form by means of a 5-point index referred to as Q-values. The key faunal indicator groups and

their relationships with the Biotic Index (Q values) are set out in Table 1.

Environmeutal Efficieiicy Consultants (Ire.) Etd. 6

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T dk 9 Standish (Roscrea) Ltd. Document No. 39518

The general characteristics of the various biological quality classes and their relationship

to water quality are set out in Table 3.

Table 1 Relationship between Biotic Index (Q) and the Five Faunal Indicator Groups

present on eroding substrata or riffles

*=

$-H=

++= + = +/- = Scarce or absent;

Nunierous or dominant, 25-75% of total

Common, IO-20% of total fauna;

Small numbers, 4 0 % of total fauna; Scarce,

Table 3 General Characteristics of the various Biological Quality Classes

Q4 p3-4

Slight pollution

Light

Pl 3ross pollution

Excessive

Usually very &gh

-i---

Unpolluted Heavy pollution I I Moderate pollution

Considerable None

Low (0.1 mg/l

Usually heavy May be considerable

Never Never

Considerable

May be some

Excessive growths,

Usually abundant

Usually abundant Luxuriant growths, typically Cladophora growths, diverse

communities

typically Cladophora

Diverse communities, Reduced . diversity,

luxuriant growths

Limited . diversity,

excessive growths

Tolerant species only,

may be abundant

Usually none or

tolerant species

only.

considerable growths

Sensitive forms absent.

Tolerant forms common.

Low diversity.

Tolerant forms only.

Very low diversity.

Most tolerant

forms.

Minimal diversity.

High diversity. Increased density.

Sensitive forms

scarce or common.

Very high diversity.

Very high density.

Sensitive forms scarce.

Environmental Efficiency Consultants (Ire.) Ltd.

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I

I -- I

3. Findings

3.1 Findings at loom Ups frfrfrfrfrfrfrfrfrfrfrfrfrfrfrfrfrfrf- Four species (two orders) from Group A were logged, 1 species (one order) from

Group B, 16 species (one order) from Group C and lastly 15 species (one order) from Group E at a point lOOm upstream from the main drain into the river from the

treatment plant (See Table 4). Using Table 1 the relationship between the above

findings result in a Q rating of 3 - 4.

Based on Table 2 a Q rating of 3 - 4 indicates that at this point on the River Fuarwan

it has a Quality Class ‘B’ and a Quality Status ‘Slightly Polluted’.

3.2 Findings at IOm Downstream Twenty species (one order) fiom Group A / B were logged, 19 species (two orders)

from Group C and 60 species (one order) from Group D at a point 10m downstream

fiom the main drain into the river from the treatment plant (See Table 4). Using Table

1 the relationship between the above findings result in a Q rating of 3/0 - 2/0.

A “0” is added to the end of a biotic index where a toxic effect is either apparent or

suspected; in this situation Chromium contamination is apparent.

Based on Table 2 a Q rating of 3/0,- 2/0 indicates that at this point on the River Fuarwan it has a Quality Class ‘C’ and a Quality Status ‘Moderately Polluted’.

. 3.3 Findings at 250m Downstream Four species (two orders) from Group A / B were logged and 52 species (two orders)

fiom Group C at a point 250m downstream from the main drain into the river from the treatment plant (See Table 4). Using Table 1 the relationship between the above

findings result in a Q rating of 310 - NO.

Based on Table 2 a Q rating of 3/0 - 410 indicates that at this point on the River Fuarwan it has a Quality Class ‘B’ and a Quality Status ‘Slightly Polluted’.


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B *--

3.4 Findings at 800m Downstream Fifteen species from Group A / B were logged, one species from Group B, one species

from Group C and ten species from Group D / E at a point 800m downstream from the main drain into the river from the treatment plant (See Table 4). Using Table 1 the

relationship between the above findings result in a Q rating of Q4/0 - 510.

Based on Table 2 a Q rating of 4/0 - 5/0 indicates that at this point on the River

Fuarwan it has a Quality Class ‘A’ and a Quality Status ‘Unpolluted’.

3.5 Summary table of findings

C B

Moderate I y Moderately

Polluted Polluted

A

Unpolluted

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% * \ . ") 4. I Impact of Chromium disciarge on thtz-Euarwa quality - --

Based on the findings described in Chapter 3 it appears that the River Fuanvan is

slightly polluted before it reaches the stretch that can be affected by surface run off and groundwater feeding from T. & J. Standish (Roscrea) Ltd. The quantity of blood

worms or midge larvae observed strongly indicate nutrient enrichment has occurred

along this stretch of the River Fuanvan, most likely from agricultural run off. However, the presence of a small number of stonefly nymphs and caddisfly larvae

indicate that the river is not extremely low in dissolved oxygen. These species require

a relatively clean environment to survive.

Three drains run from in front of the T. & J. Standish Ltd. site, down the hill to the river. A kick sample was analysed 10 metres downstream from the first of these drains (the main drain). Based on the findings described in Chapter 3 the water quality status

has deteriorated. It is now 'moderately polluted' as opposed to 'slightly polluted'. A

large number of leeches were found at this site. These species are generally very

tolerant of pollution. There is an increased ratio of aquatic worms to insects, which

can be viewed as an indicator of heavy metal contamination.

However, the presence of a reasonable number of mayfly nymphs indicates that the river is not highly polluted, as these species are very sensitive to any kind of pollution.

The third kick sample was taken after the next two drains leading froni T. & J.

Standish Ltd. approximately 250 metres down stream of the first downstream site. It

appears from the findings of the survey that the river is .becoming less polluted at this

point. No species from the D or E group were detected. A large number of small snails (Group C) were noted which would indicate that the river is still slightly

polluted. However, this pollution is less severe than at the 10m from DS site as indicated by the presence of Group A species i.e. stonefly nymphs and lack of any D Group species i.e. leeches.

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downstream site. From the findings, this stretch of river appears to be unpolluted.

There is a majority of ‘sensitive’ species to ‘tolerant’ species. Stonefly nymphs will

only live in unpolluted waters and there were at least 15 species of these found in the

kick sample at this site, a significant increase from 250 m DS location.

From the above, it is apparent that the river has been subjected to a variation of pollutants. Upstream from T. & J. Standish Ltd. it is evident that the river is being

subjected to some nutrient enrichment. This is not to the degree of causing serious

pollution. However, it is necessary to have this information when assessment the

impact of surface water runoff and groundwater feeding from the T. & J. Standish

Ltd. site on the River Fuarwan. It is evident that the river is slightly polluted on

entering the stretch in front of the site.

The water quality of the River Fuarwan decreases further at it passes in front of the T.

& J. Standish Ltd. site. The water quality drops to a Class B from C. After examining

the types of species found there it could be loosely said that chromium contamination

has affected the types of species found along this stretch.

However, the water quality gradually increases from a Class B (250 metres DS) to a

Class A after 800 metres. It is at this point that the river has completely recovered and @ is even cleaner than the upstream site.

In conclusion, nutrient or organic enrichment has affected the quality of the river prior

to entering the Standish catchment zone. The water quality does decrease along the

f’ront of the T. & J. Standish Ltd. site. It is possible that this can be accounted for by

additions of Cr VI. However, the river recovers to an improved status &er 250 metres

and to an unpolluted status &er 800 metres.

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- . . - ---------- " -

I .

4.2 Implications for downstream

The sample locations are all located on T. & J. Standish Ltd. land except for the final

site downstream. The river is fenced from the land along the entire length covering all

sample locations.

It is recommended that fishing be prohibited along the stretch of river in front of the

T. & J. Standish Ltd. site to a distance of approximately 250 metres downstream.

After this point Groups A, B and C dominate over Groups D and E, which indicates that the river water cannot be heavily or grossly polluted.

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-.-+ -- -- - c - -

;0.:4,-#-. FT c" i Li T H E H I G H C R T ? . I , :, 1 -Le=-- ",&-A/ -- - 1 esgc&iF & MCA E I. ~~"~ _1 .,*- ._ Le--- --&

IN THE MATTER OF AN APPLICATION PURSUANT TO THE PLANNING AND DEVELOPMENT ACT, 2000 AND IN THE MATTER OF AN

APPLICATION PURSUANT TO SECTION 160 OF THE PLANNING AND DEVELOPMENT ACT, 2000

AND IN THE MATTER OF AN APPLICATION BY

BOB HIGGINS, KIERAN DAMERY, RAY DEEGAN, MARGARET HUDSON, STEPHEN NETTLESHIP, ANN NETTLESHIP

AND THE COUNTESS OF ROSSE

-and- Applicants

T & J STANDISH (ROSCREA) LIMITED JOSEPH STANDISH, JOHN STANDISH AND TOM STANDISH

Respondents

AFFIDAVIT OF STEPHEN NETTLESHIP

I, STEPHEN NETTLESHIP , Builder, of Brownhills, Aghancon in the County of Offaly aged eighteen years and upwards hereby MAKE OATH AND SAY as follows:-

1. I say that I am the fifth named Applicant in the above entitled proceedings and I make this Affidavit on my own behalf and on behalf of each and all of the other Applicants and with their authority, from facts within my own knowledge save where otherwise appears and whereso appearing I believe the same to be true and accurate.

I . 3 I say that I am originally from Yorkshire with numerous relatives and family connections in Ireland. I say that in 1992, myself and my wife Ann, the sixth named Applicant moved to Ireland and settled in the Aghancon Valley with our children. We decided that we would far prefer to raise our children in rural Ireland rather than in the urban environment of England.

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.k 3. I say that we nqw reside soms2.-

the Respondent$fid :&i t.he-ctow a&fiom the Timber Processing Plant of 1 mile or so fiom that facility.

I I 4- , I i

I

’! I

4. I say that this Timber Processing Plant is an eyesore in an otherwise rural agricultural landscape and that depending on the nature of the prevailing wind, I and my family are too subjected to an’assault of noise emanating &om the Timber Processing Plant from time to time, sometimes late at night and up to 2.30 a.m. I myself have been woken up at night by the noise, as have my wife and my children despite the fact that we reside approximately one mile therefiom.

5. I say that I have read the Affidavits of Kieran Damery and Bob Higgins sworn herein on 2Uth July 2002 and concur with everything that they have said in relation to the operation of the Timber Processing facility by the Respondents. I say that I, together with my wife Ann, are members of the Aghancon Concerned Residents Association. In particular, I say that up to 1997, the site upon which is now erected a large-scale industrial Timber Processing Fqcility, was a green field site. In particular I say that thee was no Sawmill or Timber processing facility on that green field site up to 1997 when the Standish Family first constructed what I would describe as a small, lean-to, open-sided shed wherein they started to cut up timber.

I say that I have read the Affidavits of Kieran Damery and of Karl Searson, Consulting Engineer, and also of Mr. John Standish and of Mr. Joseph Standish wherein reference is made to intimidation. I say that I too have experienced intimidation at the hands of the Standish family and in particular, at the hands of Mr. Tom Standish, the Fourth Named Respondent.

6.

7.

I i @

I I

I say that in early November of 2001, Mr. Tom Standish threatened me with a pick axe handk outside of my door when I complained to him about a slatted cattle shed which he had altered and extended to within 30 feet of my door, without the benefit of either an application for or a Grant of Planning Permission. I say that this incident was witnessed by a number of people and was immediately reported to the Gardai at Birr Garda Station. I say that within 40 minutes of my being threatened by Mr. Tom Standish, the Gardai went to Mr. Standish’s house and there took possession of the pick axe handle used by him to threaten me. I say that this Pick Axe handle remains in the custody of An Garda Siochana in Kiniity Garda Station in County Offaly and I am awaiting the outcome of a complaint made by me against Mr. Tom Standish to the Gardai arising out of this incident,

8. I say that I too have read and am familiar with the reports ftom the Environmental Protection Agency exhibited in the Affidavit of Kieran Damery. I say that both I and my wife are fearful that in the event that the Timber Processing Plant being operated by the Respondents without the benefit of Planning Permission is allowed to continue, the Aquifer and Groundwater will become fbrther polluted with Chromates and in particular, with Chromium 6. In such circumstances, I arn fearful

for the continuing good health of my children.

9. I therefore pray this Honourable Court for Orders in the terms of the Notice of Motion herein,

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SWORN by the above named STEPHEN NETTLESHIP at Bandon in the County of Cork this %‘-day o f July 2002 before me a Commissioner for OathsPracticing Solicitor

.

Filed this Street, Bandon, County Cmk.

day of Ju1y;hWby Csey & Company, Solicitors for the Applicants, North Main

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\ Record No: 2002 No. 61 MCA

. -’__---- ~ L “,A I . b . -rrC -- - >-- -

IN THE MAT+R OFAN~AFPLICATION PURSUANT TO THE PLANNING AND’DEVELOPMENT ACT, 2000 AND IN THE MATTER OF AN

APPLICATION PURSUANT TO SECTION 160 OF THE PLANNING AND DEVELOPMENT ACT, 2000

AND IN THE MATTER OF AN APPLICATION BY

BOB HIGGINS, KIERAN DAMERY, RAY DEEGAN, MARGARET HUDSON, STEPHEN NETTLESHIP, ,4NN NETTLESHIP

AND THE COUNTESS OF ROSSE

ADD licant s -and-

r

T & J STANDISH (ROSCREA) LIMITED JOSEPH STANDISH, JOHN STANDISH AND TOM STANDISH

Respondents

AFFIDAVIT OF STEPHEN NETTLESHIP

CASEY & COMPANY, Solicitors,

North Main Street, Bandon,

County Cork.

Tel: 023 - 44400 Fax: 023 - 44853

E-Ma il: g rcasey @ e i rco m . net

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1'

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. .

,

1 ! - I :

Record No: 2002 No. 61 MCA

< IN TKE MATTER OF APJ APPLICATION PURSUANT TO THE PLANNING AND DEVELOPMENT ACT, 2000 AND IN THE MATTER OF AN APPLICATION PURSUANT TO SECTION 160 OF THlE PLANNING AND DEVELOPMENT ACT, 2000

, AND IN T m MATTER QF AN APPLICATION BY

BOB HIIGGINS, KIERAN DAM@RY, RAY DEEGAN; MARGARET HUDSON, STEPHEN NETTLESHIP, ANN NETTLESHIP AND

THE COUNTESS OF ROSSE

Applicants -and-

T & J STANDISH (ROSCREA) LIMITED JOSEPH STMDISH, JOHN STANDISH AND TOM STANDISH

Respondents

NOTICE OF RE-ENTRY OF MOTION

TAKE NOTICE that on the forenoon or at the first oppo

and development of lands at Leap in the County of Offaly. 2. An Order requiring the Respondents and each o f them to restore the said lands to the

condition which existed prior to the carrying out o f the unauthorised use and kvelopment thereof

3. An Order-prohibiting the Respondents a d each of them &om carrykg out their . sawmill, wood treatmet$ plant add retail unit busmess or any related use on the said lands unless or until a grant of planning permission for such use has been obtained.

4. A Declaration that the structures erected and works carried out by or on behalf of the ' Respondents at Leap in the County of Offaly constitute unauthorised developments.

5. An Interim and/or aa InterIocutory Order in the terms of the foregoing p w n t to

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'.

dgement of time for the re-entty o f these

le Court doth seem fit and meet. 8. An Order providing for the costs of and inciderltal to this application.

AND FURTHER TAKE NOTICE that the said Application shall be grounded upon this Notice of Motion, the proceedings already had herein, Affidavits of Bob Higgins, Peter sweetman, Greg Casey and Ronald J. Bergin dated the 23rd day of May, 2002 and the exhiiits thereto, the AfEdavit of service thereof, such firrther and other Affidavits as may be filed, the nature of the case and the reasons to be offered.

Dated this d_!-&y of November 2003. .

North Main Street, Bandon, County Cork

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FINDINGS AT 8OoM DOWNSTREAMSUMMARY TABLE OF FINDINGSERODING SUBSTRATA OR RIFFLESTABLE RELATING Q VALUE TO QUALITY CLASSGENERAL CHARACTERISTICS OF THE VARIOUS BIOLOGICAL QUALITY CLASSES

efficiency (ireland) limited48 main street, bray, co. wicklow, ireland. tel 00 353 i 276 1428 fax 00...

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