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«OFFICE OF LICENSING & GUIDANCE INSPECTOR’S REPORT ON A LICENCE APPLICATION Directors To: Emer Cooney From: - Licensing Unit Date: Application for ...»

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European Communities (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2006 (S.I. No. 74 of 2006) This site has been classified as a lower tier site under S.I. No. 74 of 2006. The National Authority for Occupational Safety and Health (NAOSH) is the competent authority responsible for administration and enforcement of these regulations.

Best Available Techniques (BAT) I have examined and assessed the application documentation and I am satisfied that the site, technologies and techniques specified in the application and as confirmed, modified or specified in the attached Recommended Decision comply with the requirements and principles of BAT. I consider the technologies and techniques as described in the application, in this report, and in the RD, to be the most effective in achieving a high general level of protection of the environment having regard - as may be relevant - to the way the installation is located, designed, built, managed, maintained, operated and decommissioned.

Fit & Proper Person Assessment The applicant’s experience, technical abilities, financial and legal standing would qualify them as Fit & Proper Persons.

Compliance Record:

The Agency issued five non-compliances to Swords Laboratories in 2006, which related to non-notification of incidents, odours and emission limit value exceedances.

The main issues identified in the enforcement of the existing licence are as follows:

• Exceedances of volume flow limit for discharge to sewer – the licensee has sought a higher limit (600 m3/day vs. previous limit of 500 m3/day) in order to rectify this issue. The higher daily volumetric limit has been included in the RD subject to the conditions specified in the Section 99E response received from Fingal County Council. This issue is dealt with in the Section of this report entitled “Emissions to Sewer”.

• Odour – this issue is dealt with in the section of this report entitled “Odour”.

• Groundwater contamination - this issue is dealt with in the section of this report entitled “Ground and Groundwater”.


The Agency received 27 complaints in 2006 in relation to this installation. 24 of these related to odour. This issue is dealt with in the section of this report entitled “Odour”.


One submission was received from the Health Service Executive (HSE) on 13 December

2006. The submission relates to a particular waste stream (acid chloride residue) which was being treated in the on-site wastewater treatment plant. This waste stream was identified by the licensee as the source of odour which was the subject of complaints received by the HSE.

The waste stream is now tankered off-site for treatment. The HSE request that the licence contain a condition requiring the waste stream to be treated off-site.

Response: Condition 5.3.8 of the RD specifies that the acid chloride residue waste stream shall not be treated in the on-site wastewater treatment plant.


The invoiced charge for 2006 was €27,952.80. The proposed charge in the RD is €30,545.

The proposed charge reflects the significant enforcement effort required for this installation.


I recommend that the Proposed Determination be issued subject to the conditions and for the reasons as drafted.

Signed Emer Cooney Procedural Note In the event that no objections are received to the Proposed Determination of the application, a licence will be granted in accordance with Section 87(4) of the Environmental Protection

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