PPC1 Section B: Application for a permit.
B1.3 Site Maps and reports.
James Donaldson Timber are located at North East Avenue, Brinscall, Chorley. This location is shown on the Pic 1 – Ordinance Survey Map.
The treatment complex has been located here since approx 1980(shown in red on Pic 2 – Chorley Site layout). This area was previously used for timber storage.
The current internal layout is shown in Pic 3 – Treatment Complex layout.
In preparing our response, we have referenced the Sector Guidance Note SG11 Best Available Techniques to demonstrate our rationale.
The complex is a fully bunded facility with roof and sides. Through the containment treatment vessels, working vessels, associated pipework, treatment vessel loading area consisting of the full rail line, and the post drying areas are covered (12, 30, 31) and an impermeable surface, spill containment kerbs, sealed construction joints and a bunded exterior, (13) there are no intentional point source emissions of List I and List II substances to groundwater. For these reasons, soil samples have not been collected from the treatment facility in order to protect the membranes/construction integrity.
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Pic 1 - Ordinance Survey Brinscall, Chorley
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Pic 2 - Chorley Site Layout
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Pic 3 -Treatment Complex Layout
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B2.1 Management Techniques
As a company we have operated an independently verifiedquality management system, which conforms with ISO 9001 since 1994; we were one of the first companies in our industry sector to achieve this certification.
To achieve our corporate aims and values we have adopted an Integrated Management System (IMS) approach, which combines all the internal business management practices into one system.
Our Integrated Management System has been developed to ensure our continued compliance with our quality assurance, environmental, health and safety and employment law responsibilities.
The backbone of our Integrated Management Systems are our Task Instructions. Task instructions exist for each individual process, operation or task, within the business. Task instructions incorporate the Safe System of Work, the Chain of Custody and Environmental Critical Control Points, the Quality Plans, and the risk/COSHH assessments. The task instructions therefore include certain processes and protocols to ensure compliance with our quality, environmental, health and safety accreditations and responsibilities.
As tasks are allocated, the employee will observe the task being carried out, and when ready, placed under the supervision of a fully competent operator. On completion, and when the Line Manager is confident the employee is competent, they will complete the competency examination. We then re-assess for competency on a three year basis.
This scheme has been audited by various third party organisations that include the Health and Safety Executive, the Trade Unions, Insurance Companies, and our independent Certification establishments.
As part of our management systems, we have a dedicated team of advisors who are responsible for internally auditing our management systems.
B2.2 Raw Materials
All wood preservatives do not contain any substances of concern as defined in the Biocidal Products Regulation (EU 528/2012). Our chemical suppliers ensure that we are using the best available products and techniques in compliance with section 87 of SG11.
At present in the treatment process we use the following products:
Protim E406-This is used in the tilting low pressure vessel.
Osmose Endcoat Wood Preservative-Only applied if ends are cut and exposed. This is also supplied on request from customers in sealed 5litre tins.
Antifoam SB-Added in drip trays to prevent foaming of preservative.
Protim Top Box Defoamer- Added in drip trays to prevent foaming of preservative.
The timber that we treat is Softwood sourced from Sweden, Finland, Latvia and the UK.
B2.3/B2.4/B2.5 Process techniques & disposal/discharges
The treatment area which consists of the treatment vessels, working vessels, associated pipework, treatment vessel loading area consisting of the full rail line, and the post drying areas are all under cover and protected from the elements to avoid the opportunity for rain water contamination (12, 30, and 31). The treatment area also has an impermeable surface, spill containment kerbs, sealed construction joints and a bunded exterior to contain treatment solution (13), and there are no intentional point source emissions of List I and List II substances to groundwater
While the treatment roof prevents rainwater contamination it also ensures water-borne fungicidal & biocidal coatings which evaporate to atmosphere at this stage are contained, and are allowed to drip onto an impermeable post treatment drying area. There is also no waste water as part of the process.
The timber is loaded onto the railing systems by forklift and the packs secured. During the treatment process, we ensure the wood packs are sloped during the treatment cycle to ensure that any excess chemicals are drained from the packs and retained within the treatment vessels (14, 26) and the process applies a final vacuum to drain any additional materials. Any shaped product is treated in such a way to prevent ponding (16 & 17). There is a closed drainage system on the treatment vessel which recovers all material (33).
B2.6/2.7 Waste Generation
The coverings applied by our suppliers to our timber packs are removed prior to any processing activities. These are separated from other waste streams and recycled by our waste company.
Our treatment chemicals are delivered in Ready To Use formulae, and therefore have no waste pallets, drums, or Intermediate Bulk Containers (IBC’s).
As part of the cleaning process any waste materials (timber, filters, etc) are collected, stored, sealed and labelled in metal bins, and disposed off as special waste by an approved contractor under the Special Waste Regulations. This is a low quality per annum (i.e. approximately 1 tonne of materials).
If we are cleaning any equipment, the waste water will be recycled and added to the treatment cycle. (29,39,40).
B2.8.1/B2.8.2Energy Consumption
The energy consumption of the treatment plant will vary depending on the type of timber being treated and the use class required. The plant should be operated and maintained to optimise the use and minimise the loss of energy (107), and the motors are fitted with VSD controls to minimise energy use (38). The process is highly unlikely to exceed a net thermal input of 3MW.
B2.9 Risk Control
All treatment vessels, working vessels, associated pipe work, and drying area has an impermeable surface, spill containment kerbs, sealed construction joints and a bunded exterior to contain treatment solution (13). The connection pipes for the delivery tankers are also contained within these areas. There are bunded areas which have the capacity to contain 110% of the contents of all the vessels contained within them. The bund walls are edge protected to ensure the forklift vehicles cannot cause damage to the bunding.
There are spill contingency procedures within the treatment area which will minimise the risk of accidental emission of raw materials, products and waste materials. These contingency arrangements have been written in conjunction with the local Fire service.
B2.10 Noise
The main element of noise at the treatment complex is generated by the forklift and delivery vehicles. This noise is reduced at the treatment complex boundary by the boarding/cladding around the building exterior. The noise generated by the sawmill prevents any noise generated at the treatment complex being audible at the site boundary, but with a waste water treatment works, an engineering works, and the river on the other site boundaries, the noise has no impact on our neighbours
B2.11 Emissions to atmosphere
As a process, the only emissions to air are a very small quantity of fugitive vapour when the timber vessel doors are opened but this very quickly dissipates. This is captured though as the treatment vessels, working vessels, associated pipework, treatment vessel loading area consisting of the full rail line, and the post drying areas are all under cover.(12,30,31)
B2.12 Cessation of activities
The timber vessels would have any residual chemical/sludgecleaned and removed by an industrial cleaning contractor. The vessels would also be removed by the same contractor. The treatment area is fully concreted and the area would be used for timber storage as it forms part of the adjoining storage shed. An appropriate site investigation would be carried out if required to determine the exact nature of any contamination that may be present.
B.3 Proposed Emissions
As a process, the only emissions to air are a very small quantity of fugitive vapour when the timber vessel doors are opened but this very quickly dissipates. This is captured though as the treatment vessels, working vessels, associated pipework, treatment vessel loading area consisting of the full rail line, and the post drying areas are all under cover.(12,30,31)
B.4 Impact on Human Health
As described in B.3, the emissions while small, are at the timber vessel door. The operator control panel is sufficiently far enough away from these doors to ensure no exposure to human health. Operators are required to wear all necessary Personal Protective Equipment to ensure their health and well being.
The site 87is not a European conservation site of Great Britain.
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