August 2008: Letter from Arup Consulting Engineers (working for Becbay) to the EPA saying the site notice and complaints monitoring system will be implemented. The EPA enforcement officer writes to Bernard McNamara saying the agency agrees that high-energy compaction technology can be used on the site.
June 2008: Dublin city council waste enforcement officer writes to a contractor for the IGB site about hazardous waste shipments at Dublin Port taken from the site. The inspector says no documents were available on the boat he inspected as required by European regulations. An email from Arup Consulting shows the EPA approved the previous January the removal of landfill and domestic waste excavated from the site to two facilities in Germany for treatment.
March 2009: Arup completes the annual report on groundwater and daytime noise. The report shows a monitoring well detected what is believed to be a thin lens of oil on the site. But the well was destroyed in December 2008 before a new test could be carried out, Arup explains.
May 2009: The EPA reminds McNamara about the reporting of minor incidents on the site.
May 2009: Arup writes to the EPA following an EPA audit on the site in early May. Arup says "19 groundwater monitoring wells have been monitored over a period of 12 years at the IGB site. This monitoring took place in phases in 1996, 1997, 2005, 2007 and on a monthly basis from early 2008 to March 2009… None of these wells has ever shown evidence of free product, except for one well, GWMW-8 in November 2008". It appears this well recorded a small oil lens. The well was accidentally demolished. "We believe this single discovery of product was an isolated incident," says Arup.
May 2009: The EPA asks the DDDA to comment on the intention of Becbay to surrender its licence.
June 2009: The EPA asks the city council to comment on Becbay's application.
July 2009: Malcolm Doak, a former EPA officer, submits an observation to the EPA opposing Becbay's application. "Principally, the risk assessments and remediation to high-density residential end-use affirmed in the transfer application documents have not been completed," Doak writes. He claims Becbay failed to follow best practice by neglecting to consider the possibility of methane migrating into basements, foundations, ducts and underground car parks.
August 2009: Commenting on Doak's submission, Arup tells the EPA that its management plan followed best practice, in consultation with the EPA, in cleaning up the site.