Site Visit Reportbunded areas, photographs IMG_0011 and IMG_0019 refers. Corrective Action: The licensee shall ensure that all hazardous waste and fuels are only stored in appropriately

Site Visit Report

The site visit process is a sample on a particular day of an installation's compliance with some of its licence conditions. Where non-compliance against a particular condition has not been reported, this should not be construed to mean that there is full compliance with that condition of the licence.

Instructions and actions arising from the visit shall be addressed, or where applicable noted, by the licensee in order to ensure compliance, to improve the environmental performance of the installation and to provide clarification on certain issues.

The licensee shall take the actions specified to close out the non-compliances and observations raised in this Site Visit Report.

Licensee

Name of Installation Oxigen Environmental (Merrywell)

Licensee Oxigen Environmental

Licence Register No. W0208-01

CRO Number 315604

Site Address Merrywell Industrial Estate, Ballymount Road Lower, Clondalkin, Dublin 22, Dublin

Site Visit Reference No. SV17002

Report Detail

Issue Date 11/04/2019

Prepared By Hilda Robinson

Site Visit Detail

Date Of Inspection 13/03/2019 Announced No

Time In 12:01 Time Out 15:10

Agency Personnel On Site Hilda Robinson

Licensee Personnel and Role John Clune, Processing ManagerLia Martinelli, Planning and Compliance OfficerBrian Moylan, Planning and Compliance Manager

Photo Taken Yes Samples Taken No Video Taken No

Odour Assessment No

Site Visit Report - SV17002 - Oxigen Environmental Page 1 of 13

Scope

Site visit to evaluate the licensee's compliance with the requirements of Industrial Emissions licence Reg. No. W0208-01.

The purpose of this report is to present the findings of the site visit.

Media

The following environmental media were assessed at the time of the site visit:

• Air• Water• Waste.

Site Areas Inspected

The following areas were inspected at the time of the site visit:

• Civic amenity site (CAS)• Main site• General yard areas• Surface water discharge manhole, SW-1.

Documents Inspected

The following documents were inspected at the time of the site visit:

• Conditions 2.1.2 / 2.2.2.6: Training records, 2018• Condition 3.12.7: Bund testing for the diesel tank, 30/05/2017• Condition 6.7 and Schedule C: Environmental monitoring, 2018• Condition 6.13.1: Daily visual bung check records 'SW-1', 2019• Condition 8.11: Waste acceptance procedure, September 2018• Condition 9.2: Emergency response procedure, 2018• Condition 11.10: Waste acceptance records, March 2019• Condition 11.11: Surface water removal records, February 2019


1. Incident Prevention

Answer Condition Number

Non Compliance

Observation

1.1 Have staff received adequate training in relation to accident prevention and incident response in the event of an incident?

Yes 2.1.2


Non Compliance

Observation

1.2 Are emergency shut-off valves for discharges to sewer and surface water easily accessible and clearly labelled?

Checked 5.4

Comment / Corrective Action

No surface water shut off value is installed at the facility. However, a bung is in place at SW1 to prevent surface water discharging from the facility for which a daily visual check schedule is in place.


Non Compliance

Observation

1.3 Where discharge/emission exceedances have occurred in the preceding 12 month period has the Licensee managed these exceedances in accordance with the licence requirements?

Not Applicable 5.1, 11.2(ii), Schedule B


No discharge / emission exceedances have been reported to the Agency in the preceding 12 month period.


2. Infrastructure Integrity & Drainage


Non Compliance

Observation

2.1 Has the integrity of bunds, tanks, pipelines and containment structures been demonstrated to the Agency and are these fit for purpose?

Checked 3.12.7 Yes


The integrity test reports for the mobile bunds were not available for inspection on the day of the site visit.

Corrective Action:

The licensee shall upload the integrity test reports for the mobile bunds as a licensee return on EDEN by 19/04/2019.


Non Compliance

Observation

2.2 Is the infrastructure installed, operated and maintained at the site adequate to protect the environment?

No 3.1


Following a fire which occurred at the facility on 25/01/2014, the main site is no longer operational.


Non Compliance

Observation

2.3 Where abatement infrastructure is installed, is it adequately maintained and operated?

Not Applicable 6.3.3


Question 2.2 refers.


3. Waste Acceptance Procedures / LoW Codes


Non Compliance

Observation

3.1 Were all practices and documentation in relation to waste acceptance and characterisation for waste entering and leaving the facility satisfactory?

No 11.10 Yes


The waste acceptance record for the civic amenity site does not record the List of Waste (LoW) code.

Corrective Action:

The licensee shall ensure that all waste accepted on-site and sent off-site for disposal / recovery is assigned an LoW code and that it will be recorded.


4. Waste Handling


Non Compliance

Observation

4.1 Are all containers, including waste and fuel tanks and drums, labelled to clearly indicate their contents?

No 8.5 Yes


Some of the waste storage bays in the civic amenity site were unlabelled, photograph IMG_0008 refers.

Corrective Action:

The licensee shall ensure that all waste is clearly labelled.


Non Compliance

Observation

4.2 Is all waste stored appropriately and in designated areas according to a Waste Storage Plan, and protected as may be appropriate against spillage and contaminated run-off?

No 3.12.2, 8.5 Yes


In the main site area there were batteries and drums of grease stored inappropriately and outside of bunded areas, photographs IMG_0011 and IMG_0019 refers.

Corrective Action:

The licensee shall ensure that all hazardous waste and fuels are only stored in appropriately bunded locations on the site.


5. Site Specific Issues


Non Compliance

Observation

5.2 Fuel Tank Checked 3.12.2, 6.4.3 Yes


A double skinned fuel tank on the main site is unbunded with no method of leak detection on the tank.

Corrective Action:

The licensee shall ensure that fuels are only stored in appropriately bunded locations.


Non Compliance

Observation

5.1 Waste Electrical and Electronic Equipment (WEEE) Storage

Checked Yes


WEEE was stored uncovered in the civic amenity site, photograph IMG_0010 refers. Section 21 and Schedule 8 of S.I No. 149 of 2014 - European Union (Waste Electrical and Electronic Equipment) Regulations 2014 states that 'sites for storage (including temporary storage) of WEEE prior to its treatment - weatherproof covering for appropriate areas'.

Corrective Action:

All WEEE on the civic amenity site shall have a weatherproof covering.


Non Compliance

Observation

5.3 Waste storage Checked 8.5 / 10.1 Yes


WEEE, tyres and other waste types were observed stored at the main site, photographs IMG_0022 and IMG_0026 to IMG_0028 refers.

This issue was previously raised in Agency site visits, SV13689 and SV14474 refers.

This is a non compliance with condition 8.5.

Corrective Action:

The licensee is reminded that due to incomplete infrastructure and lack of operational controls currently in place on the main site, no waste is to be stored on-site in any area other than the civic amenity site.

In addition, the licensee is required to identify and quantify any material on the main site arising from site activities and submit a plan on when the material will be disposed of by 26/04/2019 in accordance with condition 10.1.


Non Compliance

Observation


5.4 Waste quarantine area Checked 3.7.2 Yes


A waste quarantine area is referenced in the waste acceptance procedure for the civic amenity site but there was no waste quarantine area on site.

Corrective Action:

The licensee shall ensure that there is a waste quarantine area in the civic amenity site and that it is clearly identified.


Photographs

IMG_0008: Bays in the civic amenity not labelled

IMG_ 0011: Drums of grease stored in an unbunded area


IMG_ 0019: Batteries stored on the main site

IMG_0010: WEEE stored uncovered in the civic amenity site


IMG_0022: Soil and stone stored on the main site

IMG_0026: WEEE stored on the main site


IMG_0027: Tyres stored on the main site

IMG_0028: Bays of waste on main site


Summary

One non compliance in relation to waste storage was recorded on the day of the site visit.

In addition, seven observations were recorded which require preventative and corrective actions by the licensee.

The licensee is reminded that, due to the absence of appropriate infrastructure and operational controls in place on the main site, no waste is to be stored on the main site.

FOLLOW-UP ACTIONS

You are required to complete the instructions and actions, as outlined in this report, within the specified timeframe. Where required, you shall respond to actions specified in Compliance Investigations within the required timeframe.The licensee shall maintain documentary evidence, for review by the EPA, that the prescribed corrective actions were completed within the required timeframe.

(i) Compliance Investigations

You are not required to respond directly to items contained in this EPA site visit report; where an issue requires a direct response, the EPA will generate a Compliance Investigation through the EDEN system. You will receive notification when a Compliance Investigation instruction or action is generated.

(ii) Publication of reports and licensee response.

Please note that this Site Visit Report will be made available for public viewing via the EPA’s Licence Enforcement Access Portal within one day of the issue date and will be published on the Licence Details Page of the EPA’s website, www.epa.ie, that relates to your licence 60 calendar days after the issue date.

You may if you choose submit, within 45 calendar days of the issue date of this Site Visit Report, a Licensee Public Response that will be published alongside the Site Visit Report. This Response, should you wish to avail of it, provides you with an opportunity to inform the public about how you are implementing the actions set out in the report, activities underway, timescales and target completion dates. Please be aware that the content of your Licensee Public Response must be factual and should not breach the EPAs stated online publication standards.

If you wish to submit a Licensee Public Response to an EPA Site Visit Report, you should do this by clicking on the ‘Make a Response’ link on the Site Visits page in EDEN. A .pdf document containing your response can be attached and submitted from here.

(iii) Response to Site visit report

Where you do wish to respond directly to a site visit report, you should do this by generating a ‘Licensee Return’ of the type ‘Site Updates/Notifications’ and the sub-type ‘Response to EPA Report’ in EDEN.

Please note that you are required to comply with the conditions of your licence at all times, and where noncompliance occurs you must restore compliance within the shortest possible time. These actions will be verified during subsequent EPA visits.

Please quote the above Inspection Reference Number in any future correspondence in relation to this Report.


http://www.epa.ie/