Site Visit Report - Environmental Protection Agency · Site Visit Report The site visit ... • Storm water emission points (SWEP 2, SWEP 4, SWEP 5 and SWEP 6) • Receiving water€monitoring

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 Kerry Ingredients (Ireland) Limited (Charleville)

Licensee Kerry Ingredients (Ireland) Limited

Licence Register No. P0386-03

CRO Number 206782

Site Address Rathgoggan Middle, Charleville, Cork

Site Visit Reference No. SV11102

Report Detail

Issue Date 12/04/2017

Prepared By Michelle O'Driscoll

Site Visit Detail

Date Of Inspection 16/02/2017 Announced Yes

Time In 09:50 Time Out 14:05

Agency Personnel On Site Michelle O'Driscoll

Licensee Personnel and Role Teresa Fitzgerald - Environmental Manager

Photo Taken Yes Samples Taken No Video Taken No

Site Visit Report - SV11102 - Kerry Ingredients (Ireland) Limited Page 1 of 14

Scope

This announced planned site inspection was undertaken as part of the EPA's enforcement inspection programme for the Food and Drink sector in 2017.

Media

The media inspected on site was:

• Ground• Water• Air

Site Areas Inspected

The following areas were inspected as part of the site inspection:

• Storm water emission points (SWEP 2, SWEP 4, SWEP 5 and SWEP 6)• Receiving water monitoring points (ASW 3, ASW 4, ASW 5, ASW 6 and ASW7)• IBC chemical store yard• Middle Yard• Process cheese area• Scrap yard• Waste Water Treatment Plant and SCADA system• General yard area

Documents Inspected

The following documentation were viewed on site:

• EMS Compliance Monitoring Schedule 2017• Daily and Monthly Ambient Surface Quality monitoring (ASW3, ASW4, ASW5, ASW6 and ASW7)• SF22 Organic waste register -farm code 110 (23rd and 24th January 2017)• Odour Management Plan-Sept 2016• SF45 Integrity Test Register Rev 2 - Electronic version• Bund Liquid Retention Test Certificate - March 2016 (IBC mobile bund tests - MB01, MB02, MB09, MB10,

MB11)• Bund Liquid Retention Test Certificate - March 2016 (Chemical store unit-CS1, CS2, CS3 and CS4)• Effluent emissions trends 2016 for the relevant parameters outlined in the licence. (Electronic version)• Noise Monitoring Report Oct 2016 (draft)


1. Health and Safety

Answer Condition Number

Non Compliance

Observation

1.1 Was safe and permanent access to sampling/monitoring points provided?

Yes 3.5 Yes

Comment / Corrective Action

Emission points SWEP 02 and ASW 5 and ASW 6 were not labelled.

Corrective Action:

The licensee shall re-instate the signs as soon as possible.


2. Effluent Emission


Non Compliance

Observation

2.1 Are Licensee effluent quality test results compliant with respect to previous six months?

Yes Condition 5.1 and Schedule

B2


The trend analysis for the following parameters (Ortho P, OFG, Total N, Total P, OFG, Ammonia, Suspended Solids, pH, COD, Temp and max flow/hour) were viewed on site. All effluent analysis results for the previous 12 months were compliant.


3. Odour Management


Non Compliance

Observation

3.1 Has the installation been free of odour complaints (apart from those forwarded by the EPA ) this year? (Record number of complaints).

Yes 5.2 Yes


The installation was free of odour complaints in the previous year. During the site inspection the inspector got a very strong odour while passing a chemical store unit between the boiler house area and the CHP plant. The unit contained 2xIBCs of LQ94 and 1xIBC of Divosan Forte VT6, the bund underneath the IBC's contained a liquid with, what resembled, white foam on top (refer photo 5). The Inspector considered that some chemical material had entered the bund. The odour was extremely strong and it was not possible to remain in the area to investigate further. Divosan Forte is an oxidising agent and environmentally hazardous, care should be taken when disposing of the bund liquid in particular if it is being directed to the waste water treatment plant.

Corrective Action:

The licensee shall investigate the fugitive odour emission at this point. The liquid in the bund needs to be removed and disposed of appropriately. The licensee shall ensure the integrity of the bund has not been corroded or compromised by this leak / emission.


Non Compliance

Observation

3.2 Has the licensee carried out any odour assessments this year?

No


Non Compliance

Observation

3.3 Has the licensee an odour management plan and is it being implemented?

Yes


The licensee completed an Odour Management Plan in Sept 2016, following a recommendation from the previous site inspection carried out by the EPA. OES have completed the plan and it references the guidelines issued by the EPA - AG5.


4. Noise Management


Non Compliance

Observation

4.1 Has the installation been free of noise complaints (apart from those forwarded by the EPA ) this year?

Yes 4.5, 6.14


Non Compliance

Observation

4.2 Has the licensee carried out noise monitoring this year? ( If yes, was the noise monitoring compliant according to the licensee?)

Yes 6.14


Annual noise monitoring is a requirement at a number of Noise Sensitive Locations (NSLs) in the vicinity of the Kerry Ingredients facility at Charleville. In accordance with the requirements of Condition 4.5 the licensee is required to comply with specified daytime (55 dB) and nightime (45 dB) emission limits stipulated in Schedule B4 of the licence.

A noise monitoring survey was carried out at the facility (10th and 11th October 2016) and it was noted that the day-time, evening and night-time limit values were exceeded on a number of occasions. This was a non-compliance with condition 4.5.

These exceedances were addressed in a separate EPA correspondence under non-compliance NC007307 issued in Oct 2016.


Non Compliance

Observation

4.3 If the noise monitoring was non-compliant was this reported to the Agency as an incident?

Yes


Non Compliance

Observation

4.4 If there were noise complaints in relation to the facility in 2017 has the licensee identified the likely causes?

Yes



The site is currently working on a Noise Attenuation Plan. The following list provides an update of what has been completed and new target dates set:

• Reconfigure air compressor ducting and removal of exhaust louvre in wall facing road - completed April 2016

• Air compressor door-system is currently manual, add motor and control panel - this date has been extended from Sept 2016 to March 2017

• Processed Cheese CIP pumps - Fabricate and fit enclosure to contain noise generated - December 2016 was the original timeline, this has now been linked with the air compressor doors and will be completed at the same time, due date March 2017.

• Refrigerated Trucks - create spec for trailer providers, issue non conformances - 2 companies supply refrigerated trucks. There were noise issues with one supplier and they have recently been replaced with a new supplier. The licensee will await full production to see if the different supplier has made a difference and reduce the noise generated by the refrigerated trucks.

• Elimination of air leak on Dryer 1C Heat recovery CIP bypass- complete Jan 2017• Fitting acoustic enclosures to three fans on the roof of Dryer 1C - currently being completed.• Fitting noise attenuation measures to Dryer 1C Main Stack - currently being completed.


Non Compliance

Observation

4.5 Did the licensee take corrective/preventive action to resolve any noise issues?

Yes


Refer to the Noise Attenuation Plan outlined in section 4.4 above.


Non Compliance

Observation

4.6 Does the licensee have a noise reduction plan in place?

Yes


Refer to the Noise Attenuation Plan outlined in section 4.4 above.


5. Surface Water / Groundwater Protection


Non Compliance

Observation

5.1 Are bunds, tanks, pipelines & containment structures integrity assessed as required by the licence?

Yes 6.10


The licensee has an electronic "Integrity Test Register" which has all the bunds requiring integrity testing listed. All bunds which are required to be re-tested in 2017 are highlighted.

The following bunds were reviewed in the previous 12 months:

• IBC (Mobile bunds): MB01, MB02, MB09, MB10 and MB11 (March 2016)• Chemical Store Unit : CS1, CS2, CS3 and CS4 (March 2016)• Niro 1 : March 2016

The drains in the middle yard, powder stores and milk intake are due for inspection this year and testing was completed in Jan '17. The completed tests identified some fails and repairs are currently underway. The drains will be re-tested following the repairs and reported accordingly in the AER.


Non Compliance

Observation

5.2 Is there a corresponding integrity test report that documents repairs of defects to bunds, tanks, pipelines & containment structures?

Yes 6.10 Yes


CS1 bund report had a recommendation : Sections of the steel frame housing to the spill trays is corroded and consideration should be given to cleaning down the steel and re-painting.

Corrective Action:

The licensee shall complete the recommendation in the Bund Report for CS1.


6. Site Specific Issues


Non Compliance

Observation

6.1 Tank, Container and Drum Storage Area including bunds.

Checked 3.6 Yes


During the site inspection there was liquid present in some of the bunds. Routine monitoring of the bunds should be established and the bunds routinely emptied of rainwater as required. During the site inspection it was noted that there was liquid present in the following bunds: caustic tank bund in the process cheese area, the Microcan bund, plastic bunds in the liquid intake area.

It was noted during the site inspection that there was an unbunded IBC containing oil in the boiler house. The licensee stated during the inspection that a bund would be provided for this IBC. Maintenance was been carried out in this area and the IBC is not routinely there.

Care should be taken when selecting bunds and ensuring that they are compatible with the liquid which is being held in the respective tank. The metal bund used for caustic and acid by the liquid intake area was corroded through, and the chemicals further corroded the yard surface (refer photo 1). These metal bunds have since been replaced with plastic bunds (refer photo 1). The plastic bunds in this area are not currently in use however please note it is good practice to store the pipework inside the bunds.

It was noted during the site inspection in the skim milk area that there appeared to have been an uncontrolled release as there was red staining and a pathway had been corroded from a vent pipe into the concrete to the foul drain (refer Photo 2&3). Subsequent to the site inspection, the inspector phoned the licensee on the 07/03/17 to query floor area of the skim milk zone as it is also an unbunded area. The licensee said there was no uncontrolled release and that it is rust staining from metal and that the drain goes to the WWTP.

Observation:

The licensee shall monitor the condition of bunds and ensure that the capacity of the bunds is not being compromised by rainwater.

The licensee shall investigate what is causing the red staining and the corrosion of the concrete and look at maintaining the integrity of the floor surface in the skim milk area.


Non Compliance

Observation

6.2 Waste Management Checked


The scrap yard was full of waste material including tanks / sheeting, pipework and containers and generally untidy in nature. It needs to be tidied up and items which are no longer required should be recovered or disposed of appropriately.

There are empty IBC's in the chemical store area which are unsightly and no longer required. It is good practice to move off waste as soon as practicable, some IBC's are missing drip caps so liquid has dripped out of the IBC which can affect the integrity of the IBC and the yard area.


Summary

This was an announced site inspection. There has been a lot of progress made in the last year on the noise attenuation plan. An odour management plan was completed on foot of the previous site inspection. The WWTP proposed works were outlined as part of the site inspection. All monitoring records requested were well organised and readily available. An area requiring attention would be bund management, ensuring bunds supplied are suitable to contain the liquids intended. The licensee should also ensure that rainwater is not reducing the capacity of the bunds as required in an emergency situation. The skim milk yard area needs to be repaired and the source of the corrosion identified and relevant control measures put in place.

Finally the inspector would like to thank the licensee's representative for her time during the site inspection.

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/

Photographs

Site Inspection: Kerry Ingredients (Ireland) Limited (Charleville)

Licence Reg No.: P0386-03

Date: 16/02/17

Photos taken by: Michelle O Driscoll

Photo 1 (ref: 20170216_105549): Picture shows plastic bunds currently not in use for

the Acid and Caustic, pipework lying on the ground, end of pipe (white) should be in the

bund.

Photo 2 (ref: 20170216_105714): Photo shows the Acid after corroding the concrete

originally underneath the metal bund.


Photo 3 (ref: 20170216_110615) showing the rusted pathway generated by unknown

substance.

Photo 4: (ref 20170216_110633) showing the corroded pathway created by unknown

substance.

Photo 5 (ref: 20170216_111329): bund underneath the Divosan Forte VT 6 containing a

lot of liquid.


Photo 6 (ref: 20170216_104455): Waste IBC’s in the chemical storage area, need to be

disposed of.

Photo 7 (ref: 20170216_110631): Pipes/hoses located in an unbunded area (skim milk).


Photo 8 (ref: 20170216_110647): Vent pipe in skim milk area in an unbunded area

(skim milk). There is a clear pathway from this point to the foul drain.
