Site Visit Report · The purpose of the site visit was to investigate the discharges from the installation to the Sanitary Authority sewer and€observe the CCTV surveying of parts

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 Rosderra Irish Meats Group (Edenderry)

Licensee Rosderra Irish Meats Group

Licence Register No. P0180-02

CRO Number 452340

Site Address Carrick Road, Edenderry, Offaly

Site Visit Reference No. SV13680

Report Detail

Issue Date 03/11/2017

Prepared By Dermot Burke

Site Visit Detail

Date Of Inspection 03/10/2017 Announced Yes

Time In 09:30 Time Out 16:10

Agency Personnel On Site Dermot Burke

Cormac MacGearailt

Licensee Personnel and Role Niall Leydon - Company DirectorJimmy O'Connor - Group Technical ManagerSeamus Ryan - Operations ManagerJohn O'Connor - Environmental ManagerIggy Daly - Maintenance ManagerRepresentatives of Meehan Underground Survey and Technology Ltd.

Photo Taken Yes Samples Taken Yes Video Taken No

Odour Assessment Yes Odour Assessment Compliant Yes

Site Visit Report - SV13680 - Rosderra Irish Meats Group Page 1 of 18

Scope

The purpose of the site visit was to investigate the discharges from the installation to the Sanitary Authority sewer and observe the CCTV surveying of parts of the foul water pipeline network on-site and the treated effluent pipeline from the on-site wastewater treatment plant (WWTP) discharge point SE-1 to the connection to the foul water pipeline network.

The EPA obtained a sample from the licensee's composite sampler at licence discharge point SE-1 and a grab sample of the effluent discharge at SE-1 was also obtained. A split sample was given to the licensee to analyse.

The EPA also obtained a composite sample of the discharge to the Sanitary Authority sewer from Offaly County Council's composite sampler, which is located on the licensed site downstream from the licence emission to sewer monitoring location SE-1. The discharge to the sewer at this point is a mixture of the treated effluent from the licensee's on-site WWTP, which treats the trade effluent from the factory, and the untreated foul effluent from the factory, which consists of effluent from the factory toilets and welfare facilities.

Prior to going on-site, the EPA's Inspector conducted an odour assessment of the environs of the installation.

During the course of the site visit a meeting was held with Niall Leydon, Company Director, to discuss the environmental issues in relation to wastewater, noise, odour and storm water emissions from the installation.

Media

On-site inspections concerned the following environmental media:

• Water• Air

Site Areas Inspected

The following areas were inspected during the course of the site visit:

• On-site WWTP• Foul water pipeline network• Treated effluent pipeline from the WWTP discharge point SE-1 to the connection to the foul water pipeline

network• Cat 2/3 animal by-product for rendering storage shed• Refrigeration plant

Documents Inspected

The following documents were inspected during the course of the site visit:

• Facility WWTP Flow monitoring data- December 2016-August 2017• Animal Kill Rates- January to September 2017


1. Site Specific Issues

Answer Condition Number

Non Compliance

Observation

1.1 Unloading of materials in designated areas protected against spillage and leachate run-off

Checked 8.5 Yes

Comment / Corrective Action

The EPA's Inspector observed the following with respect to the loading, unloading and transfer of materials (See Appendix - Photos):

• Liquid was observed leaking from a waste compactor located adjacent to the inlet sump of the onsite WWTP. The liquid flowed uncontrolled across the concrete yard area and discharged to the inlet sump chamber of the WWTP.

The loading and unloading of this material was not carried out in a designated area protected against spillage and leachate runoff.

This is in non-compliance with Condition 8.5 of Licence Reg. No. P0180-02.

In addition, the EPA’s Inspector observed examples of poor housekeeping practices on-site in relation to the loading, unloading and transfer of materials at the on-site WWTP, specifically:

• Liquid was observed leaking from a sludge centrifuge onto concrete hardstand in a shed at the onsite WWTP. The liquid made its way out of the shed and flowed uncontrolled across the concrete yard area and discharged to the underground inlet sump chamber.

• Blood-coloured liquid associated with the inlet sump/step screen/drum screen at the WWTP was observed flowing over the concrete hardstand and making its way uncontrolled into the inlet sump chamber.

• Sludge like material was observed on the concrete hardstand surrounding the opening of an underground sump adjacent to the sludge consolidation tank.

• Sludge like material was observed on the concrete hardstand adjacent to a gully on the base of the Dissolved Air Flotation (DAF).

The uncontrolled flow of potentially contaminated liquids onto permeable surfaces poses a risk to the generation of nuisance odours from the installation, particularly during warm weather.

These issues were previously raised as non-compliances and observations at the EPA site visits on 11/05/2017 (SV12153), 16/05/2017 (SV12186) and on 30/08/2017 (SV12510) and have not been adequately addressed.

Corrective Actions:

The licensee shall comply with Condition 8.5 of Licence Reg. No. P0180-02 and ensure that the loading and unloading of materials on-site is being carried out in designated areas protected against spillage and leachate runoff. The licensee shall address the issues detailed above without delay.


Non Compliance

Observation

1.2 CCTV surveying of underground pipelines Checked 6.8 Yes



The EPA's Inspector observed the CCTV surveying of parts of the underground trade effluent and foul water pipeline networks on-site and the treated effluent pipeline from the on-site WWTP discharge point SE-1 to the connection to the foul water pipeline network. The EPA's Inspector observed the following discrepancies with what was shown on the external and internal underground pipeline network drawings submitted to the EPA in response to CI Actions A017924 and A017987:

• A pipeline exiting the main factory building adjacent to the Pulled Pork Line shown in the internal pipeline drawing does not exist on the ground;

• A redundant pipeline going from the car park to manhole MH F3 is missing from the external pipeline drawing; and

• An additional pipeline from the old security hut at the site entrance to manhole MH F4 is missing from the external pipeline drawing.

The treated effluent pipeline from the on-site WWTP discharge point SE-1 to the connection to the foul water pipeline network at manhole MH F4 could not be fully surveyed on the day of the site visit due to liquid in the pipeline.

Corrective Actions:

The licensee shall ensure that all underground pipelines (both internal and external) are integrity tested in accordance with Condition 6.8 of the licence. This matter is being dealt with via Compliance Investigation No. CI001481.


Non Compliance

Observation

1.3 Air purification equipment in the Category 2/3 animal by-product storage shed

Checked 6.5 Yes


The EPA's Inspector viewed the 4No. air purification units installed in the Category 2/3 animal by-product storage shed on-site. This equipment was installed in the shed to treat the odourous air in the shed as a mitigation measure for this identified odour source on-site. The EPA's Inspector observed a strong noxious odour in the shed, which was observed by the EPA's Inspectors during previous site visits. The EPA's Inspector noted that one of units appeared to be unplugged and not functioning (See Appendix - Photos). The Site Maintenance Manager did not know why the air purification unit was unplugged and was unsure as to the maintenance requirements of the units.

Corrective Action:

The licensee shall ensure that treatment/abatement equipment on-site is operated and maintained in accordance with the manufacturers instructions. The Licensee shall ensure that the air purification units treating the odourous air in the Category 2/3 animal by-product storage shed are in operation at all times and any breakdown/malfunction of this air abatement equipment shall be regarded as an incident, which shall be notified to the EPA in accordance with the licence.


Non Compliance

Observation

1.4 Odour assessment Checked 5.2


An odour assessment was completed in the environs of the installation prior to the commencement of the on-site visit. No odours that gave rise to significant impairment of, or interference with amenities or the environment beyond the installation boundary were detected during the course of the odour assessment.


Non Compliance

Observation

1.5 Sewer discharge monitoring Checked 5.1



The EPA obtained a sample from the licensee's composite sampler at licence discharge point SE-1 and a grab sample of the effluent discharge at SE-1 was also obtained. A split sample was given to the licensee to analyse.

The EPA also obtained a composite sample of the discharge to the Sanitary Authority sewer from Offaly County Council's composite sampler, which is located on the licensed site downstream from the licence emission to sewer monitoring location SE-1. The discharge to the sewer at this point is a mixture of the treated effluent from the licensee's on-site WWTP, which treats the trade effluent from the factory, and the untreated foul effluent from the factory, which consists of effluent from the factory toilets and welfare facilities.

The samples were sent to the EPA laboratory in Dublin for analysis. The results of the analysis (see Appendix - Analysis Results) indicate that the discharges to the Sanitary Authority sewer were in compliance with licence emission limit values on the day of the site visit.


Appendix – Laboratory Analysis Results









Odour Assessment

________________________________________________________________

Date of odour assessment: 03/10/2017 Start time: 09:00 Finish time: 09:22

This document’s reference number: SV13680

This odour assessment was undertaken by: Dermot Burke, EPA’s Inspector

________________________________________________________________

As per the criteria stated above an odour assessment was undertaken in accordance with EPA Air

Guidance document AG5 (Odour Impact Assessment Guidance for EPA Licensed Sites).

Due to the findings of the odour assessment it is the opinion of this Inspector that the activities

occurring on the premises of Rosderra Irish Meats Group, Edenderry, Co. Offaly were not in breach

of Condition 5.2 of the installation’s IE Licence at the time of the assessment.

EPA Air Guidance document AG5 is available online at www.epa.ie


http://www.epa.ie/

Summary

The purpose of the site visit was to investigate the discharges from the installation to the Sanitary Authority sewer and observe the CCTV surveying of underground pipelines on-site.

The EPA obtained a sample of the licensee's composite sampler at licence treated effluent discharge point SE-1 and a grab sample of the discharge was also obtained. The EPA obtained a composite sample of the discharge to the Sanitary Authority sewer from Offaly County Council's composite sampler on-site, which is located on the licensed site downstream from the SE-1. The results of the analysis indicate that the discharges to the Sanitary Authority sewer were in compliance with licence emission limit values on the day of the site visit.

Prior to going on-site, an odour assessment was completed in the environs of the installation. No odours that gave rise to significant impairment of, or interference with amenities or the environment beyond the installation boundary were detected during the course of the odour assessment.

During the course of the site visit, the EPA's Inspectors met with Mr Niall Leydon, Company Director, to discuss the environmental issues in relation to wastewater, noise, odour and storm water emissions from the installation. Mr Leydon stated that he and the Board of Directors for Rosderra Irish Meats Group was one hundred percent committed to resolving the environmental issues at the site and that resources would be supplied to fix the issues.

1No. non-compliance was recorded against Condition 8.5 of Licence Reg. No.P0180-02 in relation to:

• Failure to load/unload materials in designated areas protected against spillage and leachate runoff.

2No. observations were raised that require action to be taken by the Licensee, namely:

1. Integrity test all underground pipelines in accordance with the licence.2. Ensure treatment/abatement equipment on-site is operated and maintained in accordance with the

manufacturers instructions. Also, notify the EPA of the malfunction of the air purification units in the Catrgory 2/3 animal by-product storage shed as an incident.

The EPA will follow up on these issues at future site visits.


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/

Appendix - Photos

Photo Nos. 1 to 4 Views of liquids flowing uncontrolled at on-site WWTP


Photo No. 5 to 6 Views of air purification units installed in the Category 2/3 animal by-product

storage shed and one unplugged unit.
