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

Transcription

1 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 Licensee Lakeland Dairies Co-operative Society Limited (Castleblaney) Lakeland Dairies Co-operative Society Limited Licence Register No. P CRO Site Address Site Visit Reference No. Lough Egish, Tullynahinera, Castleblaney, Monaghan SV08420 Report Detail Issue Date 14/11/2016 Prepared By Marie Hogan Site Visit Detail Date Of Inspection 14/10/2016 Announced No Time In 10:28 Time Out 15:30 Agency Personnel On Site Licensee Personnel and Role Thomas Sexton Marie Hogan Colin Finnegan, Environmental Officer Photo Taken No Samples Taken No Video Taken No Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 1 of 17

2 Scope The purpose of the site visit was to evaluate the licensee's performance in addressing the requirements of the following: Environmental Protection Agency (EPA) 2016 Food and Drink sectoral priorities Industrial Emissions Licence (IEL) P Waste Management (Use of Sewage Sludge in Agriculture) Regulations, 1998 to 2001 Department of the Environment and Local Government's 'Codes of Good Practice for the use of Biosolids in Agriculture'. Media The following media was inspected at the time of the site visit: Waste water effluent Organic waste (waste water treatment plant sludge) Storm water Air Site Areas Inspected The following site areas were inspected at the time of the site visit: Licensed effluent emission point Ref. No. SW-4 Waste water treatment plant (WWTP) WWTP sludge treatment and storage area WWTP control room Documents Inspected The following documents were inspected at the time of the site visit: : Emergency Response Procedure training record - dated 20/06/ : Site induction and training procedure - covers out-of-hours supervision on the WWTP - dated 01/04/ : WWTP preventative maintenance records : WWTP operational control & monitoring records : Process drainage CCTV survey report, C&N Fay Environmental - dated 25/02/ : Foul Line CCTV survey report, McBreen Environmental - dated 24/07/ : Bund Register : Annual environmental noise survey - dated 28/11/ : Emergency Response Procedures - dated 01/05/ (iv): Emissions monitoring results (iv): Ambient monitoring results - Lough Egish Water Sampling - September (iv): Ambient monitoring results - Lough Egish Sediment Sampling - December (iv): Calibration records for effluent monitoring equipment (vi): Site drawings showing key process and environmental infrastructure 11.6 (vii): Effluent Plant Operation Manual - dated 06/02/ : Waste acceptance records Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 2 of 17

3 1. Licensee Monitoring 1.1 Has the integrity of pipelines (overground and underground) been found to be satisfactory? No 6.9 Yes A CCTV Survey Report by C&N Fay Environmental (issued 25/02/2015) identified 'defect grade description No.5' deformities at locations 'MH19', 'Sump15', and 'MH26' in the on-site foul/process pipeline system and indicated that these locations have collapsed or that collapse is imminent. The same report identified 'defect grade description No.4' deformities in locations 'MH3' and 'MH25' and indicated that collapse was likely in the foreseeable future at these locations. A CCTV Survey Report by McBreen Environmental (issued 24/07/2014) identified Grade 4 deformities at locations 'F3', 'F4', 'FGully', 'F12', 'F11' and 'F10'. During the site visit it was noted that the licensee failed to maintain a written record to demonstrate that any maintenance or remedial works arising from these reports have been conducted and that the underground pipes have been retested as of the date of inspection, October The licensee shall comply with 6.9 of the licence and, having regard to the Agency's guidelines on 'Storage and Transfer of Materials for Scheduled Activities' (2004), ensure that required maintenance or remedial works are completed. Testing should be repeated so as to confirm the repairs have been successful and a written record of all works should be maintained on-site at all reasonable times for inspection by Agency personnel. Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 3 of 17

4 2. Effluent Emission 2.1 Are Licensee effluent quality test results compliant with respect to previous six months? Yes Where non-compliant exceedances occurred, were they notified as incidents as per Agency guidance and the licence conditions? If no, provide details relating to the exceedances. Not Applicable 11.1 / 2A of Industrial Emissions Directive Amendment 2.3 If there were non-compliant effluent results in relation to the facility in the previous six months has the licensee identified the likely causes? Not Applicable (i) 2.4 Are all continuous meters at the final effluent discharge monitoring point as required by the licence operational? (record any meter not operational inadditional answer) Yes Did the licensee take corrective/preventive action to resolve any likely causes of noncompliant effluent emissions? Not Applicable Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 4 of 17

5 3. Emergency Response Procedure (ERP) 3.1 Have relevant staff been made aware of and have been trained on the ERP in the last 3 years? No Yes It was noted during the inspection that the last record of staff having been trained on the Emergency Response Procedure (ERP) was in June The licensee shall comply with of the licence and ensure that procedures are in place for identifying training needs, and for providing appropriate training, for all personnel whose work can have a significant effect on the environment. Given the lengthy period since the last training was provided and considering that changes in staff may have occurred in the meantime, the licensee shall provide refresher training to all relevant staff on the ERP. Appropriate records of training shall be maintained. Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 5 of 17

6 4. Storm Water 4.1 Are the surface water monitoring results satisfactory for the previous six months? Yes Schedule C Is there a record of the storm water visual inspections being maintained? Not Applicable N/A 4.3 Have Trigger Levels been established for the storm water monitoring parameters? Yes Yes The licensee has revised the trigger levels for conductivity and turbidity at storm water discharge point SW- 2 without the agreement of the Agency. The licensee shall comply with of the licence and, using up-to-date data which reflects the current level of activity on site, reassess the continuous monitoring data for conductivity and turbidity for the process lines discharging to the currently existing storm water discharge point SW-2, and revise the trigger levels. The licensee shall have regard to the 'Guidance on the setting of trigger level values for storm water discharges to off-site surface waters at EPA IPPC and Waste Licensed Facilities' published by the Office of Environmental Enforcement during this assessment and shall submit the revised trigger levels to the Agency for agreement as a 'Request For Approval' through EDEN. 4.4 Are silt traps and/or oil separators/interceptors installed on the surface water drainage system as required by the licence? Not Checked Are there up-to-date site drainage drawings of appropriate scale available? Yes 11.6 (vi) Yes Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 6 of 17

7 It was indicated by the licensee during the inspection that works are to be carried out to relocate the monitoring location for SW-2 in order to more accurately reflect surface water drainage from the site. The licensee is reminded to comply with 11.6 (vi) of the licence and, following completion of the intended works, ensure that site drawing/plans are updated to reflect the relocation of any environmental infrastructure. These drawings/plans must be maintained on-site. Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 7 of 17

8 5. Odour Management 5.1 Has the installation been free of odour complaints (apart from those forwarded by the EPA ) this year? (Record number of complaints). Yes Has the licensee carried out any odour assessments this year? No N/A 5.3 Were non-compliant odour assessments reported as incidents to the Agency? Not Applicable 11.1 (ii) 5.4 If there were odour complaints in relation to the facility in 2016 has the licensee identified the likely causes? Not Applicable (i) 5.5 Did the licensee take corrective/ preventive action to resolve any odour issues? Not Applicable Has the licensee a satisfactory odour management plan? No 5.5 Yes Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 8 of 17

9 No odour management plan has been prepared for the site since that which was submitted as part of the original licence application for P in The licensee shall consider current odour control measures onsite and review the odour management plan accordingly. This plan should include odour reduction measures appropriate for the site and should be reviewed annually. A report on the programme, including the success in meeting odour reduction on site, shall be prepared and submitted to the Agency as part of the AER. Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 9 of 17

10 6. Operational control of wastewater treatment plants 6.1 Is there an SOP or manual in place that covers out-of-hours supervision on the WWTP? Yes 11.6 (vii) The licensee maintains a Site Induction and Training Procedure which covers out-of-hours supervision on the WWTP. 6.2 Is there a preventative maintenance programme in place for the WWTP? Checked / Schedule C.2.1 The licensee has a contract in place with FM Environmental who carry out preventative maintenance on the WWTP. 6.3 Are WWTP operational control and monitoring records being reviewed by the Environmental Manager on a regular basis? (Note frequency) Yes The Environmental Manager reviews the WWTP operational control and monitoring records on a daily basis. 6.4 Is the retention capacity of the balance tank adequate to ensure a steady flow rate to the treatment processes? (Note capacity in days) Checked N/A 6.5 Is there a documented procedure in place for responding to high level alarms? Yes 3.9 Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 10 of 17

11 6.6 Is there a SCADA system in place in relation to operation and control at the WWTP? Yes N/A 6.7 Are high level alarms in place on the balance tank and aeration tank? Yes 3.9 Yes It was noted during the inspection that there is a high level alarm in place on the balance tank. The licensee is required to carry out a risk assessment to determine the need to install high level alarms on any remaining plant chambers from which spillage of environmentally significant materials might occur, and shall install such alarms if deemed to be required. 6.8 If yes are the high level alarms operational? Yes 6.3 The licensee monitors high level alarms through the SCADA system and they appeared to be operational at the time of the visit. 6.9 Is the area around the WWTP free from any evidence of spillages, leakage, ponding or overflow? If answer to the question is no, were these notified to the Agency as incidents? Yes 11.1 (iv) Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 11 of 17

12 7. Noise Management 7.1 Has the installation been free of noise complaints (apart from those forwarded by the EPA ) this year? Yes Has the licensee carried out noise monitoring this year? ( If yes, was the noise monitoring compliant according to the licensee?) Yes The licensee contracted Axis Environmental Services to carry out an Annual Environmental Noise Survey in November The resulting report, issued on the 28/11/2015, found that noise emissions from the installation were compliant and that there was no clearly audible tonal or impulsive components in the noise emission from the activity at any noise-sensitive locations. 7.3 If the noise monitoring was non-compliant was this reported to the Agency as an incident? Not Applicable 11.1 (ii) 7.4 If there were noise complaints in relation to the facility in 2016 has the licensee identified the likely causes? Not Applicable (i) 7.5 Did the licensee take corrective/preventive action to resolve any noise issues? Not Applicable Does the licensee have a noise reduction plan in place? Checked Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 12 of 17

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14 8. Surface Water / Groundwater Protection 8.1 Are bunds, tanks, pipelines & containment structures integrity assessed as required by the licence? Checked 6.9 See Question Is there a report confirming that any bunds, tanks, pipelines & containment structures integrity defects are repaired? Checked 6.9 See Question Is the integrity of the concrete in the dirty yard areas satisfactory? Yes If the integrity of the concrete in the dirty yard areas is unsatisfactory, has the licensee established a repair programme to address defects found outlining timeframes for completion of works? Not Applicable N/A Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 14 of 17

15 9. Site Specific Issues 9.1 Trigger levels for temperature - SW-2 Checked Yes The trigger levels set by the licensee for temperature on process lines discharging to SW-2 at Lough Egish seem quite elevated (warning limit: degrees Celsius, action limit: degrees Celsius). The licensee shall carry out an impact assessment to demonstrate that the trigger levels currently set for temperature do not allow any discharge to result in a temperature increase at the edge of the mixing zone of greater that 1.5 degrees Celsius in the receiving system (see of the licence). The results of this impact assessment should be submitted to the Agency as a Licensee Return of type 'Response to EPA Report' through EDEN within two months from the issue date of this site visit report. 9.2 Odour Abatement System Maintenance Checked Yes The licensee does not maintain a programme for the maintenance of the carbon filter abatement system on the WWTP balance tank. The licensee shall comply with of the licence and maintain a programme for the maintenance of the carbon filter abatement system, and any ancillary equipment, to ensure it's effectiveness in the abatement of odours. This programme shall have regard for any instructions issued by the manufacturer/supplier or installer of the equipment, and shall be maintained onsite. 9.3 WWTP Sludge Management Checked Yes Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 15 of 17

16 The licensee is permitted to accept and treat a maximum of 500 m3 per day of process effluent from specified external sources in the onsite WWTP. This treatment includes the dewatering and lime stabilisation of the resulting organic waste (WWTP sludge) prior to storage or landspreading. The licensee is required to confirm: 1) how the treatment of WWTP sludge onsite meets the requirements of the Waste Management (Use of Sewage Sludge in Agriculture) Regulations, 1998 to 2001 and the recommended treatment process conditions outlined in the then Department of the Environment and Local Government's 'Codes of Good Practice for the use of Biosolids in Agriculture'. 2) the approximate percentage of the total effluent treated onsite that is from domestic/sanitary sources. Please revert to the Agency with this information by Licensee Return of type 'Response to EPA Report' through EDEN within two months from the issue date of this site visit report. Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 16 of 17

17 Summary Three non-compliances were recorded in relation to the following: integrity testing and maintenance of underground pipelines; setting of trigger levels on process water lines discharging to surface waters; maintenance of the odour abatement system. Six observations were also recorded, in particular one regarding the licensee's compliance with the Waste Management (Use of Sewage Sludge in Agriculture) Regulations, 1998 to 2001 and the then Department of the Environment and Local Government's 'Codes of Good Practice for the use of Biosolids in Agriculture'. The licensee is required to submit further information in relation to this observation to the Agency for consideration. The licensee shall address all corrective actions specified in this report. 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 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. 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 Investigation through the EDEN system. You will receive notification when a Investigation instruction or action is generated. 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, 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. 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 in any future correspondence in relation to this Report. Site Visit Report - SV Lakeland Dairies Co-operative Society Limited Page 17 of 17