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

Size: px
Start display at page:

Download "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 Martin Jennings Wholesale Limited Martin Jennings Wholesale Limited Licence Register No. P CRO Site Address Site Visit Reference No. Knockfereen, Neale Road, Ballinrobe, Mayo SV09384 Report Detail Issue Date 26/05/2016 Prepared By Helen Boyce Site Visit Detail Date Of Inspection 19/05/2016 Announced No Time In 14:10 Time Out 16:50 Agency Personnel On Site Licensee Personnel and Role Helen Boyce Annette Jordan John Lynn, Quality Manager Colm Kennedy, Environmental Officer John Vaughan, Managing Director Photo Taken Yes Samples Taken No Video Taken No Site Visit Report - SV Martin Jennings Wholesale Limited Page 1 of 11

2 Scope The scope of the site visit was to carry out a routine inspection in accordance with the 2016 OEE Enforcement Plan. Media Items inspected related to the following media: air water/sewer soil/ground Site Areas Inspected Site areas inspected were as follows: waste water treatment plant bunded chemical store blood tank (overground) area where various streams exit from the kill line, e.g. belly grass, stomachs, etc. hard standing of yard Documents Inspected Documents inspected were as follows: GW1 monitoring results of 11/12/2015 SE-2 discharge to sewer monitoring results (past 6 months) Odour assessment records Emergency Response Procedure SOP 40 Odour Management SOP 44 Waste water treatment plant Security Check Sheet Noise monitoring records Bund testing reports Site Visit Report - SV Martin Jennings Wholesale Limited Page 2 of 11

3 1. Health and Safety 1.1 Did the licensee make you aware of any site specific health and safety issues? No 1.2 Was safe and permanent access to sampling/monitoring points provided? Yes 3.6 Sampling point SE-2 was inspected and there were no issues in relation to safe and permanent access. Site Visit Report - SV Martin Jennings Wholesale Limited Page 3 of 11

4 2. Effluent Emission 2.1 Are Licensee effluent quality test results compliant with respect to previous six months? Yes 5.1 Monitoring results for samples of the discharge to sewer from emission point SE-2 were reviewed for the past 6 months. There were no non-compliances with the emission limit values and monitoring was carried out in accordance with the schedule specified in the licence. It was noted that the Licensee had checked to ensure that the laboratory used (ASL) is accredited for each of the relevant parameters however there was no documentary evidence of this at the site inspection. It was recommended that a letter/ of confirmation is received from the lab to demonstrate that all relevant parameters are accredited. It was noted at the composite sampler, that the glass bottle for collection of the composite samples was a little dirty and it was recommended that it be cleaned. It was also recommended that when this bottle is being replaced, that it be replaced with a larger bottle to ensure that there will be at least 2 litres available for EPA sample requirements as well as that required by the Licensee for compliance monitoring. 2.2 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(i) -compliant results did not occur within the past 6 months therefore there was no requirement for incident notification. 2.3 Did the licensee take corrective/preventive action to resolve any likely causes of noncompliant effluent emissions? Not Applicable As there were no non-compliant effluent emissions, corrective/preventative actions were not required. Site Visit Report - SV Martin Jennings Wholesale Limited Page 4 of 11

5 3. Odour Management 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 There have been no odour complaints about this facility since Has the licensee carried out any odour assessments this year? Yes Yes Daily odour assessments are carried out by staff at the site. The time of the assessments are varied each day and the security officer carries out an odour survey at the facility each night. It was recommended that odour surveys only be carried out by people who are going in to the facility and not by staff who are leaving the facility as they may be de-sensitised to any odour from the facility. 3.3 Has the licensee a satisfactory odour management plan? Yes 5.7 SOP 40 Odour Management procedure was reviewed and was considered satisfactory. Items included were as follows: Skips kept covered Skips emptied daily Skip washings fed into the Cat 1 trailer and skips washed from the top down Yards washed daily Hides and skins removed daily Pet food materials stored in a designated refrigerator Bins closed at all times and collected twice weekly. Site Visit Report - SV Martin Jennings Wholesale Limited Page 5 of 11

6 4. Operational control of wastewater treatment plants 4.1 Is there an SOP or manual in place that covers out-of-hours supervision on the WWTP? Yes SOP 44 Waste Water Treatment Plant (issued 12/05/2015) was reviewed and was considered satisfactory. At night, a security guard carries out checks on the waste water treatment plant as per the checklist provided on the Security Check Sheet. SOP 44 includes a photo of the display panel at the WWTP so it is clear what each button relates to and what security personnel need to look for. Contact details for the Environmental Manager and other relevant staff are also included in the event of an incident. It was noted that the Environmental Manager and the Managing Director are often on site in evenings and weekends and they would also check on the operation of the WWTP. Site Visit Report - SV Martin Jennings Wholesale Limited Page 6 of 11

7 5. Noise Management 5.1 Has the installation been free of noise complaints (apart from those forwarded by the EPA ) this year? Yes 5.2, 4.3 There have been no noise complaints. 5.2 Has the licensee carried out noise monitoring this year? ( If yes, was the noise monitoring compliant according to the licensee?) No 6.1, 6.14 Noise monitoring has not yet been carried out in 2016 however it was carried out in November 2015 by Panther Environmental. The report confirmed that there were no tonal or impulsive elements to the noise from the facility and the monitoring results were compliant with the emission limits specified in the licence at the two noise sensitive locations. 5.3 Does the licensee have a noise reduction plan in place? Yes Noise reduction actions carried out on site as part of the noise reduction plan include the connection of refrigerated units to electricity when on site rather than running on diesel engines. Site Visit Report - SV Martin Jennings Wholesale Limited Page 7 of 11

8 6. Surface Water / Groundwater Protection 6.1 Are bunds, tanks, pipelines & containment structures integrity assessed as required by the licence? No 6.9 Yes The chemical store bund was integrity tested in 2013 and the drainage network was surveyed using CCTV in 2015 however the underground blood tank was not integrity tested. It was noted however, that any losses from the underground blood tank would be noted via a reduction in the quantity of blood being removed offsite. 6.9 of Licence P requires that all underground pipes, tanks, bunding structures and containers should be tested for integrity and water tightness at least once every three years. The Licensee is required to ensure compliance with the above licence condition. For future testing, please refer to Bund test results should be recorded using the template provided by the EPA Bund test templates: als.html. 6.2 Is there a report confirming that any bunds, tanks, pipelines & containment structures integrity defects are repaired? Checked Yes The pipeline carrying treated effluent to the sewer network was found to have tree root ingress when the CCTV survey of the drainage system was completed in It was confirmed on site that this section of pipeline was repaired. It is recommended that future survey reports provided to EPA or maintained on site for inspection contain a concise summary detailing what was inspected, the results of the inspection, identification of requirements for repair/replacement and the urgency of same. A brief report demonstrating when repairs have been completed should also be maintained on site for review. Site Visit Report - SV Martin Jennings Wholesale Limited Page 8 of 11

9 7. Site Specific Issues 7.1 Hard standing at the facility Checked Yes Maintenance of the hard standing/impermeable surface in the yard was discussed at the site inspection. It was noted that a defect in the yard at the rear of the plant had been repaired in follow up to the previous site inspection however other areas were noted at this inspection which may require repair - see photos 1 and 2 in Appendix 1. The Licensee should ensure that the concrete surface of the yard is maintained to ensure that there is no risk of soil or groundwater contamination beneath the site. A documented Maintenance Programme should be in place for maintaining the integrity of the hard standing of the yard. Site Visit Report - SV Martin Jennings Wholesale Limited Page 9 of 11

10 Summary Overall, environmental management at this facility was very good. Practices are in place to minimise the potential for odour nuisance and the facility is well maintained. There was one non-compliance raised in relation to integrity testing of the underground blood tank as this had not been completed as per the licence requirements. The licensee noted that this would be addressed without delay. 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 Martin Jennings Wholesale Limited Page 10 of 11

11 Appendix 1 - Photos Photo 1: Bloody water accumulating along joints and cracks in the concrete surface of the yard. Photo 2: Cracks noted in the concrete surface of the yard and concrete worn down to the rebar. Site Visit Report - SV Martin Jennings Wholesale Limited Page 11 of 11