Carton Bros Ltd Darkely, Shercock, Co Cavan. For inspection purposes only.

Transcription

1 emion Bro$. Lilllilccl, Shcrcock. Co, Ctv,lII, Ild,lnd. 'fi:i: 042 %6 'J %91100 Ell(: u12 'J{lll OTE 31" July 2012 Ms Sonja Smith Administration Officer Office of Climate, Licensing & Resource Use Environmental Protection Agency Regional Inspectorate Inniscarra Co Cork ~ ~~q.. ~ CARTON GROUP PROCESSING Re: Carton Bros Ltd Darkely, Shercock, Co Cavan IPPC Licence Reg. No. P Dear Ms. Smith, Further to your letter dated OS'" June 2012, we would comment as follows Please provide in/ormation regarding ti,e risk assessment outcome required under condition / your current licence. In order to reduce the effect of possible generation of firewater at Carton Bros, a number of recommendations were made. It should be noted that the recommendations alone will not fully mitigate the environmental impact of firewater generated at Carton Bros, but due to the low level of risk involved, as assessed, they will ensure compliance with standard good practice. 1) All process drains to be cleared of any debris and maintained clear so as in the event of an emergency, all firewater will drain freely. Ensure that drains are maintained free of debris by undertaking regular maintenance and inspection of the drains. 2) Consideration should be given to the development of a drainage map, which will detail the location of all surface drains and the probable spill path or flow of firewater. This will aid in the rapid and effective deployment of drain covers and spill fighting equipment in the event of a release of firewater from any facility in the factory. Dih'(IOr>: 'PP,9::"", Syslcfl1 8 11ms. l~ C.UlO111 ju,>.in I. Cutnll VinUlil A. T CHlUU It.-g. Nu. 7.\ It VAT N". II In' IRl(,7S

2 3) In the event of a release of firewater to a surface water drain or a trade effluent drain, a sample of the firewater should be taken if possible and made available for in-house and independent analysis. The approximate quantity of firewater generated should also be estimated. Procedures incorporating these recommendations should be included in the relevant sections of the company's quality management system and environmental management system. 4) Carton Bros. should investigate the feasibility of providing a facility whereby surface water drains can be directed to process effluent drains in a quick and efficient manner during an emergency. There is a diversion valve in the surface water drainage system to provide such a facility. This would eliminate the requirement to manage the diversion of firewater away from individual entry points to the surface water drainage system. 5) All active underground process and storm drains should be tested in accordance with Condition 6.9 of the Carton Bros. IPPC Licence. This will ensure that any damaged pipe work can be repaired to guarantee integrity and any contaminated firewater transferred by this pipe work does not threaten soil or groundwater. Mc Breen Environmental have been contracted by Carton Bros. ltd to carry out a camera survey of the site drainage system. Please see attached letter from the EPA approving the Firewater Risk Assessment subject to Conditions dated 21" June 2011.

3 ~ r~ ~ CARTON GROUP Please provide an update an upgrade works required under Condition 3.18 of your current licence. Please see below update on upgrade works as required under Condition IPpe Licence Description Complete Condition No Convert to a vacuum method the transfer of offal Complete and feathers from the processing building to the animal by-product storage building Optimise the use of flocculants in the WWTP Complete and Ongoing Optimise Balance tank operation and install Complete and Ongoing controlled rate transfer pumps at the WWTP Install a new Dissolved Aeration Flotation System Complete (New Nijhuis DAF after the balancing tank at the WWTP. System) Install an Anoxic tank and mixing system at the Planning permission has been WWTP granted for a new Aeration tank and anoxic tank, but this work has not complete as yet Install tertiary filtration after the clarifier at the The new Nijhuis DAF System can WWTP be utilised for tertiary treatment prior to discharge to laugh Sillan. Please provide information as to whether the abstraction of lake waterfrom Lough Sillon has been registered with the local Authority as required under the Water Pollution Act. The abstraction of lake water from Lough Sillan has been registered with Mr. Calm O' Callaghan (Environment Section) of Cavan County Council. Please don't hesitate to contact us if you have any queries in relation to the application ours-sincerely, BSc. Env, H.Dip f. T, Cert SHWW. For Carton Bros ltd Encl: Letter from EPA Re: Fire Water Risk Assessment

4 Environmental Enforcement Mr. Frank Austin Manager C/o Mr. Nevin Traynor Consultant Carton Bros. Limited Traynor Environmental Ltd Belturbet Business Park, Creeny, Bclturbet County Cavan. ".. Reg:onallnspectorilte. Mc(umi~key Hou!>e, Rich'/ie.. " Clonsxeagh ROild, Dub/In 14, Ireland. Cigireachl R~:gilmilch, Teach Mhic Chuma~caigh, Dea Radha(c. 86thar C1uain SCeach, Baile Atha Clialh 14, ~ire 1: OHIO F: E: info'ilepaje W: \'t'\"...'.epaje locall: st June 2011 Our Ref: P /akOSts Ref: Condition Fire - Water Risk Assessment Dear Mr. Austin, r refer to the fire-water risk assessment for Carton Bros. IPPC Licensed installation (Reg. No. P ) located at Darkley, Shercock Co. Cavan received by the Agency on 14 'h July 2009 and the revised fire-water risk assessment submitted on \3'h March 20 II and 4 'h May 201 I. I am to advise you thai the information as submitted is to the satisfaction of the Agency subject to the following: (I) The licensee shall ensure (a) Adequate control measures are put in place (i) (b) At compat1ment 6 (oils/lubricant storage area) that will ensure fire waters are contained; (ii) At compat1ment 8, 8A, 8B and 8e that ensure fire-waters are contained and prevented from discharging to surface waters, in pat1icular SW2; (iii) At compartment 9 that ensures that fire waters are prevented li'om discharging to surface water; All foul water/process effluent collection system manholes are labelled red and clearly numbered in accordance with "site plan showing foul water layout" (Ref. 08/44S/0S/TE); (c) All surface water collection system manholes are labelled blue and clearly numbered in accordance with "site plan showing surface water layout" (Ref. 08/44S/0S/TE); (d) That a preliminary agreement with an appropriate third parly is established!o ensure lhul fire wat~.rs are collected in the '~\'ent of fire water arising at the installation. The procedure for such an arrangement shall be considered and formalised in the emergency plan; \\owl\ol'l:\{j5. licence cnlijrccllleni,ipc lin'nec enf(lfcclllcntlipc lcrnplntes\liye ipc tcllllll<tles\let...,gcneral.dotrr\'\

5 (2) In the event of a fire and the generation of fire-water, the licensee shall not dispose of or recover the fire water on-site or off-site without the prior approval ofthe Agency; (3) The licensee shall have regard to Appendix C ofthe Agency's guidance note', the general and specific recommendations detailed in the risk assessmenl report(s) and prepare and submit to the Agency for agteement a suitable risk management programme; (4) The iicensec shall amend the ELRA and associated reports to represent th,~ Known and unknown liabilities identified in the risk assessment reports. The licensee shall submit a risk management programme to the Agency for agreement within one month of receipt of this letter. If you have any other queries in relation to this matter please contact the Mr. Thomas Scxton at telephone 0 I I00. Pleasc quote the above reference in future correspondence in relation to this matter. Yo Is sincerely, _I-f--- Th nas S x:t In~ ector. Of Ice of Environmental Enforcement I Fire _ Water Retention Facilities (Draft Guidance Note to Industry on the Requirements for Fire-Water Retention Facilities).