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 Dairygold Co-operative Society Limited (Castlefarm) Dairygold Co-Operative Society Limited Licence Register No. P CRO Site Address Site Visit Reference No. Castlefarm Centre and, Clonmel Road Centre, Mitchelstown, Cork SV08278 Report Detail Issue Date 12/08/2016 Prepared By Mary Sheehan Site Visit Detail Date Of Inspection 25/05/2016 Announced No Time In 09:00 Time Out 17:50 Agency Personnel On Site Mary Sheehan Licensee Personnel and Role Mr. Chris Hartnett, Castlefarm Site Manager, Mr. Derry Cadogan, Environmental Manager, Mr. Eugene O'Connor, Plant Manager, Clonmel Road, Dr. Gabriel Kelly, Environmental Coordinator, Ms. Marianne O'Donnell, Central Laboratory Manager, Mr. Michael O'Keeffe, EHS Coordinator, Clonmel Road, Mr. Michael Sheehan, Site Engineer, Mr. Terry O'Donnell, EHS Coordinator, Castlefarm. Photo Taken Yes Samples Taken No Video Taken No Site Visit Report - SV Dairygold Co-Operative Society Limited Page 1 of 19

2 Scope This inspection was carried in accordance with EPA's Office of Environmental Enforcement Sectoral Inspection Plan for Food and Drink installations during Items raised during the previous site inspection were also addressed. Media The inspection focussed on surface water and ground water. Site Areas Inspected Yard areas at the Castlefarm and Clonmel Road sites. Waste Water Treatment Plant Areas around the discharge pipeline to the Funshion River and pipeline jetting activities Documents Inspected AQS Method Statement "Cleaning of WWTP effluent line onsite in Dairygold Mitchelstown to Fusion River Outfall." Survey of Trade effluent lines at Dairygold Castlefarm, January 2016 Survey of effluent line, Clonmel Road to Castlefarm Annual Environmental Report (AER) for 2015 (drain/pipeline testing) Effluent Quality Test Results viewed on a screen for the following: SED/CF2 05/05/ /05/2016 (Temperature Parameter) SED/CF2 24/09/ /10/2015 (Temperature Parameter) SED/CF2 24/04/ /04/2016 (Flow, Temperature, ph, COD, BOD, SS, o-phosphate, total-phosphate, total-nitrogen, ammonia, chloride, visual, odour) Site Visit Report - SV Dairygold Co-Operative Society Limited Page 2 of 19

3 1. Licensee Monitoring 1.1 Has the integrity of pipelines (overground and underground) been found to be satisfactory? No 6.10 Yes Yes Site Visit Report - SV Dairygold Co-Operative Society Limited Page 3 of 19

4 To establish if the integrity of underground pipelines was satisfactory at the Castlefarm site, the inspector requested to view the drain/pipeline integrity documentation. The report "CCTV Survey Report of Trade Effluent Lines" relating to assessments undertaken in January 2016 was provided to the inspector. This document was taken offsite and inspected subsequently at the EPA Offices. (I) This document was inspected and it documented the lack of integrity with issues such as open joints, joint displaced, collapsed drains and weld failure recorded. Examples include: (a) E25(D/S) to E21 was tested on 20/01/2016 and was found to have a collapsed drain/sewer, grade 5. (b) E7 (U/S) to E15 was tested on 20/01/2016 and was found to have a joint displaced, 35mm of diameter, grade 4. (c) E398 (U/S) to E402 was tested on 18/01/2016 which and found to be open at E402. Apart from one report received subsequently on the repairs completed on pipeline E390-E385 ( ed on 27/05/2016) and some details provided in the 2015 AER, the EPA has not been appraised if repairs were completed on the drains/pipelines surveyed in the report and the integrity of the drains/pipelines has not been demonstrated by the licensee. This is a non-compliance with 6.10 of the licence. (II) On 30/09/2015, the licence submitted the database document "DFI- Mitchelstown Drainage Integrity Database" to the EPA containing details regarding the identities of the drains/pipelines scheduled for integrity testing during the winter shutdown of This schedule was compared with the report "CCTV survey Report of Trade Effluent Lines" as well as information submitted in the 2015 AER and the E390-E385 repair report to ascertain the current status of drains/pipelines. There remains a significant number of drains/pipelines that require to have their integrity demonstrated and that have not been tested within the last 3 years. This is a non-compliance with 6.10 of the licence. Examples include: (1) In many cases, the schedule did not provide details of the date the pipeline was last tested and what the outcome was. Furthermore, following the inspection of documentation provided, it is not known if these were tested during the winter shutdown of Examples of this include E8-E4, E13- E12, E20-E19, E203-E204, E377-E375 and E409-E403. (2) In some cases, the date the pipeline was last tested had already exceeded the 3 year timeframe and a failure was noted in the database document. It is not known if pipelines were subsequently repaired and passed testing. Furthermore, it is not known if these pipelines were tested during the shutdown. Examples include E159-E155 and E160-E159 which are documented as having failed in 2011 with the next test due in 2014 and were scheduled for the winter shutdown. (3) In other cases, the date the pipeline was last tested had already exceeded the 3 year timeframe. Furthermore, it is not known if the pipeline was tested during the shutdown. Examples include E193-E189 which was last tested 2009 with the next test due in E127-E125, E131-E125, E260- E258 which were last tested in 2010 with the next test due in 2013 while E234-E229 and E285-E343 are examples of pipelines that were last tested in 2011 with next test due in (III) The licensee during the visit outlined that integrity testing had not been completed at some sections of pipeline. The licensee explained that it was not possible to complete surveys due to the size of the bores and that the site intended to complete testing with a handheld camera. In a subsequent telephone call (21/07/2016), the licensee replied that the tests in the crystallisation and the dry casein areas were completed in June 2016 without providing specific details on the identities of the pipelines. (IV) The document "CCTV Survey Report of Process lines from Clonmel Road to Castle Farm for Dairygold Mitchelstown" detailing a survey completed on 18/12/2015 showed that infiltration was occurring in this pipeline and demonstrated that the pipeline is not impervious or water tight. This is a non-compliance with 6.10 of the licence. Corrective Action Required The integrity and maintenance of underground pipelines remains a significant issue for the site. You are required to respond to the Agency on this matter through Investigation CI000966; you do not need to respond directly to this site visit report. Site Visit Report - SV Dairygold Co-Operative Society Limited Page 4 of 19

5 2. Effluent Emission 2.1 Are Licensee effluent quality test results compliant with respect to previous six months? No The licensee, prior to the site visit, had notified the EPA of the following ELV breaches: 1. A result of 1.13 mg/l P was recorded for the orthophosphate parameter from a sample taken from SED/CF-2 on 28/04/16. The emission limit value specified in the licence is 0.5 mg/l. 2. A result of 23.8 mg/l was recorded for the suspended solids parameter from a sample taken from SED/CF-2 on 28/04/16. The emission limit value specified in the licence is 15 mg/l. 3. A result of 1.45 mg/l P was recorded for the orthophosphate parameter from a sample taken from SED/CF-2 on 03/04/16. The emission limit value specified in the licence is 0.5 mg/l. -compliances have already been issued in relation to these exceedances. 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. Yes These were notified as incidents to the EPA, refer to incident references INCI and INCI If there were non-compliant effluent results in relation to the facility in the previous six months has the licensee identified the likely causes? Yes The licensee identified the likely causes, refer to incident references INCI and INCI Did the licensee take corrective/preventive action to resolve any likely causes of noncompliant effluent emissions? Yes The actions taken are presented in the incident references INCI and INCI Site Visit Report - SV Dairygold Co-Operative Society Limited Page 5 of 19

6 Site Visit Report - SV Dairygold Co-Operative Society Limited Page 6 of 19

7 3. Storm Water 3.1 Have Trigger Levels been established for the storm water monitoring parameters? No Yes The licensee had not established trigger levels for storm water parameters which is in non-compliance with condition of the licence. This was raised as a non-compliance during the EPA's previous site visit conducted in 2015, reference SV The licensee indicated that is it expected that the trigger levels would be in place by 20th June Corrective Action Required The licensee has, subsequent to the site visit, submitted details of proposed trigger levels under Investigation CI Are silt traps and/or oil separators/interceptors installed on the surface water drainage system as required by the licence? No 3.8 Yes The licensee has failed to install and maintain silt trap(s)/oil separator(s) at the installation as required by 3.8. This was raised as a non-compliance during the EPA's two previous site visits, EPA references SV02499 for the visit conducted in 2015 and SV01002 for the visit conducted in This is a non-compliance with s 3.8 of the licence. Corrective Action Required You are required to respond to the Agency on this matter through Investigation CI000649; you do not need to respond directly to this site visit report. Site Visit Report - SV Dairygold Co-Operative Society Limited Page 7 of 19

8 4. Odour Management 4.1 Has the installation been free of odour complaints (apart from those forwarded by the EPA ) this year? (Record number of complaints). Yes 4.2 Has the licensee carried out any odour assessments this year? No Site Visit Report - SV Dairygold Co-Operative Society Limited Page 8 of 19

9 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 Has the licensee carried out noise monitoring this year? ( If yes, was the noise monitoring compliant according to the licensee?) No The licensee intends to conduct monitoring in July Does the licensee have a noise reduction plan in place? Yes Site Visit Report - SV Dairygold Co-Operative Society Limited Page 9 of 19

10 6. Surface Water / Groundwater Protection 6.1 Are bunds, tanks, pipelines & containment structures integrity assessed as required by the licence? No Yes Please refer to question 1.1 regarding pipelines. During the previous site visit in 2015 (EPA reference SV02499), the three items listed below were noted and these were followed up by the inspector during this site visit: (i) There were cracks visible in the chemical bund and in bund BU/CR-11/S (Clonmel Road site). These cracks have been repaired since the last site visit. (ii) The "bundman test" was not working on the waste oil tank (Clonmel Road site). This was still the case during the inspection. The licensee provided an update to the EPA on 21/07/2016 that a sensor was subsequently installed during June (iii) A leak of "hot caustic" on bund wall and side of bund were noted at the Castlefarm site. This is still the case, refer to photograph 1. Corrective Action Required Repair leak of "Hot Caustic" without further delay and maintain documentary evidence of the action having been taken. The EPA may follow up on this matter at any time to ensure compliance with your licence. 6.2 Is there a report confirming that any bunds, tanks, pipelines & containment structures integrity defects are repaired? No Yes The report on the testing of the repair work undertaken on effluent pipelines was not available during the inspection, refer to question 1.1. Corrective Action Required Refer to question 1.1 of this report. Site Visit Report - SV Dairygold Co-Operative Society Limited Page 10 of 19

11 7. Site Specific Issues 7.1 Sewer Pipe Outfall to River Funshion Checked Yes On 23/05/2016, the EPA received communication from a member of the public who was concerned that white material had been being deposited on the river bed from the sewer pipeline outfall to the River Funshion. Dairygold Co-Operative Society Limited was jetting the pipeline connected to this outfall. This outfall and the areas upstream and downstream of this point were visited during the site visit. The inspector noted the following: (a) The treated effluent discharge was primarily being discharged through a temporary flexible pipe to the River Funshion, draining from the treated discharge pipeline before the section that was being jetted, refer to photograph 2. The licensee outlined that a portion of the treated discharge was being discharged via this route and that the remainder was being pumped to the Mitchelstown urban waste water treatment plant line for discharge. (b) A section of the treated discharge pipeline was being jetting during the visit, refer to photograph 3. The inspector noted that most of the water being used for jetting was being recycled through a recycling tank. The jetting water that was not being sucked up by the pump was contained in the pipeline by a bunged manhole located further down the pipeline close to the sewer pipeline outfall, refer to photograph 4 and this spent jetting water was being pumped to a baffle tank to settle out solids prior to discharge, refer to photograph 5. (c) White material was observed on the river bed, refer to photograph 6. The licensee explained that this material was due to some fines in the pipeline being discharged after jetting activities had concluded for the day on 23/05/2016. The bung was removed after jetting activities had concluded and the treated discharge had been routed back through the cleaned section of pipeline. The licensee also outlined that this practice would be discontinued the next day and the discharge of treated effluent would then be kept isolated from the pipeline being jetted. (d) A method statement for the jetting process was presented. Corrective Action Required The licensee was requested during the visit to ensure that the residence time in the baffle tank was appropriate to ensure removals of solids from the spent jetting water which was being collected at the bunged manhole. The licensee contacted the inspector on 26/05/2016 to explain that the licensee had stopped using the baffle tank and any spent jetting water at the bunged manhole was instead collected by a tanker and then brought back to the licensee's waste water treatment plant. 7.2 Sodium Hypochlorite IBCs Checked 3.6 Yes Site Visit Report - SV Dairygold Co-Operative Society Limited Page 11 of 19

12 Five Intermediate Bulk Containers (IBCs) containing sodium hypochlorite were observed being stored unbunded, refer to photographs 7 and 8. The licensee outlined that a bund has been constructed and that the bund requires to be lined before being used. Corrective Action Required The licensee was instructed to move the IBCs to a bunded area. You are required to take the above corrective action and to maintain documentary evidence of the action having been taken. The Agency may follow up on this matter at any time to ensure compliance with your licence. 7.3 Cooling Water Towers Checked Yes A leak was observed in the cooling water towers area that was draining to a surface water drain, refer to photographs 9 and 10. Corrective Action Required The licensee shall ensure that leaks on site are fixed and maintain documentary evidence of the action having been taken. The EPA may follow up on this matter at any time to ensure compliance with your licence. 7.4 In-House Analysis of Emission to Sewer Parameters Checked Site Visit Report - SV Dairygold Co-Operative Society Limited Page 12 of 19

13 The inspector requested an update regarding in-house analysis of Emission to Sewer parameters which was raised during the previous site visit in 2015, EPA reference SV02499, item 8.3. While the following licensee responses were noted, the inspector did not undertake a inspection of the laboratory during the site visit. (1) During the previous site visit, it was noted that no linearity checks had been carried out on the Spectrometer and the QC standard used checks one point on the calibration curve at 100mg/l whereas the licence limit is 50mg/l. During this site visit the licensee outlined that 25 mg/l, 50mg/l, 100 mg/l standard linearity check is in place. (2) It was noted at the previous visit, that the sample taken from SED/CF1 on 09/06/15 had a chloride value >1000mg/l which could impact on the suspended solids value. In addition, there had been a failure noted in EPA Intercalibration scheme, round 111, but there was no evidence of any investigation on this carried out or the impact on the associated test results.the licensee stated that a double filter and a nonconformance system are now in place. (3) Regarding total nitrogen analysis, there had been failures noted in the EPA Intercalibration scheme, rounds 108/109/110 and this was explained as being due to the results being reported using incorrect units but there was no evidence of any investigation having been carried out on this, or the impact on the associated test results. The licensee stated during this inspection that lead technician checks and a nonconformance system are now in place. (4) and (5) The licensee informed the inspector during this site visit that a retrospective validation is in place for the water test methods. The licensee also added that the effluent laboratory had been brought into the same quality system as central laboratory as of January (6) Inspectors noted during the previous site visit that the balance instrument being used in the laboratory had a reference weight in use but only at 20g. There were no other checks carried out over the range of the balance. The licensee outlined during this site visit that three weights were in place 1g, 5g, 20g. Site Visit Report - SV Dairygold Co-Operative Society Limited Page 13 of 19

14 Summary Five compliance investigations were open prior to the site visit and these remain open after the visit. The licensee shall ensure measures are taken to address the actions specified to close out these as soon as practicable and ensure that compliance with the licence is restored within the shortest possible time. 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 Dairygold Co-Operative Society Limited Page 14 of 19

15 Photos Photograph 1 Hot caustic tank bund (photograph name P JPG) Photograph 2 Temporary pipe for treated discharge while jetting of the permanent pipeline was being completed (photograph name P JPG) Site Visit Report - SV Dairygold Co-Operative Society Limited Page 15 of 19

16 Photograph 3 Cleaning of discharge pipeline in progress. (Photograph name P JPG) Photograph 4 Bunged manhole located close to the discharge pipeline outfall (Photograph name P JPG) Site Visit Report - SV Dairygold Co-Operative Society Limited Page 16 of 19

17 Photograph 5 Baffle tank used to settle solids prior to discharge. (Photograph name P JPG) Photograph 6 White material was observed on the river bed (Photograph name P JPG) Site Visit Report - SV Dairygold Co-Operative Society Limited Page 17 of 19

18 Photograph 7 IBCs of Sodium Hypochlorite 10/11% stored unbunded (photograph name P JPG) Photograph 8 Close-up of label on IBC of Sodium Hypochlorite 10/11% (photograph name P JPG) Site Visit Report - SV Dairygold Co-Operative Society Limited Page 18 of 19

19 Photograph 9 Leak observed near cooling water area (photograph name P JPG) Photograph 10 Potential pathway to storm water drain (photograph P JPG) Site Visit Report - SV Dairygold Co-Operative Society Limited Page 19 of 19