In relation to site visit report SV14469, I would like to make the following comments:

Transcription

1 13 th July 2018 IE Licence No: W Company: RILTA Environmental Limited Subject: Re: SV14469 Site Visit Report RILTA Environmental Limited RILTA Environmental Ref: ENV3218.epa Dear Sir/ Madam, In relation to site visit report SV14469, I would like to make the following comments: EPA Report Section Number 2.2: Two large transformer shells were stored outside in the loading dock where standing water was present, photograph _ refers. In addition, oil was observed dripping from one of the large transformers into an un-bunded and unlabelled container, photograph _ refers. This is the appropriate and designated area for the temporary holding of the large electrical transformers. The area in question (bund number 15) is one of the sites nominated and tested concrete bunded structure areas. The last bund test carried out on this area was in The area passed its bund test. In addition to this testing the bund was also inspected by a structural engineer and found to be in a satisfactory condition. The unit is due re-inspection/testing in Should the Agency require it, the testing and assessment of this area scheduled for 2019 maybe brought forward to I have attached the last bund test report for your convenience. In relation to the container that was being used on the day, as outlined to the inspector, this was in use to assist in draining (i.e. removing) the remaining oil from the gear box of the transformer. To not do so would mean that oil remains in the unit and this is unacceptable to us and would not be in compliance with our scrap metal recycling programme. By utilising this system, the risk of oil leaking from the gear box and into the bund or leaking during transport to the metal recycling facility, is further minimised/removed. EPA Report Section Number 3.1: During the site visit, transport records for large transformers accepted at the facility were reviewed. The licensee was unable to demonstrate that the haulier (Aylward Heavy Haulage and Crane Hire) had a waste collection permit. 1 of 8

2 The haulage company Aylward Heavy Haulage and Crane Hire do not directly hold a waste collection permit. The vehicle in question (Vehicle Reg.: 151 LS 1026) which is owned by Aylward Heavy Haulage and Crane Hire is leased by Galway Metal Company Ltd., until 17 th August This vehicle is included under the Galway Metal Company Ltd. waste collection permit. Reference number NWCPO For your convenience, I have included a copy of this permit as an attachment to this letter. EPA Report Section Number 4.1: During the site visit the licensee indicated that an angle grinder is used to open some transformers. It was unclear what precautionary measures are taken to prevent accidental ignition. The electrical transformer units that are received at the Rilta Environmental facility are old units which have been out in the open air and in all types of weather. This means that the access panels on the units are rusted/sealed shut and cannot be opened by conventional means. Utilising angle grinders to cut open the seized nuts/bolts is the only feasible method to safely open the units. The electrical transformers are all opened in the designated deconstruction area. Within this area all flammable materials are kept to an absolute minimum with fire-fighting equipment close at hand, should it be needed. All staff operating the angle grinders are trained to do so. Staff are also certified fire marshals and trained in the operation of fire extinguishing equipment. EPA Report Section Number 4.2: A quantity of intermediate bulk containers (IBCs), containing waste transformer oil, were stored in the main warehouse in a manner that did not enable easy access to labels and dates of the IBC's, photograph _ refers. In addition, the system for ensuring stock rotation was not clear with older stock dates still clearly visible on some containers. The IBCs are used to temporarily store the oil that has been drained from the electrical transformer units. These IBCs are stored maximum 3 units high, in the bunded warehouse. As the units contain approximately 1,000litres of oil, they are heavy and are only moved via forklift. All IBCs are labelled to identify their contents and dated to enable easier stock rotation. It does 2 of 8

3 appear that the IBCs in question had two sets of dates written on the units (i.e. the previous storage date was still on the unit and had not been marked out). A tool box talk has taken place with the appropriate staff members to ensure that this does not happen in the future. EPA Report Section Number 4.3: Asbestos waste was observed stored outside in open top containers prior to shipping. Waste shipment records indicated the last time asbestos was dispatched from the site was 26/04/2018. This is a non-compliance with condition of licence Reg. No. W In addition, the doors of Store 1, 2 and 3 and the outside warehouse where asbestos is stored were open at the time of the site visit, photograph _ refers. We are working with the suppliers of the large open top containers to install tarps on the units. The doors to the storage pods 1, 2 and 3 are open when in use and closed when no longer required. A tool box talk has been completed with the appropriate staff to ensure that they are familiar with the requirements of the licence in regards to the temporary storage of pre-packaged asbestos and asbestos containing materials. EPA Report Section Number 5.1: At the time of the site visit no records of weekly drainage checks were available for inspection. This is in non-compliance with condition In addition, a review of records indicated hardstanding monitoring is carried out on a monthly basis. The weekly EHS check sheets have been updated to include all of the above requirements. Hardstanding inspections are now carried out on a weekly basis. EPA Report Section Number 5.2: The Emergency Response Procedure (ERP) did not: Include an up to date waste and chemical storage plan including the storage of waste transformer oil and asbestos Have full consideration for the findings of the fire water risk assessment Ensure all activities with a risk of accidental ignition are identified. Section 4.1 refers. 3 of 8

4 The company operates two Industrial Emissions (IE) facilities in which certain waste is stored pending transport and other types processed/treated directly on site. The company has been in the process of relocating the storage/processing of certain waste types (within the remit of the IE licences) from one licensed site to the other. This process is now complete, and the ERP has been updated accordingly. EPA Report Section Number 5.2: At the time of the site visit the waste quarantine area was not clearly labelled or delineated from the general storage area in the main warehouse building. The waste quarantine areas are flexible, moveable areas. Due to space restrictions these areas are enlarged or reduced in size to meet demand (e.g. if no materials require quarantine, the quarantine areas are reduced to their minimal size. If they are needed, then their size is expanded to meet the required space). The equipment used to divide off the quarantine areas will be upgraded to ensure that it is clear and obvious to all persons the demarcation of these areas. I trust this is to the satisfaction of the Agency. If you have any queries, please feel free to contact me. Yours sincerely, Seán Lawlor, EHS Coordinator, RILTA Environmental Limited. 4 of 8

5 5 of 8

6 6 of 8

7 7 of 8

8 8 of 8