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 Irish Packaging Recycling Limited Irish Packaging Recycling Licence Register No. W CRO Site Address Site Visit Reference No. Ballymount Road, Walkinstown, Dublin 12, Dublin SV13835 Report Detail Issue Date 10/01/2018 Prepared By Sandra Gleeson Site Visit Detail Date Of Inspection 06/12/2017 Announced No Time In 14:59 Time Out 17:18 Agency Personnel On Site Sandra Gleeson Licensee Personnel and Role Gwen Cooper, Operations Manager Eamonn Whelan, Business Development Manager Photo Taken Yes Samples Taken No Video Taken No Odour Assessment No Site Visit Report - SV Irish Packaging Recycling Page 1 of 15

2 Scope This site visit was to assess waste quantities on site on 06/12/2017. Media The following environmental media were assessed during the site visit; Waste Water Site Areas Inspected The following areas were assessed during the site visit: General yard area Front shed Back shed Surface water monitoring point SW1 Maintenance yard Documents Inspected The following documents were inspected at the time of the site visit: Daily inspection sheet Daily odour monitoring check Accident prevention policy (APP) Emergency response procedure (ERP) Fire register 11.9 / Schedule A.2 - Records of all waste accepted and dispatched from 01/01/2017 to 30/11/2017 Site Visit Report - SV Irish Packaging Recycling Page 2 of 15

3 1. Site Specific Issues 1.1 Was safe and permanent access to sampling / monitoring points provided? Answer No 3.16 Yes At the time of the site visit surface water sampling point SW-1 was not easily or safely accessible. SW-1 was located behind a stack of large wheelie bins and one of the bins had fallen on top of the manhole cover, photograph DSCF0020 refers. The licensee shall ensure that safe and permanent access to all sampling and monitoring points is provided in accordance with 3.16 of Licence Reg. No. W Answer 1.2 Waste Tonnages Checked 1.2, Schedule A.2, 11.9 Yes Waste records provided at the time of the site visit indicated that the total quantity of Mixed Dry Recyclables (MDR) and Segregated Paper, Plastic and Cardboard wastes accepted on site from January to November 2017 was 167, Tonnes. This exceeds the annual maximum tonnage limit of 150,000 Tonnes of MDR (50,000 Tonnes), Segregated Paper, Plastic and Cardboard (50,000) and Construction and Demolition (C&D) wastes (50,000 Tonnes). Subsequently, the licensee submitted MDR and Segregated Paper, Plastic and Cardboard waste records on 19/12/2017 under Investigation A018676, indicating the actual quantity of waste accepted in the same period was 112, Tonnes. This tonnage still exceeds the annual tonnage limit of 100,000 Tonnes for MDR and Segregated Paper, Plastic and Cardboard in accordance with Schedule A.2. This is in non-compliance with condition 1.2 and Schedule A.2. The licensee shall comply with waste acceptance quantities as set out in Schedule A.2. In addition, the licensee shall ensure that full and accurate records relating to waste management operations are available on site for inspection by the Agency at all times in accordance with condition Answer 1.3 Waste Storage Checked 8.1, 8.7 Yes Site Visit Report - SV Irish Packaging Recycling Page 3 of 15

4 At the time of the site visit a significant quantity of baled and loose unsegregated wastes were stored outside as follows: loose "reject" waste, photograph DSCF0018 refers Flexible Intermediate Bulk Container (FIBC) bags of shredded hangers, photograph DSCF0008 refers loose plastics and pallets, photograph DSCF0010 refers plastic tubing, photograph DSCF0009 refers. large stockpile of baled cardboard, photograph DSCF0016 refers. On the 06/10/2011 the Agency previously approved outdoor storage of baled recyclable material only, W /ak01NH refers, subject to compliance with condition 8.7 and ensuring the recyclability of the recovered material is not compromised. In addition, a significant quantity of loose and baled waste tyres (LoW ) were stockpiled on site. This included loose waste tyres blocking the entrance of the Front Shed preventing safe ingress or egress to the plastic baling area, photographs DSCF0025 and DSCF0026 refer. The quantity, source and the storage of waste tyres does not comply with the requirements of Agency approval granted on 11/03/2015, LR refers. This is in non-compliance with condition 8.1. The licensee shall ensure that only waste specified by the licence and/or approved by the Agency is stored outdoors in accordance with condition 8.1. The licensee is reminded that the Agency may, at any time, revisit or revoke the Approval for the storage of material outdoors. All waste shall be stored in designated areas and appropriately labelled and segregated in accordance with condition 8.7. (CI A refers). The licensee shall immediately reduce the quantity of waste tyres at the facility in accordance with Agency approval granted on the 11/03/2015, LR refers. Records of the safe recovery and appropriate evidence that the tyres have been removed shall be submitted to the Agency by 05/01/2018. (CI A refers). The licensee subsequently submitted evidence, on 05/01/2018 under CI A018678, that tyres had been removed from the site. Answer 1.4 Fire Safety Checked 8.7, 9.1, 9.2 Yes At the time of the site visit stockpiles of baled and loose waste were stored indoors and outdoors and were poorly segregated with no clear fire breaks between waste types to mitigate fire risk or spread, photographs DSCF0015, DSCF0016 and DSCF0024 refer. The Accident Prevention Procedure (APP) and Emergency Response Procedure (ERP) had not been updated since 24/06/2016. The procedures did not have regard to the Agency's guidance to licensee's on the Preparation of Accident Prevention Procedures and Emergency Response Procedures. This issue was raised in the previous site visit, SV08410 refers, on 15/09/2016. This is in non-compliance with conditions 9.1 and 9.2 of Licence Reg. No. W The licensee shall ensure that waste is stored in designated areas with adequate fire breaks and shall have regard to the Agency guidance note on Fire Safety at -Hazardous Waste Transfer Sites. (CI Instruction Ref. A refers). The Accident Prevention Procedure and Emergency Response Procedure shall be updated in accordance with conditions 9.1 and 9.2 and shall have regard to the Agency guidance on Preparation of Accident Prevention Procedures and Emergency Response Procedures. (CI Instruction Ref. A refers). Site Visit Report - SV Irish Packaging Recycling Page 4 of 15

5 Answer 1.5 Bunding Checked , 6.11 Yes Containers of waste oil were stored on a pallet unbunded beside the oil storage bund to the North of the site, photograph DSCF0021 refers. This is in non-compliance with condition of Licence Reg. No. W In addition a significant amount of rain water was observed in the diesel tank bund reducing the available capacity of the bund. The licensee shall ensure that all drums are appropriately bunded in accordance with condition All bunds shall be properly maintained at all times in accordance with condition Answer 1.6 Surface Water Drainage Checked 6.11, 6.13 Yes Prior to going on site the Agency inspector observed paper type sludge in the stream immediately downstream from the outlet of storm water discharge point SW-1, photograph DSCF0004 refers. The licensee indicated that the drains were recently cleaned and that the balloon for blocking discharge to surface water was not used to plug the discharge point SW-1 during the drain cleaning. Additionally, paper was observed in the gullies parallel to the Front Shed, photograph DSCF0029 refers. The licensee shall ensure that the drainage system is properly maintained at all times and that all sludge and drainage from the desludging process is collected for safe disposal. Additionally, the licensee shall investigate and submit to the Agency a detailed report of the corrective and preventative measures to be taken in regard to the paper sludge observed in the surface water stream by 29/01/2018. (CI A refers). Answer 1.7 Litter Checked 5.4, 6.21 Yes At the time of the site visit a significant amount of litter was observed on site, photograph DSCF0014 refers. This issue was raised in the previous site visit, SV08410 refers. Litter was also observed in and around the surface water stream on the north boundary of the site, photograph DSCF0004 refers. The licensee shall ensure that litter associated with the activity does not result in an impairment of, or an interference with, amenities or the environment at the facility or beyond the facility boundary. Additionally, the licensee shall ensure that the daily nuisance inspections of the facility includes the immediate surrounds of the facility in accordance with condition Site Visit Report - SV Irish Packaging Recycling Page 5 of 15

6 Answer 1.8 Oil Spill Checked 3.18, 8.6 Yes At the time of the site visit an oil spill was observed at the waste oil storage tank. Some absorbent was applied to the spill but the licensee was unable to locate a spill kit. Oil staining in the same area was raised in the previous site visit, SV08410 refers. Additionally, a significant area of oil staining was observed across the hardstanding to the north of the site, photograph DSCF0023 refers. Stains around the diesel bund were also observed and no absorbent was observed in this area. The licensee shall ensure that all spillages are adequately cleaned up and contaminated material disposed of in accordance with condition Spill kits shall be adequately stocked and be located appropriately to enable quick response and clean up to spillages. Answer 1.9 Heat Detection System Checked 11.7 (vii) Yes During the site visit the licensee indicated that heat detectors were present in the Front and Back sheds and were remotely managed. On inspection of the Fire Register a Fire Alarm Certificate issued by Independent Fire Services on 25/07/2017 provided recommendations to "install some heat detectors throughout the warehouse". The licensee was unable to clearly outline the type and quantity of heat detectors present in the buildings and what action was taken, if any, regarding the recommendation. Subsequent to this site visit a minor fire was reported to the Agency, INCI013598, 31/12/2017 refers. The licensee shall submit to the Agency detailed information and records regarding the type, locations and maintenance of the heat detection system for the facility by the 22/01/2018. Site Visit Report - SV Irish Packaging Recycling Page 6 of 15

7 Photographs 06/12/2017 DSCF0020 Sampling Point SW-1 located under plastic bins DSCF0018 Outdoor storage of loose reject waste Site Visit Report - SV Irish Packaging Recycling Page 7 of 15

8 DSCF0008 Outdoor storage of FIBC bags of shredded hangers DSCF0010 Outdoor storage of loose waste plastics and pallets Site Visit Report - SV Irish Packaging Recycling Page 8 of 15

9 DSCF0009 Outdoor storage of waste plastic tubing DSCF0015 Baled low grade unshredded SRF and waste tyres Site Visit Report - SV Irish Packaging Recycling Page 9 of 15

10 DSCF0016 Baled waste cardboard, aluminium cans and clear film DSCF0024 Indoor waste storage baled shredded paper and newsprint Site Visit Report - SV Irish Packaging Recycling Page 10 of 15

11 DSCF0025 Loose waste tyres in Front shed DSCF0026 Loose waste tyres in Front shed Site Visit Report - SV Irish Packaging Recycling Page 11 of 15

12 DSCF0021 Oil drums unbunded DSCF0004 Sludge and litter in surface water stream at north boundary Site Boundary Site Visit Report - SV Irish Packaging Recycling Page 12 of 15

13 DSCF0029 Paper in storm water gully DSCF0014 Litter at western perimeter fence Site Visit Report - SV Irish Packaging Recycling Page 13 of 15

14 DSCF0023 Oil staining on hardstanding Site Visit Report - SV Irish Packaging Recycling Page 14 of 15

15 Summary Five non-compliances were recorded during the site visit. In addition, five observations were raised. The licensee shall address all actions detailed in this report without delay. Waste storage practices were found to be very poor during the inspection of the site on 06/12/2017 as evident in the attached photographs. The licensee was found to have failed to comply with Agency approvals, LR and W /ak 01NH refer, in relation to outdoor waste storage. The licensee is reminded that the Agency may at any time, if it considers it necessary, revisit or revoke an approval. Investigation (CI) Reference No. CI was opened by the Agency on 12/12/2017 following the site visit. The licensee shall address all actions detailed in this CI within the requested timeframes. The licensee is reminded to comply with the conditions of Licence Reg. No. W , at all times. 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. (i) Investigations 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. (ii) Publication of reports and licensee response. 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. (iii) Response to Site visit report Where you do wish to respond directly to a site visit report, you should do this by generating a Licensee Return of the type Site Updates/Notifications and the sub-type Response to EPA Report in EDEN. 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 Irish Packaging Recycling Page 15 of 15