o OXigen Management ofthe Facility Attachment C Technical Competence and Site Management C.2 Environmental Management System C.3 Hours of Operation

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1 o OXigen Attachment C Management ofthe Facility C.l Technical Competence and Site Management C.2 Environmental Management System C.3 Hours of Operation

2 O:-.igcn Enyironmental Ltd Waste Licence Re\iew Application W0208-0J Attachmcnt C. I. C.l SITE MANAGEMENT The existing management and staffing structure currently in place under EPA Licence W I will remain the same. A copy of the on-site management structure is included in this attachment. This organisation chart identifies particular responsibility levels for the environmental management of the Facility. It also details training and qualifications ofthe personnel involved. Additional competent staff will be employed if necessary for the proposed increased tonnage acceptance from 250,000 TPA to 350,000 TPA and the proposed acceptance and processing of MSW. Any proposed chances to the staffing structure will be submitted to the Agency for agreement. Quality Control is monitored through the Company's Management Review Procedure (Document refaxep 23) as part of the ISO 1400 I:2004 accredited Environmental Management Procedure for the facility.

3 DOC OXE12 EPA Licence W Organisation Chart for the Identification ofenvironmental Roles, Responsibilities and Authorities. Jim DowdaU Aidan Doyle MScChem. BSc (Env. Mgt.) Environmental Director Operations Director Colm Doyle Group Maintenance Manager John Clune Cert. Mechanical Engineering Eugene O'Brien se. Operations Managerl Facilities Manager ru B.Sc (OeD) f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he Warehouse Supervisor- Hazardous s Waste Mechanics Processing Operatives and Litter Pickers Drivers Co n se nt o Machine Operators: Graham Cassidy Rudolf Kozman Brian Sheridan Martins Utinans Igors Krasilnikovs Maciej Zajac Vitalijis Vinogradous Pavel Pugaciov Dairis Ziogas Overall Responsibility;for Environmental Compliance within the Company. And responsibility to Ensu~e that all Operations at the facil~ty al'e carried out inline with iprocedures and the Environmental Policy. Key: Environmental Responsibilities Overall Responsibility for Environmental Compliance within the Company. Responsibility to ensure that any oil/grease/diesel spills from their vehicle are cleaned up and any problems with vehicles are highlighted to manager immediately. To ensure that only conforming waste enters the facility and to ensure that this is recorded accurately and appropriately. To ensure that waste is segregated and stored appropriately and to implement procedures to keep the facility complaint at all times. To Ensure that waste is handled appropriately and to ensure that all wind blown litter is picked immediately. Responsibility to ensur that all incoming loads have the correct paperwork and that that they are accepted, stored and processed in compliance with au relevant legislation. Issued on: 09/04/2010

4 Oxigcn Em ironl1lcntal Ltd Wastc Licence Rc\ie\\ Application W I Attachment C.2. C.2 ENVIRONMENTAL MANAGEMENT SYSTEM An Environmental Management System has been developed for the Facility as required under Condition of the existing Waste Licence W I. Details of this EMS were submitted to the Agency for agreement in accordance to the Licence. As required under Condition of Waste Licence W I, the EMS includes the following elements: Management and Reporting Structure Schedule of Objectives & Targets Environmental Management Programme Documentation System Corrective Action Procedures Awareness and Training Programme Communications Programme In May 2009 The EMS for the Facility was accredited to ISO 14001:2004 Standard by Certification Europe. A copy ofthis certification is included in this attachment. Environmental Procedures are in place to ensure the continual assessment of Oxigen's environmental performance. This is formally assessed during the management review which takes place on an annual basis. A copy of the Management Review Procedure (Doc ref OXEP23) is included in this attachment. A log of all procedures that have been developed as part of the EMS is also included as part of this attachment.

5 Certification Europe This is to certify that the Environmental Management System Oxigen Environmental Limited Of Oxigen Environmental Limited, Marywell Industrial Estate, Ballymount, Dublin 22 Has been assessed by Certification Europe and deemed to comply with the requirements of ISO :2004 This certificate is valid for the activities specified below: The provision of waste management services at the Ballymount site. (NACE Code 37) At Date of initial certification: 6th May 2009 Signature:~;Z:~~~~;;===- This certificate is valid until: 5th May 2012 Chairman~.White SignaIUre~~ G. ~ tr: Client Registration No.: Certificate Reference No.: N1

6 Environmental Management System Outline W o Oxigen Environmental Management System Outline Environmental Management System Document Log: Doc OXE 01 Doc OXE 02 Doc OXE 03 Doc OXE 04 Doc OXE 05 Doc OXE 06 Doc OXE 07 Doc OXE 08 Doc OXE 09 Doc OXE 10 Doc OXE 11 Doc OXE 12 Doc OXE 13 Doc OXE 14 Doc OXE 15 Doc OXE 16 Doc OXE 17 Doc OXE 18 Environmental Management Policy Accident Prevention Policy Duty and Standby Capacity Acceptable Waste List EPA Approved Destinations List EPA Approved Haulier List Internal Audit Schedule and Audit Records Training Review and Plan 2009 Compliance Summary Sheet EPA Licence W0208-0l Waste Collection Permit Summary Company Records Management System Facility Management and Reporting Structure Environmental Objectives and Targets Schedule of Environmental Management Reviews Procedure Review Schedule Register of Environmental Aspects Register of Environmental Legislation & other Applicable Requirements Closure, Decommissioning and Aftercare Management Plan Environmental Management System Procedures Log: OXEPOI OXEP 02 Waste Acceptance Procedure Receipt, Processing and Dispatch of Waste Procedure Oxigen Environmental Ltd.

7 Environmental Management System Outline W OXEP 03 OXEP 04 OXEP 05 OXEP 06 OXEP 07 OXEP 08 OXEP 09 OXEP 10 OXEP II OXEP 12 OXEP 13 OXEP 14 OXEP 15 OXEP 16 OXEP 17 OXEP 18 OXEP 19 OXEP 20 OXEP21 OXEP 22 OXEP 23 OXEP 24 OXEP 25 OXEP 26 OXEP 27 OXEP 28 Bund Testing Procedure Chemical Control Procedure Chemical Spill Control Procedure Control of MSDS Procedure Energy Audit Procedure Dust Monitoring Procedure Odour Monitoring & Control Procedure Bird Control Procedure Fly Control Procedure Litter Control Procedure Noise Monitoring Procedure Vermin Control Procedure Yard Sweeping Procedure Emergency Response Procedure Document Control and Record Management Procedure Communications Procedure Silt Trap Emptying Procedure Complaints Handling & Corrective Action Procedure Environmental Auditing Procedure Management Review Procedure Operational Control Procedure Foul Water Monitoring Procedure Transfrontier Shipments Procedure Weighbridge Procedure Gypsum Acceptance Procedures Environmental Training Procedure Oxigen Environmental Ltd.

8 Environmental Management System Outline W OXEP 29 OXEP 30 OXEP 31 Hazardous Waste Acceptance And Handling Procedure Identification of Legal and other Requirements Procedure Environmental Monitoring & Measurement Procedure Environmental Management System Methodology Log: OXEM 01 OXEM 02 OXEM 03 Methodology for Identifying Environmental Aspects Methodology for Determining Significance of Environmental Aspects Methodology for Setting and Reviewing Objectives and Targets Environmental Management System Record Forms Log: OXED 101 OXED 102 OXED 103 OXED 104 OXED 105 OXED 106 OXED 107 OXED 108 OXED 109 OXED 110 OXED 111 OXED 112 OXED 113 OXED 114 OXED 115 Daily Inspection Records Weekly Inspection Records Complaints Handling / Corrective Action Form Rejected Loads Form Quarantined Waste Form Testing of Bunded Areas Site Action Requirement Form Emergency Repol1 Chemical/Oil Spill Report Waste Acceptance Log Internal Audit Form StaffCommunication Record Form C&D Fines Quality Control Record Sheet Incident Report Form Environmental Incident Log Environmental Management System Hazardous Document Log: Doc OXEH 01 Doc OXEH 02 Hazardous Waste Flow Outline Precedence of Hazards Document Oxigen Environmental Ltd.

9 Environmental Management System Outline W Environmental Management System Hazardous Procedures Log: OXEHP 01 OXEHP 02 OXEHP 03 OXEHP 04 OXEHP 05 OXEHP 06 OXEHP 07 Hazardous Waste Acceptance Procedure Asbestos Acceptance & Handling Procedure Controlled Substances Acceptance Procedure Hazardous Waste Transport Procedure Procedure for Working in Confined Spaces in Inert or Toxic Atmospheres Off-Site Spillage Procedure External Site Audit Procedure Environmental Management System Hazardous Methodologies Log: OXEHM 01 Methodology for the Completion oftfs Notification Annex IA & 1B Environmental Management System Hazardous Record Forms Log: OXEHD 01 OXEHD 02 OXEHD 03 OXEHD 04 OXEHD 05 OXEHD 06 OXEHD 07 OXEHD 08 OXEHD 09 OXEHDIO OXEHD II OXEHDI2 OXEHD 13 OXEHDI4 OXEHD 15 OXEHD 16 OXEHD 17 Control Document Daily Hazardous Load Acceptance Log Visual Load & Container Checklist Load Defect Repoli Form Customer Information Form Asbestos Declaration Register ofcontrolled Substances Permit to Work External Pre-Audit Questionnaire External Audit Checklist Audit/Incident Findings Report Form Internal Audit Questionnaire Hazardous Waste Inspection & Acceptance Area Inspection Checklist Laboratory Inspection Checklist Drum Packing List Container Load Plan Certificate of Disposal/Recovery Oxigen Environmental Ltd.

10 OXEP 23 - Management Review Procedure Oxigen o 1.0 Purpose APPROVED The purpose ofthis procedure is to ensure that the Environmental Management System is reviewed consistently and effectively at the appropriate level of management. To ensure that there is a defined review period so that the ongoing suitability and effectiveness of the Environmental Management System can be assessed. To define the steps involved in carrying out a management review ofthe EMS. To ensure that company operations are in accordance with the Environmental Management System. 2.0 References Environmental Auditing Results Environmental Objectives and targets Environmental Policy Statement Complaint Handling / Corrective Action Forms, Doc OXEPI Records Complaint Handling / Corrective Action Forms. Doc OXEPI Procedure Reviews wi II be held at least annually and wi II take the form ofa meeting attended by: The ChiefOperations Officer The Group Environmental Manager The Group Human Resources Manager Issued on: 23/03/09 A roved by: Group Environmental Revision 01

11 The Chief Financial Officer The Environmental Manager Others as appropriate The Group Environmental Manager will issue an agenda and chair the meeting. Minutes will be recorded. The reviews will include as a minimum the following but will not be limited to these topics: Review of the site Environmental Policy Actions arising from previous meetings ew and proposed legislation Review of evaluation ofcompliance with legal and other requirements The results of internal and external audits The extent to which objectives ands targets have been met The continuing suitability ofthe EMS in relation to changing business conditions and information and review of opportunities for improvement in the EMS Changes in company policy Concerns of relevant interested parties An evaluation ofthe adequacy and effectiveness ofthe EMS as it is being implemented Establishing new objectives and targets Non-conformance's Corrective action Training requirements Others as will be specified in the agenda The review data are presented to management by the Environmental Manager for discussion. Proceedings of the meeting are documented and the minutes are filed and retained for future auditing. Issued on: 23/03/09 A roved by: Group Environmental Manaoer Revision 01 OXEP 23 Pa e 2 of 3

12 (higen Em iron mental Ltd Waste Licence Re\ie\\ Application W0208-0l Atlachment C.3. C.3 HOURS OF OPERATION Oxigen Environmental Ltd proposes to retain the hours of operation as per the existing Waste Licence W I. The facility is currently licenced to operate twenty four hours a day, seven days a week.