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 KMK Metals Recycling Limited KMK Metals Recycling Limited Licence Register No. W CRO Site Address Site Visit Reference No. Cappincur Industrial Estate, Daingean Road, Tullamore, Offaly SV11206 Report Detail Issue Date 28/03/2017 Prepared By Dermot Burke Site Visit Detail Date Of Inspection 28/02/2017 Announced No Time In 10:40 Time Out 14:00 Agency Personnel On Site Dermot Burke Licensee Personnel and Role Kurt Kyck, Owner Max Kyck, General Manager Olivia Brennan, Environmental Manager Kai Meyer, B2B Manager Edita Jurkeviciute-Ptasinskis, Logistics Manager Photo Taken Yes Samples Taken No Video Taken No Site Visit Report - SV KMK Metals Recycling Limited Page 1 of 12

2 Scope The purpose of the site visit was to check compliance with Industrial Emissions Licence Reg. No. W Media On-site inspections concerned the following environmental media: Land Air Water Site Areas Inspected The following areas were inspected during the course of the site visit: Waste intake yard Area C and hazardous waste storage building Waste Electrical and Electronic Equipment (WEEE) intake building and Small Household Appliance (SHA) processing plant Cathode Ray Tube (CRT) and flat screen processing buildings Large Household Appliance (LHA) processing building On-site waste water treatment plant, sand filter and discharge point F External yard Area D4 Waste storage shed and yard Area E Documents Inspected The following documents were inspected during the course of the site visit: Records of weekly inspection checks Air abatement infrastructure maintenance records Incoming waste characterisation documentation Waste hauiler check documentation Site drainage network map Fire water retention report 2010 Materials profiling and acceptance (incoming) procedure 301-PRO-IMS, Version 5 Site Visit Report - SV KMK Metals Recycling Limited Page 2 of 12

3 1. Incidents and Complaints 1.1 If discharge/emission exceedances have occurred in the preceding 12 month period, was the EPA and any other appropriate authorised authority notified as per licence requirements? Yes 11.1, If discharge/emission exceedances have occurred in the preceding 12 month period, has the Licensee taken appropriate and effective actions to mitigate a recurrence of these incidents? Yes 11.3, 2B of Industrial Emissions Amendment Breaches of storm water trigger levels were dealt with under incidents referred to in Q1.1 above. Site Visit Report - SV KMK Metals Recycling Limited Page 3 of 12

4 2. Incident Prevention 2.1 Are emergency shut-off valves for discharges to sewer and surface water easily accessible and clearly labelled? Yes Yes The site drainage map for the installation does not clearly show the location of the drainage system emergency shut-off valves. The drawing also needs to be updated to show the revised drainage layout for the DX discharge. Corrective Action: The licensee shall revise the site drainage map to show the location of the drainage system emergency shut-off valve and to show the revised drainage layout of the DX discharge. A copy of the revised drainage map shall be maintained on-site for inspection by the EPA during future site visits. 2.2 Have staff received adequate training in relation to fire prevention and response in the event of an incident? Yes 2.1.2, The licensee conducts regular toolbox talks which include information regarding fire prevention and response. The licensee conducted a fire safety risk assessment of the installation in 2015 which formed part of the annual ISO audit of the site. 2.3 Has the site been free of discharge/emission exceedances in the preceding 12 month period? No 5.1 3No. breaches of Total Phosphorus for emissions to water at discharge point F during 2016 (10/05/2016, 08/09/20169 & 23/11/2016) were reported to the EPA as updates under INCI that was submitted to the EPA in December No. breaches of the storm water trigger levels were notified to the EPA in 2016 under INCI and INCI Site Visit Report - SV KMK Metals Recycling Limited Page 4 of 12

5 3. Infrastructure Integrity & Drainage 3.1 Has the integrity of bunds, tanks, pipelines and containment structures been demonstrated to the Agency and are these fit for purpose? Yes 6.9 Bunds on-site were tested in 2016 and a report on the testing was submitted to the EPA under LR Tank integrity testing was completed in January 2017 and a report on the testing will be submitted to the EPA once available. The licensee has scheduled for underground pipelines on-site to be tested by the end of Quarter Has a fire water risk assessment been undertaken for the site and all associated actions been implemented? No Yes The fire water risk assessment for the installation was to be revised and submitted to the EPA by 20/06/2014. The EPA has not received a revised assessment to date. This is in non-compliance with of Licence Reg. No. W Corrective Action: The licensee shall comply with of Licence Reg. No. W and revise the existing fire water risk assessment to determine if the activity, incorporating the newest licensed area of the installation should have a fire-water retention facility. The licensee shall submit the revised assessment and a report on the findings and recommendations of the assessment to the EPA by 30/04/2017. The licensee shall have regard to the EPA draft Guidance Note to Industry on the Requirements for Fire-Water Retention Facilities, which can be downloaded at the following web address: Is the current drainage infrastructure serving the waste storage and handling areas adequate to collect & divert run-off? Yes Is a documented preventative maintenance and repair programme for hard standing in place? Yes Site Visit Report - SV KMK Metals Recycling Limited Page 5 of 12

6 3.5 Where abatement infrastructure is installed, is it adequately maintained and operated? Yes 6.6 Site Visit Report - SV KMK Metals Recycling Limited Page 6 of 12

7 4. Waste Acceptance Procedures / LoW Codes 4.1 Is documentation available to demonstrate that the waste characterisation undertaken is satisfactory? Yes Waste characterisation documentation was reviewed in relation to 3No. customers: Advanced Environmental Solutions, SIMS Recycling Solutions UK and Starrus Eco Holdings Ltd. 4.2 Is compositional analysis performed as part of the initial hazardous waste characterisation process? Yes Reports on waste compositional analysis are sent by customers to the licensee prior to agreeing to accept the waste. 4.3 If wastes are accepted from a known customer, are spot checks performed intermittently to verify the baseline characterisation data? Yes Spot checks are carried out on regular customers from time to time to verify the waste characteristics. Site Visit Report - SV KMK Metals Recycling Limited Page 7 of 12

8 5. Waste Storage 5.1 Are wastes appropriately stored and in designated storage areas i.e. not in aisles or outdoors, bunded, accessible, labelled, issues visible, segregated to prevent cross-contamination suitably sized, etc. Yes 8.5 Site Visit Report - SV KMK Metals Recycling Limited Page 8 of 12

9 6. Waste Handling 6.1 Is appropriate infrastructure installed, operated and maintained to mitigate the risk of an incident occurring? Yes 6.2 Are all containers, including waste and fuel tanks and drums, labelled to clearly indicate their contents? Yes Is there a documented waste acceptance procedure maintained at the facility? Yes Is all waste stored in designated areas, protected as may be appropriate against spillage and contaminated run-off? Checked 8.5 Yes Site Visit Report - SV KMK Metals Recycling Limited Page 9 of 12

10 Waste storage/handling practices on-site have the potential to impact on the quality of the storm water runoff from open yard areas on-site, namely: A stockpile of crushed and shredded plastic/metal material from the SHA processing plant stored in a bay in the Area E shed is open to wind and rain coming from the southern, eastern and northern directions. Liquid runoff from this material stockpile can flow uncontrolled towards the adjacent storm water drain in the Area E yard (See Appendix- Photos). The licensee representative said that this material is loaded by mechanical scoop from the stockpile onto trailers parked in the Area E yard. Dust and fine material from this loading operation can fall into the storm water drain in the Area E yard. The EPA notes that there have been intermittent exceedances of the storm water trigger levels for metals at storm water discharge point E in 2015 and The yard areas D4 and E were covered in what appeared to be a fine dust and the dust had been turned into a sludge-like coating on the surface of the yard by the rain that had fallen on the day of the site visit. The source of the dust appears to be the SHA processing plant building. It appears that the dust is being brought around the site on the wheels of the vehicles handling waste. This dust sludge can be washed into the storm water drainage system in these areas. Corrective Actions: Given the risk posed by the waste storage and handling practices on-site, the license shall implement the following measures to reduce the risk to the quality of the storm water run-off from these open yard areas: Cease the loading of crushed and shredded plastic/metal material from the SHA processing plant in close proximity to the storm water drain in the Area E yard. Intensify the daily sweeping/cleaning down of all external yard areas to ensure the dust/sludge material from waste processing buildings on-site is prevented from entering the storm water drainage system. Increase the cleaning of on-site storm water drainage system from twice a year to three times a year in order to prevent a build up of dust/sludge material in the drains and pipework. Inspect the storm water drainage system oil interceptors for the DX and E discharges and the on-site storm water attenuation tank twice a year and de-sludge/ clean out if necessary. 6.4 Where a waste acceptance procedure is in place, is it being complied with? Yes Site Visit Report - SV KMK Metals Recycling Limited Page 10 of 12

11 Summary 1No. non-compliance was recorded against licence condition of Licence Reg. No. W in relation to: Not submitting a revised fire water risk assessment for the installation. 2No. observations were recorded that require action to be taken by the Licensee, namely: 1. Revise the site drainage map for the installation. 2. Implement measures to reduce the risk to the quality of storm water discharges from the site. The EPA will follow up on these issues at future site visits. 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 KMK Metals Recycling Limited Page 11 of 12

12 Photographs Photos No.1 & 2 Stockpile of crushed and shredded plastics/metals in Area E shed and storm water drainage channel in the Area E yard where material is loaded. Photos No.3 & 4 Fine dust sludge on surface of the concrete hardstand in the SHA processing plant building and on the Area D4 yard. Site Visit Report - SV KMK Metals Recycling Limited Page 12 of 12