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 Enva Ireland Limited (Naas Road) Enva Ireland Limited Licence Register No. W0196-01 CRO 317186 Site Address Site Visit Reference No. John F. Kennedy Industrial Estate, John F. Kennedy Road, Naas Road, Dublin SV11053 Report Detail Issue Date 11/05/2017 Prepared By Barry O'Connor Site Visit Detail Date Of Inspection 13/04/2017 Announced No Time In 09:20 Time Out 16:55 Agency Personnel On Site Licensee Personnel and Role Rachel Griffith Barry O'Connor Tom Keogh - Site Supervisor Sarah Louise Malone - Site Administrator Richard Kennedy - Business Manager Photo Taken Yes Samples Taken No Video Taken No Site Visit Report - SV11053 - Enva Ireland Limited Page 1 of 15
Scope Site visit to assess compliance with Licence Reg. No. W0196-01. Media The following environmental media were assessed at the time of the site visit: Waste Water Air Site Areas Inspected The following site areas were inspected at the time of the site visit: Waste storage areas including areas 1 and 2 Waste treatment area Tank farm Yard areas Maintenance shed Sampling points Documents Inspected The following documents were inspected at the time of the site visit: 3.12.8: Bund Register 3.13.5: Surface water inspection record (SW1), Effluent inspection record (SE3) and Interceptor Cleaning record (2017) 3.13.6: Pipeline pressure tests (2014) 5.2: Waste acceptance records (2017) and rejected loads records (2017) 8.1: Groundwater and surface water monitoring records (2017) 7.1: Nuisance Control Inspection Record (2017) 9.2: Emergency response procedure and firewater risk assessment (2012) 10.3: Fire drill records, training certificates, fire safety awareness training records (2016) 12.2.1: Environmental Liabilities Risk Assessment - ELRA (2014) 4.1: Closure, Restoration and Aftercare Management Plan - CRAMP Site Visit Report - SV11053 - Enva Ireland Limited Page 2 of 15
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? Not Applicable 9.1 / 2A 1.2 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? Not Applicable 9.1 / 2B Site Visit Report - SV11053 - Enva Ireland Limited Page 3 of 15
2. Incident Prevention 2.1 Are emergency shut-off valves for discharges to sewer and surface water easily accessible and clearly labelled? Yes 3.13.2.1 2.2 Have staff received adequate training in relation to fire prevention and response in the event of an incident? Checked 2.1.3 / 10.3(b) Yes The training record for Gary Cummins was incomplete for the following sections: Fire Safety Awareness Use of extinguishers Fire Protection The licensee indicated that the above training has been completed but the record is yet to be updated. Action: The licensee shall maintain up to date records of all training undertaken by facility staff. Furthermore, the licensee shall ensure that personnel performing specifically assigned tasks shall be qualified on the basis of appropriate education, training and experience, as required and shall be aware of the requirements of Licence Reg. No. W0196-01. 2.3 Has the site been free of discharge/emission exceedances in the preceding 12 month period? Yes 6.1 Site Visit Report - SV11053 - Enva Ireland Limited Page 4 of 15
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? Checked 3.12.8 Refer to Section 6.1. 3.2 Has a fire water risk assessment been undertaken for the site and all associated actions been implemented? Yes 9.2 3.3 Is the current drainage infrastructure serving the waste storage and handling areas adequate to collect & divert run-off? Yes 3.13 3.4 Where abatement infrastructure is installed, is it adequately maintained and operated? Checked 5.7.1 Yes A carbon filter is located at the top of the holding tanks to reduce fugitive odour causing emissions. The carbon filter is not recorded on the site's preventative maintenance schedule. Action: The licensee shall ensure the carbon filter is being maintained in accordance with the instructions issued by the manufacture and shall include the filter on the site preventative maintenance schedule. Written records of all maintenance shall be maintained and kept on-site by the licensee. Site Visit Report - SV11053 - Enva Ireland Limited Page 5 of 15
4. Waste Acceptance Procedures / LoW Codes 4.1 Is documentation available to demonstrate that the waste characterisation undertaken is satisfactory? Yes 5.2.2, 5.2.6 4.2 Is compositional analysis performed as part of the initial hazardous waste characterisation process? Yes 5.2.2 4.3 If wastes are accepted from a known customer, are spot checks performed intermittently to verify the baseline characterisation data? Yes 5.2.3 Site Visit Report - SV11053 - Enva Ireland Limited Page 6 of 15
5. Waste Handling 5.1 Is appropriate infrastructure installed, operated and maintained to mitigate the risk of an incident occurring? Checked 5.7 Yes A metal rack supporting an intermediate bund container (IBC) containing waste was damaged, photograph DSCF0019 refers. Action: The licensee shall ensure the appropriate storage of materials at all times. 5.2 Is there a documented waste acceptance procedure maintained at the facility? Yes 5.2.2 Yes The waste acceptance procedure has not been updated. This issue was raised in a previous Agency site inspection in 2016, site visit Ref. No. SV08255 refers. Action: The licensee shall review and update the waste acceptance procedures at the facility, without delay, as was previously set out in a corrective action during an Agency site visit in 2016. 5.3 Are all containers, including waste and fuel tanks and drums, labelled to clearly indicate their contents? Checked 5.3.7 5.5 Is all waste stored in designated areas, protected as may be appropriate against spillage and contaminated run-off? Yes 5.4 Where a waste acceptance procedure is in place, is it being complied with? Yes Site Visit Report - SV11053 - Enva Ireland Limited Page 7 of 15
6. Site Specific Issues 6.1 Bunding Checked 3.12.8, 3.13.5 Yes All of the mobile bunds observed on site are not recorded on the facilities bund register, and records were not available to demonstrate their integrity to the Agency on the day. This is in non-compliance with 3.12.8. A bund located in the Rundown Screen Building, reference number 3, was full of oil, photograph DSCF0012 refers. The tanker dig out bund, reference number 7, contained a volume of aqueous waste and was not desludged as necessary, photograph DSCF0002 refers. This is in non-compliance with 3.13.5. Action: The licensee shall update the facilities bund register to include all bunds in use on site. Records of the integrity and water tightness of all the bunds and their resistance to penetration by water or other materials stored therein shall be kept by the licensee. All bunds shall be inspected weekly, desludged as necessary and properly maintained at all times. The licensee shall ensure that all bunds, including fixed and mobile bunds, are included in the sites inspection checklist, without delay. 6.2 DMP / ELRA Checked 4.1, 12.2.1 Yes An ELRA dated 2014 was reviewed on the day of inspection. A Decommissioning Management Plan (DMP) was not available for review during the inspection. This issue was previously raised by the Agency in a 2016 site visit Ref. No. SV08255 refers. This is in non-compliance with 4.1 Action: The licensee shall update the facilities ELRA, and prepare a fully detailed and costed plan for the decommissioning or closure of the site as per the previous corrective action outlined in Section 1.1 of the 2016 Agency site visit Ref. No. SV08255, without delay. 6.3 Emergency Response Procedure (ERP) Checked 9.2 Yes Site Visit Report - SV11053 - Enva Ireland Limited Page 8 of 15
The ERP was reviewed and the following observations were made on the day of the inspection: - The document was not dated. - Site maps were illegible. - The interceptor shut off valve is referenced in the 'General evacuation roles' section only. - The ERP does not reference the EPA 'Guidance to licensee on the Preparation of Accident Prevention Procedures and Emergency Response Procedures' document. - No reference is made to how emergency scenarios occurring out of normal hours of operation will be detected and communicated. - An up to date waste storage map for the facility is not included. - The document did not contain a senior site manager or company director signature. Action: The licensee shall carry out a review the facilities ERP document and update as required. 6.4 Filter Press Interceptor Spill Checked 3.12.4 Yes The filter press was not operating on the day of the inspection and a spillage was observed in the tank farm bund which the licensee indicated was from an overtopping of the filter press interceptor tank. The licensee indicated that more oil than normal had entered the interceptor tank through the process sludge treatment, causing a possible blockage of the sump and the licensee stated an investigation had commenced as to how this had occurred. The licensee stated that staff from another of the licensee's facilities were due on site to carry out a clean up of the bund. The licensee indicated that the filter press interceptor tank was last cleaned out on the 23/01/2017. Action: The licensee shall empty the filter press interceptor tank and carry out a clean up of the bund, without delay. The licensee shall investigate the reason for the spillage from the interceptor tank, record and retain the results of the investigation and put suitable preventative measures in place to avoid a re-occurrence. The licensee shall carry out a review of the suitability of the frequency of preventative maintenance currently scheduled for the interceptor tank. 6.5 Process Flow Diagram No 5.5.1 Yes The licensee could not provide an up to date process flow diagram for the facility on the day of inspection. Action: The licensee shall carry out activities in accordance with the facilities process flow diagram, a copy of which shall be available for inspection at all times. 6.6 Outdoor storage covers Checked Yes Site Visit Report - SV11053 - Enva Ireland Limited Page 9 of 15
The waste alum sludge pile in Bund 7 in the yard area was un-covered at the time of inspection, photograph DSCF0002 refers. The licensee indicated that the metal bars used to support the bund cover were currently under repair. The hazardous filter cake from the press was stored in a partially covered skip in the yard area. Creosote coated ESB poles were observed stored in an open top trailer unit in the yard. Action: The licensee shall ensure that all wastes stored in yard areas are covered at all times. 6.7 Spillages Checked 3.12.5, 9.3, 9.4.2 Yes Spillages of landfill leachate to hardstanding were observed during the tanker truck unloading process, photograph DSCF0008 refers. Action: The licensee shall prevent and/or put measures in place to capture spillages during transfers to the facilities tank farm. 6.8 Colour coded gullies Checked 3.13.4 Yes Some surface water gullies in the yard area were not appropriately colour coded, photograph DSCF0004 refers. Action: All surface water discharge gullies, drainage grids and manhole covers shall be painted with blue triangles. These colour codes shall be maintained so as to be visible at all times during facility operation. 6.9 Environmental Objectives Checked 2.3.2.1 Yes An air line hose used in the transfer of waste liquids to the tank farm was in constant operation during the site visit, despite no transfer of liquids occurring. The licensee indicated that this was not a maintenance issue, but does lead to a higher energy use at the facility. Action: The licensee shall give adequate consideration to updating the facilities Schedule of Environmental Targets and Objectives to target a specific reduction in energy use through the air line hose and/or any other energy reduction measures deemed appropriate. 6.10 High Level Alarm Checked 3.12.3 Yes Site Visit Report - SV11053 - Enva Ireland Limited Page 10 of 15
The grease tank (No.7) in the tank farm does not contain a high level alarm and a manual process is in place to record levels of grease. The licensee indicated that the facility were considering the installation of a SCADA remote monitoring system for all the storage tanks at the facility. Action: The licensee shall ensure compliance with 3.12.3. 6.11 Monitoring Reports Checked 10.3(e) Yes The sewer monitoring reports reviewed did not contain a summary, discussion or conclusion and did not specify the Emission Limit Value (ELV) beside the monitoring results. Action: All monitoring reports submitted to the Agency for review shall include a licensee summary as a minimum. The licensee shall specify the ELV value on result tables, or other, to allow for a direct comparison. Site Visit Report - SV11053 - Enva Ireland Limited Page 11 of 15
Summary 2 non-compliances and 13 observations were recorded against Licence Reg. No. W0196-01 during the site visit. The licensee shall implement each of the corrective actions outlined in this report in order to rectify the issues raised, without delay. 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, www.epa.ie, 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 - SV11053 - Enva Ireland Limited Page 12 of 15
Photographs 13/04/2017 DSCF0019: IBC stored on damaged racking DSCF0012: Bund full of oil in Rundown Screen Building Site Visit Report - SV11053 - Enva Ireland Limited Page 13 of 15
DSCF0002: Bund 7 Alum sludge containing aqueous waste DSCF0008: Tanker leachate spillage Site Visit Report - SV11053 - Enva Ireland Limited Page 14 of 15
DSCF0004: Surface water gully not appropriately colour coded Site Visit Report - SV11053 - Enva Ireland Limited Page 15 of 15