Site Visit Report - epa.ie · Site Visit Report The site visit process is a sample on a particular...

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 Starrus Eco Holdings Limited (Millenium Business Park)

Licensee Starrus Eco Holdings Limited

Licence Register No. W0183-01

CRO Number 527552

Site Address Millennium Business Park, Grange, Ballycoolin, Dublin 11, Dublin

Site Visit Reference No. SV14468

Report Detail

Issue Date 14/03/2018

Prepared By Sandra Gleeson

Site Visit Detail

Date Of Inspection 15/02/2018 Announced No

Time In 10:12 Time Out 17:00

Agency Personnel On Site Sandra Gleeson

Licensee Personnel and Role Kieran Connor, Operations ManagerBebhinn Brennan, Environmental and Health and Safety OfficerJoe Nicholson, Health and Safety Group Manager

Photo Taken Yes Samples Taken No Video Taken No

Odour Assessment No

Site Visit Report - SV14468 - Starrus Eco Holdings Limited of 15

Scope

Site visit to evaluate compliance with the conditions of licence Reg. No. W0183-01.

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:

• Area 1 - Commercial and Industrial (C&I) waste acceptance and storage area• Area 2 - Municipal Solid Waste (MSW) acceptance and storage area• Solid Recovered Fuel (SRF) outdoor bale storage area• General yard area• Surface water shut off valve• Wastewater monitoring point SE-1

Documents Inspected

The following documents were inspected:

• Condition 3.11.5 - Bund integrity report, May 2017• Condition 3.13.2 - Daily and weekly inspection checklists, 12/02/2018 to 15/02/2018• Condition 3.13.3 - Surface water and foul water pipeline CCTV assessment, April 2016• Condition 4.12 - Waste storage plan, 26/01/2018• Condition 8.2 - Emergency response procedure (ERP), 29/12/2017• Condition 8.5 - Accident prevention procedure (APP)• Condition 9.1(d) - Site procedures, 2017• Condition 9.2 - Waste records; 01/02/2018, 08/02/2018 and 09/02/2018• Condition 9.3(d) - Odour checklist 12/02/2018 to 14/02/2018• Condition 9.4 - Complaints procedure


1. Incident Prevention

Answer Condition Number

Non Compliance

Observation

1.1 Were all recommendations from the last fire water risk assessment/fire water retention capacity assessment implemented at the site?

No 3.14.1, 8.6 Yes

Comment / Corrective Action

Recommendation No. 3 of the Fire Risk Assessment (FRA), 2017, regarding procedures for the isolation of the Millennium Park fire water retention tank, was not incorporated into the Emergency Response Plan, revised on 29/01/2018.

Corrective Action:

The licensee shall ensure the recommendations in the FRA, in relation to fire water retention, are implemented in accordance with condition 8.6 of licence Reg. No. W0183-01.


Non Compliance

Observation

1.2 Does the Accident Prevention Procedure (APP) and the Emergency Response Procedure (ERP) for the facility have regard for the Agency Guidance Note on Fire Safety at Non-Hazardous Waste Transfer Stations?

Yes 8.2, 8.5


Non Compliance

Observation

1.3 Have staff received adequate training in relation to fire prevention and response in the event of a fire incident?

Yes 2.1.3, 2.3.2.4


Non Compliance

Observation

1.4 Have trigger levels been set for surface water and groundwater parameters (that do not have ELVs specified in licence)?

Not Applicable


Non Compliance

Observation

1.5 Where discharges/emissions above licence limits/trigger levels have occurred in the preceding 12 month period has the Licensee identified the likely cause of these elevated discharges/emissions and taken appropriate corrective/preventative action to resolve any likely cause of these elevated discharges/ emissions?

Checked 5.1


Section 2.1 refers.


2. Infrastructure Integrity & Drainage


Non Compliance

Observation

2.1 Is the current drainage system and infrastructure at the site adequate to separate, control & protect surface water and groundwater?

Checked 3.13.3


All surface water at the site is currently diverted to the wastewater sewer due to on going issues with the Millennium Park Industrial Estate surface water drainage system.


3. Nuisance


Non Compliance

Observation

3.1 Where nuisance complaints have been received in the last 12 months, has the licensee sufficiently investigated these complaint(s) to identify the likely cause and has the licensee taken appropriate and sufficient action to prevent a reoccurrence of nuisance complaints?

Checked 9.4


No complaints were recorded in 2017.


4. Waste Storage


Non Compliance

Observation

4.1 Do waste storage practices contribute to the protection of surface water and groundwater and air quality and reduce the likelihood of nuisance complaints occurring i.e. regarding dust, flies, odour and litter?

No 6.2 Yes


Skips of waste metal, waste tyres and waste Flexible Intermediate Bulk Container (FIBC) bags were stored outside in the yard area, photographs DSCF0006 and DSCF0008 refer.

Corrective Action:

The licensee shall ensure no waste is stored outdoors, unless agreed in advance by the Agency in accordance with condition 6.2.


Non Compliance

Observation

4.2 If waste storage practices are not satisfactory, has the Licensee identified corrective/preventative measures to resolve these storage issues and mitigate associated risks?

No 4.12.5 Yes


During the site visit the following waste storage practices were not in accordance with the Waste Storage Plan (WSP) provided.

• Maximum stockpile size for Commercial and Industrial (C&I) waste, photograph DSCF0001 refers• Storage of oversized rubble, photograph DSCF0010 refers• Storage of waste gas cylinders and waste PVC windows

The licensee subsequently submitted an updated WSP to the Agency on the 20/02/2018, LR033458 refers.

In addition, the licensee indicated that a new concrete cruncher for breaking up the oversized rubble was being purchased to process the stockpile on site.

Corrective Action:

The licensee shall ensure that the WSP fully complies with condition 4.12.5.


Non Compliance

Observation

4.3 Do current waste handling activities (other than waste storage) contribute to the protection of suface water and groundwater and air quality?

Yes 4.2, 4.3


Non Compliance

Observation

4.4 Were all matters in relation to the integrity testing of bund, tanks & pipelines and containment structures at the facility satisfactory?

Yes 3.13.3



Non Compliance

Observation

4.5 Were all containers of hazardous materials appropriately stored within bunds?

No 3.11.2 Yes


At the time of the site visit paint cans and drums were stored inappropriately in a mobile bund in the skip maintenance shed, photograph DSCF0013 refers.

Corrective Actions:

The licensee shall ensure that containers on mobile bunds are stored in a manner that contains potential leaks and spills.

In addition, the volume of the bund shall be in accordance with condition 3.11.2.


Non Compliance

Observation

4.6 Were all valves & flanges associated with bunded tanks contained within bunded areas?

Yes 3.11.4


Non Compliance

Observation

4.7 If spills/stains are evident outside bunds, has the Licensee identified and put a plan of action in place to mitigate this issue from recurring?

Not Applicable


5. Site Specific Issues


Non Compliance

Observation

5.1 Hardstanding Checked 3.6.3, 5.7 Yes


A large pothole was observed in the hardstanding in front of the Construction and Demolition (C&D) waste storage bay in Area 1, photograph DSCF0003 refers. In addition, leachate and standing water was observed in this area, photographs DSCF0004 and DSCF0005 refer.

The licensee indicated that repair works were scheduled for the hardstanding in Area 1. A review of documentation during the site visit indicated corrective maintenance works were scheduled to repair the damaged hardstanding.

Corrective Actions:

The licensee shall ensure that the hardstanding is maintained in accordance with condition 3.6.3.

In addition, all leachate and wastewater shall be disposed of appropriately in accordance with condition 5.7.


Non Compliance

Observation

5.2 Baled Solid Recovered Fuel (SRF) Checked 4.12.6, 8.6 Yes


The storage areas (A, B and C) for baled Solid Recovered Fuel (SRF) were not clearly delineated, photograph DSCF0015 refers.

In addition, the dates recorded on the bales did not correlate with the storage system (first in, first out) in place to track the bales.

Corrective Actions:

The licensee shall store the baled SRF in accordance with condition 4.12.6.

In addition, the licensee shall implement recommendations from the Fire Risk Assessment, regarding marking on the ground the bale storage areas A, B, C and D and the installation of external heat detection cameras, in accordance with condition 8.6.


Non Compliance

Observation

5.3 Surface Water Drainage Checked 3.13.2 Yes


At the time of the site visit surface water drainage was diverted to the wastewater sewer system. However, a number of the surface water gullies in the general yard area contained mud and debris, photographs DSCF0007 and DSCF0014 refer.

Corrective Action:

The licensee shall ensure that the drainage system is properly maintained at all times in accordance with condition 3.13.2.


Photographs

DSCF0006 Waste tyres and FIBC bags stored outdoors

DSCF0008 Waste metal stored outdoors


DSCF0001 Commercial and industrial waste in Area 1

DSCF0010 Oversized rubble in Area 2


DSCF0013 Mobile bund with paint cans and drums

DSCF0003 Water and leachate at C&D waste storage bay in Area 1


DCSF0004 Standing water in pothole in Area 1

DSCF0005 Standing water at clean timber storage bay in Area 1


DSCF0015 Solid Recovered Fuel (SRF) bale storage area

DSCF0007 Mud in surface water gully


DSCF0014 Mud and debris in surface water gully


Summary

Seven observations were recorded during the site visit.

The licensee shall inform the Agency in advance of recommencing discharge to the Millennium Park surface water drainage system.

The licensee shall adhere to the conditions of licence Reg. No. W0183-01, 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 Compliance 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) Compliance 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 Compliance Investigation through the EDEN system. You will receive notification when a Compliance 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 Number in any future correspondence in relation to this Report.


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