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 Safety Kleen Ireland Ltd Safety Kleen Ireland Limited Licence Register No. W CRO Site Address Site Visit Reference No. Unit 5, Airton Road, Tallaght, Dublin 24, Dublin SV11140 Report Detail Issue Date 22/02/2017 Prepared By Rachel Griffith Site Visit Detail Date Of Inspection 24/01/2017 Announced No Time In 09:23 Time Out 15:10 Agency Personnel On Site Rachel Griffith Licensee Personnel and Role Ceri Davies, Branch Manager Gavin Scully, Facility Administrator Photo Taken No Samples Taken No Video Taken No Site Visit Report - SV Safety Kleen Ireland Limited Page 1 of 12

2 Scope Enforcement plan visit to assess compliance against the conditions of Licence Reg. No. W Media The following environmental media were assessed: Waste Water Air. Site Areas Inspected The following site areas were inspected: Internal waste storage areas External yard area. Documents Inspected The following documents were inspected: Training records 3.12 Waste records and Waste Transfer Forms (WTF) Bund integrity test report Waste acceptance procedure Technical assessment reports Closure plan 9.1/ Schedule F.2 - Groundwater monitoring reports 9.1/ Schedule F.3 - Air monitoring reports Emergency Response Procedure (ERP) Site specific risk assessments Environmental Liabilities Risk Assessment (ELRA) Site plan Site Visit Report - SV Safety Kleen Ireland 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? Not Applicable 3.1(a), (vi) There have been no discharge/emission exceedances in the preceding 12 month period. Site Visit Report - SV Safety Kleen Ireland 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? No 7.5 Yes The penstock valve in the outdoor bunded area is not clearly labelled. The penstock valve should be clearly labelled so that it can be accessed immediately in the event of an emergency. 2.2 Have staff received adequate training in relation to fire prevention and response in the event of an incident? Yes 2.5, 2.10 Site Visit Report - SV Safety Kleen Ireland 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? No Yes The integrity and water tightness of the two flammable waste storage containers has not been tested. This is in non-compliance with of the Licence. The integrity and water tightness of these containers shall be tested and shall be reported to the Agency without delay. 3.2 Has a fire water risk assessment been undertaken for the site and all associated actions been implemented? No 1.3, 10.6 Yes Fire water retention barriers which were required to be installed within the waste storage building by the 30/06/2015 were not in place at the time of the site visit. This was previously raised in site visit report ref. SV This is in non-compliance with 1.3 of the Licence. The licensee is required to install the fire water retention barriers detailed in licensee return ref. LR by the 31/03/2017 and shall submit a site update through the EDEN portal by this date confirming that the installation has been completed. 3.3 Is the current drainage infrastructure serving the waste storage and handling areas adequate to collect & divert run-off? Yes 4.6, Where abatement infrastructure is installed, is it adequately maintained and operated? Not Applicable 7.2 Site Visit Report - SV Safety Kleen Ireland Limited Page 5 of 12

6 There is no abatement infrastructure installed at the facility. Site Visit Report - SV Safety Kleen Ireland 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 Is compositional analysis performed as part of the initial hazardous waste characterisation process? Yes 4.3 If wastes are accepted from a known customer, are spot checks performed intermittently to verify the baseline characterisation data? Yes Site Visit Report - SV Safety Kleen Ireland Limited Page 7 of 12

8 5. Waste Handling 5.1 Is appropriate infrastructure installed, operated and maintained to mitigate the risk of an incident occurring? Yes Is there a documented waste acceptance procedure maintained at the facility? Yes Are all containers, including waste and fuel tanks and drums, labelled to clearly indicate their contents? Yes Where a waste acceptance procedure is in place, is it being complied with? Yes Is all waste stored in designated areas, protected as may be appropriate against spillage and contaminated run-off? Yes 4.6 Site Visit Report - SV Safety Kleen Ireland Limited Page 8 of 12

9 6. Site Specific Issues 6.1 Waste records Checked 3.12 Yes Hazardous waste from a histology laboratory containing Diaminobenzidine (DAB) was incorrectly recorded on the licensee s internal database and the 2015 AER as List of Waste (LoW) code (medicines). The licensee s technical assessment report for this waste type identifies LoW code * (chemicals consisting of or containing hazardous substances) as being the appropriate code. Records of waste arriving at the facility (Waste Transfer Forms) show that the LoW code recorded at collection was *. Records of waste departing the facility show that the LoW code assigned to the DAB waste was changed to * when it was dispatched to Veolia. The licensee shall ensure that the correct LoW code is applied to all waste streams. The LoW applied to a waste type accepted at the facility for storage prior to transfer should not change when the waste is dispatched from the facility. The licensee shall ensure that accurate written records of waste to include associated LoW codes are maintained at the facility at all times and are reported to the Agency as required. In addition, the licensee shall ensure that, in advance of transfer to another company, waste shall be classified in accordance with National and European standards. 6.2 Decommissioning Management Plan (DMP) Checked Yes A site closure plan dated July 2010 was reviewed on site. The Decommissioning Management Plan (DMP) has not been submitted to the Agency for agreement in accordance with 8.2. This plan was required to be submitted by the 16/06/2016. This is in non-compliance with of the Licence. The licensee shall prepare, to the satisfaction of the Agency, a fully detailed and costed plan for the decommissioning or closure of the site. The licensee shall have regard to the Agency guidance as detailed in and shall include, as a minimum, the information detailed in 8.3 of the Licence. The DMP shall be submitted to the Agency without further delay as a Licensee Return on the EDEN portal. Document type Environmental Liabilities, Closure and Financial Provision and document subtype Closure, Restoration and Aftercare Management Plan (CRAMP), Residuals Management Plan (RMP) or Decommissioning Management Plan (DMP) should be selected. Site Visit Report - SV Safety Kleen Ireland Limited Page 9 of 12

10 6.3 Environmental Liabilities Risk Assessment (ELRA) Checked Yes The Environmental Liabilities Risk Assessment reviewed at the facility was dated 18/05/2009. The financial provision in place to cover the liabilities has expired. The licensee is required to review and update this risk assessment having regard for the Agency s Guidance on Assessing and Costing Environmental Liabilities (2014) and Guidance on Financial Provision for Environmental Liabilities (2015). The ELRA shall be submitted to the Agency without delay as a Licensee Return on the EDEN portal. Document type Environmental Liabilities, Closure and Financial Provision and document subtype Environmental Liabilities Risk Assessment (ELRA) should be selected. 6.4 Emergency Response Procedure (ERP) Checked 10.1, , 2.10 Yes The Emergency Response Procedure (ERP) reviewed on site was not to the satisfaction of the Agency. A site plan was not included There was no reference to the penstock valve and key The requirement to notify the Agency was not included A complete contact list was not included. In addition, staff had not been trained in the emergency response procedure. The licensee is required to review the Emergency Response Procedure having regard for the Agency Guidance to Licensees on the Preparation of Accident Prevention Procedures and Emergency Response Procedures (2016). The reviewed procedure shall be maintained on site and all relevant staff shall be trained in the procedure at appropriate intervals. Site Visit Report - SV Safety Kleen Ireland Limited Page 10 of 12

11 s NC Type Date of Date of Notification NC Failure to provide/install infrastructure 01/07/ /01/ Fire water retention barriers which were required to be installed within the waste storage building by the 30/06/2015 were not in place at the time of the Agency site visit on the 24/01/2017. This was previously raised in site visit report ref. SV NC Type Date of Date of Notification NC Bunding & Materials handling 24/01/ /01/ The integrity and water tightness of the two flammable waste storage containers at the facility has not been tested. NC Type Date of Date of Notification NC ELRA/CRAMP/FP 17/12/ /01/ A Decommissioning Management Plan (DMP) has not been submitted to the Agency for agreement in accordance with 8.2. This plan was required to be submitted by the 16/06/2016. Site Visit Report - SV Safety Kleen Ireland Limited Page 11 of 12

12 Summary There were three non-compliances recorded during the site inspection relating to firewater retention, bund testing and the Decommissioning Management Plan (DMP). There were four observations recorded during the site inspection. The licensee shall implement each of the corrective actions required to address the issues raised. 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. 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. 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. 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 Safety Kleen Ireland Limited Page 12 of 12