site visit report · img_0015 refers. in addition: • odour was detected by inspectors at the...

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 Greyhound Recycling & Recovery

Licensee Greyhound Recycling and Recovery

Licence Register No. W0205-01

CRO Number 266930

Site Address Crag Avenue , Clondalkin Industrial Estate , Clondalkin, Dublin 22, Dublin

Site Visit Reference No. SV15981

Report Detail

Issue Date 11/10/2018

Prepared By Hilda Robinson

Site Visit Detail

Date Of Inspection 11/09/2018 Announced No

Time In 09:43 Time Out 11:37

Agency Personnel On Site Barry O'Connor

Hilda Robinson

Licensee Personnel and Role Siobhain Kelly, Environmental Health and Safety OfficerJP O'Keeffe, Environmental Health and Safety OfficerDarius Swirtek, Production and Maintenance SupervisorJohn Brosnan, Managing Director

Photo Taken Yes Samples Taken No Video Taken No

Odour Assessment Yes Odour Assessment Compliant No

Site Visit Report - SV15981 - Greyhound Recycling and Recovery of 9

Scope

Site visit to carry out a routine odour impact assessment and to undertake a subsequent odour verification site assessment as part of an open compliance investigation in relation to odour nuisance CI001677 refers.

The purpose of this report is to present the findings of the site visit.

Media

The following environmental media were assessed at the time of the site visit:

• Air• Waste.

Site Areas Inspected

The following areas were inspected at the time of the site visit:

• Waste Recovery Building (WRB) 1• Waste Recovery Building (WRB) 2• Yard areas• Maintenance workshop.

Documents Inspected

The following document was inspected at the time of the site visit:

• Condition 6.10.1: Odour Investigation Field Record Sheets, 10/09/2018 and 11/09/2018.


1. Site Specific Issues

Answer Condition Number

Non Compliance

Observation

1.1 Was the EPA odour assessment compliant?

No 5.4, 6.3.3(ii) Yes

Comment / Corrective Action

An odour assessment was undertaken on the 11/09/2018.

'Intermittent' and 'Moderate' perfume and waste type odours were detected downwind of the facility during the assessment.

A subsequent inspection of the facility noted the following:

• 3 front shovel loader vehicles parked in the yard area which Agency inspectors identified as odour sources and one machine containing waste debris on its front shovel, photographs IMG_0017 and IMG_0018 refer

• A pedestrian door within WRB 2 was propped in an open position by a plank of wood, photograph IMG_0015 refers.

In addition:

• Odour was detected by inspectors at the sniff ports for the odour abatement system, refer to Section 1.2

The odour detected at the sniff ports and in the vicinity of the sniff ports was consistent with the odour detected at a downwind location off-site.

This is in non-compliance with Condition 5.4.

Furthermore a review of the licensee's odour assessment for 11/09/2018 recorded a 'intermittent' and 'moderate' odour at a downwind location.

Corrective Action:

The licensee shall adhere to the actions contained within the Compliance Investigation opened by the Agency on the 23/08/2018 in relation to odour nuisance, CI001677 refers.

The licensee shall maintain a continuous negative air pressure throughout WRB 2 and shall ensure that all doors are kept closed where possible to prevent significant escape of odours.

The licensee shall ensure that the activities shall be carried out in a manner such that emissions, including odours, do not result in significant impairment of, and/or significant interference with amenities or the environment beyond the facility boundary.


Non Compliance

Observation

1.2 Checks on Odour Abatement System Checked 6.15, 6.3.3, 9.3.1, 11.2.3

Yes


On the day of the site visit, the licensee indicated that the odour abatement system would require an immediate assessment by odour consultants to identify issues with the system.

Corrective Action:

The licensee shall adhere to the actions contained within the Compliance Investigation opened by the Agency on the 23/08/2018 in relation to odour nuisance, CI001677 refers.



Non Compliance

Observation

1.3 Were all valves within their bunded areas? No 3.18.5 Yes


A valve on an Integrated Bulk Container (IBC) within the maintenance workshop was not within its bunded area, photograph IMG_0022 refers.

Corrective Action

The licensee shall ensure the IBC valve is within the bunded area in accordance with Condition 3.18.5, without delay.


Non Compliance

Observation

1.4 Was access to all areas in WRB 2 possible?

Checked 3.16, 8.5 Yes


Access routes to waste stored at the rear of WRB 2 were not cleared of waste, photograph IMG_0011 refers.

This issue was previously raised with the licensee, site visit SV15959 refers.

Corrective Action:

The licensee shall ensure all walkways are unobstructed.

Waste shall be stored in designated areas, protected as may be appropriate, against spillage and leachate run-off.


Non Compliance

Observation

1.5 Incident Notification - Odour Abatement System

Checked 9.3, 11.2.3 Yes


At the time of the site visit, the odour abatement system was not functioning correctly, section 1.2 refers.

Corrective Action:

Any malfunction or breakdown of key control equipment leading to a loss of control of the management system shall be notified to the Agency in accordance with Condition 11.2.3.


Photographs

IMG_0017: Waste on front loader in yard area

IMG_0018: Front loader in yard area


IMG_0015: Open pedestrian access door within WRB 2

IMG_0022: Valve outside of bunded area


IMG_0011: Pedestrian obstruction within WRB 2


Odour Assessment

________________________________________________________________

Date of odour assessment: 11/09/2018 Start time: 8.37 Finish time: 9.29

Date of issue of this statement: 11/10/2018

This document’s reference number: SV15981

This odour assessment was undertaken by: Barry O’Connor

________________________________________________________________

As per the criteria stated above an odour assessment was undertaken in accordance with EPA Air

Guidance document AG5 (Odour Impact Assessment Guidance for EPA Licensed Sites).

Due to the findings of the odour assessment and the subsequent post assessment site visit to your

facility, it is the opinion of this Inspector that the activities occurring on the premises of Greyhound

Recycling and Recovery Limited, IE Licence Reg. No. W0205-01 were in breach of Condition 5.4 of the

facility’s Industrial Emissions Licence.

EPA Air Guidance document AG5 is available online at www.epa.ie


Summary

Two non-compliances were recorded on the day of the site visit relating to bunding and odour.

The Agency has an open compliance investigation in relation to odour nuisance, CI001677 refers, and the licensee shall adhere to the actions and instructions within.

The licensee shall ensure that the activities shall be carried out in a manner such that emissions, including odours, do not results in significant impairment of, and/or significant interference with amenities or the environment beyond the facility boundary.

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.


http://www.epa.ie/