Site Visit Report · IMG_0023). The contents of these drums were not clearly stated and 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 Boylan Print Limited

Licensee Boylan Print Limited

Licence Register No. P0784-01

CRO Number 179764

Site Address New Found Well, Terminfeckin Road, Drogheda, Louth

Site Visit Reference No. SV11930

Report Detail

Issue Date 22/02/2017

Prepared By Michelle Purcell

Site Visit Detail

Date Of Inspection 14/02/2017 Announced No

Time In 09:30 Time Out 16:05

Agency Personnel On Site Michelle Purcell

Marie Hogan

Licensee Personnel and Role Lorraine Walsh - EHSQ OfficerRoy Bell - EngineerPadraig Heslin - Trainee EngineerStjepan Vukelja - General Operative

Photo Taken Yes Samples Taken Yes Video Taken No

Site Visit Report - SV11930 - Boylan Print Limited of 21

Scope

The scope of the site visit was to:

• Investigate an elevated Chemical Oxygen Demand (COD) result (9350mg/l) from a storm water sample taken by the Agency at storm water emission monitoring point SW-01 on 12/01/2017 and to perform additional sampling at storm water emission monitoring point SW-01.

• To evaluate the licensee's performance in achieving the Environmental Protection Agency (EPA) 2017 surface coating sectoral priorities and Integrated Pollution Control (IPC) licence requirements.

This report presents the findings of the site visit.

Media

The following media was inspected during the site visit:

• Surface Water• Waste.

Site Areas Inspected

The following site areas were inspected during the site visit:

• Storm water emission monitoring point SW-01• Storm water drainage yard gullies• Storm water downpipes located within the internal printing area• External yard areas• Waste storage areas• Groundwater monitoring wells• Internal printing floor• Wash room.

Documents Inspected

The following documents were inspected prior to and during the site visit:

• Condition 5.1, Schedule C.2.3: SW-01 Analysis reports by Fitz Scientific for samples taken on 09/01/2017, 07/12/2016, 09/11/2016 and 11/10/2016

• Condition 5.1, Schedule B.1: Q1, Q2, Q3,and Q4 2016 Stack Emissions Monitoring Reports for emission to air monitoring points A2-3 and A2-4

• Condition 6.8: Bund Test Reports, dated 28/06/16 - 01/07/16• Condition 6.9: Procedure for the waste created by the paper off-cut unit, dated 21/06/16, Rev 1• Condition 6.9: Checklist for paper off-cut unit waste maintenance• Condition 6.9/6.10.3: Weekly leak/environmental inspection checklist• Condition 9.1: Accident Prevention Procedure• Condition 9.2: Emergency Response Procedure• Condition 9.3.1(ii): Procedure for the use of the emergency bladder valve at SW-01, dated 09/05/14, Rev 1• Condition 11.2/11.3: Incident/complaint log, dated 21/07/15, Rev 1• Condition 11.6 Annual Environmental Report 2015• Condition 11.7: Waste records.


1. Waste management

Answer Condition Number

Non Compliance

Observation

1.1 Of the waste types selected for review, were the EWC codes appropriate?

Yes 11.7(i)


Non Compliance

Observation

1.2 Of the waste types selected for review, were the hauliers/transport companies authorised to collect those EWC codes?

Yes 11.7(ii)


Non Compliance

Observation

1.3 Of the waste types selected for review, were the destination outlets authorised to accept those EWC codes?

Checked 11.7(iii) Yes

Comment / Corrective Action

Waste permit details for ARF France, which receive waste with List of Waste (LoW) code 15 02 02*, were not available in the waste file.

Corrective Action Required

The licensee shall submit permit details for ARF France which outlines that this facility is authorised to receive waste with LoW code 15 02 02*. This shall be submitted as a Response to EPA Report through EDEN.


Non Compliance

Observation

1.4 Has any waste been stored on site for longer than 6 months?

Checked N/A Yes


Waste Electrical and Electronic Equipment (WEEE) is stored in a metal bin in the external yard area (photograph reference IMG_0022). The licensee was unable to state how long this waste has been present on site.


The licensee is required to arrange for this waste to be removed and treated/recovered/disposed in accordance with National and European legislative requirements. Records relating to the removal and recovery/disposal of this waste shall be retained on site for review.


2. Air Abatement


Non Compliance

Observation

2.1 Are recent maintenance records available for air emissions abatement equipment?

Yes 6.6


3. Air Monitoring


Non Compliance

Observation

3.1 Where air samples require laboratory analysis, was the laboratory accredited for the relevant parameters?

Checked 6.1.4 Yes


Glenside Environmental Services who perform air emission monitoring are ISO 17025 accredited. Stack emission monitoring reports reviewed did not include details of laboratory accreditation.


Submit details of laboratory accreditation as a Response to EPA Report through EDEN.


Non Compliance

Observation

3.2 Have any ELV breaches been noted in air emissions monitoring in the last 12 months?

No Condition 5.1, Schedule B


4. Housekeeping


Non Compliance

Observation

4.1 Are all materials, including wastes and raw materials, stored in appropriately designated areas, protected from stormwater run-off and leachate generation?

No 8.6 Yes


Waste was not stored in appropriately designated areas and was not protected against storm water runoff. The following was observed:

• Five drums of an unknown yellow liquid were stored unbunded in the yard area. A yellow substance was leaking from one drum onto the concrete hardstanding (photograph references IMG_0024 and IMG_0023). The contents of these drums were not clearly stated and the licensee was unable to identify the content of the drums.

• Stains were present on the concrete hardstanding in the yard waste storage area (photograph references IMG_ 0003 and IMG_0004) indicating that spills in this area have occurred. The licensee was unable to provide details on how this staining occurred.

• Paper off-cuts were present on the grass verges at the site boundary, in an area beside the cyclone and around the yard area (photograph references IMG_0017 and IMG_0011).

• Waste Electrical and Electronic Equipment (WEEE) was stored in a metal bin. This waste was not protected against storm water runoff. Fluorescent tubes were stored with the WEEE and several tubes were broken on the ground (photograph references IMG_0022 and IMG_0021).

This is a non compliance with Condition 8.6 of Integrated Pollution Control (IPC) licence register number P0784-01.

Corrective Actions Required

The licensee shall comply with Condition 8.6 of IPC licence register number P0784-01 and ensure that waste is stored in designated areas, protected as may be appropriate, against spillage and leachate run-off. All waste shall be clearly labelled and segregated. The licensee is required to submit a progress report, which details actions taken to address each bullet point above. This shall be submitted as a Response to EPA Report through EDEN by 08/03/2017.


Non Compliance

Observation

4.2 Are all waste receptacles appropriately labelled to describe their contents?

No 8.6


See Section 4.1.


Non Compliance

Observation

4.3 Is there adequate emergency protection available to protect storm water points from spillages?

No 6.9 Yes



The storm water gully beside the cyclone unit contained paper off-cuts (photograph reference IMG_0013) which had become saturated in water and become a sludge.

This is a non compliance with Condition 6.9 of IPC licence register number P0784-01.

The following was also observed:

• There are no spill kits present in the yard area in the vicinity of stored wastes.• Spill training records were requested but were not available for review.


• Remove paper off-cut sludge from the storm water drainage system.• Submit a progress report which details actions taken to address each of the bullet points above. This

shall be submitted as a Response to EPA Report through EDEN by 08/03/2017.


Non Compliance

Observation

4.4 Is the overall standard of housekeeping satisfactory?

No N/A Yes


The yard area is untidy with miscellaneous items/wastes stored in undesignated areas (see Section 4.1).


• The licensee shall tidy the yard and assign designated areas for the storage of waste.• Any waste materials shall be removed and treated/recovered/disposed in accordance with National

and European waste legislative requirements.


5. Incident Prevention


Non Compliance

Observation

5.1 Has the ERP and APP been reviewed to check compliance with the new Agency Guidance (available on the EPA website)?

No 9.1, 9.2 Yes


The licensee has not reviewed the Emergency Response Procedure (ERP) or the Accident Prevention Procedure (APP) against new Agency Guidance.


The licensee shall review the APP and ERP against the Agency Guidance titled "Guidance to Licensees on the Preparation of Accident Prevention Procedures and Emergency Response Procedures", dated 2016. Any amendments required shall be incorporated into the site APP and ERP.


6. Tank & Pipeline Integrity testing


Non Compliance

Observation

6.1 Does the licensee have an up to date site drawing which includes all site drainage channels and the locations of all underground tanks and pipelines?

No 11.5 (vi) Yes


The licensee does not have drainage drawings for the storm water and foul drainage systems.


The licensee shall, without delay, prepare drainage drawings for the storm water and foul systems. A copy of these drawings shall be submitted to the Agency as a Response to EPA Report through EDEN by 15/03/2017.


7. Site Specific Issues


Non Compliance

Observation

7.1 Storm Water Emission Checked Condition 5.1, Schedule B.2

Yes


The Agency completed storm water sampling at storm water emission point reference SW-01 on 12/01/2017. Agency analysis report reference 1213, dated 03/02/2017, recorded a Chemical Oxygen Demand (COD) result of 9350 mg/l O2.

This is a non compliance with Condition 5.1 of IPC licence register number P0784-01.

On the day of the site visit the Agency performed sampling at storm water emission point reference SW-01 (photograph references IMG_0001 and IMG_0005) in the company of the site representative. The sample collected (photograph reference IMG_0008) was observed as having a dark blue colour, an oily sheen and a greasy composition. The licensee was not aware of the source of the emission and could not provide a drainage drawing to support investigations. The licensee was instructed to comply with Condition 9.3 of the licence, to investigate the source of the emission and to cease its discharge.


The licensee shall:

• Carry out a suitable survey of site drainage systems in accordance with EPA Guidance Note titled "Storage and Transfer of Materials for Scheduled Activities" (2004). Inform the Agency of the date of commencement of this survey.

• Cease the discharge of the emission at SW-01 and ensure that no emissions of environmental significance are emitted from the installation.

• In accordance with Condition 9.3 of the licence investigate the source of the emission at SW-01. An investigation report detailing findings, corrective actions and an evaluation of environmental pollution shall be submitted to the Agency as a Response to EPA Report through EDEN by 08/03/2017.


Non Compliance

Observation

7.2 Storm Water Emission Checked 1.2 Yes


On the day of the site visit the storm water emission at SW-01 was observed as having a dark blue colour, an oily sheen and a greasy composition. This emission is not taking place as set out in IPC licence register number P0784-01.

This is in non compliance with Condition 1.2 of IPC licence register number P0784-01.


The licensee shall ensure that emissions shall take place as set out in IPC licence register number P0784-01.


Non Compliance

Observation

7.3 Bunding Checked 3.5.2 Yes



Bund Integrity Test Records, submitted to the Agency on 04/07/2016, report that bund No's 1, 7, 8 and 12 do not have sufficient capacity in accordance with the requirements of Condition 3.5.2 of IPC licence register number P0784-01. A non compliance (reference NC006895) relating to this was issued by the Agency on 08/11/2016. The licensee has failed to put corrective measures in place to rectify this non compliance.

This is a non compliance with Condition 3.5.2.

On the day of the site visit five drums containing an unknown yellow liquid were stored unbunded in the yard area (photograph reference IMG_0023).


The licensee shall, in accordance with Condition 3.5.2:

• Ensure that drum storage areas are bunded.• Ensure that bunds are of sufficient capacity.


Non Compliance

Observation

7.4 Stormwater Weekly Inspection Checked 11.4 and Schedule

C.2.3

Yes


The weekly storm water inspection log is not being populated with details of the colour or odour of storm water at storm water emission point SW-01.

This is a non compliance with Condition 11.4 and Schedule C.2.3 of IPC licence register number P0784-01.


The licensee shall, in accordance with Schedule C.2.3 of the licence, record detailed information regarding the colour and odour of storm water at emission point SW-01.


Non Compliance

Observation

7.5 Groundwater Monitoring Wells Checked 3.3 Yes


Two monitoring wells, BH201S and an unlabelled monitoring well, were unlocked.


The licensee shall:

• Ensure that groundwater monitoring wells are locked at all times, except during sampling.• Label all groundwater monitoring wells.


Non Compliance

Observation

7.6 New Printer Checked 1.4 Yes



A new printer has been installed which will result in a new emission to air. The printer is not yet operational. A non compliance (reference NC006129) was previously issued by the Agency relating to the installation of the printer.

The licensee is reminded that no alteration to the activity shall be carried out or commenced without prior notice to, and without the agreement of, the Agency.


The licensee shall complete a Licence Alteration Request through EDEN and acquire any necessary approvals prior to commencing the operation of the printer.


Non Compliances

epa descriptionNC Number Type Date of Non Compliance Date of Notification Condition

NC007792 Monitoring 12/01/2017 03/02/2017 5.1

I refer to the EPA laboratory report number 1213, dated 03/02/2017, reporting results for a storm water sample taken by the Agency from SW-01 on 12/01/2017. The Agency notes that the result for COD was 9350 mg/l and the result for conductivity was 1520 μS/cm.

This is in non-compliance with Condition 5.1 of Integrated Pollution Control (IPC) Licence Register Number P0784-01 which states "no specified emission from the installation shall exceed the Emission Limit Values set out in Schedule B: Emission Limits of this licence. There shall be no other emissions of environmental significance".

NC Number Type Date of Non Compliance Date of Notification Condition

NC007854 Waste management 14/02/2017 14/02/2017 8.6

Waste was not stored in appropriately designated areas, was not protected against storm water runoff and was not labelled.

Condition 8.6 of Integrated Pollution Control (IPC) Licence Register Number P0784-01 states "Waste shall be stored in designated areas, protected as may be appropriate, against spillage and leachate run-off. The waste is to be clearly labelled and appropriately segregated".


NC007855 Waste management 14/02/2017 14/02/2017 6.9

The storm water gully beside the cyclone unit contained paper off-cuts which had become saturated in water and become a sludge.

Condition 6.9 of Integrated Pollution Control (IPC) Licence Register Number P0784-01 states "the drainage system and bunds shall be inspected weekly, desludged as necessary and properly maintained at all times..".


NC007856 Documentation & Procedures

14/02/2017 14/02/2017 11.5 (vi)

The licensee does not have drainage drawings for the storm water and foul drainage systems.

Condition 11.5 (vi) of Integrated Pollution Control (IPC) Licence Register Number P0784-01 states "The licensee shall as a minimum keep the following documents at the site...up to date site drawings/plans showing the location of key process and environmental infrastructure, including monitoring locations and emission points".


NC007860 Miscellaneous 14/02/2017 14/02/2017 1.2

The storm water emission at SW-01 was observed as having a dark blue colour, an oily sheen and a greasy composition. This emission is not taking place as set out in IPC Licence Register Number P0784-01.

Condition 1.2 of Integrated Pollution Control (IPC) Licence Register Number P0784-01 states "The installation shall be controlled, operated, and maintained and emissions shall take place as set out in this licence".


NC007861 Bunding & Materials handling

14/02/2017 14/02/2017 3.5.2

Bund Integrity Test Records, submitted to the Agency on 04/07/2016, report that bund No's 1, 7, 8 and 12 do not have sufficient capacity in accordance with the requirements of Condition 3.5.2 of IPC licence register number P0784-01. A non compliance (reference NC006895) relating to this was issued by the Agency on 08/11/2016. The licensee has failed to put corrective measures in place to rectify this non compliance.

Condition 3.5.2 states "all tank and drum storage areas shall within six months of the date of grant of this licence, as a minimum, be bunded, either locally or remotely, to a volume not less than the greater of the following (i) 110% of the capacity of the largest tank or bund within the bunded area; or (ii) 25% of the total volume of substance which could be stored within the bunded area".


NC007865 Documentation & Procedures

14/02/2017 14/02/2017 Condition 11.4 and Schedule C.2.3


The weekly storm water inspection log is not being populated with details of the colour or odour of storm water at storm water emission point SW-01.

Condition 11.4 states "The licensee shall record all sampling, analyses, measurements, examinations...carried out in accordance with the requirements of this licence..". Schedule C.2.3 requires examination of storm water for colour and odour.


Summary

A significant storm water emission was on-going at the time of the site inspection at SW-01 which represents a breach of IPC Licence Reg. No. P0784-01.

Seven non-compliances were recorded during the inspection which represent a breach of IPC Licence Reg. No. P0784-01. Non compliances related to wastes stored in non designated areas/not protected from storm water runoff, inadequate desludging of storm water drains, no drainage drawings, the release of an emission of environmental significance, bunding and storm water visual inspection.

Several observations were raised, while not considered breaches of licence conditions, require the implementation of corrective/preventative actions by the licensee.

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.

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.

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.

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/

Photographs taken 14/02/2017

IMG_0024: Five drums containing an unknown yellow liquid stored unbunded and inadequately labelled

IMG_0023: Spill of an unknown yellow liquid from a drum onto the concrete hardstand


IMG_0003: Stain on concrete hardstanding in the waste storage area

IMG_0004: Stains on concrete hardstanding in the waste storage area


IMG_0017: Paper off-cuts on grass verge area

IMG_0011: Paper off-cuts near Cyclone


IMG_0022: Waste Electrical and Electronic Equipment (WEEE) stored in the yard area

IMG_0021: Fluorescent bulbs broken on the ground


IMG_0013: Paper off-cuts in storm water gully

IMG_0001: Storm Water Emission Point SW-01


IMG_0005: Storm Water Emission Point SW-01

IMG_0008: Sample taken at SW-01 on 14/02/2017


Site Visit Report · IMG_0023). The contents of these drums were not clearly stated and the...

Documents

Transcript of Site Visit Report · IMG_0023). The contents of these drums were not clearly stated and the...