Site Visit Report - epa.ie · 3. Incident Prevention Answer Condition Number Non Compliance...

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 (Gorey)

Licensee Starrus Eco Holdings Limited

Licence Register No. W0220-01

CRO Number 527552

Site Address Ramstown, Gorey, Wexford

Site Visit Reference No. SV08460

Report Detail

Issue Date 23/03/2016

Prepared By Anthea Southey

Site Visit Detail

Date Of Inspection 16/02/2016 Announced No

Time In 14:14 Time Out 16:45

Agency Personnel On Site Anthea Southey

Licensee Personnel and Role Mr Andrew Rinkulus, Facility Manager

Photo Taken Yes Samples Taken No Video Taken No

Site Visit Report - SV08460 - Starrus Eco Holdings Limited of 22

Scope

The purpose of the Site Visit was to determine compliance with Starrus Eco Holdings Limited (Gorey), Industrial Emissions Licence Reg. No: W0220-01 and to investigate a complaint received by the Agency in relation to the facility.

Media

• Air• Surface Water• Groundwater

Site Areas Inspected

• Waste Transfer Building• Yard Areas• Perimeter Fencing

Documents Inspected

• Pest Control Records• Emergency Response Procedure• Accident Prevention Policy• Training Records• Foul Water Monitoring Records• Groundwater Monitoring Records• Waste Records• Waste Collection Permits


1. Health and Safety

Answer Condition Number

Non Compliance

Observation

1.1 Did the licensee make you aware of any site specific health and safety issues?

No


Non Compliance

Observation

1.2 Were any hazards identified on site other than those identified in the site specific risk assessment?

No


Non Compliance

Observation

1.3 If yes above, was the Licensee notified at the time?

Not Applicable


Non Compliance

Observation

1.4 Was safe and permanent access to sampling/monitoring points provided?

Yes 3.17


Non Compliance

Observation

1.5 Did any accident/incident/near miss occur during the site visit/audit?

No


Non Compliance

Observation

1.6 If yes above, what actions were taken? Not Applicable


Non Compliance

Observation

1.7 Did any hazard prevent you from carrying out your work?

No


2. CRAMP/ELRA


Non Compliance

Observation

2.1 Has a CRAMP been agreed for the facility?

Yes 10.1

Comment / Corrective Action

The Agency has approved the Closure, Residuals and Aftercare Management Plan (CRAMP) for Starrus Eco Holdings (W0220-02) on 20/06/2013. Financial Provision is in place for this installation as part of the Greenstar transfers.


Non Compliance

Observation

2.2 Has an ELRA been agreed for the facility? Yes 12.2.1


The Agency approved the Environmental Liabilities Risk Assessment (ELRA) for Starrus Eco Holdings (W0220-02) on 20/06/2013. Financial Provision is in place for this installation as part of the Greenstar transfers.


3. Incident Prevention


Non Compliance

Observation

3.1 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?

No 9.2 & 9.3 Yes


The Facility Manager stated that they have installed a 24 hour monitored fire alarm system as well as fire hoses and fire extinguishers in the Waste Transfer Building. The facility holds a Certificate in Fire Safety from Wexford County Council. The Emergency Response Procedure (ERP) and the Accident Prevention Policy (APP) were available at the time of the Site Visit. The ERP includes a section on fire prevention and how to deal with fires and explosions. However, it does not have regard to the recommendations outlined on page 4 (Fire Prevention Measures) and page 12 (Fire Response Planning) of the Agency Guidance Note on Fire Safety at Non-Hazardous Waste Transfer Stations.

Corrective Action Required:

The ERP and APP shall have regard to all aspects of the Agency Guidance Note on Fire Safety at Non-Hazardous Waste Transfer Stations (a copy was provided to the Facility Manager during the Site Visit).


Non Compliance

Observation

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

No 2.1.2 & 9.2 Yes


Fire Safety and Awareness Training is provided to all staff on an annual basis and fire drills are conducted every 6 months. However, the staff training programme does not adequately address the recommendations listed on pages 12 and 13 of the Agency Guidance Note on Fire Safety at Non-Hazardous Waste Transfer Stations.


The staff training programme on fire safety and awareness shall refer to and include all the recommendations listed on pages 12 and 13 of the Agency Guidance Note on Fire Safety at Non-Hazardous Waste Transfer Stations.


Non Compliance

Observation

3.3 Has the licensee implemented any fire-related waste storage restrictions at the facility?

No 3.15.1



The Facility Manager stated that the different waste types are segregated within storage bays in the Waste Transfer Building. All waste is generally removed within 24 hours. They do not carry out waste baling operations and do not store any baled waste at this facility. However, it was not clear if the licensee has introduced any fire-related waste storage restrictions at the facility.


The licensee shall introduce waste storage restrictions at the facility in order to reduce the risk of fires within the Waste Transfer Building. The Agency Guidance Note on Fire Safety at Non-Hazardous Waste Transfer Stations includes details on fire prevention measures, fire detection methods and fire response planning which is relevant here.


Non Compliance

Observation

3.4 Has the site been free from discharge/emission exceedances in the preceding 12 month period?

Yes 5.3


Non Compliance

Observation

3.5 If no, has the licensee taken appropriate and effective actions to mitigate a recurrence of these incidents?

Not Applicable 5.3, 9.4 & 11.8


Non Compliance

Observation

3.6 For discharges to surface water/groundwater/sewer, was the EPA and the relevant authorised authority notified of this discharge in a timely manner?



4. Infrastructure Integrity & Drainage


Non Compliance

Observation

4.1 Is a documented preventative maintenance and repair programme for hardstanding in place?

No 3.6.2 Yes


It was noted by the inspector during the Site Tour that there was some large cracks and damage to the yard areas in front of the Waste Transfer Building. This is in non-compliance with Condition 3.6.2 of the licence. The Facility Manager stated that the concrete slab in front of the Waste Transfer Building is scheduled for repair in March 2016. He was not aware of a documented preventative maintenance and repair programme for the hard standing areas but they are inspected regularly.


The licensee shall provide and maintain an impermeable hard standing surface for the yard areas in accordance with Condition 3.6.2 of the licence. A preventative maintenance and repair programme shall be established to ensure regular integrity inspection of all hard standing areas is undertaken and that records of all inspections, maintenance and repair works are maintained.


5. Nuisance


Non Compliance

Observation

5.1 Where an odour assessment has been completed, are odour emissions compliant?

Yes 5.4 & 5.6


An odour assessment was undertaken prior to going on-site, in response to a complaint received by the Agency on 02/02/2016, regarding noxious odours coming from the facility. The complaint refers to July, August and December 2015. No odours were detected prior to going on-site and a copy of the odour assessment is attached to this Site Visit Report.


Non Compliance

Observation

5.2 Has the facility been free from nuisance complaints in the last 12 months?

No 5.6 Yes


A written complaint was made to the Agency on 02/02/2016, which included photographs and a DVD recorded by the complainant. The complaint refers to issues experienced in July, August and December 2015. The Facility Manager stated that Starrus Eco Holdings Ltd (Gorey) had received a complaint from the same complainant on 30/07/2015. They investigated the issues raised in the complaint at that time and they have put a number of control measures in place since then.

The main issues raised in the complaint were as follows:

1. Noxious odours coming from the Waste Transfer Building.

2. Noise from operating machinery up to 11 pm at night.

3. Fly infestation in the summer months.

4. The Waste Transfer Building is not fully enclosed which leads to excessive odour, noise, flies and rat infestation.

The content of the complaint, the photographs and DVD indicate that there has been a significant rodent infestation within the Waste Transfer Building at Starrus Eco Holdings Ltd (Gorey). This is of serious concern to the Agency and is in non-compliance with Condition 5.6 of the licence.


The licensee shall ensure that vermin, birds, flies, mud, dust, litter and odours do not give rise to nuisance at the facility or in the immediate area of the facility in accordance with Condition 5.6 of the licence.


Non Compliance

Observation

5.3 Has the licensee sufficiently investigated nuisance complaint(s) received to identify the source of the complaint(s)?

Yes



A copy of the written complaint, the photographs and the DVD were given to the Facility Manager during the Site Visit on 16/02/2016. The complaint was also forwarded to the licensee via the Eden system on 18/02/2016 and a written response from the licensee was received on 24/02/2016.

The Facility Manager stated that they have undertaken a thorough investigation into the source of the complaint which dates back to July 2015. They have introduced a number of control measures at the facility in response to the complaint and to prevent further nuisance complaints in relation to the facility. Further details are provided in response to Question 5.4 below.


Non Compliance

Observation

5.4 Has the licensee taken appropriate and sufficient action to prevent a reoccurrence of nuisance complaints?

No 6.2, 6.3, 6.5 & 11.9

Yes


During the Site Tour, the following control measures to address the issues raised in the complaint were noted by the inspector:

1. The Facility Manager stated that all putrescible wastes are removed from the facility within 24 hours. Roller doors will be installed on the open side of the Waste Transfer Building over the next two weeks. It is envisaged that the roller doors will bring about a number of benefits including reducing nuisance odours and noise.

2. The Facility Manager stated that fly infestations are controlled by spraying the waste with insecticide during the summer months and removing all putrescible wastes within 24 hours.

3. The Facility Manager stated that the site adheres to the hours of operation specified in Condition 1.2 of the Waste Licence W0220-01. It is possible for waste loads to be delivered to the facility after 6pm in the evening due to delays with heavy traffic and breakdowns but this does not happen very often.

4. Records of visits by the pest control specialist were available during the Site Visit and indicated that the baiting stations are being inspected every two weeks. Records confirm that the number of rodents has decreased significantly since July 2015 when the licensee increased the number of baiting stations and the number of inspections from quarterly to fortnightly. A number of baiting stations were noted within the Waste Transfer Building and around the yard areas at the time of the Site Visit.

5. The Facility Manager stated that Starrus Eco Holdings Ltd (Gorey) has applied for planning permission to build a solid boundary wall between their site and the adjacent land.

6. A record of the complaint which was originally made to the licensee in July 2015 and their response to the complainant were not available at the time of the Site Visit.


The licensee shall record all complaints of an environmental nature related to the operation of the activity in accordance with Condition 11.9 of the licence. Each record shall give details of the date and time of the complaint, the name of the complainant and give details of nature of the complaint. A record shall also be kept of the response made in the case of each complaint.


Non Compliance

Observation

5.5 Where abatement infrastructure is installed, is it adequately maintained and operated to prevent offsite nuisance occurring?

No 3.15.3 & 3.15.3.1

Yes



It was noted during the Site Tour, that there was an odour suppressant system operating within the Waste Transfer Building. It was also noted that some repairs had been made to the cladding of the Waste Transfer Building and that the roller doors had been delivered. However, it was considered by the inspector that further improvements could be made to the integrity of the cladding on the building in order to prevent odour release.


The licensee shall provide and maintain adequate measures for the control of odours from the facility in accordance with Condition 3.15.3 of the licence. The doors shall be installed and maintained on the entry and exit points from the Waste Transfer Building and these shall be kept closed where possible in accordance with Condition 3.15.3.1 of the licence.


6. Waste Acceptance Procedures / LoW Codes


Non Compliance

Observation

6.1 Do the LoW codes assigned to outgoing waste reflect the changes that may have occurred to the nature & composition of the waste from onsite activities?

Checked 11.13


The Facility Manager stated that there are no changes made to the nature and composition of the waste that arrives at Starrus Eco Holdings Ltd (Gorey). The waste is largely being bulked up at the facility prior to being dispatched for disposal or further recovery off-site.

A total of 3,243.68 tonnes of waste was accepted at the facility between 01/01/16 and 15/02/16.

A total of 3,313.40 tonnes was dispatched for disposal or further recovery off-site between 01/01/16 and 15/02/16.

1. MSW (Mixed Municipal Waste)

Incoming LoW Code: 20 03 01 Total Quantity accepted on-site (01/01/16 to 15/02/16) = 1,979.17 tonnes

Outgoing LoW Code: 20 03 01 Total Quantity disposed off-site (01/01/16 to 15/02/16) = 2,243.34 tonnes

2. DMR (Dry Mixed Recyclables)

Incoming LoW Code: 20 03 01 Total Quantity accepted on-site (01/01/16 to 15/02/16) = 752.01 tonnes

Outgoing LoW Code: 20 03 01 Total Quantity disposed off-site (01/01/16 to 15/02/16) = 711.30 tonnes

3. Cardboard Packaging

Incoming LoW Code: 15 01 01 Total Quantity accepted on-site (01/01/16 to 15/02/16) = 61.44 tonnes

Outgoing LoW Code: 15 01 01 Total Quantity disposed off-site (01/01/16 to 15/02/16) = 76.48 tonnes


Non Compliance

Observation

6.2 Are the destination and haulage contractors used for these waste streams appropriately authorised.

Yes 11.13(ii)


The main destination for the MSW (LoW code is 20 03 01) is Ballynagran Landfill Ltd, IE Licence W0165-02 for disposal.

The main destination for the DMR (LoW Code 20 03 01) and cardboard packaging (LoW Code 15 01 01) is Starrus Eco Holdings Ltd (Fassaroe), IE Licence W0053-03 for further recovery.

The haulage contractor in each case is Starrus Eco Holdings Ltd, Permit No. NWCPO-13-111193-02. The permit includes authorisation for the collection of LoW Codes 20 03 01 and 15 01 01.


Non Compliance

Observation


6.3 Has the licensee, within the last 12 months, received notification of non-compliant and/or repatriated shipments by authorised officers in destination countries or the NTFSO?

No 8.3, 8.4 & 8.5


Non Compliance

Observation

6.4 If TFS issues have been identified and notified to the licensee, what actions have the licensee taken to address these issues?



Non Compliance

Observation

6.5 Have these actions reduced the frequency of issues occurring at destination countries?



7. Waste Storage


Non Compliance

Observation

7.1 Were the waste storage practices observed at the facility satisfactory?

No 6.3.1 Yes


It was noted during the Site Tour that general cleaning and housekeeping within the storage bays of the Waste Transfer Building could be improved. There was an accumulation of older waste along a concrete shelf area which is set out from the wall of the storage bays. This waste is considered to be a likely source of stale waste odours and could also attract vermin and flies.


The licensee shall ensure that operational controls are put in place and that the floor of the Waste Transfer Building is cleaned on a weekly basis and on a daily basis where putrescible waste is handled in accordance with Condition 6.3.1 of the licence.


Non Compliance

Observation

7.2 If waste is stored externally, does the Licensee have approval for this?

No 3.12.1, 3.12.2, 8.7 & 8.2.3

Yes


1. It was noted during the Site Tour that the Construction and Demolition (C&D) waste is being stored externally in a waste recovery area on an impermeable concrete slab. However, there was some dirty run-off from the C&D waste recovery area which was collecting on the yard surface. Drainage from this area should be directed to the on-site foul water storage tank.


The licensee shall provide and maintain a construction and demolition waste recovery area. The infrastructure shall at a minimum comprise of an impermeable concrete slab with collection and disposal infrastructure for all run-off in accordance with Condition 3.12.1 of the licence. Waste shall only be stored in designated areas protected as maybe appropriate, against spillage and leachate run-off in accordance with Condition 8.7 of the licence.

2. It was also noted during the Site Tour that there was a pile of old mattresses being stored at the entrance of the Waste Transfer Building both in a skip and on the ground.


The licensee shall ensure that all waste arriving at the facility shall be directed to the Waste Transfer Building and then it shall be processed for disposal or recovery within the Waste Transfer Building in accordance with Condition 8.2.3 of the licence.


Odour Assessment

________________________________________________________________

Date of odour assessment: 16/02/2016 Start time: 14:14 Finish time: 14:26

Date of issue of this statement: 23/03/2016

This document’s reference number: 16/02/2016 Odour Assessment

This odour assessment was undertaken by: Anthea Southey

________________________________________________________________

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). The Field

Record Sheet that was completed during the odour assessment has been copied in full and is

attached to this Statement of Odour Assessment.

Due to the findings of the odour assessment as presented in the attached Field Record Sheet, it is

the opinion of this Inspector that the activities occurring on the premises of Starrus Eco Holdings Ltd

(Gorey) were not in breach of Condition 5.4 of the installation’s IE Licence at the time of the

assessment.

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

(Field Record Sheet Attached)


http://www.epa.ie/

Summary

An odour inspection was completed in the vicinity of Starrus Eco Holdings (Gorey), Waste Licence W0220-01 in response to a complaint that was received by the Agency on 02/02/2016. No odours were detected off-site at the time of the assessment. A Site Visit was completed in order to investigate a number of issues raised in the complaint.

Two non-compliances have been issued to the licensee in relation to the following:

• Inadequate control and eradication of vermin which led to a compliant of serious nuisance being made to the Agency on 02/02/2016;

• Poor management and damage to the concrete hard standing areas of the yard surfaces.

Some observations were raised in relation to the following issues:

• Updates to the Emergency Response and the Accident Prevention Procedures in terms of staff training and reference to the Agency Guidance Note on Fire Safety at Non-Hazardous Waste Transfer Stations;

• Record keeping in relation to complaints;• Improvements required in terms of odour management and structural integrity of the Waste Transfer Building;• Waste storage practices, operational controls and general house keeping;• Site drainage in the C&D waste recovery areas.

The licensee is required to address the issues raised in this Site Visit Report 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 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/

Site Visit Photos – 16/02/2016

1. Roller Doors have been purchased for the entrance to the Waste Transfer

Building.

2. Cracked and damaged yard areas were noted during the Site Visit.

3. Odour suppression system within the roof of the Waste Transfer Building.


4. Old waste that has accumulated along the inside wall of the Waste Transfer

Building.

5. Poor drainage from the C&D Waste Recovery Area.

6. Large skip containing old mattresses which is stored externally.


7. Large pile of old mattresses which are on the ground and are partially outside

of the Waste Transfer Building.


Site Visit Report - epa.ie · 3. Incident Prevention Answer Condition Number Non Compliance...

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