site visit report · 2017. 9. 18. · site visit report the site visit process is a sample on a...

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 North Kerry Landfill Site

Licensee Kerry County Council

Licence Register No. W0001-04

CRO Number

Site Address Muingnaminnane, Tralee, Kerry

Site Visit Reference No. SV11113

Report Detail

Issue Date 19/07/2017

Prepared By Michelle O'Driscoll

Site Visit Detail

Date Of Inspection 23/06/2017 Announced Yes

Time In 09:30 Time Out 14:30

Agency Personnel On Site Michelle O'Driscoll

Pamela McDonnell

Licensee Personnel and Role David DoneganAlan KennellyJohn BreenGer O Brien

Photo Taken Yes Samples Taken No Video Taken No

Odour Assessment No

Site Visit Report - SV11113 - Kerry County Council of 18

Scope

The scope of this site inspection was to assess the installation's performance in addressing the items on the EPA's 2017 enforcement plan for the waste sector.

Media

The following media was inspected on site:

• Air• Water• Ground

Site Areas Inspected

The following areas were inspected on site:

• Leachate lagoons• Storm Water lagoons• Perimeter of landfill body• Cell 16

Documents Inspected

The following documentation was inspected:

• North Kerry Landfill - Emergency Response Procedure 2017 (V4)• North Kerry Utilisation Scheme - Emergency Response Plan Rev 3 - 12/10/16• B9 manual "Landfill Gas Management System Monitoring Manual"• B9 procedure "Landfill gas monitoring and balancing, 1st Sept 2001 Version 1• North Kerry Landfill gas extractive well monitoring (28/04/17, 29/05/17)• Weekly odour monitoring records 2017


1. Health and Safety

Answer Condition Number

Non Compliance

Observation

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

Yes


2. Incident Prevention


Non Compliance

Observation

2.1 Is there a Fire Prevention Plan in operation?

Yes

Comment / Corrective Action

The licensee has an Emergency Response Procedure 2017 (Version 4), which address preventative and mitigation measures regarding fire and explosion for the entire site.


Non Compliance

Observation

2.2 Is there a Fire Response Plan in place? Yes


The licensee has an Emergency Response Procedure 2017 (Version 4), which addresses response to fire / explosion within the cells, outside the cells and in relation to gas migration.


3. Landfill Gas


Non Compliance

Observation

3.1 Is there a Landfill Gas (LFG) abstraction system (gas wells, pipework etc.) in place and abstracting gas from the landfill?

Yes


The site representative stated that the landfill gas is currently being abstracted at 180m3/hr rising to 200m3/hr. B9 (landfill gas management contractors) completed a model last year and indicated that the abstraction of landfill gas was down to 100m3/hr. Since then they have undertaken works which include cap remediation, pipework and condensate management to improve extraction rates.


Non Compliance

Observation

3.2 Are landfill gas flare(s) and/or engines operating continuously?

Yes


The engine was not operational during the site visit due to maintenance. The flare was operational during the site visit.


Non Compliance

Observation

3.3 What are the flares/engines maximum design capacities (vol/hr)?

Checked


As per previous site inspections; Flare - 500m3/hr and the Engine is 200m3/hr.


Non Compliance

Observation

3.4 Are the flares/engines connected to a SCADA system?

Yes


Non Compliance

Observation

3.5 Does the facility have spare/backup capacity?

No


There is no back up but the licensee stated that they have enough capacity available between the flare and the engine.


Non Compliance

Observation

3.6 Is there a system for management of the gas field?

Yes



B9 manage the gasfield. B9 have a "Landfill Gas Management System Manual" which includes the following procedure "Landfill gas monitoring and balancing", 1st Sept 2001 Version 1.

Fehily Timoney conducted an independent assessment on North Kerry Landfill and produced a report titled "Independent Detailed Assessment of the Landfill Gas Management System in Operation at North Kerry Landfill" in June 2016. This included recommendations such as cutting back the vegetation on top of the landfill. This was taking place on Cell 16 during the site visit. The licensee is putting in new land drains and re-profiling the cap to encourage surface water run off.


Non Compliance

Observation

3.7 Have staff managing the gas field received any training on landfill gas management?

Yes


B9 provide a fully trained electrical and mechanical technician who has experience in all levels of gas management, auditing, gas levels and compositions. He also has a SAFE pass. B9 will send a replacement who is trained in gas well management and leachate management if the current technician is unavailable due to illness or leave.


Non Compliance

Observation

3.8 Are gas field balancing records being maintained?

Yes


Non Compliance

Observation

3.9 Has the licensee undertaken a recent surface VOC emissions survey?

Yes


The licensee commissioned Odour Monitoring Ireland (OMI) to carry out a VOC survey at North Kerry Landfill on the 7th April 2017. Gas Wells at the top of the landfill had been identified with elevated VOC levels.

The licensee investigated the emissions from the locations highlighted in the OMI report. The investigation found no noticeable defects with the lining and gas infrastructure. B9 Power carried out minor remedial works such as tightening of couplings. The licensee subsequently commissioned Enviroguide Consulting to carry out a Laser Methane Detection Survey to assess each of these areas following the remedial works. No Methane emissions were noted during the Enviroguides assessment.


Non Compliance

Observation

3.10 During this inspection, were practices in relation to LFG management satisfactory?

Yes


4. Leachate


Non Compliance

Observation

4.1 Is leachate being abstracted from all lined cells at the facility?

Yes


Non Compliance

Observation

4.2 Are leachate levels in cells- being maintained at <1 meter above the top of the basal liner or below agreed trigger levels (unlined cells)?

Yes


Non Compliance

Observation

4.3 Do groundwater monitoring records reviewed indicate an absence of contamination due to leachate?

Yes


Non Compliance

Observation

4.4 Do surface water monitoring records reviewed indicate an absence of contamination due to leachate?

Yes


Non Compliance

Observation

4.5 During this inspection, were practices in relation to leachate management considered satisfactory?

Checked Yes


During the site inspection a tanker was loading leachate at lagoon 1. When the contractor finished loading and took off the flexi pipe from the tanker some leachate was spilled outside of the leachate bund area (refer photo 1). More care needs to be exercised during the leachate loading.

The flexi pipe needs to be replaced in this area as it is worn and may crack (refer photo 2&3).

The electrical works for the pumping of the leachate into the road tanker are held on the back of an Isuzu jeep, which is not suitable as all the pipework containing leachate is outside the bunded area and the pipework was leaking during the loading of leachate (refer photo 4). The site representative stated that electrical upgrade works will be completed in this area by the end of the year and the Electrical Engineer is currently preparing the plan. The site representative stated during the site inspection that this area is high priority for the electrical upgrade.

The leachate lagoon liners were integrity tested in August 2016 and passed, they are next due for testing in 2019.

Observation:

Provide bunding for leachate pipes and connectors to prevent drips and spills to unprotected ground.


5. Waste Management / Other Issues


Non Compliance

Observation

5.1 Have all completed cells at the facility received a final cap as required by the Waste Licence?

Yes


6. Odour, Complaints and Incident Management


Non Compliance

Observation

6.1 Has the facility been free of complaints regarding it's activities for the preceding 12 month period?

Yes


Non Compliance

Observation

6.2 Are complaints received by the licensee being investigated and addressed by the licensee in accordance with the licence?

Not Applicable


Non Compliance

Observation

6.3 Are odour and nuisance inspections being undertaken as required?

Yes


The licensee has site have an odour monitoring protocol and conducts weekly odour monitoring.


Non Compliance

Observation

6.4 Are there appropriate Emergency Response Procedures in place at the facility?

Yes


7. Site Specific Issues


Non Compliance

Observation

7.1 Bunding Checked 3.11 Yes


2 x unlabelled IBC's were in the flare compound on the day of the site inspection. The bunds were full of water and would be unable to provide secondary containment should the need arise.

2 drums (1 labelled Sodium Hypochlorite and the other which was unlabelled appeared to contain oil) were observed on unprotected ground on the perimeter near 15a and 15b side slope risers. These were being used by the contractor clearing the vegetation on top of the landfill body. Once the inspector pointed out these drums, the site representative removed them immediately to protected ground.

Observation:

Empty the bund contents and ensure bund capacity is maintained in accordance with licence Condition 3.11.

Ensure all drums / IBC's are labelled in Condition 5.6.10.

Ensure that all employees / contractors adhere to licence requirements when on site.


Non Compliance

Observation

7.2 Colour code manholes Checked Yes


As good practice, the licensee shall colour code the manholes on site.

Red: Leachate / Effluent

Blue: Surface water


Non Compliance

Observation

7.3 Groundwater wells Checked Yes


Some of the groundwater wells checked on site had no caps on the day of the inspection (refer photo 6). Caps should be placed on the groundwater wells as a precautionary measure to ensure no contamination enters the well.


Non Compliance

Observation

7.4 Perimeter landfill gas wells Checked Yes



Some of the perimeter landfill gas monitoring wells had little or no protection against physical damage of the well head (refer photo 7 & 8). While their locations were labelled the inspectors had to look around in the vegetation near the signs to find the wells e.g. in the area for gas wells such as PGDW 6b.

An extract from a site visit report SV08232 following a site inspection by the Agency in April 2016, outlined that pipework (gas well 6B) required some investigation to be conducted. "In an effort to test the integrity of the seal of the cap/valve on one of the perimeter gas monitoring wells (labelled as gas well no. 6b), the inspector was able to pull the top of the gas well completely off. The length of well casing pipe was only about 2ft long. Assuming that the actual monitoring well extends much further underground, this represents a lack of integrity in the well casing. The licensee should investigate and remedy this defect, so as to ensure that the well accurately reflects gas levels in the ground at this location".


Non Compliance

Observation

7.5 Swales on the eastern side of the landfill body

Checked Yes


It was unclear whether the liquid gathered in a swale on the eastern part of the landfill body was contaminated water or surface water. The side of the liner had signs of leachate breakout (refer photo 9 & 10). The flow of water in this swale was obstructed by a poorly laid liner which resulted in the liquid not being able to flow freely into the drains.

Observation:

The licensee shall maintain the swale to give a better flow to the contained liquid.

It was confirmed on site by the licensee that the water in this swale will be tested to confirm whether it is contaminated or not. Records of such testing should be maintained on site for future inspections.


Summary

The licensee has invested a lot of money on the site to increase their compliance levels. A full time executive technician will be based on site permanently in the next few weeks. An area which needs immediate attention is the leachate loading area where the pipework is not in a bunded area and leachate, which is a highly potent liquid, is dripping / spilling onto unprotected ground. The final action A009817 for CI000877 on Leachate Levels was closed since the site inspection and CI000877 was subsequently closed.

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/

Photographs

Site : Kerry County Council-North Kerry Landfill

Reg No: W0001-04

Date: 23/06/17

Photos taken by: Michelle O Driscoll

Photo 1 (ref DSCN0854): note the spillage of leachate outside of the bunded area, this

occurred during the site inspection when the contractor was taking the extraction pipe

off the lorry.

Photo 2 (ref DSCN0852): Flexi pipe needs to be replaced as it was leaking leachate onto

unprotected ground.


Photo 3 (ref DSCN0853): Close up of flexi pipe which was leaking leachate as the

leachate tanker was being filled on the day of the site inspection. This was draining

onto unprotected ground.

Photo 4 (ref DSCN0856): The electrical works for pumping the leachate out of the

leachate lagoon into the road tanker is held in the back of the Isuzu jeep.


Photo 5 (ref DSCN0871): 2 drums (1 labelled Sodium hypochlorite and 1 which

appeared to contain oil). This was being used by a contractor cutting back vegetation on

the landfill body.

Photo 6 (ref DSCN0880): Groundwater well with no cap, it is good practice to provide a

cap to prevent contamination from entering the well.


Photo 7 (ref DSCN0865): Label indicating where the perimeter gas well PGDW 6b is

located however the well is not clearly visible or protected against physical damage.

Photo 8 (ref DSCN0866): Perimeter gas well (PGDW 6b) in the vegetation needs piping

around it to protect it from damage.


Photo 9 (ref DSCN0873): The side of the liner had signs of leachate breakout.

Photo 10 (ref DSCN0874): Close up of the side of the liner with what looks like

leachate breakout.


Photo 11 (ref DSCN0875): The liner position makes it difficult for water / contaminated

water to follow freely in this area.
