site visit report · materials were not within the bunded area (photographs img_0015 and img_0024...

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 Saint-Gobain Construction Products (Ireland) Limited

Licensee Saint-Gobain Construction Products (Ireland) Limited

Licence Register No. P0519-03

CRO Number 11815

Site Address In the townlands of Lisnabow, Kilmainham, Kells, Meath and in, the townlands of Knocknacran, Magheracloone, Drummond, Derrynascobe, Derrynaglah, Ballycartlan,, Enagh, Carrickmacross, Monaghan, A82PF99

Site Visit Reference No. SV18316

Report Detail

Issue Date 01/10/2019

Prepared By Caroline Kelly

Site Visit Detail

Date Of Inspection 29/08/2019 Announced No

Time In 10:50 Time Out 16:40

Agency Personnel On Site Hilda Robinson

Caroline Kelly

Licensee Personnel and Role Robert Moore, Environmental Health and Safety ManagerTony O'Reilly Safety ManagerPatrick McGuinn, Health and Safety Advisor

Photo Taken Yes Samples Taken No Video Taken No

Odour Assessment No

Site Visit Report - SV18316 - Saint-Gobain Construction Products (Ireland) Limited of 13

Scope

Site visit to evaluate the licensee's compliance with the requirements of industrial emissions (IE) licence register no. P0519-03.

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• Water• Waste.

Site Areas Inspected

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

• Open cast mine• Lagoon storage area• Board plant production area• Gypsum storage area• Gypsum recycling yard area• Mine maintenance yard• Fuelling area• Kitting area.

Documents Inspected

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

• Condition 5.12 - Blast monitoring records for blast events dated 22/08/2019 and 28/08/2019• Condition 6.9 - Bund integrity test report for mobile bunds dated February 2019• Condition 6.9 - Bund integrity test report for fixed bunds, dated September 2017.


1. Site Specific Issues

Answer Condition Number

Non Compliance

Observation

1.1 Bunding Checked 3.7 Yes

Comment / Corrective Action

Agency inspectors observed the following issues on the day of the site visit:

• Fill points and valves not within the bunded area (photographs IMG_0014, IMG_0018, IMG_0019 and IMG_0023 refer)

• Inappropriate placement of drums and Intermediate Bulk Containers (IBCs) on bunds such that materials were not within the bunded area (photographs IMG_0015 and IMG_0024 refer)

• Bunds containing water, reducing the retention capacity of the bund (photographs IMG_0020 and IMG_0025 refer).

Corrective Action:

The licensee shall comply with Condition 3.7 of the IE licence.


Non Compliance

Observation

1.2 Waste handling Checked 8.10 Yes


Agency inspectors observed empty drums which had contained hazardous corrosive materials in a skip for designated for non-hazardous metal waste (Photograph IMG_0029 refer). The licensee is prohibited from mixing a hazardous waste of one category with a hazardous waste of another category or any other non-hazardous waste.

Corrective Action:

The licensee shall comply with Condition 8.10 of the IE licence.


Non Compliance

Observation

1.3 Visual inspections of bunds and drainage systems

Checked 3.7.3 / 6.10 Yes



Agency inspectors observed a number of bunds containing water and some containing an oily residue (Photographs IMG_0020 and IMG_0025 refer). A copy of the visual inspection records for bunds and drainage systems was requested. The licensee failed to provide records of weekly visual inspections and could not demonstrate weekly visual inspections were carried out as required by Condition 6.10 of the IE licence.

Records of the testing and disposal of bund water were also requested for review during the site visit. The licensee was unable to provide these records on the day of the site visit.

Corrective Action:

The licensee shall ensure that all drainage systems, bunds, silt traps and oil separators are inspected weekly and desludged as necessary in accordance with Condition 6.10 of the IE licence.

The licensee shall ensure that all drainage from bunded areas is treated as hazardous waste unless it can be demonstrated otherwise. The licensee shall ensure that all drainage is diverted for collection and safe disposal in accordance with Condition 3.7.3 of the IE licence. A record of all testing and disposal shall be maintained and available for inspection by the Agency at all reasonable times.


Non Compliance

Observation

1.4 Open cast mine and underground mine blasting

Checked 5.10, 5.11 /5.12

Yes


Recent complaints received in relation to blasting events at the open cast mine and underground mine were reviewed during the site visit. Recent blasting monitoring results for events on the 22/08/2019 and 28/08/2019 were also reviewed.

A copy of the licensee's documented blast design system, as required under Condition 5.11, was requested however this was unavailable on the day of the site visit.

Corrective action:

The licensee shall:

• Submit quarterly blast reports containing all information specified under Condition 5.10 for 2018 and 2019 as a licensee return through EDEN by 18/10/2019. The report shall include scanned copies of the original printouts from blast monitors for all blast events.

• Submit a copy of the documented blast design system required under Condition 5.11 as a licensee return through EDEN by 18/10/2019.


Non Compliance

Observation

1.5 Double skinned fuel tanks Checked 3.11 Yes


A number of double skinned fuel tanks and a mobile fuel plant/tanker were observed on the site. The licensee was unable to confirm on the day of the site visit whether these tanks were fitted with high liquid level alarms or oil detectors.

Corrective action:

The licensee shall ensure that all double skinned tanks and mobile fuel plant/tankers are fitted with high liquid level alarms or oil detectors as required under Condition 3.11.



Non Compliance

Observation

1.6 Bund integrity testing Checked 6.9 Yes


The Agency inspected integrity test reports for both mobile and static bunds were reviewed and the following was noted:

• Integrity testing was carried out by means of visual inspection only• Defects were identified in some static bunds. It was unclear if these bunds and been repaired

following receipt of the test report.

Corrective action:

The licensee shall:

• Ensure hydrostatic testing of bunds is carried out unless it is not technically feasible. The licensee shall have regard to Agency guidance document 'Guidance to Storage and Transfer of Materials for Scheduled Activities (2004)'

• Ensure that all necessary remedial work identified in the integrity test report is carried out and a written record of such works is maintained on site in accordance with Condition 6.9 of the IE licence.


Non Compliance

Observation

1.7 Propose hazardous waste storage building

Checked 3.17 Yes


The licensee advised that it was planned to re-purpose a building within the production site yard area as a hazardous waste storage area.

Corrective action:

The licensee shall submit details of the proposed works to the Agency for agreement in accordance with Condition 3.17 - Specified Engineering Works (SEW) of the IE licence.


Non Compliance

Observation

1.8 Oil stains Checked 3.8 Yes


The Agency observed stained areas on the hardstanding at the fuelling point in the mine maintenance yard (Photograph IMG_0021 refers).

Corrective action:

The licensee shall ensure that any spillage is immediately contained using suitable absorbent material in accordance with Condition 3.8.


Non Compliance

Observation


1.9 Housekeeping Checked 5.5, 6.10 /6.19.3

Yes


Agency inspectors observed the following at the production site during the site visit:

• A build-up of dust and particulate matter at surface water drains (Photograph IMG_0006 refers)• Hardstanding in need of repair in the production yard (Photograph IMG_0010 refers).

Corrective action:

The licensee shall ensure that yard areas and drains are maintained such that dust emissions are minimised and surface water drains are kept clear of sludge and dust build-up.

The licensee shall carry out repairs to the hardstanding in the production yard.


Photographs

IMG_0006 Dust build up at surface water drainage

IMG_0010 Hardstanding at production yard


IMG_0014 Placement of IBC on bunds

IMG_0015 Placement of IBCs on bunds


IMG_0018 Drum unbunded, fill point outside bunded area

IMG_0019 Fill point outside bunded area


IMG_0020 Bund containing water and oily residue

IMG_0021 Oil stains at fueling area


IMG_0023 Fill point outside the bunded area, spillage on ground

IMG_0024 Drum placement on bund


IMG_0025 Drum placement on bund, water in bund

IMG_0029 Metal drums contaminated with hazardous materials in general metals skip


Summary

Three non compliances were recorded in breach of the licence. These non-compliances concerned bunding, waste handling and visual inspection of bunds and drainage. A number of observations were made which will require corrective action by the licensee.

In particular, the Agency noted issues in relation to the availability of records and general housekeeping, which will require corrective action 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.

(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/