site visit report · 2018-10-31 · reference img_0019). the site representative reported that...

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 Manders Coatings & Inks Ireland Limited

Licensee Manders Coatings & Inks Ireland Limited

Licence Register No. P0250-01

CRO Number 15877

Site Address Dunsinea Works, Ashtown, Dublin 15, Dublin, 15

Site Visit Reference No. SV14588

Report Detail

Issue Date 28/08/2018

Prepared By Michelle Purcell

Site Visit Detail

Date Of Inspection 26/06/2018 Announced No

Time In 09:55 Time Out 11:35

Agency Personnel On Site Michelle Purcell

Licensee Personnel and Role Alexander Smith, Director, Manders Coatings and Inks Ltd and Manders Packaging, Inks and Coatings LtdKevin Kelly, former employee

Photo Taken Yes Samples Taken No Video Taken No

Odour Assessment No

Site Visit Report - SV14588 - Manders Coatings & Inks Ireland Limited of 17

Scope

The purpose of this site visit was to determine the following:

• Verify that the licensed activity has ceased• If the installation is causing or likely to cause environmental pollution• The environmental risk associated with the site.

This report presents the findings of the site visit.

Media

The following media were inspected during the site visit:

• Waste.

Site Areas Inspected

The following areas were inspected during the site visit:

• Liquid Inks Department• Paste Ink Department• Bunded Warehouse• Area behind business called Ready Cars• Yard areas.

Documents Inspected

No documents were inspected.


1. Site Specific Issues

Answer Condition Number

Non Compliance

Observation

1.1 Waste associated with former licensed activity

Checked 13.1 Yes

Comment / Corrective Action

A large quantity of hazardous and non-hazardous waste associated with the former activity remains on-site. On the day of the site visit this waste material was present in the following areas:

• Liquid Inks Department: waste materials included 20kg drums of ink, ink contaminated water in an Intermediate Bulk Container (IBC), a drum of forklift fuel or oil, ink stained drums/containers (photograph references IMG_0015, IMG_0016, IMG_0017, IMG_0020, IMG_0021).

• Paste Ink Department: a large quantity of drums of varying sizes containing either ink or empty ink stained cans (photograph references IMG_0036, IMG_0037 and IMG_0039).

• Bunded Warehouse: solid pigments and dyes. Pigments and dyes present during the last Agency site visit conducted on 06/02/2017 (SV11410) remain within the bunded warehouse. The approximate quantity is 2,256kg (photograph reference IMG_0053).

The presence of this waste on-site is a non-compliance with Condition 13.1 of Integrated Pollution Control (IPC) licence Reg. No. P0250-01 which requires the decommissioning, rendering safe or removal for disposal/recovery, of any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter that may result in environmental pollution.

Corrective Action:

The licensee shall within one month of the date of this site visit report:

• Remove all former process waste materials from the site. This shall be carried out in accordance with the requirements of National and European waste legislation using appropriately licensed/permitted waste disposal/recovery facilities and appropriately permitted waste collection hauliers.

• Submit documentation regarding the removal of waste materials off-site for disposal/recovery to the Agency.

The licensee is advised that the surrender of IPC licence Reg. No. P0250-01 cannot progress until all of the above waste materials are removed from the site in accordance with Condition 13.1 and all associated records are submitted to the Agency and deemed appropriate.


Non Compliance

Observation

1.2 Former process equipment Checked 13.1 Yes



A significant quantity of former process equipment remains on-site in the following areas:

• Liquid Inks: ducting and ducting arms (photograph reference IMG_ 0022) and ball mill (photograph reference IMG_0019). The site representative reported that greases and oils were not removed from the ball mill since the activity ceased.

• Paste Ink Department: pumps (6) (photograph reference IMG_0035), scales (12), compressor, dust extractor unit (photograph reference IMG_0045).

• Single unit prepared for tenancy: a single unit present on site had been cleared and prepared for potential tenancy. The licensee representatives stated that ink pots and extractor fans were stored behind a wall in this area. The wall was boarded up with plywood sheets. This area was not accessible for inspection at the time of the site visit.

The presence of this equipment on-site is a non-compliance with Condition 13.1 of Integrated Pollution Control (IPC) licence Reg. No. P0250-01 which requires the decommissioning, rendering safe or removal for disposal/recovery, of any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter that may result in environmental pollution.

Corrective Action:

The licensee shall decontaminate and decommission all former plant and equipment. Any waste arising from this activity shall be managed in accordance with the requirements of National and European waste legislation using appropriately licensed/permitted waste disposal/recovery facilities and appropriately permitted waste collection hauliers.


Non Compliance

Observation

1.3 Waste deposited on-site and third party waste

Checked Waste Management

Act 1996

Yes


A significant quantity of construction and demolition (C&D) waste mixed with other waste items such as tyres, ductwork, timber, plastic, a sofa and metal was present at the rear of a former process building being rented by a company called Ready Cars (photograph references IMG_0047, IMG_0048, IMG_0049, IMG_0051). The site representative indicated that this material was recently moved to this area by a separate tenant (Rathbourne Motors) and that this material had been present within the building currently occupied and leased by Rathbourne Motors. The ductwork deposited in this area contained red ink pigment which was observed spilling out of the ductwork (photograph reference IMG_0050) onto the deposited waste material.

The licensee representative reported that wastes in the Liquid Inks Department, which included five 200 litre drums filled with empty spray cans/drums/funnels, a 200l drum of solvent thinners or methylated spirits) and a large quantity of empty primer and paint cans/tins and paint stained funnels and bottles (photograph references IMG_0015, IMG_0016, IMG_0017, IMG_0020, IMG_0021, IMG_0025, IMG_0027, IMG_0028), were left by a former tenant. A discarded office printer, which is classified as Waste Electronic and Electrical Equipment (WEEE), was also present in this area (photograph reference IMG_0031).

Corrective Action:

The licensee shall remove this waste material from the site. This shall be carried out in accordance with the requirements of National and European waste legislation using appropriately licensed/permitted waste disposal/recovery facilities and appropriately permitted waste collection hauliers.


Non Compliance

Observation

1.4 Bunding Checked 9.4.3 Yes



The hazardous wastes in the Liquid Inks Department and Paste Ink Department are stored unbunded. This is a non-compliance with Condition 9.4.3 of the licence.

Corrective Action:

These waste materials shall be stored in a bunded area prior to removal off-site.


Photographs taken 26/06/2018

IMG_0015: Liquid Inks Department – ink stained drums and drums of ink

IMG_0016: Liquid Inks Department – ink stained drums


IMG_0017: Liquid Inks Department – ink contaminated water in IBC

IMG_0020: Liquid Inks Department – drums of ink


IMG_0021: Liquid Inks Department – forklift fuel/oil

IMG_0025: Liquid Inks Department – miscellaneous waste


IMG_0027: Liquid Inks Department - empty primer and paint cans/tins and paint stained funnels and bottles

IMG_0028: Liquid Inks Department - 200 litre drums filled with empty spray cans/drums/funnels and empty cans/drums


IMG_0031: Liquid Inks Department - discarded printer and miscellaneous waste

IMG_0036: Paste Ink Department – drums both full/partially full and empty


IMG_0037: Paste Ink Department – drums both full/partially full and empty and other miscellaneous wastes

IMG_0039: Paste Ink Department – 200l drums


IMG_0053: Bunded Warehouse – pigments and dyes

IMG_0047: Waste materials deposited on-site



IMG_0050: Waste materials deposited on-site- ink pigment in ductwork


IMG_0022: Ducting and ducting arms

IMG_0019: Ball mill


IMG_0035: Pumps

IMG_0045: Dust extractor unit


Summary

A large quantity of waste materials (hazardous and non-hazardous) associated with the former activity remain on-site. The licensee is required to remove these waste materials from the site within one month of the date of this site visit report.

The licensee is advised that the surrender of Integrated Pollution Control (IPC) licence Reg. No. P0250-01 cannot progress until all waste materials are removed from the site and all associated records are submitted to the Agency and deemed appropriate.

The Agency may consider further enforcement action regarding this matter.

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/