The licensee shall take the actions specified to close out the non-compliances and observations raised in this Site Visit Report.

Transcription

1 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 Licensee Bord na Mona Allen Peat Limited Bord na Mona Allen Peat Limited Licence Register No. P CRO Number Site Address Site Visit Reference No. Allen Group, c/o Derrygreenagh Works, Rochfordbridge, Westmeath SV12524 Report Detail Issue Date 13/09/2017 Prepared By Irene Doyle Site Visit Detail Date Of Inspection 08/09/2017 Announced Yes Time In 09:30 Time Out 11:00 Agency Personnel On Site Irene Doyle Licensee Personnel and Role Enda McDonagh, Head of Environment and Health & Safety Ronan Behan, Project Manager, Bord na Mona Land & Property Photo Taken Yes Samples Taken No Video Taken No Odour Assessment No Site Visit Report - SV Bord na Mona Allen Peat Limited Page 1 of 10

2 Scope This exit audit was conducted in response to a licence change request by the licensee to remove a 5.25 ha area in Mountlucas Bog from the licenced boundary. Media Media checked during this site visit included: Water Waste Site Areas Inspected The site area included was a sample area of the 5.25 site adjacent to turbine No. 19 on Mountlucas Windfarm. Documents Inspected There were no documents requested on the day of the audit but the following documents were reviewed prior to the audit: Site Visit Report - SV Bord na Mona Allen Peat Limited Page 2 of 10

3 Site Visit Report - SV Bord na Mona Allen Peat Limited Page 3 of 10

4 Exit Audit Report F.A.O: Enda McDonagh, Environmental Manager, Bord na Mona Energy Limited, Main Street, Newbridge, Co. Kildare. This Licence Audit Report details the Agency s findings following an exit audit at Mountlucas on 08/09/ OPENING MEETING Irene Doyle gave a brief introduction to the objectives and scope of the audit and the procedure to be followed for the remainder of the audit. It was explained that this was an Exit Audit, which focuses on the condition of the site following cessation of the scheduled activity. The scope also addresses the enforcement documentation, the state of compliance with the licence and any outstanding issues. The Licensee submitted a documented Closure Audit/Decommissioning Plan to the Agency on 25/07/2017. This document was used as the principal audit document. The physical scope of this audit includes a 5.25 ha area of the P licenced site. There was never any infrastructure on the site such as workshops, tea centres or rail lines. Production ceased at the site in 1999 prior to issue of the IPC Licence P ON-SITE ASSESMENT 2.1 Review of Implementation of the Decommissioning Plan The bog area to be surrendered is located within the greater Mountlucas windfarm on the eastern road beside wind turbine No. 19. The site in question ceased peat harvesting in 1999 prior to issue of the IPC Licence. The bog is now stabilised and is covered in dense scrub and birch. There was no decommissioning required, as there was never any infrastructure installed in this area. 2.2 Site Inspection and Assessment An inspection of the site was conducted. There is no historical use of chemicals, asbestos or PCB s onsite or of any historical incidents of fuel spill in this area. 2.3 Interview The following representatives were interviewed during the audit: Name Position Issue Enda McDonagh Head of Environment, Health & Safety All issues Ronan Behan Project Manager All Issues Site Visit Report - SV Bord na Mona Allen Peat Limited Page 4 of 10

5 2.4 Documentation Documentation was not requested for review during this site visit but the associated documents reviewed prior to the visit included: Independent Closure audit at the Bord na Mona Mountlucas Site Licence alteration request Draft Rehabilitation Plan Annual Environmental Report 3. GENERAL COMMENT Peat harvesting on the 5.25 ha site ceased in 1999 and since then the site has naturally stabilised and revegetated to form new habitats. The site now comprises poor pioneer fen wetland and scrub with some birch trees. Under the Bord na Mona rehabilitation programme (2016) for the Mountlucas Bog, rehabilitation focuses on stabilisation and after-use. Peat forming vegetation is not expected to develop due to fen peat and the underlying alkaline geology. Apart from one minor observation concerning waste material, there were no other issues which require action by the licensee. 4. CLOSING MEETING The closing meeting commenced at 10:45 and the attendees were as at the opening meeting. Irene Doyle gave a summary of the audit result. The licensee was briefed on the Agency s reporting procedures and was advised that an audit report would be issued. Finally, the licensee was thanked for the courteous and co-operative manner of the staff, and the assistance and co-operation extended during the audit. 5. AUDIT FINDINGS 5.1 Audit Non-Compliances The site audit process is an overview of the apparent physical condition of the site following, part or total, cessation of the activity. It also reports on a review of enforcement documentation and success against an agreed closure plan, and other relevant conditions. The Agency did not undertake any specific sampling or analysis as part of this audit. The audit endeavours, in so far as is practicable and reasonable, given the scope of the audit as well as an understanding of the site, its operations and history, to identify and confirm satisfactory management of matters pertaining to enforcement and potentially polluting residuals. Nothing in this Report shall be construed as relieving the current owner or any future purchaser of the site from its/their present or future liabilities in relation to environmental or human health matters connected with this site whether arising from or connected with IPC licence P or otherwise. The Licensee was found to be in compliance with the requirements of the licence on the day of the audit. Site Visit Report - SV Bord na Mona Allen Peat Limited Page 5 of 10

6 5.2 Audit Observations While observations do not constitute non-compliances with any condition of the licence, they should be addressed or where relevant noted by the Licensee in order to ensure compliance, improve environmental performance of the installation and provide clarification on certain issues, as required. 1. Waste Material The Independent Closure Audit highlighted a small quantity of broken plastic piping on the site. During the exit audit the licensee confirmed that this waste material has not yet been removed. Corrective Action The licensee shall arrange for the disposal of the waste material without delay in accordance with National and International legislation. Site Visit Report - SV Bord na Mona Allen Peat Limited Page 6 of 10

7 Summary The licensee was found to be compliant in the areas checked during this site visit. One observation was raised concerning the removal of a small quantity of waste plastic pipe from the site. The EPA notes that the bog has stabilised and has naturally vegetated over the circa 20 since peat extraction activity ceased. 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, 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. Site Visit Report - SV Bord na Mona Allen Peat Limited Page 7 of 10

8 Photographs Index Figure 1 View of the site demonstrating stabilised shrub and birch trees in the distance Figure 2 View of the site demonstrating stabilised shrub and birch trees in the distance Figure 3 Remnant of original drainage line showing wet conditions Figure 4 Shrub coverage on the bog Site Visit Report - SV Bord na Mona Allen Peat Limited Page 8 of 10

9 Figure 5 view of the site demonstrating stabilised shrub and birch trees in the distance Figure 6 view of the site demonstrating stabilised shrub and birch trees in the distance Site Visit Report - SV Bord na Mona Allen Peat Limited Page 9 of 10

10 Figure 7 Remnant of original drainage line showing wet conditions Figure 8 Shrub coverage on bog Site Visit Report - SV Bord na Mona Allen Peat Limited Page 10 of 10