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 Arrabawn Co-operative Society Limited

Licensee Arrabawn Co-operative Society Limited

Licence Register No. P0791-02

CRO Number

Site Address Stafford Street, Nenagh, Tipperary

Site Visit Reference No. SV09495

Report Detail

Issue Date 16/06/2016

Prepared By Irene Doyle

Site Visit Detail

Date Of Inspection 09/05/2016 Announced No

Time In 14:00 Time Out 15:30

Agency Personnel On Site Irene Doyle

Licensee Personnel and Role Jason McAndrew, Head of Engineering and Environmental Services
Joan McCarthy, Environmental Manager
Eddie Butler, WWTP Technician
Photo Taken Yes Samples Taken No Video Taken No

Site Visit Report - SV09495 - Arrabawn Co-operative Society Limited Page 1 of 5

 Scope

This site visit was conducted on foot of an incident at the onsite waste water treatment plant.

Media

Water

Site Areas Inspected

Waste water treatment plant

Documents Inspected

None

Site Visit Report - SV09495 - Arrabawn Co-operative Society Limited Page 2 of 5

 1. Site Specific Issues

Answer Condition Non Observation

Number Compliance
1.1 Are Waste water treatment plant No 3.12 & 5.1 Yes
operations satisfactory?

Comment / Corrective Action

Comment

On the 9 May 2016 the licensee notified the EPA of an incident at the waste water treatment plant (WWTP).
At 8:00 hours that morning the WWTP technician observed sludge flowing over the final clarifier to the sand
filter and subsequently discharging to the Nenagh River via the Clareen stream. The licensee stopped the
forward feed immediately and commenced investigations. Via a telephone call, the licensee was instructed
by the EPA to take samples at point of discharge, upstream and downstream and the Nenagh River at the
local swimming pool. These samples were analysed inhouse and the results submitted to the EPA. Analysis
results indicate an ammonia emission limit value exceedence of 2.99 mg/l N versus an emission limit value
of 1.0 mg/l N at SW2.

This is a non-compliance with Condition 3.12 & 5.1

Records from the sludge blanket detector installed on the clarifier and the turbidimeter installed on the final
discharge indicated a deviation from normal operations from approximately 19:30 hours on Sunday evening
8 May 2016 until the WWTP technician arrived onsite at 08:00 hours on Monday morning 9 May 2016.
Alarm systems had not yet been commissioned on these two instruments. The Agency notes that they were
subsequently commissioned on 10 May 2016.

At approximately 14:30 on the day of the visit, the sludge detector mechanism was reading 0.17. Action and
warning limits were to be set at 0.4 and 0.6. However records indicated that the sludge blanket went over
the clarifier at a reading between 0.5 and 0.6. This information was to be fed into the commissioning of the
alarm system the folowing day. Normal range for turbidity readings prior to the incident had been 2 to 4
FTU. On the day of the visit readings were 19.8 FTU.

The licensee's investigation noted that an operator error had caused a hydraulic load of 30,000 litres
of clean water from a wash cycle on the evaporator to discharge to drain, compromising the normal
operating conditions of the WWTP. The investigation was ongoing at the time of the site visit.

Forward feed recommenced at approximately 14:00 hours and the licensee was instructed to take a grab
sample at 14:30 and again later in the evening to demonstrate a return to compliance with licence
conditions.

Corrective action

The licensee is required to respond to the Agency on this matter through Compliance Investigation
CI001038, Action A012974 concerning a review of the capacity and suitability of the onsite WWTP to meet
production needs. In addition, the licensee shall review work practices onsite and provide training and
support where required to minimise future impact of operator error on the WWTP.

The Agency notes that alarm systems on the sludge blanket detector and the turbidimeter were
commissioned on 10 May 2016.

Site Visit Report - SV09495 - Arrabawn Co-operative Society Limited Page 3 of 5

 CI Actions / Instructions
CI Number Issue / Theme Origin
CI001038 Water/Pollution Incident Notification
Waste water treatment plant management
A spill of 37,000 litres approx to the onsite WWTP followed by a Hydraulic loading of 160,000 litres of clean
water caused a failure of the WWTP to operate under normal conditions and lead to a discharge of WWTP
sludge to the Clareen Stream. This discharge was in exceedance of licence ELVs.
An investigation into this incident and site visit by Agency inspectors highlighted a number of issues
concerning the control and management of the WWTP.
Action Number Type Due Date Status
A012974 Action 29/01/2016 Closed
Review and investigate suitability of onsite WWTP to control site wastewaters
The EPA has reviewed analysis records provided for 2015 for emissions from monitoring point SW2 (final
effluent) and analysis results of samples taken by both Tipperary County Council staff and EPA inspectors.
These results have indicated several emission limit value exceedances for, in particular, Total Ammonia,
ortho-Phosphate and Suspended Solids.
In light of these findings, the licensee is required to investigate the onsite wastewater treatment plant and to
provide a report to the Agency via the EDEN Portal in response to this request which includes but is not
limited to:
• The suitability of the WWTP infrastructure with regard to capacity and retention time to treat the onsite
waste streams
• Review of both hydraulic and nutrient loading to the plant
• Operational factors
• Ambient conditions
• Recommendations for any remediation works deemed necessary from the findings to ensure the plant is
brought into continuous compliance with licence conditions.

This report is to be submitted to the Agency by 29 January 2016. The licensee should engage the services
of external expertise in this matter if necessary.
Regards
Irene Doyle
Answer Condition Non Observation
Number Compliance
1.2 Is there an out of hours procedure in No Yes
place?

Comment / Corrective Action

Comment

An out of hours procedure, approved by the EPA was due to be implemented by 15 March 2016. This
procedure was not implemented as the alarm systems on the sludge blanket detector and the turbidimeter
were not commissioned at the time of this incident on the 9 May 2016.

Corrective action

The licensee shall implement the out of hours procedure for the WWTP and review and identify any other
areas of site to ensure that activities including normal production and maintenance works do not adversely
impact on the WWTP.

Site Visit Report - SV09495 - Arrabawn Co-operative Society Limited Page 4 of 5

 Summary

The licensee was found to be in non-compliance with licence conditions 3.12 and 5.1 concerning the capacity of the
onsite waste water treatment plant and an emission limit exceedance of ammonia at SW2. In addition one
observation was raised which will require action by the licensee concerning out of hours procedures.

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.

Site Visit Report - SV09495 - Arrabawn Co-operative Society Limited Page 5 of 5