1. Preparation for an EPA Audit and Environmental Impact Assessments Jim Dowdall Director – Enviroguide Consulting

2. EPA – Who Are They? The EPA were established in 1992 under the Environmental Protection Agency Act. They are an independent public body that have a wide range of functions in order to protect the environment. They are tasked with Environmental licensing Enforcement of environmental law Environmental planning, education and guidance Monitoring, analysing and reporting on the environment Regulating Ireland's greenhouse gas emissions Environmental research development Strategic environmental assessment Waste management Radiological protection

3. Types of EPA Audits Licence Site Inspections Full EPA Licence inspection (scheduled and routine) Site inspection following environmental complaints Licence application / amendment application prompted inspection Sampling e.g. surface water/ foul water samples Targeted site e.g. MSW processing facilities

4. Types of EPA Audits Other Approved assessors inspection - solvents WEEE & Battery retailers/ distance sellers inspection ODS/ F-Gas Contractor/ End User inspection Emissions Trading Permits Halon Use (Airports) Repak Compliance

5. Who can expect an inspection?

6. How to prepare – where to start? EHS Managers/Officers need to be very clear ; on every detail of licence on how their site operates that all site personnel are au fait with licence requirements of consequences of non compliance for viability of company overall that there may be commercial pressure to take short cuts.

7. How to prepare – where to start? Examine each condition/sub condition and list out requirements Draw up programme to do necessary work based on “once off” and regular ongoing tasks e.g monitoring Environmental Management System should be one of main planks in achieving compliance so make sure it’s contents are sensible and practical Set out a structure ( lists / checklists) to guide your work

8. How to prepare – where to start? Critical to compliance is training of site personnel to achieve their buy in. Respond to correspondence from Regulator and deal with issues raised ( sometimes a proposed timescale for action will be acceptable) Keep good records/ documentation. In House auditing could be considered

9. How to prepare – where to start? “You never get a second chance to make a fist impression”

10. How to prepare – where to start Records Put together an Environmental Folder EPA Licence / LA Waste Permit NWCPO Waste Collection Permit Weighbridge calibration certificates Bund certificates Contacts list Annual reports

11. How to prepare – where to start Communications Folder Store all correspondence to and from the EPA in a file Maintain all copies of inspection reports, letters, circular letters sent by the Agency. Print and maintain copies of letters or emails that you have sent to the EPA or responses to reports.

12. How to prepare – where to start Other files Training folders – maintain all training certification and records even items that you think may not be relevant to environmental e.g. safepass. These files may overlap with the Health & Safety files and this is ok.

13. Why is Health and Safety relevant to Environment? If people carry out the duties in a safe manner there is less chance of accidents that may have the potential to cause environmental pollution e.g. spillages onsite. Equally environmental incidents have the potential to cause H&S concerns e.g. oil spillage may cause a slip, asbestos release may cause health concerns, dust may cause irritated eyes etc. Essentially they can compliment and supplement each other.

14. Good on-site practices Many best practice requirements are made mandatory by the requirements of your Licence. However, these practices should be maintained onsite regardless: Security – no unauthorised access to the facility Bund liquids Provide spill kits Contain and clean all spillages as they occur Provide signage – storage bays, office areas etc.

15. Avoid environmental nuisances….. Mud Dust Flies Birds Odour Litter Rodents Blocked drains / drain grids

16. …..and you will avoid nuisance neighbours No waste facility here!! This place stinks – I’ll ring the EPA Oh not another complaint – I better go and do an inspection I Object!! Out Out Out!! We don’t want you here…. Community says no to SUPER DUMP How can we get rid of them?

17. Things are not as simple as they seem A high volume of waste on-site – a problem? You may not think so but your EPA inspector may have other ideas: What if there is a fire? This could act as a fuel source. What if the site closes – who will be left with disposal/ clean-up cost? Are they financially struggling – maybe they cannot secure facilities due to non-payment. We better look at their CRAMP/ ELRA. Have they a bond in place? Maybe we will request on just in case. Poor site management and transport management. This company has no regard.

18. Contractors Always use appropriately authorised contractors Waste collectors – do they have a permit, are their vehicles listed, are they authorised to collect the specific waste type, are they authorised to deliver to the destination facility? Waste destinations – do they have appropriate permits/ licences, are they authorised to collect the specific waste type/? Air con contractors – are they F-Gas registered? Is gas being installed by appropriately trained personnel? What is happening waste gas? Suppliers or electrical goods – laptops, phones etc. are the suppliers registered as WEEE Producers? Is the retailer / distance seller registered? Could your contractor be causing you problems?

19. What next? Each Licence will have its own specific conditions that need to be met. Maintain good housekeeping Maintain records and communication files Avoid environmental nuisances Ensure that a suitably qualified manager or deputy is on site at all times during the operation of the facility or ensure staff know how to contact them in the event of an inspection

20. Environmental Impact Assessment EIA is “…the process of examining the environmental effects of developments from consideration of the environmental aspects of the design stage, through to the preparation of an EIS, evaluation of the EIS by a competent authority and the subsequent decision as to whether the development should be permitted to process, also encompassing public response to that decision”

21. Life before EIA Planning permission was granted without proper environmental consideration Strategic developments was confined to local authorities and was often overruled by County Councillors Why EIA? Ensure developments are sustainable and the EIA is part of planning process and is an EU requirement. Provides objective and scientific basis for assessing effects of development on the environment. Transparent Process.

22. Annex 1 Thresholds – Developments that need an EIA Thresholds apply under Annex I and II of the EIA Directive. Examples include: Crude-oil refineries Thermal power stations Smelting of cast iron and steel Extraction of asbestos Integrated chemical installations Long-distance railway traffic and of airports Motorways Inland waterways and ports Waste disposal installations Groundwater abstraction Waste water treatment plants Extraction of petroleum and natural gas intensive rearing of poultry or pigs Quarries and open-cast mining Construction of overhead electrical power lines

23. EIA Process Screening Scoping Consideration of Alternatives Describing the Proposed Project Identify receiving environment Impact assessment Mitigation Measures Public / stakeholder consultation Residual impacts and conclusions

24. Receiving Environments Flora & Fauna Traffic Human Beings/ socio-economic Cultural Heritage Climate Air – noise, dust Water

25. Any Questions? Thank you Jim Dowdall www.enviroguide.ie