Inspection Plan for Industrial Emissions Directive, Integrated Pollution Control, and Waste Licensed Installations
2022-2025
Publication date: April 2021
This document outlines the EPA’s Environmental Inspection Plan for IED, IPC and Waste Licensed installations. It provides the overall framework in which inspections are planned and take place.
This Environmental Inspection Plan is prepared in accordance with IED requirements and with reference to best practice as outlined by relevant IMPEL1 guidance (FR-2018-17-Tool-Combined-guidance-DTRT-IED.pdf (impel.eu). The Plan is reviewed every 4 years
Ongoing Governance
The OEE has a dedicated Standards unit which monitors the successful completion of the Annual Programme of Environmental Inspections and adherence to the overall Environmental Inspection Plan. The status of compliance with the IED is reported to the Board of the EPA and procedural changes are made as required to strengthen ongoing compliance with IED requirements
Register of Installations
The EPA maintains a database for all licensed installations. This database contains detailed information about each licensed installation which is used to inform the inspection plan. There are currently over 800 licensed installations in operation
Geographical Area
The inspection plan covers all the counties in Ireland. The EPA has subdivided these counties for enforcement of the industrial activities on a regional basis by its regional inspectorates in Dublin, Cork, the South East (Wexford and Kilkenny offices) and Castlebar. Waste licences or IE licences where the primary activity is waste are enforced through a single Waste Licence Enforcement Team.
Identification of Environmental and Sectoral Issues
In addition to the Regional Enforcement Teams, the EPA monitors developments across the main sectoral areas.
Each year, the EPA identifies the main environmental issues and develops a targeted enforcement plan, consisting of both project and site inspection work.
Enforcement Priority groups
Enforcement Priority groups are established as needed to pursue sectoral projects identified by the EPA. Cross-sectoral work areas are also undertaken by Enforcement Priority groups, including the management of contaminated sites and closed sites. The Enforcement Priority Groups identify an issue and prepare a plan of action which is supported by appropriate resources. Examples of where this approach has been used is to target licensed sites that have been identified as a significant pressure under the Water Framework Directive and to target fire risk at waste transfer stations.
The EPA’s inspection activities encompass a number of assessment tools, such as:
• Site audits and inspections
• Desk-based assessments
• Water sampling and analysis
• Air emissions monitoring
• Remote compliance assessments
• Odour/Noise assessments/monitoring
• Specialist investigations e.g. drone surveys
• Landfill gas monitoring
Routine environmental inspections
The programme of routine inspections is based on several criteria:
(a) A systematic appraisal of the environmental risks of each installation is carried out as described in the following document: EPA-Revised-RBME-Risk-Model-2020.pdf
This appraisal system looks at the complexity of the activity on site, the location of the site (its proximity to a sensitive receptor or protected area and the vulnerability of the any aquifer present), the site’s enforcement history over the previous 12 months and whether the site has accredited EMAS status.
This assessment results in sites being categorised into one of twelve “Enforcement Categories”: A1, A2, A3, B1, B2, B3, C1, C2, C3, D1, D2 and D3, with A1 incorporating the highest-risk sites.
The minimum frequency of site visits required to installations within each category is set as follows:
• A sites: Site visit every year;
• B sites: Site visit every 2 years;
• C and D sites: Site visit every 3 years.
National Priority Sites
Where a site is designated as a National Priority Site for enforcement, a Site-Specific Enforcement Plan (SSEP) may be developed. Such a plan might include a schedule for additional site visits, identify site specific investigations or reports to be completed and/or identify any further enforcement or legal actions considered necessary
Routine monitoring is also carried out:
• Aqueous emissions and groundwater monitoring are conducted by EPA staff to assess compliance with the emission limit values (ELVs) set in the licences.
• Air Emissions monitoring is conducted by third party contractors appointed by the EPA, for the purposes of collecting emission samples for verification of compliance with the emission limit values (ELVs) set in the licences. The frequency and scope of these visits is risk based and considers criteria such as the likely emissions from the activity, the range and potential impact of pollutants emitted and previous compliance history based on EPA monitoring data and licensee self-monitoring data
Provision for Co-Operation with Other Authorities
The EPA coordinates a network of enforcement authorities in Ireland, which is called the Network for Ireland’s Environmental Compliance and Enforcement (NIECE). The key objective of the network is to foster co-operation between the various public service bodies involved in the enforcement of environmental legislation, so that a higher and more consistent standard of enforcement is achieved throughout the country.
The EPA also maintains specific written agreements with relevant statutory bodies in relation to how the bodies will co-operate to assist each other in achieving their objectives. For further information, please see
https://www.epa.ie/who-we-are/corporate-information/memoranda-of-understanding/
OEE reports on its inspection and enforcement activities biannually to the Board of the EPA