EPA Environmental Inspection Plan

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.

https://www.epa.ie/our-services/compliance–enforcement/support-and-supervision-of-local-councils/niece-network/

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

EPA Ireland Submission Data available as RSS, CSV and SQLite

Whilst there is a ton of useful data on the EPA Ireland web-site, it’s not exactly easy to track what’s going on.

Tool built by https://twitter.com/conoro to scrape the thousands of individual RSS feeds and generate what is hopefully helpful to those of you who wish to monitor submissions on the site.

The code is all up on GitHub here. In summary what it does is:

  • Once a day around 1.30am GMT, it scrapes all the feeds on the EPA site
  • It saves all the data into a SQLite database and uploads that to Amazon S3
  • It updates a single small RSS feed with all the submissions from the previous day
  • It generates a new CSV file with the same data as the RSS feed and saves that to GitHub

Subscribing to the RSS Feed

Use this URL in Feedly or similar: https://raw.githubusercontent.com/conoro/epa-rss/main/output/daily.xml

Viewing the daily CSV files.

They are all here in the repo starting on Sep 22nd 2022: https://github.com/conoro/epa-rss/tree/main/output/csv/daily

Getting notified by email (experimental)

If you’d like to receive email with a link to the latest CSV each day:

  • Create a GitHub Account
  • Click the drop-down menu beside “Watch” in the top right of this project’s page.
  • Select “Custom” and tick the box beside “Issues”. Then click Apply.
  • You should start receiving the emails beginning tomorrow.

SQLite Database

The latest full set of scraped data is available as a SQLite DB that you can download here. Use something like SQLiteStudio to browse and query it.

Examining the data in the SQLite Database using Datasette Lite

You can use a very cool project by Simon Willison called Datasette Lite to browse and query all the latest data in your browser by going here. I highly recommend playing around with it, as you can query by keywords and date ranges.

https://conoroneill.net/2022/09/26/epa-ireland-submission-data-available-as-rss-csv-sqlite/

EPA Spatial ETL (Extract, Transform, Load) Software

The EPA is seeking to procure spatial ETL (Extract, Transform, Load) software to assist in its spatial dataset development, workflow, and modelling tasks. The EPA receives data from a number of different sources in multiple data formats. From this data the EPA generates and builds additional datasets, import the data into existing system and run analysis and modelling on the relevant datasets

At a minimum the tool will have the ability to support multiple data formats such as (but not limited to): Shapefile, Excel, CSV, Geodatabase, SQL, KML, TAB, DWG, JSON, LiDAR, ECW, PDF, GML, PostgreSQL, GPX.

https://irl.eu-supply.com/app/rfq/rwlproposal_s.asp?PID=220994

The Persistent Organic Pollutant (POP) Module in EDEN

Per and polyfluoroalkylated substances ( are a group of manmade chemicals that may be found in aqueous film forming foam ( used in some fire suppression systems, including portable handheld fire extinguishers.

While PFAS encompass a very large number of substances and the effects of most of these are unknown, PFAS (such as perfluorooctanoic acid ( and perfluorooctane sulfonate ( are widely recognised as harmful to humans and the environment PFAS are often described as the “forever chemicals” due to their persistent nature meaning they break down very slowly, if at all, in the environment and so can pose long term risks.

Furthermore, many PFAS present in fire fighting foams are both bioavailable and bioaccumulative, meaning they are easily absorbed by living organisms and can increase in concentration within the body PFAS discharged on land, can contaminate the soil, or be washed off into streams, rivers, potentially contaminating groundwater and drinking water supplies.

There is a requirement of annual reporting to the EPA of stockpiles of fire-fighting foams containing Perfluorooctanoic Acid (PFOA) and PFOA-related substances.

A full list of substances that are classed as “PFOA, its salts and PFOA-related compounds” is available at PFAS | Environmental Protection Agency (epa.ie). This currently consists of 32 substances

EDEN reporting is only required for stockpiles > 50 kg ( smaller stockpiles are reports via email to pops@epa.ie )

Bathing Water Open Data

This is the Bathing Water Open Data API which has three API datasets: Locations, Measurements and Alerts.

This information is populated using the EPA’s CRM Bathing Water information service and the EPA’s central water quality database Aquarius.

Local authorities report this information to the EPA via the Bathing Water Information System (BWIS) and Monitoring Data System (MDS) applications on EDEN (Environmental Data Exchange Network).

The EPA provides this information to the public via the responsive beaches.ie website.

Local authorities are required to report the information for ‘identified’ bathing waters monitored and managed under the requirements of the Bathing Water Quality Regulations 2008 (SI No. 79 of 2008). In addition, local authorities report information to the EPA for other monitored waters not managed under the Regulations (non-identified bathing waters).

https://data.epa.ie/api-list/bathing-water-open-data/

BMW reporting module in EPA EDEN system

BMW stands for biodegradable municipal waste. 

General information with regard to the BMW reporting module: Biodegradable Municipal Waste (BMW) Reporting | Environmental Protection Agency   (epa.ie)

In relation to what happens to the information that landfill operators submit to the EPA – this comes into an internal system that is used by the EPA to manage the issuing and enforcement of EPA licences and other EPA authorisations. 

Some of the information held in this system is published to the EPA website (e.g. Annual Environmental Reports, Site Inspection reports), and other information is made available at EPA offices (e.g. via a user interface called LEAP). 

Summary information relating to the BMW data returns is already published on the EPA website here: ‘First Look’ Data | Environmental Protection Agency (epa.ie)

There are three active municipal waste landfills accepting waste in Ireland at present – Knockharley Landfill (W0146-02), Drehid Landfill (W0201-03) and Ballynagran Landfill (W0165-02). 

Should public wish to see more specific information/data about the three landfills, each of these landfills operates under an Industrial Emissions (IE) licence, so they can find more specific information by searching for the relevant licence here:

Search for a Licence/Permit | Environmental Protection Agency (epa.ie), and then clicking on the “View Licence Enforcement Documents” button.

The “BMW Reporting Module” in EDEN is not a dataset, and there is no facility to view landfill data on that module, other than any data returns that someone has previously submitted to the EPA for a landfill under their control. 

The BMW reporting module is only a mechanism for landfill operators to submit specific information to the EPA on municipal waste acceptance which is required to be submitted under the conditions of their licence.

EDEN Walkthrough – what data is collected by the EPA when a waste operator / local authority submits an Article 11 request (for Waste Disposal and Recovery Activities)

Waste Management (Facility Permit and Registration) Regulations, 2007, Amended by the Waste Management (Facility Permit and Registration)(Amendment) Regulations, 2008

Request under Article 11 of the Regulations to the Environmental Protection Agency for determination as to whether an activity requires a waste licence, waste facility permit, certificate of registration or none of these

Note from EPA: You must have following information to-hand before completing the Article 11 Request form.

  • Contact email address.
  • Grid Reference (Eastings & Northings).
  • Site map, showing outline of site of proposed activity.
  • The Authorisation or Registration Number if you have existing authorisation i.e. Waste/IPPC Licence, Waste Permit, Certificate of Registration.
  • The Reference Number if you have submitted a previous Article 11 request.
  • Description of Waste, including:
    • Solid or Liquid
    • European Waste Catalogue (EWC) Code
    • Annual intake in tonnes
    • Annual intake in litres
    • Source of Waste
  • The amount, in tonnes and litres, of ‘residual waste’ remaining after recovery that is to be sent on for disposal.
  • Whether ‘biological treatment’ is involved in the proposed activity.
  • For biological treatment processes, the quantity of biowaste, digestate and compost, as relevant, in tonnes and cubic metres that will be present at the facility at any one time.
  • For land deposition/reclamation/restoration activities, the amount of waste (in tonnes) to be deposited over the operational lifetime of the activity.
  • Information related to Planning – planning reference number or evidence of exemption.
  • Information on Designated Sites, where applicable (e.g. Special Areas of Conservation, Special Protection Areas, Ramsar sites, Natural Heritage Areas). Information should include:
    • Site Name
    • Site Code
  • Confirmation as to whether or not the site of the proposed activity is in, or next to, a wetland.

Local Authority- Do I need a Waste Licence or Certificate of Registration

Private Sector – Do I need a Waste Licence, Permit or Certificate of Registration

Drop down for “Source of Waste” is as follows:

Construction & Demolition

Municipal (Household & Commercial)

Household

Commercial

Gardens & Parks

Industrial

Agricultural

Healthcare

Waste Management Industry

Other

For more details see

https://www.epa.ie/our-services/licensing/waste/declaration-on-waste-authorisations-art-11/

FAQs

https://www.epa.ie/resources/faqs/waste/general-article-11-questions/#d.en.84156

Database for waste facility permits and certificates of registration

The Waste Facility Permit and the Certificate of Registration Database is a register for waste facility permits and certificates of registration issued by local authorities under the Waste Management (Facility Permit and Registration) Regulations, S.I. No. 821 of 2007, as amended. This website is a central register hosted by the National Waste Collection Permit Office (NWCPO) of all waste facility permits and certificates of registration granted, reviewed, revoked and expired. The database can be accessed at the following link: http://facilityregister.nwcpo.ie/

Sample waste permit

http://facilityregister.nwcpo.ie/details.aspx?recordId=39567