attachment no i.7: noise · site (accompanied by horn blasts at a level crossing), and a ride on...

Industrial Emissions Licence Application Dairygold Agri Business Lombardstown

Attachment No. I.7

ATTACHMENT No I.7: NOISE

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NOISE ASSESSMENT

Dairygold Agri Business Ltd,

Feed Mill and Grain Operations Facility,

Lombardstown,

Co. Cork.

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16718-6005-A Noise Assessment November 2015

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ISSUE FORM

Project number 16718

Document number 6005

Document revision A

Document title Noise Assessment – Dairygold AgriBusiness Feed Mill and Grain Operations

Facility, Lombardstown, Co. Cork

Document status Final

Document prepared by Peter Barry

Document checked by Caitriona Fox

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Table of contents

1 INTRODUCTION ......................................................................................................... 1

2 METHODOLOGY ......................................................................................................... 1

2.1 Prevailing Noise Environment............................................................................................ 1

2.1.1 Noise Monitoring Locations .................................................................................................................. 1

2.1.2 Survey Equipment ................................................................................................................................. 4

2.1.3 Survey Protocol ..................................................................................................................................... 4

2.1.4 Measurement parameters .................................................................................................................... 4

2.1.5 Meteorological Conditions .................................................................................................................... 4

2.2 Assessment Criteria .......................................................................................................... 5

2.3 Existing Noise Evironment ................................................................................................. 6

2.3.1 Daytime Survey ..................................................................................................................................... 6

2.3.2 Evening time survey .............................................................................................................................. 8

2.3.3 Night time survey .................................................................................................................................. 9

3 CONCLUSIONS AND RECOMMENDATIONS ............................................................... 10

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1 INTRODUCTION

This Noise Assessment was undertaken by Malachy Walsh and Partners on behalf of Dairygold Agri

Business Ltd in respect of its existing Feed Mill and Grain Operations facility at Lombardstown,

County Cork. This report provides an understanding of the prevailing noise environment, the nature

and character of the facility noise sources, including such features as tonal characteristics,

intermittency, duration and timing, and noise sensitive receptors in proximity to the Feed Mill

facility.

2 METHODOLOGY

This assessment has been prepared in accordance with best practice and guidelines including:

IEMA: Guidelines for Environmental Noise Assessment, November 2014.

EPA: Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to

Scheduled Activities (NG4), April 2012.

2.1 PREVAILING NOISE ENVIRONMENT

A survey was undertaken to establish the existing prevailing noise environment. The survey was

undertaken on the 12th August 2015. Day-time, Evening and Night-time measurements were carried

out. The measurement locations, equipment used, survey protocol, measurement parameters, and

assessment criteria are described in the following sections.

2.1.1 Noise Monitoring Locations

The baseline survey locations included a combination boundary locations and locations

representative of the nearest noise sensitive locations. The noise monitoring locations are shown on

Drawing no. 16718-SK 17 and are set out in Table 2-1.

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Table 2-1 Description of Noise Monitoring Locations

Location

Reference Description Justification

N1

N1 is located at the north

western site boundary in

proximity to the site entrance.

Boundary measurement close to the nearest

noise sensitive receptor

N2

N2 is located along the western

site boundary, within the facility

complex.

Boundary measurement close to a noise

sensitive receptor.

N3

N3 is located along the western

site boundary on Greenfield

lands south of the facility

complex.

Boundary measurement close to a noise

sensitive receptor.

N4

N4 is located along the north

eastern site boundary on

Greenfield lands east of the

facility complex

Boundary measurement, east of the facility.

Locations N1, N2, N3 can be considered representative of the houses nearest to these measurement

locations, while N4 is considered a slight over estimate as the measurement location is considerably

closer to the noise source than the receiver.

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16718-6005-A Noise Impact Statement September 2015

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Figure 2-1 Baseline Noise Survey Locations

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16718-6005-A Noise Impact Statement November 2015

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2.1.2 Survey Equipment

The measurements were made using a Bruel & Kjaer type 2250 Light Logging integrating Sound Level

Meter. This instrument is a Type 1 instrument in accordance with IEC 651 regulations. The Time

Weighting used was Fast and the Frequency Weighting was A-weighted as per IEC 651. The

instrument was calibrated with a B&K type 4231 calibrator prior to and after the measurement

period. Factory calibration certificates for the noise level meter and acoustic calibrator are available

on request.

2.1.3 Survey Protocol

Noise monitoring was undertaken at 30 and 15 minute intervals. The sound level meter (SLM) was

mounted on a tripod at 1.5m above ground level and at least 2m away from any sound reflecting

objects. A windshield was placed on the microphone to reduce wind interference during

measurements.

2.1.4 Measurement parameters

Several parameters were measured in order to be able to interpret the noise levels correctly. These

included the;

LAeq Time-averaged A weighted noise level. This is the equivalent continuous sound level.

It is a type of average and is used to describe a fluctuating noise in terms of a single noise

level over the sample period (T). The A weighting most closely represents the range of

human hearing.

LA90 Noise level exceeded for 90% of measurement period (steady underlying noise

level). It will therefore exclude the intermittent features of traffic and is used to describe a

background level.

LA10 Noise level exceeded for 10 % of measurement period. It is used to determine the

intermittent high noise level features of locally generated noise and usually gives an

indicator of the level of road traffic.

2.1.5 Meteorological Conditions

Meteorological conditions were noted as dry, mild with light winds not exceeding 5 meters per

second (ms-1) at any time during the survey. A hand held anemometer and temperature probe was

used to determine wind speed and temperature during each reading.

Weather conditions during the survey were for the most part dry and calm. An analysis of the data

indicates no significant impact from excessive rain or high winds.

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2.2 ASSESSMENT CRITERIA

Dairygold Lombardstown intends to apply to the Environmental Protection Agency (EPA) for an

Industrial Emissions Licence. The EPA provides noise assessment criteria for licensed activities. The

EPA Noise Guidance Document (NG 4) provides for a daytime limit of Leq 55dBA, an evening limit of

Leq 50dBA, and a night time limit of Leq 45dBA. The EPA limits are set out in Table 2-2 below. The

daytime, evening and night time periods are also defined.

Table 2-2 EPA Licence Emission Values

Specific Environment

(Outdoor values) Critical health effect(s) LAeq dB(A)

Daytime 07:00 to 19:00 55dB LAr, T

Evening 19:00 to 23:00 50dB LAr, T

Night time 23:00 to 07:00 45dB LAeq, T

As the facility operates through the night, the most critical noise criteria are the night time levels, i.e.

45dB LAeq, T

.

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2.3 EXISTING NOISE EVIRONMENT

The prevailing noise environment is made up of a combination of sources including the existing

Dairygold Lombardstown operation, traffic on the local road network, and trains on the Railway Line

which is in close proximity to the northern boundary of the site. The site is located in a rural

agricultural setting with several large scale agricultural enterprises also in the locality. The baseline

noise survey results describe the existing noise environment. Noise levels were measured during

day, evening and night time periods. This will allow the existing noise levels to be compared against

relevant standards and guidelines. The results are presented in the following tables.

The noisiest activity takes place during the harvest season which runs from June to early October.

During this period, the vents, fans, aeration blowers, and conveyors, all intrinsic to the drying and

storage of grain, are in operation to some degree. When in operation, these are the loudest noise

sources on site. The zone of influence is to the North as sound from these noise sources propagates

North while other silos and buildings largely inhibit the transmission of sound propagating in other

directions. The results of the baseline survey undertaken in August 2015 are presented in Table 2-3,

Table 2-4 and Table 2-5 below.

2.3.1 Daytime Survey

Table 2-3 Daytime Noise Survey Results

Location Duration

(m)

Start

time LAeq dB LA10 dB LA90 dB Description

N1 30

11.20 55.1 53.7 41.8

Local rd traffic/ Site traffic entering and exiting

the site/ Train blast/ Tannoy system

14.25 71.5 72.6 46.9 Lorry entering/ HGV/ HGV stopped at

entrance/ Lawnmower

14.57 74.1 64.3 42.8 Shots (Vermin control)/ Lorry exiting/ Ride on

lawnmower/ Tannoy/ Train blast.

N2 30

09.25 52.8 52.9 47.3 HGV traffic on site/ Birds/ Train blast/ Grain

loading vehicles/ Tannoy

12.05 55.7 56.2 48.0 HGVs/ Forklifts/ Tannoy/ Auger squeaking.

12.37 56.4 57.6 53.9 Loader bucket banging/ Lorry tipping/ Squeaky

auger/ Low flying aircraft/ Car starting nearby/.

N3 30

10.03 49.5 51.3 47.7 Tractor on road / Tannoy system.

13.18 52.8 54.3 51.0 Lorry tipping grain/ Dog barking/ Gate crashing

closed/ Passing tractor/ Passing lorry.

13.49 52.4 53.8 49.8

Tipping lorry/ Dumper loader in upper yard/

Birds/ Banging of bucket in mill/ Strimmers in

main car park area.

N4 30

10.42 42.4 43.8 39.6 Road traffic faintly audible/ Mechanical noise

from facility/ Aeroplane.

15.36 41.0 42.7 38.5 Road traffic from N72 faintly audible. Tannoy

system.

16.06 43.8 45.1 38.8 Truck horn on N72/ Tannoy system/ Truck

reversing alarm/ Train blast/ Train passing.

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N1

N1 is located near the existing site entrance (see also Drawings 16718-SK17 for Locations of N1 to

N4). Over the course of the day, the main noise sources at this location were related to trucks

entering and exiting the site. However many other intermittent loud noise events were also

observed which would have contributed to the measured noise level. These included a shot blast

which is used to control vermin, the onsite tannoy system used for onsite communications, the

occasional train on the Cork to Kerry rail line which runs adjacent to the northern boundary of the

site (accompanied by horn blasts at a level crossing), and a ride on lawnmower. The ride on

lawnmower distorted the ambient noise measurement (LAeq) during the survey period when it was

operational.

The day time ambient noise level ranged from 55 dBA to 74 dBA. However the 74 dBA should be

discounted as it’s predominantly the ride on lawnmower. The ambient noise level at this location

was made up of many sources.

The daytime background noise levels represented by the L90 parameter ranged from 42 dBA to 47

dBA. The LA90 parameter generally excludes loud intermittent noise events and is an indication of

the steady underlying noise levels.

N2

The noise environment at N2 is similar to N1. Many of the same noise sources influenced the noise

levels measured at this location. The total noise level measured over the thirty minute survey

periods ranged from 53 to 56 dBA. The ride on lawn mower was not working during these survey

periods. Mobile and intermittent noise sources were the main contributors including cars, trains,

HGV’s, loaders, lorries and augers.

The background noise levels which are indicative of the underlying noise level, ranged from 47 dB(A)

to 54 dB(A).

N3

N3 is close to a house, approximately 90 m south of the existing South Boundary. The ambient noise

level ranged from 50 to 53 dB (A). The main noise sources included lorries, tractors, the internal

tannoy system, dumper loader in upper yard, and a strimmers in the main car park area, a tractor

and internal tannoy system.

The background noise levels which are indicative of the underlying noise level, ranged from 48 to 51

dB (A).

N4

N4 is located in the proposed development area, where the grain store is to be located. The ambient

noise level ranged from 42 to 44 dB(A). Traffic noise from the N2 was faintly audible. Other

contributing noise sources included trucks on site and the occasional passing train.

The background noise levels which are indicative of the underlying noise level, ranged from 39 to 40

dB (A).

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2.3.2 Evening time survey

Table 2-4 Evening Noise Survey Results

Location Duration

(m)

Start

time LAeq dB LA10 dB LA90 dB Description

N1 30 21.22 51.8 52.9 44.0

Traffic on local roads. Children playing.

Dogs barking. Passing train, sounding at

crossing.

Noise from facility included cutting mill,

conveyor auger (whine/ squeak), Tannoy)

N2 30 20.50 49.7 50.6 48.4

Distant traffic on N72 audible. Birdsong.

Site noise included HGV’s leaving site and

mill activity including conveyor-auger

squeak.

N3 30 22.01 47.7 45.6 46.6

Distant traffic on N72 audible. Birdsong.

Site noise included HGV’s leaving site and

mill activity including conveyor-auger

squeak.

N4 30 22.39 52.3 53.2 51.3 Grain Dryers and associated vents and

dryers.

With the exception of N4, the evening noise levels show a decrease over the daytime noise levels.

This can be attributed to a reduction in the intensity of external site activities. Similar to the daytime

levels, there is a greater variation in noise levels at N1 and N2, than at N3 and N4. This suggests as

confirmed by on site observations that near the site entrance noise levels are mainly influenced by

loud mobile and intermittent noise sources. The influence of the existing facility is much less South

and East as one moves away from the main activities in the grain intake area and site access. The

receptors West of the facility, are screened from the Grain dryers noise sources by the existing

facility buildings and silos.

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2.3.3 Night time survey

Table 2-5 Night time Noise Survey Results

Location Duration (m) Start time LAeq dB LA10 dB LA90 dB Description

N1 15 00.05 44.0 43.7 40.8 Traffic on N72 Note 1 (Results for

N2 representative)

N2 15 00.05 44.0 43.7 40.8 Traffic on N72

N3 15 23.34 42.9 44.7 40.3 Dryers wind down. Traffic on

N72

N4 15 23.10 52.5 53.4 51.5 Dryer equipment including

blower and vents

As expected the night time noise levels were reduced at N2 and N3. However the noise levels were

higher during the night at N4. It can seen in Table 2-5 above that a steady noise dominated the noise

measurement at N4 at a level of 52 to 53 dB(A). It was observed that the existing dryers were in

operation during this night time measurement at N4. The main noise sources associated with the

dryers would be the vents and air blowers. The vents are elevated and the dryers are at ground

level. Similar noise levels would be expected during the day and evening periods if the dryers were in

operation.

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3 CONCLUSIONS AND RECOMMENDATIONS

A review of the baseline boundary noise levels indicates that a programme of noise improvement

works will be necessary in order to combat existing elevated noise emissions from the site in

particular at night during the harvest period, when existing Grain Dryers and Stores are in operation.

In conclusion it is considered that with appropriate noise attenuation measures in place, the

Dairygold AgriBusiness Feed Mill and Grain Operations facility will not adversely impact on the noise

environment beyond the site boundary.

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Attachment No. I.8

ATTACHMENT No I.8: CONCLUSIONS ON BAT

Reference Document on Best Available Techniques for Food, Drink& Milk Industries

Reference Document on Best Available Techniques for Energy Efficiency

Reference Document on Best Available Techniques for Emissions from Storage July 2006

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Attachment No. I.8

Reference Document on Best Available

Techniques for Food, Drink& Milk Industries

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Conclusions on BAT from the Food, Drink and Milk Industries BAT Reference Document (extracts) The full and complete Food, Drink and Milk Industries BAT reference document (August 2006) is available at the EIPPC Bureau website: http://eippcb.jrc.ec.europa.eu/reference/

SCOPE All Feed Manufacturing processes and activities at the installation

Conclusions on BAT Applicability Assessment (describe how the technique applies or not to your installation)

State whether it is in place or state schedule for implementation

5.1 General BAT for the whole FDM sector

BAT 1. BAT is to ensure, e.g. by training, that employees are aware of the environmental aspects of the company’s operations and their personal responsibilities (see Section 4.1.2).

Back to Work Training each Year. All staff required to complete Environmental Module as prescribed training

In place

BAT 2. BAT is to design/select equipment, which optimises consumption and emission levels and facilitates correct operation and maintenance (see Section 4.1.3.1), e.g. to optimise the pipework system for the capacity to minimise product losses and install pipes at a gradient to promote self-draining.

All equipment selected through specifications and technical analysis for this purpose

In place

BAT3. BAT is to control noise emissions at source by designing, selecting, operating and maintaining equipment, including vehicles to avoid or reduce exposure (see Sections 4.1.2, 4.1.3.1, 4.1.3.2, 4.1.3.3, 4.1.3.4 and 4.1.5) and, where further reductions in noise levels are required, enclosing noisy equipment (see Section 4.1.3.5).

All equipment selected through specification, maintained in accordance with PM programme and enclosed where feasible

In place

BAT 4. BAT is to operate regular maintenance programmes (see Section 4.1.5).

PM programme in place in place

BAT 5. BAT is to apply and maintain a methodology for preventing and minimising the consumption

The business routinely evaluates the site plant and operations for ways to conserve

In place

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http://eippcb.jrc.ec.europa.eu/reference/

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of water and energy and the production of waste (see Section 4.1.6) incorporating: 5.1 obtaining management commitment, organisation and planning (see Sections 4.1.6.1) 5.2 analysis of production processes, including individual process steps to identify areas of high water and energy consumption and high waste emissions to identify opportunities to minimise these (see Sections 4.1.6.2, 4.1.6.2.1, 4.1.6.2.2 and 4.1.6.2.3), taking into account the water quality requirements for each application, hygiene and food safety 5.3 assessment of objectives, targets and system borders (see Section 4.1.6.3) 5.4 identification of options for minimising water and energy consumption, and waste production (see Section 4.1.6.4), using a systematic approach, such as pinch technology (see Section 4.1.6.4.1) 5.5 carrying out an evaluation and doing a feasibility study (see Section 4.1.6.5) 5.6 implementing a programme for minimising the consumption of water and energy and waste production (see Section 4.1.6.6) and 5.7 ongoing monitoring of water and energy consumption; waste production levels and the effectiveness of control measures (see Section 4.1.6.7). This can involve both measurement and visual inspection

resources and improve energy efficiency, water conservation and waste reduction to achieve a high general level of protection of the environment taken as a whole.

BAT 6. BAT is to implement a system for monitoring and reviewing consumption and emission levels for both individual production processes and at site level, to enable actual performance levels to be optimised. Examples of parameters to monitor include: energy consumption; water consumption; waste water volumes; emissions to air and water; solid waste generation; product and by-product yield; consumption of harmful substances and frequency and severity of unplanned releases and spillages. A good knowledge of the process inputs and outputs is required to identify priority areas and options for improving environmental performance. A good monitoring system will include records of operating conditions, sampling and analytical methods and will ensure that measuring equipment is calibrated. Further information is available in the “Reference Document on the General Principles of Monitoring” [96, EC, 2003].

Monitoring of energy consumption, waste water volumes, and emissions to water takes place.

Monitoring of emissions to air currently not undertaken.

Inventory of all inputs, outputs and wastes generated is maintained

Monitoring of emissions to air to be undertaken within 6 months of grant of licence.

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BAT 7. BAT is to maintain an accurate inventory of inputs and outputs at all stages of the process from reception of raw materials to dispatch of products and end-of-pipe treatments (see Section 4.1.6.2)

Automated reception, production and dispatch systems controls all aspects of material inputs and outputs

In place

BAT 8. BAT is to apply production planning to minimise associated waste production and cleaning frequencies (see Section 4.1.7.1)

Batch manufacturing of products is undertaken to minimise number of change-overs and cleaning frequencies

In place

BAT 9. BAT is to transport solid FDM raw materials, products, co-products, by-products and waste dry (see Section 4.1.7.4), including avoiding fluming except where washing involving the re-use of water is carried out during fluming and where fluming is necessary to avoid damage to the material being transported

All material is conveyed in enclosed transfers systems

In place

BAT 10. BAT is to minimise storage times for perishable materials (see Section 4.1.7.3)

Warehouse management and automated production systems controls all aspects of storage

In place

BAT 11. BAT is to segregate outputs, to optimise use, re-use, recovery, recycling and disposal (and minimise waste water contamination) (see Sections 4.1.7.6, 4.1.6, 4.1.7.7, 4.7.1.1, 4.7.2.1, 4.7.5.1 and 4.7.9.1)

Segregation undertaken of all materials generated including dedicated segregated waste storage area

In place

BAT 12. BAT is to prevent materials from falling on the floor, e.g. by using accurately positioned splash protectors, screens, flaps, drip trays and troughs (see Section 4.1.7.6).

Process controls and enclosed transfers systems minimise losses

In place

BAT 13. BAT is to optimise the segregation of water streams (see Section 4.1.7.8), to optimise re-use and treatment

Manufacturing process does not produce a wastewater stream. Wastewater from the installation limited to canteen, grey laboratory wastewaters and toilet facilities and directed for treatment to on-site wwtp. Residual laboratory chemicals collected separately and held in dedicated containers for collection by licenced contractor .

In place

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BAT 14. BAT is to collect water streams, such as condensate and cooling water separately to optimise reuse (see Section 4.1.7.8)

Steam condensate recovered for use as boiler feed make-up water

In place

BAT 15. BAT is to avoid using more energy than needed for heating and cooling processes, without harming the product (see Section 4.1.7.9)

The plant is completed automated and all processes are constantly monitored

In place

BAT 16. BAT is to apply good housekeeping (see Section 4.1.7.11).

Housekeeping programme in place In place

BAT 17. BAT is to minimise noise nuisance from vehicles (see Section 4.1.7.12)

Plant layout ensures that loading/unloading activities are positioned away from noise sensitive receptors. Where practical, vehicle engines switched off during loading/unloading. Deliveries to the feed mill typically occur outside of night-time hours. Internal road surfaces in good repair.

In place

BAT 18. BAT is to apply storage and handling methods as concluded in the “Storage BREF” [95, EC, 2005]. Further controls may be required to provide and maintain the required hygiene and food safety standards

Where applicable, methods of storage and handling in line with Storage BREF and EPA guidance on the storage and transfers of materials

In place

BAT 19. BAT is to optimise the application and use of process controls to, e.g. prevent and minimise the consumption of water and energy and to minimise the generation of waste (see Section 4.1.8) and in particular: 19.1 where heat processes are applied and/or materials are stored or transferred at critical temperatures, or within critical temperature ranges, to control the temperature by dedicated measurement and correction (see Section 4.1.8.1) 19.2 where materials are pumped or flow, to control flow and/or level, by dedicated measurement of pressure (see Sections 4.1.8.2) and/or dedicated measurement of flow (see Section 4.1.8.4) and/or dedicated measurement of level (see Section 4.1.8.3) and using control devices, such as valves (see Section 4.1.8.7)

The plant is fully automated and all processes are constantly monitored on a central electronic control system to continuously assess the performance of the plant.

In place

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19.3 where liquids are stored or reacted in tanks or vessels, either during manufacturing or cleaning processes, use level-detecting sensors and level measurement sensors (see Section 4.1.8.3) 19.4 to use analytical measurement and control techniques to reduce waste of material and water and reduce waste water generation in processing and cleaning and in particular to: 19.4.1 measure pH to control additions of acid or alkali and to monitor waste water streams to control mixing and neutralising prior to further treatment or discharge (see Section 4.1.8.5.1) 19.4.2 measure conductivity to monitor levels of dissolved salts prior to water re-use and detect levels of detergent prior to detergent re-use (see Section 4.1.8.5.2) and 19.4.3 where fluids may be cloudy or opaque due to the presence of suspended matter, measure turbidity to monitor process water quality and to optimise both the recovery of material/product from water and the reuse of cleaning water (see Section 4.1.8.5.3)

BAT 20. BAT is to use automated water start/stop controls to supply process water only when it is required (see Section 4.1.8.6).

Not applicable – production processes do not have water requirement

n/a

BAT 21. BAT is to select raw materials and auxiliary materials which minimise the generation of solid waste and harmful emissions to air and water (see Sections 4.1.9.1 and 4.1.9.2)

All raw materials used by the installation are industry norm

In place

BAT 22. BAT is that landspreading is an option for the outlet of materials from the FDM sector, subject to local legislation, as discussed in Section 4.1.6.

Not applicable – not undertaken n/a

5.1.1 Environmental management BAT 23. BAT is to implement and adhere to an Environmental Management System (EMS) that incorporates, as appropriate to individual circumstances, the following features: (see Chapter 3) • definition of an environmental policy for the installation by top management (commitment

Dairygold Agri Business currently has an integrated Quality and Health and Safety Management system in place. Dairygold Co-Operative Society Ltd has a documented Group environmental policy

Integrated Managment system to be implemented on an ongoing basis over the next 2-5 years

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of the top management is regarded as a precondition for a successful application of other features of the EMS) • planning and establishing the necessary procedures • implementation of the procedures, paying particular attention to structure and responsibility; training, awareness and competence; communication employee involvement; documentation; efficient process control ; maintenance programmes emergency preparedness and response; safeguarding compliance with environmental legislation. • checking performance and taking corrective action, paying particular attention to monitoring and measurement (see also the “Reference Document on the General Principles of Monitoring”) corrective and preventive action maintenance of records independent (where practicable) internal auditing to determine whether or not the environmental management system conforms to planned arrangements and has been properly implemented and maintained. • review by top management.

statement whereby all Group businesses are required to meet the same standard of proactice for the effective management of environmental performance. Dairygold Agri Business as a Dairygold Co-Operative Society Ltd Group Business adheres to this policy statement. At site level, the systems in place to manage and maintain environmental policy goals and to manage and control environmental risks include documented Process controls and procedures; Accident Prevention and Emergency Response Plans and procedures; on-going Environmental, Health and Safety Awareness and training for all employees.

5.1.2 Collaboration with upstream and downstream activities BAT 24. BAT is to seek collaboration with upstream and downstream partners, to create a chain of environmental responsibility, to minimise pollution and to protect the environment as a whole, (see, e.g. Sections 4.1.7.2, 4.1.7.3, 4.1.7.12, 4.1.9.1, 4.2.1.1, 4.2.4.1 and 4.7.2.3).

Material inputs delivered in bulk. All wastes generated by facility taken off site by licensed contractor to approved facility

In place

5.1.3 Equipment and installation cleaning BAT 25. BAT is to do the following: 1 remove raw material residues as soon as possible after processing and clean materials storage areas frequently (see Section 4.3.10) 2 provide and use catchpots over floor drains and ensure they are inspected and cleaned frequently, to prevent entrainment of materials into waste water (see Section 4.3.1.1) 3 optimise the use of dry cleaning (including vacuum systems) of equipment and

Housekeeping programme in place. Central vacuum system used within Feed mill to remove dust. Limited application of wet cleaning systems used. All cleaning chemicals used are industry norm

In place

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installations, including after spillages (see Sections 4.3.1, 4.7.1.2, 4.7.2.2, 4.7.5.2 and 4.7.9.2) prior to wet cleaning, where wet cleaning is necessary to achieve the required hygiene levels 4 pre-soak floors and open equipment to loosen hardened or burnt-on dirt before wet cleaning (see Section 4.3.2) 5 manage and minimise the use of water, energy and detergents used (see Section 4.3.5) 6 fit cleaning hoses used for manual cleaning with hand operated triggers (see Section 4.3.6) 7 supply pressure-controlled water and do this via nozzles (see Section 4.3.7.1) 8 optimise the application of the re-use of warm open-circuit cooling water, e.g. for cleaning (e.g. see Section 4.7.5.17) 9 select and use cleaning and disinfection agents which cause minimum harm to the environment (see Sections 4.3.8, 4.3.8.1 and 4.3.8.2) and provide effective hygiene control 10 operate a cleaning-in-place (CIP) of closed equipment (see Section 4.3.9), and ensure that it is used in an optimal way by, e.g. measuring turbidity (see Section 4.1.8.5.3), conductivity (see Section 4.1.8.5.2) or pH (see Section 4.1.8.5.1) and automatically dosing chemicals at the correct concentrations (see Section 4.3.9) 11 use single-use systems for small or rarely used plants or where the cleaning solution becomes highly polluted, such as UHT plants, membrane separation plants, and the preliminary cleaning of evaporators and spray driers (see Section 4.3.9) 12 where there are suitable variations in the pHs of the waste water streams from CIP and other sources, apply self-neutralisation of alkaline and acidic waste water streams in a neutralisation tank (see Section 4.5.2.4) 13 minimise the use of EDTA, by only using it where it is required, with the frequency required and by minimising the quantity used, e.g. by recycling cleaning solutions (see Sections 4.3.8, 4.3.8.2, 4.3.8.2.2, 4.3.8.2.3 and 4.3.8.2.5). When selecting chemicals for disinfecting and sterilising equipment and installations, BAT is to: 14 avoid the use of halogenated oxidising biocides, except where the alternatives are not

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effective (see Sections 4.3.8.1, 4.5.4.8, 4.5.4.8.1 and 4.5.4.8.2).

5.1.4 Additional BAT for some processes and unit operations applied in a number of FDM sectors 5.1.4.1 Materials reception/despatch

BAT 26. During the reception and despatch of materials, BAT is to do the following: when vehicles are parked and during loading and unloading, switch off the vehicle engine and the refrigerator unit, if there is one and provide an alternative power supply (see Section 4.2.1.1).

Where practical, vehicle engines switched off

In place

5.1.4.2 Centrifugation/separation n/a n/a BAT 27. In all FDM installations carrying out centrifugation, BAT is to do the following: operate centrifuges to minimise the discharge of product in the waste stream (see Section 4.2.3.1).

Activity not undertaken at the installation

n/a

5.1.4.3 Smoking n/a n/a

BAT 28. In all FDM installations carrying out smoking, BAT is to do the following: achieve a TOC air emission level of <50 mg/Nm3 (see, e.g. Sections 3.3.1.2.2 and 4.4.3.11.1).


n/a

5.1.4.4 Frying n/a n/a

BAT 29. In all FDM installations carrying out frying, BAT is to do the following: recirculate and burn exhaust gases (see Section 4.2.7.1)..


n/a

5.1.4.5 Preservation in cans, bottles and jars n/a n/a BAT 30. In all FDM installations carrying out preservation in cans bottles and jars, BAT is to do the following: 1 apply automated can, bottle and jar seasoning filling systems incorporating closed circuit


n/a

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recycling of spilled liquids (see Section 4.2.8.2) 2 use can, bottle and jar cleaning tanks with floating oil recovery when preserving oil, foods canned in vegetable oils or oily foods (see Section 4.2.8.3).

5.1.4.6 Evaporation n/a n/a

BAT 31. In all FDM installations carrying out evaporation, BAT is to do the following: use multi-effect evaporators (see Section 4.2.9.1) optimising vapour recompression (see Section 4.2.9.2) related to heat and power availability in the installation, to concentrate liquids.


n/a

5.1.4.7 Freezing and refrigeration n/a n/a BAT 32. In all FDM installations carrying out freezing and refrigeration, BAT is to do the following: 1 prevent emissions of substances that deplete the ozone layer by, e.g. not using halogenated substances as refrigerants (see Section 4.1.9.3) 2 avoid keeping air conditioned and refrigerated areas colder than necessary (see Section 4.2.15.1) 3 optimise the condensation pressure (see Section 4.2.11.2) 4 regularly defrost the entire system (see Section 4.2.15.3) 5 keep the condensers clean (see Section 4.2.11.3) 6 make sure that the air entering the condensers is as cold as possible (see Section 4.2.11.3) 7 optimise the condensation temperature (see Section 4.2.11.3) 8 use automatic defrosting of cooling evaporators (see Section 4.2.15.5) 9 operate without automatic defrosting during short production stops (see Section 4.2.11.7) 10 minimise transmission and ventilation losses from cooled rooms and cold stores (see Section 4.2.15.2).


n/a

5.1.4.8 Cooling n/a n/a BAT 33.

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In all FDM installations carrying out cooling, BAT is to do the following: 1 optimise the operation of cooling water systems to avoid excessive blowdown of the cooling tower (see Section 4.1.5) 2 install a plate heat-exchanger for precooling ice-water with ammonia, prior to final cooling in an accumulating ice-water tank with a coil evaporator (see Section 4.2.10.1) 3 recover heat from cooling equipment. Water temperatures of 50 – 60 °C can be achieved (see Section 4.2.13.5).

Activity not undertaken at the installation n/a

5.1.4.9 Packing BAT 34. In all FDM installations carrying out packing, BAT is to do the following: 1 optimise the design of packaging, including the weight and volume of material and the recycled content, to reduce the quantity used and to minimise waste (see Section 4.2.12.2) 2 purchase materials in bulk (see Section 4.1.7.2) 3 collect packaging material separately (see Section 4.2.12.3) 4 minimise overflowing during packing (see Section 4.2.12.6).

Currently undertaken by the installation In place

5.1.4.10 Energy generation and use BAT 35. BAT is to do the following: 1 for installations where there is a use for the heat and power produced, e.g. in sugar manufacturing, milk powder production, whey drying, instant coffee production, brewing and distilling, use combined heat and power generation in new or substantially altered installations or those renewing their energy systems (see Section 4.2.13.1) 2 use heat pumps for heat recovery from various sources (see Section 4.2.13.4) 3 switch equipment off when it is not needed (see Section 4.2.13.6) 4 minimise the loads on motors (see Section 4.2.13.7) 5 minimise motor losses (see Section 4.2.13.8) 6 use variable speed drives to reduce the load on fans and pumps (see Section 4.2.13.10) 7 apply thermal insulation, e.g. of pipes, vessels and equipment used to carry, store or treat

1. Not applicable to the installation.

Limited opportunity for CHP 2. Feasible energy recovery systems

have been identified inlcuiding heat recovery units on compressors (currently installed but not commissioned) and condensate recovery system for boiler feed make up water

3. Equipment switched off when not in use

In Place

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substances above or below ambient temperature and to equipment used for processes involving heating and cooling (see Section 4.2.13.3) 8 apply frequency controllers on motors (see Section 4.2.13.9).

4. VSD motors are used where appropriate

5.1.4.11 Water use

BAT 36. If groundwater is used, BAT is to do the following: only pump up the quantities of water that are actually required (see Section 4.2.14.1).

Limited groundwater requirement. Water only pumped as required

In Place

5.1.4.12 Compressed air systems BAT 37. For compressed air generation, BAT is to do the following: 1 review the pressure level and reduce it if possible (see Section 4.2.16.1) 2 optimise the air inlet temperature (see Section 4.2.16.2) 3 fit silencers at air inlets and exhausts, to reduce noise levels (see Section 4.2.16.3).

The compressors are fully automated and use line pressure control systems to monitor demand Externally ducted air used Need for Silencers to be investigated

In place In Place To be installed if required

5.1.4.13 Steam systems n/a n/a

BAT 38. For steam systems, BAT is to do the following: 1 maximise condensate return (see Section 4.2.17.1) 2 avoid losses of flash steam from condensate return (see Section 4.2.17.2) 3 isolate unused pipework (see Section 4.2.17.3) 4 improve steam trapping (see Section 4.1.5) 5 repair steam leaks (see Section 4.1.5) 6 minimise boiler blowdown (see Section 4.2.17.4).


n/a

5.1.5 Minimisation of air emissions BAT 39. To prevent air emissions from FDM installations, BAT is to do the following: 1 apply and maintain an air emissions control strategy (see Section 4.4.1) incorporating: 1.1 definition of the problem (see Sections 4.4.1.1 and 4.4.1.1.1) 1.2 an inventory of site emissions, including, e.g. abnormal operation (see

Refer to relevant EPA BAT Guidance Note for BAT Associated Emission Levels Emission abatement technologies installed on all major dust emission

Annual measurement of emissions from major emission sources to be undertaken within 6

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Sections 4.4.1.2 and 4.4.1.2.1) 1.3 measuring the major emissions (see Sections 4.4.1.3 and 4.4.1.3.1) 1.4 assessing and selecting the air emission control techniques (see Section 4.4.1.4) 2 collect waste gases, odours and dusts at source (see Section 4.4.3.2) and duct them to the treatment or abatement equipment (see Section 4.4.3.3) 3 optimise the start-up and shut-down procedures for the air emission abatement equipment to ensure that it is always operating effectively at all of the times when abatement is required (see Sections 4.4.3.1) 4 unless specified otherwise, where process-integrated BAT which minimise air emissions by the selection and use of substances and the application of techniques do not achieve emission levels of 5 – 20 mg/Nm3 for dry dust, 35 – 60 mg/Nm3 for wet/sticky dust and <50 mg/Nm3 TOC, to achieve these levels by applying abatement techniques. This document does not specifically consider emissions from combustion power plants in FDM installations and these levels are, therefore, not intended to represent BAT associated emission levels from those combustion plants. Some air abatement techniques are described in Sections 4.4 to 4.4.3.12 5 where process-integrated BAT do not eliminate odour nuisance, apply abatement techniques. Many of the techniques described in Section 4.4 are applicable to odour abatement.

sources. Measurement of emissions to air currently not undertaken.

months of grant of licence.

5.1.6 Waste water treatment BAT 40. For the treatment of waste water from FDM installations, BAT is to use a suitable combination of the following: 1 apply an initial screening of solids (see Section 4.5.2.1) at the FDM installation 2 remove fat using a fat trap (see Section 4.5.2.2) at the FDM installation, if the waste water contains animal or vegetable FOG 3 apply flow and load equalisation (see Section 4.5.2.3) 4 apply neutralisation (see Section 4.5.2.4) to strongly acid or alkaline waste water 5 apply sedimentation (see Section 4.5.2.5) to waste water containing SS 6 apply dissolved air flotation (see Section 4.5.2.6)

Refer to relevant EPA BAT Guidance Note for BAT Associated Emission Levels Not applicable to the installation. Manufacturing process does not produce a wastewater stream. Wastewater from the installation limited to canteen, laboratory and toilet facilities. Wastewater treated in domestic type WWTP capable of achieving existing

In place – new tertiary treatment to be added to existing WWTP

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7 apply biological treatment. Aerobic and anaerobic techniques applied in the FDM sector are described in Sections 4.5.3.1 to 4.5.3.3.2 8 use CH4 gas produced during anaerobic treatment for the production of heat and/or power (see Section 4.5.3.2). Unless otherwise stated in this chapter, the emission levels given in Table 5.1 are indicative of the emission levels that would be achieved with those techniques generally considered to represent BAT (see Section 4.5.1.1). They do not necessarily represent levels currently achieved within the industry but are based on the expert judgement of the TWG.

When further treatment is required to either achieve these levels or to meet special

discharge limits, the following techniques are available:

9 remove nitrogen biologically (see Sections 4.5.4.1 and 4.5.4.7)

10 apply precipitation to remove phosphorus (see Section 4.5.2.9), simultaneously with the

activated sludge treatment, where applied (see Section 4.5.3.1.1)

11 use filtration for waste water polishing (see Section 4.5.4.5)

12 remove dangerous and priority hazardous substances (see Section 4.5.4.4)

13 apply membrane filtration (see Section 4.5.4.6).

discharge licence emission limits.

- BAT 41. Not applicable to the installation. No n/a

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When the quality of the waste water is suitable for re-use in FDM processing, BAT is to do the following: 14 re-use water after it has been sterilised and disinfected, avoiding the use of active chlorine (see Sections 4.5.4.8, 4.5.4.8.1 and 4.5.4.8.2) and which meets the standard of Council Directive 98/83/EC [66, EC, 1998].

process water requirement and no wastewater generated from processing activity.

BAT 42. BAT is to treat waste water sludge using one or a combination of the following techniques: 15 stabilisation (see Section 4.5.6.1.2) 16 thickening (see Section 4.5.6.1.3) 17 dewatering (see Section 4.5.6.1.4) 18 drying (see Section 4.5.6.1.5), if natural heat or heat recovered from processes in the installation can be used.

N/A - Waste water sludge disposed of by licenced contractor

n/a

5.1.7 Accidental releases BAT 43. In general, to prevent accidents and minimise their harm to the environment as a whole, BAT is to do the following: 1 identify potential sources of incidents/accidental releases that could harm the environment (see Section 4.6.1) 2 assess the probability of the identified potential incidents/accidental releases occurring and their severity if they do occur, i.e. to carry out a risk assessment (see Section 4.6.2) 3 identify those potential incidents/accidental releases for which additional controls are required to prevent them from occurring (see Section 4.6.3) 4 identify and implement the control measures needed to prevent accidents and minimise their harm to the environment (see Section 4.6.4) 5 develop, implement and regularly test an emergency plan (see Section 4.6.5) 6 investigate all accidents and near misses and keep records (see Section 4.6.6).

All risks areas on site identified and accident prevention and emergency response procedures in place.

In place

5.2 Additional BAT for some individual FDM sectors 5.2.1 Additional BAT for the meat and poultry sector

n/a n/a

BAT 44.

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In addition to the BAT in Section 5.1 - 5.1.7, for meat and poultry processing installations, BAT is to do the following: 1 thaw meat in air (see Section 4.2.2.5) 2 avoid the use of flake ice by using a suitable mixture of chilled and frozen raw materials (see Section 4.7.1.3) 3 dose spices and other solid ingredients from a bulk container rather than from plastic bags (see Section 4.1.7.2) 4 stop the water supply automatically when sausage fillers and similar equipment are not used at breaks or at production stops (see Section 4.1.8.4).

Activity not undertaken at the installation n/a

5.2.2 Additional BAT for the fish and shellfish sector n/a n/a BAT 45. In addition to the BAT in Section 5.1 - 5.1.7, for fish and shellfish processing installations, BAT is to do the following: 1 maintain the quality of fish for optimal use by minimising storage times (see Section 4.1.7.3) 2 use high quality fish by ensuring collaboration with upstream suppliers (see Section 4.7.2.3) 3 operate regular maintenance programmes (see Section 4.1.5) to, e.g. ensure efficient skinning (see Section 4.7.2.3) 4 thaw mackerel, by immersing them in containers filled with water which is mixed by bubbling air through it. The level of the water is maintained by recirculation and using level-actuated switches (see Section 4.2.2.1), achieving a water consumption of <2 m3/t of raw fish 5 thaw whitefish, by immersing them in containers filled with water which is mixed by bubbling air through it. The level of the water is maintained by using level-actuated switches (see Section 4.2.2.2), achieving a water consumption of 1.8 – 2.2 m3/t of raw fish 6 thaw shrimps and prawns by immersing them in containers filled with filtered peeling water, if available. The water is mixed by bubbling air through it. The level of the water is maintained by recirculation and using level-actuated switches (see Section 4.2.2.1), or by using level-actuated switches (see Section 4.2.2.2)


n/a

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7 avoid scaling if the fish is subsequently skinned (see Section 4.7.2.7) 8 where scaling is undertaken, i.e. where fish is not subsequently skinned, use filtered recirculated scaling waste water for preliminary fish rinsing and properly adjust the scaler operation by weighing the right amount of scales for a specific water flow (see Section 4.7.2.8) 9 remove and transport skin and fat from the skinning drum using vacuum suction (see Section 4.7.2.4) 10 remove and transport fat and viscera from mackerel by vacuum suction (see Section 4.7.2.5) 11 use fine mesh conveyor belts to transport solid products, by-products and wastes, to enable their separation from water (see Section 4.7.2.6) 12 when filleting: 12.1 remove the frames from fish fillets by two sets of rotating knives (see Section 4.1.8.8) 12.2 where water nozzles or spray cleaning systems are required, install them with presence-activated sensors (i.e. intermittent operation) (see Section 4.1.8.8). 12.3 a 60 - 75 % reduction in water consumption can be obtained by: 12.3.1 removing unnecessary nozzles so that water is only added where required (see Section 4.1.8.8) 12.3.2 replacing those nozzles that take the fish from the tail cut with a mechanical device (see Section 4.1.8.8) 12.3.3 replacing the nozzles for cleaning the driving wheels on the filleting part with mechanical devices (see Section 4.1.8.8) 12.3.4 replacing existing nozzles by nozzles with a lower water consumption (see Section 4.1.8.8) 12.3.5 using pulsating water nozzles, i.e. alternating the opening and closing of the water supply using an automatic valve (see Section 4.1.8.8) 12.3.6 replacing the waste drain by drain-belts and closing the nozzles in the waste drain. The waste will be separated from the process water directly near the filleting machine, resulting in shorter contact time (see Section 4.7.2.6)

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12.4 reduce both the number and size of spray nozzles (water saving of about 75 %) (see Section 4.1.8.8).

5.2.3 Additional BAT for the fruit and vegetables sector n/a n/a

BAT 46. In addition to the BAT in Section 5.1 - 5.1.7, for fruit and vegetable processing installations, BAT is to do the following: 1 where storage cannot be avoided, minimise storage times (see Section 4.1.7.3), and where weather conditions do not increase the speed of degradation and/or harm the quality, avoid refrigeration by storing fruit and vegetables and their by-products which are intended for use as animal feed, outdoors in a clean covered area or in containers (see Section 4.7.3.3) 2 apply dry separation of rejected raw material from the sorting step and solid residues (e.g. in sorting, trimming, extraction, filtration steps) (see Section 4.1.7.6) 3 collect soil in sedimentation and/or filtration steps instead of washing into the WWTP (see Sections 4.1.7.6, 4.5.2.5 and 4.5.4.5) 4 peel fruit and vegetables using a batch steam process (see Section 4.7.3.4.2) or a continuous steam process (see Section 4.7.3.4.1) not using cold water to condense the steam and, if for technological reasons steam peeling cannot be applied, use dry caustic peeling (see Section 4.7.3.4.6), unless the recipe requirements cannot be met if either of these techniques is used 5 after blanching, cool fruit and vegetables before freezing them by passing them through cold water (see Section 4.7.3.6) 6 optimise the re-use of water with or without treatment, depending on the unit operations which require water and the quality of water these require, ensuring that adequate hygiene and food quality standards are maintained (see Section 4.7.3.7).


n/a

5.2.4 Additional BAT for the vegetable oils and fats sector n/a n/a

BAT 47. In addition to the BAT in Section 5.1 - 5.1.7, for vegetable oil processing installations, BAT is to do the following: 1 use a countercurrent flow desolventiser-toaster in vegetable oil extraction (see


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Section 4.7.4.2) 2 in vegetable oil processing, use the vapour generated in the desolventiser-toaster in the first step of the miscella distillation pre-evaporator (see Section 4.7.4.3) 3 use the exothermic reaction heat from the hydrogenation of vegetable oil to heat the product to the desired reaction temperature and to generate steam later in the reaction (see Section 4.7.4.4). The achievable energy (steam) generation is 25 – 125 kWh/t (90 - 450 MJ/t) (40 – 200 kg/t) unrefined oil 4 use water ring pumps to generate an auxiliary vacuum for oil drying, oil degassing or minimising oxidation of oil (see Section 4.7.4.11) 5 recover hexane from condensable vapours from meal desolventising-toasting, miscella distillation and from the stripping column of the mineral oil system, using a hexanewater gravity separator and a reboiler (see Section 4.7.4.6) 6 use a mineral oil scrubber to recover hexane from uncondensable vapours from meal desolventising-toasting, miscella distillation, the reboiler and from the stripping column of the mineral oil system (see Section 4.7.4.5) 7 use cyclones, to reduce wet dust emissions arising from vegetable oil extraction, to achieve a wet dust emission level of <50 mg/Nm3 (see Section 4.7.4.10) 8 refine crude oils by physical refining (see Section 4.7.4.7.2), or if they have an ffa content <2 %, by chemical refining (see Section 4.7.4.7.1) 9 deodorise vegetable oils using a double scrubber in combination with a once-through cooling system (see Section 4.7.4.12.1).

5.2.5 Additional BAT for dairies n/a n/a BAT 48. In addition to the BAT in Sections 5.1 - 5.1.7, for dairies, BAT is to do the following: 1 partially homogenise milk (see Section 4.7.5.3) 2 replace batch pasteurisers with continuous ones (see Section 4.7.5.5) 3 use regenerative heat exchange in pasteurisation (see Section 4.7.5.6) 4 reduce the required frequency of cleaning of centrifugal separators by improving the preliminary milk filtration and clarification (see Section 4.7.5.7) 5 use just-in-time “component filling” to avoid losses and minimise water pollution (see


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Section 4.7.5.12) 6 maximise the recovery of diluted, but otherwise uncontaminated, product from CIP initial rinses, HTST start-up, shut-down and change-over and from the rinsing of other equipment and pipework by online detection of transition points between the product and the water phase (see Section 4.7.5.10). This can be done by, e.g. measuring the volume using flow (see Section 4.1.8.4) or density transmitters; measuring the density using conductivity transmitters (see Section 4.1.8.5.2) and using scattered light turbidity sensors (see Section 4.1.8.5.3) to differentiate water from the product 7 for large dairies with highly branched tubing, use several small CIP systems instead of a centralised CIP system (see Section 4.3.9) 8 re-use cooling water, used cleaning water, condensates from drying and evaporation, permeates generated in membrane separation processes and final rinse-water after the treatment, if any required, to ensure the level of hygiene necessary for the re-use application (see Section 4.7.5.16) 9 achieve the levels given in Table 5.2 (see Section 5.2.5.1), Table 5.3 (see Section 5.2.5.2) and Table 5.4 (see Section 5.2.5.5). These are indicative of the levels that can be achieved by applying in-process BAT. They are based on achieved levels reported by the TWG. The ranges reported reflect a variety of conditions under which installations operate. Energy consumption levels may vary due to, e.g. production volumes. Warm climates may use more energy for cooling and vice versa. Water consumption and waste water emission levels may vary due to, e.g. different product portfolios, batch sizes and cleaning. The waste water emission level may be lower compared to the water consumption level because many dairies measure the intake of cooling water, often from their own wells, but then discharge it unmeasured. In warm climates water may be lost due to evaporation.

5.2.5.1 Additional BAT for the production of market milk n/a n/a

BAT 50. In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.5, for the production of market milk, BAT is to do the following: 1 achieve the consumption and emission levels shown in Table 5.2 (see


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Sections 3.3.5.1.1, 3.3.5.1.2, 3.3.5.4 and 5.2.5 paragraph 9)

5.2.5.2 Additional BAT for milk powder production n/a n/a BAT 51. In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.5, for milk powder production, BAT is to do the following: 1 to produce powdered milk use multi-effect evaporators (see Section 4.2.9.1), optimising vapour recompression (see Section 4.2.9.2) related to heat and power availability in the installation, to concentrate liquid milk before spray drying, followed by FBD, e.g. integrated FDB (see Section 4.7.5.8) 2 apply an early warning fire alarm, e.g. CO detector, to reduce the risks of explosion in spray driers (see Section 4.7.5.8). 3 achieve the consumption and emission levels shown in Table 5.3 (see Sections 3.3.5.1.1, 3.3.5.1.2, 3.3.5.4 and 5.2.5 paragraph 9)


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5.2.5.3 Additional BAT for buttermaking n/a n/a

BAT 52. In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.5, for buttermaking, BAT is to do the following: 1 remove residual butter from pipework using a cooled butter block pushed by compressed air (see Section 4.3.4) 2 rinse the cream heater with skimmed milk before cleaning it (see Section 4.7.5.13.1).


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5.2.5.4 Additional BAT for cheesemaking n/a n/a

BAT 53. In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.5, for cheesemaking, BAT is to do the following: 1 use the heat from warm whey for preheating cheese milk (see Section 4.7.5.14.7) 2 maximise whey recovery and use (see Section 4.7.5.14.4) 3 segregate salt whey (not to be mixed with sweet or acid whey) (see Section 4.7.5.14.4) 4 reduce fat and cheese fines in whey and screen liquid streams to collect fines (see Section 4.7.5.14.2) 5 minimise the occurrence of acid whey and drain the top or platform of the salting vats to avoid brine spillage to the WWTP (see Section 4.7.5.14.3) 6 to produce whey powder use multi-effect evaporators (see Section 4.2.9.1), optimising vapour recompression (see Section 4.2.9.2) related to heat and power availability in the installation, to concentrate whey before spray drying, followed by FBD, e.g. integrated FDB (see Section 4.7.5.8).


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5.2.5.5 Additional BAT for ice-cream manufacturing n/a n/a BAT 54. In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.5, for ice-cream manufacturing, BAT is to do the following: 1 achieve the consumption and emission levels shown in Table 5.4 (see Sections 3.3.5.1.1, 3.3.5.1.2, 3.3.5.4 and 5.2.5 paragraph 9)


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5.2.6 Additional BAT for starch manufacturing n/a n/a BAT 55. In addition to the BAT in Sections 5.1 - 5.1.7, for the starch sector, BAT is to do the following: 1 optimise the re-use of process water and/or potato fruit juice in the potato starch making process (see Sections 3.3.7.1, 4.1.6, 4.1.7.6 and 4.7.6.1) 2 use gluten process water (in the protein separation step) for germ and fibre washing and steeping processes in maize starch processing (see Section 4.1.7.8) 3 wash starch slurry, using a countercurrent flow, before it is dewatered and dried (see Section 4.7.6.1).


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5.2.7 Additional BAT for the sugar sector n/a n/a BAT 56. In addition to the BAT in Sections 5.1 - 5.1.7, for the sugar beet sector, BAT is to do the following: 1 recycle transport water (see Section 4.7.7.3) 2 use evaporator condensate for sugar extraction from sugar beets (see Section 4.1.7.8) 3 avoid drying sugar beet pulp if an outlet is available for pressed sugar beet pulp, e.g. animal feed; otherwise dry sugar beet pulp using steam driers (see Section 4.7.7.1.4) or using high temperature driers (see Section 4.7.7.1.2), combined with measures to reduce emissions to air. In HTD possible measures to reduce emissions to air include, e.g. minimising the


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quantity of small beet particles dried, drying to a maximum dry matter content of 91 %, mechanical pressing of pulp prior to drying, minimising the quantity of added mollases before drying and optimising the operation of cyclones (see Section 4.4.3.5.2) and spray scrubbers (see Section 4.4.3.5.3).

5.2.8 Additional BAT for the coffee sector n/a n/a

BAT 57. In addition to the BAT in Sections 5.1 - 5.1.7, for the coffee sector, BAT is to do the following: 1 when roasting coffee, recirculate air from the roaster back into the roaster (see Section 4.7.8.4.1) 2 when roasting coffee, where process-integrated BAT which minimise air emissions by the selection and use of substances and the application of techniques do not achieve emission levels of 5 – 20 mg/Nm3 for dry dust; <50 mg/Nm3 TOC for light roasted coffee (this level is more difficult to achieve as the darkness of roasting is increased, see Section 3.2.39.2); to achieve these levels by applying abatement techniques. Some air abatement techniques are described in Sections 4.4 to 4.4.3.12. Emission levels for NOx were provided too late for full verification by the TWG, these are reported in Section 7.5 of the Concluding remarks chapter 3 in instant coffee manufacturing, use the waste heat from the hot liquid coffee extract to heat the process water prior to extraction and use countercurrent heat-exchange to use the heat from spray drying within the roasting sector (see Section 4.7.8.1) 4 during instant coffee manufacturing, after drying, agglomerate the dust to make granules then recycle the remaining dust and apply air abatement (see Section 4.7.8.2).


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5.2.9 Additional BAT for drinks manufacturing n/a n/a

BAT 58. In addition to the BAT in Sections 5.1 - 5.1.7, for drinks processing installations, BAT is to do the following: 1 if CO2 is used in the installation, use CO2 which is either recovered from the fermentation process or as a by-product of another process, to avoid the production of CO2 directly derived from fossil fuels especially for use in the installation (see Section 4.2.4.1)


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2 recover yeast after fermentation (see Section 4.7.9.3) 3 where diatomaceous earth is used as a filter, collect the spent filter material to optimise re-use and/or disposal (see Section 4.7.9.4.3) 4 use multistage bottle cleaning systems (see Section 4.7.9.5.2) 5 optimise water consumption of the rinsing zone in the bottle cleaning machine, by controlling the rinsing water flow, installing an automatic valve to interrupt the water supply in case the line stops and using fresh water for the two last rows of rinsing nozzles (see Section 4.7.9.5.4) 6 re-use bottle cleaning overflows after sedimentation and filtration (see Section 4.7.9.5.3).

5.2.9.1 Additional BAT for brewing n/a n/a BAT 59. In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.9, for breweries, BAT is to do the following: 1 optimise the re-use of hot water from wort cooling (see Section 4.7.9.6.4) and recover heat from wort boiling (see Section 4.7.9.6.5) 2 re-use bottle pasteurising overflow water (see Section 4.7.9.5.5) 3 achieve a water consumption level of 0.35 – 1 m3/hl of beer produced (see Section 3.3.11.1).


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5.2.9.2 Additional BAT for winemaking n/a n/a BAT 60. In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.9, for winemaking, BAT is to do the following: 1 after the cold stabilisation of wine, re-use the alkaline cleaning solution (see Section 4.7.9.8.1) and when the spent alkaline solution can no longer be re-used and the pH is still high enough to disrupt the operation of theWWTP, apply self-neutralisation (see Section 4.5.2.4) or if the pH levels and the flowrate will not disrupt the operation of the WWTP, gradually release the cleaning solution to the WWTP (see Section 4.7.9.8.2).


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Attachment No. I.8


Techniques for Energy Efficiency

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Conclusions on BAT from Reference Document on Best Available Techniques for Energy Efficiency (February 2009)

Conclusions on BAT Applicability Assessment (describe how the technique applies or

not to your installation)

State whether it is in place or state schedule for

implementation BAT FOR ACHIEVING ENERGY EFFICIENCY AT AN INSTALLATION LEVEL

ENERGY EFFICIENCY MANAGEMENT

1. BAT is to implement and adhere to an energy efficiency management system (ENEMS) that incorporates, as appropriate to the local circumstances, all of the following features a) commitment of top management (commitment of the top management is regarded as a

precondition for the successful application of energy efficiency management) b) definition of an energy efficiency policy for the installation by top management c) planning and establishing objectives and targets (see BAT 2, 3 and 8) d) implementation and operation of procedures paying particular attention to:

i. structure and responsibility ii. training, awareness and competence (see BAT 13)

iii. communication iv. employee involvement v. documentation

vi. effective control of processes (see BAT 14) vii. maintenance (see BAT 15)

viii. emergency preparedness and response ix. safeguarding compliance with energy efficiency-related legislation and agreements (where such

agreements exist). e) benchmarking: the identification and assessment of energy efficiency indicators over time (see BAT

8), and the systematic and regular comparisons with sector, national or regional benchmarks for energy efficiency, where verified data are available (see Sections 2.1(e), 2.16 and BAT 9)

f) checking performance and taking corrective action paying particular attention to: i) monitoring and measurement (see BAT 16) ii) corrective and preventive action iii) maintenance of records iv) independent (where practicable) internal auditing in order to determine whether or not the

energy efficiency management system conforms to planned arrangements and has been properly implemented and maintained (see BAT 4 and 5)

g) review of the ENEMS and its continuing suitability, adequacy and effectiveness by top management h) when designing a new unit, taking into account the environmental impact from the eventual decommissioning of the unit i) development of energy efficient technologies, and to follow developments in energy efficiency

techniques.

Senior Management commitment to energy conservation and efficiency is guaranteed. The business is energy conscious and improvement in energy efficiency is included in the companys overall strategic plan. The installation currently does not have a documented energy efficiency management system however Senior Management at the Dairygold Agri Business Ltd installation at Lombardstown is committed to improving its Energy management strategy and is currently developing an integrated management system to manage, control and continually improve organisational performance. The system will encompass Environmental and Energy Management and will be developed in line with BAT requirements for Energy Efficiency Management. The systems will

produce an energy policy statement

Fix targets and objectives to meet the policy

Use data to better understand and make decisions about energy use

Measure the results

Review how well the policy works, and Continually improve energy management.

This will be implemented on an ongoing basis over the next 2-5 years

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implementation PLANNING AND ESTABLISHING OBJECTIVES AND TARGETS

Continuous environmental improvement

2. BAT is to continuously minimise the environmental impact of an installation by planning actions and investments on an integrated basis and for the short, medium and long term, considering the cost-benefits and cross-media effects.

The business routinely evaluates the site plant and operations for ways to conserve resources and improve energy efficiency, water conservation and waste reduction to achieve a high general level of protection of the environment taken as a whole. The planned new development proposals include measures to improve emissions from the site (eg a tertiary filter to the WWTP and new petrol interceptor on stormwater drainage network .

Yes - In place

Identification of energy efficiency aspects of an installation and opportunities for energy savings

3. BAT is to identify the aspects of an installation that influence energy efficiency by carrying out an audit. It is important that an audit is coherent with a systems approach (see BAT 7).

An Energy review of the existing facility has been carried out and a number of energy improvement projects have been identified. These are to be carried out on a planned basis. Energy Efficient Design (EED) methodology will be applied in designing new development proposals.

A comprehensive energy audit will be undertaken in developing and implementing the Energy management system being developed.

4. When carrying out an audit, BAT is to ensure that the audit identifies the following aspects a. energy use and type in the installation and its component systems and processes b. energy-using equipment, and the type and quantity of energy used in the installation c. possibilities to minimise energy use, such as:

controlling/reducing operating times, e.g. switching off when not in use

ensuring insulation is optimised,

optimising utilities, associated systems, processes and equipment (see Chapter 3) d. possibilities to use alternative sources or use of energy that is more efficient, in particular energy surplus from other processes and/or systems, e. possibilities to apply energy surplus to other processes and/or systems, f. possibilities to upgrade heat quality

These aspects were considered as part of the energy review undertaken at the installation.

A comprehensive energy audit will be undertaken in developing and implementing the Energy management system being developed

5. BAT is to use appropriate tools or methodologies to assist with identifying and quantifying energy optimisation, such as:

energy models, databases and balances (see Section 2.15)

a technique such as pinch methodology (see Section 2.12) energy or enthalpy analysis (see Section

The plant is completely automated and site processes are constantly monitored on a central electronic control system to continuously assess the performance of the

In place

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implementation 2.13), or thermoeconomics (see Section 2.14)

estimates and calculations (see Sections 1.5 and 2.10.2).

plant. The system includes energy metering of equipment and systems.

6. BAT is to identify opportunities to optimise energy recovery within the installation, between systems within the installation (see BAT 7) and/or with a third party (or parties), such as those described in Sections 3.2, 3.3 and 3.4.

Limited opportunities exist at the installation for Energy recovery systems. Feasible energy recovery systems have been identified including heat recovery units on compressors (currently installed but not commissioned) and condensate recovery system for boiler feed make up water.

In place

A systems approach to energy management

7. BAT is to optimise energy efficiency by taking a systems approach to energy management in the installation. Systems to be considered for optimising as a whole are, for example:

process units (see sector BREFs)

heating systems such as:

steam (see Section 3.2)

hot water

cooling and vacuum (see the ICS BREF)

motor driven systems such as:

compressed air (see Section 3.7)

pumping (see Section 3.8)

lighting (see Section 3.10)

drying, separation and concentration (see Section 3.11).

The following measures are in place at the installation to optimise energy efficiency:

Chemical treatment of the boiler water systems to prevent scaling and damage to pipework and thus ensuring efficiency of the system

boiler blowdown minimised by water treatment

steam system piping, valves, fittings and vessels are well insulated

The compressors are fully automated and use line pressure control systems to monitor demand

Variable speed drive motors are used where appropriate

Lighting is controlled through process control central system and automatically turns off when area is not in use.

Preheating boiler feed-water by using Collect and return condensate. This subsequently avoids using more energy than is needed as it minimises the need for pumping of clean water and reduces the overall volume of wastewater requiring treatment.

Where feasible, LED lighting used throughout the installation.

In place

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implementation Establishing and reviewing energy efficiency objectives and indicators

8. BAT is to establish energy efficiency indicators by carrying out all of the following: a. identifying suitable energy efficiency indicators for the installation, and where necessary, individual processes, systems and/or units, and measure their change over time or after the implementation of energy efficiency measures (see Sections 1.3 and 1.3.4) b. identifying and recording appropriate boundaries associated with the indicators (see Sections 1.3.5 and 1.5.1) c. identifying and recording factors that can cause variation in the energy efficiency of the relevant process, systems and/or units (see Sections 1.3.6 and 1.5.2).

These requirements will be met as part of implementing and conformance with the Energy Management System

This will be implemented on an ongoing basis over the next 2-5 years

Benchmarking

9. BAT is to carry out systematic and regular comparisons with sector, national or regional benchmarks, where validated data are available.

Requirement met through consultation with suppliers, maintenance contractors and Industry reps

In place

ENERGY EFFICIENT DESIGN (EED)

10. BAT is to optimise energy efficiency when planning a new installation, unit or system or a significant upgrade (see Section 2.3) by considering all of the following: a. the energy efficient design (EED) should be initiated at the early stages of the conceptual design/basic design phase, even though the planned investments may not be well-defined. The EED should also be taken into account in the tendering process b. the development and/or selection of energy efficient technologies (see Sections 2.1(k) and 2.3.1) c. additional data collection may need to be carried out as part of the design project or separately to supplement existing data or fill gaps in knowledge d. the EED work should be carried out by an energy expert e. the initial mapping of energy consumption should also address which parties in the project organisations influence the future energy consumption, and should optimise the energy efficiency design of the future plant with them. For example, the staff in the (existing) installation who may be responsible for specifying design parameters.

Energy Efficient Design (EED) methodology is being applied in designing the new development proposals. All equipment and systems will be selected through specifications and technical analysis.

Yes –the new systems will be designed and constructed as stated.

INCREASED PROCESS INTEGRATION

11. BAT is to seek to optimise the use of energy between more than one process or system (see Section 2.4), within the installation or with a third party.

There is limited opportunity for this at the installation.

Yes in place where currently feasible

MAINTAINING THE IMPETUS OF ENERGY EFFICIENCY INITIATIVES

12. BAT is to maintain the impetus of the energy efficiency programme by using a variety of techniques, such as: a. implementing a specific energy efficiency management system (see Section 2.1 and BAT 1) b. accounting for energy usage based on real (metered) values, which places both the obligation and credit for energy efficiency on the user/bill payer (see Sections 2.5, 2.10.3 and 2.15.2) c. the creation of financial profit centres for energy efficiency (see Section 2.5) d. benchmarking (see Section 2.16 and BAT 9)

Will be in place

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implementation e. a fresh look at existing management systems, such as using operational excellence (see Section 2.5) f. using change management techniques (also a feature of operational excellence, see Section 2.5).

MAINTAINING EXPERTISE

13. BAT is to maintain expertise in energy efficiency and energy-using systems by using techniques such as: a. recruitment of skilled staff and/or training of staff. Training can be delivered by in-house staff, by external experts, by formal courses or by self-study/development (see Section 2.6) b. taking staff off-line periodically to perform fixed term/specific investigations (in their original installation or in others, see Section 2.5) c. sharing in-house resources between sites (see Section 2.5) d. use of appropriately skilled consultants for fixed term investigations (e.g. see Section 2.11) e. outsourcing specialist systems and/or functions (e.g. see Annex 7.12)

All Engineering personnel have to meet a minimum level of experience, qualifications and standards before they can be considered for a position within the Dairygold Engineering Team

Resources and expertise are shared across all Dairygold businesses.

There are qualified and experience personnel supporting various operating requirements such as maintenance, calibrations, mechanical and civil inspection, auditing, risk management and emergency response.

The services of suitability qualified external professional are employed as required, eg systems auditing, equipment calibration, boiler maintenance.

All staff required to complete training relevant to their area of work and duties as prescribed

Currently in place

EFFECTIVE CONTROL OF PROCESSES

14. BAT is to ensure that the effective control of processes is implemented by techniques such as: a. having systems in place to ensure that procedures are known, understood and complied with (see Sections 2.1(d)(vi) and 2.5) b. ensuring that the key performance parameters are identified, optimised for energy efficiency and monitored (see Sections 2.8 and 2.10) c. documenting or recording these parameters (see Sections 2.1(d)(vi), 2.5, 2.10 and 2.15).

SOPs are developed for all process

Operators are provided with training

The site processes are constantly monitored on a central electronic control system to continuously assess the performance of the plant and identify any adjustments necessary

Currently in place.

MAINTENANCE

15. BAT is to carry out maintenance at installations to optimise energy efficiency by applying all of the following: a. clearly allocating responsibility for the planning and execution of maintenance b. establishing a structured programme for maintenance based on technical descriptions of the equipment, norms, etc. as well as any equipment failures and consequences. Some maintenance activities may be best scheduled for plant shutdown periods c. supporting the maintenance programme by appropriate record keeping systems and diagnostic

There are qualified and experience personnel supporting various requirements such as maintenance, calibrations, mechanical and civil inspection, The installation is actively involved in a voluntary AMIS programme of Asset

Currently in place

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implementation testing d. identifying from routine maintenance, breakdowns and/or abnormalities possible losses in energy efficiency, or where energy efficiency could be improved e. identifying leaks, broken equipment, worn bearings, etc. that affect or control energy usage, and rectifying them at the earliest opportunity.

Management A schedule maintenance plan is in place and routine maintenance is undertaken. The site processes are constantly monitored on a central electronic control system to continuously assess the performance of the plant and identify any adjustments necessary. Leak detection system, energy metering and alarms are all included

MONITORING AND MEASUREMENT

16. BAT is to establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of operations and activities that can have a significant impact on energy efficiency. Some suitable techniques are given in Section 2.10.

The site processes are constantly monitored on a central electronic control system to continuously assess the performance of the plant and identify any adjustments necessary. Leak detection system, energy metering and alarms are all included Documented procedures to be developed.

Will be developed and implemented as part of the energy management system

BEST AVAILABLE TECHNIQUES FOR ACHIEVING ENERGY EFFICIENCY IN ENERGY-USING SYSTEMS, PROCESSES, ACTIVITIES OR EQUIPMENT

Combustion

17. BAT is to optimise the energy efficiency of combustion by relevant techniques such as:

those specific to sectors given in vertical BREFs

those given in Table 4.1.

Energy Generation and Use complies with Vertical BREF for Food Drink and Milk Industries as follows:

for installations where there is a use for the heat and power produced, use combined heat and power generation in new or substantially altered installations or those renewing their energy systems (Requirement 5.1.4.10.1)

Not applicable – existing installation. Will be considered as part of future upgrades and changes

switch equipment off when it is not needed (Requirement 5.1.4.10.3)

in place - Automated systems included in design

minimise the loads on motors (Requirement 5.1.4.10.4)

in place - VSD control

minimise motor losses (Requirement 5.1.4.10.5)

Efficient motors used where possible

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implementation use variable speed drives to reduce the load on fans and pumps (Requirement 5.1.4.10.6)

VSD on pumps were appropriate Will also be considered as part of future upgrades and changes

apply thermal insulation, e.g. of pipes, vessels and equipment used to carry, store or treat substances above or below ambient temperature and to equipment used for processes involving heating and cooling (Requirement 5.1.4.10.7)

in place –

apply frequency controllers on motors(Requirement 5.1.4.10.8)

In place - VSDs on motors

Steam systems

18. BAT for steam systems is to optimise the energy efficiency by using techniques such as:

those specific to sectors given in vertical BREFs

those given in Table 4.2

Steam Systems comply with Vertical BREF for Food Drink and Milk Industries as follows:

maximise condensate return(Requirement 5.1.4.13.1)

Yes - in place

isolate unused pipework(Requirement 5.1.4.13.3)

Yes - Maintenance programme in place

improve steam trapping(Requirement 5.1.4.13.4)

Yes -Steam traps are monitored

repair steam leaks(Requirement 5.1.4.13.5) Yes - PM system in place

minimise boiler blowdown (Requirement 5.1.4.13.6)

Yes - TDS control on boilers in place

Heat recovery

19. BAT is to maintain the efficiency of heat exchangers by both: a. monitoring the efficiency periodically, and b. preventing or removing fouling

Limited opportunity for use of heat recovery systems at the installation. Feasible energy recovery systems have been identified including heat recovery units on compressors (currently installed but not commissioned) and condensate recovery system for boiler feed make up water.

Will be considered as part of future upgrades and changes

Cogeneration

20. BAT is to seek possibilities for cogeneration, inside and/or outside the installation (with a third party).

Limited opportunity for this type of system at the installation.

Will be considered as part of future upgrades and changes

Electrical power supply

21. BAT is to increase the power factor according to the requirements of the local electricity Requirements currently in place. The Electrical In place

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implementation distributor by using techniques such as those in Table 4.3, according to applicability

Installing capacitors in the AC circuits to decrease the magnitude of reactive power

Minimising the operation of idling or lightly loaded motors

Avoiding the operation of equipment above its rated voltage

When replacing motors, using energy efficient motors

power distribution services are in accordance with industry standards and guides. Standard Operating Procedures are in line with equipment specifications.

22. BAT is to check the power supply for harmonics and apply filters if required (see Section 3.5.2). VSD fitted with filters In place

23. BAT is to optimise the power supply efficiency by using techniques such as those in Table 4.4, according to applicability:

Ensure power cables have the correct dimensions for the power demand

Keep online transformer(s) operating at a load above 40 _ 50 % of the rated power

Use high efficiency/low loss transformers

Place equipment with a high current demand as close as possible to the power source

Requirements included in current design. Low loss transformers selected Transformer located close to power source

In place

Electric motor driven sub-systems

24. BAT is to optimise electric motors in the following order (see Section 3.6): 1. optimise the entire system the motor(s) is part of (e.g. cooling system, see Section 1.5.1) 2. then optimise the motor(s) in the system according to the newly-determined load requirements, by applying one or more of the techniques in Table 4.5, according to applicability 3. when the energy-using systems have been optimised, then optimise the remaining (nonoptimised) motors according to Table 4.5 and criteria such as: i. prioritising the remaining motors running more than 2000 hrs per year for replacement with EEMs ii. electric motors driving a variable load operating at less than 50 % of capacity more than 20 % of their operating time, and operating for more than 2000 hours a year should be considered for equipping with variable speed drives.

Using energy efficient motors where possible

Proper motor sizing

VSDs on motors where appropriate

In place

Compressed air systems (CAS)

25. BAT is to optimise compressed air systems (CAS) using the techniques such as those in Table 4.6, according to applicability:

Will be in place – included in design upgrade Will be in place – included in

System Design

Overall system design including multi-pressure system Not applicable as this is an existing facility. The overall CAS however is considered to be in line with current best practice

Upgrade Compressor Not applicable as this is an existing facility. Compressors however currently are fully automated and use line pressure control

systems to monitor demand. Reduce frictional pressure losses Not applicable as this is an existing facility.

Improvement of drives (high efficiency motors) High efficiency motors are used where appropriate

Improvement of drives (speed control) Variable speed drives for compressors

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implementation Use external cool air as intake Externally ducted air used

design upgrade

Use of sophisticated control systems Computerised compressor control system. Compressors are fully automated and use line pressure control systems to monitor demand. Typically, a drop in pressure signals an increase in demand, which is corrected by increased compressor output. Rising pressure, indicating a drop in demand, causes a reduction in compressor output. The automated system will monitor changes in pressure and adapt the air supply to the changing air demand.

System Operation and Maintenance

Optimise certain end use devices Addressed by maintenance programme

The automated system will monitor changes in pressure and adapt the air supply to the changing air demand

In place

Reduce air leaks

More frequent filter replacement

Optimise working pressure

Pumping systems

26. BAT is to optimise pumping systems by using the techniques in Table 4.7, according to applicability (see Section 3.8):

Design Avoid over-sizing when selecting pumps and replace oversized pumps Lifetime cost benefit assessment to be undertaken

Will be undertaken as part of future upgrades and changes and where determined by lifetime cost benefit assessment

Match the correct choice of pump to the correct motor for the duty

Design of pipework system

Control & Maintenance

Control and regulation system Systems are automated and monitored constantly as part of the central electronic control system. VSD on motors are installed as appropriate

In place

Shut down unnecessary pumps

Use of variable speed drives

Use of multiple pumps

Regular maintenance. Where unplanned maintenance becomes excessive check for cavitation, wear, wrong type of pump

Distribution System

Minimise the number of valves and bends commensurate with keeping ease of operation and maintenance

Not applicable as this is an existing facility. Will be considered as part of future upgrades and changes

Avoiding using too many bends

Ensuring the pipework is not too small

Heating, ventilation and air conditioning (HVAC) systems

27. BAT is to optimise heating, ventilation and air conditioning systems by using techniques such as: • for ventilation, space heating and cooling, techniques in Table 4.8 according to applicability • for heating, see Sections 3.2 and 3.3.1, and BAT 18 and 19 • for pumping, see Section 3.8 and BAT 26

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implementation • for cooling, chilling and heat exchangers, see the ICS BREF, as well as Section 3.3 and BAT 19 (in this document).

Design & Control

Overall system design. Identify and equip areas separately for: - general ventilation - specific ventilation - process ventilation

Not applicable as this is an existing facility. However, a number of specific areas are currently equipped separately as follows:

General ventilation is provided to the goods store and, transformer,

Specific ventilation in bulk out-loading

Process ventilation for coolers, grinders, dryers

In place

Optimise the number, shape and size of intakes Not applicable as this is an existing facility. However the air intakes have been optimised by locating all supply air AHU’s as close to where it is required.

Will be considered as part of future upgrades

Use fans: - of high efficiency - designed to operated at optimal rate

Process control determines usage – automatic shut down if not needed (ie if process shuts down so do associated fans)

In place

Manage airflow. Including consideration of dual flow ventilation Not applicable as this is an existing facility. Air flow is however managed by monitoring of filters. Process control shuts down AHU when not needed


Air system design: - ducts are of a sufficient size - circular ducts - avoid long runs and obstacles such as bends, narrow sections

Not applicable as this is an existing facility. However, the ductwork with the processing systems is considered to be sized sufficiently and fit for purpose. Bends and long runs of ductwork have been kept to a minimum.

Will be considered as part of future upgrades.

Optimise electric motors and consider installing a VSD Not deemed necessary because of the nature of the fans on site – baffles


Use automatic control systems. Integrate with centralised technical management systems

Not applicable as this is an existing facility. However, HVAC system is currently linked to process control system– automated shut down during periods where production is not operating.

In place

Integration of air filters into air duct system and heat recovery from exhaust air (heat exchangers)

Not applicable as this is an existing facility. However air filters and cyclones integration has occurred where necessary

In place

Reduce heating / cooling needs by:

building insulation Processing areas has no general heating requirement. Canteen, laboratory and offices

In place.

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implementation efficient glazing

air infiltration reduction

automatic closure of doors

destratification

lowering of temperature set point during non-production period (programmable regulation)

reduction of the set point for heating and raising it for cooling

are thermostatically controlled

Improve the efficiency of heating systems through:

recovery or use of wasted heat

heat pumps

radiative and local heating systems coupled with reduced temperature set points in the non-occupied areas of the building

Heating systems relate to support facilities (offices, canteen, laboratory). Temperature is thermostatically controlled. General processing areas are not heated.

In place

Improve the efficiency of cooling systems through the use of free cooling Not applicable to this site. .No cooling energy required. All product can be stored close to ambient temp

Not applicable

Maintenance Stop or reduce ventilation where possible The HVAC systems fully shut down during periods where production is not operating.

In place

Ensure system is airtight, check joints Undertaken as part of the maintenance programme .

In place

Check system is balanced Undertaken as part of the maintenance programme .

In place

Air filtering, optimise: recycling efficiency

pressure loss

regular filter cleaning/replacement

regular cleaning of system

Gauge in place on grinder filters to check air flow. Maintenance of filters and cleaning of components performed in accordance with Dairygold maintenance frequencies and procedures.

In place.

Lighting

28. BAT is to optimise artificial lighting systems by using the techniques such as those in Table 4.9 according to applicability (see Section 3.10):

Design of Lighting Requirements

Identify illumination requirements in terms of both intensity and spectral content required for the intended task

All lighting levels and requirements for the different tasks and areas meet the appropriate need.

In place

Plan space and activities in order to optimise the use of natural light The overall installation design is principally influenced on achieving efficiency of process flow. Where reasonable, opportunities to avail of natural light will be taken advantage of in the new building proposals

Will be considered as part of future upgrades.

Selection of fixtures and lamps according to specific requirements for the intended All fixture and fittings have been selected to In place

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implementation use specific requirements and intended use.

Operation, Control and Maintenance

Use of lighting management control systems including occupancy sensors , timers etc

The lighting system is controlled centrally via the process controller and remotely via security

In place

Train building occupants to utilise lighting equipment in the most efficient manner The lighting system is controlled centrally via the process controller and remotely via security

In place

Drying, separation and concentration processes

29. BAT is to optimise drying, separation and concentration processes by using techniques such as those in Table 4.10 according to applicability, and to seek opportunities to use mechanical separation in conjunction with thermal processes:

Design Select the optimum separation technology or combination of techniques to meet the specific process requirements

Drying and Separation processes apply only to the grain drying activity. The system technologies and techniques comply with industry norm and manufacture guidelines

In place

Operation Use of surplus heat from other process Limited opportunity to use surplus heat from other processes for this activity. 95% of heat is direct injection.

n/a

Use a combination of techniques Not applicable Not applicable

Mechanical process eg filtration, membrane filtration Not applicable Not applicable

Thermal processes eg - Directly heated dryers - Indirectly heated dryers - Multiple effect

The grain dryers are vertical directly heated dryers. The use of vertical directly heated dryers are the most the efficient form of grain drying

In place

Direct drying Not applicable Not applicable

Superheated steam Not applicable Not applicable

Heat recovery (including MVR and heat pumps) Not undertaken at present. Plan to investigate areas where this can be achieved

Optimise insulation of the drying system Appropriate insulation is provided to all equipment to reduce heat losses

In place

Radiation processes Not applicable Not applicable

Process automation in thermal drying processes The entire drying processes is fully automated and constantly monitored on a central electronic control system to continuously assess the performance of the plant

In Place

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Attachment No. I.8


Techniques for Emissions from Storage July 2006

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Conclusions on BAT from the Emissions from Storage BAT Reference Document (extracts) The full and complete Emissions from Storage BAT reference document (July 2006) is available at the EIPPC Bureau website: http://eippcb.jrc.ec.europa.eu/reference/

SCOPE Storage of all materials used, produced and generated on-site at Dairygold Agri Business Lombardstown



5.1 Storage of liquids and Liquefied gases 5.1.1.1 General principles to prevent and reduce emissions

BAT 1. BAT for a proper design is to take into account at least the following: • the physico-chemical properties of the substance being stored • how the storage is operated, what level of instrumentation is needed, how many operators are required, and what their workload will be • how the operators are informed of deviations from normal process conditions (alarms) • how the storage is protected against deviations from normal process conditions (safety instructions, interlock systems, pressure relief devices, leak detection and containment, etc.) • what equipment has to be installed, largely taking account of past experiences of the product (construction materials, valve quality, etc.) • which maintenance and inspection plan needs to be implemented and how to ease the maintenance and inspection work (access, layout, etc.) • how to deal with emergency situations (distances to other tanks, facilities and to the boundary, fire protection, access for emergency services such as the fire brigade, etc.).

Infrastructural and Operational features -

Bulk storage of materials are managed in accordance with Reference Document on Best Available Techniques on Emissions from Storage, July 2006 and IPC Guidance Note on Storage and Transfer of Materials for Scheduled Activities, EPA (2004).

All potential risk areas on site where spills or leaks of potentially polluting materials may occur have been identified and appropriate control and containment measures are in place

All potentially polluting substances, including waste, is stored in designated areas in appropriate approved containers within bunds or on spill pallets, as required.

Bunds provide containment to a volume not less than the greater of the following:

Yes in place

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http://eippcb.jrc.ec.europa.eu/reference/

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(i) 110% of the capacity of the largest tank or drum within the bunded area; or

(ii) 25% of the total volume of substance that could be stored within the bunded area.

Transfer of liquid materials are conveyed by overground piping systems.

Procedural Controls:

Site personnel are provided with role specific training on accident prevention and emergency response. Refresher training is provided, as necessary.

All personnel and contractors are technically competent and suitably trained to undertake the tasks assigned.

All storage tanks and containment bunds are subject to routine inspection.

Trained staff supervise loading and unloading.

Good housekeeping practices are be maintained on site.

A Preventative Maintenance Programme (PMP) for plant and equipment is in place.

A comprehensive set of emergency response procedures have been developed for the site to protect staff and prevent the release of any hazardous compounds that might cause risk to the community or the environment. The scope of the Emergency Response Plan (ERP) includes procedures to cover both the avoidance of control loss and the actions to restore control and minimise the potential for environmental impact at the installation.

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BAT 2. BAT is to apply a tool to determine proactive maintenance plans and to develop risk-based inspection plans such as the risk and reliability based maintenance approach; see Section 4.1.2.2.1.

A Preventative Maintenance Programme (PMP) for plant and equipment is in place.

The PMP will be revised to incorporate calibration and integrity testing of monitoring, abatement and control equipment.

A planned schedule of inspection for water tightness and integrity testing of tanks and underground pipeline will be undertaken

In place Will be in place within 12 months of grant of licence Will be in place within 12 months of grant of licence

BAT3. BAT is to locate a tank operating at, or close to, atmospheric pressure aboveground. However, for storing flammable liquids on a site with restricted space, underground tanks can also be considered. For liquefied gases, underground, mounded storage or spheres can be considered, depending on the storage volume.

All tanks are located above ground

Yes – in place

BAT 4. BAT is to apply either a tank colour with a reflectivity of thermal or light radiation of at least 70 %, or a solar shield on aboveground tanks which contain volatile substances, see Section 4.1.3.6 and 4.1.3.7 respectively.

Tanks are industry appropriate and meet BAT requirements

Yes – in place

BAT 5. BAT is to abate emissions from tank storage, transfer and handling that have a significant negative environmental effect, as described in Section 4.1.3.1

Tank storage abatement measures include: All external tanks storing liquids are suitably bunded to 110% of the capacity of the largest tank

Yes – in place

BAT 6. On sites where significant VOC emissions are to be expected, BAT includes calculating the VOC emissions regularly.

Not applicable - materials held on site would not be likely to give rise to significant VOC emissions

Not applicable

BAT 7. BAT is to apply dedicated systems; see Section 4.1.4.4.

Dedicated systems of material storage on-site:

Dedicated liquid ingredients storage tanks

Dedicated waste storage areas

Yes – in place

5.1.1.2 Tank specific considerations

Open top tanks BAT 8. If emissions to air occur, BAT is to cover the tank by applying:

Not applicable - no open top tanks on site

Not applicable

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• a floating cover, see Section 4.1.3.2 • a flexible or tent cover, see Section 4.1.3.3, or • a rigid cover, see Section 4.1.3.4. Additionally, with an open top tank covered with a flexible, tent or a rigid cover, a vapour treatment installation can be applied to achieve an additional emission reduction, see Section 4.1.3.15. The type of cover and the necessity for applying the vapour treatment system depend on the substances stored and must be decided on a case-by-case basis.

BAT 9. To prevent deposition that would call for an additional cleaning step, BAT is to mix the stored substance (e.g. slurry), see Section 4.1.5.1.

Not applicable Not applicable

External floating roof tank

BAT 10. The BAT associated emission reduction level for a large tank is at least 97 % (compared to a fixed roof tank without measures), which can be achieved when over at least 95 % of the circumference the gap between the roof and the wall is less than 3.2 mm and the seals are liquid mounted, mechanical shoe seals.

Not applicable – no floating roof tanks on -site Not applicable

BAT 11. BAT is to apply direct contact floating roofs (double-deck), however, existing non-contact floating roofs (pontoon) are also BAT. See Section 3.1.2. A dome can be BAT for adverse weather conditions, such as high winds, rain or snowfall. See Section 4.1.3.5.


BAT 12. For liquids containing a high level of particles (e.g. crude oil), BAT is to mix the stored substance to prevent deposition that would call for an additional cleaning step, see 4.1.5.1.


Fixed roof tanks BAT 13. For the storage of volatile substances which are toxic (T), very toxic (T+), or carcinogenic, mutagenic and reproductive toxic (CMR) categories 1 and 2 in a fixed roof tank, BAT is to apply a vapour treatment installation.

Not applicable - volatile substances not held on site

Not applicable

BAT 14. For other substances, BAT is to apply a vapour treatment installation, or to install an internal floating roof (see Sections 4.1.3.15 and 4.1.3.10 respectively). Direct contact floating roofs and non-contact floating roofs are BAT.


Yes in place

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BAT 15. For tanks < 50 m3, BAT is to apply a pressure relief valve set at the highest possible value consistent with the tank design criteria.


Yes in place

BAT 16. For liquids containing a high level of particles (e.g. crude oil) BAT is to mix the stored substance to prevent deposition that would call for an additional cleaning step,

Not applicable – these liquids not held on site Not applicable

Atmospheric horizontal tanks BAT 17. For the storage of volatile substances which are toxic (T), very toxic (T+), or CMR categories 1 and 2 in an atmospheric horizontal tank, BAT is to apply a vapour treatment installation.

Not applicable to the installation Not applicable

BAT 18. For other substances, BAT is to do all, or a combination, of the following techniques, depending on the substances stored: • apply pressure vacuum relief valves; see Section 4.1.3.11 • up rate to 56 mbar; see Section 4.1.3.11 • apply vapour balancing; see Section 4.1.3.13 • apply a vapour holding tank, see Section 4.1.3.14, or • apply vapour treatment; see Section 4.1.3.15. The selection of the vapour treatment technology has to be decided on a case-by-case basis.


Pressurised storage BAT 19. BAT for draining depends on the tank type, but may be the application of a closed drain system connected to a vapour treatment installation, see Section 4.1.4. The selection of the vapour treatment technology has to be decided on a case-by-case basis.

Closed drain systems used around tanks which drain to the process wastewater drainage system.

Yes in place

Lifter roof tanks BAT 20. For emissions to air, BAT is to (see Sections 3.1.9 and 4.1.3.14): • apply a flexible diaphragm tank equipped with pressure/vacuum relief valves, or • apply a lifter roof tank equipped with pressure/vacuum relief valves and connected to a vapour treatment installation. Selection of the vapour treatment technology has to be decided on a case-by-case basis.

Not applicable - no lifter roof tanks on-site

Not applicable

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Underground and mounded tanks BAT 21. For the storage of volatile substances which are toxic (T), very toxic (T+), or CMR categories 1 and 2 in an underground or mounded tank, BAT is to apply a vapour treatment installation.

Not applicable - no underground or mounded tanks on-site

Not applicable

BAT 22. For other substances, BAT is to do all, or a combination, of the following techniques, depending on the substances stored: • apply pressure vacuum relief valves; see Section 4.1.3.11 • apply vapour balancing; see Section 4.1.3.13 • apply a vapour holding tank, see Section 4.1.3.14, or • apply vapour treatment; see Section 4.1.3.15. The selection of the vapour treatment technology to be decided on a case-by-case basis.


Not applicable

5.1.1.3 Preventing incidents and (major) accidents

BAT 23. BAT in preventing incidents and accidents is to apply a safety management system as described in Section 4.1.6.1.

Dairygold Agri Business currently has an integrated Quality and Health and Safety Management system in place to manage and control organisational performance in accordance with UFAS Certification requirements.

Emergency Response Plan (ERP) currently in place.

Accidents and Incidents Procedures in Place

All staff given Training annually

All staff required to complete safety Module as prescribed training

Yes - in place

BAT 24. BAT is to implement and follow adequate organisational measures and to enable training and instruction of employees for safe and responsible operation of the installation as described in Section 4.1.6.1.1.

Training is given to staff. All staff required to complete safety training modules relevant to their area of work and duties as prescribed.

Yes - in place

BAT 25. BAT is to prevent corrosion by:

All materials appropriate to the product / substance which is stored

Scheduled for integrity testing of tanks and

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• selecting construction material that is resistant to the product stored • applying proper construction methods • preventing rainwater or groundwater entering the tank and if necessary, removing water that has accumulated in the tank • applying rainwater management to bund drainage • applying preventive maintenance, and • where applicable, adding corrosion inhibitors, or applying cathodic protection on the inside of the tank.

Routine visual inspections of tanks and bunds undertaken.

bunds will be developed within 6 months of grant of licence

BAT 26. Additionally for an underground tank, BAT is to apply to the outside of the tank: • a corrosion-resistant coating • plating, and/or • a cathodic protection system.

Not applicable – no underground tanks on-site n/a

BAT 27. BAT is to prevent stress corrosion cracking (SCC) by: • stress relieving by post-weld heat treatment, see Section 4.1.6.1.4, and • applying a risk based inspection as described in Section 4.1.2.2.1.

A planned schedule of visual and internal inspections all tanks is in place and carried out

Yes

BAT 28. BAT is to implement and maintain operational procedures – e.g. by means of a management system – as described in Section 4.1.6.1.5, to ensure that: • high level or high pressure instrumentation with alarm settings and/or auto closing of valves is installed • proper operating instructions are applied to prevent overfill during a tank filling operation, and • sufficient ullage is available to receive a batch filling.

Liquid storage tanks will be fitted with level gauges and alarms to prevent overfilling.

SOP for materials handling and plant operation in place

All personnel and contractors are technically competent and suitably trained to undertake the tasks assigned.

Will be in place with 12 months of grant of licence

In place

In place

BAT 29. BAT is to apply leak detection on storage tanks containing liquids that can potentially cause soil pollution.

All external tanks storing liquids are suitably bunded to 110% of the capacity of the largest tank. Bunds are visually inspected.

Yes – in place

BAT 30. BAT is to achieve a ‘negligible risk level’ of soil pollution from bottom and bottom-wall connections of aboveground storage tanks. However, on a case-by-case basis, situations might be identified where an ‘acceptable risk level’ is sufficient.

Storage tanks are suitably bunded and impervious to the materials stored within

Yes – in place

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BAT 31. BAT for aboveground tanks containing flammable liquids or liquids that pose a risk for significant soil pollution or a significant pollution of adjacent watercourses is to provide secondary containment, such as: • tank bunds around single wall tanks; see Section 4.1.6.1.11 • double wall tanks; see Section 4.1.6.1.13 • cup-tanks; see Section 4.1.6.1.14 • double wall tanks with monitored bottom discharge; see Section 4.1.6.1.15.

All external tanks storing liquids are suitably bunded to 110% of the capacity of the largest tank.

Yes - in place

BAT 32. For building new single walled tanks containing liquids that pose a risk for significant soil pollution or a significant pollution of adjacent watercourses, BAT is to apply a full, impervious, barrier in the bund, see Section 4.1.6.1.10.

Not applicable- no new liquid tanks to be installed

n/a

BAT 33. For existing tanks within a bund, BAT is to apply a risk-based approach, considering the significance of risk from product spillage to the soil, to determine if and which barrier is best applicable. This risk-based approach can also be applied to determine if a partial impervious barrier in a tank bund is sufficient or if the whole bund needs to be equipped with an impervious barrier. See Section 4.1.6.1.11.

Storage tanks are suitably bunded and impervious to the materials stored within

Yes – in place

BAT 34. For chlorinated hydrocarbon solvents (CHC) in single walled tanks, BAT is to apply CHC-proof laminates to concrete barriers (and containments), based on phenolic or furan resins. One form of epoxy resin is also CHC-proof. See Section 4.1.6.1.12.

Not applicable –solvents not stored or used on-site

Not applicable

BAT 35. BAT for underground and mounded tanks containing products that can potentially cause soil pollution is to: • apply a double walled tank with leak detection, see Section 4.1.6.1.16, or • to apply a single walled tank with secondary containment and leak detection, see Section 4.1.6.1.17.


Not applicable

BAT 36. For toxic, carcinogenic or other hazardous substances, BAT is to apply full containment.

All tank containment bunds are impervious to the material stored within the bund

In place

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5.1.2. Storage of packaged dangerous substances

BAT 37. BAT in preventing incidents and accidents is to apply a safety management system as described in Sections 4.1.6.1. The minimum level of BAT is to assess the risks of accidents and incidents on the site using the five steps described in Section 4.1.6.1






Yes in place

BAT 38. BAT is to appoint a person or persons who is or are responsible for the operation of the store.

Designated personnel are appointed for on-site materials management

Yes in place

BAT 39. BAT is to provide the responsible person(s) with specific training and retraining in emergency procedures as described in Section 4.1.7.1 and to inform other staff on the site of the risks of storing packaged dangerous substances and the precautions necessary to safely store substances that have different hazards.

All staff required to complete environmental and safety training modules relevant to their area of work and duties as prescribed. Training and SOP’s are in place for the operation of the facility in order to ensure proper handling and storage of hazardous materials

Yes in place

BAT 40. BAT is to apply a storage building and/or an outdoor storage area covered with a roof, as described in Section 4.1.7.2. For storing quantities of less than 2500 litres or kilograms dangerous substances, applying a storage cell as described in Section 4.1.7.2 is also BAT.

Dedicated areas within site buildings provided for the storage of any dangerous substances.

Yes - in place

BAT 41. BAT is to separate the storage area or building of packaged dangerous substances from other storage, from ignition sources and from other buildings on- and off-site by applying a sufficient distance, sometimes in combination with fire-resistant walls.

All materials stored in accordance with requirements as set out in MSDS and with dedicated storage area within buildings

Yes – in place

BAT 42. All materials stored in accordance with Yes – in place

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BAT is to separate and/or segregate incompatible substances. For the compatible and incompatible combinations see Annex 8.3.

requirements as set out in MSDS

BAT 43. BAT is to install a liquid-tight reservoir according to Section 4.1.7.5, that can contain all or a part of the dangerous liquids stored above such a reservoir. The choice whether all or only a part of the leakage needs to be contained depends on the substances stored and on the location of the storage (e.g. in a water catchment area) and can only be decided on a case-by-case basis.

All packaged liquid dangerous substance stored in contained area and/or on appropriately sized mobile bunds or spill trays

Yes – in place

BAT 44. BAT is to install a liquid-tight extinguishant collecting provision in storage buildings and storage areas according to Section 4.1.7.5. The collecting capacity depends on the substances stored, the amount of substances stored, the type of package used and the applied fire-fighting system and can only be decided on a case-by-case basis.

Building drainage systems discharge to the WWPP

in place

BAT 45. BAT is to apply a suitable protection level of fire prevention and fire-fighting measures as described in Section 4.1.7.6. The appropriate protection level has to be decided on a case-by-case basis in agreement with the local fire brigade.

Fire fighting facilities and fire brigade access is in compliance regulations.

Fire water risk management programme will be developed for the installation within 6 months of grant of licence

BAT 46. BAT is to prevent ignition at source as described in Section 4.1.7.6.1.

measures to prevent ignition at source are in place. Hot works, etc. Is controlled under a permit to work system.

Yes - in place

5.1.3 Basins and lagoons

BAT 47. Where emissions to air from normal operation are significant, e.g. with the storage of pig slurry, BAT is to cover basins and lagoons using one of the following options: • a plastic cover; see Section 4.1.8.2 • a floating cover; see Section 4.1.8.1, or • only small basins, a rigid cover; see Section 4.1.8.2. Additionally, where a rigid cover is used, a vapour treatment installation can be applied to achieve an extra emission reduction, see Section 4.1.3.15. The need for and type of vapour

Not applicable – no storage basins or lagoons on-site

Not applicable

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treatment must be decided on a case-by-case basis.

BAT 48. To prevent overfilling due to rainfall in situations where the basin or lagoon is not covered, BAT is to apply a sufficient freeboard, see Section 4.1.11.1.


Not applicable

BAT 49. Where substances are stored in a basin or lagoon with a risk of soil contamination, BAT is to apply an impervious barrier. This can be a flexible membrane, a sufficient clay layer or concrete, see Section 4.1.9.1


Not applicable

5.2 Transfer and handling of liquids and liquefied gases 5.2.1 General principles to prevent and reduce emissions

BAT 50. BAT is to apply a tool to determine proactive maintenance plans and to develop risk-based inspection plans such as, the risk and reliability based maintenance approach; see Section 4.1.2.2.1.

A Preventative Maintenance Programme (PMP) for plant and equipment is in place. The PMP will be updated to incorporate calibration and integrity testing of monitoring, abatement and control equipment.

PMP will be revised and updated within 12 months of grant of licence.

BAT 51. For large storage facilities, according to the properties of the products stored, BAT is to apply a leak detection and repair programme. Focus needs to be on those situations most likely to cause emissions (such as gas/light liquid, under high pressure and/or temperature duties). See Section 4.2.1.3.

Leak detection systems and alarms, connected to the manned control room, installed on gas transfer lines. Gas leaks will trigger alarms and shut off valves within the site

Yes – in place

BAT 52. BAT is to abate emissions from tank storage, transfer and handling that have a significant negative environmental effect, as described in Section 4.1.3.1.

All potentially polluting substances, including waste, are stored in designated areas in appropriate approved containers within bunds or on spill pallets, as required. All areas on site with potentially polluting substances are hardstanding with channels directing run-off to the process wastewater drainage system.

Yes – in place

BAT 53. BAT in preventing incidents and accidents is to apply a safety management system as

Dairygold Agri Business currently has an integrated Quality and Health and Safety

Yes – in place

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described in Section 4.1.6.1. Management system in place to manage and control organisational performance in accordance with UFAS Certification requirements.





BAT 54. BAT is to implement and follow adequate organisational measures and to enable the training and instruction of employees for safe and responsible operation of the installation as described in Section 4.1.6.1.1.

Training is given to staff. All staff required to complete environmental and safety training modules relevant to their area of work and duties as prescribed.

Yes - in place

5.2.2 Considerations on transfer and handling techniques 5.2.2.1 Piping

BAT 55. BAT is to apply aboveground closed piping in new situations, see Section 4.2.4.1. For existing underground piping it is BAT to apply a risk and reliability based maintenance approach as described in Section 4.1.2.2.1.

Transfer of liquid materials are conveyed by overground piping systems.

Yes – in place

BAT 56. BAT is to minimise the number of flanges by replacing them with welded connections, within the limitation of operational requirements for equipment maintenance or transfer system flexibility, see Section 4.2.2.1.

Welded connections will be used where appropriate

Will be in place Assessment of flanges within be undertaken within 12 months of grant of licence and a schedule for replacement developed.

BAT 57. BAT for bolted flange connections (see Section 4.2.2.2.) include:

All equipment in accordance with industry guidance standards

Yes - in place

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• fitting blind flanges to infrequently used fittings to prevent accidental opening • using end caps or plugs on open-ended lines and not valves • ensuring gaskets are selected appropriate to the process application • ensuring the gasket is installed correctly • ensuring the flange joint is assembled and loaded correctly • where toxic, carcinogenic or other hazardous substances are transferred, fitting high integrity gaskets, such as spiral wound, kammprofile or ring joints.

BAT 58. BAT is to prevent corrosion by: • selecting construction material that is resistant to the product • applying proper construction methods • applying preventive maintenance, and • where applicable, applying an internal coating or adding corrosion inhibitors.

All materials are appropriate to the product / substance which is stored or transferred.

A Scheduled for inspection of pipe work will be developed within 12 months of grant of licence.

BAT 59. To prevent the piping from external corrosion, BAT is to apply a one, two, or three layer coating system depending on the site-specific conditions (e.g. close to sea). Coating is normally not applied to plastic or stainless steel pipelines. See Section 4.2.3.2.

Not applicable – stainless steel and plastic pipelines used throughout

Yes - in place

5.2.2.2 Vapour treatment

BAT 60. BAT is to apply vapour balancing or treatment on significant emissions from the loading and unloading of volatile substances to (or from) trucks, barges and ships. The significance of the emission depends on the substance and the volume that is emitted, and has to be decided on a case-by-case basis. For more detail see Section 4.2.8.

Not applicable Not applicable

5.2.2.3 Valves

BAT 61. BAT for valves include: • correct selection of the packing material and construction for the process application • with monitoring, focus on those valves most at risk (such as rising stem control valves in continual operation) • applying rotating control valves or variable speed pumps instead of rising stem control valves • where toxic, carcinogenic or other hazardous substances are involved, fit diaphragm,

Valves are appropriate for the process application and operated in accordance with industry standards

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bellows, or double walled valves • route relief valves back into the transfer or storage system or to a vapour treatment system.

5.2.2.4 Pumps and compressors

BAT 62. The following are some of the main factors which constitute BAT: • proper fixing of the pump or compressor unit to its base-plate or frame • having connecting pipe forces within producers’ recommendations • proper design of suction pipework to minimise hydraulic imbalance • alignment of shaft and casing within producers’ recommendations • alignment of driver/pump or compressor coupling within producers’ recommendations when fitted • correct level of balance of rotating parts • effective priming of pumps and compressors prior to start-up • operation of the pump and compressor within producers’ recommended performance range (The optimum performance is achieved at its best efficiency point.) • the level of net positive suction head available should always be in excess of the pump or compressor • regular monitoring and maintenance of both rotating equipment and seal systems, combined with a repair or replacement programme.

Pumps and compressors are appropriate for the process application and operated in accordance with industry standards

In place

BAT 63. BAT is to use the correct selection of pump and seal types for the process application, preferably pumps that are technologically designed to be tight such as canned motor pumps, magnetically coupled pumps, pumps with multiple mechanical seals and a quench or buffer system, pumps with multiple mechanical seals and seals dry to the atmosphere, diaphragm pumps or bellow pumps.

Pumps and seals are appropriate for the process application and operated in accordance with industry standards

In place

BAT 64. BAT for compressors transferring non-toxic gases is to apply gas lubricated mechanical seals.


BAT 65. BAT for compressors, transferring toxic gases is to apply double seals with a liquid or gas barrier and to purge the process side of the containment seal with an inert buffer gas.

Not applicable - toxic gases not used at the facility

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BAT 66. In very high pressure services, BAT is to apply a triple tandem seal system.


5.2.2.5 Sampling connections

BAT 67. BAT, for sample points for volatile products, is to apply a ram type sampling valve or a needle valve and a block valve. Where sampling lines require purging, BAT is to apply closed-loop sampling lines. See Section 4.2.9.14.


5.3 Storage of solids 5.3.1 Open storage

BAT 68. BAT is to apply enclosed storage by using, for example, silos, bunkers, hoppers and containers, to eliminate the influence of wind and to prevent the formation of dust by wind as far as possible by primary measures. See Table 4.12 for these primary measures with cross-references to the relevant sections.

Open storage of solids only applicable to storage of waste or temporary storage of grains/cereals. Waste storage area and temporary grain/cereal storage areas are partially sheltered from wind blow by semi enclosed storage bays

In place

BAT 69. BAT for open storage is to carry out regular or continuous visual inspections to see if dust emissions occur and to check if preventive measures are in good working order. Following the weather forecast by, e.g, using meteorological instruments on site, will help to identify when the moistening of heaps is necessary and will prevent unnecessary use of resources for moistening the open storage. See Section 4.3.3.1.

Open storage of grain/cereal Dust monitoring plan will be implemented within 6 months of grant of licence

BAT 70. BAT for long-term open storage are one, or a proper combination, of the following techniques: • moistening the surface using durable dust-binding substances, see Section 4.3.6.1 • covering the surface, e.g. with tarpaulins, see Section 4.3.4.4 • solidification of the surface, see Table 4.13 • grassing-over of the surface, see Table 4.13.

Not applicable – no long term open storage of materials at the installation

Not applicable

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BAT 71. BAT for short-term open storage are one, or a proper combination, of the following techniques: • moistening the surface using durable dust-binding substances, see Section 4.3.6.1 • moistening the surface with water, see Sections 4.3.6.1 • covering the surface, e.g. with tarpaulins, see Section 4.3.4.4.

Not appropriate for open grain / cereal storage.

Where the occurrence of significant dust is generated by open storage, Dairygold will investigate and implement alternative appropriate dust management measures

5.3.2 Enclosed storage

BAT 72. BAT is to apply enclosed storage by using, for example, silos, bunkers, hoppers and containers. Where silos are not applicable, storage in sheds can be an alternative. This is, e.g. the case if apart from storage, the mixing of batches is needed.

With the exception of temporary short term external storage of some incoming grain/cereal, dry materials are principally stored in enclosed storage silos

Yes in place

BAT 73. BAT for silos is to apply a proper design to provide stability and prevent the silo from collapsing. See Sections 4.3.4.1 and 4.3.4.5.

Silos are industry appropriate and meet BAT requirements

Yes - in place

BAT 74. BAT for sheds is to apply proper designed ventilation and filtering systems and to keep the doors closed. See Section 4.3.4.2.

Ventilation and filtering systems included in design for packaging and storage areas

Yes

BAT 75 BAT is to apply dust abatement and a BAT associated emission level of 1 – 10 mg/m3, depending on the nature/type of substance stored. The type of abatement technique has to be decided on a case-by-case basis. See Section 4.3.7.

Filters installed in storage silos vents as appropriate.

Yes – in place

BAT 76. For a silo containing organic solids, BAT is to apply an explosion resistant silo (see Section 4.3.8.3), equipped with a relief valve that closes rapidly after the explosion to prevent oxygen entering the silo, as described in Section 4.3.8.4.


Yes - in place

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5.3.4 Preventing incidents and (major) accidents

BAT 77. BAT in preventing incidents and accidents is applying a safety management system as described in Section 4.1.7.1.






Yes - in place

5.4 Transfer and handling of solids 5.4.1 General approaches to minimise dust from transfer and handling

BAT 78. BAT is to prevent dust dispersion due to loading and unloading activities in the open air, by scheduling the transfer as much as possible when the wind speed is low. However, and taking into account the local situation, this type of measure cannot be generalised to the whole EU and to any situation irrespective of the possible high costs. See Section 4.4.3.1.

Loading and unloading activities in open air are limited to grain/cereal handling and is a temporary short term seasonal activity. Not always feasible to curtail handling activities to periods of low wind speeds. Where the likelihood for generation of significant dust by these activities, Dairygold will implement appropriate dust management measures

Will be in place when required

BAT 79. When applying a mechanical shovel, BAT is to reduce the drop height and to choose the best position during discharging into a truck; see Section 4.4.3.4.

Applicable to the installation for handling operations of open storage grain/cereal and removal of waste materials from grain cleaning house. Best practice in line with BAT requirement adopted.

Yes – in place

BAT 80. BAT then is to adjust the speed of vehicles on-site to avoid or minimise dust being swirled

Fixed speed restriction on site. Paved surfaces. No significant dust generation

Yes – in place

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up; see Section 4.4.3.5.2.

BAT 81. BAT for roads that are used by trucks and cars only, is applying hard surfaces to the roads of, for example, concrete or asphalt, because these can be cleaned easily to avoid dust being swirled up by vehicles, see Section 4.4.3.5.3. However, applying hard surfaces to the roads is not justified when the roads are used just for big shovel vehicles or when a road is temporary.

Hard surface areas throughout the site Yes – in place

BAT 82. BAT is to clean roads that are fitted with hard surfaces according to Section 4.4.6.12.

Hard surface kept clean as part of general site housekeeping

Yes – in place

BAT 83. Cleaning of vehicle tyres is BAT. The frequency of cleaning and type of cleaning facility applied (see Section 4.4.6.13) has to be decided on a case-by-case basis.

Wheel wash onsite Yes – in place

BAT 84. Where it neither compromises product quality, plant safety, nor water resources, BAT for loading/unloading drift sensitive, wettable products is to moisten the product as described in Sections 4.4.6.8, 4.4.6.9 and 4.3.6.1. Risk of freezing of the product, risk of slippery situations because of ice forming or wet product on the road and shortage of water are examples when this BAT might not be applicable.

Not appropriate to moist grains/cereals. Not applicable

BAT 85. For loading/unloading activities, BAT is to minimise the speed of descent and the free fall height of the product; see Sections 4.4.5.6 and 4.4.5.7 respectively. Minimising the speed of descent can be achieved by the following techniques that are BAT: • installing baffles inside fill pipes • applying a loading head at the end of the pipe or tube to regulate the output speed • applying a cascade (e.g. cascade tube or hopper) • applying a minimum slope angle with, e.g. chutes.

Applicable to bulk out-loading of feed products.

Yes - in place

BAT 86. To minimise the free fall height of the product, the outlet of the discharger should reach down onto the bottom of the cargo space or onto the material already piled up. Loading techniques that can achieve this, and that are BAT, are: • height adjustable fill pipes • height adjustable fill tubes, and

Applicable to bulk out-loading of feed products.

Yes - in place

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• height adjustable cascade tubes. These techniques are BAT, except when loading/unloading non drift sensitive products, for which the free fall height is not that critical.

5.4.2 Considerations on transfer techniques

BAT 87. For applying a grab, BAT is to follow the decision diagram as shown in Section 4.4.3.2 and to leave the grab in the hopper for a sufficient time after the material discharge.

Not applicable– grab transfer systems not used at the installation

Not applicable

BAT 88. BAT for new grabs, is to apply grabs with the following properties (see Section 4.4.5.1): • geometric shape and optimal load capacity • the grab volume is always higher than the volume that is given by the grab curve • the surface is smooth to avoid material adhering, and • a good closure capacity during permanent operation.

Not applicable– grab transfer systems not used at the installation

Not applicable

BAT 89. For all types of substances, BAT is to design conveyor to conveyor transfer chutes in such a way that spillage is reduced to a minimum. A modelling process is available to generate detail designs for new and existing transfer points. For more details see Section 4.4.5.5.

closed transfer systems used throughout Not applicable

BAT 90. For non or very slightly drift sensitive products (S5) and moderately drift sensitive, wettable products (S4), BAT is to apply an open belt conveyor and additionally, depending on the local circumstances, one or a proper combination of the following techniques: • lateral wind protection, see Section 4.4.6.1 • spraying water and jet spraying at the transfer points, see Sections 4.4.6.8 and 4.4.6.9, and/or • belt cleaning, see Section 4.4.6.10.

closed transfer systems used throughout Not applicable

BAT 91. For highly drift sensitive products (S1 and S2) and moderately drift sensitive, not wettable products (S3) BAT for new situations, is to: apply closed conveyors, or types where the belt itself or a second belt locks the material (see Section 4.4.5.2), such as: • pneumatic conveyors

Not applicable to the installation –animal feed processing industry – closed transfer systems used throughout

Not applicable

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• trough chain conveyors • screw conveyors • tube belt conveyor • loop belt conveyor • double belt conveyor or to apply enclosed conveyor belts without support pulleys (see Section 4.4.5.3), such as: • aerobelt conveyor • low friction conveyor • conveyor with diabolos. The type of conveyor depends on the substance to be transported and on the location and has to be decided on a case-by-case basis.

BAT 92. For existing conventional conveyors, transporting highly drift sensitive products (S1 and S2) and moderately drift sensitive, not wettable products (S3), BAT is to apply housing; see Section 4.4.6.2. When applying an extraction system, BAT is to filter the outgoing air stream; see Section 4.4.6.4.

Not applicable to the installation - Closed transfer systems used throughout production area. Outgoing air streams from grinder units exhausted through filters/cyclones as appropriate

Yes – in place

BAT 93. To reduce energy consumption for conveyor belts (see Section 4.4.5.2), BAT is to apply: • a good conveyor design, including idlers and idler spacing • an accurate installation tolerance, and • a belt with low rolling resistance.

Not applicable to the installation – closed transfer systems used throughout

Not applicable

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attachment no i.7: noise · site (accompanied by horn blasts at a level crossing), and a ride on...

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