nutricia - environmental protection agency · nutricia infant nutrition ltd., the owner of the...

I 0 NUTRICIA

Ms Ann Kehoe, Environmental Protection Agency, Po Box 3000, Johnstown Castle Estate, Co. Wexford.

22nd June 2007.

For attention of Ms Meave McHugh. i

Re; IPPC Licence Application for Nutricia Infant Nutrition Ltd. Macroom. Co. Cork. Reg - No PO792-01

Dear Ms Kehoe,

NUTRICIA INFANT NUTRITION LTD.

Castleview Macroom, Co. Cork, Ireland. Telephone (+353) 26 41302 Facsimile (+353) 26 42223

/ Email: [email protected]

Registered Office 30 Herbert Street, Dublin 2, Registered in Ireland - No 384474

Directors: P. J. Caulfield (Managing), B. J. Joyce

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I refer to previous submissions made to the EPA in respect of this licence application and Meave McHugh's letter of the 29th may 2007. I attach a response to the points set out in that letter and the hardcopy and CD-Rom copies requested, including one signed original, two copies in hardcopy format and two copies in PDF format on CD-ROM.

I trust this meets your requirements and e licence application.

Yours sincerely,

P J - Eamon O'Connor.

Supply Point Manager

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EPA Export 25-07-2013:21:49:58

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Re. IPPC licence amlication for Nutricia Infant Nutrition Ltd., Macroom,

Co. Cork Rep. No. P0792-01. ResDonse to EPA letter of 29 May 2007.

1. Planning permission status

The planning status of the proposed development at Nutricia is that planning permission was

granted by Cork County Council on 22 April 2007, but it was appealed to An Bord Pleanala by

a number of local residents on 21 May 2007. The matter is therefore currently in the hands of

An Bord Pleanala

2. Noise

Attached is a report (Appendix l), prepared for Nutricia by Fehily Timoney & Co. , authors of

the EIS, in response to your request for additional informai:ion in relation to noise.

3. Emissions to Surface Waters

Attached is a report (Appendix 2), prepared for Nutricia by Fehily Timoney & Co. , authors of

the EIS, in response to your request for additional information in relation to emissions to

surface waters. Nutricia strongly endorses the case made by Fehily Timoney & Co. thal the 95-

percentile flow is not a scientifically valid basis for setting a limit value for phosphate in the

effluent, nor is it consistent with the Phosphorus Regulations. On the basis of the consultants’

analysis, the mean flow in the receiving water is the appropriate basis for setting a phosphate

limit value.

4. Emissions to Air

Attached is a report (Appendix 3), prepared for Nutricia b y Fehily Timoney & Co., authors of the EIS, in response to your request for additional information in relation to emissions to air.

5. Techniaues considered to raresent BAT

Having regard to the EPA’s final draft Guidance Note on BAT for the Dairy Processing Sector,

the following techniques, implemented and proposed at Nutricia, are considered to represent

BAT:

5.1 Proposed implementation of an environmental management system as a condition

of the IPPC licence.

5.2 Reduce the use of chemicals and packaging to, minimise environmental impact.

5.3 Apply BAT to the storage and handling of he1 oil and other liquids.

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5.3 Utilise a CIP system and optimise its sequences to minimise chemical usage and

water consumption.

5.4 Optimise energy use in the manufacturing processes. Operate evaporators so as to

get the highest possible concentration of milk solids prior to drying, consistent with

product quality requirements.

5.5 Treat wastewater by primary, secondary and tertiary processes, including nutrient

removal and sand filtration to polish the final effluent.

5.6 Dewater sludge from the wastewater treatment plant before disposal.

5.7 Proposed use of bag filters to capture particulate emissions from the dryers.

5.8 Design, locate and construct buildings and equipment so as to minimise noise

emissions.

5.9 Proposed development of an emergency plan to address risks to the environment, as

an IPPC licence condition.

Details of all these BAT-related techniques are given in the EIS previously submitted to

EPA in connection with this licence application.

6. Energv efficiency considerations

Available details of energy efficiency considerations have been submitted previously as

Attachment 1.8. These showed the reductions achieved over a four-year period in the

consumption of heavy fuel oil and electricity per ton of product. Energy cost management and

energy efficiency are the focus of ongoing management attention at Nutricia, as energy costs

account for an increasing share of operating costs.

7. Containment of spillages and firewater Measures for the containment of spillages or firewater were described in Section J of

the previously submitted Application Form as follows:

Provision is made in the efluent treatment plant for an emergency response. This

involves containment of spillages, diverting the efluent discharge, spillage or loss of

containment to a holding lagoon for secondary containment and the subsequent

pumping of the stored efluent to the treatment plant for fill treatment. Similar

arrangements apply to jrewater retention. See previously submitted Attachment N0.J. I ,

Numico s;lfety PoZicy, including procedures for incident and emergency response.

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,

The provisions for containment of spillages and of firewater will be upgraded to cater

for the planned development of the Nutricia site which is the subject of the current planning

application. The details and time-scale for such upgrading will be part of the overall site

development project.

8. Convictions under environmental legislation

In relation to convictions under environmental legislation it was stated in Section L of the

previously submitted Application Form that:

Neither the applicant nor any other relevantperson has been convicted under

the POE Act, irlze Waste Management Act 1996, the Local Government (Rater Pollution) Acts I977 and 1990 or the Air Pollution Act 1987.

9. Ability to meet hancial commitments or liabilities

In relation to the Company's ability to meet its financial a)mmitments or liabilities it was

stated in Section K of the previously submitted Application Form that:

Numico is a reputable, long established and$nancially viable business and has the

necessary resources and commitment to ensure that, in the unlikely event of closure of

the facility, the site will be made environmentally safe. In the unlikely event of site

closure it is envisaged that the procedures set out in the P A Guidance Document on

Environmental Liabiliv Risk Assessment, Residuals Management and Financial

Provision would be@llowed.

Nutricia Infant Nutrition Ltd., the owner of the Macroom plant, is a wholly owned

subsidiary of Numico, an international food Company based in the Netherlands, with some 13,000 employees, sales of €2,632 million and an operating profit of €429 million in 2006.

Nutricia Infant Nutrition Ltd. is therefore part of a strong and financially secure international

Company with full ability to meet its financial commitments and liabilities.

10. UDdated non-technical summary

An updated non-techcal summary is requested with this submission. The existing summary

has been reviewed in the light of the information contained in the submission and some

amendments are made to bring it up to date. (Appendix 4).

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EPA Export 25-07-2013:21:49:58

ID Appendix 1 : Noise emissions and abatement

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EPA request 2(i):

In Tables 3.3 ana' 3.4 of the EIS you provide results ofboth daytime andnight-time

baseline noise assessment. Provide information to show the contribution to these noise

levelspom the operation of the existingplant ana' equipment at your site.

The site operates continuously 24 hours per day. Principle noise source audible at the noise

sensitive locations are the hum of the drying tower with a periodic noise from the action of an

acoustic hammer used to remove residue from the inside of'the drylng tower. To the west of the site the operation of the cooling towers also makes a contribution to noise levels.

The baseline noise was measured while the pIant was operational, with measurements taken

during daytime and during night-time. The results of the baseline measurements are given in

EIS Tables 3.3 and 3.4.

As the production at the site operates continuously and because of influences from noise from

other sources, the direct noise contribution of the site was not measured. The specific noise

level was determined by calculation using the EIS noise model to model the existing noise

situation prior to proposed developments. The principal noise source on the site - the existing

cooling towers and the existing drying tower were modelled. Both operate during the day and

during the night, and as a result the contribution of the existing facility will be similar during

both damme and night-time operation. The results of the model were compared with the

baseline results and compare well with the field measurements where results are not influenced by other noise sources (e.g. traffic), suggesting a reasonable degree of confidence in the

accuracy of the model calculations.

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13

Noise Measurement Location

NI

Estimated Contribution GIExisting Facility Operations

(Estimated by Calculation)

28

I - N 2 - 37 I N3 I 33 I

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EPA request 2(ii)

In relation to the two modelled scenarios for the prciposed plant expansion (i. e.

scenario 1 'with no mitigation' and scenario 2 'with mitigation 'please provide the

following: - -

a daytime and a night-time noise assessment for each of the two scenarios

a list of the mitigation measures proposed, with! information on the noise mitigation

expected to be associated with each.

Provide the proposed timefiame for implementation of measures to abate noise

emissions for existing and proposed noise generating plant and equipment

-

The specific noise level was calculated for six points surrounding the facility, coinciding with the locations of the baseline monitoring lot;ations, N1 to N6. The specific

noise level calculations are corrected for the presence of acoustic features, and compared to the

existing background levels. The basis of the assessment is outlined in EIS Table 3.7 Noise

Assessment Criteria.

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Scenario 1 - Daytime (No Mitigation Measures in Place)

Location Calculated Specific Noise Correction

Level

dB(A) dB

36 0 N1

43 0 N2

38 0 N3

49 0 N4

46 0 N5

55 0 N6

‘D

Rating Level

-(A)

36

43

38

49

46

55

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Back- Excess over

Baseline background Correction Rating Level ground baseline

dB (WA) L90 dB

dB(A)

Scenario 1 - Night-time (No Mitigation Measures in Place)

Assessment Location Calculated Specific Noise

N1 36

43 I N2 I 0 38 31

0 49 31 (48.)

0 46 31 (385

+7 MZXgiMl Impact

+18 Significant Impact

+I 5 Significant Impact

36 O I

31 (539

I 43 0

+24 Significant Impact

31 (47.)

-.

31 (40.)

+5

+12

Impact ~

Significant Impact

* The measured baseline background noise at N1 and at N6, were influenced by winds approaching the maximum optimum for noise measurement at 5 m/s ( wind speeds of between 3.5 - 4.5 m/s during measurements). PS a result the background noise levels are elevated above the 'true' background level, which is likely to be in the region of 30 - 35 dB(A). For a robust assessment the background noise levels (h) at NI and N6 was taken as 31 dB(A) for the assessment of impact.

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II II

Scenario 2 -Daytime (With Mitigation Measures in Place)

Back- Excess over ground baseline Baseline background

L90 dB

d W )

40 - 21

30 - 8

40 - 22

57 - 28

- 16

Assessment

1 No Si@icant

Impact

No Significant I Impact

References:

Kingspan. (2005). Acoustic Pedormance Guide - Insulated Roc$ WaN & Fapde Systems.

The Concrete Centre. (2005). Cutting D m Noise with Concrete andkfasonary Barriers. British Precast.

No Significant Impact

No Signifcant Impact

No Si@icant Impact


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13 Location Calculated Back-

Specific Noise Correction Rating Level ground Level Baseline

dB(A) dB W A ) L90

d B ( 4

N1 19 0 19 31 (47*)

N2 22 0 22 31 (40.)

N3 18 0 18 31

N4 29 0 29 31 (48.)

N5 25 0 25 31 (38.)

N6 36 0 36 31 (53*) li

Excess over baseline

background

dB

- 12

- 9

- 13

- 2

-6

+5

Scenario 2 -Night-time (With Mitigation Measures in Place)

The proposed mitigation measures for the Operational Phase are given below;

U

I Assessment


No Si&icant Impact


No Si@icant

No Significant

Mar@ 1 Impact

1. The existing drying tower will be retro-fitted with 100 mm insulated twin skin cladding

of insulated industrial cladding. For model purposes, the following noise reduction of the building wall was used, considered to be a conservative estimate of the acoustic

performance of the faqade cladding.

Requirement for acoustic performance for internal cladding.

* The measured baseline background noise at N1 and at N6, were influenced by winds approaching the maximum optimum for noise measurement at 5 m/s ( wind speeds of between 3.5 - 4.5 m/s during measurements). As a result the background noise levels are elevated above the 'true' background level, which is likely to be in the region d 30 - 35 dB(A). For a robust assessment the background noise levels (h) at N1 and N6 has taken as 31 dB(A) for the assessment of impact.

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2. The new drying tower building will be constructed with 250 mm concrete walls or

equivalent acoustic performance. For model purposes, the following noise reduction of

the building wall was used, considered to be a conservative estimate of the acoustic

performance of the wall.

Requirement for acoustic performance for building walls.

3. The existing cooling tower will be replaced in the first quarter of 2008 with a modem

low-noise emission design incorporating noise attenuation technology in the design of

the cooling tower.

The new cooling tower will include: - Baffled intake attenuator to attenuate mainly the noise generated by the

centrifugal fan. The large baffles are constructed with mineral wool plates for

optimized sound absorption.

Baffled outlet attenuator to attenuate spray noises and the sound generated by

the centrifugal fan. The large baffles are constructed with mineral wool plates

for optimized sound absorption.

-

This will be surrounded by an acoustic barrier to provide further noise protection. Thls barrier should be, as a minimum shall achieve the performance specified in IS EN 1793

Part 1 - 3, with minimum insulation performance ofB3 (IS EN 1793-2). These

mitigation measures have been developed to the outline state for the purpose of the EIS.

Detailed design will also be required prior to the specification and installation of the

cladding, including details of absorptive requirements to take account of reverberant noise within the building for employee health and safety, and to ensure that the design

meets the necessary performance requirements.

The proposed timeframe for implementation of measures to abate noise

emissions will depend on a successful outcome to bie current planning application and

will be determined by the timing of that outcome. If' the planning permission is granted

it is envisaged that the construction programme, including the installation of noise

abatement equipment will commence in the second half of 2008 and will be completed

within 18 months.

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EPA Export 25-07-2013:21:49:58

Appendix 2: Emissions to Surface Waters

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This section is in response to point no. 3 (Emissions to Surface Water) of the request for further information issued by EPA in relation to the EIS submitted.

i. Provide an assimilative capacity calculation for ortho-phosphate based on 95- percentile flow.

The assimilative capacity assessment included in the EIS and planning application was based on the mean flow. This is generally the approach taken by Fehily Timoney & Company with regard to this parameter, as it is considered the most reasonable. This approach has also been accepted by various local authorities in the past.

As requested by the EPA, however, the assimilative capacity calculation for orthophosphate based on 95 percentile flow has been included in the attached calculations .

It should be noted that the 95 percentile flow is considered to be excessively conservative and unrepresentative of the flow regime in place during the period in which the orthophosphate concentration is determined.

The reason that the mean flow, rather than the 95-percentile flow is used is as follows:

The median orthophosphate concentration (on which the Phosphorus Regulation limits are based) is provided by direct measurement of orthophosphate levels in the receiving waters over ten consecutive months, with a sample taken each month The median concentration therefore is taken during fluctuating flows The concentration on which the limit is based therefore is based on a flow regime nearer to the mean flow rather than the 95 percentile flow

In general therefore, FTC uses the mean flow to calculate the assimilative capacity of a water body with respect to orthophosphate. It is considered more appropriate that the mean flow is used since the orthophosphate concentration refers to a median value which is determined over a 10 month period.

Using the 95 percentile flow (0.83 m3/sec) the assimilative capacity of the river with respect to orthophosphate is 0.93 kg/day. At the proposed discharge rate of 2,400 m3/day, the maximum allowable orthophosphate concentration in the effluent is 0.39 mgA.

The assimilative capacity of the river, with respect to orthophosphate, in mean flow conditions (7.92 m3/sec) is calculated as 8.89 kg/day. The allow,able effluent concentration at the proposed discharge rate for this scenario therefore is 3.70 img/l.

Nutricia Ltd proposes to install phosphate reduction at the proposed wv\TTP, to reduce the levels of phosphate in the effluent. This treatment process will reduce phosphate levels to

' below 1 mgA, which is the current discharge limit. This is also well below the assimilative capacity limit with regard to orthophosphate estimated using the mean flow.

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ii. Show clearly what data were used as the C,, and CbacRllround inputs for the BODS assimilative capacity calculations. Provide a ma,p showing the location at which the BOD sampling was carried out and provide ai table showing the BOD ambient monitoring data at this location.

BOD sampling data is available from Cork County Council for Dromcarra and Bealahaglashin on the River Lee. These sampling points are situated upstream and downstream of the discharge point respectively. Figure 6.2 of the EIS shows the location of Dromcarra and Bealahaglashin. Table 1 overleaf tabulates the monthly BOD monitoring data at these locations from January 2004 to June 2006.

When calculating the assimilative capacity of the river the following formula is used:

Assimilative capacity [kglday] = 86.4 x: (C,,, - Cback) x F

The maximum allowable concentration (CmaX) of BOD is 5 mg/l as set by the Salmonid Regulations (S.I. No. 293 of 1988). Setting the background concentration (cback) equal to the average of the sampling data from Dromcarra (1.2 mg/l) and the flow in the river equal to the 95 percentile flow (0.83 m3/sec), the assimilative capacfly of the River Lee with respect to BOD is calculated as 272 kg/day. However, Memorandum No. 1 specifies that the concentration of BOD in a receiving water should not increase by more than 1 mg/l following discharge of an effluent (C, - Chck = 1 mg/l). Based on this guideline and using the 95 percentile flow, the assimilative capacity of the River Lee with respect to BOO is 72 kg/day. This more conservative scenario was incorporated into the EIS.

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EPA Export 25-07-2013:21:49:58

n Date 21 - J an4 61

Dromcarra Beala hag las hin 1.5

GJ

25-Fe b-04 18-Mar-04 15-Apr-04

Ll

cl .o <I .o 1.4

3

20-May-04 17-Jun-04

3

<I .o 1.2 1.3 1.3

Table 1 BOD monitoring data (mgll) in the vicinity of the outfall.

1 4-Jul-04 1 8-Aug-04

1.4 1.3

09-Se p-04 20-Oct-04

1.7 cl .o

17-NOV-04 16-Dec-04

1.4 cl .o 1.1 1 .o

19-Jan-05 16-Feb-05

<1 .o <I .o

13-Apr-05 1 1 -May-O5

1 .o <I .o

08-Jun-05 1 4-Jul-05

cl .o cl .o

21 -Sep-05 1 9-OCA-05 16-NOV-05 15-Dec-05 19-Jan-06 16-Fe b-06 23-Mar-06 12-Apr-06 17-May-06 14-Jun-06

1.4 2.3

cl .o 1.2 <I .o <I .o c l .o cl .o <I .o 2.1 <I .o c1.0 <I .o cl .o <I .o c1.0

1.6 2.1 1.4 1.4

3

I Average

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1.2 1.4

3

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iii. Provide all assimilative capacity calculation results in the following format: Assimilative capacity (both concentration and &@day), existing discharge (both concentration and k@day) and proposed discharge (both concentration and Wdaf i .

Revised Assimilative Capacity Calculations are attache!d. Table 2 below summarises the results of the calculations.

Monitoring of the effluent discharging from the plant took place in May 2007. The average values from this data is used as the existing discharge in the calculations. The average volume of effluent discharged daily during the monitoring period was 892 m3/day. The proposed discharge was taken as the discharge licence limits of each parameter at the increased flow rate of 2,400 m3/day.

As can be seen from the calculations and the table overleaf, with the exception of the licensed and proposed orthophosphate all parameters are significantly below the allowable concentrations and loads set by the assimilative capacity of the river.

Using the 95 percentile flow, as requested by the EPA, 1:he assimilative capacity of the river with respect to orthophosphate is limited. At the proposed discharge volume of 2,400 m3/day, the eftluent treatment standard required for orthophosphate is 0.39 mgA. This very stringent treatment standard and the treatment process required to attain this level of treatment is very expensive.

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Table 2 Summary of Assimilative Capacity Results

ii 892 m3/day Licenced - Discharge @ 1,500

BOD Actual Existing Discharge @ a ~

3 80 1 1 3 72 I 892 m3/dav Licenced Discharge @ 1,500 72

72

~. 1 Actual Existing Discharge @ 16 1675 892 m'lday Licenced Discharge @ 1,500

~ 1117 I 38 1675 25 -

m3/d ay Proposed Discharge @ 2,400 m3/dav 25 698 1 60 1 1675

Ammonia (as N) Actual Existing Discharge @ 892 m3/day Licenced Discharge @ 1,500 m3/day Proposed - Discharge @ 2,400 m'lday Nitrates las NO4 It I

I Actual Existing Discharge @ - - 892 m3/day (NO3) Actual Existing Discharge

0 495 743

15a I 310 1 36a I 743 1 m3/day Notes: a - These figures relate

'I Total Nitrogen as no reference is made to Nitrates in the Discharge Licence. 13

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EPA Export 25-07-2013:21:49:58

Nutricia EIS Job NO: CEO7-60141

Assimilative Capacity Calculations in response to the RFI

Date

21Jun-0

Calculation Set No:: 2

Purpose and Description

Salculations in response to the request for ’urther information following the assimilative :apacity calculations of the River Lee at the ocation of the discharge outfall

Prepared

CBC

Checked

DMcH

Approved

Fehily Timoney Co. Core House

PouladuR Rd. cork

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EPA Export 25-07-2013:21:49:58

Checked by: DMcH Rev: 0 Date: 21-Jun-07 Calc. set nr.: 2

'ROJECT: EIS for Nutricia IOB NO: CE07-60 1-01

IESCRIPTION: Assimilative Capacity Calculations for the Request for Further Information (RFI)

Ref. Page 1 of 12

references I Phosphorus Regulations (S. I. No. 258 of 1998) 2 Memorandum No. 1, Water Quality Guidelines, DOE 3 Salmonid Waters Regulations (S.I. No. 293 of '1988) 4 Surface Water Regulations (S.I. No. 294 of 1989) 5 www.opw.ie/hvdro 6 www. eDa. ielPublicAuthoritvServicesRtvdrometricProQrammeandSurfaceW~

7 Nutricia Effluent Monitoring Data, May 2007 8 Discharge Licence 9 2006-524-01, LA-NEE-CalcOl-Assimilative Capacity RevB

10 Cork County Council Environmental Laboratory

i List of Attachments to these Calculations None

ii List of Drawings None

I Table of Contents 1 Introduction & Purpose 2 Background 3 River Flow Calculations 4 Assimilative Capacity Assessment 5 Design Recommendations

C:tDocuments and SettingsParentalsVI Settings\Temporary Internet Files~ntent.lE5~PG\OPGNOR4NU-NElS~CalcO2~Calcs for RFl-RevO[l].xls

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EPA Export 25-07-2013:21:49:59

Prepared by: CBC Total no of pages: 12

Date:

Checked by: DMcH Rev: 0 21-Jun-07 Calc. set nr.: 2

tOJECT: EIS for Nutricia )B NO: CE07-60 1-0 1

:SCRIPTION: Assimilative Capadty Calculations for the Request for Further Information (RFI) - Ref.

8

of 12 Page 2

0 Introduction and Purpose

slculation set CalcOl was submitted previously (under job number 2006-524-01) dermining the assimilative capacity of the River Lee for 8 proposed extension to a airygold facility. lese calculations (Calc02) are in reponse to a request for further information (RFI) sued by the EPA. Section 3 of this RFI is in relation to the emissions to Surface 'ater. These calculations address this section of the RFI.

,O Background

l e site is located approximately 3.5 km south of Macroorn town in County Cork at lchinashingane off the N22 (Cork to Killarney road).

he plant was acquired by Dairygold in 1990 and by Nutricia in 1995. Dairygold ha mtinued to be associated with the activities on the site and announced in Octobc 306 its intention to purchase the Nutricia operations.

airygold have retained Fehily Timoney 8 Company to prloduce an EIS for the ctension of the facility.

he proposed extension at the site will allow the facility to process the surplus milk om the Dairygold process, which is currently exported off site, into baby powder.

he existing plant was issued a revised effluent discharge licence from Cork County .ouncil in 2006 to discharge 1,500 m3 per day of treated effluent to the River Lee. Th ible below lists the limits for each parameter under the current discharge licence.

Parameter nu

25 mg/l

ri Biological Oxygen Demand (BOD) Total Suspended Solids Oils, Fats, Greases Detergents Total Phosphorus as Phosphorus (P) Ortho Phosphate as Phosphorus (P) Total Nitrogen (N) Ammonia as Nitrogen (N) Mineral Oils

- output

C:U)ocuments and SettingsParentalsVocal Settings\Temporary Internet Files\Content.lE5\0PGVJOR4N\LA-NElS-Cal~-~l~ for RFI-RevO[l ].XIS

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EPA Export 25-07-2013:21:49:59

w

21-Jun-07 Calc. set nr.:

PROJECT: EIS for Nutricia JOB NO: CE07-601-01

DESCRIPTION: Assimilative Capacity Calculations for the Request for Further Information (RFI) [

C:\Dacuments and SetthgsParentalsLocal Settings\Temporary Internet Files\Content.lES~~UIPGNOR4NUA-NEIS_Calc02 for RFl-RevO[l]ds

19

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EPA Export 25-07-2013:21:49:59

Prepared by: CBC Checked by: DMcH

Total no of pages: 12 Rev: 0

?OJECT: EIS for Nutricia >B NO: CE07-60 1-0 1

ESCRIPTION: - Ref.

7

Assimilative Capacity Calculations for the Request for Further Information (RFI)

of 12 Page 3

The construction of the proposed extension will increase the discharge volume from 1,500 m3/day to 2,400 m3/day.

The effluent discharging to surface water was monitored during May 2007. The table below gives the average values measured during this moriitoring period. The weekly monitoring data (main table on the results sheet) are used in these calculations for Orthophosphate, Ammonia, Total Nitrogen and Nitrates.

The average volume discharged during the month = 892 m3/day

Average Parameter (rngll) pH 8

Suspended Solids 17.45 Orthophosphate (as P) 0.865 Total Nitrogen 12.5 Ammonia (as N) 0.6 Nitrates 48

BOD 3

k m e n t s I Measured dail Measured dail

- output

C:\Documents and SettingsParentalsLod Settings\Ternporary Internet Files\Content.lE5U)PGNOR4NUA-NElS-Ca~2-Cal~ for RFl-RevO[l]xls

/ , do

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EPA Export 25-07-2013:21:49:59

w

21-Jun-07 Calc. set nr.:

PROJECT: EIS for Nutricia JOB NO: CE07-60 1-0 1

DESCRIPTION: Assimilative Capacity Calculations for the Request for Further Information (RFI)

I I

C:\Documents and Settings\ParentalsVl Settings\Temporary Internet FilesX=ontent.lES\OPGNOR4NUA-NElS~Cal~~Cat~ for RFI-RevOIl ]As

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EPA Export 25-07-2013:21:49:59

Prepared by: CBC Total no of pages: 12 Checked by: DMcH Rev: 0 Date: 21-Jun-07 Calc. set nr.: 2

'ROJECT: EIS for Nutricia IOB NO: CE07-60 1-0 1

IESCRIPTION: Assimilative Capacity Calculations for the Request for Further Information (RFI) - Ref.

9

Page 4 of 1; 3.0 River Flow Calculations

Vo hydrological data is available for the River Lee in the vicinity of the outfall. Two gauging stations were operated by ESB at Lee Bridge (u/s8) and Bealahaglashan 3ridge (d/s) in the past but have since become obsolete. The 95 percentile flow (F95) and the mean flow for the river in the vicinity of the outfa Nil1 therefore be estimated using other hydrological data available on the River Lee.

The following flow rates were calculated (in Calculation Set 01) as the flow in the rive! it the discharge point:

95 percentile flow Mean flow

- - 0.83 m3/sec - - 7.92 m3/sec

1.0 Assimilative Capacity Assessment

-he assimilative capacity (AC) of a river determines the maximum discharge that cas ,e tolerated by the river without deteriorating the quallty of the river water.

issimilative capacity [kglday] = 86.4 x (Cma - CMk) x F

vhere C,, = maximum permissible concentration [mg/l] Chck = background (upstream) concentration [:mg/l] F = the flow in the receiving waters [m3/s] 86.4 = conversion factor.

ihe 95 percentile flow (Fe = 0.83 m3/s) is used in the calculations below, thi epresents a low flow, ensuring a high level of compliance for the resulting prescribe1 issimilative capacity.

- output

C:\Documents and SettingsParentalsVI Settings\Temporary Internet Files~ntent.lE5\OPGNOR4NVA-NElS~Cal~2~Cal~ for RFI-RevO[l].xls

1. j

aa

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EPA Export 25-07-2013:21:49:59

IO I Q

IO

Prepared by: CBC Total no of pages: 12

Checked by: DMcH 2 Date: 21-Juri-07 Calc. set nr.:

Rev: 0

3JECT: EIS for Nutricia 3 NO: CE07-601-01

SCRIPTION: Assimilative Capacity Calculations for the Request for Further Information (RFI)

I ief. '

Page 5 of 12 I

1 10

I

4.1 Phosphates

0.83 m3/sec F = 95 percentile flow Cmax (based on a target Q rating of Q 4-5) = 0.02 mgll P Cback = MRP-Phosphate at Dromcarra Br = 0.007 mgll P

- -

Assimilative Capacity Phosphate Assimilative Capacity (based I on 95 Dercentile flow) 0.93 kglday P - - Allowable Concentration of Phosphate in the effluent Q discharge volume of 892 m3/day 1.04 mgll P

Allowable Concentration of Phosphate in the effluent Q discharge volume of 1,500

0.62 mgll P m3/day Allowable Concentration of Phosphate in

- -

the effluent Q discharge volume of 2,400 I m3/day 0.39 mgll P - -

The 95 percentile flow is considered to be excessively conservative and unrepresentative of the flow regime in place. It is considered more appropriate that tt' mean flow is used since the phosphate concentration refers to a median value. Therefore, if the annual mean flow (7.92 m3/sec) was used in this calculation in plaa of the 95 percentile flow the results would be as follows:

8.89 kglday P Phosphate Assimilative Capacity (based on mean flow) Allowable Concentration of Phosphate in the effluent Q discharge volume of 892 m3/day Allowable Concentration of Phosphate in the effluent Q discharge volume of 1,500 m3/day Allowable Concentration of Phosphate in the effluent Q discharge volume of 2,400 m3/day

- -

9.97 mgll P - -

5.93 mgll P - -

3.70 mgll P - -

- - lutput

osphat AC

0.93

glday F

C:\Documents and SettingsParentalsVol Settings\Temporary Internet Files\Content.lE5U1F'GNOR4NVA-NElS-Cal~2-Cal~ for RFI-RevO[l]As

c s L 3

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I

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EPA Export 25-07-2013:21:49:59

U

D

U

Prepared by: CBC Total no of pages: 12 Checked by: DMcH Rev: 0 Date: 21-Juri-07 Calc. set nr.: 2

'ROJECT: EIS for Nutricia IOB NO: CE07-60 1-0 1

IESCRIPTION: Assimilative Capacity Calculations for the Request for Further Information (RFI) - - Ref.

7

-

3istina Discharae 3isting concentration of Phosphate in the !ffluent 4t a discharge rate of 892 m3/day, the ?xisting load of Phosphate in the effluent

.icenced Discharae

.icenced concentration of Phosphate in he effluent it a discharge rate of 1,500 m3/day, the !xisting load of Phosphate in the effluent

'roDosed Discharae 'roposed concentration of Phosphate in he effluent it a discharge rate of 2,400 m3/day, the xoposed load of Phosphate in the effluent

6 of 12

0.87 mgll P

0.77 kglday P

1 mgll P

1.5 kglday P

1

2.4

mgll P

kglday P

output

< AC

> AC

> AC

C:\Documents and Settings\ParentalsVocal Settings\Tempomry Internet Flles\Content.lE5\0F1GNOR4NVA-NElS-Cal~2-~l~ for RFI-RevU(l].xls

a+

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EPA Export 25-07-2013:21:49:59

U

3 10

U

Page 7 of 12 4.2 BOD

F = 95 percentile flow - - 0.83 m3/sec Cmax - - 5.0 mgll Cback = BOD at Dromcarra Br - - 1.2 mgll

,

B

21-Juri-07 Calc. set nr.:

BOD Assimilative Capacity = 86.4 x (5.0 - 1.2) x 0.83

272.05 WdaY - -

However, Memorandum No. 1 states that the concentratim of BOD in the waterbody is not to increase by more than 1 mg/l following the discharge of effluent, i.e. Cmax- Cback = 1 mgll. This figure is used in these calculations in place of 3.8 (Cmax-Cback = 5.0 - 1.2 = 3.8 mgll) as it is more conservative.

BOD Assimilative Capacity = 86.4 x 1 x 0.83

71.59 kglday - -

Assimilative Capacity BOD Assimilative Capacity Allowable Concentration of BOD in the effluent Q discharge volume of 892

71.59 kglday - -

80.26 ms/l - - le Concentration of BOD in the

effluent Q discharge volume of 1,500 47.73 mgll - -

le Concentration of BOD in the effluent Q discharge volume of 2,400

29.83 mg/l - -

Existinq Discharae Existing concentration of BOD in the

At a discharge rate of 892 m3/day, the existing load of BOD in effluent - 2.68 kglday

3 mgll - - -

C:\Documents and SettingslParentalsVI Settings\Temporary Internet Files\Content.lE5~K(;NOR4NVA-NEIS_CalcO for Rfl-RevO[l]xls

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EPA Export 25-07-2013:21:49:59


'RO J ECT: EIS for Nutricia OB NO: CE07-601-01


Ref

Licenced Discharae Licenced concentration of BOD in the effluent At a discharge rate of 1,500 m3/day, the existing load of BOD in the effluent

Proposed Discharae Proposed concentration of BOD in the effluent At a discharge rate of 2,400 m3/day, the Droposed load of BOD in the effluent

Page 8 of

10

15

10

24

rngll

kglday

rngll

kglday

12

- output

c AC

e AC

C:\Documents and SettingsWarentalsVocal Settings\Temporary Internet F~~~~\C~~~~~~.~ESU)PGNOR~NVA-NEIS-C~~CO-C~ICS for RFI-RevO[l]xls

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EPA Export 25-07-2013:21:49:59

.. . -. .. .. .

3 10


F = 95 percentile flow Cmax Cback = SS at Drorncarra Bridge =

'ROJECT: EIS for Nutricia IO6 NO: CE07-60 1-01

7


Existing concentration of SS in the effluent At a discharge rate of 892 m'lday, the existing load of SS in the effluent

Licenced Discharae Licenced concentration of SS in the effluent At a discharge rate of 1,500 m3/day, the existing load of SS in the effluent

Proposed Discharae Proposed concentration of SS in the effluent At a discharge rate of 2,400 &day, the proposed load of SS in the effluent

Ref I 4.3 Suspended Solids (SS)

Assimilative Capacity SS Assimilative Capacity Allowable Concentration of SS in the effluent Q discharge volume of 892 m3/day Allowable Concentration of SS in the effluent @ discharge volume of 1,500 m3/day Allowable Concentration of SS in the effluent Q discharge volume of 2,400 m3/day

Existina Discharqe

9

0.83 25 1.6

1675.23

1878.06

11 16.82

698.01

17.45

15.57

25

37.50

25

60

of

rn3/sec rngll mgll

kglday

mgll

ms/l

mgll

ms/l

kglday

mgll

kglday

mgll

WdaY

12

- output

SS AC 1675

kglday

e AC

e AC

c AC

C:Wuments and SettingsParentalsVocal Settings\Temporary Internet Files\Content.lE5\0FGNOR4NLA-NEIS-Cal~-Cal~ for RFI-RevO[l]Jds

' ,P 27 '

I

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EPA Export 25-07-2013:21:49:59

lil

4.4 Ammonia

F = 95 percentile flow

Cmax (Ammonium) (Ammonia)

Cback = Ammonium at Dromcarra Bridge

(Ammonia)

Assimilative Capacity Ammonium Assimilative Capacity Ammonia Assimilative Capacity Allowable Concentration of Ammonia in the effluent Q discharge volume of 892 m3/day Allowable Concentration of Ammonia in the effluent Q discharge volume of 1,500 m3/day Allowable Concentration of Ammonia in the effluent @ discharge volume of 2,400 m3/day

Existina Discharae Existing concentration of Ammonia in the effluent At a discharge rate of 892ma/day, the existing load of Ammonia in the effluent

Licenced Discharpe Licenced concentration of Ammonia in the effluent At a discharge rate of 1,500 m3/day, the existing load of Ammonia in the effluent

Proposed Discharae Proposed concentration of Ammonia in the effluent At a discharge rate of 2,400 m3/day, the proposed load of Ammonia in the effluent

IO IO IO

IU


'ROJECT: EIS for Nutricia OB NO: CE07-60 1-0 1


Ref

3

10

7

10

0.83 1

0.78 0.036 0.028

69.01 53.50

59.98

35.67

22.29

0.6

0.54

0.5

0.75

0.5

1.2

of 12

m3/sec mgA NH4 mgll N

mgll NH4 mgll N

kglday NH4

kglday N

mgll N

mgll N

mgll N

mgll N

kglday N

ms/l

kglday

mgll N

kglday N

- output

slecular mast ivenion P18)

Ammonia A C

53.50 kglday N

AC

A C

A C

IO C:Wuments and SettingsParentalsVocal Setb'ngs\Temporary Internet Files\Content.lES\OPGNOR4NVA-NEIS_Calc02 for RFI-RevO[l)&

39

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EPA Export 25-07-2013:21:49:59

Q

U

U


'ROJECT: EIS for Nutricia IOB NO: CE07-601-01


- Ref

4 EPA

7

4.5 Nitrates

F = 95 percentile flow Cmax Cback = Nitrates at Dromcarra Bridge

Assimilative Capacity Nitrates Assimilative Capacity Allowable Concentration of Nitrates in the effluent Q discharge volume of 892 m31day drllowable Concentration of Nitrates in the effluent Q discharge volume of 1,500 m31day Nlowable Concentration of Nitrates in the effluent @ discharge volume of 2,400 m3/day

Existina Discharae Existing concentration of Nitrates in the effluent 4t a discharge rate of 892 rnulday, the existing load of Nitrates in the effluent

Licenced Discharae

11

0.83 50

4.05

3289.61

3687.90

2193.07

1370.67

48

42.82

of 12

m3/sec mgll NO3 mg/l NO3

kg/day NO3

mg/l NO3

mg/l NO3

mg/l NO3

mg/l NO3

kg/day NO3

The current discharge licence specifies an effluent limit of 15 mg/l for Total Nitrogen. No specification is made in the licence regarding allowable Nitrate discharge limi A k i E

15 - - Licenced concentration of Total Nitrogen in the effluent At a discharge rate of 1,500 rn'lday, the licensed load of Total Nitrogen in the sffluent - 22.50 -

Proposed Discharae proposed concentration of Total Nitrogen n the effluent - 15 -

output

Jitrates AC 3290

;g/day NC

< AC

mg/l

kg/day

Total Nitrogen

mg/l N

F:U-NElS-CalcOZ-Catcs for RFl-RevO(l).xls

li

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EPA Export 25-07-2013:21:49:59

II- 0 Prepared by: CBC Total no of pages: 12

Checked by: DMcH Rev: 0 Date: 21-Jun-07 Calc. set nr.: 2


DESCRIPTION: Assimilative Capacity Calculations for the Request for Further Information (RFI)

At a discharge rate of 2,400 m’lday, the proposed load of Total Nitrogen in the effluent 36 kglday N - -

C:\Documents and SettingsParentalsVocal Settings\Temporary Internet Files\Con~nt.lE5\oFINOR4NWSJEIS_Calc02_ for RFI-RevO(l].xls

30

n

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EPA Export 25-07-2013:21:49:59

;il i0

I G S

, o ' j

Total no of pages: 12 Prepared by: CBC Checked by: DMcH Rev: 0 Date: 21-Jun-07 Calc. set nr.: 2


output -

Page 12 of 12 i.0 Design Recommendations

4s can be seen from the calculations, with the exception of orthophosphate, all ,arameters are significantly below the allowable concentrations and loads set by the issimilative capacity of the river.

Jsing the 95 percentile flow, as requested by the EPA, the assimilative capacity of the iver with respect to orthophosphate (0.93 kg/day P) is inadequate to assimilate the lischarge of treated effluent w.r.t. orthophosphate for an extended plant (2.40 kglday '). However, it is not considered appropriate to use the 95 percentile flow for :alculating the assimilative capacity w.r.t. orthophosphate as this flow is considered tc ,e excessively conservative and unrepresentative of the flow regime in place during he period in which the orthophosphate concentration is determined.

kcordingly, the assimilative capacity w.r.t. orthophosphate has been assessed usinl he mean flow. Using this methodology, the assimilative capacity is 8.89 kglday F vhich is more than adequate to assimilate the discharge of treated effluent.

C:\Documents and SettingsParentalsVoI Seltings\Temporary Internet Files\Content.lE5U)PGNOR4N\LA-NElS-Cal~2-Cal~~ for RFI-RevO[l].xls

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EPA Export 25-07-2013:21:49:59

Roiul

DlUllslm L I OmmCM. Le. Dmncsm L u Dmmcana LW mmmm Le. h D m m Le. Draun Lea Dromumn LW h c u n L U Dmmcana L w R m r a n s Lea Draun L w D m ~ o m L n Dmmt.na Le. a D m m Lea D m m m L u Dmmmm Lee D m m u n Lea h s l m LO. Dmmt.na Leo hmDon L u MDrmm L u Dmmtaa L.. Dmnxllna Lee Dmmssm LW Dmmcana L u Dmmcam L u homm Lee Dmmcsm LW Romsa LOS

0.048 0,028 0.041 0.076 0.068 0.053 0.028 0.028 0.043 093 0.028 0.051 0.028 0.028 0.028 0.028 0.020 0.028

0.028 0.028 0.m 0.026 0.028 0.047 0.027 0.028 0.028 0.028 0.048

0.030 DmmCm Amlwnhm

o.mi

0.063 0.056 0.028 0.044 0.08 0.138 0.028 0.028 O.iO3 0.038 0.296 0.m 0.W 0.026 0.047 0.028

0.036 0.028 0.06 0.048 0.078 0.036 0.038 0.044 0.067 0.028 0.028 0.08 0.07

0.058 baMld&l knmorlun

0.013 0.013 0.018 0.02

0.018 0.026 0.013 0.014 0.014 0016 0914 0926 0.018 0.015 0.013 0913 0.015 0.014 0.024

0.013 0.018 0.021 0.028

0.028 0,013 0.013 0.016 0.036

0118 Dmmun

Ndh

0.021

mdl 0.051 0.021 O.Oi8 0.02 0.m 0.08

mdl ma4 1.6 1.1 1 1 1 2

1.4 1 1.2 1

1.3 1.3 1.4 1.3 2 1 2.1

1.7 2 I

Ins! 1 1

PH unh 7.4 7.6 7.3 7.8 7.8 7.7

1 3 7.8 8 1 1 7.4 7.4 1 1 7s 7.7 1 1 7.6 7.6 1 2 7.6 7.8 2 1 7.8 7.7 1 1 7a 7s 1 1 7.4 7.6 1 1 7.8 7.7 1 1 7.7 7.7 I 7.7 1 1 7.4 7.4 1 s 7.8 8.0 1 1 7.8 8 2 2 7.0 79 1 2 7 7

md 1 2 2

1 .8 4

P H d md 7.4 8.8 7 2 7.4 7.7 7.6

U 0 2 86

8 8 6 3 88 87

8.84 7.16 4.76 4.34 4.01 5.87 1 .8 1 .n 2.28 3.23

7.86 10.84 6.29 8.36 3.81 6.38 2.17 1.77 2.68 4.66 8.84 6.08 8.84 6.48 8.84 391

2.23 3.6

s 1.8 i

0.m 0.011 0.008 0.008 0.011 0.m 0.W8 0 . m 0.m 0.008

10.7 82 8.6 8 8 2 8.7 8.3 8.8 1 i 2 8.8 8.8 11

11.3 10.1 11 10.8

112 11.0 11.7 11.8 11.7 10.8 12.1 11.2

108 64 5089

88 83 101 84 (00 88 101 81 88 82 85 88

881 101

108 87 101 87

lo8 1M 101 80 80 87 128 107 101 86 100 81 86 88 82 e 6 8 0 8 6 8 5 88 87

08 102 113 101 e 6 8 6 (10 88

I 1

0.022 0.058 0.023 0.148 0.036

0.017 0.027 0.018

0.022 0.068 0.108 0.018 0.062

0.036

0.024 0.021 0.022 0.W 0.06

0.051

o m

aow nowmd=M

Nbb(mm

628 3.28 4.76 4A4 3 . w 4.08 422 1 .B1 3.11

l’a i 1.1 1 1 1 i 1 1 1.2 1 1.1

0.007 0.007 0.m 0.m 0.007 0.m 0.m 0.011 0.008 0.008 0 . m 0.m 0.m 0.007 0.018 0.011 0.011 0.008 0.008

1 1 1 2.2 1.3

1.6 1 1.4 2.5 1 1 1 1 1 1 1 1 2.1 1 1 1 1

1.8 1 2.1 1

1 1 1.4

1.2 1.4 DmmcamBesgh.rda

BOD BOD

1.77 4.68

i .77 7.20

2 i 72 7 3 1 1 7.3 7.4 3 3 7.3 7.3

11.7 11 112 10.8

11.4 11.3 12.1 12.6

12.7 8.8 11.8 8.8 10.8 8.7

Dmmcana- ioa ioA $00 97

Do DO

6.73 7.37 5.38 2.21 4.1

4.05 DlWltWla

Nbab

4.66 8.37 7.81 2.8 6.8

6.42 b&mlkhh m (d

0.007 0.011 0.m 0.008 0.008 0.m 0.008 0.016 0.008 0.006

0.m W O Dmncm Bealdlwduhi h.ph.D hrpM.

( m o m - (Mohlbw- R-) Raaclb)

4 1 7.3 7 2 1 1 7.6 7.8

4 1 7 1 7.7 7.8 7.7 7.8 1 1 0.2 7.8

ia 1.7 7.3 7.8 Dmncmm8.ohh.alaDmmcrn-

SS ss M D H w w

- - I - I I I

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EPA Export 25-07-2013:21:49:59

Station Station Name Number Location 1981 1986 1990 1994 1997 1999 2002

Dromcarra Br 0300 UIS 5 4-5 5 4-5 4-5 4 4 Toon Br 0800 uls 3-4 3-4 3-4 3-4 4 Laney Br 0500 uls 4-5 4-5 4-5 4-5 Athsollis Br 0800 dls 3-4 4 4 4 3-4

2005

4 4

4-5 3-4

Station Station Name Number Location 1990 1994 1997 1999 Dromcarra Br 0300 uls 5 4-5 4-5 4 Toon Br 0800 uls 3-4 3-4 3-4 3-4 Athsollis Br 0800 dls 3-4 4 4 4

2002 2005 4 4 4 4 3-4 3-4

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I B Appendix 3: Emissions to Air

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EPA Q. 4: Emissions to Air

0) For each combination of two boilers proposed to operate at any one time (as given in Table 4.19, 4.20 and 4.21 of the EIS), Provide the maximum predicted ground level concenl;rations of NO2 (hourly and annual), NO, (annual) and particulate matter (24 hour and annual). Specifi the thermal input rating of existing and proposed boilers (ii)

The emissions measured from the boilers by Pillinger on 29h August 2006 were expressed as

N&. These were modelled using AERMOD to predict maocimum ground level concentrations

for the existing facility and the proposed facility.

In response to the above request, to provide maximum predicted ground level concentrations

for NO2 (hourly and annual) for hture operations at the fadity, the Horizontal Guiknce Note

(IPPC HI) - Environmental Assessment and Appraisal of BAT was referenced for the

calculation of NO2 emission from NO, emissions. This document sets out a methodology for

calculating NO2 emissions from NOx as follows:

- short term emissions; convert all measured or estimate nitrogen oxide emissions to NO2

and assume 50% of this value as the short term NO2 emissions

Long term emissions: convert all measured or estimated nitrogen oxide emissions to NO2

and use this value as the long term emission

-

The assessment of boiler emissions in the EIS for future activities at the site included the

Maxecon Boiler. This boiler will now be replaced with a more efficient boiler. The emissions

from this new boiler are expected to be similar to that of the proposed boiler included in the

original assessment. Therefore the emissions for this new scenario are presented below in

Table 1 and 2 below.

Table 1 outlines the emissions for the new boilers. These are based on the specification

provided by the boiler manufacturer.

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Table 1: Maximum Emissions for the Two Proposed Boilers

CO 300 133.54 particulates 250 111.3

*Corrected to 3% ovgen, temperature 273K, Pressure 101.3kPa, diy ,gas ** Uncorrected for 5.54% oxygen and 252.3OC

Particulate emissions from the Robey boiler were not recorded by Pillinger during sampling

events. Therefore, for the purpose of th~s modelling exercise, it is assumed that particulate

emissions from the Robey boiler are the same as those from the proposed boilers.

The physical parameters used in both scenario 1 and 2 are detailed in Table 2.

Table 2: Summary of Exhaust Stream Parameters from the on-site Boilers

Robey Boiler 35.85 1.17 25,582 294 RoPo=d 35.67 1 27,360 252

Boiler

Roiler propo=d 35 1 27,360 252

Outputs from the model are compared with the limits set out in S.I. No. 271 o f 2002 - Air Quality Standards Regulations.

Therefore, two modelling scenarios were carried out as part o f this exercise:

0 Modelling of emissions from the two proposed boilers operating on high fire 0 Modelling of emission from a proposed boiler and the Robey boiler operating on high

fire

The results of the two modelling exercise is presented below:

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Table 2: Results of Two Proposed Boilers Operating on High Fire

*This limit comes in to force in 2010

Table 3: Results of Robey EL Proposed Boiler Operating on High Fire

"This limit comes in to force in 2010

The modelling exercise of future operations at the Nutrida! facility indicate that the NO*, NO, and particulate emissions from the boilers on-site will be in compliance with the limits sets out in S.I. 271 of 2002 - Air Quality Standard Regulations 2002.

The thermal input ratings o f existing and proposed boilers are given in Table E.l(i) of lthe completed Application Form. They are;

Al-1 (Robey boiler): 12.98 MW A1-2 (Proposed boiler): 13.88 MW A1-3 (Proposed replacement boiler): 13.88 MW

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Appendix 4: Non-technical Surnmary

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Nutricia Infant Nutrition Ltd., Castleview, Macroom, Co. Cork, is a modem food processing plant engaged in the manufacture of milk powder for formulation into infant milk

products. The plant is located on a well-maintained 45-acre site in a rural area about 3 km south

of Macroom. Built in 1979 on what was then a green-field location, the processing plant is

strongly integrated into the local economy, being supplied by milk from about 500 farms. It

currently employs 69 people working on average 42-hour weeks in a 4-shift production cycle.

The plant operates 48 weeks per year. It was acquired by CPairygold in 1990 and by Nutricia in

1995. Dairygold has continued to be associated with the activities on the site through the

operation of milk assembly, intake, separation and pasteurisation processes. Dairygold Food

ingredients Ltd. announced its intention to purchase the Nutricia operations and lodged a

Planning Application with Cork County Council for the fume development of the facilities

(File No. 068531). The Council granted permission on 22 April 2007 and it was appealed to An

Bord Pleanala on 21 May 2007.

This IPPC licence application takes account of bo&t the existing and planned operations

on the site and incorporates the results of the Environmental Impact Statement (EIS) which

accompanied the Planning Application.

The main activities currently carried out on site are the delivery of whole milk by road

tankers, its reception, pasteurisation and separation into skim milk and cream by Dairygold, the

processing of the skim milk into Infant Milk Formula by Nutricia and the despatch of the cream

and surplus milk for processing elsewhere. Nutricia currently processes about 10 million

gallons of skim milk annually, as well as skim powder, whey concentrate, lactose, vegetable

oils, minerals, vitamins and other ingredients. The processing operations include heat treatment and evaporation, blending-in of vegetable oils and other ingredients, homogenisation of the mix, drymg, sieving and packing. The plant currently produces about 4 tonnes of milk powder

products per hour, or 27,000 tons annually. The product is packed into one-tonne FIBC's

(flexible intermediate bulk containers) and despatched to other Nutricia plants for consumer packing

The proposed development at the site, which is the subject of the current Planning

Application, involves the processing into infant formula powder at Nutricia of surplus milk

from the Dairygold operations on site which was previously sent to other plants for furd.ler

processing.

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The workforce will increase from 69 to about 100 and operating hours will remain 48

weeks per year. It is proposed to install a second dryer to double the drying capacity from 4

tonnes to 8 tonnes per hour. It is therefore proposed to erect a second drying tower and

evaporator building and to extend the powder storage building to accommodate the increased

production capacity. The proposed extension will incorporate best environmental practice,

enhancing the environmental protections already in place at Nutricia. The development will

include in particular the following: - erection of a second dryer, drying tower and evaporator building to double

the drylng capacity from 4 tonnes to 8 tonnes per hour - installation of bag-house filters in both the existing and proposed dryers

- construction of a new milk intake area including silos and bunding: milk

silos which are at present unbunded will be relocated to the newly

constructed bund, enhancing existing secondary containment.

new bunding will be constructed for the vegetable oil intake area and its associated

storage silos. - the existing effluent treatment plant, incorporating best available techniques, will be

upgraded and extended to cater for increased production

-

Water for the Nutricia plant is supplied from the nearby Carrigadrohid Reservoir by

agreement with the ESB. Treated wastewater and clean surface waters are returned to the same

Reservoir under a Licence issued by Cork County Council. The plant currently has two boilers, both using heavy fuel oil, each with thermal inputs

of about 13 MW and nominal steam capacities of 17,000 k g h . The planned development of

the site involves the continued operation of the Robey boilcr (ref Al-1: ‘Robey boiler’): the installation of a second Maxecon boiler (ref. A1-2: ‘proposed boiler’) with the same

specifications as the existing Maxecon, and the replacement of the existing Maxecon boiler

with a model of identical specifications (ref. A1-3: ‘replacement Maxecon boiler’) for standby

use only. Only two boilers will be in operation at any time.

The boiler exhaust gases contain the usual mix of combustion products from the fuel

used, including carbon dioxide (C&), sulphur dioxide (SO:!) and oxides of nitrogen (NO,).

Typical levels measured at Nutricia in a recent survey were:

SO5 1,530 - 1,560 mg/m3 NO,: 700 - 900 mg/m3

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Longer-term emission levels are expected to comply with the normal limits set by EPA in IPPC

licences for heavy fuel oil boilers, viz:

Sulphur Dioxide (as S02): 1,700 mg/m3

Nitrogen Dioxide (as NO2): 900 mg/m3

Particulates: 200 mg/m3

The relatively wide variation in measured NO, levels at Nutricia reflects the normal

range of combustion conditions in heavy fuel oil boilers. The heights of the boiler stacks, just

over 35 metres, are designed to disperse the exhaust gases so as to have no adverse impact at

ground level beyond the site boundary. No such adverse impact has been recorded in twenty

five years of operation at the site. As part of the EIS study mathematical modelling was carried

out of the planned boiler emissions and the modelling predicted no adverse impact from future

operations. The continued use of heavy fuel oil is essential to the commercial viability of the

Nutricia operation.

The emissions from the existing dryer are currently directed through a series of

cyclones to capture as much as possible of the milk powden- present. Nutricia have

commissioned Teagasc to carry out regular surveys of the t h u s t air from the dryers to ensure

that the powder capture is as efficient and effective as possible. As with all milk drying

operations the efficiency of powder capture is determined to a significant extent by the nature

of the material being dried, whether whole milk, skim milk or whey-based products, and the

sizes and other characteristics of the particulates emitted.

The powder emissions from the Nutricia dryer have been consistently low, averaging

only 47 mg/m3 in seven surveys by Teagasc since 2002. This is within the 5-50 mg/m3 standard

for dryer emissions specified by EPA in its Draft BAT (Best Available Techniques) Guidance

Note for the Dairy Processing Sector. Nutricia can therefore claim to be already achieving BAT in relation to the average levels of emissions from its dryer. But because the upper limit of 50

rng/m3 cannot be guaranteed at all times with cyclones, the company is committed to installing

bag filters on emissions from both the existing and proposed dryers. It is planned to install the

bag filter on the existing dryer in the first quarter of 2008. Such filters have a particle capture

efficiency of greater than 99% and represent Best Available Techniques for the industry.

Baseline monitoring and mathematical modelling of emissilons from the dryers were carried out

as part of the EIS. The main focus was on the levels of PMMI (which are regulated under

national air quality standards) and smaller particles. The modelling predicted that particulate

emissions would have no significant impact on the ambient environment

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Existing and potential odour emissions were also addressed in the EIS, with a particular

focus on hydrogen sulphide, which can be associated with wastewater treatment plant

operations. Monitoring of the ambient air showed that no elevated odour levels occurred in the

vicinity of the existing wastewater treatment plant and modelling of fbture emission scenarios

predicted that, provided specified odour abatement procedures were implemented, no major

odour impact should be perceived by residents arising frorri the expanded wastewater treatment

plant.

In relation to noise emissions it is apparent that the plant is located in a quiet rural area

such that background noise levels are quite low. It is planned to design, equip and position the

new drying tower and other facilities on the site so as to minimise noise beyond the site

boundary. A detailed noise survey and modelling exercise have been carried out as part of the

EIS to identify and quantify the noise sources on site, to establish appropriate noise abatement

and mitigation measures and to predict resulting noise levells at and beyond the boundary. The

study addressed both construction-phase and operational-phase noise levels and concluded that

the former should be addressed by implementing an on-site noise management plan, while, by

implementing all the identified mitigation measures, the operational phase would meet the

standard EPA noise limits. It is planned to replace the existing cooling tower with a modem

plant incorporating optimum noise attenuation technology in the first quarter of 2008.

Wastewater originates at a number of points on the site. Clean surface water arising

from roof and yard areas is collected and piped with treated1 wastewaters to the Carrigadrohid

Reservoir on the River Lee at Farranavarrigane. The discharge point is just downstream of the

water intake for the factory. Process wastewaters, arising mainly from plant washings and

evaporator condensate, along with settled domestic wastewater from the on-site septic tank, are

piped to the wastewater treatment plant (WWTP). The WWTP consists of coarse and fine screening, dissolved air flotation, aerated balance tank with pH correction and control,

extended aeration activated sludge treatment with phosphate removal and denitrification,

settlement in a final clarifier, sand filtration and discharge of the treated wastewater. The

current discharge licence, issued by Cork County Council in December 2005, is very

comprehensive and specifies detailed limits and conditions for the discharge including ongoing

monitoring and reporting. Treated wastewater flow is currently limited to 1,500 m3/day, with a maximum BOD of 10 mgA, suspended solids of 25 mgA, total phosphate of 1.5 mgA,

orthophosphate of 1 .O mgA and total nitrogen of 15 mgA. The proposed extension will result in

a volume increase to 2,400 m3/day, without increasing the allowable contaminant

concentrations.

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The upgrading and extending of the wastewater treatment plant will involve building a

new 1,500 m3 balance tank, recommissioning the Flocor biotower which has not been needed

in recent years, conversion of the present balance tank to an intermediate clarifier following the

biotower and the installation of a second final clarifier. It is also proposed to install sand filters

as tertiary treatment to further ensure the quality of the find effluent. With this level of

treatment, no adverse impact on the receiving water is to bt: expected and thls is continned by a detailed analysis in the EIS which looked at the assimilative capacity of the River Lee and the

applicable water quality standards and concluded that the discharge fiom the upgraded

wastewater treatment plant will not have a significant impact on the quality of the receiving

waters.

Surplus sludge, produced as a by-product of the dissolved air flotation, biological

treatment and phosphate removal processes, is currently treiated and disposed of in one of two ways: either it is dewatered in a belt press to about 12% solids or it is dewatered to a similar or

better level in a proprietary on-site sludge dewatering unit supplied by Countywlde Drain

Services Ltd. In either case the dewatered sludge is removerd by the licensed contractor,

Countywide Drain Services Ltd., under permits issued by Cork County Council. The sludge is

either taken to an approved composting plant operated by McGill Environmental Systems at

Castletownroche, Co. Cork, after which it is landspread by them as compost, or it is taken

directly by the contractor for soil injection to one of a number of approved spreadlands subject

to the regulatory control of Cork County Council (Waste Permit No. CK 302/06).

The quantity of sludge removed is currently 4,700 tons per year, but this is projected to

increase to 8,000 tons per year following the planned expansion.

Packaging wastes originating on the site are recovered and reused where practicable.

The recovered cardboard is currently collected for recycling by Veolia Environmental Services (formerly Onyx). Plastic packaging is collected by Dilloan Recycling, Dundalk, and waste

FIBC's are collected by Cleary's of Wexford.

There is a strong focus on energy management and energy efficiency at the Nutricia

plant. With the spiralling cost of energy this focus will be fiurther intensified in the future.

Energy efficiency programmes have resulted in the consumption of fuel oil as a percentage of

production being cut by 15% in the last three years while the corresponding percentage cut in

the consumption of electricity was 10%. A comprehensive ]Energy Monitoring and Targeting

System, designed to achieve firther energy efficiencies, is in operation throughout the Nutricia

site.

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In summary, with the extensive application of Best Available Techniques and

appropriate environmental management systems at the Nut ricia site, no significant

environmental impacts are likely to arise from future operslltions.

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