a A

Prevention and Control (IPPC)/Waste Licensing

Review Form and Guidance Note

for the purposes of

EC Envi ron menta I 0 bjectives (Surface Waters) Regulations 2009

EPA Reg. NQ: (Office use only)

Environmental Protection Agency P.O. Box 3000, Johnstown Castle Estate, Co. Wexford

Web: www.epa.ie Email: info@epa.ie Lo Call: 1890 335599 Telephone: 053-9160600 Fax: 053-9160699

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INTRODUCTION

This Form is for the purposes of a review of an IPPC/Waste Licence in order t o ensure that all authorisations under the €PA Act 1992 to 2007 and the Waste Management Acts 1996 to 201 0 having discharges liable to cause water pollution are in compliance with the EC Environmental Objectives (Surface Waters) Regulations 2009.

While every effort has been made to ensure the accuracy of the material contained in the Review Form, the EPA assumes no responsibility and gives no guarantees, undertakings and warranties concerning the accuracy, completeness or up-to-date nature of the information provided herein and does not accept any liability whatsoever arising from any errors or omissions.

The Review Form and all supporting information shall be submitted to the Headquarters of the Agency in a format of a signed original, one hardcopy and two copies on CD-Rom. In cases where an Environmental Impact Statement (EIS) is required in support o f the Review Form, a signed original, one hardcopy plus 16 copies (or 18 copies if the activity is within Energy sector) on CD-Rom shall be submitted.

All pages, including maps/drawings/plans, shall be no larger than A3 size. All files on CD-Rom shall be submitted in searchable PDF format and be no larger than IOMB each in size. All CD-Roms shall be labelled with the Licensee's name, Licence Register Number, address of the activity and name of the file (i.e. Review Form).

Introduction

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CONTENTS

SECTION A: GENERAL .......................................................... 4

SECTION B: EMISSIONS ...................................................... 6

SECTION C: CONTROL & MONITORING ................................ 8

SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE

ACTIVITY ......................................................... 2

SECTION E: STATUTORY REQUIREMENTS ............................ 7

SECTION F: APPROVED ADJUSTMENTS & CONDITIONS ....... 9

SECTION G: DECLARATION ................................................ 12

ANNEX I: TABLES/ATTACHMENTS ..................................... 13

Con ten ts

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SECTION A: GENERAL

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Carrick-on-Shannon Co. Leitrim

Tel: 07196 59500 Fax: 07196 59508 e-mail: b m a I I o n @ mason i te. com

A . l Licensee

Name*: Masonite Ireland Address: Derryo u g hte r

Drumsna

Name and Address for Correspondence Only documentation submitted by the Licensee and by the nominated person will be deemed to have come from the Licensee.

I Name: Brian Mallon Address: Mason i te I re land

Derryoughter, Drumsna, Carrick-on-Shannon Co. Leitrim

Tel: 07196 59562 Fax: 07196 59508 e-mail: bmallon@masonite.com

Address of registered or principal office of Body Corporate (if applicable)

Address: 6 Fitzwilliam Square Dublin 2 Dublin

Company 229654 (Ireland) Register No. Tel: 01 6145000 Fax: 01 6145001 e-mail: cg I y n n @ m h c. ie

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A.2 Location of Activity

National Grid Reference (12 digit 6E,6N)

Name: Mason i te Ireland Add ress * : Derryoug hter

Drumsna

E201029 N296302

Carrick-on-Shannon Co. Leitrim

Tel: 07196 59500 Fax: 07196 59508 Con tact Name: Brian Mallon Position: Environmental Manager e-mail: bma llon @ mason i te.com

* Include any townland.

Location maps with legible grid references are enclosed in Attachment Ns A.2. The site boundary is outlined on the map in red colour.

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SECTION B: EMISSIONS

B . l Emissions to Surface Waters &/or Ground

There is one discharge point to the Shannon which is via an 8 meter diffuser sitting on the floor of the river Shannon at Grid Refereence E200831 N296054. Two emission points which mix prior to discharge to the Shannon are emitted at this point. There are no emissions to groundwater.

The nature of the discharge to the Shannon consists of the following:

1. Discharge from waste water treatment plant - Treated Process Water Emission Point - EO1

2. Discharge from storm water settlement ponds - Non Process Water Emission Point - E02

The emission points ( E 0 1 and E02) as well as their locations are presented in Attachment B. l .

1. Discharge from waste water treatment plant - Treated Process Water Emission Point - E 0 1

The discharge from E 0 1 is monitored in accordance with Schedule 2(iii) of Masonites IPC licence and subsequent EPA approved monitoring alterations many of which have been agreed as a result of continued compliant operation over a significant period. I n addition Masonite upgraded the waste water treatment plant from an Activated Sludge Plant to a Membrane Bioreactor (MBR) in 2005 which has had a significant positive impact on the quality of process water discharged via EOl. The majority of monitoring is completed in- house with only specialist analysis requiring more advanced instrumentation techniques being contracted out.

The MBR treats wood based process water with the majority of the influent arising from woodchip washing and subsequent heated plug screw dewatering. The gives the influent a "woody" colour and contains woodchip fines. These two streams account for 90% of the wastewater to be treated. Other minor sources include, waste paint processing water, scrubber sump water, furnace ash collection run-off, domestic sewage from the office block and backwashes from the well water treatment systems. Further details on the process and abatement equipment are presented in Section C. It should be noted that Masonite changed the resin used in the process from a Phenol based resin to a Urea based resin in 1998 which has made Phenol monitoring not applicable although it continues to be carried out in line with the licence monitoring schedules. The influent is characterised by very low nutrient levels and the installation of the MBR prevents any suspended solids from been emitted. This results in advanced treatment that has resulted in Masonite being comfortably in compliance with the current licence discharge limits.

2. Discharge from storm water settlement ponds - Non Process Water Emission Point - E02

The discharge from E02 is monitored in accordance with Schedule 5(i) of Masonites IPC licence and subsequent EPA approvals and requirements. Storm water flow, pH and Turbidity are monitored continuously and trended. The main site is enclosed by a concrete culvert (drain) which collects all rainwater run-off from the buildings and external areas. The run-off flows through a bar screen to remove large debris and then through a finer mesh screen to remove smaller material such as woodchips. The water then passes through a Class A interceptor before entering the storm water ponds. Two large storm water ponds operating in parallel (as one tank) facilitate settlement of solids prior to discharge via emission point E02. The storm water ponds discharge then combines with

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the waste water treatment plant discharge prior to discharge t o the Shannon. The final inspection chamber a t this discharge point is monitored daily for combined E 0 1 and E02 discharge tem peratu re.

6.2 Tabular Data on Emission Points to surface water

Point Code ~ ~~

Emission Point E 0 1 (Waste water discharge)

Emission Point E02 (Non process water discharge)

Combined discharge to Shannon

Easting 200865

200840

200842

Northing 296158

296241

296055

Verified Yes

Yes

Yes

Emission

COD BOD Suspended Solids PH Ammonical Nitrogen (as N) Nitrate (as N) Nitrite (as N) Total Nitrogen (sum of three above) Total Phosphorus (as P) Phenol Forma Id eh y d e Oil and Grease Trace Organics Toxicity Residua I Chlorine

BOD Trace Organics

Major Anions Major Cations Phenol Individual Heavy Metals COD* Ammonical Nitrogen* (as

Nitrate* (as N) Nitrite* (as N) Total Nitrogen* (sum of three above) Turbidity Conductivity

PH

N)

Te m p e ra t u re

* EPA requirement due t o Ammonia contamination from stored culled board externally in 1999, M21/nc06ec. This and other changes will be addressed in Section F.

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SECTION C: CONTROL & MONITORING

C. l Treatment, Aba temen t a n d Contro l Systems

Masonite upgraded the waste water treatment plant works in 2005 from a standard Activated Sludge plant to a state of the art Membrane Bioreactor (MBR). A training presentation detailing how the MBR operates including plant schematics and pictures is included in At tachment NQ C.1.

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The influent to the works first passes through 5mm and 0.5mm screens where woodchips and wood fines are removed. Following screening the waste water enters the Balance Tank which has a storage capacity of 1500m3. Here pH stabilisation occurs if necessary using Sodium Hydroxide and Hydro chloric acid. Domestic sewage from the office block enters the Balance Tank from an alternative pipe to the main inlet process drain. The waste water passes from here through a Dissolved Air Flotation (DAF) unit where 30-70% of the organic strength of the waste water is removed. Chemical coagulant and Polyelectrolyte can be added to the DAF to further control the organic loading to the MBR. The effluent now passes into the splitter tank of the MBR where it combines with the Return Activated Sludge (RAS) from the front of the 2 MBR tanks. Ferric sulphate is added at this location to aid Phosphorus removal. The influent splits between the 2 MBR tanks firstly passing through an anoxic zone for Nitrogen removal and then through a Fine Bubble Diffused Aeration (FBDA) zone and then into the main membrane aerated section. The anoxic, FBDA and membrane aeration are 3 distinctly1 different sections within the same tank. Each of the two MBRs has 10 banks of membranes with each bank containing 200 individual membranes. The membranes have an effective pore size of 0.Olum essentially preventing any suspended solids or bacteria from exiting in the discharge. This process eliminated the need for the two large aeration basins, 2 clarifiers and sand filter from the old plant. The MLSS is maintained between 10,00Omg/l and 20,00Omg/l resulting in high rate rapid treatment (hours instead of days for AS plants). Air for the bacteria and to keep the membranes clean is provided by 1 blower per tank. There is also a standby blower in case of failure of either main blower. Treated effluent exited through the pores of the membrane under gravity pressure. This process is controlled by permeate valves which match the outflow of the MBR to the incoming flow. MLSS is removed from the MBR to a sludge thickener and then to the sludge holding tank for pressing. The membranes are kept clean and operational using 4 processes.

Daily membrane air scour - The permeate valve closes for 30 minutes and the blowers go to full speed scouring sludge build up from the membranes

n Purge - Purge valves open for 2 minutes each day drawing water and sludge into the blower a i r nozzles clearing any sludge build up. The membranes get a six monthly clean where each membrane is filled with a dilute (0.5%) Sodium Hyperchlorite solution for 2- 24 hours.

' All membranes are removed every 3-4 years for a full power wash using water. During this time the MBR tanks are also cleaned.

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The frequency of all of the 4 processes above can be altered to maintain operational efficiency. I n addition the old activated sludge plant infrastructure has being maintained allowing the activated sludge plant to be operated in parallel to the MBR i f required.

The main improvements achieved from the MBR upgrade are:

Suspended solids of <5mg/l and normally < lmg/ l . BOD <5mg/l Automatic operation - Microscopic check irrelevant for successful operation More stable operation after shutdown periods

0 Reduced footprint than the old Activated Sludge works.

As Masonite has upgraded the waste water treatment works to MBR technology given exceptional organic pollutant removal no alternative abatement is been considered as part of the review process.

Shutdown and Upset Conditions Operation:

The MBR has been designed to accomadate up to full flow at maximum concentration. These conditions exist at full production capacity. Currently production is operating between 40 and 50% of full production capacity. For this reason there is often in- sufficient waste water to keep the MBR plant fully loaded over weekend periods. I n order to keep the MBR MLSS sustained the MLSS is fed with liquid Molasses as an alternative food source. Molasses is also used where there are extended shutdowns for maintenance in the summer and over the Christmas period.

On occasions following long duration production shut downs the MBR membranes have been partially blinded due to bacteria floc break-up. The MBR has many design features to l imit this blinding effect including operating at higher blower speeds, intermittent discharge etc. There are no environmental impacts from upset conditions as treatment is maintained with the exception that there is reduced throughput of treated waste water through the treatment works. The only adverse effect of this is the possibility of reduced production throughput for the facility.

Anticipated malfunctions and known problems associated with the treatment:

The forward feed pump and MBR blowers and permeate valves are the Primary critical parts for the operation of the MBR. The forward feed pumps and blowers are operated in duplicate with a duty and standby. The PLC will change automatically to the operation of the standby in the event of a malfunction. Where the PLC detects a fault with a permeate valve for example during a power cut the valves automatically close which then puts the MBR into standby operation until they have been repaired. This high level of malfunction protection built into the MBR process is designed to protect the membranes and prevent operation during upset conditions. I n addition a detailed list of spares is maintained to ensure no failure results in extended periods of treatment downtime. Detail of critical controls is included in Table C. l ( i ) in Attachment Ns C.1.

The waste water treatment plant and storm water instrumentation calibration schedule is also detailed in Attachment N" C.1.

Proposed monitoring to be undertaken for influent(s) to treatment plant, and in- treatment monitoring required for the management of the treatment plant is detailed in Attachment N" C.1 under the file name 'Current and Proposed Schedule 2(ii) Monitoring and Equipment' . These tables outline the current licence requirements and the proposed new licence requirements for process monitoring of the MBR as well as the critical spares required to maintain treatment. It should be noted that the proposed

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monitoring is the current range of monitoring conducted to maintain the operation of the MBR as recommended by the equipment supplier.

C.2 Monitoring and Sampling Points

The proposed sampling and monitoring points for waste water discharge (E01) and storm water discharge (E02) are per the current IPC licence. Both sampling points are equipped with flow proportionate composite samplers and are readily accessible.

As a result of the upgrade of the waste water treatment plant, significant process changes, and on-going compliance with the current licence limits the parameters to be monitored as well as the frequency of monitoring has changed. The current monitored licensed parameters and their licence frequency as well as proposed parameters and monitoring frequency is detailed in tables under Table C.2(i).

Table C.2(i) has been completed detailing current licence requirements for emissions monitoring for E01, E02, WWTP Sludge, Stormwater Pond Sludge as well as the site boreholes M W 1 to MW4. Significant changes to the test frequency for many parameters have been agreed with the EPA through letters of approval. These changes will be further detailed in Section F. Specifically for this review the following new changes for emissions monitoring are proposed:

0 Change requirement to monitor Suspended Solids from MBR discharge from daily to monthly - Suspended Solids emissions from the MBR are typically < l m g / l versus the current licence limit of 30mg/l. Due to the membrane pore size Suspended solids discharge is prevented, therefore, there is no necessity to test E 0 1 emissions daily for Suspended Solids.

Remove requirement to test EO1 and E02 emissions for Phenol. Masonite have not used phenol in the process since 1998 and therefore propose to cease emission monitoring for Phenol at E 0 1 and E02.

Propose to conduct annual emission monitoring for Heavy Metals at EO1 to bring in line with E02 requirement. Assimilative capacity calculation in Section D will show that heavy metals emissions are insignificant from both EO1 and E02 thereby justifying an annual check.

Propose to cease daily storm water (EOZ) emissions daily grab monitoring for COD, Ammonia, Total Nitrogen (Nitrate and Nitrite) and pH. This requirement arose out of an EPA audit in October 2001 when contamination of subsurface water was identified from external culled board storage giving rise to elevated levels of the above parameters in the storm water emissions. This issue has been resolved since 2003 but Masonite have continued with this monitoring. The detailed monitoring over 9 weeks on E02 (detailed in Table D.2 (ii) in Attachment N" D.l . ) shows that there is no contamination from the above parameters removing the need to continue to monitor them.

Ambient monitoring has been completed in line with the review requirements. Details of the upstream and downstream sampling locations are included in Section D. Nine weekly grab samples have been analysed by an external contract laboratory for the parameters detailed in Table C.2 (ii). Ambient monitoring is not proposed to be included as a requirement of the reviewed licence. Licence limits laid down in the new licence calculated in line with accurate and conservative assimilative capacity calculations will protect the surface water body without the additional burden of on-going ambient monitoring. The ambient monitoring data will be used as a back-up to assimilative capacity calculations to be completed in Section D.

Tables C.2 (i) and C.2 (ii) are included in Attachment Ne C.2.

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C.3 Tabular Data on Monitoring and Sampling Points

Point Code Emission Point E 0 1 (Waste water discharge)

Emission Point E 0 2 (Non process water d ischa rg e)

Com bined discharge to Shannon

Point Type

S

S

S

Easting

200865

200840

200842

Northing 296158

296241

296055

Verified Yes

Yes

Yes

Emission

COD BOD Suspended Solids

Ammonical Nitrogen (as

Nitrate (as N) Nitrite (as N) Total Nitrogen (sum of three above) Total Phosphorus (as P) Phenol Forma Ide hyd e Oil and Grease Trace Organics Toxicity Residual Chlorine

PH

N)

Flow BOD Trace Organics

Major Anions Major Cations Phenol Individual Heavy Metals COD Ammonical Nitrogen (as

Nitrate* (as N) Nitrite* (as N) Total Nitrogen (sum of two above) Turbidity Conductivity

PH

N)

Tem pera tu re

The above table is detailed in Excel format in Attachment C.3.

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SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

D . l Assessment of Impact

Treated waste water and surface water from Masonite is discharged to the Shannon Upper downstream of Drumsna, Co. Leitrim (E200831, N296054). The Shannon Upper is classified as being of “Poor Status“ overall due to poor status for Macroinvertebrates and overall ecological status. The Shannon Upper is classified as “High Status’’ for physio-chemical parameters. The aim is to improve the status of the Shannon Upper from poor to good status by 2015. The risk of achieving Good status by 2015 is l a or “At Risk”. The areas of risk are identified as follows:

Diffuse Risk Sources in category l a

RD5 Overall Unsewered (2008)

RD5a Unsewered areas - Pathogens (2008)

RDO Diffuse Overall - Worst Case (2008)

Point Risk Sources in category l a

RP3 IPPCs (2008)

RPO Overall Risk from Point Sources - Worst Case (2008)

Masonite Ireland forms part of RP3 IPPCs and as such the discharge limits are classified as being a risk to achieving Good status by 2015.

Lough Tap is 800m downstream from the Masonite discharge and is classified as Moderate status and 2b “probably not a t risk”. It also is 2b probably not a t risk for LP3 IPPCs sites which contrasts with the Shannon Upper classification.

The closest monitored flow station to Masonite is at Jamestown weir (OPW flow meter 26085) which is 3km upstream of the Masonite discharge point. The 95%ile flow at Jamestown is 2.3m3/s with a DWF of 1.4m3/sm This data will be used for assimilative capacity calculations for Masonites discharge to the Shannon. The Shannon flows into Lough Tap which is 800m downstream of the Masonite discharge point. The surrounding countryside is primarily pasture farmland. There is also a small waste water discharge point from Drumsna treatment works approximately 2km upstream of the Masonite discharge point.

Natural Heritage Areas (NHAs) and Special Areas of Conservation (SACS):

The facility does not lie within a proposed Natural Heritage Area (pNHA) as listed by the National Parks and Wildlife Services website. I t is not listed as a Special Area o f Conservation (SAC) designated in accordance with Council Directive 92/43/EEC and adopted in Ireland under S.I. No. 94 of 1997.

The site is not in an area designated as of scenic or of special amenity importance. It is not designated as a Special Area of Conservation or Special Protection Area. The closest proposed Natural Heritage Area (pNHA) is approximately 6 km south of the site a t Lough Boderg and Lough Bofin (001642). There is a second pNHA located approximately 5 km to the southwest of the site a t Kilglass and Grange Loughs (000608).

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Downstream Water Abstraction Points:

The neareset water abstraction downstream of the site is the ‘Longford Central Abstraction’ at Lough Forbes‘. This is operated by Longford County Council and is on the northern side of the lake, approximately 20km downstream of Drumsna. National Grid Co-ordinates are E208383 N2882238. The daily abstraction rate is 7,500m3.

EPA Monitoring Data:

EPA monitoring data is available for the Shannon Upper both upstream and downstream of Masonite. The closest upstream monitoring point is in Carrick-on-Shannon (RS26S020915, Rosebank Marina) which is 7km northwest of the facility. The closest downstream monitoring point is at Roosky (RS26S021415, Old Canal) which is l l k m downstream of the facility. The EPA monitoring data for both locations is detailed in Attachment D.1. The data both upstream and downstream of Masonite indicates physiochemical parameters between Good and High Status although the overall status of the Shannon Upper is poor status. The quality of the river at Roosky which is downstream of Masonite is to a higher standard than at the Rosebank Marina.

Masonite Monitoring Data:

As part of the licence review process Masonite have collected 9 weekly samples both upstream and downstream of Masonites discharge point. The upstream discharge point has been called Wards field (E200186, N296949) and is 750m upstream from Masonites discharge point. The downstream discharge point has been called Railway Bridge (200544, N295159) and is 700m downstream of Masonites discharge point. All sampling was completed in flowing water to ensure representative samples were obtained.

The data from upstream and downstream sampling; Table D. l ( i ) in Attachment D.1 shows that all physiochemical parameters are meeting High status with the exception of D.0 and Dissolved Inorganic Nitrogen. There is no increase in the level of any parameter as a result of the Masonite discharge with all parameters showing similar concentrations both upstream and downstream of the facility. The sampling period corresponds to maximum nutrient concentrations due to the absence of vegetative growth in the river.

Masonite Discharge Data:

In conjunction with receiving water sampling and analysis 9 weekly samples from E 0 1 and E02 were also sent for analysis. Masonite reviewed S.I. No. 272 of 2009 and identified a number of additional parameters that could form part of the discharge in E 0 1 or E02 based on the processes utilised on site. The purpose of this analysis was to quantify the significance of these parameters and i f they needed to be licenced or controlled. Table D.l (i) detailing all of these results is included in Attachment D. l .

Assimilative Capacity and Compliance with SI. No. 272 of 2009:

In order to quantify i f the limits set for Masonites waste water discharge (E01) and if the level of new parameters assessed comply with the requirements of the EC Environmental Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 an assessment of the assimilative capacity of the Shannon in the vicinity of Masonite has been completed. The completed assessment has been completed in line with the Water Services Training Group ‘Guidance to Applicant - Discharge to Surface Waters’, Full details of the assimilative capacity study are shown in Attachment No. D . l . l . The overall status of the Shannon Upper is poor but is considered high for physiochemical parameters. I t should be noted that the calculations are carried out using Masonites current discharge concentration limits for each individual parameter in conjunction with the flow discharge limit at E 0 1 . For E02 the maximum recorded flow for 2010/2011 in conjunction with the

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maximum measured concentration over the 9 week study period has been used for assimilative calculations.

The assimilative capacity for both E 0 1 and E02 comply with S.I. No. 272 of 2009 and the current High status for physiochemical parameters for the Upper Shannon is maintained. The calculated downstream values showing continued High Status following Masonites discharge is confirmed by the actual measured values at the Shannon Railway Bridge which also shows high status being maintained.

DO Saturation and Dissolved Inorganic Nitrogen (DIN) are not achieving High Status but this is the case both upstream and downstream of Masonites discharge. Masonites measured DIN from both E 0 1 and E02 is exceptional low and not contributing to the elevated levels of DIN in the river. Masonites licence does not require sampling and analysis for DIN but instead requires the analysis of Total Nitrogen (sum of Nitrate and Nitrite). DO saturation from Masonites discharges at EO1 and E02 similarly are not contributing to the low DO saturation in the river as both upstream and downstream of Masonite are showing similar DO saturation levels.

Masonites Contribution to Nutrient Load in Upper Shannon:

The assimilative capacity assessment shows that Masonites discharge is not adversely affecting the physiochemical status of the Shannon and High Status is maintained for the licensed parameters. However in order to take on tighter limits to further enhance the quality of the Shannon and reduce Masonite's overall licenced load of nutrients the contribution of Masonites discharge has been assessed.

Emission Point - E01: Based on Masonites Phosphorous l imit of 3mg/l Masonite contribute 40% of the Shannon assimilative capacity in the area of the facility. Masonite therefore proposes to take on a tighter limit for Phosphorus of 2mg/l. This will reduce Masonites licenced contribution to 27% of the Shannon assimilative capacity.

Similarly Masonites current licence limit for Ammonia of 10mg/l contributes 67% of the assimilative capacity of the Shannon in the vicinity of the facility. Masonite therefore proposes to take on a tighter limit for Ammonia of 5mg/l. This will reduce Masonites licenced contribution to 33% of the Shannon assimilative capacity for Ammonia.

With regards t o Total Nitrogen Masonite report the sum of Nitrate and Nitrite for compliance with the Total Nitrogen limit of 15mg/l. Although Total Nitrogen is not a specific target parameter under S.I. 272 Masonite proposes to take on a tighter limit of 10mg/l for Total Nitrogen.

Individual Heavy metals have not been detected in the E 0 1 emission in sufficient quantity to warrant the inclusion of new limits but Masonite proposes to monitor for Individual Heavy Metals from E 0 1 on an annual basis as part of the reviewed licence.

Emission Point - E02: An assessment of the emissions from E02 shows that the levels of contamination from all target parameters is exceptionally low with minimal impact on the assimilative capacity of the Shannon in the vicinity of the facility. Masonite therefore do not propose any new limits for the storm water discharge a t E02.

Summary:

Masonites actual discharge concentration of all parameters is consistently below the current licence limits and will comply with the proposed new licence limits and test

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frequency when the new licence is issued. No further upgrades are required to meet the licence limits as proposed in this review application. I t must be noted that Phosphorus removal in the Masonite treatment system is achieved through the addition of Ferric Sulphate. Ferric sulphate binds the Phosphorous into bacterial floc making the floc inactive for organic matter breakdown. Masonite believe that a Phosphorus limit any lower than 2mg/I would adversely affect the MBR sludges ability to complete full organic matter breakdown.

D.2 Environmental Considerations and Best Available Techniques (BAT)

Describe, in outline, the main alternatives, i f any, to the proposals contained in the Review Form.

Not applicable as it is an existing facility and the WWTP was upgraded in 2005.

Describe any environmental considerations which were made with respect to the use of cleaner technologies, waste minimisation and raw material substitution.

The above environmental considerations were taken into account when the WWTP was upgraded to an MBR in 2005.

Describe the measures proposed or in place to ensure that:

the best available techniques are or will be used to prevent or eliminate or, where that is not practicable, generally reduce an emission from the activity; The BAT Guidance note applicable to the Masonite Ireland facility is the "BAT Guidance Note on Best Available Techniques for the Production of Paper Pulp, Paper and Board (EPA 2010). Section 9.3.1 of this document outlines best practice for waste water reduction, re-use and treatment. All processes outlined for reduction and re-use are in place a t Masonite including Chipwash water re-use, steam minimization and separation of non-process water and process water. I n addition the MBR complies with the waste water discharge limits proposed by the BAT document.

no significant pollution is caused;

A review of the discharges from E 0 1 and E02 shows that Masonite fully comply with the IPC licence limits since the MBR was installed in 2005. I n fact all parameters emitted were only a fraction of the current licence limits. Based on the assimilative capacity calculations above Masonite are complying with the Shannon Upper EQS.

waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment; In line with the requirements of the facility EMS, Masonite aim for continuous improvement in the quantities of waste generated on site. Masonite have detailed waste management procedure to correctly manage all waste types generated where it cannot be avoided.

energy and other resources are used efficiently; As a large user of electricity Masonite have a detailed energy management system on site including an overriding site energy management policy. I n 2009 Masonite

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was recognized by its peers by winning the overall award of ' Energy Manager of the Year' in 2009 from SEI.

(e) the necessary measures are taken to prevent accidents and limit their consequences; and, I n accordance with Condition 9.4.2 of Masonite IPC licence, Masonite have a detailed emergency response plan in the event that the onsite infrastructure and procedures to prevent accidents is overwhelmed. This procedure is activated in the event of a major site incident.

(f) the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state. Masonite Corporate have detailed Environmental procedures and requirements for shutting down plants and returning the site to a satisfactory state.

This section should present a statement on energy efficiency at the site to include, where appropriate, an energy audit with reference to the €PA Guidance document on Energy Audits. Licensees should have regard to Section 5 of the €PA Acts 1992 and 2003 in selecting BAT and in particular the following:

The use of low-waste technology; The use of less hazardous substances; The furthering of recovery and recycling of substances generated and used in the process and of waste where appropriate; Comparable processes, facilities or methods of operation, which have been tried with success on an industrial scale; Technological advances and changes in scientific knowledge and u n d e rs ta n d i n g ; The nature, effects and volume of the emissions concerned;

The commissioning dates for new or existing facilities;

The length of t ime needed to introduce the BAT; The consumption and nature of raw materials, including water, used in the process and their energy efficiency;

0 The need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it; The need to prevent accidents and to minimize the consequences for the Envi ron men t ; and,

0 The information published by the Agency in the form of sectoral BAT Guidance documents and the relevant BREF documents published by the EC (available for download at http://eippcb.irc.es/ and at www.epa.ie).

The information presented above has been addressed in responses presented earlier in section D.2 of this form. A copy of Masonites Energy policy in included in Attachment D.2.

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SECTION E: STATUTORY REOUIREMENTS

E.1 Best Env i ronmenta l Practices - Compl iance with Legis lat ion

Demonstrate i f the best environmental practices are in place for control of diffuse emissions from the installation/facility as set out in the following legislation:

(a) a specification prepared by the Agency in accordance with Section 5 of the Environmental Protection Agency Act 1992 as amended by Section 7 of the Protection of the Environment Act 2003;

Masonite have appl ied BAT t o t h e management o f a l l aba tement operat ions on site. The s i te opera te an Env i ronmenta l Management System (EMS) based o n IS0 14001 app ly ing management con t ro l through documented procedures over a l l aspects o f s i te act ivi t ies. The s i te also has a detai led energy management system.

Specific pro jects f o r improvemen t are addressed t h r o u g h s i te object ives in t h e annua l Env i ronmenta l Management Plan (EMP) and progress is repor ted annua l ly in t h e Annual Env i ronmenta l Repor t (AER).

Specif ical ly t h e upgrade of t h e s i te waste w a t e r t r e a t m e n t plant, in agreement with t h e EPA in 2005, represented us ing BAT to dramat ica l l y reduce Masoni tes impact o n t h e r i ve r Shannon.

(b) the Urban Waste Water Treatment Regulations 2001 (S.I. No. 254 of 2001) as amended by the Urban Waste Water Treatment (Amendment) Regulations 2004 (S.1- No. 440 of 2004) or any future amendment thereof;

The River Shannon i s n o t des ignated as a Sensi t ive Area under t h e Urban Wastewater Trea tment Regulat ions 2001 (S.I. 254 of 2001). Al l process w a t e r i s directed t o t h e was tewa te r t r e a t m e n t p lan t and i s k e p t separate from surface w a t e r run-of f .

(c) the European Communities (Good Agricultural Practice for Protection of Waters) Regulations 2009 ( S I . No. 101 of 2009) or any future amendment the reof;

N o t Applicable.

(d) the Local Government (Water Pollution) Act, 1977 (Control o f Cadmium Discharges) Regulations 1985 (S. I. No. 294 of 1985);

N o t Applicable.

(e) the Local Government (Water Pollution) Act, 1977 (Control of Hexachlorocyclohexane and Mercury Discharges) Regulations 1986 (S. I. No. 55 of 1986);

N o t Applicable.

(f) the Local Government (Water Pollution) Acts, 1977 and 1990 (Control of Carbon Tetrachloride, DDT and Pentachlorophenol Discharges) Regulations 1994 (S. I. No. 43 of 1994);

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Not Applicable.

(9) measures or controls identified in a pollution reduction plan for the river basin district prepared in accordance with Part V of t h e €C €nvironmenta/ Objectives (Surface Waters) Regulations 2009 S I . No. 272 o f 2009 for t h e reduction of pollution by priority substances or t he ceasing or phasing out of emissions, discharges and losses of priority hazardous substances.

The on-site waste water treatment plant is managed t o ensure compliance with the current emission limit values. Projects have been completed t o further reduce emissions even while complying with current limits. Proposed reduction in l imits will require additional management and control t o further reduce emissions in line with these regulations.

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SECTION F: APPROVED ADJUSTMENTS & CONDITIONS

Amend monitoring

Details of proposed changes to monitoring frequencies and limits have been outlined in previous sections. In addition proposals for amendments to Schedules 2(ii) ' Effluent Treatment Control' as a result of the upgrade of the activated sludge plant to an MBR have been detailed in previous sections for inclusion in the revised licence.

Not applicable

A full schedule of OEE agreed amendments to the current licence with the EPA reference number and description is outlined in Attachment F. Masonite propose that these agreed changes form part of the new licence and its schedules.

frequency to monthly

Remove requirement to test for Phenol f?om E01.

The following once-off reports/assessments as required by certain conditions of the licence have also being included in Attachment F.

OEE agreed reduction to quarterly as results below LOD. EPA Letter PO02 1 - 0 1/AP 127DD 15/02/2008,

Condition 6.2. Report on study of the Shannon a t the outfall diffuser proposed location.

Condition 9.4.2 - Report on risk management programme and emergency response.

A summary of all amendments and proposed changes are detailed in the table below.

Condition No.

6.5

9.9

Schedule 2(iii)

Schedule 2(ii)

Existing CO n d i ti on

Monitoring and analyses of each emission shall be carried out as specified in Schedule 2(iii) of this licence. A report on the results of this monitoring shall be submitted to the Agency on a monthly basis.

The temperature of the combined discharge to the river Shannon shall not exceed 21.5'C (1OC during the fish breeding season). Notwithstanding the above, the combined discharge shall not alter the temperature of the receiving water by 1.5'32 outside the mixing zone. EO 1 monitoring of emissions to water. Requirement to test 24hr composite for Suspended Solids daily EO 1 monitoring of emissions to water. Requirement to test 24hr composite for Phenol weekly

Proposed Wording (where

appropriate) Monitoring and analyses of each emission shall be carried out as specified in Schedule 2(iii) of this licence. A report on the results of this monitoring shall be submitted to the Agency on a quarterly basis. The combined discharge shall not increase the temperature of the receiving water by greater than 1.5"C in ambient temperature outside the mixing zone.

OEE Agreement Reference

EPA Letter M2 1 /rrO 1 ec 23/04/2003.

Not applicable.

Description

To bring licence reporting requirements in line with current agreed timelines.

To amend Condition 9.9 and Schedule 6(i) of current licence to bring it in line wit1 requirements of S.I. No. 272 of 2009.

Not required with MBR treatment system.

Phenol not used in process since 1998 Phenol not present in influent from process.

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Schedule 2(ii)

Schedule 2(i)

Schedule 2(iii)

Schedule 2(iii)

Schedule 2(iii)

Schedule 5(i)

Schedule 5(i)

Schedule 5(ii)

EO 1 monitoring of emissions to water. Not required to monitor for Individual Heavy Metals

E 0 1 current limits: Phosphorus - 3mg/l Ammonia - 1 Omgll Total Nitrogen - 15mgll

Not in current licence.

Not in current licence.

E01 monitoring of emissions to water. Required to monitor for 2 species bi-annually (total 4 species)

E01 monitoring of emissions to water. Required to monitor for BOD on a weekly basis

E 0 1 monitoring of emissions to water. Required to monitor for Oi and Grease on a monthly basis

E 0 2 -monitoring of non- process emissions to water. Required to monitor for Oi and Grease on a bi-monthl! basis

E 0 2 -monitoring of non- process emissions to water. Required to monitor for BOD on weekly basis

Borehole monitoring frequency of bi-annual for pH, Major Anions and Cations, Phenol and Individual Heavy metals.

Requirement to test 24hr composite for Individual Heavy Metals annually

E01 proposed limits: Phosphorus - 2mg/l Ammonia - 5mgIl Total Nitrogen - 10mg/l

Approval from EPA to macerate food waste from canteen and treat in wastewater

Daily analysis of E 0 1 composite for 7 days for residual chlorine following a membrane chemical clean where Sodium Hypochlorite is used

EPA approval obtained to reduce monitoring fiequency to annually and for 2 species

EPA approval obtained to reduce monitoring frequency to monthly as MBR treatment efficiency so high.

EPA approval obtained to reduce monitoring frequency to quarterly as MBR treatment efficiency so high.

E 0 2 monitoring frequency reduced to quarterly due to low levels of results and to bring in line with EO 1 ii-equenc y.

E 0 2 monitoring frequency reduced to monthly due to low level: of results and to bring in line with EO 1 frequency.

EPA approval to reduce monitoring frequency at boreholes from bi- annually to annually

Not applicable

Not applicable

EPA Letter M21Iap65ec 02/08/2002.

EPA Letter M2 l/apSldd.doc 21/02/2004.

EPA M2lIap89dd.doc 10/06/2004

EPA Letter M2 l/ap 10 1 dd 21/05/05.

E 0 2 - EPA Letter M2 l/ap 109dd 11/04/06.

E 0 2 - EPA Letter M21lap109dd 11/04/06

EPA Letter PO02 1 - 0 l/AP 127DD 15/02/2008.

EPA Letter M2 l/ap 1 OOdd 01/04/05.

Bring EO 1 requirements in line with E02.

Reduce nutrient limit in line with S.I. No. 272 of 2009.

Management of food waste on site.

Maintenance of MBR membranes in accordance with supplier recommendations

Reduced due to continued compliance and low levels obtained in results.

MBR achieves EO1 BOD levels of <5mg/l consistently.

MBR achieves E01 OFG levels of < 1 Omgll consistently.

Low levels of OFG measured over long period of time justified reduction in monitoring frequency.

Low levels of BOD measured over long period of time justified reduction in monitoring fiequency . Approval as a result of on-going low levels of testec parameters.

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Schedule 5(ii)

Not in Licence

Notin Licence

Not in Licence

Borehole monitoring frequency of bi-annual for Phenol

Include Borehole 4 as additional well in Schedule 5(ii)

As above, approval to pump uncontaminated EHT water from groundwater ingress to stonn water ponds (E02) testing shows it meet the following limits.

COD - 100mg/l Suspended Solids - 50mg/l Approval to divert land drain sump water to storm water ponds when Ammonia is less than lmg/l

pH - 6 to 9

Remove Phenol monitoring fiom revised licence for boreholes.

EPA Letter P0021- 3 1(09)AP18HB.doc 32/09/2009.

EPA Letter (PO02 1 - Ol)09AP15HB 02/04/2009

EPA Letter PO02 1 - 0 1/08AP 129DD 2 1 /05/200 8.

Not applicable

Borehole used to measure water table level at EHT. When above floor level pump groundwater ingressed water to storm water 0302) . , discharge. Testine of EHT v

(Emergency Holding Tank) water prior to discharge to storm water system.

Pump uncontaminated land drain water to storm water instead of treating with MBR. Phenol no longer used in process. Bring in line with other test proposal! above

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SECTION G: DECLARATION

Declaration

I certify that the information given in this Review Form is truthful, accurate and com plete . I give consent to the EPA to copy this Review Form for its own use and to make it available for inspection and copying by the public, both in the form of paper files available for inspection a t EPA and via the EPA's website. This consent relates to this Review Form itself and to any further information, submission, objection, or submission to an objection whether provided by me as Licensee, any person acting on the Licensee's behalf, or any other person.

S i g n e d by: & Date: / I / - 1 2 (on behalf of the organisation)

Print s ignature n a m e : 6 & / A h / pf4LLad

Position in organisation: E/cl C, R Q ~ / md - - a/) L / Y ~ V ~ G - & - Z Z

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