Irish Distillers - For inspection purposes only.

Transcription

1 Irish Distillers - Noeleen Roche Licensing Unit Environmental Protection Agency PO Box 3000 Johnstown Castle Estate Co. Wexford 07 December 2006 Your Ref.: Reg No: 442 Dear Ms Roche, Submission on IPPC Licence Review requested by Cork County Council Following a number of meetings with the Agency and Cork County Council in relation to the above we hereby make the following submission - please refer to attachment Schematic Diagram of Emissions to Sewer and Surface Waters: BOD, COD and Total suspended solids Since the Urban Waste Water Treatment Regulations, 2001 (as amended) are being used as the justification for the review of the licence we would expect that the revised licence would contain the same limits and tolerances as those contained in the Regulations. To this end the values for concentration and minimum percentage reduction as contained in Part 1 of the Second Schedule of the Regulations should be transposed into the licence. In addition the entire contents of the Fifth Schedule should be incorporated in the licence. Total Nitrogen The proposed limit represents a significant reduction in the current limits. It should be noted that our activities do not add nitrogen to our discharges. The difficulty caused by the proposed limit is that we abstract surface and ground water both of which have a background nitrate level of 5 to 7 ppm N03-N. These waters are used as cooling tower make-up water and boiler feedwater and as a result the continuous blowdown streams from both systems will contain elevated levels of nitrate. The provisions relating to the Total Nitrogen limit should be those contained in Part 2 of the Second Schedule of the Regulations. Irish Distillers Limited, Midleton Distilleries, Midleton, Co. Cork, Ireland. Tel: +353 (0) I Fax: +353 (0) I602 info@idl.ie Directors: Paul Du? (Chief Executive),Thierry Billot (FR), Denis O'Flynn,Alexandre Ricard (FR), Maurice Smyth, Kieran Tobin. Registered in Ireland No: Registered Office: Bow Street Distillery, Smithfield. Dublin 7, Ireland.

2 Faecal Coliforms The foul drainage system for the Distillery is connected to the urban waste water system and therefore the only source of faecal contamination at the outfall would be the water abstracted from the Dungourney River or the ground water abstraction system. It is imperative that the licence condition relating to faecal coliforms be written in such a way that the background coliform levels in these two water sources be taken into consideration when determining compliance. Surface Water Emission Point SE5 Surface water from the production area currently discharges via the outfall and is subject to monitoring as per Schedule 5(i) of the current licence. In light of the fact that the outfall will be subject to continuous monitoring we feel that the schedule pertaining to SE5 is superfluous and should be deleted from the licence. Emissions to Sewer SEI The monitoring and control of SEI are detailed in Schedules 2(i) and 2(ii) of the present licence. These will obviously be amended to reflect the proposed limits. However, in January 2005 we commissioned a new Waste Water Treatment Plant which has a design capacity of 1250 m3 per day and we wish to avail of the opportunity to revise the maximum daily volume from 750 m3 to 1250 m3 with a pro rata increase in the maximum rate per hour from 45 m3 to 75 m3. The Sanitary Authority has indicated that it has no objection to the proposed increase in the treated effluent volumes. Since the discharge point for emissions to sewer will be relocated from the existing SEI to the outfall the monitoring schedule on SEI contained in Schedule 2(iii) should be should be revised accordingly. The monitoring should be reduced to a minimum to ensure that the performance of the waste water treatment is satisfactory. Surface Water Emission Points SWE3 to SWE8 The monitoring requirements for surface water emission points SWE3 to SWE8 (see attached drawing DR-0002) are contained in Schedule 5(i) of the licence. For the construction of Warehouse 26 we were asked by the Agency to provide secondary containment as per Condition 10.4 of our licence. At that the surface water emission points SWE3 to SWE8 discharged to the dry bed of the millstream. We proposed a system whereby these emission points would be connected via a 750 mm pipeline to a diversion chamber located at SWE3. Under normal circumstances surface water discharges through the diversion chamber to the dry millstream, in the event of a spill a valve in the diversion chamber is closed and the contents of the surface water drains are diverted to the redundant sedimentation tanks of the old waste water treatment plant. The Agency agreed to the proposal (M442/ap32smcc). In effect this renders SWE4 to SWE8 redundant with all the surface water from the area discharging at the point SWE3. In light of this all references to SWE4 to SWE8 should be removed from Schedule 5(i) of the licence.

3 Emission Point SWEl Ground water rises to the surface at a point on our site and discharges naturally via the tailrace of the millstream to join the Dungourney River adjacent to our premises. As part of our process we abstract the ground water and use it, untreated, as once-through cooling water. The discharged ground water then combines with the natural overflow and enters the river. The monitoring point for this discharge is SWEl and the requirements are outlined in Schedule 3(i) of the licence. The TOC of the ground water does vary and where elevated TOC values are indicated we are permitted to continue discharging provided we can establish that the contamination is present at source and not as a result of our activities. Naturally, if we are responsible for the contamination of the ground water then we are obliged to cease discharging and notify the relevant authorities. As part of this review we have requested that the ground water be discharged via the outfall. We have submitted flow data to the Sanitary Authority and understand that they have the capacity to convey the additional volumes. We would, however, request that SwEl be retained as an emergency discharge point for the ground water for the following reasons: 0 The ground water is vulnerable to pollution from external commercial and agricultural activities and there is the possibility that the BOD of the water at source could exceed the proposed licence limit. If we were forced to shut down in such an event the contaminated ground water would continue to ovemow to the river via its natural route. We believe that, in the event of the ground water being contaminated at source, we should be allowed to continue the abstraction of ground water for cooling purposes and discharge the water via SWEl. 0 The situation could arise where the Sanitary Authority does not have the capacity to convey the additional volumes even for a short duration. If we are forced to cease our ground water abstraction then the entire distillery complex will be forced to shutdown and contents of the fermenter vessels would be spoilt beyond recovery. Should you have any queries please contact the undersigned. Yours sincerely, Aidan Curran Environmental & Energy Manager

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