Objection to Proposed Determination for Grove. Turkevs Limited. IPPC Rea: PO (a)

Transcription

1 3 e tcction This Report has been cleared for submission to the Board by Programme Mana r Frank Clint n OF\ Date/$)&) CLIMATE,LICENSING Agency & RESOURCE USE r. I Directors FROM: Technical Committee - LICENSING UNIT DATE: 16'h January 2013 Objection to Proposed Determination for Grove I RE: Turkevs Limited. IPPC Rea: PO I Class(s) of activity: IPPC Directive/IED- Category of Activity Location of activity: 87( l)b notice sent: Review form received: PD issued: First party objection received: Additional Information received: 7.4.1: The operation of slaughter houses with a carcass production capacity greater than 50 tonnes Per day, 11.1: The recovery or disposal of waste in a facility within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required. 6.4(a) Smithsborough, County Monaghan. 28/07/ /201 \ 24/08/ /09/2012 Environmental Obiectives Reaulations Review Reason for Licence Review On the 28th July 2011, the Agency initiated a review of the IPPC licence held by Grove Turkeys Limited for the installation located at Smithsborough, County Monaghan, IPPC licence register number PO The reasons for initiating this review are in light of the requirements under the following Regulations: (1) The European Communities Environmental Objectives (Surface Waters) Regulations of6

2 (2) The European Communities Environmental Objectives (Ground Water) Regulations Company Grove Turkeys Limited is a producer and processor of poultry products, mainly turkeys. The installation takes in live turkeys and produces fresh and frozen whole turkeys and value added products. The installation operates 12 months of the year, with increased activity towards the end of the year, in preparation for the Christmas season, with a subsequent and significant increase in load to the WWTP. Monitoring data indicates that the effluent flow rate doubles for October and November, and is seven times the annual average during December. During the period of low activity the Licensee has the provision to import effluent for treatment (spare capacity and plant stability reasons), which is the basis for the Class 11.1 inclusion in the current licence. To date, this provision has not been utilised by the Licensee. The treated process effluent discharges to the Magherarney River. Consideration of the Objection The Technical Committee, comprising of Ann Marie Donlon (Chair) and Marie O Connor, has considered all of the issues raised in the Objection and this report details the Committee s comments and recommendations following the examination of the objection together with discussions with the inspector, Gavin Clabby, who also provided comments on the points raised. The Technical Committee consulted OEA in relation to surface water flow issues. This report considers the first party objection. No third party objections were received. The main issues raised in the objection are summarised below. However, the original objection should be referred to for greater detail and further expansion of particular points. First Party Objection The licensee makes 4 points of objection. Assimilative Capacity Assessment report. The objection is supported by an A.l. Condition The licensee shall provide and maintain a Wastewater Treatment plant at the installation for the treatment of sanitary effluent arising on-site. Any waste water treatment system and percolation area shall satisfy the criteria set out in the Code of Practice Wastewater Treatment and Disposal Systems Serving Single Houses (p.e 5 IO), published by the Environmental Protection Agency. The licensee requests that this condition be changed so that the licence requires sanitary emuent to be diverted to the on-site WWTP for further treatment. 73e licensee advises that the treatment plant has suficient capacity and this waste water stream would not adversely impact on the WWTP and discharge compliance. In particular this waste water stream would assist in raising the F/M ratio to the more favourable O.lkgBOD/ KG Mass. Technical Committee s Evaluation: 2 of 6

3 It is noted that requirement does not apply to the existing licence. The TC considers it reasonable to divert sanitary effluent arising at the installation to the on-site waste water treatment plant (WWTP). It is clear that there is capacity within the plant between January and September each year. It is a matter for the licensee to control and monitor the WWTP to ensure compliance with the ELV s set out in the licence. The diversion of sanitary waste water to the WWTP would not significantly change the character of the emission to the Magherarney River. The licensee did not provide a timeframe as part of their objection and six months is considered reasonable. Recommendation: Replace Condition 3.15 with the following: The licensee shall divert sanitary effluent arising to the on-site WWTP for treatment within six months of the date of grant of this licence or as otherwise agreed by the Agency. A.2. Condition The Licensee shall, within twelve months of date of grant of this licence, submit a proposal for the diversion of uncontaminated surface waters away from the WWTP. This proposal shall include details of the nature of the various surface water discharges arising at the installation, as well the number and location of any proposed discharge points. The licensee objeds to this condition as this would involve major site alterations and would yield no perceived benefit as average daily rainfall has been calculated at 18d/day. Technical Committee s Evaluation: This condition is a new requirement. The separation of process and non-process waste water is BAT. The application of this BAT intends to reduce water contamination and reduce energy consumption associated with treatment. However, the licensee in their objection raises a doubt as to whether significant reductions in emissions would be achieved without imposing excessive costs. Therefore, the TC considers that the licensee should firstly evaluate the application of this BAT and then apply measures as appropriate. I Recommendation: Reword Condition 3.17 as follows: The Licensee shall, within twelve months of date of grant of this licence, investigate and report as part of the Environmental Management Programme on the feasibility for the diversion of storm waters away kom the WWTP. This investigation,shall include details of the nature and quantity of the various storm water discharges arising at the installation, energy consumed during treatment, as well the number and location of any proposed discharge points. Any measures arising shall be implemented within a timeframe agreed by the Agency and reported in the AER. A.3. Condition Silt Traps and Oil Separators Subject to Condition 3.17, the licensee shall, where appropriate, and within a timekame to be agreed by the Agency, install and maintain silt traps and oil separators at the installation: 3 of 6

4 ~~ ~ ~ ~~ ~ (i) (ii) Silt traps to ensure that all storm water discharges, other than from roofs, from the installation pass through a silt trap in advance of discharge; An oil separator on the storm water discharge from yard areas. The separator shall be a Class I full retention separator, unless otherwise agreed by the Agency. The silt traps and separator shall be in accordance with I.S. EN-858-2: 2003 (separator systems for light liquids). The licensee objects to this condition for the same reasons set out in A.2 above and this condition is not necessary if all storm water continues to be treated in the site WWTP. Technical Committee's Evaluation: It is noted that a similar condition to install and maintain oil separators and silt traps is specified in the existing licence. This condition is subject to Condition 3.17 which is discussed under A.2 above. The TC do not want to pre-empt the outcome of the investigation and feasibility study now recommended under A.2 above and therefore do not see a need to remove this condition at this time. Recommendation: No change. A.4. Schedule B.2 Emissions to Water B.2 Emissions to Water Emission Point Reference No: Name of Receiving Waters: Location: Volume (m3) to be emitted: sw1 Magherarney River E; N January lst to October 1"to September 30th December 3lSt Maximum in any one day: 300 1,600 Maximum in any one hour: Parameter Temperature PH BOD Emission Limit Value 25 C (max) 6-9 mg/l 10 Note I COD Suspended Solids Nitrates (as N) Ammonia (as N) Ortho-phosphate Total Phosphorous (as P) Oils, fats & grease Chloride Note Nore Note 1: Annual Mass Emission Limit: 1095 kg/annum. 4 of 6

5 Note 2: Note 3: Annual Mass Emission Limit: 99 kg/annum. Annual Mass Emission Limit: 55 kg/annum. T The licensee objects to the ffow limits of 3OOd/day for the period Januaty to September as mass balance calculations using a combination of higher river ffows (O.O44d/s 95%ile now) and actual average concentrations (report attached to objection) indicate that the resulting concentrations in the Magherarney River would be in compliance with the EC EO (Sutface Water) Regulations The licensee also points out that they plan to increase production levels in the future with subsequent increased discharge volumes. Tech n ica I Com m ittee's Eva I ua t ion : The flow rate used (0.035m3/s) at the proposed determination stage was determined by the Hyrometrics unit within the Agency. The licensee estimated 95%ile flow rate of 0.044m3/s was based on the staff gauge at Magherarny Bridge. The discharge point from the installation is upstream of this staff gauge and the OEA highlighted that the licensee did not correct his estimated flow value due to differences in catchment sizes between the two points. Emission limit values specified in any licence are based on maximum acceptable concentrations (MAC) subject to interpretation. Average concentration limits are not typically used. The limiting parameter for this installation is for the most part, orthophosphate and the licensee does not propose an MAC less than 0.5mg/l orthophosphate (as P). Any substantial change proposed by the licensee in terms of expansion or intensification may require a review of the licence and should be notified to OEE in the first instance. The TC recommends retaining the specified volumetric limits until such time as the licensee proposes a more stringent MAC ELV for ortho-phosphate and thus maintaining the overall load limitations set out in the licence. 1 Recommendation: No change. I Overa I I Recommendation It is recommended that the Board of the Agency grant a licence to the licensee (i) (ii) and (iii) for the reasons outlined in the proposed determination and subject to the conditions and reasons for same in the Proposed Determination, subject to the amendments proposed in this report. Signed 5 of 6

6 Ann Marie Donlon for and on behalf of the Technical Committee 6 of 6