Reg No: P For inspection purposes only.

Transcription

1 IFIXIS DNMENrAL SERVICES Niamh Connolly, Licensing Inspector, Environmental Licensing Programme, Office of Environmental Sustainability, Regional Inspectorate, McCumiskey House, Richview, Clonskeagh Road, Dublin RE: Further Information as Requested by the Agency in accordance with Regulation 10(2)(b)(ii) of the EPA (Industrial Emissions) (Licensing) Regulations To whom it may concern, Reg No: P With regard to the additional information requested by the EPA in respect of the Industrial Emissions Application, Robert Smyth and Sons have issued the following response. No. A: Clarification on Discharge of Truck wash Water used for washing the trucks is collected in underground interceptors prior to discharging to a small surface water drain which eventually discharges to the River. The septic tank is treated via a percolation area. No. B: Truck wash (1) Volume of water Used at the truck wash The volume of water used at the truck was is not metered. Therefore, an estimate was made of the volume of water used per truck at approximately 4 litres per minute taking a maximum of 60 minutes to wash. This is approximately 240 litres per truck with approximately 2-6 trucks washed per day. That would be an estimated discharge of 1,440 litres per day (1.44 m3/day) during the busy period which is winter and 880 litres per day (0.88 m3/day) in the off peak seasons.

2 r ULNTAL SERVICES Tel Analysis of water from the truck wash Independent Analytical Supplies Test Re port I Lab Report Number: 1975K01 Analysis Number: 99AI I Customer ID: SMYT D3 Analysls Type: MDC Tests (99A) Contact Name: Comwny Name: Address: Sample Type: Sample Reference: Sample Description: AlDAN FALLON SMYTHS DALESIDE FEEDS BALLINDRAIT LIFFORD CO DONEGAL Effluent EFFLUENT SAMPLES A Dellvery By: Sample Card Number: Sample Condltlon: Courier G/2 Acceptable Date Sample Recelved: 14/03/2018 Date Analysls Commenced: 14/03/2018 Date Certlflcate Issued: 29/03/20 18 Total Suspended Solids 105'12 SOP I mal Total Nitrogen I Dlgestion/Colourtmetry SOP 2075 I mgll Signed r/3 (\/Lccu Date 29/03/2018 Wendy McCall - Laboratory Manager - not INAB Accmdlted - Subcontracted Thla report must not be reproduced except in full without the prior written approval of IAS Laboralories This reporl relates only to the sample submitted Oplnlonr and interpretations exqressed herein are 0uIwde the acope of INAE actrednation Uncertainty of Measurement has been calculated for all INAE accredited tests and is available upon request I 4010 Issue 3 IAS LABORATORIES. Unit 4 Bagenalstown Bus Park, Bagenalstown. CO Carlow, Phone Fax ias@iaslabs lo Web www iaslabs le

3 RXIS ONMENIAL SERVICES 4587'-' (111) Clarification of any detergents I Chemicals The only product used at the truck wash is Traffic Film Remover. This has been included in table G format Ref. Material/ CAS Danger@) NS or Substance(') Number Category Amount Annual Nature of RW- Phrase SW - Hazard Use Statement t4 Stored Usage Phrase Code (tonnes) (tonnes) 65 Traffic Film Remover Sodium Hydroxide Polycarboxylate compound Truck wash 52 None S Non-ionic surfactant Amphoteric surfactant Naor I Material/ I N/a Code Substance Odourou s YeslNo Odour Description Threshold PQirn' 65 Traffic Mild Nla Film Remover 36/38 I I Pollutants (Tick and specify GrouplFarniIy Number) EC EO (Surface Waters) EC EO Groundwater) REACH y/n ReQulallOns 2009 Regulabons 2010 Specific Priority Hazardous' Nonpollutants (hazardous) hazardow' substances SVHC"' N/a N/a Nla N/a No No 36 Substances hazardous substance (3)

4 mxis IRONMENIAL SERVICES Tel Undertake an assessment and evaluation of the capacity and appropriateness of the existing abatement system to treat truck wash From review of the outlet results the water discharged from the truck was is of high quality. There is limited information in relation to the truck wash on site. A thorough investigation was carried out to find any information either in house or from the supplier as to the details however this proved unsuccessful. The supplier has gone out of business since it was installed. The truck wash was measured at 6' deep, 11' long and 5' wide, designed and supplied as fit for purpose as a truck wash oil and solids interceptor. The truck wash is completely underground with very restricted access. A sample of water above was obtained from the outlet of the truck wash which was of good quality suggesting that the truck wash is appropriate for its purpose. Maintenance Schedule I Programme The interceptor is cleaned out on an annual basis by an approved contractor. There are no mechanical parts or items required that could fail with the exception of overloading the system and not cleaning it. It is proposed that a formal procedure will be produced for the annual cleaning of this unit and annual testing of discharge water to ensure that the system operates to a high standard. No. C: Clarify the number of employees at the installation There are c. 36 employees at the mill. No. D: Confirm how sanitary water is treated and disposed of All water from the toilets is treated in a septic tank and final discharge waters are discharged through a percolation area. No. E: Clarify the type of fuel used in the 2 boilers on site The main boiler is a dual fuel boiler LPG/ Diesel gas oil. The boiler would consistently operate on LPG unless there was an issue with the supply or other that prevented use of LPG. The standby boiler operates on diesel gas oil only and would only be used occasionally as a backup in the event of an issue with the main boiler. No. F: Compliance with limits applied The boilers can comply with emission limit values of NOx 650 and SO2 350 mg.m-3 referenced to 3% Oz. No. G: Extraction Fans I Ventilation Fans from Intake or Grinder area All emission points to atmosphere have been included in the application previously. Intake has a bag filtration system however this is within an enclosed building and the air is filtered and returned inside the building. There are no emission points to atmosphere from the grinder area. There are no updates to Table E of the licence application already submitted.

5 ICIXIS DNMENIAL SERVICES No. H: Noise Monitoring Results Location B1 was at the entrance gate of the mill and subject to noise from traffic on the adjacent road, trucks passing within 1 meter of the noise meter and on site traffic. This is not a noise sensitive location. Location 82, 83 and B4 were all located on site in very close proximity to the mill activities. These were not noise sensitive locations. The meter was erect at the nearest noise sensitive location to assess noise from the facility off site. During the day time the location was fully compliant with the limit value of 55 db(a) including traffic movements on the adjacent road which are not associated with the mill. During the night survey there was interference from road traffic not associated with the mill and dogs barking in a neighbouring dwelling. When these interfering noise sources were removed from the noise survey the resultant noise level from the plant were 46 db(a) for day time and 37 db(a) for the night time survey. A map of the proposed monitoring points for three nearest noise sensitive locations in the vicinity of the plant is attached. The distance from the closest boundarv to each location is on the mad. ' 1"J.B 'i" :. MILLSESSIAG F....'. I..*.

6 I "' 7 x I 5 MfNlA.1 SERVICES. --- No. I: Annual Fuel Consumption Fuel 2016 Consumption Where used Diesel Gas Oil 103,000 litres Fork trucks, artic trailer blower engines, back up boiler fuel LPG 97,016 litres Boilers Auto Diesel 363,000 litres Lorries, Tractor No. J: Storage for Fuel Fuel Diesel Gas Oil LPG Auto Diesel Storage Volumes 2,500 litres 12 tons (c. 23,000 litres) 27,000 litres An updated Technical summary is also attached to this reply. If you have any further queries, please do not hesitate to contact me, Yours Sincerely,

7 Industrial Emissions Activity Licence Application Updated Non-Tec h nical Summary Version 3 NVIRONMENTAL SERVICES

8 Smyths Daleside Feeds Industrial Emissions Activity Licence Application Updated Non-Technical Summary Revision 3 2 Attachment No.A

9 C AI Introduction to Smyths Daleside Feeds Smyths Daleside is based in Ballindrit, Lifford, CO Donegal producing a range of Animal Feeds. There are c. 38 employees working in the activity. The site is required to obtain an Industrial emissions licence in line with the First Schedule to the EPA Acts as amended. A2 Installation Activities The installation is applying to the EPA for an Industrial Emissions Activity Licence for the following activity: 7.8(a) The treatment and processing, other than exclusively packaging, of the following raw materials, whether previously processed or unprocessed, intended for the production of food or feed from: Only vegetable raw materials with a finished product production capacity greater than 300 tonnes per day; Industrial Emissions Directive Class 6.4( b)ii The treatment and processing, other than exclusively packaging, of the following raw materials, whether previously processed or unprocessed, intended for the production of food or feed from: Only vegetable raw materials with a finished product production capacity greater than 300 tonnes per day; EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations 2006 do not apply to this facility. A3 Material and Energy Usage Diesel and electricity are used to provide heat and power. Diesel, Molasses and Vegetable oils are all stored in silos which are within the confines of bunds or on hardstanding areas to protect ground and surface waters in the event of spillage. A4 A4(i) Sources of Emissions Emissions to Atmosphere There are 2 boilers on site, duty and standby. The duty operates on LPG normally with diesel gas oil as a back-up. This is a small boiler which is not considered a major emission point. Both boilers comply with the emission limits of 350 and 650 for SO2 and NOx respectively. There are 3 cooler emissions which are fitted with cyclone filtration systems in line with BAT. A4(ii) Emissions to Water There are no process emissions from this activity to water with the exception of water from the truck wash. This is treated in an oil/ silt interceptor prior to discharge via land drain to the river. A4(iii) Emissions To Sewer There are no process emissions to sewer from site operations. A4(iv) Emissions To Ground / Groundwater There are no emissions to soil or groundwater with the exception of the septic tank (toilets and canteen) via a percolation area. A4(v) Noise Emissions There are no noise sensitive locations impacted by the activity. It is policy to control noise generation by choice of equipment and plan abatement controls by practical measures A4(vi) Nature and Quantities of Emissions The main emissions from site are oxides of nitrogen and sulphur from the boiler. There are no process water emissions. Volumes of waste from site are also very low. Waste volumes are recorded on site as part of the accounting systems and site management. 3 Attachment No.A

10 - A4(vii) Abatement Coolers are fitted with cyclone filtration systems The grinders are fitted with bag filters and recirculate air inside the building. The truck was is fitted with an oil1 silt interceptor and discharged to a land drain. A4(viii) The amount of waste from the installation is small. Competent contractors have been appointed for waste management off site. Hazardous waste from site is limited to waste oils from hydraulic equipment and spent fluorescent tubes. A4(ix) Measures for Waste Reduction The company has implemented LEAN manufacturing systems which is a leading system for minimising waste and optimising process efficiency. The company has implemented many new and different approaches on site to ensure the volumes of energy consumed are efficiently managed, and that wastage is minimised. A4(x) Accident preventative procedures in place on site including training of operatives. Most liquid raw materials of environmental significance are stored in bunded areas. The site operates a preventative maintenance schedule for its operation. A4(xi) Measures for Permanent Cessation The installation is not contaminated. In the event of closure the company is committed to ensure the site is cleared to an environmentally sound state in line with EPA policy requirements. A4(xii) Boiler Emission Storm water Nature and Quantities of Waste Preventative Measures to Prevent Pollution Measures Planned to Monitor Emissions Annual Flue Gas Monitoring Annual storm water sample to be analysed. Air Emissions Total Particulate Monitoring A4(xiii) Measures for minimising pollution over long distances or outside Irish Territory The type of activity, location and nature of pollutants mean that there is no risk of pollution outside the territory of. A5 Environmental Impact Statement The activity is not listed in the planning regulations to produce an EIS for planning permissions. A6 Best Available Techniques I BREF BAT has not yet been described for licensable feed production activities. However, operations in the installation are designed and managed to the best available technology. Further information has been supplied to the EPA relating to Energy efficiency of the site and storage arrangements. 4 Attachment No.A