Licence application received: 09/06/98 Notices under article 11(2)(b)(ii) issued: 06/08/99 Information under article 11(2)(b)(ii) received:

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1 M E M O R A N D U M DATE: 10 th August 1999 TO: Each Board Member FROM: Dr Tom Stafford RE: Submission on application for IPC licence from E. Smithwick & Sons Ltd. (Trading as St. Francis Abbey Brewery) register number 448 Application Details Class of activity: Licence application received: 09/06/98 Notices under article 11(2)(b)(ii) issued: 06/08/99 Information under article 11(2)(b)(ii) received: Commercial brewing. 18/09/98 25/09/98 28/09/98 12/11/98 21/12/98 Site Visits/Meetings 16/05/98 05/03/99 Section 97 notice sent: 23/07/98 12/03/99 Section 97 response received: 23/09/98 16/04/99 05/08/99 Notices under article 17 issued: 19/02/99 Article 17 compliance: 19/04/99 Article 18(2) consent received 27/05/99 Company Profile The Saint Francis Abbey Brewery (SFAB) began when John Smithwick established a brewery on the site in In 1956 a public share offer was taken up by Arthur Guinness Son & Co. giving Guinness an interest in the company. In 1964 the Smithwick family sold the remaining shareholding to Guinness. In 1965 Smithwicks Brewery was integrated into Irish Ale Breweries Group which was two thirds controlled by Guinness and one third by Allied Breweries. In 1987 Guinness bought out Allied Breweries and Smithwicks became a full member of the Guinness Group. In 1996 the structure of the Guinness organisation in Ireland changed and E. Smithwick & Sons became known (trading as) St. Francis Abbey Brewery. In 1997 Guinness Group merged with Grand Metropolitan and the new organisation became known as Diageo plc. The brewery is currently capable of producing 1.2 million hectolitres (hl) of beer per year and anticipates expansion up to 1.6 million hl in the near future. Until 1986 the h:\licensing unit\licence determination\ippc\licence decisions\p0448\sfab report.doc

2 Brewery mainly produced an ale product, Smithwicks. Since then, the introduction of a new lager product, Budweiser, has seen this become the major output of the Brewery. The brewing process is carried out 24 hours per day all year round with two 12 hour shifts. The kegging plant normally operates a two 8 hour shift system during day time, commencing at 6.00am. However, kegging operations may operate an additional night shift depending on demand. The company currently employs 180 staff. Process Description The cereals for brewing namely malt, rice and chocolate malt are delivered in bulk and transferred to designated silos in the brewhouse block. The malt is first milled and mixed in the mash tun in the appropriate proportion and at a specified temperature with water and depending on the product required, rice (which is pre cooked in a separate vessel) or chocolate malt. The purpose of mashing is to use the enzymes in the malt to convert the starch to fermentable sugars and to break down the proteins and other malt materials. The mash is then transferred to the lauter tun where the worts or clear extract is separated from the spent grains and then transferred to the copper wort kettle where it is boiled. Depending on the product being brewed, liquid sugar, caramel, soluble brewing salts and hops may be added at the boiling stage. At the end of boiling, the worts are transferred to the whirlpool where the trub (solid material, e.g. grains, hops, protein precipitate from worts after mashing stage) is separated from the clear worts by centripedal action. Depending on the product,the clear worts are either cooled directly via a plate cooler, or are passed through a wort stripper where they are partially aerated before being cooled. Cooled worts are aerated/oxygenated before being pitched with brewing yeast en route or directly into the fermentation vessel. At the end of fermentation the flocculated yeast is first removed and the beer transferred to a Storage Tank. The beer is then filtered, carbonated and nitrogenated as appropriate, and either kegged on site or filled into tankers for bottling or canning at other locations. Proposed Determination Air: There are two boilers on site, one of MW rating and the other MW. Both are fuelled by natural gas. In addition there are two standby electrical generators onsite, 800 kw and 600 kw which are fuelled by gas oil. The generators are used for peak looping during the winter months and operate for about 225 hours per annum. The Proposed Determination (PD) requires the monitoring of the boilers for NOx and CO and the generators for SOx, NOx and CO on an annual basis. Carbon Dioxide, produced during the fermentation process, is recovered to levels at or around 90% and is reused in the kegging lines. The site is approximately 90% self-sufficient in Carbon Dioxide. CO 2 is emitted from the fermentation vessels in the early stages of the brewing process until the CO 2 reaches a purity at which it becomes possible to recover it. Roughly 900 tonnes of CO 2 are emitted every year which, in comparison with approx. 1.8 million tonnes from Irish Industrial sources in 1995, is not significant with respect to Kyoto agreement. The processes do emit a brewery type odour, consistent with hops and volatiles generated during boiling etc. While not generally considered objectionable, and no 2

3 complaints have been received in relation to odour, it is proposed to include a general condition in the PD prohibiting odour nuisance in Condition 5.5. Sewer: SFAB discharge large quantities of process effluent to the Kilkenny Co. Council sewer. Since the Council issued its Trade Effluent licence in 1986, production at the Brewery has increased significantly mainly due to increased sales of the Breweries main product Budweiser. With the exception of ph balancing no on-site treatment of effluent takes place. The parameter of most concern in relation to the breweries effluent discharge is its organic load in terms of BOD 5. The 1986 Trade Effluent licence allowed the Brewery to discharge up to 2730 kg/day BOD based on the capacity of the Councils WWTP which was apportioned as follows: Source Kg/day BOD Saint Francis Abbey Brewery 2,727 Kilkenny Corporation/County Council 1,528 Small Industry (including allowance for expansion) 613 Purcellsinch Industrial Estate (former Fieldcrest factory) 1,591 Total 6,459 Shortly after the WWTP plant was opened in 1979, the Fieldcrest plant closed and the allocation available to the IDA has not since been utilised by a replacement industry. Hence during expansion of the Brewery in the late eighties/early nineties, the County Council were in a position to accept an increased loading of up to 4,000 kg/day BOD from the Brewery SFAB currently produce 1.2 million hectolitres (hl) of beer per annum. The effluent BOD loading arising from this operation during peak production may reach 6,500 kg/day BOD, of which 4,000 kg/day is discharged to sewer and the remaining 2,500 kg/day is land spread. Current daily averages are estimated at 5,000 kg/day BOD with approximately 2,600 kg going to sewer. Soil injection of Brewery Wastes commenced in September 1997 in response to operational difficulties experienced by the Council at the Purcellsinch WWTP and is discussed below under Land Spreading Activities. This IPC licence application is accompanied by two separate Environmental Impact Statements, one for the Installation of 3 no. Fermenter/Storage Vessels submitted with the IPC application and one for the Installation of 5 no. Fermenter/Storage Vessels.. submitted subsequent to the IPC application. This proposed expansion will result in a production capacity for the Brewery of 1.6 million hectolitres per annum. It is estimated that this increase in production will result in an increased effluent BOD loading from the Brewery of 20% resulting in an average load of 6,000 kg BOD/day and a peak load of 7,800 kg/day. The current effluent to sewer limit of 4,000 kg/day BOD available to the Brewery is the maximum allowable given the capacity of the WWTP at Purcellsinch. It is understood that the Brewery and Kilkenny County Council have entered into discussions in relation to expansion of the Purcellsinch plant. This expansion would allow for a reserved treatment capacity for the Brewery of 8,000 kg BOD/day and an additional 3,732 kg BOD/day for all other sources, giving a total capacity of 11,732 kg BOD/day. In these circumstances the Brewery would be responsible for 67% of the total capacity of the waste water treatment plant. 3

4 The proposed determination does not include limits for the proposed expansion of the Breweries operation as the Kilkenny County Council (Sanitary Authority) are not in a position at this time to make the required capacity available to the Brewery. However, the PD does include a Condition (6.6) requiring the licensee to undertake an investigation into the use of cleaner technology and/or alternative production methods for the reduction of effluent arising on site, or where this is not possible the treatment of same. There may be sufficient scope in this approach to allow the Brewery to expand it operations and to live within the effluent discharge limits in this Proposed Determination. Should this not be the case, either the licensee or the Sanitary can initiate a review of the IPC licence. Section 97 consent was received for the discharge and the conditions in the PD were drafted accordingly. A 10,000mg/l COD hourly max. limit proposed by the Sanitary Authority has been imposed to ensure that shock loading of the WWTP at Purcellsinch does not occur. On the recommendation of the Sanitary Authority a condition (10.5) has been included which requires the licensee to submit a proposal relating to the precision, accuracy and reliability of all monitoring and analysing equipment for monitoring emissions to sewer. Non-Process Water There are 17 surface water emission points from the site to the Rivers Nore and Breagagh. These are all for stormwater run-off from yard and roof areas. No monitoring results for these discharges was included in the IPC application. It is proposed to carry out a survey of surface water quality in the absence of the above information which is conditioned in Condition of the PD and is to be carried out under the EMP. In 1980 a spillage of PCB on site (500 litre) resulted in the contamination of the River Breagagh. More than 95% of the contamination was removed in a clean-up operation directly after the spill. The Brewery have agreed a further programme of remediation of the River bed with the County Council which will commence shortly. Condition 9.2 requires a firewater retention assessment to be carried out. Condition 9.3 controls bunding arrangements on site. Waste: A number of hazardous and non-hazardous wastes are generated by the activities on site at SFAB. Hazardous wastes include fluorescent lamps, waste oils, waste laboratory chemicals and microbiological plates. Extensive recovery/recycling of other waste streams is in place with glass, cardboard and wooden pallets all segregated for recycling purposes. Waste Yeast and spent grains are used as animal feed with general waste being sent to landfill. Landspreading Provision is made for land spreading of Brewery effluents under Condition 7.5 of the PD. The waste streams to be land spread are as follows: Weak Worts Waste Beer Tank Bottoms The total volume is estimated as 51m 3 per day which equates to a BOD loading of 2400 kg/day. With the exception of Tank Bottoms, which constitute 25% of the volume spread, the additional wastes have little by way of nutrient value and are in effect a waste disposal operation. 4

5 All of the standard provisions which are required for land spreading of wastes have been included in this Proposed Determination. The licensee is required to provide six months storage on-site for landspread wastes which equates to 9,300 m 3. Storage capacity is not a problem on-site, however storage of increased volumes of liquid wastes will limit production capacity. Condition specifies that Effluent shall not be removed to off-site storage facilities without prior written approval by the Agency. Where this is to be allowed Condition specifies: Storage facilities off-site shall be certified as integral by a structural engineer prior to storage of effluent. Certification of off-site storage facilities shall be undertaken yearly. Certificates shall be available for inspection by any authorised persons of the Agency, at all reasonable times and copies shall be included as part of the AER. This condition is in response to a incident where effluent from SFAB was transferred off-site by Landfeeds Environmental Ltd and stored in a Farmyard storage tank. Effluent leaked from the storage tank and was released into a tributary of the River Barrow resulting in a fish kill. The Brewery utilises 2 landbanks for soil injection of effluents. The usable area of the land banks totals 1,036 hectares and is sufficient for the disposal of 40,800 m 3 /annum of Brewery effluent. One of the landbanks, that operated by Greenfields Environmental has been prohibited from use under Condition until such time as sufficient information on ground water vulnerability has been received by the Agency. Noise: The site is located in Kilkenny City Centre on Parliament Street, a predominantly commercial business area. It is located between the River Nore to the East, Parliament Street and Vicar Street to the West, Green Street to the North and a commercial car park (Dunnes Stores) to the South. The noise sensitive locations identified as immediate to the site are as follows: Dwelling houses along Vicar Street; The Theatre and Youth Hostel (No. 35) on Parliament Street; The public park area between the site and the Nore to the north-east of the site; The public park area along the far bank of the Nore to the east of the site and the dwelling houses behind that park on Michael Street. The operations of SFAB vary considerably over the period of the day. The brewing is carried out 24 hours per day throughout the year while kegging operations are performed generally on a 2 shift system which commences at 6.00 am. The applicant has stated that a three shift (24 hour) kegging operation may be required on occasion depending on demand. No complaints in relation to noise have been received by the company or the Agency. The plant is located in a busy city centre location and the impact of noise emissions during day time operations is not significant. Traffic is the dominant source of noise in the area and so the proposed determination primarily deals with tackling of problem noise sources in order to protect Noise Sensitive Location s. The Noise survey undertaken for the licence application indicated a number of tonal and impulsive qualities to some of the noise emissions from the site. The company proposes to address these noise emissions and to investigate noise reduction measures for a number of on-site sources. This improvement programme is conditioned in the proposed determination and incorporates a targeted approach towards eliminating noise sources that may impact on sensitive receptors. The company is required to comply with Agency guidance on Noise at noise sensitive locations within 18 months of date of grant of licence. 5

6 Residuals Management/ Environmental Liabilities Having considered the on site activities and reviewed latest Agency guidance in this area, it is not considered necessary to include any conditions in these areas. Environmental Improvement Projects The most obvious candidate for cleaner production in breweries lies in the untreated wastewater with very high organic content. The PD (Condition 6.6) requires the licensee to...undertake an investigation into the use of cleaner technology and/or alternative production methods for the reduction of effluent arising on site, or where this is not possible the treatment of same..... In addition, a series of objectives and targets have been included in Schedule 6(I) of the licence which are derived form information provided in a United Nations Environment Programme publication entitle Environmental Management in the Brewing Industry These objectives and targets relate to consumption of raw materials and energy and the production of wastes and by-products. The target figures included are those provided in the UNEP report as those achievable for a brewery with low consumption figures Submissions Six submission were received on this application: 1. The Southern Regional Fisheries Board 2. The Purcellsinch Business & Residents Group 3. Department of the Marine and Natural Resources 4. Mr Donal Deering 5. Mr Donal Deering 6. The Purcellsinch Business & Residents Group The issues raised were as follows: The Southern Regional Fisheries Board (Received 10/6/98) The submission constitutes a copy of a letter dated 15 May 1998 to Kilkenny Corporation in relation to the Application for Planning Permission by E. Smithwick and Sons Ltd., for extension of existing fermenter/storage vessel block and ancillary works (145/97). As such the submission centres on the content of the EIS submitted as part of the above application. The SRFB raise concern with regard to disposal of certain wastes by soil injection and in particular argues for the use of the most recent Teagasc phosphorus recommendations in the assessment of the land-bank. The submission specifically addressed spreadlands outlined in the EIS who s P levels exceed these guidelines. The land bank which was submitted as part of the IPC application (additional information) does not contain lands referred to in the submission by SRFB. The land banks submitted were assessed on the basis of exclusion of lands with a soil P value in excess of 15 mg/l. These lands are excluded from the land-bank in Schedule 3(iv) of the PD. The applicant bases the application rate of slurry on REPS (pre May 1996) figures. Revised recommendations reducing REPS and agronomic P application rates were implemented by Teagasc in May 1996 and June 1997 respectively. The quantity of 6

7 on-farm waste to be applied to the landbank will be incorporated into a NMP prepared to the satisfaction of the Agency. In the PD the applicant is required to submit an NMP each year for approval. Thus there is opportunity for the Agency to reduce application rates if the soil monitoring results indicate that there is P accumulation in the soil. Monitoring of soil fertility status is requested every two years for soils 10 mg P l -1 and annually for soils >10 but 15 mg P l -1. This testing rate exceeds that recommended by Teagasc for agronomic recommendations. Also, the PD provides for extensive buffer zones in the vicinity of water courses which further mitigate the risk of excessive P movement from the soil to waterways. The overall thrust of the licence conditions is to ensure that the input of P to the soil is balanced by the output of P via the cropping regime. The PD requires annual testing of the nutrient content of the slurry. Purcellsinch Business and Residents Group (Received 14/7/98) This submission relates predominantly to the effect of the Brewery effluent on the Waste Water Treatment Plant at Purcellsinch. The submission outlines the problems local residence have experienced with respect to odour from the WWTP, which, they were informed by Kilkenny County Council engineers are Brewery related. The submission requested a meeting with the Agency to discuss the problems. As the waste water treatment plant at Purcellsinch is under the control of the Sanitary Authority, Kilkenny County Council, and a Section 97 consent has been received from same accepting the effluent from SFAB, these issues are not within the control of this proposed Integrated Pollution Control Licence. A meeting was held with the Purcellsinch Business and Residents Group at Agency Headquarters and the situation with regard to the scope of this licence was explained. During this meeting the representatives were introduced to Dr Matt Crow and the Agency s role under Section 63 of the Act was explained. Nonetheless, this proposed determination does contain Condition (6.6) requiring the Licensee to...undertake an investigation into the use of cleaner technology and/or alternative production methods for the reduction of effluent arising on site, or where this is not possible the treatment of same.... This proposal will be available and open to the public to comment on following receipt by the Agency. Condition 2.9 of the PD also requires the licensee to provide a programme to ensure that members of the public can obtain information on the environmental performance of the licensee. Department of the Marine and Natural Resources (Received 6/8/98) This submission briefly states that the point raised in Section 5.5 Impacts and Mitigation of the EIS are acceptable and should be made a condition. These points are as follows: Soil injection to be carried out in accordance with Code of Practice contained in EPA Guidelines Soil NMP to be adopted and agreed with the Agency Upper limits on application rates of 50m3/HA per single application and 250 kg N/HA per annum not to be exceeded. Only lands conforming with the soil NMP to be used for soil injection. The above point have been fully addressed in condition 7.5 of the PD which deals with landspreading of organic waste. 7

8 Mr Donal Deering (Received 29/9/98) This submission relates to the operation of the Waste Water Treatment Plant at Pursellsinch and is beyond the scope of this proposed IPC licence. A copy has been forwarded to the local authority to consider and reply. Mr Donal Deering (Received 2/10/98) This submission relates to the following: Dumping of PCB s into the Bregagh River Failure of the Waste Water Treatment Plant at Purcellsinch Environmental Management at the Brewery Dumping of PCB s into the Bregagh River The issue in relation to contamination of the River Bregagh has been addressed above under Non-Process Water. Failure of the Waste Water Treatment Plant at Purcellsinch The Agency has been informed of one incident where acid from the Brewery has resulted in shock loading, indeed, elimination of some operational elements of the Purcellsinch WWTP. In this incident an incorrect connection during commissioning of the on-site ph balancing tank resulted in 3,774 litres of concentrated sulphuric acid being pumped to sewer. As a result of this incident, a ph alarm system has been installed on the ph neutralising station which has been installed in the brewhouse panel, which has operator presence 24 hours per day. The Sanitary Authority have imposed a limit of 10,000 mg/l COD (1 hour max) on the discharge to sewer to protect the WWTP from shock loading. The Applicant is currently commissioning a continuous monitor which will allow measurement of COD, BOD and other parameters. Condition (10.5) of the PD requires that : The licensee shall within six months of the date of grant of this licence submit a proposal to the Agency on the monitoring and analysis equipment to be employed for monitoring the effluent discharge to sewer. This proposal shall detail the precision, accuracy and reliability of each of the proposed monitors and analysers. This should allow for adequate monitoring and control of effluent discharges from the plant such that shock loading of the Municipal WTTP should not occur. Environmental Management at the Brewery No specific details were given in the submission in relation to the above and as such it cannot be addressed. Condition 2 of the PD specifically addresses the Environmental Management of the Activity with particular emphasis on certain aspects of the activity. Purcellsinch Business and Residents Group (Received 24/11/98) This submission relates predominantly to the effect of the Brewery effluent on the Waste Water Treatment Plant at Purcellsinch, specifically the following: Odours from the WWTP; Expansion and upgrading of the WWTP; Overloading of the plant; Inequity in the financial contribution by SFAB versus the capital and running costs of the plant; 8

9 Shock loading of the plant and subsequent discharge of semi-treated effluent to the River Nore; The Shielding Effect of SFAB, i.e. the brewery do not have to take responsibility for any problems down stream; Suitability of WWTP design for the nature and concentration for Brewery effluent; The use of on-site treatment as an alternative by the Brewery. The Purcellsinch Business and Residents Group suggest a preferred BATNEEC Solution of; A combination of on-site treatment; On or off-site anaerobic digestion of concentrates; Very low grade high volume treatment at Purcellsinch with continuous emissions monitoring with sever peak load restrictions of BOD level to substantially below the licence (Trade effluent) level of 2700 kgs BOD As may be seen from the above, the majority of this submission relates to the operation/expansion of the WWTP at Purcellsinch and as such is beyond the scope of this proposed IPC licence. A copy has been sent to the local authority for consideration. In relation to the Groups proposals for a preferred BATNEEC Solution, as previously mentioned, this proposed determination contains Condition (6.6) which requires the licensee to evaluate the implementation of cleaner technologies, alternative production methods and on-site treatment with the aim of reducing the effluent load from the Brewery. Objectives for a low consumption brewery have been included in Schedule 6(i) of the PD. Land spreading of effluent is viewed as an interim solution to the Breweries effluent loading problem. It is intended that with a determined drive towards cleaner production that this option may be obviated. However, retention of land spreading may be considered as a peak looping option should this obviate the need to expand the WWTP at Purcellsinch while allowing expansion of the Brewery to its target production capacity of 1.6 million hectolitres per annum. Recommendations: That the Board approve the proposed determination as submitted. Signed Dr Tom Stafford 9