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2 1. Details of how the Air Quality Standards will be met particularly in relation to SO x and NO x and demonstrate the means by which this will be achieved. Source of Emissions SO x and NO x emissions are generated from the five heavy fuel oil (HFO) boilers (BP-1 to BP- 5) located in the three boiler rooms (refer to A8787-N006-B Emissions to Atmosphere Drawing E1.1). It should be noted that boiler BP-3 with emission point A1-3 is not operational. The five boilers were installed during the period At this time the combustion of HFO was considered acceptable on a national industrial scale for use in the generation of steam. At any one time typically three boilers will be in use. Up to three boilers will be operational 24hrs per day from March to October. During the off-peak season (November to February) typically one boiler will be operational 24hrs per day. Usually this will be running for a period depending on processing requirements. It may be the case that the boiler would not be operating for a month or longer. An example of SO x and NO x emissions recorded at the emission points are referenced in Table 1.1 below. Table 1.1 Stack Emission Details using 1% Low Sulphur Fuel HFO Stack Reference NO X (mg/nm 3 ) SO 2 (mg/nm 3 ) A A A Fuel Legal Compliance Council Directive 1999/32/EC of 26 April 1999 relating to a reduction in the sulphur content of certain liquid fuels states that from 1 January 2003 heavy fuel oils are not permitted to be used if their sulphur content exceeds 1% by mass. Arrabawn use HFO (max 1% sulphur) as the fuel source for the generation of steam. An example specification sheet is enclosed (refer to EMO Product Specification sheet at the end of Response No.2) to demonstrate that although the maximum concentration is 1% Sulphur, the average concentration is approximately 0.8%. In order to reduce the risk to health from poor air quality, national and European statutory bodies have set limit values in ambient air for a range of air pollutants. These limit values or Air Quality Standards are health- or environmental-based levels for which additional factors may be considered. The ambient air quality standards for NO 2 and SO 2 are outlined in S.I. No. 271 of 2002 and referenced on Table 1.2 below. 1 EPA Export :21:37:19

3 Table 1.2 Ambient Air Quality Standards Pollutant Regulation Limit Type Margin of Tolerance Value Nitrogen Oxides Sulphur dioxide S.I. 271 of 2002 S.I. 271 of 2002 Hourly limit for protection of human health - not to be exceeded more than 18 times/year Annual limit for protection of human health Annual limit for protection of vegetation Hourly limit for protection of human health - not to be exceeded more than 24 times/year Daily limit for protection of human health - not to be exceeded more than 3 times/year Annual & Winter limit for the protection of ecosystems 50% until 2001 reducing linearly to 0% by % until 2001 reducing linearly to 0% by 2010 None 90 µg/m 3 until 2003, reducing linearly to 0 µg/m 3 by µg/m 3 NO 2 40 µg/m 3 NO 2 30 µg/m 3 NO + NO g/m 3 None 125 g/m 3 None 20 µg/m 3 Dispersion Model In November 2006 Arrabawn commissioned AWN Consulting Limited to carry out an air dispersion model exercise for the facility (based on worst case conditions). Predicted ambient ground level concentrations were below the relevant air quality standards for nitrogen dioxide and as such, do not require further investigation. Predicted ambient ground level concentrations exceeded the relevant air quality standards for sulphur dioxide (refer to Table 1.3 below). 2 EPA Export :21:37:19

4 Table 1.3 Predicted Ambient Ground Level Concentrations Pollutant / Scenario NO 2 / Maximum Operation SO 2 / Maximum Operation Annual Mean Background (µg/m 3 ) Averaging Period 15 Annual Mean 99.8 th %ile of 1-hr means th %ile of 1-hr means 99.2 nd %ile of 24-hr means Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standar d (µg/nm 3 ) Compliance & Future Plans In recent years there has been a slight shift to the use of Natural Gas for environmental benefits (reduces SO x & NO x emissions), economic benefits and available supply. At Arrabawn s request, a meeting was held on 28 th February 2006 with a number of the North Tipperary politicians to discuss the availability of natural gas for Nenagh town. This issue was due to be followed up and discussed with the Minister, but to date no formal response has been received. According to Bord Gais Networks:- For a town to be connected to the gas network, certain economic criteria need to be satisfied. This is to ensure that over a certain period the costs of connecting the town are paid for through the consumption of gas and the associated tariffs. In April 2006 a new connection policy was published (CER/06/032), setting out revised criteria for the connection of new towns. Where towns, under the old policy, were deemed to be uneconomic and therefore did not qualify for connection, under the new policy some of these towns may qualify under the new criteria. The purpose of this study is to evaluate the connection of towns under the new policy (source Terms of reference for New Town Evaluation Working Group Study, Cer/06/125, June 2006). The reports are expected to examine individual towns and towns grouped on a geographic/regional basis, which currently are not connected to the gas network, to ascertain the feasibility from a gas economics perspective of connection under the new connection policy to the gas network and identify what towns, or groups of towns, qualify for connection. The Commission for Energy Regulation s (CER) decision on the extension of the natural gas network to eleven towns along the route of the Galway to Mayo pipeline was announced on 3 November This announcement was made under Phase 1 of a study into the viability of connecting new towns along this pipeline route. Towns were evaluated based on the expected demand for gas, and the cost for connecting that town to the network over a 25 year period. Phase 2 of the New Towns Analysis under the Connections policy is continuing, with the viability of connecting other towns in other parts of Ireland to the gas network being reviewed (source CER Newsletter Volume 2, Issue 6, December/January 2007). 3 EPA Export :21:37:19

5 Arrabawn has lobbied Bord Gais in the past to provide a connection for Nenagh town. But at the time the town did not support sufficient supply requirements for natural gas, hence Bord Gais postponed proposals to extend the pipeline for the short-term. Over the last decade Nenagh town has expanded rapidly and continues to do so. Arrabawn are in the process of reopening the lines of communication and are requesting that the town be reconsidered for the Phase 2 New Towns Analysis. Although BAT refers to best available techniques (as defined in Section 5 of Environmental Protection Agency Acts, 1992 and 2003, and Section 5(2) of the Waste Management Acts 1996 to 2005), the costs and benefits of the available options are required to establish the best option. The most environmentally friendly and economically viable option for Arrabawn is to transfer the entire system to natural gas fuel. The company is committed to this conversion should natural gas become available in Nenagh. In the absence of a Natural Gas supply for the town, Arrabawn has undertaken an assessment of other viable options. In the intervening period (following receipt of the EPA s requirement for supporting information to the IPPC Licence Application) Arrabawn has carried out some research and cost benefit analysis into upgrading the boilers. During this assessment period it was determined that replacement of HFO by alternative fuels (e.g. light fuel oil) was not economically viable. Replacement of the burners was originally considered as an option to increase efficiency of the system, however following a review by Arrabawn and discussions with the suppliers it was established that substituting the burners would not reduce the SO x emissions to meet the BAT requirement. 2. Clarify the Sulphur content of heavy fuel oil in use at the installation Heavy fuel oil (HFO) is supplied to Arrabawn by two companies, namely Inver Energy Ltd. and Emo Oil Ltd. Both suppliers deliver HFO with a sulphur content of <1%. HFO is regulated for industrial use and is governed by the British Standards BS:2869 Class G where a maximum of 1% sulphur is permitted. Emo Product Specification (enclosed) Maximum sulphur is reported as 1%; typical at 0.8% (downloaded from EMO web-page Inver Specification Sheet (enclosed) Max sulphur content is reported as 1%. Table E.1(i) has been amended to reflect the maximum sulphur content utilised at the installation and is enclosed with this response. The only changes to these tables is the reference to section Boiler Fuel, % Sulphur Content. 4 EPA Export :21:37:19

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8 TABLE E.1(i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Emission Point Ref. N o : A1-1 Location : Grid Ref. (12 digit, 6E,6N): Boiler House E, N Vent Details Diameter: 0.65m Height above Ground(m): Date of commencement of emission: 33.5m May 1973 Characteristics of Emission: Boiler rating Steam Output: Thermal Input: Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content: kg/hr 8.67 MW Heavy Fuel Oil kg/hr Low Sulphur Oil (<1% Sulphur) NOx 756 mg/nm 3 0 o C. 3% O 2 (Liquid or Gas), 6% O 2 (Solid Fuel) Maximum volume of emission 10,160 Nm 3 /hr Temperature o C(max) o C(min) 254 o C(avg) (i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included): Periods of Emission (avg) min/hr hr/day day/yr Peak Season: Typically the boiler runs 24 hours per day during March October (three boilers collectively). Off-peak Season: Generally, one boiler runs 24 hours per day from November to February but at times other boilers may be running for a period depending on processing requirements. EPA Export :21:37:19

9 TABLE E.1(i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Emission Point Ref. N o : A1-2 Location : Grid Ref. (12 digit, 6E,6N): Boiler House E, N Vent Details Diameter: 0.65m Height above Ground(m): Date of commencement of emission: 33.5m May 1973 Characteristics of Emission: Boiler rating Steam Output: Thermal Input: Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content: kg/hr MW Heavy Fuel Oil kg/hr Low Sulphur Oil (<1% Sulphur) NOx 753 mg/nm 3 0 o C. 3% O 2 (Liquid or Gas), 6% O 2 (Solid Fuel) Maximum volume of emission 14,784 Nm 3 /hr Temperature o C(max) o C(min) 242 o C(avg) (i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included): Periods of Emission (avg) min/hr hr/day day/yr Peak Season: Typically the boiler runs 24 hours per day during March October (three boilers collectively). Off-peak Season: Generally, one boiler runs 24 hours per day from November to February but at times other boilers may be running for a period depending on processing requirements. EPA Export :21:37:20

10 TABLE E.1(i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Emission Point Ref. N o : A1-3 Location : Grid Ref. (12 digit, 6E,6N): Boiler House E, N Vent Details Diameter: 0.65m Height above Ground(m): Date of commencement of emission: 33.5m August 1974 Characteristics of Emission: Boiler rating Steam Output: Thermal Input: Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content: kg/hr 8.67 MW Heavy Fuel Oil kg/hr Low Sulphur Oil (<1% Sulphur) NOx mg/nm 3 0 o C. 3% O 2 (Liquid or Gas), 6% O 2 (Solid Fuel) Maximum volume of emission m 3 /hr Temperature o C(max) o C(min) o C(avg) (i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included): Periods of Emission (avg) min/hr hr/day day/yr This boiler is currently not operational. EPA Export :21:37:20

11 TABLE E.1(i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Emission Point Ref. N o : A1-4 Location : Grid Ref. (12 digit, 6E,6N): Boiler House E, N Vent Details Diameter: 0.65m Height above Ground(m): Date of commencement of emission: 33.5m March 1975 Characteristics of Emission: Boiler rating Steam Output: Thermal Input: Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content: kg/hr MW Heavy Fuel Oil kg/hr Low Sulphur Oil (<1% Sulphur) NOx 699 mg/nm 3 0 o C. 3% O 2 (Liquid or Gas), 6% O 2 (Solid Fuel) Maximum volume of emission 9,141 Nm 3 /hr Temperature o C(max) o C(min) 213 o C(avg) (i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included): Periods of Emission (avg) min/hr hr/day day/yr Peak Season: Typically the boiler runs 24 hours per day during March October (three boilers collectively). Off-peak Season: Generally, one boiler runs 24 hours per day from November to February but at times other boilers may be running for a period depending on processing requirements. EPA Export :21:37:20

12 TABLE E.1(i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Emission Point Ref. N o : A1-5 Location : Grid Ref. (12 digit, 6E,6N): Boiler House E, N Vent Details Diameter: 0.75m Height above Ground(m): Date of commencement of emission: 33.5m September 1978 Characteristics of Emission: Boiler rating Steam Output: Thermal Input: Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content: kg/hr MW Heavy Fuel Oil kg/hr Low Sulphur Oil (<1% Sulphur) NOx 675 mg/nm 3 0 o C. 3% O 2 (Liquid or Gas), 6% O 2 (Solid Fuel) Maximum volume of emission Not Available Temperature o C(max) o C(min) 247 o C(avg) (i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included): Periods of Emission (avg) min/hr hr/day day/yr Peak Season: Typically the boiler runs 24 hours per day during March October (three boilers collectively). Off-peak Season: Generally, one boiler runs 24 hours per day from November to February but at times other boilers may be running for a period depending on processing requirements. EPA Export :21:37:20

13 3. For emissions to atmosphere outside BAT guidance limit (i.e. Niros 1 & 2), a full evaluation of the existing abatement/treatment systems must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a timescale, together with options for modifications, upgrading or replacement as required to bring emissions within the limits as set out in the BAT guidance notes. Evaluation of Existing Abatement/Treatment Systems During the IPPC Licence Application process in 2006 Arrabawn were made aware that two of the dryers (A2-3 and A2-4) exceeded the Emission Levels for Discharge to Air specified in the relevant BAT guidance document (Draft BAT Guidance Note on Best Available Techniques for the Dairy Processing Sector, V11, June 2006). Table 3.1 BAT-Associated Emission Levels for Emissions to Air Constituent Group or Parameter Emission Level (mg/m 3 ) Mass Threshold (kg/hour) Total Particulates <0.2 The emission points for the Niro dryers are located in the Whey Powder Plant (A2-3) and the Skim Milk Powder Plant (A2-4); refer to Emissions to Atmosphere Drawing E1.1 ; A8787-N006-B. As described in Attachment F.1 of the IPPC application both Niro dryers operate on the basis of steam drying the powder. Both dryers are fitted with cyclones to reduce product loss and to minimise dust emissions to the atmosphere. Primary cyclones separate the drying air from the powder and the transport cyclones separate the transport/cooling air from the powder. The mechanical separator uses centrifugal force to remove large and high-volume dust. Centrifugal collectors use cyclonic action to separate dust particles from the gas stream. In a typical cyclone, the dust gas stream enters at an angle and is spun rapidly. The centrifugal force created by the circular flow throws the dust particles toward the wall of the cyclone. After striking the wall, these particles fall into a hopper located underneath. EPA Export :21:37:20

14 In the intervening period (following receipt of the EPA s requirement for supporting information to the IPPC Licence Application) Arrabawn has assessed the cyclone efficiency for both dryers. The outcome of this assessment determined it unlikely for Arrabawn to increase the efficiency and reduce the emission levels to BAT limits. Although Arrabawn was not issued with an Air Emissions Licence by the Council (hence there was no requirement to monitor the dryers), biannual monitoring of the dryers was undertaken to assess their atmospheric emissions. Table 3.3 below details the total dust concentration recorded in 2005 and 2006 for both Niro 1 and Niro 2. Table 3.3 Total Dust Concentrations Analysis (units): DRYER EMISSION ANALYSIS Flow (N cu m/h) Dust Concentration (mg/n cu m) Year: BAT Emission Limit Value Dryer Name Niro 1 (A2-3) 62,372 72, mg/m³ Niro 2 (A2-4) 115, , mg/m³ The dust concentration at the emission points exceeds the BAT limit of 50mg/m³. When considering this it should be noted that no complaints have been received of any adverse effects from dust on the air quality beyond the site boundary. The Niro dryers were installed in 1974 and 1979 whereas the Septu and Gorgan dryers were installed in 1988 and 1993 respectively. In the 70 s bag filters were not considered a requirement for the dairy and similar industrial sectors. As technological advances progressed in the 1980 s, bag filters were installed at the site to keep in line with best available technologies. Analysis of the Septu Dryer for 2004 and 2006 demonstrates the effectiveness of the bag filters (refer to Table 3.4 below). Dust concentrations were recorded at 3 mg/ m³ and 15mg/ m³ which are well below the BAT limit of 50mg/ m³. Table 3.4 Total Dust Concentrations Analysis (units): Dryer Name DRYER EMISSION ANALYSIS Flow (N cu m/h) Dust Concentration (mg/n cu m) Year: BAT Emission Limit Value Septu No.1 10,555 10, mg/m³ Arrabawn is committed to reducing their air emissions at the site to become BAT compliant. The following is a proposed programme of improvement to meet these requirements. EPA Export :21:37:20

15 Programme of Improvement A large number of customers in this sector have many reservations in purchasing product which has been processed using bag filters. This is primarily based on the fact that using these filters presents a risk of filaments from the bag contaminating the final product. Arrabawn are aware of and committed to their requirement to become BAT compliant, however, in order to ensure a stable market for their product it will take time to discuss the implications with their customers and iron out any difficulties encountered. Arrabawn intend to undertake an assessment immediately into the best available technology to ensure future compliance with the BAT Limits. Current projections envisage an upgrade of both Niro dryers by installing bag filters to reduce the particulate emissions to atmosphere. An application has been submitted for grant aid (the Dairy Fund Grant in October 2006) to upgrade the existing plant however the outcome will not be available until later this year. The cost associated with upgrading two of the dryer systems is in the region of 1.5million. This is in addition to other necessary upgrades/site works that are due to be carried out at the facility. Dairy processing operations are seasonal. Peak-season is from March to October with operations winding down in December and January. The only window for upgrading the dryers is during the winter months when all processing operations have ceased. It is not possible for Arrabawn to make arrangements for bag filters to be installed in 2007 as there is insufficient time to commission a supplier to manufacture the filter before this year s winter window. As the financial constraints associated with upgrading this plant play s a large role in ensuring Arrabawn remains operational and financially viable. Arrabawn proposes to implement the following programme to bring the emissions within the BAT guidance limits. Table 3.5 YEAR Spring/Summer 2007 Improvement Programme to meet BAT Guidelines TASKS Research into best available technology Autumn/Winter 2007 Generate specification for upgrade requirements Spring/Summer 2008 Suppliers visit site prior to submitting fee proposal. Review of tender submissions. Autumn/Winter 2008 Commission supplier (upgrade of Niro 1) Spring/Summer 2009 Supplier to manufacture Bag Filter 1 Winter 2009 Install Bag Filter 1 Autumn/Winter 2009 Commission supplier (upgrade of Niro 2) Spring/Summer 2010 Supplier to manufacture Bag Filter 2 Winter 2010 Install Bag Filter 2 EPA Export :21:37:20

16 4. Provide details of any proposed new emissions to the environment and complete the relevant tables from licence application form Arrabawn propose to introduce a new dryer AHP-5 (refer to Emissions to Atmosphere Drawing E1.1 ; A8787-N006-B) in the section directly east of the powder store (to dry whey permeate). This dryer (with bag filter) will be similar in design to the existing Septu dryer. For this reason the emissions associated with the proposed new installation are expected to be comparable to Septu levels previously recorded, all falling within the required standards. The proposed new whey permeate dryer emissions A2-5 are likely to be discharged to a similar location and design as the stack at Niro 1 (emission point A2-3). The detail of the emission points will be agreed in advance with the Agency. Completed relevant tables (E.1(ii), E.1(iii), F.1(i) and F.2(ii)) for the IPPC Licence Application which include the proposed new dryer are included with this response document. EPA Export :21:37:20

17 TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point Ref. N o : Proposed new dryer - A2-5 Source of Emission: Location : Grid Ref. (12 digit, 6E,6N): Vent Details Diameter: Height above Ground(m): Date of commencement: Proposed New Dryer (Attrition No. 3) location is expected to be in the vicinity of A2-3 Whey Powder Plant ~186720E N ~1.58(m) ~31 (m) Proposed Characteristics of Emission: (i) Volume to be emitted: Average/day m 3 /d Maximum/day m 3 /d Maximum rate/hour New Emission Point ~10,896 m 3 /h (proposed emission similar to Septu Dryer) (ii) Temperature Other factors For Combustion Sources: o C(max) o C(min) Min efflux velocity m.se c o C(avg) Volume terms expressed as : wet. dry. %O 2 (iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) min/hr hr/day day/yr *Note: The dryer typically runs 24 hours per day during February Early December. It is proposed to introduce a new dryer AHP-5 (in the vicinity of emission Point A2-3) which will be similar in operation to A2-1 Septu Dryer. This will be used to dry whey permeate. The new emission point will be agreed in advance with the Agency. EPA Export :21:37:20

18 TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (1 table per emission point) Emission Point Reference Number: Proposed New Dryer Emission A2-5 (Attrition No. 3 - Whey Permeate) is to be located in the vicinity of A2-3 Parameter Prior to treatment (1) Brief As discharged (1) mg/nm 3 kg/h description mg/nm 3 kg/h. kg/year Avg Max Avg Max of treatment Avg Max Avg Max Avg Max Dust - Milk Powder Proposed New Dryer - Bagfilter ** ** 1. Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0 o C,101.3kPa). Wet/dry should be the same as given in Table E.1(ii) unless clearly stated otherwise. ** Note: Details of dust monitoring results for the proposed new dryer are expected to be similar to Septu Dryer (A2-1) provided in Attachment E.1 (Table E1.1), Details also provided on Table 3.3 and 3.4 of this response document EPA Export :21:37:20

19 TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A2-5 Proposed New Dryer (Attrition No. 3) location expected to be in the vicinity of A2-3.Control 1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up Dust - Milk Powder Bagfilter (Attrition No.3) Will be checked by plant operators on a weekly basis and as required. Bag filter will be replaced when necessary Requirements will be established during procurement & commissioning Requirements will be established during procurement & commissioning Control 1 parameter Dust - Milk Powder Monitoring to be carried Monitoring equipment Monitoring equipment out 3 calibration None None None 1 List the operating parameters of the treatment / abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement / treatment system. 3 List the monitoring of the control parameter to be carried out. EPA Export :21:37:20

20 TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS - ( 1 table per monitoring point) Emission Point Reference No. : A2-5 Proposed New Dryer Emission - location expected to be in the vicinity of A2-3 Parameter Monitoring frequency Accessibility of Sampling Points Sampling method Analysis method/ technique Dust Biannual Accessible* Standard sampling method Isokinetic sampler - Sampling contracted to specialist with calibrated instrumentation * Sampling point will be installed to allow monitoring of the proposed new dryer Note - Details of emission points and sampling locations will be agreed in advance with the Agency EPA Export :21:37:21

21 5. Clarify the number of surface water emission points and any associated sampling points, if different and provide a scaled drawing showing the exact locations thereof. The purpose of any firewater sumps or other pipes and manholes shown on Drawing number A8787-N0007-A (Emissions to Surface Water Drawing E2.1) which do not appear to be linked to drainage system, should be clarified. Table 5.1 Summary of Emission & Sampling Points Emission Description Associated Description Point Sampling Point - - ASW-1 Upstream ambient monitoring location SW-2 Treated Effluent SWM-2 Final effluent monitoring location prior to discharge RW-3 Rainwater Loading ASW-2 Downstream ambient SW-1 RW-2 RW-1 Bay Condensate & rainwater from Casein Plant Rainwater Liquid Milk Area Rainwater Dry Goods Store & Car Park SWM-1 & ASW-2 ASW-2 monitoring location Condensate monitoring location & Downstream ambient monitoring location Downstream ambient monitoring location - Proposed visual assessment of rainwater discharge Emissions Points Emissions to receiving waters come from two sources as follows: Emissions from Surface Water Collection System The following is discharged to surface water through the culvert which runs across the site: Surplus condensate from the evaporator and rain water diverted from the roof of the Casein Plant (SW-1) Rain water and roof drainage from Dry Goods Store & Car Park (RW-1) Rain water from the covered Liquid Milk Area (RW-2) Rain water from the covered Loading Bay (RW-3) (Note in the drawings rain water is described as storm water) The culvert discharges directly to the Nenagh River via the Clareen Stream (refer to Drawing E2.1 Emissions to Surface Water A8787-N007-B for locations of emission points). The National Grid Reference for all emission points are referred to on the map. Emissions from Waste Water Treatment Plant The effluent arising from the processing plant is treated in the on-site Waste Water Treatment Plant (Drawing F.1 WWTP Process Flow Diagram) and discharged to the Nenagh River via the Clareen Stream. This discharge point, SW-2, is illustrated on Drawing E2.1 Emissions to Surface Water A8787-N007-B. EPA Export :21:37:21

22 Sampling Points There are two primary waste water monitoring points (SWM) that discharge to the surface water and five monitoring locations at different stages of the waste water treatment process (MP). Monitoring points are identified on Drawing F2 Emission Monitoring & Sampling Points; A8787-N011-B Primary Monitoring Points Condensate (SWM-1) Treated Effluent final discharge (SWM-2) (Note In the IPPC Application SWM-1 & 2 are referred to as SW-1 & 2 in the text). Monitoring Points at different stages of treatment Dairy Balance Tank (MP-1) Casein Balance Tank (MP-2) Aeration Tanks:- Sludge Tank 1 (MP-3) Sludge Tank 2 (MP-4) Sludge Tank 3 (MP-5) While there is only one emission point to surface water at SW-2 (treated effluent, final discharge point), monitoring points are located throughout the different stages of plant and give an indication of the efficiency of the various processes in operation at the WWTP. Ambient Surface Water Monitoring Points: There are two ambient surface water monitoring points located at Arrabawn to record the impact of the emissions to surface water on the Clareen Stream as follows: ASW-1 upstream of the treated effluent discharge point, Clareen Stream; and ASW-2 downstream of the treated effluent and condensate discharge point, Clareen Stream. Firewater Sump Two large manholes are located behind the new office & laboratory (formerly the carton store) and Liquid Milk Area to enable fire brigade access to the stream to extract water in an emergency situation. These manholes are identified on Drawing E2.1 Emissions to Surface Water A8787-N007-B. Redundant Manholes Effluent from the butter area was historically routed to the sewer via the eight manholes in the front yard. These are now redundant. Effluent from this area is currently conveyed to the WWTP via the collection system. These manholes are identified on Drawing E2.1 Emissions to Surface Water A8787-N007-B. EPA Export :21:37:21

23 6. Provide details of current storm water and condensate sampling frequency and the range of sampling parameters. Storm Water The culvert discharges directly into the Nenagh River via the Clareen Stream (Drawing E2.1 Emissions to Surface Water; A8787-N007-B). No monitoring of the individual storm water contributions is carried out at the site. Taking into account the storm water discharges originate from the roof tops and staff car park, it is not considered necessary to monitor the rain water. Indirect monitoring of the storm water discharges is carried out on the Clareen Stream on a monthly and weekly basis at ambient upstream and downstream monitoring point ASW-1 and ASW-2. Monitoring parameters are included on Table 6.1 below. Table 6.1 ASW-1 & ASW-2 Monitoring parameters and Frequency Parameter Monitoring Frequency BOD Suspended Solids Total Phosphorous Total Nitrogen ph COD Monthly Monthly Monthly Monthly Weekly Weekly Condensate Surplus condensate from the evaporators is discharged to the culvert that runs across the site via the surface water collection system at SW-1 (approximate location difficulty in determining exact discharge point). Condensate samples are monitored at sampling point SWM-1. Samples are extracted by an automatic valve which opens each time the pump is activated. Following activation of the high level probe, the pump starts and the sample valve open s for a period of 5 seconds. Condensate is then pumped to a cooling tower on the roof and flows by gravity to the drain as it is conveyed to the stream. When the tank reaches its low level, the pump stops until the tank refills and the next high level activates the cycle. The sample is collected in a 5 gallon drum which it is usually full every morning during the processing season. Condensate sampling is carried out for COD, Total Phosphorus, Suspended Solids and BOD during the processing season as detailed in Table 6.2 below. In addition the discharge is measured for continuous flow and temperature. Table 6.2 Condensate Sampling During the Processing Season Sampling Parameter COD Total Phosphorus Suspended Solids BOD Frequency Weekly Weekly Weekly Weekly Completed relevant tables (E.2(i)) for the IPPC Licence Application which include the revised emission points are contained within this response document. EPA Export :21:37:21

24 TABLE E.2(i): EMISSIONS TO SURFACE WATERS (One page for each emission) Emission Point: Emission Point Ref. N o : Source of Emission: Location : Grid Ref. (10 digit, 5E,5N): Name of receiving waters: SW-1 Cooling water and condensate from evaporators and storm water from the covered Casein Area Gully access to pipe discharging to Nenagh River via Clareen Stream E, N Nenagh River via the Clareen Stream Flow rate in receiving waters: Available waste assimilative capacity: Emission Details: (i) Volume to be emitted 0.15 m 3.sec -1 Dry Weather Flow 0.30 m 3.sec -1 95%ile flow Normal/day < 909 m 3 Maximum/day < 909 m 3 Maximum rate/hour Not Available kg/day (ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 60 min/hr 24 hr/day 365 day/yr EPA Export :21:37:21

25 TABLE E.2(i): EMISSIONS TO SURFACE WATERS (One page for each emission) Emission Point: Emission Point Ref. N o : Source of Emission: Location : Grid Ref. (10 digit, 5E,5N): Name of receiving waters: Flow rate in receiving waters: SW-2 Discharge from WWTP Final Flow Measurement Chamber E, N Nenagh River via the Clareen Stream 0.15 m 3.sec -1 Dry Weather Flow 0.30 m 3.sec -1 95%ile flow Available waste assimilative capacity: Emission Details: (i) Volume to be emitted Refer to Attachment I2 Impacts on the Receiving Waters Assimilative Capacity kg/day Normal/day 1364 M 3 Maximum/day 2,271 m 3 Maximum rate/hour (ii) Not Available Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 60 min/hr of 24 hr/day of 365 days/yr EPA Export :21:37:21

26 TABLE E.2(i): EMISSIONS TO SURFACE WATERS (One page for each emission) Emission Point: Emission Point Ref. N o : Source of Emission: Location : Grid Ref. (10 digit, 5E,5N): Name of receiving waters: RW-1 Rain Water (Storm Water) discharge from the covered Dry Goods Store & Car Park At the site entrance - pipe discharging to Nenagh River via Clareen Stream E, N Nenagh River via the Clareen Stream Flow rate in receiving waters: Available waste assimilative capacity: Emission Details: (i) Volume to be emitted kg/day m 3.sec -1 Dry Weather Flow m 3.sec -1 95%ile flow Normal/day M 3 Maximum/day m 3 Maximum rate/hour Not Available (ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 60 min/hr of 24 hr/day of 365 days/yr EPA Export :21:37:21

27 TABLE E.2(i): EMISSIONS TO SURFACE WATERS (One page for each emission) Emission Point: Emission Point Ref. N o : Source of Emission: RW-2 Rain Water (Storm Water) discharge from the covered Liquid Milk Area Location : In the yard directly south of the Changing Area - pipe discharging to Nenagh River via Clareen Stream Grid Ref. (10 digit, 5E,5N): Name of receiving waters: E, N Nenagh River via the Clareen Stream Flow rate in receiving waters: Available waste assimilative capacity: Emission Details: (i) Volume to be emitted kg/day m 3.sec -1 Dry Weather Flow m 3.sec -1 95%ile flow Normal/day M 3 Maximum/day m 3 Maximum rate/hour Not Available (ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 60 min/hr of 24 hr/day of 365 days/yr EPA Export :21:37:21

28 (One page for each emission) Emission Point: Emission Point Ref. N o : Source of Emission: Location : Grid Ref. (10 digit, 5E,5N): Name of receiving waters: Flow rate in receiving waters: RW-3 Rain Water (Storm Water) discharge from the covered Loading Bay - pipe discharging to Nenagh River via Clareen Stream In the yard beside the Gas Tank E, N Nenagh River via the Clareen Stream m 3.sec -1 Dry Weather Flow m 3.sec -1 95%ile flow Available waste assimilative capacity: Emission Details: (i) Volume to be emitted kg/day Normal/day M 3 Maximum/day m 3 Maximum rate/hour Not Available (ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 60 min/hr of 24 hr/day of 365 days/yr EPA Export :21:37:21

29 7. Provide an assessment of assimilative capacity of Nenagh River. The Clareen stream is a small tributary of the Nenagh River. It flows through an area characterised by varying extents of urban development, flowing from south to north through Nenagh town, under Arrabawn creamery (where it is culverted) before it s confluence with the Nenagh River north of the town. The flow is variable to the extent that there are periods of no flow on an annual basis. This observation is supported by the River Water Quality Report 2005 (EPA provisional data) which states that the Clareen Stream has low flows-dry on occasion. After taking into consideration the degraded nature of the stream running through the town of Nenagh and the fact that the stream is culverted, the Agency have considered it appropriate to carry out an assimilative capacity assessment on the Nenagh River. Biological Monitoring The EPA conducts biological monitoring at various stations along the Nenagh River every three years. The most recent monitoring was conducted in The results of biological monitoring at Station No. s 500, 550 and 700, upstream and downstream of Arrabawn are provided in Table 7.1 EPA Biological Monitoring of Nenagh River as these are the stations closest to the confluence of the Clareen Stream with the Nenagh River (refer to Drawing I2.1 EPA Receiving Water Monitoring Points, A8787-N014- A of the IPPC Application). Table 7.2 Biological Monitoring System gives detail of the Q-rating system used. Table 7.1 EPA Biological Monitoring of Nenagh River Sampling Stations Biological Quality Ratings (Q Values) No. Location Br nr Tyone Abbey 0550 Bennett s Br Br d/s Nenagh Br Source: Interim Report on the Biological Survey of River Water Quality; Results of 2003 Investigations (EPA. 2003) and EPA 2005 data from the EPA, Dublin. Note 1995 to 1997 is the reference year for the Phosphorus Regulations hence the base Q- value is 4 Table 7.2 Biological Monitoring System Quality Ratings Category of River Water Quality Q5, Q4-5, Q4 Unpolluted Q3-4 Slightly polluted Q3, Q2-3 Moderately polluted Q2, Q1-2, Q1 Seriously polluted Physico-chemical Overall physico-chemical water quality is satisfactory however some loss of quality is evident downstream of Nenagh town. Phosphorous removal was introduced at the Nenagh sewage works in 1997 and this helped to improve water quality significantly. However, high levels of dissolved oxygen at the last two stations indicate that eutrophic conditions may be returning (River Water Quality 2005, EPA). EPA Export :21:37:21

30 The EPA monitors the Nenagh River for physico-chemical analysis at various locations along the stretch of river. The two closest monitoring stations to Arrabawn are at station number 500 Bridge near Tyone Abbey upstream of the creamery and at station number 600 Kyleeragh Bridge, 1 km downstream of Clareen confluence. The most recent monitoring results for theses two stations are provided in Table 7.3 EPA Physico-Chemical Monitoring of the Nenagh River, EPA Export :21:37:21

31 Table 7.3 EPA Physico-Chemical Monitoring of the Nenagh River, 2005 Nenagh River Analysis Results for 2005 Sampling Station Feb May Jul Aug Nov Feb May Jul Aug Nov Parameter Temperature C D.O.% saturation D.O. mg/l O BOD mg/l O Colour Hazen < ph Conductivity µs/cm Ortho-Phosphate mg/l <0.01 < <0.01 < Total Ammonia mgn/l 0.02 < < < Un-ion-amm mg/l NH Nitrite mg/ N Nitrate mg/l N Chloride mg/l Cl Source: Provision 2005 River Quality data from the EPA. EPA Export :21:37:22

32 Flow Data The two closest hydrometric stations to the confluence of the Clareen Stream with the Nenagh River are at Tyone, station number (upstream) and Nenagh Bridge, station number (downstream). The 95%ile, Dry Weather Flow (DWF), arithmetic mean and median for these two stations are provided in Table 7.4 Flow Data for the Nenagh River. Table7.43 Flow Data for the Nenagh River. Station Number Station Name River DWF * (m³/s) 95%ile* (m³/s) Arithmetic Mean ** (m³/s) Median ** (m³/s) Tyone Nenagh Nenagh Bridge Nenagh * Source: Hydrometric data, EPA, ** Source: EPA hydrometric data (Tipperary North County Council monthly means for August 1988 to July 1990 and January 2000 to January Both the arithmetic mean and median was calculated based on the available information, i.e. 9 years of monthly means). Assimilative Capacity Treated effluent, uncontaminated cooling water condensate and rain water are discharged from Arrabawn into the Nenagh River via the Clareen Stream at emission points to surface water SW-1, SW-2 and RW-1 to RW-3. The assimilative capacity of the receiving waters is the capacity of, in this case the Nenagh River, to receive and biologically / chemically process and breakdown waste waters. As such, the potential impacts on the receiving surface waters have been assessed through calculating the assimilative capacity for Biological Oxygen Demand (BOD), Suspended Solids and Ortho-phosphate (as mg/l P) at Tyone Bridge, Nenagh River. Rainwater discharges have not been included in these calculations as it is considered to be an uncontaminated and non process discharge. The Tyone Bridge has been identified as the closest upstream EPA monitoring point to the confluence point of the Clareen Stream and Nenagh River prior to the discharge to surface waters from Arrabawn. The Clareen Stream is dry or maintains a very low flow for a significant portion of the year and the main volume of water can be attributed to the discharge of treated effluent and uncontaminated waste waters from Arrabawn Co-operative Society. At certain times during the year the discharge from the Arrabawn site represents the sole flow in the Clareen Stream. As a result of the poor flows, the culverted nature of the stream through Arrabawn and the urban characteristics of the area which the Clareen Stream flows through, the impacts from the emissions on the receiving waters are considered to be more appropriate in the context of the Nenagh River. Furthermore, more data is available on the Nenagh River than the Clareen Stream, i.e. the Nenagh River has flow data dating back to 1979 and it is regularly monitored for biological diversity (i.e. Q-rating) and for a range of physico-chemical parameters as previously described in this Section. The following set of Tables 7.5 to 7.8 provide information on the background levels in the river, the load discharged from Arrabawn and the new levels with the addition of the Arrabawn discharge for the parameters BOD, suspended solids and Ortho- Phosphate. From these Tables the available assimilative capacity in the river at the Tyone Bridge and compliance with the relevant legislation is determined. EPA Export :21:37:22

33 Table 7.5 identifies the average existing background levels of BOD, suspended solids and Ortho-Phosphate (EPA 2005 results) present at Tyone Bridge, Nenagh River. Table 7.5 Average 2005 Background levels at Tyone Bridge. Background Levels River Flow 0.3m³/sec (95%ile); 2.9m³/sec (median) BOD 0.82 mg/l Suspended Solids 0.0 Note 1 Ortho-phosphate 0.01 mg/l* Note 1 No information was available on suspended solids from the EPA and therefore the level of 0.0 is taken as a worst case scenario. * Measured median for 2005; EPA Table 7.6 identifies the maximum measured load from the condensate into the Nenagh River via the Clareen Stream. Table 7.6 Maximum Load from the Condensate into the Nenagh River. Levels Max Flow m³/sec BOD 7.0 mg/l Suspended Solids 5.0 Ortho-phosphate mg/l* * Median for 2005/2006 (16 samples) using total phosphorus levels. The median Orthophosphate level monitored in 2006 was 0.095mg/l; average 0.19mg/l (6 monitoring results available) Table 7.7 identifies the maximum load from the Arrabawn WWTP into the Nenagh River via the Clareen Stream. The figures for BOD, suspended solids and Ortho- Phosphate are based on the limits specified in the trade effluent discharge licence (ref. no ) for Arrabawn unless otherwise stated as described below. Table 7.7 Maximum Load from Arrabawn WWTP into the Nenagh River. Levels Max Flow m³/sec BOD 20.0 mg/l Suspended Solids 30.0 Ortho-phosphate 1.0 mg/l BOD: When calculating the load of BOD discharging from surface water emission point SW-2 at the Arrabawn site, the maximum amount of BOD permitted (20 mg/l BOD) in the trade effluent discharge licence was taken and a maximum flow of 2,300 m³/day. In addition the maximum flow of 909 m³/day and 7mg/l BOD for the condensate was included. Suspended Solids: When calculating the load of suspended solids discharging from emission point reference SW-2 at the Arrabawn site, the maximum amount of suspended solids (S.S.) permitted (30 mg/l S.S.) in the trade effluent discharge licence was taken and a maximum flow of 2,300 m³/day. In addition the maximum flow of 909 m³/day and 5mg/l S.S. for the condensate was included. EPA Export :21:37:22

34 Ortho-Phosphate Ortho-Phosphate is measured as mg/l of P. There is no limit for Ortho-Phosphate specified in the trade effluent discharge licence and therefore when calculating the load of Ortho-Phosphate discharging from emission point reference SW-2 at the Arrabawn site, the level of Ortho-Phosphate of 1.0 mg/l of P was used for this calculation and the maximum flow was taken as 2,300 m³/day. In addition the maximum flow of 909 m³/day and median concentration of 0.215mg/l Orthophosphate for the condensate was included. Table 7.8 identifies the new levels of BOD, suspended solids and Ortho-phosphates in the Nenagh River after the addition of the discharge from the Arrabawn site. Table 7.8 New Levels in Nenagh River for WWTP, Condensate and both WWTP & Condensate Maximum Load Maximum Load Combined (WWTP) (Condensate) Maximum Load Flow (95%ile from m³/sec m³/sec m³/sec Nenagh River m³/sec ) BOD 2.39 mg/l 1.03 mg/l 2.6 mg/l Suspended Solids 2.45 mg/l 0.17 mg/l 2.62 mg/l Ortho-phosphate* mg/l mg/l mg/l * As per Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations, 1998, the calculations are based on the median MRP concentration (most recent EPA monitoring i.e.2005, median has been measured as 0.01mg/l; EPA) and the median flow rate. The base Q-value for is Q-4. BOD: With the addition of the Arrabawn load the levels of BOD in the Nenagh River increase from the background level of 0.82 mg/l to 2.6 mg/l. The BOD loading in the River after the addition of the Arrabawn load (Table 7.8) remains within the limits of the European Communities (Quality of Surface Water intended for the abstraction of drinking water) Regulations 1989 (S.I. 294 of 1989) and the European Communities (Quality of Salmonid Waters) Regulations 1988 (S.I. 293 of 1988) both of which specify a limit of 5mg/l BOD. Suspended Solids: With the addition of the Arrabawn load the levels of suspended solids in the Nenagh River increase the background level by 2.62 mg/l. Although the background level has not been recorded, a contribution of 2.62mg/l S.S is considered minor in the context of the limit of 50 mg/l European Communities (Quality of Surface Water intended for the abstraction of drinking water) Regulations 1989 (S.I. 294 of 1989). Ortho-Phosphate In the case of discharge standards for P these have been calculated in line with the Local Government (Water Pollution) Act 1977 (Water Quality Standards for Phosphorus) Regulations, These require that for waters categorised as Q4 (recorded at Tyone I 1996) the minimum target Biological Quality (Q) Rating/Q Index is Q4 which corresponds to a median orthophosphorus concentration of 0.03 mg/l expressed as P. On the basis that the regulations deal with median concentration, the EPA median flow data has been used to calculate the median orthophosphate concentration. With the addition of the Arrabawn load the levels of Ortho-Phosphate in the Nenagh River increase from the background level of 0.01 mg/l to mg/l. The Ortho- EPA Export :21:37:22