Kerry Ingredients (Ireland) Ltd. Attachments to Objection No 8 of Appeal to Draft IPPCL No Schedule B: B.1 Emissions to Air

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1 Attachments to Objection No 8 of Appeal to Draft PPCL No. 749 Kerry ngredients Ltd: Appeal of PPC Licence No 749 Schedule B: B.1 Emissions to Air Bl.1 Bailer Emissions Submission by Envirocon Ltd relating to the reduced SO2 emissions for Boilers Ai-2 to Ai-6. Emissions Tests Results for Boilers Ai-2 to Ai-6: Kerry ngredients (reland) Ltd. Attachments to Objection No 8 of Appeal to Draft PPCL No. 749

2 ^ 3 2 r 1. Air Pollution and Environmental Consultancy Old Road, Kilcarn Bridge Navan, Co. Meath Phone: Fax: inf o@envirocon. ie APPEAL BY KERRY NGREDLENTS (RELAND) LTD. TO PROPOSED DETERMNATON OF REVEW OF LCENCE (REGSTER NO 749) - < i 'i ' 'd 4 The company is appealing the emission limit concentrations for Sulphur Dioxide (SOZ) specified in Schedule B. 1.1 of Licence Reg No 749. The emission limit values (ELV's) for emission reference points A1-2, A1-3, A1-4, A1-5, A1-6, A-7, A1-8 and A1-9 are as follows:- A1-2 A1-3 A1-4 A1-5 A1-6 A1-7 A1-8 A t As specified in Condition 4.2 of Licence No 749 The concentration and volume flav limits for emissions to atmosphere specijed in this licence shall be achieved without introduction of dilution air and shall be based on gas volumes under standard conditions oj n the case of combustion gases: Temperature 273z Pressure Pa, dry gas; 3% oxygen for liquid or gas fuels; 6% oxygen for solid fuels. The ELV's specified in Schedule B. 1.1 are based on the emission concentrations derived for the air dispersion modelling study (Envirocon Report, December 2005, Table 2). However, it is stated in Section 2 of this report that 'The amount of sulphur dioxide (Sod emitted in the exhaust gaspom the boilers is based on the hourly rate ENVROCON LTD., Registered in reland No Directors M.L. Bailey, L. Bailey

3 of the fuel burnt and the sukhur content of the fiel. The pollutant concentrations given in Table 2 (column 2) are based on this calculated emission rate divided by the exhaust flow and not from manual emission monitoring results. n other words, these emission concentrations for SO, are based on concentrations in the exhaust gas flow calculated on a wet discharged basis and not dry and at the reference oxygen % (3% for oil-fired boilers and 6% for the solid he1 boiler). For example, the SO2 mass emission concentration for Boiler No 5 (A-5), as wet discharged; based on the exhaust volume flow of 25,000 Nm3k and fbel consumption of 1100 kgh at 0.95% sulphur is 836 mg/nm3. Correcting for example, a theoretical oxygen content in the exhaust gas of 5% and a moisture content of 10% gives an emission concentration at the Reference Condition specified in the Licence of 1046 mg/nm3 [836 m@m3 x (20,9-3/20.9-5) x (1 00/90) = 1046 mg/ m3j. At the time of the emission measurement being obtained the concentration may be higher, dependmg on the actual oxygen content and moisture of the exhaust gas. Therefore, the ELV s specified in Schedule B should be revised to those appropriate for the Licence Reference Conditions and not those equivalent to wet-dmharged exhaust flows. t is recommended that the ELV s for SOz specified in Schedule B. 1.1 are changed to the following:- Michael L. Bailey Managing Director / 5 May 2006

4 REPORT ON EMSSONS TO ATMOSPHERE AT KERRY NGREDENTS JUNE 2005 Prepared for Kerry pgredients Lis towel Co. Kerry Our Reference: Report prepared by: Report reviewed by: MDE0244/05/06 Joe Hunter B.Sc., M.Sc Environmental Consultant Paul ChadwickB.Sc., M.Sc. Technical Director Date: 29* July 2005

5 BREF FOR CONSULTANCY Kerry ngredients requested RPS Group to monitor Particulate Matter, Flue Gas emissions to atmosphere and Volumetric Flows fi-om the 5 Oil boilers, the Casein burner, the Niro 2 Burner and the Solid Fuel Boiler at the Kerry ngredients facility in Listowel. The emission points were sampled on the 29~ June EXECUTVE SUMMARY t c The levels determined for Particulate Matter fiom Burners 1-5, the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. The levels determined for Nitrogen Oxide (as NO,) and Sulphur Dioxide (SOZ) emissions fiom Oil Burners 1-5, the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. The average volumetric flows fiom Oil Burner 1, Niro 2 Burner and the Solid Fuel Boiler are above the emission limit guideline stated in Kerry ngredients PC Licence. Volumetric flows fi-om all other emission points (Oil Burners 2-5 & the Casein Burner) are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. JOE HUNTER Environmental Consultant PAUL CHADWCK Technical Director

6 CONTENTS 1.O Brief for Consultancy 2.0 Executive Summary 3.O ntroduction * Methodologies! & 5.0 Results 6.0 Conclusions Appendix Sampling and Analysis - Methods and Details

7 * 3.0 NTRODUCTON Kerry ngredients requested RPS Group to monitor Particulate Matter and Flue Gas emissions to atmosphere from Oil Burners 1-5, the Casein Burner, Niro 2 Burner and the Solid Fuel Boiler at the Kerry ngredients facility in Listowel. The emission points were sampled 'on the 29& June METECODOLOGES 4.1 Particulates. Total particulate measurements were carried out using extractive sampling under isokinetic conditions as outlined in British Standard BS: 3405 using a Zambelli A sample of the stack gas was extracted through a sample nozzle of known cross-sectional area and a probe, fitted with a heated line, into a filter box to trap particulates. The filter box contained a 0.8- micron pore-size filter. The flue gas then passed into an impinger train containing anhydrous silica gel to remove all moisture from the gas, prior to volumetric measurement through a dry gas meter. Before and arer sampling, the glass fibre filters were dried in an oven at 103'C then reweighed at the RPS laboratory in order to gravimetrically determine the mass of particulate collected. 4.2 Monitoring of Flue Gasses Flue gas emissions were measured using a Testo 350x1 flue gas analyser (S Certified Equipment). This is a specialised flue gas analysis system hlly equipped with electrochemical sensors for measurement of NO, and S02. This instrument is compliant with Schedule 1 (iii) of PC Licence Registration N" 393, for monitoring of emissions to atmosphere, as produced by the Environmental Protection Agency.

8 4.3 Monitoring of Volume Flows AU airflows and temperatures in emission stack were measured using a pitot tube, digital manometer and digital thermometer. Stacks were measured at 5 to 10 equally spaced points across the stack and in two planes at 90" to each other in accordance with British Standard BS This allowed the calculation of mass flows for all relevant parameters.

9 5.0 RESULTS 5.1 Particulates Oil Burner 2 Oil Burner Note: 1: Flue Gasses Oil Burner 4 Oil Burner Casein Burner Niro 2 Burner As stated in Schedule 10) of PC Licence Register No. "April2002 The results of flue gas analysis are presented below: so Table Results of flue gas emission monitoring at Oil Boiler 1

10 Oil Boiler 2 NO,(asN02) so so so Oil Boiler 5 NO, (a NO2) so

11 ,.' '., Table Results of flue gas emission monitoring at the Casein Burner -. Oil Burner 2 Oil Burner 3 Oil Burner 4 Table Results of flue gas emission monitoring at Niro 2 Burner 165 4,780 4, ,720 11, ,230 8,400 Oil Burner ,710 11,000 Casein 270 1,185 1,200 Niro 2 Burner Solid Fuel 198 1,110 1, ,900 48,000 Note: 1 As stated in Schedule (i) of PC Licence Register No. 393, from 1" April 2002.

12 a. V : t 6.0 CONCLUSONS 6.1 The levels determined for Particulate Matter from Oil Burners 1-5, the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence * 6.3 The levels determined for Nitrogen Oxide (as NO,) and Sulphur Dioxide (S02) emissions from Oil Burners 1-5, the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. The average volumetric flows from Oil Burner 1, Niro 2 Burner and the Solid Fuel Boiler are above the emission limit guideline stated in Kerry ngredients PC Licence. Volumetric flows from all other emission points (Oil Burners 2-5 & the Casein Burner) are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence.

13 -...; a e APPENDX SAMPLNG AND ANALYSS - METHODS AND DETALS A.l.l Location of Sampling Kerry ngredients Ltd. Listowel Co. Kerry A.1.2 Date & Time of Sampling i 29* June 2005 i A.1.3 Personnel Present During Sampling Joe Hunter, RPS Group, Dublin Ross Daly, RPS Group, Dublin 1 A.1.4 nstrumentation 1 Temperature probe and Atmospheric Pressure Probe Velocity Meter and Pitot Tube Zambelli 6000

14 DOCUMENT CONTROL SHEET Client Project Title Document Title Document No. This Document Comprises Kerry ngredients, Listowel Co. Kerry Emissions to Atmosphere Monitoring at Kerry ngredients Emissions Monitoring March 2006 M DE0244Rp003 No. of DCS TOG Text List of Tables List of Figures Appendices Rev. Status Author($) Revkwed By Approved By Office of Origin 1 SSUe Date FO 1 Final J. Hunter P. Chadwick P. Chadwick Dublin Environment 03/03/06

15 1 Emissions to Atmosphere Monitoring at Kerry ngredients Emissions Monitoring March Draft TABLE OF CONTENTS 1 NTRODUCTlON... 1 EXECUTVE SUMMARY METHODOLOGES... 2 PARTCULATE MATER... 2 MONTORNG OF VOLUME FLOWS... 2 FLUE GAS ANALYSS RESULTS PARTCULATE MATTER VOLUME FLOW FLUE GAS ANALYSS CONCLUSONS... 6 LST OF TABLES Table Results of Particulate Matter monitoring at Kerry ngredients on the 13th March Table 3.2.0: Results of Volume Flow Monitoring at Kerry ngredients on the 13* March Table : Results of Flue Gas Analysis at Oil Burner 1 on the 13th March Table 3.3.2: Results of Flue Gas Analysis at Oil Burner 2 on the 13* March Table 3.3.4: Results of Flue Gas Analysis at Oil Burner 3 on the 13th March Table 3.3.5: Results of Flue Gas Analysis at Oil Burner 4 on the 13* March Table 3.3.6: Results of Flue Gas Analysis at Oil Burner 5 on the 13* March Table 3.3.7: Results of Flue Gas Analysis at the Casein Burner on the 13* March Table 3.3.8: Results of Flue Gas Analysis at Niro 2 Burner on the 13m March APPENDCES APPENDX A Sampling & Analysis. Methods & Details MDE0244Rp003 FO1

16 Emissions to Atmosphere Monitoring at Kerry ngredients Emissions Monitoring March Draft 1 NTRODUCTON EXECUTVE SUMMARY Kerry ngredients requested RPS Group to monitor Particulate Matter, Flue Gas emissions to atmosphere and Volumetric Flows from the 5 Oil boilers, the Casein burner, the Niro 2 Burner and the Solid Fuel Boiler at the Kerry ngredients facility in Listowel. The ernissin points were sampled on the 13* March As produdion was down in Oil Burner 2 at the time of sampling, RPS were unable to receive a sample for analysis on this occasion. The levels determined for Particulate Matter from the Solid Fuel Boiler, Oil Ebrners & 5. the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. The levels determined for Nitrogen Oxide (as NOx) and Sulphur Dioxide (SQ) emissions from the Solid Fuel Boiler, Oil Burners 1, the Casein Burner and Niro 2 Burner are in compliance with the emission limit guidehne stated in Kerry ngredients PC Licence. The average volumetric Rows from the Solid Fuel Boiler, Oil Burners 1,3,4 & 5. the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. MDE0244Rp003 1 mi

17 Emissions to Atmosphere Monitoring at Kerry ngredients Emissions Monitoring March Draft 2 METHODOLOGES PARTCULATE MATTER Total particulate measurements were carried out using extractive sampling under isokinetic conditions as outlined in British Standard BS: A sample of the stack gas was extracted through a sample nozzle of known cross-sectional area and a probe, fitted 4th a heated line. into a filter box to trap particulates. The filter box contained a O.&micron pore-size filter. The flue gas then passed into an impinger train containing anhydrous silica gel to remove all moisture from the gas, prior to volumetric measurement through a dry gas meter. Before and after sampling, the glass fibre filters were dried in an oven at 103 C then reweighed at the RPS laboratory in order to gravimetrically determine the mas of particulate collected. -. MONTORNG OF VOLUME FLOWS All airflows and temperatures in emission stack were measured using a pitot tube, digital manometer and dsital thermometer. Stacks were measured at 5 to 10 equally spaced points across the stack and in two planes at 90" to each other in accordance with British Standard BS This allowed the calculation of mass flows for all relevant parameters. FLUE GAS ANALYSS NOx and SOn emissions were sampled from the Solid Fuel Boiler at 5minute intervals over a 30- minute period. Flue gas emissions were measured using a Test0 350x1 flue gas analyser (S Certified Equipment). This is a specialised flue gas analysis system fully equipped with electrochemical sensors for measurement of NOx and SO2.. MDE0244Rp003 2 Fo1

18 ~ : 3 RESULTS 3.1 PARTCULATE MATTER Emissions to Atmosphere Monitoring at Kerry ngredients Emissions Monitoring March Draft Table 3.1.0: Results of Particulate Matter monitoring at Keny ngredients on the 13* March 2006 Oil Burner 2 Oil Burner 3 Oil Burner 4 Oil Burner 5 Casein Burner Solid Fuel Boiler Oil Burner 1 Oil Burner 2 Oil Burner 3 Oil Burner 4 Oil Burner 5 Casein Burner Niro 2 Burner Note: 1 :As stated in Schedule 1 (i) of PC Licence Register No from la April 2002 Note: 2:Production Down at the time of sampling - No sample received 3.2 VOLUME FLOW Table 32.0 Results of Volume How lllonitodng at Kerry ingredients on the 13* March OilBumer , (2) 4, , , ,366 8, ,958 11, ,060 1,200 1 Niro2 Burner ,000 Solid Fuel Boiler ,920 48,000 Note: 1 :As stated in Schedule 1 (i) of PC Licence Register No from ls April 2002 Note: 2:Production Down at the time of sampling - No sample received M DE0244Rp003 3 FO1

19 ... Emissions to Atmosphere Monitoring at Keny ngredients Emissions Monitoring March Draft 3.3 FLUE GAS ANALYSS Table : Results of flue Gas Analysis at Oil Burner 1 on the 1 3th March 2006 Oil Burner 1 NO,(asNO2) Oil Burner so2 i 478 ' 1700 Table 3.3.2: Results of Flue Gas Analysls at 011 Burner 2 on the 13th March 2006 Oil Burner2 NO,(asNO2) Oil Burner2 so Note: 2:Production Down at the time of sampling - No sample received Table 83.4: Results of Flue Gas Analysis at Oil Burner 3 on the 13'h March , i Oil Burner3 SO Table 3.36: Results of Flue Gas Analysis at Oil Bumer 4 on the 13th March 2006 Oil Burner 4 Oil Burner 4 NO, (as NO So;! Table 83.6: Results of Flue Gas Analysis at Oil Bumer 5 on the 13th March 2006! Oil Burner 5 Oil Burner 5 NO, (as NOZ) SO Table 3.3.7: Results of Hue Gas Analysis at the Casein Burner on the 13th March 2006 Casein Burner Casein Burner NO, (as N02) so MDE0244Rp003 4 Foi

20 Emissions to Atmosphere Monitoring at Kerry ngredients Emissions Monitoring March Draft Table 3.3.8: Results of Flue Gas Analysis at Niro 2 Burner on the llh March 2006 Niro 2 Burner so MDE0244Rp003 5 FO 1

21 t Emissions to Abnosphere Monitoring at Keny ngredients 4 CONCLUSONS Emissions Monitoring March Draft The levels determined for Particulate Matter from the Solid Fuel Boiler, Oil Burners 1, , the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. The levels determined for Nitrogen Oxide (as Nox) and Sulphur Dioxide (502) emissions from the Solid Fuel Boiler, Oil Burners 1.3, the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. The average volumetric flows from the Solid Fuel Boiler, Oil Burners & 5. the Casein Burner and Niro 2 Burner are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. MDE0244Rp003 6 FO1

22 . APPENDX A Sampling & Analysis - Methods & Details

23 A.l.l Location of Sampling Kerry ngredients Ltd. Listowel Co. Kerry A.1.2 Date of Sampling 1 3'h March 2006 A.1.3 Personnel Present During Sampling Joe Hunter, RPS Group, Dublin A.1.4 nstrumentation Temperature probe and Atmospheric Pressure Probe Velocity Meter and Pitot Tube Stadtmite 11 Dust & Gas Sampler Test0 Flue Gas Analyser A

24 EMSSONS TO ATMOSPHERE. REPORT FOR KERRY NGREDENTS JUNE 2004 Prepared for Keny ngredients Listowel 0. T7...._ -".._j.. Our Reference: MDE0244/ARO l(0) Report prepared by: Martin Doherty B.Sc. Environmental Consultant Report reviewed by: Pau1,Chadwick B.Sc., M. Se. Technical Director Date: 28& July 2004 EPA Export :19:07:31

25 1.0 BREF FOR CONSULTANCY. 1.1 Kerry ngredients requested RPS Group to monitor emissions to atmosphere from Boiler 1, Boiler 5, Solid Fuel Boiler and the Casein Burner at the Kerry ngredients facility in Listowel. The emission points were sampled on the 24' June EXECUTVE SUMMARY The levels determined for Particulates from all emission points are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. 2.2 The average volumetric flows from emission points Al-1 and A1-6 are above the emission limit. All other emission points are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. 2.3 The Nitrogen Oxides (as WO,) emissions from aii emission points are in compliance with the Emission Limit Value stated in Kerry ngredients PC Licence. 2.4 The Sulphur Dioxide (SOz) emissions fiom all emission points are in compliance with the Emission Limit Value stated in Kerry ngredients PC Licence. MARTN DOHERTY Environmental Consultant PAUL CHADWCK Technical Director 2 EPA Export :19:07:31

26 CONTENTS * 1.o Brief for Consultancy Executive Summary ntroduction Methodologies Results Conclusions MDEOWARO i(0) 3 EPA Export :19:07:31

27 3.0 NTRODUCTON Kerry ngredients requested RPS Group to monitor emissions to atmosphere from Boiler 1, Boiler 5, Solid Fuel Boiler and the Casein Burner at the Kerry ngredients facility in Listowel. The emission points were sampled on the 24* June METHODOLOGES 4.1 Particulates Total particulate measurements were carried out using extractive sampling under isokinetic 1 conditions as outlined in British Standard BS:3405 using a Zambelli A sample of the. stack gas was extracted through a sample nozzle of known cross-sectional area and a probe, fitted with a heated line, into a filter box to trap particulates. The filter box contained a 0.8- micron pore-size filter. The flue gas then passed into an impinger train containing anhydrous silica gel to remove all moisture fiom the gas, prior to volumetric measurement through a dry gas meter. Before and after sampling, the glass fibre filters were dried in an oven at 103 C then reweighed at the RPS laboratory in order to gravimetrically determine the mass of particulate collected. 4.2 Monitoring of Volume Flows All airflows and temperatures in emission stack were measured using a pitot tube, digital manometer and digital thermometer. Stacks were measured at 5 to 10 equally spaced points across the stack and in two planes at 90" to each other in accordance with British Standard BS This allowed the calculation of mass flows for all relevant parameters. 4.3 Monitoring of Flue Gases NOX and SOz emissions were sampled from the Solid Fuel Boiler and Casein Burner at 5- minute intervals over a 30-minute period. MDE0244/AROl(O) 4 EPA Export :19:07:31

28 1 Flue gas emissions were measured using a Testo 3 50x1 flue gas analyser (S Certified Equipment). This is a specialised flue gas analysis system fully equipped with electrochemical sensors for measurement of NO, and SOz. MDEOWAROl(0) 5 EPA Export :19:07:31

29 5.0 RESULTS 5.1 Particulates W Note: : As stated in Schedule (i) of PC Licence Register No. 393, from s April 2002 Volume Flow 004. A1-l A ,197 5, , ,000 A ,917 48,000 A ,081 1,200 Note: 1 As stated in Schedule (i) ofpc Licence Register No. 393,from s April _1_ 6 EPA Export :19:07:31

30 . 5.3 FueGas The results of flue gas analysis are presented below: Table Results of flue gas emission monitoring at Boiler 1 P : Table Results of flue gas emission monitoring at Boiler 5 Emission point Parameter Average conc. Emission limit valuc so Table Results of flue gas emission monitoring at the Solid Fuel Boiler Emission point Parameter A -9 NO, (= N02) so2 Average conc. (mg/nm3) Emission limit valuc Table Results of flue gas emission monitoring at the Casein Burner (mg/m3) 7 EPA Export :19:07:31

31 .= 6.0 CONCLUSONS 6.1 The levels determined for Particulates fiom all emission points are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence. 6.2 The average volumetric flows fiom emission points Al-1 and A1-6 are above the emission limit. All other emission points are in compliance with the emission limit guideline stated in Kerry ngredients PC Licence The Nitrogen Oxides (as NOx) emissions &om all emission points are in compliance with the a 12 0 / 1 Emission Limit Value stated in Kerry ngredients PC Licence. 6.4 The Sulphur Dioxide (SOZ) emissions fiom all emission points are in compliance with the Emission Limit Value stated in Kerry ngredients P C Licence. 8 EPA Export :19:07:31

32 ~ V APPENDX SAMPLNG AND ANALYSS - METHODS AND DETALS A.l.l Location of Sampling Kerry ngredients Ltd. Listowel Co. Keny L 1 i A.1.2 Date & Time of Sampling ' 24& June 2004 A.1.3 Personnel Present During Sampling Paul Chadwick, RPS Group, Dublin 1 ' A.1.4 nstrumentation Temperature probe and Atmospheric Pressure Probe V GlUblty VlGlG il1u KllVl 1 UUe Zambelli 6000 Testo Flue Gas Analyser \ MDEOMAROl(0) 9 \ EPA Export :19:07:31

Stephenson CO-GENERATION PLANT STACK EMISSION TESTING TOOHEYS PTY LTD LIDCOMBE, NSW PROJECT NO.: 5938/S24635/18 DATE OF SURVEY: 12 MARCH 2018

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