DATE: 11 November 1999 TO: Each Board Member FROM: Becci Cantrell RE: Application for IPC licence from Guinness Ireland Group. Reg. No.

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1 M E M O R A N D U M DATE: 11 November 1999 TO: Each Board Member FROM: Becci Cantrell RE: Application for IPC licence from Guinness Ireland Group. Reg. No. 301 Application Details Name of applicant; Guinness Ireland Group, (St. James s Gate Brewery) Location of activity: St. James s Gate, Dublin 8. Class of activity: Licence application received: 23/7/97. Section 97 Notice sent 27/7/ Commercial brewing and distilling The production of energy in combustion plant the rated thermal input of which is equal to or greater than 50 MW other than any such plant which makes direct use of the products of combustion in a manufacturing process. Notices under article 11 issued: 25/7/97, 30/7/98, 29/10/98, 25/2/99. Information under Article 11 received: 8/9/98, 2/9/98, 30/12/98, 4/1/99, 24/3/99. Notices under Article 17 issued: 12/5/99, 28/6/99. Notices under Article 17 received: 21/5/99, 22/9/99. Section 97 reply received 26/2/99. Submissions received: Company None. This application was transferred to the Agency under Section 99(4) of the EPA Act 1992 after an application was made to Dublin Corporation for a review of existing single media licences. The St. James s Gate Brewery is the largest of five sites in Ireland owned by the Guinness Ireland Group whose main parent company is Diageo. It was founded in The site now covers 64 acres on either side of James Street extending down to Victoria Quay on the River Liffey. Guinness stout is the main product generated. Furstenburg lager is imported and kegged. Bottling is not carried out on-site. Approximately 435,000 m 3 is produced annually. Guinness flavour extract is produced on-site for export to other breweries throughout the world. Research is conducted in the R&D section on existing beers and trials are carried out for the development of new beers. The plant operates 24 hours per day for 365 days. The St. James s Gate brewery is accredited to ISO 9001 and ISO h:\licensing unit\licence determination\ippc\licence decisions\p0301\301ir.doc

2 Process Description Incoming grain is in the form of malt and barley and is weighed and distributed to the roasthouse, brewhouse and GFE plant. All malt is bought in as malting is not carried out on-site. The roasthouse has two roasters each consisting of a prehopper, roasting drum, cooler and dedicated day bin. Grain is roasted in batches of 3.5 tonnes in a rotating cylinder which is heated by an external gas burner. The grain changes colour during this process and once a satisfactory colour is reached water is sparged into the drum. Once a safe temperature is reached the grain is released into a cooler and then into the day bin for transfer to the roast material silos. Malted, roasted, milled and flaked barley and roast malt are supplied to the brewhouse and stored in headers. Grain is weighed and sent to hoppers which feed the mills. Milled grain which is referred to as grist is then mashed with hot liquor (water or small worts from previous brews). The mash is then stored in a mash vessel to convert the starch into simple sugars. After three hours the mash is transferred into an extraction/filtration vessel or kieve for extraction of sweet worts. The kieve has a false-bottom which allows liquid to drain through as worts. Once a set volume has drained through hot water is sparged onto the bed of grain husks for better worts extraction. Worts is collected in a holding tank or upperback for transfer to a kettle. The worts are boiled for 90 minutes in the kettle/whirlpool with other additives such as roast material extract, clarified trub, hop pellets and hop extract. The whirlpool effect causes sediment in the worts to deposit at the bottom of the vessel as trub. The steam produced by the boiling worts is condensed and sent to drain. Wort is drained from the kettle through a plate heat exchanger before transfer to the Fermentation and Beer Processing Plant (FBP) or Guinness Flavour Extract Plant (GFE). Cooling water is re-used in subsequent brews. The trub is transferred to a centrifuge which produces clarifed trub and trub sludge. Clarified trub is reused for subsequent brews at the kettle stage. Hopped worts sent to the fermentation plant are pitched with yeast and fermented under controlled conditions at high gravity in cylindroconical vessels. The resulting green beer is centrifuged for yeast recovery and transferred either to Maturation Vessels for conditioning or directly to Storage Vessels. During this transfer, the beer is cooled and finings are dosed in-line to clarify the beer. After a period of settling in the Storage vessels, the heavy sediment which has settled to the bottom of the vessel is removed. This high gravity beer is then transferred from the storage vessel to the Bright Beer Tank (BBT) with adjustment to final product specification and from there to the Keg Plant or Tank Station. CO 2 produced by fermentation is collected after hours of fermenting and sent to the CO 2 plant for purification. In addition to the main process, roast materials from the roasthouse are sent to the GFE I Plant. Roast material extract is produced in GFE I and is supplied to the GFE II plant to make GFE brews. Roast material extract is also used in the main brewing process. Proposed Determination Air: Atmospheric emissions consist of boiler, main and minor emissions. There are five boiler emission points and five main process emission points. These include two afterburners on the roasters in the roasthouse and three bag filters in the dust extraction system at the grain intake area. CHP Plant The brewery changed in 1998 from oil fired boilers to a gas fired combined heat and power plant (CHP). The turbines have low NO x combustion chambers and there are low NO x burners on the boilers. The use of natural gas instead of heavy fuel oil has eliminated sulphuric emissions from the site. The old power station is now decommissioned. The CHP plant consists of three gas turbines, each capable of producing 4.8 MW of electricity. The aggregated rated thermal input of this combustion plant is greater than 50 MW and the company have applied for a licence under Class 2.1. Planning permission was not required for the CHP Plant. Under normal operating conditions, three turbines are in operation. The exhaust gases from 2

3 the gas turbines are ducted into three waste heat boilers with a thermal input rating of 26.5 MW each. There is one standby boiler (21 MW) which is dual fired and can be used independently of the gas turbines. It is seldom used as it is for back-up purposes only. Emissions from the boilers are discharged to atmosphere through a single multicore stack (46.4 m high). There is a by-pass stack (36.4 m high) on gas turbine no.1 which enables it to generate electricity without producing steam. It operates automatically throughout the day to discharge the exhaust gases from the turbine when the steam demand on-site is very low. In the event that the gas supply is lost, the turbines will automatically change over to standby gas oil. A report is required to be submitted on emissions from the CHP Plant while using gas oil, detailing the impact of these emissions (Condition 5.4). Use of gas oil in the CHP plant requires prior written agreement from the Agency (Condition 5.5). Three turbines operate for 65 hours in the week, Monday to Friday, 8:00 to 21:00 and two turbines operate for the remaining 103 hours. Total NO x emissions from each boiler are 80 mg/m 3 and are within the existing new plant limit of 350 mg/m 3 as specified in the Air Pollution Act 1987 (Emission limit values for combustion plant) Regulations (S.I. No. 264 of 1996). The proposed Council Directive on the limitation of emissions of certain pollutants into the air from large combustion plants, for new plant gas turbines used in a CHP system >50 MW specifies a limit of 75 mg/m 3. A consultants report on air dispersion modelling submitted by the applicant concluded that emissions from the CHP plant with the three main stacks operating simultaneously are anticipated not to have any adverse effects on the surrounding environment. The maximum predicted 98 percentile ground level concentration (75 µg/m3) is within the existing air quality standards (S.I. No. 244 of 1987) of 200 µg/m 3 NO 2 taking ambient NO 2 levels (44 µg/m3-98%ile of hourly values) into account. Ambient values are taken from annual summary results for Rathmines The annual average ground level concentrations are within the proposed limit value of 40 µg/m 3 taking ambient NO 2 levels of 21 µg/m 3 into account. The maximum predicted 99.8 percentile ground level concentration from the CHP plant is 182 µg/m 3. Taking ambient levels of approximately 61 µg/m3 into account the total NO 2 is within the limit value of 300 g/m 3 specified in the new EU Directive 1999/30/EC (limit values for SO 2, NO 2 and NO x, particulate matter and lead in ambient air). This directive requires tighter limits to be phased in over ten years therefore the impact of current emissions from the CHP Plant and current NO 2 ambient levels will be excessive after Proposals are required within four years under Condition 5.6 for the reduction of NO 2 to meet the requirements of the appropriate EU legislation (Directive 1999/30/EC) taking ambient NO 2 levels into account. The Proposed Determination requires a programme for continuous ambient air quality monitoring of nitrogen oxides to be submitted (Condition 11.9). Roasthouse Afterburners Maximum total organic carbon (TOC) emissions from the afterburners were measured at 22.9 mg/m 3 at a mass flow of 0.13 kg/hr and 58.3 mg/m 3 at a mass flow of 0.32 kg/hr. These emissions are within the T.A. Luft limits for organic substances. Limits of 0.2 kg/hr and 0.4 kg/hr TOC are proposed for emission point references A2-1 and A2-2. Maximum NO x emissions were measured at 75 mg/m 3 at a mass flow of 0.37 kg/hr. These emissions are within the TA Luft limit value of 500 mg/m 3 at a mass flow of 5 kg/hr. Annual TOC monitoring is required at the two afterburners. Grain Intake Dust Extraction System Results of particulate emission monitoring from the bag filters were well below new plant BATNEEC limit for Total Particulate Matter (50 mg/m 3 at a mass flow 5kg/h). Particulate concentrations were measured at <3 mg/m 3 and mass flow rates were < 0.07 kg/hr. The efficiency of the bag filters was measured at 99.95%. New plant limits are proposed and annual monitoring for particulates is required for the three emission points. 3

4 Minor Emissions There are over 80 minor emission points located throughout the site comprising mainly vents for steam, water vapour, air and particulates. CO 2 Recovery Plant CO 2 of suitable purity from the fermentation process is recycled and reused in the process. The site is 100% self-sufficient in carbon dioxide. In 1998 approximately 7,900 tonnes of CO 2 was collected and 5,500 tonnes reused on-site. Excess CO 2 is sold on to other Guinness sites. A total of 79,100 tonnes of CO 2 is emitted to atmosphere from the site as compared to approximately 1.8 million tonnes emitted from Irish industrial sources in CO 2 emissions from the site can be broken down as follows: fermentation plant: 9,000 tonnes GFE plant: 1,800 tonnes CHP plant: 68,300 tonnes The further reduction of CO 2 emissions to atmosphere is required to be addressed under the schedule of environmental objectives and targets. A CO 2 explosion occurred on-site in 1986 when a CO 2 storage tank associated with the CO 2 recovery plant exploded as a result of a latent defect in the base of the tank. A new state of the art CO 2 recovery plant was subsequently installed. Fugitive Emissions Fugitive emissions comprise mainly CO 2 and odour. CO 2 arises from purging and venting tanks and kegs and from the discharge of low quality CO 2 at the early stages of fermentation which cannot be recovered. A distinctive brewing odour is emitted at times, however no complaints have been received in relation to odour. Previous odour sources have been reduced by installing afterburners on the roasters and condensers on the kettles. While the odour is not generally considered objectionable, it is proposed to include a general condition in the Proposed Determination prohibiting odour nuisance in Condition 5.7. Process Effluent: Guinness discharge process effluent with a high organic matter content to the Corporation sewer at three discharge points. Process effluent results from the draining and flushing of vessels, cleaning-in-place washings, floor washings, condensate and waste beer. Emission limit values have been set in accordance with Section 97 consent conditions received from Dublin Corporation. Maximum daily discharges of 7,000 m 3 (SE-1), 1,200 m 3 (SE-2) and 1,100 m 3 (SE-3) are proposed. A neutralisation plant has recently been installed on-site at the largest discharge point located at Cookes Lane (SE-1). This plant treats effluent from the main process and the majority of the site. The maximium BOD load discharging at Cookes Lane is likely to be in the order of 24,000 kg/day. The GFE II plant has a separate discharge point at Crane Street (SE-2). Effluent from the Keg plant is discharged at Victoria Quay (SE-3). The neutralisation plant consists of an initial underground sump, an aboveground 560 m 3 capacity equalisation tank and 190 m 3 first and second stage neutralisation tanks. Sulphuric acid and sodium hydroxide are dosed into the latter two tanks. The plant is controlled based on ph measurement in the three tanks. Levels are monitored in all tanks and sumps. The plant is situated within a containment wall and in the event of a tank failure any spillages will be directed to the sewer outfall. A storm overflow will divert process effluent, bypassing neutralisation to the final discharge sump if the new diverter drain cannot take the flow. High liquid level alarms are required in the sumps and on the storm overflow. The sewer ultimately discharges to Dublin Bay via the Ringsend treatment works where it undergoes primary treatment. A secondary treatment plant is scheduled to be in place at Ringsend by 31 st. December 2000 after which time discharge values are expected to reach the following standards: BOD-25ppm, COD-125ppm and SS- 35ppm. One of the Section 97 consent conditions (6.12) requires a research project 4

5 to be carried out into the impact of trade effluent on the secondary sewage treatment process following selection of the specific treatment type for the Ringsend Sewage Treatment Plant. The ph balancing system at SE-2 is designed for ph correction of caustic liquid waste from GFE II by means of sulphuric acid dosing. It is automatically controlled according to the ph of the effluent with manual control as back-up. A well on-site supplies cooling water to the FBP plant to cool incoming wort from the brewhouse and to cool ammonia in two vertical condensers. It is then discharged to the River Liffey at Victoria Quay. A single media licence was issued by Dublin Corporation for this discharge. Continuous flow, temperature and ph monitoring and monthly monitoring for other parameters is proposed. Monthly monitoring of the River Liffey upstream and downstream of the discharge point is also required. Surface Water: Surface water run-off from most of the site goes to the combined sewer. Some areas near Victoria Quay may discharge directly to the River Liffey. The drainage system on-site has evolved over many years and would be virtually impossible to separate the surface water from the foul and trade effluent on-site. The average daily surface water run-off is equivalent to 1.5% of the maximum effluent volumes proposed. However the company will be required to investigate the feasibility of separate drainage in areas of future development on-site under the schedule of objectives and targets. Existing surface water drains that discharge to the river are required to be identified and the normal water quality established as part of the EMP (Condition ). Groundwater: Cooling water for the fermentation cooling plant is supplied at a rate of 1,027 m 3 /day from an on-site well. It is circulated through a cooling tower prior to discharging into the River Liffey. The applicant reported that this groundwater abstraction results in a drop of the watertable to several metres below the river level thereby causing ingress of river water into the aquifer. As the applicant may increase this abstraction in the future, it is proposed to include a condition requiring an investigation to be carried out into the impact of this pumping well taking any plans for future cooling water requirements into account (Condition ). An oil spill occurred in 1990 at a tank farm containing bulk oil storage tanks. According to the applicant, most of the oil went to sewer and some into the River Liffey. Due to previous history of spillages on-site, the age of the site, its pipework and to the existence of underground storage tanks it is proposed to include a condition requiring a hydrogeological investigation of the site to identify any soil and groundwater contamination and to provide for future monitoring requirements (Condition ). Waste: Hazardous waste produced on-site consists of waste oil, waste chemicals, fluorescent tubes, asbestos waste and laboratory waste. All wastes are disposed of or recycled by suitable contractors. Extensive recycling/recovery of other waste streams is in place. Most of the spent grain, screenings, dust and yeast are reused as animal feed. Paper, glass, pallets and scrap metal are recycled. Chemical drums are returned to the supplier. General waste and some spent grain is sent to Balleally landfill. Noise: The site is located adjacent to commercial, business and residential areas. The main brewing process is carried out 24 hours every day. Kegging operations are conducted during day-time hours only. Noise levels at the boundary of the site are in many cases dominated by traffic noise. A noise survey identified four areas where noise could have an impact on nearby noise sensitive locations. The sources include the power station, brewhouse and the GFE plant. The power station has since been decommissioned, the grist blowers have been replaced with bucket elevators in the brewhouse and the incoming pressure to the CO 2 vapour quenchers at the GFE plant has been reduced. These measures should ensure that noise emissions from the 5

6 facility are within Agency guidance on noise at noise sensitive locations. Environmental Improvements: The St. James Gate brewery have an environmental management system in place since 1996 under the requirements of ISO Environmental management on-site should be directed at resource consumption and on reducing emissions. The trending of resource consumption can be used as an indication of overall process efficiency. The ratio of resources used is measured against a hectolitre of beer produced. The main resources of concern are energy, water and malt. Spent grains generated are also measured. Optimum resource ratios taken from the United Nations Environment Programme (1996) and the Swedish EPA fact sheet on breweries are compared with those existing at St. James Gate brewery in the following table: Resource Ratio / hl Low consumption (UN) Swedish EPA Guinness Water 4-10 hl/hl 3-5 hl/hl 9 hl/hl Energy 150 MJ/hl MJ/hl Electricity 8-12 kwh/hl 12.5 kwh/hl Effluent 3.5 hl/hl - 6 hl/hl BOD 0.8 kg/hl kg/hl 2 kg/hl Spent grains 14 kg/hl kg/hl Guinness resource consumption ratios are in general higher than the optimum achievable ratios, showing that improvement can be achieved in each area. Trending and reduction of resource consumption ratios is required to be addressed under the schedule of objectives and targets with a view to ensuring continual improvement and ultimately optimum process efficiency if possible. Submissions No submissions were received in relation to this application. Recommendation That the Board approve the Proposed Determination as submitted. Rebecca Cantrell Inspector, Licensing and Control 6