ATTACHMENT N o A1: NON-TECHNICAL SUMMARY

Transcription

1 ATTACHMENT N o A1: NON-TECHNICAL SUMMARY

2 A1 INTRODUCTION Dairygold AgriBusiness Ltd is making an application to the Environmental Protection Agency for an Industrial Emissions Licence which relates to its Feed Mill facility at Lombardstown, Co. Cork. The class of activity in accordance with the First Schedule of the Act of 1992, as amended by the European Union (Industrial Emissions) Regulations 2013, to which the facility relates, is: Class Description 7.8 (a)(ii) The treatment and processing, other than exclusively packaging, of the following raw materials, whether previously processed or unprocessed, intended for the production of food or feed from: only vegetable raw materials with a finished product production capacity greater than 300 tonnes per day or 600 tonnes per day where the installation operates for a period of no more than 90 consecutive days in any year; Planning permissions relating to the site are provided in Attachment B.6 (ii) of the application. An EIS is not included with the application. BAT guidance documents relevant to the installation are as follows: Document BREFs Title of Document Reference Document on Best Available Techniques for Food, Drink & Milk Industries Reference Document on Best Available Techniques for Energy Efficiency Reference Document on Best Available Techniques for Emissions from Storage July 2006 EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations 2006 do not apply to the installation. A derogation under Section 86A(6) in respect of the installation activities, technologies or emissions is not being sought. Page 1 of 13

3 A2 THE INSTALLATION AND ITS ACTIVITIES Overview The Dairygold Agri Business Ltd installation at Lombardstown is a Feed Manufacturing Mill and Grain Drying and Storage facility which was established in Prior to this the site was greenfield agricultural land. The facility manufactures quality animal feedstuffs for supply to customers, primarily in the Munster Area. Feed Raw Materials such as native cereals, native beans, soya, distillers, corn products and byproducts, molasses, mineral supplements and vitamins are received into raw material storage at the mill. These raw materials are then processed into highly nutritional animal feeds. The mill can produce in excess of 300,000 tonnes of animal feedstuffs per annum. The Dairygold Agri Business Ltd Grain Handling Operation at Lombardstown involves the intake, drying, treatment and storage of grains. The facility currently handles in excess of 20,000 tonnes of grain per annum. The activities at the installation are supported by associated ancillary services, i.e. administration offices, maintenance workshop, engineering facilities, utilities, boiler plant, an on-site domestic package wastewater treatment plant (WWTP) and a laboratory which facilitates the testing of raw materials and finished feeds as well as grass, silage and soil testing. The Dairygold facility at Lombardstown has a trade effluent discharge licence to discharge treated wastewater from the on-site WWTP and site stormwater to the Duvglasha river. The licence was reviewed in 2012 and a renewed licence (Licence Ref WP (W) 03/12(R)) was granted by the local authority on 14 th April Proposed Installation Changes Dairygold Agri Business Ltd has recently been granted permission by Cork County Council for the proposed new developments at the existing Lombardstown facility (Planning reference 15/05743). The development granted under planning reference 15/05743 is essentially to facilitate the reorganisation of the Site Layout and support Facilities which exist at present in order to improve operating and environmental management. They do not of themselves form part of production. The layout of the existing facility is illustrated in Drawing No. 2 (Existing Site Layout) provided in Attachment B.2. The layout of the proposed changes under planning application 15/05743 are illustrated in Drawing No. 3 (Proposed Site Layout- scale 1:2,000) and Drawing No. 4 (Proposed Site Layout- scale 1:1,000) provided in Attachment B.2. Page 2 of 13

4 Products Products manufactured at the mill comprise quality ruminant feedstuffs. These include compound feeds in the form of pellets and coarse mixed meals (unbound mix of ingredients). Product outputs from the grain handling operations are dried grains. Processes The range of operational processes and unit operations undertaken at the installation are set out in Table A.1. Table A.1 Installation Processes and Unit Operations ACTIVITIES PROCESSES UNIT OPERATIONS 1. Feed manufacturing Materials reception Milling operations Post milling operations Materials handling and storage Weighing Grinding or Rolling Mixing Conditioning Pelleting Cooling Storage Packing and Storage 2. Grain Handling Materials reception Materials handling and storage A3 Process operations Post process operations Cleaning Drying Treatment Storage RAW AND AUXILIARY MATERIALS, OTHER SUBSTANCES AND THE ENERGY USED IN OR GENERATED BY THE INSTALLATION. Materials and Substances The range of materials, substances, intermediates, products, fuels, and chemicals which are/will be produced or utilised by the installation can generally be categorised under the following groupings: Table A.2 Materials Used in the Installation MATERIAL CATEGORY Ingredients (Feed Ingredients Raw Material Inputs) Products Cleaning Chemicals Boiler Treatment Chemicals Effluent Treatment Plant Chemicals Fuels and Lubricants Process Gases Laboratory Chemicals Packaging Materials Page 3 of 13

5 Energy The installation currently uses LPG and electricity as energy inputs. The installations thermal energy requirement is currently produced on-site by two (2) direct gas fired boilers. Space heating for site offices and other on-site buildings is provided by two (2) domestic gas boilers. A4 SOURCES OF EMISSIONS FROM THE INSTALLATION Air Emissions: A summary list of the point emissions to the atmosphere from the installation is set out in Table A.3 below. Table A.3 List of Point Emissions to the Atmosphere from the Installation Emission Type Emission Point Source Item Emission Point Reference Boiler Emissions Boiler House Boiler 1 stack A1-1 Boiler 2 stack A1-2 Main Emissions Mill Complex Pellet Feed Cooler Line 1 exhaust vent A2-1 Pellet Feed Cooler Line 2 exhaust vent A2-2 Pellet Feed Cooler Line 3 exhaust vent A2-3 Pellet Feed Cooler Line 4 exhaust vent A2-4 Pellet Feed Cooler Line 5 exhaust vent A2-5 Minor emissions to atmosphere from the installation can be attributed to the mill complex cleaning system, raw material grinding units, the on-site laboratory fume hood, feed store warehouse air vents, grain cleaning, grain dryers, and the bulk grain storage silos. Surface Water Emissions: There is one (1) emission point to surface waters (SW1) from the installation as set out below. Emission Point Ref SW1 Emission Type Emission Source Receiving Water wastewater and stormwater Combined site surface water runoff (stormwater) and Treated effluent from facility WWTP Duvglasha River Wastewater Emissions The grain storage and milling processes at the Lombardstown site do not have a water requirement and there is no process wastewater stream generated by these operations. Wastewaters discharging from the installation are limited to wastewater generated on site from the installations canteen, laboratory and toilet facilities. Wastewater generated by these activities is treated by an on-site package wastewater treatment plant (WWTP). All process wastewaters are directed to the facility s wastewater treatment plant (WWTP) prior to discharging the Duvglasha River via the licenced discharge point SW1. Page 4 of 13

6 Stormwater Emissions Stormwater/Surface water arising on the site (from roofs and yard areas) is collected by a main storm drain running east/west to the north of the Main Building (Warehouse) with three (3) main branch lines collecting a network of gullies. There are currently a number of silt traps and a Petrol Interceptor on the system. From the site, the Storm drain is piped under the public road and discharges into the Duvglasha River, some 300 m upstream of its confluence with the River Blackwater. Noise Emissions: The main sources of external noise emissions are associated with air intakes and exhausts from the grain drying systems. A5 THE ENVIRONMENTAL CONDITIONS OF THE SITE OF THE INSTALLATION. Air Quality The location of the installation is essentially rural in character and principal land-uses in the environs of the site are agricultural and residential in nature. With the exception of the Dairygold Feed Mill, there are no major industrial activities and little or no pollution sources. The main sources of air pollution in the area which influence the local air quality can be attributed to exhaust emissions from traffic on the surrounding road networks, the existing activities at the Dairygold Feed Mill, emissions from agriculture activities and emissions from fuel combustion for domestic purposes. The area is classified as Zone D in terms of assessment and management of air quality under EU legislation as it is outside a population area of >15,000. Although no ambient monitoring has been carried out in this rural area of North Co. Cork, concentrations of the main pollutants would be typical of rural areas across Munster with levels of SO 2, NO 2, NO x and PM 10 well below the NAQS corresponding short-term and annual average values that are specified in the Air Quality Standards Regulations 2011 (SI No 186 of 2011). Water Quality The nearest surface water body to the facility is the Duvglasha River, which is at distance of approximately 57m west of the site entrance. This river is a tributary of the Blackwater River which flows approx 360 metres north of the site. The Duvglasha River is designated as a Special Area of Conservation (SAC) for a stretch of over 1km (from Gortroe to the River Blackwater) as part of the Blackwater River (Cork/Waterford) SAC (Site Code: ). The River Blackwater is a designated Freshwater Pearl Mussel (Margaritifera, margaritifera) site listed in the first Schedule of the Eurpoean Communities Environmental Objectives (Freshwater Pearl Mussel) Regulations S.I. No. 296 of 2009 (Pearl Mussel Regulations). There is a requirement for status improvement to high status by 2015 under these regulations. The River Blackwater is also a designated Salmonid Water, however this designation does not extent to the Duvglasha River. The receiving Duvglasha River has a high water quality status rating under the Water Framework Directive due to ecological status. The South Western River Basin District (SWRBD) has set the water quality objective for this waterbody as Protect. Page 5 of 13

7 Noise The prevailing noise environment is made up of a combination of sources including the existing Dairygold Lombardstown operation, traffic on the local road network, and trains on the Railway Line which is in close proximity to the northern boundary of the site. The site is located in a rural agricultural setting with several large scale agricultural enterprises also in the locality. A6 NATURE AND QUANTITIES OF EXISTING AND PROPOSED EMISSIONS FROM THE INSTALLATION INTO EACH MEDIUM AS WELL AS A SUMMARY OF THE ASSESSMENT OF THE EFFECTS OF THE EMISSIONS ON THE ENVIRONMENT AS A WHOLE. Air Emissions: Emissions of Nitrogen Oxides (as NO2) and Sulphur Dioxide (SO2) from the exhaust stacks of the boilers and Particulates (as PM10) emissions from the mill and grain Dryer exhausts were considered in relation to compliance with the relevant National Air Quality Standards (NAQS) and it was determined that the emissions would not be of the magnitude likely to impair the environment beyond the facility boundary. Surface Water Emissions: Wastewater Emissions It is projected that there be a slight increase in the existing volume of wastewater generated by the facility due to a predicted future increase in staff numbers. The existing WWTP will be able to accommodate the future additional wastewater load and ensure that the current discharge licence emission limit values (ELVs) will continue to be achieved. Therefore the treated discharges from the proposed development will continue to comply with the conditions of the current discharge licence and subsequently will not have a significant impact on the status of the Duvglasha River. Stormwater Emissions Stormwater emissions are not likely to significantly impact on the water quality of the Duvglasha River. These emissions are to be routed through a new full class interceptor. Noise Emissions: Noise emissions from the Dairygold AgriBusiness Lombardstown facility do not to exceed recommended EPA day, evening and night time limits along the western and southern boundaries. Noise levels along the northern site boundary are dominated by the existing grain dryers and measurements taken along the northern boundary indicates that a programme of noise improvement works will be necessary in order to reduce existing elevated noise emissions from the site in particular at night during the harvest period, when existing Grain Dryers and Stores are in operation. Page 6 of 13

8 A7 PROPOSED TECHNOLOGY AND OTHER TECHNIQUES TO PREVENT OR ELIMINATE, OR WHERE THIS IS NOT PRACTICABLE, LIMIT, REDUCE OR ABATE EMISSIONS FROM THE INSTALLATION Air Emissions: Boiler emissions are principally controlled by load management measures, including optimal matching of boiler load to production requirements, monitoring of flue gas temperature and adjusting the air to fuel ratio linkages feeding the boiler burner to achieve the optimum excess air and resulting combustion efficiency is undertaken daily. These measures ensure the safe running and efficiency of the boiler and help maintain proper emissions from the boiler systems. Each of the pellet feed line cooler exhausts are currently equipped with a cyclone abatement system to reduce the release of particulate emissions to atmosphere. Each of the grinder unit exhausts are currently equipped with a bag filter abatement system to reduce the release of particulate emissions to atmosphere. The mill complex housekeeping exhaust is currently equipped with a filter abatement system to reduce the release of particulate emissions to atmosphere. Each of the grain dryer exhausts are currently equipped with a cyclone abatement system to reduce the release of particulate emissions to atmosphere Surface Water Emissions: Process Effluent Emissions All process effluent arising at the site is treated at an onsite wastewater treatment plant. The purpose of the wastewater treatment plant (WWTP) at the facility is to treat wastewater to a standard suitable for discharge to the Duvglasha River. It is proposed to upgrade the existing WWTP by adding a tertiary filter treatment stage. Stormwater Emissions To ensure protection to the receiving water body, the surface water drainage system design incorporates pollution control measures including an oil/petrol interceptor with silt chamber. In addition the following best site management practices to prevent contamination of the surface water are implemented: Inadvertent releases to the environment are minimised by the containment of potentially polluting materials during storage and transport, and the site s SOPs and Management System. All potential risk areas on site where spills or leaks of potentially polluting materials may occur have been identified and appropriate control and containment measures are in place. All materials and liquids on site are stored above ground and contained in bunds or other appropriate spill containment systems. All bund, tanks, pipelines comply with Page 7 of 13

9 Environmental Protection Agency Guidance Note on Storage and Transfer of Materials for Scheduled Activities. Transfer of liquid materials is principally conveyed by overground piping systems. Materials handling and storage is discussed in Attachment H.1. All product, chemical and fuel tanks are located within bunds. Noise Emissions: Noise attenuation / reduction measures will be undertaken on the existing grain dryer to reduce noise emissions associated with this plant. A8 SUMMARY OF THE QUANTITY AND NATURE OF WASTES WHICH MAY BE PRODUCED OR ACCEPTED AT THE INSTALLATION The waste types and quantities generated at the site are presented in Table H.3(i) of the application form. The waste streams typically comprise packaging wastes (cardboard and plastics), waste oils, empty containers, laboratory wastes, and general domestic type waste (canteen and office). There are a number of dedicated waste storage areas located throughout the facility for holding waste materials prior to their collection for disposal/ recovery. All waste handling contractors and waste disposal facilities used by Dairygold are fully permitted (by the Local Authorities, National Waste Collection Permit Office) and/or licensed (by the EPA). A9 MEASURES TO ENSURE THAT WASTE PRODUCTION IS AVOIDED IN ACCORDANCE WITH THE WASTE HIERARCHY IN COUNCIL DIRECTIVE 98/2008/EC ON WASTE AND SECTION 21A OF THE WASTE MANAGEMENT ACT 1996, AS AMENDED; WHERE WASTE IS GENERATED, IT IS PREPARED FOR RE-USE, RECYCLED OR RECOVERED OR, WHERE THAT IS TECHNICALLY AND ECONOMICALLY IMPOSSIBLE, IT IS DISPOSED OF WHILE AVOIDING OR REDUCING ANY IMPACT ON THE ENVIRONMENT (APPLICANTS SHOULD PROVIDE THIS INFORMATION IN THE CONTEXT OF THE WASTE MANAGEMENT ACT 1996, AS AMENDED) Waste preventive and minimisation measures are discussed in Attachment H.2. Key strategies employed at Dairygold Mallow for waste prevention and minimisation include: prevent spillages automate CIP systems maintain equipment monitor processes (alarms) waste management program staff training Where waste streams are generated, these will be recovered off site if possible. Disposal will only be undertaken where recovery is not technically possible. All wastes to be disposed will only be sent to an approved facility. Page 8 of 13

10 A10 PREVENTIVE MEASURES TAKEN AGAINST POLLUTION, IN PARTICULAR THROUGH APPLICATION OF THE BEST AVAILABLE TECHNIQUES (BAT) OR BAT CONCLUSIONS DECISION The plant is fully automated and the site, and control room, is manned 24 hrs a day, 365 days a year. Process Control Monitoring - All aspects of the plant are controlled and monitored by a central electronic control system. The system allows for maintenance of optimum conditions required at the various stages of the plant to ensure safe and efficient operation of the plant. Leak detection systems and alarms, connected to the manned control room are installed on gas and designated liquid transfer lines. Bulk storage of materials is managed in accordance with Reference Document on Best Available Techniques on Emissions from Storage, July 2006 and IPC Guidance Note on Storage and Transfer of Materials for Scheduled Activities, EPA (2004). All areas on site with potentially polluting substances are hardstanding and impervious to the materials stored within. All potentially polluting substances, including waste, are stored in designated areas in appropriate approved containers within bunds or on spill pallets, as required. Bunds provide containment to a volume not less than the greater of the following: (i) 110% of the capacity of the largest tank or drum within the bunded area; or (ii) 25% of the total volume of substance that could be stored within the bunded area. Storage of gases are in specifically designed facilities. Site personnel are provided with role specific training on accident prevention and emergency response. Refresher training is provided, as necessary. All personnel and contractors are technically competent and suitably trained to undertake the tasks assigned. All storage tanks and containment bunds are subject to routine inspection. Integrity testing of all underground pipework will be subject to routine inspection. Chemicals, oils and waste stores are inspected regularly to ensure that containers have not become damaged or degraded. Loading of liquid tanks take place within bunds. Trained staff supervise loading and unloading. Good housekeeping practices are maintained on site. A Preventative Maintenance Programme (PMP) for plant and equipment is in place. The PMP incorporates calibration and integrity testing of abatement and control equipment. Duplicate or stand-by equipment will be provided, where necessary. Page 9 of 13

11 A11 MEASURES TO BE TAKEN UNDER ABNORMAL OPERATING CONDITIONS, INCLUDING START UP, SHUTDOWN, LEAKS, MALFUNCTIONS, BREAKDOWNS AND MOMENTARY STOPPAGES The entire site process are constantly monitored on a central electronic control system to continuously assess the performance of the plant and identify any adjustments necessary to prevent technical issues arising. Should any problems, malfunctions or breakdowns occur, processing will be stopped until such time as the problems are rectified. A12 MEASURES TO BE TAKEN ON AND FOLLOWING PERMANENT CESSATION OF ACTIVITIES TO AVOID ANY RISK OF ENVIRONMENTAL POLLUTION AND RETURN THE SITE OF THE ACTIVITY TO A SATISFACTORY STATE OR THE STATE ESTABLISHED IN THE BASELINE REPORT IF REQUIRED Should operations at the site permanently cease, Dairygold AgriBusiness will implement a site closure plan that will be used to safely decommission the installation in an environmentally considerate manner. The Site Closure Plan will detail the environmental aspects of decommissioning and closure process at the installation. It will comprise a detailed proposal setting out the proposed closure, and if necessary restoration and aftercare activities. The information provided in the plan will describe all operations to be carried during the site closure process and timescales for achieving the works. Detailed method statements and environmental protection protocols regarding Plant/Equipment Decontamination, Plant/Equipment Disposal or Recovery, Waste Disposal or Recovery and Soil or Spoil Removal will be provided. A cost estimate for the decommissioning and details of financial provisions to undertake closure activities will to be included in the plan. Refer to Attachment N o K. Page 10 of 13

12 A13 MEASURES PLANNED TO MONITOR EMISSIONS INTO THE ENVIRONMENT Air Emissions: It is proposed that monitoring of the following air emission points will be undertaken. Standard sampling and analytical techniques will be employed. Emission Type Emission Point Source Emission Parameter to Frequency Point Ref be monitored Boiler Emission Boiler 1 A1-1 NOx, CO Annually Boiler 2 A1-2 NOx, CO Annually Main Emission Feed Pellet Cooler Line 1 A2-1 Particulates Annually Feed Pellet Cooler Line 2 A2-2 Particulates Annually Feed Pellet Cooler Line 3 A2-3 Particulates Annually Feed Pellet Cooler Line 4 A2-4 Particulates Annually Feed Pellet Cooler Line 5 A2-5 Particulates Annually Surface Water Emissions: It is proposed that monitoring of the following surface water emission points will be undertaken in line with the current discharge licence. Standard sampling and analytical techniques will be employed. Emission Type Process Wastewater Stormwater Emission Point Source Wastewater Treatment Plant Stormwater run-off Emission Point Ref Parameter to be monitored Frequency SWD1 Flow Continuous ph Quarterly Temperature Quarterly BOD Quarterly Total Suspended Solids Quarterly Fats, Oils, Grease Biannually Detergents Biannually Total Nitrogen (as N) Biannually Orthophosphate (as P) Quarterly Total Ammonia (as N) Quarterly SWD2 ph Monthly Temperature Biannually BOD Total Suspended Solids Fats, Oils, Grease Detergents Total Nitrogen (as N) Orthophosphate (as P) Total Ammonia (as N) Monthly Monthly Biannually Annually Biannually Biannually Biannually Page 11 of 13

13 Noise Emissions: An ambient noise survey will be carried out annually at six (6) representative locations (NML1 NML6) within and in the vicinity of the installation. Refer to Drawing 13 in Attachment F.2 of the Application. Groundwater Monitoring : There are no direct emissions to ground or groundwater from the installation. Groundwater monitoring is currently undertaken at the supply well GW1 only. A14 MEASURES TO COMPLY WITH AN ENVIRONMENTAL QUALITY STANDARD The technologies, abatement, operating procedure and monitoring will ensure emissions from the installation are capable of achieving compliance with relevant environmental quality standards. A15 MEASURES TO COMPLY WITH COUNCIL DIRECTIVE 80/68/EEC AND 2006/118/EC IN RELATION TO THE PROTECTION OF GROUNDWATER There are no direct discharges from the Installation to groundwater. Inadvertent indirect emissions are prevented by appropriate material handling and storage protocols. The following best site management practices to prevent risk of contamination will be implemented: All potential risk areas on site where spills or leaks of potentially polluting materials may occur have been identified and appropriate control and containment measures are in place. All materials and liquids on site are stored above ground and contained in bunds or other appropriate spill containment systems. All bund, tanks, pipelines comply with Environmental Protection Agency Guidance Note on Storage and Transfer of Materials for Scheduled Activities. Transfer of liquid materials are principally conveyed by overground piping systems. Materials handling and storage is discussed in Attachment H.1. All product, chemical and fuel tanks are located within bunds. All bund, tanks, and pipelines comply with Environmental Protection Agency IPPC Guidance Note on Storage and Transfer of Materials for Scheduled Activities. Regular cleaning and servicing of gullies, pipework, silt trap and interceptor will be carried out to ensure the surface water drainage system is operating at its optimum Page 12 of 13

14 A16 MEASURES TO BE TAKEN FOR MINIMIZING POLLUTION OVER LONG DISTANCES OR OUTSIDE THE TERRITORY OF IRELAND The installation is unlikely to cause pollution over long distance. Any waste generated by the installation requiring disposal abroad are limited in quantity. A17 MAIN ALTERNATIVES TO THE PROPOSED TECHNOLOGY, TECHNIQUES AND MEASURES STUDIED BY THE APPLICANT No alternative technology or techniques were considered by the applicant. The technology and techniques employed at the installation are industry standards and comply with BAT. Refer to Attachment N o I.8. Page 13 of 13