RE: Application from Monery By-Products (2000) Limited, Crosssdoney, Co. Cavan for Review of IPC Licence Reg. No. 365

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1 M E M O R A N D U M DATE: 11 January 2001 TO: FROM: Each Board Member Leo Sweeney RE: Application from Monery By-Products (2000) Limited, Crosssdoney, Co. Cavan for Review of IPC Licence Reg. No. 365 Application Details Class of activity: 7.7 The rendering of animal byproducts Name & Address of activity: Monery By-Products (2000) Limited, Crosssoney, Co. Cavan Review Register Number: 591 Notice under Section 85(1)(b) issued: 21 December 2000 Information under Section 85(1)(b) received: 08 January 2001 Site visit: 06 December 2000 Company The Company were originally granted an IPC licence (Reg. No. 37) on the 2 February A revised IPC licence was issued to the Company on the 21 May 1998 bearing Register No The review was necessary at that time in order to facilitate updating of the odour clause. The activity is situated in a rural location, approximately 3 km from Crossdoney village, Co. Cavan. The facility operates 24 hours per day and 7 days per week. Material arriving at the plant for processing is crushed and conveyed to batch cookers heated with steam. The cooked material is separated into tallow oil and meat & bone meal (MBM). Condition 7.28 of the PD restricts the Company to processing no more than 216 tonnes per day, prior to the provision of alternative arrangements to treat gases from the rendering process as detailed in Condition The Agency decided to review the existing licence, as provided for under Section 88(1)(b) of the EPA Act, 1992, in the light of the results of an audit of the facility, developments in process technology, together with material changes to emissions. h:\licensing unit\licence determination\ippc\licence decisions\p0591\591insprep.doc

2 Following an environmental audit undertaken at the facility on the 27 March 2000 the audit report concluded, The Agency are most concerned with the environmental management and operational practices at this site having particular regards to the raw material intake area and the waste water treatment plant. The conditions contained in this PD address the areas of concern raised in the audit report. The Company are to be prosecuted by the Agency in respect of breaches of IPC licence conditions on foot of the audit. The Company are presently examining alternative treatment technologies for the rendering industry, in particular recuperative thermal oxidation systems to deal with emissions arising from the cooking process (representing approximately 60% of the total volume of waste water arising for treatment and disposal). This PD will require the Company to submit proposals for appropriate technical options within three months (Condition 5.18). Thermal oxidation is presently used at a number of rendering facilities throughout Europe with the added advantage of combusting odourous gas streams as well as incorporating heat recovery. It is suggested that further savings can be made by using tallow oil derived from processing animal byproducts and/or SRM to fuel the thermal oxidation process. Proposed Determination The Proposed Determination (PD) as drafted takes account of the requirements of Council Directive 96/61/EC concerning integrated pollution prevention and control. The PD sets out the necessary conditions to ensure that the facility is operated in such a way that all appropriate preventative measures are taken to endure that no significant environmental pollution is caused. In addition Condition 10. Energy Use deals with energy use, reduction and efficiency on site, while Condition 15. Residuals Management provides for decommissioning of the site following cessation of the activity. Materials Handling The Company propose to handle animal by-products as well as specified risk material (SRM) and blood arising from depopulated herds and cohorts of BSE infected animals. SRM is defined in Glossary of Terms contained in the PD in accordance with Commission Decision of 20 June 2000 regulating the use of material presenting risks as regards transmissible spongiform encephalopathies. It should be noted that this definition includes SRM not removed from dead animals i.e. fallen animals. The Department of Agriculture, Food and Rural Development (DAFRD) have direct legislative responsibility for implementing of Council Decision of 20 June and all associated matters concerning the meat industry. This PD is primarily related to the provision of environmental controls and management of the rendering process. Under Condition 7. Materials Handling of the PD, twenty eight conditions are specified which regulate the transportation, handling and processing of animal byproducts, SRM and blood from depopulated herds. Condition 7.1 prohibits the facility from processing bovine or animal products which have been tested positive for BSE. Condition 7.2 requires that all bovine animals arising from depopulated herds or cohorts of BSE infected animals shall be tested for 2

3 the presence of the abnormal protease-resistant form of a normal host protein, prior to arriving at the site for processing. Only those carcasses and associated animal byproducts, SRM and blood which have tested negative shall be admitted to the site for processing. Whole bovine animal carcasses arising from depopulated herds or cohorts of BSE infected animals arriving at the site for processing shall be treated as if they were fallen animals. (Conditions 7.22 and 7.23). Condition 7.3 prohibits processing of animal by-products or SRM arising from animal diseases listed under the Diseases of Animals Act, 1966, without the prior written agreement of the Agency. Condition 7.4 states that only liquid blood arising from the slaughtering of depopulated herds or cohorts of BSE infected animals, which have tested negative for the presence of the abnormal protease-resistant form of a normal host protein shall be accepted at the site for processing. Condition 7.21 requires all fallen bovine animals arriving for processing shall be transferred directly from vehicles, trailers or containers to dedicated storage area awaiting testing prior to processing. Conditions 7.5 and 7.6 aim to minimise the age of the material being received for processing and thereby reducing loadings on the treatment systems with a particular emphasis on reducing odours. Conditions 7.10, 7.11, 7.12 and 7.13 require that particular attention and consideration is given to material to ensure that there is no spillages or odour nuisance during transportation. Condition 7.9 requires upgrading of the animal by-products and SRM intake area within two months of the date of grant of the licence. The licensee is required to have regard to the requirements of Condition in undertaking this work. Condition requires the licensee, not later than two months of the date of grant of the licence, to test and demonstrate the suitability, adequacy, integrity and water tightness of all areas used to store material including tanks used to collect run-off and washings. These areas are to be tested at least once every three years thereafter. Condition 7.23 requires the licensee prior to carrying out the activity to submit to the Agency for approval a programme to ensure that all fallen bovine animals arriving at the site are tested for the presence of the abnormal protease-resistant form of a normal host protein. Condition 8.3 requires the licensee not later than one week of the date of grant of the licence, to provide the Agency with full details of the measures to be adopted for the disposal off-site of BSE positive or suspect material which may arise from on-site testing. The condition also requires details relating to the removal for disposal/recovery of meat and bone meal and/or tallow oil, prior to transport of-site. Condition 7.20 requires that all meat & bone meal and tallow oil derived from the processing of SRM is heat treated to achieve the requirements of the First Schedule of S.I. No 182 of 2000 i.e Max. Particle Size 50 mm, Temp. >133 0 C, Time 20 minutes and Pressure greater than or equal to 3 bar. The condition also requires validation of the heat treatment process in accordance with the Third Schedule of this S.I. This heat treatment process is widely regarded as achieving a reduction of up to 1,000 fold in the BSE agent infectivity. Conditions 7.24, 7.25 and 7.26 require that the licensee handles meat & bone meal in a manner such as to prevent loss or spillage. Furthermore, all such handling is to be undertaken in an enclosed area and conveyed directly to bags and sealed awaiting further disposal. 3

4 Emissions to Atmosphere There are no odour complaints associated with the operation of this activity. The PD as drafted contains a comprehensive range of conditions to address odourous air streams. Conditions 5.4 and 5.5 requires the licensee to undertake an odour assessment to identify and quantify all significant odour releases as well as assessing the suitability and adequacy of the odour abatement system(s). Condition 5.6 requires the licensee to... prepare to the satisfaction of the Agency, a programme to demonstrate negative pressure throughout all buildings where animal by-products, SRM, intermediates or finished products are deposited, stored, processed or manufactured to ensure that there are no significant escape of odours. Condition 5.8 requires proposals for the provision of an air lock system at the material intake area while Condition 5.7 requires the venting of tallow storage tanks and blood storage tank(s) to air abatement plant. Condition 5.18 requires the preparation of a programme to monitor fugitive emissions to air. Condition 5.12 provides for the combustion of odorous gases in the boiler subject to compliance with all national emission standards. Conditions 7.16, 7.17 and 7.18 necessitate the maintenance of building integrity, and negative pressure to prevent the escape of odourous air to atmosphere. Proposals by the Company to install technology to further treat gases from the rendering process and product cooling processes, should effectively eliminate all nuisance odours associated with the operation of this activity. Condition 5.18 of the PD refers. Schedule 1(i) Emissions to Atmosphere of the PD sets out ELV s and monitoring requirements for emission arising from the biofilter. Condition 7.27 limits the total quantity of animal by-products and/or SRM which can be received on any one day for processing to 216 tonnes. Condition 5.13 requires that fuel oil used in boilers shall have a sulphur content less than 1% by weight. Condition 5.14 requires the licensee to maintain records of all fuel deliveries to the site. Waste Water Treatment Trade waste waters arising for disposal originate from two main sources. The primary source arises from condensed cooker off gases and secondly from wash waters originating from vehicles, trailers, containers, storage areas, equipment used for the collection, transfer and handling of animal by-products and SRM, as well as runoff arising from animal by-products and SRM. Treated waste waters are discharged to the river Erne. Condition 6.6 of the PD requires that all waste waters arising from the secondary source detailed above is passed through a screen with a perforation size of 4 mm. The screened waste water stream is then passed to heat treatment as specified under the First Schedule of S.I. No 182 of 2000 (Condition 6.5) and discussed earlier in this report. The removal of solids material followed by heat treatment provides precautionary management and represents best practice for this waste stream prior to passing to preliminary and secondary biological waste water treatment processes. 4

5 During the Agency s audit of the site (27 March 2000) a treated waste water sample was collected and on analysis was found to have excessively high levels of ammonia present (475 mg/l v 30 mg/l IPC ELV). A Notification of Non-Compliance was issued to the Company on 31 March stating that in view of the serious nature of the waste water treatment system the Agency insist that you cease all further discharges to the Erne river. The Company recommenced discharging treated waste water to the Erne river on the 24 August and have been fully compliant with all ELV s for discharge to water since 18 November Ongoing daily monitoring undertaken by the Company confirms this. Considerable improvement and upgrading works have been undertaken at the on-site waste water treatment plant including the installation of a new sludge de-watering press as well as a new sand filter for the tertiary treatment of waste waters. There are no changes to the ELV s for discharge to water specified in the PD from those in the previous licence. Condition 5.18 as already discussed, requires the Company to submit proposals to further treat gasses from the rendering processes. Waste Conditions relating to disposal of BSE positive material as well as the removal for disposal/recovery of meat and bone meal and tallow oil derived from the processing of SRM have been discussed earlier in this report. Condition 8.7 of the PD requires all preliminary and primary sludges arising during processing to be returned to the intake building for processing with raw materials. Condition 6.6 requires that all screenings removed during primary waste water treatment processes are returned for processing with raw material. Noise There is no history of noise nuisance associated with the operation of this activity and it is anticipated that the noise levels specified in the PD will not be exceeded at the nearest noise sensitive location(s). Facilities for the Protection of Groundwater and Surface Water Condition requires that all tank and drum storage areas (including tallow oil storage) to be bunded and the integrity and water tightness demonstrated to the Agency (Condition ). Condition discussed earlier in this report represent a significant improvement over existing IPC licenses issued to rendering activities in seeking to establish the integrity of areas and tanks used to contain animal by-products and SRM as well as runoff arising from the storage and handling of this material. The PD also requires the Company to carry out a risk assessment to determine if the activity should have a fire water retention facility in light of proposals to process SRM (Condition 11.2). The Company engaged Project Management (PM) to examine the wall that forms a barrier between the facility and the river. A report undertaken by PM was 5

6 subsequently submitted to the Agency addressing the concerns raised. The more important issues raised in this report are reproduced below. The purpose of this Report is to establish the effects, if any, which flood conditions on the river will have on the site. In addition the potential for wash water to leach through the boundary into the river must be established. The rear of the Raw Material intake Building is located in close proximity to the bank of the river. The rear wall of the site is formed by a reinforced concrete retaining wall, which continues eastwards as far as the end of the effluent plant at which point it returns southwards. In addition it extends southwards along the west elevation of the Raw materials intake. A visual inspection confirmed this wall to be in good condition throughout. The internal face although untidy in some areas, displays no signs of structural or integrity deterioration and would appear from our inspection to be fit for purpose. The location of the plant adjacent to the river could raise concerns of a potential for flooding, however, when one investigates the conditions in greater detail additional factors become apparent. A level survey was carried out to establish the relative levels of the yard and the flood plain on the opposite bank As can be ascertained from this survey, the level of the yard slab increases from a low point of m (OD Poolbeg) at the base of the Retaining wall adjacent to the river. This level is equivalent to the highest point on the flood plain, which is an isolated mound. The general level of the flood plain is an average of 400mm lower than this, the lowest point of the yard slab. The flood plain extends at this level for approximately 1km in a northerly direction and similarly in a westerly direction. [A report was prepared by Mr. Micheal Mac Carthaigh, EPA on the Return Periods of Peak Water Levels in the River Erne in the Vicinity of Monery By-Products Premises, Crossdoney, Co. Cavan. This report indicates the water levels that could occur, adjacent to the facility for the following return periods: 50 year return period: OD (Poolbeg datum) 100 year return period: OD (Poolbeg datum) 150 year return period: OD (Poolbeg datum). For each of the return periods predicted, water levels are slightly higher than the low point of measured within the site of the facility. However the PM report addresses this issue below stating that the reinforced concrete retaining wall which would act as a barrier in such an event, is some 1.8 metres higher than the yard level.] The PM report continues: At the time of the survey the river was in semi-swell with some areas of the flood plain submerged. At this junction the level of the water was still an average of 600mm below the general flood plain level, and hence approximately 1m below the level of the yard slab. In addition the top level of the reinforced concrete retaining wall is a further 1.8m higher than the yard level. This would mean that in order to flow over the top of the 6

7 retaining wall the river would have to rise by almost 3 meters, across the complete flood plain. Details of river levels over the last ten years taken at Bellahillan bridge by the OPW... The worst recorded in the last 44 years for this point was 50.97m O.D Poolbeg recorded on the 22 of January 1965, this is still lower than the low site level of m. Taking into account the above information, one can conclude that in the event of a rise in water level, the northern flood plain shall cater for any subsequent flooding, and that in the event of a extreme rise in the levels, the retaining wall will protect the site, in the unlikely event that it rises above the site level. The only break in the boundary is at the pump house access located at the northwestern corner, however in order to breach this ope and enter the building the river level would be required rise by a minimum of 1m above the level observed on the 6 th of December In order to maintain the impermeability of the boundary we would recommend that this ope is closed, by infilling with reinforced concrete and sealed with hydrophilic water bar. (Condition 7.9 (i) of the PD refers). The completion of the external site bunding by closing the pump access door ope and relocation of the pumps serves to provide a substantial barrier to the ingress of water to the site flooding of the site is highly unlikely. The construction of the additional retaining wall provides further integrity to the external skin and also forms a further seal. Taken in conjunction with the remedial works to the small number of joints in the floor and the ramps of each door, this will serve to provide a full bund for the area of the Raw material intake. (Condition 7.9 (ii) of the PD refers). The improvement of falls on the floor and the provision of the upgraded channel drainage and sump means wash water will be moved from the floor more promptly and hence be treated more efficiently. (Condition 7.9 (iii) and (iv) of the PD refers). When reviewing the facts one can appreciate the potential for flooding of the site under normal environmental conditions is extremely remote. In addition the implementation of the works outlined in this report will fully bund the critical areas and ensure that no wash water make it s way out of the building. As the integrity of the barrier wall is of vital importance in the prevention of flooding at this site, Condition of the PD requires the integrity and water tightness of the reinforced concrete wall and slab area, which forms a barrier between the site of the facility and the river Erne, to be inspected and tested as appropriate to demonstrate its suitability and adequacy to the satisfaction of the Agency. The results shall be reported to the Agency not later than six months from the date of grant of this licence. This wall shall be inspected and tested as appropriate at least once every three years thereafter. The recommendations of the report have been incorporated into the PD as indicated in the conditions referred to above. 7

8 Condition requires the licensee to identify, inspect and map the entire underground piping/drainage network in order to identify redundant pipework and tanks as well as dealing with the decommissioning, replacement or upgrading as necessary. Submissions There were no submissions received on the Monery By-Products (2000) Limited, IPC licence review. Recommendations I am recommending that the Board approve the PD to Monery By-Products (2000) Limited with the conditions as attached. Signed Leo Sweeney Inspector 8

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