17
Our Ref. 237208/0F/kos Ms. Grainne Oglesby Administration Officer Office of Licensing & Guidance Environmental Protection Agency PO Box 3000 Johnstown Castle Estate Co. Wexford ]1 Mott MacDonald Mott MacDonald Pettit 5 Eastgate Avenue Eastgate Little Island Co. Cork Ireland T +353 (021) 4809800 F +353 (021) 4809801 21 November 2007 Re: Arrabawn Co-operative Society - Reg. No. P0791-01 Dear Ms. Oglesby, Mott MacDonald Pettit (hereafter referred to as MPI) on behalf of Arrabawn Co-operative Society would like to respond to correspondence received from Suzanne Wylde (Inspector) dated 24 th October 2007, with reference to IPPC Licence Application P0791-0 1. As requested, please find accompanying this letter, two digital copies, one signed original and two copies in hardcopy fonnat. If you require any additional infonnation, please do not hesitate to contact the undersigned at your convemence. Innealtolri Comhairleach Consulting Engineers Directors: DJ Horgan BE (Elec) MIEI MConsEI (Chairman) T J O'Connor BE CEng MIEt (Managing) T Bolger BE MSc CEng MIEI MCon,Ei S Brewilt BA BAI CEng FIEI MIStruct MCEI D K Howel's BSc MBA CEng MICE MCIWEM (British) F McCivern BSc DipEnvEng C(ng MIEI JT Murphy BE HDlp MM CEng FIEI MClT V Murphy BE BA CEng Eurlng MIEI C O'Donovan BE MBA CEng MIEE G O'Sllllivan BSc (Eng) CEng FIE! MClWEM MConsEI W J Rankln MSc CEng FICE IBritish) G Reilly BEng CEng MIEI MICE K J SlOvell BSc (Eng) ACCI (British) P Wickens BSc CEng MICE FIStructE (British) Registered in Ireland no. 532BO Registered office; South Block, Rockfield Dundrum, Dublin 16, Ireland Company Secretary; E Brady FCCA MOlt MacDonald Petllt Limited a member of the MOll MacDonald Group For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 25-07-2013:22:24:25

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Our Ref. 237208/0F/kos

Ms. Grainne OglesbyAdministration OfficerOffice of Licensing & GuidanceEnvironmental Protection AgencyPO Box 3000Johnstown Castle EstateCo. Wexford

] 1 MottMacDonald

Mott MacDonald Pettit5 Eastgate AvenueEastgateLittle IslandCo. Cork

Ireland

T +353 (021) 4809800F +353 (021) 4809801

21 November 2007

Re: Arrabawn Co-operative Society - Reg. No. P0791-01

Dear Ms. Oglesby,

Mott MacDonald Pettit (hereafter referred to as MPI) on behalf of Arrabawn Co-operative Societywould like to respond to correspondence received from Suzanne Wylde (Inspector) dated 24th October2007, with reference to IPPC Licence Application P0791-0 1.

As requested, please find accompanying this letter, two digital copies, one signed original and twocopies in hardcopy fonnat.

If you require any additional infonnation, please do not hesitate to contact the undersigned at yourconvemence.

Innealtolri Comhairleach

Consulting EngineersDirectors:

DJ Horgan BE (Elec) MIEI MConsEI (Chairman)

T J O'Connor BE CEng MIEt (Managing)

T Bolger BE MSc CEng MIEI MCon,Ei

S Brewilt BA BAI CEng FIEI MIStruct MCEI

D HO~"i6~00008n.docK Howel's BSc MBA CEng MICE MCIWEM (British)

F McCivern BSc DipEnvEng C(ng MIEI

J T Murphy BE HDlp MM CEng FIEI MClT

V Murphy BE BA CEng Eurlng MIEI

C O'Donovan BE MBA CEng MIEE

G O'Sllllivan BSc (Eng) CEng FIE!

MClWEM MConsEI

W J Rankln MSc CEng FICE IBritish)

G Reilly BEng CEng MIEI MICE

K J SlOvell BSc (Eng) ACCI (British)

P Wickens BSc CEng MICE FIStructE (British)

Registered in Ireland no. 532BO

Registered office; South Block, Rockfield

Dundrum, Dublin 16, Ireland

Company Secretary; E Brady FCCA

MOlt MacDonald Petllt Limited

a member of the MOll MacDonald Group

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1. Provide a timeframe for the implementation of the proposed measures for reducingthe SOx emissions as detailed in the 'Report on Boiler Emission Study', received bythe Agency on 2Sth September 2007.

As regards SOx emissions, the financial impact of compliance is a matter of grave concernfor Arrabawn. If the facility is to switch to a purposely prepared blend of low sulphur oil itmay add in the region of €700,000 to the annual fuel bill (depending on the type of blend, thebase oil quality and the price of oil on the day). As there is no saving by way of increasedefficiency, this charge will have to be passed back to the milk suppliers by way of a reducedmilk price of approximately 0.3c/litre. This will place Arrabawn at a considerabledisadvantage compared to their main competitors. Milk prices paid to farmers is a crucialelement of the dairy business. Even slight disparities with competitor prices may result indetrimental impacts on the economic feasibility of the business. For instance, should thisreduction in milk price be passed onto the farmer, it could result in a loss of €13.65 per cow.Fanners in such a position are likely to deliver to other co-operatives.

At this time Arrabawn is in discussions with Bord G<iis who are considering extending theirnetwork to Nenagh. Two meetings have been held with Bord Gais (early October 2007 and 9th

November 2007) since Arrabawn's last submission, dated 24th September 2007. A further meetingwith Bord G<iis is due to take place in Nenagh on 20th November with businesses interestedin a connection to the natural gas network. Arrabawn anticipate a decision by Bord Gillswithin the next 3 months on when or if this will happen, however achievement of thistimeframe is outside Arrabawn's control.

A change to either natural gas or low sulphur oil will require modifications to the burners orreplacement of same. Replacement and modifications required to alter the boilers for naturalgas is likely to involve a capital investment of €150,000 - €200,000 in addition to acontribution for piping the network to the facility. Modifications required to alter the boilersfor a purposely prepared blend of low sulphur oil is likely to involve a significant amount ofre-commissioning and a capital investment of c. €80,000 - €100,000. In addition to the fuelcosts, this is again another major financial investment. For this reason Arrabawn do not wishto make any immediate changes that may have to be undone in the short-term as this wouldbe a wasted investment.

It is Arrabawn's intention at this time to progress discussions with Bord Gais and if thenetwork is extended to Nenagh, obtain a connection as soon as possible.

If it's confirmed that natural gas is not going to be made available to Nenagh in theimmediate future Arrabawn will engage in discussions with their oil suppliers and whatevermodifications that are required of the boilers would be completed during the annualshutdown in the Winter of2008, with a view to reducing emissions in 2009.

23n0800008n .doe

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2. The Licence/permit register number of the waste collection agents or disposal/recoveryoperators, as required in Summary Tables H (i) and H (ii), as well as the expiry date of therelevant permits.

Table H (i)• Irish Lamp Recycling• Rilta Environmental• ENVA (also known as Atlas Environmental)

• AES

Table H (ii)

• AES• Hegarty Metals Processors• Maunce Cremins• Quicksharp• John Mackey• All security mobile shredding

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TABLE H.l(i): WASTE Hazardous Waste Recovery/Disposal

;';-: 't}:ff~~~t~~~~posal

(MethQd;i~(a:tjon&""Uiideh~ke'h)-',

Hazard waste disposal,Smithstown Industrial Estate,ShannonCo. Clare,ENVA (Atlas EnvironmentalIreland Ltd. - WCP033(2)/OY/281105; reviewed every2yrs)

...~.

">::~~'.:" )'.:1:. A~...tdc.l.a..·.·ve...d... La.ndfill~d'~Q:th. ...• '\ ;Tlpp.er~GQU~tyCounCil

- ;~[li@te'tinYy~Q': ::rif?P~re;try,AEs (WtP053(2)!OYf3~V06"':.reviewed every 2 yeMs)..;

Off-site Recovery, Reu~eorRecycling l' "

(Method,Locati~il.& .Undertaker}... ';',

. "': •.

Recycled,Greenogue Business Park, ". "c", •• ,. _

Rathcoole, Co. Dublin",';';. " ~:' ..ilL' -.". . "'-. ,), ~"'r ~-. - M;

Rilta Environmental. ~~P~:.·.. ,c;~_.;;, .'"397laY1494/07· - reviewedeY'e~;_2yrs) . . .•.

Recycled;TCAth:fc6: kildare,'

"IrIsh Lamp Recycling (WCP03'5(2)/OY/400106 - reviewedeV~rY2 yrs)

...'"

}~.. :'t.

(MeiJrod~&Location )~. /_. .~

On-site RecoveiyfI)fsposal

Drain (dilut~d);;lli~ii<tre-aied

in the wwt'P- .~':;0·01325

0.0015

.~. ~.,

0.7~,

Laboratory

Laboratory

Main Sours~kl~;,' ,;'":';Quantity

..:;~eiyts~~> >

':.1, ~..

EWCCode

~", ' .( .',

200199

200114

200114' ,-

130100 & I Services130200

A reference should be made to the main activity I process for each waste.

Waste C.O.D.Vials

~.. ' •.

Waste Acids

... ';.<__ ,~,.... _"l

Waste Material

Waste Oil

Bio-hazardous'Waste

"c

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TABLE H.l(ii) WASTE - Other Waste RecoverylDisposal

','

...,.,,,,-

¥A'

- ).",

Off-site Disposal

(Meth9.d" Locan-0n &", UiIdertaker). ,

Landfilled - North TipperaryCounty Council, Ballinhenny, Co.

Landfilled - North TipperaryCounty Council, Ballinttenny, Co.Tipperary;'ABSLtd{WCP ,053(2)/()Y/351/06 - reviewedevery 2 years).

'":~ ;r

"

i cv."

R~cycled,Netlagh, Co. TipperaryAES Ltd. (WCP053(2)/OY/351/06 - reviewed,every, 2 ~ears),

~; \

RecY41ed, silT1ysimon Rd.Limerick Co. Limerick, HegartyMetals Processors (WCPo13(2)/OY/289/05 - b~~iewea, "every2 :yrs) '. ,. .!,

,'-~~

Off{s~te R:e~6very,Reuse or" ' Recycling(Method, Location &

Und,e.:.~t*,er) c.'

Recycled, Spripgfort Cross,Nen~ih; C0 tipperatj:ABB't.td. (WCP053(2)/OY/35l/06 - reviewedevery 2 years),

Recycled, Springfort Cross,Nenagh, CQ Tip.I?~~#Y' .JAES Lta.,(W€P'q,53'(2)JOY/35lJ06 - reviewedevery 2 years).

,~: ..

-,

'tor~~~ .

~~.\

-

,"''''::,

:';Un-site Recovery/Disposae.

(Method~Location)

"

--

/;,~ b

~" -.t"

-~'m"/

Month

':1':

."

Quantity

:·~r·<

"

6:6

9.8

-:.

,ci.1

Ton.Jj,es/l\:fonth

~ --<I::::

""',•.

Skip points(see MapHl.l)

ChemicalL'cOAlPdund

",Po~ders'

"Labor4~pry,~. _ .. "

'.L.Butter,PackagingStore

150102

,

[Sdi03l~oWde"I "": d' '.... ~ ~~ ~;.;.

15C5103TW~reho~~e ,,'. ,;' 0.1

. ,

Drums

Office paper waste

Scrap p:allets,

,',

PalletS""

{, t.."

'Wi(steMa(~dal' n. :'EWC;'I NiaH{Source1'

Code

GenJr'iil Rubbish(Office Waste,Canteen Waste,;Plastic, .,,Eqpkag(ng:t

,Scrap Metal

RecycledI;CardQ:0'ard

"; ,

If,e

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" Off~site Disposal

(lVIe.~hod,Location &Undertaker)

Landfilled North Tipperary CountyCouncil Ballinhenny, Co.Tipperary, AES ltd. (WCP053(2)/OY/351106 - reviewedevery 2 years).

Skip Landfilled, North TipperaryCounty Council Ballinhenny, Co.Tipperary, AES. (WCP053(2)/OY/351106 - reviewedevery 2 years). "

Tipperary, AES Ltd. (WCP.,053(2)/OY/351106 - reviewedevery '2 years).

,ill;. ,..::."

Off-site Recovery"Reuse orRecycling

(Method, Location &Und.~r,tl!-k-er)

A) Land-spread: ~: ;..... - "Nencrgh; Cb. TipperaryJohn Mackey (WCPH4/0Y/224/05 - reviewed every

'r2TIs) ' .. .Q~'icJ('iShafP.J?:t(L0¥CP

129(2)'/OYI35E/0{5:'---r~Vi~wed'every)yx:s) " ,

UJ?it.l4' ~u8.iJ:Iess Park,'Prlul:gfQid,Co. KilkennyS)c:.GQIhp'b,stedc'€fQ141e~;'Broadford, Co.LimeI1tk" .Maurice Crernin (WPLK 23 (A) ­

',t,e~ppJ<Ui 20 I0)

,@n;;siteRecovery/. Disposal2

(Me.thod & Location)

~ ..

',1;1 .....::., .'i·

m~/

Month

Quantity

1.3

0.2

249

'Tonnes/Month

. . 1Main Source ..

Milk powder,casein & whey'plailts~·..\~'. 'e~~"" '; ~t' ::J........

200199

.'- ./;. :- ~,

~

W3S~~:Ma(~i~d';'l':EWC'. '" .., -< ,_i~.Q4e"

." t·,

.. -­~..' ~.\:

t ".,t, ..,-'

;Slh?,lge"

;;

~..t..~ "

1

;,is'olidLaboratorj'.;\~{ast~,:'~' . ~ ."

I, A reference should be made to the main activity/ process for each waste.2. The method of disposal or recovery should be clearly described and referenced to Attachment H.I

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3. An updated non-technical summary to include information in relation to all the mattersspecified in paragraph (f) to (v) ofArticle 10(2) ofEPA licensing Regulations 1994-2004.

NON TECHNICAL SUMMARYArrabawn Co-Operative Society Ltd. is a dairy processor located in Nenagh Co. Tipperary.The plant produces a range of milk powders and butter products for sale mainly on the worldmarket.

The plant and associated infrastructure is located on the edge of the town of Nenagh. Tworoads form the boundary on the northwest and northeast of the site. The Limerick ­Ballybrophy railway line runs along the back of the site. The Clareen stream runs through thesite underground.

The creamery was founded as Nenagh Co-op in 1913 on this site. Over the years the plant wasexpanded by the addition of various plants. In 1973 the first dryer was installed and the seconddryer was installed in 1978. The casein plant was installed in 1988. The butter plant wasmodernized and upgraded in 1993. Whey production in Arrabawn was started in 1997.

In 2002, Nenagh Co-op merged with Mid West Farmers Co-op to form Arrabawn Co­operative Society.

There are approximately 83 people working on the site during peak periods of production.There are approximately 10 contractors on-site at anyone time but many contractors aredependent on the co-op for their business, e.g. all milk collection is by independent contractor.During peak season, production is on going on a continuous basis, 24/7. Administration staffworks between 09.00 and 17.00, Monday to Friday and 09.00 to 13.00 on Saturday. TheSecurity office is located at the main entrance gate to the plant and is staffed from 5.30pmuntiI3.30am.

The Arrabawn plant, as shown on Drawing A1.1 (Map A and B) Site Layout Plan, is locatedto the south of the town of Nenagh. The plant is bordered by Stafford Street to the north, bythe Thurles road to the east, by agricultural land to the south and by a livestock mart to thewest. There are three main production buildings on the site. These include:

• the powder plant which contains the separator room, evaporator room, the Niro dryers andpowder bagging area;

• the butter plant which contains the butter chum and butter packer, and

• the casein plant which contains the Ultra Osmotic Plant and Septu Dryer.

The rest of the site comprises of the boiler house used for steam generation, laboratories,canteen, car parks, yards and service areas. The wastewater treatment plant which consists oftwo holding effluent tanks, a bio tower, three sludge tanks and settlement ponds, sludgedecanter and service buildings, is situated on the lands to the south of the facility and thetreated waters are discharged to the Nenagh River via the Clareen Stream. The layout of theinstallation is shown on Drawing A1.1 (Map C) Site Layout Plan.

PROCESS DESCRIPTIONDetails of the main processes on the site are outlined in Section D ofthis application. Below isa summary of the main process operations:

Milk IntakeMilk arrives in bulk lorries with tank capacities of 18,000L to 27,000L and is weighed at theweighbridge. The milk is tested in the milk intake lab and is taken into the plant in the milkintake bay. The raw milk is stored in one of two raw milk silos.

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SeparationThe raw milk is separated into cream and skim milk. The skim milk is pasteurised to noc for15 seconds while the cream is pasteurised to 94°C for 30 seconds. Both are cooled and arestored in silos for further production.

ButterThe cream coming from the separators is stored in one of four silos for 24 - 36 hours. Thecream can be turned into lactic, unsalted, or salted butter. The cream is churned into butter inone of two chums. This butter is packed off in 25kg boxes which are placed on pallets and arestored in a cold store for transport. Buttermilk that comes from the chum during the churningprocess is stored in a silo for transport to another co-op for further processing.

Skim MilkFrom the skim silos where the pasteurized skim is stored, the skim milk is sent to theevaporator where it is concentrated to approximately 48% total solids to form a concentrate.The evaporated water is cooled and condensed and this condensate is discharged to stream.The concentrate is pumped to the dryer where it is atomised and dried with hot air atapproximately 185°C. The powder is blown into storage silos, from where it is bagged off,palletised and stored at ambient temperatures until despatch.

Acid CaseinSkim milk is pumped from the skim milk silos to a balance tank in the casein plant. The skimmilk is then acidified by the addition of dilute hydrochloric acid. This precipitates the caseinfrom the whey by forming a curd and whey mixture. The mixture is passed through adecanter, this uses centrifugal force to separate the 2 streams, curd from the whey. The curd iswashed with water to remove any lactose that might remain after the separation step and isthen transferred to the dryer, where it is converted into powder at an air temperature ofapproximately 110°C to 150°C. The powder is stored in a powder silo where it is bagged off,palletised and stored at ambient temperatures until despatch.

WheyWhey from the casein production is pumped into the Ultra Osmosis (UO) Plant, a membraneplant which raises the concentration of the whey from 5% to 25% total solids. After ultraosmosis the concentrate is either diverted to the ultra filtration (UF) plant in order to makewhey protein concentrate (WPC) and deproteinised whey (DPW). or is neutralised with KOH,cooled and sent to the concentrate storage silos. In the U.F plant the whey proteins areseparated and concentrated as the first step of WPC manufacture. The whey concentrate ispumped through the evaporator and then to the drier to produce whey powder, which is storedin storage silos prior to bagging off. It is then palletised and is then stored at ambienttemperatures until despatch.

Whey Protein ConcentrateWhey from the UO Plant is treated in the UF Plant. The UF plant is a membrane filtrationprocess which allows molecules of the size of salts and sugars to pass through the membranepores (deproteinised whey), while molecules the size of proteins are rejected (whey proteinconcentrate). The protein is concentrated from ca. 10 to 35% protein in dry matter. The wheyconcentrate is then cooled and the pH is adjusted by the addition of KOH. This concentrate istreated in the evaporator, which brings the solids up to 50%. The concentrate is then spraydried. The WPC Powder is stored in a silo before being packed.

Deproteinised WheyThe deproteinised whey comes from the UF plant at around 16-20% Total Solids. Thedeproteinised whey is pumped into silos where the pH is adjusted using KOH. The whey isthen evaporated in the evaporator. The concentrate is then pumped to the crystallisation tankswhere it is cooled. This promotes crystallization .The concentrate whey is then spray dried andbagged off.

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CleaningCleaning-in-place (CIP) techniques are used primarily for the washing and sterilization ofequipment. Caustic and Acid washes are used to wash most equipment. Special cleaningenzyme products are used in the cleaning of membranes in the casein plant. The wash isreused until it is spent and it is then sent to the WWTP. This reduces the amount of detergentused.

LaboratoryQuality monitoring and control are carried out in the laboratories. A number of physical,chemical and biological test are carried out on samples of intermediate products and on allfinished products. In addition, testing is carried out on milk samples from farmers and bulkdrivers, water used on site, effluent streams going to WWTP and treated water entering theClareen stream. Recyclable non hazardous waste is segregated from the Laboratory waste. Allcontaminated agar plates are autoclaved before dumping. Hazardous COD vials are collectedand treated off site.

PLANT OPERA TlONSThe operations of the different sections of the Co-op are controlled by computer systems.Each area has its own independent system, which controls the running of that plant. Thesesystems are controlled by operators who can over see the running of the entire plant and makeadjustments to the overall system as needed.

RAw AND AUXILlARY MATERIALS

Milk is the main raw material used on-site. Other minor ingredients, include sodium carbonateand calcium hydroxide used in the production of caseinates, are stored on-site. HydrochloricAcid, used to precipitate casein from skim milk powder, is stored along with nitric acid andlactol (the bulk chemicals used in cleaning). A complete list of chemicals is described inSection G of this Application.

The main fuels used on-site are Heavy Fuel Oil and Liquid Petroleum Gas. All fuelscombusted on-site are monitored and recorded as part of the plants Greenhouse Gas EmissionsPermit.

ENERGY USEThree forms of energy, heavy fuel oil (HFO), liquid petroleum gas (LPG) and electrIcity,power the plant. The HFO is used to generate steam, which in turn is used mainly in thepasteurisation of milk and the drying of powder. It is also used for other applicationsthroughout the plant. The LPG is used to dry powder in the casein plant. Electricity is used topower the machinery in the plant. There is in place an electrical energy management system inthe plant to reduce any unnecessary energy usage and plans to monitor the steam system witha view to preventing steam loss and increasing efficiency are being investigated.

EMISSIONS

WaterThe main source of emission to water are from the plant is the wastewater treatment plant(WWTP). Waste water from the plant is sent to the WWTP, here it is passed through a numberof treatment systems and is discharged to the Nenagh river via the Clareen Stream as cleanwater (this discharge point, SW-2, is illustrated on Drawing E2.l Emissions to Surface WaterA8787-N007-B). Other sources of emissions to water include condensate water, a by-productof the evaporation process, which is discharged directly to the Clareen Stream. Storm waterdrains located around the plant (taking mainly rainwater from the roofs of buildings) are alsodischarged to the stream. A summary of the surface water emission points and sampling pointsare included in the table below.

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Eiri'ission Description Ass6cblteU D,~sc.nption"

,Point.

San1pli4g , -"

, Poidt .,;: '.,

'.",' ~

-.(i' ASW-I Upstream ambient monitoring-,

" J

" locationSW.,2 Treated Effluent SWM-2 Final effluent monitoring

• >~ . ~"'. location prior to dischargeRW~3 Rainwater - L~ading Bay ASW-2 Downstream ambient monitoring

.~. ~. ;-'; ;"<; locationSW':l:, , .Condensate &- ,rafu'water SWM-I & Condensate monitoring location

" ." '., .. ': from CaseinPi~rit ' ASW-2 & Downstream ambient.

monitoring locationRW~2' Rainwater - Liqufd Milk ASW-2 Downstream ambient monitoring

, . ," Area location

Rw:i" , .Rainwater - Dry'<:r'riods - Proposed visual assessment of:< :S:tore & Car ParI(.- ..~ rainwater discharge

The assimilative capacity of the Nenagh River has been calculated and it has been found thatthe effect of the discharged water from the site is within limits specified in the relevantlegislation.

AirThe main sources of emissions to air are from the boilers and powder production. Air emissionpoints are identified in the table below.

: En;rl~~j()nPijjiJ,t

AI-2 "

AI-4AI-5

.A2-1

Descriptro~

Boiler IBoiler 2

Boiler;3..(Currentlv non operational),'> .." Boiler 4 ' '; .

:A2:-4

Gorgan Dryer (lpfrequent use) ';. ~

Low sulphur HFO (1.0%) is used in the boilers to reduce emissions from the boilers stacks, Arecent survey concluded that the boiler emissions for SOx exceeded the Ambient Air Qualitylimits. Arrabawn are currently exploring the possibility of having Nenagh connected to the gasnetwork. If this is not feasible, a new lower sulphur fuel will be used in the boilers to reducethe SOx levels.

All powder silos, casein silos and casein dryers have filtration equipment fitted with bags.These remove dust from the air displaced from the silo. The powder dryers (Niro I & 2) arefitted with cyclones to reduce powder emissions to air. Although these cyclones reducedemissions, the PM IO values still exceed the BAT limits. Arrabawn is proposing to fit bag filtersto further reduce emissions and is currently researching this option. A programme for thisimprovement has been submitted to the EPA.

Fugitive emissions from the plant are considered negligible.

NoiseTo reduce noise emissions, as far as possible all plant is kept indoors; this helps to reducenoise generated by the plant. All cooling tower fans have been fitted with acoustic cowls. Theexhaust fans on the driers all have flexible couplings to reduce vibration. All air compressors

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are in enclosures. The blower at the effluent plant has been enclosed in a house that has noisesuppressant material and the pipe is lagged. A noise survey was carried out on site. Arrabawnare currently reviewing the findings to ensure compliance with the guidelines.

WasteSolid waste from the plant is mainly generated from packaging and waste product. All non­hazardous waste streams are sorted into recyclables and other waste. Designated areas(detailed in Section H) for cardboard, scrap metal, pallets, florescent lamps, and office paperhave been set up to facilitate separation for recycling. Hazardous materials including waste oiland COD vials are collected from the site and taken on for further processing in licensedfacilities. Further analysis of the waste streams in the plants is taking place to ensure areduction in waste generation and an increase in recycling.

GroundThere are no emissions to ground on site. Sludge generated in WWTP is recycled and used asa fertilizer which is spread on designated land (with the exception of the over winteringstorage period.) The management of the sludge including the preparation of nutrientmanagement plans and sludge disposal is contracted out. The sludge is regularly tested for it'snutrient value and this is used in the preparation of the Nutrient management plan for the landback. During the winter period when the sludge cannot be spread on land, it is composed in adesignated facility.

ENVIRONMENTAL MONITORING

Daily environmental monitoring takes place in the plant. An environmental technician takesdaily samples from the Clareen stream both up and downstream of the Co-op. Samples arealso taken from monitoring points around the plant and effluent treatment plant.

Readings from the water meter are taken to ensure water conservation is being maintained. Arange of testing is carried out on these samples to ensure that the discharge waters to thestream are within the set limits.

Out-of-spec samples (not within the set limits) are recorded and the source of the emission islocated and dealt with immediately. All information is recorded and department heads areinformed of any problems in their section.

The environmental manager reports on a monthly basis at the plant operations meeting on theenvironmental monitoring. Any complaints are investigated and resolved by theenvironmental manager.

ENVIRONMENTAL MANAGEMENT

Although a formal environmental management system has not been developed, there areprocedures in place under the ISO 9001 quality control system to manage the effluent plantand environment.

Arrabawn are currently preparing an accident and emergency response plan. This will includeboth health and safety and environmental aspects.

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23720800008n.doc

Al-l Map A - Site Layout Plan(Drawing Number N237208 - N005)

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Notes

Refer to B

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IPPC LICENCE APPLICATION

OFRE FMcG

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+353 (0)214809800+353 (0)214809801'NWw,monmaCpttllt,ledcclllmonmacpeUlt.lc

o Frtyne:

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Eng.Chk.

CoordInation

ISSUED FOR APPROVAL

Drawn Description

STrlllaud

]111::Donald

SITE LAYOUT PLANALl(MAPAj

A 14.11.07 5TRI

Designed

Drawn

Rev Date

Client

ARRABAWN CO-OPERATIVESOCIETY

~~

2372 OB-NOO 5

c

This document should not be relied on or used in circumstances other than those for which it was originally prepared and for which Mott MacDonald Pettitwas commissioned. Mott MacDonald Pettit accepts no responsibility for this document to any other party other than the person by whom it was commissioned.

Dwg.Chk.

Scale atAl

1:2,000Drawing No

Project

CAOOle

Approved F McGlve,n

A8787

237208N005

Stalu.l

lARev

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23720800008n.doc

Al-l Map B Site Layout Plan(Drawing Number N237208 - N006)

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Notes

IPPC LICENCE APPLICATION

OFRE FMcG

Ch'k'd App'd

+353 IO)Zl 4809800+353 (O)ZI 4809801www.monmacpenlt.ledccil'monmacpettlt.le

MottMac:DonlldPlrtIt5 EutgateAvenueEastgateUull!lslandCo. CorkIreland

Coordination

Eng.Chk. 0 Freynll

Approved F McGtvern

ISSUED FOR APPROVAL

Drawn Description

STrlllaud

]111 =Donald

SITE LAYOUT PLANAI.l(MAP B)

ARRABAWN CO-OPERATIVESOCIETY

A 14.11.07 STRI

Dwg.Chk.

Drawn

Designed

Rev Date

Client

Title

o

Dry Goods---Store

o 0

Bun~compoc~

2372 08-N006This document should not be relied on or used in circumstances other than those for which it was originally prepared and for which Mott MacDonald Pettitwas commissioned. Mott MacDonald Pettlt accepts no responsibility for this document to any other party other than the person by whom It was commissioned.

Scale atA3

1:1,000Drawing No

Project

CADnle

A8787

237208N006

Status

lARev

A

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23720800008n.doc

Al-l Map C Site Layout Plan(Drawing Number N237208 - N007)

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Notes

o

IPPC LICENCE APPLICATION

ARRABAWN CO-OPERATIVESOCIETY

OFRE FMcG

Ch'k'd App'd

+353 (0)214809800+35] (0)[email protected]

MonMl.cDonaldPlttJl5 EastgateAvenueEal.lgateUttlelslandCo. CorkIreland

ISSUED FOR APPROVAL

Drawn DescrIption

]111 ::Donald

SITE LAYOUT PLANALl

(MAP Cl

A 14. I 1.07 STRI

Rev Date

Title

Client

c

"1:oU

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Designed Eng.Chk. QFrevne

Drawn 5 Trlllaud Coordination

Dwg.Chk. Approved F McGlvern

237208-1\1007

This docUment should not be relied on or used in circumstances other than those for which it was originally prepared and for which Mott MacDonald Pettitwas commissioned. Mott MacDonald Pettit accepts no responsibility for this document to any other party other than the person by whom it was commissioned.

Scale atA]

1:1,000DraWing No

Project

CAD meA8787

237208N007

Status

lAR,v

A

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