Abbott - Environmental Protection Agency · 2011. 8. 16. · Proposed trimer levels for TOC and Total Nitroqen for diversion to the waste water treatment pbJ Evaporator condensate

Abbott Ireland Nutrition Division, t + 353 49 5559200 f + 353 49 5559201 Cootehill,

Cavan Ireland.

Ann Kehoe, Office of Climate, Licensing & Resource Use, €PA, PO Box 3000, Johnstown Castle Estate, County Wexford.

08fh August 2011

Re: Additional In formation requested for IPPC License Review Application - Reg No:

PO687-02

I n response to Loretta Joyce letter dated 22nd June 2011 and subsequent emails requesting

additional information in support of IPPC License Review Application please find each of the

questions addressed in the text below along with referenced attachments.

Question 1

Oetail how Similac and Gain condensate are separated, Clarify how the proposed divert

system for the Similac condensate stream would function given that high Total Nitrogen

readings for Similac condensate were observed during the TOC monitor testing, Provide

proposed trigger levels for TOC (with COO equivalent) and Total Nitrogen for Similac

condensate for diversion t o the waste water treatment plant.

Separation of Similac and Gain condensate

Similac and Gain products are processed, pasteurised, evaporated, dried and packed separately

(reference Attachment 01 of IPPC License Application). Both Similac and Gain products are

manufactured in batches. The condensate is a by-product of the evaporation process. Similac is

primarily evaporated in Evaporator 1 and Gain in Evaporator 2. Evaporators 1 and 2 are stand

alone. Similac condensate (condensate from Evaporator 1; SW1) was historically directed to

Oromore River with a conductivity diversion system to the WWTP. Gain condensate (condensate

from Evaporator 2; SW2) is permanently directed to the Waste Water Treatment Plant. Going

forward the plant would like t o have flexibility of using both Evaporators for both product

Abbott A Promise for Life

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types. If agreed with the Agency following the installation of a Biotector in Evaporator 1 a

second Biotector will be installed in Evaporator 2 and a divert system identical to the one

proposed in Evaporator 1 would be implemented. This would allow for a more flexible operation.

Diversion of the condensate

The BioTector shall divert the condensate stream to the Waste Water Treatment Plant based

on a determined alarm level for Total Nitrogen (TN) and likewise the BioTector output signal

shall re-divert the condensate to the river when the Total Nitrogen levels drop below the

preset alarm level.

This is achieved by use of an alarm relay built into the BioTector which can then control the

diversion valve position. The alarm level can be freely set during commissioning. Please note that

diversion of the condensate based on TOC level is controlled by the same method and will have

its own alarm relay.

Therefore TOC and/or TN values above the preset alarm level values will result in the diversion

valve connected to the BioTector operating, and both TOC and TN would be required to drop

below the preset alarm levels t o allow the condensate to flow to the river once again. Both TOC

& TN will also have their own separate 4-20ma signals from the BioTector which will be

connected to the process control room.

Proposed trimer levels for TOC and Total Nitroqen for diversion to the waste water treatment

pbJ

Evaporator condensate will be diverted to the Waste Water Treatment Plant at the following

trigger levels:

TUC > 27 mg//. This trigger value is equivalent to a COD of 80 mg/l which is a limit value that

was agreed with the Agency in 2010.

TN > 25 mg//. This trigger level corresponds with a 25 mg/l limit value that is in place for

SW2 as per IPPC License PO687-01 emission limit value.

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Question 2

Provide confirmation from Inland Fisheries Ireland that the measures proposed in the

letter dated 28th February 2011 are satisfactory

Appendix A contains confirmation from the Inland Fisheries that the measures proposed in the

letter dated 28th of February 2011 are satisfactory,

Question 3

Given that the proposed diffused air discharge may be in the path of the fish pass,

provide confirmation that fish life will not be adversely affected;

The proposed technology will not diffuse air discharge; it will diffuse treated water discharge,

The proposed diffuser system will consist of multiple ports which will improve dilution of the

treated water and will therefore improve river water quality. The diffuser pipe will extend

part way (approximately 60%) of the river's width. I t is not expected to be an obstacle for fish

to pass as the hydraulic conditions over and at the foot of the diffuser pipe (velocity, depth of

the water, aeration, turbulence, etc.) in relation to the swimming and leaping capacities of fish

will have no or little change to current river conditions. The diffuser will be surmountable in

both low and high flows.

A copy of the drawing for the location of the proposed diffuser has been sent to the Fisheries

and they have communicated that they are satisfied that there will be no negative impacts on

fish life once it is in place (see Appendix A).

Question 4

Provide building heights, with corresponding stack heights, for emission points AI-I, AI-2,

A2-I and A2-2;

Al-1, A1-2, A1-3 boiler emissions combine and exit from one stack. Stack height is 40.06

metres, the closest corresponding building height is 31.995 metres.


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A2-1 stack height is 37.06 metres, the closest corresponding building height is 33.265 metres.

A2-2 stack height is 36.15 metres, the closest corresponding building height is 31.995 metres.

Question 5

Provide the specifications of the two interceptors (Class and full retention or bypass);

visitor Car Park Interceptor

The interceptor at the visitor car park is class 1 and is a bypass interceptor.

Employee Car Park Interceptor

The interceptor at the employee car park is class 1 and is a full retention interceptor.

Question 6

With regard to Attachment I. 2, provide workings in relation to assimilative capacity

calculations for BOO, ammonia and orthophosphate. I n particular, clarify the source of

the background (upstream) concentration for ammonia and orthophosphate i.e. the Abbott

monitoring data provides a background concentration for orthophosphate of 0.05mg/l but it

appears that 0.038mg/1 was used in the calculation provided;

The full calculations for the assimilative capacity exercise are included as Appendix B to this

response for the following parameters: Bob, ammonia and orthophosphate.

I n relation to the value used for the upstream orthophosphate concentration, data from two

sources were used for the calculations; Abbott's own monitoring data and the Local Authority

data (Cavan County Council). The Local Authority data is shown in Table 2.1 of Attachment 1.2

(see table reproduced below). These sample locations are immediately adjacent to each other,

i.e. just off the New Bridge North of Clementstown.


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Table 2.1 Cavan County Council Monitoring Data - 2009/2010

20/08/20 09

Stati on Name

0.062 98.65

rc 0

z m

z

L

3

Stati on Name

600

t E v) t

5 - 5 U

0.038 15/10/200 88.3 9

cc 0

z

3 A5

9

<2

4

2

2 2.4

0.011

0.033

12.18 48 211

16.11 35 188

15.77 49 209

12.29 97 204 14.28 54.43 209

0 01/07/201

62.95 0.015 1 15/04/201 I I

0 21/10/201 0 Average

79.48 0.021

75.61 0.077 87.08 0.04

20/08/20 09

Station bate

<0.04 89.5

Hardness Nitrates* I /

600

mg/l mg/l

0.159 15/10/200 90.8 9

0.226

40.04

1 15/04/201 1 I 0 78.7 0.136 01/07/201

21/10/201 0.357 0.22

BOO I Chloride 1 1 Colour Cond.

us/c m mg/l mg/l

18.26

13.27

(2 1 12.05 1 75 1 210

<0.02 I 0.022 I 7.41 1 17.1

<0.02 I 0.023 I 7.8 ~ [:E!: ~

C0.02 <0.01 8.29

0.013

15.6 * Data used in assimilative capacity calculations as background Upstream Concentrations

bissolv ed Oxygen

mg/l

NT

8.28

7.1

8.44

7.71

8.64

8.69 8.1

Total Oxidise d Nitroge n*

mg/l

0.23

~0.04

<0.04

0.16

0.15

<0.04

0.37 0.228

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Where possible the Local Authority data was used, as it is understood that this monitoring is

part of the Water Framework Directive monitoring programme. Where Local Authority data

was not available the Abbott data was used. The exception t o this was BOD, as the Local

Authority monitoring had a limit of detection (LOD) o f (2 mg/l, whereas the laboratory analysis

LOD used by Abbott was lower and therefore measured actual concentrations below 2 mg/l. As

the table above from the Assimilative Capacity report shows, the values used from Cavan

County Council were denoted with an asterix.

As can be seen from the table, the average measurement for orthophosphate in 2009 and 2010

was 0.038 mg/l P, which was the value used for the assimilative capacity calculations. I t can also

be seen from the table that, with the exception o f one sample period (Zl/lO/lO), the

orthophosphate concentrations were below the average value.

Similarly, the ammonia concentration used in the assimilative capacity calculations is from the

Cavan County Council data set and was the average concentration for 2009 and 2010. The value

is reported as 0.04 mg/l in Table 2.1, this was rounded up from the actual measurement of

0.038 mg/l.

Question 7

Given that, according to Appendix 1 of Attachment 1.2.1, the lowest river flow occurred

in June 2008, and flow was augmented in May, June and July 2010, justify the assertion

in Attachment 1.2.2 that periods of low flow do not generally correspond with the

spawning periods for coarse fish.

The spawning periods for coarse fish that have been recorded in the Dromore Lake are outlined

in Table 3.1 below.


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Table 3.1 Spawning Periods for Coarse Fish Fish Type Spawning Period Spawning Areas

Pike Feb - April Flooded grass, reeds Tench June - July Plants, shallows Roach May - June Plants, stones Bream May - June Weed bed, shallows Perch April - May Weeds, submerged bushes

, Rudd April - June Stems of water weeds

Attachment 1.2.2 of the IPPC License review application states that periods of low flow do not

generally correspond with the spawning periods outlined above, with the low flow in the river

occurring late summer. The low flows detailed in Appendix 1 of Attachment 1.2.1 show the

average low flows over the past four years (2007 - 2010), with augmentation taking place on a

number of occasions, I t is agreed that over these years, the lowest average flows tended to be

from May - July. However, the report was referring in general to a longer period of flow

monitoring, i.e. records of flow monitoring from 1999. This monitoring data show that overall,

the periods of low flow were not limited to these months (May - June) as the months with the

lowest flows recorded are as follows:

1999 - May, August & September

2000 - March, May & October

2001 - August & September

2002 - January & August

2003 - June, July & September

2004 - January, February & March

2005 - June, July & September

2006 - July, August & September

2007 - April, May & September

From the flow monitoring data (Appendix C) it can be seen that the low flows are variable and

that the low flow periods were not always over consecutive months. Over the period where river


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flows were monitored, May and June have certainly shown low flows at times, but months such

as September and August also showed periods of low flow.

As per the Lake Abstraction Assessment (Attachment 1.2.2 of the application), it is

recommended that should lake levels drop significantly over a long period of time due to

drought conditions, then augmentation pumping and water abstraction rates should be reviewed

with relevant bodies, i.e. the €PA and Fisheries Board, in order to avoid ecological damage,

especially to spawning grounds on the lake.

Question 8

I n addition to the above please also provide an updated non-technical summary t o reflect

the information provided in your reply.

The NTS has been updated to reflect the information provided in this response and is included

with the response

Question 9

As part o f your Section 90 response, would you please provide confirmation from the

Planning Authority that, in the granting of planning approvals t o Abbott Ireland at

bromore West, Cootehill, Co. Cavan, no Environmental Impact Statement was required in

relation t o planning permissions granted, since your IPPC licence was granted, on 7'h

February 2005.

Please see confirmation letter from planning permission issuing Authority Monaghan County

Council in Appendix D which states that no Environmental Impact Statement was required in

relation to planning permissions granted since February 2005.


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Question 10

I n relation to pumping of lake water, what is the level agreed with Inland Fisheries

Ireland, below which pumping of lake water is prohibited? Also, how often are readings

taken from the staff gauge a t the edge of the lake?

I t was agreed with the Inland Fisheries that pumping o f lake water wil l stop at 0.38m below

the lake level at which augmentation commenced. A trigger level of 75% of 0.38m was agreed

i.e. 0.285 m below the lake level at which augmentation commenced. When this level is reached,

Abbott Ireland will notify the Inland Fisheries.

Readings are visually observed from the staff gauge (Grid Ref. 259832 E, 315153 N) when

augmentation is in operation. However as the staff gauge is not on Abbott property it is not a

controllable secure monitoring instrument and therefore Abbott also monitors the bromore

lake level on Abbott property using a level meter, the meter is located approximately 1 metre

upstream of the weir (Grid Ref. 259741 E, 315171 N). The meter is calibrated and maintained

by Abbott. The meter readings are continuously recorded and managed by Abbott. When

augmentation is initiated the level meter is monitored continuously and the drop in lake level is

calculated. Should a drop o f 0.285 m occur it would be reported to Inland Fisheries. We have

not breached the agreed drop level since the IPPC license was issued in 2005 and the Fisheries

have not communicated any issues to Abbott regarding the level of the lake. Going forward we

propose to only use Abbott lake level meter (Grid Ref. 259741 E, 315171 N).

Question 11

What is the agreed monitoring frequency for temperature upstream and downstream in the

bromore River? Also do you have the analysis methodhechniques used for Oromore River

flow and bromore lake level and if possible the location (coordinates) of these two

monitoring points?

There was no official agreed monitoring frequency for temperature upstream and downstream

in the bromore River with the Agency. Condition 6.9 on existing license PO687-01 states "No


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effluent or condensate shall be discharged which results in a temperature increase at the edge

of the mixing zone of greater than 1.5oC in the receiving system." Schedule 2 (i) states:

S'chlpduie Z(i) Emissiu~s to Wafer EndssionPoint Refcirnct So.: SW1

Same of Recehtng Wztcrr: JhmoreRiver

Locatioa: w h n g c -

Abbott has temperature meters upstream and downstream of the discharge point and records

the temperature reading on a daily basis. The meter readings are continuously recorded and

managed by Abbott and there is a plan to install an alarm system to alert Abbott if the

temperature difference exceeds 1.5 degree Celsius.

Currently and historically Abbott have been monitoring Oromore River flow by means of a daily

river height measurement and indirect flow calculation. However it was agreed with the Agency

in March 2011 that Abbott install a permanent flow meter in the river to ensure that the flow is

recorded by a direct accurate method. The installation of the Channel Master HAOCP,

Telemetry Oata logger for the recording of velocity / flow data took place in April 2011.

Connections from the Channel Master flow meter are made to a telemetry datalogger for the

collection of velocity and stage data. The meter is currently in commissioning phase. Please find

the Abbott letter detailing the new flow meter to the License Inspector and the Agency's

approval letter in Appendix E.

Abbott monitor the Dromore lake level using a level meter, the meter is located approximately 1

metre upstream of the weir (Grid Ref. 259741 E, 315171 N). The meter is calibrated and

maintained by Abbott. The meter readings are continuously recorded and managed by Abbott.


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EPA Export 16-08-2011:03:47:04

bromore lake level staff gauge coordinates are 259832 E, 315153 N and bromore Lake level

electronic meter on Abbott property coordinates are 259741 E, 315171 N.

bromore River Flow meter coordinates are 259741 E, 315171 N.

Note: GPS not used, grid references obtained from Ordnance Survey Ireland Raster data

Question 12

Oromore River is noted as having 'good status in your review application - I 'm finding that

it is showing up as 'poor' status. You might clarify where your information came from or if

it's an error.

The current status for the bromore River is 43, both upstream and downstream of the Abbott

site, which is 'poor' as you noted. This information is provided on the EPA ENVision website. At

the time of assessing the surface water environment for the purpose of the Licence review

application, the status was noted as 'good' on the available database.

I n relation to the impact assessment of the bromore River that was carried out as part of the

review application, 'good status' regulatory limits were used for the assimilative capacity

calculations. Regardless of whether the river is currently of 'poor' or 'good' status, the river

must achieve good status (by 2015) as part of the Water Framework Directive requirements. I n

addition, actual monitoring data was used for the calculations and not the Q values given on the

EPA database. Therefore the limits used are still appropriate to assess the impact of the

increase in F E discharge from the Abbott facility to the bromore River,


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We trust that the above information meets with your requirements. Should you require any further information, please do not hesitate to contact me.

Yours Sincerely,

~~

Petrina Ashford Environmental Coordinator


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Appendix A

Inland Fisheries biffuser Confirmation Letter


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lascach lntire Eireann / / Inland Fisheries Ireland f

Petrina Ashford, Environmental Coordinator, Abbott Ireland, Cootehill, Co. Cavan 21st July 2011

Re: Proposed alteration to Final Treated Effluent (FTE) to Dromore River by discharge via multi-port diffuser.

Dear Ms. Ashford,

We refer to the drawing received from you in relation to above. We have no issues with the proposed works outlined.

Yours Sincerely,

Fisheries Environmental Officer

-~ -~~ _ - . _____ _______ ~ ~

Ceantar Abhantrai an larthuaiscirt, Uachtar Achaidh, Corrlios Mor, An Cabhbn. - North Western River Basin District, Woteraughy, Corlesrnore, Co. Cavan.

+ 353 (0) 49 4337 I74 - [email protected] - www.fisheriesireland.ie

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Appendix B

BOO, ammonia and orthophosphate Calculations


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Calculations for Effluent at Maximum Concentrations Measured in 2010

BOD

upstream receiving river flow, 95

percentile flow (m3/s)

C downstream=(F river 95* C

0.168

back) + (F effluent * C effluent)/

(F river 95 + F effluent)

SW Regs Limit

Existing SW Regs limits

background/upstream concentration in

receiving water (mg/l)

effluent flow discharging to receiving

waters, use average (m3/s)

permissible effluent concentration

discharging

to receiving waters (mg/l)

C downstream

1.18

0.037

5.5

F river 95

C back

F effluent

C effluent

Ammonia

C downstream=(F river 95* C back) +

(F effluent * C effluent)/ (F river

95 + F effluent)

New SW Regs Limit


C downstream

1.96

2.6 (Good Status - 95%ile)

6

Downstream concentration in

receiving water (mg / I)

0.28 (0.13 as N)*

0.14 (95%ile)

0.2 (A1 Waters)

bownstream concentration in


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F river 95 0.168 145OOm3/day * C back 0.038

3.037 F effluent 3ZOOm3/day

C effluent

C downstream=(F river 95" C back) +


95 + F effluent)

New SW Regs Limit


C downstream

F river 95

C back


0.067


0.03



upstream receiving river flow,

95 percentile flow (m3/s) 0.168 145OOm3/day


95 percentile flow (m3/s)

bac kground/upstream

concentration in receiving water

(mg/l)

effluent flow discharging to

receiving waters, use average

(m3/s)

permissible effluent

concentration discharging

to receiving waters (mg/l)

*N calculated from NH3-N as percentage of molecular mass (N = 14, NH3-N = 31)


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EPA Export 16-08-2011:03:47:04

i i

C downstream=(F river 95" C

back) + (F effluent * C

effluent)/ (F river 95 + F

effluent)

SW Regs Limit


F effluent

C effluent

4.58


<5

background/upstream


(mg/l)

effluent flow discharging to

"eceiving waters, use average

:m3/s)

Iermissible effluent

:oncentration discharging

o receiving waters (mg/l)

2 downstream

: river 95

Calculations for Effluent at Maximum Permitted Concentrations


upstream receiving river flow, 95

percentile flow (m3/s) 0.168 14500m3/day

BOO

background/upstream concentration in

receiving water (mg/l) back

0.038

1.18

3.037 32OOm3/day

.;I- -

Downstream concentration in

Page I? Abbott A Promlse for Life

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F effluent

C effluent

effluent flow discharging to receiving

waters, use average (m3/s) 0.037 320Om3/day

permissible effluent concentration

discharging

to receiving waters (mg/l) 20

Page 18



95 + F effluent)

New S W Regs Limit


C downstream

F river 95

S back

: effluent


0.28 (0.13 as N)*

0.14 (95%ile)

0.2 (A1 Waters)



u p 0 %--

95 percentile flow (m3/s) 0.168 14500m3/day

background/upstream


(mg/l) 0.038 effluent flow discharging to


(m3/s) 0.037 3ZOOm3/day

permissible effluent

effluent


to receiving waters (mg/l) 1.4

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Orthophosphate (MRP)



95 + F effluent) 0.067 New S W Regs Limit

Existing SW Regs limits 0.03



C downstream receiving water (mg/l)

F river 95 95 percentile flow (m3/s) 0.168 145OOm3/day

background/upstream



C back (mg/l) 0.038 effluent flow discharging to


F effluent (m3/s) 0.037 32OOm3/day permissible effluent


to receiving waters (mg/l) 0.2 C effluent

Page IQ 3 Abbott A Promise for Life

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EPA Export 16-08-2011:03:47:04

Appendix C

1999 to 2007 River Flows

Page 20 Abbott A Promise for Llfe

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18/03/1999 I 175656 I 28/06/1999 I 37056 19/03/1999 I 202536

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Date 29/06/1999 30/06/1999 01/07/1999 1 Shutdown 1 11/10/1999 I 317664 02/07/1999 1 Shutdown I 12/10/1999 1268248

River Flow m3/day Date River Flow m3/day 46872 09/10/1999 431448 37056 10/10/1999 370848

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I I I I

For

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EPA Export 16-08-2011:03:47:05

24/07/2000 1 Shutdown I 03/11/2000 I 1720392 21/08/2000 1 40296 I 04/11/2000 1 1869864

06/09/2000 I 129384 I 17/12/2000 1 2023440 07/09/2000 1 122040 I 18/12/2000 I 1720392

19/10/2000 1 15768 20/10/2000 1 16752

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EPA Export 16-08-2011:03:47:05

22/02/2001 23/02/2001 24/02/2001

168504 04/06/2001 44,500 144552 05/06/2001 44,500 122040 06/06/2001 <14,500

I 07/06/2001 I 08/06/2001

25/02/2001 I 88104 25/03/2001 1 193826

< 14,500 44,500

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EPA Export 16-08-2011:03:47:05

04/09/2001 1 (14.500 I 13/12/2001 I 597528 05/09/2001 I 44,500 1 14/12/2001 I 349224 06/09/2001

07/09/2001 08/09/2001 09/09/2001 10/09/2001 11/09/2001

44,500 15/12/2001 262250.4

(14.500 16/12/2001 220416 44,500 17/12/2001 168504 44.500 18/12/2001 262250.4 44.500 19/12/2001 220416 (14,500 20/12/2001 168504

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EPA Export 16-08-2011:03:47:05

11/01/2002 I 49440 I 28/02/2002 I 3160392 12/01/2002 I 49440 I 01/03/2002 I 3115344 13/01/2002 I 49440 I 02/03/2002 1 2925672 14/01/2002 I 59256 I 03/03/2002 I 2591952 15/01/2002 I 59256 I 04/03/2002 1 2221032

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21/04/2002 I 438384 I 09/06/2002 I 392928 22/04/2002 I 438384 I 10/06/2002 I 349224

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I

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EPA Export 16-08-2011:03:47:05

1 08/07/2003 1 22334 113/09/2003 I 19608 09/07/2003 I 19620 1 14/09/2003 I 15000 10/07/2003 I 36672 1 15/09/2003 1 (14,500

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EPA Export 16-08-2011:03:47:05

08/11/2003 I >lo7928 I 25/12/2003 I 461760 09/11/2003 I >lo7928 I 26/12/2003 I 461760

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29/12/2003 I 497592 30/12/2003 I 473568

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EPA Export 16-08-2011:03:47:05

16/10/2004 I 1118160 I 13/11/2004 I 844152 17/10/2004 [ 993192 I 14/11/2004 1 717216 18/10/2004 19/10/2004 20/10/2004 21/10/2004 22/10/2004 23/10/2004

902784 15/11/2004 676488 801072 16/11/2004 597528 717216 17/11/2004 534312 663024 18/11/2004 497592 703560 19/11/2004 473568 858672 20/11/2004 844152

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EPA Export 16-08-2011:03:47:05

14/03/2005 15/03/2005 16/03/2005 17/03/2005 18/03/2005

24679 23/04/2005 287162 27156 24/04/2005 229574 33528 25/04/2005 185232 40728 26/04/2005 152400 44926 27/04/2005 114883

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EPA Export 16-08-2011:03:47:05

bote

09/05/2005 10/05/2005

River Flow m3/day 88106 70152

30/04/2005 01/05/2005 02/05/2005 03/05/2005 04/05/ 2005 05/05/2005 06/05/2005

185232 229574 238824 238824 185 2 3 2 168504 176782

11/05/2005 12/05/2005 13/05/2005 14/05/2005 15/05/2005 16/05/2005 17/05/2005 18/05/2005 19/05/2005 20/06/2005 21/06/2005 22/06/2005 23/06/2005 24/06/2005

08/05/2005 I 122040

44926 44926 30598 25920 24679 22334 20076 19620 169520 (14.500 < 14,500 < 14,500 16920 17952

07/05/2005 08/05/2005 09/05/2005 10/05/2005 11/05/2005 12/05/2005 13/05/2005

168504 136872 129389 101131 75907 75907 59256

14/05/2005 15/05/2005 16/05/2005 17/05/2005 18/05/2005 19/05/2005 20/05/2005 21/05/2005 22/05/2005 23/05/2005

36912 33528 27156 16920 22334 24679 27156 44926 44926 88106

25/06/2005 26/06/2005 27/06/2005 28/06/2005 29/06/2005 30/06/2005 01/07/2005 02/07/2005 03/07/2005 04/07/2005

16920 (14.500 (14,500 (14.500 44,500 (14.500 (14.500 (14.500 N/A (14.500

24/05/2005 25/05/2005 26/05/2005 27/05/2005

94512 94512 262250 338592

05/07/2005 06/07/2005 07/07/2005 08/07/2005

(14.500 < 14,500 < 14,500 < 14,500

09/07/2005 10/07/2005 11/07/2005

< 14,500 (14.500 (14.500

31/05/2005 01/06/2005 02/06/2005 04/06/2005 05/06/2005 06/05/2005 07/05/2005

307394 277248 262250 229574 220416 193826 144550

12/07/2005 13/07/2005 14/07/2005 15/07/2005 16/07/2005 17/07/2005 18/07/2005 19/07/2005

(14.500 (14.500 (14.500 (14,500 (14.500 (14.500 (14.500

N/ A

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31/07/2005

02/08/2005 03/08/2005

01/08/2005 Shutdown 18/09/2005 81888

Shutdown 20/09/2005 114883 Shutdown 21/09/2005 129389

Shutdown 19/09/2005 101131

25/08/2005

27/08/2005 26/08/2005

13/10/2005 160363 (14,500 14/10/2005 176782

44.500

(14,500 15/10/2005 176782

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, , ,.*,*-..#,a-

05/09/2005 06/09/2005

44,500 24/10/2005 229574 (14,500 25/10/2005 521976

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EPA Export 16-08-2011:03:47:05

Date 01/01/2006 02/01/2006 03/01/2006 04/01/2006 05/01/2006

River Flow m3/day Date River Flow m3/day 559296 10/02/2006 15000 597528 11/02/2006 15950 597528 12/02/2006 20076 546768 13/02/2006 24679 497592 14/02/2006 88106

18/01/2006 19/01/2006 20/01/2006 21/01/2006 22/01/2006

I 09/02/2006 I 19620

731712 27/02/2006 70152 703560 28/02/2006 54221 717216 01/03/2006 23520 689976 02/03/2006 21216 649800 03/03/2006 16920

04/02/2006 05/02/2006 06/02/2006 07/02/2006 08/02/2006

36912 17/03/2006 1382688 27156 18/03/2006 1215312 24679 19/03/2006 1008528 22334 20/03/2006 844152 22334 21/03/2006 623496

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29/04/2006 30/04/2006

15000 (14,500

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EPA Export 16-08-2011:03:47:05

Date I River Flow m3/dav I bate I River Flaw m3/dav 10/06/2006 11/06/2006

12/06/2006 13/06/2006 14/06/2006

15/06/2006 16/06/2006

21216 18/07/2006 44,500 16920 19/07/2006 (14,500 15950 20/07/2006 (14.500 13176 21/07/2006 (14.500 15000 22/07/2006 44.500

19620 23/07/2006 (14.500 17952 24/07/2006 (14.500

17/06/2006 18/06/2006 19/06/2006

22334 25/07/2006 (14.500 22334 26/07/2006 < 14,500 21216 27/07/2006 Shutdown

20/06/2006 21/06/2006 22/06/2006 23/06/2006

20076 28/07/2006 Shutdown 22334 29/07/2006 Shutdown 20076 30/07/2006 Shutdown 23520 31/07/2006 Shutdown

04/07/2006 05/07/2006

06/07/2006 07/07/2006 08/07/2006 09/07/2006 10/07/2006

15000 11/08/2006 Shutdown 15000 12/08/2006 Shutdown

(14,500 13/08/2006 Shutdown 44,500 20/08/2006 < 14,500 (14,500 21/08/2006 < 14,500 (14.500 22/08/2006 (14,500 44.500 23/08/2006 (14.500

11/07/2006 12/07/2006 13/07/2006

44,500 24/08/2006 (14.500 (14,500 (14.500

14/07/2006

15/07/2006 16/07/2006 17/07/2006

(14.500

44,500 (14.500 (14.500

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22/09/2006 I 297240 I 08/11/2006 1 1008528 23/09/2006 I 370848 I 09/11/2006 I 873312

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10/01/2007 I 1469136 I 05/03/2007 I977928 11/01/2007 I 1813344 I 06/03/2007 I 1086480

29/01/2007 30/01/2007 31/01/2007

801072 676488 571968

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04/08/2007 05/08/2007 06/08/2007 07/08/2007 08/08/2007

Shutdown 25/09/2007 20076 Shutdown 26/09/2007 21216 Shutdown 27/09/2007 21216 Shutdown 28/09/2007 33528 Shutdown 29/09/2007 36912

30/09/2007 44926

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18/11/2007 19/11/2007

~~

152400 370848

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EPA Export 16-08-2011:03:47:05

Appendix b

Updated Non-Technical Summary


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EPA Export 16-08-2011:03:47:05

ABBOTT COOTEHILL EPA IPPC LICENCE REVIEW

APPLICATION

NON-TECHNICAL SUMMARY

Technical Report Prepared For

Environmental Protection Agency

Technical Report Prepared By

Mairead Morrissey BSc MSc

Our Reference

MM/10/5356A.I Rev.3

Date of Issue

3rd August 201 1

Unit 5, ATS Building, Carrigaline Industrial Estate, Carrigaline, CO Cork. Ireland

T: + 353 21 438 7400 F: + 353 21 483 4617 E: [email protected] W: www.awnconsulting.com

Dublin Office The Tecpro Building, Clonshaugh Business R Technology Park, Dublin 17, Ireland 1. F

t. 353 1 847 42?0 + 35.3 1 847 4257

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EPA Export 16-08-2011:03:47:05

Abbott Cootehill IPPC Licence Review Application - NTS AWN Consulting Limited

Report Prepared By: Report Checked By:

MAIREAD MORRISSEY Principal Environmental Consultant

DR FERGAL CALLAGHAN Director

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I ** -*-.-_I.-


1 .o 2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0

10.0

CONTENTS

INTRODUCTION GENERAL INFORMATION

2.1 Planning Permissions 2.2 Site Notice and Notification of Application Intent 2.3 Activities to be Licensed 2.4 Seveso II Regulations

3.1 Description of Facility 3.2 Hours of Operation 3.3 Outline EMS 3.4 Structure & Personnel 3.5 Operations at the Facility 3.6 Overview of Quality Management System 3.7 Emissions Sources

EXISTING ENVIRONMENT & PREDICTED IMPACTS 4.1 Air Quality 4.2 Surface Water 4.3 Groundwater 4.4 Noise

DESCRIPTION OF THE SITE & ACTIVITIES

PROPOSED CHANGES TO SAMPLING/MONITORING POINTS OR LIMITS 5.1 Air Quality Monitoring 5.2 Treated Effluent Sampling 5.3 Noise Monitoring

6.1 Air Quality 6.2 Noise Emissions 6.3 Emissions to Surface Water

MITIGATION/ABATEMENT MEASURES

6.4

MATERIALS & ENERGY USE

ACCIDENT & EMERGENCY PROCEDURES AFTERCARE, DECOMMISSIONING & RESTORATION CONCLUSIONS

Surface Water Runoff & Similac Condensate

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4

4 4 4 5 5

5 5 5 5 6 6 9 10

12 12 13 16 17

17 18 18 19

20 20 21 21 22

23

24

24

25

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1 .o

2.0

2.1

2.2

INTRODUCTION

Abbott is applying to the Environmental Protection Agency (EPA) for a Review of their current Integrated Pollution Prevention & Control Licence for the operation of the dairy product manufacturing facility at Dromore West, Cootehill, Co. Cavan (See Attachment A. 1.1).

A review is required due to the increase in capacity of the facility by approximately 40% of current production, and the works associated with this increase in capacity.

This Non-Technical Summary is included as Attachment A.l of the application to the EPA (herein referred to as the Agency) and summarises the sections of the application form and associated attachments.

GENERAL INFORMATION

Planning Permissions

A number of planning permissions have been applied fodgranted since the previous IPPC Licence application, for various works at the site. The most recent permissions granted are to facilitate an increase in capacity of the facility, by Monaghan Co. Co.

Planning Reference: 10/173, was granted on the 21" June 2010 for the following:

- A single storey office extension at the southweastern end of the existing

A new evaporator tower connected to the northern elevation of the existing

An extension to the existing staff car park (23 new spaces)

warehouse building

dryer tower (33m height) -

-

Planning Reference: 10/580 was granted on the 1 Oth February 201 0 for the following:

- Upgrade of the existing effluent treatment plant

A copy of these permissions is included with the IPPC Licence review application, along with all planning permissions applied for and granted since the previous application.

It has been confirmed in a letter from planning permission issuing authority Monaghan County Council, which is included as part of the response to a Request for Additional Information from the EPA that no Environmental Impact Statement was required in relation to planning permissions granted since February 2005.

Site Notice and Notification of Application Intent

A Site Notice advising of the IPPC Licence review application has been erected at the entrance to the Abbott site. The notice will remain in place for one month after the date of submission to the EPA.

Notification of the IPPC Licence review application was also placed in the following newspaper publication: Irish Times (dated Thursday 2Ist April, 2011), which is a paper circulated both locally and nationally.

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Written notification was provided to Monaghan County Council, as the relevant Local Authority, on 2gth March 2011 by AWN Consulting Ltd on behalf of Abbott Cootehill. Notification was also provided to Cavan County Council.

2.3 Activities to be Licensed

The licensable activity is the manufacture of dairy products.

The Activities, under the First Schedule of the EPA Act, 1992 are:

- Class 7.2 the manufacture of dairy products where the processing capacity

Class 2.2 the burning of coal or oil in a boiler or furnace with a nominal heat exceeds 50 million gallons of milk equivalent per year; and

output exceeding 50 MW. -

2.4 Seveso II Regulations

Based on information available for products used on site and corresponding usage and storage volumes, the EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations 2006 (S.I. No. 74 of 2006) do not apply to the site.

3.0 DESCRIPTION OF SITE AND ACTIVITIES

3.1 Description of Facility

A plan drawing of the site is provided (Drawing Nos 001, 002, 003 and 003a), showing the location of all activities and identifying all buildings and facilities.

3.2 Hours of Operation

The facility is currently in operation 7 days per week all year round with the exception of two shutdown periods, one in the summer and one at Christmas (these last from one to two weeks each). Normal operating hours are Monday - Sunday, 24 hours per day on a shift basis. These operating hours will not change as a result of the increase in capacity.

3.3 Environmental Management System (EMS)

There is an EMS in place at the facility, to manage and control potential impacts of the facility on the environment.

The EMS is certified to IS014001 and it incorporates procedures for pro-active management of environmental issues and liabilities. The facility gained accreditation in 1997. Prior to IS014001 Abbott Cootehill had certification to BS7750, an EMS specification standard. Through IS014001 , Abbott operates a formal structure for environmental management, ongoing assessment of environmental performance and continual improvement at the site.

Specific Targets for each operational year are made and included in the EMS. There are specific roles and responsibilities established within the facility to manage, control and operate the EMS.

Standard Operating Procedures are in place as part of the EMS. These are procedures that are followed to ensure legal environmental compliance, to prevent

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EPA Export 16-08-2011:03:47:06


and mitigate environmental pollution on site and to allow the environmental targets for the facility to be achieved e.g. energy-use reduction targets, waste recycling targets, etc.

Training is provided for employees and management at the facility in order to ensure the EMS is implemented and maintained correctly.

An environmental records system is maintained as part of the EMS. These records include data on energy consumption, natural resource and raw material use, waste generation, waste disposal and waste recovery/recycling and emissions from the facility (odour, air quality, noise & vibration etc)

The EMS is audited twice a year by an external auditor. The objectives and targets and the environmental procedures for the facility are included with the main application.

3.4

3.5

Structure and Personnel

The structure of management and staff for the facility is detailed below.

The Site Director has overall responsibility for the running of the facility. The EHS/Operations Manager reports to the Site Director. The EHS Co-ordinator reports to the EHS/Operations Manager.

The Engineering Manager reports to the Site Director. The Process Engineering Manager reports to the Engineering Manager and controls the daily running of the processes at the facility. The Utilities Engineer reports to the Process Engineering Manager and controls operation of all utilities and effluent treatment operations.

The EHS Coordinator is responsible for the environmental management of the facility, overseeing and coordinating monitoring, sampling, liaison with the EPA and relevant authorities, implementing and maintaining the various elements of the EMS for the facility and reporting environmental issues to the EHS/Operations Manager.

Operations at the Facility

Existing operations at the facility will continue and an overview of these operations is presented in this section. In addition, a number of upgrades and changes to the operations have taken place or will take place as part of Project ICE.

Project ICE includes the following: - Upgrade to the Refrigeration Plant (Completed July 201 0)

Upgrade to the Water Treatment Plant (In progress) Upgrade to the Wastewater Treatment System/Plant (In progress) Installation of Bag-Off in Packing Area to allow for Bulk Bagging (Not Complete) Installation of 3rd Oil Blend System for increased processing speed (Completed July 201 0) Installation of Parallel CIP and Drier Feed Circuits. Second Feedline on Dryer 2 (Completed July 201 0) Upgrade to Internal and External Facilities to accommodate changeshpgrades (Ongoing) Installation of 3'' Evaporator (planning permission granted but this has not yet been approved internally) A third packing line will be added in the future

- - - -

-

-

-

-

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EPA Export 16-08-2011:03:47:06


Drawing No. 001 - Ref: 21029/CD/OO1 shows the overall site layout and site boundary, with Drawing No. 002 - Ref. 21029/CD/001, 003 - Ref. 21029/CD/OO1 and 004 - Ref. 21 029/CD/001 showing more detail of the facility and ancillary items on the site.

The elements of the site are as follows: Warehousing

Offices

Canteen

Laboratories

Wet Process Area

Dry Ingredients Area

Evaporators & Evaporator Tower

Drier Towers

Canning and Filling Area

Blending and Powder Silos

Engineering Offices

Bulk Storage Area

Boilers

Refrigeration Plant

Water Treatment Plant

Wastewater Treatment Plant

Main Switch Room and Emergency Generator

River Water Pump House

Security Hut

Milk, Oil and Syrup Intake Building

Wet Process

Pasteurisation and Evaporation

Ingredient Intake, Blending, Heating, Mixing, Homogenisation and Chilling

Dw Process

Drying & Powder Storage

CanningIPackaging

Skim milk, vegetable oil and syrup are delivered to the intake bay and stored in silos on site. Sucrose and other dry ingredients are delivered to site and transferred to silos or storage areas.

The purpose of the wet process stage is to mix the streams of skim milk, blended oil, syrup and bulk dry materials. The wet process production process involves blending and heating liquid and/or powdered skim milk with ingredient water, sucrose,

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vegetable oils, syrup, flavouring, vitamins, minerals and other powdered foodstuff ingredients.

The liquid mixture produced in the wet process area must be pasteurised and evaporated. The purpose of pasteurisation is to apply heat to the product to reduce bacterial and enzyme activity. The purpose of evaporation is to significantly reduce the water content and increase solids content.

Milk water condensate from the evaporation process is routed to the dryer heating coil where heat is recovered from the condensate and the condensate is cooled. At present all condensate (finished powder type 1 and type 2) is routed to effluent plant.

Once the liquid product has been evaporated and pasteurized, it is then pumped via high pressure pumps to two dryers. Drying involves the application of heat under controlled conditions to remove water in order to produce solid product. During the process, hot exhaust air is discharged via exhaust fans through an exhaust duct.

Once product is dried in the dryers it can be bagged off directly at the dryers or conveyed to finished powder silos. These silos supply powder either directly to the 2 existing packing lines or to two dry powder ribbon blending systems for additional ingredient addition and then onwards to the packing lines.

The objective of the packaging process is to ensure that the product is appropriately contained, protected and preserved so that it reaches the consumer as it left the production plant. The product is filled into a variety of cankontainer types and sizes depending on market requirements and the product is labeled. Pallets of full containers are transferred by forklift truck, off the out-feed conveyor, for stacking in the designated aisles within the warehouse awaiting distribution. Bulk products are transported for packaging off-site.

Ancillarv Operations The ancillary processes and operations are as follows:

Laboratory Operations - Microbiological testing of raw materials, intermediates and products and analytical analysis of raw materials, intermediates, products and water

Refrigeration PlanVChilied Water System - Chilled water circulation pumps circulate chilled water to the necessary processes, including product cooling, temperature maintenance of liquid milk and liquid product silos and air conditioning. An upgrade to the refrigeration plant was completed in July 2010

0 Water Treatment - Treatment of river water from the Dromore River for process requirements. This is currently being upgraded.

0 Waste Water - Treatment domestic and process effluents, for discharge of treated effluent into the Dromore River. This plant is being upgraded as part of Project ICE

Power & Energy Supply - Steam is produced on site using 3 no. gas oil burning boilers for indirect heating of the dryers, pasteurisers, heating the evaporators, calorifier (ingredient water heating), clean-in-place (CIP) systems and process plate heat exchangers. Compressed natural gas will be used in the future as an alternative to gas oil.

Electricity - Electrical power is supplied to the site by the Electricity Supply Board (ESB). 2 no. emergency 2,000 kVA diesel generators provide back-up power to the site.

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Compressed Air - There are four main 'oil free' air compressors at the site and local compressors for a number of areas

Bulk Nitrogen and Carbon Dioxide Storage and Distribution - Bulk nitrogen (N2) and carbon dioxide (CO2) are stored at the site and used in the packing operation of the product. N2 is also used in the vegetable oil system, syrup storage system and finished powder silos for blanketing and pipe p u rg i ng/f I u s h i ng . Cleaning in Place (CIP) - CIP of road tankers, skim milk silos, evaporators, dryers, product lines etc., is carried out from a centralised CIP station located in a dedicated contained area where any spills are diverted to drains leading to the waste water treatment plant.

Fire Protection - Firewater is supplied to the site from the Dromore River and distributed over the site to hydrants via a ring main. Sprinklers are installed in the main warehouse. A deluge system is also located within the dryers.

Offices - There are a number of offices on site for Administration/Finance, Human Resources, Manufacturing, Quality Assurance, Development, Engineering and Materials

Support Facilities - The main support facilities on site are the medical centre, canteen and security

Warehousing & Bulk Storage - All incoming packaging materials (cans, containers, cases, scoops, lids, etc.) and dry ingredients and other minor ingredients are stored in the warehouse. There are numerous storage and containment areas around the site for specific materials.

Waste Management - All recyclable wastes are segregated on site and collected for recycling by permitted waste contractors. General non-hazardous waste are compacted on site and collected for disposal by a licensed waste disposal contractor. All hazardous waste is labelled appropriately, covered where necessary and stored in contained areas on site before being collected by a permitted hazardous waste contractor and brought to a licensed facility for disposal, recovery or recycling. This includes laboratory wastes, empty hazardous containers and waste oils.

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3.6 Overview of Quality Management System

Abbott Nutritional Cootehill has a quality policy and is IS09001 accredited. The quality policy endeavours to:

0

0

Build quality into products, processes and services; and Incorporate continuous improvement into all aspects of the business.

There is a Quality and Food Safety Manual for the facility, which outlines the process-based approach to both Quality Management and Food Safety Management and meets the requirements of ISO9001, IS02200 and PAS220. The process based approach is designed to to facilitate consistency with the standards, allow ease of implementation and compliance assessment, as well as facilitation of more ongoing control and effectiveness of detailed processes within the organisation.

The Quality and Food Safety Systems Manual details organizational structure, defined roles and responsibilities and an outline of the documentation structure used to support the Quality and Food Safety System.

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Point Code

A1 -1

3.7 Emission Sources

Emission

NOx, SOX, CO, Particulates

Emissions to Air The main emissions to air are from boilers on site, and also from the dryer exhausts.

A1 -3

A2-1 A2-2

Air emission points are as follows:

NOx, SOX, CO, Particulates

Total Dust (Particulates) Total Dust (Particulates)

A34 A3-5 A3-6 A3-7

1 AI-2 1 NOx, SOX, CO, Particulates 1

Particulates Particulates Particulates Particulates

Point Code sw-1

I Organic and inorganic solvent vaDours I A3-1

Emission COD, Temperature

Organic and inorganic solvent vapours

Organic and inorganic solvent vaDours

A3-2

A3-3

I A3-8 I Oraanic vaDours I ianic vaDours

I A3-12 I Oraanic vaDours I

Emissions to Surface Water The main emission points to surface water emission points are at SW-1 from surface water and condensate (uncontaminated) and at SW-2 from treated effluent from the WVVTP.

Surface water emission points are as follows:

1 sw-2 CI, N, Ammonia, TP, MRP, OFG, BOD

Noise There are various noise generating items of equipment associated with the normal operation of the Abbott Cootehill plant. There is also equipment that is only used in emergency situations (e. g . em erg e ncy gene rat0 r) .

There are no new significant external noise generating items of equipment that will be installed as part of Project ICE, however there are a number of items that will generate some noise.

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There is a wide range of plant/equipment on site (including Project ICE). However, as most of these are currently installed and operating, noise measurements that were taken at the site for the purpose of this application take into account one or more items of noise generating equipment/plant. These noise measurement locations are therefore considered to be the noise source locations.

Noise emission points/sources are as follows:

I N-5 I I

~ ~

I N-I 2 I dB(Al -1

I N-I 5 I dB(A) I I N-16 I dB(A\ I

I N-24 I dB(AI I I N-25 I dB(A1 I I N-26 I dB(A\ I

There are 5 no. Noise Sensitive Locations that are monitored as part of the current IPPC Licence. See Section 4.4 for more detail.

G rou nd/G rou ndwate r There will be no emissions to ground or groundwater on site.

Various containment measures (bunding of materials stored on site, 2 no. interceptors etc.) are in place to prevent / contain any accidental releases which could potentially impact on ground or groundwater quality. The interceptor at the visitor car park is class 1 and is a bypass interceptor. The interceptor at the employee car park is class 1 and is a full retention interceptor.

Sludge is produced at the wastewater treatment plant. Due to the phasing out of landfilling of sludge, alternative means are now used for recycling the sludge, such as composting and landspreading. Currently sludge is being taken off site for composting, however sludge from the facility has been landspread in 2010 and this option may be utilized again in the future. The location of the landspreading is a farm

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owned by Mr Pat Callan, and it is located in Dunleer, Co. Louth. The company that currently manages both the composting and landspreading is Clearpower.

4.0

4.1

EXISTING ENVIRONMENT & PREDICTED IMPACTS

Air Quality

Existing Environment There is air quality monitoring carried out on the boiler emission points Al-1 (Boiler No.l), A1-2 (Boiler No.2) and A1-3 (Boiler No.3) as part of the current IPPC Licence. The parameters are NO,, SOx, CO and particulates.

There is also monitoring carried out on the dryer emission points A2-1 (Dryer No.l), and A2-2 (Dryer No.2) as part of the current IPPC Licence. The parameters are Total Dust.

The most recent monitoring results, i.e. for 2010 monitoring show that all parameters measured for the boilers and dryers were within the IPPC Licence limits. Full monitoring reports are included as part of the main application.

No monitoring is carried out for the 12 no. minor emission points.

Predicted Impact Air dispersion modeling was carried out for the main emission sources at Abbott Cootehill to predict the maximum ground level concentrations (GLCs) of pollutants (NOx, SOx, particulates) likely to occur as a result of atmospheric emissions from the plant.

The air dispersion modelling analysis was carried out using AERMOD dispersion model (Version 09292) which has been developed by the U.S. Environmental Protection Agency (USEPA) and following guidance issued by the EPA. The model input data included the stack discharge parameters, emission concentrations, receptor locations, five years of Clones Met Station meteorological data (2002 - 2006), building down-wash, terrain heights and land use. This air dispersion model takes into account, and assesses the potential impacts of, all aspects of Project ICE, including the proposed 3‘ evaporator.

The following stack and building heights were used: - Al-1, A1-2, A1-3 boiler emissions combine and exit from one stack. Stack

A2-1 stack height is 37.06 metres, the closest corresponding building height is

A2-2 stack height is 36.1 5 metres; the closest corresponding building height is

height is 40.06 metres, the closest corresponding building height is 31.995 metres;

33.265 metres; and

31.995 metres.

-

-

From the air dispersion model, it was determined that the maximum predicted GLCs would be below all applicable statutory Air Quality Standard (AQS) limit values. These limit values have been set to protect human health and the environment. As the maximum predicted GLCs of pollutants occurring as a result of emissions from the expanded plant are below the AQS limit values, emissions from the plant should not have any significant adverse impact on human health and the environment and the existing ambient air quality. As mentioned above compressed gas will be used in the future instead of fuel oil, this will not result in any increase in emissions.

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4.2 Surface Water

Existing Environment There is monitoring carried out on the surface water emission points: SW1 (Discharge to Dromore River) and SW2 (FTE Discharge to Dromore River) as part of the current I PPC Licence.

As part of the IPPC Licence requirements, for SW1 the parameters monitored are temperature, COD, pH, conductivity and a visual inspection. For SW2 the parameters are volume, pH, temperature, residual chlorine, suspended solids, total nitrogen, total ammonia, total phosphorus, orthophosphate and oils, fats & greases.

In addition, there are ambient monitoring points on the Dromore River, ASWl and ASW2, upstream and downstream of the facility respectively.

Abbott has continuous temperature meters upstream and downstream of the discharge point on the Dromore River and records water temperature daily. In April 201 1 new temperature meters were installed. The meter readings are continuously recorded and managed via SCADA and there is a plan to install an alarm system to alert Abbott if the temperature difference exceeds 1.5 degree Celsius.

Currently and historically Abbott have been monitoring Dromore River flow by means of a daily river height measurement and indirect flow calculation. However it was agreed with the Agency in March 201 1 that Abbott install a permanent flow meter in the river to ensure that the flow is recorded by a direct accurate method. The installation of the Channel Master HADCP, Telemetry Data logger for the recording of velocity / flow data took place in April 201 1. The meter is currently in commissioning phase.

Similac and Gain products are processed, pasteurised, evaporated, dried and packed separately (reference Attachment D. 1 of the IPPC Licence Application). Both Similac and Gain products are manufactured in batches. The condensate is a by-product of the evaporation process. Similac is primarily evaporated in Evaporator 1 and Gain in Evaporator 2. Evaporators 1 and 2 are stand alone. Similac condensate (condensate from Evaporator I; SWI) was historically directed to Dromore River with a conductivity diversion system to the WWTP. Gain condensate (condensate from Evaporator 2; SW2) is permanently directed to the Waste Water Treatment Plant.

In recent months the Similac condensate that makes up part of the emissions to SW1 has been diverted to the WWTP and treated with the effluent. This is due to TOC spikes that were noted in the condensate discharge. The cause of this is currently under investigation.

However, it is proposed to recommence discharging the Similac condensate through SW1 in the next few months. In order to do so without a potential risk to the surface water body, i.e. the Dromore River, and as part of this Licence review, a TOC monitor and divert system is proposed for the condensate stream (El), which would divert any discharge to the WVVTP automatically if required, i.e. if the TOC or BOD exceeds a certain limit.

Going forward the plant would like to have flexibility of using both Evaporators for both product types. Therefore a TOC meter is also planned for Evaporator 2 Condensate stream (E2), which will allow this stream to be monitored should Similac be sent to SW1 from this evaporator in the future.

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If agreed with the Agency following the installation of a Biotector in Evaporator 1 a second Biotector will be installed in Evaporator 2 and a divert system identical to the one proposed in Evaporator 1 would be implemented. This would allow for a more flexible operation.

The BioTector shall divert the condensate stream to the Waste Water Treatment Plant based on a determined alarm level for Total Nitrogen (TN) and likewise the BioTector output signal shall re-divert the condensate to the river when the Total Nitrogen levels drop below the preset alarm level. This is achieved by use of an alarm relay built into the BioTector which can then control the diversion valve position. Therefore TOC and/or TN values above the preset alarm level values will result in the diversion valve connected to the BioTector operating, and both TOC and TN would be required to drop below the preset alarm levels to allow the condensate to flow to the river once again. Both TOC & TN will also have their own separate 4- 20ma signals from the BioTector, which will be connected to the process control room.

Evaporator condensate will be diverted to the Waste Water Treatment Plant at the following trigger levels:

TOC > 27 mg/L This trigger value is equivalent to a COD of 80 mg/l, which is a limit value that was agreed with the Agency in 2010.

TN > 25 mg/L This trigger level corresponds with a 25 mg/l limit value that is in place for SW2 as per IPPC License PO687-01 emission limit value.

See Section F. l of the application for more details on the proposed TOC monitoring system. E l condensate will continue to be diverted to the WWTP until the TOC monitoring system is in place and is approved by the EPA.

In addition to the emission point monitoring, ambient surface water monitoring is carried out at the site, with 2 no. monitoring points: ASW-1 and ASW-2. Monitoring results for 201 0 are included with the main application. The results show that the river water quality was good for 2010 and that the discharges from the facility did not have a negative impact on the Dromore River. The most recent EPA status for the Dromore River was ‘poor’, based on the Q value for the waterbody, i.e. Q3.

Predicted Impact

The planned increase in capacity at the Abbott facility (Project ICE) will mean the Final Treated Effluent (FTE) discharge to the River Dromore will increase from a maximum of 2000 m3/day to a maximum of 3200 m3/day, which is approximately 60% increase in treated effluent discharge. The normal daily discharge will be approximately 2,500 m3/day.

The EC Environmental Objectives (Surface Waters) Regulations came into force recently and give effect to the Water Framework Directive (2000/60/EC). With these Regulations, there are new surface water limits for certain parameters, which will be enforced to ensure that Ireland meets it’s obligations under the Water Framework Directive.

An assimilative capacity study has been carried out in order to assess the receiving water body, i.e. the Dromore River, and how the increase in discharge will impact the surface water quality. It should be noted that the assimilative capacity assessment takes into account, and assesses the potential impacts of, all aspects of Project ICE,

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including the proposed 3‘ evaporator. The assimilative capacity assessment report is presented as Attachment 1.2.1 of the main application.

In relation to the assimilative capacity assessment, for the baseline values used for upstream river water quality, data from two sources were used for the calculations; Abbott’s own monitoring data and the Local Authority data (Cavan County Council). These sample locations are immediately adjacent to each other, i.e. just off the New Bridge North of Clementstown.

Where possible the Local Authority data was used, as it is understood that this monitoring is part of the Water Framework Directive monitoring programme. Where Local Authority data was not available the Abbott data was used. The exception to this was BOD, as the Local Authority monitoring had a limit of detection (LOD) of <2 mg/l, whereas the laboratory analysis LOD used by Abbott was lower and therefore measured actual concentrations below 2 mg/l. As the tables included in the Assimilative Capacity report show, when values from Cavan Co.Co. were used these were denoted with an asterix.

Ongoing monitoring of the river has shown that no significant deterioration in water quality occurs from the discharge from the plant and no pollution incidents have occurred as a result of the ongoing discharge.

The assimilative capacity report concludes that, based on the predictive calculations, it can be shown that the Dromore River has the capacity to assimilate an increase in the maximum discharge volume of final treated effluent from the Abbott site, even at low flow conditions in the Dromore River. This will result in maintaining current discharge concentrations (with the exception of MRP which would increase to 0.2 mg/l), but an increase in the overall mass emissions. It is concluded that the current concentrations for the final treated effluent are acceptable even with the proposed increase in discharge.

Predicted Impact on Lake Levels & Dromore River The current water abstraction from Dromore River for operational requirements of the facility is approximately 1800 m3/day. By fully implementing Project ICE, the water demand will increase by a maximum of 900 m3/day to approximately 2,700 m3/day. An assessment of the predicted impact on the levels of the lake immediately upstream of the weir at the facility has been carried out to determine how the increase in water abstraction for processing requirements will impact the lake levels.

The assessment findings were that the lake levels would not be adversely affected from the additional water use by the facility and that the Dromore River downstream of the site would benefit from increased water flow in the channel.

In relation to lake level monitoring, there is a system in place for recording the level of the lake and a level below which water abstraction/pumping must be stopped.

It was previously agreed with the Inland Fisheries that pumping of lake water will stop at 0.38m below the lake level at which augmentation commenced. A trigger level of 75% of 0.38m was agreed i.e. 0.285 m below the lake level at which augmentation commenced. When this level is reached, Abbott Ireland must notify the Inland Fisheries.

Readings are visually observed from the staff gauge (Grid Ref. 259832 E, 315153 N) when augmentation is in operation. However as the staff gauge is not on Abbott property it is not a controllable secure monitoring instrument and therefore Abbott

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also monitors the levels on Abbott property using a level meter, the meter is located approximately 1 metre upstream of the weir (Grid Ref. 259741 E, 315171 N). The meter readings are continuously recorded and managed via the sites Supervisory Control And Data Acquisition system. When augmentation is initiated the level meter is monitored continuously and the difference in lake level calculated and should the difference of 0.285 m occur it is reported to Inland Fisheries. Going forward Abbott propose to only use Abbott level meter (Grid Ref. 259741 E, 315171 N).

In relation to fish life, no negative impact is predicted for spawning beds on the lake. Attachment 1.2.2 of the IPPC License review application states periods of low flow do not generally correspond with recorded spawning periods for various fish. Generally over a long period of flow monitoring, i.e. records of flow monitoring from 1999 to 2010, the monitoring data show that the periods of low flow were not limited to the months of May - June, but lowest flows ranged from March through to October. Low flows were variable and low flow periods were not always over consecutive months.

In addition, by closing the side channel of the weir and therefore directing the water through the fish pass at the centre of the river, this will benefit the water flow down the fish pass. This report is included as Attachment 1.2.2 of the main application, along with the submission made to the Fisheries Board in relation to the Dromore River/Lake and weir management.

It is proposed to install a diffuser system on the FTE discharge pipe to aid the mixing of the discharge from the Abbott site. The proposed diffuser system will consist of multiple ports which will improve dilution of the effluent and will therefore improve river water quality. The diffuser pipe will extend part way (approximately 60%) of the river’s width. It is not expected to be an obstacle for fish to pass as the hydraulic conditions over and at the foot of the diffuser pipe (velocity, depth of the water, aeration, turbulence, etc.) in relation to the swimming and leaping capacities of fish will have no or little change to current river conditions. The diffuser will be surmountable in both low and high flows.

The Inland Fisheries Board is aware of this proposal and has been provided with a drawing detailing the location and dimensions of the diffuser. The Fisheries Board has indicated by means of letter to Abbott that they are satisfied with the proposal.

4.3 Groundwater

Existing Environment There is groundwater monitoring carried out at GWI, GW2 and GW3, which are the 3 no. boreholes on site, as part of the current IPPC Licence requirements. The monitoring includes the following parameters: pH, COD, major anions, major cations, total & faecal coliforms and total petroleum hydrocarbons.

In April 1997 a small leak was detected in an underground fuel diesel line feeding the generator after evidence of a small volume of oil was observed on the surface of the Dromore River. Emergency response measures were contained and a site investigation was conducted to determine the extent of pollution that had occurred, followed by remediation. The issue was resolved to the satisfaction of the EPA. The 2010 monitoring results showed that there were no exceedences of regulatory groundwater limits.

Predicted ImDact There is no predicted impact on the groundwater as a result of on site activities. As previously mentioned, sludge from the WWTP is taken off-site for either composting

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or landspreading. In the event of landspreading, the subject lands are approved and permitted sites with Nutrient Management Plans (NMPs) for the activity. The predicted impact on the environment as a result of the landspreading activities is considered to be negligible.

4.4 Noise

Existing Environment There is a noise audit carried out annually as part of the current IPPC Licence at noise sensitive locations as determined by Abbott and approved previously by the EPA. Daytime and night time surveys are carried out and the results are reported annually to the EPA.

The 2010 noise monitoring results showed that the sound level at all locations measured (Noise Sensitive Locations) were within the permitted levels for both daytime and night time, with the exception of NSL4 (the amenity park) during the night time survey. It should be noted that the results of the survey stated that traffic was the attributable noise source at that location. However, as the park is not open at night, the limit does not apply in this instance.

Predicted Impact A review of the facility noise generating items and noise measurements was carried out by a qualified acoustic consultant to determine the predicted impact of the plant and equipment that is part of Project ICE on the established noise sensitive locations. This report is included as Attachment 1.7.2 of the main application.

Details of plant items and their sound power / pressure levels as well as proposed equipment location drawings were obtained from Abbott and distances to the nearest noise sensitive locations were measured. Desktop noise level calculations were conducted with corrections applied for location/orientation of the equipment, attenuation due to distance and screening. Calculation predictions for each source was conducted at each of the five noise sensitive locations identified in the most current ( I l t h June 2010) IPPC noise emission monitoring report. The results of the calculations were then compared to existing Abbott facility noise emission at each location in order to determine the relative noise impact of the new equipment and its complicity with the IPPC licensing requirements.

Based on this prediction assessment, it was concluded that (a) Project ICE plant noise emission levels will be within the IPPC criterion of

55dB(A) for the daytime period at each of the nearest noise sensitive locations (b) Project ICE plant noise emission levels will be within the IPPC criterion of

45dB(A) for the night time period (except at NSL 4 which is a park and therefore a night time assessment is not applicable)

(c) Project ICE plant noise emissions should not increase existing Abbott Ireland plant noise emission levels at noise sensitive locations during the daytime by more than 1.5dB

(d) Based on the above results, the expected noise impact of Project ICE plant noise emissions on adjacent noise sensitive locations is expected to be insignificant and the plant selections would therefore be considered acceptable.

5.0 PROPOSED CHANGES TO SAMPLlNGlMONlTORlNG POINTS OR LIMITS

This subsection outlines proposed changes to sampling/monitoring points or limits that are in the current IPPC Licence. Justification for each of these is outlined below.

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5.1 Air Quality Monitoring

Stack Monitorina - Dryers Since the original IPPC licence application, both Dryer Towers are now fitted with bag filters, which have reduced the dust emission levels from the dryers (with reduced emission limits as outlined above). 201 0 monitoring of air emissions has shown that the dust concentrations were very low for the dryers. The monitoring results can be seen in Appendix A to this Attachment. In light of this, it is requested that the monitoring frequency for dust is reduced from 4 times per year to once a year.

5.2 Treated Effluent Sampling

Volumetric and Mass Emission Limit It is proposed that the limit values for the mass volumetric flow and the mass emissions of the FTE are increased by 60% of the current Licence limits.

This would mean that the concentration limits for the parameters measured in the FTE would remain as they are (with the exception of residual chlorine and orthophosphate - see below for justification), but that the mass emissions would increase. Table 1 outlines what these new mass emission limits would be.

Table 1 FTE Emission Limit Values

There are a number of drivers behind the volumetric increase of FTE. These are as follows:

There will be increased milk condensate associated with increased production Increased ingredient water usage associated with increased production There will be increased cleaning of process silos and milk trucks due to increased production Increase in items to be cleaned with more off line cleaning

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Skew towards increase of GAIN (vanilla) product versus Similac product, which generates more effluent There will be increased back-washing due to increased water treatment required This also includes for a potential third evaporator in the future

In order to justify these increases in mass emissions, an assimilative capacity study of the Dromore River was carried out, which is included as Attachment 1.2.1. The study shows that the river does have capacity for the increase in mass emissions.

In addition, it is proposed to extend the final treated effluent discharge pipe further into the centre of the river, with diffusers that will disperse the treated effluent more evenly. This will ensure a faster and more homogenous dispersion of the FTE in the river and therefore less of an impact on the receiving water.

Orthophosphate It is proposed to increase the concentration limit of orthophosphate from 0.03 mg/l to 0.2 mg/l. At present large amounts of ferric sulphate are used (as a coagulant) in the WWTP to reduce the orthophosphate levels. Using large quantities of this compound can lead to discoloration of the water.

A report was carried out on the use of ferric sulphate for removal of orthophosphate from the effluent by Veolia in November 2009. The report concluded that, although the iron and sulphate levels in the receiving waters, i.e. the Dromore River, were not excessively high, the amount of ferric suphate used could be reduced significantly by increasing the limit for orthophosphate.

The assimilative capacity assessment showed that the river has capacity to accept the increase in concentration whilst still meeting the regulatory limits for orthophosphate and total phosphorus in the receiving waters and also meeting the mass emissions limits of the Licence.

Residual Chlorine It is proposed that the current limit value of 0.005 mg/l for residual chlorine in the Final Treated Effluent (FTE) is increased to 0.03 mg/l. The low limit value is very hard to measure by the laboratory and is considered unduly onerous, as chlorine is not used extensively at the plant and is not, nor has it been in the past, an issue in terms of the FTE.

The increase to 0.03 mg/l had been verbally agreed between the EHS/Operations Manager and a previous EPA Inspector (Ms. Jennifer Cope) based on the fact that the laboratory instruments on site are only sensitive enough to record concentrations at 0.03 mg/l or greater.

5.3 Noise Monitoring

Noise Sensitive Locations Schedule 4(iv) of the current Licence requires that Belmont House (Monitoring Location Ref: NSL3) is included as a noise sensitive location. It is located northeast of the site. Abbott request that this monitoring point is excluded from the Licence for 2 main reasons:

(1) The location is no longer a justifiable noise sensitive location

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Belmont House was included as a noise sensitive location a number of years ago due to noise complaints raised by the inhabitants of the house at the time. Since the complaint noise attenuation has been fitted to both Dryers. The house is no longer occupied (only very occasionally) and no complaints have been made in relation to noise since Summer 2005.

(2) The location is hard to access for survey purposes

As the house is not occupied most of the time, the monitoring location is not easy to access. The access is protected by an electronic gate, and because nobody lives there anymore, trying to obtain access is very problematic.

As the house is no longer occupied, it is proposed to take this monitoring point off the list of noise sensitive locations for the Licence once reviewed.

Noise measurements were taken during the most recent noise survey (24‘h May 2010). The report, which is included in full as Section F.2 Appendix E of the main application, states that at Belmont House (NSL 3), the sound level readings were taken at the front of the house and that the site was not visible from the monitoring location.

The report states that during the daytime there was no major noise contributor and the Abbott facility was not audible during the survey. During the night time, there was no major noise contributor and the Abbott facility was faintly audible during the survey. The report concluded that the relevant conditions of the current IPPC Licence, i.e. 8.3 and 8.4 were met.

Therefore, as there appear to be no noise issues at the location, the house is no longer continuously occupied and no complaints have been received by the site in recent times in relation to noise, it is proposed that this noise monitoring location is not part of the reviewed Licence.

6.0 MITIGATION MEASURESlABATMENT

6.1 Air Quality

Drvers There are abatement systems in place for the 2 no. dryers in relation to emissions to atmosphere. The exhaust air from each chamber passes through cyclones to recover particulate material. This particulate matter is incorporated back into the product. The exhaust air from the each dryer tower passes through a bag filter after passing through the cyclones.

The dryer exhaust filtration technology that was installed reduces particulate emissions from the exhaust stream from Dryers to below 20mg/m3 as required in the terms and conditions of the current IPPC Licence for the facility.

Odour Abatement Svstem

An odour abatement system was installed when the existing wastewater treatment plant was installed at the facility.

Foul air from the following are collected and treated to remove odour: 2 No. Balance Tanks Sludge Thickener

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Sludge Holding Tank 0 Sludge Dewatering Building

Odourous gas is extracted by pump, passed through filter media and the odourous components of the gas are removed. The existing odour abatement unit will be used for the new WWTP. As part of the WWTP Increase Capacity Expansion contract Veolia (the supplier) carried out a feasibility study on the existing odour abatement unit and found that with the new WWTP technology and loading the unit will remove >99% of odour. The raw influent balancing tank will be connected to the existing odour control system with the air flow from each balance tank balanced via dampers in the ductwork from each tank.

Odour control for the raw influent inlet works will also be provided. An auto bagging unit and collection bin will be provided that will collect and contain any screenings produced in an enclosed area thus eliminating any risk of foul odours.

Minor Emissions In addition, there are 12 minor emission points from the site that are not monitored. No specific abatement is in place for these minor emission points. Controls include the SOPS that are part of the Environmental Management System for the facility.

6.2 Noise Emissions

h

Noise attenuators were fitted to both dryers at the facility. The sound attenuation units are designed and built by GEA Niro NS, the specific model used is SOUNDCIP, Sanitary Sound Attenuator, Size 1000.

Each unit consists of a rectangular housing with process gas inlet at the bottom and outlet on the upper opposite side of the housing. The baffles and carriers are installed inside the housing. The baffles are made of a sound absorbing material wrapped and sealed in PFTE foil, which is welded. The baffles act to attenuate the noise from the source as it passes through the unit.

6.3 Emissions to Surface Water

There is a WWTP on site to treat the effluent before discharge of the final treated effluent to the Dromore River. This is being upgraded as part of Project ICE. The proposed changes to the WWTP are to the satisfaction of the Agency, subject to conditions, as confirmed by letter from the current licensing inspector (Ms Maeve O’Reilly) issued on the 2gth July 201 1 (Ref. 0687-01/akl5.mor.docx). An overview of the treatment plant is given below.

Raw Influent Inlet Works All the waste produced in the manufacturing facilities on site, both production and domestic wastes, combine in an existing collection manhole located beside the raw influent pumping station.

Raw Influent Pumping Facility All flows from the inlet works gravitate to the influent pump sump from where all flows are pumped to the wastewater treatment facility.

Raw Influent Balancinn Facility Raw influent will be pumped into buffer tanks. pH correction will take place. The incoming influent will be mixed and as a result any large peak variations in the

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influent pH will be balanced out. Continuous pH measurement will be provided and pH correction chemicals will be administered as necessary

The SBR feed pumps will be reused to transfer the influent from the influent buffer tank to the biological reactor.

WVVT Process Treatment Train:

The Process train is as follows:

Biological Treatment --+ Secondary Clarification -+ Actiflo --+ Hydrotech

Bioloqical Treatment Biological treatment of the influent will take place. As part of the upgrade, one of the existing SBR tanks will be converted into an anoxic biological reactor (reactor 1) and the other SBR tank will be converted into an aerobic reactor (reactor 2). The facility can operate in both anoxic or aerobic conditions.

Secondaw Clarification Following the biological treatment of the influent, secondary clarification is provided to separate the sludge produced in the biological treatment process from the continuation flow.

Actiflo This is tertiary treatment for the effluent. The Actiflo process is used to further reduce MRP (orthophosphate) and to precipitate the soluble phosphorous out of solution.

Hydrotech A Hydrotech tertiary filter is used to further remove the MRP and soluble phosphorous from solution. The clarified water from the Actiflo process is coagulated and flocculated prior to the Hydrotech tertiary filter.

Final Effluent Buffering & Sampling The final effluent from the Hydrotech Tertiary Filter will gravitate to the existing final effluent outlet manhole from where it will gravitate to the existing outfall. The existing final effluent monitoring and sampling equipment will be reused.

6.4 Surface Water Runoff & Similac Condensate

Similac Condensate Mitigation measures to protect against potential contamination arising from releases to surface waters are in place at the facility.

Historically, the condensate from the Similac manufacturing process was released into the Dromore River, mixed with the surface water runoff. In recent months, the condensate has been diverted to the W P , due to occurrences of TOC spikes recorded in the condensate stream (El).

TOC monitors will be put in place at the facility. The analyzer is a BioTector product, which is designed for on-line continuous monitoring. Until the TOC monitor is put in place, the condensate will be diverted to the WVVTP. A TOC monitor is also planned for the E2 stream from Evaporator 2. See Section 4.2 of this NTS for more details.

Accidental Spills or Leaks In relation to potential pollution from accidental discharges, there is a spill prevention and control procedure, which is part of the site’s environmental management system

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DieseVGas Oil

LPG

(EMS). This procedure aims to ensure that the number of spills occurring is minimised and that those that do occur are controlled to prevent contamination. There is also an SOP for environmental incidents.

2009 9,534,44 1 litres 201 0 10,389,825.1 litres

incl. ICE 11,918,051 litres 2009 1.4 tonnes 201 0 2.5 tonnes

incl. ICE 1.75 tonnes

Two oil/petrol interceptors on the storm water runoff drainage system from hard standing areas prevent oil contamination reaching the river. All delivery off loading areas used by vehicles transporting substantial quantities of potentially polluting material are designed to contain spillages. Milk, vegetable oil and syrup are delivered to a dedicated milkhegetable oil /syrup intake area. This area drains to a pipe that leads to the wastewater treatment plant.

Electricity

7.0 MATERIALS USE & ENERGY EFFICIENCY

2009 21,240,382 kWH 201 0 19.091,712 kWH

incl. ICE 26,550,478 kWH

Raw Materials Skim milk (liquid and powder), vegetable oil and syrup, water, sucrose and other dry ingredients are the main raw ingredients required on site. In addition, there are other raw ingredients required, and materials including oils, chemicals (processing and laboratory) and packaging materials and oils.

A full list of materials is included in the main application.

Products The product is milk formula, with two main types produced at the facility - Similac and Gain.

Storage & Transportation In terms of storage on site, Section 2.0 of this NTS outlines the storage of raw ingredients, materials, fuels and products on site.

In relation to transport systems on site there are a number of SOPS which are part of the EMS for the facility that outline how transport of ingredients and raw materials are transported onto and around the site. There is also a specific SOP for the transport of hazardous materials on site.

Energy Requirements

The energy consumption figures for 2009 and 2010 are shown below. Predicted fuellenergy consumption once ICE is fully in place and capacity at the facility has increased by 40%, is shown below. This will be an increase of approximately 25%.

I Source I Year I Quantitv I Units I

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Energy Efficiency Measures

Abbott is continuously trying to reduce energy use and increase the efficiency of the facility. An energy performance review was carried out by the facility and the report was produced in April 2010, with a number of proposals to reduce energy consumption further.

Abbott has in place an Energy Management System, which was certified to IS 393 in June 2009 and to IS EN 16001 - Energy Management Systems in May 2010. Energy metering is extensive throughout the site and area specific Electricity, Water, Steam, Oil and Compressed Air is monitored closely. The sites Energy Champion team consists of a representative from each area and meet monthly. Responsibilities include performing audits, suggesting reduction projects & assisting in their execution.

8.0

9.0

There is a Standard Operating Procedure (SOP) for Energy Monitoring on site, which is part of the certified EMS to IS014001 for the site. The energy reduction measures will continue to be implemented through the installation and operation of Project Ice.

There are also energy reduction objectives and targets, which are part of the EMS for the facility, for 201 1.

ACCIDENT & EMERGENCY PROCEDURES

The operators of the facility have existing accident and emergency procedures for events that may arise during operations at the facility. These will not change with the expansion.

There is an accident and emergency response plan in place for the facility. This plan was updated in March 2010. In addition there is an SOP in place for accidents or incidents that may occur on site, as part of the accredited IS014001 EMS. The full procedures are included with the main application.

AFTERCARE, DECOMMISSIONING & RESTORATION

Abbott Cootehill commit to providing required finances and sufficient resources to fully decommission the site in the event of closure, including to render safe, or remove for disposal/recovery, any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter container therein or thereon that may result in environmental pollution.

Abbott Cootehill will adhere to the EPA ‘Guidance on Environmental Liability Risk Assessment, Residuals Management Plans and Financial Provision’ 2006, in the event of closure or partial closure of site operations and will engage fully with the EPA on all aspects of decommissioning operations.

A Residual Management Plan to fully detail the arrangements and costs for site decommissioning or closure or part thereof can be prepared, where requested by the EPA.

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10.0 CONCLUSIONS

This non-technical summary includes a brief overview of the IPPC licence review application, detailing each of the sections contained within the application that are relevant and applicable to the Abbott facility.

The NTS has been updated following the Request for Additional Information issued by the Agency in June and July 201 1.

It should be noted that, in order to obtain a comprehensive and detailed description of the facility and the activities that will be carried out there, the full application should be viewed.

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Appendix E

Monaghan County Council EIS Confirmation Letter


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Acmhainni Daonna Human Resource

047 30586

Airgeadas Finance

047 30589

Na Bbithre Roads

047 30597

< ,la dToghthoiri Register of Electors

047 30547

Comhshaol Environment 047 30593

Deontais Ardoideachais Higher Education Grants

047 30550

Na hEalaiona Arts

047 71 114

lasachtai IDeontais Tithiochta Housing LoanslGrants

047 30527

County Library 047 51 143

Comhairle Contae Mhuineachain Monaghan County Council

Our ref: Abbott Ireland, Cootehill Date: 18* July 201 1

Ms Petrina Ashford Environmental Co-ordinator Nutrition Division Cootehill Cavan

Re: Environmental Impact Statement(s)

A Chara,

I refer to your correspondence dated 1 2'h July 20 1 1 in respect of the requirement for any Environmental Impact Statement(s) to accompany the approved planning permissions since 7th February 2005 at Abbott, Cootehill.

For your reference I can confirm that no Environmental Impact Statement(s) were required to be submitted as part of the planning permissions which have been granted at this site since 7'h February 2005.

I trust this correspondence will prove satisfactnry and answer any queries yev may have had in relation to this matter.

Yours sincerely

2-- Ronan Woods

Planning Officer Motarchain Motor Tax 047 81 175

Musaem an Chontae County Museum

047 82928

Pleanail Planning

047 30532

Pobal & Fiontar Community & Enterprise

047 30500

Rialu DbiteainlFoirgnimh FirelBuilding Control

047 30521

Seirbhisi Uisce Comhairle Contae Mhuineach6in, Oifigl an Chontae, An Gleann, Muineachbn. Eire

Water Services Monaghan County Council, Council Offices, The Glen, Monaghan, Ireland.

047 30504 363 47 3050 47 82739 @ infoOmonaghancoco ie www monaghan ie

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.*-

Appendix F

New flow meter Agency Communication


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Abbott Ireland Nutrition Division, t + 353 49 5559200

Cootehill, Cavan Ireland.

f + 353 49 5559201

Ms Maeve O'Reilly, Inspector. The Environmental Protection Agency, Off ice o f Environmental Enforcement , East/North East Region, McCumiskey House, Richview , Clonskeagh Road, Dublin 14. 07/03/2011

IPPC Register No. : PO687-01

Subject: Notification of River Flow Meter Installation Works

Dear Ms O'Reilly,

Please find a proposal for the installation of 2 new flow meters at Dromore River

attached. Also attached is the method statement of the planned works.

I hope you will find that the new equipment to be an improvement of the existing flow

measurement and all the paperwork is in order.

Yours Sincerely,

Petrina Ashford EH5 Coordinator petrina.ashf [email protected]


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Abbott Ireland Nutrition Division, t + 353 49 5559200 f + 353 49 5559201 Cootehill,

Cavan Ireland.

RIVER METER INSTALLATION WORKS REPORT

IPPC Register No. : Company Name:

PO687-01 Abbott Ireland, Cootehill, CO Cavan

BACK6ROUND Historically Abbott have been monitoring Dromore River flow by means o f river height measurement and indirect flow calculation. As stated in a letter sent to the €PA and Fisheries on the 15th of December 2011 Abbott commissioned A W N Consulting to undertake flow monitoring in the Dromore River in August/September 2010, in order to cross check against the flow data Abbott had been recording for a number of years.

On completion of this extensive exercise and the review o f all data we noticed that the OPW and A W N data were in reasonable agreement but that the Abbott data was tending to over predict river flows.

As a preventive measure Abbott are now planning to install new flow meters in the Dromore River. This will allow direct flow readings to be obtained on a continuous basis rather than relying on an indirectly calculated flow rate based on river height measurement.

OBJECTZVE DATE ZME AND OFTAILS OF THE WORKS The objective is to install, commission and verify operation of equipment needed to fulf iI continuous river flow requirements. The installation will include a Channel Master HADCP, Telemetry Data logger and associated equipment required for the recording o f velocity / flow data, this data will be available to view and download locally. Connections from the Channel Master flow meter will be made to a telemetry datalogger for the collection o f velocity and stage data. As part of the works the flow system with be fully commissioned and setup.

Capital Water Systems Ltd plan to begin installation of the flow meters on the 15th of March 2011. The installation o f flow meters will take approximately 2 days. Final commissioning will be on the 29th March when the commissioning certificate will be issued.

Abbott a A Promise for Life

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cHAN6E IN LOCATION OF RIVER FLOW MONlTO~N6 POINT There will be a minor change in location of the flow metering. The historical level transmitter is located at the augmentation pipe downstream of the abstraction point. The new flow meters will be located on both sides of the river. The meter on the Abbott side o f the river will be located between 1 to 2 meters upstream of the original level transmitter device and the meter on the far side of the river will be located diagonally at a position closer to the weir. Please find the method statement for the works attached which includes a photograph of the original level transmitter and the position of the new flow meter.

MAINTENANCE AND CALIMATTON The flow data will be continuously trended and any abnormalities will be identified. The weir and river are inspected daily therefore any visual problem will be identified without delay. Capital Waster Systems have been hired to calibrate the equipment once per annum.


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it^^ METHOD STATEMENT for ChannelMaster Installation. CONTRACT: Abbott Cootehill Method Statement Author: V Browne Method Statement Date: 3'd March 2011

WatE'F ~y~~~~~~ ttC1.

Emergency Contacts

Principal Contractor: Capital Water Systems Ltd Representative: Val Browne (087 8224404)

Instrument Installer: Representative: Val Browne (087 8224404)

Capital Water Systems Ltd

Client: Representative: Darryl Flint (049 5559261)

Petrina Ashford (049 5559261)

Obiective To install, commission and check operation of equipment needed to fulfil site flow requirements. The installation will include a ChannelMaster HADCP, Telemetry Datalogger and associated equipment required for the recording of velocity / flow data, this data will be available to view and download locally or from the HL Timeview Website. Connections from the ChannelMaster flowmeter will be made to a telemetry datalogger for the collection of velocity and stage data. As part of this project the flow system with be fully commissioned and setup. The installation will take place at the client's site which is owned and operated by said client. This method statement only covers Capital Water System's elements of work only. Effects on Client Operations There is likely to be minimal if any effect on client operations, Capital Water Systems will liaise closely with the client with regards to access and clearance to work. There may be a need to isolate certain equipment to enable safe access, this will be discussed locally and only conducted by authorized personnel. There will be no alteration or modifications to the clients existing systems, however it is expected that some of these systems may require isolating during installation. Programme Start date is the TBC. It is anticipated that the whole installation will take approximately 2 Days. If weather is good, working hours will be between 8.30am. to 4.00pm. Normal Capital Water Systems working hours 8.00am to 5.30pm Mon. to Fri. Permits to Work Authorisation to work on the sites will be required from the client. This will be obtained by Capital Water Systems prior to work commencing. Installations will not commence until all authorisations and permissions are in place. Access Access to the site is either via local roads or tracks. Weather conditions should be watched closely as tracks may become impassable very quickly should any snow or heavy rain fall.

Equipment and Tools and PPE Cordless drill; Mechanical saw (for cutting metal and wood); Hand tools. Normal PPE. (Safety Boots, Hi Vis Jackets)

Abbott Cootehill CM Install Method Statement Page 1 of 7

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c ~ ~ i f ~ ~ METHOD STATEMENT for ChannelMaster Installation. CONTRACT: Abbott Cootehill Method Statement Author: V Browne Method Statement Date: 3’d March 2011

water ~ ~ ~ t ~ f f i ~ itd..

Personnel Ix CWS Instrument Engineer; l x Other; CWS Lone Worker system in operation should it be required. Hazards Site Hazards. Working in location around an operational site and in close proximity to electricity and water. There is likely to be site personnel and possibly the public in the vicinity so additional care should be taken at all times. CWS loan working procedure to be employed whilst on site. Noise from equipment and plant. See Risk Assessment for further details. Environmental Concerns All unused equipment and packaging is to be removed from site following installation. Any existing / redundant eauiDment will also be removed. Emergency Procedures Explained to operatives when on site. Site held folder has copy of emergency procedures and location map and telephone number of local emergency or site services. 1’‘ aid kit carried in vehicle.

Safety All works to be carried out with regards to the Health & Safety at Work Act and Capital Water system’s Health and Safety Policy. Any site specific requirements should be understood before commencement. Statements of Competency All Capital Water Systems staff involved in these installations are competent to work to the ‘electricity at works regulations 1989’. Val Browne who is leading this project is an indentured and qualified Instrument Engineer with extensive experience in both the Chemical and Water industries. All isolations will be made as per the below method statement, with ‘re-energisations’ being made only after full off line checks are complete. It should be noted here that under no circumstances will any modifications be made to the sites current wiring.


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METHOD STATEMENT for ChannelMaster Installation. CONTRACT: Abbott Cootehill Method Statement Author: V Browne Method Statement Date: 3rd March 2011

viethod. rhis method statement is to cover all CWSL installations onlv.

1. Report to site and inform client as required.

2. Complete site induction.

3. Check Risk Assessment and Method Statement to confirm that they are still valid and that there have been no changes. Make any adjusts and report any concerns.

4. Find a suitable place to park, as close to the work area as possible, then transfer tools and materials to site. Whilst the transfer process is in motion the vehicle shall be secured and parked in a safe position. This should afford a safe environment for other site personnel in the vicinity.

5. When the transfer is complete, the vehicle will be locked and all operatives will be at the work area,

6. Gain access to the work area.

Fixing and connecting of ChannelMaster.

7. Locate position for fixing.

8. Gain safe access to water course. This may require a working platform or a boat, consult dedicated Risk Assessment for specific risks.

9. Drill and secure appropriate bracket to River bank using adequate fixings.

10. Fix ChannelMaster to bracket using only stainless steel fittings.

11. Power up ChannelMaster and connect to PC. Using WinHADCP setup correct orientation. Assure pitch and Roll are less than or equal to 1*.

12. Remove all equipment from water course.

13. Install ducting between mounting location and telemetry logger enclosure.

14. Run ChannelMaster cable through ducting.

Installation of Telemetry Enclosure.

15. Confirm mounting position for telemetry enclosure.

16. Fix enclosure in position assuring both that the unit is secure both for mounting and access.

17. Fit Hawk XT + any power isolation / transformation equipment required. If this power equipment is for connection to a mains supply assure that the power is isolated and do not

Page 3 of 7 Ahbott Cootehill C M Install Method Statement

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~ ~ p i t ~ l METHOD STATEMENT for ChannelMaster Installation. CONTRACT: Abbott Cootehill Method Statement Author: V Browne Method Statement Date: 3rd March 2011

water systen1s Itd

apply power until full testing is complete.

18. Connect SDil2 and power cables to Hawk logger

19. Setup logger and configure channels.

20. Check operation of each channel back to the datalogger.

21. Using Harvest software, trigger a dial out and confirm connection and data transfer.

22. Check all new and existing cables and confirm that there has been no modifications that could adversely effect site operation.

23. Prior to re-energisation assure cabinet / panel is closed and all tools and cabling is accounted for.

24. Close up cabinet and re-energise.

25. Check that the station is fully operational.

Setup of ChannelMaster.

26. Connect ChannelMaster Serial cable to Laptop and open WinHADCP.

27. Using an initial setup that exceeds the water course width obtain 10 transects.

28. Review transects and adjust bin size and number to enable unit to measure a clear portion of the water course.

29. Make notes of setup and leave unit to run for a few minutes to obtain a good initial data set.

30. Confirm that the SDi 12 data is being logged.

3 1. Disconnect Serial cable and box up.

32. Transfer all equipment, tools and rubbish to vehicle.

33. Make final site assessment, and take pictures for completion report.

34. Inform client that work is complete and depart site.

There is now a need to develop an Index Velocity Rating for the station. This is achieved by making numerous flow measurements and comparing mean velocity to the velocity measured by the ChannelMaster.

Abbot1 Cootehill CM Install Method Statement Page 4 of 7

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capital METHOD STATEMENT for ChannelMaster Installation. CONTRACT: Abbott Cootehill Method Statement Author: V Browne Method Statement Date: 3rd March 2011

\vater 5yderi3s Itd

Mounting Locafion

have understood the Method Statement and Risk Assessment explained by nd I will fully comply with its requirements Vame 1 Signature I Date


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capital METHOD STATEMENT for ChannelMaster Installation. CONTRACT: Abbott Cootehill Method Statement Author: V Browne Method Statement Date: 3rd March 2011

water iystems Ird

Method Statement Review:

Did things go as planned? Any Incidents or Near Misses:

If ‘Yes’, provide details:

Yes I No Yes I No

I Dateh):

Details to H.O. for distribution to all Managers

How could this have been prevented?

Signed : Name:

Date:


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~ ~ p i ~ ~ l METHOD STATEMENT for ChannelMaster Installation. CONTRACT: Abbott Cootehill Method Statement Author: V Browne Method Statement Date: 3'' March 2011

wafer iyder?ti

Notes.

Abbott Cootehill CM Install Method Statement Page I of I

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I Office of Environmental Enforcement Regional Inspeciorate, McCurniskey House. Richview. Cionskeagh Road, Dublin 14, Ireland.

Cigtreacht Reigiunach. Teach Mhtc Chumascaigh. Dea-Radhatc. 861har CIuain Sceach, Bade Atha Cliafh 14, Etre

7 +353 1 268 0100 F +353 1 268 0199 E: infoOepa.ie W:w.epa. ie

LoCall: 1890 33 55 99

Ms Petrina Ashford EHS Coordinator A bbo tt Ireland Nutrition Division Dromore West Cootehill County Cavan

15/03/2011 Our Ref: P0687-01/akl3mor.docx

Dear Ms Ashford,

I refer to your request for approval in relation to the installation of a new “ChannelMaster” flow meter in accordance with Condition 9.2.1 , dated 07/03/2011 and additional information submitted via email on 14/03/20] 1. I am to inform you that the proposal is to the agreement of the Agency subject to the following:

1.

2.

3.

4.

5.

6.

7.

River flow measurements shall continue to be recorded using the traditional method until the flow data has been validated to the satisfaction of the Agency. At least 12 direct flow measurements shall be taken to cover as wide a range of water level and flow conditions experienced at the site as possible, in order to develop a robust Index Velocity Rating for the ChannelMaster. Following this and not later than the 01/05/2012, the licensee shall submit an ongoing calibration proposal to the Agency for agreement. The licensee shall maintain a record of the occurrence of significant factors (e.g. sluice gate use, abstraction pump rate etc.) which may influence the recorded river flow/level, in order to minimise the number of anomalies. Maintenance and calibration requirements of the equipment as recommended by the manufacturer shall be added to the Abbott preventative maintenance schedule. Maintenance and calibration records shall be maintained for review by the authorised persons. The acoustic doppler pathway used by the flow meter equipment shall be maintained so as to prevent interference with the correct operation of the monitoring system. Data recorded by the ChannelMaster shall be backed up or saved for future use or review by the Agency. The agreed location of the flow meter may be subject to change, following review of the new system’s flow data.

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If you have any queries, please contact the undersigned on 0 1-2680 100. Please quote the above reference in future correspondence in relation to this matter.

Yours sincerely,

* 3r162vpc Maeve O'Reilly Inspector Office of Environmental Enforcement

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Documents

Abbott - Environmental Protection Agency · 2011. 8. 16. · Proposed trimer levels for TOC and Total Nitroqen for diversion to the waste water treatment pbJ Evaporator condensate