Attachment 1 Toxicity Test Report · energy audit 2007 are incorporated in the Schedule of Environmental Objective and targets 2006 – 2111. Condition 2.2.2.2 - PO393-02 & Condition

Attachment 1 Toxicity Test Report

CONFIDENTIAL REPORT SHANNON AQUATIC TOXICITY LABORATORY Front Cover Report Sheet Dept. Toxicity Sheet no. 1 of 3 sheets Tox F020 Ver. 2.2 Customer Title Kerry Ingredients Toxicological analysis of an Listowel effluent sample Co. Kerry Attn: Mr. Sean Pender Report reference: 08T071 Order no.: 68276C Report by: Robert Hernan Date received: 17.06.08 Approved by: Jim Clancy Head of Department Copies to: R.6. Files Date of issue: 24.06.08 Standard Terms & Conditions for Testing and Consultancy Assignments

1. Reports issued by the Shannon Aquatic Toxicity Laboratory of Enterprise Ireland are copyright to Enterprise Ireland and shall not be used, either in whole or in part, for the purpose of advertising, publicity or litigation without the written consent of the Chief Executive or his nominee.

2. Reports shall only be reproduced in full. 3. Non-perishable samples received for testing or laboratory work

shall be disposed of after three months from date of final report unless claimed or unless instructions to the contrary have been notified to Shannon Aquatic Toxicity Laboratory, Enterprise Ireland by the client within the said three month period.

4. Payment for work carried out shall be in accordance with the

terms stated on Enterprise Ireland’s invoices

5. No action or legal proceeding shall be taken (except in the case of wilful neglect or default) against Enterprise Ireland or the Board or any member of the Board or any committee appointed by the Board or any officer or servant of Enterprise Ireland by reason of or arising out of the carrying out of research, investigation, test or analysis or the publication of

the results thereof in the name of Enterprise Ireland. 6. Enterprise Ireland will not release any information received from or provided to the client in relation to this report except as may be required by law, including the Freedom of Information Act 1997, or as specified by the client. 7. This contract is governed by the laws of Ireland whose courts

shall have exclusive jurisdiction.

Test report relates only to the sample(s) tested

TOXICOLOGICAL ANALYSIS REPORT Form No.: ToxF035-1 Ver 2.2

TEST RESULTS Customer: Kerry Ingredients Customer sample description: Final effluent, composite, 16.06.08 Tox. Ref. No.: 08T071 Test Date: 17.06.08 – Daphnia magna 18.06.08 – Vibrio fischeri

Test Results Test Parameter Concentration

% vol./vol. Toxic Units 95%

Confidence Limits

% vol./vol.

Method of Calculation

48 h EC50 to Daphnia magna

>100 <1 n/a n/a

5 min EC50 to Vibrio fischeri

>45 <2.2 n/a n/a

15 min EC50 to Vibrio fischeri

>45 <2.2 n/a n/a

Comments: 48 h EC50 to Daphnia magna None of the Daphnia were immobilized at 100% vol./vol. 5,15 min EC50 to Vibrio fischeri Less than 5% light inhibition occurred at 45% vol./vol. compared to the control. Test Method(s): (see Appendix on back of page 3) Method 1: Daphnia magna Method 2: Vibrio fischeri

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TOXICOLOGICAL ANALYSIS REPORT Form No.: ToxF035-2 Ver 2.2

SAMPLE INFORMATION

SATL Customer Other Sampled by: Collected by:

Tox Ref. No.

08T071

Sampling procedure n/a

Date of analysis

17.06.08

Storage conditions (°C)

3±3

Temperature (°C)

18.6

pH (at 18.8°C) 8.1

Dissolved oxygen (mg/l)

8.6

Dissolved oxygen (% saturation)

93.1

Conductivity (mS/cm at 25°C)

3.97

Salinity (ppt at 20°C)

2.0

Note: Sample container not chemically inert

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Attachment 2 Environmental Management Programme

Issue 37 December 4th 2007 Kerry Ingredients: EMP – Objectives & Targets 2006 - 2011

OBJECTIVE ACTION DUE DATE RESP. STATUS

1) Maintain ISO 14001 Certification

Correct Corrective Actions & Observations raised during SGS audit Dec 4th 2006.

Qtr 1 2007

All

Completed

2) Achieve reduction in load to Effluent Plant in line with Production Output

Condition 2.2.2.2 PO393-02 Condition 2.2.2.2 PO393-02 Condition 2.2.2.2 PO393-02

I. Review manufacturing processes with a view to identifying load reduction to WWTP

II. WDM: New technology is under evaluation, which has the

potential to reduce water, acid & caustic consumption substantially.

III. Reduce chloride and sulphates in effluent discharge. IV. Evaluate diverting uncontaminated cooling water and surface/

storm water from the WWTP over a 5 year period (Sept 9th 2111).

V. Reduce particulates from site as a whole

Qtr 3 2006

Qtr 3 2007 Qtr 1- 4 2007 Qtr 1 2008 Qtr 1- 4 2007

All

T.N.

All

Eng Dept

All

The load for 2005 was significantly less, at 19.61% for COD and 10.62% for volume. Year to date COD load has increased by 17.3% mainly due to increased load from WDM. Plant installed and commissioned. Usage reduced by 5619m3 or 0.3% over 2006, which is less than the target of 5% for the site. Mass kg of Sulphate emitted was only 7.5% of the permitted load The chloride load discharged is in conformity with the new IPPC ELV’s Draft a plan for phase 1 and submit to Agency for approval by March 31st 2008 Completed - Emissions for the site are only 9% of the permitted load and are 26.66% lower than 2005 levels.

3) Condition 7.3 PO393-02 Achieve reduction in water consumption in line with Production Output.

I. Proposals from all departments for a 5% reduction in water usage in 2007 in each dept.

II. Each dept to submit proposals to reduce water consumption

at next O & T meeting in Jan 200 III. Identify water reduction projects in these areas: WDM uses

the most water and the new plant has reduced consumption by 5% YTD. (Local WDM meters show a larger reduction and this needs to be checked as the overall total for the site is only 0.3% less than 2006)

On-going

Qtr 1 2008

Qtr 1 2008

All

All

TN & J McA

The overall reduction for 2007 was 0.30%, which is well below the target of 5% All areas are now being metered. The reduction targets for 2006 were not achieved – 0.37% for the site while the reduction for 2007 was 0.3% WDM is 5% less ytd on 2006 due to the new plant.


OBJECTIVE ACTION DUE DATE RESP. STATUS

4) Reduce Emissions of SO2,

NO2 and particulates to IPPC Licence Limits

1. Continue to operate and maintain all bag – filters so that all particulate limits are met.

On-going

DC

Completed - Sox, & NOx emissions are < 12.5 of the permitted load and were 9.5% less in 2006 than 2005, showing a continual improvement.

5) Reduce odour nuisance from the plant

I. Two odour complaints have been received year to date and

on investigation were sourced to farmers spreading slurry. II. One noise complaint was due to a sonic horn in a dryer. III. One complaint was due to smoke from an overheated v-belt

in the WWTP. �� One noise complaint due to steam valve lifting at cheese

dept. Silencer to be fitted this valve to reduce impact of recurrence.�

Services & Powder Depts

Qtr 4 2007

SP S.McE, JM C.O’S

DC

On-going

In Progress

6) Condition 7.4 PO393-02: Reduce Waste to Landfill Site on an annual basis in line with Production Output.

I. All departments are to monitor their waste cardboard and waste plastic to maximise the quantity for recycling.

II. Investigate replacing cardboard boxes with re-usable plastic

“jumbo boxes” for tubs & lids.

Qtr 1- 4 2007

Qtr 1- 4 2007

Dept. Mgrs

Dept. Mgrs

Landfill for 2006 up by 91 tns on 2005 (10%) Production depts to check skips for packaging materials. 971 tonnes 2007 (3.4% Red) Investigation Stage

7) Reduce disposal of sludge by land-spreading.

I. Identify projects to reduce the amount of sludge for land-spreading.

Qtr 2 2006

SP

The sludge tonnage is now 20% less than the 2000 baseline figure of 26,025 tonnes. The tonnage increase in 2007 to 22,721 is due to the new WDM plant.

8) Reduce the Amount Whey for Disposal as animal feed.

I. This is being achieved. Tonnage for 2006 was 8% less than 2005.

II. Meter and sample the whey to establish the tonnes of dry

whey solids/month going to storage.

Qtr 4 2006

Completed

TN, JMcA

SP

Tonnes 2005 : 3916 Tonnes 2006 : 3610 (7.8% red) Tonnes 2007 : 3143 (13% Red) The whey tonnage is now 86% less than the 2003 figure of 19,352 tonnes

�

�) Maintain Noise Levels

I. Install noise corrective measures where required.

Qtr 1-4 2007

Eng dept

New silencers installed in the Casein fans in Oct 2006. Annual noise survey


OBJECTIVE ACTION DUE DATE RESP. STATUS within IPPC Licencing Guidelines. Condition 6.13, Schedule B4

II. Noise survey 2007

Qtr 3 2007

PB

conducted on Oct 13th & 14th 2006 and in Aug & Oct 2007 were compliant with IPPC Licence limits. All measurements were within the EPA limits in 2006 & 2007. Completed: Oct 13th2006 & Aug + Oct 2007.

10.0 Condition 7.2 PO393-02: Reduce Usage of Energy in line with Production Output.

Site Energy efficiency to be audited by Sept 9th 2007. (Completed August 2007) Recommendations are incorporated in the Schedule of Environmental Objective and targets 2006 – 2111. Condition 2.2.2.2 PO393-02 & Condition 7.2 PO393-02

Investigate energy saving proposal using biogas to heat Digester Investigate recovery of Superheat from the chilled water compressors Investigate heat recovery from the casein dryers. External lighting: Areas such as the loading bay, and rear of cold

stores should be fitted with motion sensors to reduce energy, while other areas like the SFB and perimeter lights should have their photocells checked.

Investigate the feasibility of isolating sections of the air distribution

system in order to conduct leak audits and reduce energy by isolating when plants are off. Also check the cost of metering compressed air to the main users.

Cold Stores: Reduce thermal losses from lighting by installing

lighting controls. Cold Stores: Install rapid roll doors to reduce heat loss via

doorways. Blast Freezeers: Re-locate power switch externally and switch off

Blast Freezers and Ammonia pumps when room is empty. Crystallization Tanks Project: Quantify payback in reduced energy costs by using a cooling tower for the 1st stage of

cooling instead of chilled water.

Motive Power: Quantify the payback in energy savings of replacing large electric motors with Class 1 units. 280 KW

Qtr 1 2006

Qtr 4 2006

Qtr 4 2006

Qtr 1 2006

Qtr 2 2006

Qtr 2 2008

Qtr 2 2008

Qtr 2 2008

Qtr 2 2006

SP MB DC

MB

MB

Maint Mgrs

MF

Jn.O’C

Jn. O’C

Jn.O’C

TN/D.Culloty

Completed.

Completed Project postponed to 2008

Completed – not feasible

Completed.

Completed.

Meters installed

In Progress

In Progress

In Progress

Completed ( 5,000 tns CO2 saving)


OBJECTIVE ACTION DUE DATE RESP. STATUS 10.0 Contd. Reduce Usage of Energy in line with Production Output. Recommendations of site energy audit 2007 are incorporated in the Schedule of Environmental Objective and targets 2006 – 2111. Condition 2.2.2.2 - PO393-02 & Condition 7.2 - PO393-02

motor of ID fan at SFB put on VSD. Holvrieka No. 4 Project: Modify evaporator in order to

reduce steam & water during CIP XII Do a thermographic survey of cold stores to identify energy losses.

XIII Draft a report and submit to the Agency outlining the areas audited and a schedule for completing a full energy audit of the site within the next 12 months.

Qtr 1 2006

Qtr 1 2008

Sept 7th 2007

Qtr 1 2008 �

DC /MF TN/D.Culloty

Jn O’C

DC & MF

Completed

Installation in Progress

Energy audit of cold store completed in accordance with Condition 7.2 of

IPPC licence.

In Progress

11) Protection of underground resources (surface waters and groundwater)

MW No. 4

Condition 3.6 PO393-02 Condition 3.6 PO393-02

11.

Drains Remediation Programme Phase 1 – 4 Completed

Phase 4 – Report completed (Repairs to storm-water)

Phase 5 – repairs to storm water lines - 2007 MW No. 4 & MW 5 have elevated levels of ammonia and faecal coliforms. All the monitoring well are to be sampled on a monthly basis from Nov 2007, until further notice and report results to the Agency on a monthly basis Site Bunding Proposal Heavy Fuel Oil / Light Fuel Oil & Effluent Chemical Bund. Acid Tanks

Six tanks for primary storage- bunded. Bund Test.

Qtr 2-4 2006 Qtr 1-4 2007 Qtr 2 2007 Qtr 2 2007 Qtr 4 2007 Qtr 1 2007

SP

SP

SP

Eng Dept

SP Jn O’C

Eng Dept

Completed

S7 – S 14 Completed

3 Reports submitted to Sept 20th 2007

Effluent Chemical bund test completed.

Oil bund test scheduled for Jan 2008

Completed


OBJECTIVE ACTION DUE DATE RESP. STATUS Protection of underground resources (surface waters and groundwater)

Condition 3.6 PO393-02

I. Local Chemical Storage

Review the storage of chemicals on site, which are remotely bunded to the WWTP plant.

SP JnO’C

Completed – The Line from the chemical storage compound to the

WWTP has been re-lined and integrity tested.

The final report was submitted to the

Agency on Aug 14th 2007.

12.) Concrete Pavement Remedial Works

The copy of the report by MRG in relation to the pavement condition survey and remedial works specification was issued on Aug 2nd 2005.Proposed Action Plan on remedial work was forwarded to the EPA for approval. Yards & Roadways Remedial Programme: Phase 1- Areas requiring immediate repairs denoted Blue & thus /////// Phase 2- Joints in Roadways denoted in Purple on Dwg 10515-001 Phase 3 – Areas in Dwg No. 10515-001 denoted in Dark Brown Phase 4 – Areas in Dwg No. 10515-001 denoted Green Phase 5 – Areas in Dwg No. 10515-001 denoted in Light Brown

Qtr 1- 4 2006 Qtr 1- 4 2007 Qtr 1- 4 2008 Qtr 1- 4 2009 Qtr 1- 4 2010

Eng Dept

PB & Jn.O’C

Jn O’C

Plan submitted to EPA for approval in Jan 2006 and 1st phase completed in Oct 2006 Phase 1 Commenced in March 2006 Phase 1 Completed Oct 2006 Phase 2 – Renewal areas completed in Feb 2007. Joints to be completed by Feb 2008.

�

�

�

�


�

Attachment 3 River Feale Biological & Water Quality Monitoring Report

RIVER FEALE BIOLOGICAL & WATER QUALITY MONITORING

FOR KERRY INGREDIENT’S IPC LICENSE

(August 2008)

Commissioned by: Kerry Ingredients, Listowel. Carried out by: Aquatic Services Unit, UCC. (October 2008)

2

Introduction & Brief The Aquatic Services Unit UCC were requested by Mr. Sean Pender of Kerry Ingredients plc. (Listowel) to carry out a biological and chemical survey of the River Feale upstream and downstream of the discharge from the final treated effluent discharge from the Kerry Ingredients treatment plant. The survey was carried out during August 28th and 29th 2008. The water levels were unseasonably high at the time and made sampling difficult. This has been the case for the last 3 years. In the past the River Feale suffered from severe 24hour fluctuations in dissolved oxygen as a result of excessive filamentous algal growth brought about by elevated nutrient levels in the river stretch between Listowel Town and Finuge Bridge. This is why the oxygen levels in the river are measured at several times during the day, including the early morning to detect any significant drop in oxygen levels, which would be in evidence at that time of day. During the current water quality monitoring exercise however, because the river was much higher than in a typical August, the algal growths normally present had either not developed or had been washed away. In this situation one would expect that the diurnal variations in pH and dissolved oxygen would be far less than normal. In addition, the August water levels provided very good dilution of the effluent being discharged at the time. Finally, macroinvertebrates were collected in order to evaluate the medium-term condition of the water quality in the river as macroinvertebrate integrate water quality effects over several months or more. Conditions at the time of the survey were generally cool, dull to bright with water levels above those, which would normally be expected in August. Three sampling sites were chosen for monitoring: Site 1 at 70m upstream of the effluent discharge, Site 2 (at a new location) about 1400m downstream of the discharge after it is substantially mixed and Site 3 at Scartlea Weir a further 2km further downstream, where in the past the worst oxygen depletion had been noted in the past. A further site (Site 3a) was chosen a few hundred metres downstream of Scartlea Weir for a kick-sample, as the substrate is not suitable for macroinvertebrate sampling in the immediate vicinity of the weir. Note that the Site 2 sampling point is several hundred metres further downstream than previously because there was a suspicion that the effluent had not fully mixed by the time they reached the previous location for Site 2. The new location was just downstream from a point in the river that Irish Hydrodata has shown from a modelling exercise was the point of full mixing of the effluent. At each sampling site, water samples and macroinvertebrate samples were taken although at Site 3 only water samples and at Site 3a only macroinvertebrate samples were taken for the reasons already outlined. See map in Figure 1 for sampling site locations. See also Plates in Appendix 1.

Methods Water Analysis Dissolved oxygen, pH and temperature were measured on site. One-litre samples were collected on site and stored in insulated box on ice during transport to the ASU lab, where analysis began the following morning after over-night storage at 4°C. Analysis was carried out using standard methods or modifications of same as outlined in Table 1.

5

Table 1 River Feale water quality monitoring parameter list & test methods Parameters Laboratory Test Methods Ammonical Nitrogen ASU Automated Lachat Quik-Chem 8000 series

Method BOD ASU WTW OXI 320 DO Meter with BOD bottle

adapters. Samples incubated at 20 °C for 5 days. Dilution if required as per Standard Method (APHA 1989( Method 5210-B)

Suspended Solids ASU Gravimetric using Whatman GF/C filters and drying at 103-105 °C as per Standard Methods (APHA 1989) Method 2540-B

Dissolved Oxygen ASU WTW OXI 320 DO Meter (on site analysis) Chloride ASU Automated ferricyanide method (TecatorFIA

Method AN 63/83) (see Standard Methods (APHA 1989) Method 4500-Cl-E for reagents

Colour ASU Spectrophotometric using Platinum-Cobalt colour standard solutions for standards

Electrical Conductivity ASU WTW LF330 Conductivity/Salinity Meter calibrated with standardised KCl after Standard Methods (APHA 1989) Method 2510-B

pH ASU WTW pH meter 320 following 2-point calibration on fresh pH 4 & 7 buffer solutions

Temperature ASU WTW Thermistor (as on WTW OXI 320 DO Meter) on site analysis

Ortho Phosphate ASU Automated Lachat Quik-Chem 8000 series Method based on Murphy & Reily Method (Molybdate – Ascorbic Acid)

Sulphate ASU Automated Lachat Quik-Chem 8000 series IC

Total Phosphorus ASU As for orthophosphate following digestion of the unfiltered sample with persulphate and sulphuric acid (autoclave)

Total Oxidised Nitrogen ASU Automated FIA with copper-amalgamated cadmium column for reduction to nitrite followed by colorimetric detection using pink-azo dye (sulphanilimide/NED-dichloride method) see Standard Methods (APHA 1989) Method 4500-NO2-B

6

Macroinvertebrate Sampling & Analysis Replicate Surber sample collections were made in areas of moderate to swift turbulent flow in coarse substrate. Due to the high water condition experienced during sampling, Surber sampler could only be used at Site 1, at the other two sites, kick-samples were taken instead. Samples were preserved on site in a mixture of formalin and alcohol and returned to the lab for full sorting, enumeration and identification using the appropriate keys from the Freshwater Biological Association of the UK. The macroinvertebrate data arising was assessed using a the same biotic index system used by the Environmental Protection Agency (EPA) in their on-going monitoring of biological quality in Irish rivers. The index assigns a score to the macroinvertebrate collection at a given site depending on the relative proportion of pollution sensitive and pollution tolerant organisms present. The greater the number and diversity of pollution sensitive types present (particularly, certain mayflies, stoneflies and cased caddis flies) the higher the score or quality class assigned to a given site. The highest score category is Q5 which indicates pristine water quality conditions and is recognised by having a high proportion of pollution sensitive species and very few or any pollution tolerant forms, whereas Q1 at the other end of the scale indicates gross pollution. The table below indicates the Q-value scores, which can be assigned and the corresponding degree of pollution associated with them. Q-Value Degree of Pollution Q5, Q4-5, Q4 Unpolluted Q3-4 Slightly Polluted Q3, Q2-3 Moderately Polluted Q2, Q 1-2, Q1 Serious to Gross Pollution A system used in the UK called the Biological Monitoring Working Party score (BMWP) was also calculated for the samples taken in the Feale. This is calculated by attributing a numerical score (1-10) to each family of macroinvertebrate present in the kick-sample depending on their degree of pollution tolerance. Families, which are pollution sensitive such as flat mayfly nymphs of the family Heptageniidae, are assigned a score of 10, while Tubificid worms receive a score of 1. The scores of each family present in the collection are then summed to give the total score for the site. A variant of this index called the Average Score Per Taxon (ASPT) is calculated by dividing the BMWP Score by the number of families used to calculate. This is considered a more robust method than the former because the number of families present doesn’t affect it. These latter two indices were calculated as supporting evidence for the main index (EPA Q-value) and because they are less influenced by inter-operator variation. The UK BMWP and ASPT scores are as follows: BMWP ASPT Rating Water Quality 151+ 6.0+ 7 Excellent quality 121-150 5.5-5.9 6 Excellent quality 91-120 5.1-5.4 5 Excellent quality 61-90 4.6-5.0 4 Good quality 31-60 3.6-4.5 3 Moderate quality 15-30 2.6-3.5 2 Poor quality 0-14 0.2.5 1 Very poor quality It is important to point out that the UK scores are not automatically transferable to the Irish context, however they employ most of the same organisms and tend to give reasonably similar results in general.

7

Results Water Chemistry – 24hour Dissolved Oxygen Variation Table 2 presents the results of the 24-hour dissolved survey. Ideally, to get a full impression of the 24hour variation one should sample every few hours throughout the day or use an automatic DO, pH, and temperature probe. Several previous such surveys undertaken by the author at the same river sites has indicated that the lowest dissolved oxygen, pH and temperatures are usually measured between 06:00 and 07:00 in the morning, whereas the highest tend to be recorded at between 16:30 and 18:30 in the afternoon. Thus a 2-point measurement at these times of the day will normally give a very good indication of the daily range on any given day. The results for the current survey are presented in Table 2 and they indicate the lowest inter-site difference and within site difference in 24hr dissolved oxygen variation yet recorded in this monitoring series i.e. <7% saturation and less than 0.8mg/l, O2. This compares with 12% saturation at Scartlea Weir (Site 3) in 2007, 25% at the same site in 2006 and 83.6% in 2003. The water levels for the last three years, 2008, 2007 and 2006 sample runs have been quite high compared to 2003, when the water levels were at or below 95%ile levels (~1.4m3/s). Thus the higher flows of the three most recent monitoring runs would be expected to overcome most if not all the plant respiration induced drop in DO in the river. The higher water levels transport more oxygen and therefore dilute the respiration of plants and the attendant turbulence facilitates atmospheric re-aeration. Furthermore, high water flows both in August and throughout most of the summer in 2008 have undoubtedly contributed to the near 100% dissolved oxygen recorded this year. Firstly by inhibiting a build-up of algal growth, (ii) by reducing the amounts of sediment on the bed of the river, which would be giving, rise to bed respiration and (iii) by increasing the re-aeration capacity of the river. The lowest absolute levels of dissolved oxygen recorded in the 2008 survey, i.e. 9.47 mg/l,O2 (at Site 3) is ideal for all freshwater aquatic life. During the 2008 sampling run, the pH range (0.05-0.07) is the lowest recorded in recent years and is probably explainable for the same reasons as the low variation in dissolved oxygen. In contrast, the 2003 figures which correspond to samples taken in much lower flows and higher diurnal ranges in dissolved oxygen were considerably higher (on average 1.64 units) than the four most recent surveys. Table 2 Dissolved oxygen, pH and temperature at three River Feale sampling sites at

three times over 24hrs (28th – 29th of August 2008) Date Site Time Temp

(°C) pH Dissolved

Oxygen (mg/l, O2)

Dissolved Oxygen (% sat.)

(S1) u/s 17:35 16.3 7.22 10.15 102.6 (S2) d/s 17:06 16.5 7.22 10.12 102.6

28/08/08

(S3) Scartlea weir

16:16 16.6 7.17 102.6 101.2

(S1) u/s 07:20 15.9 7.21 9.57 96.4 (S2) d/s 06:57 16.0 7.18 9.49 95.7

29/08/08

(S3) Scartlea weir

06:35 16.0 7.15 9.47 95.5

(S1) u/s 12:44 - 7.26 9.70 98.8 (S2) d/s 11:48 16.8 7.24 9.95 101.9

29/08/08

(S3) Scartlea weir

11:16 16.5 7.22 9.89 100.7

Water Chemistry – General Water Quality Parameters

8

There was virtually no difference in the water chemistry between Site F1 upstream of the factory discharge and the two sites downstream (F2 and F3). This was to be expected as the high flows at the time provided large dilution for the Kerry Ingredient effluent. Only conductivity and chloride showed any significant difference in concentration, with slightly higher concentrations at Site 3, after full mixing. In general the quality of the factory’s effluent was very high at the time of sampling. Table 3 Water quality physico / chemical analysis results at three River Feale sampling

sites and of effluent from end of Kerry Ingredients outfall pipe (29/08/08) Sample Units

F1 Effluent

F2 F3

Time 12:44 12:33 11:48 11:16 Temp °C - 24.6 16.8 16.5 pH 7.26 7.41 7.24 7.22 D.O. (mg/l, O2) 9.7 - 9.95 9.89 *D.O. % sat. 98.8 - 101.9 100.7 Conductivity µs/cm @25°C 132 3500 155.4 172 Colour Hazen 152 33 152 150 Chloride mg/l, Cl 18.35 770.38 22.95 26.05 Sulphate mg/l, SO4 5.29 45.21 5.43 5.64 SS mg/l 3.0 6.3 3.3 3.0 BOD mg/l, O2 1.2 2.7 1.0 1.0 Ammonia mg/l, N 0.031 0.030 0.027 0.026 TON mg/l, N 0.797 7.424 0.836 0.891 Ortho-P mg/l, P 0.018 0.296 0.019 0.020 Total-P mg/l, P 0.058 0.772 0.061 0.063 Macroinvertebrates Appendix 1 presents a detailed description of the habitat and substrate types both in-stream and along the banks at the three macroinvertebrate sampling sites. Table 4 presents the different types of macroinvertebrate collected in kick-samples and Table 5 lists the values of three biotic indices derived from the data. The data show that all three sampling sites had a varied and relatively diverse macroinvertebrate community with a mixture of pollution sensitive and pollution tolerant forms and that there was very little to choose between the sites in terms of water quality again in 2008. The species composition was very similar to that encountered in 2007 and the same degrees of dominance among the groups was also generally in evidence. All three sites were classified as unpolluted (Q4), although Site 2 was considered to be veering toward slightly polluted conditions (Q3-4) due to the slightly higher representation of Baetis and Simuliidae suggesting marginally more enriched conditions. A comparison of the ASTP (Average Score per Taxon) results between this year and those of both 2007 and 2006 (Figure 2), suggests that 2008 was marginally better than the previous two years.. Impacts of Chloride and Sulphate Discharges There was no evidence from the biological data that chloride or sulphate discharged from the factory was adversely impacting the river. For example Fontinalis moss, mayflies, stoneflies,

9

and freshwater crustaceans were all equally abundant upstream as downstream, or at least, not noticeably different. Furthermore sulphur bacterial flocs were not in evidence downstream of the discharge, although, the heavy flows would be expected to have washed any away at the time of sampling had any been present. However, there is little likelihood that such bacterial scums would have existed anyway given the good state of the other indicators listed and the current low level of sulphate in the factory’s effluent. Overall Conclusion For the fourth year in a row, the main feature of the sampling run was the fact that the river had risen considerably by the time samples were taken and this had a significant influence on the water chemistry and may also have influenced the macroinvertebrate sampling results. Furthermore, the conditions prevailing at the time of the survey confirms the river’s continuing suitability as a channel for salmonid fish feeding and holding as well as for inward and outward migration of salmonid fish.

10

Table 4 Macroinvertebrate results from 2 replicate (a & b) Surber samples at 3 sampling sites on the River Feale (28/08/2008)

EPA

Quality Class

BMWP Score

Site 1 u/s Effluent

Site 2 d/s Mixing Zone

Site 3 d/s Scartlea Weir

A B A B A B

MAY FLIES (Ephemeroptera)

Baetis sp. C 4 26 58 90 100+ 28 45

Ephemerella sp. B 10 2 2 1 1 Heptageniidae: A 10 * * * * * *

Ecdyonurus sp. 1 Heptagenia sp. 10 3 1 10 5 3

Caenis sp. C 7 1 STONE FLIES (Plecoptera) Leuctra sp. B 10 5 1 4 2 4 3 Protonemoura sp. B 7 1 1 CADDIS FLIES (Trichoptera) Rhyacophila sp. C 7 1 4 3 4 1 Hydropsyche sp. C 5 3 3 2 7 8 3 Polycentropus sp. C 7 1 1 Glossosoma sp. C ~ 1 1 2 1 Athripsodes sp. B 10 1 2 4 Goera pilosa B 10 1 Psychomyia pusilla C 8 1 Philopotamus montanus C 8 1 TRUE FLIES (Diptera) Chironomidae D 2 14 12 35 3 12 20

Simuliidae C 5 45 40 100+

100+ 60 55

BEETLES (Coleoptera) Hydraena gracilis C 5 1 2 Elmidae C 5 * * * * * * Adults 1 1 2 25 21 Liminius volckmari 1 3 3 2 3 Esolus parallelepidus 3 2 6 2 2 3 Oulimnius sp. 3 6 3 9 11 F/W SHRIMPS (Crustacea) Gammarus sp. C 6 1 2 SNAILS (Mollusca) Ancylus fluviatilis C 6 2 9 13 Potamopyrgus sp. D 3 7 30 8 Lymnaea peregra D 3 1 LEECHES (Hirudinea) Glossophonia complanata D 3 1 1 2 Trocheta sp. D 3 3 1 WORMS (Annelida) Oligochaetae E 1 1 5 1 2

11

Table 5 Macroinvertebrate biotic indices results averaged from the two replicate samples from each of the three sampling sites on the River Feale (28/08/2008)

Biotic Indices Site 1 u/s Effluent

Site 2 d/s Mixing Zone

Site 3a d/s Scartlea Weir

EPA Q Value Q4 Q4 (Q3-4) Q4 Total BMWP Score 60 81.5 100 ASPT 5.7 5.7 6.2

0

1

2

3

4

5

6

7

Site 1 Site 2 Site 3

Site

Mea

n A

SP

T .

2001

2002

2003

2004

2005

2006

2007

2008

Figure 2 Average Score Per Taxon (ASTP) values for each sites sample replicate

for the 2001 to 2008 surveys.

12

Appendix 1 Macroinvertebrate Sampling Site Descriptions & Site Plates As in 2006 the elevated flows in the Feale and attendant increase in colour made it difficult to view the riverbed macrophytes with ease. The elevated flows probably also reduced the amounts of Cladophora present in the channel. It was this fact, which prompted a shift to an August sampling in 2007. However, that year there was an unseasonably wet August so nothing was gained by the strategy and the exact same pattern manifested itself in 2008, the only difference being that rainfall was more persistent throughout the course of the summer in 2008. Site 1 Feale u/s Discharge The river at this point is 70m upstream of the company’s main effluent discharge where the river is more than 10m wide (Plate 1). The substrate, where Surber samples were taken consisted of plant-free cobbles, pebble, fine gravel and coarse sand in very swift turbulent flows of about 35cm depth. Both samples were taken just out from the right bank, as the water was too deep elsewhere to take a sample safetly. It was difficult to get an overview of the macrophyte cover at this site due to the water depth, turbidity and turbulence, although the substrate at the sampling area was free of filamentous algae and mosses. On the left hand side of the channel (looking downstream) Fontinalis moss was common over and locally abundant boulders in the marginal shallows, where scattered clumps of long trailing Ranunculus were also present. The 1RHS bank had Willow species, with an understorey of Reed Canary-grass (Phalaris), and scattered plants of hemlock Water-dropwort (Oenanthe crocata). The LHS bank had Sycamore, Willow, Bramble, Phalaris, and Himalayan Balsam. Site 2 Feale d/s Mixing Zone In 2008 this site was moved further downstream than it had been previously because there was a concern that the effluent from KI had not fully mixed at the previous site location. The substrate at the new site comprised plant-free cobbles and pebbles in a moderate to swift turbulent flow (Plate 2). The water was about 22cm deep and coloured. On the right side of the river there was a vegetated cobble bar, which was covered in Reed Canary-grass (Phalaris), along with localised clumps of Spiked rush (Eleocharis sp.) and Water Pepper (Persicaria hydropiper). The HS bank is formed by a high drainage embankment covered in grasses, Willow, bramble and nettle, while the LHS bank is steep and with Willow and Alder above and Phalaris, Himalayan balsam, nettle and grass below. Site 3a Feale d/s Scartlea Weir At this point in the river two rock-filled gabion weirs, which form blunt upstream facing chevrons, are constructed across the channel with a gap toward the centre. In 2008 both were downed out again (Plate 4). Kick-samples were taken in very swift laminar flows of about 30cm depth. The actual sample was taken in the substrate of the gabions of the downstream weir, in angular pebbles, gravel and coarse sand. The depth and poor visibility meant that only Fontinalis moss was visible (it was common) apart from the odd clump of Ranunculus. The RHS bank was grassed and also had nettle, Hedge Bindweed, Himalayan balsam, Phalaris at the water’s edge and occasional Purple loosetrife (Lythrum salicaria), while the LHS bank had Alder, Willow, Phalaris, Himalayan Balsam and nettles.

1 RHS = right hand side (in the direction of the flow)

13

Kick-samples were taken immediately downstream of a damaged part of the weir where the substrate consisted of angular cobbles, gravel and coarse sand in moderate to swift turbulent flow.

14

Plate 1 View of River Feale at Site 1, downstream toward the Kerry Ingredients

outfall on the left bank (view downstream, 28-8-2007).

Plate 2 River Feale at Site 2 (new downstream location) i.e. downstream of the Kerry

Ingredients outfall mixing zone. (August 28th 2008).

15

Plate 3 River Feale at Site 3 - Scarlea Weir (August 28th 2008).

Plate 4 View upstream at Site 3a. Note low gabion weir where

macroinvertebrate kick-samples were taken is drowned out. (August 28th 2008).

Attachment 4 Kerry Ingredients Listowel Site Drainage Project

Attachment 5 EPA PRTR Summary Data Table 2008

| PRTR# : P0393 | Facility Name : Kerry Ingredients (Ireland) Limited | Filename : P0393_2008.xls | Return Year : 2008 | 2354 25/03/2009 14:31

Version 1.1.03

REFERENCE YEAR 2008

1. FACILITY IDENTIFICATIONParent Company Name Kerry Ingredients (Ireland) Limited

Facility Name Kerry Ingredients (Ireland) LimitedPRTR Identification Number P0393

Licence Number P0393-02

Waste or IPPC Classes of ActivityNo. class_name

7.2.1

The treatment and processing of milk, the quantity of milk received being greater than 200 tonnes per day (average value on a yearly basis).

2.1.0The operation of combustion installations with a rated thermal input equal to or greater than 50MW

Address 1 Tralee RoadAddress 2 ListowelAddress 3 County KerryAddress 4

Country IrelandCoordinates of Location 09891326

River Basin DistrictNACE Code 105

Main Economic Activity Manufacture of dairy productsAER Returns Contact Name Padraig Sayers

AER Returns Contact Email Address [email protected] Returns Contact Position Operations Manager

AER Returns Contact Telephone Number 068 - 50100AER Returns Contact Mobile Phone Number

AER Returns Contact Fax Number 068 - 21562Production Volume 137676.0

Production Volume Units tonnesNumber of Installations 1

Number of Operating Hours in Year 8640Number of Employees 600

User Feedback/CommentsWeb Address www.kerrygroup.com

2. PRTR CLASS ACTIVITIESActivity Number Activity Name8c Treatment and processing of milk1c Thermal power stations and other combustion installations5d Landfills

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)Is it applicable? No

Have you been granted an exemption ? NoIf applicable which activity class applies (as per

Schedule 2 of the regulations) ?Is the reduction scheme compliance route being

used ?

AER Returns Worksheet

4.1 RELEASES TO AIR | PRTR# : P0393 | Facility Name : Kerry Ingredients (Ireland) Limited | Filename : AER PRTR 2008_P0393-02.xls | Return Year : 2008 | 27/03/2009 09:03

8 10 18 18 26 26 6 14 6 6 6 6 6SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

QUANTITYA1-2 A1-3 A1-4 A1-5 A1-6 A1-7 A1-8 A1-9 DG1

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 Emission Point 4 Emission Point 5 Emission Point 6 Emission Point 7 Emission Point 8Emission Point

9T (Total) KG/Year

A (Accidental) KG/Year

F (Fugitive) KG/Year

11 Sulphur oxides (SOx/SO2) C PER Flue gas analyser 3831.0 7167.0 13856.0 7507.0 191350.0 247.0 1192.0 871.0 0.0 226021.0 0.0 0.008 Nitrogen oxides (NOx/NO2) C PER Flue gas analyser 2166.0 3484.0 8332.0 4917.0 57354.0 255.0 1287.0 934.0 0.0 78729.0 0.0 0.003 Carbon dioxide (CO2) C PER CEN accredited laboratory 2754984.0 5212008.0 2044464.0 4416684.0 58811350.0 315456.0 1412160.0 836352.0 117727.0 ######### 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


Additional Data Requested from Landfill operators

Landfill: Kerry Ingredients (Ireland) LimitedPlease enter summary data on the quantities of methane flared and / or utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method CodeDesignation or

DescriptionFacility Total Capacity m3

per hourTotal estimated methane generation (as per

site model) 0.0 N/AMethane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)Net methane emission (as reported in Section

A above) 0.0 N/A

METHOD

POLLUTANT METHODMethod Used

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Method Used

RELEASES TO AIRPOLLUTANT METHOD

Method Used

POLLUTANT

RELEASES TO AIR

RELEASES TO AIR

Method Used

4.2 RELEASES TO WATERS | PRTR# : P0393 | Facility Name : Kerry Ingredients (Ireland) Limited | Filename : P0393_2008.xls | Return Year : 2008 | 25/03/2009 14:32

8 10 18 18 26 33 6 6 6 6SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility

QUANTITYSW1

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year79 Chlorides (as Cl) C PER APHA 1229633.0 1229633.0 0.0 0.013 Total phosphorus C PER APHA 1384.0 1384.0 0.0 0.076 Total organic carbon (TOC) (as total C or COD/3) C PER Standard Calculation 22376.0 22376.0 0.0 0.0


SECTION B : REMAINING PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year306 COD C PER Hach 63127.0 63127.0 0.0 0.0238 Ammonia (as N) C PER APHA 394.0 394.0 0.0 0.0303 BOD C PER APHA 5584.0 5584.0 0.0 0.0308 Detergents (as MBAS) C PER APHA 165.0 165.0 0.0 0.0327 Nitrate (as N) C PER APHA 19047.0 19047.0 0.0 0.0332 Ortho-phosphate (as PO4) C PER APHA 1175.0 1175.0 0.0 0.0343 Sulphate C PER APHA 68271.0 68271.0 0.0 0.0240 Suspended Solids C PER APHA 19005.0 19005.0 0.0 0.0


Method Used

POLLUTANTMethod Used

POLLUTANT

POLLUTANTRELEASES TO WATERS

Method Used

RELEASES TO WATERS

RELEASES TO WATERS

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0393 | Facility Name : Kerry Ingredients (Ireland) Limited | Filename : P0393_2008.xls | Return Year : 2008 | 25/03/2009 14:33

5 19 18

Transfer DestinationEuropean Waste

Code HazardousQuantity T/Year Description of Waste

Waste Treatment Operation M/C/E Method Used

Location of Treatment

Name and Licence / Permit No. of Recoverer / Disposer /

BrokerAddress of Recoverer /

Disposer / Broker

Name and Address of Final Destination i.e. Final

Recovery / Disposal Site (HAZARDOUS WASTE

ONLY)

Licence / Permit No. of Final Destination i.e. Final

Recovery / Disposal Site (HAZARDOUS WASTE

ONLY)Within the Country 02 05 99 No 2149.0 Whey solids used for animal feeds R10 M Weighed Offsite in Ireland WCP/LK/093/02b SoIWM, Tarbert, Co.KerryWithin the Country 02 05 02 No 25144.0 Sludges from onsite effluent treatment R10 M Weighed Offsite in Ireland WCP/LK/093/02b SoIWM, Tarbert, Co.Kerry

Within the Country 15 01 01 No 514.0 Paper and cardboard packaging R11 M Weighed Offsite in Ireland

WP/03/02WCP/LK/1033/02bWCP/LK/077/02bWCP/LK/077/04c WP/2/98

Repak via Glenoire Waste Paper Ltd. Castletownroche, Co. Cork ,Dillon Waste Disposal, Tralee

Within the Country 20 01 02 No 59.0 Plastics R5 M Weighed Offsite in Ireland

WP/03/02WCP/LK/033/02bWCP/LK/077/02bWCP/LK/077/04c WP/2/98

Glenoire Waste Paper Ltd. Castletownroche, Co. Cork.Dillon Waste Disposal, Tralee

Within the Country 20 01 02 No 0.0 Glass R11 M Weighed Offsite in Ireland WCP/LK/119/03bRehab Recycling Partnership, Monaghan Road, Cork City

Within the Country 20 01 40 No 185.73 Metals R4 M Weighed Offsite in Ireland

WP/5/00WCP/LK/027/02b

Within the Country 20 01 38 No 374.0 Wood R4 M Weighed Offsite in Ireland

WCP/LK/037/02bWCP/LK/037/02cWCP/LK/212/04b

Buckley Waste Disposal ListowelThomas O’Neill, Castleconnel, Co Limerick.

To Other Countries 20 01 25 No 319.77 Edible oils and fats R9 M Weighed Abroad

Permit No. JP3931SG Reg. No.YRI/446290/CBEWC 020501

Brocklesby Ltd. The North Cave Hull, East Yorkshire, UK. HU15 2PG

Within the Country 17 09 04 No 496.0 Construction and demolition waste R5 M Weighed Offsite in Ireland

WCP/LK/037/02BWCP/LK/077/02bWCP/LK/077/04c WP/2/98

Buckley Waste Disposal Listowel, Dillon Waste Disposal, Tralee.

Within the Country 20 03 01 No 919.0 Mixed municipal waste D1 M Weighed Offsite in Ireland

WCP/LK/077/02bWCP/LK/077/04c WP/2/98 WCP/LK/037/02b

Dillon Waste Disposal, Tralee, Buckley Waste Disposal Listowel

Within the Country 10 01 02 No 6192.0 Coal fly ash D1 M Weighed Offsite in Ireland

WCP/LK/113/03b WCP/LK/113/05c IPPC Licence No. PO393_02 J. Finnerty, Listowel, Co.

Kerry,

Within the Country 16 05 08 Yes 0.0Discarded organic chemicals consisting of or conatining dangerous substances D15 M Weighed Offsite in Ireland

WCP/LK/028/02bWaste Licence Reg 185-1WCP/LK/056/02b

Minchem Environmental Services Ltd. (Indaver) Dun Laoghaire, Co DublinCedar Resource Management (Reagecon), Rathcoole Co Dublin.

Within the Country 20 01 21 Yes 0.36 Flourescent tubes R3 M Weighed Offsite in Ireland

WP/02/2000ES CP/LK57 IL/SK WCP/LK/057/02b Irish Lamp Recycling, Athy,

Co Kildare.

Within the Country 16 07 08 Yes 12.98 waste containing oils R9 M Weighed Offsite in Ireland

IPC Reg. No. 472Waste Licence Reg 184-1WCP/LK/052/02bWCP/LK/002/05b

Atlas EnvironmentalCo Laois.SITA Ireland Limited Unit 6, Ballyorgan Business Park, Co.Dublin

Within the Country 20 01 33 Yes 1.0 Batteries D2 M Weighed Offsite in Ireland

WCP/LK/060/06cWP 97/2002A

Returnbatt LtdUnit A, Oldmill Ind. Estate,Oldmilltown, Kill, Co. Kildare

Method Used

Attachment 6 OCM Groundwater Monitoring Summary

Attachment 7 ______ SO2 & NO2 Ambient Air Monitoring Results

ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON

AMBIENT SO2 AND NO2 MONITORING SURVEY

FOR 2008 ANNUAL PERIOD ----------

KERRY INGREDIENTS LISTOWEL CO. KERRY

----------

ENVIROCON ENVIROCON ENVIROCON

ENVIROCON ENVIROCON ENVIROCON ENVIROCON

AIR POLLUTION AND ENVIRONMENTAL CONSULTANCY ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON LTD. ENVIROCON OLD ROAD ENVIROCON KILCARN BRIDGE ENVIROCON NAVAN, CO. MEATH ENVIROCON Tel: (046) 9074135 ENVIROCON Fax: (046) 9074055 ENVIROCON e-mail: [email protected] ENVIROCON _____________________________________________________________________ Date: 20 MARCH 2009 Report By: Michael L. Bailey

ENVIROCON LTD., AMBIENT AIR MONITORING PROGRAMME –ANNUAL 2008 -20/03/09 1

1.0 INTRODUCTION An ambient air quality monitoring programme is being undertaken by Kerry Ingredients at two boundary locations at the dairy manufacturing facility in Listowel Co. Kerry. Monitoring is carried out continuously for sulphur dioxide (SO2) and nitrogen dioxide (NO2) and the following report details the results for the 2008 annual period. The results are compared with the National Air Quality Standards specified in the Air Quality Standards Regulations 2002 (SI No 271 of 2002). 2.0 DESCRIPTION OF MONITORING SITES Ambient monitoring is carried out at two locations as requested by the Environmental Protection Agency as part of the IPPC Licence compliance monitoring requirements (Figure 1). The monitoring location S1 is situated near the SW boundary, approximately, 100m to the West of the boiler plant building (Figure 2a). The monitoring location S2 is near along the NE field boundary and is on lands owned by the company, approximately 450m to the NE of the Fuel Oil boiler stacks and 550m east of the solid fuel boiler stack (Figure 2b). The field is used for silage production and so for much of the year the ground is well covered with grass with no extensive areas of exposed soil. The monitoring equipment is installed within a secure steel cage near the northern boundary of this field, about 100m from the N69 Tralee Road. This second monitoring location is situated approximately 100m to the SW of the nearest residential property from the eastern site boundary. 3.0 AMBIENT AIR QUALITY COMPLIANCE CRITERIA

Table 1 National Air Quality Standards (SI No 271 of 2002)

Pollutant Criteria (µg/m3) Compliance

Date SO2 Hourly – 99.73% (not to

be exceeded more than 24 times per year)

350 1 Jan 2005

Daily – 99.2% (not to be exceeded more than 3 times per year)

125 1 Jan 2005

NO2 Hourly – 99.8% ( not to be exceeded more than 18 times per year)

200 1 Jan 2010

Annual average 40 1 Jan 2010


Measured SO2 and NO2 concentrations obtained at the two boundary locations are compared with the hourly and daily National Air Quality Standards (NAQS) values specified in the Air Quality Standards Regulations 2002 (SI: No 271 of 2002) (Table 1). These Standards are based on the limit values specified in the EU Council Directive 99/30/EC, which was adopted under the 1996 Framework Directive on Air Quality Assessment and Management (96/62/EC). In the case of NO2 concentrations, the NAQS values enter into force from January 1 2010 with an hourly NAQS of 200 �g/m3 , expressed as a 99.8 percentile and an annual average limit value of 40 �g/m3. The hourly percentile concentration equates to the 19th highest hourly average value measured over the year. 4.0 MONITORING METHODOLOGY 4.1 Sulphur Dioxide (SO2) Continuous ambient monitoring for SO2 is undertaken using an advanced design UV fluorescence analyser (Monitor Europe, Model ML 9850). The air sampled is exposed to a UV light source which causes excitation of the SO2 molecules in the gas stream, which occurs in the presence of a specific wavelength of UV light. The subsequent reaction results in an emission of fluorescent radiation that is detected by a multiplier tube as the SO2 molecules return to their initial state. This method of measurement provides high resolution measurements of SO2 to give hourly average values that allow hourly and daily average concentrations to be compared with the NAQS limit values. 4.2 Nitrogen Dioxide (NO2) Nitrogen dioxide is measured continuously using a chemiluminescence analyser (Monitor Europe, Model ML 9841) that provides accurate monitoring of NO, NO2 and NOx. A single reaction chamber and photomultiplier tube measures the chemiluminescence produced by the reaction between NO and ozone. The measurement process determines the concentration of NO and NOx present and the difference between the two readings provide a calculated NO2 value. This reliable method of ambient NO2 sampling provides a high resolution for continuous monitoring so that short-term concentrations (15-minute averages) can be compared with the NAQS hourly and annual limit values. 5.0 MONITORING RESULTS 5.1 Sulphur Dioxide (SO2) The hourly and daily average concentrations measured at locations S1 and S2 for the January-December 2008 survey period are given in Figures 3-6. Due to a fault with the analyzer, the results for the days 1/4-9/4,4/7-14/7 and 3/10-15/10. are not available for location S1. A quality-control check was carried out for the annual data-set to remove erroneous results that give ‘outlier’ spikes in the results due to calibration sample checks


or other infrequent exceptionally high hourly average concentrations that were well outside the levels reported before and after the event.

Table 2: Monthly SO2 monitoring results at Location S1 for 2008 (�g/m3) Monitoring Period Maximum Hourly

Average Maximum Daily

Average Monthly Average

January2008 11.9 10.2 6.0 February 2008 8.4 7.9 5.4 March 2008 49.5 23.1 10.8 April 2008 42.5 15.7 9.3 May 2008 94.4 34.5 11.2 June 2008 63.4 26.6 8.8 July 2008 33.2 8.4 5.0

August 2008 58.8 6.5 4.5 September 2008 45.9 10.4 5.0

October 2008 22.7 8.7 4.4 November 2008 11.5 8.3 4.6 December 2008 41.0 16.3 6.4 NAQS Limit

Values 350 125 20

Note: Data missing for period 01/04-09/04/08, 04/07-14/07/08, 3/10-15/10/08 due to equipment fault.

Table 3: Monthly SO2 monitoring results at Location S2 for 2008 (�g/m3) Monitoring Period Maximum Hourly

Average Maximum Daily


January2008 34.4 19.3 6.3 February 2008 14.9 6.8 5.4 March 2008 12.1 6.7 5.4 April 2008 22.8 8.8 5.6 May 2008 30.7 10.5 5.3 June 2008 26.4 18.1 6.9 July 2008 18.8 8.2 5.5

August 2008 23.6 9.6 5.5 September 2008 22.2 8.0 5.0

October 2008 11.8 6.5 5.1 November 2008 7.6 6.8 4.8 December 2008 10.6 7.3 5.3 NAQS Limit

Values 350 125 20


The maximum hourly and daily concentrations observed over each month during the survey period at monitoring location S1 are given in Table 2. The maximum hourly concentration was 94.4 �g/m3, with a corresponding maximum daily SO2 concentration, which were both reported on 13th May. A secondary peak hourly concentration that coincided with the 2nd highest daily concentration occurred on the 24th June. The maximum hourly and daily levels reported at monitoring location S2 are given in Table 3. The highest reported hourly average concentration at location S2 was 34.4 �g/m3 on 25th January, and the highest daily concentration was also low with a level of 19.3 �g/m3. The 99.7 percentile of hourly SO2 levels over the 2008 survey period observed at location S1 are approximately 10% of the NAQS limit value (Table 4). The corresponding 99.2 percentile of daily SO2 concentrations was reported to be 15% of the NAQS value. At location S2, the hourly and daily percentile SO2 concentrations are 8% and 11% of the NAQS limit values. The annual average SO2 concentration reported at both monitoring locations was less than 35% of the annual NAQS specified in the legislation for the protection of ecosystems.

Table 4: Summary of SO2 monitoring results at Locations S1 and S2 (�g/m3)

Location Hourly 99.7%ile Daily 99.2%ile Annual

Average S1 36.2 19.3 6.9 S2 27.6 13.9 5.6

NAQS Limit Values

350 125 20

5.2 Nitrogen Dioxide (NO2) The hourly average NO2 concentrations measured at locations S1 and S2 during 2008 are given in Figures 7 and 8. Results are unavailable for S1 for January and February due to a fault with the instrument data logger. The maximum hourly concentrations during each month at the 2 locations are given in Tables 5 and 6 and the highest level was 93.5 �g/m3 at location S1, which was reported on 13th May. This NO2 value occurred when the maximum SO2 hourly average for 2008 was also reported. The highest hourly NO2 concentration at location S2 was slightly lower, with a level of 59.3 �g/m3 recorded in March and also December. The monthly average NO2 concentrations ranged from 5.7-21.6 �g/m3 at Location S1 and 9.7-21.6 �g/m3 at location S2.


Table 5: Monthly NO2 monitoring results at Location S1 for 2008 (�g/m3)

Monitoring Period Maximum Hourly


January2008 NA NA February 2008 NA NA

March 2008 30.2 5.7 April 2008 47.1 9.7 May 2008 93.5 14.0 June 2008 43.7 7.2 July 2008 29.6 7.4

August 2008 34.5 7.0 September 2008 26.9 10.2

October 2008 34.2 11.4 November 2008 36.6 15.6 December 2008 40.2 21.6 NAQS Limit

Values 200 40

Note: Data missing for period, 01/01/08—27/02/08 due to equipment fault.

Table 6: Monthly NO2 monitoring results at Location S2 for 2008 (�g/m3)

Table 7 gives the hourly concentrations expressed as 99.8 percentile levels for both monitoring locations. The reported levels are well below the hourly NAQS of 200 �g/m3

Monitoring Period Maximum Hourly Average

Monthly Average

January2008 45.4 14.4 February 2008 58.0 21.3 March 2008 59.3 16.3 April 2008 40.3 14.2 May 2008 43.3 14.2 June 2008 46.5 12.3 July 2008 27.4 10.2

August 2008 36.7 9.4 September 2008 43.4 12.9

October 2008 46.8 12.9 November 2008 51.8 13.9 December 2008 59.3 17.1 NAQS Limit

Values 200 40


that enters into force in January 2010, with a 99.8 percentile of 39.8 ug/m3 at location S1 and 50.8 ug/m3 at location S2. The annual average NO2 concentrations are less than 35% of the annual NAQS at both locations.

Table 7: Summary of NO2 monitoring results at Locations S1 and S2 (�g/m3)

Location Hourly 99.8%ile Annual Average

S1 39.8 11.0 S2 50.8 14.1

NAQS Limit Values

200 40

6.0 CONCLUSION The air quality monitoring results obtained at the two boundary locations of the Kerry Ingredients facility demonstrate that the ambient measurements for both SO2 and NO2 during the annual survey period in 2008 were substantially below the National Air Quality Standards (NAQS) specified in the 2002 Regulations. At monitoring location S1, which is near the SW boundary, both the maximum hourly SO2 and NO2 average concentrations were less than 20% of the NAQS value. The corresponding levels at location S2, to the NE of the manufacturing facility, were less than 8% and 25% respectively of the SO2 and NO2 hourly NAQS limit values. The maximum daily average SO2 results for both locations were less than 16% of the NAQS. The annual average SO2 and NO2 concentrations reported at both monitoring locations were also well below the NAQS values for these pollutants.


FIGURES 1-8


Figure 1: Ambient air monitoring locations


Figure 2a – Ambient Monitoring Location S1 Figure 2b – Ambient Monitoring Location S2


Figure 3: Hourly average SO2 monitoring results at location S1 for 2008 survey period. (�g/m3) Note: Data missing for period 01/04-09/04/08, 04/07-14/07/08, 3/10-15/10/08 due to equipment fault.


Figure 4: Hourly average SO2 monitoring results at location S2 for 2008 survey period. (�g/m3)


Figure 5: Daily average SO2 monitoring results at location S1 for 2008 survey period. (�g/m3) Note: Data missing for period 01/04-09/04/08, 04/07-14/07/08, 3/10-15/10/08 due to equipment fault.


Figure 6: Daily average SO2 monitoring results at location S2 for 2008 survey period. (�g/m3)


Figure 7: Hourly average NO2 monitoring results at location S1 for 2008 survey period. (�g/m3) Note: Data missing for period, 01/01/08—27/02/08 due to equipment fault.


Figure 8: Hourly average NO2 monitoring results at location S2 for 2008 survey period. (�g/m3)

Attachment 8 _________ Land Bank Register

Farm Code Grid Reference Spread Area Reps Capacity

B028 R04,46; R04,47; R04,48 106.69 No 930

B024 R17,36 15.10 No 163.64

H001 E1208N0905 19.25 No 95.41

B101 Q979 483; R015 475 42.65 No 179.21

H098 E2605N8907 4.80 Yes 17.455

H006 E1305N0907 62.44 No 404.436

H102 E1403N1007 5.20 Yes 18.909

H041 E1402N0907 43.68 No 240.6436

H099 E2550N8650 23.57 Yes 155.348

H003 E1203N0809 46.10 No 245.298

H119 E89927N117545 31.83 Yes 192.7205

B002 Q96,34; Q95,33 38.75 No 264.75

B003 Q95,33; Q97,33; Q98,34; Q99,31 38.11 No 274.84

H044 E1309N1008 31.37 No 174.3686

B072 Q89,28 39.50 No 174.83

H114 E96073N129127 39.66 No 180.742

H007 E1401N0903 37.88 Yes 185.163

B160 Q87,41 17.96 No 146.02

B006 Q89,31 Q88,32 14.06 No 99.78

B103 Q984 467 34.64 No 141.53

B162 R09,45 50.92 No 369.46

B104 R005 375 21.13 No 94.8

H074 E1302N0906 42.25 Yes 204.079

B009 Q96,33 33.00 No 143.2

H115 E89430N125090 8.53 Yes 50.404

H076 E1308N0904 21.19 No 115.355

H081 E3701N8705 20.76 Yes 95.35

H079 E1701N8001 24.31 Yes 110.3

B035 R06,26 31.16 No 327

B012Q93,30 Q92,31, Q84,24 , Q93,32 , Q94,31188.96 No 1725.68

B158 Q93,47 Q94,46 12.32 No 60.45

H113 E80556N123382 18.50 Yes 70.681

H082 E1709N8405 28.06 Yes 130.218

B106 R005 365 11.63 No 76.65

B107 R935 313; Q92,32; Q95,30 17.66 No 98.94

H011 E1204N0804 51.81 Yes 369.198

B108 Q945 413 15.13 No 85.96

H083 E1705N8205 27.05 Yes 162.079

B017 Q98,44 42.62 No 183.76

B110 R015 470 58.07 No 255.97

B004 Q12,46 14.57 No 115.9

H089 E1150N8650 30.99 Yes 180.821

H010 E1302N0906 16.50 Yes 108.75

H116 E95071N130326 32.80 Yes 166.409

B021Q91,24; Q96,32; Q96,31; Q97,32; Q93,31; Q91,3469.61 No 461

H080 E2605N8907 35.13 No 189.808

H084 E1602N8205 3.38 Yes 14.595

H100 E1403N1007 28.25 Yes 121.989

H073 E1308N0904 3.87 No 26.386

B022 Q91,27 84.61 No 586.94

B023 Q98,34; Q95,32 37.53 No 324.56

H014 E1405N1009 15.66 No 132.754

H011 E1405N1009 23.42 Yes 134.041

H050 E1403N1007 22.53 Yes 97.289

B181 Q96,27 12.32 No 98

B027 Q94,35 33.42 No 197.26

B115 Q892,415; Q918,403 70.52 No 451.24

B117 Q89,90 13.73 No 98.425

B030 Q87,24; Q84,22 22.82 Yes 283.82

B125 R27,09 , R07,24 34.62 No 495.03

B143 Q922,245; Q912,323 8.07 No 71.52

B034 Q70,31; Q77,31; Q82,33; Q80,23 83.29 No 526.35

B118 R019 299, R037 295 9.64 No 63.54

H017 E1309N0906 28.16 Yes 151.532

B036 Q95,30; Q95,28 26.43 No 152.15

H094 E2520N8850 14.86 Yes 64.377

B121 R022 296 11.20 No 73.8

H101 E1403N1007 3.74 No 34

Farm Code Grid Reference Spread Area Reps Capacity

B001 R12,35; R12,36 61.85 No 268.9

B025 R10,36; R11,34 23.40 No 209.59

B187 Q81,33; R17,30 121.02 No 868.495

H021 E1206N0901 25.15 No 118.708

B015 R04,32; R07,30 117.05 No 1019.874

H095 E1410N9120 12.36 Yes 53.373

B123R015 338; R013 343; R028 410; Q98734747.50 No 350.16

B126 Q88,44 42.50 No 205.93

B154 Q90,28 10.90 No 99

B039 Q88,37 , Q89,37 27.80 No 290.68

H023 E1303N0903 31.44 No 149.7097

H022 E1303N0903 48.22 No 183.0335

H097 E1650N8250 40.72 Yes 324.732

B153 Q92,34 23.86 No 157.26

H024 E1308N0904 22.06 No 94.194

H025 E1308N0904 24.55 No 120.999

B042 Q94,32 17.21 No 76.43

H109 E92910N123799 16.98 Yes 61.745

B130 Q950 433; Q948 453 14.79 No 117.65

H028 E1309N0905 32.22 No 143.541

B044 R04,37 22.82 No 172

H112 E80556N123382 14.98 Yes 89.205

H015 E1309N1005 12.27 No 64.062

B018 R05,35 11.73 Yes 133.29

H111 E80556N123382 26.96 Yes 167.009

H103 E1305N0907 33.08 No 193.531

B045 Q91,27 18.35 No 125.19

B020 R14,29 20.25 No 210.9

B046 Q87,41; Q86,39 33.48 No 266.32

B048 R06,48; R04,47; R02,46 43.05 No 272.1

B050 Q90,33 8.29 Yes 37.125

B132 R010 478 11.40 No 49.227

B038 Q96,39 45.00 No 441.64

B010 R10,31; R09,31; R11,26; R12,23 110.04 Yes 848.92

B053 Q88,23 100.01 No 592.59

H104 E1403N1007 38.64 Yes 224.082

H105 E96214N133991 9.67 Yes 41.757

B190 Q99,28; Q98,58 32.31 No 237.84

H090 E4700N9300 22.54 Yes 97.332

H065 E1204N0904 117.05 No 810.63

H118 E87842N128539 26.00 No 253.038

H117 E87842N128539 29.28 Yes 126.436

B010 Kerry O.S. 4/3 16/6 16/10 29.78 No 197.24

H093 E2350N8780 15.09 Yes 65.16136

B136 Q957 283 20.93 No 118.92

B058 Q99,37; Q95,39; R04,29 37.69 No 202.79

H086 E1705N8405 13.65 Yes 51.943

H068 E1406N1007 7.45 Yes 32.171

B062 R01, 28 23.39 No 101

B041 Q98,36 77.61 No 654.14

H092 E2550N8650 28.01 No 158.126

B068 Q86,21 72.83 No 305.361

H087 E2403N8701 17.89 Yes 77.252

H105 E1406N1006 68.83 No 248.6147

B065 Q98,31; Q99,31 60.09 No 301.67

H108 E91529N123334 13.68 Yes 72.618

B031 R36,22 41.06 No 347.2

B141 R005 310; R015,315; R043, 312 70.60 No 483.65

B071 Q93,40 18.31 No 101.07

H038 E1202N0902 41.86 No 265.931

H036 E1301N0806 7.20 No 43.242

H096 E2340N8920 30.12 Yes 130.0636

H110 E108964N147387 37.72 No 255.4824

B043 R13,31 45.85 No 416.5

H071 E1405N0909 13.36 No 50.7528

4,551.75 29486.0408

Documents

Attachment 1 Toxicity Test Report · energy audit 2007 are incorporated in the Schedule of Environmental Objective and targets 2006 – 2111. Condition 2.2.2.2 - PO393-02 & Condition