ATTACHMENT No E.4 EMISSIONS TO · PDF fileE.4.1 Emissions to Ground ... Sludge De-Watering Decanter with Lime addition ... A level sensor governs the speed of forward feed pumps to

Industrial Emissions Review Application – Dairygold Mallow P0403-02 Attachment No. E.4

ATTACHMENT No E.4 – EMISSIONS TO GROUND

Contents

E.4.1 Emissions to Ground

E.4.2 Details of Nature and Quality of Substances to be Landspread

E.4.3 Details on the receiving lands

Copy of Organic Trust Certificate

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E.4.1 Emissions to Ground

There are no direct discharges from the installation to ground. Dairygold Mallow however currently

monitors groundwater in three (3) wells downgradient of the site on an annual basis in accordance

with the requirements of Schedule C.6 of the existing Licence Register Reference No. P0403-02.

To ensure protection of groundwaters, Dairygold Mallow will have a number of control measures on-

site to minimise the risk of environmental harm from liquid spills and leaks. All materials and liquids

on site will be stored above ground and will be contained in bunds or other appropriate spill

containment systems. Transfer of liquid materials will principally be conveyed by overground piping

systems. Refer to Attachment H.1 for further details.

E.4.2 Details of Nature and Quality of Substances to be Landspread

It is estimated that the Dairygold Mallow effluent treatment plant could generate approximately

1900 tonnes of sludge per annum at full build out of the installation.

The sludge generated through the treatment of process wastewaters at the effluent treatment plant

has the following characteristics:

% Dry Matter

13.0

% Total Nitrogen 2.5

Total Phosphorus (mg/Kg as P) 42,015

Total Potassium (mg/Kg) 1110

This material is certified annually by the Organic Trust as a Dairy Sludge Fertiliser. Copy of Certificate

is attached.

As is the current practice this sludge is to be recovered by landspreading under an approved nutrient

management plan (NMP) and in accordance with condition 8.10 of the facility’s existing Licence. All

landspreading is carried out by a permitted contractor.

E.4.3 Details on the receiving lands

The sludge is landspread on an approved landbank and application of material is strictly controlled

through a Nutrient Management Plan (NMP). A NMP is prepared annually and submitted to the EPA

for approval prior to landspreading. The NMP facilitates management control over the landspreading

activities of the waste management contractors involved in landspreading. A copy of the current

NMP is included in Attachment No I.4.

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ATTACHMENT No E.5 – NOISE EMISSIONS

Contents

Drawing No. 11 Noise Emission Sources

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Industrial Emissions Review Application – Dairygold Mallow P0403-02 Attachment No. F.1

ATTACHMENT No F.1 – TREATMENT, ABATEMENT AND CONTROL SYSTEMS

Contents

F.1.1 Air Quality

F.1.2 Surface Water Quality

F.1.3 Noise Abatement Existing Dryer (A2-1) Schematic and data sheet

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F.1.1 AIR QUALITY

Boiler Emissions

There is no existing or planned abatement equipment in place on emissions to the atmosphere from

the installation boilers. Boiler emissions are controlled by the following measures:

The installation boiler operators continuously monitor the boiler’s operation to ensure

proper operation, efficiency and safety.

Load management measures, including optimal matching of boiler size and boiler load to

production requirements, monitoring of flue gas temperature and adjusting the air to fuel

ratio linkages feeding the boiler burner to achieve the optimum excess air and resulting

combustion efficiency is undertaken daily.

A schedule is in place for boiler maintenance, routine servicing, and inspection. Boiler

maintenance and inspections alternate between day to day operational inspection and

routine periodic internal inspection. The day-to-day boiler operation, maintenance and

service is the responsibility of the Boiler operator. The site operator employs an external

boiler contractor to undertake periodic inspections of the boiler system.

These measures ensure the safe running and efficiency of the boiler and help maintain proper

emissions from the boiler systems.

Emission Point A2-1 (Existing Dryer 1)

There is currently an abatement system in place on exhaust air emissions from the existing Niro

Dryer, emission point A2-1. A wet scrubber is integrated in the spray drying plant for removal of

powder particles in the outlet gas, which are so small that they could not be completely removed by

the previous steps of the drying process. The outlet gas is mixed with a scrubbing liquid, the

particles are bound and the clean gas released.

A schematic and technical data sheets are attached.

Details on the operating parameters of the abatement system which control its function, monitoring

systems and equipment necessary for the proper function of the abatement / treatment system are

provided in Table F.1(i) of the Application Form

The existing dryer also has an explosion suppression system. This system ensures that an explosion

or major fire will not occur in the dryer.

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Emission Point A2-3 and A2-4 (Proposed Dryer 2 and Dryer 3)

There will be abatement systems in place for the new dryers in relation to emissions to atmosphere.

The exhaust air from each chamber will pass through a bag filter in order to remove particulate

matter from the exhaust stream.

The dryer exhaust filtration technology that will be installed will reduce particulate emissions from

the exhaust stream from the dryers to levels compliant with current licence emission limits.

Details on the operating parameters of the abatement system which control its function, monitoring

systems and equipment necessary for the proper function of the abatement / treatment system are

provided in Table F.1(i) of the Application Form

All equipment associated with the dryers will be maintained and calibrated as required by

manufacturers operational and maintenance recommendations

F.1.2 SURFACE WATER QUALITY

SWD1 (Process Wastewater Emissions)

All process waters arising at the site are treated at an onsite wastewater treatment plant. The purpose of the waste water treatment plant (WWTP) at the facility is to biologically treat waste water to a standard suitable for discharge to the River Blackwater. The treatment methods comprise biological treatment and solid removal through chemical dosing and clarification.

The WWTP consists of the following elements: - Inlet Pumping Station DAF Tank (No. 1) Aerated Balance tank (with pH correction) Aerated Balance Tank (out-of-use) Forward Feed Pumps DAF Tank (No. 2) Splitter Chamber Bio-Tower No. 1 Interstage Sedimentation Tank Bio-Tower No. 2 Interstage Sedimentation Tank Alternating Distribution Filter (ADF) forward feed pumps ADF 1 Interstage Sedimentation (Humus) Tank ADF 2 Phosphorus Removal

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Final Clarifier Final Effluent flow measurement & sampler Sludge Stabilisation Tank Picket Fence Thickener (PFT) Sludge De-Watering Decanter with Lime addition

The WWTP was originally designed to treat a BOD5 load of 6,000 kgs/day to a 20:30 discharge standard. The loading now proposed is less than 50% of that. The configuration of the existing WWTP has been designed specifically to treat the high concentrations of BOD5 arising from a Milk processing Plant. The key operational control functions on the plant are explained hereunder: - Effluent is drained from process areas and protected yards 400m south to the WWTP by gravity via an underground pipeline. A mag-now meter records inflow into the inlet sump, Effluent is pumped from the inlet sump to dissolved Air Floatation unit No. 1 (DAF 1), where floated fat is scrapped off, falling into a DAF Fats Storage Tank beneath DAF 1. From DAF 1 effluent flows to an aerated Balance Tank, which provides equalisation. The effluent is pumped into DAF 2, fitted with aerators. Floated fats also fall into the Fats Storage Tank. A level sensor governs the speed of forward feed pumps to optimise level in Balance Tanks. pH correction (caustic/acid) takes place in the Balance Tank and is controlled from a pH probe on the outlet. The effluent flows to Splitter Chamber No. 1 (SC1) distributed across the top of Biotower No. 1, which contains Flocor F plastic media to support a biofilm. It trickles through the filter and is collected in the floor sump, gravitating back to SC1. Some is recirculated to Biotower 1 with remainder gravitating to Interstage Settlement Tank No.1 (ISST1). The supernatant from ISSTI flows to Splitter Chamber No. 2 (SC2), some of which is recirculated across Biotower 2. The remainder gravitates to TSST2 The supernatant from ISST2 flows to a combined Alternating Double Filter (ADF) and Humus Tank Distribution Chamber, from where it is pumped and distributed to ADF1. From here it gravitates to the Primary Humus Tank. Supernatant flows back to the Humus Tank Distribution Chamber and is pumped and distributed over ADF2. The effluent then flows to the Secondary Humus Tank. From here, it discharges to the River Blackwater via the Outlet Chamber, where a flow-proportionate composite sample is taken in accordance with the License. Phosphate removal is effected by addition of aluminium chloride dosed flow proportionately into the ADF Pump Station No.1. A meter located at the outflow from the Balance Tank controls the speed of the dosing pumps. Sludge from ISST1, ISST2, and the Primary & Secondary Humus Tanks is intermittently drawn off and discharged to the Combined Sludge Chamber. The sludge is pumped to the Sludge Stabilisation Tank (SST) containing 2 No.venturi aerators with associated air blowers, to effect stabilisation. A draw-off

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valve near the top of the tank allows sludge to flow to a Picket Fence Thickener (PFT), which concentrates the sludge from approximately 0.5% to 2% dry solids. Sludge recirculation from the PET to the SST is effected by means of a Mona-type pump rated at 14m3/hr. Sludge is dewatered using a Westphalia Decanter, resulting in solids concentration of between 8% and 20% maximum, Fats from the Fats Storage Tank is bled into the effluent sludge prior to decanting at an approximate rate of 1:5. Dewatered sludge is transported off-site for land-spreading in accordance with an EPA-approved Nutrient Management Plan.

SWD2 (Stormwater Emissions)

As part of the Dryer Expansion project it is proposed to entirely renew the stormwater collection and

discharge system. Refer to Drawing No. 8. The system will include an appropriately sized Class 1

Petrol Interceptor and a Divert system, controlled by Conductivity and pH meters. In the unlikely

event of a Pollution incident the liquids in the storm water system will be diverted to the process

drains by an overflow system and carried to the WWTP for treatment when flow rates arriving at the

WWTP permit. There is adequate balancing volume available at the WWTP to allow this.

In addition the following best site management practices to prevent contamination of the surface water will be implemented:

Dairygold Mallow will have a number of control measures on-site to minimise the risk of

environmental harm. Inadvertent releases to the environment will be minimised by the

design of the facility, the containment of potentially polluting materials during storage and

transport, and the site’s SOPs and Management System.

All potential risk areas on site where spills or leaks of potentially polluting materials may

occur have been identified and appropriate control and containment measures have been

included in the design.

All materials and liquids on site will be stored above ground and will be contained in bunds

or other appropriate spill containment systems. All bund, tanks, pipelines will comply with

Environmental Protection Agency Guidance Note on Storage and Transfer of Materials for

Scheduled Activities. Transfer of liquid materials will principally be conveyed by overground

piping systems. Materials handling and storage is discussed in Attachment H.1.

All product, chemical and fuel tanks are located within bunds.

All bund, tanks, and pipelines will comply with Environmental Protection Agency IPPC

Guidance Note on Storage and Transfer of Materials for Scheduled Activities.

The milk intake areas is covered and the internal milk intake bays drain to the foul water

system.

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The access road from the entrance to the milk intake area will be protected via the revised

stormwater collection systems. The system will include a full Class 1 petrol Interceptor and

divert system, controlled by conductivity and pH metres on each outfall.

Regular cleaning and servicing of gullies, pipework, silt trap and interceptor will be carried out to ensure this system is operating at its optimum

F.1.3 NOISE ABATEMENT

Noise Attenuators (for Existing dryer A2-1) Noise attenuation will be installed on the air intake duct to the existing dryer to reduce noise

emission associated with this plant. Specific detail of the abatement is not available at this time as

the supplier of the equipment has not yet been selected. It is proposed that the abatement system

to be installed will reduce noise emission in the order of 15 – 20 dBA.

Noise Attenuators (for New dryers A2-2 and A2-3) Noise attenuators will be fitted on the exhausts of both the new dryers at the facility. The attenuator will be made of a sound absorbing material and will fixed to the outlet pipe on the underside of the roof.

Noise Attenuators for Compressors

Silencers will be fitted at air inlets and exhausts associated with compressors to reduce noise levels.

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ATTACHMENT No F.2 – EMISSION MONITORING AND SAMPLING POINTS

Contents

F.2.1 Emissions Monitoring / Sampling Points

F.2.1.1 Emissions to Atmosphere F.2.1.2 Emissions to Surface Water F.2.1.2 Emissions to Sewer

F.2.2 Ambient Monitoring/ Sampling Points

F.2.2.1 Noise F.2.2.2 Groundwater Drawing No. 10 Groundwater Monitoring Locations Drawing No. 12 Noise Monitoring Locations

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This Attachment includes details on the proposed monitoring and sampling to be undertaken at the Installation.

Subsection F.2.1 sets out the proposed monitoring and sampling of emissions from the installation. Subsection F.2.2 sets out the proposed ambient monitoring/ sampling to be undertaken. F.2.1 EMISSIONS MONITORING AND SAMPLING POINTS

F.2.1.1 Emissions to Atmosphere

Boiler Emissions

It is proposed that monitoring of the following boiler emission points will be undertaken.

Emission Point Source Emission Point Ref

Boiler 1 A1-1

Boiler 2 A1-2

Boiler 3 A1-3

CHP Plant A1-4

Dryer 2 gas burner (Thermoheater) A1-5

Dryer 3 gas burner (Thermoheater A1-6

These boiler emission points will be monitored in line with Schedule C.1.2 of the current licence as follows:

Further details of boiler emission monitoring to be undertaken are set out in Tables F.2(i) of the IEL Application form. The location of Boiler emission monitoring /sampling points are as emission point shown in Drawings No. 5.

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Main Emissions

It is proposed that monitoring of the following dryer exhaust emission points will be undertaken.


Niro Dryer A2-1

Dryer 2 A2-2

Dryer 3 A2-3

These Dryer exhaust emission points will be monitored in line with Schedule C.1.2 of the current licence as follows:

Further details of dryer exhaust emission monitoring to be undertaken are set out in Tables F.2(i) of the IEL Application form. The location of Dryer exhaust emissions monitoring /sampling points are as emission point shown in Drawings No. 5. Minor Air Emissions Sampling or monitoring is not planned to be carried out on the minor air emission points from the

site.

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F.2.1.2 Emissions to Surface Water

It is proposed that monitoring of the following surface water emission points will be undertaken.


Wastewater Treatment Plant SWD1

Stormwater run-off SWD2

SWD1

Monitoring and sampling will be carried out on surface water emission point SWD1 which discharges

to the River Blackwater. This surface water emission point will be monitored and sampled in line

with Schedule C.2.2 of the current licence as follows:

Sampling of final effluent emissions will be facilitated from a dedicated monitoring chamber positioned after final treatment. Further details of monitoring/sampling of emission point SWD1 is outlined in Tables F.2(i) of the IEL Application form. The location of SWD1 emission monitoring /sampling point is shown in Drawings No. 6 and Drawing No. 13.

SWD2

Monitoring and sampling will be carried out on stormwater water emission point SWD2 which

discharges to ‘Linehans Stream’. This stormwater emission points will be monitored and sampled in

line with Schedule C.2.3 of the current licence as follows:

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Sampling of stormwater emissions will be facilitated from a dedicated monitoring chamber positioned after the petrol interceptor and silt trap. Further details of monitoring/sampling of stormwater emission point SWD2 are outlined in Tables F.2(i) of the IEL Application form. The location of SWD2 emission monitoring /sampling point are shown in Drawing No. 8.

F.2.1.3 Emissions to Sewer

Effluent discharged to the Water Services Authority sewer will be limited wastewater generated from

the installations canteen, toilet facilities and laboratory including milk wastes (including chemicals

used in testing) from sample bottles. No monitoring or sampling of the effluent at emission point SE1

to the public sewer is proposed.

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F.2.2 AMBIENT MONITORING AND SAMPLING POINTS

F.2.2.1 Noise

An ambient noise survey will be carried out annually at five (5) locations in the vicinity of the

installation. The locations of ambient noise monitoring points are shown in Drawing No. 12.

Ambient monitoring will be carried out in accordance with the EPA NG4 Guidance Note. The results will be reported annually to the EPA and included as part of the Annual Environmental Report (AER). Further details of ambient noise monitoring are outlined in Tables F.2(ii) of the IEL Application form.

F.2.2.2 Groundwater

Ambient monitoring of groundwater is planned to be undertaken at the three (3) supply wells

downgradient of the site. (AGW1, AGW2, AGW3). The locations of groundwater monitoring points

are shown in Drawing No. 10.

It is proposed that groundwater in these wells will be monitored and sampled in line with Schedule

C.6 of the current licence as follows:

Wells will be purged prior to sample collection and the samples will be collected using a dedicated

bailer for each well. Wells will be purged three well volumes prior to sampling. After purging each

well of three volumes, and once the physical parameters had stabilised, a sample will be collected

for analysis

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Industrial Emissions Review Application – Dairygold Mallow P0403-02 Attachment No. G

ATTACHMENT No G: RESOURCE USE AND ENERGY EFFICIENCY

G.1 Materials, substances, fuels, energy produced by or utilised in the activity

G.2 Energy Efficiency

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G.1 List of the raw and ancillary materials, substances, preparations, fuels and energy which will be produced by or utilised in the activity.

The range of materials, substances, intermediates, products, fuels, and chemicals which are/will be

produced or utilised by the installation can generally be categorised under the following groupings:

A comprehensive list of all of materials produced or utilised at Dairygold Mallow under each

category are provided in Tables G.1 (i) and G.1(ii) of the IEL Application form. Details of Risk Phases,

Safety Phases and Hazard Statements are also provided.

Food Grade Raw Material Inputs

With the exception of vegetation oil which is required for in the production of fat filled powder milk,

there will be no changes in the types of raw materials currently used on site.

Products

The products to be manufactured at Dairygold Mallow will continue to comprise milk powders,

including whole milk powders (instant, 26%, 28%), skim milk powders, and blended milk powders. It is

being proposed that fat filled powders will also be manufactured on site in addition to the current range

of milk powder products. Surplus cream will also continue to be produced on-site as a saleable by-

product.

In addition the improved plant and technologies would also facilitate speciality dairy ingredients to

be manufactured on site.

Chemicals

There will be no change to the range of chemicals and detergents currently utilised on site for cleaning,

water treatment and wastewater treatment processes.

Fuels/Lubricants

There will be no changes to the types of fuel inputs or lubricants currently utilised on site.

REF CODE MATERIAL CATEGORY

ING Ingredients (Food Grade Raw Material Inputs)

PD Products

WTC Water Treatment Chemicals

CC Cleaning Chemicals

BTC Boiler Treatment Chemicals

ETP Effluent Treatment Plant Chemicals

CTC Cooling Tower Chemicals

F/L Fuels and Lubricants

PG Process Gases

RG Refrigeration Gases

LC Laboratory Chemicals

PM Packaging Materials

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Gases

Gases currently used on site will continue to be utilised. In addition, Nitrogen gas and CO2 will be used

in packaging of finished products.

Packaging Materials

There will be no changes to the types of packing materials currently utilised on site.

G.2 Energy Efficiency

G.2.1 Energy Consumption

Approximately eight percent (80%) of the installations energy requirement is thermal energy to

generate hot water and produce steam/heat for process operations (e.g pasteurisation, evaporation

and milk drying) and for cleaning purposes. The remaining twenty percent (20%) is electrical energy

to drive processing machinery (pumps, conveyors etc), refrigeration, compressor air and lighting.

The installations thermal energy requirement is currently produced on-site by three (3) direct gas

fired boilers and a waste heat boiler which forms part of a CHP (Combined Heat and Power) plant.

The CHP plant also supplies some electrical energy to the installation in parallel with the ESB national

grid.

There is sufficient boiler capacity on-site to meet future process steam demand and so no additional

boiler plant is required as part of the proposed installation redevelopment. However, it is being

proposed that two (2) new additional gas fired air heaters will be installed to supply process heat to

the two (2) new spray dryers.

The installation currently uses natural gas and electricity as energy inputs. Diesel oil can used as a back-

up for the on-site boilers in the event of an interruption to the gas supply. There will be no changes to

these types of energy inputs. The installations current and predicted future annual average energy

demand and corresponding supply sources are indicated below.

Site Energy Consumption and Source Supply

ENERGY SOURCE UNITS Current Future

Natural Gas MWH 71,752 514,000

Electricity* MWH 7,282 62,000

TOTAL MWH 79,034 576,000 *includes imported and CHP generated electricity

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G.2.2 Energy Efficiency Measures

The following energy efficient measures are being implemented as part of the development:

The installation will use clean natural gas fuel for steam generation and drying processes.

The CHP boiler will continue to operate as the main boiler with additional demand being met

by Boiler No 1. Boilers No 2 and 3 will only be used as back-up. Combined Heat and Power

(CHP) is a highly fuel-efficient energy technology. The CHP process also supplies some of

the facility’s electricity. By using the heat and the electricity, the natural gas is used in the

most efficient manner.

Each of the boilers on the Mallow site has an economiser. An economiser is a heat

exchanger which uses the heat from the exhaust gases to preheat the feed water to the

boiler.

Load management measures, including optimal matching of boiler size and boiler load to

production requirements, is undertaken daily.

It is being proposed to use gas fired air heaters to supply process heat to the new spray

dryers in favour of steam. The gas air heaters have an operating energy efficiency of 90%

versus 75% of the CHP. The estimated energy savings to be achieved for each gas heater is

outlined below.

Gas Heater- Estimated Energy & CO2 Emissions Saving

Description Quantity Units

Energy Saving 1222 (kW)

Amount of Steam Saved Per Hour 2.274 (T/h)

Annual Production Run Time for Dryer 5,000 (h)

Estimated Steam Saving Per Year 11,370 (T)

Amount of CO2 Saving 1,478 (T)

It is proposed to install heat recovery systems on the exhaust air streams from each of the

new spray dryers. The heat recovery system will recover high-temperature exhaust air from

the spray dryer to pre-heat the air intake to the spray dryer enabling the main heater to

operate with a lower energy consumption and avoid using more energy than needed for

heating. The estimated energy savings to be achieved using these heat recovery systems is

outlined below

Gas Booster Heater- Estimated Energy & CO2 Emissions

Description Data Units

Dryer Exhaust Heat Recovery Energy Saving Estimate 934 (kW)

Input Energy Required @ 90% Burner η 1,038 (kW)

Amount Of Natural Gas Saved. 98 (Nm³)

Amount Of Natural Gas Saved In MJ 3,736 (MJ)

Amount Of Natural Gas Saved In Therms 35 (Therms)

Amount Of Natural Gas Saved Per Annum 177,062 (Therms)

Amount of CO2 Saving Per Annum 990 (T)

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Page 4 of 4

Multiple-effect evaporators will be used. The vapours from one effect are utilised as a heating medium in the following effect. Thus the total energy consumption is considerably reduced.

Chemical treatment of the process water systems will prevent scaling and damage

to pipework and thus ensuring efficiency of the system

The compressors will be fully automated and use line pressure control systems to monitor

demand.

All motors will be IE3 Motor efficiency where appropriate.

It is proposed to recover and re-use process condensate where possible to minimise clean

water usage. This will subsequently avoid using more energy than is needed as it minimises

the need for pumping of clean water and reduces the overall volume of wastewater

requiring treatment.

Automatic blowdown units controlled by conductivity/TDS meter will be installed on the

Cooling towers to reduce unnecessary wastewater discharges, and subsequent energy used

in pumping and treatment.

Where feasible, LED lighting will be used throughout the installation. LEDs are currently considered to be the most energy efficient light bulbs available.

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Industrial Emissions Review Application – Dairygold Mallow P0403-02 Attachment No. H.1

ATTACHMENT No H.1: Raw Materials, Intermediates, Product Handling

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H.1 Raw Materials, Intermediates and Product Handling

The range of materials onsite can be categorised as follows:

Food Grade Raw materials

Intermediates and Finished Products

Chemicals

Fuels

The handling, storage and internal distribution of each category of material is described in the

following sections.

H.1.1 Food Grade Raw Materials

Food Grade Raw Materials handled on onsite comprise both liquid and dry materials. All raw liquid

and bulk dry food grade materials will be stored in a number of dedicated silos and tanks. The

locations of Tanks and Silos is provided on Drawing No. 3.

The transfer of materials from the storage silos and tanks to processing will be conveyed by

overground piping systems. Cross contamination between the environment and the conveyed

material is eliminated since the conveying systems are closed.

Other dry food grade material inputs are typically delivered in bagged packaging and these will be

stored on pallets in dedicated material storage areas and manually transferred to the production

processes as required.

All liquid storage tanks and silo will be suitably bunded to prevent pollution risks of any

spills/leakages. This is a redevelopment of an existing facility with all bunding and containment

structures to be constructed in line with the EPA’s Guidance Note for Storage and Transfer of

Materials for Scheduled Activities. Bunds will be 110% of largest tank or 25% of total volume of

silos. All such newly installed silos and tanks, constructed containment structures, and material

transfer systems will be tested in accordance with EPA Guidance. This will include routine visual

inspection of bunds and overground pipelines and bund and tank integrity testing to be undertaken

every three years.

H.1.2 Intermediates and Finished Products

All intermediate products will be stored in a number of dedicated tanks. The transfer of

intermediates for processing will be conveyed via a network of above ground pipelines.

All intermediates storage tanks and silos will be suitably bunded to prevent pollution risks of any

spills/leakages. This is a new redevelopment of an existing facility with all bunding and containment

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Page 2 of 3

structures being constructed in line with the EPA’s Guidance Note for Storage and Transfer of

Materials for Scheduled Activities. Bunds will be 110% of largest tank or 25% of total volume of

silos. All such newly installed silos and tanks, constructed containment structures, and material

transfer systems will be tested in accordance with EPA Guidance. This will include routine visual

inspection of bunds and overground pipelines and bund and tank integrity testing to be undertaken

every three years.

Finished milk powder products will be temporary stored in bulk powder storage silos which will be

enclosed within the dryer building (Building No. 70). The location is provided on Drawing No. 3.

Packaged milk powders will be stored in the dedicated palletised milk powder storage building prior

to dispatch (Building No. 05). The location is provided on Drawing No. 3.

H.1.3 Chemicals

All chemicals and chemical cleaning mixtures held on site will be stored in dedicated containers or

storage tanks which will be suitably bunded to retain the contents in the event of a spill/leak.

All chemicals will be segregated according to their individual properties and stored appropriately.

Large volumes of incoming chemicals will be stored in a dedicated bulk chemical storage bund

(Storage bund 17). A number of individual cleaning in place (CIP) storage tanks will be stored in

bunds located adjacent to their associated processes. These include raw milk CIP tanks (Storage

bunds 30) pasteuriser milk CIP tanks (Storage bund 31) and pasteurised milk CIP tanks (Storage bund

33). The locations of the bulk chemical storage tanks and CIP storage tanks are shown on Drawing

No. 3.

Transfers from the bulk chemical storage tanks to the CIP tanks will be via a network of above

ground pipelines.

This is a new redevelopment of an existing facility with all bunding and containment structures being

constructed in line with the EPA’s Guidance Note for Storage and Transfer of Materials for Scheduled

Activities. Bunds will be 110% of largest tank or 25% of total volume of silos. All such newly

installed tanks, constructed containment structures, and material transfer systems will be tested in

accordance with EPA Guidance. This will include routine visual inspection of bunds and overground

pipelines and bund and tank integrity testing to be undertaken every three years.

Any smaller quantities of chemicals to be used on site will be stored in close to their points of uses.

These chemicals will be stored on suitable self contained bunds or spill trays.

WWTP chemicals will be stored at the WWTP. These chemicals will be stored on suitable self

contained bunds.

Laboratory reagents will be stored in the Lab/Admin Building.

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Page 3 of 3

Empty chemical drums or IBCs requiring disposal will be stored within a designated area of the site suitable for the storage of these containers. Refer to Drawing No. 14.

H.1.4 Fuels

The primary fuel in use the installation is natural gas which is piped to the site gas compound. The

location of the gas compound is shown on Drawing No. 3.

Diesel is held on site as a back-up boiler fuel. This will be stored in a dedicated diesel storage tank

(Storage tank No. 36) located in proximity to the boiler house and will be suitably bunded in line with

the EPA’s Guidance Note for Storage and Transfer of Materials for Scheduled Activities. The location

of the diesel storage tank is shown on Drawing No. 3.

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ATTACHMENT No H.2: WASTE PREVENTION

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H.2: WASTE PREVENTION

The measures to prevent and minimise the generation of waste by site activities are described in the

following sections. The installation currently has not participated in any projects under the National

Waste Prevention Programme.

Production wastes

Production waste largely relate to waste powders and wastewater treatment plant sludge. The

newly upgraded installation will ensure that processes are designed and operated to prevent, or

minimize, the quantities of wastes generates. Key strategies employed at Dairygold Mallow for

waste prevention and minimisation include:

prevent spillages

automate CIP systems

maintain equipment

monitor processes (alarms)

waste management program

staff training

Good housekeeping, operating and maintenance practices will be implemented to reduce the

amount of waste resulting from materials that are out-of-date, off-specification, contaminated, or

damaged.

Packaging Wastes

The procurement of food grade raw material inputs and chemicals are generally in bulk. By bulk

procurement, the generation of small-sized containers and packaging is largely avoided and thus

minimises the generation of unnecessary waste requiring recycling of disposal.

In the procurement of materials, opportunities to use suppliers facilitating return of usable materials

such as containers and other packaging materials will be availed of.

Operating Wastes

The application of cleaning chemicals and water will be optimised by the modified CIP system

resulting in reduced usage of chemicals and water inputs. This will subsequently reduce the volumes

of wastewater requiring treatment and indirectly minimises the generation of unnecessary waste

sludge.

Fluorescent light bulbs

Where possible it is planned that LED lighting will be used in the installation. LEDs are currently

considered to be the most efficient light bulbs available and have a lifespan of approximately twice

that of fluorescent lighting therefore minimising bulb replacement and subsequently waste bulbs

disposals.

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ATTACHMENT No H.3: Recovery/Disposal Of Wastes Generated

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H.3 RECOVERY/DISPOSAL OF WASTES GENERATED AT THE INSTALLATION

The waste types generated by the installation can generally be categorised under the following

headings:

Production wastes (waste powders, wastewater treatment plant sludge)

Packaging Wastes (product packaging, pallets, drums and containers)

General Municipal Waste (office and canteen)

Maintenance Wastes (oils, filters, cloths etc)

Fluorescent light bulbs

Laboratory wastes (spent chemical vials, reagents, glassware)

Table H.3(i) outlines the recovery and disposal routes for waste generated at Dairygold Mallow.

Drawing No. 14 indicates the locations on-site where wastes generated by the site are temporary

stored prior to removal off site. Empty chemical drums/containers and waste materials temporarily

stored outside of buildings will be stored on an impervious surface and within a suitably secure bund.

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TABLE H.3(i): Generation of waste at the installation and its management

Waste description EWC Code

(use asterisk

to indicate

whether

hazardous

waste or not)

Category per

Animal By-

products

Regulation

1069/2009

Source of waste Quantity

generated

(tonnes per

month)

Location of

recovery of

disposal (on-site,

off-site,

exported)

Method of

recovery or

disposal (e.g.

recycling, energy

recovery, other

incineration,

landfill)

Mixed Municipal Waste 20 03 01 n/a Site offices and

canteen

4 Off site in

Ireland

D1

Paper and cardboard packaging 15 01 01 n/a Incoming goods 7 Off site in

Ireland

R5

Plastic packaging 15 01 02 n/a Incoming/outgoing

goods

1.5 Off site in

Ireland

R5

Wooden Packaging 15 01 03 n/a Broken storage

pallets

1 Off site in

Ireland

R5

Fluorescent tubes

20 01 21* n/a Site lighting 0.02 Off site in

Ireland

R4

Waste Electrical and Electronic

Equipment (WEEE)

20 01 21 n/a All sections of the

installation

0.25 Off site in

Ireland

R4

Laboratory chemicals 16 05 06* n/a On-site Laboratory <0.005 Off site abroad D10 /R1

Batteries 16 06 01* n/a All sections of the

installation

<0.005 Off site in

Ireland

Recycling

Synthetic engine, gear and

lubricating oils

13 02 06*

13 02 08*

13 03 08*

n/a Maintenance of site

equipment

0.05 Off site in

Ireland

R9

Degreasing wastes 11 01 13* n/a Maintenance of site

equipment

0.1 Off site in

Ireland

R2

Discarded organic chemicals 16 05 08 * n/a Site boilers 0.2 Off site abroad D10/R1

Absorbents, filters, wiping cloths 15 02 02* n/a Utilities &

Maintenance, Oil

filters, air filters,

0.03 Off site in

Ireland

R1

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Waste description EWC Code

(use asterisk

to indicate

whether

hazardous

waste or not)

Category per

Animal By-

products

Regulation

1069/2009

Source of waste Quantity

generated

(tonnes per

month)

Location of

recovery of

disposal (on-site,

off-site,

exported)

Method of

recovery or

disposal (e.g.

recycling, energy

recovery, other

incineration,

landfill)

Protective clothing

15 02 03 n/a Production activities 0.025 Off site in

Ireland

D1

Chemical plastic drum/IBC

containers /Lubricating oil Metal

drums

15 01 10* n/a Utilities &

Maintenance

- Off site in

Ireland

Recycling –

returned to

supplier for re-

use

Powder tailings / waste powder 02 05 01 n/a Production/

manufacturing

0.1 Off site in

Ireland

D1

sludges from on-site effluent

treatment

02 05 02 n/a On-site wastewater

treatment plant

15 Off site in

Ireland

R10

biodegradable kitchen and

canteen waste

20 01 08

n/a Personnel Food waste 0.1 Off site in

Ireland

D1

glass 20 01 02 n/a Laboratory

glassware, canteen

- Off site in

Ireland

Recycling

mixtures of wastes from grit

chambers and oil/water

separators

13 05 08* n/a Petrol interceptors unknown Off site in

Ireland

Recycling

oil from oil/water separators

13 05 06* n/a Petrol interceptors Unknown Off site in

Ireland

Recycling

solids from grit chambers and

oil/water separators

13 05 01* n/a Petrol interceptors Unknown Off site in

Ireland

Recycling

oily water from oil/water

separators

13 05 07* n/a Petrol interceptors unknown Off site in

Ireland

Recycling

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ATTACHMENT NO H.4: WASTE HIERARCHY

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H.4 Waste hierarchy

In accordance with the waste hierarchy in Council Directive 98/2008/EC on waste and section 21A of

the Waste Management Act 1996, as amended, waste production is avoided through planning and

management of activities and in particular through the handling of raw materials.

Materials are managed in bulk storage silos and piped to processing areas as required. This bulk

handling of materials prevents unnecessary waste. Operation of the Dairygold facility results in the

generation of hazardous and nonhazardous wastes and these are managed in line with the waste

hierarchy (beyond prevention). Wastes produced on site are segregated at source and every effort is

made to divert from landfill through re-use and recovery. Mixed waste from the canteen and some

laboratory chemical wastes must be disposed of. However most waste streams are recovered.

Refer to TABLE H.3(i): Generation of waste at the installation and its management

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ATTACHMENT NO H.5: Waste Recycling And Recovery

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H.5 WASTE RECYCLING AND RECOVERY

H.5.1 Describe how the activities at the installation contribute to national targets for the

recycling and recovery of waste

Through site waste management procedures, Dairygold diverts waste for recycling and recovery,

which contributes to national recycling and recovery targets. All wastes onsite are segregated and

the appropriate waste streams for recycling and recovery are diverted accordingly.

Waste packaging is segregated as paper and cardboard, plastic, and wooden packaging, and all

streams are recycled. Adherence to the packaging regulations results in recycling of waste packaging

in line with the national rate.

Dairygold also arrange for the recycling of fluorescent tubes and of chemical packaging i.e. empty

drums and IBCs, by returning these to the supplier so that they may be reused within industry.

Synthetic oils and degreasing wastes from maintenance activities are also segregated and

reclaimed/regenerated.

Where feasible, as part of the current site redevelopment works, concrete from the demolition will

be crushed and graded and retained on site as fill material under formation levels of new structures.

It is also proposed to maximise the segregation of domestic recyclables and organic waste generated

by the installation. This would result in a decreased quantity of waste requiring disposal at landfill

within the Region.

Refer to TABLE H.3(i): Generation of waste at the installation and its management

H.5.2 State whether and describe how food waste will be managed in accordance with the

requirements, as may be relevant, of the Waste Management (Food Waste) Regulations

2009.

The Waste Management (Food Waste) Regulations 2009 do not apply to the installation. The

canteen facility at the Dairygold Mallow installation will only provide suitable and sufficient facilities

for persons at work to avail of a seated eating area, obtain a hot drink, and a means for heating their

own food. Food will not be supplied to employees or prepared on the premises.

Segregation of employee food waste and recyclable refuse will however be promoted. It is proposed

that segregated waste receptacles (food, dry recyclables, non recyclables) will be provided in the

canteen so that any food waste generated by employees can be placed into a dedicated bin and a

brown bin collection service will be used so that the collected food waste is subsequently recycled

by composting or by other approved recycling process and not disposed via landfill. Similarly, a

recycling waste collection service will be used so that dry recyclable refuse is not disposed via

landfill.

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Industrial Emissions Review Application – Dairygold Mallow P0403-02 Attachment No. I.1

ATTACHMENT No I.1: ASSESSMENT OF ATMOSPHERIC EMISSIONS

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Page 1 of 7

I.1.1 Describe the existing environment in terms of air quality with particular reference to ambient

air quality standards.

The site of the Dairygold installation at Mallow is industrial and urban in character. The site is

surrounded by residential, commercial and office buildings typical of an urban environment. The

predominant road networks are the N20 National Primary Road, and a number of inter-urban road

networks which envelop the site. Principal sources of emissions to the atmosphere from the

Dairygold Mallow installation include the on-site boilers and CHP plant and dryer exhaust stacks.

The existing air quality environment is principally defined by traffic from the N20 and local road

networks. Emission sources from the Dairygold Mallow installation, along with fuel combustion for

space heating for other commercial activities and residential developments also contributed to the

ambient air quality, principally in terms of Nitrogen Oxides, Sulphur Dioxide, and PM10.

EU Legislation on Air Quality requires Member States to divide their country into 4 zones (A-D), for

the purpose of air quality monitoring, reporting, assessment and management. Outside of the Dublin

and Conurbation and towns with populations greater than 15,000 the remainder of the country is

within Zone D. Mallow is within the Zone D (small town/rural) air quality zone classification.

Representative air quality data for Zone D locations in Ireland indicate air quality as good.

I.1.2 Statement as to whether or not emissions of main polluting substances (as defined in the

Schedule of EPA (Industrial Emissions)(Licensing) Regulations 2013, S.I. No. 137 of 2013) to

the atmosphere are likely to impair the environment.

Emissions of main polluting substances (as defined in the Schedule of EPA (Industrial

Emissions)(Licensing) Regulations 2013, S.I. No. 137 of 2013) to the atmosphere by the installation

include:

1. Sulphur dioxide and other sulphur compounds

2. Oxides of nitrogen and other nitrogen compounds

3. Carbon Monoxide

4. Dust including fine particulate matter

Emissions from the installation will lead to an increase in ambient concentrations of these

pollutants. The predicted increases in the concentrations of these pollutants, in combination with

ambient levels, are below the relevant National Air Quality Standards (NAQS) specified in the Air

Quality Standards Regulations 2011 (SI: No 180 of 2011). Consequently it is considered that the

emissions to air will not have a significant negative effect on the environment.

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I.1.3 Summary details and assessment of the impacts of existing or proposed emissions on the

environment

As part of the environmental impact assessment (EIS) prepared for the planning application, an

air quality impact assessment of the proposed expansion development on local air quality was

undertaken (Refer to EIS Volume 2 Chapter 8 and Volume 3 Appendix 8). The detailed study

examined the ‘No Development’ and ‘With Development’ operational scenarios using air quality

dispersion modelling software.

The ‘No Development’ scenario examined the impact of emissions from the existing boiler stacks

and particulate emissions from the existing Niro Dryer on local air quality.

The ‘With Development’ scenario examined the air quality impact of atmospheric emissions

from the two new dryers and thermoheaters in addition to the existing boilers and Niro Dryer.

The predicted impacts due to emissions of Nitrogen Oxides (as NO2) and Sulphur Dioxide (SO2)

from the exhaust stacks of the boilers and Particulates (as PM10) emissions from the Dryer

exhaust stacks were examined in relation to compliance with the relevant National Air Quality

Standards (NAQS) specified in the Air Quality Standards Regulations 2011 (SI: No 180 of 2011).

Table I.1.1 gives the maximum ground level concentrations of NO2, SO2 predicted beyond the

boundary of the Dairygold Mallow facility for the ‘No Development’ and ‘With Development’ boiler

plant operational scenarios.

The predicted hourly and annual NO2 ground level concentrations are calculated for the ‘total’

(facility emissions + background) air quality impact. This is based on the contribution from the boiler

emissions and an existing annual background NO2 level of 14 μg/m3 in the locality.

The highest hourly 99.8% concentration beyond the site boundary increases from 21% of the NAQS

for the ‘No Development’ to 24% of the NAQS based on the ‘With Development’ maximum emission

scenarios. The change in the predicted annual average concentration is very small and in the order

of 5% increase, with the ‘With Development’ annual level 55% of the NAQS, including a background

concentration. The increase arises due to the emissions of the 2 new thermoheaters that will be

installed with an increase in ground level concentrations close to the facility boundary.

The predicted maximum 99.8 percentile of hourly concentrations is 24% of the hourly NAQS based

on boiler and thermoheater emissions for the proposed Dryer expansion development with a small

increase in ambient levels near the boundary. Similarly, there is a small increase in the annual

concentrations near the boundary. However, this predicted increase in hourly and annual NO2

concentrations is insignificant compared to the NAQS limit values.

The predicted SO2 hourly and daily concentrations based on maximum emissions arising from the

boiler operational scenario where gasoil is being burnt due to unavailability of natural gas are

very low and less than 5% of the hourly and daily NAQS. This grade of oil has a sulphur content of

0.1% by weight of fuel burnt so even with two boilers running to meet production steam

demand; the resulting SO2 emissions will have a negligible impact on local air quality. When the

predicted levels due to emissions from the facility are added to a derived background

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Page 3 of 7

concentration of twice the annual average of 5μg/m3, the total impact is 7% of the hourly and

14% of the daily NAQS.

Table I.1.1 1

Table I.1.2 gives the maximum predicted daily and annual concentrations due to emissions from

the dryer stacks and the ‘total’ (facility emissions + background concentration), along with the

percentage compliance with the NAQS values. The predicted 90.4% of daily concentrations are

32% and 46% of the daily NAQS value for the ‘No Development’ and ‘With Development’

emission scenarios respectively. The ‘total’ air quality impact of the proposed development, with

the inclusion of the annual background concentration of 18μg/m3, results in a daily

concentration of 82% of the NAQS and an annual average 63% of the NAQS. The predicted

change in air quality impact due to the addition of 2 dryers to the existing Niro Dryer and PM

emissions from the exhaust stacks will be small with a 20% increase in the predicted ‘total’ daily

90.4 percentile and 14% in the annual average.

Table I.1.22

1 Source: EIS Vol 2 Chapter 8 Table 8.7

2 Source: EIS Vol 2 Chapter 8 Table 8.8

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Page 4 of 7

These modelled results are based on a conservative approach, where all the PM is emitted as PM10

size material, at a concentration in the flue gas of 50 mg/Nm3 from the existing Dryer stack and at

20 mg/Nm3 from the planned two Dryers. Actual emissions are likely to be substantially lower. Each

of the Dryers is also assumed to be operating at maximum output on a continuous basis throughout

the year, whereas no production currently takes place during the winter months. The results

demonstrate that for both the ‘No Development’ and ‘With Development’ scenarios that the daily

90.4 percentile and annual average are below the NAQS limit values.

Overall, the results of the modelling study demonstrate that there will be no significant impact on the

health of the local community or surrounding environment due to the projected change in the boiler

and Dryer stack emissions occurring as a result of the Dryer expansion programme at the Dairygold

Mallow facility.

I.1.4 Details of dispersion modelling of atmospheric emissions from the activity

I.1.4.1 Introduction

The ADMS4 (Atmospheric Dispersion Modelling System Version 4.2, February 2010) air quality

dispersion model was used to predict ground level concentrations within 0.75km of the facility

boundary. This is an advanced air quality model that is suitable for modelling complex industrial

sources with buildings and numerous emission sources and is approved for use by the Environmental

Protection Agency in Ireland. The ADMS4 model has been developed by CERC (Cambridge

Environmental Research Consultants) and is a third generation prediction model. It has been used

for air pollution studies worldwide and the modelling software has been approved by the

Environmental Protection Agency for IPPC applications. The ADMS4 model takes account of the

substantially improved understanding of the plume dispersion within the atmospheric boundary

layer by the use of more complex parameterisation, than used in previous generation models. It uses

boundary layer theory based on the Monin-Obukhov length and boundary layer height instead of the

categories of atmospheric stability

I.1.4.2 Model Input Parameters

Emission Source Characteristics

Data relating to the stack height and exit diameter, exit velocity and temperature with the NOx and

SO2 emissions for each of the boilers and PM emissions from the dryer stacks were input into the

model. The emission rates for these pollutant parameters are based on continuous maximum

emissions for each exhaust stack. No daily or seasonal variation in the operational conditions for the

boilers was applied and so the emission rates represent a ‘worst-case’ air dispersion modelling

scenario for predicting ground level concentrations of NOx and SO2 for both the ‘No Development’

and ‘With Development’ plant scenarios.

Maximum continuous daily operation of the dryer plant was also assumed in calculating the daily

average PM emission rates from the dryer stacks. However, for each of the dryers there will be

occasions during the year when one or more are not in production and so particulate emissions will

be zero. The daily variation in the number of hours of production was also not included and so the

PM (expressed as PM10 in the model) was based on maximum output.

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Building Wake Effects

The effect of buildings on the dispersion of emission plumes from nearby stacks can have a

significant effect on predicted downwind ground level concentrations, under certain weather

conditions. The presence of a building creates turbulence around the structure, which may result in

the emission plume being caught in this area of turbulence. This zone consists of a recirculating flow

region or cavity near the building with a diminishing turbulent wake further downwind. The emission

plume entrained in the cavity region will be brought down to ground level near the building and so

this will result in a significant increase in predicted ground level concentrations.

Buildings that are more than 30% of the stack heights being modelled should be included in the

ADMS4 model as these can contribute to building wake effects on plume dispersal from an exhaust

stack. An assessment of the existing buildings layout and proposed redevelopment of the dryer

building area to house the new dryer plant was undertaken based on digital site plans and elevations

of the various buildings. There are a number of building structures within the site, which are used for

production and storage, along with tanks and other miscellaneous smaller buildings such as the

boiler building. The 4 boilers are housed within a building, which has a roof height of 5.5m and the 4

exhaust stacks are located on the roof of this building. In the case of the Boiler No 1, 2 and 3 stacks

which are over 33m high the roof of the boiler building is well below 30% of these stacks and so will

not contribute to significant wake effects on the plume dispersion. However, the CHP stack is much

lower at 18.8m and the boiler building may have a marginal effect on plume dispersion and so was

included in the dispersion model.

The dominant building affecting the emission plume from the existing dryer exhaust stack and

thermoheater stack is the dryer building and evaporator building structure with an overall maximum

height of 32m. With the proposed redevelopment of this part of the site to construct the buildings

for the new dryers the maximum height will increase to 39-40m. Dimensions of the main building

structures are as follows with each structure aligned with the side identified as ‘Length’ orientated

approximately along a N-S axis.

Existing Dryer Building – Height 31.7m, Length 19m, Width 38m

New Dryer Building – Height 39.6m, Length 38m, Width 45m

New Evaporator Building – Height 29m, Length 17m, Width 40m

Packaging/Storage Building – Height 16m, Length 19m, Width 25m

Storage Building – Height 16m, Length 130m, Width 45m

Climatological Data Sequential hourly climatological data from the meteorological station at Cork Airport (35km to SE)

were used in predicting the ground level concentrations of the various pollutants in the locality of

the Dairygold Mallow facility. A two-year period of hourly climatological data (2005 and 2006) from

this station was used. In addition, climatological data for 2006 from Shannon Airport (60km to N)

were also included in the 3-year data-set as Mallow is further inland and at a lower altitude of 50m

OD than Cork Airport (154m OD) and so will also tend to reflect overall wind conditions across the

North Cork area . Therefore, it was considered that a combination of these two sets of climatological

data would be indicative of the wind field pattern throughout the year for the Mallow area. This

would provide a data-set for evaluating the direction and rate of dilution of the boiler and process

stack emission plumes from the Dairygold facility using the ADMS4 model.

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The year-to-year variations in wind speed and direction were taken into account in the modelling by using the three data-sets; instead of relying on predicted concentration results based on a single year. Input parameters for wind speed, direction, cloud cover and air temperature provided values to

enable the degree of atmospheric turbulence, or stability within the lower air layers to be calculated.

Atmospheric instability occurs due to heating of the ground by solar radiation and this is related to

the amount of cloud cover, coupled with the solar inclination, which is a function of the time of year.

These parameters are computed by the ADMS4 dispersion model.

Surface Roughness

The vertical wind profile above the ground is an important parameter in determining the structure of

the atmospheric boundary layer near the ground. The Monin-Obukhov length provides a measure of

the relative importance of buoyancy generated by heating of the ground and mechanical mixing

generated by the frictional effect of the earth’s surface. This frictional effect is related both to the

surface roughness length and wind speed. The former parameter is supplied as input to the ADMS4

dispersion model and it can vary from 0.001m over open sea to 1.5m in urban areas. It is used in

calculating the boundary layer structure, which determines the rate of dispersion of an emission

plume both in the horizontal and vertical plane as the plume travels downwind from the stack. A

surface roughness length value of 0.5m, which approximates to surfaces within suburban/parkland

areas, was used in the ADMS4 model to represent conditions in Mallow.

Receptor Grid

A receptor grid with regular spacing of 2,500 receptor points (50x50 grid) was used to predict ground

level concentrations within the locality. The grid covered an area of 1.2 x 0.9 km around the site with

a grid reference of 154800E, 098200N for the SW corner and extending to 156000E, 099600N at the

NE corner of the grid. This area is where the maximum ground level impact of emissions from the

Dairygold manufacturing plant is likely to occur, due to the effects of building wake turbulence as

the plume disperses downwind of the site.

Terrain

The surrounding terrain is flat or gently undulating in the locality, with a low slope gradient and so a

flat terrain was assumed for the modelling runs. The terrain module in the ADMS4 is generally for

assessing the impact of dispersion of the emission plume along slopes of greater than 1:10 and so

the local terrain profile did not require this additional refinement in the model.

NOx and NO2 modelling

As the emission plumes from the boiler stacks disperse downwind, the nitric oxide (NO) component

emitted is partially converted to NO2. The rate at which this conversion takes place varies with the

degree of solar insolation present and the atmospheric instability conditions and so changes

throughout the day and over the year. The conversion rate of NO to NO2 is generally limited by the

level of ozone present. This is normally at a maximum value during the summer, with strong

sunshine forming convective cells near the ground resulting in unstable flow conditions.

The ADMS4 model incorporates the reactions between ozone, NO and NO2 using the simple

reaction, which is based on the chemical reactions between ozone, NO and NO2. This scheme takes

account of the photo-chemical reactions, in the conversion process of NO to NO2 within the

emission plume, based on solar radiation and travel time of the pollutant between the emission

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Page 7 of 7

source and receptor locations. Background concentrations of ozone and NOx are used to initialise

the chemistry scheme in the ADMS4 model. An annual average level for NOx of 30 μg/m3 and 14

μg/m3 for NO2 was used as background concentrations appropriate for Mallow. An annual average

ozone concentration of 44 μg/m3 was used in the model, based on results from an EPA monitoring

site at Glashaboy Co. Cork, will be typical of background levels in the North Co. Cork area.

In the absence of any ambient monitoring data for Mallow, concentrations for NO2, SO2 and

PM10 given in Table I.1.3 were used as background values. This allows an estimate to be

calculated of the total or combined impact on local air quality of predicted contribution from

the facility with existing pollutant levels. This combined impact can then be compared with the

NAQS values. The ‘total’ impact is calculated by adding twice the background SO2 concentration

to the predicted hourly 99.7 percentile or daily 99.2 percentile value.

Table I.1.3 Background Concentrations used in Dispersion Model

In relation to combined NO2 impacts, a background annual average value is already included in the

ADMS4 model for NOx and NO2 calculations and so no additional background value is required.

There is no ambient particulate monitoring data for Mallow and so an annual average concentration

of 18 μg/m3 was used as indicative of maximum PM10 concentrations for the town. This value is

based on the median observed concentration of the 7 Zone C and D towns reported by the EPA for

2010 (Air Quality in Ireland 2011). These 7 urban areas include Galway and smaller towns such as

Ennis, Longford and Castlebar. This annual background PM10 concentration allows an estimate to be

calculated of the maximum total or combined impact on local air quality of the predicted PM10

contribution from the facility with existing background levels. The annual average background PM10

level is added to the predicted daily 90.4 percentile daily concentrations from the dryer emissions to

give a ‘total’ concentration that can then be compared with the NAQS value. Similarly, the annual

background concentration is added to the predicted annual level due to the Dryer emissions, to give

the ‘total’ annual PM10 concentration to assess compliance with the annual NAQS.

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ATTACHMENT No I.2: ASSESSMENT OF IMPACT ON RECEIVING SURFACE WATER

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Page 1 of 3

I.2.1 Describe the existing environment in terms of water quality with particular reference to

environmental quality objectives and standards and any objectives and standards laid down

for protected areas. Table I.2(i) should be completed

All process wastewater from the Dairygold Mallow installation discharge into the River Blackwater. The

receiving Blackwater River has a ‘moderate’ water quality status rating under the Water Framework

Directive due to macroinvertebrate and ecological status. The South Western River Basin District

(SWRBD) has set the water quality objective as ’restore to high status by 2021’.

The River Blackwater is a designated Freshwater Pearl Mussel (Margaritifera, margaritifera) site listed in

the first Schedule of the Eurpoean Communities Environmental Objectives (Freshwater Pearl Mussel)

Regulations S.I. No. 296 of 2009 (Pearl Mussel Regulations). There is a requirement for status

improvement to high status by 2015 under these regulations.

I.2.2 Provide a statement whether or not emissions of main polluting substances (as defined in

the Schedule of EPA (Licensing)(Amendment) Regulations 2004, S.I. No. 394 of 2004) to

water are likely to impair the environment.

Emissions of main polluting substances (as defined in the Schedule of EPA (Licensing)(Amendment)

Regulations 2004, S.I. No. 394 of 2004) to water by the installation include:

Materials in suspension;

Substances which contribute to eutrophication (in particular, nitrates and phosphates);

Substances which have an unfavourable influence on the oxygen balance (and can be

measured using parameters such as BOD, COD, etc.)

The emission limit values specified in the current licence were determined with aim of achieving high

status standards specified in the Surface Water Regulations 2009. The wastewater treatment plant

is capable of achieving the required emission limit values. Consequently it is considered that the

emissions to water do not have a significant negative effect on the environment.

I.2.3 Indicate whether or not the activity complies with the requirements of the EC

Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009.

Emissions to Surface Waters from the installation and the capacity of the River Blackwater to receive

effluent from the Dairygold WWTP were reviewed by the Environmental Protection Agency (EPA) in

2011 under the European Communities Environmental Objectives (Surface Water) Regulations 2009

[S.I.No.272 of 2009]. The Agency indicated that regard was had to the requirements of standards or

objectives laid down for protected areas specifically the following:

The European Communities Environmental Objectives (Freshwater Pearl Mussel) Regulations

2009

Habitats and Species of European Sites directly dependant on water

Urban Waste Water Treatment Directive [91/271/EEC]

EC Freshwater Fish Directive [2006/11/EC]

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The outcome of the review was a renewal of the facilitys former licence P0403-01 to P0403-02 with

minor changes to emission limit values (ELVs) for discharges of treated process wastewater from the

existing licensed discharge point (SWD1). As required by the Surface water Regulations 2009, the

emission limit values set out in the revised licence were determined with the aim to achieve high status

in the receiving water body and consequently will contribute to the achievement of a favourable

conservation status for protected areas.

I.2.4 If the discharge is to water body that is already achieving high status, or if the discharge is

to waters draining to the surface water bodies identified under the First Schedule of the EC

Environmental Objectives (Freshwater Pearl Mussel) Regulations 2009, compliance must be

with the 95%ile high status limits.

The emission limit values set out in the revised licence were determined with the aim to achieve high

status in the receiving water body by 2021 and consequently will contribute to the achievement of a

favourable conservation status for protected areas.

I.2.5 Give summary details and an assessment of the impacts of any existing or proposed emissions

on the environment, including environmental media other than those into which the

emissions are to be made.

Surface water features

The Dairygold site consists of two parts, a northern site and a southern site. The milk processing

operations are located on the northern site while the production wells which supply water to the

facility for processing activities and the wastewater treatment plant which treats process

wastewater from the facility are located on the southern site.

Linehans Stream, also referred to as ‘The Hospital Stream’, flows in a southerly direction, partly

underground in a culvert, through the middle of the northern Dairygold property and along the

eastern boundary of the southern site eventually discharging into the River Blackwater. The River

Blackwater flows in an easterly direction approximately 0.5km to the south of the northern site and a

short distance (about 100m) to the south of the southern site.

As part of the environmental impact assessment (EIS) prepared for the planning application, an

assessment of the installations impacts on surface waters was undertaken. Full details of the

assessment and other relevant information on the receiving water environment are

provided in EIS Volume 2 Chapter 6 and Volume 3 Appendix 6

Process wastewater discharges to the River Blackwater

All process wastewaters generated by the installation discharge to the River Blackwater. The

outcome of the assessment on process wastewater emissions indicates that the treated discharges

from the proposed development will continue to comply with the conditions and emission limit

values set out in the current licence. The mass balance assessment undertaken by the EPA in their

Review of the Licence in 2012 predicts the following change in water quality of the River Blackwater

from discharges at ELV as set out in the Licence. This shows slight increases in the background

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Page 3 of 3

downstream concentrations following discharges from the Dairygold WWTP. The predicted

downstream concentrations do not breach water quality standards.

An assessment on the capability of the existing WWTP to treat the predicted future wastewater load

to the ELVs was undertaken as is provided in Volume 3 Appendix 6. This assessment shows that the

additional wastewaters generated by the proposed development will remain well within the

theoretical capacity of the WWTP to meet current licence ELVs, and will not require any adjustment

of the existing licence conditions on wastewater. Therefore the treated discharges from the

proposed development will continue to comply with the conditions of the IPPC licence and

subsequently will not have a significant impact on the status of the River Blackwater. The assessment

however shows that in its current state some refurbishment of the WWTP is required.

Stormwater discharges to Linehans Stream

Currently storm water run-off from the Dairygold Mallow site discharges to the adjacent Linehan’s

(Hospital) Stream at two (2) outfall points licensed under IPPC Licence P0403-02. (SWD2 and SWD3)

As part of the site redevelopment it is proposed to entirely renew the stormwater collection and

discharge system. The installation’s revised stormwater drainage system is shown in Drawing No. 8.

The existing stormwater emission point SWD2 will be retained and emissions to Linehans stream via

this emission point will effectively comprise rainwater only and incorporates roof and ground run-off

from the installation building roofs, paved areas and internal roadways. Under normal operation,

stormwater emissions are not likely to significantly impact on the water quality of Linehan’s stream.

The system will include a full Class 1 Petrol Interceptor and a Divert system, controlled by

Conductivity and pH meters on each outfall. In the unlikely event of a Pollution incident the liquids in

the storm water system will be diverted to the process drains by an overflow system and carried to

the WWTP for treatment when flow rates arriving at the WWTP permit. There is adequate balancing

volume available at the WWTP (4,675 m3) to allow this.

All potential risk areas on site where spills or leaks of potentially polluting materials may occur have

been identified and appropriate control and containment measures have been included in the

design. All product, chemical and fuel tanks are located within bunds. The milk intake area is covered

and the internal milk intake bays drain to the foul water system. The access road from the entrance

to the milk intake area will be protected via the revised stormwater collection system as outlined

above.

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ATTACHMENT No I.3: ASSESSMENT OF IMPACT OF SEWAGE DISCHARGES

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Page 1 of 1

I.3.1 Discharges to Sewer

Currently, wastewater generated on-site from the installation canteen, toilet facilities and laboratory

is collected by a series of on-site foul water sewer lines and connects to the Mallow town public

sewerage system. The average volume of this wastewater stream generated by the installation is

circa 5m3 per day.

As part of a licence review of the Dairygold Mallow installation undertaken by the EPA in 2011/2012,

[to bring the licence into compliance with the EC Environmental Objectives (Surface Waters)

Regulations 2009], a Section 99E request was issued to Cork County Council regarding these

discharges to the municipal sewer. Consent was granted by the local authority on 12th January 2012

for these trade effluent discharges and is provided for by way of Condition 6.13 of the existing licence

which stipulates that trade effluent discharged to the Water Services Authority sewer is limited to

milk wastes (including chemicals used in testing) from sample bottles. A log detailing the chemicals

used in the milk testing procedures and the volume discharged are to be maintained by the licensee

on a daily basis and shall be available for inspection by the Water Services Authority on request.

As is currently permitted, it is proposed that discharges to the municipal sewer will be limited to

wastewaters arising from the installations canteen, toilet facilities and laboratory including milk

wastes (together with chemicals used in testing) from sample bottles. It is anticipated that the

volume of this wastewater stream to be generated by future site activities will increase from 5m3 per

day to approximately 7m3 per day.

I.3.2 Impact of Discharges to Sewer

As has previously been determined by the competent authority, the proposed trade effluent discharges

from Dairygold Mallow will not have an adverse impact on either the receiving sewer or receiving

treatment works. The municipal sewer and downstream treatment plant, into which the effluent

discharges, is designed to take effluents of a wide variety in composition including domestic and non-

domestic sources. The proposed volume increase in discharges from the installation to the municipal

sewer are not significant. The Municipal WWTP in Mallow is currently operating at approximately 75%

of its design capacity (source Inspectors report of 23rd November 2012 on the Waste Water Discharge

Licence Application for Mallow Town and Environs) and therefore would be able to accommodate the

proposed increased load.

I.3.2 Impact of Sewer Discharges

The Municipal WWTP in Mallow discharges into the same waterbody as that of the installation

WWTP, namely the River Blackwater. The Municipal WWTP in Mallow operates under a Wastewater

Discharge Licence (WWDL) (Licence Reg No. D0052-01) issued to Cork County Council by the EPA.

The licence sets out the conditions which control and manage the wastewater discharges from the

WWTP. Therefore an equivalent level of protection of the receiving waterbody is guaranteed.

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