For inspection purposes only. Consent of copyright …Section D Operational Information P0793-03 Newmarket Co-Operative Creameries Ltd. D.1 Operational Information This section outlines

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Section D Operational Information P0793-03

Newmarket Co-Operative Creameries Ltd.

D.1 Operational Information

This section outlines the operations at Newmarket Cooperative Creameries.

D1.1 Plant History and Background

Newmarket Co-Operative Creameries Ltd is located in North West county

Cork servicing the needs of the local farmers since its foundation as a Co-op

in 1944. The facility was acquired by the Kerry Group in 2010 and forms part of

the Kerry Ingredients and Flavours Europe Middle East and Africa (EMEA)

Region.

Before Newmarket Cooperative Creameries was established the Dairy

Disposal Board operated a creamery on the site and before them a

creamery was owned and controlled by private enterprise.

A new creamery predominantly producing butter but also some cheese was

built on the site in 1961. Butter was the main product at this time and with

some cheese also manufactured. It was after this time that cheese became

the main product at the facility, with butter manufacturing ceasing at the

facility in 2005.

There were many improvements and expansion works undertaken at the site

since the 1960’s with the most significant developments taking place at the

facility between 2008 and 2009 developing a state of the art cheese

manufacturing facility to supply markets worldwide.

The developments at the site provided excess processing capacity at the site

which exceeded the milk pool available within Newmarket Cooperative

Creameries and as a result, milk, historically was purchased from other

suppliers for processing at the facility.

D1.2 Process

Milk is collected for processing by private hauliers in stainless steel bulk tankers

from the suppliers in the region. This is organised by Kerry Agri business on an

every other day basis. In addition to locally supplied milk, milk is also collected

and brought to the site from other milk suppliers within the Kerry Group.

On arrival at the facility milk is weighed, sampled, cooled and pumped to a

pre-selected milk silos. There are 7 insulated milk silos at the site and 2

insulated cream silos.

From the silo milk is pumped through filters to the pasteurizer and if required

through the bactofuges and standardising system. Milk is then pumped to the

cheese vat where ingredients are added and curds and whey are formed.

From the cheese vat the curds and whey are pumped to a cheddaring

machine to allow the curds and whey to be separated.

The curd is cheddared, milled and salted and is transported to the block

formers where 20 kilo blocks of cheese are formed. After the block formers the

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cheese is vacuum sealed, metal detected to ensure no metal has entered

the product, boxed and conveyed to the rapid chill area of the plant before

being place in cold storage to allow the cheese to mature before being

dispatched off site.

A schematic of the process is provided in Figure 1.

Figure 1. Cheddar Cheese Processing

D1.2.1 Whey Processing

There are two whey processes, one involves separating the cream from the

whey and the secondary process involves recovery of whey solids. A

schematic of the initial separation process is provided in Figure 2.

The whey is put through a clarifier to recover any fines and is then separated

to recover any remaining fat as cream.

A schematic of the Whey processing at the site is provided below.

Raw Ingredients

Milk Pasteurised, Separation, Bactofuge

Cheese Vats

Alfomatic

(

Curd Blower

Block Formers

Packaging

Chill & Storage Dispatch

Whey Clarifier Whey Separation

Divert Flow

Milk Tanker

Milk Intake

(Weighed, Pumped to Silo, Cooled)

Filter Reject Tank

Starter Module 2 Water Module 4

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Figure 2. Whey & Cream Processing

It is then pasteurised and put through a reverse osmosis plant to concentrate

the solids whey content. The whey is passed through a 40 micron filter before

entering the Reverse Osmosis (RO) membranes to prevent them from being

fouled. The RO plant passes through a bank of 7 membranes before entering

a nano filtration stage.

A polishing system, addition of further membranes was established at the

facility in 2009 which has led to further recovery of product from the reject

stream and improved the quality of the permeate so that it can be

discharged to the waste water treatment plant.

The whey solids recovered as the retentate are recovered and sent for further

processing or storage and dispatched off site.

A schematic of the process is provided in Figure 3.

Whey Storage Tanks

Whey Separators

Raw Cream Tank

Cream Pasteuriser/Cooling

Cream Storage Tanks

Dispatch

Whey (ex Alfomatic)

Clarifier Balance Tank

Whey Clarifier

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Figure 3. Whey Processing

D1.3 Ancillary Services

Steam Boilers

There are two steam raising boilers at the site which supply steam for the

process. The boiler units are run on medium fuel oil and operate on a

lead/standby basis, with one boiler being sufficient to meet the steam

demand at the site.

Water

Water is pumped from a number of deep wells on site to 2 reservoirs, from

where it is supplied for use across the site. In addition to the onsite wells the

facility maintains a supply from the local authority potable water main. All

water is chlorinated via a dosing station prior to storage in the reservoirs.

40 Micron Filters

Nano Filtration (Stage 8)

Concentrate Balance Tank

Concentrate Cooling and Storage

Dispatch

Permeate Recovery

Raw Whey Tanks

Whey Pasteurizer

RO Feed Balance Tank

Permeate to Polisher Permeate to Drain Reverse Osmosis (Stages 1-7)

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Refrigeration System

Refrigeration is a critical utility at the site as much of the product produced at

the site needs to be maintained at low temperatures to prevent spoiling.

Refrigeration is provided in centralised plants in the utilities building and

cheese factory services area. The refrigeration system uses ammonia, R404

and R22 (which is being phased out) as the refrigerants. Refrigeration centres

at the site consist of a number of compressors in succession, expansion vessel,

cooling towers and condensers.

Compressors

Compressed air is used extensively at the site for the operation of valves, filling

and packing machines and numerous other activities such as local cleaning

of equipment.

D1.4 Abatement Equipment

Process Waste Water Treatment

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

Dalua. The treatment methods comprise of activated sludge (biological

treatment) and solid removal through clarification.

The treatment plant comprises the following items:

• Balancing Tank

• Dissolved Air Flotation (DAF) unit

• Biotower

• Aeration ditch

• Anoxic Tank

• Clarifier

• Sand Filtration System

• Sludge holding tank

• Sludge dewatering

• Measurement and sampling station

Process waste waters from processing areas of the site are collected centrally

and conveyed to an underground sump from where they are pumped

forward to two combined balance tanks. The WWTP balance tanks allow

waste streams from the various sections of the plant to be mixed so that a

consistent quality of effluent is pumped forward in the treatment system.

Effluent is pumped from the balance tank to a DAF unit via a forward feed

pump. After the DAF unit, the effluent is pumped to the Biotower for further

BOD reduction. Chemical agents to reduce orthophosphate are added at

this stage. From the biotower water is pumped to an anoxic zone, where the

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water is exposed to an anaerobic environment, in this zone the nitrate is

broken down to nitrite.

Further organic removal occurs in the oxidation ditch, wastewater is then

pumped from the oxidation ditch to a clarifier for removal of solids, the water

is passed through a sand filter before final discharge for additional suspended

solids removal.

Figure 4. Wastewater Treatment Plant

Factory Effluent CIP Effluent

Wastewater Sump

DAF Unit

Balance Tank 1 Balance Tank 2

pH Control

Outfall Chamber & Flow

Meter

Odour Control DAF Sludge Tank

Bio-Tower

Anoxic Tank

Aeration Basin

Clarifier

Sand Filter

Picket Fence Thickener

Sludge Dewatering

Sludge

Water

Odour Control

Key

Odour Control Chemical Dosing

(Phosphorous Removal)

Flow Meter

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The balance tanks, bio-tower and anoxic tank are under negative pressure to

force the air inside the units to an odour treatment system to remove odours

form the air before release.

In addition, the sludge press is located within an enclosed building. The

building is under negative pressure and all air from the building is forced

through a odour treatment system prior to release to atmosphere.

All odour control units at the site are supplied by Bord Na Mona and are the

companies Monashell Product.

D1.5 Surface Water Treatment

A Bypass separator has been installed on the storm water line conveying

water from the car park area of the site. The system is designed to remove

sediments and oil from surface water runoff. The separator installed is a Class

1 Bypass Separator and has been designed and installed in accordance with

the standard IS EN858-2 2003 Separator systems for light liquids (e.g. oil and

petrol). Selection of nominal size, installation, operation and maintenance.

D1.6 Boiler Exhaust Gas Treatment

KIF Newmarket installed a treatment system on both boilers in 2012 to reduce

the particulate content of the flue gas. The water injection system is based on

the addition of small, metered quantities of water in a finely divided form

before atomisation of the oil in the burner.

The water absorbs onto particles in the fuel oil which are then combusted

which vaporise during the normal combustion process resulting in greater

combustion of solids which under normal circumstances are not burned.

The system is run off a centralised water system and each burner is fitted with

an injection unit and injection controller.

This reduces particulate emissions and as a result of combustion of the

formerly unburnt carbon, improves the efficiency of the unit.

In addition, as a result of the improved combustion the rate of soot deposit on

the boiler heat transfer surfaces, which will form an insulating layer, is greatly

reduced. This maintains the designed heat transfer properties for a longer

period and allows the intervals between boiler cleaning to be extended.

D1.7 Emergency Facilities

The facility has an extensive fire protection system at the site with fire

extinguishers available in all areas of the site. The facility provide fire hydrants

on the site for attending fire appliances. The fire hydrants are provided with a

water supply from the local authority and from the onsite storage tanks.

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A fire water retention tank was installed at the facility in 2013 which has been

designed to retain contaminated firewater which arises in the event of an

emergency on the site.

D1.8 Laboratories

There are two separate laboratories at the NCC facility. The Quality

Laboratory is located adjacent the processing building, all testing associated

with product quality is undertaken in this laboratory. No environmental related

analysis is undertaken in this laboratory.

All Environmental analysis is undertaken in the Environmental Laboratory

located at the site WWTP. The Environmental laboratory undertake all water

analysis required by the facilities IPPC Licence, with the exception of BOD,

Oils, fats and Grease and low range orthophosphate which is sent to external

accredited laboratories for analysis.

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Newmarket Cooperative Creamery Ltd IPPC Licence Review Application

IPPC Reg. No. P0793-03

Attachment No D1

Operational Information

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Attachment No D2

Development & Operational History

of the Site

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Attachment D.2 P0793-03


Attachment D.2 – Development & Operational History of the Site

Kerry Group acquired Newmarket Co-operative Creameries Ltd. in October

2010 and the facility now trades as ‘Kerry Ingredients & Flavours EMEA

Newmarket’ (KIF Newmarket) however, Newmarket Cooperative Creameries

Ltd. remains the registered company name under the IPPC licence.

NCC was set up in 1944 as a modern general purpose creamery being

constructed in 1961. Over the years, NCC increasingly specialized in cheese

production with butter production ceasing at the installation in 2005.

The facility made an application to the Agency in 2006 for an IPPC Licence

and the IPPC Licence Registration Number P0793-01 was granted in

September 2009.

Although NCC commenced processing activities at the Newmarket site in

1944 their has been as series of developments at the site since this data, with

the most recent and significant occurring between 2007 and 2009 when the

plant was upgraded to facilitate production of 35,000 tonnes of cheese per

annum at the site. A summary of the developments are provided below.

Date Description

27/09/2010 Retention of a single storey extension to the existing salt room

21/05/2009 Single-storey storage building to rear of exisitng feed store &

associated site works

12/07/2007 Construction of a single storey structure over the existing

loading yard, single storey chill building incorporating a plant

room, single storey desalination building including switchroom,

single storey sludge handling building and associated works

and retention of covered truck wash area

10/6/1998 Extension to offices

21/11/1995 Extension to existing laboratory

20/09/1995 Alterations to Cheddaring Room by increasing the roof height

of the building to facilitate the installation of new process

equipment

17/08/1995 Alterations to Cheddaring Room, including roof height.

03/01/1995 448 cubic metres water storage tank

10/09/1990 Blockformer house roof

25/1/1980 Office building (Administration)

10/07/1979 New Dry Goods Store- Change of Layout

19/04/1979 New Cheese Starter Room

19/04/1979 Wastewater Treatment Plant Biotower

19/04/1979 Boiler House

19/04/1979 Erection of Dry Goods

18/07/1975 Erection of 10Kv Substation

01/07/1975 Erection of Cheese Store

15/04/1975 Extension to Cheese Factory There are no known pollution events or prosecutions at the site. A septic tank

which served the administration building was decommissioned in 2011.

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Attachment No F1

Treatment, Abatement and

Control Systems

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Attachment F.1. P0793-03


Attachment F.1 – Treatment, Abatement and Control Systems

The facility has abatement equipment installed on air and surface water

emission points from the site. These include equipment installed on the boiler

exhaust stacks for reduction of particulates, wastewater treatment for

treatment of wastewater and silt and oil separator for removal of oil and

sediments from surface runoff from the car park area of the site.

F2.1 Boiler Exhaust Gas Treatment

KIF Newmarket installed a treatment system on both boilers in 2012 to reduce

the particulate content of the flue gas. The water injection system is based on

the addition of small, metered quantities of water in a finely divided form

before atomisation of the oil in the burner.

A schematic of the installation is provided below.

The system works on the basis of water absorbing onto particles in the fuel oil

which are then combusted. The water is vaporised during the normal

combustion process resulting in greater combustion of solids which under

normal circumstances are not burned.

The system is run off a centralised water system and each burner is fitted with

an injection unit and injection controller.

The system cleans the exhaust gas and as a result of combustion of the

formerly unburnt carbon, improves the efficiency of the unit.

In addition, as a result of the improved combustion the rate of soot deposit on

the boiler heat transfer surfaces, which will form an insulating layer, is greatly

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reduced. This maintains the designed heat transfer properties for a longer

period and allows the intervals between boiler cleaning to be extended.

The water injection abatement system is not activated when the boilers are

on low fire, but is activated immediately once a load is placed on the boiler.

F2.2 Wastewater Treatment System

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

Dalua. The treatment methods comprise of activated sludge (biological

treatment) and solid removal through clarification and sand filtration.

The treatment plant comprises the following items:

• Balancing Tank

• Dissolved Air Flotation (DAF) unit

• Biotower

• Aeration ditch

• Anoxic Tank

• Clarifier

• Sand Filter

• Sludge holding tank

• Sludge dewatering

• Measurement and sampling station

Process waste waters from processing areas of the site are collected centrally

and conveyed to an underground sump from where they are pumped

forward to two combined balance tanks. The WWTP balance tanks allow

waste streams from the various sections of the plant to be mixed so that a

consistent quality of effluent is pumped forward in the treatment system.

Effluent is pumped from the balance tank to a DAF unit via a forward feed

pump and is dosed with chemical agents to reduce orthophosphate. After

the DAF unit, the water is pumped to the biotower for further BOD reduction.

From the biotower water is pumped to an anoxic zone, where the water is

exposed to an anaerobic environment, in this zone the nitrate is broken down

to nitrite.

Further organic removal occurs in the oxidation ditch, wastewater is then

pumped from the oxidation ditch to clarifiers for removal of solids, the water is

passed through a sand filter before final discharge for additional suspended

solids removal.

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Figure 4. Wastewater Treatment Plant

The balance tanks, bio-tower and anoxic tank are under negative pressure to

force the air inside the units to an odour treatment system to remove odours

form the air before release.

In addition, the sludge press is located within an enclosed building. The

building is under negative pressure and all air from the building is forced

through a odour treatment system prior to release to atmosphere.

Factory Effluent CIP Effluent

Wastewater Sump

DAF Unit

Balance Tank 1 Balance Tank 2

pH Control

Outfall Chamber & Flow

Meter

Odour Control DAF Sludge Tank

Bio-Tower

Anoxic Tank

Aeration Basin

Clarifier

Sand Filter

Picket Fence Thickener

Sludge Dewatering

Sludge

Water

Odour Control

Key

Odour Control Chemical Dosing

(Phosphorous Removal)

Flow Meter

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All odour control units at the site are supplied by Bord Na Mona and are the

companies Monashell Product.

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Attachment No G2

Energy Efficiency

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Attachment G.2. P0793-03


Attachment G.2 – Energy Efficiency

NCC has installed a number of steam and electricity meters at the site in 2012

as part of an energy efficiency programme at the site. The additional

monitors at the site will allow the major centres for energy use to robustly

analysed and accordingly permit energy efficiency initiatives to be

developed from a firm basis. This will allow performance to be reassessed

after improvements have been made.

NCC have a heat transfer system in place for recovering thermal energy from

milk and whey streams at the site, this is based on a number of heat

exchangers at the facility which feeds hot water back to a raw water silo at

the site. The purpose of the silo is to recover heat from pasteurizers and other

such heated processes providing warm water for processes at the site. This

supply of warm water reduces significantly the load placed on the boilers.

Other measures have been undertaken at the facility to improve the

efficiency of the cooling systems, whereby old refrigeration units have been

replaced with modern systems. In addition, the facility installed water injection

technology on the boilers in January 2012 which both reduces particulate

emissions but also improves the efficiency of the boilers.

NCC continue to seek opportunities for more efficient use of energy for

processing operations at the facility.

An energy efficiency audit was undertaken at the facility in 2010.

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Attachment No H1

Raw Materials, Intermediates and

Product Handling

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ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON

AIR QUALITY IMPACT OF SO2 NOX and PM

EMISSIONS FROM THE BOILER STACKS

(IPPC P0793-02 LICENCE REVIEW)

-------- NEWMARKET CO-OPERATIVE

CREAMERIES LTD. SCARTEEN LWR, NEWMARKET

CO. CORK ----------

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: 12 APRIL 2013 Report By: Michael L. Bailey ____________________________________________________________________

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mailto:[email protected]

ENVIROCON LTD., NEWMARKET CO-OP – IPPC LICENCE REVIEW 04/13 1

1.0 INTRODUCTION Newmarket Co-operative Creameries Ltd was issued with an IPPC Licence (Register No. P0793-02) on 1st May 2012 by the Environmental Protection Agency for the dairy production facility in Newmarket. Schedule B of this Licence specifies emission limit values for sulphur dioxide (SO2), nitrogen oxides (NOx) and particulates (PM) for the two boilers stacks A1-1 and A1-2. The emission limit value given in Schedule B for SO2 is 1190 mg/Nm3. Furthermore, Condition 3.14 requires that the fuel oil burnt in the two boilers shall have a sulphur content of less than 0.7% by weight. Arising from the results emission monitoring of the flue gases from the boilers, it was found that both the SO2 and Particulate Matter (PM) emissions exceeded the limit value given in the licence. The proposed emission limit value for SO2 would be revised to 1700 mg/Nm3 with the burning of Medium Fuel Oil (MFO) ( Class F Oil Grade. In addition, the NOx (as NO2) would be revised to 900 mg/Nm3 and the PM concentration increased to 350 mg/Nm3. The facility has recently installed abatement technology for reducing PM emissions from the two boilers. Furthermore, it is requested Condition 3.14 of the licence should be revised such that the limit on the permitted percentage sulphur content of the fuel oil is increased to a maximum of 1% by weight of fuel. The following air quality modelling report has been prepared to support the IPPC Licence Review application of Licence Reg. No. P0793-02 and amend the Schedule B emission limit values, taking into account the proposed changes to the emission concentrations for SO2, NOx and PM. The predicted ground level concentrations of SO2, NO2 and PM in the locality of the Newmarket Co-operative facility are compared with the National Air Quality Standards (NAQS), specified in the Air Quality Standards Regulations 2011 (SI: No 180 of 2011). 2.0 EMISSION SOURCES Fuel consumption and emission data for the two boiler exhaust stacks (A1-1 and A1-2) were supplied by the company (Table 1). The hourly SO2 emission rate for each boiler exhaust stack is given in Table 2. These rates are based on the hourly quantity of Medium Fuel Oil (MFO), also referred to as Class F Oil (British Standard 2869), burnt in each boiler with a maximum sulphur content in the oil of 1.0% by weight. In the case of Boiler No 1, the maximum oil-firing rate is 418 kg/h and for Boiler No 2 it is rated at 423 kg/h. A maximum hourly oil burn rate was used to calculate the emissions from Boiler No 1 stack. This is the primary boiler with supplementary steam demand provided during peak periods by running Boiler No 2. However, to ensure that both boilers are capable of meeting the steam demand for the site at any time the primary boiler can be switched to Boiler 2 if required.

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Table 1 Emission characteristics for each boiler at full load

Stack

( IPPC Licence Designation)

Stack Ht (m)

Diameter (m)

Ref (i) Exhaust Volume (Nm3/h)

Actual Exhaust Volume (Nm3/h)

Exit T.

(oC)

Exit Vel

(m/s)

A1-1 Oil Boiler No 1 25.0 0.58 6,010 7,450 215 14.0 A1-2 Oil Boiler No 2 25.0 0.58 5,700 7,100 270 14.8

Note: (i) Schedule B Reference Conditions of Dry/ 3% O2 exhaust flows (as Nm3/h). Actual exhaust

volume flows are based on O2/moisture conditions in the flue gas of 6% O2 and 3% moisture.

Table 2

SO2, NOx and PM emission estimates from each boiler at full load (g/s)

Stack ( IPPC Licence Designation)

Hourly SO2

Daily SO2

Hourly NOx

Daily PM

A1-1 Oil Boiler No 1 2.32 1.86 1.50 0.46 A1-2 Oil Boiler No 2 2.35 1.88 1.42 0.44

Table 3

Emission characteristics of the boiler stacks at maximum operating load scenario

Stack ( IPPC Licence

Designation)

Stack Ht (m)

Diameter (m)

Ref (i) Exhaust Volume (Nm3/h)

Actual Exhaust Volume (Nm3/h)

Exit T.

(oC)

Exit Vel

(m/s)

A1-1 Oil Boiler No 1 25.0 0.58 6,010 7,450 215 14.0 A1-2 Oil Boiler No 2 25.0 0.58 3,420 4,250 270 9.0

Note: (i) Schedule B Reference Conditions of Dry/ 3% O2 exhaust flows (as Nm3/h). Actual exhaust

volume flows are based on O2/moisture conditions in the flue gas of 6% O2 and 3% moisture.

Table 4

SO2, NOx and PM emission estimates from the boilers at maximum operating load scenario (g/s)

Stack

( IPPC Licence Designation) Hourly

SO2 Daily SO2

Hourly NOx

Daily PM

A1-1 Oil Boiler No 1 2.32 1.86 1.50 0.46 A1-2 Oil Boiler No 2 1.41 1.12 0.86 0.27

However, the maximum hourly steam requirements for the facility can be achieved by running one of the boilers at 100% and the other at 60% load and the hourly emission characteristics for the two boilers in Tables 3 and 4 are based on these loading factors. In the scenario presented in these two tables, Boiler No 1 is operating at full load with Boiler No 2 running at 60% load.

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The daily average SO2 emission rates for the two boilers will be less than the emission rate based on the two boilers operating continuously, due to the variation in steam demand that occurs throughout the day. Estimates obtained from recent boiler demand records indicate that the daily average requirement is typically a maximum of 60-80% of the hourly load, during the peak production period. Therefore, the daily average emission rate for Boiler No 1 used in the air quality model was calculated based on 80% of the maximum hourly load, with emissions from Boiler No 2 based on 48% (80% x 60%) of the hourly load. The rate of NOx emissions from the boilers depends on the oil grade burnt and combustion conditions within the flame zone of the boiler. Formation of NOx in the flue gas is a complex process as it is related not only to the amount of combustion air available and chemistry of the fuel burnt but also to the temperature within the flame area of the boiler. Over 95% of the total nitrogen oxides (NOx) in the exhaust gas from industrial boilers burning fuel oil is typically emitted as nitric oxide (NO) with the remainder (< 5%) emitted as nitrogen dioxide (NO2). The NOx forms in the zone downstream of the burner where the combustion air is mixed. The NOx emission rates for the boilers (Table 2) were calculated from the hourly exhaust flow from each stack and a maximum emission concentration of 900 mg/Nm3. The emission rate of particulates (PM) from each boiler stack was calculated based on the hourly exhaust flows and an emission concentration of 350 mg/Nm3. The daily operational load was based on the same percentages used to calculate daily average SO2 emissions during the peak production period; ie 80% for Boiler No 1 and 48% for Boiler No 2. It is assumed that all the PM is emitted as PM10 (particulates with a mean aerodynamic diameter of <10μm) when the MFO is burnt. This is the relevant size fraction for determining compliance with the NAQS daily limit value. However, depending on the fuel quality and combustion efficiency, the actual PM10 emission rate can be substantially lower. The fraction of particles that can be larger than 10μm in the exhaust from a boiler fired on fuel oil is dependent on a number of factors including combustion efficiency, load and age and may even include grit-sized particles if combustion conditions are poor. 3.0 MODEL REQUIREMENTS 3.1 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. 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

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theory based on the Monin-Obukhov length and boundary layer height instead of the categories of atmospheric stability 3.2 Model Input Parameters 3.2.1 Emission Source Characteristics Data relating to the stack height, exit diameter, exit velocity and temperature, SO2 NOx and PM emission rates from the boiler exhaust stacks given in Tables 3 and 4 were input into the model. The hourly emission rates for these pollutant parameters were based on continuous maximum emissions for Boiler No 1 running at full load and 60% load for Boiler No 2. For the daily SO2 and PM emission rate a value equivalent to 80% of the hourly emission rate was used in the model. No 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 evaluating compliance with the NAQS. 3.2.2 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 contribute to building wake effects on plume dispersal. There are a number of building structures within the site, which are used for cheese manufacturing and storage, along with tanks and other miscellaneous smaller buildings. The boilers are housed within a building, which has a roof height of 7m and the two 25m boiler stacks are situated at the rear of this building. The dominant building affecting the emission plume from the 2 boiler stacks is the cheese factory with an overall height of 10-14m and a maximum height of 16m. Other large building structures within the site are the cheddering room and cheese store with roof heights of 10.5m. There are a number of vertical cylindrical storage tanks within 20m of the boiler building, which range in height from about 12m to 18m. Dimensions of these three main building structures are as follows with each aligned with the longest side orientated along a NW to SE axis.

Cheese Factory – Height 14m, Length 56m, Width 35m Cheddering Room – Height 10.5m, Length 30m, Width 10m Cheese Store – Height 10.5m, Length 70m, Width 23m

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3.2.3 Climatological Data Sequential hourly climatological data from the meteorological station at Cork Airport (50km to SE) were used in predicting the ground level concentrations of the various pollutants in the locality of the Newmarket 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 (50km to N) were also included in the 3-year data-set as Newmarket is approximately equidistant between the two meteorological stations. These two sets of climatological data will be indicative of the wind field pattern throughout the year for the Newmarket area. 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. The wind roses for the three separate years at Cork Airport and Shannon Airport are given in Figure 1. 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. 3.2.4 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 0.3m, which approximates to agricultural areas, was used in the ADMS4 model to represent conditions in the area around Newmarket. 3.2.5 Receptor Grid A receptor grid with regular spacing of 2025 receptor points (45x45 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 131300E, 107100N for the SW corner and extending to 132550E, 108000N at the NE corner of the grid. This area is where the maximum ground level impact of emissions from the dairy manufacturing plant is likely to occur, due to the effects of building wake turbulence as the plume disperses downwind of the site.

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3.2.6 Terrain The effect of local topography on the dispersion of the plumes from the two boiler exhaust stacks was included in the modelling study. The ADMS4 model uses advanced algorithms to calculate the effect of changes in slope gradients on plume dispersal from a point source. Terrain data based on a 32 x 32 grid matrix were processed for input into the ADMS4 model. The elevation above sea-level datum within a 2 x2km receptor grid area was manually extracted from maps obtained from the Ordnance Survey 1:50,000 Discovery Series (No 72), which show 10m contour intervals. 3.2.7 NOx and NO2 modelling As the emission plume from the multiflue stack disperses 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 source and receptor locations. Background concentrations of ozone and NOx are used to initialise the chemistry scheme in the ADMS4 model. Annual average levels of 6ppb and 12ppb were also used for NO2 and NOx respectively, which are required as input for the chemistry module of the ADMS4 model. An annual average O3 concentration of 28 ppb was used in the model. These ambient values would be typical of background levels in the Newmarket area. 3.2.8 Background Concentrations

Table 5

Air Quality in Zone D (non-urban) Regions of Ireland in 2009 (μg/m3)

Pollutant Annual average concentration Sulphur Dioxide (SO2) 4

Nitrogen Dioxide (NO2) 3-11 PM10 8-13

Source: Air Quality in Ireland 2009, EPA 2010 EU Legislation on Air Quality require 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. Newmarket is

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within the Zone D (small town/rural) air quality zone classification. Representative air quality data for Zone D locations in Ireland for 2009 published by the EPA (Air Quality in Ireland 2009) are given in Table 5. In the absence of any ambient monitoring data for Newmarket, concentrations for SO2 and PM10 given in Table 5 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. An estimate of the maximum combined SO2 concentrations can be obtained by adding twice the annual background concentrations with the predicted hourly or daily values from the facility stack emissions. For PM10, the annual average background level is added to the predicted daily concentrations from the facility emissions. In relation to combined NO2 impacts, a background annual average value is already included in the ADMS4 model for NOx and NO2 calculations as outlined in Section 3.2.7 above and so no additional background value is required. 4.0 RESULTS OF MODELLING STUDY 4.1 Introduction

Table 6 National Air Quality Standards (SI No 180 of 2011)

Pollutant Criteria (µg/m3) Compliance

Date SO2 Hourly – 99.7% (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 Particulates (as PM10) Daily – 90.4% (not to be

exceeded more than 35 times per year)

50 1 Jan 2005

Annual Average 40 1 Jan 2005 Source: Air Quality Standards Regulations 2011 (SI No 180 of 2011) Predicted ground level SO2, NO2 and PM concentrations were compared with the hourly and daily National Air Quality Standards (NAQS) values specified in the Air Quality Standards Regulations 2011 (SI: No 180 of 2011) (Table 6). The results of the modelling study are presented as ground level concentration contour plots, based on the hourly and daily boiler operational load scenario, described in Section 2 above. The predicted values shown in the contour plots are the maximum percentile statistic

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obtained at each of the receptor points within the modelled area over the three separate climatological data-sets used in the study. The PM emissions from the boiler exhaust stacks were modelled as total particulates and so it is assumed that all particulates present in the exhaust are within the particle size fraction of PM10 so that comparison with the daily and annual NAQS can be made. 4.2 Predicted impact 4.2.1 Sulphur Dioxide (SO2) 4.2.1.1 Hourly SO2 The pattern of the predicted 99.7 percentile of hourly SO2 concentrations in the locality of the Newmarket Co-op facility based on maximum hourly emissions, including background levels, from Boiler No 1 and 2 are shown in Figure 2. The highest levels are predicted to occur close to the NW and SE boundaries with a rapid decrease within 200m of the boundary of the facility. The maximum predicted hourly 99.7 percentile concentration is significantly below the NAQS hourly standard of 350 μg/m3. The highest level is 183 μg/m3, or 52% of the hourly NAQS and this is predicted near the SE corner of the facility. Towards the town centre, the highest 99.7 percentile hourly SO2 level is predicted to be less than 160 μg/m3, or 46% of the NAQS value. Beyond 200m from the boundary, the predicted hourly levels are less than 90 μg/m3, which is 26% of the hourly NAQS. For most of the year, the total steam demand for the dairy manufacturing facility can be met with only one boiler running with the other one on standby. For this boiler scenario, with only Boiler No 1 in operation, the maximum predicted hourly SO2 concentration decreases to 110 μg/m3 or 31% of the hourly NAQS limit value. At the nearest house to the area of maximum impact the predicted hourly concentration decreases to 160 μg/m3, which is equivalent to 46% of the NAQS limit value. 4.2.1.2 Daily SO2 The 99.2 percentile concentrations are shown in Figure 3 and the contour plot shows the highest levels occur close to the facility, with a rapid decrease downwind of the boundary. This concentration contour plot is based on the combined impact of emissions from the facility coupled with background concentrations. The maximum predicted concentration is 105 μg/m3, which is 84% of the daily NAQS. This small zone of highest predicted daily levels occurs within lands owned by the company just beyond the IPPC boundary to the SE of the boiler plant. This concentration is based on the scenario of Boilers No 1 and 2 operating at 80% and 48% of the hourly load respectively. A secondary peak of about 83 μg/m3, or 66% of the daily NAQS, occurs near the NW IPPC site boundary. Approximately 100m beyond the boundary the predicted daily SO2 concentrations rapidly decrease to less than 80 μg/m3 or 64% of the NAQS limit value. At the nearest house to the zone of maximum impact, the predicted 99.2 percentile concentration is 88 μg/m3, which is 70% of the daily NAQS value.

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4.2.2 Nitrogen Dioxide (NO2) 4.2.2.1 Hourly The predicted 99.8 percentile of hourly NO2 ground level concentrations due to the combined emissions of NOx from the 2 boiler stacks and a background level is given in Figure 4. The highest 99.8 percentile of hourly NO2 concentrations beyond the boundary is 48μg/m3 and this maximum level occurs within 100m of the NW boundary of the facility. This maximum 99.8 percentile value is less than 25% of the NAQS.

4.2.2.2 Annual The predicted annual average NO2 ground level concentration pattern indicates maximum annual average levels of 18 μg/m3 beyond the IPPC boundary. These predicted ground level concentrations include an annual background level used in the air quality model of 12 μg/m3. The predicted annual concentrations are 45% of the annual NAQS of 40 μg/m3. 4.2.3 Particulates (as PM10) 4.2.3.1 Daily The predicted daily particulate concentrations are shown in Figure 6, expressed as the 90.4 percentile over an annual period. The predicted levels are calculated on the assumption that all of the PM emissions from the two boiler stacks are emitted as PM10 size material. The results indicate that the predicted concentrations, including a background level of 13 μg/m3, are substantially below the daily NAQS value of 50 μg/m3 even where this conservative modelling approach has been applied. The maximum 90.4 percentile daily concentration beyond the facility boundary is 29 μg/m3, which is equivalent to 58% of the daily NAQS. This maximum predicted level occurs within the lands owned by the company, about 75m to the SE of the facility. Beyond 200m from the boundary, the predicted daily concentrations decrease to less than 21 μg/m3, which is equivalent to 42% of the NAQS. At the nearest house, located on the Main Street, the predicted concentrations are 23 μg/m3 or 46% of the daily NAQS. 4.2.3.2 Annual PM10 The predicted annual average PM10 concentrations due to the combined impact of the boiler stacks and a background concentration are shown in Figure 6. The maximum annual average PM10 concentration beyond the boundary is 17 μg/m3, or 42% of the NAQS value of 40 μg/m3. The area where the highest levels are predicted to occur is approximately 100m to the SE of the boundary. Beyond approximately 200m from the facility boundary, the predicted PM10 annual average rapidly decreases below 15 μg/m3 or 38% of the annual NAQS value.

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5.0 CONCLUSION A detailed air quality dispersion modelling study was undertaken using the ADMS4 model to evaluate the impact of the emissions from the two boilers at the Newmarket Co-operative facility. The operational scenario modelled represents ‘worst-case’ emissions since it is assumed that the both boilers are operating continuously with a

Table 7

Summary of maximum SO2, NO2 and PM10 predicted concentrations beyond the site boundary

Pollutant Modelled

Period NAQS(i) (g/m3)

Predicted Max Conc.

(g/m3)

Max Conc. as a % of

NAQS

SO2 Hourly 99.73%- 350 183 52 Daily 99.2% - 125 105 84

NO2 Hourly 99.8% - 200 48 24 Annual Average - 40 18 45

PM10 Daily 90.4% - 50 29 58 Annual Average - 40 17 42

Note: (i) Air Quality Standards Regulations (SI: No 180 of 2011)

Table 8

Summary of maximum SO2, NO2 and PM10 predicted concentrations at the nearest house or sensitive receptor

Pollutant Modelled

Period NAQS(i) (g/m3)

Predicted Max Conc.

(g/m3)

Max Conc. as a % of

NAQS

SO2 Hourly 99.73%- 350 160 46 Daily 99.2% - 125 88 70

NO2 Hourly 99.8% - 200 45 22 Annual Average - 40 18 45

PM10 Daily 90.4% - 50 23 46 Annual Average - 40 15 38

Note: (i) Air Quality Standards Regulations (SI: No 180 of 2011)

combined hourly steam generating capacity of 160% and a daily load factor of 80% of the hourly firing rate. However, given the steam requirement at the facility during the peak production period, steam demand can normally be achieved with only one of the two boilers on full load, with the other boiler on low load. A summary of the highest predicted concentrations obtained from the two exhaust stacks combined with background levels and percentage compliance with the NAQS at the location of maximum impact and at the nearest house (sensitive receptor), are given in Tables 7 and 8. The SO2 emissions used in the model were based on oil consumption rates with Boiler No 1 operating at high and Boiler No 2 on medium

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load and burning MFO grade oil, with a maximum sulphur content of 1%. This approach to calculating maximum mass emission rates of SO2 from boilers based on oil consumption rates and applying a sulphur content factor is the preferred method, compared to multiplying exhaust volume flows by the emission limit value of 1700 mg/Nm3 that is specified in IPPC Licences for fuel oil boilers. In terms of air quality impact assessment, the important emission parameter for SO2 is the emission rate as g/s at the operating load modelled and this should be calculated from oil consumption data for the boiler. In the case of NOx and PM10 emissions, the modelled results are based on a maximum emission concentration in the flue gas of 900 mg/Nm3 and 350 mg/Nm3 respectively and multiplying these values by the exhaust volume flows. The predicted maximum hourly concentrations of SO2 and NO2 due to emissions from the two boiler stacks combined with background levels are 52% and 24% of the NAQS. At the nearest house, the predicted hourly concentration for these two pollutants decreases to 46% and 22% and so are well below the corresponding NAQS. The maximum predicted daily SO2 concentration downwind of the IPPC boundary is 84% of the daily NAQS. However, this occurs within a small zone on lands owned by the company and not in an area of where the community are exposed. At the nearest house the predicted daily 99.2 percentile concentration is 70% of the daily NAQS, when combined with the background concentration. The maximum predicted impact of particulate emissions (as PM10) from the two boiler stacks combined with the background concentrations are also below both the daily and annual NAQS limit value beyond the boundary. Schedule 3 of the Air Quality Standards Regulations 2011 state that “Compliance with the limit values directed at the protection of human health shall not be assessed at any location situated within areas where the members of the public do not have access and there is no fixed habitation”. Therefore, according to this approach to impact assessment, the relevant locations are at houses or sensitive receptors and so this excludes lands owned by the company, both within and outside the legal site boundary for the IPPC Licence. The highest SO2 ground level concentrations are predicted to occur to the South of the facility legal boundary but within lands now owned by the company. On this basis, the relevant values and percentage compliance are those at the nearest house that are given in Table 8. In conclusion, no significant impairment on local community health, amenities or the environment is predicted from the Newmarket Cooperative facility as a consequence of the proposed revisions to the current emission limit values specified in Schedule B of IPPC Licence Reg. No. P0793-02. The model results demonstrate that predicted ground level concentrations comply with the requirements specified in the Air Quality Standards Regulations 2011.

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FIGURES 1-6 WIND ROSES

AIR QUALITY DISPERSION MODELLING RESULTS

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FIGURE 1a – WIND ROSE FOR 2005 – CORK AIRPORT

FIGURE 1b – WIND ROSE FOR 2006 – CORK AIRPORT

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FIGURE 1c – WIND ROSE FOR 2006 – SHANNON AIRPORT

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FIG 2: PREDICTED 99.7 PERCENTILE OF HOURLY SO2 CONCENTRATIONS DUE TO EMISSIONS FROM BOILERS NO 1 AND 2 (STACKS A1-1 AND A1-2) COMBINED WITH BACKGROUND CONCENTRATION (μg/m3)

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FIG 3: PREDICTED 99.2 PERCENTILE OF DAILY SO2 CONCENTRATIONS DUE TO EMISSIONS FROM BOILERS NO 1 AND 2 (STACKS A1-1 AND A1-2) COMBINED WITH BACKGROUND CONCENTRATION (μg/m3)

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FIG 4: PREDICTED 99.8 PERCENTILE OF HOURLY NO2 CONCENTRATIONS DUE TO EMISSIONS FROM BOILERS NO 1 AND 2 (STACKS A1-1 AND A1-2) COMBINED WITH BACKGROUND CONCENTRATION (μg/m3)

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FIG 5: PREDICTED 90.4 PERCENTILE OF DAILY PM10 CONCENTRATIONS DUE TO MAXIMUM PARTICULATE EMISSIONS FROM BOILERS NO 1 AND 2 COMBINED WITH BACKGROUND CONCENTRATION ( STACKS A1-1 AND A1-2) (μg/m3)

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FIG 6: PREDICTED ANNUAL AVERAGE PM10 CONCENTRATIONS DUE TO MAXIMUM PARTICULATE EMISSIONS FROM BOILERS NO 1 AND 2 ( STACKS A1-1 AND A1-2) COMBINED WITH BACKGROUND CONCENTRATION (μg/m3)

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Attachment No I1

Assessment of Atmospheric

Emissions

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Attachment I.1 P0793-03


Attachment I.1 – Assessment of Atmospheric Emissions

I1.0 Assessment

In order to establish the impact of air emissions from the NCC facility, detailed

air dispersion modeling was undertaken on the boiler exhaust gases. The

potential impact was demonstrated by comparing the predicted pollutant

concentrations to those set out in the National Air Quality Standards

Regulations (S.I. 180 of 2011) and establish if air pollution, as defined in the Air

Pollution Act, arises as result of exhaust gas emissions from the boilers at NCC.

It is noted that a modeling exercise was undertaken as part of the original

IPPC Licence application for the facility. It is acknowledged that there has

been no change in the installed capacity of the boilers at the site since the

original IPPC Licence was made, however the original modeling exercise was

based on a restricted sulphur content in the fuel and particulate emission limit

values which are unattainable on boilers the scale of which are installed at

NCC.

I1.1 Proposed Emission Limit Values

I1.1.1 Sulphur Dioxide

In accordance with the Sulphur Content of heavy Fuel Oil, Gas Oil and

Marine Fuels Regulations (S.I. 119 of 2008), NCC cannot burn oil which has a

sulphur content of greater than 1% as oil with sulphur content of greater than

1% is not legally permitted for use. In the absence of legal requirement or

otherwise for fuel to contain sulphur content lower than 1%, the emission limit

values for SO2 are based on fuel containing 1% sulphur.

I1.1.2 Nitrogen Oxides

Formation of NOx in the flue gas is a complex process as it is related not only

to the amount of combustion air available and chemistry of the fuel burnt but

also to the temperature within the flame area of the boiler. Over 95% of the

total nitrogen oxides (NOx) in the exhaust gas from industrial boilers burning

fuel oil is typically emitted as nitric oxide (NO) with the remainder (< 5%)

emitted as nitrogen dioxide (NO2). The Nitrogen Oxide emission limit value has

been included in the model as 900 mg/Nm3.

I1.1.3 Particulate Matter

The emission limit value as specified in the IPPC Licence of 50 mg/Nm3 is not

achievable on boilers of the size and nature of those installed at NCC. The

facility has installed (January 2012) abatement technology on the boilers at

the site which, will ensure that the particulate concentration remains below

350 mg/Nm3.

It is noted that this assessment is based on the assumption that all of the

particulate emissions are emitted as PM10, which is a conservative approach

as a substantial quantity of the particulate emissions may not fall within the

PM10 size fraction.

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I1.2 Emission Characteristics

The emission characteristics are provided on the basis of the worst case

operational scenario, whereby one boiler operates at 100% of its capacity

and the second boiler is operating at 60% capacity, based on volumetric

emissions rates.

Table 1. Boiler Emission-Characteristics

Stack

( IPPC Licence

Designation)

Stack Ht

(m)

Diameter

(m)

Ref (i)

Exhaust

Volume

(Nm3/h)

Actual

Exhaust

Volume

(Nm3/h)

Exit

T.

(oC)

Exit Vel

(m/s)

A1-1 Boiler No 1 25.0 0.58 6,010 7,450 215 14.0

A1-2 Boiler No 2 25.0 0.58 3,420 4,250 270 9.0

I1.3 Predicted Emissions

Maximum Hourly Emission Rates

The predicted maximum hourly mass emission of SO2, NOx and particulate

matter are provided in Table 2. The hourly mass emissions are based on one

(A1-1) boiler operating at 100% load and the second boiler (A1-2) operating

at 60% load.

Maximum Daily Emission Rates

On review of steam demand and associated boiler loadings the daily

average requirement is typically a maximum of 60-80% of the hourly load,

during the peak production period. Therefore, the daily average emission rate

for Boiler No 1 used in the air quality model was calculated based on 80% of

the maximum hourly load, with emissions from Boiler No 2 based on 48% (80%

x 60%) of the hourly load. This is considered to be the worst case scenario, as

one boiler is capable of meeting the steam demand for operations at the

site. It is noted that the emission rate for SO2 has been calculated on the basis

of the fuel containing a maximum of 1% sulphur.

Table 2. Hourly Mass Emissions (g/s)

Stack

( IPPC Licence Designation)

Hourly

SO2

Daily

SO2

Hourly

NOx

Daily

PM

A1-1 Oil Boiler No 1 2.32 1.86 1.50 0.46

A1-2 Oil Boiler No 2 1.41 1.12 0.86 0.27

I1.4 Ambient Air Quality

Ireland, based on European Legislation has divided the country into 4 air

quality zones (A to D). Outside of Dublin and other large urban centres areas

with populations less than 15,000 people fall within zone D. In the absence of

local monitoring records for SO2 and particulates the ambient air quality of air

quality for zone D as published by the EPA (Air Quality in Ireland 2009) is

considered to be representative of ambient conditions surrounding the site.

The ambient levels for zone D are provided in Table 3.

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Table 3. Ambient Air Quality (Zone D)

Pollutant Annual average concentration

Sulphur Dioxide (SO2) 4

Nitrogen Dioxide (NO2) 3-11

PM10 8-13 Source EPA Air Quality in Ireland 2009 (EPA, 2010)

An estimate of the maximum combined SO2 concentrations is obtained by

adding twice the annual background concentrations with the predicted

hourly or daily values from the facility stack emissions.

For PM10, the annual average background level was added to the predicted

daily concentrations from the facility emissions. For NO2 impacts, a

background annual average value is already included in the ADMS4 model

for NOx and NO2 calculations and therefore no additional background value

is required.

I1.5 Predicted Impact

The predicted emissions from the development beyond the site boundary

and at the closest sensitive receptor are provided in Table 4 and 5

respectively.

Table 4. Predicted Pollutant Concentration

Pollutant

Modelled

Period NAQS

(i)

(µµµµg/m3)

Predicted

Max Conc.

(µµµµg/m3)

Max Conc. as

a % of NAQS

SO2 Hourly 99.73%- 350 183 52

Daily 99.2% - 125 105 84

NO2 Hourly 99.8% - 200 48 24

Annual Average - 40 18 45

PM10 Daily 90.4% - 50 29 58

Annual Average - 40 17 42 Note: (i) Air Quality Standards Regulations (SI: No 180 of 2011)

Table 5. Predicted Pollutant Concentration at nearest house.

Pollutant

Modelled

Period NAQS

(i)

(µµµµg/m3)

Predicted

Max Conc.

(µµµµg/m3)

Max Conc. as

a % of NAQS

SO2 Hourly 99.73%- 350 160 46

Daily 99.2% - 125 88 70

NO2 Hourly 99.8% - 200 45 22

Annual Average - 40 18 45

PM10 Daily 90.4% - 50 23 46

Annual Average - 40 15 38 Note: (i) Air Quality Standards Regulations (SI: No 180 of 2011)

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The predicted maximum hourly concentrations of SO2 and NO2 due to

emissions from the two boiler stacks combined with background levels are

52% and 24% of the NAQS. At the nearest house, the predicted hourly

concentration for these two pollutants decreases to 46% and 22% and so are

well below the corresponding NAQS.

The maximum predicted daily SO2 concentration downwind of the IPPC

boundary occurs within a small zone on lands owned by the company and

not in an area of where the community are exposed. At the nearest house

the predicted daily 99.2 percentile concentration is 70% of the daily NAQS,

when combined with the background concentration.

The maximum predicted impact of particulate emissions (as PM10) from the

two boiler stacks combined with the background concentrations are also

below both the daily and annual NAQS limit value beyond the boundary

(daily and annual levels are 46 and 38% respectively) and based on the

modelling approach taken are conservative as it assumes that all particulate

from the stack are emitted in the PM10 fraction.

Schedule 3 of the Air Quality Standards Regulations 2011 state that

“Compliance with the limit values directed at the protection of human health

shall not be assessed at any location situated within areas where the

members of the public do not have access and there is no fixed habitation”.

Therefore, according to this approach to impact assessment, the relevant

locations are at houses or sensitive receptors and so this excludes lands

owned by the company, both within and outside the legal site boundary for

the IPPC Licence. The highest SO2 ground level concentrations are predicted

to occur to the South of the facility legal boundary but within lands now

owned by the company. On this basis, the relevant values and percentage

compliance are those at the nearest house that are given in Table 5.

The assessment concluded that no significant impairment on local community

health, amenities or the environment is predicted from the Newmarket

Cooperative facility as a consequence of the proposed revisions to the

current emission limit values specified in Schedule B of IPPC Licence Reg. No.

P0793-02. The model results demonstrate that predicted ground level

concentrations comply with the requirements specified in the Air Quality

Standards Regulations 2011.

Full details of the modeling are provided in the Envirocon modeling report

included in section I of the application form.

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Documents

For inspection purposes only. Consent of copyright …Section D Operational Information P0793-03 Newmarket Co-Operative Creameries Ltd. D.1 Operational Information This section outlines