ABBOTT COOTEHILL EPA IPPC LICENCE REVIEW … · Abbott Cootehill IPPC Licence Review Application ... The EMS is certified to ISO14001 and it incorporates procedures for pro ... The

ABBOTT COOTEHILL EPA IPPC LICENCE REVIEW

APPLICATION

NON-TECHNICAL SUMMARY

_______________________________________________ Technical Report Prepared For

Environmental Protection Agency

_______________________________________________ Technical Report Prepared By

Mairead Morrissey BSc MSc

_______________________________________________

Our Reference

MM/10/5356A.1Rev.1

_______________________________________________ Date of Issue

21st April 2011

_______________________________________________

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Abbott Cootehill IPPC Licence Review Application AWN Consulting Limited _____________________________________________________________________________________________________

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Report Prepared By: Report Checked By:

MAIREAD MORRISSEY DR FERGAL CALLAGHAN Principal Environmental Consultant Director

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CONTENTS Page

1.0 INTRODUCTION 4

2.0 GENERAL INFORMATION 4 2.1 Planning Permissions 4 2.2 Site Notice and Notification of Application Intent 4 2.3 Activities to be Licensed 5 2.4 Seveso II Regulations 5

3.0 DESCRIPTION OF THE SITE & ACTIVITIES 5 3.1 Description of Facility 5 3.2 Hours of Operation 5 3.3 Outline EMS 5 3.4 Structure & Personnel 6 3.5 Operations at the Facility 6 3.6 Overview of Quality Management System 9 3.7 Emissions Sources 10

4.0 EXISTING ENVIRONMENT & PREDICTED IMPACTS 12 4.1 Air Quality 12 4.2 Surface Water 12 4.3 Groundwater 14 4.4 Noise 14

5.0 PROPOSED CHANGES TO SAMPLING/MONITORING POINTS OR LIMITS 15

5.1 Air Quality Monitoring 15 5.2 Treated Effluent Sampling 16 5.3 Noise Monitoring 17

6.0 MITIGATION/ABATEMENT MEASURES 18 6.1 Air Quality 18 6.2 Noise Emissions 19 6.3 Emissions to Surface Water 20

7.0 MATERIALS & ENERGY USE 21

8.0 ACCIDENT & EMERGENCY PROCEDURES 22

9.0 AFTERCARE, DECOMMISSIONING & RESTORATION 22

10.0 CONCLUSIONS 22

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1.0 INTRODUCTION Abbott is applying to the Environmental Protection Agency (EPA) for a Review of their current Integrated Prevention & Control Licence for the operation of the dairy product manufacturing facility at Dromore West, Cootehill, Co. Cavan (See Attachment A.1.1). A review is required due to the increase in capacity of the facility by approximately 40% of current production, and the works associated with this increase in capacity. This Non-Technical Summary is included as Attachment A.1 of the application to the EPA (herein referred to as the Agency) and summarises the sections of the application form and associated attachments.

2.0 GENERAL INFORMATION 2.1 Planning Permissions

A number of planning permissions have been applied for/granted since the previous IPPC Licence application, for various works at the site. The most recent permissions granted are to facilitate an increase in capacity of the facility, by Monaghan Co. Co. Planning Reference: 10/173, was granted on the 21st June 2010 for the following: - A single storey office extension at the southweastern end of the existing

warehouse building - A new evaporator tower connected to the northern elevation of the existing

dryer tower (33m height) - An extension to the existing staff car park (23 new spaces)

Planning Reference: 10/580 was granted on the 10th February 2010 for the following: - Upgrade of the existing effluent treatment plant

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

2.2 Site Notice and Notification of Application Intent

A Site Notice advising of the IPPC Licence review application has been erected at the entrance to the Abbott site. The notice will remain in place for one month after the date of submission to the EPA. Notification of the IPPC Licence review application was also placed in the following newspaper publication: Irish Times (dated Thursday 21st April, 2011), which is a paper circulated both locally and nationally. Written notification was provided to Monaghan County Council, as the relevant Local Authority, on 29th March 2011 by AWN Consulting Ltd on behalf of Abbott Cootehill. Notification was also provided to Cavan County Council.

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2.3 Activities to be Licensed

The licensable activity is the manufacture of dairy products. The Activities, under the First Schedule of the EPA Act, 1992 are: - Class 7.2 the manufacture of dairy products where the processing capacity

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

output exceeding 50 MW. 2.4 Seveso II Regulations

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

3.0 DESCRIPTION OF SITE AND ACTIVITIES

3.1 Description of Facility

A plan drawing of the site is provided (Drawing No.s 001, 002, 003 and 003a), showing the location of all activities and identifying all buildings and facilities.

3.2 Hours of Operation

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

3.3 Environmental Management System (EMS)

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

The EMS is certified to ISO14001 and it incorporates procedures for pro-active management of environmental issues and liabilities. The facility gained accreditation in 1997. Prior to ISO14001 Abbott Cootehill had certification to BS7750, an EMS specification standard. Through ISO14001, Abbott operates a formal structure for environmental management, ongoing assessment of environmental performance and continual improvement at the site.

Specific Targets for each operational year are made and included in the EMS. There are specific roles and responsibilities established within the facility to manage, control and operate the EMS. Standard Operating Procedures are in place as part of the EMS. These are procedures that are followed to ensure legal environmental compliance, to prevent

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and mitigate environmental pollution on site and to allow the environmental targets for the facility to be achieved e.g. energy-use reduction targets, waste recycling targets, etc. Training is provided for employees and management at the facility in order to ensure the EMS is implemented and maintained correctly. An environmental records system is maintained as part of the EMS. These records include data on energy consumption, natural resource and raw material use, waste generation, waste disposal and waste recovery/recycling and emissions from the facility (odour, air quality, noise & vibration etc) The EMS is audited twice a year by an external auditor. The objectives and targets and the environmental procedures for the facility are included with the main application.

3.4 Structure and Personnel

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

The Site Director has overall responsibility for the running of the facility. The EHS/Operations Manager reports to the Site Director. The EHS Co-ordinator reports to the EHS/Operations Manager. The Engineering Manager reports to the Site Director. The Process Engineering Manager reports to the Engineering Manager and controls the daily running of the processes at the facility. The Utilities Engineer reports to the Process Engineering Manager and controls operation of all utilities and effluent treatment operations.

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

3.5 Operations at the Facility

Existing operations at the facility will continue and an overview of these operations is presented in this section. In addition, a number of upgrades and changes to the operations have taken place or will take place as part of Project ICE. Project ICE includes the following: - Upgrade to the Refrigeration Plant (Completed July 2010) - Upgrade to the Water Treatment Plant (In progress) - Upgrade to the Wastewater Treatment System/Plant (In progress) - Installation of Bag-Off in Packing Area to allow for Bulk Bagging (Not Complete) - Installation of 3rd Oil Blend System for increased processing speed (Completed

July 2010) - Installation of Parallel CIP and Drier Feed Circuits. Second Feedline on Dryer 2

(Completed July 2010) - Upgrade to Internal and External Facilities to accommodate changes/upgrades

(Ongoing) - Installation of 3rd Evaporator (planning permission granted but this has not yet

been approved internally) - A third packing line will be added in the future

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

The elements of the site are as follows:

Warehousing

Offices

Canteen

Laboratories

Wet Process Area

Dry Ingredients Area

Evaporators & Evaporator Tower

Drier Towers

Canning and Filling Area

Blending and Powder Silos

Engineering Offices

Bulk Storage Area

Boilers

Refrigeration Plant

Water Treatment Plant

Wastewater Treatment Plant

Main Switch Room and Emergency Generator

River Water Pump House

Security Hut

Milk, Oil and Syrup Intake Building

Wet Process

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

Pasteurisation and Evaporation

Dry Process

Drying & Powder Storage

Canning/Packaging

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

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

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vegetable oils, syrup, flavouring, vitamins, minerals and other powdered foodstuff ingredients. The liquid mixture produced in the wet process area must be pasteurised and evaporated. The purpose of pasteurisation is to apply heat to the product to reduce bacterial and enzyme activity. The purpose of evaporation is to significantly reduce the water content and increase solids content. Milk water condensate from the evaporation process is routed to the dryer heating coil where heat is recovered from the condensate and the condensate is cooled. At present all condensate (finished powder type 1 and type 2) is routed to effluent plant. Once the liquid product has been evaporated and pasteurized, it is then pumped via high pressure pumps to two dryers. Drying involves the application of heat under controlled conditions to remove water in order to produce solid product. During the process, hot exhaust air is discharged via exhaust fans through an exhaust duct. Once product is dried in the dryers it can be bagged off directly at the dryers or conveyed to finished powder silos. These silos supply powder either directly to the 2 existing packing lines or to two dry powder ribbon blending systems for additional ingredient addition and then onwards to the packing lines. The objective of the packaging process is to ensure that the product is appropriately contained, protected and preserved so that it reaches the consumer as it left the production plant. The product is filled into a variety of can/container types and sizes depending on market requirements and the product is labeled. Pallets of full containers are transferred by forklift truck, off the out-feed conveyor, for stacking in the designated aisles within the warehouse awaiting distribution. Bulk products are transported for packaging off-site. Ancillary Operations

The ancillary processes and operations are as follows:

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

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

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

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

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

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

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

Bulk Nitrogen and Carbon Dioxide Storage and Distribution - Bulk nitrogen (N2) and carbon dioxide (CO2) are stored at the site and used in the packing operation of the product. N2 is also used in the vegetable oil system, syrup storage system and finished powder silos for blanketing and pipe purging/flushing.

Cleaning in Place (CIP) - CIP of road tankers, skim milk silos, evaporators, dryers, product lines etc., is carried out from a centralised CIP station located in a dedicated contained area where any spills are diverted to drains leading to the waste water treatment plant.

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

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

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

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

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

3.6 Overview of Quality Management System

Abbott Nutritional Cootehill has a quality policy and is ISO9001 accredited. The quality policy endeavours to: Build quality into products, processes and services; and Incorporate continuous improvement into all aspects of the business.

There is a Quality and Food Safety Manual for the facility, which outlines the process-based approach to both Quality Management and Food Safety Management and meets the requirements of ISO9001, ISO2200 and PAS220. The process based approach is designed to to facilitate consistency with the standards, allow ease of implementation and compliance assessment, as well as facilitation of more ongoing control and effectiveness of detailed processes within the organisation. The Quality and Food Safety Systems Manual details organizational structure, defined roles and responsibilities and an outline of the documentation structure used to support the Quality and Food Safety System.

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3.7 Emission Sources

Emissions to Air The main emissions to air are from boilers on site, and also from the dryer exhausts. Air emission points are as follows:

Point Code Emission

A1-1 NOx, SOx, CO, Particulates



A2-1 Total Dust (Particulates) A2-2 Total Dust (Particulates)

A3-1 Organic and inorganic solvent

vapours


vapours


vapours A3-4 Particulates A3-5 Particulates A3-6 Particulates A3-7 Particulates A3-8 Organic vapours A3-9 Organic vapours

A3-10 Particulate A3-11 Particulates A3-12 Organic vapours

Emissions to Surface Water

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

Surface water emission points are as follows:

Point Code Emission

SW-1 COD, Temperature

SW-2 Cl, N, Ammonia, TP, MRP, OFG,

BOD

Noise There are various noise generating items of equipment associated with the normal operation of the Abbott Cootehill plant. There is also equipment that is only used in emergency situations (e.g. emergency generator). There are no new significant external noise generating items of equipment that will be installed as part of Project ICE, however there are a number of items that will generate some noise.

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

Point Code Emission N-1 dB(A) N-2 dB(A) N-3 dB(A) N-4 dB(A) N-5 dB(A) N-6 dB(A) N-7 dB(A) N-8 dB(A) N-9 dB(A) N-10 dB(A) N-11 dB(A) N-12 dB(A) N-13 dB(A) N-14 dB(A) N-15 dB(A) N-16 dB(A) N-17 dB(A) N-18 dB(A) N-19 dB(A) N-20 dB(A) N-21 dB(A) N-22 dB(A) N-23 dB(A) N-24 dB(A) N-25 dB(A) N-26 dB(A)

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

Ground/Groundwater

There will be no emissions to ground or groundwater on site. Various containment measures (bunding of materials stored on site, 2 no. interceptors etc.) are in place to prevent / contain any accidental releases which could potentially impact on ground or groundwater quality.

Sludge is produced at the wastewater treatment plant. Due to the phasing out of landfilling of sludge, alternative means are now used for recycling the sludge, such as composting and landspreading. Currently sludge is being taken off site for composting, however sludge from the facility has been landspread in 2010 and this option may be utilized again in the future. The location of the landspreading is a farm owned by Mr Pat Callan, and it is located in Dunleer, Co. Louth. The company that currently manages both the composting and landspreading is ClearPower.

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4.0 EXISTING ENVIRONMENT & PREDICTED IMPACTS

4.1 Air Quality

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

There is also monitoring carried out on the dryer emission points A2-1 (Dryer No.1), and A2-2 (Dryer No.2) as part of the current IPPC Licence. The parameters are Total Dust. The most recent monitoring results, i.e. for 2010 monitoring show that all parameters measured for the boilers and dryers were within the IPPC Licence limits. Full monitoring reports are included as part of the main application. No monitoring is carried out for the 12 no. minor emission points. Predicted Impact Air dispersion modeling was carried out for the main emission sources at Abbott Cootehill to predict the maximum ground level concentrations (GLCs) of pollutants (NOX, SOX, particulates) likely to occur as a result of atmospheric emissions from the plant. The air dispersion modelling analysis was carried out using AERMOD dispersion model (Version 09292) which has been developed by the U.S. Environmental Protection Agency (USEPA) and following guidance issued by the EPA. The model input data included the stack discharge parameters, emission concentrations, receptor locations, five years of Clones Met Station meteorological data (2002 - 2006), building down-wash, terrain heights and land use. This air dispersion model takes into account, and assesses the potential impacts of, all aspects of Project ICE, including the proposed 3rd evaporator. From the air dispersion model, it was determined that the maximum predicted GLCs would be below all applicable statutory Air Quality Standard (AQS) limit values. These limit values have been set to protect human health and the environment. As the maximum predicted GLCs of pollutants occurring as a result of emissions from the expanded plant are below the AQS limit values, emissions from the plant should not have any significant adverse impact on human health and the environment and the existing ambient air quality. As mentioned above compressed gas will be used in the future instead of fuel oil, this will not result in any increase in emissions.

4.2 Surface Water

Existing Environment There is monitoring carried out on the surface water emission points: SW1 (Discharge to Dromore River) and SW2 (FTE Discharge to Dromore River) as part of the current IPPC Licence. As part of the IPPC Licence requirements, for SW1 the parameters monitored are temperature, COD, pH, conductivity and a visual inspection. For SW2 the parameters are volume, pH , temperature, residual chlorine, suspended solids, total nitrogen, total ammonia, total phosphorus, orthophosphate and oils, fats & greases.

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In relation to the SW1 emission monitoring point, in recent months the Similac condensate that makes up part of the emissions to SW1 has been diverted to the WWTP and treated with the effluent. This is due to TOC spikes that were noted in the condensate discharge. The cause of this is currently under investigation. However, it is proposed to recommence discharging the Similac condensate through SW1 in the next few months. In order to do so without a potential risk to the surface water body, i.e. the Dromore River, and as part of this Licence review, a TOC monitor and divert system is proposed for the condensate stream (E1), which would divert any discharge to the WWTP automatically if required, i.e. if the TOC or BOD exceeds a certain limit. A TOC meter is also planned for Evaporator 2 Condensate stream (E2), which will allow this stream to be monitored should Similac be sent to SW1 from this evaporator in the future. See Section F.1 for more details on the proposed TOC monitoring system.

E1 condensate will continue to be diverted to the WWTP until the TOC monitoring system is in place and is approved by the EPA. In addition to the emission point monitoring, ambient surface water monitoring is carried out at the site, with 2 no. monitoring points: ASW-1 and ASW-2. Monitoring results for 2010 are included with the main application. The results show that the river water quality was good for 2010 and that the discharges from the facility did not have a negative impact on the Dromore River. Predicted Impact

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

The EC Environmental Objectives (Surface Waters) Regulations came into force recently and give effect to the Water Framework Directive (2000/60/EC). With these Regulations, there are new surface water limits for certain parameters, which will be enforced to ensure that Ireland meets it’s obligations under the Water Framework Directive. An assimilative capacity study has been carried out in order to assess the receiving water body, i.e. the Dromore River, and how the increase in discharge will impact the surface water quality. It should be noted that the assimilative capacity assessment takes into account, and assesses the potential impacts of, all aspects of Project ICE, including the proposed 3rd evaporator. The assimilative capacity assessment report is presented as Attachment I.2.1 of the main application. Monitoring of the river has shown that no significant deterioration in water quality occurs from the discharge from the plant and no pollution incidents have occurred as a result of the ongoing discharge. The assimilative capacity report concludes that, based on the predictive calculations, it can be shown that the Dromore River has the capacity to assimilate an increase in the maximum discharge volume of final treated effluent from the Abbott site, even at low flow conditions in the Dromore River. This will result in maintaining current discharge concentrations (with the exception of MRP which would increase to 0.2 mg/l), but an increase in the overall mass emissions. It is concluded that the current

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concentrations for the final treated effluent are acceptable even with the proposed increase in discharge. Predicted Impact on Lake Levels & Dromore River The current water abstraction from Dromore River for operational requirements of the facility is approximately 1800 m3/day. By fully implementing Project ICE, the water demand will increase by a maximum of 900 m3/day to approximately 2,700 m3/day. An assessment of the predicted impact on the levels of the lake immediately upstream of the weir at the facility has been carried out to determine how the increase in water abstraction for processing requirements will impact the lake levels. The assessment findings were that the lake levels would not be adversely affected from the additional water use by the facility and that the Dromore River downstream of the site would benefit from increased water flow in the channel. In relation to fish life, no negative impact is predicted for spawning beds on the lake. In addition, by closing the side channel of the weir and therefore directing the water through the fish pass at the centre of the river, this will benefit the water flow down the fish pass. This report is included as Attachment I.2.2 of the main application, along with the submission made to the Fisheries Board in relation to the Dromore River/Lake and weir management.

4.3 Groundwater

Existing Environment There is groundwater monitoring carried out at GW1, GW2 and GW3, which are the 3 no. boreholes on site, as part of the current IPPC Licence requirements. The monitoring includes the following parameters: pH, COD, major anions, major cations, total & faecal coliforms and total petroleum hydrocarbons.

In April 1997 a small leak was detected in an underground fuel diesel line feeding the generator after evidence of a small volume of oil was observed on the surface of the Dromore River. Emergency response measures were contained and a site investigation was conducted to determine the extent of pollution that had occurred, followed by remediation. The issue was resolved to the satisfaction of the EPA. The 2010 monitoring results showed that there were no exceedences of regulatory groundwater limits. Predicted Impact There is no predicted impact on the groundwater as a result of on site activities. As previously mentioned, sludge from the WWTP is taken off-site for either composting or landspreading. In the event of landspreading, the subject lands are approved and permitted sites with Nutrient Management Plans (NMPs) for the activity. The predicted impact on the environment as a result of the landspreading activities is considered to be negligible.

4.4 Noise

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

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The 2010 noise monitoring results showed that the sound level at all locations measured (Noise Sensitive Locations) were within the permitted levels for both daytime and night time, with the exception of NSL4 (the amenity park) during the night time survey. It should be noted that the results of the survey stated that traffic was the attributable noise source at that location. However, as the park is not open at night, the limit does not apply in this instance. Predicted Impact A review of the facility noise generating items and noise measurements was carried out by a qualified acoustic consultant to determine the predicted impact of the plant and equipment that is part of Project ICE on the established noise sensitive locations. This report is included as Attachment 1.7.2 of the main application. Details of plant items and their sound power / pressure levels as well as proposed equipment location drawings were obtained from Abbott and distances to the nearest noise sensitive locations were measured. Desktop noise level calculations were conducted with corrections applied for location/orientation of the equipment, attenuation due to distance and screening. Calculation predictions for each source was conducted at each of the five noise sensitive locations identified in the most current (11th June 2010) IPPC noise emission monitoring report. The results of the calculations were then compared to existing Abbott facility noise emission at each location in order to determine the relative noise impact of the new equipment and its complicity with the IPPC licensing requirements.

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

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

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

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

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

5.0 PROPOSED CHANGES TO SAMPLING/MONITORING POINTS OR LIMITS This subsection outlines proposed changes to sampling/monitoring points or limits

that are in the current IPPC Licence. Justification for each of these is outlined below. 5.1 Air Quality Monitoring Stack Monitoring – Dryers

Since the original IPPC licence application, both Dryer Towers are now fitted with bag filters, which have reduced the dust emission levels from the dryers (with reduced emission limits as outlined above). 2010 monitoring of air emissions has shown that the dust concentrations were very low for the dryers. The monitoring results can be seen in Appendix A to this Attachment. In light of this, it is requested that the monitoring frequency for dust is reduced from 4 times per year to once a year.

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5.2 Treated Effluent Sampling Volumetric and Mass Emission Limit It is proposed that the limit values for the mass volumetric flow and the mass

emissions of the FTE are increased by 60% of the current Licence limits. This would mean that the concentration limits for the parameters measured in the

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

Table 1 FTE Emission Limit Values

Parameters Emission Limit Value

(mg/l)

Proposed Mass Emissions Limit Value

(kg/day)

Volume - 3200 m3/day

Volume - 133 m3/hr

Temperature 25 Deg.C N/A

pH (Range) 6-9 pH N/A

Residual Chlorine 0.03 N/A

Suspended Solids 30 96

BOD 20 64

Total Ammonia (as N) 1.5 4.8

Total Phosphorus 0.7 2.24

Total Nitrogen 25 80

Nitrates (as N) Not in licence N/A

Fats, Oils, Grease 10 32

Molybdate Reactive Phosphate 0.2 0.64

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

follows:

• There will be increased milk condensate associated with increased production • Increased ingredient water usage associated with increased production • There will be increased cleaning of process silos and milk trucks due to

increased production • Increase in items to be cleaned with more off line cleaning • Skew towards increase of GAIN (vanilla) product versus Similac product,

which generates more effluent • There will be increased back-washing due to increased water treatment

required • This also includes for a potential third evaporator in the future

In order to justify these increases in mass emissions, an assimilative capacity study

of the Dromore River was carried out, which is included as Attachment I.2.1. The study shows that the river does have capacity for the increase in mass emissions.

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

Orthophosphate

It is proposed to increase the concentration limit of orthophosphate from 0.03 mg/l to 0.2 mg/l. At present large amounts of ferric sulphate are used (as a coagulant) in the WWTP to reduce the orthophosphate levels. Using large quantities of this compound can lead to discoloration of the water. A report was carried out on the use of ferric sulphate for removal of orthophosphate from the effluent by Veolia in November 2009. The report concluded that, although the iron and sulphate levels in the receiving waters, i.e. the Dromore River, were not excessively high, the amount of ferric suphate used could be reduced significantly by increasing the limit for orthophosphate. The assimilative capacity assessment showed that the river has capacity to accept the increase in concentration whilst still meeting the regulatory limits for orthophosphate and total phosphorus in the receiving waters and also meeting the mass emissions limits of the Licence.

Residual Chlorine It is proposed that the current limit value of 0.005 mg/l for residual chlorine in the

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

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

5.3 Noise Monitoring Noise Sensitive Locations

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

(1) The location is no longer a justifiable noise sensitive location Belmont House was included as a noise sensitive location a number of years ago due to noise complaints raised by the inhabitants of the house at the time. Since the complaint noise attenuation has been fitted to both Dryers. The house is no longer occupied (only very occasionally) and no complaints have been made in relation to noise since Summer 2005. (2) The location is hard to access for survey purposes As the house is not occupied most of the time, the monitoring location is not easy to access. The access is protected by an electronic gate, and because nobody lives there anymore, trying to obtain access is very problematic.

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As the house is no longer occupied, it is proposed to take this monitoring point off the list of noise sensitive locations for the Licence once reviewed. Noise measurements were taken during the most recent noise survey (24th May 2010). The report, which is included in full as Section F.2 Appendix E of the main application, states that at Belmont House (NSL 3), the sound level readings were taken at the front of the house and that the site was not visible from the monitoring location. The report states that during the daytime there was no major noise contributor and the Abbott facility was not audible during the survey. During the night time, there was no major noise contributor and the Abbott facility was faintly audible during the survey. The report concluded that the relevant conditions of the current IPPC Licence, i.e. 8.3 and 8.4 were met. Therefore, as there appear to be no noise issues at the location, the house is no longer continuously occupied and no complaints have been received by the site in recent times in relation to noise, it is proposed that this noise monitoring location is not part of the reviewed Licence.

6.0 MITIGATION MEASURES/ABATMENT

6.1 Air Quality

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

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

Odour Abatement System

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

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

Odourous gas is extracted by pump, passed through filter media and the odourous components of the gas are removed. The existing odour abatement unit will be used for the new WWTP. The raw influent balancing tank will be connected to the existing odour control system with the air flow from each balance tank balanced via dampers in the ductwork from each tank.

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

Minor Emissions

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

6.2 Noise Emissions

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

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

6.3 Emissions to Surface Water

There is a WWTP on site to treat the effluent before discharge of the final treated effluent to the Dromore River. This is being upgraded as part of Project ICE.

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

Raw Influent Pumping Facility

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

Raw Influent Balancing Facility

Raw influent will be pumped into buffer tanks. pH correction will take place. The incoming influent will be mixed and as a result any large peak variations in the influent pH will be balanced out. Continuous pH measurement will be provided and pH correction chemicals will be administered as necessary

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

WWT Process Treatment Train: The Process train is as follows: Biological Treatment → Secondary Clarification → Actiflo → Hydrotech Biological Treatment

Biological treatment of the influent will take place. As part of the upgrade, one of the existing SBR tanks will be converted into an anoxic biological reactor (reactor 1) and

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the other SBR tank will be converted into an aerobic reactor (reactor 2). The facility can operate in both anoxic or aerobic conditions.

Secondary Clarification

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

Actiflo

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

Hydrotech

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

Final Effluent Buffering & Sampling

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

6.4 Surface Water Runoff & Similac Condensate

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

Historically, the condensate from the Similac manufacturing process was released into the Dromore River, mixed with the surface water runoff. In recent months, the condensate has been diverted to the WWTP, due to occurrences of TOC spikes recorded in the condensate stream (E1).

TOC monitors will be put in place at the facility. The analyzer is a BioTector product, which is designed for on-line continuous monitoring. Until the TOC monitor is put in place, the condensate will be diverted to the WWTP. A TOC monitor is also planned for the E2 stream from Evaporator 2.

Accidental Spills or Leaks In relation to potential pollution from accidental discharges, there is a spill prevention and control procedure, which is part of the site’s environmental management system (EMS). This procedure aims to ensure that the number of spills occurring is minimised and that those that do occur are controlled to prevent contamination. There is also an SOP for environmental incidents.

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

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7.0 MATERIALS USE & ENERGY EFFICIENCY

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

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

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

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

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

Source Year Quantity Units

Diesel/Gas Oil 2009 9,534,441 litres 2010 10,389,825.1 litres

incl. ICE 11,918,051 litres

LPG 2009 1.4 tonnes 2010 2.5 tonnes

incl. ICE 1.75 tonnes

Electricity 2009 21,240,382 kWH 2010 19.091,712 kWH

incl. ICE 26,550,478 kWH

Energy Efficiency Measures Abbott is continuously trying to reduce energy use and increase the efficiency of the facility. An energy performance review was carried out by the facility and the report was produced in April 2010, with a number of proposals to reduce energy consumption further. Abbott has in place an Energy Management System, which was certified to IS 393 in June 2009 and to IS EN 16001 – Energy Management Systems in May 2010. Energy metering is extensive throughout the site and area specific Electricity, Water, Steam, Oil and Compressed Air is monitored closely. The sites Energy Champion team consists of a representative from each area and meet monthly. Responsibilities include performing audits, suggesting reduction projects & assisting in their

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execution. There is a Standard Operating Procedure (SOP) for Energy Monitoring on site, which is part of the certified EMS to ISO14001 for the site. The energy reduction measures will continue to be implemented through the installation and operation of Project Ice.

There are also energy reduction objectives and targets, which are part of the EMS for the facility, for 2011.

8.0 ACCIDENT & EMERGENCY PROCEDURES

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

There is an accident and emergency response plan in place for the facility. This plan was updated in March 2010. In addition there is an SOP in place for accidents or incidents that may occur on site, as part of the accredited ISO14001 EMS. The full procedures are included with the main application.

9.0 AFTERCARE, DECOMMISSIONING & RESTORATION

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

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

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

10.0 CONCLUSIONS

This non-technical summary includes a brief overview of the IPPC licence review application, detailing each of the sections contained within the application that are relevant and applicable to the Abbott facility. It should be noted that, in order to obtain a comprehensive and detailed description of the facility and the activities that will be carried out there, the full application should be viewed.

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Abbott Cootehill - EPA Waste Licence Review Application AWN Consulting Limited _____________________________________________________________________________________________________

_____________________________________________________________________________________________________

Attachment A.1.1 – Site Location & Site Drawings

Drawing No. 001 Drawing Ref: 21029/CD/001 – Overall Master Site Plan Figure No.1 Site Location Plate No.1 Aerial View of Site

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Project

Abbott Cootehill IPPC Licence Review

Reference

10_5346

Figure 1

Site Location

Unit 5, ATS Building, Carrigaline Industrial Estate, Carrigaline, Co. CorkT: +353 21 438 7400 F: +353 21 483 4606

© Ordnance Survey Ireland EN0003510 Scale 1:50,000

N

Abbott Facility

N

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Project

Abbott Cootehill IPPC Licence Review

Reference

10_5346

Plate 1

Site Layout Photograph – Aerial View

Unit 5, ATS Building, Carrigaline Industrial Estate, Carrigaline, Co. CorkT: +353 21 438 7400 F: +353 21 483 4606

© Ordnance Survey Ireland EN0003510

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ABBOTT COOTEHILL EPA IPPC LICENCE REVIEW … · Abbott Cootehill IPPC Licence Review Application ... The EMS is certified to ISO14001 and it incorporates procedures for pro ... The

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