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    www.environment-agency.gov.uk

    Sector Guidance Note IPPC S6.13

    General Guidance for the Dairy and

    Milk Processing Sector

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    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 i

    Commissioning Organisation

    Environment Agency

    Rio House

    Waterside Drive

    Aztec West

    Almondsbury

    Bristol BS32 4UD

    Tel 01454 624400 Fax 01454 624409

    Environment Agency

    First Published 2001

    ISBN 0 11 3101740

    This document is Environment Agency copyright . We specifically allow the following: Internal business or personal use. You may use this document for your own private use or for use within your

    business without restriction. Giving copies to others. You may do this without restriction provided that you make no charge.

    If you wish to use this document in any way other than as set out above including in particular for commercial gain,for example by way of rental, licence, sale or providing services you should contact:

    Liz Freenland

    Data and Information Exploitation Manager

    Environment AgencyRio House

    Waterside Drive

    Aztec West

    Almondsbury

    Bristol

    BS32 4UD

    This is an uncontrolled document. To ensure you are using the latest version please check onany of the websites listed within the references.

    Written comments or suggested improvements should be sent to Mark Maleham at the Environment Agency byemail at [email protected] or at:

    Environmental Protection National Service

    Environment Agency

    Block 1

    Government Buildings

    Burghill Road

    Westbury-on-Trym

    Bristol.

    BS10 6BF

    Telephone 0117 914 2868

    Table 0.1: Record of changes

    Version Date Change Template Version

    Issue 1 October 2003 V5

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    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 ii

    Executive summary

    This guidance has been produced by the Environment Agency for England and Wales with the Scottish

    Environment Protection Agency (SEPA) and the Northern Ireland Environment and Heritage Service

    (EHS). Together these are referred to as the Regulator throughout this document. Its publication

    follows consultation with industry, government departments and non-governmental organisations.

    What is IPPC Integrated Pollution Prevention and Control (IPPC) is a regulatory system that employs an integrated

    approach to control the environmental impacts of certain industrial activities. It involves determining the

    appropriate controls for industry to protect the environment through a single Permitting process. To

    gain a Permit, Operators will have to show that they have systematically developed proposals to apply

    the Best Available Techniques (BAT) and meet certain other requirements, taking account of relevant

    local factors.

    This Guidance and the

    BREF

    This UK Guidance for delivering the PPC (IPPC) Regulations in this sector is based on the BAT

    Reference document BREF (see Ref. 1) produced by the European Commission. The BREF is the

    result of an exchange of information between member states and industry. The quality,

    comprehensiveness and usefulness of the BREF is acknowledged. This guidance is designed to

    complement the BREF and is cross-referenced to it throughout. It takes into account the information

    contained in the BREF and lays down the indicative standards and expectations in the UK (England

    and Wales, Scotland and Northern Ireland). The reader is advised to have access to the BREF.

    The aims of this Guidance The aims of this Guidance are to:

    provide a clear structure and methodology for Operators to follow to ensure they address all aspects

    of the PPC Regulations and other relevant Regulations

    minimise the effort by both Operator and Regulator in the permitting of an installation by expressing

    the BAT techniques as clear indicative standards

    improve the consistency of Applications by ensuring that all relevant issues are addressed

    increase the transparency and consistency of regulation by having a structure in which the Opera-

    tor's response to each issue, and any departures from the standards, can be seen clearly and whichenables Applications to be compared

    To assist Operators in making applications, separate, horizontal guidance is available on a range of

    topics such as waste minimisation, monitoring, calculating stack heights and so on. Most of this

    guidance is available free through the Environment Agency, SEPA or EHS (Northern Ireland) websites

    (see References)

    key environmental issues The key environmental issues for this sector are:

    Water use

    Effluent management

    Waste handling

    Accident risk

    Hygiene

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    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 iii

    Contents

    1 Introduction ..............................................................................................1

    1.1 Understanding IPPC .............................................................................................2

    1.2 Making an application ...........................................................................................51.3 Installations covered .............................................................................................6

    1.4 Timescales ............................................................................................................71.4.1 Permit review periods ............................................................................................ 71.4.2 Upgrading timescales for existing plant ................................................................. 7

    1.5 Key issues .............................................................................................................9

    1.6 Summary of releases ..........................................................................................11

    1.7 Technical overview ..............................................................................................12

    1.8 Economics ...........................................................................................................131.8.1 Sector costs ........................................................................................................ 14

    2 Techniques for pollution control ..........................................................16

    2.1 The main activities and abatement .....................................................................172.1.1 In-process controls .............................................................................................. 172.1.2 Materials handling, unpacking, storage ............................................................... 202.1.3 Pasteurisation, Sterilisation and UHT .................................................................. 212.1.4 Evaporation ......................................................................................................... 222.1.5 Drying .................................................................................................................. 232.1.6 Centrifugation and Bactofugation ........................................................................ 252.1.7 Membrane Separation ......................................................................................... 262.1.8 Ion Exchange ...................................................................................................... 272.1.9 Filtration .............................................................................................................. 282.1.10 Churning ............................................................................................................ 292.1.11 Cooling and Chilling .......................................................................................... 302.1.12 Freezing and Blast Cooling ............................................................................... 31

    2.1.13 Mixing, Blending and Homogenisation .............................................................. 322.1.14 Filling ................................................................................................................. 342.1.15 Fermentation/Incubation Process ..................................................................... 352.1.16 Cleaning and sanitation ..................................................................................... 36

    2.2 Abatement of point source emissions .................................................................412.2.1 Abatement of point source emissions to air ........................................................ 412.2.2 Abatement of point source emissions to surface water and sewer ..................... 462.2.3 Abatement of point source emissions to groundwater ........................................ 612.2.4 Control of fugitive emissions to air ...................................................................... 622.2.5 Control of fugitive emissions to surface water, sewer and groundwater ............. 652.2.6 Odour .................................................................................................................. 67

    2.3 Management techniques .....................................................................................69

    2.4 Raw materials .....................................................................................................722.4.1 Raw materials selection ...................................................................................... 722.4.2 Waste minimisation ............................................................................................. 742.4.3 Water use ............................................................................................................ 77

    2.5 Waste handling ...................................................................................................82

    2.6 Waste recovery or disposal .................................................................................83

    2.7 Energy .................................................................................................................852.7.1 Basic energy requirements (1) ............................................................................ 862.7.2 Basic energy requirements (2) ............................................................................ 872.7.3 Further energy-efficiency requirements ............................................................... 89

    2.8 Accidents .............................................................................................................90

    2.9 Noise ...................................................................................................................94

    2.10 Monitoring .........................................................................................................962.10.1 Emissions monitoring ........................................................................................ 962.10.2 Environmental monitoring (beyond installation) ................................................ 99

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    2.10.3 Monitoring of process variables ...................................................................... 1002.10.4 Monitoring standards (Standard Reference Methods) .................................... 101

    2.11 Closure ............................................................................................................103

    2.12 Installation issues ............................................................................................105

    3 Emission benchmarks .........................................................................106

    3.1 Emissions inventory ..........................................................................................106

    3.2 Emission benchmarks .......................................................................................1083.2.1 Emissions to air associated with the use of BAT ............................................... 1083.2.2 Emissions to water associated with the use of BAT .......................................... 1093.2.3 Standards and obligations ................................................................................. 1093.2.4 Units for benchmarks and setting limits in permits ............................................ 1103.2.5 Statistical basis for benchmarks and limits in permits ....................................... 1113.2.6 Reference conditions for releases to air ............................................................ 111

    3.3 Biochemical oxygen demand ............................................................................112

    3.4 Chemical oxygen demand .................................................................................114

    3.5 Halogens ...........................................................................................................115

    3.6 Heavy metals ....................................................................................................116

    3.7 Nitrogen oxides .................................................................................................117

    3.8 Nutrients (phosphates and nitrates) ..................................................................1183.9 Particulate and suspended solids .....................................................................120

    3.10 Sulphur dioxide ...............................................................................................121

    3.11 Volatile organic compounds ............................................................................122

    4 Impact ..................................................................................................123

    4.1 Impact assessment ...........................................................................................123

    4.2 Waste Management Licensing Regulations .....................................................125

    4.3 The Habitats Regulations ..................................................................................126

    References ...............................................................................................................127

    Abbreviations ...........................................................................................................130

    Appendix 1: Some common monitoring and sampling methods .............................131

    Appendix 2: Equivalent legislation in Scotland & Northern Ireland .........................135

    Appendix 3: Groundwater Regulations 1998 Sechdule of listed substances and recom-mendations for List I (DEFRA) .......................................................................137

    List of figures

    Figure 1.1: Overview of the activities within the milk processing sector ............................................. 12

    Figure 2.1: Cleaning-in-place chemical recovery membrane system ................................................. 76

    Figure 2.2: Example of four-stage counter-flow system based on pea cannery ................................. 81

    List of tables

    Table 1.1: Specific timescale improvements ......................................................................................... 8

    Table 2.1: Process monitoring and control equipment ........................................................................ 19

    Table 2.2: Abatement options for specified pollutants ........................................................................ 44

    Table 2.3: Abatement options information .......................................................................................... 45

    Table 2.4: Water treatment for the Food and Drink sector .................................................................. 57

    Table 2.5: Summary of aerobic and anaerobic treatment processes ................................................. 58

    Table 2.6: Membrane bio reator (MBR) - activated sludge (AS) comparison ..................................... 60

    Table 2.7: Raw material substitutions ................................................................................................. 74

    Table 2.8: Potential use for waste ....................................................................................................... 84

    Table 2.9: Example breakdown of delivered and primary energy consumption ................................. 86

    Table 2.10: Example format for energy efficiency plan ....................................................................... 88

    Table 2.11: Monitoring of process effluents released to watercourses ............................................... 97

    Table 2.12: Monitoring of process effluents released to sewer ........................................................... 98

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    Table 2.13: Monitoring substances released from sources ................................................................ 98

    Table 2.14: Monitoring of process variables ..................................................................................... 100

    Table 3.1: Biochemical oxygen demand: water quality objectives in England, Wales and NorthernIreland ............................................................................................................................. 112

    Table 3.2: Biochemical oxygen demand: water quality objectives in Scotland ................................. 112

    Table 3.3: Halogen standards ........................................................................................................... 115

    Table 3.4: Benchmark emission values ............................................................................................ 115

    Table 3.5: Heavy metal standards .................................................................................................... 116

    Table 3.6: Heavy metal benchmark emission values ........................................................................ 116

    Table 3.7: Nitrogen oxides benchmark emission values ................................................................... 117

    Table 3.8: Nutrients:water quality objectives in England, Wales and Northern Ireland .................... 118

    Table 3.9: Nutrients:water quality objectives in Scotland .................................................................. 118

    Table 3.10: Particulate and suspended solids in water ..................................................................... 120

    Table 3.11: Particulate and suspended solids: benchmark emission values .................................... 120

    Table 3.12: Sulphur dioxide: benchmark emission values ................................................................ 121

    Table 3.13: Volatile organic compounds: benchmark emission values ............................................ 122

    Table 4.1: Measurement methods for common substances to water ............................................... 131

    Table 4.2: Measurement methods for other substances to water ..................................................... 132

    Table 4.3: Measurement methods for air emissions ......................................................................... 134

    Table 4.4: Equivalent legislation ....................................................................................................... 135

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    Introduction Techniques Emissions Impact

    Understand-ing IPPC

    Making anapplication

    Installationscovered

    Timescales Key issues Summary of releases

    Technicaloverview

    Economics

    Introduction

    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 1

    1 Introduction

    The status and aims of

    this Guidance

    This Guidance has been produced by the Environment Agency for England and Wales, with the

    Scottish Environment Protection Agency (SEPA) and the Environment and Heritage Service (EHS) in

    Northern Ireland - each referred to as the Regulator in this document. Its publication follows

    consultation with industry, Government departments and non-governmental organisations.

    It aims to provide Operators and the Regulators officers with advice on indicative standards of

    operation and environmental performance relevant to the industrial sector concerned, to assist the

    former in the preparation of applications for PPC Permits and to assist the latter in the assessment of

    those Applications (and the setting of a subsequent compliance regime). The use of techniques quoted

    in the guidance and the setting of emission limit values at the benchmark values quoted in the guidance

    are not mandatory, except where there are statutory requirements from other legislation. However, the

    Regulator will carefully consider the relevance and relative importance of the information in the

    Guidance to the installation concerned when making technical judgments about the installation and

    when setting Conditions in the Permit, any departures from indicative standards being justified on a

    site-specific basis.

    The Guidance also aims (through linkage with the Application Form or template) to provide a clear

    structure and methodology for Operators to follow to ensure they address all aspects of the PPC

    Regulations and other relevant Regulations, that are in force at the time of writing. Also, by expressing

    the Best Available Techniques (BAT) as clear indicative standards wherever possible, it aims to

    minimise the effort required by both Operator and Regulator to apply for and issue, respectively, a

    Permit for an installation.

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    Introduction Techniques Emissions Impact

    Understand-ing IPPC

    Making anapplication

    Installationscovered

    Timescales Key issues Summary of releases

    Technicaloverview

    EconomicsUnderstandingIPPC

    Introduction

    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 2

    1.1 Understanding IPPC

    IPPC and the Regulations Integrated Pollution Prevention and Control (IPPC) is a regulatory system that employs an integratedapproach to control the environmental impacts of certain listed industrial activities. It involves

    determination by the Regulator of the appropriate controls for those industries to protect the

    environment, through a single permitting process. To gain a Permit, Operators have to demonstrate in

    their Applications, in a systematic way, that the techniques they are using or are proposing to use, are

    the Best Available Techniques (BAT) for their installation, and meet certain other requirements, taking

    account of relevant local factors.

    The essence of BAT is that the techniques selected to protect the environment should achieve an

    appropriate balance between environmental benefits and the costs incurred by Operators. However,

    whatever the costs involved, no installation may be permitted where its operation would cause

    significant pollution.

    IPPC operates underThe Pollution Prevention and Control Regulations(for equivalent legislation in

    Scotland and N Ireland see Appendix 2). The three regional versions of the PPC Regulations

    implement in the UK the EC Directive on IPPC (96/61/EC). Further information on the application of

    IPPC/PPC, together with Government policy and advice on the interpretation of the English & Welsh

    Regulations, can be found in IPPC: A Practical Guide published by the Department for Environment,

    Food and Rural Affairs (Defra). Equivalent guidance on the Scottish Regulations is provided in PPC

    Regulations: A Practical Guide (Part A Activities), published by the Scottish Executive and SEPA.

    The Department of the Environment, Northern Ireland has published equivalent guidance on its

    Regulations.

    Installation based, NOT

    national emission limits

    The BAT approach of IPPC differs from regulatory approaches based on fixed national emission limits

    (except where General Binding Rules or Standard Permits are issued). The legal instrument that

    ultimately defines BAT is the Permit, and Permits can only be issued at the installation level.

    Indicative BAT Standards Indicative BAT standards are laid out in national guidance (such as this) and, where relevant, should be

    applied unless a different standard can be justified for a particular installation. BAT includes the

    technical components, process control, and management of the installation given in Section 2, and the

    benchmark levels for emissions identified in Section 3. Departures from those benchmark levels can

    be justified at the installation level by taking into account the technical characteristics of the installation

    concerned, its geographical location and the local environmental conditions. If any mandatory EU

    emission limits or conditions are applicable, they must be met, but BAT may go further (see BAT and

    EQS below).

    Some industrial sectors for which national guidance is issued are narrow and tightly defined, whilst

    other sectors are wide and diffuse. This means that where the guidance covers a wide variety of

    processes, and individual techniques are not described in detail, the techniques (and their associated

    emission levels) which might constitute BAT for a particular operation, are more likely to differ, with

    justification, from the indicative BAT standards than would be the case for a narrow, tightly-defined

    sector.

    BAT and EQS The BAT approach complements, but differs fundamentally from, regulatory approaches based on

    Environmental Quality Standards (EQS). Essentially, BAT requires measures to be taken to prevent

    emissions - and measures that simply reduce emissions are acceptable only where prevention is not

    practicable. Thus, if it is economically and technically viable to reduce emissions further, or prevent

    them altogether, then this should be done irrespective of whether or not EQSs are already being met.

    The BAT approach requires us not to consider the environment as a recipient of pollutants and waste,

    which can be filled up to a given level, but to do all that is practicable to minimise emissions from

    industrial activities and their impact. The BAT approach first considers what emission prevention can

    reasonably be achieved (covered by Sections 2 and 3 of this Guidance) and then checks to ensure that

    http://../DETR_IPPC_practical_guide/detrprac.dochttp://../DETR_IPPC_practical_guide/detrprac.doc
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    Understand-ing IPPC

    Making anapplication

    Installationscovered

    Timescales Key issues Summary of releases

    Technicaloverview

    EconomicsUnderstandingIPPC

    Introduction

    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 3

    the local environmental conditions are secure (see Section 4 on page 123 of this Guidance and also

    Guidance NoteIPPC Environmental Assessments for BAT). The BAT approach is therefore the

    more precautionary one because the release level achieved may be better than that simply required to

    meet an EQS.

    Conversely, if the application of indicative BAT might lead to a situation in which an EQS is still

    threatened, a more effective technique is required to be BAT for that installation. The Regulations allow

    for expenditure beyond indicative BAT where necessary, and, ultimately, an installation will only be

    permitted to operate if it does not cause significant pollution.

    Further advice on the relationship between BAT, EQSs and other related standards and obligations is

    given in IPPC: A Practical Guide, its Scottish equivalent, and also in Section 3.

    Assessing BAT at the

    sector level

    The assessment of indicative BAT takes place at a number of levels. At the European level, the

    European Commission issues a BAT reference document (BREF) for each main IPPC sector. It also

    issues horizontal BREFs for a number of general techniques which are relevant across a series of

    industrial sectors. The BREFs are the result of an exchange of information between regulators, industry

    and other interested parties in Member States. Member States should take them into account whendetermining BAT, but they are allowed flexibility in their application. UK Sector Guidance Notes like this

    one take account of information contained in relevant BREFs and set out current indicative standards

    and expectations in the UK. At national level, techniques that are considered to be BAT should

    represent an appropriate balance of costs and benefits for a typical, well-performing installation in the

    sector concerned. They should also be affordable without making the sector as a whole uncompetitive,

    either within Europe or world-wide.

    Assessing BAT at the

    installation level

    When assessing applicability of sectoral indicative BAT standards at the installation level, departures

    may be justified in either direction. Selection of the technique which is most appropriate may depend

    on local factors and, where the answer is not self-evident, an installation-specific assessment of the

    costs and benefits of the available options will be needed. The Regulators guidance IPPC

    Environmental Assessments for BAT and its associated software tool may help with the assessment.Individual installation or company profitability (as opposed to profitability of the relevant sector as a

    whole) is not a factor to be considered, however.

    In the assessment of BAT at the installation level, the cost of improvements and the timing or phasing of

    that expenditure, are always factors to be taken into account. However, they should only be major or

    decisive factors in decisions about adopting indicative BAT where:

    the installations technical characteristics or local environmental conditions can be shown to be so

    different from those assumed in the sectoral assessment of BAT described in this guidance, that the

    indicative BAT standards may not be appropriate; or

    the BAT cost/benefit balance of an improvement only becomes favourable when the relevant item of

    plant is due for renewal/renovation (eg. change to a different design of furnace when the existing

    furnace is due for a rebuild). In effect, these are cases where BAT for the sector can be expressed

    in terms of local investment cycles; or

    a number of expensive improvements are needed. In these cases, a phasing programme may be

    appropriate - as long as it is not so drawn out that it appears to be rewarding a poorly performing

    installation.

    In summary, departures by an individual installation from indicative BAT for its sector may be justified

    on the grounds of the technical characteristics of the installation concerned, its geographical location

    and the local environmental conditions - but not on the basis of individual company profitability, or if

    significant pollution would result. Further information on this can be found in IPPC: A Practical Guide

    and IPPC Part A(1) Installations: Guide for Applicants, or the equivalent Scottish Guidance.

    Innovation The Regulators encourage the development and introduction of innovative techniques that advanceindicative BAT standards criteria, ie. techniques which have been developed on a scale which

    reasonably allows implementation in the relevant sector, which are technically and economically viable

    http://../DETR_IPPC_practical_guide/detrprac.dochttp://../DETR_IPPC_practical_guide/detrprac.dochttp://../DETR_IPPC_practical_guide/detrprac.dochttp://../Guide_for_applicants/A1Guide.pdfhttp://../Guide_for_applicants/A1Guide.pdfhttp://../DETR_IPPC_practical_guide/detrprac.dochttp://../DETR_IPPC_practical_guide/detrprac.doc
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    Understand-ing IPPC

    Making anapplication

    Installationscovered

    Timescales Key issues Summary of releases

    Technicaloverview

    EconomicsUnderstandingIPPC

    Introduction

    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 4

    and which further reduce emissions and their impact on the environment as a whole. One of the main

    aims of the PPC legislation is continuous improvement in the overall environmental performance of

    installations as a part of progressive sustainable development. This Sector Guidance Note describes

    the indicative BAT standards at the time of writing but Operators should keep up-to-date with

    improvements in technology - and this Guidance note cannot be cited as a reason for not introducing

    better available techniques. The technical characteristics of a particular installation may also provide

    opportunities not foreseen in the Guidance, and as BAT is determined at the installation level (except in

    the case of General Binding Rules (GBRs)), it is a requirement to consider these even where they go

    beyond the indicative Standards.

    New installations Indicative BAT standards apply, where relevant, to both new and existing installations, but it will be

    more difficult to justify departures in the case of new installations (or new activities in existing

    installations) - and for new activities, techniques which meet or exceed indicative BAT requirements

    should normally be in place before operations start.

    Existing installations -

    standards

    For an existing installation, it may not be reasonable to expect compliance with indicative BAT

    standards immediately if the cost of doing so is disproportionate to the environmental benefit to beachieved. In such circumstances, operating techniques that are not at the relevant indicative BAT

    standard may be acceptable, provided that they represent what is considered BAT for that installation

    and otherwise comply with the requirements of the Regulations. The determination of BAT for the

    installation will involve assessment of the technical characteristics of the installation and local

    environmental considerations, but where there is a significant difference between relevant indicative

    BAT and BAT for an installation, the Permit may require further improvements on a reasonably short

    timescale.

    Existing installations -

    upgrading timescales

    Where there are departures from relevant indicative BAT standards, Operators of existing installations

    will be expected to have upgrading plans and timetables. Formal timescales for upgrading will be set

    as Improvement Conditions in the Permits. See Section 1.4.2 on page 7 for more details.

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    Understand-ing IPPC

    Making anapplication

    Installationscovered

    Timescales Key issues Summary of releases

    Technicaloverview

    EconomicsMaking anapplication

    Introduction

    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 5

    1.2 Making an application

    A satisfactory Application is made by: addressing the issues in Sections 2 and 3 of this guidance;

    assessing the environmental impact described in Section 4 (and in England and Wales Environ-

    mental Assessment and Appraisal of BAT (IPPC H1));

    demonstrating that the proposed techniques are BAT for the installation.

    In practice, some Applicants have submitted far more information than was needed, yet without

    addressing the areas that are most important - and this has led to extensive requests for further

    information. In an attempt to focus application responses to the areas of concern to the Regulator,

    Application forms (templates) have been produced by the Environment Agency, by SEPA and by EHS

    in N Ireland. In addition, as the dates for application have approached, the operators in most industrial

    sectors in England and Wales have been provided with Compact Discs (CDs) which contain all relevant

    Application Forms, technical and administrative guidance, BREFs and Assessment tools, hyper-linkedtogether for ease of use.

    For Applicants with existing IPC Authorisations or Waste Management Licences, the previous

    applications may provide much of the information for the PPC application. However, where the

    submitted Application refers to information supplied with a previous application the Operator will need

    to send fresh copies - though for many issues where there is a tendency for frequent changes of detail

    (for example, information about the management systems), it will be more appropriate simply to refer to

    the information in the Application and keep available for inspection on site, up-to-date versions of the

    documents.

    For further advice see IPPC Part A(1) Installations: Guide for Applicants (for England and Wales)

    orPPC Part A Installations: Guide for Applicants (for Scotland) or the equivalent Northern Irelandguide for Applicants.

    http://../cross-sector_guidance/H1.pdfhttp://../cross-sector_guidance/H1.pdfhttp://../Guide_for_applicants/A1Guide.pdfhttp://../Guide_for_applicants/A1Guide.pdfhttp://../cross-sector_guidance/H1.pdfhttp://../cross-sector_guidance/H1.pdf
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    Understand-ing IPPC

    Making anapplication

    Installationscovered

    Timescales Key issues Summary of releases

    Technicaloverview

    EconomicsInstallationscovered

    Introduction

    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 6

    1.3 Installations covered

    This Guidance relates to installations containing the activities listed below, as described in Part A(1) ofSchedule 1 to the The Pollution Prevention and Control Regulations. The schedules of listed

    activities are slightly different in Scotland and Northern Ireland so for their equivalent Regulations see

    Appendix 2

    Section 6.8

    (e) Treating and processing milk, the quantity of milk received being greater than 200 tonnes per

    day (average value on an annual basis).

    The installation includes the main activities as stated above and associated activities which have a

    technical connection with the main activities and which may have an effect on emissions and pollution.

    They include, as appropriate:

    Raw milk reception Pasteurisation

    Cheesemaking

    Butter

    Yogurt production

    Packing

    Cleaning

    Refrigeration

    the control and abatement systems for emissions to all media;

    the power plant

    The installation will also include associated activities which have a technical connection with the mainactivities and which may have an effect on emissions and pollution, as well as the main activities

    described above. These may involve activities such as:

    the storage and handling of raw materials;

    the storage and despatch of finished products, waste and other materials;

    the control and abatement systems for emissions to all media;

    waste treatment or recycling.

    Environment Agency advice on the composition of English or Welsh installations and which on-site

    activities are to be included within it (or them) is given in its guidance document The Pollution

    Prevention and Control Regulations (SI 2000 No. 1973) (www.hmso.gov.uk).. Operators are

    advised to discuss the composition of their installations with the Regulator before preparing their

    Applications.

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    1.4 Timescales

    1.4.1 Permit review periods

    Permits are likely to be reviewed as follows:

    for individual activities not previously subject to regulation under IPC or Waste Management Licens-

    ing, a review should be carried out within four years of the issue of the PPC Permit

    for individual activities previously subject to regulation under IPC or Waste Management Licensing,

    a review should be carried out within six years of the issue of the IPPC Permit

    However, where discharges of Groundwater List I or List II substances have been permitted, or wherethere is disposal of any matter that might lead to an indirect discharge of any Groundwater List I or II

    substance, a review must be carried out within four years as a requirement of the Groundwater

    Regulations.

    These periods will be kept under review and, if any of the above factors change significantly, they may

    be shortened or extended.

    1.4.2 Upgrading timescales for existing plant

    Existing installation

    timescales

    Unless subject to specific conditions elsewhere in the Permit, upgrading timescales will be set in the

    Improvement Programme of the Permit, having regard to the criteria for improvements in the following

    two categories:

    1 Standard good-practice requirements, such as, management systems, waste, water and energy

    audits, bunding, housekeeping measures to prevent fugitive or accidental emissions, good waste-

    handling facilities, and adequate monitoring equipment. Many of these require relatively modest

    capital expenditure and so, with studies aimed at improving environmental performance, they

    should be implemented as soon as possible and generally well within 3 years of issue of the Permit.

    2 Larger, more capital-intensive improvements, such as major changes to reaction systems or the

    installation of significant abatement equipment. Ideally these improvements should also be com-pleted within 3 years of Permit issue, particularly where there is considerable divergence from rele-

    vant indicative BAT standards, but where justified in objective terms, longer time-scales may be

    allowed by the Regulator.

    Local environmental impacts may require action to be taken more quickly than the indicative timescales

    above, and requirements still outstanding from any upgrading programme in a previous permit should

    be completed to the original time-scale or sooner. On the other hand, where an activity already

    operates to a standard that is close to an indicative requirement a more extended time-scale may be

    acceptable. Unless there are statutory deadlines for compliance with national or international

    requirements, the requirement by the Regulator for capital expenditure on improvements and the rate

    at which those improvements have to be made, should be proportionate to the divergence of the

    installation from indicative standards and to the environmental benefits that will be gained.

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    The Operator should include in the Application a proposed programme in which all identified

    improvements (and rectification of clear deficiencies) are undertaken at the earliest practicable

    opportunities. The Regulator will assess BAT for the installation and the improvements that need to be

    made, compare them with the Operators proposals, and then set appropriate Improvement Conditions

    in the Permit

    All improvements should be carried out at the earliest opportunity and to a programme approved by the

    Regulator. Any longer timescales will need to be justified by the Operator.

    The Applicant should include a proposed timetable covering all improvements.

    Table 1.1: Specific timescale improvements

    Improvement By whichever is the later of:

    Activities under Section 6.8di

    (see Section 1.3) Animal raw

    materials

    Activities under Section 6.8dii

    and 6.8e (see Section 1.3)

    Vegetable raw materials and

    milk

    Waste minimisation audit in

    accordance with Section 2.4.2

    on page 74

    31 August 2005

    or one year from the issue of

    the Permit

    31 March 2006

    or one year from the issue of

    the Permit

    A review of water use (water

    efficiency audit) in accordance

    with Section 2.4.3 on page 77

    31 August 2005

    or one year from the issue of

    the Permit

    31 March 2006

    or one year from the issue of

    the Permit

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    1.5 Key issues

    An assessment of the issues indicates that there are no areas where there is a fundamental clashbetween good environmental practice and good business practice. However the implementation of

    pollution prevention and control measures represents a balance between environmental protection and

    costs incurred by the operators and will not always result in cost savings for the operator.

    Waste minimisation

    Commercial considerations mean that the controls of parameters such as process yield and product

    wastage are usually understood. These parameters are also key pollution prevention issues as product

    loss accounts for a significant proportion of the sectors environmental impact.

    Water use

    The sector is a significant water consumer, the vast majority of which is used for cleaning, both

    manually and in CIP (cleaning in place) systems, which are widely used throughout the industry. In

    addition to minimising the use of a raw material, measures to optimise water use will be important

    pollution prevention measures relating to effluent management. There are a number of opportunities to

    either reuse water (for example low-grade wash waters) or to recycle water from for example

    membrane systems (also see Hygiene and Food Safety).

    Releases associated with energy use

    The industry is a major energy user. There remain significant opportunities for reduction of emissions

    caused by energy use and choice of energy source (CO2, SOx, NOx, etc. contributing in particular to

    global warming and acidification). The dairy industry has entered into a Climate Change Levy

    Agreement with the Government, dated the 6th March 2001. The applicability of techniques and

    standards for IPPC is explained in Section 2.6.

    Emissions to air

    It is an inherent factor within the food, drink and dairy industries that emissions of VOC and odour arise,

    for example from drying and other processes, including effluent treatment. Emissions of dust and

    particulate material can also be a factor from milk powder drying and the transfer of materials. Odour

    emissions can be problematic, not only because of the sometimes subjective nature of the problem, but

    as emissions tend to be fugitive. Other fugitive emissions considerations include those potentially

    arising from refrigeration, cooling and effluent treatment systems.

    Effluent management

    The composition of the effluent within the dairy industry is very highly variable, dependant on the

    activity, working patterns, product wastage and cleaning systems. Of these the most important iskeeping raw materials, intermediates, product and by product out of the wastewaters, by controlling

    product wastage and cleaning processes.

    Accident risk

    All types of milk, cream and most other dairy products have a very high oxygen demand and spills and

    leaks into the water environment are serious events. In addition to normal spills and process leaks,

    they typically arise from for example, overfilling of vessels and failure of containment, wrong drainage

    connections and blocked drains.

    Hygiene and food safety

    Health and safety and product quality issues apply to industry as a whole, but hygiene and food safetyis of fundamental importance to the dairy sector. Consequently particular attention must be given to

    these considerations when specifying particular techniques, especially in relation to pollution prevention

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    measures, in for example measures relating to water use, cleaning and reuse and recycling of water.

    Industry experience of managing risk in relation to hygiene and food safety issues is a sound basis for

    environmental management issues.

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    1.6 Summary of releases

    Note:

    1. Most of the other releases to water pass through the effluent treatment plant (ETP). Included here

    are only those which arise as a direct result of the operation of the ETP.

    2. Releases to air usually result in a subsequent, indirect emission to land and can therefore affect

    human health, soil and terrestrial ecosystems.

    3. Releases identified above to water can all also appear in the effluent treatment sludge (see Section

    2.5 on page 82).

    Storagean

    dhandlingofraw

    Cuttingand

    Mixingand

    blending(powdersand

    Mixing,

    blen

    dingandhomogenisation(solid/liquid

    )

    Pasteurisationandsterilisation

    Dryingand

    evaporation

    Cleaninga

    ndsanitisation

    Storagean

    ddispatchoffinished

    Coolingan

    drefrigeration

    Boilerand

    Combustionplant

    Effluentplant(Note1)

    Oxides of sulphur - - - - - - - - - A -

    Oxides of nitrogen & car-

    bon

    - - - - - - - - - - -

    Particulate/TSS AW W AW W W AW AW AW - A W

    COD/BOD W W - W W W W W - - W

    Odour A AW W A AW A A A - A A

    Biocides - W - - - - W - - - W

    Dispersants & sur-

    factants

    - - - - - - W - - - -

    Phosphates & nitrates - - - - - W - - - -

    Refrigerants

    Ammonia, HCFC, Glycol

    - - - - - - - AW W W

    Sludges - - - - - - - - L

    KEY A Release to Air, W Release to Water, L Release to Land

    SOURCE

    RELEASES

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    1.7 Technical overview

    Figure 1.1: Overview of the activities within the milk processing sector

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    1.8 Economics

    The food and drink industry is an important part of the manufacturing industry in the UK. It is the largestindustrial sector in turnover terms: with a market value in excess of 90 billion. . It is a large and

    diverse sector and accounts for about 9% of manufacturing output and a commensurate fraction of the

    jobs available in UK manufacturing. Table 1-1 shows a breakdown of the main activities by SIC code

    and it is clear that a wide range of activities is represented.

    Almost half of the milk sold to first-hand buyers under wholesale contract is used to supply the liquid

    market, with the remainder being processed into a widening range of milk products. Much of the this

    manufactured product is sold to consumers (e.g. as cream, butter or cheese) but large quantities are

    also used by food manufacturers as ingredients in the production of a vast range of foods.

    At one time, much of the by-product (such as skim milk and whey) was of minimal value and was fed to

    livestock, particularly at times of seasonal surplus. However, such end-uses have diminished as the

    industry has sought to extract the maximum value from each litre of milk produced and as quotas have

    sharply reduced milk output. As a result, the vast majority of milk leaving the farm is now destined for

    human consumption. However, as the table below suggests, there is a mix in size of the dairy

    companies within England and Wales, with around 38% of them processing in excess of 30 million

    litres/year, although many more smaller companies processing up to 30 million litres/year.

    The dairy industry is extremely complex and can be characterised as follows:

    there are a wide range of unit operations

    some of the unit operations such as pasteurisation, are not well known outside of the immediate

    industry

    the consumer market is becoming more sophisticated and demanding

    there is a continual need for process innovation

    plant and equipment needs to be flexible to respond to changes in demand

    quality of production is paramount (and is matched only by pharmaceutical standards)

    These factors contribute to making the plant and equipment of dairy food production increasingly

    complex. Associated abatement equipment needs to be equally flexible and adaptable. There is a

    potential reluctance to invest in large capital abatement plant when it may be made redundant by a

    change in the production process, however, changes in the process are opportunities for environmental

    investment.

    The food and dairy market-place is characterised by:

    Short time-to-market and competitiveness, where the time between product conception and deliver-

    ing the product to the market-place is continually reducing; against a background of increasing com-

    petitiveness and reduced margins, the emphasis during product development is on the production

    process itself.

    Size Band

    (million litres/year)

    No. of Companies

    processing milk

    Percent of Total

    1 and under 15 13.3%

    Between 1 and 10 35 31.0%

    Between 10 and 30 19 16.8%

    Between 30 and 100 23 20.4%

    Over 100 21 18.6%

    TOTAL 113 100%

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    Product innovation with more and more product variations available now to the consumer; this

    implies that existing products face stiffer competition and product lifetimes become shorter, with the

    result that manufacturing processes and production lines require change more frequently.

    Product complexity with the introduction of new flavours, mixtures and combinations of products,

    pre-prepared products, new packaging, etc..

    The production runs also become shorter as tastes change more frequently.

    Raw materials are generally natural and are therefore more variable than other sectors.

    All of these factors contribute to the dynamic and complex nature of dairy food production. While this

    can imply the potential for more frequent upgrade of processing equipment, it has the drawback of

    providing a degree of instability. With the end of the end of the Milk Marketing schemes in 1994, the milk

    market in the UK was opened up for greater competition, both for producers selling their milk and for the

    processors buying the milk. However, the price ex. farm has dropped significantly over the past few

    years, as the table below shows:

    N.B.: Data from Dairy Facts and Figures see Ref. 8. 2000 data based on January to November only

    This highlights the drop in revenues experienced by the farmers, which has also resulted in a drop in

    milk prices at the supermarkets. The current (December 2001) cost of a 4-pint polybottle (2.27 Litres) is93pence, which equates to a cost of c. 40 pence per litre to the consumer.

    This means that the simple milk processing companies, those who take farm milk for liquid consumption

    in either polybottles for the supermarkets or glass for the declining doorstep delivery market operate at

    low margins. This requires them to be very efficient in all manner of production, not least in wastage of

    raw materials. The most successful companies are therefore the most efficient. Considering the

    manufacturing companies, there is more scope for adding value to their products and hence profit

    margins are greater.

    1.8.1 Sector costs

    Costs, both capital and revenue, for effluent treatment at dairy plants are site specific, and can vary

    markedly depending on effluent volumes and loadings, as well as ancillary items such as:

    Landscaping, fencing or planting requirements

    Access roadways

    Ground conditions (e.g., piling requirements)

    However, in order to provide some specific information, some example projects and costs are provided

    below.

    YEAR UK Farm Gate Prices, pence per litre

    (including bonus payments)

    1995 24.94

    1996 25.02

    1997 22.12

    1998 19.37

    1999 18.35

    2000(1) 16.89

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    N.B.: Costs assume 2001 base, with inflationary increases of 5%pa.

    In all cases, it is recommended that competent professional assistance is sought to provide a detailed

    design specification, against which prospective contractors can quote. This provides for competitive

    quotations on a like-for-like basis.

    For revenue costs, again the actual costs will be site specific but as a guideline, the following figures

    provide a reference:

    Conventional Activated sludge = 16pence/kgCOD treated

    Conventional filtration plants = 12pence/kgCOD treated

    MBR activated sludge = 19pence/kgCOD treated

    These costs are based on electricity and sludge disposal only.

    As a comparison, the average cost of discharging dairy effluent to sewer for treatment at a local sewage

    works by the Water Service plc will be 56 pence/kgCOD, assuming 3,000 mg/l COD and 800 mg/l TSS.

    This is based on the standard Trade Effluent Charging tariffs and does not include the Scottish water

    companies.

    Project Total Cost

    at 2001 prices

    Crude Effluent Final Effluent Plant Outline

    Volume

    m3/day

    Loading

    kgCOD/

    d

    A 660,000 300 1,000 40:60 Primary screening,

    4,800m3 HDPE-lined

    lagoon, 8.5m diameter

    settlement tank

    B 2.8 million 1,230 5,240 20:30:5 Anoxic tank, 13,000m3

    concrete tank, 15m diam

    settlement tank and sand

    filters

    C 1.0 million 1,800 6,720 25:25 Retrofit to existing plant,

    including 3,000m3 aera-

    tion tank, 1,000m3 bal-

    ance tank, 2 settlement

    tanks

    D 200,000 500 2,000 25:40:25 Retrofit to remove old

    technology filter plant,

    replace with activated

    sludge

    E 160,000 1,000 N/A N/A Pump sump and fat trap,300m3 balance and 50m3

    divert tank and control

    equipment

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    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandling

    Wasterecovery ordisposal

    Energy Accidents Noise Monitoring Closure Installationissues

    Economics

    Techniques for pollution control

    2 Techniques for pollution control

    BAT Boxes to help in

    preparing applications

    To assist Operators and the Regulators officers in respectively making and determining applications for

    PPC Permits, this section summarises the indicative BAT requirements (i.e. what is considered to

    represent BAT for a reasonably efficiently operating installation in the sector). The indicative BAT

    requirements may not always be absolutely relevant or applicable to an individual installation, when

    taking into account site-specific factors, but will always provide a benchmark against which individual

    Applications can be assessed.

    Summarised indicative BAT requirements are shown in the BAT boxes, the heading of each BAT box

    indicating which BAT issues are being addressed. In addition, the sections immediately prior to the

    BAT boxes cover the background and detail on which those summary requirements have been based.

    Together these reflect the requirements for information laid out in the Regulations, so issues raised in

    the BAT box or in the introductory section ahead of the BAT box both need to be addressed in

    any assessment of BAT.

    Although referred to as indicative BAT requirements, they also cover the other requirements of the PPC

    Regulations and those of other Regulations such as the Waste Management Licensing Regulations

    (see Appendix 2 for equivalent legislation in Scotland and Northern Ireland) and the Groundwater

    Regulations, insofar as they are relevant to PPC permitting.

    For further information on the status of indicative BAT requirements, see Section 1.1 on page 2 of this

    guidance orGuidance for applicants.

    It is intended that all of the requirements identified in the BAT sections, both the explicit ones in the BAT

    boxes and the less explicit ones in the descriptive sections, should be considered and addressed by theOperator in the Application. Where particular indicative standards are not relevant to the installation in

    question, a brief explanation should be given and alternative proposals provided. Where the required

    information is not available, the reason should be discussed with the Regulator before the Application is

    finalised. Where information is missing from the Application, the Regulator may, by formal notice,

    require its provision before the Application is determined.

    When making an Application, the Operator should address the indicative BAT requirements in this

    Guidance Note, but also use the Note to provide evidence that the following basic principles of PPC

    have been addressed:

    The possibility of preventing the release of harmful substances by changing materials or processes

    (see Section 2.1 on page 17), preventing releases of water altogether (see Section 2.2.2 on page

    46), and preventing waste emissions by reuse or recovery, have all been considered, and

    Where prevention is not practicable, that emissions that may cause harm have been reduced and

    no significant pollution will result.

    This approach should assist Applicants to meet the requirements of the Regulations to describe in the

    Applications techniques and measures to prevent and reduce waste arisings and emissions of

    substances and heat - including during periods of start-up or shut-down, momentary stoppage, leakage

    or malfunction.

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    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandling

    Wasterecovery ordisposal

    Energy Accidents Noise Monitoring Closure Installationissues

    The mainactivities andabatement

    Techniques for pollution control

    2.1 The main activities and abatement

    (includes directly associated activities in accordance with the PPC Regulations)

    2.1.1 In-process controls

    Improved process control inputs, conditions, handling, storage and effluent generation will minimise

    waste by reducing off-specification product, spoilage, loss to drain (for example, fitting a level switch,

    float valve, or flow meter will eliminate waste from overflows), overfilling of vessels, water use and other

    losses.

    Product loss or wastage is a significant benchmark for the dairy industry and is a useful guideline for an

    operator to assess the performance of the installation against industry standards. In assessing the

    wastage efficiency of milk processing sites, two co-efficients are used to measure milk loss and water

    usage:

    %COD (or milk) loss to effluent (measured as COD)

    Effluent:Milk Intake Ratio (or Water:Milk Intake Ratio)

    These techniques have been used for many years, and have proven themselves much more accurate

    than trying to assess %milk loss using yield calculations or mass balances, which are used by the

    majority of the dairy companies in the UK. Mass balance or yield figures often give negative variances

    (milk is gained instead of lost which is clearly impossible), whereas this never occurs when actually

    measuring the loss to effluent using %COD loss techniques.

    To calculate the %COD loss to effluent, the procedure is to use effluent loadings and compare this

    against the milk intake, converted to kgCOD, as follows:

    To do this we usually consider the COD equivalent of milk as 220 kgCOD/m3, or 220,000 mg/l, although

    this can vary depending on butterfat content, SNF ratios, etc. As an example, consider a site with a the

    following conditions:

    Milk intake:650,000 lpd

    Effluent volume:1,200 m3/day

    Indicative BAT requirements:

    1 See each subsection of this section 2.1.

    Effluent Load, kgCOD

    Milk Intake, as kgCOD

    %COD loss = x 100

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    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandling

    Wasterecovery ordisposal

    Energy Accidents Noise Monitoring Closure Installationissues

    The mainactivities andabatement

    Techniques for pollution control

    Effluent loading:3,650 kgCOD/day

    The effluent:milk ratio (or water:milk ratio) is simply a ratio between the amount of effluent or water used

    compared against milk or product intake. Again, this allows for comparison across similar processing

    sites. Using the example above, the effluent:milk ratio would be 1,200/650 or 1.84:1.0, which means

    that 1.84 litres of effluent are generated for every litre of milk processed.

    Good wastage co-efficients for simple milk processing sites would be c. 1.5% milk loss to effluent and c.

    1.5:1 effluent:milk ratio. Some sites with excellent wastage management can (and do) achieve less

    than 1% milk loss to effluent and an effluent:milk ratio of 1:1, or less. Sites with poor wastage

    management, or inefficient processing profiles, can have losses in excess of 5% milk loss.

    Clearly, these figures can only be a guide as actual wastage performance depends on many other

    factors including product type and mix, processing profiles, plant utilisation efficiency, age of processing

    equipment and control systems, and effluent pressure. Using these techniques as part of the wastage

    monitoring for the site will allow the operator to demonstrate historical wastage performance and

    highlight improvements as part of an overall wastage control campaign

    The factors that influence wastage control on a dairy include, but are not limited to the following:

    Management awareness and motivation to improve wastage

    Operator awareness

    Measurement of losses

    Constraints on the effluent disposal route

    Process design of the CIP systems

    Plant utilisation efficiency and downtime

    Willingness to invest time money and effort

    For example, consider a small traditional cheese-making factory, with a high desire to implement

    wastage control to reduce Trade Effluent Charges, and having a committed management team.

    Despite the oldest of equipment and processes within the dairy, they achieved losses measured at

    0.88% COD loss and an effluent:milk ratio of 0.89.

    Consider, also a very large multiproduct dairy with a milk intake capacity of over 1,000,000 li tres/day,

    but only handling around 380,000 litres/day. This plant has a large effluent plant (due to its maximum

    capacity) but with little pressure to monitor losses as the effluent discharge is well within specification.

    The losses here are 8.44% COD loss and 3.85 effluent:milk ratio.

    Finally, consider a another large manufacturing dairy, with a very focussed management team, with

    effluent pressure due to an old, not very efficient effluent plant discharging into a trout river. The factory

    was equipped with simple but effective wastage monitoring, including individual drain lines to enable

    checking on CIP systems, etc., and achieved 0.77% COD loss and a 1.21 effluent:milk ratio. Despite

    these figures, further on-site survey work highlighted savings of 149,000 pa in product, water and

    effluent costs.

    To successfully tackle wastage control and maintain impetus within a factory requires a consideration of

    all the points detailed above. In addition, a systematic approach is essential for action to be effective,

    and the one outlined below will provide some guidance:

    %COD loss =3,650 kgCOD

    650m3 x 220

    x 100

    %COD loss = 2.55

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    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandling

    Wasterecovery ordisposal

    Energy Accidents Noise Monitoring Closure Installationissues

    The mainactivities andabatement

    Techniques for pollution control

    Determine the size of the problem - this requires effluent monitoring to be set up to provide information

    on wastewater loadings (kgCOD and volume). This information can be converted into product or

    money equivalents, and the loss co-efficients mentioned above can be calculated. If youre not

    monitoring it.you cant manage it

    Set targets/objectives/KPIs - this could be a reduction in daily kgCOD or volume, a percentage

    reduction in Trade Effluent Charges, or any other specific objective. As with all objectives, the target

    should be measurable, realistic and agreed by those who are going to implement it and achievable.

    Investigate/isolate high loss areas - this is often where factory personnel provide the best input for

    suggestions and information. Specific machines or departments can be assessed or a complete factory

    effluent audit conducted, itemising the effluent loadings from all manufacturing and cleaning processes.

    Catching people doing things RIGHT can be key to ensuring their commitment and interest.

    Action - this stage may mean an input of capital or revenue expenditure for pipework or recovery

    systems, but this can be offset against the potential savings. All financial input should have a return on

    investment, and following completion this should be audited to prove the savings. Often changes in

    working practices or techniques will provide savings without the need for any additional expenditure.

    Continue monitoring and review - has the action worked? Have we reached target? Do we re-set our

    target for further improvements?

    Selection of process techniques also has a bearing on product loss. While selection is primarily based

    on product requirements, it will also have implications for pollution. Operators should consider this

    trade off when implementing BAT. .

    It is important that process monitoring and control equipment selected is designed, installed, calibrated

    and operated so that it will not interfere with hygiene conditions in the production process and itself lead

    to product loss and waste. Measures, which should be implemented as appropriate, include:

    Table 2.1: Process monitoring and control equipment

    Technique Application Outcome

    Temperature

    measurement

    Storage and processing ves-

    sels, transfer lines, etc.

    Reduced deterioration of materials and out-of-

    specification products

    Pressure Meas-

    urement

    Indirect control of other

    parameters, for example flow

    or level

    Minimise waste from material damaged by

    shear friction forces

    Level measure-

    ment

    Storage and reaction vessels Prevent storage overflow of materials and asso-

    ciated wastage from storage or reaction tanks;

    minimise waste from transfer losses in inaccu-

    rate batch recipes in vessels; and minimise out-

    of-date stock or production losses due to insuffi-

    cient material

    Flow measure-

    ment

    Transfer lines Accurate addition of materials to processing

    vessels and minimise excessive use of materi-

    als and formation of out-of-specification prod-

    ucts

    Steam supply Maintain correct operating temperature and min-

    imise waste from underheated or overheated

    materials and products

    Cleaning systems Control and optimise water use, and minimise

    effluent generation

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    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 20

    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandling

    Wasterecovery ordisposal

    Energy Accidents Noise Monitoring Closure Installationissues

    The mainactivities andabatement

    Techniques for pollution control

    The most accurate way of measuring milk intake into most sites is the use of a weighbridge, although

    this is sometimes not the most convenient approach. Weighbridges are normally very accurate with

    measurement errors typically less than 0.05%. The move within the UK dairy industry to the use of in-

    situ tanker flow meters has introduced significant errors into milk loss measurement, as it is now

    generally accepted that unless the flow meter error on the tanker meter is greater than 60 litres, this

    discrepancy is acceptable. An error of 60 litres on a volume of say 15,000 litres equates to 0.4%, which

    falls well below the level required for accurate measurements of factory losses, particularly when using

    yield or mass balance calculations.

    Packing line efficiency

    Poorly designed and operated packing lines cause many companies to lose as much as 4% of their

    product and packaging. To improve efficiency and productivity and to reduce wastage, individual

    machines should be correctly specified so that they work together as part of an efficient overall design.

    2.1.2 Materials handling, unpacking, storage

    Summary of the activities Materials handling applies to the receipt, storage and internal conveying of raw materials, intermediate

    products and final products.

    Solid materials are commonly delivered in bags on pallets. They are transported with forklift trucks, and

    stored in a store. The same holds for liquid ingredients in containers. Larger amounts of solid raw

    materials and powders are mostly delivered in bulk trucks. These are off-loaded directly for processing

    or stored in silos. Solid raw materials can be conveyed by water (vegetables, roots, tubers), by air

    (solid particles, powder) or by conveyer belts and elevators.

    Conveyor systems include:

    gravity systems (direct flow to receptacle)

    mechanical systems (belts, screw conveyors or buckets)

    pneumatic systems (positive or negative pressure systems)

    fans

    Liquid raw materials are normally delivered in bulk tankers and then pumped into storage tanks. Internal

    transport of liquid is carried out by pumping through, sometimes extensive and complex, piping

    systems.

    Environmental impact Water: Leakages, for example from pipework or flume systems. Effluent from cleaning. Results in the

    release of suspended solids (both organic and/or inorganic) and soluble compounds (both organic and/

    or inorganic) to water, which leads to a considerable biochemical oxygen demand and turbidity.

    Air: Potential emissions from vessel vents whilst filling, which could consist of particulates, gases and

    odours. Dust and particulate from conveyor systems.

    Land: Deposition from emissions to air and contamination from leaking pipework.

    Waste: Residues from vessels and other material handling equipment. Reworked for sale as animal

    feed where possible.

    Flow control Constant flow valves Control flow rate to water ring vacuum pumps

    Flow regulators Control process water flow rates for specific

    processes

    Table 2.1: Process monitoring and control equipment

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    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 21

    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandling

    Wasterecovery ordisposal

    Energy Accidents Noise Monitoring Closure Installationissues

    The mainactivities andabatement

    Techniques for pollution control

    Energy: Materials handling is almost exclusively electrically driven.

    Accidents: Spillage from, for example, flume systems or cleaning activities or transfer of materials, for

    example containers being dropped. Overfilling of storage vessels.

    Noise: No issue from vessels and static conveying equipment, but there might be noise from certain

    types of vehicle-mounted blowers used to discharge solids and liquids from road vehicles into silos and

    other vessels. Safety horns on forklift trucks may also be a factor.

    2.1.3 Pasteurisation, Sterilisation and UHT

    Summary of the activities Heat treatment of products is one of the main techniques used in the food industry for conservation.

    Within the dairy industry, heat treatment kills all micro-organisms capable of causing disease as well as

    improving the keeping quality of the end product. In heat treatment various time/temperature

    combinations can be applied, depending on product properties and shelf life requirements.

    In pasteurisation generally a heating temperature below 100 C is applied (72 to 75oC for 15 seconds

    for High Temperature Short Time pasteurisation), this means a reduction of enzyme and bacterial

    activity and a stable shelf life. Sterilisation commonly means a heat treatment over 100oC for such

    times that a longer shelf life is achieved. UHT means Ultra High Temperature treatment, usually 135 to

    140oC during very short times; and was pioneered on milk products to produce extended shelf life.

    Generally for sterilisation the milk product is canned or bottled and then heat-treated in a retort in hot

    water (under overpressure) or steam. Sterilising retorts may be batch or continuous in operation.

    Environmental impact

    Indicative BAT requirements for storage and handling of materials:

    1 The main control issues are:

    cleaning techniques see Section 2.1.16 on page 36

    air emissions from conveyors see Section 2.5 on page 82

    accidents, for example overfilling of storage silos see Section 2.8 on page 90

    2 No further issues are identified.

    Air: Potential for fugitive losses from refrigeration systems.Water: Once-through cooling post heat treatment requires substantial quantities

    of cooling water. Fouling of heat transfer surfaces requires cleaning.

    Land: No direct impacts.

    Waste: Product residues and concentrated flushes can be collected for recovery

    or animal feed.

    Energy: Energy required in the form of steam or hot water treatment and for cool-

    ing. Cooling can be accomplished by once-through cooling or with a recir-

    culating chilled water system. The latter will involve a mechanical

    refrigeration system. Most dairy pasteurisers now use a regenerative

    heat exchangers which can be up to 96% energy efficient

    Accidents: Not applicable.

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    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 22

    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandling

    Wasterecovery ordisposal

    Energy Accidents Noise Monitoring Closure Installationissues

    The mainactivities andabatement

    Techniques for pollution control

    BAT for pasteurisation etc.

    2.1.4 Evaporation

    Summary of the activities Evaporation is the partial removal of water from liquid food by boiling. Milk or milk products can be

    evaporated to produce concentrated, condensed, or evaporated products. Water is usually removed

    from liquid milk in an evaporator prior to drying. Milk products are normally condensed from an initial

    solids content of 9 to 13% to a final concentration of 40 to 50% total solids before drying.

    Steam or vapour is usually used as heating medium. The latent heat of condensation is transferred to

    the liquid to raise its temperature to the boiling point and evaporate the water. The vapour is then

    removed from the surface of the boiling liquid.

    Evaporation systems may be single-stage or multi-stage (also called effects) with 2, 3 or more

    evaporator or vacuum units. In multi-stage evaporators the effects operate at decreasing pressure as

    the product moves through the stages. These stages are usually under vacuum so that evaporation and

    boiling temperatures are lower than at atmospheric pressure, so as to reduce heat input and damage to

    the products.

    Other options to reduce energy consumption by re-using heat contained in vapours include:

    vapour recompression;

    preheating using the vapour to heat incoming feedstock or condensed vapour is used to raise steam

    in a boiler.

    Periodical chemical cleaning is carried out in order to ensure clean surfaces and an efficient heattransfer. The cleaning frequency is, depending on product and evaporator type, from 8 to more than 48

    hours.

    Environmental impact

    Noise: Not applicable.

    Indicative BAT requirements for heat treatment processes:

    1 The main control issues are:

    water use see Section 2.5 on page 82 the operator should justify why the reuse of once through cooling waters is not possible.

    cleaning techniques see Section 2.1.16 on page 36

    fugitive emissions to air (refrigerants) see Section 2.8 on page 90

    energy efficiency see Section 2.8 on page 90 for use of regenerative heat exchangers

    2 No further issues are identified.

    Air: Odour and particulate arising from incondensable gases vented to ensure

    efficient heat transfer and entrainment, where a fine mist of concentrate is

    produced during violent boiling.

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    Guidance for the Dairy and Milk Processing Sector IPPC S6.13 | Issue 1 | Modified on26 October, 2003 23

    Introduction Techniques Emissions Impact

    The mainactivities andabatement

    Abatement ofpoint sourceemissions

    Managementtechniques

    Rawmaterials

    Wastehandli