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Cknt Project NO:
PM Project NO:
Document No:
File NO:
100811
100811-22-RP-001
100811=22-010
KERRY INGREDIENTS, LISTOWEL
FIREWATER RUN-OFF STUDY
Updated Risk Assessment & Risk Management Programme
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Kerry Ingredients, tistowel Firewaler Run-off Study
COfUENTS
10081 I-22.RP-001, Issue B 17 May, 2004
1. INTRODUCTION 3
2. SUMMARY 4
3. RISK ASSESSMENT METHODOLOGY 6
4. FIREWATER RISK ASSE+SMENT BY AREA 10
5. CALCULATION OF VOLUME OF FIREWATER 29
6. RISK MANAGEMENT PROGRAMME 31
APPENDICES
Appendix I Site Layout Plan
Appendix II Tank Register
Appendix 111 Fire Prevention and Emergency Response
Appendix IV Details of Proposed Drainage Modifications
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Kerry Ingredients, Ustowel f00811-22-RP-001, Issue 6 Flrewater Run-off Study 17 May, 2004
1. iNTRClDUCTfON
Kerry Ingredients has retained Project Management Limited to carry out a revised and updated risk assessment to determine the requirements for the retention of firewater run-off at the facility located at Tralee Road, Listowel, Co. Kerry.
A previous risk assessment report was prepared in December 2001 by Kerry Ingredients in compliance with Condition 9.2.1 of their IPC Licence (Licence Register 393) as issued by the EPA.
Since the original risk assessment was carried out in 2001, a number of changes have occurred at the Kerry Ingredients site. In particular, some modifications to buildings I material storage areas have changed the risk ratings for these areas and this has a bearing on the outcome of the risk assessment. In addition, an updated and more detailed inventory of materials, and the nature of their storage and management on site, is available. A more detailed interpretation of the water hazard classification of certain food grade materials is also included which has an impact on the risk assessment,
A revised Risk Management Programme is put forward based on the updated risk assessment. This Risk Management Programme acknowledges the need for the retention of firewater for certain potential fire scenarios. The programme seeks to maximise the use of existing avallable storage capacity within the site infrastructure, while ensuring that the required deiign flrewater run-off volumes can be safely retained on site, thereby preventing release to the receiving environment.
The revised risk assessment and management programme is based primarily on the procedures outlined in the most recent version of the draft EPA ‘Guidance Note to Industry on the Requirements for the Establishment of Firewater Retention Facilities’. Reference is also made to the EPA’s recently circulated ‘draft guidance note on the storage and transfer of materials for scheduled activities’, which incfudes some relevant new guidance for the food and dairy sector.
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Kerry Ingredients, Listowel Firewater Run-off Study
1008 1 I-22-RP-001, Issue B 17 May, 2004
2. SUMMARY A revised risk assessment has been performed at the Kerry Ingredients site in Listowel, Co. Kerry. For ease of analysis, the site has been divided into 15 areas, these being the same 15 areas assessed in the previous risk assessment in 2001. The 15 areas are listed below and are identified on the facility layout drawing, included as Appendix I. The need for firewater retention in each area is summarlsed in Table 1, and compared with the findings of the previous risk assessment.
Table 1: Assessment of Requirement for Firewa ter Retention by Area
It is noted that a revised assessment of the requirement for firewater retention applies to 3 of the 15 areas, the Fuel Storage/ Dispensing area (area 31, the Cold Stores (area 5) and the Casein Plant (area 8).
Fuel StorageI Dispensing {area 3) The majority of fuel (primarily diesel) s?orecl in this area is within underground steel tanks encased in concrete. A more detailed assessment of the manner in which a fire could occur in this area and the means by which the fire would be tended confirms that the risk of significantly contaminated firewater from this area reaching the environment is very low.
The Environmental Risk rating for this area has thus been revised to ‘Low’.
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Kerry Ingredients, Listowel 100811-22-RP-001, Issue 5 Firewafer Run-off Study 17 May, 2404
Cold Stores (area 5)
The cold stores at the Kerry Ingredients site is subdivided into 7 separate fire compattments. whereas the previous risk assessyent considered the cold store as a single compartment. The fire compartmentation of this area has the effect of reducing the environmental load and fire load by a factor of 7.
The cold stores are used primarily for the storage of packaged butter and cheese products. The water hazard classification of these materials has been reviewed, as well as the risk of these materials being entrained in the firewater run-off. As a result, the Environmental Risk rating has been revised to ‘Low’ and consequently it is deemed that no specific firewater retention is required for this area.
Casein Plant {area 6)
The fire load and the corresponding risk of a fire in this area have been reclassified as ‘Low’ based on the non-flammable nature of the materials stored within.
The environmental rjsk associated with the area has been reclassified as ‘low’ based on a review of the water hazard classification of the primary storage material (casein powder) and the risk of this material being entrained in the firewater run-off.
Risk Management Programme
Under the revised risk assessment, there are two site areas identified as requiring firewater retention:
l Milk Powder Store (including bottle blow moulding and bottle filling) -area 4
l Maintenance Area (including fuel storage) - area 14
in the case of the Maintenance Area, the key determinant of Environmental Risk is the Environmental Load associated with the inventory of heavy fuel oil and diesel oil in bulk storage. The revised risk assessment for this area takes into account the local storage capacity available within the containment bundlng capacity provided around the bulk storage tanks. A more detailed assessment of the manner in which a fire could occur in this area and the means by which the fire would be tended confirms that there is adequate firewater retention available locally within the tank bunding.
The high Environmental Load associated with the Milk Powder Store relates to the large quantity of milk powder stored In this area. The risk of a significant quantity of this material becoming entrained in the firewater run-& has been quantified as high. As such, retention of firewater associated with this scenario is deemed necessary.
It is proposed that retention of this firewater will be effected within the available uiiage of the site wastewater treatment plant (pending upgrading of the automation and control system).
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a Kerry hgredients, Llstowel Firewater Run-off Study
100811-22-RP-00~,lssu~B 17 May, 2!M4
3. RISK ASSESSMENT METHODOLOGY
The approach adopted for the firewater run-off risk assessment is based on a methodology to establish the extent and effects of firewater run-off in the event of a fire at Kerry ingredients, Listowel.. In accordance with the provisions of Appendix B of the EPA Draft Guidance Note, information is presented in relation to fire prevention, abatement, response, training and awareness. Much of this information has previously been presented in the 2001 Risk Assessment Report. Updated information relating to the site’s current fire prevention and response measures is included in Appendix II.
3.t Sub Division of Buildings Step 1 of the risk assessment Is to subdivide the facility into compartments or areas. Compartments are defined as areas separated by either designated firewalls or significant distance. The 2001 Risk Assessment Report considered 15 separate compartments over the entire site area. This compartmentation has been retained for the present risk assessment.
3.2 Risk Assessment Once the ccmpartmentation has been decided, an assessment of the environmental risk associated with a fire in any individual area is then carried out.
This risk assessment takes into account 4 parameters.
Fire Risk: This is the likelihood of a fire occurring in the area under consideration. Key parameters to be considered are possible sources of ignition, and the degree of fire protection available in the area being assessed.
Fire Load: This refers to the quantity of fuel available for combustion, A key parameter in assessing the Fire Load is fuel availability. For example, a low flash point flammable solvent presents a more readily available fuel than butter, which has a flash point in the order of several hundred degrees Centigrade.
Environmental Load: This refers to the inventory of material which, if released in firewater, would present a risk of pollution. The Environmental Load is calculated based on the classification of the material stored in the area, and its water hazard rating.
Environmental Risk: This refers to the risk of a significant environmental load becoming entrained in the firewater run-off and entering the receiving environment i.e., local watercourse. A key consideration in determining the overall Environmental Rlsk is the likelihood of the material becoming entrained in the firewater (e.g., liquid milk will be more easily picked up and carried than packaged milk powder or butter/cheese products). The nature of the primary material storage vessels and their likelihood cf failure in the event of a fire is also of importance.
A revised risk assessment has been conducted for each of the 15 site compartments. The risk assessment is summarised in section 4.
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Kerry Ingredients, Listowel 100811~2%RWIO?, Issue I3 Firewater Run-off Study 17 May, 2004
3.3 Determination of Volume of Firewater In accordance with the Draft Guidance Note on Firewater Retention Facilities, the calculation of the volume of firewater to be retained is based on the largest of:
(i) The maximum volume of water likely to be used in fighting a fire including water available on site, adjacent to the site or brought onto the site
(Ii) The volume of contaminated water generated as a result of a fire in a process area.
(iii) The volume of firewater likely to be generated as a result of a fire in a tank farm.
(iv) The volume of firewater likely to be generated as a result of a tire in a storage area.
in the case of Kerry ingredients, the risk assessment has shown that Ihe required retention volume will be based on criteria (i> and (ii) above i.e., the maximum volume of water arising from a fire in a process area.
3.4 Assessment of Materials (Environmental Load) it is necessary that the risk assessment take into account the environmental hazard associated with substances which may become entrained in firewater. This is done with reference to two systems of classification. These are:
l The substance WGK value (German Ministry of Environment Classification System- Ref. Section 4)
l The substance Risk Phrase as per Classification, Labeiling and Packaging Regulations.
3.4.1 Classification of Materials The classification systems which have been used are as follows:
0) EC Directive on Classification of Dangerous Substances 67/548/EEC as Amended.
(ii) The German Ministry for the Environment’s Classificaiion System for substances hazardous to water..
These are discussed in turn below.
I. ,EC Directive on Classification of Dangerous Substances 67!548/EEC as Amended.
The Commission Directive related to the classification, packaging and iabelling of dangerous substances is implemented in Ireland through Regulations SI 9 ‘I6 of 2003. The aim of the Regulations is to protect man and the environment from the harmful effects of both new and existing dangerous substances. The Regulations use phrases indicating special risks (‘R’ phrases) and safety advice (‘S’ phrases} for general classification purposes. All substances which have been or are intended to be placed on the market should be appropriately classified and labeiled with R and S phrases. Risk phrases useful for a firewater run-off risk assessment include:
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Kerry Ingredients, Lislowel 100811-22-RP-001, Issue 6 Fitewatet Run-off Study 17 May, 2004
a RlO - Flammable
o RI 1 - Highly flammable
l RI2 - Extremely flammable
l R5O - V+y toxic to aquatic organisms
a R51 -Toxic to aquatic organisms
s R52 - Harmful to aquatic organisms
l R53 - May cause long term adverse effects in the aquatic environment
The environmental risk phrases, e.g. R 51, are referred to in the EPA (Draft) Guidance Note to Industry on the Requirements for Firewater Facilities. In Table 2, Appendix II, risk phrases have been assigned to the materials on site using data from SI 116 of 2003 and the EPA (Draft) Guidance Note.
It is seen that only one entry whose risk phrase indicates potential harm to the environmeni is stored in significant quantities at Kerry Ingredients. This material is heavy fuel oil. The maximum quantity of heavy fuel oil stored on site is approximately 600 tonnes.
II. The German Ministry for the Environment’s Classification System for substances hazardous to water.
Under the WGK classification system, 4 water hazard (WGK) classes are identified. These are:
l WGK3 Severely water polluting substances
l WGK2 Water polluting substances
l WGKI Slightly water polluting substances
l WGKO Substances generally not water polluting
The evaluation procedure for these is based principally on three tests:
1. Toxicity for fish LCSO (mgll)
2. Toxicity for bacteria ECjO (mg/l)
3. Toxicity for mammals LD50 (mglkg)
To date, the German Ministry of the Environment’s Commission for Classification of Water Hazardous Material has formally evaluated 1335 materials. In Table 2, Appendix II, WGK numbers have been assigned to the materials on site using data from the German Commission’s catalogue or self assessment using the evaluation procedure and the best data currently available.
Food materiils are not ranked by the German WGK classification system. Food materials such as milk and vegetable oil demonstrate low toxicity and bioaccumulation but a high pollution risk due to their organic loading. The general consensus among the environmental professional field is that while milk is not formally defined by the German WGK system, milk should be treated as a WGK 1 material. This is based on the fact that whilst milk and milk related products do not exhibit an acute toxicity, they do present a high pollution load. Typical BOD values for whole milk (4% fa’at) and whey (0.05% fast) are 120,000 mgll and 40,000 mgil respectively (ref. Draft EPA Guidance Note on Storage and Transferof Materials for Scheduled Activities).
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Kerry Ingredients, Lisiowel 100811-22-RP-001,lssueB Firewater Runoff Study 17 May,2004
The WGW Risk Phrase approach to the determination of the possible need for firewater retention is presented in Table 2 below.
Table 2: Environmental Risk ll4a &ix
A B c Risk Phrase D
Note: Quantities in Tonnes
Key:
rotection measures to
Basic measures required to maintain risk at reduced level.
Classification of an area under column C or D of the Environmental Risk Matrix indicates that firewater retention is likely to be required.
If the quantities are below the threshold levels likely to require firewater retention, the fire risk in each area is determined. The assessment of fire risk is based on the inventory of flammable and combustible materials within the compartment, and the assessment of the level of on-site control measures regarding fire prevention, abatement and response. The following factors are considered In the assessment:
l The inventory of flammable and combustible materials within the compartment
l Assessment of the level of on-site control measures regarding fire prevention, abatement and response
+ The likelihood of firewater entering on-site or off-site environmental media (soil, air, water).
* The extent to which the firewater would be contaminated with water-polluting substances.
In assessing the environmental impact of firewater, consideration is given (in accordance with EPA guidance note) to the class of waterway into which the firewater may flaw.
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Kerry Ingredients, Liitwel 10081 l-22-RP-OOI , issue B Firewater Run-off Study 17 May, 2004
4. FIREWATER RISK ASSESSMENT BY AREA The site is considered under 15 individual areas or compartments. A revised risk assessment has been conducted for each area individually.
A summary of the outcome of the risk assessment is outlined in Table 3 below,
Table 3: Summary of Firewafer Refenfion Risk Assessments
Risk Assessment Area
I. Propane Storage Tank
2. General Store, Chemical Store
3. Vehicle Fuel Storagel Dispensing
Firs Load
High
High
High
Fire Risk Env. Env. Risk I
Retention Load Reauired?
Low Low Low No
Low LOW Low No
High Low I
No
6. Casein Plant, Offices, Control Room, Laboratory, Thermal Oil system
Med
7. Whey Plant, Spray Dwers, UF Plant
High I
Low High No
8. Butter Plant. Fat rooms, Butter Oil, Spreads
Med Low 1 Med ( Low ( No
9. Cheese Plant
IO. Milk Intake
Low
Low
Low
Low
Low
High
Law No
Low NO
II, Water Treatment Plant
12, WWTP
Low
Low
Low
Low
High
Med
Low No
Low I No
13. Energy Plant I High 1 Low I Low I Low I No
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Kerry Ingredients, Listowel 100811~2%RP-001, hue 6 Firewater Run-off Study 17 May, 2004
4.1 Risk Assessment Area 1: Propane Storage Tank
Fire Load High
Propane for use as fuel for forklifts is stored in a tank of capacity approximately 10m3. The tank is protected against vehicular impact and is vented to protect against internal overpressutisation. It is concluded that, while the fire load is relatively high, the probability of a fire involving the propane storage tank is low.
Propane is classified by the WGK system as being non-polluting. It is concluded that the environmental load and corresponding environmental risk is low.
Conclusion: Firewater retention capability is not required for this area.
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Kerry Ingredients, LIstowe 10081 I-22RP-001, Issue B Firewater Run-off Study 17 May, 2004
4.2 Risk A,ssessment Area 2: General Store, Chetinical Store
The general store contains significant quantities of packaging materials. These materials are combustible. As such, the fire load avaitable for combustion is high. However, the control of ignition sources in general, and hot work in particular, significantly reduces the likelihood of ignition. The site fire detection and alarm system would detect the fire iri an early stage of development. This would enable an early response to a small flre.
The environmental load in this area relates to the quantities of materials in the external chemical compound. The materials are generally non-hazardous. A quantity of ammonia (max. 8 tonnes approx.), which has a WGK 2 classification, is the only signlcant consideration. This quantity is below the WGK 2 threshold quantity of 20 tonnes. The environmental load and corresponding environmental risk are deemed to be low.
Conclusion: Firewater retention capability is not required for this area.
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Kerry Ingredients, Listowel 1DO811-22-RP-001, Issue B Fkewa ter Run-off Study 17 May, 2004
4.3 Risk Assessment Area 3: Vehicle Fuel Storage/ Dispensing
Fire Load . .
Fire Risk
Environmenfal Load
En vironmenfat Risk
High
Low
High
Low
The materials stored in this area are summarised as follows.
Material Maximum Quantity WGK Threshold
(Tonnes) Class [Tonnes)
Petrol 2.2 3 1
Marked Diesel 3.2 2 IO
Diesel (DERV) 33.6 2 10
It is seen that the total quantities of materials exceed the relevant WGK thresholds in the case of the petrol and DERV. It is necessary therefore to consider the requirement for the retention of firewater run-off from this area.
It is firstly to be noted that both the petrol and DERV are stored underground in steel fuel storage tanks fully encased in concrete. Consequently, the likelihood of loss of containment during a fire event Is very low, A project to install a flame arrestor on the vent of the petrol storage tank is currently being Implemented. The flame arrestor will prevent flashback of ignited petrol vapours back into the petrol storage tank. It is concluded that the risk of a fire affecting the underground fuel storage tanks is low.
It is also to be noted that the above ground marked diesel tank is bunded to 110% of the contained volume. Implicit in this capacity is the ability to contain the water/foam used for firefighting purposes.
The fact that the fire risk in this area is low, and that the risk of run-off becoming contaminated is also low, the overall environmental risk rating is deemed ‘low’.
Conclusion: Firewater retention capability is not requited for this area.
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a
Kerry Ingredients, t.istowel 1008 1 I-22.RP-OOI , Issue B Firewater Runoff Study 17 May, 2004
4.4 Risk Assessment Area Q: Milk Powder Bottle Blowing1 Filling
Environmental Load High i Environmental Risk I Med I
The materials stored in this area are summarised as follows.
It is seen that the quantity of milk powder stored in this area significantly exceeds the threshold above which firewater retention must be considered.
The fire load in the area is categorised as medium owing to the quantities of combustible materiels stored. It is to be noted however, that the area is protected by an automatic sprinkler system. As a result, if a fire were to occur, it would be contained/extinguished by the operation of the automatic sprinkler system. Therefore, the volume of firewater will be small. The automatic sprinkler system is well maintained. The volume of firewater generated is calculated in Section 6 of this report.
Overall, as the environmental load is high, and with a medlum ranked fire load, it is deemed that firewater retention for this area shoutd be provided.
Conclusion: Firewater retention is required.
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l Kerry Ingredients, tislowel 10081 I-22-RP-001, Issue B Firewater Run-off Study 17 May, 2004
4.5 Risk Assessment Area 5: Cold Stores
Fire Load Med
Fire Risk Low
Effvironmenfal Load I Med I
I Environmental Risk Low I I I 1
Material Inventory
Material 1 Maximum Quantity 1 WGK 1 Threshold
(Tonnes) Class
ITonnes)
Packaged Butter I Cheese
400 tonnes per compaftment
1” 100
* WGK classification of 1 is assumed for liquid milk. This classification is considered conservatively high for solid dairy pmducts such as butter and cheese.
The cold stores are used for the on-site storage of butter and cheese products. These are not readily combustible. The stores are divided into 7 separate fire compartments. The insulating panels used do not serve as structural components. As a result, their involvement in a fire would not result in loss of internal comparlmentation of the cold stores- It is reasonable to conclude that a fire would be c-ontained within the fire compartment within which it started.
Hot work and smoking are closely controlled. It is likely that any fire occurring would be detected in its early stages by the fire atarm system, thereby facilitating early deployment of the on-site fire crew. The early detection/ response, together with the inherent non-combustible nature of the products stored and the internal compartmentation would result in a fire being readily contained in size and most likely within the one fire compartment. Further, the operating temperature in the cold stores is generally 6 deg. C.
In ihe event of a fire in one of the compartments the risk of a significant quantity of dairy product becoming entrained in the run-off is considered low. Thus, despite the total stored quantity being high, because the material is in solid form and fully packaged, the environmentai risk is categorised as low.
Conclusion: Firewater retention capability is not required for this area.
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Kerq Ingredients, tistawel 100811-22-RP-DIN, Issue B Firewater Run-off Study i? May, 2004
4.6 Risk Assessment Area 6: Casein Plant, Offices, Control Room, Laboratory, Thermal Fluid System
Fire Load Low
fire Risk Low
Enviri3nmental Load Med
Environmental Risk Low
Material Inventory
Material 1 Maximum Quantity 1 WGK 1 Threshold
(TTonnes) CIZISS (Tonnes)
Lactic acid
Dry autolysed yeast powder
Sodium tri- PolvrJhosDhate
y-f-y
Sodium bicarbonate IO
Limbux lime N/A
Peracetic acid ii5
1 100
N/A N/A
2 10
Phomhoric acid
WGK 3 laboratory chemicals
0.04 3 : 1
The Thermal Fluid System Is considered in isolation first.
The cesein burner room contains two burners and associated circulation pumps as well as a maintenance tank. The casein burner room has solid block walls and a reinforced concrete roof. The burners have a pumped diesel fuel line with fusible-link operated sfam shut valve. The burners are fitted with fire suppression bottles. The room is also covered by an automatic sprinkler system. 1 tonne of Thermal Fluid CalFlo FG is typically in-fliiht in this area. The thermal fluid systems of Casein and Niro Dryers are linked by 4” stainless pipework. The combined volume of Casein and Njro thermal fluid systems is approximately 6 Tonnes. A 4,000 Lithe steel tank is located in the casein burner room. This tank is designed as an overflow sump on the casein thermal fluid system. tt is oversized for this purpose. This tank can also be used for temporary storage of thermal
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Kerty ingredients, Listowel 10081 I-22-RP-001, Issue 6 Firewater Run-off Study 17 May, 2004
fluid in the event of 8 major shutdown and service of the thermal fluid systems for Casein or Niro Dryers.
The environmental load associated with the thermal fluid system is consider to be low due to the quanlity of material involved (6 tonnes of WGK 2) and the systems in place to prevent release to the environment in emergency situations (sump tank).
The fire risk associated with the thermal fluid system is also classified as low due to the nature of the fire prevention measures in place.
Next we consider the Casein Plant and associated buildings.
The primary environmental risk relates to the quantity of Casein stored in this area.
Casein powder is not easily Ignited. The ignition temperature of a layer of this material is greater than 450°C (upper limit of standard test).[Dust Explosions in the Process Industries, Eckoff R., ~~616, Butterworth Heinemann, Td Ed.]. As such, ignition of casein powder on hot surfaces in process plant is considered unlikely. Given the incombustible nature of casein, the fire load is considered to be low.
It is further considered,that the fire risk is low, owing to the absence of flammable materials, good housekeeping, control of hot work and the materials of construction of plant and equipment (stainless steel equipment, tiled internal surfaces).
The overall environmental load is classed as medium, owing to the presence of approximately 90 tonnes of casein powder {and the 6 tonnes of thermal fluid). For the purpose of this risk assessment, casein powder is conservatively classified as a WGK 3 material. However, the likelihood of a significant quantity of casein powder becoming entrained in the firewater is considered low due to the fact that the material is stored in stainless steel vessels and, even If the material were to escape from a vessel, it would need lo dissolve fully with the firewater before entering the drainage system.
It is considered that there is more than adequate protection to prevent contaminated firewater being released from this area. The environmental risk is therefore classified as low.
Conclusion: Firewater retention capability is not required for this area.
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Kerry Ingredients, Listowel 100811-22-RP-001, Issue 8 Firewater Run-off Study 17 May, 2004
4.7 Risk Assessment Area 7: Whey Plant, Spray Dryers, UF Plant
Fire Load
Fire Risk
Environmental Load
Environmental Risk
High
Low
High
Low
Material lnventery
Material Maximum Quantity
(Tonnes}
WGK Class
Threshold
(Tonnes)
Milk Powder (in flisht) 1 IO I 1 1100 I
Thermal Fluid (in-flight) 1 2 10
Ammonia 1 2 IO
Sodium hydroxide 280 1 100 {caustic}
Hydrogen Peroxide 1 10.7 11 ~ II00 -1
I Divercia f64 ‘I 3.5 II II00 I Calcium chloride 3 1 100
Nitric acid 64 1 100
Calcium formate 5 1 100
Potassium hydroxide IO (caustic potash)
1 100
This area contains the Nito Spray Dryers used to produce milk powder. The potential for the occurrence of dust explosions wlthin the dryers has been recognised. As a result, the following significant control measures are in place:
)z Sodium bicarbonate fire suppression system in the fluidised bed section of the dryers
> Steam fire quench system in each dryer
P High pressure water quench system in each dryer
More detail on these systems is provided in Appendix 3.
In addition to the above, the plant areas external to the dryers are constructed of tiled surfaces and all equipment and pipework is in stainless steel and other non- flammable materials. The’whey service gantry, the spray dryer No.1 bag-off and the grading store ate protected by an automatic sprinkler system. The whey plant, whey service gantry and Nito 1 bag-house all have LPC (Loss Prevention Council) approved roofs and there is a site policy of roof replacement and upgrade to LPC specification.
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Kerry Ingredients, Lislowel Firewater Run-off Study
10081b2%RP-001, Issue B 17 May, 2004
Thus, while the fire load is deemed 10 be high due to the potential for dust explosion, the actual risk of a fire is considered to be low because of the considerable safeguards in place.
The principal WGK 1 chemicals are bulk nitric acid and caustic which are used in the UF plant. However, these chemicals are non-combustible and, in addition, are stored in bulk tanks external to the building and ‘in bunded areas. It is not envisaged that a flre would jeopardise the primary containment of these chemicals. Irrespective, secondary bunding is in plece to retain the primary chemicals and any resultant firewater.
The quantity of milk powder in the area is limited to the quantity of ‘In-flight’ powder contained within the two dryers at any one time. This does not exceed 5 tonnes per dryer system; which is well within the threshold for WGK 1 materials. In addition, there will typically be about 1 tonne of thermal fluid in-flight within the spray dryer area at any one time, which is small in the context of the 10 tonne WGK 2 threshold.
It is concluded that, while the environmental load In this area. is deemed to be high, the’risk of any of this load being released to the environment is low.
Conclusion: Firewater retention capability is not required for this area.
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EPA Export 25-07-2013:14:50:49
Kerry Ingredients, Listowel 100611-22-RP-001,lssueB Firewater Run-off Study 17 May, 2004
4.8 Risk Assessment Area 8: Butter Plant, Fat rooms, Butter Oil, Spreads
Fire Load Medium (packaging store only}
Fire Risk Low
Environmental Load Med
Environmental Risk Low
Materlal Inventory
Material Maximum Quantity
(Tonnes)
I Butter oil Is II II00 I
Vegetable oil 450 1 100 Liquid STGC 0.5 1 100
Milk Powder 7 I 100
: Salt 2 1 100
i Sodium Carbonate 1 1 100
There is a significant quantity of packaging material stored in the packaging store. This area is located in a separate fire compartment to the production area containing the WGK class 1 materials. It is reasonable to presume that, whilst the fire load in the packaging store may be reasonably high, there is an absence of WGK class 1 materials and the probability of ignition is low due to the stringent 1 control of hot work on the site.
In the production area, the likelihood of the butter/oils contained withln process equipment becoming involved in a fire is low. This is due to the high level of containment afforded by the stainless steel vessels. In addition, the oils are not flammable. The Internal plant areas are tiled extensively. The fire load in the production area is therefore very low. The risk of fire is also very tow.
Conduslon: Firewater retention capability is not required for this area.
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EPA Export 25-07-2013:14:50:49
Kerry Ingredients, Listowel 10081V22-RF-001, Issue B Firewater Run-off Study 17 May, 2004
4.9 Risk Assessment Area 9: Cheese Plant
Fire Load
Fire Risk
Environmenfal Load
Environmental Risk
Low
Low
Low
Low
Material Inventory
The cheese plant contains the wet process for cheese production. The materials stored in the plant and the materials of construction {rockwool panels) are of limited combustibiGty. Given the stringent site controls on hot work, it is unlikely that a fire would start in this area.
This area also includes the Automatic Chill Store. The automatic chill store system has an ammonia fiited refrigeration plant comprising of external block built plant room and switch room with an externally mounted ammonia receiver and fan assisted evaporative condenser. The whole store and plant room is covered by a manually activated deluge spray bar. This deluge system is designed using LPC specification & blanket the store and plant room in water in the event of a fire. The cheese plant has a powder vacuum conveying system. This powder conveying system is equipped with an Automatic Explosion Arresting system and explosion relief panels.
Based on the above, the fire risk for the area is classified as tow.
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Kerry Ingredients, Listmvel 100811-22-RF-001, Issue B Firewater Run-ofFStudy 17 May, 2004
While the combined quantity of WGK 1 material in Ihe area exceeds the threshold of 100 tonnes, the environmental risk is still deemed to be low. This is because the primary WGK I material is solid-form cheese which, in a fire scenario, will not present a risk of significant liquid release. The environmental load is thus deemed to be low, as is the overall environmental risk,
Conclusion: Firewater retention capability is not required for this area.
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EPA Export 25-07-2013:14:50:49
Kerry Ingredients, Listowel 100811-22-RP-001, Issue B Fkwater Run-oKStudy 17 May, 2004
4.10 Risk Assessment Area IO: Milk Intake
fire Load I
Low I
Fire Risk I Low I
Environmental Load High I I
Environmental Risk Low
Material lnventctry
1 Material I Maximum Quantity 1 WGK 1 Threshold 1
(Tonnes) Class (Tonnes)
1 Milk 1 1816 I1 1 100 I
The milk intake area receives milk delivered by road tankers. The milk is stored in dedicated tanks. The materials of construction of this uncovered area are non-combustible (stainless steel piping;tanks). Milk itself is an aqueous material which is non-combustible. Therefore, the fire load and fire risk are low.
Whilst milk is a WGK 1 materiat, it is conservatively assumed that there are no fme scenarios which would cause gross loss of containment of all milk storage tanks. Thus, the environmental risk is classified as low.
Conclusion: Firewater retention capability is not required for this area.
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Ken-y Ingredients, Lislowei 100811-22-RP-002, Issue B Firewater Run-off Study 17 May, 2004
4.11 Risk Assessment Area 11: Water Treatment Plant
Environmental Load 1 High I
Environmental Risk I Low I
Mateiial Inventory
Material
Hydrochloric acid
Sodium chlorite,
Sodium chloride
Maximum Quantity WGK Threshold
(Tonnes) Class (Tonnes)
130 1 100
2 2 10
IO 1 100
This area has acids and bases used for the treatment of water. Neither the acids nor the bases used are combustible. As in all areas of the plant, hot work and smoking are tightly regulated. The fire risk and the fire load are thus classified as low.
The environmental load is classified as high as the total volume of WGK 1 material exceeds the threshold. However, all the acid tanks are fully bunded, providing adequate retention in the event of firewater being applied. Based on this, and the low fire load I fire risk ratings, the overall environmental risk is low.
Conclusion: Firewater retention capability is not required for this area.
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EPA Export 25-07-2013:14:50:49
Kerry Ingredients, Listowel 100811-22-RP-OOt , Issue B Firewater Run-off Study 17 May, 2004
4.12 Risk Assessment Area 12: Waste Water Treatment Plant
E&t-onmental load
Environmental Risk Low
Material Inventory
Material
Alum Chloride
Maximum Quantity VVGK Threshold
(Tonnes) Class (Tonnes)
60 I 100
Lumitech T
Sodium hydroxide (caustic)
1 I 100
40 1 100
This area has coagulants and flocculants used as part of the w&mater treatment process. None of the chemicals used are combustible. As in all areas of the plant, hot work and smoking are tightly regulated. The fire risk and the fire load are thus classified as low.
The environmental load is classified as medium due to the total volume of WGK 1 material in the area. However, all the chemical tanks are proposed to be fully bunded, providing adequate retention in the event of firewater being applied. l3ased on this, and the low fire load I Fire risk ratings, the overall environmental risk is low.
Conclusion: Firewater retention captibiliiy is not required far this area.
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Kerry Ingredients, Listowel 30OW22-WOOI, Issue a Firewater Run-off Study 17 May, 2004
4.13 Risk Assessment Area 13: Energy Plant
Fire Load High
Fire Risk Low
En vircrnmentai Load Low
En vironmen tai Risk Low
While there is a lot of cambustible material stored in this area (coal) there are no materials stored which may give rise to a need for firewater retention.
Conclusion: Firewater retention capability is not required for this area.
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Kerry Ingredients, Listowel Firewater Run-off Study
4.14 Risk Assessment Area 14: Maintenance Area
100611-22.RF-001, issue B 17 May, 2004
I Fire Load High I
Material Inventory
It is seen that there is a significant quantity of material stored in this area which would have a detrimental impact on the River Peale. Diesel is not classified as flammable. Its flash point is in excess of 32°C. As such, it is unlikely to be the source of a fire, but may become involved if subjected to sufficient radiant heat. It is reasonable to assume that if any of the hydrocarbon storage tanks were on fire, foam would be applied to the tank on fire and water woufd be applied to adjacent tanks to ensure adequate cooling of tank contents. Given the existence of a well trained Emergency Response Team, it is likely that the necessary deployment of foam making equipment and the application of cooling water would occur in a short period after detection of a fire.
It is reasonable to conclude that all of the hydrocarbon storage tanks would not be involved In a fire.
It is seen that the total quantities of materials exceed the relevant thresholds. It is necessary therefore that adequate provision be made for firewater containment. It is lo be noted that the fuel storage tanks are bunded to 110% of the contained volume. Implicit in this capacity is the ability to contain the water/foam used for firefighting purposes.
Conclusion: Additional flrewater retention capability, over and above the available bund capacities, is not required for this area.
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Kerry Ingredients, Listowel 10081 I-22-RP-001, Issue B Firewater Run&f Study 17 May, 2004
4.15 Risk Assessment Area 15: administration Building
Fire Load Low
Material Inventory
Material
Kerosene
Maximum Quantity WGK
(Tonnes) Class
0.9 2
Threshold
(Tonnes]
10
The fire load in this area, which includes the canteen, offices, changing facilities, lab and reception area, is classified as low due to the lack of any significant combustibles.
The quantity of WGK classified material stored in the administration building area is very small. Clearly, the issue of firewater retention does not arise.
Conclusion: Firewater retention capability is not required for this area.
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Keny Ingredients, Listowel 10061 I-2%RP-004, Issue B Flrewater Run-off Study 17 May, 2004
CALCULATION OF VOLUME OF FIREWATER
The fire scenarios which need to be considered are:
i. Fire in milk powder storage area (area 4)
ii. Fire in heavy fuel oil storage / maintenance area (area 14)
In the case of scenario (ii), firewater retention is provided by the local bunding. It is to be noted that the bun& on the Kerry Ingredients site are about to undergo a programme of upgrades to improve the integrity and watertiihtness of the various structures. No additional firewater retention is deemed necessary in this area.
The design scenario for the quantification of required firewater storage is therefore based on firewater arising from fighting a fire in the milk powder storage area. If a fire were to occur, it would be extlnguished by means of the automatic sprinkler system which is installed in this area.
By design, sprinkler systems rapidly achieve control of a fire and generally extinguish a fire in a short period of time. In thls instance, it is conservatively estimated that the duration of flow of water from the sprinklers is 60 minutes, This is considered very conservative as sprinkler controlled fire could reasonably be expected to have a significantly shorter duration. It is therefore unlikely that the entire tank contents would be used.
Furthermore, the sprinkler system in the powder store is designed such that sprinkler heads will activate individually, at 38 degrees C. This ensures that a fire will be dealt with in a IocaIised manner in a very short time. For example, a typical activation might release five heads. At 300 Llminlhead, a total volume of 3Dm3 of firewater might be expected.
However, for the purpose of this study, the volume of firewater generated is conservatively estimated on the basis of maximum sprinkler output:
Sprinkler pump rating*: 5,OODlJmin
Duration of operation: 60 minutes
Volume of firewater = 5,000 x 60 = 300,ODD litres i.e. 300m3.
* Note: The sprinkler pump nameplate capacity rating is used. The actual rate of delivery of water will be less than this. Thus, the water flowrate fQure is also conservative.
In the event of sprinkler operation, it is unlikely that significant additional water application using hand-held hoses will be required. Therefore, it is not necessary to take into account the volume of water which could be supplied from site hydrants or local authority fire brigade tenders. Notwithstanding, it is recommended that an additional allowance of 50% (150m”) should be provided for.
Hence, the design volume of firewater to be retained is deemed to be in the order of #5C?m3.
This volume wili arise over a period of 60 - 90 minutes approx.
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Kerry Ingredients, Listowel 10081 I-22-f3P-!NI 1 Issue 6 Firewater Run-off Study 17 May, 2004
Rainfall Allowance:
The 24 hour rainfall records have been received from Met Eireann in relation to Listowel. The data indicates that the maximum rainfall in a 24 hour period as being 62mm (for a 20 year return period). All rainfall on the site is directed to the WWTP. The volume of rainfall is determined as follows:
The area of the site is 1 05,200m2.
Rainfall volume = 0.062 x fO5,200 x 1 = 6,522m3.
An impermeability factor of 0.75 is estimated, this being representative of the maximum proportion of the site (roofs and paved areas) draining to the WWTP.
Hence, fhe design rain wafer volume is 5,870m3 occurring over a 24 hour period. The equivalent r-ah water volume arising in a period of SO minutes (corresponding fo the anficipafed maximum period of firewafer flow) Is 370m3 approx.
: : ’
.‘( ,.j
,:’ 2’
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Kerry Ingredients, Listowel 100811~22-RP-OOI , Issue B Firewater Run-off Study 17 May, 2004
6. RISK MANAGEMENT PROGRAMNIE
6.1 General The risk assessment above has identified that the only site arealzone that requires additional firewater retention is the Milk Powder Store. The maximum firewater volume requiring retention is estimated to be in the order of 450m3, as calculated above. (Note: due allowance must also be made for rainfall contribution in accordance with the requirements of the EPA draft guidance note to industry regarding firewater retention facilities}.
A risk management programme is proposed which is based on providing the necessary firewater retention capacity within the existing on-site WWTP.
6.2 Existing Risk Management Infrastructure
Kerry Ingredients have always maintained a strict programme of risk management for the prevention of emergency or uncontrolled releases to the River Feale. The core element of this programme is based on the fact that the entire surface water drainage system covering the site is connected to the site wastewater treatment plant. Thus, any spill or unscheduled release within the confines of the slte wilt be collected and directed to the WWTP for isolation and/or treatment.
6.3 Proposed Rlsk Management Programme for Firewater Run-Off
6.3.1 Concept A new risk management programme is proposed by Kerry Ingredients which is based on utilising the existing drainage infrastructure and site WWTP to provide the caltection and retention capacities for the required firewater run-off quantities calculated above.
A successful firewater risk management plan for the Kerry Ingredients site will ensure that contaminated firewater from the identified risk area {Powder Store) will be efficiently collected and delivered to the WWTP where it can be stored and/or passed forward for treatment.
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Kerry Ingredients, Lislowel 10081 I-22-RI’-001, Issue B Firewater Run-off Study 17 May, 2004
6.3.2 Required Drainage Modifications
In the event of a fire in the Milk Powder Store water used to fight the fire would, under exisfing conditions, flow out of the building and enter the external surface water gullies. As indicated above, run-off in the vicinity of the Powder Store will then be directed to Ihe WWTP.
It has been calculated that the surface water sewer external io Powder State may not have adequate capacity to deal with the firewater load, if it coincides with a storm event. Accordingly, firewater run-off arising From the Powder Store will need to be directed to the process effluent drainage system. The firewater will then drain by gravity directly to the main infet sump of the WWTP from where it will be pumped to the maln balance tank (4,545m3 capacity). Appendix IV indudes details of the drainage modifications that will be required in the vicinity of the Powder Store to ensure firewater is directed to the process effluent collection system.
6.3.3 VVWTP Capacity for Firewatef
As already noted, the nature of the underground surface water drainage cotlection system at the Kerry Ingredients site Is such that all external surface water run-off (from paved areas and roofs) is directed to the WWTP. The WWTP is currently set-up to cater for a maximum hydraulic throughput of 10,000 m3/day (416m”/hr), which corresponds to the current limits specified in the IPC licence. This design thoughput includes allowance for the 20 year Return Period Storm Water Volume of 5,870 ma/day, as calculated in Section 5 above.
It has been calculated that, even at peak loading conditions on the WWTP (process effluent plus surface water), a minimum residual buffer capacity of 500m3 could be maintained in the WWTP balancing tank. It is proposed that this available buffer capacity would be dedicated to accommodating firewater from a fire event in the Milk Powder Store (or indeed any other area of the site that drains to the WWTP balance tank).
At present, there is insufficient automation and control within the WWTP to ensure the reliability of this buffer volume within the main balance tank. A project is currently being implemented b upgrade the automation and control system on the WWTP. Part of this work includes the upgrade of the level controls in the balance tank which ensure that a dedicated Firewater buffer capacity of 500m3 is alwavs available. Based on records of storm water and eftluent loading data for the site, the following buffer vofumes will be available:
I 500 I ) 100
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EPA Export 25-07-2013:14:50:49
Kerry Ingredients; List~el Firewater Run-off Study
20081 I-22-RP-001. Issue B 17 May, 2004
The nature of the contaminated firewater arising from a fire in the Powder Store (milk powder solution) is such that it can readily be dealt with in the activated sludge secondary treatment process. Thus, the procedure in the event of a fire in this area will be to allow the firewater run&off to continue through the normal wastewater treatment cycle. It should also be noted that, in the event of a fire on site, site evacuation of all non-emergency response personnel will result In production plant shutdown and interruption of normal &fluent flow to the WWTP. This will release further hydraulic and organic capacity at the WWTP to accommodate the firewater load. Irrespective, it is to be noted that the hydraulic load associated with the deslgn fire scenario (450m3) is comparatively small in the context of the current plant throughput (10,000m3 per day) and the total hydraulic retention of the plant (25,000m3).
lnherenf in this proposed risk management programme is the facf that fhe minimum reserve capacity of 5iXJm3 will be available to accommodate fhwater run-0H arising from a potential We in ny part of fhe western site cafchment, not just the identified risk area of the Powder Store.
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