january 2007. for inspection purposes only. · munster proteins and a letter from the suppliers has...

Ms Liz Leacy,

Office of Licensing and Guidance,

EPA,

PO Box 3000,

Johnstown Castle Estate,

Co. Wexford. 17th

January 2007.

Reg. No: P0800-01

Dear Ms Leacy,

I refer to your letter of October 5th

relating to Article 11 of the EPA (Licensing)

Regulations 1994 to 2004 and your request for further information to be submitted by

Lakeland Dairies as required by this article.

Further to your letter we have taken the following actions to comply with your

request.

Section B

A location map including the Wastewater Treatment Plant site with the site boundary

marked in colour has been attached. The centre grid reference of the Wastewater

Treatment Plant is 231067, 309024. This location map is included as Article 11

Reply - Attachment 1 - Wastewater Treatment Plant Boundary Map.

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Section D

1. In relation to the combustion of tallow oil in a thermal boiler:

(i) Compliance with EC Regulations:

Tallow is not being used in the boilers at present though it is envisaged that it will be

burned again on site in 2007. Any tallow purchased in 2006 has been purchased from

Munster Proteins and a letter from the suppliers has been attached (Article 11 Reply -

Attachment 2 – Letter from Tallow Supplier) to indicate that they comply with

Regulation (EC) No. 1774/2002 (and amendments) of the European Parliament and of

the Council of 3 October 2002 and Commission Regulation (EC) No. 2067/2005 of 16

December 2005 (Annex 1).

(ii) Operating Temperature, Residence Time and Letter of Approval:

Information relating to operating temperatures and temperature

controls, residence times and engineers certificates are currently

been collated.

There is currently no thermometer to record temperature of the tallow flame within

the furnace. A thermometer will be ordered and the temperature of the tallow flame

within the furnace determined if tallow is to be used on the site again.

The following response has been obtained from Saacke, the company who

manufactured the boiler:

„‟In relation to temperature and residence time within the chamber for the combustion

of tallow:

The initial flame temperature will be at approximately 1800 deg C and at the reversal

chamber the temperature would typically be a maximum of 450 deg C. Although

Saacke have not carried out detailed calculations for this particular site, but previous

work for typical shell boilers would give us the confidence to state that the bulk

temperature within the furnace will be greater than 1100 deg C for at least 0.2

seconds.‟‟

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Lakeland Dairies are in the process of obtaining permission from the Dept. of

Agriculture and Food to combust animal fats in a thermal boiler under EC regulation

92/2005 as amended by EC Regulation 2067/2005. The certificate of approval will be

forwarded to the Agency on receipt.

(iii) Details of the control parameters installed on the boilers:

The boilers have been fitted with temperature and pressure measuring devices prior to

feeding HFO / tallow to flame. There is an automated system employed to control

tallow feed rates to the burner. This controls the volumes, rates of application and

shut off for fuel. The fuel storage tanks have been fitted with meters to measure usage

on a continuous basis. Fuel pressure is maintained at a constant 40 psi.

Temperature controls will be installed on flame to ensure requirements for

combustion of tallow with respect to appropriate legislation are been met and

monitored.

Oxygen sensors (ETC Probe) have been fitted on the flue to ensure efficiency of

combustion.

2. Details of the Operation and Usage of the two boilers

There are two main boilers on site. These are listed in the application as Boiler 1

(Duty) and Boiler 2 (Standby). Both emission ducts feed into the one stack (listed as

A1-1 in the application).

The boilers on site operate so that Boiler 1 generally operates on full load. This has

been set at a pressure level of 10 bar. When the pressure in Boiler 1 drops to below 9

bar, due to high steam demand, Boiler 2 will automatically begin to operate. Boiler

No.2 will cease to operate when the operating pressure in Boiler No.1 again exceeds

the operating pressure in Boiler No.2 and both pressures exceed 9 bar.

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Boiler 1 is capable of burning either tallow or HFO. This change over is manually

controlled by switch. Boiler No 2 operates on Heavy Fuel Oil only.

3. Details of the Operation of the Casein Dryers to include the function of the

LPG Burners

The LPG burners on the casein stacks are used to generate hot air, which comes in

direct contact with aqueous product at the casein dryers. Emissions from each burner

are discharged to the environment through the casein dryer stacks. Flue gas analysis

of each stack was carried out in November 2006 by Teagasc. The results are included

as Article 11 Reply - Attachment 3 – Casein Dryer Stacks Emissions Reports.

Section E.1 Emissions to Atmosphere

Tables E.1(i), E.1(ii) and E.1(iii) have been completed. They are included as Article

11 Reply - Attachment 4 – Tables E.1(i) – E.1(iii) – Emissions to Atmosphere.

Section E.2 Emissions to Surface Waters

1. Details of the ortho-phosphate concentration in the treated effluent from the

Wastewater Treatment Plant

They are included as Article 11 Reply - Attachment 5 – Phosphate concentrations in

Treated Effluent.

2. Emission Limit Values sought for the effluent discharge

The emission limits sought for the effluent discharge are outlined in Tables E.2(i) -

E.2(ii). These are included as Article 11 Reply - Attachment 6 – Tables E.2(ii) – SW4

- Emissions to Surface Water.

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The phosphate loading is requested in terms of kilogrammes of P to the river per day

rather than in terms of concentration.

3. Date of commencement of discharge of effluent etc.

Discharge of effluent to the Cullies River via SW4 began in 1986. The Wastewater

Treatment Plant began operation in 1986 and the first discharge license for this

effluent was issued in October 1986.

4. Details of diversion of effluent to spray irrigation

A facility is in place to spray irrigate final effluent onto the Lakeland Dairies owned

farm in the event of malfunction at the Wastewater Treatment Plant. This facility

would have been used only a couple of times per year in the event of emergency.

The flow rate of the River Cullies is not monitored.

5. Copies of Monitoring Reports

A copy of the Monitoring Report is included as Article 11 Reply - Attachment 7 –

Effluent and Surface Water Monitoring Results.

6. Drainage Map for the Site

A copy of the Drainage Map for the Site is included as Article 11 Reply - Attachment

8 – Site Drainage Map.

7. Storm Water Drainage System

Cooling water and condensate from various machines is discharged in surface water

lines SW1, SW2 and SW3.

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Tables E.2(ii) have been completed and are included as Article 11 Reply - Attachment

9 – Tables E.2(i) - E.2(ii) – SW1,2,3 – Emissions to Surface Water.

Section F

Table F.2(i) for noise sensitive locations NSL1 and NSL2 and for groundwater wells

GW1 and GW2 are attached. Tables F.2(i) have been completed and are included as

Article 11 Reply - Attachment 10 – Tables F.2(i) – Noise and Groundwater.

Section G

There are currently 3 borehole wells drilled on site that provide water for all cleaning,

cooling and process operation. The wells have been fitted with metering devices

however this data has not been logged. A data logger will be ordered immediately for

the metering device to give daily / weekly / monthly water usage figures.

The canteen and offices are fed from mains water.

Section I

1. Complete section I.1 in relation to the impact of the boilers and the casein dryers.

Your response should include dispersion modelling of the maximum predicted

emissions of SO2, NOX and Dust. Provide, in electronic format, the input,

meteorological and terrain files used in the model.

An Air Dispersion Model relating to the impact of the boiler and casein dryer emissions

is included as Article 11 Reply - Attachment 11 – Air Dispersion Model.

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2. In relation to management and landspreading of sludge:

(i) Submit a copy of the 2006 NMP to demonstrate that adequate land is

available for the recovery of sludge generated. Include a suitable scaled

map to identify lands used.

Lakeland Dairies have sourced a suitable landbank for the spreading of organic waste.

This consists of 26 separate farms all covered under the REPS scheme. The Nutrient

Management Plans developed for REPS do not comply with the table requirements in

the IPPC application. They do however conform to the current standards for the Rural

Environmental Protection Scheme.

Lakeland Dairies have included a summary copy of the current NMP along with an

Agri-Environmental Plan for one of the sites. Lakeland Dairies will submit an updated

plan for 2007 to include compliance with the Nitrates Directive, including maps and

nutrient management tables in accordance with EPA/IPPC requirements.

The current plan has the capacity to assimilate approximately 3310 tonnes of organic

waste from Lakeland Dairies. This equates to 110% the required annual capacity for

this site, as it was calculated that the site produced approximately 3000 tonnes of

sludge in the preceding 12 months.

The Nutrient Management Plan Summary is included as Article 11 Reply -

Attachment 12 – Nutrient Management Plan Summary.

(ii) Give a description of the storage facility; give details of the available

capacity and storage period in weeks.

Sludge is produced from the centrifuge at a solids content of approximately 18%.

Lime has been added at a rate of approximately 1:5 @ 20% solids. This increases the

stability of the sludge and enables the product be piled higher in storage.

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Currently there are 5 different storage areas for over-wintering sludge. The following

table summarises details of each:

Storage

Identification

Location Dimensions

(m)

Area

(m3)

Weather

Protection

1 Large Pit 1 12 x 32 x 2.1 806 Uncovered

2 Large Pit 2 12 x 32 x 2.1 806 Uncovered

3 Bottom Pit A 6.5 x 24 x 2.5 390 Covered

4 Bottom Pit B 6.5 x 24 x 2.5 390 Covered

Total Storage Available 2,392

The current capacity of storage is 2,392 tonnes, which equates to 45 weeks of storage

capacity. The covered tanks are used as primary storage, with the pits used if required.

Runoff is collected from the uncovered pits in effluent tanks at the end of the storage

areas. Runoff would be collected and transported to the treatment plant if these areas

were to be utilised for storage.

(iii) Provide details of measures to be taken to comply with the requirements

of S.I. 378 of 2006 (Nitrates Regulations)

The following criteria have been implemented to comply with the said Regulation:

Adequate storage has been sought for 16 week storage period (15th

October

2006 – 31st January 2007)

Sludge is stored on impermeable surfaces to prevent groundwater

contamination

Sludge is stored primarily in an enclosed silage pit to prevent runoff of water

Spreading ceased on the 14th

October 2006 and will not resume until 01st

February 2007.

Annual Nutrient Management Plans have been developed for sludge produced

during treatment. The 2006 plan was largely developed to conform to

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phosphorous loading due to the uncertainty in implementation of the Nitrates

Directive this year.

3. In relation to spray irrigation of effluent:

(i) Identify the lands available for spray irrigation of effluent as required by

“emissions of trade wastewater condition 5” of the discharge licence.

The lands available for spray irrigation is included as Article 11 Reply - Attachment

13 – .Map of farm available for spray irrigation.

(ii) Submit details of the management and control of this activity to include

the maximum hydraulic loading.

Effluent is only spray irrigated in the event of Wastewater Treatment Plant

malfunction. In this situation the effluent is spread over as large an area as possible so

as to avoid applying too heavy of a hydraulic load onto any given field. Also effluent

would not be spread close to any drains on the farm.

(iii) Provide details of the measures to be taken to comply with the

requirements of S.I 378 of 2006 (Nitrates Regs).

There has been no spray irrigation of effluent since the introduction of the Nitrates

Regulations. The measures outlined in the Regulations will be complied with in 2007.

4. Complete Section I.8, with reference to the IPPC Reference Document on BAT for

the Food and Drink Industry.

Lakeland Dairies operate in an environmentally efficient manner in accordance with

BAT outlined for the Food and Drink Industry. There were no emissions determined

to exceed BAT on site. Wastewater discharges are within BAT requirements, energy

consumption has been minimised at the site to ensure operation at maximum

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efficiencies. A summary of the performance of the site is detailed in the table below.

More detailed figures are included as part of the ISO 14001 system on the site.

BAT Emission

Levels

Units BAT Compliance

Wastewater

Discharge

BOD

COD

TSS

pH

OFG

TN

TP

<25

<125

<50

6 – 9

<10

<10

0.4 – 5

mg/L

mg/L

mg/L

mg/L

mg/L

mg/L

mg/L

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Energy

Consumption

Production of

market milk from 1

litre of milk

received

0.07 – 0.2

KWh/l

Yes

Waste Water

Volume generated

0.8 – 1.7

l/l

Yes

Emissions to

Atmosphere –

Dust

<50 mg/Nm3 Yes

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Section L

1. Indicate how the requirements of Section 83(5)(a)(i) to (v) and (vii) to (x) of

the EPA Acts, 1992 and 2003 shall be met, having regard, where appropriate,

to any relevant specification issued by the Agency under section 5 (3) of the

Act and the reasons for the selection of the arrangements proposed.

1.1 Section 83 (5)a(i)

“Any emissions from the activity will not result in the contravention of any relevant

air quality standard specified under section 50 of the Air Pollution Act 1987, and will

comply with any relevant emission limit value specified under section 51 of the Air

Pollution Act 1987”.

The main emissions from this facility were products of combustion (NOx, SO2 and

particulates). Process emissions had bag filters installed and would not contribute

significantly to ambient ground level concentrations of dust.

An air dispersion model was carried out on emissions from the facility for both the

boilers and dryer stacks. It has been determined from worst-case scenarios that the

installation was not having a significant impact on the local environment and not

contravening any aspects of the Air Pollution Act. The dispersion model has been

attached in section I of this submission.

1.2 Section 83 (5)a(ii)

”Any emissions from the activity will comply with, or will not result in the

contravention of, any relevant qualify standard for waters, trade effluents and sewage

effluents and standards in relation to treatment of such effluents prescribed under

section 26 of the Local Government (Water Pollution) Act 1977”.

The site has installed a treatment plant with tertiary treatment in the form of sand

filters in order to meet and exceed all relevant regulatory emission limit values.

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An environmental management system has been implemented which will focus on the

safe and efficient operation and maintenance of the onsite wastewater treatment plant

facilities to ensure compliance with all relevant regulatory requirements.

For details of emissions to surface water from the facility and their treatment,

abatement, control and monitoring, refer to Sections E and F of the original

application or monitoring records included in section E2 of this submission.

1.3 Section 83 (5)a(iii)

“Any emissions from the activity or any premises, plant, methods, processes,

operating procedures or other factors which affect such emissions will comply with,

or will not result in the contravention of, any relevant standard including any

standard for an environmental medium prescribed under regulations made under the

European Communities Act 1972, or under any other enactment”

The facility has been operating in compliance with applicable regulations, so no

likelihood of such contravention is anticipated.

1.4 Section 83 (5)a (iv)

“Any noise from the activity will comply with, or will not result in the contravention

of any regulations under section 106”.

A noise survey has shown that there was no significant impact on the receiving

environment. For details of the noise-monitoring program, refer to Section E5 – Part 1

of the IPPC Licence Application. Equipment noise emissions have been part of

management decisions during purchase of equipment in the past and this will continue

at the plant.

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1.5 Section 83 (5)a (v)

“Any emissions from the activity will not cause significant environmental pollution”

The preceding sections of this licence application demonstrate that the operation of

the facility will not cause significant environmental pollution.

1.6 Section 83 (5)a (vi)

“Having regard to Part 111 of the Act of 1996, production of waste in the carrying on

of the activity will be prevented or minimised or, where waste is produced, it will be

recovered or, where that is not technically or economically possible, disposed of in a

manner which will prevent or minimise any impact on the environment”

Waste to be generated at the facility will comprise mainly of non-hazardous waste

(e.g. municipal waste, non-hazardous industrial waste and other wastes) and small

quantities of hazardous wastes, as defined in the EU Council Directive 91/689/EEC.

For details of the wastes arising and their classification as per the European Waste

Catalogue, refer to Section H of the IPPC application.

All wastes to be disposed of offsite are fully documented and controlled; using

licensed waste contractors, in full compliance with the Waste Management Act 1996,

Waste Management (Amendment) Act 2001, and associated Statutory Instruments

from 1997 to date.

1.7 Section 83 (5)a (viii)

“Energy will be used efficiently in the carrying on of the activity”

Energy has been listed as a growing concern on site over previous years for both

economical and environmental reasons. An informal energy management system has

been incorporated into the facility, which records, monitors, evaluates and highlights

energy consumption and potential savings.

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1.8 Section 83 (5)a (ix)

“Necessary measures will be taken to prevent accidents in the carrying on of the

activity and, where an accident occurs, to limit its consequences for the environment

and, in so far as it does have such consequences, to remedy those consequences”

The environmental management system on site ensures training was carried out with

employees to ensure risks are minimized. The accident prevention and emergency

response provisions and procedures on the site are discussed in detail in Section J of

the IPPC application.

1.9 Section 83 (5)a (x)

“Necessary measures will be taken upon the permanent cessation of the activity

(including such a cessation resulting from the abandonment of the activity) to avoid

any risk of environmental pollution and return the site of the activity to a satisfactory

state”.

A remediation, decommissioning, restoration and aftercare plan has been developed

for the purposes of this application. It is understood that upon issue of IPPC licence

the site will be requested to carry out a Residuals Management Plan (RMP) based on

the EPA’s “Guidance Documents and Assessment Tools on Environmental Liabilities

Risk Assessment and Residuals Management Plans incorporating Financial Provision

Assessment”.

2. Indicate whether or not the activity is carried out on, or may be carried out

on, or is located such that it is liable to have an adverse effect on –

(a) A site placed on a list in accordance with Chapter I of S.I. 94 of 1997, or

(b) A site where consultation has been initiated in accordance with Article 5 of the EU

Habitats Directive (92/43/EEC)

The site was is placed within any site listed on Chapter 1 of S.I. 94 of 1997 or in

article 5 of the Habitats Directive.

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3. Indicate whether any of the substances specified in the Schedule of the EPA

(Licensing) (Amendment) 2004 are discharged by the activity to the relevant

medium.

Substances listed in the Schedule to the above-mentioned regulations may be emitted

as follows:

Compounds To Air

Comment

Sulphur dioxide and other sulphur compounds

Yes

Oxides of nitrogen and other nitrogen compounds Yes

Carbon monoxide

Yes

Volatile organic compounds

None

Metals and their compounds

None

Dust

Not Significant

Asbestos (suspended particulates, fibres)

None

Chlorine and its compounds

None

Fluorine and its compounds

None

Arsenic and its compounds

None

Cyanides

None

Substances and preparations which have been proved to None

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possess carcinogenic or mutagenic properties or

properties which may affect reproduction via the air

Polychlorinated dibenzodioxins and polychlorinated

dibenzofurans-

None

Compounds To Water

Comment

Organohalogen compounds and substances which may

Form such compounds in the aquatic environment

None

Organophosphorus compounds

None

Organotin compounds

None

Substances and preparations which have been proved to

possess carcinogenic or mutagenic properties or

properties which may affect reproduction in or via the

aquatic environment

None

Persistent hydrocarbons and persistent and bio-

accumulable organic toxic substances

None

Cyanides

None

Metals and their compounds

None

Arsenic and its compounds

None

Biocides and plant health products

None

Materials in suspension

Yes – suspended solids

Substances which contribute to eutrophication (in

particular, nitrates and phosphates)

Yes nitrates and

phosphorous

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Substances which have an unfavorable influence on the

oxygen balance (and can be measured using parameters

such as BOD, COD, etc.)

Yes – organic loading in

treated water

4. Give Details of the Prosecution of Lakeland Dairies by Cavan Co Co under

the Local Government (Water Pollution) Acts, 1997 and 1990 and any

remedial action undertaken.

Lakeland Dairies were prosecuted by the Northern Regional Fisheries Board under the

Local Government (Water Pollution) Act in June 2004. The prosecution related to an

incident that occurred on November 1st 2003.

On this date there was a discharge of sludge from the Wastewater Treatment Plant to

the river. The discharge was accidental and was acknowledged to be so by the

Fisheries Board.

The incident occurred when sludge rose rather than settling in the second clarifier at

the Wastewater Treatment Plant. The sludge then blocked the sand filter on site.

When the sand filter became blocked, water and sludge began to rise in the second

clarifier and this overflowed, percolated through a stony area and ended up in a stream

beside the Wastewater Treatment Plant and then flowed into the Cullies River.

The main remedial action taken to ensure that the incident would not occur again was

to place a level control on the tank that overflowed and if the level in this tank were to

rise again, the level sensor will automatically bring on a pump in the tank, which will

pump the contents of the tank back to the Balance Tank at the Wastewater Treatment

Plant. The forward feed from the Balance Tank will be automatically stopped so that

effluent does not continue to flow through the Plant. Levels in both Balance Tanks at

the Wastewater Treatment Plant are kept quite low so as to allow for space for this

type of incident.

There has been huge investment in the Wastewater Treatment Plant in the last year to

ensure that sludge bulking does not occur. The main improvement in this area has

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resulted from the installation of a centrifuge with three times the capacity of the

previous centrifuge.

I hope all of the above responses are adequate but if there are further queries, please

do not hesitate to contact me.

Yours faithfully,

___________________________________________

RORY FARRELL

ENVIRONMENTAL MANAGER

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Article 11 Reply Attachment 1 – Map 3 - Wastewater Treatment Plant Boundary Map

231067, 309024

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Article 11 Reply - Attachment 2 – Letter from Tallow Supplier

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Article 11 Reply - Attachment 3 – Casein Dryer Stack Emissions Reports

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Article 11 Reply – Attachment 4 – Tables E.1(i) – E.1 (iii) – Emissions to Atmosphere

TABLE E.1(i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point)

Emission Point:

Emission Point Ref. No: A1-1

Location : Boiler House Stack

Grid Ref. (12 digit, 6E,6N): 230770, 309930

Vent Details

Diameter:

Height above Ground(m):

1.35 metres

25

Date of commencement of

emission:

1st October 1995

Characteristics of Emission :

Boiler rating

Steam Output:

Thermal Input:

kg/hr

20.71 MW

Boiler fuel

Type:

Maximum rate at which fuel is burned

% sulphur content:

Heavy Fuel Oil

kg/hr

<1%

NOx Max: 1000 Mg/Nm3

0oC. 3% O2(Liquid or Gas), 6% O2(Solid Fuel)

Maximum volume of emission

Standard Conditions 25,000 Nm3/hr

Temperature 250 oC(max) 160 o

C(min) ~180 oC(avg)

(i) Period or periods during which emissions are made, or are to be made,

including daily or seasonal variations (start-up/shutdown to be included):

1 week shutdown

Periods of Emission (avg) 24 min/hr 60 hr/day 360 day/yr

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EPA Export 25-07-2013:21:32:04

TABLE E.1(i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point)

Emission Point:


Location : Boiler House Stack

Grid Ref. (12 digit, 6E,6N): 230770, 309930

Vent Details

Diameter:


1.35

25

Date of commencement of

emission:

1st October 1995


Boiler rating

Steam Output:

Thermal Input:

kg/hr

20.71 MW

Boiler fuel

Type:

Maximum rate at which fuel is burned

% sulphur content:

Tallow

kg/hr

<0.1%

NOx

Maximum volume of emission 25,000 m3/hr

Temperature

(i) Period or periods during which emissions are made, or are to be made,

including daily or seasonal variations (start-up/shutdown to be included):

1 week shutdown


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TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (1 Page for each emission point)


Source of Emission: Casein Plant LPG Burner 1 (Small)

Location : Casein Plant

Grid Ref. (12 digit, 6E,6N): 230795, 307393

Vent Details

Diameter:


0.46 x 0.38

9.0

Date of commencement: 1st January 1983


(i) Volume to be emitted: Normalised (Standard) Conditions

Average/day 175080Nm3/d Maximum/day 187,000 Nm

3/d

Maximum rate/hour 7800Nm3/h Min efflux velocity - m.sec

-1

(i) Volume to be emitted: Actual Conditions

Average/day 252,000m3/d Maximum/day 272,000 m

3/d

Maximum rate/hour 10,500 m3/h Min efflux velocity - m.sec

-1

(ii) Other factors

Temperature 145oC(max) 90

oC(min) 100

oC(avg)

For Combustion Sources:

Volume terms expressed as : wet. dry. %O2

(iii) Period or periods during which emissions are made, or are to be made, including daily or

seasonal variations (start-up /shutdown to be included):


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Source of Emission: Casein Plant LPG Burner 2 (Large)


Grid Ref. (12 digit, 6E,6N): 230814, 30742

Vent Details

Diameter:


0.3444 x 0.555

23

Date of commencement: 1st January 1986

Characteristics of Emission:

(i) Volume to be emitted: Standard Conditions

Average/day 270,360 Nm3/d Maximum/day 288,000 Nm

3/d

Maximum rate/hour 12,000Nm3/h Min efflux velocity - m.sec

-1


Average/day 348,000 m3/d Maximum/day 348,000 m

3/d

Maximum rate/hour 14,500 m3/h Min efflux velocity - m.sec

-1

(ii) Other factors

Temperature 145 oC(max) 86

oC(min)

100

oC(avg)


Volume terms expressed as : wet. dry. %O2




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Source of Emission: Casein Plant LPG Burner 3


Grid Ref. (12 digit, 6E,6N): 230795, 307393

Vent Details

Diameter:


0.70

23

Date of commencement: 1st April 2006


(i) Volume to be emitted: Standard Conditions

Average/day 600,000 Nm3 Maximum/day 600,000 Nm3

Maximum rate/hour 25,000 Nm3 Min efflux velocity -


Average/day 678,500 m3 Maximum/day 678,500 m3

Maximum rate/hour 30,000 m3 Min efflux velocity -

(ii) Other factors

Temperature 100 Deg C


Volume terms expressed as: Dry Gas



Periods of Emission (avg)

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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (1 table per emission point)

Emission Point Reference Number: A2-1 (Small)

Parameter Prior to treatment(1) Brief As discharged

(1)

mg/Nm3 kg/h description mg/Nm

3 kg/h. kg/year

Avg Max Avg Max of treatment Avg Max Avg Max Avg Max

Dust No Analysis Available Baghouse Filter 5 10 0.04 0.08 120 680

1. Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0oC,101.3kPa). Wet/dry should be the same as given

in Table E.1(ii) unless clearly stated otherwise.

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Emission Point Reference Number: A2-2 (Large)


(1)


3 kg/h. kg/year

Avg Max Avg Max Of treatment Avg Max Avg Max Avg Max




given in Table E.1(ii) unless clearly stated otherwise.

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Emission Point Reference Number: A2-3


(1)


3 kg/h. kg/year

Avg Max Avg Max of treatment Avg Max Avg Max Avg Max




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EPA Export 25-07-2013:21:32:05

Article 11 Reply - Attachment 5 - Phosphate Results in Treated Effluent

Total P Total P Total P

(mg/l P) (mg/l P) (mg/l P)

03/01/2006 363 0.17 13/05/2006 1059 0.9 03/10/2006 710 0.6

10/01/2006 261 0.27 18/05/2006 1023 1.1 09/10/2006 722 1

17/01/2006 322 0.7 24/05/2006 1221 0.9 16/10/2006 537 0.6

27/01/2006 310 0.27 02/06/2006 968 0.9 23/10/2006 656 0.7

03/02/2005 404 0.78 08/06/2006 1115 0.8 01/11/2006 756 0.8

10/02/2006 334 0.5 13/06/2006 1036 0.6 08/11/2006 654 0.6

17/02/2006 314 0.3 19/06/2006 752 0.8 15/11/2006 643 0.8

24/02/2006 292 0.16 03/07/2006 839 1.2 22/11/2006 554 0.9

01/03/2006 304 0.3 12/07/2006 1054 0.9 29/11/2006 850 0.8

07/03/2006 263 0.18 20/07/2006 1009 0.7 06/12/2006 938 0.6

14/03/2006 691 0.17 28/07/2006 1142 0.8 13/12/2006 1006 0.8

20/03/2006 388 0.21 04/08/2006 1005 0.9 20/12/2006 958 0.9

28/03/2006 391 0.16 11/08/2006 736 0.6 29/12/2006 432 0.6

05/04/2006 489 0.18 18/08/2006 775 0.9

12/04/2006 862 1.6 25/08/2006 616 0.6

18/04/2006 699 1.05 31/08/2006 541 0.9

24/04/2006 843 0.9 08/09/2006 1202 0.9

01/05/2006 1006 0.8 15/09/2006 461 0.7

05/05/2006 1078 1.4 27/09/2006 616 1

Date

Flow Out

(m3)Date

Flow Out

(m3) Date

Flow Out

(m3)

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Article 11 Reply – Attachment 6 – Tables E.2(i) – E.2(ii) – Emissions to Surface

Water

TABLE E.2(i): EMISSIONS TO SURFACE WATERS (One page for each emission)

Emission Point:

Emission Point Ref. No: SW4

Source of Emission: Final Effluent from Wastewater Treatment Plant

Location : Wastewater Treatment Plant – Killeshandra

Grid Ref. (10 digit, 5E,5N): 231243, 308824

Name of receiving waters: Cullies River – Killeshandra

Flow rate in receiving

waters:

0.256 m3.sec

-1 Dry Weather Flow

0.513 m3.sec

-1 95%ile flow

Calculations based on catchment area (171km2 at the Disert

bridge upstream – EPA, and a dry weather recharge rate of

1.49/l/s/km2)

Available waste assimilative

capacity:

37.67 kg BOD/day

Based on EPA analysis data for Cullies River at New Bridge.

Background BOD of Median 2.3 for the period 1998 – 2000.

Utilising 95%ile figures accounting for 50% usage allowing

for others to discharge downstream.

Emission Details:

(i) Volume to be emitted

Normal/day 1000 M3 Maximum/day (a max

flow of 2000m3 per

day is requested)

2000 m3

Maximum rate/hour 125 M3

(ii) Period or periods during which emissions are made, or are to be made,

including daily or seasonal variations (start-up /shutdown to be included):


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TABLE E.2(ii): EMISSIONS TO SURFACE WATERS - Characteristics of the emission (1 table per emission point)

Emission point reference number : SW4 Final Effluent

Parameter Prior to treatment As discharged % Efficiency

Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)

kg/day kg/year Max. hourly average

(mg/l) Max. daily average

(mg/l) kg/day kg/year

BOD 24 hr Comp Samples 20 30 11,000 -

Suspended Solids 24 hr Comp Samples 30 45 16,500 -

pH 24 hr Comp Samples 6 – 9 - -

-

Total P 24 hr Comp Samples - 1.5 550 -

Ammonia 24 hr Comp Samples - 7.5 2,800 -

Total Oxidised N 24 hr Comp Samples - 22.5 8,200 -

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EPA Export 25-07-2013:21:32:05

Article 11 Reply - Attachment 7 - Effluent and Surface Water Monitoring Results

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EPA Export 25-07-2013:21:32:05

Article 11 Reply - Attachment 8 – Map 4 – Site Drainage Map

This map is available as hard copy. It was not possible to scan the map foe

availability on disc.

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EPA Export 25-07-2013:21:32:05

Article 11 Reply – Attachment 9 – Table E.2(i) – E.2(ii) – SW1,2,3 – Emissions

to Surface Water


Emission Point:


Source of Emission: Site Surface Water

Location : Main Factory Gate

Grid Ref. (10 digit, 5E,5N): 230781, 307462

Name of receiving waters: Town Lough – Killeshandra


waters:

Town Lough


capacity:

Emission Details:


Normal/day 766 M3 Maximum/day 2500 m

3





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Emission point reference number : SW1


Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)



(mg/l) kg/day kg/year

BOD 24 hr Comp Samples 7.5 2740 -

Suspended Solids N/A 24 hr Comp Samples 62.5 156 -

pH 24 hr Comp Samples 6 – 9 - - -

Total P 24 hr Comp Samples 0.25 91 -

Ammonia 24 hr Comp Samples 7.5 19 -

Total Oxidised N 24 hr Comp Samples 12.5 31 -

Temperature 24 hr Comp Samples 25 - -

Flow Rate 2500m3

- -

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Emission Point:



Location : Factory Gate at Butter Plant

Grid Ref. (10 digit, 5E,5N): 230839, 207562



waters:

Town Lough


capacity:

Emission Details:



3





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Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)



(mg/l) Kg/day kg/year


Suspended Solids No Treatment Employed 24 hr Comp Samples 62.5 156 -

pH 24 hr Comp Samples 6 – 9 - - -



Total Organic N 24 hr Comp Samples 12.5 31 -


Flow Rate 2500m3

- -

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Emission Point:



Location : Inside Wall at Loading Bay

Grid Ref. (10 digit, 5E,5N): 230809, 307572



waters:

Town Lough


capacity:

Emission Details:



3





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Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)



(mg/l) Kg/day kg/year


Suspended Solids No Treatment Employed 24 hr Comp Samples -

pH 24 hr Comp Samples 6 - 9 - - -



Total Organic N 24 hr Comp Samples 12.5 31 -


Flow Rate 2500m3

- -

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EPA Export 25-07-2013:21:32:06

Article 11 Reply – Attachment 10 – Tables F.2(i) – Noise and Groundwater

1. Complete Table F2.1 for Noise Sensitive Location

TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS - ( 1 table per monitoring point)

Emission Point Reference No. : NSL 1

Parameter Monitoring

frequency

Accessibility of

Sampling Points

Sampling method Analysis method/ technique

Broadband & 1/3rd

Octave

Measurements

Annual

Accessible with permission

from residents

Type 2 sound level meter

30 minute daytime measurements

15 minute night time

ISO 1996 parts 1 – 3 with reference to EPA

Guidance Document for Environmental noise

monitoring


Parameter Monitoring

frequency

Accessibility of

Sampling Points

Sampling method Analysis method/ technique

Broadband & 1/3rd

Octave

Measurements

Annual

Accessible with permission

from residents


30 minute daytime measurements


ISO 1996 parts 1 – 3 with reference to EPA

Guidance Document for Environmental noise

monitoring


Parameter Monitoring frequency Accessibility of Sampling Points Sampling method Analysis method/ technique

Broadband & 1/3rd

Octave

Measurements

Annual

Accessible with permission from

residents


30 minute daytime

measurements


ISO 1996 parts 1 – 3 with reference to

EPA Guidance Document for

Environmental noise monitoring

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2. Complete F.2(i) for Groundwater Wells GW1 and GW2

Monitoring Point Reference No. : GW1

Parameter Monitoring frequency Accessibility of

Sampling point

Sampling method Analysis method /

technique

Nitrate – N

Nitrite – N

Ammonia – N

Iron

Manganese

Phosphate

Total Dissolved Solids

pH

Conductivity

Chloride

Sulphate

Calcium

Magnesium

Sodium

Potassium

Aluminum

Annual

Good

Purge and Sample

Standard Methods for

Water and Wastewaters

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Monitoring Point Reference No. : GW2

Parameter Monitoring frequency Accessibility of

Sampling point

Sampling method Analysis method /

technique

Nitrate – N

Nitrite – N

Ammonia – N

Iron

Manganese

Phosphate

Total Dissolved Solids

pH

Conductivity

Chloride

Sulphate

Calcium

Magnesium

Sodium

Potassium

Aluminum

Annual

Good

Purge and Sample

Standard Methods for

Water and Wastewaters

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EPA Export 25-07-2013:21:32:06

A

IR D

ISP

ER

SIO

N M

OD

EL 2

00

7

Lakeland Dairies

Ref No: P0800-01

Killeshandra, Co Cavan

Report No: 2010-07-01 Version 1

AXIS environmental services

40 Coolraine Heights, Old Cratloe Road, Limerick

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EPA Export 25-07-2013:21:32:06

AXIS environmental services Lakeland Dairies Air Dispersion Model 2010-07-01

Table of Contents Non Technical Summary ………………………………………… 3 1.0 Introduction ………………………………………… 4 2.0 Model Input data ……………………………………….. 5 2.1 Pollutant Emissions ……………………………………….. 5 2.2 Building Wake Effects ……………………………………….. 6 2.3 Met Data ……………………………………….. 7 2.4 Receptor Grid ……………………………………….. 7 2.5 Current AQS ……………………………………….. 8 3.0 Results ……………………………………….. 9 4.0 Conclusions ……………………………………….. 17

Page 2 of 19 Version 1

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Executive Summary Lakeland Dairies were requested as part of the IPPC licence application process to provide an air dispersion model of the maximum predicted air emissions from both combustion and process operations at the installation. Modelling was carried out in the context of 2 separate formats: Scene A: Modelling combustion emissions for the plant under maximum operations Scene B: Modelling process emissions for the plant under current maximum operations Lakeland Dairies have 2 boilers on site, currently burning HFO. Maximum operations at the installation are to run the duty boiler primarily. If for some reason the steam pressure drops with in the system, a secondary boiler would commence. Worst case emissions from this installation would be both boilers operating at the same time. Both duty and standby boilers discharge flue gases through the one stack (A1-1). AXIS environmental services were commissioned by Lakeland Dairies to model the maximum hourly, daily and annual worst case ground level concentrations of NO2 and SO2. Worst case particulate concentrations from process emissions were also predicted for both hourly and annual situations. Breeze AERMOD prime v4.10 was used to generate predictions of maximum ground level concentrations both on the site boundary and at a number of receptor points in the vicinity of the installation. This model has been generated using worst case scenarios and meteorological data at the plant. It is expected that ground level concentrations in the immediate vicinity would be considerably lower than those mentioned in this report for most of the time.


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1.0 Introduction AXIS environmental services were commissioned by Lakeland Diaries to carry out a dispersion model of emissions from the dairy plant in Killeshandra. Pollutants of interest from the installation were NO2/ SO2 concentrations generated by the boiler and dust from process emissions. The study consists of the following components:

• Review maximum emissions from the installation, • Dispersion modelling of releases using the most appropriate meteorological data, • Presentation of concentrations of released substances at the nearest sensitive

receptors and at the maximum locations on the site boundary. • Evaluation of the significance of ground level concentrations by comparison with air

quality standards.

The maximum worst case hourly ground level concentrations of SO2 / NO2 from the boilers were predicted at a number of boundary locations and sensitive receptors in the vicinity of the plant. Maximum worst case concentrations of particulate were also determined in the vicinity as part of this project. The following table summarises the scenarios modelled in this report: Table 1 – Summary of Emissions Data Scene

Emissions Pollutant Air Quality Standard

Notes

A A1-1

HFO NO2/ SO2 S.I. 272 of 2002 Maximum hourly & annual GLC of NO2 from combustion sources. Hourly and daily SO2 concentrations.

B A2-1 A2-2 A2-3

Process Emissions

Particulate/ PM10

S.I. 271 of 2002 Maximum 90.4% daily and annual average GLC of PM10


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2.0 Model Input Data 2.1 Maximum Pollutant Emissions Table 2 – Boiler Emissions

Temp Discharge Height

Exit Velocity and Stack Flow Rate

Stack Exit

Diameter

Emission Concentration

Source

A1-1 oK m m/s Nm3/hr m mg/Nm3 g/s NOx 418 25 4.85 25,000 1.35 1000 6.94 SO2 418 25 4.85 25,000 1.35 1100 7.63 Table 3 – Process Emissions (Particulates)

Temp Discharge Height

Stack Flow Rate Stack Exit

Diameter

Emission Concentration

Source

oK m m/s Nm3/hr m mg/Nm3 g/s A2-1 373 9 12.4 7,800 0.47 10 0.0216 A2-2 373 23 17.8 12,000 0.49 10 0.0330 A2-3 373 23 18.1 25,000 0.70 10 0.0694 Emission data has been obtained from maximum monitoring results obtained on site for combustion of HFO and historical dust determinations carried out by Teagasc. Exhaust gas velocities were based on maximum loads with no rain hats to restrict gas movements. The concentration of NOx in the exhaust gas from the installed boiler is related to the amount of combustion air available, chemistry of the fuel been burnt and also the temperature within the flame area. It has been estimated that for boilers, over 95% of NOx in the exhaust gas is emitted as NO with the remainder emitted as NO2. Most of the NOx is formed in the high temperature zone downstream of the fuel injectors where the combustion air is mixed. To account for this the following assumptions could be made in the results reported;

• Ground Level NOx Concentrations adjusted to 50%

2.2 Building Wake Effects The dimensions of buildings can have a significant effect on the dispersion of a plume and ground level concentrations downwind. Breeze AERMOD prime allows for data input relating to dimensions and locations of buildings and tanks in relation to emission points. The presence of a building can create turbulence downwind of the emission. Lakeland Dairies was considered to have numerous buildings on site that may have relative effect on dispersion characteristics. The following table summarises information inserted into the Building Profile Input Program (BPIP), which is incorporated by the model to determine wake effects of buildings on dispersion in each wind direction considered. Buildings that were greater than 30% of the stack heights have been included.


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Table 4 – Building Heights

Building

Location Height (m)

1 UHT/ Finished Goods 8 2 Casein Plant (a) 6.5 3 Casein Plant (b) 20 4 Boiler House 7 5 Separation Room 9

Heights of each building were manually measured during site assessment. The dimensions of the buildings have been calculated by length measure in the model design. These buildings are accurate to within +/- 10%. 2.3 Meteorological Data The following wind rose has been generated from hourly data that represents wind direction and wind speed recorded in 2003/ 2004. The radial arms of the windrose represent the wind direction and the speed at which the wind is blowing. A general trend in the met data indicates the prevailing wind direction as south westerly.

Data aligned for rural situations was used in the model. 2.4 Receptor Grid A Cartesian grid with spacing of 25 m was chosen for this site, due to the localised building wake effects within the site. For the purpose of this survey the maximum emissions were determined on and outside the boundary of this site. Receptor flagpoles were inserted into the model at local sensitive receptors to predict worst case ground level concentrations and their compliance standings with current legislation.


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EPA Export 25-07-2013:21:32:06


2.5 Current Air Quality Standards Table 5 - S.I. 271 of 2002 Air Quality Standard Pollutant Ground Level

Concentration (ug/m3)

Averaging Period

Requirements

200 1 hour Average limit value may not be exceeded more than 18 times per year (Jan – 2010) (99.8% ile)

Nitrogen Dioxide (NO2)

40 Calendar Year

Compliance Date - Jan 2010

50 Daily Not to be exceeded more than 35 times per year (Compliance date – Jan 2005) (90.4%)

40 Calendar Year Compliance Date - Jan 2005

50 Daily Not to be exceeded more than 14 times per year (Compliance date – Jan 2008)

Particulate Matter (PM10)

20 Calendar Year Compliance Date - Jan 2010

350 1 hour Not to be exceeded more than 24 times per year. (Compliance date - Jan 2005) (99.8%ile)

Sulphur Dioxide (SO2)

125 Daily Not to be exceeded more than 3 times per year.


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3.0 Results Scene A: NOx Concentrations from Combustion at Lakeland Dairies. Table 6 – Maximum Predicted NOx GLC for 1 hour Location Co-ordinates Maximum Predicted 1 hour

Ground Level Concentration (ug/m3)

X Y GLC as NO2(1) 200

ug/m3 as NO2 Boundary

West 230674 307497 44.2 Compliant North 230807 307568 45.4 Compliant East 230843 307446 44.9 Compliant South 230706 307242 44.0 Compliant Nearest Sensitive Receptors

House 1 230558 307572 57.4 Compliant House 2 230909 307545 47.7 Compliant House 3 230847 307392 39.3 Compliant House 4 230741 307294 46.1 Compliant Maximum Predicted GLC 230984 307667 89.5 Compliant

(1) Ground level NO2 assumed 50% the Total NOx

Table 7 - Maximum Predicted NO2 GLC for Annual Concentrations Location Co-ordinates Maximum Predicted Annual


X Y GLC as NO2(2) 40

ug/m3 Boundary

West 230674 307497 0.4 Compliant North 230807 307568 0.5 Compliant East 230843 307446 0.3 Compliant South 230706 307242 0.6 Compliant Nearest Sensitive Receptors House 1 230558 307572 1.2 Compliant House 2 230909 307545 2.2 Compliant House 3 230847 307392 0.3 Compliant House 4 230741 307294 0.5 Compliant Maximum Predicted GLC 230984 307667 5.4 Compliant

(2) Ground level NO2 assumed 50% the Total NOx


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Modelling was carried out with proposed maximum emissions from the main combustion plant operating on site utilising HFO as fuel. The predicted results do not exceed current or future ground level concentration limits for NO2 either on the boundary of this site or beyond at any of the receptors defined. The highest concentrations occur to the northwest of this plant with a maximum ground level concentration of 89.5 ug/m3 predicted for NO2. This was well within the limit to be attained by January 2010 of 200 ug/m3 as NO2. Ground level concentrations were determined to decrease beyond this point. The nearest dwelling to the west of this plant had a maximum 1 hour GLC of 57.4 ug/m3. All other residential dwellings in the vicinity were also predicted within legislative requirements; ranging between 19 and 28% of the limits proposed for 2010. The limit for NO2 based on an Annual Average in SI 271 of 2002 was 40 ug/m3. This was not exceeded at or outside the boundary of the installation. Boundary concentrations ranged between 0.5 and 2% of the limit, whilst the nearest dwellings were predicted between 1 and 5.5%. The highest predictions were determined to occur within 300 m of the northern boundary at a concentration of 5.44 ug/m3. As the boundary and residential dwellings of interest are relatively close to the installation (<800 m), the 50% Ground Level NOx – NO2 assumption would be considered an overestimation of actual conditions. Predictions are worst case scenarios at the installation.


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Picture 1 – Annual Average Dispersion for NO2

0 ug/m3

1 ug/m3

2 ug/m3

3 ug/m3

4 ug/m3

5 ug/m3

Picture 2 – Hourly Dispersion for NO2

5 ug/m3

15 ug/m3

25 ug/m3

35 ug/m3

45 ug/m3

55 ug/m3

65 ug/m3

75 ug/m3

85 ug/m3


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SO2 Concentrations from Combustion at Lakeland Dairies. Table 8 – SO2 GLC for 1 hour Concentrations Location Co-ordinates Maximum Predicted 1 hour


X Y GLC as SO2 350 ug/m3 as SO2

Boundary

West 230674 307497 97.3 Compliant North 230807 307568 99.9 Compliant East 230843 307446 98.7 Compliant South 230706 307242 96.8 Compliant Nearest Sensitive Receptors

House 1 230558 307572 126.3 Compliant House 2 230909 307545 105.0 Compliant House 3 230847 307392 86.4 Compliant House 4 230741 307294 101.4 Compliant Maximum Predicted GLC 230620 307667 196.9 Compliant Table 9 – SO2 GLC for Daily Concentrations Location Co-ordinates Maximum Predicted Daily


X Y GLC 125 ug/m3

Boundary

West 230674 307497 13.8 Compliant North 230807 307568 12.9 Compliant East 230843 307446 14.2 Compliant South 230706 307242 23.7 Compliant Nearest Sensitive Receptors House 1 230558 307572 55.4 Compliant House 2 230909 307545 24.2 Compliant House 3 230847 307392 12.4 Compliant House 4 230741 307294 23.0 Compliant Maximum Predicted GLC 230906 307667 74.0 Compliant


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Picture 3 –Maximum Daily Dispersion for SO2

5 ug/m3

10 ug/m3

15 ug/m3

20 ug/m3

25 ug/m3

30 ug/m3

35 ug/m3

40 ug/m3

45 ug/m3

50 ug/m3

55 ug/m3

60 ug/m3

65 ug/m3

70 ug/m3

Picture 4 – Hourly Dispersion for SO2

10 ug/m320 ug/m330 ug/m340 ug/m350 ug/m360 ug/m370 ug/m380 ug/m390 ug/m3100 ug/m3110 ug/m3120 ug/m3130 ug/m3140 ug/m3150 ug/m3160 ug/m3170 ug/m3180 ug/m3190 ug/m3


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Modelling was carried out with maximum predicted emissions from the main combustion plant operating on site utilising HFO as fuel. The predicted results do not exceed current or future ground level concentration limits for SO2 either on the boundary of this site or beyond at any of the sensitive receptors defined. The highest concentrations occur to the northwest boundary of this plant with a maximum hourly concentration of 323.4 ug/m3 predicted for SO2. This was well within the limit to be attained of 196.9 ug/m3. Ground level concentrations were determined to decrease beyond this point. The nearest dwelling to the northwest of this plant had a maximum GLC of 126.3 ug/m3. All other residential dwellings in the vicinity were predicted within legislative requirements; ranging between 24 and 36% of the limits proposed. The limit for SO2 based on a Daily Average in SI 271 of 2002 was 125 ug/m3. This was not exceeded at or outside the boundary of the installation. Boundary concentrations ranged between 10 and 18% of the limit, whilst the nearest dwellings were predicted between 9 and 44%. The highest predictions were determined to occur within 200 m of the northern boundary.


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EPA Export 25-07-2013:21:32:07


Scene B: Dust Concentrations from Process Emissions at Lakeland Dairies. Table 10 – Maximum Predicted 24 hour 90.4% GLC

Co-ordinates Maximum Predicted daily 90.4 Percentile Ground Level Concentration (ug/m3)

Location

X Y GLC2 Limit (1) Boundary

West 230674 307497 3.24 50 North 230807 307568 3.62 50 East 230843 307446 3.91 50 South 230706 307242 4.66 50 Nearest Sensitive Receptors House 1 230558 307572 2.38 50 House 2 230909 307545 6.53 50 House 3 230847 307392 8.02 50 House 4 230741 307294 5.49 50 1st Highest Value Max Predicted GLC

230843 307394 22.63 50

(1) S.I. 271 of 2002 (2) Predicted results are ground level concentrations as total dust. PM10 fraction has not been accounted for in

these results, as the exact breakdown was not available.

Table 11 - Maximum Predicted Annual GLC

Co-ordinates Maximum Predicted Annual Average Ground Level Concentration (ug/m3)

Location

X Y GLC2 Limit1 Boundary

West 230674 307497 0.24 40 North 230807 307568 0.46 40 East 230843 307446 4.53 40 South 230706 307242 0.16 40 Nearest Sensitive Receptors House 1 230558 307572 0.16 40 House 2 230909 307545 1.23 40 House 3 230847 307392 5.70 40 House 4 230741 307294 0.19 40 1st Highest Value Max Predicted GLC

230809 307394 8.43 50

1. S.I. 271 of 2002 2. Predicted results are ground level concentrations as total dust. PM10 fraction has not been accounted for in

these results, as the exact breakdown was not available.


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Emissions monitoring results were only available for total particulate matter at Lakeland Diaries. These concentrations were run in the dispersion model to predict ground level concentrations; however legislation has been produced to incorporate ambient PM10 concentrations. It has been predicted that ground level concentrations of total dust from the installation would not cause a breach of legislative limits, assuming the total particulate emissions were all PM10. The following illustrations depict the predictions made for maximum ground level concentrations during worst case scenarios in the vicinity of Lakeland Dairies. Picture 5 - 90.4 Percentile Daily GLC for Particulates

1 ug/m3

2 ug/m3

3 ug/m3

4 ug/m3

5 ug/m3

6 ug/m3

7 ug/m3

8 ug/m3

9 ug/m3

10 ug/m3

11 ug/m3

12 ug/m3

13 ug/m3

14 ug/m3

15 ug/m3

16 ug/m3


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Picture 6 – Annual Average GLC for Particulates

0.5 ug/m3

1.0 ug/m3

1.5 ug/m3

2.0 ug/m3

2.5 ug/m3

3.0 ug/m3

3.5 ug/m3

4.0 ug/m3

4.5 ug/m3

5.0 ug/m3

5.5 ug/m3

6.0 ug/m3

6.5 ug/m3

7.0 ug/m3


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4.0 Conclusions Maximum predicted hourly, daily and annual concentrations for worst case scenarios at and beyond the boundary of this installation comply with legislative requirements of SI 271 of 2002. The model is predicting maximum worst case pollutant concentrations at each receptor location using maximum recorded emissions data over the whole averaging period. Scene A: Current Combustion Practices There are currently 2 boilers used on site at Lakeland Dairies, combusting either HFO or Tallow. Worst case scenario from this process is that both boilers may operate on full flame for a period of time. For this purpose, combined boiler emissions were modelled against proposed licensed limits. The model has predicted that ground level concentrations for 1 hour, daily and annual averages would be within legislative requirements. Boundary points and residential dwellings in the vicinity of the installation were not significantly affected by worst case combustion processes and weather conditions at this site. Scene B: Current Process Emissions Process emissions were determined to comply with requirements of BAT for particulates at this installation. The receptor points studied in this model predicted ground level concentrations within legislative requirements for the hourly 90.4 percentile and annual averages. It was assumed in the model that the PM10 content of total emissions was 100%. SI 271 of 2002 states that by January 2010 a new limit of 20 ug/m3 will be implemented for annual averages.


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References

(1) Environmental Protection Agency (2007) www.epa.ie (2) Environmental Protection Agency (2007) Air Quality Monitoring Report 2005 (3) USEPA (2005) Guidelines on Air Quality Models (4) SI 271 of 2002

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http://www.epa.ie/


House 1

House 2

House 3

House 4

Western Boundary

Northern Boundary

Southern Boundary

Eastern Boundary

Lakeland Dairies Killeshandra

Air Dispersion Model 2007 – Map L1 Receptor Locations


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EPA Export 25-07-2013:21:32:08

Article 11 Reply - Attachment 12 - Nutrient Management Plan Summary

No. Name Usable Area (ha) Organic N (kg) Total N (kg) Errors Max Chem P (kg) Max Volume of Agreed Volume of

Actual Spreadable Area Requirement From Prod Slurry and Dairy Sludge Requirement Imported Imported

Sludge (m3) Sludge (m3)

1 Robert Allison 27.69 5257 4682 TRUE 225 44 60

2 Derek Rorke 38.62 6738 5779 TRUE 586 144 150

3 Padhraig Nannery 38.66 6525 6502 TRUE 783 230 200

4 Lorna Good Hamilton 15.371 3300 2922 TRUE 602 115 100

5 Roy Bell 54.82 9157 8768 TRUE 539 132 140

6 Stuart Garland 64.706 10258 8352 TRUE 462 104 120

7 Neil Armstrong 45.66 7764 6281 TRUE 697 186 185

8 Kevin McPhillips 25.465 3562 3166 TRUE 441 117 100

9 Basil Kells 79.39 11849 11823 TRUE 715 191 200

10 Paul Farrelly 53.581 8518 8278 TRUE 733 180 190

11 Stanley Graham 49.35 8709 8692 TRUE 541 118 100

12 John Lynch 53.24 8881.6 6996 TRUE 626.75 167 160

13 Michael Smith 54.791 9163 6120 TRUE 509 136 130

14 Jim Heaslip 34.89 5290 5084 TRUE 350 93 80

15 Natasha Cleary 33.82 5740 5172 TRUE 714 190 190

16 Padraig Cosgrove 16.389 6288 2396 TRUE 254 68 60

17 John Hands 35.182 7122 6041 TRUE 388 72 100

18 Seamus Dolan 38.44 4958.3 4973 FALSE 977.1 261 210

19 Thomas McCahill 19.866 3721 2958 TRUE 432 101 110

20 Liam Leddy 24.333 4040 2877 TRUE 231 69 40

21 Noel Neill 36.223 5578 6213 FALSE 641 170 40

22 Thomas Patterson 28.865 4362.1 3746 TRUE 632 158 100

23 John Flynn 21.945 3704 2156 TRUE 159 42 40

24 Patrick Burns 20.991 3775 3355 TRUE 441 107 50

25 Declan Dinneny 23.201 3302 2510 TRUE 229 61 50

26 Kenneth Kells 31.546 5130 4568 TRUE 203 55 50

Total 967.035 3311 2955

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Article 11 Reply - Attachment 13 – Map 5 - Map of Spray Irrigation Lands

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