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II 1 ""iron mental f . .' P&c tionf
? Agency ' DEC 2014 Timoleague West Cork Ireland
Tel 023 88461 28 Fax 0238846066
M s Ann Kehoe
Administration Officer, Email info@stauntonfoods le
Office of Climate, Licensing & Resource Use,
Environmental Protection Agency,
P.O. Box 3000,
Johnstown Castle, Co. Wexford
11 December 2014
Re: PO947-01
Dear Ann
I write in response to the Agency's request for information relating to our application
for an Integrated Pollution Prevention and Control Licence as prescribed in Regulation
9 of the EPA (Industrial Emissions)(Licensing) Regulations, 2013.
Please the requested information in the attached files, of which I include one signed
original and 1 copy in hardcopy format and two copies of files in electronic searchable
PDF format on CD- ROM
Yours Sincerely
W Don O'Leary
Environment Manager
Registered in Ireland No: 226927: Registered: Spital Cross, Tirnoleague, Bandon, West Cork, Ireland
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Staunton 'Foods Ltd Timoleague, Bandon, Co. Cork
PO947-01
Review of Compliance with Best Available Techniques
December ~2014 ;. . . . ..
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Cleaner Production Promotion Unit, School of Engineering,
. University College Cork www.ucc.ie/cppu
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10 December2014 PO947 BestAvailable Technique Review
Compliance with Best Available Techniques
11) Ref Ref. #’*’ 5.1.1 BAT is to do all of the following:
1. use an environmental management system
1 ,
2. provide training
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3 use a planned maintenance programme
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4. apply dedicated metering of water consumption ’
5.- separate process and non-process waste water . >
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6. remove all running water hoses and repair dripping taps and toilets
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7. fit and use drains with screens and/or traps to prevent solid material from entering the waste water
8. dry clean installations and transport by-products dry , followed by A
pressure cleaning using hoses fitted with hand-operated triggers and where necessary hot water supplied from thermostatically controlled steam and water valves ,..
Page 2 of 16
1. The facility has a written environmental management system in place. Following licensing this system shall be reviewed and revised within six months to reflect the requirements of the licence.
2 . The facility has a substantial training programme in place including environmental procedures. Following licensing a
. ,review of environmental training needs shall be undertaken within six months to reflect the requirements of the licence. I
3. A comprehensive preventative maintenance programme is in place - the content of which has been drawn up in consultation with the relevant suppliers/manufacturers.
4. Water is metered at departmental level ~
5. Rainwater and cooling water are discharged directly to the river; Process water is sent for treafment to the WWTP
6. The use of water hoses is minimised within the plant. ‘ Dripping taps etc. are repaired as part of the plant’s
maintenance programme 7. Grease traps at in place on all drains, drains in the
slaughter hall have screens, Cowls are being installed on all drains (by March 2015)
8. All cleaners are trained to, and procedures require dry cleaning prior to washing; Where possible nozzles are fitted. Water is supplied around the factory in a ring main system. Nozzles are set to spray the minimum amount of water but hygiene / food safety remains main factor in quantity of water being used. Triggered controlled hoses are fitted in factory. 45OC, 65°C & cold water all on all switched off by a master timer switch or manually when not required
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9. apply overfilling protection on bulk storage tanks ‘ L e ... - i -
10. provide and use bunds for bulk storage tanks , 11. implement energy management systems ,
12. implement refrigeration management systems *,
13. operate controls over refrigeration plant running times 14. fit and operate chill room door closing switches
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15. recuperate heat from refrigeration plants . - ,. . . . , .. I I . .
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16. use thermostatically controlled steam and water blinding valves
17. rationalise and insulate steam and water pipework
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18. isolate steam and water services 19. implement light management systems 1
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20. store animal by-products for short periods and possibly to refrigerate them . . . . .. .. . . . : , ’ I .
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2 1. audit odour 8 ,
22. design and construct vehicles, equipment and premises to ensure that they I . are easy to clean I
!3. clean materials storage areas frequently
Page 3 of 16
PO94 7 Best A va ilable Tech 11 i y 11 e Re vie 1.v
9. There is a high level sensor on the diesel tank. For other I bulk storage Staff are trained to avoid risk of overfilling.
10. Bunding (or double skinned tanks) is in place as required 11. As discussed in the following table on energy efficiency,
phased implementation of an energy management system (EnMS) is on-going with a target implementation date of Nov 2015
management system 12. The aforementioned EnMS will include a refrigeration
13. Refrigeration plant runs 24 hours per day 14. Door closing switches are not considered necessary -
currently ‘curtains’ are in place on chill room and when not in use the doors are closed manually
15. Feasibility of heat recovery from refrigeration plant will be -> investigated as part of the environmental management +
programme (EMP) once the plant is licensed - - 16..Thermostatically controlled blending are used in the steam
tunnel .~ 17. This has not been carried out in a systematic fashion to
date, i t is proposed that this be investigated as part of the EMP once the plant is licensed
18. Isoiate values are in place 19. The aforementioned EnMS will include a light management
20. By-products are stored for short periods and refrigerated system
as deemed necessary. The majority of waste collected daily and the rest is collected weekly.
21. There have been no odour issues at the facility to date - an odouraudit will be is not considered necessary
22. Designing for ease of cleaning is inherent in the practice of the plant owning to the nature of the plant as a food production facility and requirements of the onsite DAFM Veterinary Inspectors
a t the facility using food grade chemicals. 23. A comprehensive cleaning programme is performed daily
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10 December2014 PO947 Best Available Technique Review
5.1.1.1
24. implement a noise management system 24. Noise audits have been conducted - and a noise reduction I
25. See previous point
plan is being implemented G T
26. Liquid Petroleum gas (LPC) is used onsite
27. In so far as practical animal by-products are enclosed during transport, loading/unloading and storage
28. Blood is stored in a refrigerated 'blood unit' directly on collection
29. This is not feasible due to the location of the facility
The facility has a written environmental management system in place. This is actively being develop to meet the needs of Origin Green initiative of 'which Staunton Foods are members and to anticipate the requirements of the industrial emissions
25. reduce noise at, e.g. roof extract fans, balance lagoon blowers and refrigeration plants
26. replace the use of fuel oil with natural gas, where a natural gas supply is available
27. enclose animal by-products during transport, loadinglunloading and storage ~
28. where it is not possible to treat blood before its decomposition starts to cause odour problems and/or quality problems, refrigerate it as quickly as possible and for as short a time as possible, to minimise decomposition
29. export any heat and/or power produced which cannot be used on-site BAT is to implement and adhere to an Environmental Management System (EMS) that incorporates, as appropriate to individual circumstances, the following features:
definition of an environmental policy for the installation by top management (commitment of the top management is regarded as a precondition for a successful application of other features of the EMS) planning and establishing the necessary, procedures implementation of the procedures, paying particular attention to: structure and responsibility; training, awareness and competence; communication; employee involvement; documentation; efficient process control; maintenance programme; emergency preparedness and response; safeguarding compliance with environmental legislation. checking performance and taking corrective action, paying particular attention to: monitoring and measurement; corrective and preventive action; maintenance of records; independent (where practicable) internal auditing in order to determine whether or not the environmental management system conforms to planned arrangements and has been
licence. Following licensing this system shall be reviewed and revised within six months to fully reflect the requirements of the licence.
5.1.2 . Slaughterhouses and/or animal by-products installations, operating on the Not applicable
5.1.3 same site . I t I
BAT is to seek collaboration with upstream and downstream partners, to create a chain of environmental responsibility, to minimise pollution and to
Collaboration with suppliers (farmers, ingredient producers, chemical suppliers, etc.) and customers (supermarkets,
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5.1.4
5.1.5
protect the environment as a whole
For the cleaning of slaughterhouses and animal by-products installations, BAT
1. manage and minimise the quantities of water and detergents consumed
I . is to do the following: . .
2. select those detergents which cause minimum impact on the environment without compromising the efficacy of cleaning
3. avoid, where possible, the use of cleaning and disinfectant agents containing active chlorine
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4. where the equipment‘is suitable, operate a cleaning-in-place system . For the treatment of waste water from slaughterhouses and animal by- , products,installations, BAT is to do the following: 1. prevent waste water stagnation
2. apply an initial screening of solids using sieves at the slaughterhouse or animal by-products installation
3. remove fat from waste water, using a fat trap
4. use a flotation plant, possibly combined with the use of flocculants, to remove additional solids
5. use a waste water equalisation tank 6 . provide a waste water holding capacity in excess of routine requirements 7. prevent liquid seepage and odour emissions from waste water treatment
tanks, by sealing their sides and bases and either covering them or aerating them ,
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PO947 Best Available Techiiiyue K t l ’ / /ew ’
wholesalers, etc.) is an integral part of Staunton Foods Business m,odel - as part ofthis we strive to minimise environmental impacts e.g., in the selection of cleaning detergents .
1. All hoses are fitted with trigger operated jets, detergent , concentrations are as per manufacture advice. The
company is working with chemical suppliers to reduce the usage of chemical without effecting the hygiene.
2. The company works with its chemical supp!ier to select * effective detergents that have minimum impact on the environment
3. We minimise the use of chlorinated products wherever possible, for food safety purposes, production water is. chlorinated - there are currently only two chemicals used that contains chlorine, for which we are activaley seeking alternatives
4. The steam tunnel tray washer and pan wash have CIP systems. All other cleaning is carried out manually.
1. I All drainage pipework has sufficient . I gradient to avoid’ stagnation
2. There is an preliminary screen at the WWTP
3. There are two sumps on the drains to the WTTP with fat traps
4. A dissolved air flotation (DAF) piant is used in the WWTP to remove fats ,
5 . There is a balancing tank of 390 m3 on site 6. See previous point 7. The base and sides of tanks are’sealed, the activated sludge
basins are aerated
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(l’) Refe Ref:#
5.2
8. subject the effluent to a biological treatment process.
9. remove nitrogen and phosphorus.. 10. remove the sludges produced and subject them to further animal by-
11. use CH4 gas produced during anaerobic treatment for the production of
12. subject the resulting effluent to tertiary treatment and 13. regularly conduct laboratory analyses of the effluent composition and
In addition to the general measures in Section 5.1, for all slaughterhouses BAT is to do all of the following: 1. dry scrape delivery vehicles and prior to cleaning with a high- pressure
hose 2. avoid carcase washing and where this is not possible to minimise it,
combined with clean slaughter techniques 3. continuously collect by-products dry and segregated from each other,
along the length of the slaughter-line, combined with optimising bleeding and the collection of blood and segregating the storage and handling of different kinds of by-products ’
4. operate a double drain from the bleed hall 5. collect floor waste dry
product uses. x .
heat and/or power
maintain records
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. . 6. remove all unnecessary taps from the-slaughter-line 7. insulate and cover knife sterilisers, combined with sterilising knives using
low-pressure steam 8. operate hand and apron cleaning cubicles, with a “water off” default
9. manage and monitor compressed air use
10. manage and monitor ventilation use 11. use backward bowed centrifugal fans in ventilation and refrigeration
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PO947 Best Available Technique Review
8. The plant operates a comprehensive WWTP comprising: Screens; balance tank; dissolved air floatation (DAF) system; 2x activated sludge aeration basins; Anoxic tank; UV system, clarified, sludge press
9. An anoxic tank is used prior to aeration for N removal 10. WWTP sludge is land spread in accordance with a nutrient
management plant 11. Not applicable
12. See previous point on anoxic tank 13. A comprehensive monitoring analysis regime is in place ’ for both the WWTP operation and the quality of its effluent
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1. Dry scraping of delivery vehicle floor material is carried ” out prior to washing 2. Staff are highly skilled and trained in clean slaughter
techniques 3. There is continuous dry segregation collection of the by ’
. products along the length of the slaughter hall
4. There is a double drain at the blood channel. 5. Waste is collected from all floors using dry methods prioi-
to washing . 6. There are no unnecessah taps in ;he slaughter hall ’
7. Two knife technique used with insulated container with slots for knives
B. ‘Dead man controls’ are in place for hand and apron cleaning
3. Variable speed drives are installed on compressed’air motors which control demands
10. Ventilation is part of maintenance programme 11. Backward bowed centrifugal fans are not in use in
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5.2.1
systems 12. manage and monitor the use of hot water
13. trim all hide/skin material not destined for tanning immediately after removal from the animal, except if there is no outlet for the use/valorisation of the trimmings.
In addition to the general measures in Sections 5.1 and 5.2, for all large animal slaughterhouses, BAT is to do all of the following; . 1. stop feeding animals 12 hours prior to slaughter, combined with
minimising the animals' time in the slaughterhouse to reduce manure production . ,
2. apply demand-controlled drinking water 3. shower pigs using water saving timer controlled nozzles 4. dry clean the lairage floor and to periodically clean it with water 5. use a squeegee for the initial cleaning of the blood collection trough
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6. steam scald pigs (vertical scalding) I I
7. in those existing slaughterhouses, where it is not yet economically viable to change to steam scalding, insulate and cover pig scalding tanks and control
, the water level in those tanks 8. re-use cold water within pig de-hairing machines and replace irrigation
pipes with flat jet nozzles 9. re-use, cooling water from pig singeing kilns 10. recover heat from pig singeing exhaust gases, for preheating water
11. shower pigs after singeing, using flat jet nozzles
12. replace irrigation pipes with flat jet nozzles for rind treatment in pig
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PO947 Best Available Technique Keyiew
ventilation and refrigeration systems
master switch 12. The use of hot water is monitored and managed using a
13. Skin material is trimed as requied
1. I t is a requirement for the animals to come onsite with empty stomachs; pig delivery times are staggered throughout the day to ensure no pigs are too long waiting in the yard or lairage.
2. Demand-controlled drinking water is used in lairage 3. Pigs are showered for ca. 20 minutes with manual controls. 4. Dry cleaning is conducted in lairage with periodic washing 5. The blood is mixed with an anti-coagulant in the blood
bath so there is no congealed blood left in it. I t is cleaned with a hot water power hose. In the event of congealed blood, the blood is shovelled out into .askip'as the congealed blood would block the pipework
6. Pigs are steam scalded, the temperature and timer are monitored by a trained Operative
7. Not applicable \
8. Water is re used within the pig de-hairing units. Some of the sprays have nozzles (final carcass washer). All the' other carcass washers have opened sprays.
9. The cooling water from pig singeing is reused. , 10. Heat recovery from pig singeing exhaust gasses is used to
preheat water 11. Flat n,ozzles are fitted in the carcass washer with a
12. Nozzles replaced as required
,
. diameter below two millimetres and pressurised water
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13. sterilise chest-opening saws in a cabinet with automated hot water nozzles 14. regulate and minimise the water used for moving intestines 15. use either water-spray/mist-cooling or blast-chilling/shock-cooling tunnel
16. not shower pigs before they are chilled in,a chilling tunnel
17. empty stomachs dry 18. collect the contents of small intestines dry, whether or not they are
19. regulate and minimise the water consumption during small and large
20. regulate and minimise the water consumption during rinsing of tongues
21. use a mechanised fat trap for removing fat from water 22. process fresh hides and skins as far as they are available.
to cool pigs
intended to be used for casings
intestine washing
and hearts
23. when it is impossible to process hides and skins before 8,- 12 hours, with the actual range depending on local conditions, to immediately store hides betweenlOand15oC
hours and 5 - 8 days, with the actual ranges depending on local conditions, to immediately refrigerate hides a t 2 OC
25. always immediately drum-salt all hides and skins, if they have to be stored for longer than 8 days, e.g. if they have to be transported overseas, combined with the drv collection of salt residues
24. when it is impossible to process hides before a period of between 8 - 12
P0947BestAvailable Technique Review
13. The saw is sterilised using automated hot watey nozzles 14. Water is set to minimum manually 15. Water spray used to cool pigs
16. There is no washing before veterinary inspection - carcasses are therefore washed before chilling
17. Contents are removed before washing stomach 18. Finishing machine used to remove mucosa coat and any
loose mucosa that remains in the intestine 19. The volume of water is controlled by levers operated and
monitored by trained Operative 20. Water consumption is controlled by trained Operative
during the 'Pluck' wash (Pluck heart, liver & lungs) 2 1. Fats traps are in places on the drains to WWTP 22. Skins are send off site for processing on a regular basis (as
23. Not applicable, see previous point category 3 waste it is collected daily)
24. Not applicable, see previous point
25. Not applicable, see previous point ' .
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10 December 2014 PO947 Best Available Technique Review . . . . I ,
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incorporates, as appropriate to the local circumstances, all of the following features (see Section 2.1. Theletters (a), (b), etc. below, correspond those'in Section 2.1):
a) commitment of top management (commitment of the top management is regarded as a precondition for the successful application of energy efficiency management)
b) definition of an energy efficiency policy for the installation by top management c) , planning and establishing objectives and targets (see BAT 2 , 3 and 8) d) implementation and operation of procedures paying particular attention to: i)
structure and responsibility ii) training, awareness and competence (see BAT 13) iii) communication iv) employee involvement v) documentation vi) effective control of processes (see BAT 14) vii) maintenance (see BAT 15) viii) emergency preparedness and response ix) safeguarding compliance with energy efficiency-related legislation and agreements (where such agreements exist).
-T e) benchmarking: the identification and assessment of energy efficiency indicators over time (see BAT 8), and the systematic and regular comparisons with sector, national or regional benchmarks for energy efficiency, where verified data are available (see Sections 2.l(e), 2.16 and BAT 9)
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Green initiative an energy management system (EnMS) is being put in place a t Staunton Foods on a phased basis. Current
Performance targets have been
An Energy Policy has been adopted by top management place;
established using 2013 as a reference year and An eSIP energy monitoring system has been installed and operational on site
The phased implementation of the EnMS (which will meet the requirement of 4.2.2.1) is planned to be in completed by Nov 2015
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f) checking performance and taking corrective action paying particular attention to: i) . monitoring and measurement (see BAT 16) ii) corrective and preventive action iii) . I , , x
, maintenance of records iv) independent (where practicable) internal auditing in , , order to determine whether or not the energy efficiency management system conforms to planned arrangements and has been properly implemented and maintained (see BAT 4 and 5)
g) review of the ENEMS and its continuing suitability, adequacy and effectiveness by top I
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management . _ BAT is to continuously minimise the environmental impact of an installation by planning actions and,investments on an integrated basis and for the short, medium and long term, considering the cost-benefits and cross-media effects.
Staunton Foods is committed to tracking energy performance based on 2013 figures As discussed above, phased implementation
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4.2.2.2
4.2.2.2
4.2.2.2
4.2.2.2
BAT is to identify the aspects of an installation that influence energy efficiency by carrying out an audit. I t is important that an audit is coherent with a systems approach.
When carrying out an audit, BAT is to ensure that the audit identifies the following aspects (see Section 2.11): a. energy use and type in the installation and its component systems and processes b. energy-using equipment, and the type and quantity of energy used in the installation c. possibilities to minimise energy use, such as: controlling/reducing operating 'times, e .g. switching off when not in use (e.g. see Sections 3.6, 3.7,3.8, 3.9,3.11) ensuring insulation is optimised, e.g: see Sections 3.1.7,3.2.11 and 3.11.3.7 optimising utilities, associated systems, processes and equipment (see Chapter 3) d. possibilities to use alternative sources or use of ene,rgy that is more efficient, in particular energy surplus from other processes and/or systems, see Section 3.3 e. possibilities to apply energy surplus to other processes and/or systems, see Section 3.3 f. possibilities to upgrade heat quality (see Section 3.3.2).
. ?
BAT is to use appropriate tools or methodologies to assist with identifying and quantifying energy optimisation, such as:. , energy models, databases and balances (see Section 2.15) a technique such as pinch methodology ( see Section 2.12) exergy or enthalpy analysis (see Section 2.13), or thermoeconomics (see Section 2.14) estimates and calculations (see Sections 1.5 and 2.10.21. BAT is to identify opportunities to optimise energy recovery within the installation, between systems within the installation (see BAT 7) and/or with a third party (or parties), such as
Page 10 of 16
of 4.2.2.1) is-on-going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on- going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on- going and it is planned to be in place by Nov 2015
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Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on- going and it is planned to be in place by Nov 2015 ' .
Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on-
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4.2.2.3
4.2.2.4
4.2.2.5
4.2.3
those described in Sections 3.2,3.3 and 3.4. _. .<
BAT is to optimise energy efficjency by taking a systems approach to energy management in the installation. Systems to be considered for optimising'as a whole are, for example:
process units (see se,ctor BREFS) heating systems such as: steam (see Section 3.2); hot water, cooling and vacuum (see the ICs BREF) motor driven systems such as: compressed air (see Section 3.7); pumping (see Section 3.8) lighting (see Section 3.10) drying, separation and concentration (see Section 3.11). .
BAT is to establish energy efficiency indicators by carrying out all of the following: a) identifying suitable energy efficiency indicators for the installation, and where necessary,
individual processes, systems and/or units, and measure their change over time or after the implementation of energy efficiency measures (see Sections 1.3 and 1.3.4)
b) identifying and recording.appropriate boundaries associated with the indicators (see Sections 1.3.5 and 1.5.1)
c) identifying and recording factors that can cause variation in the energy efficiency of the relevant process, systems and/or units (see Sections 1.3.6 and 1.5.2). I
BAT is to carry out systematic and regular comparisons with sector, national or regional benchmarks, where validated data are available. L -
BAT is to optimise energy efficiency when planning a new installation, unit or system or a significant upgrade (see Section 2.3) by considering all of the following: the energy efficient design (EED) should be initiated a t the early stages of the conceptual design/basic design phase, even though the planned investments may not be well-defined. The EED should also be taken into account in the tendering process the development and/or selection of energy efficient technologies (see Sections 2.1 (k) and
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PO947 Best Available Technique Review
going and it is planned to be in place by Nov 2015 '
Phased implementation of an EnMS (which will meet the requirement of 4.2.2.3) is on- going and it is planned to be in place by Nov 2015
Phased implementation of an EnMS (which will meet the re-quirement of 4.2.2.4) is on- going and it is planned to be in place by Nov 2015
' < '
Phased, implementation of an EnMS (which will meet the requirement of 4.2.2.5) is on- going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.3) is on- going and it is planned to be in place by Nov 2015
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4.2.4
4.2.5
4.2.6
2.3.1) additional data collection may need to be carried out as part of the design project or- separately to supplement existing data or fill gaps in knowledge the EED work should be carried out by an energy expert the initial mapping'of energy consumption should also address which parties in t h e project organisations influence t he future energy consumption, and should optimise the enefgy efficiency design of the future plant with them. Forexample, t h e staff in the (existing) installation who may be responsible for specifying design parameters.
.
BAT is to seek to optimise the use of energy between more than one process or system (see Section 2.4), within the installation or with a third party.
BAT is to maintain the impetus of the energy efficiency programme by using a variety of- techniques, such as: '
a) implementing a specific energy eff ic ienj management system (see Section 2.1 and BAT 1)
b) accounting for energy us age based o n real ( metered) values, which places both the obligation and credit for energy efficiency on the user/bill payer (see Sections 2.5, 2.10.3 and 2.152)
c) the creation of financial profit centres for energy efficiency (see Section 2.5) d) benchmarking (see Section 2.16 and BAT 9) ,
e) a fresh look a t existing management systems, such as using operational excellence (see Section 2,s)
f ) using change management techniques ( also a feature of operational excellence, see Section 2.51.
I ,
BAT is to maintain expertise in energy efficiency and energy-using systems by using techniques such as:
a) recruitment of skilled staff and/or training of staff. Training can be delivered by in- house staff, by external experts, by formal courses or by self-study/development (see
- I
PO947 BestAvailable Technique Review
Phased implementation of an EnMS (which will meet the requirement of 4.2.4) is on- going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.5) is on- going and it is planned to be in place by Nov 2015
I . .
I _ . . . . ! . . . . . . ... ... ...
. . . . . . . . , ' . ,. ? : -I . . . . . . . . . . . . .
Phased implementation of an EnMS (which will meet the requirement of 4.2.6) is on- going and it is planned to be in place by Nov 2015
Page 12 of 16
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10 December 2014
4.2.7
4.2.8
4.2.9
Section 2.6) b) taking staff off-line periodically to perform fixed term/specific investigations ( in their
original installation or in others, see Section 2.5) c) sharing in-hou,se resources between sites (see Section 2.5) d) use of appropriately skilled consultants for fixed term investigations ( e.g. see Section
e) outsourcing specialist systems and/or functions (e.g. see Annex 7.12) 2.11)
BAT is to ensure that the effective control of processes is implemented by techniques such as: I a). having systems in place to ensure that procedures are known, understood and
b) ensuring that t he key performance parameters are identified, optimised for energy efficiency and monitored (see Sections 2.8 and 2.10)
c) 'documenting or recording these parameters (see Sections 2.l(d)(vi), 2.5,2.10 and .2.15).
complied with (see Sections 2.l(d)(vi) and 2.5) : , *
BAT is to carrysout maintenance a t installations to optimise energy efficiency by applying all of the following:
a) clearly allocating responsibility for the planning and execution of maintenance b) establishing a'structured programme fo; maintenance based on technical descriptions
of the equipment, norms, etc. a s well a s any equipment failures and consequences. Some maintenance activities may be best scheduled for plant shutdown periods
c) supporting the maintenance programme by appropriate record keeping systems and diagnostic testing
d) identifying from routine maintenance, breakdowns and/or abnormalities possible ' losses in energy efficiency, or where energy efficiency could be improved
e) identifying leaks, broken equipment, worn bearings, etc. that affect o r control energy usage, and rectifying them a t the earliest opportunity.
.
BAT is to establish and maintain documented procedures to monitor and'measure, on a regular basis, the key characteristics of operations and activities that can have a significant
Page 13 of 16
PO947 Best Available Technique Review
Phased implementation of an EnMS (which will meet the requirement of 4.2.7) is on- *going and it is planned to be in place by*Nov 2015
Phased implementation of an EnMS (which will meet the requirement of 4.2.8) is on- going and it is planned to be in place by Nov 2015 - 1 , p
I >
r * I
r' ~.
Phased implementation of an EnMS (which will meet the requirement of 4.2.9) is on-
. .
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10 December 201 4
T m p a c t on energy efficiency. Some suitable techniques are given in Section 2.10.
4.3.1 BAT is to optimise the energy efficiency of combustion by relevant techniques such as: those specific to'sectors given in vertical BREFs those given in Table 4.1. (See EAP Document for more information)
4.3.2 BAT for steam systems - . is to optimise the energy efficiency by using techniques such as: -
those specific to sectors given in vertical BREFs those given in Table 4.2 d .
- 4.3.3 BAT is to maintain the efficiency of heat exchangers by both: monitoring the efficiency
periodically, and preventing or removing fouling See Section 3.3.1.1.
4.3.4 BAT is to seek possibilities for cogeneration inside and/or outside the installation (with a third party)
, -
4.3.5 BAT is to increase the power factor according to the requirements of the local electricity distributor by using techniques such as those in Table 4.3, according to applicability (see Section 3.5.1). BAT is to check the power supply for harmonics and apply filters if required (see Section 3.5.2). '
.
4.3.5
PO947 Best Available Technique Review
going and it is planned to be in place by Nov 2015 An eSIP energy monitoring system has been installed and operational on site Phased implementation of an EnMS (which will meet the requirement of 4.3.1) is on- going and it is planned to be in place by Nov 2015 . / I
I
Phased implementation ofan EnMS (which will meet the requirement of 4.3.2) is on- going and it is planned to be in place by Nov 2015
Phased implementation of an EnMS (which will meet the requirement of 4.3.3) is on- going and it is planned to be,in place by Nov 2015 Heat recovery of steam boiler - excess steam used to heat sterilisers in slaughter hall Phased implementation of an EnMS (which will meet the requirement of 4.3.4) is on- going and it is planned to be in place by Nov 2015 Pased implementation of an EnMS (which will meet the requirement of 4.3.5) is on-going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.3.5) is on-
Page 14 of I6
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10 December 201 4 PO947 Best Available Technique Review
4.3.5
p.3.6
4.3.7
4.3.8
BAT is to optimise the power supply efficiency by using techniques such as those in Table 4.4, according to applicability:
. . . . . , . . . . . . . . . . .
BAT is to optimise electric motors in the following order (see Section 3.6): optimise the entire system the motor(s) is part of (e.g. cooling system, see Section 1.5.1) then optimise the motor(s) in the system according t o t h e newly-determined load requirements, by applying one or m ore o f t he techniques in Table 4.5, according t o applicability (See EPA Document for more information) when the energy-using systems have been optimised, then optimise the remaining (non- optimised) motors according to Table.4.5 and criteria such as: prioritising the remaining motors running more than 2000 hrs per year for replacement with EEMs electric motors driving a variable load operating a t less than 50 % of capacity more than 20 % of their operating time, and operating for more than 2000 hours a year should be considered for equipping with variable speed drives.
.
BAT is to optimise compressed air systems (CAS) using the techniques such as those in Table 4.6, according to applicability: (See Table 4.6 in the Appendices)
1 ,
BAT is to optimise pumping systems by using the techniques in Table 4.7, according to applicability (see Section 3.8): Note that throttle control is less energy wasteful than bypass control or no control. However, all are wasteful of energy and should be considered for replacement according to size of the pump and how frequently it is used.
Page 15 of 16
going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.3.5) is on- going and it is planned to be in place by Nov 2015. Phased implementation of an EnMS (which will meet the requirement of 4.3.6) is on- going and it is planned to be in place by Nov 2015
,
c - 3
Phased implementation of an EnMS (which will meet the requirement of 4.3.7)'is on- going and it is planned to be in place by Nov 2015 Variable speed drives are installed on compressed air motors which control demand
Phased.implementation of an EnMS (which will meet the requirement of 4.3.8) is on- going and it is planned to be in place by Nov 2015
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10 December 201 4
4.3.10
4.3.11
Chapter 5
AT is to optimise heating, ventilation and air conditioning systems by using techniques such as
for ventilation, space heating and cooling, techniques in Table 4.8 according t o applicability for heating, see Sections 3.2 and 3.3.1, and BAT 18 and 19
for cooling, chilling and heat exchangers, see the ICs BREF, as well as Section 3.3 and BAT 19 (in this document).
for pumping, see Section 3.8 and BAT 26 . .
See Table 4.8 Heating, Ventilation and Air Conditioning System Techniques to Improve Energy Efficiency in the Appendices. BAT is to optimise artificial lighting systems by using the techniques such as those in Table 4.9 according to applicability (see Section 3.10):
_ .
BAT is to optimise drying, separation and concentration processes by using techniques such as those in Table 4.10 according to applicability, and to seek opportunities to use mechanical separation in conjunction with thermal processes:
PO947 Best Available Technique Review
will meet the requirement of 4.3.9) is on- going and it is planned to be.in place by Nov 2015 i
Phased implementation of an EnMS (which will meet the requirement of 4.3.10) is on- going and it is planned to be in place by Nov 2015 Not applicable
Emerging Techniques for Energy Efficiency 5.1 Flameless combustion (flameless oxidation) Not applicable
Not applicable 5.2 Compressed Air Energy Storage L1 '
' . . I ,. : 7 ) . _ . . .
. . . . . . . . . . . . . .
. . . . . .. ~. . .
\
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. .c -.
Staunton Foods Ltd . Timoleague; Bandon West Cork
Report on the Requiren ent for a Base ine Assess lent
. .
November 2014
DixonBrosnan .
noise & ecology specialists
d ixon brosnan .corn
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I I . .
I .
F
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. .
. .
. . .
. .
. .
. .
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Staunton Foods Ltd. Timoleague, Bandon West Cork
Report on the Requirement for a Baseline Assessment
Contents
1
2
Introduction ...; ............................................ ................................... ...................... 4 I . I Background ................................. ~ .......................................... ............. 4
Requirements for a Baseline Report' .............................. ~ ................................... 5 2. I European Legislation .................. .; ....................................................... 5 .
. 2.2 Irish Legislation ........................... :..; ................................... 1 .................. 9 ' 2.3 . Chemicals handled atStaunton-Foods Ltd ...................................... . .
3 . Discussion ....................................................................................... ......: .......... 24 4 Conclusion ..................................................................................................... ;.25
~.
I I . .
3 .:,
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Staunton Foods Ltd.
IED Site Report
1 Introduction
This report has been prepared following a request by the Agency dated
February 19th, 2014. The report sets out to meet the requirements of Article
22(2) of the Industrial Emissions Directive (201 0/75/EU) by considering the
requirement for a full baseline study.
1 .I Background
Staunton Foods Ltd. was founded in Timoleague in the 1950's by the Staunton
family, commercialising the family's experience with slaughtering pigs for a ,
small number of local customers. The company is now a division of Barryroe
Co-operative Society Ltd., trading as Staunton Foods Ltd.
Staunton Foods Ltd. has applied to the Environmental Protection Agency
(EPA) for an. Industrial Emissions Licence (reference number- PO947-01) in
respect the following classes of activity: .
4
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. . , .
. . . I . .. ~. . - . ,-. . . . . - . .
. : .
i
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Staunton Foods Ltd.
IED Site Report
This report is in response to a request for further information from the. Agency
in respect of this application.
2 Requirements for a Baseline Report 2.1 European Legislation
The Industrial Emissions Directive (2010/75/EU) also referred to as IED
entered into force on the 06/01/2011. The aim of the IED is to integrate the
IPPC Directive and the Waste Incineration Directive and five other directives in
a single Directive on emissions. For industrial activates falling under IED, like
Staunton Foods Ltd facility, Article 22(2) of chapter I t of the IED states:
“Where the activity involves the use, production or release of relevant
hazardous substances and having regard to the possibility of soil and
groundwater contamination at the site of the installation, the operator shall
prepare and submit to the competent authority a baselihe report before starting
operation of an installation or before a permit for an installation is updated for
the first time afler 7 January 2013. The baseline report shall contain the
information necessaty to determine the state of soil and groundwater
contamination so as to make a quantified comparison with the state upon
definitive cessation of activities provided for under paragraph 3. ”
The European Commission provides Guidance concerning baseline reports
under Article 22(2) of Directive 201 0/75/EU on industr/al emissions (2014/C
136103). The scope of the guidance provides information on the legal
5
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Staunton FoodsLtd.
IED Site Report
provisions concerning a baseline report and covers the following elements of
Article 22 of the IED that should be addressed in the baseline report:
i. - Determining whether a baseline report is required to be produced;
ii. Designing baseline investigations; I
iii. Designing a sampling strategy;
iv. Developing the baseline report.
There are eight stages in preparing a full Baseline Report as outlined below in
Table 1 ; this report addresses the first three stages identification of hazardous
substances, determination of which are ‘relevant’ and assessment of site-
specific pollution possibility, following which a determination is made whether a
baseline report is required or not.
Table ‘1 Stages of IED Baseline Report
Activity 0 bjective
1. Identify which hazardous substances Determine whether or not
are currently used, produced or
released at the installation
hazardous substances are
used, produced or released
in view of deciding on the
need to prepare and submit
a baseline report.
2. Identify the relevant hazardous . To restrict further
Identify, quantify and document such
hazardous substances.
substances consideration to only the
Identify which of the hazardous relevant hazardous
substances in view-of substances from Stage 1 are
‘relevant hazardous substances’ (see
Section 4.2). Discard those
deciding on the need to
prepare and submit a
baseline report. hazardous substances that-are
incapable of contaminating soil or
groundwater. Justify and record the ‘
.
- decisions taken to exclude certain
hazardous substances.
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I '
~ :
Staunton Foods Ltd.
IED Site Report
3. Assessment of the site-specific To identify which of the
pollution possibility relevant hazardous
For each relevant hazardous
substance brought forward from
Stage 2, identify the actual possibility
for soil or groundwater contamination
at the site' of the installation, including
the probability of releases and their
substances represent a
potential pollution risk at
the site based on the
likelihood of releases of
such substances occurring.
For these substances,
information must be consequences, and taking particular
account of: included in the baseline
report. the quantities of each hazardous
substance or groups of similar
hazardous substances
concerned;
how and where hazardous . .
substances are stored, used and
to be transported around the
installation;
where they pose a risk to be
released;
In case of existing installations
also the measures that have
been adopted to ensure that it is
impossible in practice that
contamination of soil or
groundwater takes place.
4. Provide a site history. Consider available
data and information:
Identify potential sources
which may have resulted in
In relation to the present use of
the site, and on emissions of
hazardous substances which have
the hazardous substances
identified in Stage 3 being
already present on the site
occurred and which may give rise
to pollution. In particular, consider
accidents or incidents, drips or
spills from routine operations,
of the installation.
7
I I I 1
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Staunton Foods Ltd.
IED Site Report
changes in operational practice,
site surfacing, changes in the
hazardous substances used.
Previous uses of the site that may
have resulted in the release of
hazardous substances, be they
the same as those used, produced
or released by the existing
installation, or different ones.
0 Review of previous investigation
reports may assist in compiling
this data.
I '
5. Identify the site's environmental setting
including: substances may go if
Determine where hazardous .
Topography; released and where to look
Geology;
Direction of groundwater flow; . environmental media and ,
Other potential migration pathways receptors that are potentially
for them. Also identify the . L
such as drains and service
channels; . other activities in the area
at risk and where there are
Environmental aspects (e.g: which release the same I
particular habitats, species,
protected areas etc.); and
hazardous substances and
may cause them to migrate
Surrounding land use. onto the site.
6. Use the results of Stages 3 to 5 to Identify the location, nature
describe the site, in particular
demonstrating the location, type, extent
and quantity of historic pollution and
potential future emissions sources noting
the strata and groundwater likely to be
affected by those emissions - making links
between sources of emissions, the
pathways by which pollution may move and
the receptors likely to be affected
and extent of existing
pollution on the site and to
determine which strata and
groundwater might be
affected by such pollution.
Compare with potential future i
emissions to see if areas are
coincident.
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Staunton Foods Ltd.
IED Site Report
7. If there is sufficient information to
quantify the state of soil and groundwater
pollution by relevant hazardous substances
on the basis of Stages (1) to (6) then go
directly to Stage 8. If insufficient information
exists then intrusive investigation of the site
will be required in order to gather such
information. The details of such
investigation should be clarified with the
competent authority.
Collect additional information
as necessary to allow a
quantified assessment of soil
and groundwater pollution by
relevant hazardous
substances.
8. Produce a baseline report for the Provide a baseline
installation that quantifies the state of
soil and groundwater pollution by
report in line with the
IED.
relevant hazardous substances.
2.2 lrish Legislation
Article 22(2), as part of Chapter II of the IED, was transposed into lrish national
law on April 23rd, 2013 by the European Union (Industrial Emissions)
Regulations 2013 (S.I. No. 138 of 2013) and resulting amendments to the
Environmental Protection Agency Act 1992. Section 86B of the Environmental
Protection Agency Act 1992, as amended, states that 4
(1) Where an industrial emissions directive activity involves the use, production
or release of relevant hazardous substances, and having regard to the
possibility of soil and groundwater contamination at the site of an installation
,concerned, the Agency shall require an applicant under this Part for a licence
or review of a licence or revised licence relating to the activity, including such a
9
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Staunton Foods Ltd.
IED Site Report
review by the Agency of its own volition, to furnish to the Agency a baseline
report in accordance with regulations under section 89.
(2) In relation to an installation, a baseline report shall contain the information
necessary to determine the state of contamination of soil and groundwater'at
I ' the time the report is drawn up in order that a quantified comparison may be
made to the state of the site upon the permanent cessation (including cessation
1~ by abandonment) of the industrial emissions directive activity concerned and
the applicant in preparing the baseline report shall. include any information
prescribed in regulations under section 89.
(3) Notwithstanding the generality of subsection (2), a baseline report shall
include at least the following information-
(a) The current use and, where available, the past use of the site,
(b) Any available information-
i. On soil or groundwater measurements that reflect the state of the site at the
time that the baseline report is drawn up, or
.. . 1 1 . On new soil and groundwater measurements, having regard to the possibility
of soil and groundwater contamination by the hazardous substances proposed
to be used, produced or released by the installation concerned.
10
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. . . . -
. .
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EPA Export 15-12-2014:23:30:28
Staunton Foods Ltd.
IED Site Report
2.3 Chemicals handled at Staunton Foods Ltd.
Chemicals utilised at Staunton Foods Ltd. relate to production process,
cleaning and maintenance operations, laboratory testing and quality
compliance, and wastewater treatment testing. A detailed list of chemicals used
onsite was assessed in accordance with Article 3 of Regulation (EC) No.
1272/2008 and the hazardous chemicals identified.
Table 2 below outlines these hazardous chemicals, which were brought
forward and assessed to determine the likelihood of release. As part of the
assessment, onsite controls and containment with respect to delivery, storage,
I and use of the chemicals, standard operating procedures, and other relevant
prevention measures, were reviewed.
. .
11
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Y
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,. .. ' . i.. ' .' .
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Slaunton Foods Lld October 2014
IED Site Report
Table 2 Determining Substances Which May Represent a Pollution Risk
Stage 3 Site Specific Characterisbcs Assessment Stage 2 Chemicals Characteristics 6 Toxicity Stage I Chemicals Handled
Ref
- Stale S-Solid 1-Liquia
L
- L
- L
Potenbal pollution nsk I likelihood of releases
Hazarp'ous substance under Stage 2 YedNo Yes
gelivery, Slorage, and Environmental 3ntro/s
Environmental /Ecologica/ Behaviour
No Informabon Available
Annual Usage (Tonnes)
440
0 025
0 025
100
25
1
0 7
QuanWy Stored (Tonnes)
,270 '
i'isk Phrases /Risk ?ategory
[his product is not iassified according IC i U legislabon
Substance Area of Use ;AS No.
'2623-859 As a result of the controls ir place to contain and preven any spillage of compressor oil the nsk of release to tht envlronment of this substance: is considered negligible and I is not considered to be 2 potenbal nsk to thf envlronment
Compressor Oil .
D Stored wthin a bunded containei within the Compressor Room
B Spill kit present within the vianity 0 the compressor room
D All bunds are inspected on a regulai basis lo ensure integnty and drair any rainwater Should a spill occur all drains coven are available and all drains within the area drain to the site WWTP
n An Emergency response team is present onsite in the unilkely even1 that a spill may occur
NIA (no further information required)
D
1 Pefro Canada Compressor oil reno 68A
NIA (no further information required).
Lubricant No 0.050 Water Pollubon Class WGK 1 Slightly water endangering (Classificabon according to German VwVwS from May, 1999) Avoid the contaminabon of soil and water
No relevant data
VIA . 2 Tunnosynfh 2000
NIA (no further informatior required).
N/A (no further information required) 0.025
0.02
Compressor Oil
No castrol Compressor oil aircol mr46
3
NIA (no further informabon required) NIA (no further informatior required).
will biodegrade Not likely to harm Aquabc environment
Production No S2, S25 MA Meat Marking Paint
4
Avoid release to the environment.
4s a result of the controls in place to prevent and contain any spillage of producbon ;hemicals , the nsk of release to the envlronment of these substances is considered negligible and they are not ansidered to be a potenbal nsk lo the envlronment
I Stored within bunded containers I Chemical spill kits are wthin the
vlcinity in the unlikely event that a spill may occur All bunds are inspected on a regular basis An Emergency response team is present onsite in the unilkely event that a spill may occur In the unlikely event that the above
Yes 7647-14-5 Production BrineSan . 5 . .
No relevant 0 2
0 05
Yes
Yes, '
T,FRWR25, SlW38, S41/45/61 R3WR371R38 '
Production
Production
cure P2
Sodium Ascorbate
6
7. data Possibly hazardous short term degradabon products are not likely However, long term
134-03-2
12
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Staunton Foods Ltd October 2014
IED Site Report
8
9
10
11
12
13
14
15
Phosphate fesf kif
Phosphate test kit mob reagent Phosphate test kif reagent vials Phosphate fesf kit sodium hydroxide 1.54N
Ammonia Test kif
Ammonia tesf kit Cyanurate reagent .
C.O.D. Vials
Nitrate test kit
HR Hydrogen Peronde Reagent
Total Nitrogen Test kit
Broxo Salt
7664-939,
7803-556
7727-24-1
231-791-2,
L 54-21-7 6132-04-3 610624-7 14402-89-2
L 6132-04-3 6106-24-7 131065-2 2893-78-9
7732-18-5 L 7732-18-5
766493-9 10294-26-5 7783-35-9
133582.0
1333-82-0
S 7757-79-1
7681-57-4 231-791-2 215-185-5 207-8304 7681-57-4 7631-86-9 129-964 57-1 3 6 7647-598-3
ROE-22- 3&'37/3& R35 S22-24-26 S37
0, Xn, Xi R20-25
R3W37, R8-22! 36/37/38/ 4m43,
C,R35 R35, R36/38 S26, s45, s37/37, S37l37 R22, R37
C, Xn, 0, Xn, Xi,,N, R08-22- 32-36/37-5053
R33, R35, R2ORlR2 C, R35 R4 1 T, N, R26/27/28 33- 5053 0, Cam, T+, T,R9-45- 46,R62-R26, 62-26.
R4R43R50R53 0, R8
R48R23-R35
Xn, XI, R2241-31
C,R35 XI,R36 Xn, Xi, R2241-31
WWTP Laboratory
W P Laboratory
WWTP Laboratory
W P Laboratory
W P leboratory
WWTP Laboratory
WWTP Labobtory
W P
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes .
Yes
degradation products may anse No lnformabon Avalable .
No Information Available.
No Information Available.
No Information Available.
Releases of Ibis material may confaminafe !he environment
No Information Available
No Information Available
. .
No Information Available
No environmental data Available Do no1 allow to enter into surface water or drains
50 Vials
50 Vials
150 Vials
125 Vials
150 Vials
100 Vials
250 Wals
250 Vials
1000 Vials
375 Wals
3,300 Wals
500 Vials
15
controls fail any chemical that may leak will flow to the WWTP
Small quantities of fhe reagenfs are used as part of the eff7uent plan! festing Small spill trays are presenl within the laboratory lo prevent fhe pofential for spills to be released from the laboratory
place and all laboratotypersonnel are
A chemical spill procedure IS in place
In the unlikdy event fhat a spills
All dreins are conveyed fo fhe W P Used wals are stored in a (light- sensdive) closed box, or within individual comparfmenfalised Styrofoam boxes unfrl sufficient quantities are present to required disposed using a licenced hazardous waste contractor ,
A chemical handling procedure is in
trained
af fhe site
occurs it will be cleaned up
See above
The salf IS sfored Mhin a designafed area within fhe W P Mhin in bags and IS solid in nature
These chemicals are used in small amounts and sorted in a designated place wlthin the waste water treatment laboratory Owing lo the controls in place, the nsk of release to the environment of these substances is considered negligible and they are not considered to be a potenbal nsk to the enwronment
See above
As the salt is stored wlthin the WWTP there is negligible potenbal for this to be released to the enwronment, any spillages would be easily deaned up therefore it is not considered likely that this substance would be released to
13
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. .
. . . . . .,
' .
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I .
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I
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Staunton Foods Ltd October 2014
IED Site Report
- L
~~~
All delivenes are SuDervised bv the enwronment
W P
W P
W P
WWTP
WWTP W P
W P
W P
W P
W P
W P
W P
Factory deaning
WGK 2 water endangering
No lnformabon Available No infonabon Available Large discharges may contnbute to the alkalisabon of water and may be fatal to fish and other aquabc life Bioaccumulabve Water Soluable No eqenmental Toxlcity values available Should not be allowed In waterways Product mcderatel y increases pH - value in Aqueous solubon
Topxlaty EC50 Daphnia magna >100mg Acute toxlcity values Acute LC50 for fathead minnow is > 1 OOmgn EC50 for manne mussel abra alba is > 100mgA EC50 for Daphnia Magna is > 100mgA TONG to aquabc organisims Decomposes in Water or Soil Not expected to bioaccumlate No lnformabon Available
10
52
52
10
45 15
25
1 3
I 50
3
0 025
0 025
0 05
75150-29-7 68213-230 64742-46-7 7446-70-0
7446-70-0 42751-791 1310-73-2
64-1 7-5 42751 -79-1
144-55-8
R51153 R41/50 R65 C,R36,R38 .
Yes.
Yes
Yes
1 16
17
18 '
trained personnel Stored wth a bunded units within tht WWTP area Bunds onsite provide minimum of 110% capaaty of the largest vessel or 25% of total capacity of tanks within the bund (whichever requires the greatest volume) All IBC's are adequately bunded and checked for leaks on a regular basis as per the requirements of internal envlronmental procedure Visual bund inspecbons are undertaken regularly Bund Inspechons. and integnty tesbng are programmed as part of preventabve maintenance are undertaken on a regular basis to ensure that they are intact Rainwater is empbed from the bund to ensure there is adequate capaclty to contain any potenbal spillages Chemical usage at the WWTP is managed and scheduled to ensure that only the amount required IS accepted at the ate Spill kits are available within Re area in the unlikely event that a spill may occur All drains within the vicinity of the flow to the WWTP
To date there has not been any inadent in the handling of chemicals at the WWTP
As a result of the controls in place, the nsk of release to the envlronment of these substances is considered negligible and they are not considered to be a potenbal nsk to the envlronment
L
L -
Remphos A 13
CellnOC A2013
Caudic Soda
1
. ' C,R36 R30 R35, S24l25 L Yes 1 19
20 21
22
23
24
L L -
- S
F, R11, S7-16 XI, R36
Yes Yes
Yes
Yes
Yes
2 1
Alcohol Cellfloc C5
See above
Sodium Bicarbmate
2
L R36, R38 S24, S25, S36
0.125
0.150
Defoam V20
Defoam 60 L
L
No CAS number for Defoam 60
7681-52-9
500-220-1
231-781 -8
215-185-5
7681-52-9
Chloropol R36,R38 0.25
L Yes ,
Yes
Yes
0 05.
0 05
0 1
Turbo
Persulfate Reagent
Xi,R41 Small quanbbes used onsite Contained within the WWTP laboratory wthin a bunded container A chemical handling and spill response procedure is in place and WWTP are bained in the correct use All chemicals used for factory
UA (no further information equired).
L
C,R35 ,
Neat product is dangerous to the
Chloman .hese chemicals are used in a mtrolled manner athin the . .
14
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. .
Staunton Foods Ltd October 2014 IED Sile Report
Environment if discha!ged direct to
deaning and maintenance operabons are stored in designated areas on bunds within the building A chemical handling and spill response procedure is in place Spill kits are available within the building in the unlikely event there is a spillage Visual bund inspecbons are undertaken regularly All drains within the factory flow to the site WWTP Should a spill occur all drains covers are available and all drains within the area drain to the site WWTP
factory All chemicals are storei in a designated place within the factory on bunds h n g to the controls in place, the nsk of release to the environment of these substances IS considered negligible and they are not considered to be a potenbal nsk to the enwronment
watercourses. This product is not dassified as environmentally hazardous.
29 Yes Xi, R38, R41
xi R36/38 M7 Hand Soap Factory
deaning 0.04
0.02
0 52
0 1
15
5
200
0 05
0 600
Perbac Factory deaning 30
Yes
S26, R20122 S36137139 Xn, C, 0, R20/22, S45. S51. R35. R7
79-21-0
Maxifoam Plus Factory Cleaning
Yes
Yes
Large or frequent spills can have a harmful or damaging effect on the environment This mixture is not dassified as t o m to aquabc organisms Not expected to
Bioaccumulate Phosphates are plant nutnent and as such may contribute to the growth of phytopanctons in water Inorganic product, which cannot be eliminated from water by biological purificabon process Not regarded as
dangerous to the environment
2 31 32
d a wc Anti Zoagulant Thermphos
Blood Unit 0.4
Xn, R22, R3i Sodium Irish Casings perservative
Yes 2 Helabisulphate
See above)
See above) L 35 4lkfoam i l l - 7 6 2 Xn, XI, R36138, R20121122 XI, R36/38 F, R i 1 XI, R36, R68 XI, R36138 F, R i l , R36, R68, XI C, R35 XI, R36138
Cleaning factory
Yes - ' 0.025
21 5-1 85-5 221-416-0
L Yes . 36 Xn, Xi, N,R21.R22. '
R37138,R50 3romotech 52-51-7 Cooling tower 0.300 Not regarded as
dangerous for the environment
50,96 Hrs. FISH mgn >loo mgn (Bluegill sunfish),
15
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I .
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EPA Export 15-12-2014:23:30:28
Staunton Fwds Ltd October 2014
IED Site Report
37
38
39
40 , .
h l t e c h
-armsan
Vopac
PP44
Multitech '
'632-00-0
I31 073-2
1, T, N, RB,R25,R50
01, XI, R22 ;, R35 ;, R34 (n N. R20/21 ;,R34, S24/25,526, I6137/39,545.S60
lot Classified
2, R35
Cooling tower
Factory Cleaning
Cleaning factory
Cleaning factory
Steam boiler
les
les
res
Yes
(Oncorhynchus mykiss) EC 50,48 Hrs, DAPHNIA, mgn 4 6mgn (Daphnia) IC 50, 72 Hrs. ALGAE, mgn 1 9 9 3 mgn ( N w
The substance has a low potenhal for bio- accumulahon Dangerous to the environment Very toxlc to aquahc organisms Not expected to Bioaccumulate
This product is not dassified as environmentally hazardous However, this does not exdude the possibility that large or frequent spills canhave a harmful or damaging effect on the environment Acute Fish Toxlcity Fish toxlaty LCO >1600mgn (Goldorfen, 48 h) Bactenal Toxlaty EC50 >iooomgn (OECD 209) LC 50,96 Hn, Fish myl >IO00
mykiss) EC 50,48 Hrs,
(Onchorilynchus
Daphnia, mgn 485 IC 50,72 Hrs, Algae, mgn> 1000 Bioaccumulabve potenbal Concentabons
3.300
3.025
3 025
3 1 .
D 600
3 125
D 075
0 5
500
(See above)
(See above)
(See above)
See above)
16
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, ,!
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Slaunton Foods Ltd.
IED Site Recod
October 2014
.- , Steam Boiler les 300 ' greater than 10
ppm, especially in fresh water or a pH value equal to or greater than 10 5 may be fatal to fish and other aquabc organisms Can cause damage to aquabc plants When used for its intended purpose should not cause adverse affects in the environment
Harmful to aquabc life in low concenbabons No data available
No data available No data available No data
f i , Xi, R22,R41,R31 '681-57-4
18955-555 1.01
1.300
0 1
0 600
0 025
0 5
0 025
0 025
0 025
0 025
0 05
XJ, N. R38, R41,R50
C.R35 C. R31, R34
Xn, R22 R31
Factory :leaning
les 12 1 lomestos
Steam Boiler les '631-90-5 13 iorrotech CPN
S24125, S36, 537. SI, S60
les Maintenance Water Soflener Lubncant Maintenance Maintenance
Maintenance
'647- 14-5 14 '- inderol H I High erformance food rade inderol C-NRT I
'LUS 100 FG iassida fluid 'P100 llba food beanng
1025
11
102
I 004
1025
1025
Non Haz UA
1 1-486
15
16
47 .
18
19
50
51
Xn les
les R22
Non Haz
Non Haz
da available No data
lrease '
Mina oil 917 Ja Maintenance \lo
rl0 Maintenance ila
4IA ,
8955-555
ihell Cassida oil 50 :ream Cleaner
Iomestos
avalable No data available When used for its intended purpose should not cause adverse affects in the
Factory Cleaning
Non Haz
Xi, N, R38, R41,R50 Factory Cleaning
1.001 0.01
0.050
environment. When used for C,R35 Factory
Cleaning ,
Yes 131073-2
i68!-52-9
its intended purpose should notcause . adverse affects in the environment Not expected to Bioaccumulate Release of alkaline or acid solubon klling p H sensibve
C. R31, R34
Factory Cleaning
res D.025
C,Xi,RH, R37 3834-92-0 3cef 52
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* .
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. . .
. .
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E D Site Report
microbes in the 5011, breaks down soil structure, contaminates groundwater, raises total dissolved solids concentrabon
53 TWS L Xi, R 3 M 8 Factory Yes Not expected to 0 25 Cleaning Bioaccumulate
Holquat Cleaning Bioaccumulate
C, R36138 L 131073-2 C. R35 Factory Yes Not expected to 0 375
68131-395 XI, N, R41. R50, s24125
55 Oven and Utensil L 63449-41-2 Xn, C, N, R21122 Factory Yes Large or 0 4 Cleaner M6 S26, S37 Cleaning frequent spills
have a harmful 131073-2 C or damaging
effect on the environment
can
56 Auto AL L 1310-58-3 C. Xn, R35, R22, S26, Factory Yes This product 0 025 s45. Cleaning consists solely of
inorganic matenals for which bicdegradabon assessment is not applicable
classified as hazardous to the enwronment
57 Drysan L 1312-76-1 XI. R38,R41,S24125 Factory Yes This product is 0 04 7320-34-5 XI, R36 S36,37, Cleaning
39,S60 67-630 F XI, R l l , R36,R67,
S25, S26. S51,s49 58 07440-37-12 0, PAS, S9, 523 Maintenance
Argon Gas 14m3 G Yes No ecological 1 X 14 m3
59 Argon Gas 14m3 G 07440-37-12 0, RAS, Maintenance Yes No ecological 1 X 1 4 m3
damage caused by this product
damage caused by this product
60 LPG G 101-97-8 F, R12, S9, S9, S16 Factory Yes NIA No known ecological damage caused by this product
18
. .
0 65
2 6 Extensive nehvork of process drains Due to controls in place it IS not within the site should any of the chemicals spill Faality has a rolling inspecbon and test programme in place for all process pipelines
Any spills wlll be deaned up following standard operatmg procedures All personnel using chemicals are trained in the sites chemical handling procedure Spill bts are available Whin the factory should any spills occur All drains in the area flow to the sites WWTP See above
considered that this chemical will have the potenbal to be released to the enwronment
2 Stored within a bunded unit Due to controls in place it is not considered that these chemicals will have the Potenbal to be released to the enwronment
0 025
See above
0 255
Stored within the plant in a designated area mthin a pressunsed vessel
the safe use of the gas
Control measures are in place with respect to storage and use of the gas and the nsk of
Maintenance operabve are trained in release IS considered negligible
24 m3
5 6 m3
400 LPG is stored in a protecbve cylinder Control measures are in place and is inspected be a by a qualified with respect to storage and use technician as required to ensure the of the gas and the nsk of valves, connecbons, piping, and release to the environment is hoses are free of leaks considered negligible A release valve is present which emits the gas controlled manner to prevent the cylinder from exploding due to over-pressunzabon The is regularly S ~ M C ~ S as part of a preventabve maintenance programme
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Staunton Foods Ltd
IED Site Report
Propane gas cylinder
Diesel
Ammonia
Freon 404A
101-97-8
64742467
7664-41-7
354-33-6
:, R12
61, N, R20, R38, 765, R51I53.
',T,C,N R10. R23, 734, R50
R36,R37
Factory
T N C ~ 8 forklifl
Refngeranl
Refngerant
t'es
les
les
Yes
No known ecological damage is caused by this product
Oil contaminates soils in the area, and subsequent conlaminabon of groundwater
Release of toxic gas lo the environmen t
R-404A is a gas at rwm temperature, therefore, it is unlikely to remain in water
1
2
?/a
1260
1
200
1
0.260 1
October2014
Stored in a Well-ventilated and dr fire resistant locabon and away fror electncal urcuits Stored within a pressunsed vessel The vessels are regularly inspecte by trained personnel to ensure th: the regulators, pressure relief valve and cylinder connections are entac and they are free of wrrosior leakage, pi lng, dents or gouges Diesel is stored wlthin a double slunned tank All refuelling operabons take place oi a hardstanding area and are supervised by site personnel
0 A spill kil is present in the unlikely event of a spill area Drains in the area flow to via an oil interceptor prior to discharging to the sile Water Treatment Plant
Ammonia is conlained within
Refngerabon system is mamtained enclosed system
by expenenced external professionals Alarm system in place to detect if ammonia leak occurs Stored wilhin a pressunsed vessel Used in small quanbties
The likelihood of occurrence is considered negligible, a vehicles are anended dunng refuelling, a hardstand is provided in the refuelling area and all liquids falling are routed through an oil interceptor before discharge - the collected matenal is stored in lhe waste oil bunded tank before being sen1 for treabnent
Due to controls in place and the fad thal is gas at rwm temperature it is not considered to present a fhreat to surface and groundwater
Used in small quantities and stored within a designaled location within the facility Due to controls in place and the fact thaf is gas a! m m temperafure it is not considered to p s e n t e threat lo surface and groundwater
i
I The Freon 404A has not been replaced since plant became oper?tional
i a I "
. .
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... , , i -
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October 2014 Staunton Foods Ltd
IED SI - teport
Refrigerant L
- L
- S
- s
N/A (no further information required) WGK Germany 1 Low hazard to waters Product is not a bio- ammulator - biological half- life is less than 3 hours Biodegradabon This product is water soluble and moves readily in soil and water
322 ' N/A
120
30007
-
NIA (no further informabon required)
j7-55-6 ' Glycol 65 '
Pig Stunning When discharged in large quantities may contribute to the greenhouse effect. . No data
available. ,
3
1.0005
N/A (no further informahon required)
0. Ras.SS 1
1
CO2 Gas is stored in pressunsed vessels All personnel are trained in the correct operabon and use
56 CO2 gas
les NIA (no further informabon required)
102.954 xn, R22 Micro Lab 1 Used in a small quanbbes within the Micro Lab
1 Present in a solid state so not potenbal for leaking to drain
1 Specific training is provlded for those personnel who are involved in handling chemicals as part of their daily dubes
I NI waste plates are removed from the laboratory by approved hazardous waste contractors
N/A (no further informabon required)
57 V@d Agar
IO plates rl0 NIA (no further informabon required)
N/A (no further informahon required)
don Haz Micro Lab Blood Agar 68
69 N/A (no further informabon required) No ecological problems are to be expected when handled wth due care
No data available
No data available
?O ml Micro Lab vo Baallus Subhlis
300 ml
1005
1005
1005
I 2 litres
1005
NIA (no further information required) 3.0005 . NIA (no further informabon required)
NIA (no further informabon required)
I is considered there is no nsk if these chemicals being eleased to the enwronment Iue to the controls in place Should spillages occur they ould be easily swept up herefore not considered to be a iotenbal nsk
Micro Lab don Haz
lon Haz
'447-47-8
Plate count agar 70
NIA (no furlher informabon required)
Present in a solid state so not potenbal for leaking to drain All personnel are trained in the correct use and disposal of this matenal All waste matenal is stored in a designated area and removed from the laboratory by approved hazardous waste contractors
1.0005
1.0005
Micro Lab rl0
les
Maximum recovery diluents Baird parker agar
71
72 Xn, Xi, R22/36/38 Nodata . available. Bio Lab
les j00 ml '790-58-1 T. Xi, R25136I38
xn, w 2
Egg yolk tellurite
Chromocull tbx
73 No data available
No data available.
Bio Lab
S Bio Lab les 102-95-4 1.0005 . 74
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I . . , . - 1
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Staunton Foods Lld October 2014
206-132-7
7647-01-0
7789-00-6
7601-54-9
9001-75-6
N/A
IED Site Rewrl
Xn
C, XI, R34. R37
T.N, R36/37/38. R43, R50153
R36138
XI, R36137138/42,
Non Haz S22-24-26-36-37
Non Haz
Non Haz
HCL 37% 71 Potassium Chromate
pH Test Agar 8 0
Pepsin
pH Test Agar 6 0
Enwrochedt contact 5
Brain heart brote I
Bio Lab
Bio Lab
Yes
Yes
Bio Lab
Bio Lab
Bio Lab
Bio Lab 1 No
No data 1 available
No data 2 available
No data 0 00052 available . No data 0 005
available. , 0.0005
110 plates
0 0005
Spill kits are located in the area and employees are trained in response control
0 05 I
0 005 NIA (no further informabon required)
NIA (no further informabon required)
NIA (no furlher informabon required)
plates
Bio Lab I No
required)
required)
required)
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. .
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Staunton Foods Ltd. October 2014
IED Site Report
3. Discussion
As can be seen from Table 2 a robust system of environmental control is
exercised with respect to hazardous chemicals from delivery, storage and use
through to spill response and pollution prevention measures.
Procedures are in place to risk assess any new chemicals to the facility to
ensure that controls are put in place to ensure environmental protection. All
deliveries of chemicals to the facility are supervised by trained staff members.
All hazardous chemicals are stored on bunded units which are regularly
inspected and where necessary emptied of rain water. A programme of
integrity testing is in place at the site to ensure containment and supervision of
deliveries is undertaken by trained site personnel. Spillages and leaks from
mobile tankers, or drums during movement around site, if they were to occur,
would be detected and the potential for contamination would be mitigated by
way of site emergency procedures. In the unlikely event that there is a spillage,
of chemicals, spill kits are available and detailed emergency procedures are in
place and will be enacted.
The WWTP at Staunton Foods is run efficiently and is closely monitored to
ensure that the plant operates within the emission limit values. Freeboard is
always maintained in the balance tank to ensure unexpected hydraulic loads
can be balanced. The WWTP is also fitted with a high level alarms in place.
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. -
Staunton Foods Ltd. October 2014
IED Site ReDort
3 Conclusion
The hazardous chemicals, which have the potential to have an adverse impact
on the environment, have' been identified as part of the IED site report.
Potential chemical pathways have been comprehensively assessed at the
Staunton's Food Ltd. facility through critical evaluation of current activities and
site environmental management.
Owing to the storage and processes undertaken at the site and environmental
performance, the potential for releases of such substances is considered low
due to the controls in place. The control measures in place at Staunton Foods
Ltd. ensure that hazardous chemicals do not present a risk to the environment.
Site environmental management were found to be proactive I in their
performance in environmental management and the facility has a strong
compliance record with their CCC Licence.
For these reasons, based on the assessment details in table 2, we conclude
that there is no requirement for a full baseline study for the site.
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