Integrated Pollution Prevention and · PDF fileIntegrated Pollution Prevention and Control (IPPC) Licensing Application Form Environmental Protection Agency P.O. Box 3000, Johnstown

Integrated Pollution

Prevention and Control

(IPPC) Licensing

Application Form

Environmental Protection Agency

P.O. Box 3000, Johnstown Castle Estate, Co. Wexford Lo Call: 1890 335599 Telephone: 053-9160600 Fax: 053-9160699

Web: www.epa.ie Email: [email protected]

EPA Reg. No: (Office use only)

IPPC Application Form V2/12

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CONTENTS

ABOUT THIS APPLICATION FORM ........................................... 3

SECTION A: NON-TECHNICAL SUMMARY ............................. 4

SECTION B: GENERAL .......................................................... 5

SECTION C: MANAGEMENT OF THE INSTALLATION............ 12

SECTION D: INFRASTRUCTURE & OPERATION................... 15

SECTION E: EMISSIONS..................................................... 18

SECTION F: CONTROL & MONITORING .............................. 35

SECTION G: RESOURCE USE AND ENERGY EFFICIENCY...... 42

SECTION H: MATERIALS HANDLING .................................. 46

SECTION I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY........................................................................... 54

SECTION J: ACCIDENT PREVENTION & EMERGENCY RESPONSE ......................................................................... 71

SECTION K: REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE............................................. 76

SECTION L: STATUTORY REQUIREMENTS .......................... 78

SECTION M: DECLARATION................................................ 89

ANNEX 1: TABLES/ATTACHMENTS.........................................90 ANNEX 2: CHECKLIST FOR ARTICLE 10 COMPLIANCE .............170


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ABOUT THIS APPLICATION FORM

This form is for the purpose of making an application for an Integrated Pollution Prevention and Control (IPPC) Licence under the Environmental Protection Agency Acts, 1992 and 2011. There is a separate application form for applicants who wish to apply for the Pig & Poultry sector. The Application Form must be completed in accordance with the instructions provided in the IPPC Licensing Application Guidance Note. The Guidance Note gives an overview of IPPC Licensing, outlines the licence application process (including number of copies required) and specifies the information to be submitted in the application. The Guidance Note and application forms are available to download from the IPPC Licensing pages of the EPA’s website at www.epa.ie. A valid application for an IPPC licence must contain the information prescribed in the Environmental Protection Agency (Licensing) Regulations, 1994 to 2010. Article 10 of the Regulations sets out the statutory requirements for information to accompany a licence application. The application form is designed in such a way as to set out these questions in a structured manner and not necessarily in the order presented in Article 10. In order to ensure a legally valid application in respect of Article 10 requirements, please complete the Article 10 Checklist provided in Annex 2. This Application Form does not purport to be and should not be considered a legal interpretation of the provisions and requirements of the Environmental Protection Agency Acts, 1992 and 2011 and the Environmental Protection Agency (Licensing) Regulations 1994 to 2010. While every effort has been made to ensure the accuracy of the material contained in the Application Form, the EPA assumes no responsibility and gives no guarantees, undertakings and warranties concerning the accuracy, completeness or up-to-date nature of the information provided herein and does not accept any liability whatsoever arising from any errors or omissions.

Should there be any contradiction between the information requirements set out in the Application Form and any clarifying explanation contained in the accompanying Guidance Note, then the requirements in this Application Form shall take precedence.


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SECTION A: NON-TECHNICAL SUMMARY

A non-technical summary of the application is to be included here. The summary should identify all environmental impacts of significance associated with the carrying on of the activity/activities, and describe mitigation measures proposed or existing to address these impacts. This description should also indicate the normal operating hours and days per week of the activity. The following information must be included in the non-technical summary: A description of: − the installation and its activities, − the raw and auxiliary materials, other substances and the energy used in or

generated by the installation, − the sources of emissions from the installation, − the environmental conditions of the site of the installation (e.g. soil and

groundwater, air, noise, surface water), − the nature and quantities of foreseeable emissions from the installation into each

medium as well as identification of significant effects of the emissions on the environment,

− the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation,

− where necessary, measures for the prevention and recovery of waste generated by the installation,

− further measures planned to comply with the general principles of the basic obligations of the operator i.e.

(a) all the appropriate preventive measures are taken against pollution, in

particular through application of the Best Available Techniques (BAT); (b) no significant pollution is caused; (c) waste production is avoided in accordance with the waste hierarchy in Council

Directive 98/2008/EC on waste and section 21A of the Waste Management Acts 1996 to 2011 (as amended in 2011); where waste is produced, it is prepared for re-use, recycled or recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment (applicants should provide this information in the context of sections 29(2A), 32 and 38(5A) of the Waste Management Acts 1996 to 2011);

(d) energy and other resources are used efficiently; (e) the necessary measures are taken to prevent accidents and limit their

consequences; (f) the necessary measures are taken upon definitive cessation of activities to

avoid any pollution risk and return the site of operation to a satisfactory state. − measures planned to monitor emissions into the environment. Supporting information should form Attachment No A.1

The Non-Technical Summary has been included as a separate document in Attachment A1.


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SECTION B: GENERAL

B.1. Owner/Operator

Name*: Irish Distillers Limited Address: Midleton Distilleries Midleton Co. Cork Tel: 021 - 4631821 Fax: 021 - 4631602 e-mail: [email protected]

* This should be the name of the applicant which is current on the date this IPPC Licence Application is lodged with the Agency. It should be the name of the legal entity (which can be a limited company or a sole trader). A trading/business name is not acceptable. Name and Address for Correspondence Only application documentation submitted by the applicant and by the nominated person will be deemed to have come from the applicant.

Name: Irish Distillers Ltd. Address: Midleton Distilleries Midleton Co. Cork Tel: 021 - 4631821 Fax: 021 - 4631602 e-mail: [email protected]

CRO No. and address of registered or principal office of Body Corporate (if

applicable)

CRO No. 23732 Address: Simmonscourt House Simmonscourt Road Ballsbridge Dublin 4 Tel: 01 2129000 Fax: 01 2129001 e-mail: [email protected]

If the applicant is a body corporate, the following information must be attached as Attachment B1: a) a Certified Copy of the Certificate of Incorporation. b) the Company’s Registration Number from the Companies Registry Office. c) Particulars of Registered Office of the Company.

Certified copies of the various “Certificate of Incorporation” are included in Attachment B1, including the most recent one in 1970 when the company name was changed to “Irish Distillers Ltd.” – which is still the name in use today. The Company’s Registration Number is included on the certificates (23732), while the Registered address of the Company has been provided above.


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Name and address of the proprietor(s) of the Land on which the Activity is

situated (if different from applicant named above):

Proprietor’s

Name:

Not Applicable

Address: Tel: Fax: e-mail:

Name and address of the owner(s) of the building and ancillary plant in which the

activity is situated (if different from applicant named above):

Name: Not Applicable Address: Tel: Fax: e-mail:

B.2. Location of Activity

Name: Irish Distillers Limited Address*: Midleton Distilleries Park North Midleton Co. Cork Tel: 021 - 4631821 Fax: 021 - 4631602 Contact Name: Mr. Aidan Curran Position: Environmental & Energy Manager e-mail: [email protected]

* Include any townland.

National Grid Reference

(12 digit 6E,6N)

188715E, 073677N

Location maps (≤A3), appropriately scaled, with legible grid references should be enclosed in Attachment B.2. The site boundary must be outlined on the map in colour.


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Geo-referenced digital drawing files (e.g. AutoCAD files) in Irish Grid projection of the site boundary and overall site plan, including labelled emission, monitoring and sampling points, are also required. This data should be provided to the Agency on a separate CD-Rom containing sections B.2, E.6 and F.3.

Name of geo-referenced

digital drawing files

A full list of the Drawings included in the Licence Review Application is provided in Attachment B2. Map No. 3 is included in Attachment B8.

Name of CD-Rom with

digital drawing files

Irish Distillers Ltd. Midleton Distilleries Midleton Co. Cork IPPC Licence Review Application P0442-01 July 2012 Disc Containing Sections B.2, E.6 & F.3

B.3. Class of Activity

Identify the relevant activities in the First Schedule of the EPA Acts 1992-2011 to which the activity relates:

Schedule Class DescriptionNote 1

Schedule 1 (Protection of the Environment Act, 2003)

7.3.2 Distilling in installations where the production capacity exceeds the equivalent of 1,500 tonnes per year measured as pure alcohol, not included in Paragraph 7.8.

Secondary Activity as advised by the EPA in their letter dated the 13th April 2012 to Irish Distillers Limited.

Schedule Class DescriptionNote 1

Schedule 1 (Protection of the Environment Act, 2003)

2.1 The operation of combustion installations with a rated thermal input equal to or greater than 50MW.

Note 1: In order to give a precise identification select only those words from the description of the class or classes that best describes the nature of the activity for which the licence is being applied for.

B.4. Employees/ Capital Cost

Give-

(i) In the case of an established activity, the number of employees and other persons working or engaged in connection with the activity on the date after which a licence is required and during normal levels of operation, or (ii) In any other case, the gross capital cost of the activity to which the application relates.

Number of Employees (existing facilities): 111 (increasing to 135)

Gross Capital Cost (new proposals) € Not Applicable


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B.5. Relevant Planning Authority and/or Public Authority

Give the name of the planning authority in whose functional area the activity is or will be carried out.

Name: Cork County Council Address: County Hall Carrigrohane Road Cork Tel: 021 - 4276891 Fax: 021 - 4867007

Planning Permission relating to this application:

has been obtained x is being processed is not yet applied for is not required

Local Authority Planning File Reference

No:

11/06531

Give the name of the planning authority in whose functional area the activity is or will be carried out.

Name: Midleton Town Council Address: Pearse Memorial Chambers Youghal Road Midleton Co. Cork Tel: 021 - 4631580 Fax: 021 - 4631429

Planning Permission relating to this application:

has been obtained x is being processed is not yet applied for is not required

Local Authority Planning File Reference

No:

11/56014

Attachment B.5 should contain all planning permissions, including a copy of all conditions, a copy of the planning inspector’s report and the required copies of any EIS should also be enclosed. For existing activities, Attachment No B.5 should also contain all licences and permits past and present in force at the time of submission. Where applicable, provide a copy of any screening for Appropriate Assessment report and Natura Impact Statement (NIS) that was prepared for consideration by any planning/public authority as defined in Regulation 2(1) of the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477 of 2011) in relation to the activity. Where a determination that an Appropriate Assessment is required has been made by any planning/public authority in relation to the activity, a copy of that


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determination and any screening report and Natura Impact Statement (NIS), and any supplemental information furnished in relation to any such report or statement, which has been provided to the planning/public authority for the purposes of the Appropriate Assessment shall be included in Attachment No B.5.

The planning permissions relevant to this proposed expansion process are as follows:

• Cork County Council (11/06531) • Midleton Town Council (11/56014)

Copies of these permissions are included in Attachment B.5 along with the Planning Inspector’s report for Cork County Council. An Environmental Impact Statement (EIS) was submitted with both planning applications and a copy of this has been included with the IPPC Licence Review Application. It has been included as a separate document. As well as the above documents Attachment B.5 also includes:

• Natura Impact Assessment • Extracts from planning clarifications sent on the 8th February 2012 in response to

queries from Cork Co. Co. • Extracts from planning compliance documents forwarded to Cork Co. Co. and

Midleton Town Council 29th March 2012 • Close out of IPPC Licence P0442-01, Schedule 6(i) Once-Off Reports and relevant

licence conditions

The existing environmental licences associated with the IDL site are as follows:

• IPPC Licence (P0442-01) • Greenhouse Gas Permit (IE-GHG005-03)

Both of these licences can be viewed on the EPA website – www.epa.ie .

B.6. Relevant Water Services Authority

In the case of a discharge of any trade effluent or other matter to a sewer of a Water Services Authority, give the name of the Water Services Authority in which the sewer is vested or by which it is controlled.

Name: Cork County Council Address: County Hall Carrigrohane Road Cork Tel: 021 - 4276891 Fax: 021 - 4867007

In the case of a discharge of any trade effluent or other matter to a sewer not vested by a Water Services Authority, the applicant must supply as Attachment No B.6; (a) the name and address of the owner(s) of the sewer and the waste water treatment plant to which the sewer discharges and who are responsible for the quality of the treated effluent discharging to waters and (b) a copy of the effluent regulations and the agreement between the applicant and the aforementioned.


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Name: Not Applicable Address: Tel: Fax:

B.7. Relevant Regional Health Service Executive

The applicant should indicate the Regional Health Service Executive where the activity is or will be located.

Name: HSE South (Cork & Kerry) Address: Administrative Headquarters Wilton Road Cork Tel: 021 4923774 Fax: 021 4923627

B.8 Site Notice, Newspaper Advertisement and Planning Authority Notice.

Attachment No B.8 should contain a copy of the text of the site notice, a map (no larger than A3) showing its location on site (in accordance with Article 7 of the Regulations) and a copy of the newspaper advertisement. A copy of the notice given to the Planning Authority should also be included. Attachment No. B.8 contains this information including a full page copy of the “Newspaper Notice” and Map No. 3 identifying the location of the Site Notice. B.9 Seveso II Regulations

State whether the activity is an establishment to which the EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations (S.I. No. 74 of 2006) apply.

If yes, outline how the process comes under these regulations. Supporting information should be included in Attachment No B.9. IDL is subject to these Regulations due to the storage of alcohol (ethanol) on site. The amount stored on-site in the warehouses is above the qualifying quantity of 50,000 tonnes for a category 6 (flammable) dangerous substance as outlined in Schedule 1 (part 2) of the Regulations. The site is designated as a top tier Seveso site with a 300m consultation zone for any proposed development. The current Health and Safety risks identified for the site have been identified in a Safety Report that was recently approved by the Health and Safety Authority (HSA). The 300m Seveso boundary is shown in Figure 17.2 (Page 184) of the EIS.


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B.10 IPPC Directive

Specify whether the activity is a category of industrial activity referred to in Annex I of the IPPC Directive (2008/1/EC) and if yes specify the category.

Category Description

1.1 Combustion installations with a rated thermal input exceeding 50 MW.

Specify whether the activity is a category of industrial activity referred to in Annex I of the Industrial Emissions Directive (2010/75/EU) and if yes specify the category.

Category Description

1.1 Combustion of fuels in installations with a total rated thermal input of 50 MW or more.

Supporting information should be included in Attachment No B.10. The EPA has indicated to Irish Distillers Ltd. that their main site activity does not come under either the IPPC or IED Directives. However, due to the combined thermal input capacity of the three main boilers on-site (61.8 MW) the EPA considers that the categories provided in the Tables above should be considered secondary activities for the site. This is based on correspondence sent to the EPA on the 7th March 2012 by PM Group (Consultants acting on behalf of Irish Distillers Ltd.).


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SECTION C: MANAGEMENT OF THE INSTALLATION

C.1 Site Management & Control

Details should be provided on the management structures for the activity. Organisational charts and all relevant environmental management policy statements, including provisions for on-going assessment of environmental performance, are required. An organisational chart for the site has been provided in Attachment C1. The roles and responsibilities for the following personnel are also outlined in Attachment C1:

• Environmental and Energy Manager • Production Services Process Engineer • Wastewater Treatment Plant Operative • Quality, Safety & Environmental (QSE) Systems Co-ordinator

As part of the site’s integrated management system it is the policy of IDL Midleton Distilleries that personnel performing QSE related work shall be competent on the basis of appropriate education, training, skills and experience.

Competence, Awareness & Training

IDL Midleton Distilleries recognises the need to train its employees to ensure that they have the appropriate knowledge and are competent to conduct their work and have an understanding of the actual and potential QSE impacts of their work. Employees are made aware of how they contribute to the achievement of the business objectives through the issue of relevant monthly reports and the display of the site QSE policy. IDL Midleton Distilleries also recognises in QSE030 Competence Assessment Policy, that competence, particularly in the context of the Control of Major Accident Hazards (COMAH), is the continuing ability of all employees operating, maintaining and managing the facility to perform reliably the Major Accident Hazard Elements of their roles, responsibilities and tasks and for this to be demonstrable.

Competence & Training

The provision of training is formally reviewed annually and records of this training are maintained by the relevant manager. The competence of employees is assessed as part of the training process. The procedure, responsibility and records related to training and the assessment of competence are defined in procedure QSE003 Competency Assessment & Training. Awareness

Management at IDL Midleton Distilleries ensure that all personnel are aware of the relevance and importance of their activities and how they contribute to the achievement of the organisation’s QSE objectives. The aim of awareness training conducted company wide is to make employees aware of the importance of:

• Conformance with the documented policies and procedures and the

requirements of the management system

• The QSE consequences, actual or potential of their work activities and the benefits of improved personal performance


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• Their roles and responsibilities as part of the management system, including emergency preparedness and response requirements

• The potential consequences of departing from documented procedures.

Awareness is achieved through appropriate training and the internal communications process (periodic newsletter articles, posters and electronic mail messages, etc. - Section 5.5.3.1 Internal Communications of the Management Manual).

Management of WWTP

The main abatement / treatment system operated on-site is the wastewater treatment plant (WWTP). The management and responsibility with the operation and control of the WWTP lies with the Environmental and Energy Manager and the Production Services Process Engineer. There is a WWTP Operative assigned to operate the plant, including sludge handling, in compliance with the IPPC licence. Their roles and responsibilities are provided in Attachment C1 while EPP001 is the procedure used for the operation of the WWTP. Calibration and Maintenance Systems

There is a Calibration Procedure on-site (QSE013) which has the following objectives:

• To ensure that equipment used to measure those parameters which have been deemed to be critical to product quality, food safety and environmental control and is used to verify conformance to specified requirements, is maintained in a known state of calibration.

• To ensure that all such instruments are used in a suitable environment. • To ensure that all non-critical process related instruments are subject to

formal checks.

Engineering Maintenance & Control

Procedure EP001 (Engineering Maintenance & Control) sets out how IDL achieves its objective to maintain the plant in a safe and reliable manner; decrease downtime, engineer out problems and improve efficiencies. Work on-site is broken into 2 distinct categories – planned and unplanned.

• Planned work is generated through PEMAC (Planned Engineering Maintenance and Control).

• Unplanned consists of requests from other departments (excluding engineering),

breakdowns, etc.

Waste Control Systems

There are a number of procedures on-site for the management of waste, as follows:

EPP004 Handling and Disposal of Non Hazardous Waste from IDL EPP005 Handling and Disposal of Hazardous Waste from IDL EPP020 Waste Tracking

Quality Control System

The quality control system for the site forms part of the QSE management system and is certified to ISO 9001:2008.


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C.2 Environmental Management System (EMS)

Indicate whether an Environmental Management System has been developed for the installation. If yes, specify which standard and include a copy of the accreditation certificate. The site has developed an integrated Quality, Safety and Environmental Management System. The scope of the IDL Midleton Distilleries management system includes all activities involved in the production of distilled beverages and byproducts. A Management System Manual has been developed to provide a single point of reference for the management of all quality, food safety, feed safety, health & safety and environmental matters at IDL Midleton Distilleries. This manual applies to all activities carried out at Irish Distillers Pernod Ricard, Midleton, in compliance with ISO 9001:2008, ISO 14001:2004, ISO 22000:2005, OHSAS 18001:2007 and FEMAS (Feed Materials Assurance Scheme) management system standards. A copy of the ISO 14001:2004 Accreditation Certificate issued by IQNet / NSAI is included in Attachment C2. Through ongoing monitoring, internal and external audits and regular management reviews the site’s environmental management team is able to continually assess the environmental performance of the site against ever changing regulatory requirements. A list of environmental procedures used to assist with maintaining and improving the site’s environmental management system is provided in Attachment C2.

C.3 Hours of Operation

Provide details of the hours of operation for the installation, including: (a) Proposed hours of operation. (b) Proposed hours of construction and development works and timeframes. (c) Any other relevant hours of operation expected. This information should form Attachment No C. a) Proposed Hours of Operation

24 hours per day 7 days per week 52 weeks per annum (this includes holiday and summer shut-down periods) – typically the plant operates for 48 weeks per annum with plant maintenance carried out during the other 4 weeks.

b) Proposed Hours of Construction

These have been specified by the planning permissions, as follows: “No construction shall take place outside the hours of 08:00 – 19:00 on Mondays to Fridays and 09:00 to 16:00 on Saturday – except in exceptional circumstances which are subject to the prior written agreement of the Planning Authority.” IDL have sought the prior written approval of the Planning Authorities to extend the start time to 7.30 am to ensure construction traffic impact is minimised during peak traffic times.


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SECTION D: INFRASTRUCTURE & OPERATION

D.1. Operational Information Requirements

Describe the plant, methods, processes, ancillary processes, abatement, recovery and treatment systems, and operating procedures for the activity, to include a copy of such plans, drawings or maps, (site plans and location maps, process flow diagrams), and such other particulars, reports and supporting documentation as are necessary to describe all aspects of the activity. Maps and drawings must be no larger than A3 size. A development and operational history of the site should be included here. Operational Information Requirements

This information has been provided in a separate document included in Attachment D. Development and Operational History

Whiskey has been distilled and matured in Midleton since 1825. In 1975 a new distillery complex was built on this site and consolidated the production of Jameson and Powers from Dublin with Paddy from Midleton into a state of the art facility. The new Midleton Distillery complex was commissioned and began to produce whiskey in 1975 and at the same time had a capacity to produce 21 million litres of alcohol per annum. Significant investment was made in the Distillery by Pernod Ricard in 1999 and as a result the capacity increased to 33.5 million litres of pure alcohol per annum. Midleton has been near full capacity for the last two years and sales projections indicate it will need additional capacity in 2013. This additional capacity will require the expansion of the following facilities:

• Fermentation – there is a need for an additional 24 tanks for the fermentation process.

• Still House – there is a need for a new still house to provide the capacity for the Pot Line distillation process.

• Still House Tankfarm – there is a need for a new tankfarm associated with the still house.

• Distillation Columns – there is a need for 6 new distillation columns to distil the alcohol.

• Columns Tankfarm – there is a need for a new tankfarm associated with the distillation columns.

• Fire Water Retention Pond – there is a need to install a new retention pond on site to protect the environment in the case of an emergency. A report on this was previously submitted to the EPA in January 2012 and is included in Attachment J1.

• Process Water – there is a need to augment the supply of water by abstracting ground water from 8 boreholes.

• Increase the treatment capacity of the existing wastewater treatment plant.


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IDL has previously received approval from the EPA, under Condition 1.2 of their existing licence, to install a new water treatment plant. Since 1998, IDL have sought and received planning permission from Cork County Council for the following developments on-site.

Planning

Reference No.

Development Description

98/448 Construction of warehouse

99/974 Construction of 2 No. warehouse blocks

00/278 Construction of 3 No. warehouse blocks

00/3900 Construction of extension and alterations to existing Workshop facility.

00/5743 Alterations and extension to existing Brew House building

00/7215 Alterations and extension to Spirit Store to include MCC room, canopy to house barrel unloading mechanism and install roller shutter door.

00/7472 Retention of Electrical Switchroom

01/1579 Retention of building to house Reverse Osmosis equipment

01/2613 Construction of Laboratory building linked to Office block and alterations and extensions to existing building to provide stores and offices.

01/6673 Construction of a new sign at main site entrance.

03/6030 Retention of extension to Spirit Store for use as an electrical switchboard room

03/6520 Upgrading of wastewater treatment plant to include an aeration tank with associated sumps and platforms, a control building / plant room and miscellaneous tanks and items of equipment.

04/3669 2 No. warehouse blocks

04/6855 Construction of pallet storage shed and fork lift access road.

05/5032 Retention of 20 No. Fermenters, cold wash charger, beer well and access walkway and permission for erection of 4 No. Fermenters and 2 No. hot water tanks.

06/10477 Construction of retention pond and ancillary drainage work.

07/7646 Construction of 22 No. warehouses in 4 No. blocks of 4 with attached ancillary pumphouses, landscaping and associated works and services.


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Planning

Reference No.

Development Description

08/5953 Mechanical Vapour Recompression (MVR) Evaporator Unit with associated fan building, electrical switchroom, access stairs and platforms, electrical transformer and relocation of exit door to the existing Feeds Recovery building and retention and completion of stillage storage tanks on a bunded base.

09/7565 Construction of extension to existing Vat House to facilitate a new Motor Control Centre (MCC) and all ancillary site development works.

10/8126 Completion of erection of 4 No. fermenters and 2 No. hot water tanks granted under planning permission (Reg No. 05/5032).

11/06248 Construction of a 3 storey, 573 square meter extension to the existing Brew House.

11/06531 Current site expansion – copy provided in Attachment B5.

Proposed Construction Schedule for Site Expansion

The dates provided below are approximate but they provide an overall view of the proposed construction schedule for the site.

Location Construction Completion Date

Brew House Extension July 2012

New Still House Jan 2013

New Still House Tank Farm Nov 2012

New Fermenters Tank Farm Nov 2012

New Columns Structure (Phase 1 – Wash) Dec 2012

New Columns Structure Tank Farm Nov 2012

New Firewater Retention Pond Jan 2013

Wastewater Treatment Plant Upgrade Q4 2013

Commissioning of the new plant will commence shortly after construction work has been completed in each area. Attachment No D should contain a list of all unit operations (processes) to be carried out, including flow diagrams of each with any relevant additional information.

Attachment D describes the processes carried out on-site. This attachment also includes simplified process flow diagrams and identifies the various emissions associated with each process. The following drawings are also provided in Attachment D: Drawing No. 1 Site Services Layout (Natural Gas) Drawing No. 2 Location of Existing and Proposed Unit Operations


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SECTION E: EMISSIONS

E.1. Emissions to Atmosphere

E.1.A. Details of all point emissions to atmosphere

Details of all point emissions to atmosphere should be supplied. Complete Table E.1(i) for Boiler Emissions and Table E.1(ii) and E.1(iii) for all other main emission points. Complete Table E.1(iv) for minor emission points. A summary list of the emission points, together with maps and/or drawings (no larger than A3), and supporting documentation should be included as Attachment No E. Plans of emission elevations, relevant roof heights, etc., should also be included, as should detailed descriptions and schematics of all abatement systems. The applicant should address in particular any emission point where the substances listed in the Schedule of EPA (Licensing)(Amendment) Regulations 2004, S.I. No. 394 of 2004, are emitted.

For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s). These notes can be found on the EPA website at www.epa.ie. E.1.B. Fugitive and Potential emissions

Give summary details of fugitive and potential emissions in Table E.1(v). In relation to activities listed in the Schedule of Council Directive 1999/13/EC (for VOC Solvents Emissions) S.I. No.543 of 2002 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations;

− specify the relevant category of activity in the Schedule − specify how the requirements in relation to fugitive emissions will be met.

Full details and any supporting information should form Attachment E.1.B

E.1.A – Introduction

Tables E.1(i) to E.1(iv) have been completed for all atmospheric emission points. As well as the information provided below for the various emission points, Section 15 of the EIS presents a complete discussion on Air Quality and Climate. In particular, it assesses the potential impacts on ambient air quality from the proposed distillery expansion and takes into account emissions from the main on-site emission points and minor emission points which could contribute to offsite odour issues. The assessment addresses the following parameters:

• Carbon Monoxide • Oxides of Nitrogen • Sulphur Dioxide • Total Particulate Matter • Odour


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Under the conditions of the site’s existing Greenhouse Gas (GHG) Permit (No. IE-GHG005-03), there are a number of emission points licenced, as follows: A1-1 Production Boiler A (referred to as Boiler 1 in the GHG permit) A1-2 Production Boiler B (referred to as Boiler 2 in the GHG permit) A1-3 Production Boiler C (referred to as Boiler 3 in the GHG permit) A5-1 Office Boiler A5-2 Central Lab Boiler A3-1 Diesel Engine (Sprinkler Pumphouse) AHU-1 Spirit Store Heater (W) AHU-2 Spirit Store Heater (E) AHU-3 Cask Store Heater AHU-4 Engineering Stores Heater A4-1 Cooperage Boiler HU1 Cooperage Heater 1 HU2 Cooperage Heater 2 With the exception of the main boilers (A1-1, A1-2 and A1-3), the other GHG emission points have not been included in the IPPC Licence review application as they are already licensed under the GHG permit conditions. In order to avoid confusion, the following ID numbers have not been used in the IPPC Licence review application:- A5-1, A5-2, A3-1 and A4-1. E.1.A (i) Boiler Emissions

There are three main boilers located on-site which provide over 95% of the site’s hot water requirements and all of the site’s steam requirements. These boilers have their own individual stacks for monitoring purposes. These three stacks are then located within one boiler stack as shown in the Stack Configuration diagram below.

Stack Configuration Production Boiler A utilises both natural gas and fusel oil as it’s energy supply input. Production Boilers B & C utilise natural gas only. There are no planned changes associated with the existing boilers and the EPA has previously been informed of the operation of these boilers both as part of the original IPPC Licence Application in 1998 and the Greenhouse Gas Permit application.


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E.1.A (ii) Main Emissions

Fermentation Tanks

In the 1998 IPPC Licence Application, the fermentation tanks were considered as one main emission point (A2-2). The same strategy is being proposed for the licence review application with all the existing and new fermentation tanks being considered as one main emission point (A2-2). Tables E.1 (ii and iii) have been completed for this emission point. The calculated CO2 emissions identified in Table E.1(iii) from all 46 fermenters is based on an annual production volume of 64 million litres of pure alcohol. Feeds Recovery Stack

There are no changes planned for the Feeds Recovery Stack (A2-1), however Tables E.1 (ii and iii) have been completed. Section I.1 addresses those emission points where the substances listed in SI No. 394 of 2004 (EPA (Licensing)(Amendment) Regulations) are emitted. E.1.A (iii) Minor Emissions

Since the original IPPC licence application in 1998 there have been a number of changes to the processes on-site and for which approval was given by the EPA under various Condition 1.2 letters. IDL made a decision at the beginning of this licence review to undertake a complete assessment of the minor emissions associated with both the existing and proposed site process activities. As a result of this assessment all existing and future minor emission points have been identified and renumbered. In relation to existing atmospheric emission points no additional information has been provided as these have already been approved by the EPA under the original IPPC licence application back in 1998 or under separate Condition 1.2 approvals since then. In relation to new atmospheric emission points details of the expected emissions have been provided where information is available.


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E.1.B Fugitive & Potential Emissions

E.1.B(i) Fugitive Emissions

In the original licence application in 1998 emissions from storage tanks / vats that passed through flame arrestors were considered minor emission points. Based on the IPPC Licence Application Guidance Note from the EPA, IDL has taken a decision to identify all emission points from storage facilities (tanks/vats) as fugitive emissions and identified these under A5-nn. These are listed separately in Attachment E1. As part of this licence review application, IDL has completed calculations to quantify fugitive emissions from the new storage tanks to be located within the:

a) Still House Tank Farm b) Still House Building c) Distillation Column Building Tank Farm

In order to complete the study, reference was made to the following US EPA publication: “AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1, Stationary

Point & Area Sources, Chapter 7 – Liquid Storage Tanks.”

For each storage vessel, both the standing and working losses of alcohol were calculated in accordance with the method outlined in the above document. A summary of the results is provided in the table below. The total loss of alcohol through the flame arrestor vents on each storage tank comes to 19,975 kgs per annum. This is based on a production output of 64 million litres of pure alcohol per annum. This equates to total fugitive emissions from these storage tanks of 0.04% of the total production output. In terms of the overall site, the total fugitive emissions are considered to be less than 0.08% of the total production output. This is allowing for fugitive emissions from the Vat House receiver vessels and some emissions from the existing Still House which may be used as a future R&D plant.


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Fugitive Emissions Study on New Tank Farms Storage Vessels

Material Storage Tank ID Alcohol Tank Volume Standing Losses Working Losses Total Losses Comments for Total Average Loss per Tank

% m3 kgs/yr kgs/yr kgs/yr Losses Calculation kgs/yr

Grain Spirit Q-3611 95% 190 636.60 1402.18 3,948.58 4 tanks included in standing losses 987.14

Q-3612 95% 190 1 pump allowed for working losses

Q-3613 95% 190

Q-3614 (future) 95% 190

Columns Feint Reciever Q-3616 95% 100 446.30 448.79 895.08 895.08

Pot Spirit Receiver Q-3831 85% 60 344.87 249.33 2,567.86 6 tanks included in standing losses 427.98

Q-3832 85% 60 2 pumps allowed for working losses

Q-3833 85% 60

Q-3834 (future) 85% 60

Q-3835 (future) 85% 60

Q-3836 (future) 85% 60

7's Receiver Q-3841 85% 60 344.87 0.00 1,034.60 3 tanks included in standing losses 344.87

Q-3842 85% 60

Q-3843 85% 60

Pot Feints Receivers Q-3837 85% 30 159.72 276.51 1,191.91 4 tanks included in standing losses 297.98


Q-3839 85% 30

Q-3840 (future) 85% 30

Low wines Receivers Q-3825 45% 40 212.68 242.40 1,335.50 4 tanks included in standing losses 333.88


Q-3827 (future) 45% 40

Q-3828 (future) 45% 40

Secondary Low Wines Receivers Q-3829 60% 40 212.68 510.34 935.69 2 tanks included in standing losses 467.85

Q-3830 60% 40 1 pump allowed for working losses

Wash Recyle Tank Q-3617 95% 100 446.30 0.00 446.30 446.30

Intermediate Still Charger Q-3816 70% 60 344.87 621.42 966.29 966.29

heat contents to 60degC in 4 hrs

Spirits Still 1 Charger Q-3819 70% 60 344.87 500.94 2,036.48 3 tanks included in standing losses 678.83

heat contents to 60degC in 4 hrs Q-3822 (future) 70% 60 2 pumps allowed for working losses

Q-382x (future) 70% 60

Hot Wash Charger Vessel Q-3815 15% 80.0 393.71 1035.22 1,428.94 1,428.94

heat to 70degC, also CIP'd

Drop Tank Q-3618 5% 190.0 700.29 1035.22 2,435.81 2 tanks included in standing losses 1,217.91

Also CIP'd Q-36xx (future) 5% 190.0 1 pump allowed for working losses

Low Wines Collection Vessel Q-3712 45% 5 18.82 158.83 177.65 177.65

Secondary Low wines collection vessel Q-3718 60% 5 18.82 447.32 466.14 466.14

Pot Spirit Collection Vessel Q-3721 85% 2.5 12.51 95.15 107.66 107.66

Total Losses 19,974.48


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E.1.B(ii) Potential Emission Points

In the original licence application in 1998 there was one potential emission identified for the site (A4-1 Bursting Disc on Pot Stills Drop Tank). Since then the bursting disc has been changed to a flame arrestor and therefore this emission point has been re-categorised as a fugitive emission. As part of this application, new potential emission points have been identified and these are included in Table E.1(v). Potential emission points have been identified based on emissions under abnormal operations that contain raw material or product and that are emitted to the external atmosphere.

Drawing No.’s 3 to 11 in Attachment E.1 show the locations of all atmospheric emission points (boiler, main, minor, potential and fugitive).

E.1.B(iii) VOC Solvent Emissions

IDL activities do not come under Council Directive 1999/13/EC for VOC solvent emissions. E.1.B(iv) Pressure Relief Venting

The above ground storage tanks (Still House and Columns Building Tank Farms) and the Still / Wash Pots are equipped with normal vents (venting through flame arrestors) and emergency relief vents to comply with European design standards. The normal vents permit vapours to be released from the tank / stills due to filling, evaporation, and changes in ambient temperatures. The emissions from these have been calculated and are included in Tables E.1(iv) for the minor emission points and Attachment E1.1 for the fugitive emission points. Normal vents also prevent a vacuum from developing when contents are dispensed or in the case of the Still/Wash Pots rapid cooling during cleaning operations. When storage tanks are located above ground, EPA and other guidance require that secondary containment is provided. When these tanks contain ignitable liquids, these liquid releases may pool around the tank, producing a direct fire exposure. Emergency relief vents are larger than normal vents and are sized to allow vapours produced by sudden or extreme heating of the tank contents, due to an exposure fire, to escape without pressurizing the tank or Pot/Wash Still beyond its design limits. These relief vents are required to deal with major accident scenarios and are not considered an environmental emission point in the context of the EPA classification system of atmospheric emission points.

E.1.C Discussion on BAT Guidance Limits

E.1.C(i) Boilers

The BAT Guidance Note for the Large Combustion Plant (LCP) Sector and the Industrial Emissions Directive (IED) (2010/75/EU) have been reviewed as they may apply to the site as the three boilers have a combined thermal input capacity greater than 50 MW. The relevant limit values for gas fired boilers are as follows:


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Parameter Units BAT Guidance

Note for LCP

Limit Value

IED

Limit Value

Sulphur Dioxide (SO2) mg/Nm3 10-35 35

Nitrogen Oxides (NOx) mg/Nm3 50-450 100

Carbon Monoxide (CO) mg/Nm3 - 100

Dust mg/Nm3 5 5

The existing NOx (as NO2) licence limit value for the boilers is 28 kg/hr (combined emission). This equates to a limit value for NOx of 778 mg/Nm3 at a combined flowrate of 36,000 Nm3/hr.

During recent rounds of monitoring in 2011 and 2012, the following NOx levels were measured:

Stack Units IDL Result

September

2011

EPA April

2012

A1-1 mg/Nm3 107 194

A1-2 mg/Nm3 101 204

A1-3 mg/Nm3 115 173

Results have been corrected to 3% O2 Dry. For the assessment on air quality the following emission level concentrations were used for the three boiler stacks.

Parameter Units Emission Level

Concentration

Flowrate (Combined Total of all 3 Stacks)

Nm3/hr 36,000

Sulphur Dioxide (SO2) mg/Nm3 10

Nitrogen Oxides (NOx) mg/Nm3 250

Carbon Monoxide (CO) mg/Nm3 10

Dust mg/Nm3 5

The air quality assessment identified that by using these emission levels there were no exceedances of the offsite impact criterion (Table 15.16 of the EIS – Page 165). With the exception of Nitrogen Dioxide all emission level concentrations are within the IED limit values while all are within the BAT level for LCP. IDL is seeking a limit value of 250 mg/Nm3 for Nitrogen Oxide emissions as part of this licence review due to: a) The results of the air quality assessment showing offsite compliance with relevant air

quality standards and,


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b) The boilers were manufactured and installed in 1975. Requested Limit Values for Boiler Emissions

Parameter Units Stack A-1 Stack A1-2 Stack A1-3

Nitrogen Oxides (NOx) mg/Nm3 250 250 250

Carbon Monoxide (CO) mg/Nm3 10 10 10

As the EPA has previously been informed, the flowrate from the three stacks cannot be measured. During the annual monitoring programme, the air flowrate is theoretically calculated using inlet gas flow values to each boiler and exhaust flue gas Oxygen concentration. For the air dispersion modelling assessment, completed for the EIS (Section 15), a total air flowrate of 36,000 Nm3/hr for all three boiler stacks was used. Due to the existing monitoring port arrangement at the site it will not be possible to measure for particulates or sulphur dioxide in accordance with the EPA Guidance Note on Air Monitoring (AG2) and as a result it is requested that limit values are not set for these two parameters. These parameters would be expected to be low due to the use of natural gas as the fuel source for the boilers. The boilers are maintained on a six monthly basis through an external contractor – Pillingers. E.1.C(ii) Feeds Recovery

The Feeds Recovery Stack has an existing emission limit value for Total Particulate Matter of 50 mg/Nm3 (at mass flows>0.5 kg/hr). This is within the BAT Associated Emission Level for Emissions to Air of 5-50 mg/Nm3 for mass flow threshold greater than 200 g/hr. Therefore, there is no requirement to complete a full evaluation of the emissions from the feeds recovery stack. IDL are seeking to retain the existing emission limit values for the feeds recovery stack (A2-1). E.1.C(iii) Assessment of Emissions (Odour)

An assessment of all point and non-point sources with the potential to cause odour nuisance offsite has been completed and is discussed further in Section I of this licence review application. The complete assessment can found in Section 15 of the EIS.

E.2 Emissions to Surface Waters

Tables E.2(i) and E.2(ii) should be completed. A summary list of the emission points, together with maps/drawings (no larger than A3) and supporting documentation should be included as Attachment No E.2. The applicant should address in particular any emission point where the substances listed in the Schedule of EPA (Licensing)(Amendment) Regulations 2004 S.I. No. 394 of 2004, are emitted.

Details of all List I and List II substances listed in the Annex to EU Directive 2006/11/EC (as amended), contained in any emission must be presented. All surface water runoff


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and storm water drains discharging to surface water bodies must be included. A National Grid References (12 digit, 6E, 6N) must be given for all discharge points. The identity and type of receiving water (river, ditch, estuary, lake, etc.) must be stated.

Details of all substances listed in the European Communities Environmental Objectives (Surface Waters) Regulations 2009, contained in any emission must be presented. All surface water runoff and storm water drains discharging to surface water bodies must be included. A National Grid Reference (12 digit, 6E, 6N) must be given for all discharge points the identity and type of receiving water (river, ditch, estuary, lake, etc.) must be stated

For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s). E.2 Introduction to Surface Waters

The IDL site has a number of separate surface water catchment areas that discharge into various media – surface waters, sewer and to ground. The following sections of the EIS discuss various aspects of surface water emissions and should be read as part of this section of the IPPC Licence review application:

• Section 10 Water & Aqueous Emissions • Section 11 Hydrogeology • Section 12 Hydrology • Section 13 Ecology

Figure 10.5 of the EIS (Page 90) identifies five separate surface water catchment areas for the site as follows:

• Warehouse Catchment • Lower Fields Catchment • Car Park Catchment • Vat House Catchment • Production Area Catchment

E.2(i) Warehouse Catchment

The warehouse catchment serves the majority of the site’s warehousing area and conveys all collected run-off to a point on the old Mill Stream channel. The surface water emission point associated with this catchment area is SWE 3 and is included in the existing IPPC licence. The drainage system associated with this catchment area is shown in Drawing No. 12 in Attachment E2. Under normal operations rainwater runoff from this area is passed through a TOC monitoring chamber and if the TOC level is below 60 ppm then the runoff discharges into the Mill Stream. If the TOC level is above 60 ppm then an actuated valve on the stormwater drainage line is closed and the rainwater runoff is diverted to storage tanks associated with the site’s wastewater treatment plant (WWTP). In the event of a fire, a new firewater retention pond is being installed as part of the proposed expansion and a separate discussion on firewater runoff is included in Section J of this licence review application.


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As there is no planned development for this catchment area it is considered that there will not be any increase in rainfall runoff from the area to SWE 3. E.2(ii) Lower Fields Catchment

This area drains to ground at a place known as Fox’s Hollow. This is discussed in more detail under Section E.4 – Emissions to Ground. E.2(iii) Car Park Catchment

This area drains to ground. This is discussed in more detail under Section E.4 – Emissions to Ground. E.2(iv) Vat House Catchment

The Vat House catchment area discharges to the Mill Stream at IPPC Licence emission point – SWE 2. There is currently no continuous TOC monitoring associated with SWE 2. However, there is a procedure (EPP025) in place to close a manual valve on the discharge line to the Mill Stream in the event of a spillage in this catchment area. The drainage system associated with this catchment area is shown in Drawing No. 15 in Attachment E2. As with the warehouse catchment area the Vat House catchment area is included in the new firewater retention catchment area and this is discussed in further detail in Section J. As there is no planned development for this catchment area it is considered that there will not be any increase in rainfall runoff from the area to SWE 2. E.2(v) Production Area Catchment

Based on a risk assessment and the priority to protect the receiving waters of the Dungourney River, this catchment area is drained to the main pumping station where collected runoff combines with treated effluent from the site’s WWTP and then pumped as part of the “SE Final” discharge to the Rathcoursey Point outfall in Cork Harbour North Channel. “SE Final” is a licensed emission point to sewer. Further information on this discharge is provided under Section E.3 – Emissions to Sewer. E.2(vi) SWE 1 – Cavern Water

Apart from surface water runoff from the site there is an additional licensed discharge to surface water – SWE 1. Cavern water (groundwater) is used as cooling water (on a once through basis) on the fermentation tanks and some process equipment located within the Brew House and Still House. Please refer to Section 10.4 of the EIS (Page 83) for a description on the use of cavern water and it’s discharge to the Mill Stream or the WWTP depending on both the daily visual inspections and ongoing TOC monitoring. There is a separate drainage system for the cavern cooling water system on-site and this is shown in Drawing No. 17 in Attachment E2. As part of the site expansion the cooling water requirement for the site will increase from 2,560 m3/day to 6,120 m3/day. However, as it is intended to recycle some of the cooling


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water usage it is intended to increase the discharge requirement at SWE 1 from 2,560 m3/day to 4,020 m3/day. The impact of this increase in discharge volume is discussed in Sections 12 and 13 of the EIS and in Section 1.2 of this application. On SWE 1, IDL have agreed warning and actions levels of 15 and 20 ppm respectively with the EPA. When the TOC level reaches 40 ppm the actuated valve closes automatically and diverts the cavern water to the outlet of the WWTP. Depending on the TOC level it is possible to divert the cavern water to the WWTP for treatment. The valve will not reset until the TOC has returned to less than 20 ppm. The TOC analyser self calibrates once every 24 hours and zero’s itself once every 12 hours. E.2(vii) Firewater Retention

A new firewater retention facility is being installed as part of the development in order to protect offsite surface waters and this is discussed in more detail in Section J of the licence review application. E.2(viii) Schedule of EPA (Licensing)(Amendment) Regulations 2004 S.I. No.

394 of 2004

IDL has reviewed the list of substances for discharges to water and can confirm that there is a potential for substances to be discharged which may have an unfavourable influence on the oxygen balance in the receiving waters from SWE 1 to SWE 3. To protect against unfavourable influences on the receiving waters IDL has fitted continuous TOC analysers on two of the three discharge points to surface water (SWE 1 and SWE 3) and if a set TOC level is exceeded the discharge can be diverted away from the receiving waters. Section 1.2 also discusses these Regulations in the context of the proposed discharge from the IDL site.

E.2(ix) EU Directive 2006/11/EC

IDL has reviewed the list of substances listed under Annex 1 of this Directive and can confirm that none of the listed substances are discharged to SWE 1, SWE 2 and SWE 3. E.2(x) European Communities Environmental Objectives (Surface Waters)

Regulations 2009

As indicated previously, TOC analysers are fitted on two of the three discharge points to surface water (SWE 1 and SWE 3). There was some monitoring undertaken by White Young Green (WYG) in 2011 of the Dungourney River in relation to the Surface Water Regulations. These results and assessment have been included as additional information supplied with the EIS and referred to in Section I.2 of this review application. The results would suggest that existing and future surface water emissions from the site to Receiving Waters will not lead to any exceedance of the 2009 SW Regulations outside of the relevant mixing zones.


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The emission details included in Table E.2(i) for SWE 2 and SWE 3 are based on figures provided in the table below.

Location Catchment

Area (m2)

Normal (m3/day)

Based on Annual

Average of 1100

mm/yr

Maximum (m3/day)

25 mm of rainfall

SWE 2 18,093 55 452

SWE 3 102,761 310 2,569

The emissions to SWE 1 are based on cooling water usage and have previously been discussed in Section E.2(vi). Emissions from SWE 1 are within BAT associated emission levels and are discussed further in Section I.2. E.3 Emissions to Sewer

Tables E.3(i) and E.3(ii) should be completed. A summary list of the emission points, together with maps and/or drawings (no larger than A3) and supporting documentation should be included as Attachment No E.3. Details of all List I and List II substances listed in the Annex to EU Directive 2006/11/EC (as amended), contained in any emission must be presented. All relevant information on the receiving sewer, including any effluent treatment/abatement systems, not already described, with schematics as appropriate should also be included in Attachment No E.3. For emissions outside BAT guidance limit (where given), a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within any limits set out in the BAT guidance note(s). E.3 Introduction

Section 10 of the EIS provides a comprehensive discussion on water usage at the site and the main sewer / surface water emissions. Figure 10.1 in the EIS (Page 80) details the sites current and future water cycle. There are a number of emissions to sewer from the site as follows: SE 1 Outlet from on-site wastewater treatment plant (WWTP). The on-site WWTP

treats organic process effluent and condensate from the MVR process. SE Final Combined discharge of WWTP effluent from SE 1, cooling tower blowdown,

rainfall from the production area and cavern water diversion (excess water / high TOC) to Cork County Council industrial sewer.

SE 2 Foul effluent from offices / canteen / toilets to Heritage Centre foul sewer

and then to Cork County Council foul sewer. (Please note that this is different to the SE 2 emission point that was

provided in the original IPC Licence application form. That SE 2 did not

become a licensed emission point in Licence P0442-01). At the time of the

original application back in 1998, foul effluent was being discharged to a

septic tank, however it is now discharged to Cork County Council’s foul

sewer.


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E.3(i) SE 1 & SE Final

SE 1 and SE Final are existing IPPC licence emission points and have associated emission limit values (ELV’s). Tables E.3(i) and (ii) have been completed based on the existing ELV’s with the exception of SE 1 where the flow limit has been increased from an existing ELV of 1,250 m3/day and 75 m3/hr to 2,500 m3/day and 150 m3/hr. A description of the existing WWTP and future capacity increase options is provided in Section F of this licence application. The BAT associated emission levels for discharges to water are provided below alongside the existing ELV’s for the SE 1 and SE Final.

Parameter Units BAT* SE 1 ELV

(Existing)

SE Final

(Existing)

SE Final

(Proposed)

pH 6 – 9 - 6.5 – 9.0 6.5 – 9.0

BOD mg/l 20 – 40 - 25 25

COD mg/l 125 – 250 125 125 125

Suspended Solids mg/l 50 35 35 35

Total Nitrogen (as N) mg/l 5 – 25 - 15 15

Oils, Fats & Grease mg/l 10 - 15 20 20 20

* BAT Guidance Note for the Brewing, Malting & Distilling Sector. With the exception of oils, fats and grease (OFG’s) all other parameters have existing ELV’s within the BAT associated emission level. It should be noted that the BAT associated level is for emissions to water and not to sewer. Therefore the existing limit of 20 mg/l for OFG’s is considered appropriate for the site and does not require a planned programme of improvement to meet the lower BAT level range of between 10-15 mg/l. Figure 10.4 in the EIS (Page 86) shows the route the discharge from SE Final takes to its final discharge location at Rathcoursey Point. The impact of the combined IDL and Midleton municipal WWTP’s on the receiving waters is discussed on Pages 86-88 of the EIS. The main issue to note is that as part of the planning permission conditions issued by Cork County Council for the proposed expansion a new tidal holding tank will be required at Rathcoursey prior to discharging to Cork Harbour. It is also important to note that the combined discharge at Rathcoursey Point is licensed by the EPA separately (D0056-01) with Cork County Council being the licensee. Drawing No.’s 16, 18, 19 and 20 in Attachment E3 identify the various process effluent drainage systems associated with SE 1 and SE Final. These drawings include the new drainage system tie-ins associated with the plant expansion.


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E.3(ii) SE 2 – Foul Sewer

Emission point SE 2 discharges all separately collected foul effluent from the site to the Heritage Centre foul sewer and from here it then discharges into Cork County Council’s foul sewer located in Midleton Town. Drawing No. 21 in Attachment E3 shows the current and future layout of the foul sewer. All the foul effluent (existing and future) is directed to a pumping chamber located to the north-east of the proposed firewater retention facility. The effluent is pumped from here to another manhole located on the north-west side of the proposed firewater retention facility and then from here it passes through the site’s IPPC licence site boundary and into the Heritage Centre’s foul sewer by gravity. For the purposes of this licence application the emission point is located at the pumping chamber. With the exception of the Cooperage Building there is no other foul effluent discharged into the foul sewer from the IPPC licensed area prior to it entering the Heritage Centre foul sewer. As part of the site expansion there will be some slight changes made to the foul sewer to move it away from new structures / buildings. However, there is no need to increase its pipeline capacity even though it has been assumed that the foul effluent generated on-site may increase from 20 m3/day to 40 m3/day following the completion of the expansion works. These figures include effluent from the visitor centre. This is what is discharged at the County Council sewer at the visitor centre and not the on-site pumping station. It is not planned to monitor the discharge from this sewer for any parameters. The combined discharge is passed through a flow monitoring device at the last manhole located in the visitor centre site to enable Cork County Council charge IDL for the treatment of foul effluent in the Midleton Town WWTP. E.3(iii) EU Directive 2006/11/EC

IDL has reviewed the List I and List II substances identified in Annex 1 of this Directive and can confirm that there are no discharges to sewer containing any of these substances.


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E.4 Emissions to Ground

Describe the existing or proposed arrangements necessary to give effect to Council Directive 80/68/EC on the protection of groundwater against pollution by certain dangerous substances. The applicant should supply details of the nature and quality of the substance (agricultural and non-agricultural waste) to be landspread (slurry, effluent, sludges etc) as well as the proposed application rates, periods of application and mode of application (e.g., pipe discharge, tanker) having regard to, European Communities (Good Agricultural Practice for Protection of Waters) Regulations 2009, S.I. No 101 of 2009. For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s). E.4 Introduction

There are two identified emissions to ground from the site – GE 1 and GE 2. Both emissions relate to surface water runoff from hardstanding and roof areas. E.4(i) GE 1 – Lower Fields Surface Water Drainage

In October 2006, IDL informed the EPA under Condition 1.2 of it’s IPPC Licence, that they intended to construct 17 warehouses in the Lower Fields area. The Lower Fields catchment area drains into an active karst swallow hole known as Fox’s Hollow. The drainage system has been designed to discharge water through a flow control chamber. Stormwater runoff will normally pass through this chamber via a motorised valve upstream of an oil interceptor. This interceptor will remove any traces of oil and also settle out any suspended solids. If the TOC level (60 ppm) is exceeded an alarm is activated and the valve automatically closes. This will cause the stormwater flow to be diverted to the existing retention pond located at Fox’s Hollow. Water held within the retention pond will only be released to Fox’s Hollow once the TOC level has come back to within acceptable limits. The retention pond has been designed to maintain a certain level of water at all times. Since the installation of this drainage system there has never been an exceedance of the TOC level. While no emission point ID number was provided in the October 2006 submission to the EPA, it has been decided to give this emission to ground the reference number – GE 1. The surface water drainage layout and emission point (GE 1) are shown on Drawing No. 13 in Attachment E4.


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E.4(ii) GE 2 – Car-Park & Offices Surface Water Drainage

(Please note that in the original licence application in 1998, the surface water drainage

system from the car-park and offices was included in the licence application as emission

point GE 3). Emission point GE 2 discharges surface water from the car park and offices area to an underground cavern network (via a soakaway) located close to the main vehicle entrance to the site. The catchment area for this discharge is shown in Figure 10.5 of the EIS (Page 90). The drainage system is shown on Drawing.No. 14 in Attachment E4. The car-park and office block area is considered to be a low risk area and therefore there has never been any requirement to monitor this discharge as part of the IPPC Licence. E.4(iii) 2010 Groundwater Regulations & BAT

Emissions to GE 1 are protected through the continual monitoring of TOC and the diversion valve in place should TOC levels increase above 60 ppm. The runoff water from the GE 2 catchment area is outside of production areas and relates to car-parks and office roof areas, therefore the risk of groundwater contamination is low. There are no emissions to ground outside of BAT levels. E.5 Noise Emissions

Give particulars of the source, location, nature, level, and the period or periods during which the noise emissions are made or are to be made. Table E.5 (i) should be completed, as relevant, for each source. Supporting information should form Attachment No E.5

For emissions outside the EPA Guidance Note for Noise in Relation to Scheduled Activities 2nd Edition (2006), a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the Guidance Note. Section 14 of the EIS discusses the assessment completed into the likely noise and vibration impact associated with the proposed development. This section, along with Section I.7 of this application discusses existing and predicted noise levels from the site. Table 14.13 in the EIS (Page 150) identifies sound power levels for various new equipment items. While these figures could be used to complete Table E.5(i) for each noise source, it is IDL’s preference not to complete these tables until such time as the relevant suppliers of the equipment have been identified. At that point the supplier would provide the necessary information once a decision has been finalised on the actual piece of equipment. The EPA recently prepared a new “Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4)”. AWN Consulting were requested to complete an updated noise survey for the site and assessment based on this new guidance note. This is discussed in more detail in Section I.7 of this licence review application.


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E.6 Tabular Data on Emission Points

Applicants should submit the following information for each emission point: Point

Code

Point Type Easting Northing Verified Emission

Provide label ID’s assigned in section E

A=Atmospheric SW=Surface Water SE = Sewer GW=Groundwater N = Noise SL=Soil/Ground WS=Waste

6E-digit GPS Irish National Grid Reference

6N-digit GPS Irish National Grid Reference

Y = GPS used N = GPS not used

e.g. SO2, HCl, NH3

An individual record (i.e. row) is required for each emission point. Acceptable file formats include Excel, Access or other upon agreement with the Agency. A standard Excel template can be downloaded from the EPA website at www.epa.ie. This data should be submitted to the Agency on a separate CD-Rom containing sections B.2, E.6 and F.3. See Attachment E.6 for a hardcopy of this information. This information has also been included on a separate CD-Rom, as requested. Please note that the standard excel template downloaded from the EPA website is

different to the one shown above, in that there is no column for “Emission”.


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SECTION F: CONTROL & MONITORING

Describe the proposed technology and other techniques for preventing or,

where this is not possible, reducing emissions from the installation/facility.

F.1: Treatment, Abatement and Control Systems

Details of treatment/abatement systems (air and effluent emissions) should be included, together with schematics as appropriate.

For each Emission Point identified complete Table F.1(i) and include detailed descriptions and schematics of all abatement systems. Attachment No F.1 should contain any supporting information.

F1.1 Emissions to Air

There are no abatement systems associated with any of the main boilers (A1-1, A1-2 and A1-3) or main air emission (A2-2). These systems currently have discharges within the existing IPPC licence emission limit values and therefore abatement is not required. There are cyclones located on the discharge from each dryer (A, B, C) and the pellet cooler. These cyclones remove solids from the exhaust air and divert the collected solids back into the mixing conveyor through rotary valves. The cyclones are cleaned weekly and they undergo a full maintenance overhaul once a year. The cyclones have been in place since the original licence application and the annual monitoring results of the feeds recovery stack (A2-1) show it to be compliant with its emission limit values. There is no requirement to change or alter the abatement systems associated with the Feeds Recovery process. F1.2 Emissions to Surface Water

As previously discussed in Section E.2, TOC levels are continuously monitored on the discharges from SWE 1 and SWE 3. The TOC analyser on SWE 1 self calibrates once every 24 hours and zero once every 12 hours and on SWE 3 the TOC analyser self calibrates every 24 hours.

F1.3 Emissions to Sewer

Wastewater Treatment Plant (Existing)

The main abatement system installed on-site is the site’s wastewater treatment plant (WWTP). Refer to Section 10 of the EIS (Pages 84 and 85) regarding the existing WWTP and one option being explored for the proposed expansion of the WWTP. A process flow diagram of the existing WWTP is provided in Attachment F.1. There are two main waste water streams treated on-site:

• The ‘MVR Condensate’ is fed directly from the feeds recovery plant to the Equalisation / Balancing Tanks. (MVR = Mechanical Vapour Recompression)


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• The other “organic” wastewater stream gravitates to the Reception Chamber. This stream is then pumped through Drum Screens to remove any large objects. The wastewater then gravitates to a pair of adjacent Equalisation/Balancing Tanks. The solids collected on the drum screen are discharged into a skip for offsite disposal.

The combined wastewater streams are then mixed/aerated by a set of air blowers. The mixed liquor gravitates to an adjoining Mixed Liquor Pump Sump, from where it is pumped to a Mixing Chamber and appropriate chemicals are added. The mixer is a submersible unit. The list of WWTP chemicals used on-site is included in Table G. The liquor gravitates from the mixing chamber to an Aeration Tank, within which it is aerated by a Fine Bubble Diffused Aeration system. A ‘splitter’ tank delivers, by gravity, the overflow from the aeration tank to a pair of Membrane Filters, where any fine solids are mechanically removed. The bioreactor (aeration lane) is operated at a biomass concentration of about 9 g/l up to a maximum allowable concentration of 10 g/l. The total system consists of 2 no. ZeeWeed® filtration trains, each designed to operate in parallel. The system has been designed to be capable of operating with a single filtration tank in the case of low hydraulic loading. The filtered liquor is pumped from the filters, by Permeate/Backpulse pumps, when in the ‘Permeate’ mode. This liquor may then be routed through an Air Blast Cooler, to reduce the temperature, before being discharged to a Permeate Pumping Station (PPS). From the PPS it can be pumped to either a subsequent re-use, associated with a cooling tower or to the existing Final Outfall Pumping Station (SE Final). The SE 1 licensed emission point is located at the WWTP permeate pumping station. The sludge from the Membrane filters is returned to the Aeration Tank, to maintain the biological treatment. Excess sludge is removed, by a pair of pumps, from the Aeration Tank and delivered to a Centrifuge. There is a poly-dosing system associated with the centrifuge to assist the liquids-solids separation process. The dewatered sludge is discharged into a skip and sent offsite for disposal. The existing treatment plant meets with the BAT requirements for the treatment of wastewater (Section 5.4.2 of the EPA’s BAT Guidance Document for the Brewing, Malting & Distilling Sector). With the exception of oils, fats and greases (20 mg/l) the existing licensed discharge parameters from the WWTP are within the BAT associated emission levels (Table 6.2 of the BAT Guidance document). Wastewater Treatment Plant (Proposed Options)

Option 1 – Doubling Capacity of Existing WWTP

One of two options being considered for the future expansion of the treatment plant to treat the additional wastewater volumes is essentially to double the capacity of the existing WWTP. Figure 10.3 in the EIS (Page 84) identifies the additional equipment required to be installed to meet the future site requirements with this option. The expanded treatment plant, as described in the EIS, will also meet BAT requirements.


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Option 2 – Anaerobic Treatment

A process flow diagram of the proposed Anaerobic Fermentation Process is included in Attachment F.1. a) Screening

The “Organic” waste stream will be passed through a 6mm automatic screen which will remove any particles liable to cause blockages in the WWTP. The screenings will be collected in a dedicated collection skip. b) Influent Pumping Station

Downstream of the automatic screen, the screened “Organic” wastewater and the MVR condensate will be combined in a raw influent pumping station. The raw influent pumping station will be equipped with 2 No. submersible pumps which will operate on a duty / standby basis and will pump the raw effluent to the influent balance tanks. The expected combined flow is 85 m3/hr and the raw influent pumps will be sized to each cater for 100 m3/hr. The raw influent sump will be provided with a level transmitter and level probes to control the operation of the pumps and provide the necessary monitoring and alarms. c) Balance Tanks

Two wastewater balancing tanks (each with 1,800m3 capacity) will be installed. The purpose of the balance tanks is to provide both biological load balancing for the WWTP and to provide hydraulic balancing of the influent. The combined volume of the balancing tanks equates to in excess of 1.5 days influent volume at the expanded site. Both tanks will be provided with submersible mixers and aeration facilities to ensure that the tank contents are maintained homogenised, fresh and suitable for biological treatment. The balance tanks will be constructed in a local partial bund. This bund will be connected, by gravity, to the proposed new firewater retention pond. Therefore, in the unlikely event of an overflow / spillage or leakage from the balance tanks, the contents will be contained. The balance tanks will work in series with the influent passing from Balance Tank No. 1 into Balance Tank No. 2 before being sent for treatment. d) pH Correction

Continuous pH measurement will be provided in Balance Tank No. 2 and pH correction chemicals (acid or alkali) will be administered as necessary to maintain the contents of the balance tank at a suitable pH for biological treatment. e) Biological Treatment Process

The biological treatment process that follows is: Anaerobic Fermentation => Aerobic Treatment => Membrane Separation

i) Anaerobic Fermentation

Anaerobic fermentation is a process where micro-organisms break down the organic matter contained in the raw influent into biomass and gas in the absence of oxygen. The gas produced contains methane which can be used as an energy source.


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ii) Conditioning:

Raw influent from the balancing tank will be pumped via duty / standby centrifugal pumps to the anaerobic fermentation conditioning tank. The influent will be conditioned to create stable and optimal environmental conditions for the anaerobic bacteria in the BIOBED ® EGSB reactor. In order to condition the effluent the following steps are taken within the conditioning tank:

• External recirculation with treated anaerobic effluent • Addition of nutrients and micronutrients • pH adjustment • Temperature adjustment

The external recirculation loop ensures that the optimum fluidisation velocity is maintained in the EGSB reactor thereby ensuring optimum performance of the process. The conditioning tank will operate at a temperature between 30-36oC. iii) Biobed ® EGSB Reactor:

The influent flow of conditioned wastewater will be distributed over the whole reactor surface area through a specially designed Influent Distribution System (IDS). The influent will pass a dense anaerobic ganular biomass bed where the biological conversion process takes place. Organic compounds are converted into mainly biogas and a small fraction (typically 2-4% of the COD load) of sludge. As the biogas is produced in the sludge granule it will decrease its settleability. The sludge granule will start to move upwards until the biogas is sheared off and the sludge granule settles back into the sludge bed. Three phase separators will be installed internally at the top of the reactor where the treated water is separated from the produced biogas and biomass. The reactor will operate at a temperature between 30-36oC. iv) Biomass Storage:

A sludge storage tank (50m3) will be installed to store the surplus anaerobic sludge produced in the reactor. v) Biogas Handling:

Biogas from the reactor will be diverted into a biogas storage bag or to a biogas flare. The biogas flare is only used in the case when the biogas cannot be used on-site in the new small combined heat and power (CHP) plant. Under normal operating conditions, the biogas will be directed to a CHP plant where it will be used to generate hot water and electricity. The hot water will be used to heat the influent entering the conditioning tank via heat exchangers. The electricity will be used for equipment located on-site. There is currently no technical information available for the proposed CHP plant. A separate submission will be made to the EPA and the Office of Climate Change in relation to the CHP plant if the decision is taken by IDL to proceed with Option 2 (Anaerobic Process). The air emissions from the flare and the CHP plant stack will be considered minor emission points.


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vi) Aerobic Treatment Process

As the anaerobic fermentation process is for “bulk” pollutants removal, the quality of the effluent from the anaerobic fermentation process is not suitable for direct discharge. An aerobic process downstream of the anaerobic process is necessary to “polish” the effluent prior to discharge. The existing aeration tank can be used for this process. Due to the provision of the anaerobic treatment process upfront of the aerobic process, the actual biological load to the existing aeration tank for the expanded site will be lower than the current load. Therefore the existing biological reactor and associated equipment (air blowers, etc.) have sufficient capacity for the plant upgrade. vii) Membrane Separation

The existing secondary clarification process consists of the use of membrane filtration to separate the biomass / sludge from the effluent flow. The current nominal capacity of the membrane filtration plant is 52 m3/hr. This existing capacity will need to be supplemented with additional capacity to provide an overall treatment rate of 104 m3/hr. Sludge Treatment (Both Options)

Two types of sludge are generated on the IDL site – one from the water treatment plant and one from the on-site wastewater treatment plant. A process flow diagram for future sludge treatment at the IDL site is provided in Attachment F.1. Water Treatment Plant Sludge

The sludge produced in the water treatment plant will be pumped to a dedicated sludge thickening tank, where the sludge will be thickened from circa 1% w/v to circa 3% w/v. Polymer will be dosed into the sludge thickening tank to aid thickening. The thickened sludge will then be transferred into a dedicated sludge storage tank from where it will be dewatered using a centrifuge. Supernatant from the sludge thickening tank and filtrate from the dewatering process will be pumped back to the aeration tank for aerobic treatment. Wastewater Treatment Plant Sludge

The sludge produced in the wastewater treatment plant will be pumped to a dedicated sludge thickening tank, where the sludge will be thickened from circa 0.6% w/v to circa 3% w/v. Polymer will be dosed into the sludge thickening tank to aid thickening. The thickened sludge will then be transferred into a dedicated sludge storage tank from where it will be dewatered using a centrifuge. Supernatant from the sludge thickening tank and filtrate from the dewatering process will be pumped back to the aeration tank for aerobic treatment. Sludge Dewatering

Decanter centrifugation will be used as the on-site dewatering system. The centrifuge can generate a consistent, dry dewatered sludge cake on a 24 hour basis whilst catering for different types of sludge. The main process control parameters for the successful operation of the centrifuge involve polymer flow, solids loading, hydraulic loading and differential speed. The performance of the centrifuge will be gauged on the cake and the centrate dried solids content. The centrate will be pumped back to the aeration tank.


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Licence Parameters

As discussed in Section E of this licence review application, it is intended to seek the existing IPPC licence parameters for the treated effluent (SE 1) with the exception of an increase in flow. Both treatment plant options will be able to meet these licence limit values. WWTP Options

At the time of this licence review application a final decision has not been taken by IDL in relation to which option will be used to provide the necessary wastewater treatment in the expanded site. Both options comply with BAT associated emission levels and incorporate BAT identified technology as identified in the BAT Guidance Note for the Brewing, Malting and Distilling Sector. Once a decision has been taken by IDL, this will be notified to the EPA. If the anaerobic process is chosen, IDL will prepare a submission on the small CHP plant and flare for consideration by the EPA. However, there is currently no information available for inclusion with this licence application. No matter which option is chosen by IDL there is a requirement to install new equalisation tanks in order to cater for the increased load and to replace the existing old tanks. IDL is proceeding with installing 2 new glass lined tanks with a capacity of 1,800m3 each. These tanks will be located alongside the existing equalisation tanks and have been designed by Veolia. The tanks will be located in a kerbed area which will have its own drainage system that will be connected to the new firewater retention pond. Each tank will be fitted with a fine bubble diffuser mixing system and air blowers required for the diffuser system. F1.3 Emissions to Ground

As previously discussed in Section E, TOC levels are continuously monitored on the discharges from GE 1. The TOC analyser self calibrates once every 24 hours. There is no abatement / treatment technology employed for the surface water emissions from the car-park and offices as this is considered to be a low risk area.

F.2: Emissions Monitoring and Sampling Points

Identify monitoring and sampling points and outline proposals for monitoring emissions. Table F.2 (i) should be completed (where relevant) for air emissions, for emissions to surface waters, for emissions to sewers, for emissions to ground, and for waste emissions. Where ambient environment monitoring is carried out or proposed, Table F.2 (ii) should be completed as relevant for each environmental medium. Include details of monitoring/sampling locations and methods. Attachment No F.2 should contain any supporting information. Tables F.2 (i) and F.2(ii) have been completed. The monitoring proposed is the same as that is currently required under the existing IPPC licence with the exception of GW 05.


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Section I.5 of this application requests for GW 05 to be excluded from any future groundwater monitoring requirements. There are no new additional monitoring points being requested. Drawing No. 22 in Attachment F2 shows the locations of the proposed monitoring points for the site. F.3: Tabular Data on Monitoring and Sampling Points

Applicants should submit the following information for each monitoring and sampling point: Point

Code

Point Type Easting Northing Verified Pollutant

Provide label ID’s assigned in section F3

M=Monitoring S=Sampling

6E-digit GPS Irish National Grid Reference

6N-digit GPS Irish National Grid Reference

Y = GPS used N = GPS not used

e.g. SO2, HCl, NH3

An individual record (i.e. row) is required for each monitoring and sampling point. Acceptable file formats include Excel, Access or other upon agreement with the Agency. A standard Excel template can be downloaded from the EPA website at www.epa.ie. This data should be submitted to the Agency on a separate CD-Rom containing sections B.2, E.6 and F.3. Point source monitoring/sampling refers to monitoring from specific emission points (e.g. from a boiler stack or outlet from a wastewater treatment plant). Examples of ambient monitoring includes monitoring of ambient air quality (e.g. boundary or off-site) or monitoring of river quality upstream/downstream of an effluent discharge. See Attachment F.3 for a hardcopy of this information. This information has also been included on a separate CD-Rom, as requested. Please note that the standard excel template downloaded from the EPA website is

different to the one shown above, in that there is no column for “Emission”.


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SECTION G: RESOURCE USE AND ENERGY EFFICIENCY

G.1 Give a list of the raw and ancillary materials, substances, preparations,

fuels and energy which will be produced by or utilised in the activity.

The list(s) given should be very comprehensive, all materials used, fuels, intermediates, laboratory chemicals and product should be included. Particular attention should be paid to materials and product consisting of, or containing, dangerous substances as described in the EU (Classification, Packaging, Labelling and Notification of Dangerous Substances) Regulations 2003 [SI 116/2003] and Regulation (EC) No. 1272/2008. The list must classify these materials in accordance with both of these Regulations, and must specify the designated Risk Phrases (R-Phrases) and Hazard Statements. R-Phrases for each substance should be in accordance with Article 21 of the S.I 1272/2008. Tables G.1 (i) and G.1(ii) must be completed. Copy as required. Supporting information should be given in Attachment No G.

G.1 Introduction

Tables G.1 (i) and G.1 (ii) have been completed as required. A separate listing of laboratory chemicals has been included in Attachment G1 as previously agreed with the EPA.

G.2 Energy Efficiency

A description of the energy used in or generated by the activity must be provided. Outline the measures taken to ensure that energy is used efficiently and where appropriate, an energy audit with reference to the EPA Guidance document on Energy Audits should be carried out. IDL continually monitor the site’s energy usage to comply with:

a) Annual IPPC licence reporting requirements, b) Annual independent verification audits required under their GHG permit, c) Corporate reporting to Pernod Ricard.

IDL has an internal Key Performance Indicator (KPI) system which is closely monitored by both internal and corporate management teams. The largest energy saving project completed over the past few years was the installation of the MVR unit in the Feeds Recovery process. This has significantly reduced the site’s steam requirements and hence natural gas usage. As part of the site expansion programme a significant amount of design work has been completed over the past 18 months to design more energy efficient column distillation units and pot still units. As part of the annual reporting requirements to the EPA, the following energy and resource parameters are reported:

• Natural Gas • Electricity


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• Groundwater • Surface Water • Municipal Water

Since 1990 (Kyoto base year), IDL has monitored its gas and electricity usage in terms of “normalised usage per unit of alcohol”. The most recent graphs which include the 2011 figures are provided below.

The natural gas graph shows that there has been an ongoing reduction is gas usage per litre of pure alcohol produced. The introduction of the new MVR process in late 2008 / early 2009 reduced the site’s natural gas requirement but increased the site’s electricity requirement. These changes


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can be seen in the above two graphs. However, overall the site has reduced it’s energy requirement (measured as kWhr) with the introduction of the MVR process. IDL will continue to monitor its energy performance on a regular basis. In relation to water usage figures for 2009, 2010 and 2011 are provided in Table G.2 below.

Table G.2 – Water Usage Figures

Water Source 2009 2010 2011

(m3) (m3) (m3)

Groundwater 641,638 776,416 935,072

Surface Water 405,762 460,554 539,194

Municipal Water 43,237 51,806 48,274

Total Water 1,090,637 1,288,776 1,522,540

The increase in water usage has coincided with an increase in production on-site. Section 10 of the EIS discusses water usage. In 2010, the site produced 27.67 million litres of pure alcohol (LPA). The average daily water usage was 4,250 m3 spread over 303 production days. The future production figure for the site is 66 million LPA. This will require an average daily water requirement of 8,040 m3. Refer to Tables 10.1 and 10.2 of the EIS (Page 79) for a breakdown of the site’s water balance. This additional water requirement will come from the following sources:

• Cavern Water (existing source) (at higher abstraction rates but within limits of existing abstraction licence)

• Groundwater wells (new source) • River Water Abstraction (existing source)

(no increase in abstraction rate) • Municipal (Mains) Water (existing source)

(some increase in water supply) Energy Audits

Due to the significant energy costs for the site, IDL personnel will continue to monitor energy usage and identify projects that could potentially reduce the site’s energy requirements. From previous experience it has been found that the utilisation of internal resources to identify potential energy saving projects is better and more practical than the use of external consultants who may not understand the site processes. For this reason any ongoing requirement for site energy audits will be completed with IDL personnel and will be completed in accordance with relevant EPA Guidance Notes.


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Energy Reduction Projects

As part of the planned site expansion there are three main energy reduction projects being proposed. Each project is described below. Project 1: Improved Grain Column Distillation

Currently all three columns operate at atmospheric pressure and are driven independently of each other using indirect steam through a reboiler for the Beer Column and callandrias for the Extractive Distillation (ED) and Rectifying (EDR) Columns, respectively. As a result of this, they are energy intensive and are typically running at a thermal energy input of 3.663 kWh/lpa. The new 3 column unit will operate as an energy coupled process whereby the energy from the third column (Rectifying) will be used to preheat the material entering column 2 and the energy from column 2 will be used to preheat the material entering column 1 thereby reducing the overall steam requirement. The thermal energy input is expected to reduce to 3.004 kWh/lpa with electrical requirement increasing from 0.09 kWh/litre to 0.14 kWh/litre. The overall expected thermal energy saving is 29.05 GWh per annum. Project 2: Pot Stills Heat Recovery

Currently the pot stills are heated indirectly with steam. It is proposed to install additional equipment to recover some heat from the vapours by means of Thermal Vapour Recompression (TVR). This should provide a 36% energy saving on wash distillation. This saving is 4.24 GWh per annum based on 2011 production figures. Project 3: Low Temperature Brewing

The objective of the project is to reduce live steam demand by reducing the cooking temperature and by recovering heat from the flash vapour. The current process requires the mash to be heated in a loop to 150oC and then flash cooled to 63oC. Heat is not recovered. The new system requires grist to be mixed in a liquids jet solids mixer and then held at 85oC for a minimum of 90 minutes. The mash water gets its energy from heat recovery of the flash vapour and some small amount of live steam. The expected saving in energy is 9.9 GWh per annum based on 2011 production figures. IDL will continue to focus, at all levels across the site, on energy usage and will identify energy reduction projects through its QSE management system and in particular the Environmental Management Programme.


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SECTION H: MATERIALS HANDLING

H.1 Raw Materials, Intermediates and Product Handling

All materials should be listed in Tables G.1 (i) and G.(ii) of Section G. Details of the storage conditions, location within the site, segregation system used and transport systems within the site should be outlined here. In addition, information relating to the integrity, impermeability and recent testing of pipes, tanks and bund areas should be outlined. H1.1 Drainage Systems

As detailed previously in Section E of this licence review application there are a number of drainage systems associated with the site as follows:

• Surface water (various systems) • Foul effluent from toilets / showers / canteen etc. • Cooling water (cavern water) • Process effluent (organic) • Inorganic effluent (from cooling towers, boilers, seal waters etc. ) • MVR condensate line

Drawings of these drainage systems are included in Attachment E. In 2009, integrity testing of the foul sewer, MVR condensate line and process effluent (organic) drainage system was undertaken with recommended remedial works completed during 2010 on both the foul sewer and organic drains. The MVR drainage system was found to be in a satisfactory condition. This line will be retested during the 2012 summer shutdown period. These were reported to the EPA in the 2009 and 2010 AERs. These drainage systems are due to be retested during 2012 and this work will be completed as soon as the underground civil works for the site expansion project is completed. H1.2 Material Transport

Grain is brought to site in trucks and they discharge directly into the grain hoppers in the Grain Store / Brew House. The trucks are weighed on their way in and out of the site. From the Brew House through to the Spirit Store all production material is transported through above ground pipelines located on pipe-racks. Once the immature alcohol is discharged into butts / barrels in the Spirit Store, the material is then transported by forklift/conveyors to a truck located external to the building. The truck is loaded and this truck is then used to transport the butts / barrels to the relevant warehouse – either located on or offsite. These same trucks are used to bring the barrels back to the Spirit Store (following maturation) where it is unloaded by forklift/conveyors. The butts / barrels are emptied through a pipeline into Vat Receivers prior to blending. The blended material is then brought by above ground pipe to the tanker filling station where road tankers are filled before being sent offsite to external bottling plants.


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Material produced in the Feeds Recovery building is discharged from various storage tanks directly into trucks for offsite usage. There is a loading bay located within the Feeds Recovery building for this purpose. Sludge produced in the WWTP is discharged into covered skips and these are then brought offsite by a licensed waste contractor. There are also various movements of waste contractor’s trucks throughout the site collecting waste from different locations on-site. The existing waste storage compound, where the majority of the site waste is handled, is being moved as part of the site expansion and its new location is situated to the east of the WWTP. Figure 1.3 in the EIS (Page 4) shows the production flow for the site. H1.3 Storage Locations

There are a number of storage areas located throughout the site. These areas are used to store raw materials, intermediate and finished products and chemicals. The main storage areas (existing and proposed) are as follows:

• Grain Storage • Feeds Recovery (Intermediate and Finished Product) • Receivers / Vats (Intermediate and Finished Product) • Warehouses (Maturing Product) • Chemical Store • Water Treatment Plant

In 2009, IDL completed a bund integrity assessment on all fixed bunds located throughout the site. This assessment was included in the 2009 AER submitted to the EPA. A list of the existing bunds is provided in Attachment H1. This list also contains a preliminary listing of future bunds to be located on-site. All existing bunds have been designed in accordance with the existing IPPC licence conditions allowing for 110% capacity of the largest vessel within the bund. Drawing No. 23 in Attachment H1 identifies all the main bund locations on-site (existing and future) and the main storage areas. Please note that not all existing bunds have been shown on this drawing however all proposed new bunds and their locations are included. In relation to any new bunds they will be designed to meet the larger of the 110% capacity of the largest vessel or 25% of the total volume stored within the bunded area. Fermenters – New Storage Bunds

As part of the site expansion, it is necessary to install two additional bunds to cater for an increase in fermentation capacity. The first of the two bunds is currently being installed and will cater for 12 No. fermentation vessels, a beer well and cold wash vessels. There is also an allowance for a future water tank. The locations of the fermenter bunds (Bunds 54 and 55) are shown in Drawing No. 23. The second bund (Bund 55) will cater for 10 No. additional fermentation vessels. The bunds will be constructed from reinforced concrete and will be tested prior to the installation of any equipment in accordance with EPA Guidelines. Records of the integrity tests will be maintained on-site for future inspection.


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While the second bund is not yet being constructed it will be similar in design to the first bund (Bund 54) that is currently under construction. The sizes of the various storage tanks are as follows: Fermentation Vessels: 232 m3 Beer Well: 285 m3 Cold Wash: 285 m3 The EPA Guidance Note on Storage and Transfer of Materials for Scheduled Activities states that where retention is required the following capacity is to be provided, either locally or remotely, to a volume not less than the greater of the following: 1) 110% of the capacity of the largest tank or drum within the bunded area, 2) 25% of the total volume of the substance which could be stored within the bunded area. The design of the two bunds has allowed for the containment of 110% of the largest vessel located within the bunds. While the 25% capacity requirement could be achieved by raising the bund wall height from the existing design value of 1.6m to 2.0m, it is considered unsafe to do so from a health and safe aspect (eg. safe access, confined entry issues) and from a tank stability point of view in the event of the bund filling with process material. In order to provide for remote bunding, in the unlikely event of having to provide storage capacity of 25% of the total volume stored, the design of the new bunds will allow the overflow of material from the new bunds into the existing fermentation bunds. Two weirs are being installed to join the new bund (under construction) with the existing fermenter bunds. The weirs will be located 0.25m below the top of the bund wall and will connect to the existing bund through 2 No. 300mm diameter pipes. The existing fermenter bund is made up of 5 smaller interconnecting bunds (Bunds 17-21). The table below identifies the various storage tanks in each bund and the existing bund capacities.

Fermenter Bunds

Bund Ref

No. of Tanks &

Capacity (m3)

110%

capacity of

Largest

Vessel

25%

capacity of

Total

Volume

Bund

Volume

(m3)

Interconnected

Volume (m3) -

Existing

Fermenters

Interconnected

Volume (m3) -

New Fermenters

in Bund 54

Interconnected

Volume (m3) - New

Fermenters in

Bund 55

17 8 x 232 255.2 N/A 292.5

18 8 x 232 255.2 N/A 292.5

19 8 x 232 255.2 N/A 292.5

20 2 x 285 313.5 N/A 148

21 Empty N/A 108

54 12 x 232

2 x 285

55 10 x 232 255.2 580 Note 1

Note 1 - Design of bund not yet complete

??1750.5

313.5 838.5 617

1133.5


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In summary, the design philosophy to achieve the 25% storage capacity requirement for the new bunds is to allow Bund 55 overflow into Bund 54 and for Bund 54 to overflow into the interconnecting bunds (Bunds 17-21). Bunds 17-21 were all constructed in accordance with Condition 10.4.1 of IPPC Licence P0442-01. Bunds 17-21 have a combined capacity of 1,133.5 m3. The largest volume to be held within these interconnected bunds is 313.5 m3 leaving an available volume of 820 m3 for any overflow from the new fermenter bunds (Bunds 54 and 55). At this stage of the process, the material is not flammable and as such is not a cause of concern for the Health and Safety Authority (HSA). The HSA has been involved with the project since the planning application was submitted. All new and existing bunds are due to be integrity tested during 2012. H1.4 Drainage System Philosophy – Secondary Containment

a) SWE 2 / SWE 3

In order to provide secondary containment for the Spirit Store, Vat House and the tanker loading bay it is intended to carry out some modifications to the SWE 2 and SWE 3 drainage system. It is proposed to install a new surface water drain between SWE 2 and SWE 3 so that surface water runoff from the Spirit Store, Vat House and tanker loading bay areas can be directed to the monitoring chamber at SWE 3. The surface water from these areas currently discharges to SWE 2 – see schematics below. Under normal operations, the surface water runoff from the SWE 2 and SWE 3 catchment areas will pass through a newly split TOC monitoring chamber where separate TOC samples will be taken on each drainage system by the one TOC analyser. If the TOC levels are below 60ppm then the surface water will be discharged to the Mill Stream at SWE 3. If the TOC level from the SWE 2 catchment area exceeds 60ppm then Valve 2 on the outlet of the split monitoring will close and will divert the contaminated surface water to the 800m3 inlet chamber of the new firewater retention tank through the extended drainage system associated with the firewater pond. Valve 3 will remain open and discharge the surface water from the warehouse catchment area to SWE 3. If the TOC level from the SWE 3 catchment area exceeds 60ppm then Valve 3 on the outlet of the split monitoring chamber will close and will divert the contaminated surface water to the 800m3 inlet chamber of the new firewater retention tank. Valve 2 will remain open and discharge the surface water from the vat house catchment area to SWE 3. While the design of the system has not been finalised, there may be a requirement to keep Valve 1 located at the SWE 2 outfall in the event of unforeseen circumstances. Valves on SWE 3 and GE 1

The actuated valves on the SWE 3 and GE 1 drainage systems are normally in the closed position, with SWE 3 discharging to the WWTP sedimentation tanks and GE 1 discharging to the Lower Fields firewater retention pond respectively.


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The TOC analyser works in conjunction with a level probe in each monitoring chamber. When it starts raining the level in the TOC monitoring chamber will increase, thereby triggering the level probe which in turn starts the TOC analyser. The TOC analyser then goes through a calibration routine, rinsing, sampling and checking regime. If the TOC reading is between 0 and 60ppm, then the valves will open and discharge the rainwater to SWE 3 or GE 1. If the TOC reading is greater than 60ppm then the valves remain shut and the rainwater runoff will continue to be diverted to the WWTP sedimentation tanks and the Lower Fields firewater retention pond, as appropriate. As part of the future drainage system for SWE 3, as discussed above, the rainwater will be directed to the inlet chamber (800m3 capacity) of the firewater retention pond rather than the WWTP sedimentation tanks.


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SWE 2 Catchment Area

There will be some minor modifications carried out to the surface water drainage system in the SWE 2 catchment area. Internal floor drains in the Spirit Store and Vat House will be redirected to a new organic drain. This new drain will then be directed to a pump sump and from here pumped to the existing organic drainage system – refer to Drawing No. 18 in Attachment E3.1. Ramps will be installed at either end of the tanker loading bay and the kerbing improved in the area in order to provide containment within the area in the event of a tanker spillage. The drainage from the new containment area will discharge to the new organic drain being provided for the Vat House and Spirit Store.

Spirit Store

Area

Vat House

Area

Tanker Loading Bay

Area

SWE 2

Manual Valve 1

Existing System

Spirit Store

Area

Vat House

Area

Tanker Loading Bay

Area

Proposed System

TOC Monitor

Warehouse

Area

Valve 2 Firewater Pond

Internal 800m3

Chamber

Valve 3

SWE 3

Manual Valve 1

SWE 2


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New Waste Storage Area

A new waste storage compound has been constructed next to the wastewater treatment plant. Any liquid wastes stored in this area are provided with secondary containment. The surface water drainage from this area is currently passed through an oil interceptor and then discharged to the surface water drainage system for the process catchment area. This discharges to SE Final. This is a temporary measure. As part of the wastewater treatment plant (WWTP) upgrade it is intended to divert the surface water runoff from the waste storage area through the oil interceptor and into the reception pit of the expanded WWTP. Firewater Retention Pond

As previously discussed a copy of the Firewater Retention report was submitted to the EPA in January 2012 and is included in Attachment J1. The retention pond has been designed with an 800m3 inlet chamber which then overflows into the remaining capacity of the retention pond. The purpose of the 800m3 chamber is to capture any surface water diversions, due to elevated TOC levels, and to deal with these before they can contaminate the contents of any water within the remainder of the firewater pond. The contents of the 800m3 inlet chamber will be pumped into the drainage system discharging to SE Final which is equipped with TOC/pH continuous monitoring or into the on-site WWTP for treatment if a spillage has been known to have occurred on-site and which has been discharged into the inlet chamber. H.2 Describe the arrangements for the recovery or disposal of solid and

liquid wastes accepted into or generated by the installation/facility.

For each waste material, give full particulars of: (a) Name (b) Description & nature of waste (c) Source (d) Where stored and integrity/impermeability of storage areas (e) Amount (m3) and tonnage (f) Period or Periods of generation (g) Analysis (include test methods and Q.C.) (h) European Waste Catalogue Code (Council Directive 98/2008/EC) (i) Waste Category per EC Reg. 1069/2009/EC where relevant Where any waste would be classified as Hazardous Waste as defined in the Waste Management Acts, 1996 to 2011, this should be made clear in the information provided. Summary Tables H.1(i) and H.1(ii) should also be completed, as appropriate, for each waste. The licence/permit register number of the waste collection agent or disposal/recovery operator should be supplied as well as the expiry date of the relevant permits.


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Supporting information should form Attachment No H.2

Tables H.1(i) and H.1(ii) have been completed based on the wastes removed offsite during 2011. An estimate has been made in relation to future quantities of each individual waste stream. Please note that waste contractors can change and any new contractor used on-site has to comply with IDL’s own waste management procedures as well as the site’s IPPC licence conditions. All waste contractors are required to have their own waste permits / licences up-to-date. Waste contractors are regularly audited by the IDL QSE management team. Drawing No. 24 in Attachment H2 identifies the storage locations of the main waste streams, as follows:

• Rubble bin from grain intake • WWTP sludge • WWTP Screenings • Wood shavings from barrel coring • Waste from Reverse Osmosis water purification plant • Waste compound

H.3 Waste disposal by on-site landfilling

For wastes to be disposed of by landfilling on-site, full details of the disposal site should be submitted (to include inter alia, site selection procedures, location maps, (no larger than A3) geology, hydrogeology, operational plan, containment, gas and leachate management, post-closure care). Supporting information should form Attachment No H.3. There is no on-site landfilling of waste. There was historical landfilling of waste on site and this has been comprehensively dealt with by IDL in the original IPPC licence application back in 1998 and subsequent reports required under IPPC Licence P0442-01. There is ongoing monitoring of groundwater and landfill gas in this area and IDL are seeking to discontinue this monitoring due to the consistent negligible results obtained on a biannual basis over the past over the past 14 years.


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SECTION I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

Describe the conditions of the site of the installation.

Provide an assessment of the effects of any emissions on the environment,

including on an environmental medium other than that into which the emissions

are made.

Describe, where appropriate, measures for minimising pollution over long

distances or in the territory of other states.

I.1.Assessment of atmospheric emissions

Describe the existing environment in terms of air quality with particular reference to ambient air quality standards. As outlined in Section 15 of the EIS, air quality in the vicinity of the site is average / good and shows typical levels for a suburban area with all pollutants (carbon monoxide, nitrogen oxides, sulphur dioxides and PM10) within the relevant Irish and EU limits. The Air Quality Standards Regulations 2011 (SI No. 180 of 2011) supersede the Air Pollution Act, 1987 (Air Quality Standards) Regulations (SI No. 272 of 2002) and specify ambient air quality standard limit values for nitrogen dioxide, sulphur dioxide, particulates, lead, benzene and carbon monoxide and implement a number of European Directives. Section 15.2, Table 15.1 of the EIS outlines the relevant ambient air quality standards. Provide a statement whether or not emissions of main polluting substances (as defined in the Schedule of EPA (Licensing)(Amendment) Regulations 2004 S.I. No. 394 of 2004) to the atmosphere are likely to impair the environment. Section 15 of the EIS investigated the potential impacts on ambient air quality from the proposed expansion, particularly in relation to the main polluting substances (as defined in the Schedule of EPA (Licensing) (Amendment) Regulations 2004 S.I. No. 394 of 2004).

Principal Polluting Substance

S.I. 394 of 2004

Relevance

to IDL Site

Potential Impact

1 Sulphur dioxide and other sulphur compounds

Applicable Negligible

2 Oxides of nitrogen and other nitrogen compounds

Applicable Negligible

3 Carbon monoxide Applicable Negligible 4 Volatile organic compounds Applicable Fugitive emissions (ethanol) –

negligible impact 5 Metals and their compounds NA None 6 Dust Applicable Negligible 7 Asbestos (suspended particulates,

fibres) NA None

8 Chlorine and its compounds NA None 9 Fluorine and its compounds NA None 10 Arsenic and its compounds NA None 11 Cyanides NA None 12 Substances and preparations which

have been proved to possess carcinogenic or mutagenic properties

NA None


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or properties which may affect reproduction via the air

13 Polychlorinated dibenzodioxins and polychlorinated dibenzofurans

NA None

The impact assessment included the following main polluting substances: odours, carbon monoxide, oxides of nitrogen, sulphur dioxide and total particulate matter. The assessment (Section 15.6 and Table 15.16 of the EIS) demonstrated that the level of emissions (identified in Table E of this application) will not result in any air quality impact in line with both Irish and European assessment criteria limits and existing IPPC Licence (P0442-01) Limits as specified in Schedule 1(i) of the licence. Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made. Details of the potential impacts on air quality resulting from the operational phase of the proposed expansion are provided in Section 15.6 of the EIS. The impact assessment demonstrated that the level of emissions associated with the proposed expansion will not result in any air quality impact in line with Irish and European assessment criteria limits.

Attachment No I.1 should also contain full details of any dispersion modelling of atmospheric emissions from the activity, where required. When carrying out dispersion modelling, regard should be had to the "Guidelines for the Preparation of Dispersion Modelling Assessments for Compliance with Regulatory Requirements – an Update to Royal Meteorological Society Guidance" or similar guidelines from a recognised authority. Full details of the dispersion modelling carried out to predict the impact of the proposed expansion on the ambient air quality and at sensitive receptors is provided in Sections 15.3 and 15.6 of the EIS. As noted on Page 157 of the EIS, modelling was carried out in accordance with “Air Dispersion Modelling Guidance Document for Industrial Installations – Guidance Note AG4, EPA 2010.” The model demonstrated that the maximum cumulative predicted ground level concentrations of carbon monoxide, oxides of nitrogen, sulphur dioxide and particulate matter as PM10 and PM2.5 when the proposed facility is at 100% operation, are well within the specified air quality limit values (range of 5.02 to 72.57% of impact criterion) at each of the named sensitive receptors in the vicinity of the facility. Likewise, the maximum predicted ground level concentration of odour at the worst case receptor was 64% of the odour impact criterion. I.2. Assessment of Impact on Receiving Surface Water Describe the existing environment in terms of water quality with particular reference to environmental quality objectives and standards and any objectives and standards laid down for protected areas. Table I.2(i) should be completed. The existing environment in terms of water quality is described in detail in Section 12.3 of the EIS. Table 12.3 within the EIS presents the Biological Quality Ratings of the Dungourney River and Table 12.4 presents details of baseline monitoring results for physiochemical parameters. The biological water quality assessment shows the Dungourney River to be in Poor Ecological Status, both upstream and downstream of the IDL plant, but that IDL is not responsible for this unsatisfactory status.


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There are no proposed National Heritage Areas (pNHA), Special Protection Areas (SPA) or Special Areas of Conservation (SAC) or Groundwater Dependant Terrestrial Ecosystems (GWDTE) within 500m of the proposed development site. As the proposed development will result in an increase in coolant water discharging to the Dungourney River, which is upstream of two Natura 2000 sites, Special Area of Conservation 001058 (Great Island Channel SAC) and Special Protection Area 004030 (Cork Harbour SPA) and the site itself which is located approximately 1km from the Natura sites, a Natura Impact Statement (NIS) in accordance with European Communities (Birds and Natural Habitats) Regulations 2011 was prepared and was submitted with the planning application and EIS. A copy of the NIS is included in Attachment No B. Provide a statement whether or not emissions of main polluting substances (as defined in the Schedule of EPA (Licensing)(Amendment) Regulations 2004 S.I. No. 394 of 2004) to water are likely to impair the environment. As noted in the EIS (Section 12.3), the proposed development will not result in any negative impact to the local receiving waters or ground waters due to the increases in surface water arising on the site. Water uses in the process generate a number of aqueous streams that are required to be returned to the environment. These include spent cooling water (SWE 1 to Dungourney River), surface runoff at SWE 2 and SWE 3, process wastewater SE Final to CCC sewer (SE Final – discussed in Section I.3) and domestic wastewater SE 2 to Midleton Urban WWTP (discussed in Section I.3). SWE 1 - Spent Cooling Water

Presently, in the order of 2,560 m3 per day of spent cooling water from the underground cavern is discharged to the Dungourney River at IPPC Licence reference SWE 1 downstream of the Millstream tailrace (refer to Drawing No. 17, Attachment E2.1). Other than a slight increase in temperature, the cooling water is the same quality as when abstracted from the ground and is suitable for return to the local surface water environment. As a result of the expansion, the final maximum quantity of cooling water required to be returned to the environment following its immediate cooling duty is 4,020 m3/day. It is proposed that the spent cooling water will continue to be returned to the Dungourney River in the same manner as present. SWE 2 and SWE 3 - Surface Water Runoff

A small increase in the overall run off quantity will be confined to the production area catchment which drains to the site pumping station for discharge to the Cork Harbour outfall via SE Final (refer to Section I.3). The upper warehouse catchment serves the majority of the site’s warehousing area and conveys all collected run-off to a point on the old Mill Stream channel. The existing surface water emission point associated with this catchment area is SWE 3 and this is described in more detail in Section E.2 (i). As there is no planned development for this catchment area it is considered that there will not be any increase in rainfall runoff from the area to SWE 3. The existing Vat House catchment area discharges to the Mill Stream at IPPC Licence emission point – SWE 2. As there is no planned development for this catchment area it is considered that there will not be any increase in rainfall runoff from the area to SWE 2. A further description of SWE 2 can be found in Section E.2 (iv).


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Further detailed information on the surface water environment is available in Section 12.3 of the EIS.

Principal Polluting

Substance S.I. 394 of 2004

Relevance to

IDL Site

Potential Impact

1 Organohalogen compounds and substances which may form such compounds in the aquatic environment

NA None

2 Organophosphorus compounds NA None 3 Organotin compounds NA None 4 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.

NA None

5 Persistent hydrocarbons and persistent and bio-accumulable organic toxic substances

NA None

6 Cyanides NA None 7 Metals and their compounds NA None 8 Arsenic and its compounds NA None 9 Biocides and plant health

products NA None

10 Materials in suspension NA None 11 Substances which contribute to

eutrophication (in particular nitrates and phosphates)

NA None

12 Substances which have an unfavourable influence on the oxygen balance (and can be measured using parameters such as BOD, COD, etc.)

Applicable SWE 1 - Temperature increase. SWE 1, SWE 2 & SWE 3 – TOC Refer to Monitoring and Mitigation Measures

Monitoring and Mitigation Measures

Temperature Assessment

The temperature assessment as detailed in the EIS (Section 12.5 – Page’s 129/130) showed that the proposed condition would result in an acceptable level of temperature increase for most (95%) of the time. It is only during drought summer low flow conditions of the Dungourney River that the background water temperature would be exceeded by more than 1.5oC to about 2.2oC (an increase of 0.7oC) assuming a worst case scenario of a 23oC discharge temperature and full volume of discharge. As WYG noted in their submission made to Cork County Council as part of IDL’s response to planning queries in February 2012, (please refer to Attachment No. B5.6 for full details) there will be no impact on the existing Q rating of the Dungourney River as a result of the proposed increase in water discharge from the site as the potential rise in overall water temperatures during normal conditions is low and the mixing zone is restricted to a short portion of one bank of the river.


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As it is not proposed to discharge cooling water to the Dungourney River during low flow conditions there will be no impact on the Dungourney River, Owennacurra River or estuary (Refer to Attachment No. B5.7 Water Management Plan). Mitigation measures that will be adopted by IDL during these worst case conditions have been identified in the EIS (Page 131). Prior to commissioning of the groundwater production well IDL will gather background information from the section of the Dungourney River below the cooling water discharge as detailed in the Water Management Plan. Increased temperature will not affect the physio-chemical water quality parameters of the river apart from DO. However, the length of the Millstream through the old Distillery grounds, (including its use to drive the historic Mill Wheel), helps to oxygenate and reduce the temperature of the cooling water. Baseline data assessment in the EIS (page 124) indicated that there was no discernable change in river DO values downstream of the discharge from the Millstream to the river. The Q-Rating, which is based on the macro –invertebrates habitat of the river, will not be affected from the increased water volume. Water volumes within the river fluctuate on an ongoing basis due to rainfall, tidal influence etc and not only from cooling water discharges from the IDL site. TOC Monitoring

SWE 1: When the TOC level reaches 40 ppm the actuated valve closes automatically and diverts the cavern water to the outlet of the WWTP. Depending on the TOC level it is possible to divert the cavern water to the WWTP for treatment.

SWE 2: There is currently no continuous TOC monitoring associated with SWE 2. However, there is a procedure (EPP025) in place to close a manual valve on the discharge line to the Mill Stream in the event of a spillage in this catchment area. SWE 3: Under normal operations rainwater runoff from this area is passed through a TOC monitoring chamber and if the TOC level is below 60 ppm then the runoff discharges into the Mill Stream. If the TOC level is above 60 ppm then an actuated valve on the stormwater drainage line is closed and the rainwater runoff is diverted to storage tanks associated with the site’s wastewater treatment plant (WWTP). Water Management Plan (WMP)

A specific Water Management Plan (WMP) as required by Condition 25 of Cork County Council (CCC) Planning Permit and Condition 31 of Midleton Town Council (MTC) Planning Permit which details the monitoring of baseline surface water levels and flow rates in the Dungourney River (one gauging station upstream of the site and the other downstream of the surface water abstraction point) and their relationship with groundwater pumping rates prior to commissioning of the proposed abstraction wells in Q1, 2013 has been prepared on behalf of IDL by an external consultant White Young Green (WYG). This WMP was submitted to CCC and MTC on the 29th of March 2012 as part of the submission regarding Compliance with Planning Conditions. A copy of this Water Management Plan is included in Attachment No B5.7. The primary objective of the river monitoring exercise is to gain an increased understanding of the interaction, if any, between the Dungourney River and the groundwater beneath the IDL site, during periods of normal and low flow. The continuous monitoring data will provide sufficient baseline data on the river to enable an


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assessment of any potential long-term impact to the river as a result of the proposed increased groundwater abstraction onsite. Indicate whether or not the activity complies with the requirements of the EC Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009. The activity complies with the requirements of the EC Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009. Other than a slight increase in temperature, the cooling water is the same quality as when abstracted from the ground and is suitable for return to the local surface water environment. As detailed in the WYG correspondence to CCC (refer to Attachment No. B5.6) surface water samples analysed in 2010 were tested for a wide range of parameters including the majority of those listed in S.I. 272 of 2009 and no exceedances above the guidelines occurred for any parameter, Ref. Table 1 in Attachment B5.6. A smaller suite of parameters was tested from five river water samples acquired in March 2011 and again there were no exceedances above the relevant S.I. 272 of 2009 parameters, Ref. Table 2 in Attachment B5.6. Schedule 5 of the 2009 Regulations, Table 9 Physico-chemical conditions supporting the biological elements, Part A: Thermal Conditions specifies the following Thermal Conditions Criteria:

Thermal

Conditions

River Water

Body

Lake Water

Body

Transitional

Water Body

Coastal Water

Body

Temperature Not greater than a 1.5˚C rise in ambient temperature outside the mixing zone

Section 12.3 of the EIS describes the baseline monitoring and temperature profile of the existing discharge and the Dungourney River in detail and also correspondence from WYG on behalf of IDL to CCC in February 2012 (refer to Attachment No. B5.6). Section 12.5 of the EIS reviews in detail the results of a hydraulic model that was developed for a section of the Dungourney and Owenacurra Rivers. Findings show that the proposed discharge would not cause any significant hydrological impact during the daily mean flow condition of the Dungourney River and this is independent on the season. During the worst case condition, which was assessed as the summer low flow drought condition, water temperature of the Dungourney River was found to increase by 2.2˚C in comparison to the baseline condition for a river length of 500m. It is not proposed to discharge cooling water to the Dungourney River during low flow conditions and consequently there will be no impact on the Dungourney River, Owennacurra River or estuary. Details of the mitigation measures to be implemented with regards to surface water impact from elevated water temperature and water abstraction are provided in Section 12 of the EIS (Mitigation Measures) and Attachment No B5.7. (ie Water Management Plan for Groundwater/Surface Water Monitoring and Associated Mitigation Measures). As outlined in the impact assessment of the proposed increase in spent cooling water discharged to the Dungourney River as described in Section 12 of the EIS and the Planning Clarifications with regards to emissions to surface water prepared by WYG on behalf of IDL as described in Attachment No. B5.6, taking operational mitigation measures into account, the final residual impact on the surface water environment will be imperceptible. If the discharge is to water body that is already achieving high status, or if the discharge is to waters draining to the surface water bodies identified under the First Schedule of the


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EC Environmental Objectives (Freshwater Pearl Mussel) Regulations 2009, compliance must be with the 95%ile high status limits. Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made. Not applicable. The Dungourney River is classified as poor ecological status (as defined by the European Communities Environmental Objectives (Surface Waters) Regulations 2009) in terms of biological water quality (Refer to Attachment No. B5.5). Additionally, the River Basin Management Plan for the South Western River Basin District classifies Cork Harbour as being of Moderate Status. Full details of the assessment and any other relevant information on the receiving environment should be submitted as Attachment No I.2.

For emissions outside emission limit established according to the combined approach, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting the upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits established in accordance with the combined approach. Not applicable. The activity and the proposed increase in spent cooling water discharge to the Dungourney River complies with the requirements of the EC Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009. I.3. Assessment of Impact of Sewage Discharge. Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made. Full details of the assessment and any other supporting information should form Attachment No I.3.

A projected process water requirement of 3,620 m3/day is proposed to be met by the existing surface water abstraction from the Dungourney River, supplemented by the reuse of spent cooling water. Water abstracted from the Dungourney River used in the various production operations around the site ultimately generates a series of process wastewater streams requiring on-site treatment in the WWTP prior to discharge at SE Final (Drawing No. 22, Attachment F2) to the dedicated Cork County Council (CCC) Industrial Sewer. The volumetric discharge limit for the treated effluent from the WWTP (SE 1) needs to be increased from the current level of 1,250 m3/day to 2,500 m3/day. However, IDL are not seeking any change to the existing IPPC licence limits (with exception of pH) that currently govern the final emission from the site (SE Final) as the SE 1 volumetric increase can readily be accommodated within the current SE Final limit of 5,000 m3/day. Refer to Section 10.5 of the EIS for a detailed description and assessment of impact of the sewage discharge on the receiving waters. Refer to Section E of the application for discharge details. En route to Ballinacurra Treated Effluent Pumping Station, the IDL SE Final stream is mixed with the treated effluent from the Midleton Municipal WWTP. The combined


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effluent is pumped to a tidal holding tank at Rathcoursey prior to discharge to the North Channel of Great Island at Rathcoursey via a diffuser outfall, Refer to Figure 10.4 of EIS. As discussed in Section 10.5, page 87 of the EIS, the final discharge to Rathcoursey point is governed by an EPA Waste Water Discharge License issued to Cork County Council Southern Division of the Midleton Agglomeration (Reg. No. D0056-01 issued 6th January 2011). The discharge assessed as part of the Midleton Agglomeration includes an allowance of 5,000 m3/day for the IDL’s SE Final discharge. The emission limit values for the discharge to Rathcoursey point are in compliance with the requirements of the Urban Wastewater Treatment Regulations, 2001 (S.I. 254 of 2011) as amended, and are summarised in Table 10.10 of the EIS. No domestic (foul) effluent from the site operations (toilet, canteen, etc.) is directed to the site wastewater treatment plant (WWTP). Domestic effluent in the order of 20 m3/day is collected separately and directed to the Midleton Urban WWTP, this will increase to 40 m3/day following implementation of the proposed expansion. The impact of proposed expansion due to increased domestic effluent load to the municipal sewer and treatment plant is negligible. A complete assessment of impact on receiving waters from the sewage and domestic discharges to sewer is presented in Section 10 and Section 13 of the EIS.

I.4 Assessment of Impact of Ground/Groundwater Emissions Describe the existing groundwater quality. Tables I.4 (i) should be completed. Give summary details and an assessment of the impacts of any existing or proposed emissions on the ground (aquifers, soils, sub-soils and rock environment), including any impact on environmental media other than those into which the emissions are to be made. This includes landspreading, land injection etc. Emissions to ground are as per that described in Table E.4(i), surface water runoff i.e. rainfall runoff at GE 1 and GE 2 (refer to Drawing No.s 13 and 14, Attachment E4). The existing groundwater environment including aquifer classification, vulnerability, hydrogeological features of importance, groundwater flow direction, hydrochemistry and test well groundwater quality are described in detail in Sections 11.3, 11.8 and 11.9 of the EIS. Section 11.9 of the EIS discusses the hydrochemistry and groundwater quality in detail. In order to assess the groundwater resource on-site, a well field of eight groundwater abstraction boreholes was drilled within the limestone bedrock beneath the site with a productive gravel aquifer resource encountered along the eastern site boundary. Given the karst environment the hydraulic connection between the groundwater and surface water is likely to be quite complex with the river gaining baseflow from the aquifer during high water table and losing it to the natural sediments and bedrock during drier periods. The groundwater flow direction beneath the site is seen to be in a south westerly flow direction. The groundwater quality analysis indicates elevated manganese in groundwater along the eastern side of the site with high hardness across the site. Groundwater bacteriological quality is very low compared to the Dungourney River. In accordance with Schedule 5(ii) of IDL’s IPC Licence, four boreholes, GW1 to GW4 are monitored annually and GW5 is monitored biannually. Table I.4 (i) has been completed, illustrating the quality of the groundwater. The analytical results for GW1 to GW4 show predominately normal groundwater values.


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WYG made a submission to CCC on behalf of IDL in February 2012 as part of IDL’s response to planning queries (refer to Attachment No. B5.6). Within the WYG correspondence, comparison is made within Table 1 - MW01 (lower field) to the Groundwater Regulations, S.I. No. 9 of 2010. All parameters were within the EC Environmental Objectives (Groundwater) Regulations 2010, S.I. No. 9, groundwater threshold values (GTVs) with the exception of nickel (154 ug/l versus a GTV of 15 ug/l) and ammonium (0.23 ug/l versus GTV of 0.175 ug/l). Relocation of GW2

Groundwater well GW2 is located in the vicinity of the proposed firewater retention pond (refer to Drawing No. 22, Attachment F2) and has therefore had to be relocated. A new well was drilled during July 2012 and it’s new location is shown on Drawing No. 22. A drilling log and photo of the new well is included in Attachment I.4. Land on which material may be landspread shall be identified on a suitable scaled map (1:10,560 and 1:50,000) and submitted as no greater than A3 size. All vulnerable (as a result of ground emissions) surface water bodies must be identified on these maps. Additional information should be included in Attachment No I.4. Not applicable. Landspreading of Agricultural/Non Agricultural Wastes Not applicable. Tables I.4(ii) and I.4.(iii) should be complete where applicable. Further information is available in the Application Guidance Document. Not applicable. I.5 Ground and/or Groundwater Contamination Summary details of known ground and/or groundwater contamination, historical or current, on or under the site must be given. There is a small scale disused landfill on site containing putrescible waste. The historical contamination is not related to process related waste, it is attributable to garden and canteen waste mainly. Use of this landfill was discontinued in 1998 for which a Landfill Residuals Management Plan was submitted to the EPA in 2000. A monitoring well GW5 was drilled to bedrock and is monitored every six months for landfill gas and leachate. An external consultant is commissioned to conduct bi-annual gas and groundwater monitoring on GW5 and annual Groundwater monitoring at GW 1-GW 4. GW5 was installed to monitor methane and carbon dioxide concentrations from the small scale disused landfill. For the past 13 years GW 5 borehole has been dry indicating little or no infiltration. Trigger levels for methane and carbon dioxide have been set at 1.0 and 1.5% v/v respectively for gas concentrations in perimeter monitoring points for the landfill. The landfill gas analysis occasionally shows trace levels of methane and carbon dioxide. Recent results of GW 5 show no exceedence of the trigger levels. As noted above, the analytical results for GW 1 to GW 4 show predominately normal groundwater values. IDL submitted the 2011 AER to the EPA in March of 2012 comparing the groundwater results against the Groundwater Regulations, SI 9 of 2010 - Groundwater Threshold Values (GTVs). As indicated in Table I.4 (i), GW 1 exceeded the


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GTV value of 0.065-0.175 mg/l for ammonia and GW 2 exceeded the GTV value of 7.5 ug/l for Arsenic. All the remaining parameters monitored in GW 1 to GW 4 as outlined in Table I.4(i) were within the respective GTVs. Removal of GW5 as a Scheduled Monitoring Point from the IPPC Licence

As part of this submission, IDL is formally requesting the removal of GW 5 from monitoring requirements. Currently GW 5 is required to be monitored under Schedule 5(ii) and Condition 10.3.2 of the IPPC Licence. This is now regarded as a legacy monitoring point. As outlined above, in the past fourteen years, GW 5 has been dry indicting little or no infiltration and has shown no exceedence of the trigger levels for methane and carbon dioxide which were set at 1.0 and 1.5% v/v respectively for gas concentrations in perimeter monitoring points for landfill. Indicate whether or not compliance with the requirements of the EC Environmental Objectives (Groundwater) Regulations 2010, S.I. No. 9 of 2010 can be achieved. Historically GW 5 borehole has been dry indicting little or no infiltration. Therefore, no comparison to the Groundwater Regulations can be made against GW 5. Full details including all relevant investigative studies, assessments, or reports, monitoring results, location and design of monitoring installations, plans, drawings, documentation, including containment engineering, remedial works, and any other supporting information should be included in Attachment No I.5. Details of aftercare and treatment have previously been submitted to the EPA by IDL in the original IPPC licence application back in 1998 and subsequent reports required under IPPC Licence P0442-01. A Landfill Residuals Management Plan was submitted to the EPA in 2000. I.6 Assessment of the Environmental Impact of On-site Waste Recovery and/or Disposal.

Describe the arrangements for the prevention and recovery of waste generated by the activity.

Give details and an assessment of the impact of any existing or proposed on-site waste recovery/disposal on the environment, including environmental media other than those into which the emissions are to be made. This information should form Attachment No I.6.

Details of historical waste landfill on-site discussed in Section I.5 above. I.7 Noise Impact Give details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Ambient noise measurements Complete Table I.7 (i) in relation to the information required below: (i) State the maximum Sound Pressure Levels which will be experienced at typical

points on the boundary of the operation. (State sampling interval and duration)


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(ii) State the maximum Sound Pressure Levels which will be experienced at typical noise sensitive locations, outside the boundary of the operation.

(iii) Give details of the background noise levels experienced at the site in the absence of

noise from this operation. Prediction models, maps (no larger than A3), diagrams and supporting documents, including details of noise attenuation and noise proposed control measures to be employed, should form Attachment No I.7. Ambient Noise Measurements

The existing noise climate around the boundary of the site was surveyed in October 2011, during both daytime and night-time periods and has been found to be mostly controlled by noise emissions from the facility. A repeat survey was carried out in May 2012 in accordance with the EPA Guidance Note for Noise (2012): License Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4). All measured daytime noise levels were in accordance with the daytime EPA criterion and is therefore compliant with the IPPC Licence criterion. All night time noise levels were in accordance with the night time EPA criterion and are therefore generally compliant with IPPC licensing requirements. A copy of the 2012 IPPC Noise Emission Survey carried out by AWN Consulting on behalf of IDL is included in Attachment No. I7. Prediction Model

As detailed in Section 14 of the EIS, it has been predicted that neither of the potential sources i.e. mechanical equipment process noise and additional vehicular traffic on public roads will increase the existing noise climate sufficiently so as to be likely to cause a disturbance. Please refer to Section 14 of the EIS for a detailed impact assessment including prediction model results. In light of the IPPC Licence Review Application, IDL are requesting the retention of the existing noise criteria as specified in the existing Licence under Condition 3.4 and Conditions 9.1 and 9.2. Retention of Existing Noise Criteria

In accordance with the Guidance Note for Noise (2012): Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4) document which states on Page 7 that:

“retention of the existing daytime and night-time periods and criteria may

be appropriate in certain cases, for example, in situations where a site has

been operating successfully for a significant period of time without any

history of noise complaints”,

Irish Distillers wish to apply for retention of the existing license criteria on this basis. There have been no significant past history of noise complaints on site. Current similar and continual facility operation throughout the evening and night time periods indicate that the evening period measurements would be redundant (i.e. night time and evening period levels being similar, therefore there is only a requirement to be assessed against the more stringent criteria which is during the night time period). Notwithstanding the above, IDL propose that the continued monitoring of day and night time periods at N1, N2, N3, NSL1 and NSL 2 would be in full compliance with the NG4 guidance requirement.


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Table I.7 (i) has been completed accordingly. I.8 Environmental Considerations and BAT

Describe in outline the main alternatives, if any, to the proposals contained in

the application.

Describe any environmental considerations which have been made with respect to the use of cleaner technologies, waste minimisation and raw material substitution. Describe the measures proposed or in place to ensure that: (a) The best available techniques are or will be used to prevent or eliminate or, where

that is not practicable, generally reduce an emission from the activity; (b) no significant pollution is caused; (c) waste production is avoided in accordance with the waste hierarchy in Council

Directive 98/2008 EC on waste and section 21A of the Waste Management Acts 1996 to 2011 (as amended in 2011); where waste is produced, it is prepared for re-use, recycled or recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment (applicants should provide this information in the context of sections 29(2A), 32 and 38(5A) of the Waste Management Acts 1996 to 2011);

(d) energy and other resources are used efficiently; (e) the necessary measures are taken to prevent accidents and limit their

consequences; (f) the necessary measures are taken upon definitive cessation of activities to avoid

any pollution risk and return the site of operation to a satisfactory state. Supporting information should form Attachment No I.8.

As described in Section D, the proposed expansion will be based on the existing specialised distillery process of milling, mashing/cooking, fermentation and distillation on site. Whilst there will be improvements in efficiencies and significant energy reductions associated with the new equipment selected, the type of process plant selected is restricted by the unique nature of the distillery process itself.

I.8-1 Energy Usage

Energy usage and energy savings projects being included in the proposed expansion has previously been discussed in Section G.2. I.8-2 BAT

In assessing BAT for the site expansion, the following guidance has been taken into account:

• Article 3 and Annex IV of Council Directive 2008/1/EC concerning integrated pollution, prevention and control.

• BAT Guidance Note on Best Available Techniques for the Brewing, Malting &

Distilling Sector (2008), published by the EPA (this includes reference to the BREF Document on Best Available Techniques in the Food, Drink and Milk Industries (2006)).


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Article 3 of Council Directive 2008/1/EC lists the general principles governing the obligations of the operator to ensure that appropriate pollution prevention and control measures are put in place. These are discussed in Table I8-1 below.

Table I8-1: General Principles Governing the Basic Obligations of the Operator

Obligation Assessment

a) All the appropriate preventive measures are taken against pollution, in particular through application of the best available techniques.

This is assessed under Section L of this licence review application.

Also, the EIS has identified a number of mitigation measures to be taken during both the construction and operational phase of the development and these are being implemented by IDL.

b) No significant pollution is caused.

Existing operations on site are controlled by the existing IPPC Licence P0442-01 and no pollution is caused as a result of IDL activities. The proposed activities will not cause any significant environmental pollution. The pollution generated from the site, in the form of emissions to atmosphere, discharges to surface water, emissions to sewer and waste has been addressed in Section I.1, I.2, I.3 and H.2 respectively. It has also been addressed throughout the accompanying EIS. The proposed activities will not cause any significant environmental pollution.

c) Waste production is avoided in accordance with Council Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment.

The generation, prevention and recovery of waste at the site is managed in accordance with the site’s QSE management system as described in Section C. The production of waste is minimised where possible, and where waste is produced, it is recycled or recovered wherever practicable in accordance with the EU Waste Hierarchy as outlined by SI 126 of 2011, EC (Waste Directive) Regulations 2011. The recovery / recycling routes have been identified in Table H.

The generation of by-products from the production process are passed through a feeds recovery process and the products from this process are sent offsite for agricultural use.

d) Energy is used efficiently.

The efficient use of energy on-site is a key environmental objective and performance indicator for IDL. In order to reduce energy consumption and improve energy efficiency at the site, IDL has carried out a wide range of energy related projects driven through the QSE management system and IPPC licence requirements. These projects have resulted in the improved use of energy at the site. The new technologies being incorporated into the Brew House expansion, new pot stills and distillation columns will all lead to significant energy usage savings.

e) The necessary measures are taken to prevent accidents and

IDL has an Internal Emergency Plan in place to prevent accidents and limit their consequences. This is addressed in Section J of the application. The Site is a top tier Seveso II


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limit their consequences.

site and there is a statutory obligation test the internal emergency plan every three years in consultation with the HSA.

Additionally as part of this IPPC Review Application, IDL have included the details of a new firewater retention pond that is being installed, refer to Section J for details.

f) The necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state.

The investment being made by IDL on this expansion shows its commitment to operate at Midleton Distilleries for the foreseeable future. In the unlikely event of definitive cessation of activities at the site, IDL undertakes to ensure that appropriate measures are taken to avoid any pollution risk and return the site to a satisfactory state. This is addressed in Section K.

In addition to these general obligations placed on operators, Annex IV of Council Directive 2008/1/EC lists the considerations to be taken into account generally. Or in specific cases, when determining best available techniques as defined in the Directive, bearing in mind the likely costs and benefits of a measure and the principles of precaution and prevention. These considerations are discussed in Table I8-2 below.

Table I8-2: Assessment Topics for Determining BAT

Topic Assessment

1. The use of low-waste technology.

There will always be a quantity of residual material generated as part of the production process, however IDL has managed to convert over 90% of this residual material into a saleable by-product for the agriculture sector. This conversion takes place in the on-site Feeds Recovery building. This process will continue as part of the site expansion process with an expected doubling of by-product output (over 2011 levels) once full production is achieved.

2. The use of less hazardous substances.

There is minimal use of hazardous substances during the production process with most hazardous substances used in the water and wastewater treatment plants. The hazardous substances are required to meet strict water and wastewater quality parameters. IDL, along with external suppliers, continually review new less hazardous substances and these are introduced to site following approval for use.

3. The furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate.

IDL already recovers most of the residual material generated in the Brew House and Still House and sends it on for further treatment in the Feeds Recovery building to generate by-products for offsite sale.

IDL also tries to encourage waste contractors to recover as much waste as possible from the site and these efforts can be seen in the quantity of waste that was sent offsite in 2011 for recovery and recycling (refer to the 2011 AER).

4. Comparable processes, facilities or methods of operation which have been tried with success on an

The new technologies being employed in the Brew House, Still House and Distillation Columns are successfully in use at other brewing plants worldwide and at a similar industrial scale.


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industrial scale.

5. Technological advances and changes in scientific knowledge and understanding.

Improvements and changes in the design and control have been incorporated into the new processes compared with the existing processes on-site. As outlined in the introductory paragraph, the type of process plant selected is restricted by the unique nature of the distillery process itself.

6. The nature, effects and volume of emissions concerned.

The main emissions from the new production buildings have previously been discussed in Section E. The impact of the increase in emissions has been comprehensively dealt with in the accompanying EIS as well as in Section I. There will be increases in air emissions, surface water emissions, emissions to sewer and emissions to ground. There will also be an increase in waste generated at the site. All increases in emissions will have a minimal impact on the environment.

7. The commissioning dates for new and existing installations.

The new processes will start being commissioned during July 2012 (Brew House extension) with the final phase of commissioning due to start in January 2013 in this phase of development.

8. The length of time needed to introduce the best available technique.

A number of Best Available Techniques have been and are currently employed at the site. Additional techniques to further reduce the impact on the environment are incorporated into the design of the new processes, the new WWTP and the site’s QSE management system – Environmental Management Programme. There is no requirement to introduce new measures on-site to achieve BAT associated emission levels.

9. The consumption and nature of raw materials (including water) used in the process and energy efficiency.

As detailed in Section 10 of the EIS, there will be an increase in water usage requirements for the site. Raw materials consumption will also increase as production output is doubled over time. Some of the new processes being introduced on-site (i.e. Brew House expansion) will lead to a reduction in water usage per litre of pure alcohol (LPA) produced compared with existing volumes. Other site processes, including those in the new Still House and Distillation structure, will lead to a reduction in energy usage per LPA produced.

10. The need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risk to it.

The existing IPPC Licence ensures that the existing process minimises the impact of the emissions on the environment. The impact of the emissions from the proposed expansion on the environment and the risk to the environment is considered to be low and has been fully assessed in the accompanying EIS.

Air dispersion modelling of the emissions indicates that the atmospheric emissions from the site will not adversely impact on the air quality in the vicinity of the site.

Modelling of the cooling water discharge to Dungourney River shows a potential impact in relation to temperature increase during low flow river conditions. Cooling water will not be discharged to the river during these low flow conditions. Noise modelling concluded that the overall impact of noise emissions from the proposed expansion is not considered significant.

11. The need to prevent The site is a Top-Tier Seveso II site. As a result of this, a


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accidents and to minimise the consequences for the environment.

Safety Report has been prepared for the site and has been approved by the Health and Safety Authority (HSA). There is also a significant Health and Safety focus across the site which is implemented through the QSE management system. There are both internal and external emergency plans for the site. Through the existing IPPC licence there has also been a strong focus on site to minimise environmental impacts from on-site processes on the surrounding area.

12. The information published by the Commission pursuant to Article 17(2) second paragraph, or by international organisations.

The BAT Guidance Note for the Brewing, Malting & Distilling Sector and its requirements are discussed briefly below.

The associated BREF document, published by the EC, is “Best Available Techniques in the Food, Drink and Milk Industry.”

The EPA’s publication BAT Guidance Note on Best Available Techniques for the Brewing, Malting and Distilling Sector is the relevant guidance note on BAT for the sites operations. This guidance note is closely linked to the European Commission’s BREF Note on Best Available Techniques in the Food, Drink and Milk Industries. The considerations identified in Section 5 of the EPA Guidance Note are discussed in Table I8-3 below. Table I8-3: BAT for the Brewing, Malting & Distilling Sector

Topic Assessment

Section 5.2 – General Preventative Measures

The site operates an environmental management system to the ISO 14001 standard. There are also a number of operators employed throughout the site to maintain a high standard of housekeeping both inside and outside production buildings.

Section 5.2.1 – Minimisation of Water Consumption

Water is a major resource requirement for the site and has been discussed throughout this application and in the EIS. There are plans to recycle some of the cooling water (provided by new groundwater wells) into the production process.

Section 5.2.2 – Minimisation of Energy Consumption

Energy usage and energy reduction measures are treated very seriously on-site due to the costs involved throughout the process and the increasing cost of energy supply to the site. The new processes being introduced to the site will all require a lower energy demand per litre of alcohol produced.

Section 5.2.3 – Minimisation of Emissions to Air

There are five main emission points associated with the site. Emissions from four of these, (the three boilers and the feeds recovery stack) are all within the relevant BAT associated emission levels.

The fifth emission point relates to the combined CO2 emission from the fermenters located on-site. Various companies have investigated the recovery of CO2 from these tanks but so far it has not been proven to be financially viable.

Brewing odours are not considered to be offensive and as a result IDL has not installed any odour abatement systems on-


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site.

Section 5.2.4 – Minimisation of Emissions to Water

The cleaning-in-place (CIP) programme on-site has been revised and improved over a number of years in order to minimise the quantity of water used in the process and hence the quantity of water requiring treatment in the on-site wastewater treatment plant. There are also plans to reuse cooling water in order to stay within the existing licensed water abstraction levels from the Dungourney River and the underground cavern.

Section 5.2.5 – Protection of Surface and Groundwater

There are both localised and remote bunding facilities located on-site to capture any spillages / leaks from various storage vessels. These bunding facilities are tested once every 3 years in accordance with the sites IPPC licence.

As IDL utilises both surface waters and groundwater in it’s production process it is extremely important that there are satisfactory protection measures in place on-site.

The foul sewer and process drainage lines are also integrity tested once every 3 years.

Section 5.2.6 – Waste Minimisation

IDL recycle/recover over 95% of waste generated on site, details of which are submitted to the EPA as part of the AER reporting process.

Section 5.2.7 – Prevention of Noise Emissions

The main production facilities are located very close to residential areas and as a result IDL is very conscious of noise generating equipment on-site and their requirements to reduce noise levels to maintain IPPC licence compliance. Noise emissions for both the existing and expanded site have been assessed in Section 14 of the EIS.

As part of this licence application, a noise survey was completed to take into account the EPA’s recently published guidance note (NG4) on noise.

Section 5.4.2 – Treatment of Wastewater

There are two options being considered by IDL for the expansion of the wastewater treatment plant. Both options are considered BAT (i.e. aerobic or anaerobic treatment).


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SECTION J: ACCIDENT PREVENTION & EMERGENCY RESPONSE

Describe the existing or proposed measures, including emergency procedures, to minimise the impact on the environment of an accidental emission or spillage. Also outline what provisions have been made for response to emergency situations outside of normal working hours, i.e. during night-time, weekends and holiday periods. Describe the arrangements for abnormal operating conditions including start-up, leaks, malfunctions or momentary stoppages. Supporting information should form Attachment No J.

A list of Health and Safety procedures for the site are included in Attachment C2.

J.1 Emergency Plans

IDL has an Internal Emergency Response Plan (QSE008). This plan outlines the methodology employed by the company to deal with emergency incidents occurring anywhere in Midleton Distilleries and is in line with both the statutory COMAH emergency planning requirements and the emergency preparedness and response requirements of OHSAS 18001:2007, ISO 14001:2004 and IPPC Licence No. P0442-01. The purpose of this plan is to be prepared for any on-site emergency which may arise and minimise risk to personnel, damage to the distillery property, upset to the community or damage to the environment. There is also an External Emergency Plan (which is a specific Sub-Plan of the Major Emergency Plan of each Principal External Response Agency), internal reference HSP090. In practice, the Internal Emergency Plan is the key Emergency Response document owned and operated by the site. However, in the event of a major accident (in the context of COMAH) both the Internal Emergency Plan and External Emergency Plan are activated simultaneously. Thus, the scope of the Internal Emergency Plan covers both the declared major accident scenarios (as submitted to the COMAH Authority in the Draft Safety Report – dated March 2009) and any other emergency on site. This report was approved by the HSA early in 2012. As discussed under Section C, the site operates an integrated Quality, Safety and Environmental (QSE) management system and this system is certified to the relevant standards.


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Declared Major Accident Scenarios

No. Activity Hazard

1 Storage of casks in Maturation Warehouse

Flammable liquid release and subsequent fire/explosion. Potential for fire-water run-off (on fire) to discharge to nearby river/estuary.

2 Stillhouse – Batch (Pot) Distillation System

Highly flammable liquid release and potential for subsequent pool fire/flash fire/explosion.

3 Continuous (Column) Distillation System


4 Vathouse Operations Highly flammable liquid release and potential for subsequent pool fire/flash fire/explosion.

Other Potential Emergencies on Site

• Major/Serious fire (apart from the declared major accident scenarios).

• Major/Serious explosion (apart from the declared major accident scenarios).

• Major/Serious injury to a number of personnel (multiple injuries).

• Major/Serious natural gas leak.

• Major/Serious spillage.

• Other Major/Serious environmental accident/incident.

• Rescue from confined space/from height.

• Any other accident/incident declared an internal emergency by site management.

As part of the site expansion process, all emergency plans will be updated as required to take into account new processes and new buildings / tank farms. The relevant procedures detail how the emergency plan is activated and the roles and responsibilities of the various people on-site. In relation to the provisions for responding to accidental emissions and emergency situations which arise outside normal working hours the following procedure is in place (extract taken from the Internal Emergency Plan):

“As both the Main Control Team (MCT) and the Forward Control Team (FCT) are

present on site only during office working hours (Monday to Friday, inclusive), and

as the minimum staffing level for the FCT for safe emergency response is 6 people,

then activation of the Internal Emergency Plan is not applicable.

When a Shift Production Supervisor is on site, he is the Person-In-Charge of the

site and he is authorised to evacuate personnel by activating either one of the

evacuation/emergency alarm buttons. He is also authorised to activate both the

External Emergency Services via Security (for emergencies apart from the declared

major accident scenario) and the External Emergency Plan for declared major

accident scenarios.


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When the plant is in 5½ days production, Security is responsible for activating both

the External Emergency Services and the External Emergency Plan when IDL

management are not on site.”

J.2 Spill & Emergency Containment Measures & Structures

IDL incorporates a number of pollution prevention measures on its site. These measures protect nearby surface waters (Mill Stream and the Dungourney River) and the underlying soil and groundwater. Details of these are provided below. Spill Procedures

There are a number of procedures on-site to deal with spills as follows:

• Spill Control at IDL (EPP009) • Spill Control Training (EPP050) • Spill Kit Inspection Procedure (EPP051)

As discussed previously in Section E, there are a number of TOC meters on surface water discharge lines that are used to divert surface water to various containment structures or direct to sewer. There is a procedure (EPP025) in place for the operation of the storm water isolation valves. Containment Facilities (Existing and Proposed)

The existing containment structures consist of: a) Firewater retention pond for the Lower Fields warehouse area. The information on

this has previously been submitted to the EPA in October 2006. The capacity of the retention pond is 7,800m3. This caters for potential firewater runoff or spills in the Lower Fields warehouse catchment area only.

b) Disused settlement tanks in the existing wastewater treatment plant area – capacity

of 800m3. These tanks can be used to capture spills from the remaining warehouse area and the Vat House / Spirit Store areas. They can also be used as overflow facilities for the equalisation tanks / mixed effluent chamber in the WWTP.

As part of the site expansion it is proposed to install a second firewater retention pond with a storage capacity of 7,600 m3. A Firewater Retention Study report was submitted to the EPA on the 27th January 2012 as part of the Technical Amendment request and is included in Attachment J1. This new firewater pond will take firewater runoff from some existing warehouses, Vat House / Spirit Store and Production catchment areas. Once installed, the settlement tanks in the WWTP area will no longer be required. Section 10.8 of the EIS (Pages 91 and 92) as well as Figure 10.5 of the EIS (Page 90) provide a summary overview of the proposed facility. Bunding Facilities

IDL has had various discussions with the EPA in relation to the provision of remote bunding facilities for a number of external storage tanks and process buildings. As part of the submission for the new 190 m3 capacity High Wines tank an updated calculation was completed and submitted to the EPA.


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A copy of the original and High Wines tank calculations is provided in Table J1 below. Table J1

Summary Table: Areas remotely bunded by WWTP equalisation tanks

1. As submitted with original IPC licence application

Area Total Capacity 25% of Total Capacity Largest Vessel 110% of Largest Vessel Bunding Requirement

(m3) (m

3) (m

3) (m

3) (m

3)

Fermentation/Backloft 3462 866 227 250 866

Feeds Recovery 419 105 182 200 200

Still House 1240 310 190 209 310

Brew House 489 122 89 98 122

Largest Volume 866

2. Current scenario (including new high wines receiver)

Area Total Capacity 25% of Total Capacity Largest Vessel 110% of Largest Vessel Bunding Requirement

(m3) (m

3) (m

3) (m

3) (m

3)

Fermentation/Backloft 137 34 36 40 40

Feeds Recovery 282 71 182 200 200

Still House 1240 310 190 209 310

Brew House 474 118 89 98 118

Largest Volume 310 Due to the installation of separate tank farms for both the New Still House and Distillation Column Building there will be considerably less number of tanks located within each building than is currently the case in the existing Still House. As a result, the remote bunding capacity requirement of 310m3 for the existing Still House will be more than capable of taking any product spilled inside each of the two new production areas. In summary, IDL maintains a level in the WWTP equalisation tanks so that there is always spare capacity to take 310 m3 from a potential spillage / rupture of a remotely located storage vessel. There are also some new bunding facilities associated with the proposed development. These have previously been identified in Drawing No. 23 in Attachment H1. All new bunded structures will be constructed of reinforced concrete and will be in accordance with BS 8007, Condition 10.4 of the IPPC Licence and the EPA Guidance Note on the Storage and Transfer of Materials for Scheduled Activities. In relation to existing bunds on-site, these were last integrity tested during 2009, a copy of this report was submitted with the 2009 AER and these bunds are due to be retested during 2012, in accordance with the IPPC Licence. Records of all future bund integrity tests will be maintained on-site for future site inspection by the EPA. J.3 Site Drainage

Catchment Areas

Surface water catchment areas have previously been discussed in Section E including how surface water runoff from each area is dealt with. A map detailing the surface water catchment can be found on Page 90 of the EIS (Figure 10.5).


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Process Drainage Systems

The foul sewer, MVR condensate line and the process organic drainage system were integrity tested during 2009. A copy of the reports and associated repair schedules were submitted to the EPA as part of the 2009 AER. The repair works, that were identified at the time, were completed during 2010 and a summary of the repair work was included in the 2010 AER. There were No repair works required on the MVR condensate line. As part of the site expansion there will be additional process and foul sewers installed on-site and connected into the existing drainage systems. All new process and foul drains will be integrity tested as part of site commissioning of new production areas. Drawings showing the various drainage systems on-site have been provided in Attachment E. J.4 Public Liability Insurance

This is discussed under Section K below.


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SECTION K: REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE

Describe the existing or proposed measures to minimise the impact on the environment after the activity or part of the activity ceases operation, including provision for post-closure care of any potentially polluting residuals. Supporting information should be included as Attachment No. K.

Residuals Management Plan (RMP)

Environmental Liabilities Risk Assessment (ELRA)

Financial Provision (FP)

Under Conditions 14 and 15 of the existing IPPC Licence (P0442-01), IDL were required to complete the following documents: a) Landfill Residuals Management Plan (RMP) b) Environmental Liabilities Risk Assessment (ELRA) The Landfill RMP was submitted to the EPA in April 2000 and following the submission of this report no further action was requested by the EPA and the issue was deemed closed. The ELRA was submitted to the EPA in October 2000 and following the submission of this report no further action was requested by the EPA and the issue was deemed closed. Since the submission of these two reports the EPA has issued a Guidance Document – Environmental Liabilities Risk Assessment, Residuals Management and Financial Provision, 2006. To date, IDL has not been required to update the above two documents and as such these documents are somewhat out of date. IDL is aware that revised documents will be requested as part of any new IPPC licence and as such there will be commitment by on-site management to complete these documents in accordance with the relevant licence conditions. The documents will be prepared in accordance with relevant EPA guidance notes and will identify costs for site closure / decommissioning, aftercare monitoring and management and remediation costs, if required. Review of Environmental Liabilities Insurance Cover

Irish Distillers Ltd. and its parent company Irish Distillers Group Ltd are subsidiaries of the French multinational drinks company Group Pernod Ricard. Irish Distillers Group and Subsidiary Companies carry an Insurance Policy specifically for Environmental Pollution, which is placed with a panel of insurers, AXA Insurance Company being the leading office. The following cover is provided: Pollution Liability

Limit of Indemnity Greater than €13,000,000 any one event Accidental Pollution €50,000,000 per year Pollution cover applies if it is caused by a sudden, identifiable, unattended and unexpected incident which takes place in its entirety at a specific time and place during the period of insurance.


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Pollution or contamination is defined in the policy to mean:

1. All pollution or contamination of buildings or other structures or of water or land or the atmosphere and;

2. All loss or damage or injury directly or indirectly caused by such pollution or contamination.

This level of cover is in excess of the potential liabilities outlined in the Environmental Liabilities Risk Assessment report submitted to and approved by the Environmental Protection Agency. Future Site Decommissioning Activities

As part of the plant expansion, the following items will be decommissioned:

• Old settlement tanks in the WWTP (currently used for secondary containment) will be replaced by a new firewater retention pond. An existing warehouse (A3) will need to be demolished to make way for the firewater retention pond.

• The existing batch brewing process will become redundant.

• The existing Still House will cease functioning for main product lines but may be used for R&D products.

• Supervisors office, located next to the existing Still House, will become redundant.

• The existing water treatment plant will be decommissioned and demolished.

• The existing equalisation tanks in the WWTP may be replaced by 2 No. glass lined tanks each with 1,800 m3 capacity.

• Relocation of waste storage area, with decommissioning of old storage area.

All decommissioning and demolishing works will be carried out in accordance with existing health and safety and environmental procedures in place on-site. This will include the proper removal of all waste material by approved waste contractors.


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SECTION L: STATUTORY REQUIREMENTS

Indicate how the requirements of Section 83(5)(a)(i) to (v) and (vii) to (x) of the EPA Acts, 1992 and 2011 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. Indicate whether or not the activity is carried out, or may be carried out, or is located such that it is liable to have an adverse effect on - (a) a site placed on a list in accordance with Part 3 of S.I. 477 of 2011, or (b) a site where consultation has been initiated in accordance with Article 5 of the EU Habitats Directive (92/43/EEC). Undertake a screening for Appropriate Assessment and state whether the activity, whether individually or in combination with other plans or projects is likely to have a significant effect on a European Site(s), in view of best scientific knowledge and in view of the conservation objectives of the site(s). Where it cannot be excluded, on the basis of objective scientific information, following screening for Appropriate Assessment, that an activity, either individually or in combination with other plans or projects, will have a significant effect on a European Site, provide a Natura Impact Statement, as defined in Regulation 2(1) of the European Communities (Birds and Natural Habitats) Regulations (S.I. No. 477 of 2011). Where based on the screening it is considered that an Appropriate Assessment is not required, provide a reasoned response. Indicate whether or not the activity is liable to have an adverse effect on water quality in light of the European Communities Environmental Objectives (Surface Water) Regulations 2009 (S.I. No. 272 of 2009). Indicate whether or not the activity is liable to have an adverse effect on water quality in light of the European Communities Environmental Objectives (Ground Water) Regulations 2010 (S.I. No. 9 of 2010). Indicate whether any of the substances specified in the Schedule of the EPA (Licensing)(Amendment) 2004, S.I. No. 394 of 2004, are discharged by the activity to the relevant medium.


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Indicate if the best environmental practices are in place for control of diffuse emissions from the installation/facility as set out in the following legislation:

(a) a specification prepared by the Agency in accordance with Section 5 of the Environmental Protection Agency Act 1992 as amended by Section 7 of the Protection of the Environment Act 2003;

(b) the Urban Waste Water Treatment Regulations 2001 (S.I. No. 254 of 2001)

as amended by the Urban Waste Water Treatment (Amendment) Regulations 2004 (S.I. No. 440 of 2004) or any future amendment thereof;

(c) the European Communities (Good Agricultural Practice for Protection of

Waters) Regulations 2009 (S.I. No. 101 of 2009) or any future amendment thereof;

(d) the Local Government (Water Pollution) Act, 1977 (Control of Cadmium

Discharges) Regulations 1985 (S.I. No. 294 of 1985);

(e) the Local Government (Water Pollution) Act, 1977 (Control of Hexachlorocyclohexane and Mercury Discharges) Regulations 1986 (S.I. No.

55 of 1986);

(f) the Local Government (Water Pollution) Acts, 1977 and 1990 (Control of Carbon Tetrachloride, DDT and Pentachlorophenol Discharges) Regulations

1994 (S.I. No. 43 of 1994); and, measures or controls identified in a pollution reduction plan for the river basin district prepared in accordance with Part V of the EC Environmental Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 for the reduction of pollution by priority substances or the ceasing or phasing out of emissions, discharges and losses of priority hazardous substances. Fit and Proper Person The PoE Act in Section 83(5)(xi) specifies that the Agency shall not grant a licence unless it is satisfied that the applicant or licensee or transferee as the case may be is a fit and proper person. Section 84(4) of the PoE Act specifies the information required to enable a determination to be made by the Agency. • Indicate whether the applicant or other relevant person has been convicted under

the Environmental Protection Agency Act 1992 to 2011, the Waste Management Acts 1996 to 2011, the Local Government (Water Pollution) Acts 1997 and 1990, the Air Pollution Act 1987, and the Air Pollution Act 1987 (Environmental Specifications for Petrol and Diesel Fuels)(Amendment) Regulations 2004.

• • Provide details of the applicant’s technical knowledge and/or qualifications, along

with that of other relevant employees. • Provide information to show that the person is likely to be in a position to meet any

financial commitments or liabilities that may have been or will be entered into or incurred in carrying on the activity to which the application relates or in consequence of ceasing to carry out that activity.

Supporting information should be included as Attachment No L with reference to where the information can be found in the application.


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L.1 Air Pollution Act, 1987

Section 83(5)(a)(i) of the EPA Acts 1992 and 2011 states that the Agency shall not grant

a licence unless it is satisfied that:

“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 1997 and will comply

with any relevant emission limit value specified under Section 51 of the Air Pollution Act

1987.”

The Air Quality Standards Regulations 2011 (SI No. 180 of 2011) supersede the Air Pollution Act, 1987 (Air Quality Standards) Regulations (SI No. 272 of 2002) and specify ambient air quality standard limit values for nitrogen dioxide, sulphur dioxide, particulates, lead, benzene and carbon monoxide and implement a number of European Directives. Section 15 of the EIS investigated the potential impacts on ambient air quality from the proposed expansion, particularly in relation to odours, carbon monoxide, oxides of nitrogen, sulphur dioxide and total particulate matter. The assessment demonstrated that the level of emissions (identified in Table E of this application) will not result in any air quality impact in line with both Irish and European assessment criteria limits. L.2 Water Pollution Act, 1977

Section 83(5)(a)(ii) of the EPA Act’s 1992 and 2011 states that the Agency shall not

grant a licence unless it is satisfied that:

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

any relevant quality standards, 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 following sections of the EIS discuss various aspects of surface water emissions:

• Section 10 Water & Aqueous Emissions • Section 11 Hydrogeology • Section 12 Hydrology • Section 13 Ecology

Each of these sections discusses various aspects of the surface water discharges and emissions to sewer against the relevant regulations. Mitigation measures have been identified when the Dungournay River is at low flow conditions to reduce the impact of any potential temperature increase due to cooling water discharges at SWE 3. This is discussed further in Section L.11 below. During the planning application process, Cork County Council requested IDL to compare the limit values identified in the EC Environmental Objectives (Surface Waters) Regulations 2009 (SI No. 272 of 2009) against the monitoring results for the Dungourney River. This review was completed by White Young Green (WYG) and a separate submission was made in February 2012 to Cork County Council. A copy of this submission can be found in Attachment B5.6. All monitoring results of the Dungourney River were found to be below the relevant limit values. A significant amount of assessment work has been completed as part of the EIS and following the implementation of the recommended mitigation measures, the proposed increase in emissions from the IDL site should not have any significant impact on the surrounding environment.


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L.3 European Legislation

Section 83(5)(a)(iii) of the EPA Act’s 1992 and 2011 states that the Agency shall not


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

procedures or other factors which effect such emissions will comply with, or 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 IDL facility has been designed in accordance with relevant BAT standards / guidance and the emissions from the facility will be in compliance with European Standards. L.4 Noise

Section 83(5)(a)(iv) of the EPA Act’s 1992 and 2011 states that the Agency shall not


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

Regulations under Section 106.”

Section 106 of the EPA Act, 1992 enables the Minister for the Environment to make

Regulations for the purpose of the prevention or limitation of noise which may cause a

nuisance. The EPA Guidance Note for Noise in relation to Scheduled Activities

recommends that to avoid disturbance the noise level at sensitive locations should not

exceed an LAeq T value of 55 dBA during the daytime and 45 dBA at night time. It also

recommends that audible tones and impulsive noise at sensitive locations at night should

be avoided.

Presently, IDL occasionally exceeds it’s night time noise limit value of 45 dB(A) at the nearest sensitive location (NSL 1). However, as the site is located in an urban setting and right up against the site boundaries of residential houses it has always been difficult to achieve the night time limit value. Section 14 of the EIS provides an assessment into the likely noise impact associated with the proposed development. The conclusion reached in relation to the operational phase of the proposed development is that the mechanical equipment noise emission increase at all adjacent noise sensitive locations is predicted to range from 0.0dB(A) to 1.5dB(A). This is not considered to be a significant increase. IDL will continue to monitor noise levels at its licensed monitoring points and in accordance with the IPPC Licence and the EPA’s recent guidance note on noise (NG4).

L.5 Significant Environmental Pollution

Section 83(5)(a)(v) of the EPA Act’s 1992 and 2011 states that the Agency shall not


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

Ongoing monitoring of emissions, surface water and groundwater at the IDL site indicate that there is no environmental pollution at the site. As well as the ongoing monitoring


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programmes being undertaken there are also a significant number of procedures to minimise any environmental risks caused due to an accident or emergency on-site. The installation of a new firewater retention pond will provide additional protection to adjoining surface water and groundwater. L.6 Waste

Section 83(5)(a)(vii) of the EPA Act’s 1992 and 2011 states that the Agency shall not


“Having regard to Part III 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.”

Both hazardous and non-hazardous waste is generated on-site. All existing waste disposal, recovery outlets have been prior approved by the EPA and only licensed waste contractors are used by IDL. Waste is managed on site in accordance with the EU Waste Hierarchy as specified in the EC (Waste Directive) Regulations 2011, SI 126 of 2011. Residual product from some production processes is collected and sent to the Feeds Recovery building where it is processed to produce three high value by-products that can be used in animal feed. This is discussed in more detail in Attachment D. There is also a Fusel Oil that is produced during the distillation process and this is used on-site in one of the three boilers (Production Boiler A). Fusel oil data is reported annually in the Greenhouse Gas Monitoring and Reporting Returns to the EPA. L.7 Energy Efficiency

Section 83(5)(a)(viii) of the EPA Act’s 1992 and 2011 states that the Agency shall not


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

As discussed in Section G of this application energy efficiency forms part of the site’s environmental management policy commitment. Throughout the design process of the Distillery expansion, energy usage and energy savings have been considered at all management levels in order to reduce the carbon emissions associated with the site and energy costs. The GHG permit for the site and its associated carbon EU allowances also focuses the site’s management team on identifying opportunities for reducing their reliance on the on-site boiler system. The recent installation of the MVR process in the feeds recovery building instead of the APV process led to a significant reduction in on-site steam requirements.


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L.8 Accident Prevention & Response

Section 83(5)(a)(ix) of the EPA Act’s 1992 and 2011 states that the Agency shall not


“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.”

As outlined in Section J, IDL has it’s own Internal Emergency Plan procedure (QSE008) which outlines the methodology employed by the company to deal with emergency incidents occurring anywhere in Midleton Distilleries and is in line with both the statutory COMAH emergency planning requirements and the emergency preparedness and response requirements of OHSAS 18001:2007, ISO 14001:2004 and IPPC Licence No. P0442-01. There is also a separate External Emergency Plan (which is a specific Sub-Plan of the Major Emergency Plan of each Principal External Response Agency), internal document reference HSP090.

In the event of a major incident on-site both internal and external emergency plans are activiated. The scope of the Internal Emergency Plan covers both the declared major accident scenarios (as submitted to the COMAH Authority in the Draft Safety Report – dated March 2009) and any other emergency on site. The list of declared major accident scenarios and other potential emergencies are provided in the tables below.

Declared Major Accident Scenarios

No. Activity Hazard

1 Storage of casks in Maturation Warehouse

Flammable liquid release and subsequent fire/explosion. Potential for fire-water run-off (on fire) to discharge to nearby river/estuary.

2 Stillhouse – Batch (Pot) Distillation System


3 Continuous (Column) Distillation System


4 Vathouse Operations Highly flammable liquid release and potential for subsequent pool fire/flash fire/explosion.


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Other Potential Emergencies on Site

• Major/Serious fire (apart from the declared major accident scenarios).

• Major/Serious explosion (apart from the declared major accident scenarios).

• Major/Serious injury to a number of personnel (multiple injuries).

• Major/Serious natural gas leak.

• Major/Serious spillage.

• Other Major/Serious environmental accident/incident.

• Rescue from confined space/from height.

• Any other accident/incident declared an internal emergency by site management.

L.9 Cessation of Activity

Section 83(5)(a)(x) of the EPA Act’s 1992 and 2011 states that the Agency shall not


“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.”

The following reports, as discussed separately under Section K of the licence application, have been prepared for the site under the terms and conditions of the existing IPPC Licence: a) Residuals Management and Aftercare Plan (RMP) – Submitted April 2000 b) Environmental Liabilities Risk Assessment (ELRA) – Submitted October 2000 Review of Environmental Liabilities Insurance Cover

Irish Distillers Ltd. and its parent company Irish Distillers Group Ltd are subsidiaries of the French multinational drinks company Group Pernod Ricard. Irish Distillers Group and Subsidiary Companies carry a specific Insurance Policy on Environmental Pollution which is placed with a panel of insurers, AXA Insurance Company being the leading office. The following cover is provided: Pollution Liability Limit of Indemnity Greater than €13,000,000 any one event Accidental Pollution €50,000,000 per year Pollution cover applies if it is caused by a sudden, identifiable, unattended and unexpected incident which takes place in its entirety at a specific time and place during the period of insurance. Pollution or contamination is defined in the policy to mean: 3. All pollution or contamination of buildings or other structures or of water or land

or the atmosphere and; 4. All loss or damage or injury directly or indirectly caused by such pollution or

contamination.


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This level of cover is in excess of the potential liabilities outlined in the Environmental Liabilities Risk Assessment report submitted to and approved by the Environmental Protection Agency. The site’s insurance is renewed on an annual basis. L.10 Designated Areas

Indicate whether or not the activity is carried out, or may be carried out, or is located

such that it is liable to have an adverse effect on-

a) A site placed on a list in accordance with Part 3 of SI 477 of 2011, or

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

Habitats Directive (92/43/EEC).

c) A European Site as defined in Regulation 2(1) of SI No. 477 of 2011.

Figure 13.1 in the EIS (Page 135) identifies the following conservation areas in the vicinity of the IDL site: Special Protection Area – 004030 Special Area of Conservation – 001058 Proposed Natural Heritage Areas As the proposed development will result in an increase in coolant water discharging to the Dungourney River, which is upstream of two Natura 2000 sites, Special Area of Conservation 001058 (Great Island Channel SAC) and Special Protection Area 004030 (Cork Harbour SPA) and the site itself which is located approximately 1km from the Natura sites, a Natura Impact Statement (NIS) in accordance with European Communities (Birds and Natural Habitats) Regulations 2011 was prepared and was submitted with the planning application. A copy of the NIS is included in Attachment B5. Section 13 of the EIS also provides information in relation to Ecology for the site.

L.11 Surface Water Regulations

Indicate whether or not the activity is liable to have an adverse effect on water quality in

light of the European Communities Environmental Objectives (Surface Water) Regulations

2009 (SI No. 272 of 2009).

Cork Harbour While SE Final is a licensed discharge to sewer, it is eventually discharged to Cork Harbour along with treated effluent from the Midleton municipal WWTP. This discharge to Cork Harbour is licensed by the EPA (Licence Ref. D0056-01) and is discussed in detail in Section 10.5 of EIS. As part of the licence review process for this discharge, the EPA and Cork County Council have already reviewed the impacts this combined discharge has on surface water quality. An IDL discharge rate of 5,000m3/day was used by both parties in the licence review process. There is no planned increase in relation to this flowrate. Dungourney River SWE 1 discharges into the Millstream and then into Dungourney River. The impact of this discharge has been reviewed under Section 12.6 of the EIS “Hydrology – Impact Assessment”, particularly in relation to temperature as this is the main parameter of interest.


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The Surface Water Regulations state that for thermal conditions the temperature increase should not be greater than a 1.5oC rise in ambient temperature outside of the mixing zone. The temperature assessment showed that the proposed condition would result in an acceptable level of temperature increase for most (95%) of the time. It is only during drought summer low flow conditions of the Dungourney River that the background water temperature would be exceeded by more than 1.5oC to about 2.2oC (an increase of 0.7oC) assuming a worst case scenario of a 23oC discharge temperature and full volume of discharge. It is not proposed to discharge cooling water to the Dungourney River during low flow conditions. Mitigation measures that could be adopted by IDL during these worst case conditions have been identified in the EIS (Page 131), please also refer to IDL (WYG) Planning Compliance correspondence referred to in Attachment No. B5. L.12 Ground Water Regulations

Indicate whether or not the activity is liable to have an adverse effect on water quality in

light of the European Communities Environmental Objectives (Ground Water) Regulations

2010 (SI No. 9 of 2010).

Section 11 of the EIS discusses the hydrogeology beneath the IDL site. In particular, Section 11.9 (Pages 107-110) discusses groundwater sampling of on-site wells in relation to both the Drinking Water Standards (SI No. 278 of 2007) and Groundwater Regulations (SI No. 9 of 2010). Table 11.14 (Page 121) within the EIS provides an assessment of the predicted impacts, mitigation measures and residual impacts during the operational phase. Section I.4 of the Application also assesses the groundwater beneath the site in light of the EC Environmental Objectives (Ground Water) Regulations 2010 (SI No. 9 of 2010). L.13 Discharges of Substances (SI No. 394 of 2004)

Indicate whether any of the substances specified in the Schedule of the EPA (Licensing)

(Amendment) 2004, SI No. 394 of 2004, are discharged by the activity to the relevant

medium.

The following substances are discharged from the site through licensed emission points. Air

Substance Location of Discharge

Sulphur Dioxide (as SO2) A1-1, A1-2 and A1-3

Oxides of Nitrogen A1-1, A1-2 and A1-3

Carbon Monoxide A1-1, A1-2 and A1-3

Dust A1-1, A1-2 and A1-3, A2-1

As stated in Section E previously, it is not possible to measure for flow, SO2 and particulates with the current boiler exhaust stack configurations.


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Water

The main emissions to water include SWE 1, SWE 2, SWE 3 (Surface Waters) and GE 1 / GE 2 (Groundwater). Emissions to sewer (SE 1, SE Final and SE 2) are all eventually discharged to Cork Harbour at Rathcoursey Point under a separate EPA licence for Cork County Council.

Substance Location of Discharge

Substances which have an unfavourable influence on the oxygen balance. TOC monitoring is currently carried out on SWE 1, SWE 3 and GE 1.

Increased temperature as a result of SWE 1 discharge. It is not proposed to discharge cooling water to the Dungourney River during low flow conditions.

SWE 1

SWE 2

SWE 3

GE 1

GE 2

L.14 Control of Diffuse Emissions

There are no diffuse emission points from IDL. L.15 Fit & Proper Person

The PoE Act in Section 83(5)(xi) specifies that the Agency shall not grant a licence unless it is satisfied that the applicant or licensee or transferee as the case may be is a fit and proper person. Section 84(4) of the PoE Act specifies the information required to enable a determination to be made by the Agency. a) Indicate whether the applicant or other relevant person has been convicted under:

• the Environmental Protection Agency Acts 1992 to 2011, • the Waste Management Acts 1996 – 2011, • the Local Government (Water Pollution) Acts 1997 and 1990, • the Air Pollution Act 1987, and • the Air Pollution Act 1987 (Environmental Specifications for Petrol and Diesel

Fuels)(Amendment) Regulations, 2004. IDL has never been convicted under any of the above referenced Acts. b) Provide details of the applicant’s technical knowledge and/or qualifications, along

with that of relevant employees.

IDL has been operating under an existing IPPC Licence since 1999 and has built up a significant level of on-site environmental expertise since before and after the issuing of the original licence. Attachment C1.3 identifies the roles and responsibilities of the main personnel involved in the area of environmental management and IPPC licence compliance. All personnel have to meet a minimum level of qualifications and standards before they can be considered for a position within the IDL environmental team. In relation to the Energy and Environmental Manager the minimum requirements are:

• 3rd Level Qualification (Science, Engineering)


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• Qualification in environmental engineering • IT Skills, Communication Skills, People Management Skills • Knowledge of brewing and distilling • Previous (5+ years) experience of managing others in similar

manufacturing/production setting

The current Energy & Environmental Manager meets these requirements and he is the main site contact for IPPC licence related queries. He has also been responsible for the implementation of the IPPC Licence since it was implemented 13 years ago. c) Provide information to show that the person is likely to be in a position to meet any

financial commitments or liabilities that may have been or will be entered into or incurred in carrying on the activity to which the application relates or in consequences of ceasing to carry out that activity.

Section K details the insurance policies currently in place to cover any accidental emissions. As part of any revised IPPC Licence, IDL is aware that it may be requested to complete an updated Closure, Restoration and Aftercare Management Plan (CRAMP) and an Environmental Liabilities Risk Assessment (ELRA). These reports will identify the necessary costs required to cover these liabilities and at that point in time IDL will put in place the necessary financial provisions, following EPA approval.


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ANNEX 1: TABLES/ATTACHMENTS


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Table E.1 (i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Boiler No. A Emission Point Ref. No:

A1-1

Location:

Boiler House Stack

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

188714E, 073678N

Vent Details

Diameter: 0.5m

Height above Ground(m): 46.5m

Date of commencement of emission:

1975

Characteristics of Emission: Boiler rating Steam Output: Thermal Input:

27,000 kg/hr

20.6 MW Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content:

Natural Gas / Fusel Oil

Not Applicable kg/hr

NOx 250 mg/Nm3

0oC. 3% O2(Liquid or Gas), 6% O2(Solid Fuel) Maximum volume* of emission

Not Applicable m3/hr 0oC, 3 % O2 (liquid or gas), 6 % O2 (solid fuel)

Minimum efflux velocity

Not Applicable m.sec-1

Temperature

oC(max) oC(min) 220oC(avg)

* Volume flow limits for emissions to atmosphere shall be based on Normal conditions of temperature and pressure, (i.e. 0oC,101.3kPa), dry gas; 3% oxygen for liquid and gas fuels; 6% oxygen for solid fuels. (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): Periods of Emission (avg)

60 min/hr 24 hr/day 334 day/yr


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Table E.1 (i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Boiler No. B Emission Point Ref. No:

A1-2

Location:

Boiler House Stack


188714E, 073678N

Vent Details

Diameter: 0.5m



1975


27,000 kg/hr


Natural Gas


NOx 250 mg/Nm3





Temperature






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Table E.1 (i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Boiler No. C Emission Point Ref. No:

A1-3

Location:

Boiler House Stack


188714E, 073678N

Vent Details

Diameter: 0.5m



1975


27,000 kg/hr


Natural Gas


NOx Not Applicable mg/Nm3





Temperature




Back-Up min/hr Back-Up hr/day Back-Up day/yr


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TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point Ref. No:

A2-1

Source of Emission:

Feeds Recovery Stack

Location:

Feeds Recovery Building


188731E, 073699N

Vent Details Diameter:

Height above Ground(m):

0.80m 59.98 m

Date of commencement:

1980

Characteristics of Emission:

(i) Volume to be emitted:

Average/day Nm3/d Maximum/day 878,000 Nm3/d

Maximum rate/hour 36,600 Nm3/h Min efflux velocity 12.0 m.sec-1

(ii) Other factors

Temperature oC(max) oC(min) 75oC(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): Periods of Emission (avg) 60 min/hr 24 hr/day 334 day/yr


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TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point Ref. No:

A2-2

Source of Emission:

Fermentation Tanks (Combined Emission Point)

Location:

Fermentation Tank Farm (Existing and Proposed)


188658E, 073743N

Vent Details Diameter:

Height above Ground(m):

0.2m 18m

Date of commencement:

1975 (original tanks replaced on a phased basis since the mid 1990s)

Characteristics of Emission: Breathing Losses (CO2)

(i) Volume to be emitted:

Average/day Not Applicable Nm3/d

Maximum/day Not Applicable Nm3/d

Maximum rate/hour Not Applicable Nm3/h

Min efflux velocity Not Applicable m.sec-1

(ii) Other factors

Temperature Not Applicable

oC(max) Not Applicable

oC(min) Not Applicable 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): Periods of Emission (avg) 60 min/hr 24 hr/day 350 day/yr


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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

Parameter Prior to treatment(1) Brief As discharged(1)

mg/Nm3 kg/h description mg/Nm3 kg/h. kg/year

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

Total Particulate

Matter

None 50 1.83 14,662

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.


Page 97 of 174

TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (1 table per emission point) Emission Point Reference Number: A2-2

Parameter Prior to treatment(1) Brief As discharged(1)

mg/Nm3 kg/h description mg/Nm3 kg/h. kg/year

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

Carbon Dioxide

(CO2)

None 50,000

(Based on production throughput of 64 million litres)

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.


Page 98 of 174

TABLE E.1(iv): EMISSIONS TO ATMOSPHERE - Minor atmospheric emissions

Grains Intake & Storage

Emission point Description Emission details1 Abatement system employed

Reference Numbers material mg/Nm3(2) kg/h. kg/year

A3-71 Grain Intake Hoppers Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-2 Barley Elevator Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-3 Malt Elevator Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-4 Maize Elevator Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-5 Malt Crossover Conveyor Vent Particulates Existing Licensed Emission Pt None

A3-6 Maize Crossover Conveyor Vent Particulates Existing Licensed Emission Pt None

A3-7 Barley Crossover Conveyor Vent Particulates Existing Licensed Emission Pt None

A3-8 Malt Storage Bin Vent Particulates Existing Licensed Emission Pt None

A3-9 Barley Storage Bin Vent Particulates Existing Licensed Emission Pt None

A3-10 Primary Maize Storage Bin Vent Particulates Existing Licensed Emission Pt None

A3-11 Secondary Maize Storage Bin Vent Particulates Existing Licensed Emission Pt None

1 The maximum emission should be stated for each material emitted, the concentration should be based on the maximum 30 minute mean. 2 Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0oC101.3kPa). Wet/dry should be clearly stated. Include

reference oxygen conditions for combustion sources.


Page 99 of 174


Brew House (Continuous Brewing)



A3-12 Donaldson Extract Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-13 Malt Hammer Mill Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-14 Corn Slurry Tank Vent Vapours Existing Licensed Emission Pt None

A3-15 Low Temperature Cooker – Vent 1

Steam Existing Licensed Emission Pt None

A3-16 Low Temperature Cooker – Vent 2


A3-17 Steam Ejector / Vacuum Pump Vent


A3-18 Cooker Converter Vent Steam Existing Licensed Emission Pt None




Page 100 of 174


Brew House (Batch Brewing - Existing)



A3-19 Buhler Screen Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-20 Rubble Bin Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-21 Malt / Barley Weigh Bin Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-23 Converter A Vent Steam Existing Licensed Emission Pt None

A3-24 Converter B Vent Steam Existing Licensed Emission Pt None

A3-25 Lauter Tun A Vent Steam Existing Licensed Emission Pt None

A3-26 Lauter Tun B Vent Steam Existing Licensed Emission Pt None

A3-27 Copper A Vent Steam Existing Licensed Emission Pt None

A3-28 Copper B Vent Steam Existing Licensed Emission Pt None

A3-29 Underback Vent Steam Existing Licensed Emission Pt None

A3-22 Bub Tanks – Common Vent

CO2 Existing Licensed Emission Pt None




Page 101 of 174


Brew House Expansion (Batch Brewing – New Process) (Previously Supplied to the EPA under a Condition 1.2 Notification)


Reference Numbers material mg/Nm3(2)

kg/h. kg/year

A3-30 Combi Cleaner Vent

(5,400 Nm3/hr)

Particulates 20 0.108 785 Dust filter on exhaust

A3-31 Malt Mill – Cyclone Vent

(1,900 Nm3/hr)

Particulates 7 0.0133 97 Dust filter on cyclone exhaust

A3-32 Barley Mill – Cyclone Vent (5,800 Nm3/hr)

Particulates 7 0.0406 295 Dust filter on cyclone exhaust

A3-33 Mashing-In Vessel Vent Steam - 70 5.09E+05

None – tank vented directly to atmosphere

A3-34 Mash Tun No. 1 - vent Steam - 392 2.85E+06


A3-35 Mash Tun No. 2 - vent Steam - 392 2.85E+06


A3-36 Strong Wort Tank Vent Product Vapours

Tank Venting None – tank vented directly to atmosphere

A3-37 Weak Wort Tank Vent Product Vapours

Tank Venting None – tank vented directly to atmosphere




Page 102 of 174


Existing Still House (Continuous Distillation)



A3-38 Wash Rectification Column Condenser Vent

Alcohol Vapours

Existing Licensed Emission Pt

Safety Aspect: There is a flame arrestor on vent discharge.

A3-39 Extractive Distillation (ED) Column Vent

Alcohol Vapours



A3-40 Extractive Distillation Rectification (EDR) Column Condenser Vent

Alcohol Vapours



A3-41 Wash Pot A Condenser Vent Alcohol Vapours



A3-42 Wash Pot B Condenser Vent Alcohol Vapours



A3-43 Scrubber Condenser Vent Alcohol Vapours



A3-44 Wash Column Condenser Vent

Alcohol Vapours






Page 103 of 174


Existing Still House (Pot Distillation)



A3-45 Feints Still Charger Vent Alcohol Vapours



A3-46 Spirits Still Charger Vent Alcohol Vapours



A3-47 Feints Still Condenser Vent Alcohol Vapours



A3-48 Spirits Still Condenser Vent Alcohol Vapours



A3-49 Flash Vapour Condensate Tank Vent

Alcohol Vapours / Steam



A3-69 Hot Wash Charger Vent Alcohol Vapours / Steam






Page 104 of 174


Feeds Recovery



A3-50 MVR Vacuum Pump Vent Steam Existing Licensed Emission Pt

A3-51 Outloading Bay Dust Extract Vent

Particulates Existing Licensed Emission Pt

A3-52 Wet Grains Silo Vent Particulates Existing Licensed Emission Pt

A3-53 Pellet Bin No. 1 Vent Particulates Existing Licensed Emission Pt



A3-56 Centrifuge No. 2 Vent Particulates & vapours






A3-59 Cake Conveyor Vent Particulates & vapours


A3-60 Pellet Cooler Cyclone Vent Particulates Existing Licensed Emission Pt

A3-61 Draff Tank Vent Particulates Existing Licensed Emission Pt

A3-62 Pellet Elevator vent Particulates Existing Licensed Emission Pt




Page 105 of 174


Office Block, Central Laboratory, Spirit Store and Cooperage Areas



A3-63 R&D Distillation Stack Alcohol Vapours Existing Licensed Emission Pt None

A3-64 ICP / AA Unit Vent Alcohol Vapours Existing Licensed Emission Pt None

A3-65 Fume Cupboard Vent Alcohol Vapours Existing Licensed Emission Pt None

A3-66 Blending Laboratory Vent Alcohol Vapours Existing Licensed Emission Pt Carbon Filter

A3-67 Steam Steriliser & Autoclave Vent


A3-68 Storage Area Vent General air extract Existing Licensed Emission Pt None

A3-70 Barrel coring dust collection system

Particulates Existing Licensed Emission Pt None




Page 106 of 174


New Still House


Reference Numbers material mg/Nm3(2) kg/day kg/year

A3-72 Wash Pot Still C Vent Ethanol vapours - 37.8 12,625 Safety Aspect: There is a flame arrestor on vent discharge.

A3-73 Feints Still No. 2 Vent Ethanol vapours - 169.8 56,713 Safety Aspect: There is a flame arrestor on vent discharge.

A3-74 Pot Still No. 2 Vent Ethanol vapours - 169.8 56,713 Safety Aspect: There is a flame arrestor on vent discharge.

A3-75 Wash Pot Still D Vent Ethanol vapours - 37.8 12,625 Safety Aspect: There is a flame arrestor on vent discharge.

A3-76 Feints Still No. 3 Vent Ethanol vapours - 169.8 56,713 Safety Aspect: There is a flame arrestor on vent discharge.

A3-77 Pot Still No. 3 Vent Ethanol vapours - 169.8 56,713 Safety Aspect: There is a flame arrestor on vent discharge.


reference oxygen conditions for combustion sources. Note: The stills may be filled 6 times a day and operational for 334 days per annum. The wash still has a calculated ethanol emission of 6.3 kg/fill while the feints / pot stills have a calculated ethanol emission of 28.3 kg/fill, each. These rates are equivalent to 0.02% and 0.09% (respectively) of the alcohol content (ethanol) filled into each still.


Page 107 of 174


New Distillation Column Building (GEA Wash Column Plant & GEA Grain Distillation Plant)



A3-78 Vent from Vacuum Pump Scrubber System

Ethanol Vapours 0.002 16 None

(Wash Column Plant) Water Vapours 1 8,016

CO2 19 152,304

A3-79 Vent from Vacuum Pump Scrubber System

Ethanol Vapours 0.014 112 None

(Grain Distillation Plant) Water Vapours 7 56,112

CO2 133 1,066,128




Page 108 of 174

TABLE E.1(v): EMISSIONS TO ATMOSPHERE – Fugitive and Potential atmospheric emissions

Emission point ref. no. (as per flow diagram)

Description Malfunction which could cause an

emission

Emission details (Potential max. emissions)1

Material mg/Nm3 kg/hour

A4-10 Pressure Relief Panel in malt grain elevator vent

Over-pressure in elevator system

Malt Grain - 3 (based on contents of two elevator buckets)



















1 Estimate the potential maximum emission for each malfunction identified.


Page 109 of 174

TABLE E.1(v): EMISSIONS TO ATMOSPHERE – Fugitive and Potential atmospheric emissions

Emission point ref. no. (as per flow diagram)

Description Malfunction which could cause an

emission

Emission details (Potential max. emissions)1

Material mg/Nm3 kg/hour

A4-8 Pressure Relief Panel in barley grain elevator vent


Barley Grain - 3 (based on contents of two elevator buckets)

A4-9 Pressure Relief Panel in maize grain elevator vent


Maize Grain - 3 (based on contents of two elevator buckets)

A4-11 Pressure Relief Panel in pellet elevator vent


Pellets - 6 (based on contents of two elevator buckets – higher density)

1 Estimate the potential maximum emission for each malfunction identified.


Page 110 of 174

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

Emission Point:

Emission Point Ref. No: SWE 1

Source of Emission: Cavern Water (used for cooling)

Location of discharge : Mill Stream

Grid Ref. (12 digit, 6E,6N): 188720E, 073628N

Name of receiving waters and water body code: Dungourney River (via the Mill Stream) and onto Owennacurra River

Flow rate in receiving waters: 0.03 m3.sec-1 Dry Weather Flow

Dungourney River 0.06 m3.sec-1 95%ile flow

Available assimilative capacity:

Refer to Natura Impact Statement & Section 13 of the EIS kg/day

Emission Details:

(i) Volume to be emitted

Normal/day N/A m3 Maximum/day 4,020 m3

Maximum rate/hour N/A 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):

Periods of Emission (avg) 60 min/hr 24 hr/day 334 day/yr


Page 111 of 174

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

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)


kg/day kg/year

Total Organic Carbon (TOC)

<40 N/A


Page 112 of 174


Emission Point:


(will become mainly redundant when SWE 2 drainage is connected to the SWE 3 drainage system)

Source of Emission: Rainfall Runoff from Spirit Store and Vat House Catchment Area

Location of discharge : Mill Stream (during the normal course of events the flow discharges to the bed of the Mill Stream, under extreme rainfall events the runoff will flow to the Dungourney River)







Emission Details:


Normal/day 55 m3 Maximum/day 452 m3

Maximum rate/hour N/A m3 Normal per day based on 30-yr annual average rainfall = 1,100 mm/yr averaged out over 365 days.

Maximum per day based on a 25mm per day rainfall event. (Total Area = 18,093 m2)

(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):

Periods of Emission (avg) Dependent on Rainfall min/hr hr/day day/yr


Page 113 of 174







kg/day kg/year

Total Organic Carbon

(TOC)

N/A N/A


Page 114 of 174


Emission Point:


Source of Emission: Rainfall Runoff from Warehouse Catchment Area

Location of discharge : Mill Stream – (during normal course of events the flow discharges to the bed of the Mill Stream, under extreme rainfall events the runoff will flow the Dungourney River)







Emission Details:


Normal/day 310 m3 Maximum/day 2,569 m3


Maximum per day based on a 25mm per day rainfall event. (Total Area = 102,761 m2)


to be included):

Periods of Emission (avg) Dependent on Rainfall Volumes min/hr hr/day day/yr


Page 115 of 174







kg/day kg/year


<60 N/A


Page 116 of 174

TABLE E.3(i): EMISSIONS TO SEWER (One page for each emission)

Emission Point:

Emission Point Ref. No: SE 1

Location of connection to sewer: Wastewater Treatment Plant Discharge

Grid Ref. (12 digit, 6E,6N): 188793 E, 073506 N

Name of sewage undertaker: Midleton UDC

Emission Details:


Normal/day m3 Maximum/day 2,500 m3

Maximum rate/hour 150 m3


to be included):

Periods of Emission (avg)



Page 117 of 174

TABLE E.3(ii): EMISSIONS TO SEWER - Characteristics of the emission (1 table per emission point) Emission point reference number: SE 1






kg/day kg/year

COD 125 312.5 114.063

TOC 120 300 109,500

Suspended Solids 35 87.5 31,938

Fats, Oil & Grease 20 50 18,250


Page 118 of 174


Emission Point:

Emission Point Ref. No: SE Final

Location of connection to sewer: Wastewater Treatment Plant Discharge


Name of sewage undertaker: Midleton UDC

Emission Details:


Normal/day m3 Maximum/day 5,000 m3



to be included):




Page 119 of 174

TABLE E.3(ii): EMISSIONS TO SEWER - Characteristics of the emission (1 table per emission point) Emission point reference number: SE Final






kg/day kg/year

BOD Note 1 & 3 25 125 45,625

COD Note 1 & 3 125 625 228,125

Suspended Solids Note 2 & 3

35 175 63,875

Total Nitrogen (as

N) Note 4 & 5

15 75 27,375

Sulphates 600 3000 1,095,000

Cadmium 0.2 1.0 365

Chromium 0.5 2.5 912.5

Copper 0.5 2.5 912.5

Lead 0.5 2.5 912.5

Zinc 0.5 2.5 912.5

Nickel 0.5 2.5 912.5

Fats, Oil & Grease 20 100 36,500

Faecal Coliforms Note

6 & 7

Geometric mean of less than or equal to 250

fc/100mls of sample


Page 120 of 174

Notes taken from Amendment C to the existing IPPC Licence (P0442-01). Notes:

Note 1: Non-compliant samples shall not deviate from the parametric value by more than 100%. Note 2: Non-compliant samples shall not deviate from the parametric value by more than 150%. Note 3: The frequency of non-compliant samples shall be in accordance with those figures listed in the 5th Schedule of the Urban

Waste Water Treatment Regulations, 2001- SI No. 254 of 2001. Note 4: Compliance shall be assessed using the annual mean figure; the annual mean of the samples shall conform to the

Emission Limit Value. Note 5: The requirements for Total Nitrogen (as N) can be assessed using daily average concentration figures where, as per the

Urban WWT Regulations, 2002 (SI NO. 254 of 2001), it is proved that the same level of protection is provided to the receiving water. In this case the daily average must not exceed 20 mg/l of Total Nitrogen (as N) for all samples when the temperature from the effluent in the biological reactor is superior or equal to 12oC.

Note 6: Compliance shall be measured on the basis of a 50 (fifty) sample rolling programme. Note 7: 95% of all faecal coliform results shall be less than, or equal to, 1,000 fc/100mls.


Page 121 of 174


Emission Point:

Emission Point Ref. No: SE 2

Location of connection to sewer: Foul Sewer Discharge to Heritage Centre Foul Sewer


Name of sewage undertaker: Cork County Council (after discharge from Heritage Centre)

Emission Details:


Normal/day m3 Maximum/day 40 m3



to be included):




Page 122 of 174

TABLE E.3(ii): EMISSIONS TO SEWER - Characteristics of the emission (1 table per emission point) Emission point reference number: SE 2






kg/day kg/year

No measurements

taken – emissions

from toilets and

canteen only.


Page 123 of 174

TABLE E.4(i): EMISSIONS TO GROUND (1 Page for each emission point)

Emission Point or Area: Emission Point/Area Ref. No:

GE 1

Emission Pathway: (borehole, well, percolation area, soakaway, landspreading, etc.)

Surface water runoff from roofs and roadways.

Location :

Fox’s Hollow (Lower Fields Catchment)


188899E, 074078N

Elevation of discharge: (relative to Ordnance Datum)

4.51m (Top of wall at weir)

Aquifer classification for receiving groundwater body:

Regionally Important Limestone Karstic Aquifer

Groundwater vulnerability assessment (including vulnerability rating):

Extreme to High (Refer to Figure 11.2 of the EIS – Page 99)

Identity and proximity of groundwater sources at risk (wells, springs, etc):

Fox’s Hollow (Underground cavern network)

Identity and proximity of surface water bodies at risk:

Dungourney River

Emission Details:


Normal/day 193 m3 Maximum/day 1, 600 m3


Maximum per day based on a 25mm per rainfall event. (Total Area = 63,990m2)


to be included):



Page 124 of 174

TABLE E.4(ii): EMISSIONS TO GROUND - Characteristics of the emission (1 table per emission point) Emission point/area reference number: GE 1






kg/day kg/year


<60 N/A


Page 125 of 174

TABLE E.4(i): EMISSIONS TO GROUND (1 Page for each emission point)

Emission Point or Area: Emission Point/Area Ref. No:

GE 2

Emission Pathway: (borehole, well, percolation area, soakaway, landspreading, etc.)

Surface water runoff from roofs and roadways.

Location :

Underground Cavern located by site entrance


188646E, 073982N

Elevation of discharge: (relative to Ordnance Datum)

5.9m

Aquifer classification for receiving groundwater body:

Regionally Important Limestone Karstic Aquifer

Groundwater vulnerability assessment (including vulnerability rating):

Extreme to High (Refer to Figure 11.2 of the EIS – Page 99)

Identity and proximity of groundwater sources at risk (wells, springs, etc):

Underground cavern network

Identity and proximity of surface water bodies at risk:

Dungourney River

Emission Details:


Normal/day 26 m3 Maximum/day 215 m3

Maximum rate/hour m3 Normal per day based on 30-yr annual average rainfall = 1,100 mm/yr averaged out over 365 days.

Maximum per day based on a 25mm per rainfall event. (Total Area = 8,608m2)


to be included):



Page 126 of 174

TABLE E.4(ii): EMISSIONS TO GROUND - Characteristics of the emission (1 table per emission point) Emission point/area reference number: GE 2






kg/day kg/year

See Note 1 below

Note 1: Emission has not been characterised as it contains only rainfall runoff from hardstanding areas from the catchment area

identified in Figure 10.5 of the EIS (Page 90).


Page 127 of 174

Table E.5(i): NOISE EMISSIONS - Noise sources summary sheet

Source Emission

point Ref. No

Equipment Ref. No

Sound Pressure1 dBA at

reference distance

Octave bands (Hz) Sound Pressure1 Levels dB(unweighted) per band

Impulsive or tonal qualities

Periods of

Emission

31.5 63 125 250 500 1K 2K 4K 8K

1. For items of plant sound power levels may be used. Please refer to Section 14 of the EIS and in particular Table 14.13 (Page 150). The noise source levels used in the EIS

assessment should be considered indicative only. Actual plant items (not yet finalised) will be selected using the EIS

indicative levels as maximum sound power level criteria.


Page 128 of 174

TABLE F.1(i): ABATEMENT / TREATMENT CONTROL

Emission point reference number: SE 1 / WWTP

Control1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up

Feed to WWTP Flow Transmitter (FT-4202)

On PEMAC System – critical item

Annual Not applicable

WWTP Discharge (SE 1 Discharge)

Flow Transmitter (FT-4205)


Annual Not applicable

Equalisation Tank pH pH probe (AT-4201) On PEMAC System – critical item

Monthly (+/- 0.2 pH units)

Not applicable

Mixing Chamber pH pH probe (AT-4203) On PEMAC System – critical item


Not applicable

Aeration Tank DO Dissolved Oxygen meter (AT-4205)


Six Monthly (+/- 0.5 DO units)

Not applicable

Control1 parameter Monitoring to be carried out3 Monitoring equipment Monitoring equipment calibration

1 List the operating parameters of the treatment / abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement / treatment system. 3 List the monitoring of the control parameter to be carried out.


Page 129 of 174


Emission point reference number: SE 1 / WWTP


Aeration Tank MLSS Mixed Liquor Suspended Solids Probe (AT-4206)


Annually (+/- 1.0 MLSS units)

Not applicable

Aeration Tank pH pH probe (AT-4208A) On PEMAC System – critical item


Not applicable

Aeration Tank Temp Temp probe (AT-4208B) On PEMAC System – critical item

Monthly (+/- 2.0 oC) Not applicable

Equalisation Tank Levels Level Probe No. 1 (LT-4202A)


Annually Not applicable

Equalisation Tank Levels Level Probe No. 2 (LT-4202B)






Page 130 of 174


Emission point reference number: SE 1 / WWTP / SE Final


SE Final Flow Flow Transmitter (FT-4207)



Permeate pH (SE 1) pH probe (AT-4211A) On PEMAC System – critical item


Not applicable

SE FInal pH pH probe (AT-4209A) On PEMAC System – critical item


Not applicable




Page 131 of 174

TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : A1-1

Parameter Monitoring frequency Accessibility of Sampling Points

Sampling method Analysis method/ technique

NOx (as NO2) Annually Accessible EN14792:2005 Flue Gas Analyser

CO Annually Accessible EN15058:2004 Flue Gas Analyser


Page 132 of 174







Page 133 of 174







Page 134 of 174




Total Particulate

Matter

Annually Accessible EN13284-1:2002 Particulates Sampler


Page 135 of 174

TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : SE 1



TOC Continuous Accessible On line TOC meter

with recorder

EN ISO 1484:1997

Chemical Oxygen

Demand (COD)

Daily Accessible 24-hr flow

proportional

Composite Sample

Hach Method 8000

Suspended Solids Daily Accessible 24-hr flow

proportional

Composite Sample

APHA 2540

Oils, fats and greases Monthly Accessible 24-hr flow

proportional

Composite Sample

APHA98.5520.D


Page 136 of 174

TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : SE Final



Flow Continuous Accessible On-line flow meter

with recorder

Temperature Continuous Accessible On-line temperature

probe with recorder

pH Continuous Accessible pH electrode/meter

and recorder

TOC Continuous Accessible On line TOC meter

with recorder

Chemical Oxygen

Demand (COD)

Daily Accessible 24-hr flow

proportional

Composite Sample

Hach Method 8000

Biological Oxygen

Demand (BOD)

Monthly Accessible 24-hr flow

proportional

Composite Sample

APHA98.5210.B

Suspended Solids Weekly Accessible 24-hr flow

proportional

Composite Sample

APHA 2540

Total Nitrogen Monthly Accessible 24-hr flow

proportional

Composite Sample

EN 12260:2003

Sulphates Bi-annually Accessible 24-hr flow

proportional

Composite Sample

ISO 10304-04


Page 137 of 174

TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : SE Final



Heavy Metals

(cadmium, chromium,

copper, lead, zinc,

nickel)

Annually Accessible 24-hr flow

proportional

Composite Sample

Standard Method (ICP-

MS)

Oils, fats and greases Monthly Accessible 24-hr flow

proportional

Composite Sample

APHA 5520D

Faecal Coliforms Fortnightly Accessible Grab Sample APHA 9222B

Volatile Organic

Compounds

Annually Accessible 24-hr flow

proportional

Composite Sample

Standard Method


Page 138 of 174

TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : SWE 1



pH Weekly Accessible Grab pH electrode/meter

and recorder

TOC Continuous Accessible Continuous On line TOC meter

with recorder

Visual Daily Accessible Grab Not Applicable


Page 139 of 174




pH Monthly Accessible Grab pH electrode/meter

COD Quarterly Accessible Grab Hach Method 8000

Visual Weekly Accessible Grab Not Applicable


Page 140 of 174




pH Monthly Accessible Grab pH electrode/meter

COD Quarterly Accessible Grab Hach Method 8000

Visual Weekly Accessible Grab Not Applicable


with recorder


Page 141 of 174

TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : GE 1




with recorder


Page 142 of 174

TABLE F.2(ii): AMBIENT ENVIRONMENT MONITORING AND SAMPLING POINTS ( 1 table per monitoring point)

Monitoring Point Reference No: GW 1

Parameter Monitoring frequency Accessibility of Sampling point

Sampling method Analysis method / technique

pH

COD

Nitrate

Total Ammonia

Total Nitrogen

Conductivity

Chloride

Fluoride

Lead

Zinc

Potassium

Phosphorus

Arsenic

Sulphate

Mercury

Annually Accessible Grab – following

purging of well water

-

Colorimetry

Colorimetry

Colorimetry

Calculation

Electrometry

Colorimetry

Colorimetry

ICP-MS

ICP-MS

ICP-MS

Colorimetry

ICP-MS

Colorimetry

ICP-MS


Page 143 of 174





pH

COD

Nitrate

Total Ammonia

Total Nitrogen

Conductivity

Chloride

Fluoride

Lead

Zinc

Potassium

Phosphorus

Arsenic

Sulphate

Mercury



-

Colorimetry

Colorimetry

Colorimetry

Calculation

Electrometry

Colorimetry

Colorimetry

ICP-MS

ICP-MS

ICP-MS

Colorimetry

ICP-MS

Colorimetry

ICP-MS


Page 144 of 174





pH

COD

Nitrate

Total Ammonia

Total Nitrogen

Conductivity

Chloride

Fluoride

Lead

Zinc

Potassium

Phosphorus

Arsenic

Sulphate

Mercury



-

Colorimetry

Colorimetry

Colorimetry

Calculation

Electrometry

Colorimetry

Colorimetry

ICP-MS

ICP-MS

ICP-MS

Colorimetry

ICP-MS

Colorimetry

ICP-MS


Page 145 of 174





pH

COD

Nitrate

Total Ammonia

Total Nitrogen

Conductivity

Chloride

Fluoride

Lead

Zinc

Potassium

Phosphorus

Arsenic

Sulphate

Mercury



-

Colorimetry

Colorimetry

Colorimetry

Calculation

Electrometry

Colorimetry

Colorimetry

ICP-MS

ICP-MS

ICP-MS

Colorimetry

ICP-MS

Colorimetry

ICP-MS


Page 146 of 174

Table G.1(i) Details of Process related Raw Materials, Intermediates, Products, etc., used or generated on the site

Ref.

No or

Material/

Substance(1)

CAS

Number

Danger(2)

Category

Amount

Stored

Annual

Usage

Nature of Use R(3) -

Phrase

S(3) -

Phrase

Hazard

Statement (4)

Code (tonnes) (tonnes) Raw Materials Grain Not applicable Not applicable 400 165,000 Raw material Not applicable Not applicable Not applicable Product/By-

product

Distillers Dark Grains Not applicable Not applicable 240 32,000 By-Product Not applicable Not applicable Not applicable Moist grains Not applicable Not applicable 170 42,000 By-Product Not applicable Not applicable Not applicable Syrup Not applicable Not applicable 120 20,000 By-Product Not applicable Not applicable Not applicable Pot Whiskey (Ethanol

60-64% v/v) Not applicable Not applicable

66,025 17,358 Product R23,24,25 S16 Not applicable

Grain Whiskey (Ethanol 65-70% v/v)

Not applicable Not applicable 118,500 34,716

Product R23,24,25 S16 Not applicable

Process Additions

Amylo 300 9032-08-0 (10-25%)

Harmful, Xn 6 80

Brewhouse R42 S23 Not available

Ban 240

9000-90-2 (1-10%)

Harmful, Xn 6 50

Brewhouse R42 S22,S23 Not available

Bioamylase D 9000-90-2 Harmful, Xn 6 50 Brewhouse R42 S23,S24,S36/37 Not available

Biogard 79-09-4 Corrosive

3 10 Feeds Recovery R34 S25.S26.S45,

S1/2 Not available

Cakeguard

79-09-4 Corrosive 3 10

Feeds Recovery R22, R36/38, R51/53

None defined Not available

Convertase LD 9032-08-0 Harmful, Xn 4 30 Fermentation R42 S23 Not available Damped Yeast Food 9032-08-0 Harmful, Xn 0.4 4 Fermentation R42 S23 Not available DCL'M' Yeast Not applicable Not applicable 3 100 Fermentation Not applicable Not applicable Not applicable

Hitempase STXL 9000-90-2 Harmful, Xn

4 50 Brewhouse R42 S23, S24,

S36/37 Not available


Page 147 of 174

Table G.1(i) Details of Process related Raw Materials, Intermediates, Products, etc., used or generated on the site (contd.)

Ref.

No or

Material/

Substance(1)

CAS

Number

Danger(2)

Category

Amount

Stored

Annual

Usage

Nature of Use R(3) - Phrase S(3) -

Phrase

Hazard

Statement (4)

Code (tonnes) (tonnes)

Promalt 4 TR 9000-90-2; 62213-14-3; 76774-43-1

Harmful, Xn 4 100

Brewhouse R42 S23,S24, S36/37

Not available

Pinnacle Yeast Not applicable Not applicable 3 100 Fermentation Not applicable Not applicable Not available Rapeseed Oil Not applicable Irritant, Xi 0.1 1 Feeds Recovery Not applicable Not applicable Not applicable

Termamyl Classic 9000-90-2 Harmful, Xn

4 50 Fermentation R42 S23, S24,

S36/37. Not available

CIP Chemicals

Brucos (Bulk Caustic B/hse)

1310-73-2 (25-30%)

Corrosive, C

25000 L 800000 L Brewhouse

R35 S2, S26, S36/37/39, S45

Not available

BTA70 (IBC)

5064-31-3 Irritant, Xi; Harmful, Xn 3000 L 10000 L Feeds Recovery

R22, R36. S24/25.S26,S28, S36/37/39

Not available

Circul SHC (Stillhouse)

1310-73-2 Corrosive, C 10000 L 60000 L Stillhouse

R35 S1/2, S26, S37/39, S45

Not available

Cirtol 6

Not applicable Not applicable 500 L 2000 L Feeds Recovery

R38 S2, S26, S27, S37/39.

Not available

Hydrox 12

7722-84-1 (<10%) 79-21-0 (10-20%)

Irritant, Xi; Corrosive, C

500 L 2000 L Feeds Recovery

R36, R34, R8, R5, R20/21/22, R36/37, R35

S3, S24/25, S36/37/39, S26, S27/28

Not available

L61 (IBC)

50-00-0 Toxic, T 3000 L 10000 L Feeds Recovery

R23/24/25, R34, R40, R43.

Not applicable Not available

Stabicip MC

64-02-8 (25-30) 22919-56-8 (2-5%)

Harmful, Xn; Irritant, Xi; 500 L 5000 L Brewhouse

R22, R41, R36/37/38.

S2, S26, S39. Not available

Stabicip OXI

7722-84-1 (8-35%) 146340-16-1 (1-5%) 28348-53-0 (1-5%)

Corrosive, C; Harmful, Xn; Irritant, Xi; Oxidising, O; Dangerous for the environment, N.

500 L 5000 L Brewhouse

R22,R35, R8, R5, R36, R38, R50

Not applicable H271, H272, H302, H314, H315, H318, H319, H335, H400

Nitric Acid

7697-37-2 Corrosive, C 2000 L 10000 L N/A

R35 S1/2, S23, S26, S36, S45

Not available


Page 148 of 174


Ref.

No or

Material/

Substance(1)

CAS

Number

Danger(2)

Category

Amount

Stored

Annual

Usage

Nature of Use R(3) - Phrase S(3) -

Phrase

Hazard

Statement (4)

Code (tonnes) (tonnes) WWTP Chemicals Citric Acid 77-92-9 Xi, Irritant 500 L 10 WWTP R36 S26 Not available

Hydrochloric Acid (IBC)

7647-01-0

Corrosive, C 4000 L 70

WWTP R34, R37 S1/2, S36, S36/37/39, S45.

Not available

Liq. Caustic (Bulk WWTP)

1310-73-2 Corrosive, C 1000 L 30

WWTP R35 S1/2, S26, S37/39, S45.

Not available

Liq. Caustic (Biocel IBC)

1310-73-2 Corrosive, C 1000 L 5

WWTP R35 S1/2, S26, S37/39, S45.

Not available

Zetag 9068FS

69011-36-5 (<5%) 64742-47-8 (20-30%) Harmful, Xn; Irritant Xi 2 20

WWTP R36/R38 S26, S28.1, S23.3

Not available

Cooling Tower

Chemicals

Midland 171 7631-90-5 Harmful, Xn 0.4 2 Cooling Tower R22, R31 S2, S36/37/39. Not available

Sod. Hypochlorite (25 Litre)

007681-52-9 Corrosive, C 5000 L 3000 L

Cooling Tower R31, R34, R36/38.

S1/2, S28, S45, S50.

Not available

Cooling Care 1550 Not applicable Not applicable 2 10 Cooling Tower Not applicable Not applicable Not applicable

Cooling Care 8466

23783-26-8 (5-10%) 113221-69-5 (2-5%)

Corrosive, C

0.5 6

Cooling Tower R35, R43, R22, R34, R35.

S2, S26, S36/37/39.

Not available

Cooling Care 1250 Not applicable Not applicable 0.5 6 Cooling Tower Not applicable Not applicable Not applicable

Componenta FG

Not applicable Not applicable 0.1 0.5

Cooling Tower - defoamer

Not applicable Not applicable Not applicable

P3 Hypochloron RS

7681-52-9 (5-10%) Corrosive, C

2 30

Cooling Tower - disinfectant

R34, R31, R50. S2, S7, S26, S36/37/39, S45.

Not available


Page 149 of 174


Ref.

No or

Material/

Substance(1)

CAS

Number

Danger(2)

Category

Amount

Stored

Annual

Usage


Phrase

S(3) -

Phrase

Hazard

Statement (4)

Code (tonnes) (tonnes) Boiler Chemicals Granular Salt 007647145 Not applicable 10 50 Boilers Not applicable Not applicable Not applicable

BoilerCare 1011 7631-90-5 (10-20%) Not applicable 0.5 5 Boilers R22, R31. Not applicable Not available

BoilerCare 2036 Not available Not applicable 0.5 3 Boilers Not applicable Not applicable Not applicable

RO Plant

Chemicals

Flocon 135 71050-62-9 (33-37%) Not applicable 100 L 500 L RO Plant Not applicable Not applicable Not applicable

Memclean AVP 11

15630-89-4 7758-29-4 60-00-4

Xi, Irritant

0.05 0.15

RO Plant R36 S26, S28, S36/37/39

Not available

Memclean AVP03

77-92-9 (?%) 7758-29-4 (?%)

Xi, Irritant 0.05 0.15

RO Plant R36 S26, S28, S36/37/39

Not available

Polyaluminium Chloride

39290-78-3 Xi, Irritant 100 L 500 L

RO Plant R36/38 S1/2, S26, S28.

Not available

Sodium Metabilsuphite

7681-57-4 Xn, Harmful 0.3 0.3 RO Plant R22, R31, R41.

S2, S26, S39, S46.

Not available

Water Treatment

Chemicals

ShowerHead Plus

Not applicable Xi, Irritant 0.1 0.4

Site wide R36/38 S2, S24/25, S26, S45.

Not available

P3 Stabicip HX

64-02-8 (25-30%) 215-185-5 (0.5-1%)

C, Corrosive; Xn, Harmful

2.5 20

WTP R22, R41, R35

S2, S26, S36/37/39, S45

Not available


Page 150 of 174


Ref.

No or

Material/

Substance(1)

CAS

Number

Danger(2)

Category

Amount

Stored

Annual

Usage


Phrase

S(3) -

Phrase

Hazard

Statement (4)

Code (tonnes) (tonnes) Engineering

Rocol RTD Not Classified Not Classified 12 X

500mL 24 X 500mL

Engineering and maintenance


Polyglass Hand Applied

100-42-5 (20-30%) 80 - 62 – 6 (0 – 5%)

Xn, Harmful & F, Flammable

N/A N/A


R10, R20, R36/38 R11, R37/38, R43

S23, S37/39

Not available

Mobil DTE 24 Not Classified Not Classified 1 x 208ltr 2 x 208ltr



Mobil DTE 26 (Mobil DTE 16M)

Not Classified Not Classified 2 x 208ltr 4 x 208ltr



Mobilgear 600 XP 220 (630)
















Shell Retinax Grease LX2&3 (Replaced Mobillux EP 2)

12001-85-3 (1-2%) Xi, Irritant 3 boxes of 12 x 0.4ltr

4 boxes of 12 x 0.4ltr


R36/38, R51/53

Not applicable Not applicable

Shell Diala GX Dried Transformer Oil

Not Classified Not Classified 1 x 20ltr N/A



Solvent SKI 75(Replaced SW-3i)

64742-47-8

Xn, Harmful 1 x 5ltr 4 x 5ltr


R65, R66 S16, S24, S62.

Not available

Mobil SCH 625 (Clg Tw A)




Mobil FGL-2 Not Classified Not Classified 2 x 50ltr 4 x 50ltr



Shell Cassida Fluid GL 220





Page 151 of 174


Ref.

No or

Material/

Substance(1)

CAS

Number

Danger(2)

Category

Amount

Stored

Annual

Usage


Phrase

S(3) -

Phrase

Hazard

Statement (4)

Code (tonnes) (tonnes) Shell Cassida Fluid GL

320 Not Classified Not Classified

1 x 50ltr 3 x 50ltr Engineering and maintenance


Shell Cassida Fluid GL 460




Shell Cassida Fluid HF 32(Replaced Mobiltemp SHC 100)

Not Classified. Not Classified.

1 x 25ltr 2 x 25ltr





1 x 25ltr 2 x 25ltr





1 x 25ltr 2 x 25ltr



Shell Cassida Grease EPS 00

Not Classified. Not Classified. 6 x 19ltr 8 x 19ltr



Shell Cassida Grease RLS 2

Not Classified. Not Classified. 3 x 19ltr 3 x 19ltr



Pureshield Argon 7440-37-1

Asphyxiant 3 x 85kg 3 x 85kg



Oxygen (High Purity) 7782-44-7

Oxidant 5 x 85kg 5 x 85kg


R8 S9, S17 Not applicable

Acetylene (Dissolved) 74-86-2

Explosive / Highly Flammable 4 x 83kg 4 x 83kg


R12, R5, R6

Not applicable H280, H220, EUH006

Nitrogen (Zero Grade) 7727-37-9

Asphyxiant 2 x 85kg 2 x 85kg


Not applicable Not applicable Not available

Propane

74-98-6.

Flammable 1 x 15kg 1 x 15kg


R12 S9, S16 Not applicable

Laboratory

Materials A full list of laboratory related materials is provided in Attachment G – note laboratory related materials are used in small quantities on site.

Notes: 1. In cases where a material comprises a number of distinct and available dangerous substances, please give details for each component substance. 2. Article 2(2) of S.I. No. 116/2003

3. Schedules 9 and 10 of S.I. No. 62/2004 (as amended by S.I. No. 271/2008) 4. EC Regulation 1272/2008 (Chemicals Act 2008 (13 of 2008) and 2010)

n/a = not applicable


Page 152 of 174

Table G.1(ii) Details of Process related Raw Materials, Intermediates, Products, etc., used or generated on the site

Ref.

No or

Material/

Odour Pollutants

(Tick and specify Group/Family Number)

Code Substance(1) Odourous Yes/No

Description

Threshold

EC EO (Surface Waters) Regulations 2009

EC EO Groundwater) Regulations 2010

µg/m3 Specific pollutants

Priority (hazardous) substances

Hazardous1

Non-hazardous1

Process Additions

Amylo 300 Yes Slight fermentation

odour n/a n/a n/a n/a n/a

Ban 240 No n/a n/a n/a n/a n/a n/a

Bioamylase D Yes Slight fermentation


Biogard Yes Pungent n/a n/a n/a n/a n/a Cakeguard Yes Pungent n/a n/a n/a n/a n/a

Convertase LD Yes Slight fermentation


Damped Yeast Food

Yes Slight fermentation odour

n/a n/a n/a n/a n/a

DCL'M' Yeast No n/a n/a n/a n/a n/a n/a

Hitempase STXL Yes Slight fermentation


Promalt 4 TR

Yes Slight fermentation odour

n/a n/a n/a n/a n/a

Pinnacle Yeast Yes Yeasty n/a n/a n/a n/a n/a Rapeseed Oil Yes Weak odour n/a n/a n/a n/a n/a Termamyl Classic No n/a n/a n/a n/a n/a n/a


Page 153 of 174

Table G.1(ii) Details of Process related Raw Materials, Intermediates, Products, etc., used or generated on the site (contd.)

Ref.

No or

Material/

Odour Pollutants



Description

Threshold





Hazardous1 Non-hazardous1

CIP Chemicals Brucos (Bulk Caustic

B/hse) Yes Faint odour n/a n/a n/a Undetermined Undetermined

BTA70 (IBC) No n/a n/a n/a n/a Undetermined Undetermined

Circul SHC (Stillhouse) Yes Slight n/a n/a n/a Undetermined Undetermined

Cirtol 6 Yes Slight n/a n/a n/a n/a n/a

Hydrox 12

Yes Vinegar like n/a n/a n/a 7722-84-1: undetermined 79-21-0: n/a

7722-84-1: undetermined 79-21-0: non hazardous

L61 (IBC) Yes Characteristic n/a n/a n/a n/a Non Hazardous

Stabicip MC Yes Amine-like n/a n/a n/a n/a n/a

Stabicip OXI

Yes Aromatic n/a n/a n/a CAS No. 7722-84-1: Undetermined

CAS No. 7722-84-1: Undetermined

Nitric Acid Yes Pungent n/a n/a n/a Undetermined Undetermined

WWTP Chemicals Citric Acid Yes Slight n/a n/a n/a Undetermined Undetermined

Hydrochloric Acid (IBC) Yes Pungent, Characteristic n/a n/a n/a n/a n/a

Liq. Caustic (Bulk WWTP) No n/a n/a n/a n/a Undetermined Undetermined

Liq. Caustic (Biocel IBC) Yes Slight odour n/a n/a n/a Undetermined Undetermined

Zetag 9068FS Yes Of hydrocarbons n/a n/a n/a n/a n/a


Page 154 of 174


Ref.

No or

Material/

Odour Pollutants



Description

Threshold






Cooling Tower

Chemicals

Midland 171 Yes Pungent Sulphur n/a n/a n/a Undetermined Undetermined

Sod. Hypochlorite (25 Litre)

Yes Characteristic bleach odour

n/a n/a n/a n/a Non Hazardous

Cooling Care 1550 No n/a n/a n/a n/a n/a n/a

Cooling Care 8466 Yes Faint odour n/a n/a n/a n/a n/a

Cooling Care 1250 No n/a n/a n/a n/a n/a n/a

Componenta FG Yes Aromatic n/a n/a n/a n/a n/a

P3 Hypochloron RS Yes Chlorine n/a n/a n/a n/a Non Hazardous

Boiler Chemicals

Granular Salt No Odourless n/a n/a n/a Undetermined Undetermined

BoilerCare 1011 No n/a n/a n/a n/a n/a n/a

BoilerCare 2036 Yes Faint odour n/a n/a n/a n/a n/a

RO Plant Chemicals

Memclean AVP 11

Yes Slight n/a n/a n/a CAS 7758-29-4: n/a CAS 60-00-4: Undetermined

CAS 7758-29-4: Non Hazardous CAS 60-00-4: Undetermined

Memclean AVP03 Yes Slight n/a n/a n/a Undetermined Undetermined

Polyaluminium Chloride No n/a n/a n/a n/a n/a n/a

Sodium Metabilsuphite

Yes Slightly pungent, smell of sulphur dioxide

n/a n/a n/a Undetermined Undetermined


Page 155 of 174


Ref.

No or

Material/

Odour Pollutants



Description

Threshold






Water Treatment

Chemicals

ShowerHead Plus Yes Barely perceptible odour n/a n/a n/a n/a n/a

P3 Stabicip HX CAS 001310-73-2

Yes Faint odour n/a n/a n/a Undetermined

Undetermined

Engineering

Rocol RTD Yes Characteristic n/d n/a n/a Hazardous n/a

Polyglass Hand Applied Yes Aromatic odour of styrene n/a n/a

CAS 80-62-6:n/a; CAS 100-42-5: Hazardous

CAS 80-62-6: Undetermined; CAS 100-42-5:n/a

Mobil DTE 24 Yes Characteristic n/d n/a n/a Undetermined Undetermined Mobil DTE 26 (Mobil DTE

16M) Yes Characteristic n/d n/a n/a Undetermined Undetermined Mobilgear 600 XP 220

(630) Yes Characteristic n/d n/a n/a n/a n/a Mobilgear 600 XP 320



(636) Yes Characteristic n/d n/a n/a n/a n/a Shell Retinax Grease

LX2&3 (Replaced Mobillux EP 2) Yes Slight hydrocarbon n/a n/a n/a n/a n/a

Shell Diala GX Dried Transformer Oil Yes Slight hydrocarbon n/a n/a n/a n/a n/a

Solvent SKI 75(Replaced SW-3i) Yes Characteristic n/a n/a n/a n/a n/a


Page 156 of 174


Ref.

No or

Material/

Odour Pollutants



Description

Threshold






Mobil SCH 625 (Clg Tw A) Yes Characteristic n/d n/a n/a n/a n/a Mobil FGL-2 Yes Mineral oil odour n/a n/a n/a n/a n/a Shell Cassida Fluid GL 220 No n/a n/a n/a n/a n/a n/a Shell Cassida Fluid GL 320 No n/a n/a n/a n/a n/a n/a Shell Cassida Fluid GL 460 Yes mild n/a n/a n/a n/a n/a Shell Cassida Fluid HF

32(Replaced Mobiltemp SHC 100) No n/a n/a n/a n/a n/a n/a

Shell Cassida Fluid HF 68(Replaced Mobiltemp SHC 100) No n/a n/a n/a n/a n/a n/a

Shell Cassida Fluid HF 100(Replaced Mobiltemp SHC 100) No n/a n/a n/a n/a n/a n/a

Shell Cassida Grease EPS 00 No n/a n/a n/a n/a n/a n/a

Shell Cassida Grease RLS 2 No n/a n/a n/a n/a n/a n/a

Usine Silicone Free Oil (Lubricant)

Pureshield Argon No n/a n/a n/a n/a n/a n/a Oxygen (High Purity) No n/a n/a n/a n/a n/a n/a Acetylene (Dissolved) Yes Garlic like n/a n/a n/a n/a n/a Nitrogen (Zero Grade) No n/a n/a n/a n/a n/a n/a Propane Yes Sweet n/d n/a n/a n/a n/a Shell Cassida Fluid GL 320 No n/a n/a n/a n/a n/a n/a Shell Cassida Fluid GL 460 Yes mild n/a n/a n/a n/a n/a

Note 1: The EPA Classification of Hazardous and Non-Hazardous Substances in Groundwater, December 2010 n/a = not applicable n/d = determined


Page 157 of 174

TABLE H.1(i): WASTE - Hazardous Waste Recovery/Disposal Refer to the 2011 AER Returns Workbook for full details of disposal / recovery outlets for each waste type.

Waste material EWC Code Main source1 Quantity On-site

Recovery/Disposal

Off-site Recovery, reuse or recycling

Off-site Disposal

Tonnes / month

m3 / month

(Method & Location )

(Method, Location &

Undertaker)

(Method, Location & Undertaker)

Nitric Acid 06 01 05 Production - Feeds Recovery MVR

30.0 R6 – Rilta (W0192-02)

Organic Solvents

07 01 04 Production

1.0 D10 – Veolia (W0050-02)

Degreasing Waste

11 01 13 Engineering Workshop

0.1 R2 – Safety Kleen (W0099-01)

Filters etc 15 02 02 QES Laboratory 1.0 D15 – Veolia (W0050-02)

Discarded Equipment

16 02 13 All areas 0.01 R4 – Veolia (W0050-02)

Inorganic Wastes

16 03 03 Reverse Osmosis (RO) Plant

0.15 R6 – Rilta (W0192-02)

Inorganic Wastes

16 03 03 Reverse Osmosis (RO) Plant

0.05 D8 – Rilta (W0192-02)

Inorganic

Wastes

16 03 03 Reverse Osmosis

(RO) Plant

0.15 D10 – Rilta

(W0192-02)

Discarded Inorganic Chemicals

16 05 07 QES Laboratory 0.002 D10 – Veolia (W0050-02)

1 A reference should be made to the main activity / process for each waste.


Page 158 of 174

TABLE H.1(i): WASTE - Hazardous Waste Recovery/Disposal Refer to the 2011 AER Returns Workbook for full details of disposal / recovery outlets for each waste type.


Recovery/Disposal

Off-site Recovery, reuse

or recycling

Off-site Disposal

Tonnes / month

m3 / month

(Method & Location )



Discarded

organic

Chemicals

16 05 08 QES Laboratory 0.003 D10 – Veolia

(W0050-02)

Lead

Batteries

16 06 01 Pyroban

Forklift Truck

0.2 R4 – Enva

(W0184-01)

Aqueous

Liquid Waste

16 10 01 Chemical

store

0.03 R3 – Rilta

(W0192-02)

Asbestos

Waste

17 06 05 Demolition /

construction

projects-

varies

2.0 D1 – Rilta

(W0192-02)

Solid

Combustible

Wastes

19 02 09 Main offices 0.0005 D10 – Veolia

(W0050-02)

Fluorescent

Tubes

20 01 21 All areas on

site

0.015 R4 – Irish

Lamp Recycling

(WFP-KE-08-

0348-01)

1 A reference should be made to the main activity / process for each waste.


Page 159 of 174

TABLE H.1(ii) WASTE - Other Waste Recovery/Disposal Refer to the 2011 AER Returns Workbook for full details of disposal / recovery outlets for each waste type.


recovery/disposal2


Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker)

Materials unsuitable for

consumption or processing

02 07 04 Grain intake screenings

100 R3 – CTO Env. Solutions (WFP-CK-

09-0018-02)

WWTP Sludge 02 07 05 WWTP & WTP 15 R3 – McGill Env Systems (W0180-01)

WWTP Sludge 02 07 05 WWTP & WTP 140 R3 – Bord na Mona (W0198-01)

Waste printing toner

08 03 18 Office Printers

0.002 R13 – Veolia (W0052-02)

Plastic Packaging 15 01 02 Ecloab Midland Drums

0.01 R5 – Greenstar (W0136-02)

Mixed Packaging 15 01 06 Production 0.2 R3 – Shuetz (UK), EAWML 43575

1 A reference should be made to the main activity/ process for each waste. 2 The method of disposal or recovery should be clearly described and referenced to Attachment H.1


Page 160 of 174



recovery/disposal2


Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker)

End of Life Tyres 16 01 03 Bond production

services

0.03 R3 – Hanover Tyres

End of Life Tyres 16 01 03 Bond production services

0.15 R3 – Southern Tyres

Discarded Equipment

16 02 14 All areas onsite

0.04 R4 – Veolia (W0050-02)

Discarded Chemicals

16 05 09 Chemical store

0.15 R3 – Rilta (W0192-02)

Alkaline Batteries 16 06 04 All areas onsite

0.002 R4 – Rilta (W0192-02)

Mixture of concrete, bricks,

tiles etc

17 01 07 Construction related

materials

0.8 R13 – O’Brien Skip Hire (WFP-CK-11-

0094-02)

Wood 17 02 01 Construction related

1.5 R3 – O’Brien Skip Hire (WFP-CK-11-0094-02)



Page 161 of 174



recovery/disposal2


Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker)

Plastic 17 02 03 C&D Styrofoam Insulation

3.0 R3 – Greenstar (W0136-02)

Iron and Steel 17 04 05 All areas - civil and electrical engineering works in plant

16.0 R4 – Cork Metal Co. (WCP-CK-10-0067-01)

Cables 17 04 11 All areas - Engineering works in plant

0.6 R4 – Cork Metal Co. (WCP-CK-10-0067-01)

Mixed Construction

Waste

17 09 04 Construction related projects

6.0 R13 – O’Brien Skip Hire (WFP-CK-11-

0094-02)

Mixed Construction Waste


0.2 D5– O’Brien Skip Hire (WFP-CK-11-0094-02)

Mixed Construction Waste


2.0 R3– O’Brien Skip Hire (WFP-CK-11-0094-02)

Wood 19 12 07 Chemical Store,

Bond

0.33 R3 – Greenstar

(W0136-02)

Paper & Cardboard

20 01 01 Bond, Main Offices, Spirit Store, Supervisors Office, etc.

0.15 R3 – Rehab (03/10)



Page 162 of 174



recovery/disposal2


Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker)

Paper &

Cardboard

20 01 01 Bond, Main Offices, Spirit

Store, Supervisors Office, etc.


(W0136-02)

Glass 20 01 02 Central

Laboratory,

QES

Laboratory

0.9 R5 – Rehab

(WFP-KE-08-

0357-01)

Biodegradable

Kitchen Waste

20 01 08 Canteen 0.85 R3 – Greenstar

(W0136-02)

Edible Oil & Fat 20 01 25 Canteen 0.045 R9 – Frylite

(LN/08/11)

Wood 20 01 38 Wood

shavings

(Bond)


(W0136-02)

Wood 20 01 38 Wood

(C&D)

0.8 R3 – Cork City

Council (W0012-

02)

Wood 20 01 38 Timber

pallets


(W-173-01)



Page 163 of 174



recovery/disposal2


Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker)

Plastics 20 01 39 Bond - Spirit

Store,

Warehouses

0.2 R3 – Midleton

Skip hire (WFP-

CK-10-0052-01)

Mixed Municipal

Waste

20 03 01 General Site

& Canteen

7.0 D5 – Greenstar

(W0136-02)

Other Batteries 16 06 05 All areas on

site

0.001 R4 – Rilta

(W0192-02)

3 A reference should be made to the main activity/ process for each waste. The method of disposal or recovery should be clearly described and referenced to Attachment H.1


Page 164 of 174

Table I.2(i) SURFACE WATER QUALITY

(Sheet 1 of 2) Monitoring Point/ Grid Reference: _Dungourney River - March 2012 – 188988E, 073618N Parameter Results

(mg/l)

Sampling

method2

(grab, drift etc.)

Normal

Analytical

Range2

Analysis method

/ technique

8th Mar 9th Mar 10th Mar 11 Mar

pH 8.15 6.93 7.58 8.04 Grab 0.01pH units MDL Electrometry

Temperature 8.3 8.2 9.1 9.0 Grab n/a n/a

Electrical conductivity EC 325 356 332 344 Grab 100uS/cm MDL Metrohm

Total Ammonia as N <0.03 - <0.03 <0.03 Grab 0.03 mg/l MDL Kone analyser

Chemical oxygen demand - - - - n/a n/a n/a

Biochemical oxygen

demand

- - - - n/a n/a n/a

Dissolved oxygen DO - - - - n/a n/a n/a

Orthophosphate as P

(Phosphorus) (ug/l)

<5.0 - 5.0 12.0 Grab 5.0 ug/l FT 014 Molybdovanadate Colorimetric Method

Nitrate as N - - - - n/a n/a n/a

Nitrite as N - - - - n/a n/a n/a

Calcium Ca 36.3 - 37.5 38.3 Grab n/a FT013 Atomic Abs. Method,

Cadmium Cd - - - - n/a n/a n/a

Chromium Cr - - - - n/a n/a n/a

Chloride Cl 38.1 - 28.1 28.5 Grab 0.3 mg/l MDL Kone analyser

Copper Cu - - - - n/a n/a n/a

Iron Fe (ug/l) <20 38.0 36.0 22.0 Grab 20 ug/l MDL ICP-OES (Dissolved)

Lead Pb - - - - n/a n/a n/a

Magnesium Mg 5.6 - 5.8 5.8 Grab n/a FT013 Atomic Abs. Method

Manganese Mn (ug/l) <2.0 6.0 5.0 7.0 Grab 2 ug/l MDL ICP-OES (Dissolved)

Mercury Hg - - - - n/a n/a n/a

MDL – Method Detection Level


Page 165 of 174

Surface Water Quality (Sheet 2 of 2)

Parameter Results

(mg/l)

Sampling

method

(grab, drift etc.)

Normal

Analytical Range

Analysis method

/ technique

8th Mar 9th Mar 10th Mar 11 Mar

Nickel Ni - - - - n/a n/a n/a

Potassium K - - - - n/a n/a n/a

Sodium Na 14.8 - 15.2 15.5 Grab 0.1 mg/l MDL ICP-OES (Dissolved)

Sulphate SO4 19.84 - 5.90 11.39 Grab 0.05 mg/l MDL Kone analyser

Zinc Zn - - - - n/a n/a n/a

Total alkalinity (as CaCO3) 135 84 151 90 Grab n/a n/a

Total organic carbon TOC 6.0 6.0 6.0 7.0 Grab 3 mg/l MDL Infra red

Total oxidised nitrogen

TON

- - - - n/a n/a n/a

Nitrite NO2 19.8 - 5.9 12.0 Grab 0.02 mg/l Kone analyser

Nitrate NO3 <0.02 - <0.02 <0.02 Grab 0.2 mg/l Kone analyser

Faecal coliforms (

/100mls)

- - - - n/a n/a n/a

Total coliforms ( /100mls) - 1553 - 866 Grab n/a MTC12/MDW Part 4D (2009)

Phosphate PO4 - - - - n/a n/a n/a


Page 166 of 174

Table I.4(i) GROUNDWATER QUALITY

(Sheet 1 of 2) Monitoring Point/ Grid Reference: MW 1 (Lower Field) 2010 Sampling (189061E, 074210N); GW 1 (189237E,

074192N); GW 2 (188731E, 073583N); GW 3 (189045E, 073965N); GW 4 (189114E, 074084N)

Parameter Results

(mg/l)

MW 1 24 Jun ‘10

GW 1 6 Apr ‘11

GW 2 6 Apr ‘11

GW 3 6 April ‘11

GW 4 6 April ‘11

Sampling

method

(composite

etc.)

Normal

Analytical

Range

Analysis method

/ technique

pH 6.43 6.8 7.4 7.3 7.1 Pump 0.01pH units MDL Metrohm

Temperature 11.9 - - - - Pump Not specified Thermometer

Electrical conductivity EC 546 878 575 676 624 Pump Not specified Electrometry

Total Ammonium as N 0.23 0.268 0.105 0.019 0.01 Pump Not specified Colorimetry

Nitrite as N - - - - - NA NA NA

Nitrate as N - - - - - NA NA NA

Orthphosphate as P - - - - - NA NA NA

Dissolved oxygen DO - - - - - NA NA NA

Residue on evaporation

(180oC)

- - - - - NA NA NA

Aluminium Al <1.5 - - - - NA 20 ug/l MDL ICP-OES (Dissolved)

Arsenic As ug/l <0.9 3.6 8.072 <0.10 0.189 Pump 0.9 ug/l MDL ICPMS

Boron B ug/l 4.9 - - - - Pump 12 ug/l MDL ICP-OES (Dissolved)

Calcium Ca (dissolved) 91.5 - - - - Pump Not specified ICP-OES

Cadmium Cd ug/l 0.45 - - - - Pump 0.5 ug/l MDL ICP-OES (Dissolved)

Chromium Cr ug/l 1.1 - - - - Pump 1.5 ug/l MDL ICP-OES (Dissolved)

Chloride Cl 21.0 16.41 37.34 54.82 16.97 Pump 0.3 mg/l MDL Colorimetry

Copper Cu ug/l 3.0 - - - - Pump 7 ug/l MDL ICP-OES (Dissolved)

Cyanide Cn, total <0.04 - - - - Pump 0.05 mg/l MDL Not specified

Iron Fe (total) ug/l 9376.0 - - - - Pump 20 ug/l MDL ICP-OES (Dissolved)

Lead Pb ug/l 1.5 1.258 <0.02 0.045 0.466 Pump 5 ug/l MDL ICP-OES (Dissolved)

Magnesium Mg (dissolved) 4.0 - - - - Pump Not specified ICP-OES (Dissolved)

Manganese Mn (total) ug/l 1282 - - - - Pump 2 ug/l MDL ICP-OES (Dissolved)

Mercury Hg ug/l <0.5 0.124 0.113 0.720 0.079 Pump 1 ug/l MDL ICP-OES (Dissolved)

Nickel Ni ug/l 154 - - - - Pump 2 ug/l MDL ICP-OES (Dissolved)

Potassium K 0.5 1.791 1.424 2.271 0.5 Pump Not specified ICP-OES (Dissolved)

Sodium Na 10.9 - - - - Pump 0.1 mg/l MDL ICP-OES (Dissolved)

Sulphate SO4 21.24 24.79 2.76 17.650 10.78 Pump 0.05mg/l Colorimetry


Page 167 of 174

Groundwater Quality (sheet 2 of 2)

Parameter Results

(mg/l)

MW 1 24 Jun ‘10

GW 1 6 Apr ‘11

GW 2 6 Apr ‘11

GW 3 6 April ‘11

GW 4 6 April ‘11

Sampling

method

(composite,

dipper etc.)

Normal

Analytical

Range

Analysis method

/ technique

Phosphate PO4 - 0.145 0.091 0.02 0.060 Pump Not specified Colorimetry

Sulphate SO4 (repeated in

sheet 1) - - - - - NA NA NA

Zinc Zn ug/l 20.4 1.498 <0.41 <0.41 <0.41 Pump 0.41 ug/l MDL ICP-OES (Dissolved)

Total alkalinity (as CaCO3) - - - - - NA NA NA

Total organic carbon TOC <2.0 - - - - Pump 3 mg/l MDL Infra red

Total oxidised nitrogen

TON

- <0.28 <0.28 5.16 1.99 NA 0.28 mg/l MDL Colorimetry

Arsenic As (repeated in sheet 1)

- - - - - NA NA NA

Barium Ba ug/l 28.0 - - - - Pump NA NA

Boron B (repeated in sheet 1) - - - - - NA NA NA

Fluoride F <0.3 0.24 0.11 0.020 0.05 Pump 0.3 mg/l MDL Colorimetry

Phenol - - - - - NA NA NA

Phosphorus P - - - - - NA NA NA

Selenium Se ug/l <1.2 - - - - Pump 3 ug/l MDL ICP-OES (Dissolved)

Silver Ag - - - - - NA NA NA

Nitrite NO2 <0.02 - - - - Pump 0.02mg/l MDL Kone analyser

Nitrate NO3 7.8 <0.272 <0.272 5.16 1.98 Pump 0.2 mg/l MDL Colorimetry

Faecal coliforms (

/100mls)

- - - - - NA NA NA

Total coliforms ( /100mls) 5.0 - - - - Pump NA MTC12/MDW Part 4D (2009)

Water level (m OD) 6.135 4.7 3.2 11.3 13.0 Pump NA Dip meter

- indicates not analysed emboldened results indicate those that exceeded the Groundwater Threshold Value range (GTV) of the Groundwater Regulations SI 9 of 2010.


Page 168 of 174

TABLE I.4(ii): LIST OF OWNERS/FARMERS OF LAND

Not Applicable

Land Owner

Townlands where landspreading Map

Reference Fertiliser P requirement for each farm

*NMP must take account of on-farm slurry

Total P requirement of the client List _____________ TABLE I.4(ii): LANDSPREADING

Not Applicable

Land Owner/Farmer________________________________ Map Reference_______________________

Field ID

Total Area (ha)

(a) Usable Area (ha)

Soil P Test Mg/l

Date of P test

Crop P Required (kg P/ha)

Volume of On-Farm Slurry Returned (m3/ha)

Estimated P in On-Farm Slurry (kg P/ha)

(b) Volume to be Applied (m3/ha)

P Applied (kg P/ha)

Total Volume of imported slurry per plot (m3)

TOTAL VOLUME THAT CAN BE IMPORTED ON TO THE FARM:

Not Applicable

Concentration of P in landspread material - kg P/m3

Concentration of N in landspread material - kg N/m3


Page 169 of 174

Table I.7(i): AMBIENT NOISE ASSESSMENT AWN Consulting Annual Noise Report May 2012

Third Octave analysis for noise emissions should be used to determine tonal noises

National Grid Reference Sound Pressure Levels

(6N, 6E) L(A)eq L(A)10 L(A)90

1. SITE BOUNDARY

Daytime Location 1: N1 188649E, 073824N 58-61 61-65 52-54

Location 2: N2 188618E, 073690N 61-64 63-66 58-60

Location 3: N3 188853E, 073546N 56-57 58-59 54-55

Night

Location 1: N1 188649E, 073824N 46-47 47 45

Location 2: N2 188618E, 073690N 56-58 46-59 55-57

Location 3: N3 188853E, 073546N 48 49 47

2. NOISE SENSITIVE

LOCATIONS

Daytime

Location 1: NSL1 188641E, 073835N 52-54 n/a* n/a*


Night



NOTE: All locations should be identified on accompanying drawings. * All measurements were at the boundary so only projections for the LAeq noise level (i.e. the facility noise emission) are possible for the Noise Sensitive Locations


Page 170 of 174

ANNEX 2: CHECKLIST FOR ARTICLE 10 COMPLIANCE

Article 10 of the Environmental Protection Agency (Licensing) Regulations, 1994 to 2010 sets out the statutory requirements for information to accompany a licence application. The Application Form is designed in such a way as to set out these questions in a structured manner and not necessarily in the order presented in Article 10. In order to ensure a legally valid application in respect of Article 10 requirements, all Applicants should complete the following checklist and submit it with the completed Application Form.

Article 10(2)

Section in

Application

Checked by

Applicant ��

(a) give the name, address and telephone number of the applicant and, if different, any address to which correspondence relating to the application should be sent and, if the applicant is a body corporate, the address of its registered or principal office,

B.1

��

(b) give - (i) in the case of an established activity, the number of employees and other persons working or

engaged in connection with the activity on the date after which a licence is required and during normal levels of operation, or

(ii) in any other case, the gross capital cost of the activity to which the application relates,

B.4

��

(c) give the name of the planning authority in whose functional area the activity is or will be carried on,

B.5

��

(d) in the case of a discharge of any trade effluent or other matter (other than domestic sewage or storm water) to a sewer of a Water Services Authority, give the name of the Water Services Authority in which the sewer is vested or by which it is controlled,

B.6

��

(e) give the location or postal address (including where appropriate, the name of the relevant townland or townlands) and the National Grid reference of the premises to which the activity relates,

B.2

��

(f) specify the relevant class or classes in the First Schedule to the Act to which the activity relates,

B.3

�� (g) specify the raw and ancillary materials, substances, preparations, fuels and energy which will be

produced by or utilised in the activity,

G.1 & G.2

��

(h) describe the plant, methods, processes, ancillary processes, abatement, recovery and treatment systems, and operating procedures for the activity,

D.1

��


Page 171 of 174

Article 10(2) continued../

Section in

Application

Checked by

Applicant ��

(i) indicate how the requirements of section 83(5)(a)(i) to (v) and (vii) to (x) of the Act 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,

L.1 to L.9

��

(j) give particulars of the source, nature, composition, temperature, volume, level, rate, method of treatment and location of emissions, and the period or periods during which the emissions are made or are to be made,

E.1 to E.5 ��

(k) describe the arrangements for the prevention or minimisation of waste and, where waste is produced, the on and of site arrangements for the recovery or disposal of solid and liquid wastes,

H.2 ��

(l) specify, by reference to the relevant European Waste Catalogue codes as prescribed by Council Directive 98/2008/EC of 19 November 2008, the quantity and nature of the waste or wastes produced or to be produced by the activity,

H.2 ��

(m) provide: (i) details, and an assessment, of the impacts of any existing or proposed emissions on the

environment, including on an environmental medium other than that or those into which the emissions are or are to be made, and

(ii) details of the proposed measures to prevent or eliminate, or where that is not practicable, to limit, reduce or abate emissions,

I.1 to I.7

F.1

��

(n) identify monitoring and sampling points and outline proposals for monitoring emissions and the environmental consequences of any such emissions,

F.2 & F.3 ��

(o) describe the condition of the site of the installation,

D.1 & I.1

to I.7

��

(p) describe in outline the main alternatives, if any, to the proposals contained in the application which were studied by the applicant,

I.8 ��

(q) specify the measures to be taken to comply with an environmental quality standard where such a standard requires stricter conditions to be attached to a licence than would otherwise be determined by reference to best available techniques,

N/A ��


Page 172 of 174

Article 10(2) continued../

Section in

Application

Checked by

Applicant ��

(r) describe the measures to be taken for minimising pollution over long distances or in the territory of other states,

I.1 - N/A ��

(s) describe the measures to be taken under abnormal operating conditions, including start-up, shutdown, leaks, malfunctions, breakdowns and momentary stoppages,

D & E ��

(t) describe the measures to be taken on and following the permanent cessation of the activity or part of the activity to avoid any risk of environmental pollution and to return the site of the activity to a satisfactory state,

L.9 & K.1 ��

(u) describe, in the case of an activity which gives, or could give rise, to an emission containing a hazardous substance which is discharged to an aquifer and is specified in the Annex to Council Directive 80/68/EEC of 17 December 1979 on the protection of groundwater against pollution caused by certain dangerous substances, the arrangements necessary to comply with said Council Directive,

E.4 - N/A ��

(v) include any other information required under Article 6(1) of Council Directive 2008/1/EC of 15 January 2008 concerning integrated pollution prevention and control,

I.8 ��

(w) include a non-technical summary of information provided in relation to the matters specified in paragraphs (f) to (v) above,

A ��

(x) state whether the activity consists of, comprises, or is for the purposes an establishment to which the European Communities (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2006(S.I. No. 74 of 2006) apply,

B.9 ��


Page 173 of 174

Article 10(3)

Without prejudice to Article 12(1), an application for a licence shall be accompanied by -

Section in

Application

Checked by

Applicant ��

(a) a copy of the relevant page of the newspaper in which the notice in accordance with article 6 has been published,

Attachment

B.8 ��

(b) a copy of the text of the site notice erected or fixed on the land or structure in accordance with article 7,

Attachment

B.8 ��

(c) a copy of the notice given to the planning authority under section 85(1)(a) of the Act,

Attachment

B.8 ��

a copy of such plans, including a site plan and location map (no larger than A3), and such other particulars, reports and supporting documentation as are necessary to identify and describe -

(i) the activity

Attachment

B.2 ��

(ii) the position of the site notice in accordance with article 7,

Attachment

B.8 ��

(iii) the point or points from which emissions are made or are to be made, and

Attachment

E.1 to E.6 ��

(d)

(iv) monitoring and sampling points, and

Attachment

F.2 & F.3 ��

(e) a fee specified in accordance with section 94 of the Act.

With Cover

Letter ��


Page 174 of 174

Article 10(4)

Checked by

Applicant ��

A signed original and 1 hardcopy of the application and accompanying documents/particulars in hardcopy format plus 2 copies of all files in electronic searchable PDF format on CD-Rom shall be submitted to the headquarters of the Agency. In cases where an E.I.S. is required to be submitted to the Agency in support of the application, a signed original and 2 hardcopies of the EIS plus 16* copies of all files in electronic searchable PDF format on CD-Rom shall be submitted to the headquarters of the Agency. * Energy sector applicants = 18 copies

��

Hardcopies submitted.

��

(b)

CD version submitted.

��

Documents

Integrated Pollution Prevention and · PDF fileIntegrated Pollution Prevention and Control (IPPC) Licensing Application Form Environmental Protection Agency P.O. Box 3000, Johnstown