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OES Consulting FBD House, Fels Point, Tralee, Co. Kerry p: 066 7128321 w: www.oes.ie Tipperary Co-Operative Creamery Ltd Station Rd, Tipperary, Co. Tipperary Annual Environmental Report 2011 IPPC Licence Reg. No. P0801-01

Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

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Page 1: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

OES Consulting

FBD House, Fels Point, Tralee, Co. Kerry

p: 066 7128321 w: www.oes.ie

Tipperary Co-Operative

Creamery Ltd

Station Rd, Tipperary, Co. Tipperary

Annual Environmental Report

2011

IPPC Licence Reg. No. P0801-01

Page 2: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Table of Contents

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

1.1 Licence Details............................................................................. 1 1.2 Description of Activity.................................................................. 1 1.2.1 Company Profile........................................................................... 1 1.2.2 Company Profile........................................................................... 2 1.2.3 Economic Contribution................................................................ 5 1.2.4 Expenditure on Environmental Protection.................................. 5 1.3 Environmental Policy .................................................................... 6 1.4 Environmental Management Programme ................................. 7 1.5 Organisational Structure............................................................... 7

2. Summary of Annual Environmental Performance ....................................... 8 2.1 Emissions to Air.............................................................................. 8 2.1.1 Boiler Emissions .............................................................................. 9 2.1.2 Boiler Emissions ............................................................................ 13 2.2 Emissions to Surface Water......................................................... 16 2.2.1 Compliance Summary ............................................................... 19 2.3 Emissions to Sewer....................................................................... 19 2.3.1 Compliance Summary ............................................................... 21 2.4 Storm Water Emissions................................................................. 21 2.5 Noise Emissions ............................................................................ 22 2.6 Odour........................................................................................... 23 2.7 Waste Management .................................................................. 23 2.7.1 Organic Waste Summary........................................................... 26 2.8 EPA Monitoring and Enforcement ............................................. 27 2.8.1 EPA Site Inspections.................................................................... 27

2.9 Energy Balance........................................................................... 35 2.10 Water Balance ............................................................................ 36 2.11 Pipeline Integrity Testing Programme........................................ 36 2.12 ELRA/RMP .................................................................................... 37 2.13 Environmental Incidents and Complaints................................. 37 2.14.1 Environmental Incidents............................................................. 37 2.14.2 Environmental Complaints......................................................... 37

3. Environmental Management Programme-Summary Update .................. 38 3.1 EMP Report 2011 ........................................................................ 38

Page 3: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 1 of 38

1. Introduction

This document is the fourth Annual Environmental Report (AER) covering

environmental performance at the Tipperary Cooperative Creamery

Ltd. (TCC) facility located at Station Road, Tipperary, Co. Tipperary

This report covers the period from the 1st of January 2011 to the 31st of

December 2011 and has been prepared in accordance with the EPA

‘Guidance note for: Annual Environmental Report’ (October 2001) and

other relevant guidance as provided by the EPA on the Agency website

(www.epa.ie).

Since the licence was issued by the Agency in April 2008, TCC have

communicated with the Agency on a regular basis in order to

demonstrate routine compliance with the terms of the licence.

TCC operate an Environmental Management Programme (EMP), which

sets out targets on a range of environmental projects. Progress in

achieving these targets under the EMP, as well as the revisions to the

Programme for 2012, are included in Section 3 of this AER.

The next AER will cover the calendar year 2011 and will be issued in the

first quarter of 2013.

1.1 Licence Details

Licensee Tipperary Co-op Creamery Ltd

Location of

Installation

Station Road.

Tipperary

Co. Tipperary

IPPC Licence

Reg. No.

P0801-01

Date of Issue 22nd April 2008

Class of Activity 7.2.1

Company

Profile

The treatment and processing of milk, the

quantity of milk received being greater than

200 tonnes per day (average value on an

annual basis)

Year Formed Pre 1900

1.2 Description of Activity

The company profile, process description, economic

contribution of the business and annual expenditure are

summarised in the following sections.

1.2.1 Company Profile

The facility was established as a dairy-processing site pre 1900. It

operated under the name ‘The Condensed Milk Company’ in

1928 as a milk processing factory, which subsequently changed

at a later date to ‘The Dairy Disposal Company’. Milk and

Page 4: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 2 of 38

butter were manufactured at the facility until 1948 and in 1949

the facility began to produce milk powder.

It was purchased by Tipperary Cooperative Creamery (TCC) Ltd.

in 1972 and operates as Tipperary Cooperative Creamery Ltd to

the present day. As part of an expansion works after purchasing

the facility, the company constructed a new milk powder

factory and wastewater treatment plant (WWTP) in addition to a

boiler house and refrigeration facilities.

1981 saw TCC establish a new cheese production facility

equipped with a cheese store and a cheese cutting facility.

TCC extended its cheese packaging area in 2007 with a new

packaging hall.

Currently, the facility has a processing capacity of 1,137 m3 of

milk per day and operates butter, cheese, and milk powder

processing activities on a twenty-four hour basis, seven days per

week.

The facility’s primary environmental emissions include treated

condensate water to the Ara River, powder fines and boiler flue-

gas emissions to the atmosphere and treated effluent

discharging to the local County Council wastewater treatment

plant.

The Facility obtained an IPPC Licence (Reg. No P0801-01) from

the Environmental Protection Agency on the 22nd of April 2008.

The IPPC Directive class of activity carried out at the facility is:

Class 7.2.1 the treatment and processing of milk, the quantity of

milk received being greater than 200 tonnes per day (average

annual basis)

1.2.2 Company Profile

The primary raw material for production at the plant is raw, fresh

milk. Following collection from local farms and delivery by road

tanker to the on-site storage silos, milk is cooled and tested.

Once tested, the liquid milk is utilised in cheese, butter or milk

powder manufacture.

The whole fresh milk is separated into cream and skim milk. The

cream is used in the manufacture of butter. A by-product of

butter manufacture, buttermilk, is evaporated and spray dried

to give butter milk powder.

The fresh skim milk is also evaporated and spray dried to

produce a skim milk powder product. There are two milk

evaporators utilised for this purpose on-site; evaporator one

processing 34m3/hour and evaporator two processing 30

m3/hour. The plant operates a single Anhydro Spray Drier at a

rate of 3 tonnes per hour.

Page 5: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 3 of 38

Within the cheese factory, whole milk is pasteurised at a rate of

c. 12 m3/hour in the production of Emmental cheese. The

pasteurised milk is inoculated with starter culture and rennet. This

initiates the precipitation and subsequently coagulation of milk

protein into cheese curd.

The curd is separated from the whey and is transferred to tanks

for storage. Whey is then processed as whey cream or whey

concentrate.

The curd is further processed on site to achieve the appropriate

texture. Salt is added to aid preservation and assist in the

development of flavour during maturation. The cheese is formed

into blocks of approximately 60kg and packaged.

The cheese is ripened for a period, producing the distinctive

Emmental appearance, prior to being cut into 60kg blocks for

dispatch.

Schematics of the processes undertaken at TCC are illustrated in

Figure 1.

Page 6: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 4 of 38

Raw Fresh Milk

Intake/Cool/Store/

Test/Separate

Cream

Pasteurise/Churn

Skim Milk

Pasteurise/Evapor

ate, Spray Dry

Butter

Package

Buttermilk

(by-product)

Evaporate, Spray

Dry

Buttermilk

Powder

Package

Skim Milk

Powder

Package

1 tonne 25kg

1 tonne 25 kg

Cheese Milk Pasteurise/ Add

Starter&Rennet/

Separate

Whey

Separate

Curd

Press/Salt

Whey

Concentrate/

Drying/Dispatch

Whey Cream

Dispatch

600 kg Blocks

Package/Ripen

60 kg blocks and

smaller

Buttermilk Powder Process

Whey Processing

Cheese Process

Skim Powder Process

Butter Powder Process

Butter Process

Whey Process

Figure 1. Process Flow Diagram

Page 7: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 5 of 38

1.2.3 Economic Contribution

TCC is a significant employer in Tipperary, employing

approximately 145 personnel. Indirectly, taking a 1:3 multiplier,

there is an estimated 435 people involved in the supply of

services and materials to the plant.

Furthermore, we are the processing hub for our 400 milk suppliers

in the region.

1.2.4 Expenditure on Environmental Protection

TCC are committed to improving the environmental

performance at the facility and have demonstrated this

throughout the 2011 reporting year.

The project to change our steam generating plant to run on

natural gas was completed in mid 2011 and will result in a 20%

reduction in our carbon dioxide emissions. The move away from

Heavy Fuel Oil which was transported to our site by road tanker

and to piped natural gas also represents significant

environmental improvement.

Notwithstanding infrastructural investment at the facility, TCC

continued through out the 2011 reporting year to apply all

necessary resources to ensure compliance with the conditions

of the IPPC Licence.

A breakdown of the expenditure in 2011 is presented in Table 1

below.

Table 1. Summary of Expenditure on Environmental Protection

Item Cost (€)

Effluent Treatment 60,000

Boiler Upgrade* 1,250,000

Compressed Air Efficiency* 20,000

Chilled Water Efficiency* 20,000

Energy Management* 270,000

Waste Disposal 180,000

EPA Annual Fee 21,000

Total 2011 1,821,000

* Works initiated in 2010 and completed in the 2011 reporting

year.

Page 8: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 6 of 38

1.3 Environmental Policy

The TCC Environmental Policy Statement is set out below.

Tipperary Co-operative Creamery Ltd. recognises the

fundamental importance between the interaction of food

products and the environment. The company manufactures

cheese, butter, powdered milk and whey produce at their

facility located at Station Rd., Co. Tipperary.

In order to ensure “continual improvement” of environmental

performance and compliance with the requirements of our IPPC

Licence (Reg. No. P0801-01) the following measures will be

implemented:

• Undertake process and production operations in a manner

which will minimise any risk to the environment and conserve

Natural Resources as far as practically possible.

• Ensure all our activities are in compliance with legal

requirements relevant to our environmental aspects at

international, E.U. and Irish levels.

• Assess the environmental impact before undertaking a major

capital project, and take account of possible clean

technologies to reduce pollution, promote waste minimisation,

and conserve resources.

• Encourage all third parties involved in our business to adopt

similar environmental standards to our own.

• Training and development of employees to conduct work in a

manner which will achieve the company’s policy and

objectives.

• Ensure that this Environmental Policy is clearly understood,

implemented and maintained at all levels of the company,

publicly available on request, and is applicable to all our

activities and their associated effects. Details of

environmental objectives and targets are also available on

request, and are applicable to all our activities and their

associated effects.

• Review our Environmental Policy on a regular basis

The Environmental Policy shall be achieved through the

implementation and maintenance of the Environmental

Management System at all levels of the Organisation.

-------------------------------

Ted O’Connor

General Manager

Page 9: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 7 of 38

1.4 Environmental Management Programme

TCC operate an Environmental Management Programme (EMP)

to facilitate achievement of environmental objectives and

targets including energy efficiency, reduction in water

consumption, environmental training and awareness to deliver

ongoing improvements in environmental performance at the

plant. The EMP specifies the objectives and targets to be

achieved, the designation of responsibilities and the means and

timeframe by which they are to be achieved.

The EMP is periodically reviewed and updated. Progress in

achieving the EMP targets as well as the revisions to the

programme for 2012/2013 are included in Section 3 of this AER.

1.5 Organisational Structure

TCC operates a management structure with a strong emphasis

on teamwork. The company organogram is shown below in

Figure 2 and indicates the responsibility for day-to-day

management of environmental issues at the plant.

Figure 2. Tipperary Cooperative Creamery Environmental Management

Structure

Ted O’ Connor

General Manager

John Lewis

Environmental

Manager Environmental Reporting

and Co-ordinating

Denis Kenneally

Environmental

Engineer, Production WWTP, Environmental

Monitoring

Noel Heffernan

Energy & Services

Manager

Environmental Monitoring

Liam Walsh

Environmental

Laboratory Manager Environmental Analysis

John Ryan

Environmental

Maintenance Engineer

Environmental Calibrations

and Integrity Inspections

Page 10: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 8 of 38

2. Summary of Annual Environmental Performance

This section of the Annual Environmental Report (AER) summarises

monitoring, resource use, complaints and waste management

information for the calendar year 2011.

Information on emissions to air are summarised as average mass

emissions for the reporting period, massed up on the basis of the

average measured concentration of the relevant parameter, average

flow value and hours of operation.

Discharges to water are summarised as total mass emissions for the

reporting period and are based on the average measured

concentration for the relevant parameter multiplied by the total flow

data for the reporting period from the relevant emission point.

Information on waste arisings is presented in accordance with the AER

electronic report spreadsheet as issued by the EPA.

Summary totalised and relative data on resource (power and fuel) and

estimated water usage at the plant during 2011 is presented in

comparison with previous year’s data to permit annual performance to

be compared against previous year’s production.

This section includes an evaluation of all complaints received regarding

the installation, in addition to all non-compliances with the conditions

and schedules of the IPPC Licence, together with a summary of

environmental incidents reported to the Agency during 2011.

Summary information on all emissions, discharges and waste arisings has

been compiled on an electronic spreadsheet. A print out of this

summary spreadsheet is included as Attachment A to this AER. The

spreadsheet has also been submitted electronically to the Agency in the

Pollution Release and Transfer Register (PRTR) at http://aer.epa.ie/prtr

2.1 Emissions to Air

TCC processed approximately 279,381m3 of milk in 2011.

Incoming raw milk to the plant is transformed from the liquid

phase to a range of solid and powdered products through a

series of manufacturing steps, which involve the application of

heat as steam or hot air.

Consequently, the atmospheric emissions from the plant

comprise combustion gases, associated with steam generation

and thermal oil heating and particulates from product drying.

The installation has emission points to air which include three

boilers, one thermal oil heater and two driers. Emissions to air for

the period of January to December 2011 are summarised in

sections 2.1.1 and 2.1.2 below.

Page 11: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 9 of 38

It is noted that the steam raising plant fuel was changed in 2011

from Heavy Fuel Oil to Natural Gas. Changing the fuel type at

the facility from Heavy Fuel Oil (HFO) to Natural Gas (NG) has

been a significant step in developing a fuel firing strategy which

will reduce emissions to atmosphere from the facility.

TCC continued to communicate with the Agency Office of

Licensing, Guidance and Resource Use (OCLR) throughout the

2011 reporting period to resolve issues associated with the

permitted Emission Limit Values (ELV’s) set out in Schedule B of

the IPPC Licence. This will be resolved through the submission of

a licence review application to the EPA.

An air dispersion modelling assessment of the proposed fuel firing

strategy has been prepared and demonstrates that the resultant

concentration of emissions from our plant are significantly below

national air quality standards.

2.1.1 Boiler Emissions

During the 2011 reporting year, the A1-1 and A1-3 boiler

operated on HFO from January until May, before being

converted to Natural Gas. It is noted that the A1-3 boiler will

remain on site as a standby unit and will be fired solely on

Natural Gas when in use.

In addition to the steam raising plant, heating demands for the

Anhydro Drier is supplied by a thermoheater operating on Gas

Oil (GO), emissions from this unit are emitted at licence

discharge point A1-4.

All emissions to air are discharged in accordance with Schedule

B.1: Emissions to Air of the IPPC Licence which specifies the

Emission Limit Values (ELVs) to which the discharge must

conform. These ELVs are described in Table 2.

Table 2.: Boiler Emission Limit Values

Emission

Point

A1-1

(Boiler 1)

A1-2

(Boiler 2)

A1-3

(Boiler 3)

A1-4

Location Boiler Stack

No. 1

Boiler Stack

No. 2

Boiler Stack

No. 3

Thermo

heater

Height *16.5 m *16.5 m 18.5 m 25.0 m

Parameter Emission Limit Value

Volume 12,310 m3/hr 7,450 m3/hr 9350 m3/hr 2070

m3/hr

NO2 (as

NO x)

450 mg/Nm3 450 mg/Nm3 450 mg/Nm3 450

mg/Nm3

SO2 (as SO

x)

170 mg/Nm3 170 mg/Nm3 170 mg/Nm3

Particulate 50 mg/Nm3 50 mg/Nm3 50 mg/Nm3 ─

* Extended to 22 metres as part of boiler house upgrade.

Page 12: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 10 of 38

Under Schedule C.1.2, of the IPPC Licence - Monitoring of

Emissions to Air TCC is required to carry out air monitoring

biannually.

Summary monitoring results for 2011 are given in Table 3 as

average mass emissions from the plant.

The mass emissions (kg/year) for each boiler is based upon the

average analytical result for each parameter (mg/m3) and the

average flow value (m3/h) for each boiler, expressed as hourly

mass emissions (kg/hr). The average mass emission for the

reporting period is calculated on the basis of hours of maximum

operation for each boiler throughout the period.

Permitted mass emissions are based on the IPPC Licence ELV

multiplied by the hourly flow and taking a 24 hour operating

period over the 365 days between January 1st and December

31st 2011.

Table 3: Boiler Mass Emissions 2011

Boiler Parameter M.E. (kg)

2010

M.E. (kg)

2011

Permitted

M.E. (kg)

Nitrogen

Monoxide and

Nitrogen Dioxide

(as NO 2) 26,664 18,353 48,530

Sulphur Dioxide (as

SOx) 39,337 18,242 18,308

A1-1

Particulates 12,455 9,965 5,392

Nitrogen

Monoxide and

Nitrogen Dioxide

(as NO2) 28,707 9,418 29,346

Sulphur Dioxide (as

SOx) 52,543 4,064 11,125

A1-2

Partculates 17,999 2,069 2,256

Nitrogen

Monoxide and

Nitrogen Dioxide

(as NO x) 4,199 8,782 36,880

Sulphur Dioxide (as

SO x) 4,856 16,881 13,924

A1-3

Particulates 4,765 16,947 4095

A1-4

Nitrogen

Monoxide and

Nitrogen Dioxide

(as NO x) 1,574 1,012 8,160

Mass emissions from each of the boilers and the thermoheater

are presented in Figures 3, 4, 5 and 6 below.

Page 13: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 11 of 38

kg/yr

NOx kg/yr

SOx kg/yr

PM

A1-1 2011

A1-1 2010

A1-1 Permitted

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

50000

A1-1 2011

A1-1 2010

A1-1 Permitted

Figure 3 A1-1 Boiler Annual Mass Emissions

It is clear from Table 3 and Figure 3 that there has been a

significant reduction in the mass of SOx (54%), NOx (31%), and

Particulates (20%) from boiler A1-1 between the 2010 and 2011

reporting years. The reduction has been as a result of changing

the fuel type at the facility from HFO to Natural Gas.

Both NOx and SOx emissions from emission point A1-1 were

below the permitted mass emission from this emission point.

However, the particulate emissions exceeded the permitted

mass emission due to the combustion of HFO from January to

May which based on the nature of the fuel gives rise to high

particulate emissions

kg/yr

NOx kg/yr

SOx kg/yr

PM

A1-2 2011

A1-2 2010

A1-2 Permitted

0

10000

20000

30000

40000

50000

60000

A1-2 2011

A1-2 2010

A1-2 Permitted

Figure 4. A1-2 Boiler Annual Mass Emissions

Page 14: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 12 of 38

Similar to A1-1, there was a significant reduction in mass

emissions from emission point A1-2 during the 2011 reporting

period when compared to 2010. This is as a result of boiler 2

being replaced with a new unit running on NG.

In the case of all parameters, the emissions were below the

annual permitted levels. It is also noted that the reason mass

emissions from A1-2 are lower than those from A1-1 was as a

result of less HFO being burned in the boiler associated with the

A1-2 emission point during the reporting period.

The use of NG as combustion fuel in the main boiler will reduce

significantly the emissions to atmosphere in future reporting

years.

kg/yr

NOx kg/yr

SOx kg/yr

PM

A1-3 2011

A1-3 2010

A1-3 Permitted

0

5000

10000

15000

20000

25000

30000

35000

40000

A1-3 2011

A1-3 2010

A1-3 Permitted

Figure 5: A1-3 Boiler Annual Mass Emissions

During the 2011 reporting year boiler A1-3 was used to provide

steam for the plant while works were being undertaken on boiler

A1-1 and A1-2. The boiler was operating on HFO over the period

when the boiler house plant was being upgraded to NG and

therefore the SOx and PM levels were higher than previous

years. It is noted that the unit is now converted to run on GO

which will result in a dramatic reduction of SOx and PM emissions

in all future operations.

Compliance Summary

It was determined from air emissions monitoring that the

emissions from boilers A1-2 and A1-3 breached ELV’s as set out

in the licence at the time of monitoring. Details of these non-

compliances are presented in Table 4 below. Boiler A1-1 was

Page 15: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 13 of 38

brought off line unexpectedly the day that the compliance

monitoring was undertaken at the facility. Details of Agency

compliance monitoring of boiler A1-1 is included in Table 5.

Table 4: Boiler Non-Compliances 2011-(Licensee

Monitoring)

Boiler Flow (m3/hr)

ELV 7,450

A1-2 Exceedence 9,289

Table 5: Boiler Non-Compliances 2011-(Agency

Monitoring)

Boiler Flow (m3/hr)

ELV 7,450

A1-2 Exceedence 9,123

All emission monitoring undertaken for NOx, SOx and

Particulates were in compliance with the IPPC Licence. The

volumetric limit for boiler A1-2 was exceeded in both the EPA

and Licensee monitoring, exceeding the emission limit value has

been demonstrated to have little impact on the receiving

environment as comparisons against national air quality

standards have shown emission concentrations are significantly

below the levels set out in the National Air Quality Standards.

2.1.2 Boiler Emissions

TCC operate an anhydro milk drier in the production of milk

powder. The Anhydro Milk Drier (A2-1) operated at a rate of

circa 3 tonnes per hour in 2011.

In addition, the site has two Box Spray Driers based on the

‘Rogers Process’, whereby the aerosol containing the dried

product passes through fabric filters prior to discharge to

atmosphere. These driers are used infrequently at the site and

were not used during the 2011 reporting period. Owing to their

infrequent use only one of the driers is a licensed emission point

(A2-2).

ELV’s for drier emissions as described in Schedule B.1.2: Emissions

to Air are tabulated in Table 6 below.

Page 16: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 14 of 38

Table 6: Drier Emission Limit Values

Emission Point Ref No. A2-1

Location Stack from Anhydro

Dryer

Stack Height 25.0 m

Parameter Emission Limit Value

Volume 80,600 m3/hr

Particulates 50 mg/Nm3

A monitoring frequency for drier emissions is not specified in the

IPPC licence. However, monitoring was carried out on three

occasions during the 2011 reporting period by Teagasc.

Summary monitoring for the 2011 monitoring period is described

in Table 7.

Table 7: Drier Mass Emissions 2011

Drier Parameter M.E. 2010

(kg)

M.E. 2011

(kg)

Permitted

M.E. (kg)

A2-1 Particulates 17,098 18,397 32,361

Particulate mass emissions for drier A2-1 were well below their

permitted mass emission limits. This is illustrated in Figure 6 below

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

Mass Emissions 2009

(kg)

Mass Emissions 2010

(kg)

Mass Emissions 2011

(kg)

Permitted Mass

Emissions (kg)

kg/yr

Mass Emissions 2009 (kg)

Mass Emissions 2010 (kg)

Mass Emissions 2011 (kg)

Permitted Mass Emissions

(kg)

Figure 6: A2-1 Drier Mass Emissions

Page 17: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 15 of 38

Compliance Summary

Air emissions monitoring was undertaken on the driers on three

occasions during 2011. All monitoring results were below the

50mg/m3 emission limit value, however, there were

exceedences of the maximum hourly airflows. The daily

discharge has not been exceeded. Table 8 presents the non

compliant results from the anhydro drier.

Table 8: Non Compliant Dryer Emission Results

Date Parameter Result Emission Limit Value

09/06/2011 Flow 80,965 m3/hr

03/10/2011 Flow 84,859 m3/hr

07/04/2011 Flow 82,996 m3/hr

80,600 m3/hr

2.1.3 Dust Deposition

Condition 6.14: Dust Monitoring of the IPPC Licence requires TCC

to undertake ambient dust monitoring at four on-site locations

at the northern, southern, eastern and western boundaries of

the installation.

Table 9: Dust Monitoring Results 2011

Month Point 1

(North)

Point 2

(South)

Point 3

(East)

Point 4

(West)

Emission

Limit

Value

Mg/Nm3

January 122 98 107 76

February 105 94 100 98

March 108 90 78 62

April 68 76 62 108

May 56 60 47 43

June 79 97 102 48

July 76 93 68 67

350

August 65 88 110 76

September 45 37 64 58

October 76 56 83 98

November 98 88 76 72

December 107 82 96 65

The results of analysis will be assessed against the emission limit

value of 350 mg/m2/day as set out in Schedule B.5: Dust

Deposition Limits of the Licence.

Page 18: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 16 of 38

As can be seen from Table 9 all of the dust emissions were well

below the emission limit value for the 2011 monitoring period.

2.2 Emissions to Surface Water

TCC has one licensed emission point relating to the process

which discharges to the River Ara (Ref Point: SW-2).

Condensate liquid arises from the milk drying process

undertaken on-site. First and second phase condensate is

reused as boiler feed water. Further phases of condensate are

treated and discharged to surface water. Treatment is achieved

by a purpose built and designed treatment plant which is based

on super chlorination, filtration and cooling processes. All

components of the treatment plant were upgraded in the third

quarter of 2010.

Condensate water is discharged in accordance with Schedule

B.2: Emissions to Water of the IPPC Licence which specifies the

emission limit values (ELVs) to which the discharge must

conform. These ELV’s are described in Table 10.

Table 10. Condensate Emission Limit Values

Emission Point Reference No.: SW-2

Name of Receiving Waters: River Ara

Location:

Discharge Point from

Evaporator Condensate

Treatment Plant

Parameter Emission Limit Value

Maximum Volume per day: 696m3

Maximum Volume per hour: 29m3

Temperature 25 ْC (max)

pH 6-9

Conductivity 100 µS/cm

Toxic Units 5

BOD 5 mg/l

COD 100 mg/l

Suspended Solids 5 mg/l

Total Nitrogen 15 mg/l

Ammonia (as N) 0.1 mg/l

Total Phosphorus (as P) 1 mg/l

Orthophosphate (as P) 0.5 mg/l

Oils, Fats and Grease 15 mg/l

Page 19: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 17 of 38

The discharge at SW-2 is monitored, as per Schedule C: Control

and Monitoring of the IPPC Licence. Flow, pH, temperature and

conductivity are monitored continuously and the remaining

parameters on a daily, weekly or monthly basis.

TCC are committed to reducing emissions to the River Ara and

reuse condensate for boiler feed water and CIP wherever

possible. It is noted that further reuse of condensate is limited at

the facility owing cross contamination of product, however, TCC

constantly look for opportunities for condensate reuse.

Summary monitoring results for 2011 are tabulated as total mass

emissions for the reporting period.

The total mass emission (kg) for each parameter is based on the

average analytical result for that parameter (mg/l) as massed

up by the total volume (m3/day) of effluent emitted over the

reporting period.

Similarly, the permitted mass emission for 2011 is determined

from the product of the permitted emission limit value (mg/l)

and the maximum flow per day (m3/day) over the 12 month

period.

Table 11 below shows the summary monitoring results for the

2011 reporting period, the calculated mass emission for 2010 is

provided for comparison purposes.

Table 11: 2011 Total Mass Emissions and Permitted Mass

Emissions at SW-2

Parameter Total M.E.

2009

Total

M.E. 2010

Total

M.E. 2011

Permitted

M.E

Volume (m3) 160,624 132,359 139,763 254,040

Kg Kg Kg Kg

BOD 655 640 451 1270

COD 4,065 3696 4236 25,404

Suspended

Solids 803 547 580 1,270

Total Nitrogen 1,635 801 988 3,810

Ammonia 18 11 10 25

Total P 79 66 56 254

Ortho-

phosphate 29 18 21 127

Oils, Fats,

Grease 487 187 1029 3,810

All parameters were below their respective permitted mass

emissions. This is illustrated in Figure 7.

Page 20: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 18 of 38

Volume (x100)

BOD

COD

Suspended Solids

Total Nitrogen

Ammonia

Total P

Ortho-phosphate

Oils, Fats, Grease

Total Mass Emission 2011

Permitted Mass Emission

0

5000

10000

15000

20000

25000

30000

Total Mass Emission 2011 Permitted Mass Emission

Figure 7: 2011 Total Mass Emissions and Permitted Mass Emissions

at SW-2.

Surface Water Emission (SW-2) Trend Analysis

A trend analysis is provided in Figure 8 for emissions to surface

water for 2011 by way of comparison against the results for

similar reporting periods in 2009 and 2010.

Volume (x100)

BOD

COD

Suspended Solids

Total Nitrogen

Ammonia

Total P

Ortho-phosphate

Oils, Fats, Grease

Total Mass Emission 2011

Total Mass Emission 2010

Total Mass Emission 2009

Permitted Mass Emission0

5000

10000

15000

20000

25000

30000

Total Mass Emission 2011

Total Mass Emission 2010

Total Mass Emission 2009

Permitted Mass Emission

Figure 8. Surface Water Discharge (SW2) Trend Analysis

Page 21: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 19 of 38

As illustrated in Figure 8, mass emissions from monitoring point

SW-2 are significantly below permitted mass emission at SW-2.

Furthermore, there is no marked difference between each of

the parameters (with the exception of fats, oils and grease)

when compared to recent years.

Although similar periods have been compared, it is noted that

the volume of milk dried on an annual basis can vary from year

and is dependent on milk supply and markets. It is also noted

that the product being dried (Skim, Butter, Whole Milk, Whey

etc.) can impact on the quality of the condensate produced at

the plant.

2.2.1 Compliance Summary

Percentage compliance with emission limit values for liquid

condensate was high during 2011. Percentage compliance was

calculated as the number of compliant days as a percentage

of the total number of monitoring days for each parameter.

Table 12: SW-2 Percentage Compliance

Parameter % Compliance

Flow 100%

Temperature 100%

Conductivity 99%

pH 100%

BOD 100%

COD 100%

Suspended Solids 100%

Total Nitrogen 100%

Ammonia 100%

Total P 100%

Orthophosphate 100%

Oils, Fats, Grease 100%

2.3 Emissions to Sewer

Process wastewater arising from operations at TCC is treated at

the on-site Wastewater Treatment Plant. Treatment to a desired

quality is achieved through treatment train which includes a

dissolved air flotation unit, bio-tower and activated sludge tanks.

By-products of this process include a biological waste water

sludge which is removed off site by an appropriate contractor

and an effluent discharge to the South Tipperary County

Council sewerage system. Following further treatment within the

municipal waste water treatment plant, the effluent is

discharged to the River Ara.

Page 22: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 20 of 38

Emission limit values (ELVs), as specified in Schedule B.3:

Emissions to Sewer of the IPPC Licence, have been applied to

the discharge of treated effluent and are detailed in Table 13.

Table 13: Treated Effluent ELVs

Emission Point Reference No.: SE-1

Name of Receiving Waters: River Ara

Location: Entrance to Sewer at Station

Road

Parameter Emission Limit Value

Max Volume in any one day: 792m3

Max Volume rate per hour: 33m3

Temperature 35 ْC (max)

pH 6-10

BOD 60 mg/l

COD 250 mg/l

Suspended Solids 90 mg/l

Orthophosphate (as P) 5 mg/l

Oils, Fats and Grease 30 mg/l

The discharge is monitored, as per Schedule C: Control and

Monitoring of the IPPC Licence, at emission point SE-1. Flow, pH

and temperature are monitored continuously and the other

parameters on a daily, weekly or monthly basis.

Table 14 shows a summary of the monitoring results obtained in

2011 against the permitted mass emissions for the reporting

period. The mass emission discharged to the town sewer in 2009

and 2010 is also provided for comparison purposes.

Table 14: 2011 Total Mass Emissions (M.E.) and Permitted

Mass Emissions at SE-1

Parameter

M.E.

2009

M.E.

2010

M.E

2011

Permitted

Annual M.E

Flow (m3) 151,419 108,771 163,635 289,080

Kg Kg Kg Kg

BOD 3421 2474 4895 17344

COD 7500 5135 13159 72270

Suspended

Solids 13627 4018 6996 26017

Orthophosphate 412 404.8 556 1445

Oils, Fats,

Grease 692 396 2003 8672

Page 23: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 21 of 38

All parameters were below their respective permitted mass

emission limits as can be seen in Figure 9. It is also noted that

there has been an increase in volumetric emission from the

WWTP in 2011 in comparison to 2010, this has resulted in higher

mass emissions of the licensed parameters.

Flow v (x

100) (m3)

BOD Kg

COD Kg

Orthpho

sphate Kg

Suspend

ed Solids

Kg

Oils,Fats,G

rease Kg

Discharged 2011

Discharged 2010

Discharged 2009

Permitted

0.0

10000.0

20000.0

30000.0

40000.0

50000.0

60000.0

70000.0

80000.0

Discharged 2011

Discharged 2010

Discharged 2009

Permitted

Figure 9: 2011 Total Mass Emissions and Permitted Mass

Emissions at SE-1

2.3.1 Compliance Summary

Percentage compliance with emission limit values for discharges

of treated wastewater from the site WWTP to the local town

sewer at discharge point SE-1 are presented in Table 15.

Table 15: SE-1 Percentage Compliance

Parameter % Compliance

Flow 100%

BOD 100%

COD 100%

Orthophosphate 100%

Suspended Solids 100%

Oils/Fats/Grease 100%

All parameters were fully compliant with Schedule B.3: Emissions

to Sewer of the IPPC Licence over the reporting period

2.4 Storm Water Emissions

Uncontaminated surface water and storm water run-off from

hard standing areas is discharged to the River Ara at emission

points SW-1, SW-3, SW-4 and SW-5.

Page 24: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 22 of 38

There are no ELV’s set for storm water emission points in the IPPC

licence. However, monitoring frequencies are specified. Storm

water emission points are monitored on a weekly basis for pH,

conductivity, BOD and total ammonia. A visual inspection of

colour and odour is preformed daily.

2.5 Noise Emissions

Noise monitoring was undertaken at the facility in September

2011 at the site boundaries during day and night time periods.

Results of day time noise monitoring are presented in Table 16.

Table 16 Summary of Noise Emissions Daytime

Location LAeq LA90 LA10

N1 47.1 45.2 48.4

N2 46.0 43.9 47.4

N3 55.1 52.6 56.8

N4 57.6 55.8 58.7

N5 63.7 57.2 66.5

Night time measurements were undertaken at boundary of the

site and three measurements were also taken at noise sensitive

locations to determine if there is an off site noise impact. The

results of the noise monitoring are presented in Table 17 below.

Table 17 Summary of Noise Emissions Night time

Location LAeq LA90 LA10

N1 49.2 46.6 50.5

N2 47.0 45.4 48.2

N3 55.4 53.2 57.1

N4 56.6 55.6 57.2

N5 55.9 50.7 56.0

NSL 1* 39.9 30.1 39.5

NSL 2* 45.0 37.0 48.5

NSL 3* 48.8 42.2 52.0

Page 25: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 23 of 38

Day time monitoring results indicate that the facility is compliant

with the noise emission limit values on the southern, western and

northern boundaries of the TCC facility. However, measurements

undertaken along the eastern boundary when compared to the

facilities IPPC licence limit are recorded higher. It was noted in

the noise survey report, that there was significant noise

associated with passing traffic and noise within the locality at

the time of the survey.

Due to extraneous noise sources at the eastern boundary (N5)

during daytime measurements it is extremely difficult to

determine the noise attributable to TCC and to ultimately

establish compliance with the noise criterion values.

There was no tonal or impulsive noises recorded at any of the

measurement locations which warranted the addition of any

penalties to the sound power levels recorded during either day

or night time measurements.

Night time measurements undertaken at facility monitoring

points N3, 4 and 5 exceed the night time emission limit value set

out in the IPPC licence for protection of residential amenity.

Noise levels recorded at N1 & N2 were found to be above the

ELV’s also, however significant extraneous noise was noted

during the survey and as a result, noise from the facility was not

considered to be exceeding the ELV. Noise measurements

undertaken at appropriate noise sensitive locations closest to

the facility were determined to be below 45dB.

2.6 Odour

Activities associated with the WWTP operation may give rise to

intermittent odour problems. In addition, the nature of dairy

processing, i.e. heating milk, producing milk products and

associated cleaning activities, can give rise to an odour which is

characteristic of the dairy industry.

TCC replaced the surface aerators in the WWTP aeration basin

with dissolved aerators in the final quarter of 2011. This will result

in less vigorous mixing of the water within the tank and potential

for generating odorous aerosols.

2.7 Waste Management

Summary information of the waste generated by TCC in 2011 is

presented in Tables 18 & 19.

Page 26: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creameries Ltd. 2011 AER

AER 2011 Page 24 of 38

Table 18 Summary Information on Waste Arisings 2011

Waste 2011

Total quantity of waste

produced in calendar year

(Tonnes) 1367.07

total quantity of waste disposed

off-site 81.97

total quantity of waste

recovered off-site 1285.10

2011

Quantity of non-hazardous

waste produced in calendar

year 1291.9

quantity of non-hazardous

waste disposed of off-site 81.97

quantity of non-hazardous

waste recovered off-site 1209.93

2011

Quantity of hazardous waste

produced in calendar year

(Tonnes) 75.16

quantity of hazardous waste

disposed of off-site 0

quantity of hazardous waste

recovered off-site 75.16

Page 27: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

Annual Environmental Report 2010

AER 2011 Page 25 of 40

Table 19 Description of Waste Streams (2011)

Transfer

Destination

European

Waste

Code

Hazar

dous

Quantit

y T/Year Description of Waste

Waste

Treatment

Operation

Location

of

Treatment

Name and Licence / Permit No. of

Recoverer / Disposer / Broker

Within the

Country

20 01 21*

Yes

0.01

Fluorescent tubes and

mercury containing

waste. R4

Offsite

Ireland

Claushuis Metals,

3899AH,Zeewolde,Holland

Within the

Country 17 04 05 No 30

Iron and Steel R4

Onsite in

Ireland

Cork Metal Co. Ltd., Dublin Hill, Cork.

CK(S)491/07

Within the

Country 20 03 01 No

81.97

Mixed Municipal D1

Onsite in

Ireland

Mr Binman Luddenmore, Grange,

Kilmallock, Co. Limerick, Waste Licence

Reg W0061-03

Within the

Country 20 01 38 No

60.15

Wood R3

Onsite in

Ireland

Mr Binman Luddenmore, Grange,

Kilmallock, Co. Limerick, Waste Licence

Reg W0061-03

Within the

Country 15 01 01 No

15.94

Cardboard R3

Onsite in

Ireland

Mr Binman Luddenmore, Grange,

Kilmallock, Co. Limerick, Waste Licence

Reg W0061-03

Within the

Country 13 07 03* Yes 29.96

Waste Heavy Fuel Oil R13

Onsite in

Ireland

Enva Ireland Ltd. Cloninam Industrial

Estate, Portlaoise, Co Laois W0184-01

Within the

Country 13 07 03* Yes 44.2

Waste Heavy Fuel Oil R13

Onsite in

Ireland

Enva Ireland Ltd. Cloninam Industrial

Estate, Portlaoise, Co Laois W0184-01

Within the

Country 13 07 03* Yes 1

Waste Heavy Fuel Oil R13

Onsite in

Ireland

Enva Ireland Ltd. Clonminam Industrial

Estate, Portlaoise, Co Laois W0184-01

Within the

Country 02 05 02 No 522.72

Effluent Treatment

Plant Sludge R10

Onsite in

Ireland

BEOFFS, WFP KK-09-004-01, Camphill

Callen, Kilkenny.

Within the

Country 02 05 02 No 92.54 Effluent Treatment

Plant Sludge R10

Onsite in

Ireland

Waddocks, Kilmaster, Co Carlow

WP11/04

Within the

Country 02 05 02 No 425.36

Effluent Treatment

Plant Sludge R10

Onsite in

Ireland

Littleton Composting Facility, W0249-01,

Littleton, Tipperary.

Within the

Country 02 05 02 No

63.22 Effluent Treatment

Plant Sludge R10

Onsite in

Ireland

McDonnell Farm Biogas, Dunmoylan,

Shanagolden, Co. Limerick.

WFP/LK/2011/50/R2/T1

Page 28: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

Annual Environmental Report 2011

AER 2011 Page 26 of 38

2.7.1 Organic Waste Summary

Organic waste arising from processing activities within the plant

comprises activated sludge from the wastewater treatment

plant and sludge from the DAF.

The generation of organic waste at the plant is directly related to

production activity and is seasonal, in line with milk deliveries.

Figure 10 shows the monthly variation in organic waste arisings,

with a peak occurring during the summer and autumn periods.

0.00

20.00

40.00

60.00

80.00

100.00

120.00

140.00

160.00

January

February

March

April

May

June Ju

ly

August

September

October

Novem

ber

Decem

ber

Month

Tonnes

Figure 10: Monthly Plot of organic waste arisings in 2011

A register of WWTP sludge (“Sludge register”) that was removed

off-site for composting was maintained throughout 2010.

Summary details are included in Table 20.

Table 20: Sludge Removed Offsite 2011

Month Sludge (Tonnes)

January 62.18

February 46.62

March 91.30

April 151.75

May 143.71

June 115.94

July 133.88

August 111.48

September 53.44

October 112.76

November 41.02

December 39.76

Total 1103.84

Page 29: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

Annual Environmental Report 2011

AER 2011 Page 27 of 38

2.8 EPA Monitoring and Enforcement

This section of the AER outlines the results of site inspections

undertaken at the facility by the EPA in 2011.

2.8.1 EPA Site Inspections

The Agency undertook two site inspections during 2011(July and

December).

The Agency identified four non-compliances and 6 observations

with the IPPC licence during the inspection. Summary details of

the non-compliances and observations are described in Table

21 & 22, together with a summary of TCC’s corrective actions.

Page 30: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 28 of 38

Table 21 Summary of Inspection Non Compliances and Status of Corrective Actions

Audit Ref.

No.

Audit Non-Compliance Corrective Action Required TCC Corrective Action Plan Completion

Date NC-1 Bunds (Condition 3.6.2)

The Agency identified a non

compliance with regard to

bunding at the site, and a

number of areas were identified

as requiring attention as follows:

• Dalkia Works

• Cheese Whey Tanks

• Cheese Factory Milk Tanks

• Rogers Building Milk Tanks

• Lactose Milk Tanks

1. Submission of time frame for

enclosing Dalkia bunds and removal

of Liquid. Include bunds on weekly

inspection log and commence

weekly inspections.

2. Demonstration that the concrete lip

surrounding the whey tanks is

sufficient to prevent spillages to of

whey from the area to surface

water.

3. Submission of proposal to prevent

spillages from the cheese factory

milk tanks.

4. Installation of a concrete kirb along

the boundary of the site adjacent

the River Ara.

1. All liquids have been

emptied from the Dalkia

Bunds. Dalkia are currently

installing bund covers to the

satisfaction of TCC.

2. TCC is currently undertaking

a review of material stored

and the collection system in

place, the results of this

review will be issued to the

Agency in separate

correspondence.

3. TCC propose to assess the

feasibility of connecting this

drain to the foul water

drainage system.

If deemed practical the civil

works will be carried out to

make the gully redundant or

route it to the process water

sewer network.

4. Design requirements are

currently being prepared for

submission to Civil

Contractors to provide

Complete-

closed

Complete-

closed

Complete-

closed

Complete-

closed

Complete-

closed

Page 31: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 29 of 38

Audit Ref.

No.

Audit Non-Compliance Corrective Action Required TCC Corrective Action Plan Completion

Date

quotations.

Works to be completed

during the winter shut down.

Complete-

closed

NC-2 Noise Survey

The Agency noted its

dissatisfaction with the Noise

Survey Report completed in

June 2010.

1. Compliance with Condition 4.5 of

the IPPC Licence.

2. Notification to the EPA of breaches

of emission limits values.

3. Investigation to determine measures

to reduce noise impact detected at

monitoring locations B4 & B5.

1. TCC have scheduled the

2011 annual noise

monitoring to be

undertaken at the facility to

determine compliance with

ELV’s.

2. TCC will notify the Agency

of all breaches of emission

limit values together with

proposed corrective

actions.

3. On the basis of the results

from the 2011 noise survey, a

program of works will be

developed and submitted

to the Agency.

Complete-

closed

Ongoing

NC-3 Underground Tank and Pipeline

Integrity Test Report (Condition

6.9.1)

1. The licence shall comply with

condition 6.9.1 of the IPPC Licence

and arrange for and have carried

1. TCC will engage a suitably

qualified person to

undertake integrity tests on

Ongoing

Page 32: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 30 of 38

Audit Ref.

No.

Audit Non-Compliance Corrective Action Required TCC Corrective Action Plan Completion

Date The underground tank and

pipeline assessment was not

completed in 2010 due to

inaccessibility of pipe work due

to processing.

out an underground tank and

pipeline integrity test.

bunding structures and

containers and to assess

their resistance to

penetration by water or

other materials. All tests will

be carried out on a three

year cycle.

NC-4 Annual Environmental Report

(Condition 11.8)

2010 Annual Environmental

report has not been submitted.

1. Submit the Annual Environmental

Report 2010.

1. The 2010 Annual

Environmental Report was

submitted to the Agency on

the 29th of July 2011 and

uploaded to the EPA

website on the 30th of July

2011.

Complete-

Closed

Page 33: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 31 of 38

Table 22 Summary of Inspection Observations and Status of Corrective Actions

Audit Ref.

No.

Audit Observations Corrective Action Required TCC Corrective Action Completion

Date

Obs-1 Waste Water Treatment Plant

Odour Emanating from the

balance tank.

1. The Agency requires the Licensee

to carry out an assessment of the

waste water treatment plant

settlement tank to establish how

the odour from the settlement tank

can be addressed so as not cause

a nuisance odour beyond the site

boundary.

1. TCC is currently reviewing

all feasible options for

odour reduction from the

site and will submit the

status of these findings to

the Agency once all

sources and methods for

reduction have been

evaluated.

Ongoing

Obs-2 Sample Bottle Container SW-2

Current condition of sample

container has potential to

contaminate sample.

1. The Licensee is required to install a

new sample bottle at SW-2

composite sampler without delay.

2. All composite sample bottles

should be cleaned out after each

sample has been removed and a

new bottle should be installed as

appropriate.

1. TCC has put a new drum in

place for collection of the

daily composite sample.

2. Environmental monitoring

personnel have been

advised as to the

importance of keeping the

composite sampling bottles

clean.

Closed

Closed

Obs-3 Response to Complaints

The Agency noted that wind

direction was noted when

carrying out odour assessments

with response to complaints.

1. The licensee shall note wind

direction when carrying out

odour assessments.

2. The licensee shall have due

regard to AG5 when carrying

1. TCC will undertake all odour

assessments in accordance

with the Agency Guidance.

2. A copy of the AG5

guidelines is retained at the

site for reference.

Closed

Page 34: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 32 of 38

Audit Ref.

No.

Audit Observations Corrective Action Required TCC Corrective Action Completion

Date

out odour assessments.

Obs-4 Antibiotic Contaminated Milk

Rejection Procedure

Procedure for dealing with

rejected milk.

1. The Licensee shall submit to the

Agency details of the final

destination of the contaminated

milk removed from the facility or

disposed by the facility in 2010.

2. Amend the current Antibiotic

Rejection Procedure without delay.

3. The Licensee is required to maintain

records of all contaminated milk

received and rejected from the

facility. The records shall include

dates, quantities and reasons fro

rejection and shall apply to all milk

collected by Tipperary Co-Op

Tankers and other External

Transporters.

1. Details of the final

destination of the

consignment of milk sent off

site are appended with this

letter.

2. The antibiotic procedure

has been amended to

reflect current practice at

the facility.

3. TCC are developing a log

which will be completed for

all rejected milk from the

site. Full details of

destination of the disposed

milk will include. This log will

be available at the site for

inspection.

Closed

Closed

Closed

Obs-5 Submission of Reports and

Responses to the Agency

The Agency noted that recently,

the Licensee has failed to meet

a number of Agency deadlines,

in particular on notification of

incidents, reports on follow up

investigations, reports on

complaint responses, quarterly

reports, AER and submission of

1. The Licensee shall ensure the timely

submission of reports and

documents to the Agency and shall

comply with all timelines specified in

Agency correspondence.

2. The Licensee is reminded of Agency

correspondence reference ‘gc23jf’

relating to quarterly monitoring

reports.

1. TCC are committed to

meeting all submission

requests within the timelines

set by the Agency.

2. The most recent monitoring

results are appended with

this letter.

Ongoing

Ongoing

Page 35: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 33 of 38

Audit Ref.

No.

Audit Observations Corrective Action Required TCC Corrective Action Completion

Date

specified engineering works

(SEW’s)

3. The Licensee shall refer to the

licence emission point reference

names in all reports submitted to the

Agency.

Obs-6 Emissions to Water & Sewer

Monitoring Reports & Daily

Inspection Log.

The Agency identified a

discrepancy between results

recorded in the laboratory and

those recorded by handheld

monitoring equipment.

1. The Licensee is required to

investigate the situation and

establish which set of results are

accurate.

2. If the Licensee is to continue with a

handheld device, it shall be

calibrated and without delay and

in future as per manufacturers

recommendations.

3. The Licensee shall record the units of

measurement for each result

recorded.

1. All units of measurement will

be recorded on all

monitoring documents at

the facility.

Closed

Obs. 7 Calibration Records

Copies of Calibration

Certificates on composite

samplers.

1. The Licensee shall forward copies of

the calibration records for the

onsite composite samplers to the

Agency.

1. Copies of the Calibration

Certificates are appended

with this letter.

Closed

Obs. 8 Bund Integrity Test Reports &

Weekly Inspection Logs.

Content of Bund Integrity Report.

Description of Weekly Inspection

Log.

1. All future test reports must include

the capacity of the largest tanks

within the bund and/or the largest

tank.

1. TCC will ensure that all

future reports include the

capacity of the largest tank

stored on the bund.

Closed

Page 36: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 34 of 38

Audit Ref.

No.

Audit Observations Corrective Action Required TCC Corrective Action Completion

Date

2. A site map is to be included in all

future reports to indicate the

location of bunds.

3. The bund inspection log is to be

renamed to (Weekly Bund

Inspection Log)

4. The Licensee shall record the status

of bunds on the inspection logs,

e.g. bund contains water, requires

emptying etc.

2. TCC will ensure a site map is

developed detailing the

locations of all bunds.

3. Bund inspection log has

been amended.

4. TCC will ensure that all

details of inspection findings

are recorded on the log

sheets.

Closed

Closed

Obs. 9 Notification of Incidents

Failure to notify the Agency of

incidents in a timely manner.

1. The Licensee shall ensure the timely

submission of notification of

incidents to the Agency in a timely

manner and shall comply with all

Agency correspondence.

1. TCC is committed to

improving its

communication with the

Agency on all incidents

together with proposed

corrective actions and

progress reports.

Ongoing

Page 37: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 35 of 38

2.9 Energy Balance

The processing of bulk liquid milk to a range of dry dairy

products involves a range of energy intensive stages where

heat is required.

Fuel usage on-site is comprised of heavy fuel oil (HFO), light fuel

oil (LFO), diesel and lubricating oil.

HFO is utilised by the two principal steam producing boilers (A1-

1 and A1-2) for milk processing and cleaning operations on-site.

HFO is also used by the stand-by boiler (A1-3). A thermoheater

(A1-4) which provides heating for the Anhydro Drier operates on

LFO.

Electricity is used on-site to power motors, compressors,

refrigeration, agitators, conveyors and lighting on-site.

Energy is a key raw material at the plant and significant effort

has been made in improving energy efficiency. TCC implement

an Energy Conservation Plan where they monitor energy usage

with the aim of improving energy efficiencies with regard to

compressed air, chilled water usage, butter cold store, lighting,

etc.

Energy costs contribute significantly to overall operating costs.

As a result, energy efficiency is a high priority and relative

energy consumption, i.e. energy consumption per m3 of taken

into the plant, is closely tracked. Figures for energy consumption

in 2009, 2010 and 2011 are tabulated in Table 23.

Table 23: Energy Consumption 2009, 2010 & 2011.

Year HFO Gas Oil Electricity

m3

m3/m3

milk m3

m3/m3

milk kW

kW/m3

milk

2009 7740 0.029 341 0.00129 11,300,000 42.20

2010 7741 0.029 318 0.00113 11,455,768 41.06

2011 2161 - 341 0.00122 11,550,000 41.34

* TCC consumed 5,153,322Nm3of NG during 2011.

In order to draw a comparison between monitoring results, the

natural gas usage and HFO have been converted to KW,

converting previous years oil consumption will direct

comparison between years.

The calculations are based on conversion rates for fuel oil and

natural gas posted by the Carbon Trust (120874kwh per tonne

and 11kwh per m3 respectively).

Page 38: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 36 of 38

Table 24. Boiler Energy Comparison

Year KWh

2010 93,565,467

2011 82,806,549

% Change -11.49

As presented in Table 24 above, there has been a significant

reduction in energy used to generate steam for the process.

In order to compare energy usage on a unit milk processed

basis, the total KWh of energy used in 2010 and 2011 were

compared against the volume of milk processed at the facility.

It was found that there was 11.27% less steam energy required in

2011 vs. 2010 to process a cubic meter of milk. It is noted that

Tipperary Cooperative is an integrated site and so energy

usage in milk processing varies depending on the product type,

regardless, the savings are substantial.

2.10 Water Balance

TCC obtains its water from an on-site well and from the mains

supply provided by Tipperary South County Council.

Water is a key raw material in the plant and is used in a number

of areas including cleaning, process and production and

services (boiler, chilled water, etc). Table 25 presents the water

usage figures for 2009, 2010 & 2011 compared with milk intake

figures.

Table 25 Water usage figures for 2009, 2010 & 2011.

M

i

l

k

.

2.11 Pipeline Integrity Testing Programme

Tipperary Cooperative Creamery carried out a comprehensive

pipeline integrity assessment at the facility in the in the last

quarter of 2011 and first quarter of 2012. No defects were found

in 80% of all foul lines inspected. The remaining 20% of lines

inspected require further testing or local repair. A programme

of further inspection and repair has been developed.

Year Water Usage Milk Intake

m3 m3

2009 266,420 267,759

2010 280,702 278,976

2011 274,389 279,381

Page 39: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 37 of 38

2.12 ELRA/RMP

It is noted that the removal of HFO off site as a fuel for steam

generation on site reduces significantly the site liability.

Furthermore, as part of the boiler house upgrade and

conversion to natural gas, both of the HFO tanks and bund

were cleaned by specialist contractors, with all oily wastes

derived sent off site for treatment at regulated facilities

Tipperary Cooperative Creameries will undertake a review of

both the ELRA and RMP in 2012.

2.13 Environmental Incidents and Complaints

In order to fully comply with Condition 11.4 of the IPPC Licence,

TCC has introduced a procedure (“EP005 Non-Conformance

Corrective Action Procedure”) for notification of environmental

incidents, non-compliances or emergencies to the EPA and

other relevant bodies including South Tipperary County Council

and the Southern Fisheries Board.

In the event of an environmental incident at or associated with

the plant, TCC is required to inform the EPA by telephone and

fax. A record of the incident must be made and submitted to

the Agency.

A proposal is then submitted for approval within one month of

the incident occurring regarding preventative measures put in

place to avoid reoccurrence and any other remedial action

required as per Condition 9.3.2.

TCC also operates a system for logging formal complaints

received from the public and notifying the EPA as to the nature

of the complaint and the follow-up investigation.

2.14.1 Environmental Incidents

There was one environmental incident at the site in June 2011,

where a white discharge was observed in the river downstream

of the SW-2 discharge point. TCC carried out a thorough

investigation of the river downstream of the facility including

chemical analysis of the water. No deterioration in the quality of

the receiving water was identified.

2.14.2 Environmental Complaints

TCC log and investigate any complaints of an environmental

nature, in accordance with Condition 11.5 of the IPPC Licence.

There were no environmental complaints taken at the facility

during 2011.

Page 40: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Tipperary Cooperative Creamery Ltd 2011 AER

AER 2011 Page 38 of 38

3. Environmental Management Programme-Summary

Update

This section of the AER contains summary information on the Tipperary

Co-operative Creamery Ltd. Environmental Management Programme

(EMP), and a review of the facilities performance in achieving the

specified targets throughout 2010. The EMP covers all compliance and

improvement programmes developed at Tipperary Co-operative

Creamery.

It is noted that both the EMP and Schedule of Objectives and Targets fall

under the site Environmental Management System and accordingly, are

included within a structured system of management review and periodic

auditing by internal auditors.

3.1 EMP Report 2011

The EMP includes the Company Environmental Objectives and

Targets, the means by which these will be achieved and

associated timescales.

This document aims to address the requirements of the IPPC

Licence and much of the environmental management efforts

undertaken on site are focused on compliance with the licence.

The progress made at the facility in 2011 and works planned for

2012 are presented in Attachment B appended with this report.

Page 41: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Attachment A

Pollutant Register Transfer Register 2011

Page 42: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Sheet : Facility ID Activities AER Returns Workbook 7/8/2012 15:33

| PRTR# : P0801 | Facility Name : Tipperary Co-Operative Creamery Limited |

Filename : P0801_2011.xls | Return Year : 2011 | 5062 07/08/2012 15:33

Guidance to completing the PRTR workbook

Version 1.1.13

REFERENCE YEAR 2011

1. FACILITY IDENTIFICATION

Parent Company Name Tipperary Co-Operative Creamery Limited

Facility Name Tipperary Co-Operative Creamery Limited

PRTR Identification Number P0801

Licence Number P0801-01

Waste or IPPC Classes of Activity

No. class_name

7.2.1

The treatment and processing of milk, the quantity of milk received

being greater than 200 tonnes per day (average value on a yearly

basis).

Address 1 Station Road

Address 2 Tipperary

Address 3 County Tipperary

Address 4

Tipperary

Country Ireland

Coordinates of Location -8.16245 52.4709

River Basin District IESE

NACE Code 1051

Main Economic Activity Operation of dairies and cheese making

AER Returns Contact Name John Lewis

AER Returns Contact Email Address [email protected]

AER Returns Contact Position Environmental Manager

AER Returns Contact Telephone Number 062 33111

AER Returns Contact Mobile Phone Number 087 2051540

AER Returns Contact Fax Number 062 32000

Production Volume 0.0

Production Volume Units

Number of Installations 0

Number of Operating Hours in Year 0

Number of Employees 0

User Feedback/Comments

Web Address

2. PRTR CLASS ACTIVITIES

Activity Number Activity Name

8(c) Treatment and processing of milk

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)

Is it applicable? No

Have you been granted an exemption ? Yes

If applicable which activity class applies (as per

Schedule 2 of the regulations) ?

Is the reduction scheme compliance route being

used ?

AER Returns Workbook

| PRTR# : P0801 | Facility Name : Tipperary Co-Operative Creamery Limited | Filename : P0801_2011.xls | Return Year : 2011 | Page 1 of 1

Page 43: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : P0801 | Facility Name : Tipperary Co-Operative Creamery Limited | Filename : P0801_2011.xls | Return Year : 2011 | 07/08/2012 15:35

8 10 18 18 26 26 6 10 6 6 6 6 10

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

Please enter all quantities in this section in KGs

QUANTITY

A1-1 A1-2 A1-3 A1-4 A2-1

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 Emission Point 4 Emission Point 5 T (Total) KG/Year

A (Accidental)

KG/Year

F (Fugitive)

KG/Year

11 Sulphur oxides (SOx/SO2) E EN 14791:2005 18242.0 4064.0 16881.0 0.0 0.0 39187.0 0.0 0.0

08 Nitrogen oxides (NOx/NO2) E CRM

Kane May Quintox Flue Gas

Analayser 18353.0 9418.0 8782.0 1012.0 0.0 37565.0 0.0 0.0

86 Particulate matter (PM10) E CRM

Zambelli ZB2 Stack

Sampler and 5005 Control

Unit 9965.0 2069.0 16947.0 0.0 18397.0 47378.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS

Please enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)

Please enter all quantities in this section in KGs

QUANTITY

A1-1

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

Additional Data Requested from Landfill operators

Landfill: Tipperary Co-Operative Creamery Limited

Please enter summary data on the

quantities of methane flared and / or

utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method Code

Designation or

Description

Facility Total Capacity m3

per hour

Total estimated methane generation (as per

site model) 0.0 N/A

Methane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)

Net methane emission (as reported in Section

A above) 0.0 N/A

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane)

flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4)

emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Method Used

Method Used

POLLUTANT

RELEASES TO AIR

POLLUTANT METHOD

Method Used

RELEASES TO AIR

RELEASES TO AIR

METHOD

POLLUTANT METHOD

Method Used

Page 44: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

4.2 RELEASES TO WATERS Link to previous years emissions data | PRTR# : P0801 | Facility Name : Tipperary Co-Operative Creamery Limited | Filename : P0801_2011.xls | Return Year : 2011 |

8 9 17 17 25 29 6

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT b

Please enter all quantities in this section in KGs

SW-2

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year

13 Total phosphorus E ALT Standard Method 56.0 56.0

12 Total nitrogen E ALT Standard Method 988.0 988.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS

Please enter all quantities in this section in KGs

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year

0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

Please enter all quantities in this section in KGs

SW-2

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year

306 COD E ALT Standard Method 4236.0 4236.0

303 BOD E ALT Standard Method 451.0 451.0

387 Ortho-phosphate (as P) E ALT Standard Method 21.0 21.0

238 Ammonia (as N) E ALT Standard Method 10.0 10.0

314 Fats, Oils and Greases E ALT Standard Method 1029.0 1029.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

RELEASES TO WATERS

Method Used

RELEASES TO WATERS

RELEASES TO WATERS

Method Used

POLLUTANT

Method Used

POLLUTANT

POLLUTANT

Page 45: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

07/08/2012 15:35

6 6 6 6 6 29

Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility

QUANTITY

A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0

0.0 0.0

QUANTITY

A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0

QUANTITY

A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0

0.0 0.0

0.0 0.0

0.0 0.0

0.0 0.0

Page 46: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

4.3 RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data | PRTR# : P0801 | Facility Name : Tipperary Co-Operative Creamery Limited | Filename : P0801_2011.xls | Return Year : 2011 |07/08/2012 15:35

8 8 16 20 6 6 6 6 20

SECTION A : PRTR POLLUTANTS

Please enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

Please enter all quantities in this section in KGs

QUANTITY

SE-1

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

306 COD E ALT Standard Method 13159.0 13159.0 0.0 0.0

303 BOD E ALT Standard Method 4895.0 4895.0 0.0 0.0

387 Ortho-phosphate (as P) E ALT Standard Method 556.0 556.0 0.0 0.0

240 Suspended Solids E ALT Standard Method 6996.0 6996.0 0.0 0.0

314 Fats, Oils and Greases E ALT Standard Method 2003.0 2003.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

Method Used

Method Used

POLLUTANT METHOD

POLLUTANT METHOD

Page 47: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0801 | Facility Name : Tipperary Co-Operative Creamery Limited | Filename : P0801_2011.xls | Return Year : 2011 | 07/08/2012 15:35

5 16 Please enter all quantities on this sheet in Tonnes 10

Quantity

(Tonnes per

Year)

Haz Waste : Name and

Licence/Permit No of Next

Destination Facility Non

Haz Waste: Name and

Licence/Permit No of

Recover/Disposer

Haz Waste : Address of Next

Destination Facility

Non Haz Waste: Address of

Recover/Disposer

Name and License / Permit No. and

Address of Final Recoverer /

Disposer (HAZARDOUS WASTE

ONLY)

Actual Address of Final Destination

i.e. Final Recovery / Disposal Site

(HAZARDOUS WASTE ONLY)

Transfer Destination

European Waste

Code Hazardous Quantity T/Year Description of Waste

Waste

Treatment

Operation M/C/E Method Used

Location of

Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

To Other Countries 20 01 21 Yes 0.01

fluorescent tubes and other mercury-

containing waste R4 E Volume Calculation Abroad

Irish Lamp Recycling,WCP-

DC-08-115-01

Woodstock Industrial

Estate,Kilkenny Road,Athy,

Co Kildare,Ireland

Clausheis

Metals,MB/00.091030/A,389

9AH

,Zeewolde,.,.,Netherlands

3899AH

,Zeewolde,.,.,Netherlands

Within the Country 17 04 05 No 30.0 iron and steel R4 E Volume Calculation Offsite in Ireland

Cork Metal Co.

Ltd,CK(S)491/07 Dublin Hill,.,Cork,.,Ireland

Within the Country 20 03 01 No 81.97 mixed municipal waste D1 M Weighed Offsite in Ireland Mr Binman ,W0061-03

Luddenmore,Grange,Kilmallo

ck Limerick,.,Ireland

Within the Country 20 01 38 No 61.15 wood other than that mentioned in 20 01 37 R3 M Weighed Offsite in Ireland Mr Binman ,W0061-03

Luddenmore,Grange,Kilmallo

ck Limerick,.,Ireland

Within the Country 15 01 01 No 15.94 paper and cardboard packaging R3 M Weighed Offsite in Ireland Mr Binman ,W0061-03

Luddenmore,Grange,Kilmallo

ck Limerick,.,Ireland

Within the Country 13 07 03 Yes 29.96 other fuels (including mixtures) R13 M Weighed Offsite in Ireland

ENVA Ireland Ltd. ,W0184-

01

Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

ENVA Ireland Ltd,W0184-

01,Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

Within the Country 13 07 03 Yes 44.2 other fuels (including mixtures) R13 M Weighed Offsite in Ireland

ENVA Ireland Ltd. ,W0184-

01

Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

ENVA Ireland Ltd,W0184-

01,Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

Within the Country 13 07 03 Yes 1.0 other fuels (including mixtures) R13 M Weighed Offsite in Ireland

ENVA Ireland Ltd. ,W0184-

01

Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

ENVA Ireland Ltd,W0184-

01,Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

Clonminum Industrial

Estate,Portlaoise,.,.,Ireland

Within the Country 02 05 02 No 522.72 sludges from on-site effluent treatment R10 M Weighed Offsite in Ireland

BEOFFS,WFP-KK-09-001-

01

Camphill,Callen

,Kilkenny,.,Ireland

Within the Country 02 05 02 No 92.54 sludges from on-site effluent treatment R10 M Weighed Offsite in Ireland Waddocks,WP11/04 Kilmaster,Carlow,.,.,Ireland

Within the Country 02 05 02 No 425.36 sludges from on-site effluent treatment R10 M Weighed Offsite in Ireland

Littleton Composting

Ltd,W0249-01 Littleton,Tipperary,.,.,Ireland

Within the Country 02 05 02 No 63.22 sludges from on-site effluent treatment R10 M Weighed Offsite in Ireland

McDonnell Farm

Biogas,WFP/LK/2011/50/R2/

T1

Dunmoylan,Shanagolden,Li

merick,.,Ireland

* Select a row by double-clicking the Description of Waste then click the delete button

Link to previous years waste data

Link to previous years waste summary data & percentage change

Method Used

Page 48: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

Attachment B

Environmental Management Programme 2011/2012

Page 49: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time

Scale

Responsibility Status

1.1 To develop an Environmental

Management System (EMS)

for the site.

Condition 2.2.1

of IPPC Licence

No. P0801-01

Compile Environmental Manual 01.09.2008 Environmental

Manager

Complete

Submit EMP as part of 2011 AER 31.03.2011 In progress

Review Progress with 2011 EMP Quarterly On going

Prepare 2013 EMP 31.1.2013 Ongoing

Carry out internal environmental audits Ongoing Ongoing

Identify environmental training needs of

all employees

Ongoing Environmental

Manager

Ongoing

Schedule appropriate training Ongoing Environmental

Supervisor

Ongoing

Provide environmental awareness training

to all employees

Ongoing Environmental

Supervisor

Ongoing

Include environmental awareness training

on Agenda with all other staff training.

Ongoing Ongoing

Review environmental performance of

facility.

Ongoing

Review EMP for 2012/2013

Prepare and Review AER 01.03.2013 Ongoing

1.0 Objective To maintain and improve environmental management at TCC

20.12.2012 Environmental

Team

1.4 Prepare and submit Annual

Environmental Report (AER).

Condition 11.8 of

IPPC Licence No.

Environmental

Manager

1.2 To ensure that all employees

are made aware of

requirements of the site

environmental system.

Condition 2.2.2.7

of IPPC Licence

No. P0801-01.

1.3 To conduct Annual

Environmental Review

Meetings.

Condition 2.2.2.3

of IPPC Licence

No. P0801-01

Page 50: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time

Scale

Responsibility Status

1.0 Objective To maintain and improve environmental management at TCC

Submit AER 31.03.2012

Prepare annual statement on

Environmental Liabilities

01.12.2008 Complete

Submit as part of AER 2011 31.03.2012

Update ELRA to take account of boiler

house upgrade.

30.10.2012 In Progress

Identify type of Management system

suitable for needs of Tipperary Co-

Operative Creamery

30.12.2008 Complete

Make updates to the EMP as required. 30.06.2011 In Progress

Implement system Ongoing Ongoing

1.7 Provide a copy of the PRTR

report to the Water Services

Authority on an annual basis.

Condition 11.9 of

IPPC Licence No.

P0801-01

Submit a copy of the PRTR for to Tipperary

Town Council on an annual basis.

Ongoing Environmental

Manager

Ongoing

In progress

1.6 Develop and establish Data

Management System.

Condition 6.19 of

IPPC Licence No.

P0801-01

01.03.2012 Environmental

Manager

1.8 To review annually the

decommissioning plan and

proposed amendments to

Condition 10.2.2

of IPPC Licence

No. P0801

Review decommissioning plan. Make

amendments where necessary and

include in the Annual Environmental

Environmental

Manager

1.5 Prepare Environmental

Liabilities annual statement.

Condition 12.3.2

of IPPC Licence

No. P0801-01

Environmental

Manager

Environmental Report (AER). IPPC Licence No.

P0801-01

Manager

Page 51: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

2.1 All tank container and drum

storage areas shall be

rendered impervious.

Condition 3.6.1 of

IPPC Licence No.

P0801

Review storage of tanks, drums and

container areas.

01.03.2009 Environmental

Manager

Complete

Document a bund emptying procedure

as part of the EMS

Complete

Demonstrate that all storage areas are

impervious to materials stored therein and

repair if necessary

01.09.2008 Ongoing

Install stainless steel liner in CIP bulk

Storage Bund.

01.03.2009 Complete

Install covers on outside bunds to stop in

the ingress of rainwater

01.04.2009 Complete

Install spill tray at Whey storage area. 28.02.212 Complete

Upgrade road diesel bund. 28.02.2012 Complete

Installation of a collectin system at the

entrance to the chemical storage shed.

30.07.2010 Complete

Repair Whey Silo Platform repairs. 30.09.2010 Complete

Relocated Hydrox bund to location

ouside of surface water management

plan.

31.08.2010 Complete

2.0 Objective To establish suitable site infrastructure at TCC

Page 52: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

2.0 Objective To establish suitable site infrastructure at TCC

Integrity testing of

underground pipes, tanks,

bunding structures.

Review site drawings and develop a

programme of works for integrity testing

01.10.2008 Complete

Undertake programme of integrity testing Rolling

Programme

Ongoing

Review integrity of the HFO bund, make

repairs where necessary.

31.08.2010 Complete

Prepare and submit scaled drawing of

drainage network.

01.03.2009 Complete

Submit findings of programme as part of

AER

31.03.2012 Complete

Develop repairs prgramme for pipelines

identified as requiring repair in 2012.

30.9.2012 In progress

Agree the laboratory and the scope of

testing to in advance with the EPA.

Complete

Undertake testing Complete

2.3 To undertake acute toxicity

of the undiluted final

condensate effluent on four

aquatic species from

different trophic levels by a

competent laboratory.

Condition 6.11.1

of IPPC Licence

No. P0801

01.08.2008 Environmental

Manager

2.2 Condition

6.9.1&6.9.2 of

IPPC Licence No.

P0801

Environmental

Manager

Page 53: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

2.0 Objective To establish suitable site infrastructure at TCC

Submit two upstream and downstream

monitoring locations to the Agency for

approval

01.05.2010 Environmental

Manager

Ongoing

Review requirements for toxicity

monitoring as part of IPPC Licence

Review.

30.09.2012 Environmental

Manager

Ongoing

Develop inspection and maintenance

programme as part of EMS.

Ongoing Complete

Undertaken efficiency testing. Annual

Requirement

Scheduled

2.6 Ensure that landspreading

only occurs on lands agreed

in advance by the EPA.

Condition 8.11.1

of IPPC Licence

No. P0801

Agree landspreading locations with the

EPA.

01.12.2008 Environmental

Manager

Complete

Identify with Agency approval suitable

means for disposal of waste sludge.

Ongoing. Ongoing

Contractors taking waste off site for

landspreading have submitted NMP's to

the Agency on our behalf.

Ongoing Ongoing

Ensure that Tipperary Coop have a record

of all information sent to the EPA.

Ongoing Ongoing

2.4

Condition 6.2 of

IPPC Licence No.

P0801

Environmental

Manager

Toxicity Testing Condition 6.11.1

of IPPC Licence

No. P0801

2.5 Inspect maintain and boilers

annually and have

combustion efficiency

testing.

Page 54: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

2.0 Objective To establish suitable site infrastructure at TCC

Ensure that alterations to the land bank

have written approval from the EPA.

Ongoing Ongoing

01.04.2009 Environmental

Manager

Complete-Sludge from

the WWTP is currently

sent for composting.

2.7 To asses the suitability of the

temporary holding structure

for organic wastes (WWTP

sludge) in accordance with

the Department of

Agriculture Specification S. 13

1; Minimum Specification for

Earth Lined Slurry/Effluent

Stores and Ancillary Works.

Condition 8.10 of

IPPC licence No.

P0801

Ensure that any organic waste stored at

off site locations is stored in accordance

with Dept of Agriculture specifications.

TCC to seek clarification from Dept of

Agriculture

Page 55: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

3.1 Prepare programme for

identification and reduction of

fugitive emissions.

Condition 6.8 of

IPPC Licence No.

P0801

Action recommendations set out in

Fugitive Emissions Report.

30.12.2010 Environmental

Manager

In progress

3.2 Carry out an Annual Noise Survey. Condition 6.13.1

of IPPC Licence

No. P0801

Undertake noise monitoring as per

Icondition 6.13 of the IPPC Licence.

30.09.2012 Environmental

Manager

Scheduled

3.2.1 To prepare a noise management

programme for the site.

Condition 6.13.2

of IPPC Licence

No. P0801

The programme will be developed

based on the results of the noise

survey.

31.10.2012 Environmental

Manager

Ongoing

3.3 Prepare programme for the

identification and reduction of

noise emissions.

Condition 6.13.3

of IPPC Licence

No. P0801.

Identification and reduction of noise

emissions will be developed based

on the results of the noise survey.

30.10.2011 Environmental

Manager

Ongoing

3.4 To prepare a test Programme for

all abatement equipment noted

in condition 6.3.1 of the IPPC

Licence.

Condition 6.3. of

IPPC Licence No.

P0801

Prepare Test Programme 01.10.2008 Environmental

Manager

Complete

3.5 Undertake a feasibility study to

reduce discharges of condensate

to the River Ara.

Condition 6.11.4

of IPPC Licence

No. P0801

Review all water uses on site and

identify potential areas where water

is used at the site.

30.11.2012 Services

Manager

Ongoing

Carry out feasability study on the

resue of secondary cosndensate

30.01.2012 Services

Manager

Ongoing

3.6 To undertake ambient dust

monitoring

Condition 6.14 of

IPPC Licence No.

P0801

Gauges to be installed and

procedure to be put in place for

monitoring and analysis.

01.03.2011 Environmental

Manager

Complete

3.0 Objective To establish and maintain site control at TCC

Page 56: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

3.0 Objective To establish and maintain site control at TCC

Gauges to be installed and

procedure to be put in place for

monitoring and analysis.

01.03.2011 Complete

Personnel to be trained in the

procedure.

Ongoing

3.7 Prepare a programme of works to

address the odour nuisance

created by the on-site WWTP.

Condition 6.15.2

of IPPC Licence

No. P0801

Programme of works will be

developed based on the findings of

the Odour Audit.

01.02.2012 Environmental

Manager

Ongoing

(Surface Aerators have been

replaced with dissolved aeration

system. Maintenance works have

also been carried out on the

Biotower)

Page 57: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

Carry out energy efficiency Audit. 01.04.2009 Environmental

Manager

Ongoing

Complete Energy Audit on the basis of

the new plant and equipment installed

in the boiler house.

30.10.2011

Implement recommendations of the

audit.

01.12.2011 Ongoing

Apply electricity metrics to various

areas of the plant (cheese, butter,

powder) to permit energy targets to be

put set and monitored. 30.11.2012

Services

Manager

4.2 Reuse of water onsite to be addressed

as part of action 3.5.

01.12.2008 Environmental

Manager

Ongoing

4.2.1

Develop a water balance for the facility.30.11.2012

Services

Manager Ongoing

4.2.2 Identify areas where water savings can

be made. 31.12.2012

Services

Manager Ongoing

Undertake efficiency raw materials.

Water usage, oil, gas, and packaging

via waste figures are reported annually

in the AER.

01.12.2008 Environmental

Manager

Ongoing

Assessment of oil and electricity used

versus production is undertaken on a

monthly basis.

Ongoing Facilities

Manager

Ongoing

4.3 To undertake an

assessment of the

efficiency of use of raw

materials.

Condition 7.4 of

IPPC Licence No.

P0801

4.0 Objective To Improve Energy Efficiency Use at TCC

4.1 To carry out energy

efficiency Audit.

Condition 7.1, 7.2

of IPPC Licence

No. P0801

To identify opportunities for

reduction in the quantity of

water used on site

including recycling and

reuse initiatives, wherever

possible.

Condition 7.3 of

IPPC Licence No.

P0801

Page 58: Tipperary Co-Operative Creamery LtdLicensee Tipperary Co-op Creamery Ltd Location of Installation Station Road. Tipperary Co. Tipperary IPPC Licence Reg. No. P0801-01 Date of Issue

No. Target Licence

Condition

Plan Time Scale Responsibility Status

Prepare Accident Prevention Policy 01.10.2009

Review Annually Ongoing

To establish Emergency

Response procedure.

Prepare Emergency Response Procedure. 01.10.2008 Complete

Review Annually Implement Emergency Response

Procedure.

01.11.2008 Complete

Review Annually Ongoing Ongoing

5.2 Condition 9.2 of

IPPC Licence No.

P0801

Environmental

Manager

5.0 Objective: To Improve Emergency Preparedness at TCC

5.1 To establish Accident

Prevention Policy.

Condition 9.1 of

IPPC Licence No.

P0801

Environmental

Manager

Complete