Integrated Pollution Prevention and Control Licensing

Application Form

For inspection purposes only. Consent of copyright owner required for any other use. o EPA Reg. N : (Office use only)

This document does not purport to be and should not be considered a legal interpretation of the provisions and requirements of the EPA Acts 1992 and 2003.

Environmental Protection Agency P.O. Box 3000, Johnstown Castle Estate, Co. Wexford Telephone : 053-60600 Fax : 053-60699

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Environmental Protection Agency

Application for an Integrated Pollution Prevention and Control Licence

Environmental Protection Agency Acts, 1992 and 2003.

CONTENTS

INTRODUCTION 3

CHECK LIST FOR ARTICLE 10 COMPLIANCE 4

SECTION A NON-TECHNICAL SUMMARY 10

SECTION B GENERAL 15

SECTION C MANAGEMENT OF THE INSTALLATION 22

SECTION D INFRASTRUCTURE & OPERATION 23

SECTION E EMISSIONS 25

SECTION F CONTROL & MONITORING 29

SECTION G RESOURCE USE AND ENERGY EFFICIENCY 33 For inspection purposes only. Consent of copyright owner required for any other use.

SECTION H MATERIALS HANDLING 34

SECTION I EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY 37

SECTION J ACCIDENT PREVENTION & EMERGENCY RESPONSE 44

SECTION K REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE 45

SECTION L STATUTORY REQUIREMENTS 46

SECTION M DECLARATION 48

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INTRODUCTION

A valid application must contain the information prescribed in the Environmental Protection Agency (Licensing) Regulations, 1994 to 2004. The applicant is strongly advised to read the Application Guidance Notes for Integrated Pollution Prevention and Control Licensing, available from the EPA.

The applicant must conform to the format set out in the guidance notes for applications (available from the EPA). Each page of the completed application form must be numbered, e.g. page 5 of 45, etc. Also duplicated pages from the application form should be uniquely numbered, e.g. page 5(i) of 45, etc. The basic information should for the most part be supplied in the spaces given in application form and any supporting documentation should be supplied as attachments, as specified. Consistent measurement units must be used throughout.

The applicant should note that the application form has been structured so that it requires information to be presented in an order of progressive detail.

When it is found necessary, additional information may be provided on supplementary attachments which should be clearly cross referenced with the relevant sections in the main document.

While all sections in the application form may not be relevant to the activity concerned, the applicant should look carefully through all aspects of the form and provide the required information, in the greatest possible detail.

All maps/drawings/plans must be no larger than A3 size and scaled appropriately such that they are clearly legible. In exceptional circumstances, where A3 is considered inadequate, a larger size may be requested by the Agency. For inspection purposes only. Consent of copyright owner required for any other use.

Information supplied in this application, including supporting documentation will be put on public display and open to inspection by any person. Should the applicant consider information to be confidential, this information should be submitted in a separate enclosure bearing the legend “ In the event that this information is deemed not to be held as confidential, it must be returned to ...... ”. In the event that information is considered to be of a confidential nature, then the nature of this information, and the reasons why it is considered confidential (with reference to the “ Access to Information on the Environment” Regulations) should be stated in the Application Form, where relevant.

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CHECK LIST FOR ARTICLE 10 COMPLIANCE

Article 10 of the Environmental Protection Agency (Licensing) Regulations, 1994 to 2004 sets out the statutory requirements for information to accompany a licence application. The application form is designed in such a way as to set out these questions in a structured manner and not necessarily in the order presented in Article 10. In order to ensure a legally valid application in respect of Article 10 requirements please complete the following check-list.

Article 10(2)(a) give the name, address and telephone number of the applicant and, if different, any address to which correspondence relating to the application should be sent and, if the applicant is a body corporate, the address of its registered or principal office,

LOCATION CHECKED Applicant √ Official

(b) give - (i) in the case of an established activity, the number of employees and other persons working or engaged in connection with the activity on the date after which a licence is required and during normal levels of operation, or

(ii) in any other case, the gross capital cost of the activity to which the application relates,

For inspection purposes only. LOCATION Consent of copyright owner required for any other use.

CHECKED Applicant √ Official

LOCATION CHECKED Applicant √ Official

(d) in the case of a discharge of any trade effluent or other matter (other than domestic sewage or storm water) to a sewer of a sanitary authority, give the name of the sanitary authority in which the sewer is vested or by which it is controlled,

LOCATION CHECKED Applicant √ Official

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(e) give the location or postal address (including where appropriate, the name of the relevant townland or townlands) and the National Grid reference of the premises to which the activity relates,

LOCATION CHECKED Applicant √ Official

(f) specify the relevant class or classes in the First Schedule to the Act to which the activity relates,

LOCATION CHECKED Applicant √ Official

(g) specify the raw and ancillary materials, substances, preparations, fuels and energy which will be produced by or utilised in the activity,

LOCATION CHECKED Applicant √ Official

(h) describe the plant, methods, processes, ancillary processes, abatement, recovery and treatment systems, and operating procedures for the activity,

LOCATION CHECKED Applicant √ Official

(i) indicate how the requirements of section 83(5)(a)(i) to (v) and For inspection purposes only. (vii) to (x)Consent of of copyrightthe Ac ownert requiredshall forbe any otherme use.t, having regard, where appropriate, to any relevant specification issued by the Agency under section 5(3) of the Act and the reasons for the selection of the arrangements proposed,

LOCATION CHECKED Applicant √ Official

(j) give particulars of the source, nature, composition, temperature, volume, level, rate, method of treatment and location of emissions, and the period or periods during which the emissions are made or are to be made,

LOCATION CHECKED Applicant √ Official

(k) describe the arrangements for the prevention or minimisation of waste and, where waste is produced, the on and of site

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arrangements for the recovery or disposal of solid and liquid wastes,

LOCATION CHECKED Applicant √ Official

(l) specify, by reference to the relevant European Waste Catalogue codes as prescribed by Commission Decision 2000/532/EC of 03 May 2000, the quantity and nature of the waste or wastes produced or to be produced by the activity,

LOCATION CHECKED Applicant √ Official

(m) provide: (i) details, and an assessment, of the impacts of any existing or proposed emissions on the environment, including on an environmental medium other than that or those into which the emissions are or are to be made, and

(ii) details of the proposed measures to prevent or eliminate, or where that is not practicable, to limit, reduce or abate emissions,

LOCATION CHECKED Applicant √ Official

(n) identify monitoring and sampling points and outline proposals for monitoring emissions and the environmental consequences of any such emissions, For inspection purposes only. Consent of copyright owner required for any other use.

LOCATION CHECKED Applicant √ Official

(o) describe the condition of the site of the installation,

LOCATION CHECKED Applicant √ Official

(p) describe in outline the main alternatives, if any, to the proposals contained in the application which were studied by the applicant,

LOCATION CHECKED Applicant √ Official

(q) specify the measures to be taken to comply with an environmental quality standard where such a standard requires stricter conditions to be attached to a licence than would

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otherwise be determined by reference to best available techniques,

LOCATION CHECKED Applicant √ Official

(r) describe the measures to be taken for minimising pollution over long distances or in the territory of other states,

LOCATION CHECKED Applicant √ Official

(s) describe the measures to be taken under abnormal operating conditions, including start-up, shutdown, leaks, malfunctions, breakdowns and momentary stoppages,

LOCATION CHECKED Applicant √ Official

(t) describe the measures to be taken on and following the permanent cessation of the activity or part of the activity to avoid any risk of environmental pollution and to return the site of the activity to a satisfactory state,

LOCATION CHECKED Applicant √ Official

(u) describe, in the case of an activity which gives, or could give rise, to an emission containing a hazardous substance which is For inspection purposes only. dischargedConsent to an of copyrightaquifer owner and required is specifiedfor any other use. in the Annex to Council Directive 80/68/EEC of 17 December 1979 on the protection of groundwater against pollution caused by certain dangerous substances, the arrangements necessary to comply with said Council Directive,

LOCATION CHECKED Applicant √ Official

(v) include any other information required under Article 6(1) of Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and control,

LOCATION CHECKED Applicant √ Official

(w) include a non-technical summary of information provided in relation to the matters specified in paragraphs (f) to (v) above,

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LOCATION CHECKED Applicant √ Official

(x) state whether the activity consists of, comprises, or is for the purposes an establishment to which the European Communities (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2000 apply,

LOCATION CHECKED Applicant √ Official Article 10(3) Without prejudice to Article 12(1), an application for a licence shall be accompanied by -

(a) a copy of the relevant page of the newspaper in which the notice in accordance with article 6 has been published,

LOCATION CHECKED Applicant √ Official

(b) a copy of the text of the site notice erected or fixed on the land or structure in accordance with article 7,

LOCATION CHECKED Applicant √ Official

LOCATION For inspection purposes only. CHECKED Consent of copyright owner required for any other use. Applicant Official

(d) a copy of such plans, including a site plan and location map (no larger than A3), and such other particulars, reports and supporting documentation as are necessary to identify and describe -

(i) the activity

LOCATION CHECKED Applicant √ Official

(ii) the position of the site notice in accordance with article 7,

LOCATION CHECKED Applicant √ Official

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(iii) the point or points from which emissions are made or are to be made, and

LOCATION CHECKED Applicant √ Official

(iv)monitoring and sampling points, and

LOCATION CHECKED Applicant √ Official

(e) a fee specified in accordance with section 94 of the Act.

LOCATION CHECKED Applicant √ Official

Article 10(4)(b) A signed original and 2 hardcopies of the application and accompanying documents/particulars in hardcopy format plus 2 copies of all files in electronic searchable PDF format on CD- Rom shall be submitted to the headquarters of the Agency.

In cases where an E.I.S. is required to be submitted to the Agency in support of the application, a signed original and 2 hardcopies of the EIS plus 16* copies of all files in electronic searchable PDF format on CD-Rom shall be submitted to the headquarters of the Agency.

* Energy sector applicants = 18 copies

LOCATION For inspection purposes only. Consent of copyright owner required for any other use. CHECKED Applicant √ Official

CD version PROVIDED Y/N CHECKED Applicant √ Official

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SECTION A NON-TECHNICAL SUMMARY

Non-Technical Summary of IPC Licence Application

A non-technical summary of the application is to be included here. The summary should identify all environmental impacts of significance associated with the carrying on of the activity/activities, and describe mitigation measures proposed or existing to address these impacts. This description should also indicate the normal operating hours and days per week of the activity.

The following information must be included in the non-technical summary:

A description of: − the installation and its activities, − the raw and auxiliary materials, other substances and the energy used in or generated by the installation, − the sources of emissions from the installation, − the conditions of the site of the installation, − the nature and quantities of foreseeable emissions from the installation into each medium as well as identification of significant effects of the emissions on the environment, − the proposed technology and other techniques for preventing or, where this not possible, reducing emissions from the installation, − where necessary, measures for the prevention and recovery of waste generated by the installation, − further measures planned to comply with the general principles of the basic obligations of the operator i.e.

(a) all the appropriate preventive measures are taken against pollution, in particular through application of the best available techniques; For inspection purposes only. (b) no significant pollutionConsent is caused; of copyright owner required for any other use. (c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment; (d) energy is used efficiently; (e) the necessary measures are taken to prevent accidents and limit their consequences; (f) the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state.

− measures planned to monitor emissions into the environment.

Supporting information should form Attachment No A.1

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NON-TECHNICAL SUMMARY

The installation and its activities: Summary: Cadbury Ireland currently employs 1500 people in the manufacture of chocolate and confectionary at a 51,113m2 plant on the Malahide Road, Coolock making it a major employer in the region. Environmental Management is a core value in the company and the site follows the requirements of ISO14001, although it has not yet sought accreditation. The plant was established approximately 50 years ago.

Cadbury operate an EMS based on continual improvement and legal compliance. Attachment C.1 contains the Environmental Policy and Attachment C.3 the Environmental Manual. Cadbury Ireland work closely with Cadbury Corporate to ensure that resources and finance are available for ongoing environmental improvement, including waste avoidance and reduction, re-use and recycling, avoidance and reduction of emissions and optimisation of processes to reduce the use of resources by the operation.

Licence Requirement: Cadbury is applying for an IPPC Licence because, as a result of on-going growth and expansion, the organisation will have the capacity to produce “food products from animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day” as of 12th September 2006.

Process Flows: The process flows are outlined in Attachments D.1 -D.12.

For inspection purposes only. Consent of copyright owner required for any other use.

Raw and auxiliary materials, other substances and the energy used in or generated by the installation:

Raw materials used on site are food ingredients in the following categories: Acidity Regulators, Cereals, Chocolate Products, Cocoa, Colour, Confections, Dairy, Emulsifiers, Fats & Oils, Flavours, Fruit, Functional Ingredients, Hydrocolloids, Nuts & Seeds, Processing Aids, and Sweeteners. Further details of the raw materials are contained in Attachment G.1. The raw materials are not considered hazardous. Auxiliary materials comprise laboratory chemicals, cleaning materials and pest control chemicals. Laboratory chemicals are for the Analytical Laboratory and the Micro-biological Laboratory. These are listed in Attachment G.1. The laboratory chemicals are used in small quantities.

The energy used on site is also detailed in Attachment A.1. Energy used is Natural Gas and Electricity.

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Sources of emissions from the installation: The site has a Greenhouse Gas Emissions Permit, register number IE-GHG097- 02. The emissions from the installation fall into the following categories: ¾ Airborne emissions ¾ Water emissions from industrial process waste water and foul/domestic waste water ¾ Noise emissions from boilers, stacks, roof fans, and chiller units. The fire pump and generators generate noise when run as part of emergency drills. The significant noise emissions come from the chillers and fire pump.

Conditions of the site of the installation: The site is located in a largely residential area and borders the river Santry. It is bordered on the other three sides by roadways.

The nature and quantities of foreseeable emissions from the installation into each medium as well as identification of significant effects of the emissions on the environment: The emissions to air have been monitored and estimated for each emission point. The boiler assessments concluded:

1 A worst-case assessment was analysed to estimate the worst-case air quality impact in the vicinity of the Babcock 40,000 llb/hr Boiler 1 stack located in Cadbury Ireland Ltd, Malahide Road, Coolock, Dublin 5. 2 During 37% and 100% fire capacity (ref: Scenarios 1 and 2 in the report), there will be no significant air quality impact in the vicinity of the facility with all identified compounds less than the regulatory ground level concentrations. A worst-case meteorological file was used in the study. For inspection purposes only. Consent of copyright owner required for any other use. The emissions to water go to foul drain. These emissions are monitored and maintained within the Local Authority licence limits. There are no emissions to surface or ground water. Further details of the concentrations and levels of emissions may be found in the tables in Annex 1.

The proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation: Bag filters are used on the mills and cocoa stack and effectively minimize any particulate emissions. A deodoriser is used in the cocoa block to remove odours. A description of the operation and control of these technologies is included in Section F.1.

Measures for the prevention and recovery of waste generated by the installation, further measures planned to comply with the general principles of the basic obligations of the operator: Waste management on the site is conducted in cooperation with waste management contractors for the site. Further details can be found in section H. There are ongoing reduction, re-use and recycling programmes in place.

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a. all the appropriate preventive measures are taken against pollution, in particular through application of the best available techniques: ¾ An environmental management system is in place on site in compliance with the environmental management system standard ISO14001. This system effectively manages waste and ensures that an environmental management programme works to proactively reduce the level of waste generated. ¾ Waste is stored and segregated effectively on site to ensure that where possible waste is reused or recycled. ¾ A waste management area has been developed where all non- hazardous wastes are segregated and protected as required to allow recycling. ¾ Hazardous wastes streams in excess of 0.5 Tonne per annum are: Deodoriser fat, Gear oil, Chemicals (lab waste), Chemicals (detergents).

b. no significant pollution is caused: ¾ Waste storage, segregation and disposal is managed to ensure that no significant pollution is caused. ¾ All hazardous waste is segregated and stored in a dedicated hazardous materials storage area, where hazardous materials and wastes are stored in bunded chemical storage containers. ¾ Non-hazardous wastes are stored in a dedicated non-hazardous waste management area external to the building. Segregated storage and compaction equipment are managed by the waste management contractor, Greyhound Limited.

For inspection purposes only. c. waste productionConsent of copyrightis avoided owner required forin any otheraccordance use. with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment: ¾ full details of the disposal routes for all waste streams are outlined in Table H of Annex 1.

d. energy is used efficiently: ¾ Energy used on site comes from Natural Gas and Electricity. ¾ There are a wide variety of energy reduction and management programmes ongoing on site. ¾ An energy audit was conducted approximately three years ago and an Energy Strategy Report was completed in April 2006. The company has implemented a number of projects as a result (Attachment No. A.1 (7) contains the Energy Strategy Report. ¾ A CHP plant feasibility study has been completed and is included in Attachment No. A.1 (8).

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e. the necessary measures are taken to prevent accidents and limit their consequences: ¾ The environmental management system includes operational control procedures and an emergency preparedness and response plan. The Emergency Preparedness and Response Plan forms Attachment J. These include procedures for ensuring that waste is handled effectively on site.

f. the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state. ¾ Cadbury take full responsibility for any measures required to avoid any pollution risk and return the site to a satisfactory state on definitive cessation of activities. The Environmental Management System in place on site is designed to ensure that there is no significant pollution caused by the operation and thus the site should be retained at all times in a satisfactory state.

For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION B GENERAL

B.1. Owner/Operator

* Applicants Name: Cadbury Ireland Ltd.

Address: Malahide Road

Coolock

Dublin 5

Telephone No: 01 8480000 Fax No: e-mail : [email protected]

* This should be the name of the applicant on the date the Application is lodged with the Agency. This should be the name of the legal entity (which can be a limited company or a sole trader). A trading/business name is not acceptable.

Address for correspondence : (if different from above)

For inspection purposes only. Consent of copyright owner required for any other use.

Address of Body Corporate : (if applicable)

e-mail :

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The applicant must also supply the following:

(a) Certified Copy of Certificate of Incorporation Please see attachment B.1

(b) Company’s Number in Company’s Registration Office and Company’s Number is 8306

Name and address of the proprietor(s) of the Land on which the Activity is situated (if different from applicant named above).

Proprietor’s Name:

Address:

Name and address of the owner(s) of the building and ancillary plant in which the activity is situated ( if different from applicant named above).

Name: For inspection purposes only. Consent of copyright owner required for any other use. Address:

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B.2. Location of Activity

Name: Cadbury Ireland Limited

Full Address: Malahide Road

Coolock

Dublin 5

Telephone No: 01 8480000 Fax No:

Contact Name(s): Tom Byrne Position(s): Site Environmental Health and Safety Manager

e-mail : [email protected]

National Grid Reference (12 digit-6E, 6N)

239416E, 319820 N

Location maps (no larger than A3), with grid references should be enclosed in Attachment No B.2. For inspection purposes only. Consent of copyright owner requiredo for any other use. Location Maps are contained in Attachment N B.2.

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B.3. Class of Activity

Identify the relevant activities in the First, Third or Fourth Schedule of the PoE Act 2004 to which the activity relates:

Schedule Class DescriptionNote 1 1 7.8 (a) Treatment or processes for the purposes of the production of food products from animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day.

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

B.4. Employees/ Capital Cost

Give-

(i) In the case of an established activity, the number of employees and other persons, working or engaged in connection with the activity on the date after which a licence is required and during normal levels of operation, or

(ii) In any other case, the gross capital cost of the activity to which the application relates.

Number of Employees For inspection(existing purposes facilities) only. 1500 Consent of copyright owner required for any other use.

Gross Capital Cost (new proposals)

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B.5. Relevant Planning Authority

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

Name: Dublin City Council

Address: Dublin City Council, Civic Offices, Wood Quay, Dublin 8

Telephone No: 353 1 222 2222

Planning Permission for this project :-

Obtained √ Is being processed Not applied for

Local Authority Planning File Reference No: 2140/01 - New vehicular entrance off Oscar Traynor Road

Attachment No B.5 should contain all planning permissions including a copy of all conditions. For existing activities, Attachment No B.5 should also contain all licences and permits past and present in force at the time of submission.

For inspection purposes only. Consent of copyright owner required for any other use.

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B.6. Relevant Sanitary Authority.

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

Name: Dublin City Council

Address: Dublin City Council, Civic Offices, Wood Quay, Dublin 8

Telephone No: 353 1 222 2222

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

Name: Not Applicable Address:

For inspection purposes only. Consent of copyright owner required for any other use.

Telephone No:

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B.7. Relevant Health Board Region

The applicant should indicate the Health Board Region where the activity is or will be located.

Name: Health Service Executive, Eastern Area Address: Parkgate St. Business Centre, Dublin 8

Telephone No: +353 (0)1 635 2500

Give the position of the site notice in accordance with article 7 of the Regulations.

Attachment No B.8 should contain a copy of the text of the site notice, a map (no larger than A3) showing its location on site and a copy of the newspaper advertisement. A copy of the notice given to the Planning Authority should also be included.

B.9 Seveso II Regulations

State whether the activity is an establishment to which the EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2000 (S.I. No. 476 of 2000) apply.

If yes, outline how the process comes under these regulations.

Supporting information should be included in Attachment No B.9.

The activity is not an establishment to which the EC (Control of Major Accident Hazards involving Dangerous Substan For inspectionces) purposes Regulations, only. 2000 (S.I. No. 476 of Consent of copyright owner required for any other use. 2000) apply.

B.10 IPPC Directive

Specify whether the facility is a category of industrial activity referred to in Annex I of the IPPC Directive (96/61/EC) and if yes specify the category.

The facility is a category of industrial activity as specified in section 6.4 (b) of IPPC Directive (96/61/EC), Installations for the treatment or processes for the purposes of the production of food products from animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day.

Supporting information should be included in Attachment No B.10.

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SECTION C MANAGEMENT OF THE INSTALLATION

C.1 Site Management & Control

Details should be provided on the management structures for the activity. Organisational charts, and all relevant environmental management policy statements, including provisions for on-going assessment of environmental performance are required.

Indicate whether an Environmental Management System has been developed for the installation.

If yes, specify which standard and include a copy of the accreditation certificate.

This information should form Attachment No C.

Cadbury Ireland Limited maintains an Environmental Management System following the requirements of ISO14001 to ensure ongoing compliance and continuous improvement. The system has not yet been accredited. The E.H.S. Manual (Attachment C.3) outlines the means used to ensure compliance with legislation, prevention and control of pollution (in particular with regard to significant environmental aspects) and continuous improvement in environmental performance.

Attachment No C contains the following Environmental Management System documents: C.1: EHS Policy Statement C.2: Register of Environmental Aspects

C.3: Environmental, Health a n d ForSafety inspection Manual purposes only. Consent of copyright owner required for any other use.

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SECTION D INFRASTRUCTURE & OPERATION

D.1. Operational Information Requirements

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

A development and operational history of the site should be included here.

Overview: The site was originally envisioned as a factory within a garden and this concept was retained by the site management over the years. There is a pitch and putt course on the site and in general it is landscaped and maintained to a high standard. There is one entrance/exit to the site which is continuously manned by security.

The site operates a three cycle shift, Days, Evenings and Nights and also runs specific areas of the plant on Saturdays depending on demand. Currently this applies to Area C (see below) where chocolate flake is manufactured, and for which there is high demand.

The manufacturing areas are divided into Area A, B, C and K. Areas A, B and C are involved in manufacturing chocolate confectionary products including chocolate Flake, Moro, Timeout, and Twirl. The chocolate for these processes starts off with Conching, this helps to give the For Chocolat inspection purposese i tonly.s smooth texture and taste. Alpine Consent of copyright owner required for any other use. mills grind the Chocolate Crumb before Conching, there are no direct emissions associated with grinding other than potential emissions within the plant which are controlled by filters. There is some emission to the foul drain from “cookers” and CIP with small quantities of waste.

Area K (the Cocoa Block) is the producer of the intermediate material for Areas A, B and C. This involves the production of cocoa butter from cocoa beans which are worked to give Cocoa Mass which is sent to Rathmore for addition into the process for making Chocolate Crumb. The processing of the beans also yields C Butter which is added to the Conching stages of Chocolate for flavour. Area K has an additional process known as deodorising which involved the removal of contaminants from the cocoa butter. This includes caffeine and unwanted solids which form a hazardous waste stream for incineration in Germany. There have been no substantiated complaints regarding odour from the site.

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Plant and equipment: Plant and equipment are shown in schematic format in the process maps and equipment layouts are shown in the equipment layout drawings for each section. The main plant and equipment consist of mixers, rolling, conveying and packaging equipment, Ovens and cooling equipment, and storage vessels for raw and intermediary materials.

Chemicals and Services: The materials and chemicals used on site are detailed in Table G1 (i). Small quantities of hazardous materials and chemicals are used in the laboratories. Detergents are used for cleaning the process areas and oils and greases are used by maintenance for facilities applications. Natural gas is used for heating and process applications. The raw materials used on site are food ingredients and thus non-hazardous. Hazardous chemicals are stored in small quantities in the laboratory. A hazardous chemical and hazardous waste storage area is situated external to the plant in a segregated and secure area with bunded storage containers.

Attachment No D should contain a list of all unit operations (process) to be carried out, including flow diagrams of each with any relevant additional information.

Attachment D.1 lists all operations and flow diagrams are appended in Attachment D.2 - D.12 for all process operations.

For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION E EMISSIONS

E.1. Emissions to Atmosphere

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

Details of all point emissions to atmosphere should be supplied. Table E.1.(i) (for Boiler emissions) must be completed for boilers over 20MW thermal input. Complete Table E.1(ii) and E.1(iii) for all other main emission points. Complete Table E.1(iv) for minor emission points.

Please see detail in Table E.1 (i), although the individual boilers are below this threshold. Also, Greenhouse Gas Emissions Permit IE-GHG097-02 is included in Attachment E.1 (2).

The main boiler operates on natural gas and is rated at 11.7 MW. A secondary boiler is not operated except on a test basis as a back up. The main boiler has been tested by Odour Monitoring Ireland Limited as part of an Air Dispersion Modelling study for the plant (see Section I and Attachment I).

Gravimetric isokinetic Total Particulates sampling of the cocoa flue vent located at K Block was also carried out by Odour Monitoring Ireland Limited. The report is to follow week commencing 11th December 2006. A summary table of results is presented in section I.

A summary list of the emission points, together with maps and/or drawings (no larger o than A3), and supporting docum entation For inspection should purposes be only. included as Attachment N E. Plans Consent of copyright owner required for any other use. of emission elevations, relevant roof heights, etc., should also be included, as should detailed descriptions and schematics of all abatement systems.

The applicant should address in particular any emission point where the substances listed in Schedule of S.I. 394 of 2004 are emitted.

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

E.1.B. Fugitive and Potential emissions.

Give summary details of fugitive and potential emissions in Table E.1(v).

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In relation to activities listed in the Schedule of Council Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations; − specify the relevant category of activity in the Schedule − specify how the requirements in relation to fugitive emissions will be met.

¾ The activity does not fall into a category listed in the Directive ¾ Fugitive emissions are controlled by bag filters on mills which have the potential to create particulate emissions

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

E.2 Emissions to Surface Waters

Tables E.2(i) and E.2(ii) must be completed.

A summary list of the emission points, together with maps/drawings (no larger than A3) and supporting documentation should be included as Attachment No E.2.

The applicant should address in particular any emission point where the substances listed in the Schedule of S.I. No. 394 of 2004 are emitted.

¾ No substances listed in the schedule of S.I. No 394 of 2004 are emitted to surface water

Details of all List I and List II substances listed in the Annex to EU Directive 76/464/EEC (as amended), contained in any emission must be presented. All surface water runoff and storm water drains discharging to surface water bodies must be For inspection purposes only. included. A National Grid ReferencesConsent of copyright (10 owner dig requiredit, 5E, for any5N) other m use.ust be given for all discharge points. The identity and type of receiving water (river, ditch, estuary, lake, etc.) must be stated.

¾ List I and List II substances are not present in emissions

¾ There are no emissions to surface water other than storm water

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Tables E.3(i) and E.3(ii) should be completed.

A summary list of the emission points, together with maps and/or drawings (no larger than A3) and supporting documentation should be included as Attachment No E.3. Details of all List I and List II substances listed in the Annex to EU Directive 76/464/EEC (as amended), contained in any emission must be presented. All relevant information on the receiving sewer, including any effluent treatment/abatement systems, not already described, with schematics as appropriate should also be included in Attachment No E.3.

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

Process effluent goes to Dublin City Council’s Waste water Treatment Plant in Ringsend and is licensed by the Council.

E.4. Emissions to Ground

Describe the existing or proposed arrangements necessary to give effect to Articles 3,4,5,6, and 7 of Council Directive 80/68/EEC of 17 December 1979 on the protection of groundwater against pollution by certain dangerous substances.

¾ The organisation does not discharge to ground or to ground water For inspection purposes only. ¾ Any accidental leaksConsent or ofspills, copyright ownerfor requiredexam forple any other of use. diesel or oil, will be fully remediated by the organisation

The applicant should supply details of the nature and quality of the substance (agricultural and non-agricultural waste) to be landspread (slurry, effluent, ash, sludges etc) as well as the proposed application rates, periods of application and mode of application (e.g., pipe discharge, tanker).

¾ Not applicable

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E.5. Noise Emissions

Give particulars of the source, location, nature, level, and the period or periods during which the noise emissions are made or are to be made.

¾ The noise sources which have the potential to be heard outside the plant are the air compressors, air cooled chillers and cooling tower fans. ¾ The plant is situated in an industrial estate and is for the most part surrounded by other factories and by internal and external roads. The nearest noise sensitive location is adjacent to the site. ¾ There have been no complaints in recent years received by the Company regarding noise. ¾ At the time (November 2006) of the last environmental noise survey, the measured noise at four of the five locations exceeded both the daytime (8am to 10pm) and night-time (10pm to 8am) noise limits of 55 & 45 dB(A) respectively. BNL2 was below these limits as a result of its situation away from the roads that bound the Cadbury’s site. ¾ A ‘hum’ from the plant, discernible during night-time measurements, was only evident during lulls in the almost constant traffic flow. ¾ The plant site is bounded on three sides by busy roads, and the traffic on these roads is undoubtedly the main source of noise measured at four of the boundary locations, for both day and night-time measurement intervals. ¾ Consequently, it can be concluded that while all but two of the measured Leq levels exceeded the noise limits, none of these For inspection purposes only. can be attributedConsent to of copyrightactivities owner required on for anythe other use.Cadbury Ireland site.

(Noise survey report, November 2006)

Table E.5(i) should be completed, as relevant, for each source.

Supporting information should form Attachment No E.5

Attachment No E.5 contains a copy of environmental noise measurement surveys conducted by TMS Consultancy Ltd. in November 2006 and TMS Analytical Ltd. in May 2004.

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

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SECTION F CONTROL & MONITORING

Describe the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation/facility.

F.1: Treatment, Abatement and Control Systems

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

For each Emission Point identified complete Table F.1 (i) and include detailed descriptions and schematics of all abatement systems.

Attachment No F.1 should contain any supporting information.

¾ Water emissions to foul drain are largely untreated, although the grease traps on the process effluent is treated with bacteria to control the pH at approximately 6 ¾ There are no emissions to surface or ground water ¾ Surface water drains are regularly inspected and valves closed in the event that any contamination is detected ¾ Air emissions from the mills are abated by bag filters which are regularly inspected and maintained (see details below).

Alpine Mills Abatement System The Mikro-Pulsaire is a self-cleaning dust filter used for the Alpine Mills. It contains felted filtering elements which retain particles sub-micron in size and allows the main gaseous stream to pass through. For inspection purposes only. Consent of copyright owner required for any other use.

The process involves dust laden air entering the lower section of the collector housing under suction or pressure. Air passes through filter cylinders that retain the dust particles and continues up through Venturi sections into the upper plenum chamber and out the collector exhaust. A manometer indicates the pressure differential across the filter elements in inches of water (see Attachment F1).

The performance curve is such that once the dust loading rises above a given high value (usually 20 to 50 grains/ft.3) further increase in dust loading does not increase the differential pressure, or reduce CFM/FT.2 of filter area.

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Timeout Plant Filter System The dust master is a vacuum system used for the “Timeout” Plant. The filters are Nordic cartridges Type NA803 PTFE which carry a B.I.A. rating USGC 99.95% efficiency. The central vacuum cleaning design is based on the diameter of the suction hose and the number of operators, i.e. airflow requirement for a 40mm hose is 90 CFM, a 50mm hose is 180 CFM etc.

40mm hose is mainly used for light dust spillages and 50mm hose is needed to lift larger particles or heavy spillages. As a rule of thumb the hose should be twice the diameter of the largest particle to be lifted (to allow it to be carried on an air stream).

Pick up velocity is normally circa 8,000 ft/min which falls to 4,000 ft/min in the main suction line. The pressure drop in the 100mm diameter main suction line is circa 0.5” Hg per 100 ft. The pressure drop in a 7.5m x 40mm hose is 3.82” Hg and in a 7.5m x 50mm hose s 2.09” Hg. A C.V.C. plant usually has a vacuum rating of 6 to 10” W.G.

Cocoa Block Abatement System A deodoriser is used in the Cocoa Block. This involves 6 stages:

1. Preheat 2. Heat For inspection purposes only. Consent of copyright owner required for any other use. 3. Deodorising 4. Precooling 5. Cooling 6. Discharge

A vacuum is generated using four steam ejectors to reduce the pressure from atmospheric pressure down to a vacuum of less than 3 mbar. The compression ratio for each stage is 5:1. Steam above 11 bar must be used. Steam usage of 785kg/hr is required to generate the vacuum. In order to maintain the vacuum, the steam and vapours must be condensed. Recirculated water is used to cool the vapours. This water becomes acidic. A free fatty acid (FFA) scrubber is used to collect the FFA’s. This operates at >95% efficiency and at a temperature of >75˚C in order to prevent blockages. See the diagram below for the layout of the Deodoriser.

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Attachment F1 contains data and schematics on the deodoriser unit in the Cocoa Block and filter units used on-site.

F.2: EMISSIONS MONITORING AND SAMPLING POINTS

Identify monitoring and sampling points and outline proposals for monitoring emissions. For inspection purposes only. Table F.2(i) should be comConsentpleted of copyright (w ownerhere required relevant) for any other for use. air emissions, for emissions to surface waters, for emissions to sewers, for emissions to ground, and for waste emissions. Where ambient environment monitoring is carried out or proposed, Table F.2(ii) should be completed as relevant for each environmental medium.

The following monitoring is proposed: Air emissions from boilers and mills once per year. Foul drain effluent (pH, COD, SS, BOD and other parameters as required by the current effluent licence) once per quarter. Surface water (pH, COD) twice per year. Noise at site boundary and sensitive locations once per year. Fugitive Emissions monitoring: One off monitoring programme at locations around the site.

Include details of monitoring/sampling locations and methods. Standard monitoring and sampling methods will be used, following EPA guidelines where applicable.

Attachment No F.2 should contain any supporting information.

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For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION G RESOURCE USE AND ENERGY EFFICIENCY

G.1 Give a list of the raw and ancillary materials, substances, preparations, fuels and energy which will be produced by or utilised in the activity.

The list(s) given should be very comprehensive, all materials used, fuels, intermediates, laboratory chemicals and product should be included.

Particular attention should be paid to materials and product consisting of, or containing, dangerous substances as described in the EU (Classification, Packaging, Labelling and Notification of Dangerous Substances) Regulations 1994 [SI 77/94]. The list must classify these materials in accordance with Article 2 of these Regulations, and must specify the designated Risk Phrases (R-Phrases) of each substance in accordance with Schedule 2 of the Regulations

Tables G.1(i) and G.1(ii) must be completed. Copy as required.

Supporting information should be given in Attachment No G.

¾ Fuels used are natural gas, with back-up use of diesel ¾ Attachment G.1 lists all the chemicals and materials used on site. ¾ The site produces chocolate and confectionary

For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION H MATERIALS HANDLING

H.1 Raw Materials, Intermediates and Product Handling All materials should be listed in Tables G.1(i) and G.(ii) of Section G.

Details of the storage conditions, location within the site, segregation system used and transport systems within the site should be outlined here. In addition, information relating to the integrity, impermeability and recent testing of pipes, tanks and bund areas should be outlined.

Diesel and waste oil are fully bunded. Hazardous materials and hazardous waste are stored in bunded containers in the hazardous materials storage area outside the plant. There are a number of double skinned and pressurised tanks for storing organic raw materials. The overpressure in the skin is designed to prevent the egress of any liquid in the event of a breach of the inner wall. The double skinned containers also sit in a bund, although the bund is not sufficient to contain 100% of the contents of the tank. Pipes, tanks and bunds are regularly inspected, including surface water and waste water drains. A bund integrity testing programme is proposed.

H.2 Describe the arrangements for the recovery or disposal of solid and liquid wastes accepted into or generated by the installation/facility.

For each waste material, give full particulars of;

(a) Name

For inspection purposes only. (b) Description & natureConsent of waste of copyright owner required for any other use.

(d) Where stored and integrity/impermeability of storage areas

(e) Amount (m3) and tonnage

(f) Period or Periods of generation

(g) Analysis (include test methods and Q.C. )

(h) European Waste Catalogue Code

(i) Waste Category per EC Reg 1774/2002/EC where relevant

Details are included in Tables H.1 (i) and H.1 (ii) for all hazardous and non-hazardous waste. The following waste streams are generated on site:

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1. Non-hazardous wastes Name: General Cardboard Plastic Paper Timber Aluminium Metal Pallets etc. Description: Solid Solid Solid Solid Solid Solid Solid Source: Factory Factory Factory Factory Factory Factory Factory Canteen Storage area: Segregation Yard Yard Yard Yard Yard Yard Ctr Quantity 8 tonne 8 tonne 8 tonne 8 tonne 8 tonne 8 tonne 8 tonne stored: Generated: Manufacturing Manufacturing Manufacturing Manufacturing Manufacturing Manufacturing Manufacturing Analysis: N/A N/A N/A N/A N/A N/A N/A EWC Code: 150106 150101 150102 150101 150103 151104 150104 Waste Reduce, Re- Reduce, Re- Reduce, Re- Reduce, Re- Reduce, Re- Reduce, Re- Fingal County Use & Use & Use & Use & Use & Use & Council management Recycle Ltd Recycle Ltd Recycle Ltd Recycle Ltd Recycle Ltd Recycle Ltd Landfill Company Waste 95-1 95-1 95-1 95-1 95-1 95-1 95-1 permit/licence

The waste management areas consist of two separate locations, the hazardous materials area and the non-hazardous recycling and segregation area. These are exterior to the plant.

2. Hazardous wastes

Name: Fat Oil Chemicals Chemicals Description: Deod Fat Gear Oil Lab Waste Detergents Source: K Block Factory Lab Factory Storage Deod Fat Waste Oil Hazardous Hazardous Compound Tank Materials Materials Huts area: Huts Quantity 18Tonnes 10 Tonnes 5 Tonnes 5 tonnes max For inspectionMax purposes only. Consent of copyright owner required for any other use. stored: Generated: Deodoriser Machines Lab Factory Analysis: N.A. N.A. N.A. N.A. EWC Code: 020304 130205 160506 161001

Where any waste would be classified as Hazardous Waste as defined in the Waste Management Acts, 1996 to 2003, this should be made clear in the information provided.

Summary Tables H.1(i) and H.1(ii) should also be completed, as appropriate, for each waste. The licence/permit register number of the waste collection agent or disposal/recovery operator should be supplied as well as the expiry date of the relevant permits.

Supporting information should form Attachment No H.1 Attachment H.1 contains the Greyhound Waste Acceptance Report January – July 2006. Solid waste details for 2005 and 2006 are included in this attachment. Information regarding waste to energy operated by Greyhound

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Recycling and Recovery Ltd. is also included in Attachment H.1 “Processing and Movement of Refuse Derived Fuel (RDF)”

H.2 Waste disposal by on-site landfilling.

For wastes to be disposed of by landfilling on-site, full details of the disposal site should be submitted (to include inter alia, site selection procedures, location maps, (no larger than A3) geology, hydrogeology, operational plan, containment, gas and leachate management, post-closure care).

Supporting information should form Attachment No H.2.

¾ Not applicable. It is not intended to dispose of waste by onsite landfilling.

For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION I EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

Describe the conditions of the site of the installation

Provide an assessment of the effects of any emissions on the environment, including on an environmental medium other than that into which the emissions are made.

Describe, where appropriate, measures for minimising pollution over long distances or in the territory of other states.

I.1.Assessment of atmospheric emissions Describe the existing environment in terms of air quality with particular reference to ambient air quality standards.

Provide a statement whether or not emissions of main polluting substances (as defined in the Schedule of S.I. 394 of 2004) to the atmosphere are likely to impair the environment.

Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Attachment No I.1 should also contain full details of any dispersion modelling of atmospheric emissions from the activity, where required.

Air dispersion modelling for the boiler stack was conducted by Odour Monitoring Ireland Ltd.

For inspection purposes only. A worst-case assessmConsentent was of copyright analysed owner required to for eanys timateother use. the worst-case air quality impact in the vicinity of the Babcock 40,000 lb/hr Boiler 1 stack. A worst-case meteorological file was used in the study and two scenarios, 37% firing capacity and 100% firing capacity respectively. It was concluded that there will be no significant air quality impact in the vicinity of the facility as all identified compounds were less than the regulatory ground level concentrations. The efficiency of the boiler was measured at 92 % with CO emissions at less than 1 ppm. NOx emissions levels were measured at a maximum of 22 ppm. Emission and volumetric flow values have been established and are presented in Table 2.4 and 2.5 of the Air Quality Impact Assessment Report carried out by Odour Monitoring Ireland, which is included in Attachment I1.

The cocoa stack is the main emission point from the plant and a study on both concentration and impact carried out by Odour Monitoring Ireland Limited is due week commencing 11th December 2006. In the event that an impact may be expected due to the cocoa stack appropriate measures will be taken.

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A summary table is presented below and includes the normalised concentration and mass emission rates of Total Particulates from the cocoa flue vent. All testing was carried out in accordance with the international standard ISO 9096:2003. The diameter of the sampling point was 390mm ID while the temperature of the airstream was on average 63.4˚C. From observation, the airstream was mainly comprised of fine particulate and oil mist.

Filter Number Sample Total Volumetric Mass Location Particulates Airflow Rate Emission (mg/Nm-3) (Nm-3/s) Rate (kg/hr) 4052 Cocoa flue 477.92 0.326 0.561 vent – sample 1 4049 Cocoa flue 568.11 0.326 0.667 vent – sample 2 Average Totals --- 523.02 0.326 0.614

I.2. Assessment of Impact on Receiving Surface Water Describe the existing environment in terms of water quality with particular reference to environmental quality standards or other legislative standards. Table I.2(i) should be completed For inspection purposes only. Consent of copyright owner required for any other use. The surface water emission points discharge to the river Santry. Sampling and analysis of surface water leaving the site is proposed. The EHS department conduct daily inspections of the surface water and also inspect the river to identify any potential contamination. In the event that any contamination is detected an isolation procedure is implemented. The valves are isolated and any surface water is retained within the onsite drain system. Any contaminated surface water is then removed by a licensed waste contractor (Pipe and Drain Limited).

Provide a statement whether or not emissions of main polluting substances (as defined in the Schedule of S.I. 394 of 2004) to water are likely to impair the environment.

Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

There is no impact on the receiving water under normal conditions. There is no emission to surface water from the operations of the facility.

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Full details of the assessment and any other relevant information on the receiving environment should be submitted as Attachment No I.2.

I.3. Assessment of Impact of Sewage Discharge.

Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Domestic waste arises from toilets, washrooms, and the canteen. It is discharged to the local sanitary authority foul sewer and treated at the Ringsend Waste Water Treatment Plant. Industrial or process wastewater arising from the process is discharged to the sanitary authority foul sewer, which goes to the Ringsend WWTP. The impact on the receiving water is expected to be minimal as the treatment plant has been designed to effectively treat all emissions. Cadbury Ltd. and Dublin City Council have agreed the limits for the effluent based on the capacity of the WWTP and the capacity of the plant. Cadbury have been issued with an effluent discharge licence for its process waste water. Monthly samples are taken from the two pipes which feed into the final outlet. The sample is taken over a 24 hour period. The samples are mixed to form a composite which is analysed for a range of parameters as specified by the licence.

Full details of the assessment and any other supporting information should form Attachment No I.3.

I.4 Assessment of impac t of ground/groundwater For inspection purposes only. emissions Consent of copyright owner required for any other use.

Describe the existing groundwater quality. Tables I.4(i) should be completed. Give summary details and an assessment of the impacts of any existing or proposed emissions on the ground (aquifers, soils, sub-soils and rock environment), including any impact on environmental media other than those into which the emissions are to be made. This includes landspreading, land injection etc.

No impact on ground or groundwater is expected under normal conditions as the site was greenfield to begin with.

Full details of the assessment as well as a hydrogeological report (to include meteorological data and water quality, and aquifer classification, vulnerability, source and resource identification and zonation should be included in Attachment No I.4. A soils survey must also be included where emissions are directly onto or into soils. All vulnerable (as a result of ground emissions) surface water bodies must be identified.

There are no emissions to ground in normal conditions and the facility’s Emergency Response Plan is designed to avoid any release to ground and to minimise the effects if such a release should occur.

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Landspreading of Agricultural/Non Agricultural Wastes

Tables I.4(ii) and I.4.(iii) should be complete where applicable. Further information is available in the Application Guidance Document.

Not Applicable.

I.5 Ground and/or groundwater contamination

Summary details of known ground and/or groundwater contamination, historical or current, on or under the site must be given.

Full details including all relevant investigative studies, assessments, or reports, monitoring results, location and design of monitoring installations, plans, drawings, documentation, including containment engineering, remedial works, and any other supporting information should be included in Attachment No I.5.

Please see I.4 above

I.6 Assessment of the environmental impact of on-site waste recovery and/or disposal.

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

Give details, and an assessment of the impact of any existing or proposed on-site waste recovery/disposal on the environment, including environmental media other than those into which the emissions are to be made.

This information should form Attachment No I.6. For inspection purposes only. Consent of copyright owner required for any other use. There is no on-site disposal of waste.

I.7 Noise Impact.

Give details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

The noise emissions have been summarised as follows: “The plant site is bounded on three sides by busy roads, and the traffic on these roads is undoubtedly the main source of noise measured at each of the boundary locations, for both day and night- time measurement intervals”.(Noise survey report, May 2004)

Ambient noise measurements Complete Table I.7(i) in relation to the information required below:

(i) State the maximum Sound Pressure Levels which will be experienced at typical points on the boundary of the operation. (State sampling interval and duration)

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

(iii) Give details of the background noise levels experienced at the site in the absence of noise from this operation.

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

The site is located in largely residential area and is bounded on three sides by roads and on the forth by the river Santry. The main noise sources identified at the boundaries of the site are from traffic on the roadways. Therefore the impact of noise emissions from the site is low. This is supported by the fact that there have been no complaints in recent years about noise from the activity.

For inspection purposes only. Consent of copyright owner required for any other use.

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I.8 Environmental Considerations and BAT

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

Describe any environmental considerations which have been made with respect to the use of cleaner technologies, waste minimisation and raw material substitution.

Describe the measures proposed or in place to ensure that:

(a) The best available techniques are or will be used to prevent or eliminate or, where that is not practicable, generally reduce an emission from the activity; ¾ (b) no significant pollution is caused; ¾ (c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment

¾ Hazardous waste streams consist primarily of waste from the deodorizer plant, laboratory solvent waste and other chemical waste, and waste oils and lubricants.

(d) energy is used efficiently;

¾ An energy audit was last conducted three years ago and projects are ongoing to reduce energy use. This includes a project to identify and eliminate compressed air leaks. For inspection purposes only. Consent of copyright owner required for any other use. (e) the necessary measures are taken to prevent accidents and limit their consequences;

¾ Cadbury have developed and implemented an Emergency Response Plan (Attachment J) which addresses the prevention of accidents and the mitigation of any possible consequences. An Emergency Response Team is trained and available to respond to all incidents. Spill response kits are available in all areas where there is the potential for spills of hazardous materials. All hazardous liquid chemical storage is bunded.

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

¾ Cadbury Corporate resources will be available to ensure that any pollution risk is avoided upon cessation of activities at the facility and to ensure the site is returned to a satisfactory state. A residuals management plan will be prepared and will entail removal of all

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chemicals and wastes as well as safe cleaning of all plant prior to closure. ¾ The ongoing environmental management system at the site is designed to avoid pollution and retain the site in a satisfactory condition during operations.

Supporting information should form Attachment No I.8.

For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION J ACCIDENT PREVENTION & EMERGENCY RESPONSE

Describe the existing or proposed measures, including emergency procedures, to minimise the impact on the environment of an accidental emission or spillage.

Also outline what provisions have been made for response to emergency situations outside of normal working hours, i.e. during night-time, weekends and holiday periods.

Describe the arrangements for abnormal operating conditions including start-up, leaks, malfunctions or momentary stoppages.

Supporting information should form Attachment No J.

The Accident Prevention and Emergency Response Procedure forms Attachment No. J.

Cadbury assesses potential accident and emergency response needs (including emergency equipment), develops procedures and processes to cope with them, tests planned responses and seeks to improve the effectiveness of its responses.

¾ Procedures

¾ Emergency procedures will be tested and reviewed regularly

For inspection purposes only. Consent of copyright owner required for any other use.

Emergency procedures will be tested and reviewed regularly by the EHS Manager in consultation with the plant incident controller.

The Emergency Response Team is trained to deal with all spills, leaks, and fires.

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SECTION K REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE

Describe the existing or proposed measures to minimise the impact on the environment after the activity or part of the activity ceases operation, including provision for post- closure care of any potentially polluting residuals.

Supporting information should be included as Attachment No. K.

A full risk assessment will be carried out and a residuals management plan will be drawn up in accordance with the EPA's own guidance document. This plan will include removal of all wastes and contaminants etc and will be fully costed. Appropriate financial provision will be made in respect of this.

For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION L STATUTORY REQUIREMENTS

Indicate how the requirements of Section 83(5)(a)(i) to (v) and (vii) to (x) of the EPA Acts, 1992 and 2003 shall be met, having regard, where appropriate, to any relevant specification issued by the Agency under section 5 (3) of the Act and the reasons for the selection of the arrangements proposed.

Indicate whether or not the activity is carried out on, or may be carried out on, or is located such that it is liable to have an adverse effect on - (a) a site placed on a list in accordance with Chapter 1 of SI 94 of 1997, or (b) a site where consultation has been initiated in accordance with Article 5 of the EU Habitats Directive (92/43/EEC), or

Indicate whether or not the activity is liable to have an adverse effect on water quality in light of S.I. No. 258 of 1998 (Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations, 1998).

Indicate whether any of the substances specified in the Schedule of the EPA (Licensing) (amendment) 2004 are discharged by the activity to the relevant medium.

Levels of sulphur dioxide and oxides of nitrogen in boiler emissions are included in the boiler emission data in table E. 1 below. These are well below the limits set in the TA Luft and are in accordance with best practice for boiler management.

Oils, fats and greases, and BOD and COD are monitored in the process water effluent and are below the limits given in the effluent discharge licence.

Fit and Proper Person For inspection purposes only. Consent of copyright owner required for any other use.

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

• Indicate whether the applicant or other relevant person has been convicted under the PoE Act, the Waste Management Act 1996, the Local Government (Water pollution) Acts 1977 and 1990 or the Air Pollution Act 1987.

• Provide details of the applicant’s technical knowledge and/or qualifications, along with that of other relevant employees.

• Provide information to show that the person is likely to be in a position to meet any financial commitments or liabilities that may have been or will be entered into or incurred in carrying on the activity to which the application relates or in consequence of ceasing to carry out that activity.

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The applicant or other relevant persons have not been convicted under any of the Acts noted above. The technical and management resources of Cadbury are consistent with commitment to the requirements of ISO14001. The organisational structure at Cadbury Ireland, Coolock, is detailed in the Environmental Manual, Attachment C.3. The management of Cadbury Ireland meet the requirement of a "fit and proper person". None of the management team has any convictions for breech of environmental law (including the EPA Acts and Waste Management Acts)

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

Accounts are provided under separate cover as confidential documents.

For inspection purposes only. Consent of copyright owner required for any other use.

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SECTION M DECLARATION

Declaration

I hereby make application for a licence / revised licence, pursuant to the provisions of the Environmental Protection Agency Acts, 1992 and 2003 and Regulations made thereunder.

I certify that the information given in this application is truthful, accurate and complete.

I give consent to the EPA to copy this application for its own use and to make it available for inspection and copying by the public, both in the form of paper files available for inspection at EPA and local authority offices, and via the EPA's website. This consent relates to this application itself and to any further information, submission, objection, or submission to an objection whether provided by me as Applicant, any person acting on the Applicant’s behalf, or any other person.

Signed by : Date : (on behalf of the organisation)

Print signature name: For inspection purposes only. Consent of copyright owner required for any other use.

Position in organisation :

Company stamp or seal:

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For inspection purposes only. Consent of copyright owner required for any other use.

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

Emission Point:

Emission Point Ref. No: A1-1 Babcock Steambloc Gas-fired Boiler

Location : Adjacent to carpark

Grid Ref. (12 digit, 6E,6N): 319881.52E, 239534.89N

Vent Details Diameter: 0.4657m

Height above Ground(m): 25.9 m

Date of commencement of 1984 emission:

Characteristics of Emission:

Boiler rating Steam Output: 11,723 KW Thermal Input:

Boiler fuel Type: Natural gas For inspection purposes only. Consent of copyright owner required for any other use. Maximum rate at which fuel is burned 18,144 kg/hr % sulphur content: <1ppm

CO: 1 ppm o NOx : 22 ppm 0 C. 3% O2(Liquid or Gas), 6% O2(Solid Fuel)

Maximum volume of emission 4.65m3/hr

Temperature (max) (min) 474K/ 200oC(avg)

(i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included):

Periods of Emission (avg) min/hr 24/7 hr/day day/yr

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

Emission Point:

Emission Point Ref. No: A1-2

Location : Second boiler not used (started several times per year only)

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

Vent Details Diameter:

Height above Ground(m):

Date of commencement of 1984 emission:

Characteristics of Emission :

Boiler rating Steam Output: kg/hr Thermal Input: 2.7 MW

Boiler fuel For inspection purposes only. Type: Consent of copyright owner required for any other use.

Maximum rate at which fuel is burned kg/hr N.A. % sulphur content: NOx o 0 C. 3% O2(Liquid or Gas), 6% O2(Solid Fuel)

Maximum volume of emission m3/hr

Temperature oC(max) oC(min) oC(avg)

(i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included):

Periods of Emission (avg) Back up only min/hr hr/day day/yr

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

Emission Point Ref. No: A2-1

Source of Emission: Cocoa Stack

Location : Roof of Cocoa Block

Grid Ref. (12 digit, 6E,6N): 319844E, 239588N

Vent Details Diameter: Vent Diameter: 300mm Internal Diameter: 400mm (where measurements taken) Height above Ground(m): 12m

Date of commencement: 1954

Characteristics of Emission: Full report to follow week commencing 11th December 2006

(i) Volume to be emitted:

Average/day m3/d Maximum/day m3/d

Maximum rate/hour m3/h Min efflux velocity m.sec-1 For inspection purposes only. Consent of copyright owner required for any other use. (ii) Other factors

Temperature oC(max) oC(min) oC(avg)

For Combustion Sources:

Volume terms expressed as : wet. dry. ______%O2

(iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included):

Periods of Emission (avg) min/hr hr/day day/yr

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

th Emission Point Reference Number: A2-1 Cocoa Stack Full report to follow week commencing 11 December 2006

Parameter Prior to treatment(1) Brief As discharged(1) mg/Nm3 kg/h description mg/Nm3 kg/h. kg/year Avg Max Avg Max of treatment Avg Max Avg Max Avg Max

For inspection purposes only. Consent of copyright owner required for any other use.

1. Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0oC,101.3kPa). Wet/dry should be the same as given in Table E.1(ii) unless clearly stated otherwise.

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

Emission point Description Emission details1 Abatement system employed Reference material mg/Nm3 kg/h. kg/year Numbers (2) Several small See GHG Permit No abatement system boilers on-site (attachment E1 (2)) for details. These are the equivalent of household heating boilers and are not measured.

For inspection purposes only. Consent of copyright owner required for any other use.

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

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

Emission point Description Emission details1 Abatement system employed Reference Numbers material mg/Nm3(2) kg/h. kg/year

For inspection purposes only. Consent of copyright owner required for any other use.

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

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TABLE E.1(v): EMISSIONS TO ATMOSPHERE - Potential atmospheric emissions

Emission point ref. no. Description Malfunction which could Emission details (as per flow diagram) cause an emission (Potential max. emissions)1 Material mg/Nm3 kg/hour Cocoa Block Mill No emissions would arise ------as it is a positive pressure release point, i.e. the system is not mechanically forced, it consists of passive venting Boiler There is 1 main duty Malfunction of the boiler ------boiler and 1 standby would result in automatic boiler shutdown and the use of the standby boiler. As a result no emissions are anticipated. For inspection purposes only. Filters ExplosionConsent doorsof copyright are owner fitted required The for any dust other use.consists of food Emission for safety reasons. In the particles (wafer or rates are case of malfunction this chocolate crumb) variable would result in an depending on immediate burst of dust to load and atmosphere. throughput of product.

1 Estimate the potential maximum emission for each malfunction identified.

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TABLE E.2(i): EMISSIONS TO SURFACE WATERS – NOT APPLICABLE (One page for each emission)

Emission Point:

Emission Point Ref. No:

Source of Emission:

Location:

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

Name of receiving waters:

Flow rate in receiving m3.sec-1 Dry Weather Flow waters: m3.sec-1 95%ile flow

Available waste assimilative kg/day capacity:

Emission Details:

(i) Volume to be emitted

m3 m3 Normal/day For inspection purposesMaximum/day only. Consent of copyright owner required for any other use.

Maximum rate/hour m3

(ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included):

Periods of Emission (avg) min/hr hr/day day/yr

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NOT APPLICABLE TABLE E.2(ii): EMISSIONS TO SURFACE WATERS - Characteristics of the emission (1 table per emission point)

Emission point reference number :

Parameter Prior to treatment As discharged % Efficiency Max. hourly Max. daily kg/day kg/year Max. hourly average Max. daily average kg/day kg/year average average (mg/l) (mg/l) (mg/l) (mg/l)

For inspection purposes only. Consent of copyright owner required for any other use.

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

Emission Point:

Emission Point Ref. No: 2 lines discharged to manhole at K Block, Ref # 4.1

Location of connection to sewer:

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

Name of sewage undertaker: Dublin City Council Sanitary Authority

Emission Details:

(i) Volume to be emitted

Normal/day See Attachment Maximum/day 700m3 per day B6

Maximum rate/hour 50 litres /second

(ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included):

For inspection purposes only. Consent of copyright owner required for any other use. Periods of Emission (avg) min/hr 24/7 hr/day day/yr

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

Emission point reference number: 4.1

Parameter Prior to treatment As discharged % Efficiency Max. hourly Max. daily kg/day kg/year Max. hourly average Max. daily average kg/day kg/year average average (mg/l) (mg/l) (mg/l) (mg/l)

BOD 6,000 3,000mg/l O2 2,100 COD 12,000 6,000 4,200 pH pH range 6-10 TEMPERATURE 42 Degrees C Suspended solids 3,000 1500 1,050 Detergents 100 70 Oils/fats/greases 800mg/l 420kgs For inspection purposes only. Consent of copyright owner required for any other use. Phosphate 50 35 Volume 50 litres/second 700m3/day

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TABLE E.4(i): EMISSIONS TO GROUND NOT APPLICABLE (1 Page for each emission point)

Emission Point or Area:

Emission Point/Area Ref. No:

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

Location :

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

Elevation of discharge: (relative to Ordnance Datum)

Aquifer classification for receiving groundwater body:

Groundwater vulnerability assessment (including vulnerability rating):

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

Identity and proximity of surface water bodies at risk:

For inspection purposes only. Consent of copyright owner required for any other use.

Emission Details:

(i) Volume to be emitted

Normal/day m3 Maximum/day m3

Maximum rate/hour m3

(ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included):

Periods of Emission (avg) min/hr hr/day day/yr

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TABLE E.4(ii): EMISSIONS TO GROUND - NOT APPLICABLE Characteristics of the emission (1 table per emission point)

Emission point/area reference number :

Parameter Prior to treatment As discharged % Efficiency Max. hourly Max. daily kg/day kg/year Max. hourly average Max. daily average kg/day kg/year average average (mg/l) (mg/l) (mg/l) (mg/l)

For inspection purposes only. Consent of copyright owner required for any other use.

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

Source Emission Equipment Sound Pressure1 Octave bands (Hz) Impulsive or Periods point Ref. No dBA at reference Sound Pressure1 Levels dB(unweighted) per band tonal qualities of Ref. No distance Emission 31.5 63 125 250 500 1K 2K 4K 8K

1. For items of plant sound power levels may be used.

For inspection purposes only. Consent of copyright owner required for any other use.

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

Emission point reference number: Filtration Systems On-site

Control1 Equipment 2 Equipment Equipment Equipment parameter maintenance calibration back-up Air Emission Filter systems Breakdown ------Abatement maintenance and yearly overhaul involving replacement of filters

Control1 Monitoring to be carried Monitoring equipment Monitoring equipment 3 parameter out calibration ------

For inspection purposes only. Consent of copyright owner required for any other use.

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

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

Emission Point Reference No. : SE1

Parameter Monitoring frequency Accessibility of Sampling Points Sampling method Analysis method/ technique BOD Monthly Sampling point currently in use Flow proportional APHA method composite sampling 5210B and 4500-O C COD Monthly Sampling point currently in use Flow proportional APHA method composite sampling 5210B and 4500-O C PH Daily As above As above COP 107 Suspended Solids Monthly As above As above APHA method 2540 D Detergents Monthly As above As above APHA method Oils, Fats, Greases Monthly As above As above APHA method 5520 D Phosphates Monthly As above As above APHA method Volume Daily As above As above Flow meter

For inspection purposes only. Consent of copyright owner required for any other use.

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

Emission Point Reference No. : A1.1

Parameter Monitoring frequency Accessibility of Sampling Points Sampling method Analysis method/ technique CO Annual Sampling point currently in use Isokinetic sampling Flue Gas Analyser NOx Annual Sampling point currently in use Isokinetic sampling Flue Gas Analyser SOx Annual Sampling point currently in use Isokinetic sampling Flue Gas Analyser Efficiency Weekly Sampling point currently in use

Emission Point Reference No. : A2.1

Parameter Monitoring frequency Accessibility of Sampling Points Sampling method Analysis method/ technique Particulate Annual Sampling point currently in use Isokinetic sampling Gravimetry

For inspection purposes only. Consent of copyright owner required for any other use.

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

Monitoring Point Reference No: Ambient particulate monitoring data to be available from Odour Monitoring Ireland w/c 11/12/2006

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

Particulate Annually Not applicable Particulate Monitoring Gravimetry

For inspection purposes only. Consent of copyright owner required for any other use.

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

Analytical Laboratory Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S-Phrase No or Substance Number Stored Usage Code (Tonnes) (Tonnes) 52900 1,1,1, - Trichloroethane 71-55-6 Harmful by Analytical Laboratory R20 S24/25 inhalation. Avoid skin/eye contact. 34863/3 2-Propanal Chromasol 67-63-0 Highly flammable. Analytical Laboratory R11 S7, 16 3539 1000300 Acetone 67-64-1 High Flammable Analytical Laboratory 11 9-16-33-23 27141 Ammonia solution GPR 1336-21-6 Causes burns. Analytical Laboratory R34-50 S26- Very toxic to aquatic 36/37/39-45- animals. 61 3300900 Anti-bumping granules 1344-28-1 N/A Analytical Laboratory 34 26-36/37/39- (fused alumina) 45 26039 Calcium hypochlorite 7778-54-3 Contact with Analytical Laboratory R8-31-34 S2-26-43 combustible material may cause fire. Contact with acids For inspection purposes only. liberates toxConsentic gas. of copyright owner required for any other use. Causes burns. ECO200 Citric Acid Anhydrous 77-92-9 Irritating to eyes Analytical Laboratory 36 26 32203 Diethyl ether 60-29-7 May form explosive Analytical Laboratory 12-19 9-16-29-33 peroxides 1034000 Dichloromethane GPR 75-09-2 Limited evidence of Analytical Laboratory 40 24/25-23- (methylene chloride) carcinogenic effect. 36/37 21258 Digestion Solution for COD N/A Toxic and corrosive Analytical Laboratory 49, 23/24/25, 26, 28a, 45, 33, 35, 52/53 60 28304 Ethanol 99.7-100% absolute 64-17-5 Highly flammable. Analytical Laboratory R11 S7-16 Vapour/air mixture

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explosive 33220 Formaldehyde solution 50-00-0 Toxic Analytical Laboratory R23/24/25, S26, 36/37, 34, 40, 43 44, 51 MSD004 Glass Microspheres American May cause eye, Analytical Laboratory N/A N/A 05A containing Borosilicate glass MSDS. skin, and lung & Soda Lime glass None irritation. specified.

For inspection purposes only. Consent of copyright owner required for any other use.

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S-Phrase No or Substance Number Stored Usage Code (Tonnes) (Tonnes) 2845100 Glucose monohydrate 14431-43- N/A Analytical Laboratory N/A N/A powder 7 34805 Hydranal N/A N/A Analytical Laboratory N/A N/A 34849 Hydranal Water Standard N/A Flammable. Harmful Analytical Laboratory 10-20/21 26, 36/37/39 by inhalation and 37/38 41, 67 skin contact. Irritating to respiratory system and skin. Risk of serious damage to eyes. Vapours may cause drowsiness and dizziness. 30721/0 Hydrochloric Acid 7647-01-0 Corrosive. Eye and Analytical Laboratory 34, 37 2, 26 7102 respiratory irritant. HDHE- Isopar G 90622-57- May cause lung Analytical Laboratory 10, 65, 66 23, 24, 43A, C-00014 4 damage if 62 swallowed. For inspection purposes only. Repeated Consentexposure of copyright owner required for any other use. may cause skin dryness/cracking. Liquids can release vapours that can form flammable mixtures when above flash point. Can accumulate static charge.

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109279 Karl Fisher Solution 111-77-3 May cause harm to Analytical Laboratory 61 53-24/25-45 unborn child. Restricted to professional users.

For inspection purposes only. Consent of copyright owner required for any other use.

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S-Phrase No or Substance Number Stored Usage Code (Tonnes) (Tonnes) 53650 Kovacs indole reagent N/A Flammable. Skin Analytical Laboratory R10-22- S26-39 and respiratory 37/38-41-67 system irritant. Risk of serious damage to eyes. Vapours may cause drowsiness and dizziness. 1013900 Lactose 5989-81-1 None specified Analytical Laboratory N/A N/A 1015700 Mercury AnalaR 7439-97-6 Toxic by inhalation. Analytical Laboratory R23-33 S7-45 Danger of cumulative effects. 1015800 Methanol 67-56-1 Highly flammable. Analytical Laboratory 11-23/25 7-16-24-45 Vapour/air mixture explosive. 3024300 Methylated spirit 99% (74 N/A Highly flammable. Analytical Laboratory 11-20/22 7-16-24-45 O.P.) Vapour/air mixture explosive. For inspection purposes only. 5400100 Molecular sieve 0.4nm 1318-02-1 N/A Consent of copyright owner required for any other use. Analytical Laboratory N/A N/A beads M029 Mono Propylene Glycol 57-55-6 Low toxicity under Analytical Laboratory N/A N/A normal conditions of handling and use. 1016800 Nitric Acid GPR 7697-37-2 Causes severe Analytical Laboratory R35 S23A-26- burns. 36/37/39-45 1401700 Paraffin liquid colourless 8012-95-1 N/A Analytical Laboratory N/A N/A light GPR

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S-Phrase No or Substance Number Stored Usage Code (Tonnes) (Tonnes) 1017800 Petroleum spirit 40-60° 8032-32-4 Highly flammable. Analytical Laboratory R11-52/53 65 S9-16-23-24 GPR Harmful to aquatic 33-62 organisms, may cause long-term adverse effect to aquatic environment. May cause lung damage if swallowed. Phenolphthalein GPR 77-09-8 N/A Analytical Laboratory N/A N/A 2008800 Polydimethylsiloxane 63148-62- N/A Analytical Laboratory N/A N/A (100%) Brookfield 9 Viscometer std fluid) 31534 Potassium Acid Phthalate 877-247 May cause eye Analytical Laboratory N/A N/A irritation on contact. ON ingestion may cause For inspection purposes only. vomiting/paresthesiaConsent of copyright owner required for any other use. of hands/feet. May cause respiratory tract irritation on inhalation. 1019800 Potassium chloride GPR 7447-40-7 N/A Analytical Laboratory N/A N/A 1910600 Potassium hydroxide 0.1 1310-58-3 Irritating to eyes and Analytical Laboratory R36/38 S26 mol/l (0.1N) AnalaR skin. Volumetric Solution 1022400 Propan-2-ol 67-63-0 Highly flammable. Analytical Laboratory R11 S7-16

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1110936 SAL-T 75/ SC 75 N/A N/A Analytical Laboratory N/A N/A 20.0645/ 1110954

For inspection purposes only. Consent of copyright owner required for any other use.

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S-Phrase No or Substance Number Stored Usage Code (Tonnes) (Tonnes) 0151075 SAL-75/ SAL-T 75/ SC-75 N/A N/A Analytical Laboratory N/A S2 /20.0645 /015007 5 0151053 SAL-53/ SAL-T53/ SC-53 13446-18- Irritating to eyes and Analytical Laboratory R36/38 S2, 24,26,62 /20.0643 9 skin. Don’t ingest. /015005 (Magnesiu 3 m nitrate) 3309300 Sand purified by acid GPR, 7631-86-9 N/A Analytical Laboratory N/A N/A fine - Silicone Fluid 702 - Analytical Laboratory - - 3006200 Silica gel N/A May cause cancer Analytical Laboratory R49 S53a-45 by inhalation 1000277 Siloxanes & Silicones, Di- N/A N/A Analytical Laboratory N/A N/A 9 Methyl S008 Sodium Bicarbonate 144-55-8 Low hazard in Analytical Laboratory N/A N/A normal conditions of handling and use. For inspection purposes only. VZ47250 Sodium Chloride 7647-14-5 May be harmfulConsent of on copyright owner required for any other use. Analytical Laboratory N/A N/A

00 inhalation, ingestion or skin absorption. Causes eye/skin irritation. 1802500 Sodium Hydroxide 1 mol/l N/A Causes burns Analytical Laboratory R35 S26-37/39- (N) low in carbonate AnalaR 45 Volumetric Solution 3016900 Sodium hypochlorite 7681-52-9 Contact with acids Analytical Laboratory R31-34 S28-50 solution liberates toxic gas.

06160 Cadbury IPPC licence application Revision 1.doc

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Causes burns. 1802800 Sodium thiosulphate N/A N/A Analytical Laboratory N/A N/A 0.1mol/l (0.1N) AnalaR Volumetric Solution

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S-Phrase No or Substance Number Stored Usage Code (Tonnes) (Tonnes) 3323700 Spillage absorption N/A N/A Analytical Laboratory N/A N/A granules 1027400 Sucrose extra pure 57-50-1 N/A Analytical Laboratory N/A N/A

Notes: 1. In cases where a material comprises a number of distinct and available dangerous substances, please give details for each component substance. 2. c.f. Article 2(2) of SI No 77/94 3. c.f. Schedules 2 and 3 of SI No 77/94

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:37 IPPC Application Form

Micro-Laboratory Ref. Material/ CAS Danger Category Amount Annual Nature of Use R(3) - S(3) - No or Substance Number Stored Usage Phrase Phrase Code (Tonnes) (Tonnes) 20 100 API 20 E Strips N/A N/A Micro-Laboratory N/A N/A 20 600 API 20 Strep Strips N/A N/A Micro-Laboratory N/A N/A 3401500 Brilliant Green 633-03-4 Harmful of Micro-Laboratory R22-36 S26 (Hydrogen sulpfate) swallowed. Irritating to eyes. CM0897 Buffered Listeria N/A N/A Micro-Laboratory N/A - Enrichment Broth Base SR0078 Chloramphenicol 56-75-7 Limited evidence Micro-Laboratory R40 S22 Selective Supplement 200-287-4 of a carcinogenic R42/43 S28 effect. May cause R46 S36/37 sensitisation by R61 S45 inhalation and skin S53 contact. May cause heritable genetic damage. May cause charm to unborn child. For inspection purposes only. May causeConsent harm of copyright owner required for any other use. conjunctival irritation. 5356600 Chromocult TBX Agar N/A N/A Micro-Laboratory N/A N/A 20 600 GP Medium N/A N/A Micro-Laboratory N/A N/A CM0419 Hektoen Enteric Agar N/A N/A Micro-Laboratory N/A - 70 540 JAMES 7647-01-0 (HCl N) 84562-48-1 (may Micro-Laboratory N/A N/A 84562-48-1 (p- be harmful by dimethlyamino-2- inhalation, methoxybenzalde ingestion or skin

06160 Cadbury IPPC licence application Revision 1.doc

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hyde) absorption

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R(3) - S(3) - No or Substance Number Stored Usage Phrase Phrase Code (Tonnes) (Tonnes) CM0701 KF Streptococcus 26628-22-8 Harmful if Micro-Laboratory R22 S61 Agar 247-852-1(sodium swallowed. R52/53 azide) Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment. Exposure to dust at high conc. may cause irritation of nose, throat and respiratory tract. 5363600 Kovacs indole reagent N/A Flammable. Micro-Laboratory R10-22- S26-39 Harmful if 37/38- swallowed. 41-67 Irritating to respiratory system and skin. Risk of serious damage to For inspection purposes only. eyes. VapoursConsent of copyright owner required for any other use. may cause drowsiness and dizziness. SR0141 Listeria Enrichment 66-81-9 Very toxic if Micro-Laboratory R28 S53 Selective Supplement 200-836-0 swallowed. R40 S28 (Cyclohaximide) Limited evidence R46 S36/37 3374-05-8 of carcinogenic R61 S45 222-159-7(Sodium effect. May cause salt) heritable genetic 8048-52-0 damage. May (Acriflavine) cause harm to the unborn child.

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R(3) - S(3) - No or Substance Number Stored Usage Phrase Phrase Code (Tonnes) (Tonnes) CM0856 Listeria selective agar 7447-41-8 Harmful if Micro-Laboratory R22 S26 base 231-212-3 (Lithium swallowed. Irritating R36/37/ S36/37 Chloride) to eyes, respiratory 38 system and skin. LAB150- M.S.R.V Semi-solid - Organic dust may Micro-Laboratory - - A Rappaport Medium cause irritation of skin and respiratory system. Prolonged skin contact may cause rash. CM0059 Malt extract agar 8002-48-0 May cause Micro-Laboratory R42 S22 232-310-9 (malt sensitization by S45 extract) inhalation. CM0733 Maximum Recovery N/A N/A Micro-Laboratory N/A N/A Diluent 152- Modified LICNR Broth - Organic dusts can Micro-Laboratory - - 90050 cause irritation. SR0206 Modified Listeria 1264-72-8 May cause Micro-Laboratory R42/43 S53 For inspection purposes only. Selective Supplement (Collistin Sulphate) sensitisationConsent ofby copyright owner required for any other use. R46 S22 1397-89-3 inhalation and skin S24 Ampholenicin B) contact. May cause S37 215-742-2 heritable genetic S45 28018-09-9 damage. (Fosfomycin) 8048-52-0 (Acriflavine) 20 030 NaCl 0.85% Medium N/A N/A Micro-Laboratory N/A N/A 20 060

06160 Cadbury IPPC licence application Revision 1.doc

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20 710

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R(3) - S(3) - No or Substance Number Stored Usage Phrase Phrase Code (Tonnes) (Tonnes) 70 490 NIN 485-47-2 Flammable. May Micro-Laboratory R10 S53 (ninhydrine) impair fertility. May R60 109-86-4 (2- cause harm to the R61 methoxyethanol) unborn child. R20/21/ Harmful by 22 ingestion, in contact with skin and if swallowed. 491207 Novobiocin, Sodium 1476-53-5 May be harmful if Micro-Laboratory R22 S36 salt swallowed. May R42/43 cause allergic respiratory and skin reaction. May cause damage to the following organs; blood, liver, gastrointestinal

tract, stomach. For inspection purposes only. CM0325 Plate Count Agar N/A May causeConsent slight of copyright owner required for any other use. Micro-Laboratory N/A N/A

(Tryptone glucose irritation to eyes. yeast agar) May cause irritation to skin. Moderate irritation to respiratory system 32 700 Rapid ID 32E Strips N/A N/A Micro-Laboratory N/A N/A CM0549 Rose-Bengal N/A N/A Micro-Laboratory N/A N/A Chloramphenicol Agar Base M42 Salmonella Latex N/A May irritate eyes. Micro-Laboratory Agglutination kit)

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R(3) - S(3) - No or Substance Number Stored Usage Phrase Phrase Code (tonnes) (tonnes) ?? Sodium Chloride ?? Micro-Laboratory Medium 70 400 TDA N/A Micro-Laboratory N/A N/A 10838000 2,3,5 - 298-96-4 N/A Micro-Laboratory N/A N/A Triphenyltetrazolium chloride CM0087 Tryptone Water N/A N/A Micro-Laboratory N/A N/A 822187 Tween 9005-65-6 N/A Micro-Laboratory N/A N/A CM0485 Violet Red Bile 302-95-4 N/A?? Micro-Laboratory R22 N/A Glucose Agar 206-132-7 R37/38 (Sodium Deoxycholate) 361-09-1 206-643-5 (Sodium Cholate) 70 420 VP1 1310-58-3 Corrosive. Causes For inspection purposes only. Micro-Laboratory R35 S2 S26 S27 Consent of copyright owner required for any other use. severe burns S37/39 70 430 VP2 90-15-3 Highly flammable Micro-Laboratory R11 S7 S16 164-17-5 CM0469 X.L.D. Medium 57-50-1 N/A Micro-Laboratory R22 N/A 200-334-9 R37/38 (Sucrose) 361-09-1 206-643-5 (Sodium Cholate) 302-132-7 206-132- 7(Sodium Deoxycholate)

06160 Cadbury IPPC licence application Revision 1.do1185-57-5c 214-886-6 Ammonium Ferric Citrate EPA Export 25-07-2013:20:50:37 IPPC Application Form

Ref. Material/ CAS Danger Amount Annual Nature of Use R(3) - S(3) - No or Substance Number Category Stored Usage Phrase Phrase Code (tonnes) (tonnes) 70 470 ZYM A 77-86-1 (Tris) N/A Micro-Laboratory N/A N/A 151-21-3 (Sodium Dodecysulfate) 70 480 ZYM B 5486-84-0 (Fast Flammable. May Micro-Laboratory R10 R60 S53 blue BB salt) impair fertility. R61 109-86-4 (2- May cause harm R20/21/22 Methoxyethanol) to the unborn child. Harmful by ingestion, in contact with skin and if swallowed.

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

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Cleaning Materials

Ref. Material/ CAS Danger Category Amount Annual Nature of Use R -Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) Alcodes N/A N/A Cleaning Material R11 S2 S16 297 Assert Lemon N/A N/A Cleaning Material R36/38 S2 S24 S12 S26 7L847 Brasso 8052-41-3 N/A Cleaning Material N/A N/A Deb Jizer N/A Extremely Cleaning Material R12 S1/2 S16 S33 flammable. Spraying in a horizontal or inverted position may release butane propellant. Deliberate inhalation abuse could be fatal in extreme cases. Cans may rupture if heated to excess. 610717 Dilac N/A Corrosive-causes Cleaning Material - - burns. This product For inspection purposes only. Consent of copyright owner required for any other use. contains a material with an OES/MEL published in HSE document EH40. 2223661 Disinfectant Wipes N/A Highly flammable Cleaning Material R11 S7-16 04 623397 Diversey HD2 N/A Irritant-irritating to Cleaning Material - - eyes and skin 624536 Diversey HD3 N/A Corrosive-causes Cleaning Material - - severe burns. This

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product contains a material with an OES/MEL published in HSE document EH40.

Ref. Material/ CAS Danger Category Amount Annual Nature of Use R -Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) Diversey Lever Clipton N/A N/A Cleaning Material N/A N/A VC11 Draine N/A Prolonged contact Cleaning Material N/A N/A with the skin can cause irritation. . En-Guard Barrier Cream N/A Eye contact: may Cleaning Material N/A S2 cause mild irritation.

Etch Chem N/A Eye contact: may Cleaning Material N/A - cause irritation. Skin contact: may For inspection purposes only. degreaseConsent skin of copyrightand owner required for any other use. cause irritation. Inhalation: High levels of vapour do not arise in normal use. Ingestion: Single dose oral toxicity is low. Aspiration may cause rapid

06160 Cadbury IPPC licence application Revision 1.doc

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absorption via lungs, resulting in injury to other body systems. Evans Vanodine N/A N/A Cleaning Material N/A S2/26 S45 620682 Fleetclean Premium N/A Flammable Cleaning Material - - Degreaser

Ref. Material/ CAS Danger Category Amount Annual Nature of Use R -Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) Foodguard Barrier Cream N/A Eye contact: may Cleaning Material N/A S2 S16 cause mild irritation. Glade Aerosol 68476-85-7 Extremely Cleaning Material R12 N/A flammable 511150 Jeyes Disinfectant N/A Harmful Cleaning Material R65 R36/38 S2/24/ 25 S29 S38/39 Jizer N/A Irritating to skin. Cleaning Material R38 R51/53 S2 S24/25 May cause lung R65 S35 S37/39 damage if S45 S46 S51 swallowed. Mirage 74-98-6 Skin & eye irritant. Cleaning Material R12 S2 S51 S16

(propane) Vapour harmful For inspectionon purposes only. S23 106-97-8 prolongedConsent ex ofposure copyright owner required for any other use.

(Butane) or in high concentrations 4102 Neodisher A 8 215-185-5 Contact with acids Cleaning Material R31 R35 S26 S27 S28 (Sodium liberates toxic gas. S36/37S39 hydroxide) S45 229-912-9 Causes severe (disodium burns. metasilicate) 207-838-

06160 Cadbury IPPC licence application Revision 1.doc

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8(Sodium Carbonate) 220-767-7 (Dichlorisocy anuric acid)

Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) 4201 Neodisher N 231-633-2 Causes burns Cleaning Material R34 S26 S27 S28 Phosphoric S36/37 S39 acid) S45 Novakleen N/A Cleaning Material R38 S2 S35 S46 S26 Oasis 111 – Floor Cleaner N/A Irritant Cleaning Material Oasis 133 Multipurpose N/A N/A Cleaning Material Cleaner Oasis 498- Cleaner N/A Corrosive Cleaning Material Disinfectant Pine N/A Irritant to eyes & Cleaning Material R36/38 S2 S24/25 For inspection purposes only. Consentskin of copyright owner required for any other use. S26/28 S37/39 406620 Pledge Polish Trigger Spray 90622-57-4 N/A Cleaning Material R10-R65 N/A (Petroleum) C203 Precare OS Barrier Cream 59-50-7 (4- N/A Cleaning Material R21/22 N/A Chloro-m- R41/43 cresol) R50/52/53 R65 31095 Premier Cream Cleaner N/A N/A Cleaning Material N/A N/A 31036

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) 3331 Quatsan 68989-00- N/A Cleaning Material R22, 36/38 N/A 4(Alkyl Dimethyl R34 Benzyl Ammonium Chloride) 61791-31-9 (Coconut Fatty Acid Diethanolamine) 304 Seamar Cream Cleaner N/A N/A Cleaning Material N/A S2 S24/25/26 BD1550 Spectrus BD1550 N/A N/A Cleaning Material R41 S26 S36/37/39 61-5000- Stainless Steel Cleaner 7732-18-5 Extremely flamable Cleaning Material 6132-2 & Polish (3M) (Water) GN- 8042-47- 0300- 5(Petroleum) 5919-2 75-28- FZ-0100- 5(Isobutane0 0672-9 1338-43-8 (Sorbitan For inspection purposes only. Oleate) Consent of copyright owner required for any other use. R58759 Suma Rinse A5 N/A N/A Cleaning Material N/A N/A v Super X 6334-92-0 Irritant Cleaning Material R36/38 S2 S26 (Sodium S24/25 Metasilicate) 5064-31-3 (Trisodium nitriacetate) 68439-45-2 (Alkyl alcohol ethoxylate)

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) Tego Diocto TR 2372-82-9 (N.N- May burn if ingested Cleaning Material R34 S24/25 bis-3- Corrosive Material S36/37/39 S45 aminopropyl S28/26 dodocylamine) 69227-21-0 9alcoho; alkoxylate) 64-19-7 (Acetic acid) Tegoid Tincture 67-63-0 ( Flammable Cleaning Material R10/11 S2 S7 S16 (Propane –2-ol) Tolette 5329-14- Irritating to eyes & Cleaning Material R36/38 S26 S37 6(sulphanic skin S24/25 S50 Acid) 7664-38-2 (Phosphoroc Acid) Toprinse N N/A N/A Cleaning Material Tuf-e Nuf N/A N/A For inspection purposes only. Cleaning Material N/A N/A Consent of copyright owner required for any other use. VA1 Detergent 7664-38-2 Corrosive Cleaning Material R34 S26 S28 (phosphoric S36/37/39 S45 acid) Windowlene Glass N/A May cause skin & Cleaning Material R36/35 S2 S46 Cleaner eye irritation 699999 Zerospot N/A N/A Cleaning Material N/A N/A

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Pest Control Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) Alphachloralose 135879-93-3 Harmful by Pest Control R20/22 N/A Concentrate inhalation and if swallowed 2902 Aquapy 8003-34-7, May cause Pest Control N/A 36/37, 45 51-03-6 transient irritation of the eyes, skin and mucous membranes. Allergic respiratory symptoms of over- exposure may develop after several hours. Toxic to fish and other aquatic life. Decomposes in a fire to emit acrid smoke, irrita ting For inspection purposes only. Consent of copyright owner required for any other use. fumes and carbonmonoxide Contrac Block 28772-56-7 Harmful by Pest Control N/A N/A ingestion F985 Coopex Maxi Smoke Gen’s 52645-53-1 N/A Pest Control R22, 36/37, 45 3811-04-9 R50/53 R9 R20/22

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:37 IPPC Application Form Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S- Phrase No or Substance Number Stored Usage (tonnes) (tonnes) Code SIS 2 Crackdown May cause Pest Control N/A N/A D137/89 transient irritation (max 24hrs) of the eyes, skin and mucous membranes. Toxic to fish and other aquatic life. Drax Gel 10043-35-3 Irritation to eyes Pest Control N/A N/A and broken skin. Nausea if ingested in large quantities. CR Ficam D N/A Pest Control N/A 22, 36/37 14298 45 2757 Ficam W Harmful by Pest Control N/A N/A inhalation. Harmful if swallowed. BROD80 Klerat-Brodifacoum Wax 56073-10-0 N/A Pest Control R26/27/28 N/A 339 Blocks R48/23/24/25 R50/53 For inspection purposes only. AE Maxforce Gel 67485-29-4 Harmful Consentif of copyright owner required for any other use. Pest Control R22 S35 F149320 56-81-5 swallowed. Very R50/53 00RB02A toxic to aquatic 4 organisms, may cause long term adverse effects in the aquatic environment

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) 0593826 Pro Control Fik 21317 584-79-2 Extremely R52/53 S2 0 209-542-4 flammable. R65 S16 52645-53-1 Harmful by R66 S23 258-067-9 inhalation and if R12 S35 51-03-6 swallowed. May R50/53 S51 200-076-7 64742-47-8 cause S57 265-149-8 sensitization by 106-97-8 skin contact. Very 203-448-7 toxic to aquatic organisms, may cause long term adverse effects in the aquatic environment. May cause lung damage if swallowed. Repeated For inspection purposes only. exposureConsent may of copyright owner required for any other use. cause skin dryness or cracking

06160 Cadbury IPPC licence application Revision 1.doc

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R-Phrase S- Phrase No or Substance Number Stored Usage Code (tonnes) (tonnes) AE Pybuthrin 33 8003-34-7 Irritating to skin. Pest Control R38 S35 F027198 51-03-6 Toxic to aquatic R51/53 S57 04 UL04 64742-47-2 organisms, may R65 S62 A1 cause long-term effects in the aquatic environment. May cause lung damage if swallowed BROD83 Sorex Brodifacoum Grain 56073-10-0 N/A Pest Control R26/27/28 N/A 000 R48/25

For inspection purposes only. Consent of copyright owner required for any other use.

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Ref. Material/ CAS Danger Category Amount Annual Nature of Use R- S- No or Substance Number Stored Usage Phrase Phrase Code (tonnes) (tonnes ) Ingredients Not Applicable –Non- Ingredients of NA NA SALT,VACUUM,25KG hazardous confectionary BASE,SODIUM Not Applicable –Non- Ingredients of NA NA BICARBONATE, hazardous confectionary POWDER,25KG STARCH,TAPIOCA,MODIFIE Not Applicable –Non- Ingredients of NA NA D, 25KG hazardous confectionary CER PRO,CRISPED Not Applicable –Non- Ingredients of NA NA RICE,150KG hazardous confectionary STARCH,MALTODEXTRIN,25 Not Applicable –Non- Ingredients of NA NA KG hazardous confectionary BISC,EXTRUDED,HIGH Not Applicable –Non- Ingredients of NA NA ERH,200KG hazardous confectionary BISC,EXTRUDED,NON Not Applicable –Non- Ingredients of NA NA HYDROG,200KG hazardous For inspection purposes only. confectionary Consent of copyright owner required for any other use. BISC,SHORTCAKE,7.5MM,36 Not Applicable –Non- Ingredients of NA NA 0KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA FLOUR,WAFER BLEND,20KG hazardous confectionary CHOC,DARK,REFINER Not Applicable –Non- Ingredients of NA NA FLAKE,POWDER,20KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA CHOC,DARK CHIPS,25KG hazardous confectionary C BEAN,GHANA,BULK Not Applicable –Non- Ingredients of NA NA

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hazardous confectionary COCOA Not Applicable –Non- Ingredients of NA NA BUTR,UNDEODORISED hazardous confectionary A,BOXED,25KG COCOA BUTR,DEODORISED Not Applicable –Non- Ingredients of NA NA A, LIQUID,BULK hazardous confectionary COL Not Applicable –Non- Ingredients of NA NA ART,GREEN,SOLN,4.5KG hazardous confectionary COL ART,CARAMEL 50/50 Not Applicable –Non- Ingredients of NA NA BLEND,5KG hazardous confectionary COL NAT,TITANIUM Not Applicable –Non- Ingredients of NA NA DIOXIDE,5KG hazardous confectionary CONF,CRISPED RICE & Not Applicable –Non- Ingredients of NA NA OAT,6KG hazardous confectionary CONF,CARAMEL Not Applicable –Non- Ingredients of NA NA CRUNCH,15KG hazardous confectionary CONF,HAZELNUT Not Applicable –Non- Ingredients of NA NA PASTE,12.5KG hazardous confectionary DAIR POWD,WHEY Not Applicable –Non- Ingredients of NA NA DEMINERALISED,BULK hazardous confectionary DAIR POWD,FULL Not Applicable –Non- For inspection purposes only. Ingredients of NA NA CREAM,AGGLOMERATED,90 hazardous Consent of copyright owner required for anyconfectionary other use. 0Kg DAIR Not Applicable –Non- Ingredients of NA NA POWD,SMP,STANDARD,25K hazardous confectionary G DAIR POWD,SMP,LOW Not Applicable –Non- Ingredients of NA NA HEAT,700KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA DAIR POWD,WHEY,25KG hazardous confectionary DAIR POWD,WHEY Not Applicable –Non- Ingredients of NA NA DEMINERALISED,25KG

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hazardous confectionary DAIR LIQ,MILK, Not Applicable –Non- Ingredients of NA NA WHOLE,BULK hazardous confectionary DAIR FAT,BUTTER Not Applicable –Non- Ingredients of NA NA OIL,SOLID,1000KG hazardous confectionary DAIR Not Applicable –Non- Ingredients of NA NA LIQ,MILK,SKIMMED,BULK hazardous confectionary Not Applicable –Non- Ingredients of NA NA DAIR FAT,BUTTEROIL, BULK hazardous confectionary EMULSIF LIQ,YN Not Applicable –Non- Ingredients of NA NA LECITHIN,HYDROG,900KG hazardous confectionary EMULSIF LIQ,YN Not Applicable –Non- Ingredients of NA NA LECITHIN,900KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA EMULSIF LIQ,PGPR,20KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA EMULSIF DRY,GMS,15KG hazardous confectionary FAT OIL,PALM Not Applicable –Non- Ingredients of NA NA KERNAL,12.5KG hazardous confectionary FAT OIL,PALM KERNAL+ 2% Not Applicable –Non- Ingredients of NA NA LECITHIN,25KG For inspection purposes only. hazardous Consent of copyright owner required for anyconfectionary other use. Not Applicable –Non- Ingredients of NA NA FAT OIL,CBE,S90, BULK hazardous confectionary Not Applicable –Non- Ingredients of NA NA FAT OIL,PALM,12.5KG hazardous confectionary FAT OIL,RAPESEED Not Applicable –Non- Ingredients of NA NA OIL,HYDROG,BULK hazardous confectionary FAT OIL,PALM + 2% Not Applicable –Non- Ingredients of NA NA LECITHIN,HYDROG,25KG hazardous confectionary FAT OIL,HPKO+2.5% Not Applicable –Non- Ingredients of NA NA

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:37 IPPC Application Form

LECITHIN,HYDROG,25KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA FAT OIL,SUNFLOWER,2L hazardous confectionary FAT OIL,RAPESEED + Not Applicable –Non- Ingredients of NA NA PALM,HYDROG,12.5KG hazardous confectionary FAT OIL,CBE, CDM Not Applicable –Non- Ingredients of NA NA SUMMER,BULK hazardous confectionary Not Applicable –Non- Ingredients of NA NA FAT OIL,CBE,CDM,BULK hazardous confectionary FAT OIL,PALM Not Applicable –Non- Ingredients of NA NA KERNEL,FRACTION,BULK hazardous confectionary FAT OIL,PALM Not Applicable –Non- Ingredients of NA NA KERNAL,HYDROG,25KG hazardous confectionary FAT OIL,HPKO + 1.8% Not Applicable –Non- Ingredients of NA NA LECITHIN,HYDROG,25KG hazardous confectionary FAT,OIL,PALM,HYDROG,INT Not Applicable –Non- Ingredients of NA NA ERESTER,12.5KG hazardous confectionary DAIR FAT,BUTTER Not Applicable –Non- Ingredients of NA NA OIL,SOLID,25KG hazardous confectionary FAT OIL,PALM Not Applicable –Non- Ingredients of NA NA KERNAL,HYDROG,2%SFLEC For inspection purposes only. hazardous Consent of copyright owner required for anyconfectionary other use. Not Applicable –Non- Ingredients of NA NA FLAV,HAZELNUT,10KG hazardous confectionary ESSENT Not Applicable –Non- Ingredients of NA NA OIL,PEPPERMINT,5KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA FLAV,CARAMEL BLEND,4.5L hazardous confectionary FLAV,RASPBERRY,FLAV & Not Applicable –Non- Ingredients of NA NA COL MIX,4.5L hazardous confectionary FLAV,CREAMY Not Applicable –Non- Ingredients of NA NA

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:37 IPPC Application Form

VANILLA,1000KG hazardous confectionary FLAV,COFFEE,POWDER,10K Not Applicable –Non- Ingredients of NA NA G hazardous confectionary Not Applicable –Non- Ingredients of NA NA FLAV,CARAMEL,25L hazardous confectionary FLAV,VANILLIN Not Applicable –Non- Ingredients of NA NA CRYSTALS,25KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA FLAV,TURKISH,4.5L hazardous confectionary ESSENT Not Applicable –Non- Ingredients of NA NA OIL,LEMON,CONC,5KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA FLAV,BUTTER,25KG hazardous confectionary FLAV,MASKING FOR Not Applicable –Non- Ingredients of NA NA GUARANA,10KG hazardous confectionary FLAV,CREAMY Not Applicable –Non- Ingredients of NA NA VANILLA,10KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA FLAV,TURKISH,UK,5L hazardous confectionary Not Applicable –Non- Ingredients of NA NA FLAV,TURKISH,5L For inspection purposes only. hazardous Consent of copyright owner required for anyconfectionary other use. Not Applicable –Non- Ingredients of NA NA FLAV,HAZELNUT,10KG hazardous confectionary ESSENT Not Applicable –Non- Ingredients of NA NA OIL,PEPPERMINT,5KG hazardous confectionary FRUIT Not Applicable –Non- Ingredients of NA NA DRD,RAISIN,STANDARD,11. hazardous confectionary 5KG FRUIT Not Applicable –Non- Ingredients of NA NA DRD,CRANBERRY,15.44KG hazardous confectionary

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:37 IPPC Application Form

Not Applicable –Non- Ingredients of NA NA PHARM,CAFFEINE,25KG hazardous confectionary Not Applicable –Non- Ingredients of NA NA BOTAN, GUARANA,25KG hazardous confectionary BOTAN,GUARANA Not Applicable –Non- Ingredients of NA NA CAFFEINE BLEND,1.05KG hazardous confectionary HYDROCOL,AGAR,POWDER Not Applicable –Non- Ingredients of NA NA ,25KG hazardous confectionary

NUT SEED,HAZEL 10- Not Applicable –Non- Ingredients of NA NA 12MM,WHOLE ROAST,25KG hazardous confectionary NUT SEED,PEANUT,SPLIT Not Applicable –Non- Ingredients of NA NA ROAST,25KG hazardous confectionary NUT SEED,HAZEL,NIBBED,2- Not Applicable –Non- Ingredients of NA NA 4MM,25KG hazardous confectionary NUT Not Applicable –Non- Ingredients of NA NA SEED,ALMOND,BLANCH hazardous confectionary WHOLE,22.68KG NUT Not Applicable –Non- Ingredients of NA NA SEED,COCONUT,DESICCAT hazardous confectionary ED,FINE,10KG NUT Not Applicable –Non- For inspection purposes only. Ingredients of NA NA SEED,COCONUT,DESICCAT hazardous Consent of copyright owner required for anyconfectionary other use. ED,FINE,25KG NUT Not Applicable –Non- Ingredients of NA NA SEED,ALMOND,BLANCH hazardous confectionary HALVES, 12.5KG PRO AID,GLYCERINE 99.5% Not Applicable –Non- Ingredients of NA NA PH.EUR,1200KG hazardous confectionary

SWT DRY, SUGAR,WHITE Not Applicable –Non- Ingredients of NA NA GRANULATED,1000KG hazardous confectionary SWT Not Applicable –Non- Ingredients of R36 NA

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:37 IPPC Application Form

DRY,GLUCOSE,POWDER,25 hazardous confectionary KG BAG SWT DRY,SUGAR,WHITE Not Applicable –Non- Ingredients of NA NA GRANULATED,25KG hazardous confectionary SWT DRY,SUGAR,WHITE Not Applicable –Non- Ingredients of NA NA GRANULATED,BULK hazardous confectionary SWT DRY,DEXTROSE Not Applicable –Non- Ingredients of R36 NA MONOHYDRATE,25KG BAG hazardous confectionary SWT LIQ,GLUCOSE Not Applicable –Non- Ingredients of R36 NA SYRUP,63DE,BULK hazardous confectionary SWT DRY,SUGAR,SILK, Not Applicable –Non- Ingredients of R36 NA 20KG hazardous confectionary SWT LIQ,GLUCOSE Not Applicable –Non- Ingredients of R36 NA SYRUP,42DE,BULK hazardous confectionary SWT Not Applicable –Non- Ingredients of R36 NA DRY,DEXTROSE,ANHYDRO hazardous confectionary US,25KG BAG

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

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

Ref. TA Luft Odour EU Lists I and II No or Material/ Class 1, (Tick and specify Group/Family Number) Code Substance(1) 2 or 3 Odourous Threshold Dangerous Substances Directive Groundwater Directive Yes/No Description 76/464/EEC 80/68/EEC µg/m3 List I List II +1294 List I List II

NOT AVAILABLE

For inspection purposes only. Consent of copyright owner required for any other use.

Notes (cont.): 4. The European Commission priority candidate list

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

TABLE H.1(i): WASTE - Hazardous Waste Recovery/Disposal

Waste material EWC Code Main source1 Quantity On-site Off-site Recovery, reuse Off-site Disposal Recovery/Disposal or recycling

Tonnes / m3 / month (Method & Location ) (Method, Location & (Method, Location & month Undertaker) Undertaker) Iron & Steel 17.04.05 Scrap Plant 3 Store in compound Hammond Lane

Waste Oil 13.02.07 Gear Box Oil !/2 0.5 Waste oil Tank Enva Oil, Co Laois

Waste Oil 13.02.08 Engine Oil !/2 0.5 Waste Oil Tank Enva Oil, Co Laois

Construction Waste 17.01.06 Building renovations 4 Builder Skip Greenstar Ltd Materials.

Deodoriser Fat 02.06.01 Deodoriser K Block 1.2 1.2 In IBC’s in compound Rialta Ltd

Small Lab Waste Laboritory Tests 0.1 Stored in Haz Material Rialta Ltd Store

For inspection purposes only. Consent of copyright owner required for any other use.

1 A reference should be made to the main activity / process for each waste.

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

TABLE H.1(ii) WASTE - Other Waste Recovery/Disposal

Waste material EWC Code Main source1 Quantity On-site recovery/disposal2 Off-site Recovery, reuse Off-site Disposal or recycling Tonnes / month m3 / month (Method & Location) (Method, Location & (Method, Location & Undertaker) Undertaker) Animal Feed 02.06.99 End of belt waste 90 2 load/week Storage in Bags on pallets Millstream Power Ltd Feed Permit WCP/KE/218C/04B Cocoa Shell 02.07.01 Cocoa Bean 80 4 loads/week Fed into transport Millstream Power Ltd Horticulture Processing containers. Rialta Ltd Grease Trap Waste 02.06.03 Plant Washdowns 10 10 Grease Traps License 35-1 Composting Reduce, Reuse and Plastic Packaging 15.01.02 Plastic liners & 2 Baled on site Recycle Ltd Recycled by 3rd party. bags Reduce, Reuse and Paper Cardboard 15.01.01 Spoiled boxes & 18 Baled on site for collection Recycle Ltd Ditto protective Lic. 95-1; Permit sheeting CPD165-1 Timber Pallets 15.01.03 Broken Pallets & 3 Stacked for collection Reduce, Reuse and Ditto. Non std pallets Recycle Ltd Garden Waste 02.06.99 Grass Cuttings 2.5 Open Skip Reduce, Reuse and Ditto. Recycle Ltd Waste to Energy 15.01.05 Laminated 20 4 loads/week Compactors Reduce, Reuse and UK Incineration. packaging. Recycle Ltd Slough Heat and Power UK For inspection purposes only. Consent of copyright owner required for any other use. 1 A reference should be made to the main activity/ process for each waste. 2 The method of disposal or recovery should be clearly described and referenced to Attachment H.1 3 A reference should be made to the main activity/ process for each waste. The method of disposal or recovery should be clearly described and referenced to Attachment H.1

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

NOT APLLICABLE – NO EMISSIONS TO SURFACE WATER Table I.2(i) SURFACE WATER QUALITY

(Sheet 1 of 2) Monitoring Point/ Grid Reference: ______

Parameter Results Sampling Normal Analysis (mg/l) method2 Analytical method / (grab, drift Range2 technique etc.) Date Date Date Date pH Temperature Electrical conductivity EC Ammoniacal nitrogen NH4-N Chemical oxygen demand Biochemical oxygen demand Dissolved oxygen DO Calcium Ca Cadmium Cd Chromium Cr For inspection purposes only. Consent of copyright owner required for any other use. Chloride Cl Copper Cu Iron Fe Lead Pb Magnesium Mg Manganese Mn Mercury Hg

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

Surface Water Quality (Sheet 2 of 2) Parameter Results Sampling Normal Analysis (mg/l) method Analytical method / (grab, drift Range technique etc.) Date Date Date Date Nickel Ni Potassium K Sodium Na Sulphate SO4 Zinc Zn Total alkalinity (as CaCO3) Total organic carbon TOC Total oxidised nitrogen TON Nitrite NO2 Nitrate NO3 Faecal coliforms ( /100mls) Total coliforms ( /100mls) Phosphate PO4

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

NOT APLLICABLE – NO EMISSIONS TO GROUND Table I.4(i) GROUNDWATER QUALITY (Sheet 1 of 2) Monitoring Point/ Grid Reference: ______Parameter Results Sampling Normal Analysis (mg/l) method Analytical method / (composite Range technique etc.) Date Date Date Date pH Temperature Electrical conductivity EC Ammoniacal nitrogen NH4-N Dissolved oxygen DO Residue on evaporation (180oC) Calcium Ca Cadmium Cd Chromium Cr Chloride Cl Copper Cu For inspection purposes only. Consent of copyright owner required for any other use. Cyanide Cn, total Iron Fe Lead Pb Magnesium Mg Manganese Mn Mercury Hg Nickel Ni Potassium K Sodium Na

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

GROUNDWATER QUALITY (SHEET 2 OF 2) Parameter Results Sampling Normal Analysis (mg/l) method Analytical method / (composite, Range technique dipper etc.) Date Date Date Date Phosphate PO4 Sulphate SO4 Zinc Zn Total alkalinity (as CaCO3) Total organic carbon TOC Total oxidised nitrogen TON Arsenic As Barium Ba Boron B Fluoride F Phenol Phosphorus P

Selenium Se For inspection purposes only. Consent of copyright owner required for any other use. Silver Ag Nitrite NO2 Nitrate NO3 Faecal coliforms ( /100mls) Total coliforms ( /100mls) Water level (m OD)

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

TABLE I.4(ii): LIST OF OWNERS/FARMERS OF LAND NOT APPLICABLE

Land Owner Townlands where landspreading Map Fertiliser P requirement for each farm Reference *NMP must take account of on-farm slurry

Total P requirement of the client List ______

For inspection purposes only. Consent of copyright owner required for any other use.

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form

TABLE I.4(ii): LANDSPREADING NOT APPLICABLE

Land Owner/Farmer______

Map Reference______

Field Total (a) Soil Crop P Volume of Estimated P (b) P Applied Total Volume ID Area Usable P Date Required On-Farm in On-Farm Volume to be (kg P/ha) of imported (ha) Area Test of P (kg P/ha) Slurry Slurry Applied slurry per plot (ha) Mg/l test Returned (kg P/ha) (m3/ha) (m3) (m3/ha)

For inspection purposes only. Consent of copyright owner required for any other use. TOTAL VOLUME THAT CAN BE IMPORTED ON TO THE FARM.

Concentration of P in landspread matterial - kg P/m3

Concentrarion of N in landspread material - kg N/m3

06160 Cadbury IPPC licence application Revision 1.doc

EPA Export 25-07-2013:20:50:38 IPPC Application Form Table I.7(i) Ambient Noise Assessment

Third Octave analysis for noise emissions should be used to determine tonal noises National Grid Sound Pressure Levels Reference (5N, 5E) L(A)eq L(A)10 L(A)90 1. SITE BOUNDARY

Location 1: BN1 Daytime 59 61 52 Night-time 60 64 47 Location 2: BN2 Daytime 48 50 44 Night-time 47 49 43 Location 3: BN3 Daytime 65 60 52 Night-time 56 59 50 Location 4: BN4 Daytime 63 66 56 Night-time 60 63 54 BN5 Daytime 58 60 51 Night-time 54 56 51 2. NOISE SENSITIVE LOCATIONS Location 1: Location 2: Location 3: Location 4: NOTE: All locations should be identified on accompanying drawings.

For inspection purposes only. Consent of copyright owner required for any other use.

IPPC Licence Application September 2006

EPA Export 25-07-2013:20:50:38 CADBURY IPPC LICENCE APPLICATION ATTACHMENTS

A.1 Maps, Plans and General information

1. Site Layout 2. Area A Equipment Layout 3. Area B Equipment Layout 4. Area C Equipment Layout 5. Area K Equipment Layout 6. Energy Used on Site 7. Energy Strategy Report 2006 8. CHP plant feasibility study

B.1 Certified Copy of Certificate of Incorporation

B.2 Location Maps of Cadbury Site

B.5 Permits and Licences

B.6 Waste effluent sampling and analysis results

B.8 Site Notice Map showing site notice Newspaper Notice Letter to Planning Authority

For inspection purposes only. C.1 EHS Policy Consent of copyright owner required for any other use.

C.2 Register of Environmental Aspects

C.3 EHS Manual

D.1 List of All Process Operations

D.2-D.12 Flow Diagrams for All Process Operations

E.1- 1. Overall Site Plan Air Emissions Points for Plant 2. Greenhouse Gas Permit

E.2 Drawing: Overall Site Drainage

E.5 Environmental noise measurement survey reports and map

EPA Export 25-07-2013:20:50:38 F.1 Treatment, Abatement and Control Systems Deodoriser Unit in Cocoa Block Alpine Mills Filters Dust Master Filters

G.1 Resource Use and Energy Efficiency

Chemicals and Materials used on-site

H.1 Materials Handling and Supporting Waste Data

1. Greyhound Recycling Waste Acceptance Report January July 2006. 2. Processing and Movement of Refuse Derived Fuel (RDF) 3. Solid Waste 2006 4. Solid Waste 2005

I.1 Air Emissions Monitoring and Air Dispersion Modelling Reports

J.1 Emergency Preparedness and Response Procedure

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:38 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:38 2006 Contract V Performance by Period

Elct 0.651kgs C02 per Kwh Gas 0.19kgs Co2 per Kwh

Period 12345678910111213 Totals Contract Tons 2924 3641 3612 3653 3697 2923 3400 2623 26473

Electricity Kwh/ton 587.3 519 508 477 471 518 508 571

Electricity Kwh 1717492 1889516 1834844 1742242 1743222 1513824 1726170 1498720

Electricity tons Co2 1118 1230 1194 1132 1134.5 985.499 1124 976 8893.999

N Gas Kwh/ton 1064 924 992 783 623 603 552 583

N Gas Kwh 3110845 3363388 3582009 2859623 2302559 1763885 1877866 1529387 M3 135344 N Gas tons Co2 591 639 681 543 437.5 335.138 357 291 3874.638

Water M3 12300 7805 8881 10085 10193 9785 11885 8558 Per ton 4.2 2.1 2.46 2.76 2.76 3.35 3.5 3.26 Effluent M3 4451 3291 3922 3888 4908 2939 3823 2414 12768.637 Per ton 1.52 0.91 1.09 1.06 1.33 1.01 1.12 0.92 S-Waste Kgs 162320 164270 196036 164700 274270 172150 139600 195236 per ton 55.5 45.12 54.27 45 74.19 58.89 41.06 74.43 480 Kgsper ton Recycling 92 93 93 93 93 94 94 95

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Invoices N Gas Kwh 3406190 3497952 3799622 2778435 2602278 2006 Invoices Electricity 2123369 1872149 2011244 1827199 1983830 2006 Net C Value N Gas SEI Gas Co2 Kgs 647176.1 664610.88 721928.18 527902.65 494432.82 SEI Electricity Co2 Kgs 1382313.2 1218769 1309319.84 1189506.55 1291473.33 For inspection purposes only. Consent of copyright owner required for any other use. EPA Convert to TJ Gas Tera Joule Convert to CO2 Gas * 57.26

Cost N Gas from Invoices Euros 232327 160695 169202 89754 74987 Cost Electricity from Invoices Euros 185283 198024 181062 195954

EPA Export 25-07-2013:20:50:38 2005 Contract V Performance by Period

Elct 0.651kgs C02 per Kwh Gas 0.19kgs Co2 per Kwh

Period 12345678910111213 Totals Contract Tons 8074 4071 3896 4187 3059 3716 2325 5750 4502 4099 4387 2685 50751

Electricity Kwh/ton YTD 480 470 448 446 453 463.9 459.5 440 438 441 443 450

Electricity Kwh 3879350 1487114 1981936 1828094 1533272 1974966 973484 1925166 1929008 1901878 2037776 1563472 23015516

Electricity tons Co2 2525.5 968 1290 1190.1 998.2 1285.7 634 1253.3 1255.8 1238.122 1326.59 1017.82 14983.134

N Gas Kwh/ton 848 843 831 792 768 746.7 739 682 663 659 673 688

N Gas Kwh 6843227 3078252 3326315 2704404 1859560 2282871 1534553 2225328 2312279 2548104 3566119 2593537 34874549

N Gas tons Co2 674 674 606.4 655 532.77 366 449.7 302.3 438.3 457.4 484.139 677.56 492.77 6810.339

Water M3 26006 9927 11033 9985 9834 10323 8433 14254 9517 10500 8679 6676 135167 Per ton 3.2 3 2.85 2.74 2.8 2.8 2.939 2.86 2.78 2.762 2.69 2.679 Effluent M3 6904 4452 8180 7763 6800 2070 4042 4347 33202 Per ton 0.85 0.91 0.89 0.96 1.17 1.26 1.23 1.2 1.12 1.11 1.07 1.107 S-Waste Kgs 422210 255126 312700 792576 1464456 315520 192740 182229 301064 256320 237390 181710 4914041 per ton Recycling 92 93 93 92 91 93 90 92 93 93 92 93 For inspection purposes only. Consent of copyright owner required for any other use.

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total Kwh

2005 Invoices N Gas Kwh 3001898 3889737 3585672 3326315 3106032 2181843 2114217 2137014 2431941 2590584 3787396 2994346 35146995 2005 Invoices Electricity 2006679 1992362 2005999 2081843 2035940 1916244 2061453 1635530 2083560 2077200 2183179 1563472 23643461 2005 Net C Value N Gas 2791765.14 3617455.41 3334674.96 3093472.95 2888609.76 2029113.99 1966221.81 1987423.02 2261705.13 2409243.12 3522278 2784742 Gas Co2 Kgs 570360.62 739050.03 681277.68 631999.85 590146.08 414550.17 401701.23 406032.66 462068.79 492210.96 719605.2 568925.7 6677929 6677 Electricity Co2 Kgs 1306348.03 1297027.66 1305905.35 1355279.79 1325396.94 1247474.84 1342005.9 1064730.03 1356397.56 1866556 1783980 1783980 17035082 17035.1

Convert to TJ Gas Tera Joule 10.0503545 13.0228395 12.0048299 11.1365026 10.3989951 7.30481036 7.07839852 7.15472287 8.14213847 8.67327523 12.6802 10.02507 Total 117.6721393 (EPA ) Convert to CO2 Gas * 57.26575.483299 745.687788 687.396558 637.67614 595.446461 418.273441 405.309099 409.679432 466.218849 496.63174 726.0684 574.0355 Total CO2 6737.906694

Cost N Gas from Invoices 87785.64 108336.58 90950.17 65335.84 61504.03 47044 44593 44823 49063 93046 141717 163591 997789.26 Cost Electricity from Invoices 187720 186140 165268 193005 189326 179987 190805 156370 192556 192079 220072 220000 2273328

EPA Export 25-07-2013:20:50:38 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:38 14 Orlagh Lodge, Scholarstown Road, Templeogue, Dublin 16.

Date: 14th-April-2006

Client Cadburys Ire, Malahide Road, Coolock, Dublin 5

For inspection purposes only. Consent of copyright owner required for any other use.

Title Review of the Hot Water/Space Heating/Domestic Hot Water Heating Systems

Report By. Patrick Duke

Signed By.

EPA Export 25-07-2013:20:50:38 Acknowledgement:

The author would like to thank Tom Byrne, Norman Briggs and the Managers of each Block for their time while undertaking this survey.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:38

Contents Page No.

Acknowledgement 2

List of Diagrams & Tables 4 Executive Summary. 1.0 Introduction 5

2.0 Review of the current installation in terms of the number of boilers, their 20 rating, location, control strategy, safety, reliability, and efficiency.

3.0 Evaluate the cost of supplying hot water for process, space heating and 33 domestic hot water using steam.

4.0 Cadburys Future Energy Strategy 45

Appendices Appendix A 2005 gas Consumption For inspection purposes only. Consent of copyright owner required for any other use. Appendix B 2005 Electrical & Natural Gas Consumption & Cost Appendix C List of Boilers/Heaters Appendix D Sample H.A. O’Neill Survey Report Appendix E List of Thurley Heaters & Maintenance Report Appendix F Quotes for Maintaining Hot Water boilers & heaters Appendix G Proposed Layout of New Steam System Appendix H Quotes for Steam System Appendix I IBEC in response to a new EU Green Paper on Energy Policy. Appendix J Week No. 52 Electrical Energy Usage Appendix K SEI Domestic Fuel Cost Sheet Appendix L BEMS Software Functions

EPA Export 25-07-2013:20:50:38

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:38 List of Diagrams

Fig. 1 Energy Use 1996 to 2005 Page 6 Fig. 2 On/Off Controls Showing Undershoot & Overshoot Page 61 Fig. 3 P, PI & PID Control Page 61

List of Tables

Table 1 Categorising of Items from H.A. O’Neill’s Boiler Inspection Page 26 Table 2 Summary of Boiler/Heaters Condition Page 28 Table 3 Thurley Heaters Operating and Replacement Costs Page 31 Table 4 Cost of Space Heating Equipment Page 39 Table 5 Estimated Cost of an 850 kW Wind Turbine Page 47 Table 6 Wind Turbine Simple pay back under various operating load and Electricity costs including 10% Grant Page 48 Table 7 Simple Pay Back on Solar Collector based on Average Unit Cost of 3.35 c/kWh for Natural Gas Page 56 Table 8 Simple Pay Back on Solar Collector based on Average Unit Cost of 10 c/kWh for Natural Gas Page 57 Table 9 Boilers Hour Run Meter Readings Page 59 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:38 1.0 Introduction

At the request of Mr. Tom Byrne, Energy & Environment Manager, Integrated Energy Consultancy Ltd. carried out a review of the hot water/space/domestic hot water heating system at the Cadburys plant at Coolock Dublin 5.

The purpose of the study was as follows;

• Review the current installation in terms of the number of boilers, their rating, location, control strategy, safety, reliability, and efficiency,

• Evaluate the options of supplying hot water for process, space heating and domestic hot water using steam,

• Outline a strategy to improve the current system performance,

• Provide a written report outlining the findings, making recommendations on how the system can be improved and provide an energy strategy for the future.

For inspection purposes only. 1.1 Overview of Thermal EnergyConsent ofUsage copyright owner required for any other use.

Natural gas is used for steam raising, heating ovens, process heating, space heating and domestic hot water heating. Appendix A shows the weekly gas consumption by area for 2005. It shows that the percentage breakdown of natural gas usage is as follows;

• Steam Boilers 53% (58%) • Ovens 19% (17%) • Space/Process/Domestic Heating 28% (25%)

The figures in brackets show the usage when audited in 2002. Space/process/domestic heating is provided throughout the site by over 100 separate units.

EPA Export 25-07-2013:20:50:38 Appendix B shows the 2005 electrical and natural gas consumption and cost. The useful cost of thermal energy (natural gas) is calculates at 3.34 c/kWh based on a boiler efficiency of 70%. The average cost of electricity is 8.5 c/kWh.

Fig 1 shows the historical energy consumption from 1996 to 2005. The trend in total energy consumption had risen from 1998 to 2002, more so with gas consumption than electricity usage. Since 2002 Cadburys have undertaken a number of energy studied which has help to reduce consumption which has remained reasonable steady from 2003 to date.

Fig.1 Energy Use 1996 to 2005

80,000,000 70,000,000 60,000,000 Gas h 50,000,000

W 40,000,000 Electricity k e 30,000,000

Us Total 20,000,000 10,000,000 0 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 Year For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:39 2.0 Summary & Conclusion

2.1 Brief Overview of Process/Space/Domestic Hot Water Boilers

• Steam Boilers 53% • Ovens 19% • Space/Process/Domestic Heating 28%

There are 102 individual boilers/heaters which provide process heating, space heating and domestic hot water. A list of all the boilers/heaters is contained in Appendix B.

Cadburys recently commissioned HA O’Neill’s to undertake a study of the hot water boilers/heaters. The survey assessed the condition of the boilers under 14 headings and included a section which made comments on action required. Appendix D contains a sample survey sheet. A copy of this report is on file.

For inspection purposes only. Consent of copyright owner required for any other use.

2.1.2 Review of Process/Space/Domestic Hot Water Boilers

As part of the review of the hot water boiler heating system a meeting and discuss took place with the relevant manager in each block and also the manager responsible for the office heating to ascertain their opinion on how reliable the system is and what are their main operational concerns and maintenance issues. All manages agreed within reason that the current system is very reliable and has caused very little problems from the point of view of system availability and reliability. There was a general consensus that the boilers would benefit from an annual service which should include the following;

EPA Export 25-07-2013:20:50:39 • A record of the work done and this information should be documented so details and history of the condition of all boilers is on file.

• The service should include the testing of the associated back-up electrical emersion system and all ancillary equipment such as the pressurised hot water heating system.

A problem which can occur is should a boiler fail to ignite and the back-up emersion operates that there may be no indication this has occurred. K Block has installed an alarm system to indicate such a fault. This is quite a simple but effective system and therefore consideration should be given to the installing a similar system for all other process heating boilers.

With regards to boilers safety this has been addressed by the HA O’Neill survey but there still is a need to periodically check the installation for leaks. Cadburys have an extensive metering system in place, but it is unlikely to detect any minor gas leaks. Gas leak detection is an option for the boiler house locations but not for any boiler located in the main factory. Therefore it is recommended that a quarterly inspection be undertaken by the Cadburys maintenance staff to check the soundness of the gas installation in each For inspection purposes only. block. Gas leak detection shouldConsent be of installed copyright owner in required all boiler for any other houses. use.

In general the conditions of the boilers/heaters are in reasonable good condition. Any out standing work as identified on the HA O’Neill’s study should be rectified as part of an annual service. To ensure the continued availability, reliability, safety and efficiency of theses boilers/heaters they need to be put on a preventive maintenance schedule. It is recommended that this should be contracted out to a specialist boiler service agent. Based on quotes received the cost for an annual boiler/heater servicing is estimated at Euro 23,000. This covers an annual service, spare parts and annual boiler replacement cost. The boiler service agent should be giving the responsibility of recording, documenting and reporting to the Facility Manager on all work done.

EPA Export 25-07-2013:20:50:39 The Thurley heaters are on average 21 years old and they will need to be replaced in the near future. Therefore finance will need to be made available for their replacement. When the heater are being replaced they should be replaced with the re-circulation air type and controlled through the Building Energy Management System (BEMS) so they can be time scheduled and take into consideration outside and inside ambient temperature so as to reduce their energy cost.

2.1.3 Proposal to supplying hot water for process, space heating and domestic hot water using Steam

Taking into consideration the age of the current process/space/domestic hot water heating system, i.e. many of the boilers/heaters are 20 year old this provides an ideal opportunity to evaluate the benefits of replacing the existing system with a steam heating system. Cadburys UK use similar type of process, space and domestic hot water heating systems but use steam as the heating medium.

The total cost of a new steam system based on quotes received is as follows;

For inspection purposes only. New Boiler Capital & InstallationConsent Costs of copyright owner required for any other Eurouse. 171,725

Steam Distribution Capital & Installation Costs Euro 1,715,500 Steam Equipment Costs Euro 764,736

Capital Cost Euro 2,651,961

Annual Boiler Maintenance Costs Euro 20,000 Annual Maintenance of Steam Distribution Systems Euro 5,000 Annual Fuel Cost Euro 81,302

Annual Operating Cost Euro 106,302

EPA Export 25-07-2013:20:50:39

The annual cost of maintaining the existing system was quoted at Euro 23,000. This cost is insignificant when compared to the cost of installing a new steam system to provide the process/space/domestic hot water requirement. Further more the annual operating and maintenance cost of the proposed steam system is approximately 4 times the estimated cost of maintaining the existing system. Therefore there is no financial justification in replacing the existing system with a steam heating system.

The report shows that at a very reasonable cost the reliability, availability, safety and efficiency of the process/space heating/domestic hot water boiler can be maintained into the future by putting into place a preventive maintenance programme for these boilers and their associated equipment.

2.1.4 Future Energy Strategy for Cadburys Ireland

Sections 5.0 of the report outlines the options which Cadburys Ireland should consider to reduce it reliance on imported fuels.

IBEC in response to a new EU Green Paper on Energy Policy outlined Ireland

For inspection purposes only. vulnerability to any future enConsentergy ofcrises. copyright ownerIt goes required on for anyto other stat use.e that Ireland must become more self sufficient and broaden it fuel mix. It outlines that since 2001 electricity and gas tariffs to business have increased by 60% and 100% respectively. In their statement IBEC states that Ireland must “become more self sufficient and broaden it fuel mix”, and this can be similarly applied to Cadburys Ireland.

2.1.4.1 Wind Energy

Dundalk Institute of Technology recently installed a wind turbine. This is the first urban wind turbine in Ireland and is situated on the college campus surrounded by a residential area. There were no major planning problems and the system is used to reduce the college electricity bills with any excess electricity being sold to the national grid. Dundalk is an average wind site and would have lower average wind velocity than sites in the west of

EPA Export 25-07-2013:20:50:39 Ireland. A feasibility study for their 850 kW wind turbine shown the following financial details;

Simple Pay back 8.1 years (no grant) 5.0 years (with grant) IIR 3% (no grant) 18.3% (with grant)

Assuming that Cadburys installed a similar sized turbine and at the current energy cost the worst case scenario (2,500 hours of operation per annum) gives an 8.3 year pay back and this improves to 5.5 years when operating under best case scenario (3,500 hours of operation per annum). So it can be expected that the actual pay back will be some where between theses two values. Cadburys could achieve a 5.4 years simple pay back if based on a 30% load factor which is what is expected to be achieved for the DKIT wind turbine. The simple pay back based on a 10% grant assistance towards the capital cost from SEI would achieve a 4.8 year pay back based on a 30% load factor at current electrical energy costs.

Another option is for Cadburys in Rathmore Co. Kerry to installing the wind turbine and to use all the electricity on their site and/or to exporting it to Cadburys (Dublin). This location would have far more favourable wind velocity profiles than the Dublin site and

For inspection purposes only. may be easier to achieve plaConsentnning of copyrightperm ownerission. required It forwould any other use.require a grid connection if electricity was to be exported.

The demonstrating of wind turbine on industrial site is part of the SEI strategy. To-date no financial support has been awarded to any industrial company for the on-site wind generation. SEI will provide upto 10% of the capital cost for any such project provided it meets their requirement.

Financial support is available for a feasibility study with the potential of further support depending on the report findings. It is recommended that Cadburys Ireland initially pursue this line of action by undertaking a feasibility study. SEI will fund upto 50% of

EPA Export 25-07-2013:20:50:39 the cost of a feasibility study. Any feasibility study would need to address the following areas;

1. Return on Capital Investment 2. Local Wind Data 3. Economical Size of Wind Turbine 4. Planning Permission 5. Connects to the National Grid

2.1.4.2 Biomass

In recent years there has been a growth in the use of solid biomass to provide hot water heating through the combustion of specially manufactured wood pellets. Theses pellets are carbon neutral and therefore do not contribute to greenhouse gases.

For inspection purposes only. revenue streams from the saleConsent of of copyrightexcess owner carbon required for permany otherits. use. Cadburys Ireland has an allowance of 8,059 tonnes of Carbon Dioxide for 2005, 2006 and 2007. They produced 6,510 in 2005 with an output of 39,556 tonnes of product. This means they have an excess 1,549 tonne of CO2 for 2005. The cost penalty should they exceed their carbon allowance is 24 Euro/Tonne of carbon.

The current useful cost of natural gas is 3.34 c/kWh compared to wood pellets at 5.6 c/kWh and hence there is no financial advantage to be gained from changing from natural gas to wood pellet boiler. In fact replacing all theses boiler with wood pellet boiler would increase energy cost by Euro 423,375 based on current fuel costs.

EPA Export 25-07-2013:20:50:39 Therefore the economical breakeven point for changing to wood pellets will depend on the unit cost of natural gas, unit cost of wood pellets and the cost penalty per tonne of carbon. The most likely scenario is that natural gas ant the penalty cost per tonne of carbon will increase at a greater rate than the cost of wood pellets and some time in the future it will be economical to change to a wood pellet boiler.

SEI is to announce in the near future a Bio-Heat Boiler Deployment Programme. This is a pilot grant support programme aimed at supporting the deployment of boilers fuelled by wood chips and / or wood pellets and applied in large buildings/small industrial sites in Ireland. The programme supports qualifying boiler systems typically rated between 60kW and 1,000kW that are fuelled by wood pellets and/or wood chip fuel. The Government's 2006 Budget announced funds for a full scale grant scheme for this sector. While details of the funding proposed should be available shortly, it can be expected that the level announced will provide a major stimulus to the sector.

This is a programme which Cadburys could make use of in the form of a pilot study in the use of bio-heat boiler in replacing it existing gas fired boiler used for process/space heating/domestic hot water generation. There are a number of boilers used for space heating and domestic hot water production and to a lesser extent process boiler which

For inspection purposes only. would fall into this kilowatt siConsentze ca teof copyrightgory. Aownerlthough required for it any has other already use. been shown that on a fuel cost bases it is not economical, this would be an ideal opportunity for Cadburys to utilise the grant support from SEI to install a bio-heat boiler as a pilot project and monitor it performance. This would provide Cadburys with valuable information should the need to switch all their boilers to bio-fuel in the future in the advent of any significant increase in both natural gas costs and carbon charges. For example replacing one of the Office boilers with a bio-heat boiler would have no impact on the manufacturing process but at the same time provide the Engineering Department with information on operation and maintenance costs of a bio-heat boiler.

EPA Export 25-07-2013:20:50:39 2.1.4.3 Solar Heating

Solar heating uses collectors to transform sunlight into heat to provide space and/or water heating. For July in Dublin the average daily solar energy is approximately 0.235 kW/m2, while in December this falls to 0.022 kW/m2. For summer periods this equates to approximately 5.7 kWh per day/m2 of collector.

An analysis of the pay back based on current cost natural gas of 3.35c/kWh and a future cost of 10 c/kWh for a 4m 2 solar collector gives a simple pay back of 43 years and 14 years respectively. Therefore base on the economics it is unlikely, even taking the reduction of carbon cost into consideration, that solar heating will play any significant role in providing thermal energy to Cadburys Ireland in near future

2.1.4.4 Mirco CHP

A feasibility study in 2004 (40% Grant aided by SEI) on the installation of a micro CHP unit to supply hot water identified two possible projects as follows;

Option No. 1. A Micro-CHP unit providing heat for the boiler feed make-up only

For inspection purposes only. CHP Unit Capital Cost Consent of copyright owner required for any other Eurouse. 127,000 (SIZE)?

Net CHP savings Euro 16,903

CO2 Cost reduction Euro 2,040 Simple Payback 6.7 years

Option No. 2. A Micro-CHP Plant providing heat to boiler feed make-up & K 8 Boilers CHP Unit Capital Cost Euro 135,000 Net CHP savings Euro 19,275

CO2 Cost reduction Euro 2,040 Simple Payback 6.3 years

EPA Export 25-07-2013:20:50:39 At the time of the study both options showed to long a payback period and therefore they were not considered for investment.

SEI is to announce in the near future financial support for CHP demonstrating projects. As Cadburys have already undertaken a feasibility study which was granted aided by SEI they should be a good position to get support provided they fulfil the grant criteria. The application of a micro CHP system to provide process heating is unique in Ireland and therefore a submission should achieve favourable support from SEI. A 10% grant support towards the capital cost will achieve a 3.88 simple pay back based on the costing outlined below.

Option No. 2. A Micro-CHP Plant providing heat to boiler feed make-up & K 8 Boiler with 10% Capital Cost Grant Support CHP Unit Capital Cost Euro 135,000 Net CHP savings Euro 19,275

CO2 Cost reduction Euro 2,040 Grant Euro 13,500 Simple Payback 3.88 years

For inspection purposes only. If consideration is taken for theConsent K8 ofboiler copyright replacem owner requirede fornt any cost other thenuse. the pay back will be 3.39

years simple pay back as outlined below.

Option No. 2. A Micro-CHP Plant providing heat to boiler feed make-up & K 8 Boiler with 10% Capital Cost Grant Support & Boiler replacement Cost CHP Unit Capital Cost Euro 135,000 Net CHP savings Euro 19,275

CO2 Cost reduction Euro 2,040 Grant Euro 13,500 Boiler Replacement Cost Euro 5,000 Simple Payback 3.39 years

EPA Export 25-07-2013:20:50:39 Cadburys should now re-consider the installation of a micro CHP system as outlined in the 2004 study when SEI launch their CHP grant support programme. It is assumed as Cadburys have already undertaken a CHP feasibility study under the SEI programme they should now be in a very good position to receive financial support from SEI.

Large scale CHP should only be considered at a time in the future when the stand-by steam boiler needs to be replaced. It should also be considered in relation to operating

any new CHP plant fuelled by wood pellets. This should be review if CO2 charges are likely to become a significant cost to Cadburys in the future.

2.1.5 Building Energy Management System (BEMS)

Cadburys are at present at the proposal stage for installing a BEMS. All space and domestic hot water heating systems should be connected to the BEMS. Based on the annual gas consumption as shown in Appendix A improved control through the installation of a BEMS system should reduce this cost of the Office heating by at least 20%, resulting in a saving of Euro 5,570 per annum. A similar level of saving can be achieved for the Thurley and Reznor space heating units if they are connected to the BEMS. For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:39 2.1.6 Monitoring Boiler Operation

As part of the Micro-CHP study in 2002 hour run meters were installed on a number of boilers in B and K Blocks. Since their installation 14,780 hours had elapsed before they were read again for this study and updated as part of this study as shown below

Boiler B5 B4 B3 B2 B1 K1 K3 No. % Time 3.77 27.12 23.01 57.20 6.36 30.69 34.99 on

These simple low cost meters illustrated the percentage of time the boilers have operated since 2002. It helps raise the following question. Why are five boiler required to meeting the process heating load in B Block? This heating demand could be easily met with fewer of these boilers. The heating circuits could be modified to be supplied by 2/3 boilers. The advantages are as follows;

• Boiler maintenance cost will be reduces as there will be fewer boiler to maintained. • The removed boilers will provide spare boilers and spare parts and reduce the short term requirement for a boiler replacement budget.

For inspection purposes only. • The boiler will operatConsente near ofer copyright to their owner requireddesign for eanyd otherload use. and therefore their thermal

efficiency will improve. • The hours run is an indication of the system heating demand and can be used to better size replacement boiler and hence reduce capital cost. • Boiler more accurate sized to the heating demand will reduce their energy cost.

Therefore in order to gain better information on the operation pattern of all the boilers it is recommended that hour run meters similar to those already installed be fitted to all the boilers including the Thurley heaters and Office boilers.

EPA Export 25-07-2013:20:50:39 2.2 Conclusions

The following are the main conclusions from the report;

1. It is recommended that the maintenance of the process/space/domestic hot water boilers be contracted out to a specialist boiler service agent. He should also address any outstanding safety issues as outlined in the H.A. O’Neill’s study. The boiler service agent should be giving the responsibility of recording, documenting and reporting to the Facility Manager on all work done.

2. Finance will need to be made available for the Thurley heaters to be replaced. They should be replaced by an air re-circulation type heater and controlled through the proposed Building Energy Management System (BEMS).

3. The estimated capital cost of a proposed new steam system is Euro 2,651,961 with an annual operating cost of Euro 106,302. Compared to the cost of Euro 23,000 to maintain the existing system it therefore makes no economic sense to install a steam system.

4. A Wind Turbine is the most economical option for Cadbury Ireland in trying to

For inspection purposes only. reduce their energy costConsent and of copyrightproviding owner requiredsome for security any other use. in energy supply. Cadburys

should apply to SEI for a grant to undertake a feasibility study on wind generation with the view of installing a system in either Dublin or Rathmore with the objective of receiving a grant support towards the capital cost of installing a wind turbine.

5. SEI is to announce in the near future a Bio-Heat Boiler Deployment Programme. Although on a fuel cost basis it is not economical to install a boi-heat boiler, this would be an ideal opportunity for Cadburys to utilise the grant support from SEI to install a bio-heat boiler in the office area as a pilot project to monitor it performance and to provide Cadburys with required information should they need

EPA Export 25-07-2013:20:50:39 to switch all their boilers to bio-fuel in the future in the advent of a significant increase in both natural gas cost and carbon emission charges.

6. Cadburys Ireland should re-consider the installation of a micro CHP system as outlined in the 2004 study when SEI launches their CHP grant support programme. It is assumed as Cadburys have already undertaken a CHP feasibility study under the SEI programme they would now be in a very good position to receive financial support from SEI.

7. The proposed new Building Energy Management System should be used to control both the office and factory space and domestic hot water heating systems.

8. Hour run meters should be installed on all boiler/heaters to provide information on their maintenance requirements and energy usage.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:39 3.0 Review of the current installation in terms of the number of boilers, their rating, location, control strategy, safety, reliability, and efficiency

3.1 Hot Water Boiler Overview - Current Installation

Beside the two main steam boilers, there are 102 individual boilers/heaters which provide process heating, space heating and domestic hot water. A list of all the boilers/heaters is contained in Appendix C. These boilers range in size from small domestic type gas boilers to medium/large commercial gas boilers. The Process heating boilers are installed to provide heat to a specific area of the plant, i.e. tank and jacket heating and are provided with an electrical emersion back-up system. The space heating is provided by a mix of wall mounted/ceiling hung/free standing gas fired indirect air heaters. This includes the thirteen Thurley free standing space heating units which are mounted on the roofs of A, B & C Block. The Thurley heaters output range from 219 kW to 512 kW. Space heating in the main administration office block is provided by 5 hot water boilers which service a radiator system. The boilers are rated at 227 kW. Domestic hot water for both the factory and offices are provided by gas fired storage boilers such as the AO Smith and Potterton boilers.

For inspection purposes only. 3.2 Boiler Survey Consent of copyright owner required for any other use.

Cadburys recently commissioned HA O’Neill’s to undertake a study of the hot water boilers/heaters. The survey assessed the condition of the boilers under the following 14 headings;

1 Flue (Physical condition) 2 Flue (Operation) 3 Flame Status 4 Flame Failure Device 5 Ventilation 6 Temperature Control Thermostat

EPA Export 25-07-2013:20:50:39 7 Temperature Control High Limit 8 Gas Train 9 General Wiring Condition 10 General Boiler Condition 11 Soundness of Gas Pipe Work 12 Flue Gas Combustion Check 13 Internal Condition of Boiler Casing 14 Maintenance Records

The survey included a section which made comments on action required. Appendix D contains a sample survey sheet. A copy of the report is available on file.

3.3 Boilers Reliability

For inspection purposes only. All manages agreed within reaConsentson ofth copyrightat the ownercurren requiredt system for any other is use. very reliable and has caused

very little problems from the point of view of system availability and reliability.

In term of criticality the process boilers have the highest level due to their association with the manufacturing of chocolate. Most of theses boiler operate between a temperature of 400C to 500C and have a back-up electrical emersion heater rated at 9 kW should a boiler fail to operate. The emersion heaters are not designed to heat the product up from cold but rather to help maintain operating conditions until the boiler problem can be fixed.

Most boiler problems which have occurred in the past have been adequately dealt with by the maintenance staff within each Block. If a failure cannot be solved by Cadburys

EPA Export 25-07-2013:20:50:39 maintenance staff then expertise assistance is sought through a boiler service agent supplied by HA O’ Neill’s.

There was a general consensus that the boilers would benefit from an annual service which should include the following;

• A record of the work done and this information should be documented so details and history of the condition of the boiler are on file.

• The service should include the testing of the associated back-up electrical emersion system and all ancillary equipment such as the pressurised hot water heating system.

A problem which can occur is should a boiler fail to ignite and the back-up emersion operates there may be no indication this has occurred. K Block has installed an alarm system to indicate such a fault. In some case this problem may go on unnoticed by the operator especially if the back-up emersion is capable of maintaining the heating demand. Consideration should be given to the installing a local alarm system for all process heating boilers similar to the system used in K Block. This is quite a simple but effective For inspection purposes only. system. Consent of copyright owner required for any other use.

With regards to boilers safety this has been addressed by the HA O’Neill survey but there still is a need to periodically check the installation for leaks. Cadburys have an extensive metering system, but it is unlikely to detect any minor leaks. Gas leak detection is an option for the boiler house locations but not for any boiler located in the main factory. Therefore it is recommended that a quarterly inspection be undertaken by the Cadburys maintenance staff to check the soundness of the gas installation in each block. Gas leak detection should be installed in all boiler houses.

EPA Export 25-07-2013:20:50:39 3.4 Boiler Efficiency

The HA O’Neill’s survey made the recommendations to checking the combustion efficiency and this should form part of the annual service and reported on. The office boilers are serviced annually. The main problem with the office boiler is the lack of control. A Building Energy Management System (BEMS) is to be installed in the near future and the office boiler should be included in the control system specification. Similarly the factory space heating should be controlled by the BEMS.

Appendix A shows from the gas metering system that the offices consumed 831,168 kWh per annum (2.26% of total gas usage) at a cost of Euro 27,844. Improved control through the installation of a BEMS system should reduce this cost by at least 20%, resulting in a saving of Euro 5,570 per annum.

Part of the space heating in A, B & C blocks are provided by 13 Thurley space heating units. These are discussed in section 3.7

3.5 Boiler Call-Out Maintenance & Boiler Longevity

For inspection purposes only. From a discussion with TriadenConsentt Heating of copyright (ownersub- requiredcontrac for anyted other by use. HA O’Neill’s in relation to boiler call-outs) the following was noted:

On average Triadent Heating would undertake 10-20 breakdown calls per annum (Trident Heating are only contacted if Cadbury maintenance staff can not resolve the problem). One problem noted and also recorded during the H.A. O’Neill’s survey is the lack of maintenance records. This makes it very difficult to determine what level of work has been undertaken in the past.

The typical life of a small commercial/industrial gas boiler of the type installed is approximately 20 heating seasons. From the discussion with Cadburys managers the typical life of most of the process boilers is 10 years This is more of less equivalent to 20

EPA Export 25-07-2013:20:50:39 heating seasons as the process boiler operate continuously. Most of the process boiler have been replaced at least once since there initial installation in the 1980’s. Therefore budgetary considerations need to be made for the replacement of process boiler and form costing provided by HA O’Neill’s they recommend that a budget of Euro 5,000 per annual should be set aside for this.

The space heating boilers such as the Reznor and Thurley units are approximately 20 years old. Due to their age, getting spare part for them can be difficult and also to-days technology is different. For example for safety reasons the Reznor requires a more details inspection to check if a pressure switch is incorporated into the fan unit should it fail. In some case it may be more economical to replace such heaters. The Thurley heaters are discussed in Section 3.7.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:39 3.6 Boiler Operation, Maintenance and Safety

Appendix B shows there are 102 boilers/heaters having a total installed capacity of 11,435 kW, which provided process heating, space heating and domestic hot water. Theses can be broken down as follows;

Boiler Application No. off Installed Capacity kW

Domestic Hot Water Boilers 9 586 Process Boilers 31 1,798 Space Heating 62 9,051

Total 102 11,435

Of the 62 space heating boilers, 13 of them are Thurley heaters and were not part of the H A O’Neill’s survey. These are installed on the roofs of A, B and C blocks and have a combined rating of 6,075 kW, which equates to 53% of the total installed capacity of all these boilers.

For inspection purposes only. In order to simplify and summariseConsent of the copyright boilers owner requiredcondition for any other and use. provided this information in a concise format the 14 items as inspected in the HA O’Neill’s survey have been categorised under the following seven headings and listed in table 1,

1. Design; Where the inspection has indicated a need to improve the initial design in terms of type of equipment installed. 2. Efficiency; Where the inspection indicates that the efficiency of the unit needs to be checked. 3. Installation; Where the inspection indicates a problem with the installation of the boiler or system. 4. Operation; Where the inspection indicates a problem relating to the how the boiler is operating.

EPA Export 25-07-2013:20:50:39 5. Physical; Where the inspection indicated some structural damage to the boiler or system. 6. Safety; Where the inspection indicated a need to improve the safety features of the boiler, installation and/or system. 7. Records; Where the inspection identified the need to improve the level of documentation and records kept on the maintenance and operation of the boilers.

Table 1 Categorising of Items from H.A. O’Neill’s Boiler Inspection

No. Category Item 1 Flue (Physical condition) Physical 2 Flue (Operation) Operational 3 Flame Status Operational 4 Flame Failure Device Safety 5 Ventilation Design 6 Temperature Control Thermostat Operational 7 Temperature Control High Limit Safety 8 Gas Train Design For inspection purposes only. 9 General WConsentiring of Conditio copyright ownern required for any other use. Installation

10 General Boiler Condition Physical 11 Soundness of Gas Pipe Work Safety 12 Flue Gas Combustion Check Efficiency 13 Internal Condition of Boiler Casing Efficiency 14 Maintenance Records Records

EPA Export 25-07-2013:20:50:39 The categories in table 1 can be summarised as follows;

• Design consideration mainly refers to the need to improve ventilation level or to modify the gas train.

• Efficiency, this refers to nearly all boiler and it a requirement to check the boiler combustion efficiency and ensure the boiler is cleaned to maintain boiler efficiency and can be undertaken as part of a preventive maintenance plan

• Physical; This mainly refers to the condition of the boiler and may require some repair work to boiler.

• Installation; This mainly refers to the wiring and flue condition of the boiler.

• Operation, This mainly refers to the flue and the flame condition, but there are a few problems associated with the flame failure device which need to be repaired in the short term.

• Safety; This mainly refers to leaks which have now been repaired, and the high For inspection purposes only. limit temperature controConsentl. In of copyrightmany ownerinstance required itfor anyjust other need use. to be checked to ensure it

is operating as designed, but there are a few case where there is concern about it wiring and these need to be inspected in the short term.

• Maintenance record keeping is very poor and there is no information on previous work undertaken. This need to be rectified.

• Records; The inspection outlined that recording keeping and documentation is very poor which makes it very difficult to knowing what level of work has been undertaken in the past.

EPA Export 25-07-2013:20:50:39 Table 2 summarises the boilers/heaters condition under it location, boiler manufacture, boiler/heater function, rating, age (where details were available from the name plate) and condition. It identifies the main problem category by an “X” depending on which item was identified from the H.A. O’Neill’s survey. These items can be categorised as follows;

Design 36% Efficiency 80% Physical 20% Installation 10% Operation 27% Safety 57% Records 81%

The main areas identified in table 2 which indicated there is a problem are under the heading efficiency, safety and records. These can be addressed as follows;

• Efficiency: The HA O’Neill’s reports outlined the need to check the boiler combustion efficiency. This can very easily be done as part of the boiler annual service but it needs to be recorded and reported to management.

For inspection purposes only. Consent of copyright owner required for any other use.

• Safety: In some case the HA O’Neill’s report outlined the need to check the flame failure device. This can be done as part of the annual service and if required checked every quarterly by Cadburys maintenance staff. The report also outlined some other safety areas which need to be checked regarding the fans on the Reznor heaters. Any problems related to gas leaks have now been repaired but as outlined in section 3.3 gas leak detection should be undertaken at least quarterly by Cadburys maintenance staff.

• Records. As outlined below the service agent should be giving the responsibility of recording, documenting and reporting to the Facility Manager on all work done.

EPA Export 25-07-2013:20:50:39

In general the conditions of the boilers/heaters are in reasonable good condition. There are a number of outstanding safety issues that need to be addressed. To ensure the continued availability, reliability, safety and efficiency of theses boilers/heaters they need to be put on a preventive maintenance schedule. It is recommended that this should be contracted out to a specialist boiler service agent who should also address any outstanding safety issues as outlined in the H.A. O’Neill’s study. The service agent should be giving the responsibility of recording, documenting and reporting to the Facility Manager on all work done.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:39 3.7 Thurley Heaters

3.7.1 Overview of the Thurley Heaters Maintenance, Operating and Efficiency

There are thirteen Thurley free standing space heating units which are mounted on the roof of A, B & C Block Their output ranging from 219 kW to 512 kW. Unit No B3 is no longer in use. Theses heaters operate with no recirculation of air, i.e. on full fresh air, and therefore are always heating up the supply air based on the outside ambient air temperature.

In 2005 all theses units were serviced and a copy of the service report together with the list of each unit reference number, model details and heat input is included in appendix E. Beside the preventive maintenance undertake the report also outline a number of faults which required extra maintenance work. (See appendix E). The report also made comments as follows;

• There is a need to paint, provide rust protection and sealing; and that two units have severe corrosion problems.

For inspection purposes only. • That the control systemConsent is not of copyright operating owner required corre forctly any other and use. there is a potential to reduce

gas consumption. It outlines that the set point temperature is too high, the gas burner modulating control system is not operating correctly and with a better energy management control system there is a potential to reduce gas consumption by 21%.

• The report finally concludes that there is a new range of heater which utilise re- circulation air, which will reduce energy costs.

EPA Export 25-07-2013:20:50:39 3.7.2 Strategy to Reduce Thurley Energy Costs

Mr. Howard Davies’s of Nordair was contacted in relation to the replacement cost of the Thurley Heaters. Details of the current units were e-mail to him and Nordair supplied information on heater replacement cost, improved efficiency through air re-circulation units and improved management control. He also outlined that the life expectancy of external units are approximately 15 years, with the internal units having a maximum of 20 years. Nordair are also of the opinion that the original units were oversized, which means that on a like for like replacement they would expect a 25% saving with a further 25% saving expected with the use of re-circ air flow control i.e. a total of 50% reduction in energy costs.

The potential savings are difficult to calculate as the Thurley heaters are all on different gas meters but based on the information in appendix A which shows that “Thurley A” uses is 0.24% of the total gas consumption and applying this on a pro-rata bases to the other units then the estimate consumption of all the Thurley heaters is 758,995 kWh per annum (2.16% of the total) as shown in table 3. Based on the manufacture quotes efficiency improvements of 50% this would result in an annual saving of Euro 12,713 with an average pay back of 13 years.

For inspection purposes only. Consent of copyright owner required for any other use.

It should be noted that the estimated annual consumption of the Thurley heaters seems very low when compared to the rating of the units. It may be the case that the units do not operated that frequently. The gas metering system is not capable of measuring individual units as it would be too costly to install a separate meter for every gas consuming plant item. Therefore it is recommended that an hour run meter be installed on each unit to monitor it total hours of operation over a period of time. This simple low cost measure will help to provide more information on the units operating cost, and hence provide a better indication on the energy saving potential of the proposed new units and also provide information on the hours operated for maintenance purpose.

EPA Export 25-07-2013:20:50:39 The Thurley heaters are on average 21 years old and they will need to be replaced in the near future. Therefore finance will need to be made available for their replacement. When the heater are being replaced they should be replaced with the re-circulated air type and controlled through the BEMS so they can be time scheduled and also take into consideration the outside and inside ambient temperature so as to reduce their energy cost. Table 3 Thurley Heaters Operating and Replacement Costs

Simple Heat Replace1 Pay Model Input Use Year of Alternative Cost Saving Back Ref No. No Ser. No kW kWh Manuf. Unit Euro Euro Years A1 DW127E 84/351 586 80,455 84 DF11 17,500 1,348 13 Canteen DW118E 84/353 218 15,404 84 DF4 9,500 258 37 B2 DW124E 85/380 512 70,295 85 DF9 14,500 1,177 12 B4 DW124E 85/382 512 70,295 85 DF9 14,500 1,177 12 C1 DW121E 85/425 293 40,228 85 DF4 10,500 674 16 C3 DW124E 85/385 512 70,295 85 DF9 14,500 1,177 12 C5 DW127E 83/386 659 90,478 83 DF11 17,500 1,515 12 A2 DW127E 84/352 586 80,455 84 DF11 17,500 1,348 13 B1 DW124E 85/381 439 60,273 85 DF9 14,500 1,010 14 PMS DW124E 85/379 512 70,295 85 DF9 14,500 1,177 12 C2 DW115E 85/383 219 30,068 85 DF4 9,500 504 19 C4 DW127E 85/384 586 80,455 85 DF11 17,500 1,348 13 Total 758,995 172,000 12,713 14 % of Total 2.16 Cost = 25,426

1 The prices for full fresh air unit is abou t 15% For inspection less than purposes the in only.dicated price of the re-cir units. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:39 3.8 Cost of Maintaining Boilers/Heaters

No preventive maintenance contract or planned maintenance system exist at present for the hot water boilers/heaters other than the annual servicing of the Thurley units and the office boilers. One of the main finding from the meeting with the managers of each Block was that the boiler would benefit from an annual service. This would also be beneficially from a safety perspective as the boilers safety system would be inspected and ensured that they are operating correctly.

In order to provide a cost for an annual servicing of these boilers three quotes were sought from boiler service agents. Details of the quotes are included in appendix F. The lowest cost quote was from Ashwood Heating at Euro 10,000 per annum.

The HA O’Neill survey also identified other remedial work which needs to be undertaken to bring the units up to a satisfactory operating standard. It can be assumed that there will be a need for some extra work each year plus the cost of spares part. It is estimated that this an extra work will increases the annual maintenance of the boiler by Euro 8,000. On top of this there is the cost of periodically replacing boilers. This has been estimated at Euro 5,000 per annum by HA O’Neill’s. Therefore the cost for an annual boiler/heater

For inspection purposes only. servicing is set at Euro 23,000.Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:39 4.0 Evaluate the Cost of supplying hot water for process, space heating and domestic hot water using Steam

4.1 Introduction

Cadburys UK use similar type of process, space and domestic hot water heating systems but use steam as the heating medium. Taking into consideration the age of the current system, i.e. many of the boilers/heaters are 20 year old this provides an ideal opportunity to evaluate the benefits of replacing the existing system with a steam heating system.

4.2 Outlining the Size of the Steam System

Taking into consideration that there is a total of 102 boilers this will require a comprehensive steam distribution system. Whether all the boilers/heaters should be supplied by the steam is debatable, but for the sake of this evaluation it was decided to exclude the 13 Thurley space heating units. This is because these units are quite large and account for 53% of the installed capacity of all the process/space/domestic hot water boilers. This would significantly increase the size of the steam boiler required and also taking into account the seasonal use of theses units for space heating only this would

significantly increase the steam boiler For inspection loadi purposesng losses only. in the summer time. Also direct Consent of copyright owner required for any other use. fired heating reduces the heat transfer stages and also eliminates the need for a steam distribution system and its associated losses.

The 6 offices boilers are not include in the steam system due to the difficulty of piping steam from the main building to the office block.

EPA Export 25-07-2013:20:50:39 Therefore this leaves a total of 83 boiler/heaters which can be considered to be supplied by the steam system as follows;

• DHW = 9 Boilers • Process = 31 Boilers • Space Heating = 43 Boilers/heaters

• Total = 83 Boilers/heaters

In order to get costing on the installation of a steam system to provide the heating for the 83 boilers/heaters a quotes for the installation and the supply of equipment where requested from various suppliers under the areas of generation, distribution and utilisation as follows.

4.3 Existing Steam Generation System

Steam is currently generated at 12.5 bar gauge in a central boiler house by two gas fired smoke tube boilers. The boiler details and nominal rating are as follows,

For inspection purposes only. 0 Boiler No. Manufacture Consent of copyrightCapacity owner required (F&A for any100 otherC use.)

1 Danks 13,605 kg/hr 2 Babcock 18,080 kg/hr

Total 31,685 kg/hr (31.7 Tonne/hr)

The boilers have been down rated to 9,070 kg/hr, giving a combined total output of 18,140 kg/hr (18.14 Tonne/hr). Boiler No.1 is the main boiler and is on line for 95% of the time with boiler No.2 on hot stand-by. The natural gas usage in appendix A shows an annual usage of 58,720 m3. This equates to an average steam demand of 2,266 kg/hr.

EPA Export 25-07-2013:20:50:39 4.3.1 Proposed New Steam Generation System.

Appendix G outlines a proposed steam distribution system to supply the current process/space heating demand. The equivalent steam demand of the process/space heating demand was calculated at approximately 5,525 kg/hr. By making an allowance of 20% for boiler and system losses this is equated to a steam demand of 6,630 kg/hr.

Taking into account the existing average steam demand of 2,266 kg/hr and the proposed new steam demand of 6,630 kg/hr, this equates to a total steam demand of 8,896 kg/hr. As these are based on average values, i.e. there would be instance where the instantaneously demand exceeded this figure and with a boiler rated at 9,070 kg/hr, there will be times this would be exceeded. This would mean the stand-by boiler would need to operate more frequently. Taking into consideration the age of the stand-by boiler it was decided to include the cost of a new steam boiler in the assessment of the cost of supplying the process/space heating demands with steam. This is also this essential for plant availability and reliability.

KB Combustion were contacted and requested to provide a quote for supply and installing a steam boiler to meet the process/space heating demand. Two quotes were

For inspection purposes only. received as follows; Consent of copyright owner required for any other use.

Quote 1 Danstoker TDC No. 10 Steam Boiler rated @ 7,500 kg/hr

Boiler Cost Euro 113,115 Economiser Euro 10,810 Chimney Euro 19,800 Pipwork Euro 22,000 Commissioning Euro 3,000 Delivery Euro 3,000

Total Cost Euro 171,725

EPA Export 25-07-2013:20:50:40 Quote 2 Danstoker TDC No. 6 Steam Boiler rated @ 3,150 kg/hr

Boiler Cost Euro 75,794 Economiser Euro 7,485 Chimney Euro 14,700 Pipework Euro 20,000 Commissioning Euro 2,500 Delivery Euro 2,500

Total Cost Euro 122,979

There is just about sufficient capacity from boiler No.1 to provide the extra steam demand for the process/space heating demand and as outlined above but there is some reservation on the reliability of the boiler No.2 due to its age. Therefore for the purposes of the study a second quote for the smaller boiler was requested as Boiler No.1 could act as the main boiler with the smaller boiler acting as back up.

For the purpose of the study the quote for the larger steam boiler is taken of Euro 171,725 is used as the difference in cost is not significant in relation to ensuring sufficient steam

For inspection purposes only. and plant reliability. AppendixConsent H contains of copyright ownera copy required of for the any otherKB use. Combustion quotes.

4.4 Steam Distribution System

HA O’Neill’s has been contracted to work for Cadburys Ireland over the last 30 year in the area of new installations and maintenance. They are currently contracted to maintenance the existing steam distribution system.

HA O’ Neill’s provided a quote to install a new steam distribution system based on information provided in appendix G. This information is based on the location of the

EPA Export 25-07-2013:20:50:40 process/space heating/domestic hot water boiler as outlined in Drawing No. 18206. This drawn is on file.

Supply & install steam & condensate pipework to all blocks 982,500

Approx. 100 no. trapping sets c/w valve arrangements etc. 80,000

Local isolating valves and drain points 38,000

Insulation 315,000

Scaffolding & safety requirements. 75,000

Radiography 10,000

Prelims (Staff salaries, supervision etc. ) 200,000

Block divert valves. 15,000

Total Cost Euro 1,715,500

Note: Not included in the above cost is the methodology for installing such a big project during production at the factory and any necessary civil works. Appendix H contains a copy of the quote.

For inspection purposes only. Consent of copyright owner required for any other use. 4.5 Steam Utilisation

4.5.1 Process Heating Boilers

Table 2 outlines the boiler kilowatt rating for each process application. There are a total of 31 process heating boilers. Bases on the heating requirements as outlined in table 2 the following was decided;

The option selected to replace the process hot water boilers is to use a steam to water plate heat exchangers. Spirax Sarco provided a quote for a 60 kW and a 80 kW plate heat exchanger. The cost included all steam/hot water controls and steam trapping sets.

EPA Export 25-07-2013:20:50:40 • For the 80kW and above: Model EH-1H-ST-DHW-EL-1-HL-VS at a cost of €21k (Pneumatic actuated) or €26.5k (Electric actuates). This is an assembled unit complete with Primary Isolation, High Limit, Control and including Panel, Plate Heat Exchanger and Steam trap. The unit will work with steam up to 8 bar gauge. For anything above this a Pressure Reducing Station would have to be added. This would add about €2k to the price - the gaskets would be changed from Heat Seal F to EPDM.

• For the unit 60 kW and below we would have to put together a bespoke system and this would cost approx €15k - €18k.

For the purpose of the study the following units were selected;

• 8 of 80 kW rating @ Euro 21,000 = Euro 168,000 • 23 of 60 kW rating @ Euro 15,00 = Euro 345,000

The total cost of replacing the process heating boilers with steam to water plate heat exchangers is Euro 513,000.

For inspection purposes only. 4.5.2 Space Heating Units Consent of copyright owner required for any other use.

The option of replacing the existing space heating system depends on the existing system in use. These can be broadly classified as flue gas heaters, i.e. the Reznors and hot water boilers. The options are to replace the Reznor type heaters is with Steam Unit Heaters and the hot water boiler with plate heat exchangers similar to the process application.

Steam space heaters are available in size range of 20 or 30 kW rating. Based on the information in appendix C the following number of heaters were selected;

• 18 off 30 kW Steam Unit Heaters • 59 off 20 kW Steam Unit Heaters

EPA Export 25-07-2013:20:50:40 BSS Ireland, (British Steam Specialist), were contacted and asked to quote on the cost of supplying the above heaters. The total cost for each unit, including all isolating valves, steam trapping sets and pressure reducing valves is shown in table 4.

Table 4 Cost of Space Heating Equipment

Item No required Cost Euro

20 kW heater 59 62,245 30 kW Heater 18 21,006 Isolating Valves 231 4,075 Strainers 77 1,140 Traps 77 13,321 Sight Glass 77 4,081 PRV 77 22,869

Total Cost 128,736

For inspection purposes only. Consent of copyright owner required for any other use. 4.5.3 Domestic Hot Water Boilers

There are 8 domestic hot water boilers with output at or above 60 kW. Using the costing as supplied by Spirax Sacro for the 60 kW steam to water plate heat exchangers this equates to a total cost of Euro 120,000.

EPA Export 25-07-2013:20:50:40 4.5.4 Summary of Steam Utilisation Cost

The total cost of steam utilisation equipment is as follows;

Process Plate hat Exchangers Euro 513,000 Space Heating Euro 128,736 Domestic Hot Water Euro 120,000

Total Cost Euro 761,736

4.6. Steam System Maintenance Cost

4.6.1 Boiler Operating & Maintenance

Form information supplied by Cadburys the current cost of operating and maintaining the steam boilers is as follows;

Steam Boiler Annual Operating Cost Euro 60,000

For inspection purposes only. Steam Boiler Annual MaintenanceConsent ofCost copyright owner required forEuro any other 20,000 use.

Steam Boiler Water Treatment Cost Euro 15,000

Total Cost Euro Euro 95,000

Most of the cost of operating a new boiler would be absorbed in the above costs, but there will still be a requirement for boiler water treatment and annual maintenance. Therefore for the purpose of the study this is estimated at Euro 20,000 per annum.

EPA Export 25-07-2013:20:50:40 4.6.2. Steam Distribution Maintenance Cost

The cost of maintenance on the steam distribution system is mainly due to repair of leaks, replacing failed/faulty steam traps, repair and replace of pressure reducing valves, safety valves and control valves. It would be expected that this cost will increase with the age of the system. How well the system is designed and the installed has a bearing on the longevity of the distribution system and consideration given to installing line drain traps, cleaning strainers, pipe properly supported all contribute to system longevity.

The current steam distribution system is approximately 20 years old. For the purpose of the study it is estimated that the annual maintenance cost of the new system is Euro 5,000.

4.7 Boiler Energy Costs

The Cadburys energy monitoring system allows a reasonable accurate account of the annual gas usage to be broken between the steam boiler, ovens and space/process heating boilers as shown in appendix A.

For inspection purposes only. The energy cost of operatingConsent the ofproposed copyright owner new required steam for any other boiler use. is difficult to accurately evaluate but the following assumptions are made,

• As the boiler will be operating at a much high temperature, i.e. steam pressure of 10 bar absolute has a saturation temperature of 1900C, compared to the process boilers which operate with an average water flow temperature of 45 deg.c and the space heating boiler and domestic hot water boiler at an average temperature of 70 deg.c, and therefore the steam boiler radiant heat losses will be greater,

• The boiler loading losses will be greater. Loading losses are due to the boiler convectional losses through the boiler flue ways when the boiler is not on load. (These can be reduced by installing a flue damper). There are loading losses on all the individual

EPA Export 25-07-2013:20:50:40 boiler, and the case could be made that the sum of all theses boiler could be in the same region as the steam boilers, but taking into consideration the lower operation temperature of these boilers/heaters it is assumed that the total losses will be higher for the steam boiler.

• Not mater how well a steam/condensate system is designed it will occur losses through leaks and failed steam traps. There will also be boiler losses due to boiler blowdown, testing of boiler controls and flash steam losses at boiler feed tank and condensate tanks.

• Even though the steam/condensate system will be insulated losses will still occur due to the higher operating temperature.

As outlined above the losses from the steam system will most likely be greater than the current system and this can increased significantly with time if the system is not properly maintained. To take this into account the current annual operating cost of the hot water boilers has been increased by 10% to allow for these losses. Previous study by the author on steam system has identified much higher losses.

For inspection purposes only. Appendix A shows the usage Consentof natural of copyright gas owner for required 2005 for anyin other providing use. process/space heating

was 851, 888 m3 ( 9,413, 365 kWh). If the Office, Thurley heaters and Centra usage are subtracted from this total then this equates to 24,269,236 kWh consumption for the Process/Space/Domestic Hot Water heating use. This equates to an annual cost of Euro 813,019. The extra 10% cost of providing this heat by steam is estimated at Euro 81,302.

EPA Export 25-07-2013:20:50:40 4.8 Total Cost of New Steam System

The total cost of a new steam distribution is made up of the following

New Boiler Capital & Installation Costs Euro 171,725 Steam Distribution Capital & Installation Costs Euro 1,715,500 Steam Equipment Costs Euro 764,736

Capital Cost Euro 2,651,961

Annual Boiler Maintenance Costs Euro 20,000 Annual Maintenance of Steam Distribution Systems Euro 5,000 Annual Fuel Cost Euro 81,302

Annual Operating Cost Euro 106,302 4.9 Steam System vs. Hot Water Heating System

Section 4.8 shows the capital cost of installing a steam system is Euro 2,651,961 with an annual operating cost of Euro 106,302 (neglecting any price increases over time)

For inspection purposes only. Consent of copyright owner required for any other use.

Section 3.8 outlined an annual cost of Euro 23,000 (neglecting any price increase over time) to maintain the existing process/space heating/domestic hot water boiler system. This cost is really insignificant when compared to the cost of installing a new steam system to provide the process/space/domestic hot water requirement. Further more the annual operating and maintenance cost of the proposed steam system is approximately 4 times the estimated cost of maintaining the existing system. Therefore there is no financial justification in replacing the existing system with a steam heating system.

The report had tried within reason the get an accurate cost of installing a steam system. Even taking into consideration any errors in the costs as received the difference in both the capital and annual running cost towards the proposed cost of an annual maintenance

EPA Export 25-07-2013:20:50:40 programme makes the proposed new steam system prohibit even if the proposed cost of the annual maintenance system was to double in cost. It should be noted that the proposed steam system cost does not include any civil works or the methodology for installing such a big project during production at the factory which would increase its costs even further.

The analysis shows that at a very reasonable cost the reliability, availability, safety and efficiency of the process/space heating/domestic hot water boiler can be maintained into the future by putting into place a preventive maintenance programme for these boilers and their associated equipment.

The proposed capital cost of the steam system was very significant at Euro 2.65 million. The next section of this report investigates the options which Cadburys Ireland could consider to reduce it reliance on imported fuels. The availability of a capital budget even 50% of the proposed cost of the steam system would provide Cadburys Ireland which a significant funds to help reduce their reliance on imported fuel, reduce their energy cost base and provide a frame work to be in a better position to counteract any possible carbon charges in the future.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:40 5.0 Cadburys Future Energy Strategy

5.1 Ireland Vulnerable to the Energy Crisis

Appendix I contains a response from IBEC in response to a new EU Green Paper on Energy Policy. It outlines that Ireland is very vulnerable to any future energy crises. It goes on to state that Ireland must become more self sufficient and broaden it fuel mix. It outlines that since 2001 electricity and gas tariffs to business have increased by 60% and 100% respectively.

Although such statements at time may be seen as scare monger some consideration need to be given to them. Cadburys Ireland is very much reliant on the electricity and gas market and any significant change in their supply and cost will affect their operating profits.

Numerous television and radio programmes, newspaper articles have discussed the problem of global warming and the impact it could have on countries economies. The growth in developing countries such as China and India with their high populations will compound this problem. In their statement IBEC states that Ireland must “become more

For inspection purposes only. self sufficient and broaden it fuelConsent m ofi copyrightx”, and owner this required can for be any appliedother use. to Cadburys Ireland. The following sections outlines some of the options which Cadburys Ireland should consider to reduce it reliance on imported fuel used in the generation of electricity and the supply of thermal energy to its manufacturing plant.

5.2 Wind Power

The amount of electricity generated by a wind farm depends on its power output and on the annual number of full load operating hours. Depending on the wind speed this is generally between 2,500 and 3,500 hours per annum in Ireland.

EPA Export 25-07-2013:20:50:40 There is no fuel costs associated with the generating electricity by wind turbines. Once the project has been paid for, the only ongoing expenses are for operation and maintenance costs. The capital cost is usually between 75 % and 90 % of the total cost.

5.2.1 Introduction Wind Farms in Ireland

At present there are approximately 40 on shore and one off shore wind farms in Ireland. All bar the installation at Dundalk Institute of Technology (DKIT) are commercial sites, i.e. selling power to the national grid.

The Dundalk study was granted aid by SEI under their Public Sector Programme. The

For inspection purposes only. feasibility study for their 850 kWConsent wi of ndcopyright turb ownerine requiredshown for anythe other followi use. ng financial details;

Simple Pay back 8.1 years (no grant) 5.0 years (with grant) IIR 3% (no grant) 18.3% (with grant)

5.2.2 The Potential Energy Saving by Installing a Wind Turbine

Appendix J shows the 2005 electrical energy usage for week 52.Week 52 is Christmas week and there is no manufacturing undertaken in the plant. Cadburys had a total power consumption of 205,047 kWh in that week. This equates to an average demand of 1,220 kW. Assuming a wind turbine was installed to supply the base load only, i.e. an 850 kW

EPA Export 25-07-2013:20:50:40 wind turbine (Similar to DKIT as cost on installation is available) and exporting no electricity to the national grid.

Table 5 shows the cost of an 850 kW turbine. It is based on information from the Sustainable Energy Ireland web site on the breakdown for a 5 MW wind farm at €5.5 million. Applying this data to an 850 kW wind turbine on a pro rate bases this equates to a cost of €1.199 million for an 850 kW wind turbine. This is approximately 50% less than the cost of installing the proposed steam system with a lower future energy cost.

Table 5 Estimated Cost of an 850 kW Wind Turbine Project Areas % of Cost Cost Euro * 1000 for Cost Euro *1000 for 5.5 MW Turbine 0.85 MW Turbine Wind Turbine 64 3.52 0.816 Civil Works 13 0.72 0.166 Electrical Infrastructure 8 0.44 0.102 Grid Connection 6 0.33 0.000 Project Management 1 0.06 0.013 Installation 1 0.06 0.013 Insurance 1 0.06 0.013 Legal Costs 2 0.11 0.026 Bank Fees 1 For inspection purposes only. Consent of copyright owner required0. for06 any other use. 0.013 Construction Interest 2 0.11 0.026 Development Costs 1 0.06 0.013 Total 100 5.50 1.199

Table 6 shows the simple pay back based on the project cost for an 850 kW turbine. It shows the simple pay back based on the minimum to maximum full load hours of operation of 2,000 to 3,000 and using the current average cost of electricity of 8.5 c/kWh. It also shows the effect of a price increase in electricity costs on the simple payback.

EPA Export 25-07-2013:20:50:40 Table 6 Wind Turbine Simple pay Back under various operating load and Electricity costs including 10% Grant

Simple Simple Payback Rating Electricity Payback years with 10% kW Hours full load cost c/kWh Savings years grant 300 2000 8.5 144,500 8.3 7.5 300 2500 8.5 180,625 6.6 6.0 300 3000 8.5 216,750 5.5 5.0 300 2000 9 153,000 7.8 7.1 300 2500 9 191,250 6.3 5.6 300 3000 9 229,500 5.2 4.7 300 2000 10 170,000 7.1 6.3 300 2500 10 212,500 5.6 5.1 300 3000 10 255,000 4.7 4.2 8760 300 (30% load factor) 10 223,380 5.4 4.8

Table 6 shows at the current cost the worst case scenario gives an 8.3 year pay back and this improves to 5.5years when operating under best case scenario. So it can be expected that the actual pay back will be some where between theses two values. The last row in

For inspection purposes only. table 5 shows a 5.4 simple payConsent back. of copyright This owneris ba requiredsed onfor any a other30% use. load factor which is what is

expected to be achieved for the DKIT wind turbine.

Table 6 also includes a column showing the simple pay back based on a 10% grant towards the capital cost. At current electricity cost this gives a 4.8 year pay back based on a 30% load factor.

For the installation of an 850 kW turbine it would not be exporting to the national grid and all the electricity generated would be off setting the retails rate that Cadburys pay for electricity. It would also simplify the system, i.e. no need for a grid connection.

EPA Export 25-07-2013:20:50:40 Another option is for Cadburys in Rathmore Co. Kerry to installing the wind turbine and to use all the electricity on their site and/or to exporting part of it to Cadburys (Dublin). This location would have a far more favourable wind velocity profiles than the Dublin site and may be easier to achieve planning permission. It would require a grid connection if electricity was to be exported.

5.2.3 Financial Support from SEI for Wind Turbines

Financial support is available for a feasibility study with the potential of future support depending on the report findings. It is recommended that Cadburys Ireland initially pursue this line of action and undertake a feasibility study. SEI will fund upto 50% of the cost of a feasibility study. Any feasibility study would need to address the following areas;

For inspection purposes only. • Return on Capital InvestmConsente ntof copyright owner required for any other use.

• Local Wind Data • Economical Size of Wind Turbine • Planning Permission • Connects to the National Grid

EPA Export 25-07-2013:20:50:40 5.3. Biomass

5.3.1. Introduction

Biomass refers to the wide range of organic materials that have the potential to be converted to either heat, electricity or transport fuels. The technology used to convert biomass to useful energy ranges from wood stoves, kilns, CHP plants, gasification units, anaerobic digesters and gas engines.

Cadburys Ireland is part of the EU Emission Trading Scheme which came into force on 1st January 2005. Companies who reduce their emissions through the installation of more energy efficient technology or fuel with lower carbon emissions could generate new revenue streams from the sale of excess carbon permits. Cadburys Ireland has an allowance of 8,059 tonnes of Carbon Dioxide for 2005, 2006 and 2007. They produced 6,510 in 2005 with an output of 39,556 tonnes of product. This means they have an

For inspection purposes only. excess 1,549 tonne of CO2 forConsent 2005. of copyright The owner cost required penalty for any othershould use. they exceed their carbon

allowance is 24 Euro/Tonne of carbon.

5.3.2. Wood Pellets Boilers (Bio-Heat Boilers)

There has been a significant growth in the domestic sector and to a lesser extent in the commercial sector in the use of wood pellet boilers. A Wood pellets boiler is as automatic as any oil or gas boiler and they come supplied with hoppers to reduce the need for frequent fuelling. The fuel wood pellets are made from wood shavings and sawdust and they burn quite effectively because they have a low moisture and ash content. Therefore they must be stored in a dry area to maintain their moisture content or the efficiency of the boiler will be reduced. They are compact and easy to store and

EPA Export 25-07-2013:20:50:40 typically come in bags, but they can also be delivered in bulk by truck. Bulk purchase is cheaper. The ash content is quite low and boiler can operate for a number of days without any need for manual intervention.

Sustainable Energy Ireland (SEI) provides information on domestic energy cost on their web site. A copy of the Domestic Fuel Cost Sheet is included in appendix K and it shows a delivery cost of 4.48 c/kWh for Wood Pellets (Bulk). To equates to a useful cost of 5.6 c/kWh at a boiler efficiency of 80%.

In section 1.1 Overview of Thermal Energy Usage it showed that the useful cost of natural gas is 3.34 c/kWh and therefore the is no financial advantage to be gained from changing from natural gas to wood pellets boiler due to the higher useful fuel cost of 5.6 c/kWh. For example replacing all theses boiler with wood pellet boiler would increase energy cost by Euro 423,375. Also the wood pellet boilers require more attention from an operation perspective. Therefore from an energy cost perspective changing to wood pellets would not be economic.

Where the wood pellets have an advantage is that they do not produce Carbon Dioxide

(CO2). For example in Appendix A it showed that the process/space heating/DWH boiler

For inspection purposes only. accounts for 27.9% of the totalConsent gas of copyright consum ownerpti requiredon. forThis any otherequates use. to approximately 1,865 tonnes of CO2. For example replacing all theses boiler with wood pellet boiler would reduce carbon emissions by 1,865 tonne and save Euro 44,700 if Cadburys exceed their allowance by this amount or greater. Compared the reduce carbon cost of Euro 44,700 to the increased energy cost of Euro 423,375 still show an net increase cost of Euro 378,675. Therefore from an energy cost and potential reduction of carbon emission changing to pellet is still not justifiable.

Therefore the economical breakeven point for changing to wood pellets will depend on the unit cost of natural gas, unit cost of wood pellets and the cost penalty per tonne of carbon. The most likely scenario is that natural gas ant the penalty cost per tonne of carbon will increase at a greater rate than the cost of wood pellets and some time in the

EPA Export 25-07-2013:20:50:40 future it will be economical to change to a wood pellet boiler. There is also an option of wood chip boilers but at the time of the report no information on their unit cost was available on the SEI Domestic Fuel Comparison Energy Cost Sheet. It could be assumed that they may be slightly lower in cost than wood pellets as there is less manufacturing required but still not sufficiently low enough to justify changing at the present time.

5.3.3. SEI Bio-Heat Boiler Deployment Programme

This is a programme which Cadburys could make use of in the form of a pilot study in the use of bio-heat boiler in replacing it existing gas fired boiler used for process/space

For inspection purposes only. heating/domestic hot water generatioConsent of copyrightn. Ther ownere are required a num for anyber other of use. boilers used for space heating and domestic hot water production and to a lesser extent process boiler which would fall into this kilowatt size category. Although it has already been shown that on a fuel cost bases it is not economical, this would be an ideal opportunity for Cadburys to utilising the grant support from SEI to install a bio-heat boiler as a pilot project and monitor it performance. This would provide Cadburys with valuable information should the need to switch all their boilers to bio-fuel in the future in the advent of a significant increase in both natural gas and carbon charges. For example replacing one of the Office boilers with a bio-heat boiler would have no impact on the manufacturing process but at the same time provide the Engineering Department with information on operation and maintenance costs for a bio-heat boiler.

EPA Export 25-07-2013:20:50:40 5.4 Combined Heat & Power.

A previous study by Integrated Engineering Consultancy in January 2002 outlined the potential savings by installing a Combined Heat & Power (CHP) system. It identified a simple payback period of 8 years, but outlined that a more detail analysis on costing was required for the installation of the hot water distribution system to supply the various process/space heating/DHW boilers. The reported concluded that a more detailed study is required on the potential savings with a more accurate cost on the CHP installation and this should be re-evaluated when the time comes to replace the steam stand-by boiler. Taking into consideration that the current study evaluated the cost of provide the process/space heating/domestic hot water boiler from a steam it could be assumed that a hot water heating distribution system although not as costly would be quite significant in cost and that the 8 year pay back period is under estimated.

This study was followed in 2004 by a feasibility study (40% Grant aided by SEI) on the installation of a micro CHP unit to supply hot water. Two areas were identified from the study as follows;

Option No. 1. A Micro-CHP unit providing heat for the boiler feed make-up only

For inspection purposes only. CHP Unit Capital Cost Consent of copyright owner required for any other Eurouse. 127,000

Net CHP savings Euro 16,903

CO2 Cost reduction Euro 2,040 Simple Payback 6.7 years

Option No. 2. A Micro-CHP Plant providing heat to boiler feed make-up & K 8 Boilers CHP Unit Capital Cost Euro 135,000 Net CHP savings Euro 19,275

CO2 Cost reduction Euro 2,040 Simple Payback 6.3 years

EPA Export 25-07-2013:20:50:40 At the time of the study both options showed to long a payback period and therefore were not considered for investment purpose.

5.4.1 Financial Support from SEI for Micro-CHP

Option No. 2. A Micro-CHP Plant providing heat to boiler feed make-up & K 8 Boiler with 10% Capital Cost Grant Support CHP Unit Capital Cost Euro 135,000 Net CHP savings Euro 19,275

CO2 Cost reduction Euro 2,040 Grant Euro 13,500 Simple Payback 3.88 years

For inspection purposes only. Consent of copyright owner required for any other use.

If consideration is taken for the K8 boiler replacement cost then the pay back will be 3.39 years simple pay back as outlined below.

CO2 Cost reduction Euro 2,040 Grant Euro 13,500 Boiler Replacement Cost Euro 5,000 Simple Payback 3.39 years

EPA Export 25-07-2013:20:50:40 5.4.2 Cadburys CHP Strategy

Cadburys should now re-consider the installation of a micro CHP system as outlined in the 2004 study when SEI launch their CHP grant support programme. It is assumed as Cadburys have already undertaken a CHP feasibility study under the SEI programme they should now be in a very good position to receive financial support from SEI.

Large scale CHP should only be considered at a time in the future when the stand-by steam boiler needs to be replaced. It should also be considered in relation to the

operation any new CHP plant fuelled by wood pellets. This should be review if CO2 charges are likely to become a significant cost to Cadburys in the future.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:40 5.5 Solar Heating

Solar heating uses collectors to transform sunlight into heat to provide space and/or water heating. The energy from the sun to the earth is approximately 1.36 kW/m2 make allowance for the incident of radiation which is immediately reflected. Further loss is caused by absorption and under the most favorable conditions i.e. the desert area a maximum of 1 kW/m2 is available. This value is reduced even further when consideration is taken for periods of darkness. For example, July in Dublin the average daily solar energy is approximately 0.235 kW/m2, while in December this falls to 0.022 kW/m2. For summer periods this equates to approximately 5.7 kWh per day/m2 of collector.

Table 7 and 8 shows the simple payback for different size collector based on the current unit cost of 3.35c/kWh and a future cost of 10 c/kWh respectively for natural gas based on a 25% solar absorption factor over the year.

Table 7 Simple Pay Back on Solar Collector based on Average Unit Cost of 3.35 c/kWh for Natural Gas

Annual Max Output Energy Saving Euro Size m2 Cost/m2 Euro kWh/day m2 kWh Saving Pay Back Years 3 833 5.7 1,560 52 48 For inspection purposes only. 4 750 Consent5. of7 copyright owner required2, for08 any1 other use. 70 43 5 663 5.7 2,601 87 38 6 576 5.7 3,121 105 33 7 500 5.7 3,641 122 29 8 485 5.7 4,161 139 28 9 450 5.7 4,681 157 26 10 440 5.7 5,201 174 25

EPA Export 25-07-2013:20:50:40 Table 8 Simple Pay Back on Solar Collector based on Average Unit Cost of 10 c/kWh for Natural Gas

Max Output kWh/day Annual Energy Euro Size m2 Cost/m2 Euro m2 Saving kWh Saving Pay Back Years 3 833 5.7 1,560 156 16 4 750 5.7 2,081 208 14 5 663 5.7 2,601 260 13 6 576 5.7 3,121 312 11 7 500 5.7 3,641 364 10 8 485 5.7 4,161 416 9 9 450 5.7 4,681 468 9 10 440 5.7 5,201 520 8

It can be seen from table 8 that even when the useful cost of natural gas is increased to 10 c/kWh the simple pay back ranges from 8 to 16 years depending on the size of the collector.

For example taking a 4 m2 solar collector this gives a simple pay back of 43 years and 14 years respectively. The actual pay back may be longer as the heat provided from the collectors would need to be incorporated into the existing process heating systems and this may require installing a plate heat exchanger in series with the boiler. The system would be less complicated for the domestic hot water heating the system will still have a For inspection purposes only. Consent of copyright owner required for any other use. high pay back. Therefore base on the economics of solar heating it is unlikely, even taking the reduction of carbon cost into consideration that it will play any significant role in providing thermal energy to Cadburys Ireland in near future.

EPA Export 25-07-2013:20:50:40 5.6 Monitoring Boiler Operating Times

The Micro-CHP study initially identified two areas which had a good potential to utilise the heat from the CHP unit. These were as follows;

• K Block plus the steam boiler make-up water.

• The five boilers cluster in B Block.

As part of the study hour run meters were installed to monitor the boiler hour run to determine their output based on each boiler rating. (The cost of installing gas meters for each boiler was far too costly and this low cost monitoring method provided adequate information for the study). A make-up water meter already existed. The monitoring period indicated that K Block plus the steam boiler make up or the steam boiler make up alone show the best potential to recover heat from the CHP unit. The hours run meters showed that the B Block boiler cluster did not operate for sufficient long enough time to recover the heat from the CHP unit. These reading have now been updated as show in table 9. Table 9 Boilers Hour Run Meter Readings For inspection purposes only. Consent of copyright owner required for any other use.

K Block Hour Run Meters Date Time B Block Hour Run Meters Readings Readings B5 B4 B3 B2 B1 K1 K2 K8 8/4/2004 16.30 235.4 99.8 495.7 871.6 125.4 198.2 1.1 201.4 20/3/06 12.30 792.7 4107.6 3896 9326 1065.1 4734.2 0.7 5372.6 557.3 4007.8 3400.3 8454.4 939.7 4536 -0.4 5171.2 % Time on since hour run meters installed 3.77 27.12 23.01 57.20 6.36 30.69 0.00 34.99

The meters reading show as they did in the Micro CHP study that the boilers in B Block have a very low utilization. Only boiler B2 has operated over the period (1.69 year) for more than 50% of the time. It therefore reinforces the decision of their unsuitability for the Micro CHP unit. The meter reading reinforce that the choice of K Block boilers with

EPA Export 25-07-2013:20:50:40 the use of the steam boiler feed water make tank as a heat sink was the best option for the Micro CHP unit.

Beside the information provided by the hour run meters for the Micro CHP study they also provided other data. For example why are five boiler required to meeting the process heating load for the 5 boilers in B Block? This heating demand could be easily met with two/three of theses boilers. The heating circuits could be modified to be supplied by fewer boilers with the following advantages;

• The maintenance cost of these boilers could be reduced by up to 40%. There are a number of similar boiler clusters. Could their circuits be modified to allow fewer boilers meet their heating demand? • Removing a number of boilers would provide spare boilers/spare parts and reduce the short term requirement for a boiler replacement budget. • The boiler will operate nearer to their designed load and therefore their thermal efficiency will improve.

Therefore in order to gain better information on the operation pattern of the boiler it is recommended that hour run meters similar to those already installed are fitted to all For inspection purposes only. boilers/heaters including the ThurConsentley of copyright heaters owner and required Office for any boilers.other use.

This information can then be used to determine when boiler should be maintained as it provides a means to reduce maintenance cost. It will also provide information on heating demand and may allow a boiler to be replaced by smaller unit when it is due to be replaced. It will also provide information in locations where there is more than one boiler if the heating load can be shared by fewer boilers. This will reduce maintenance cost and provide spare back-up boilers and/or spare parts.

EPA Export 25-07-2013:20:50:40 5.7 Space Heating Control

Cadburys are in the process of installing a Building Energy Management Systems (BEMS). BEMS are ideal for the efficient control of space heating and domestic hot water heating boilers.

It is recommended that the BEMS should be set up to provide the time scheduling and temperature control of all space heating and domestic hot water boilers.

Appendix L outlined the different type of BEMS software functions a typical system should incorporate. It outlined the different type of temperature control system which can be used for example Proportional (P control), Proportional Integral (PI) control and Proportional Integral Derivate (PID) control. Compared to on/off control these control system will reduce over and under shoot of the designed temperatures. Better control through the use of Proportional (P control), Proportional Integral (PI) control and Proportional Integral Derivate (PID) control will reduce heating cost by maintaining the temperature closer to its set point. Fig 2. & Fig. 3 illustrates the advantage of PID control compared to on/off control by reducing overshoot and achieving the desired temperature with little or no off-set. Incorporating this type of temperature control together with the

For inspection purposes only. scheduling system should helpConsent to re ofd copyrightuce space owner requiredheating for any co othersts use. by upto 20%.

The BEMS should be used to control all space and hot water heating boilers in both the office and factory areas including the Thurley heaters.

EPA Export 25-07-2013:20:50:40

Fig 2 On/Off Controls Showing Undershoot & Overshoot

Desired Temperature

Fig 3 P, PI & PID Control

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EPA Export 25-07-2013:20:50:41

Appendix A 2005 Gas Consumption by Area

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EPA Export 25-07-2013:20:50:41 Appendix B 2005 Electrical & Natural Gas Consumption & Cost

Natural Gas Cost 2005 Month Use kWh Cost Euro Unit c/kWh Jan 3,001,898 77,344 2.58 Feb 3,889,737 95,477 2.45 Mar 3,585,672 80,132 2.23 Apr 3,326,315 57,477 1.73 May 3,106,032 54,189 1.74 Jun 2,181,834 41,450 1.90 Jul 2,114,217 39,290 1.86 Aug 2,137,014 39,492 1.85 Sep 2,431,941 43,228 1.78 Oct 2,867,214 69,416 2.42 Nov 3,787,396 124,861 3.30 Dec 3,200,000 110,480 3.45 Total 35,629,270 832,834 2.34

Useful cost @ 70% efficiency = 3.34

Electricity Cost 2005 Month Use kWh Cost Euro Unit c/kWh Jan 2,006,679 165,392 8.24 Feb 1,992,362 164,001 8.23 Mar 2,005,999 165,269 8.24 Apr 2,059,275 168,202 8.17 May 2,035,940 166,807 8.19 Jun 1 , 91 6, 2 4For4 inspection15 purposes8,579 only. 8.28 Consent of copyright owner required for any other use. Jul 2,061,453 168,110 8.15 Aug 1,635,530 137,772 8.42 Sep 2,083,566 169,653 8.14 Oct 2,077,200 169,233 8.15 Nov 2,183,179 193,897 8.88 Dec 1,586,034 136,497 8.61 Total 23,643,461 1,963,412 8.30

Cost based on recent charges = 8.5

EPA Export 25-07-2013:20:50:41 Appendix C List of Boilers/Heaters

List of Boilers/Heaters

Rating Location Ref. No. Manufacture Function Code kW Year Block A A1.1 Thurley Space Heating SH 586 Block A A1.2 Thurley Space Heating SH 586 Block A 1 Suprima Space Heating SH 50 Block A 2 Buderus Logamatic Praline Heating P 50 Block A 3 Potterton (70/133) Wash Room DHW 58 Block A 6 Buderus Time-out1 S/R P 44 Block A 7 Potterton Time-out1 S/R P 20 Block A 8 Buderus Logamatic G234 Time-out1 S/R P 43 Block A 9 Buderus G224L Time-out1 S/R P 73 Block A 10 A O Smith Cream Votator DHW 65 Block A 11 Reznor (XA 400) Back Ramp SH 94 Block A 12 Reznor (XA 400) Back Ramp SH 95 Block A 13 Buderus G244L (boiler) Crunchy Room P 44 Block A 14 Buderus G244L (boiler Crunchy Room P 44 Block A 15 A O Smith Crunchy Room DHW 78 Block A 20 A O Smith Snack Wafer DHW 78 Block A 21 Potterton (83/180) Snack Wafer DHW 78 Block A 22 Reznor Gents Cloaks SH 41 Block A 23 Reznor Ladies Toilet SH 58 Block A 24 Reznor Ladies Cloaks SH 41 Block A 25 Reznor Ladies Cloaks SH 41 Block A 26 Reznor Gents Cloaks SH 41 Block B 1 Reznor (XA 225 A/H) Space Heating SH 41 Block B 2 SIME RX For inspection purposesHot Wa only.ter P 49 2002 Buderus LomConsentax G244L of copyright owner required for any other use.

Block B 4 (boiler) Process htg P 31 1993 Block B 5 Buderus Process Htg P 26 1987 Block B 6 SIME Process Htg P 49 1996 Block B 7 Reznor Heater Space Heating SH 41 Block B 8 Reznor Heater Space Heating SH 41 Block B 9 Buderus Process Htg P 50 1991 Block B 10 Buderus Process Htg P 50 Block B 11 SIME Process Htg P 53 Block B 12 SIME RX Process Htg P 72 1997 Block B 13 Buderus Process Htg P 49 1997 Block B 15 Buderus Lomax G224L Process htg P 45 1991 Block B 16 Reznor Space Heating SH 18 Block B 17 Reznor Space Heating SH 18 Block B 18 Potterton (83/180) Hot Water DHW 58 Block B 19 Buderus G224L Hot Water P 40 Block B 20 Reznor Space Heating SH 41 Block B 21 Mark Eire Space Heating SH 18 Block B 22 Reznor Space Heating SH 18

EPA Export 25-07-2013:20:50:41 Block B 23 Reznor Space Heating SH 41 Block B 24 Reznor Heater Space Heating SH 41 Block B 25 Reznor Heater Space Heating SH 41 Block B 26 A O Smith Hot Water DHW 89 B Block B Canteen Thurley Space Heating SH 220 Block B B1.1 Thurley Space Heating SH 439 Block B B1.2 Thurley Space Heating SH 512 Block B B1.3 Thurley Space Heating SH 439 Block B B1.4 Thurley Space Heating SH 512 Block B PMS Thurley Space Heating SH 512 Block C 1 Reznor XA125 A/H Space Heating SH 41 Block C 2 Reznor XA125 A/H Space Heating SH 41 Block C 3 Reznor Space Heating SH 41 Block C 4 Reznor XA125 A/H Space Heating SH 41 Block C 5 Buderus No. 1 Process P 69 1995 Block C 5 Buderus No. 2 Process P 69 1997 Block C 6 Reznor X400 A/H Space Heating SH 90 1986 Block C 7 Reznor Space Heating SH 70 1986 Block C 8 Reznor Space Heating SH 41 Block C 9 Reznor Space Heating SH 41 Block C 10 Ideal Mexico Rad Heating SH 23 Block C 11 Randamax Water Heating P 96 Block C 12 Mark Eire Space Heating SH 41 Block C 13 Mark Eire Space Heating SH 41 Block C 14 Mark Eire Space Heating SH 41 Block C 15 Reznor Space Heating SH 41 Block C 16 SIME Process P 38 1998 Block C 17 Renni Space Heating SH 6 Block C 18 Kayanson / Bentone B6 400 Hot Water P 316 Block C 19 Reznor For inspection purposesSpace Heating only. SH 80 Consent of copyright owner required for any other use. Block C 20 Reznor Hot House P 12 Block C 21 Buderus Process P 30 1991 Block C 22 Reznor Air Curtain SH 41 Block C 23 Reznor Space Heating SH 41 Block C 25 Reznor Space Heating SH 40 Block C 27 Reznor Space Heating SH 40 Block C C1.1 Thurley Space Heating SH 293 Block C C1.2 Thurley Space Heating SH 219 Block C C1.3 Thurley Space Heating SH 659 Block C C1.4 Thurley Space Heating SH 586 Block C C1.5 Thurley Space Heating SH 512 Block E E4 Buderus Process P 38 1990 Block K 1 SIME Tank Heating P 90 2001 Block K 2 SIME Tank Heating P 90 2001 Block K 3 SIME Old Workshop SH 90 Block K 4 Buderus Deodoriser P 40 Block K 5 Reznor Outside wash/h SH 40 Block K 6 Reznor Reclaim SH 50

EPA Export 25-07-2013:20:50:41 Block K 7 SIME Lipp Mixer P 23 Block K 8 Buderus Pump Hse P 55 Main Boiler House 9 Reznor Space Heating SH 15 1997 Block O 1 Potterton Process DHW 4 Block O 2A Hamworthy Rads &heat SH 200 Block O 2B Hamworthy Rads &heat SH 200 Block O 2C A O Smith Water Heater Hot Water DHW 78 Block O 3 Hamworthy Rads &heat SH 200 Block O 4 Hamworthy Rads &heat SH 200 Block O 5 Hamworthy Rads &heat SH 200 Block O 6 A O Smith Hot Water SH 91 Stores None Reznor Space Heating SH 30

Total No. 102 Total Rating 11,435

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EPA Export 25-07-2013:20:50:41 Appendix D Sample H.A. O’Neill Survey Report

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EPA Export 25-07-2013:20:50:41 Appendix E List of Thurley Heaters & Maintenance Report

Ref No. Model No Ser. No Heat Input Kw Use kWh A1 DW127E 84/351 586 80,455 Canteen DW118E 84/353 217.9 15,404 B2 DW124E 85/380 512 70,295 B4 DW124E 85/382 512 70,295 C1 DW121E 85/425 293 40,228 C3 DW124E 85/385 512 70,295 C5 DW127E 83/386 659 90,478 A2 DW127E 84/352 586 80,455 B1 DW124E 85/381 439 60,273 B3 DW124E 85/378 439 not in use PMS DW124E 85/379 512 70,295 C2 DW115E 85/383 219 30,068 C4 DW127E 85/384 586 80,455 Total 758,995 % 2.16

Total gas 2005 use = 35,146,995

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EPA Export 25-07-2013:20:50:41 Appendix F Quotes for Maintaining Hot Water boilers & heaters

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EPA Export 25-07-2013:20:50:41 Appendix G Proposed Layout of New Steam System

To K 75 Meters to K Block Block Boiler House Steam Header rs te e 150 meters 35 M ters e M 45

50 meters 50 meters ters ters 45 Me

C Block B Block 100 Me A Block

For60 inspection Meters purposes only. Consent of copyright owner required for any other use. 45 Meters s r te Me 45

EPA Export 25-07-2013:20:50:41 A Block Stream Supply

A6-9 180 A 11-12 288 kg/hr kg/hr A 10 65 kg/hr A 13-14 134 kg/hr

A 15 119 kg/hr A3 76 kg/hr A2 76

kg/hr 160 Meters

50 Meters

A 20-21 238 kg/hr

For inspection purposes only. Consent of copyright owner required for any other use. A 22-26

339 kg/hr A1 76 kg/hr

EPA Export 25-07-2013:20:50:41 B Block Stream Supply

B8 B7 41 kg/hr 41kg/hr B9-B13 417 kg/hr B6 B 15 74 kg/ 69 kg/hr B16-17 hr 54 kg/hr

B 18 B 5 89 kg/hr 40 kg/hr B 19-20 124 kg/hr

B2 74 B 4 kg/hr 48 kg/hr 140 meters B 21 27 kg/hr

For inspection60 purposes meters only. Consent of copyright owner required for any other use.

B 22-26 B 1 355 kg/hr 63 kg/hr

C 25 61 kg/hr C27 61 kg/hr

EPA Export 25-07-2013:20:50:41 C Block Stream Supply

C 18 482 kg/hr

C 17 8 kg/hr C 16 38 kg/hr C 19 12 kg/hr

C 15 C 20 41 kg/hr 18 kg/ hr C 14 C21-22 41 kg/hr 64 kg/hr C23

180 Meters 63 kg/hr C 12-13 82 kg/hr

C 10-11 181 kg/hr

For inspection purposes only. Consent of copyright owner required for any other use. 50 Meters

C9 63 kg/hr C1 C2-4 C5, C7- 8 C 6 123 kg/hr 298 kg/hr 137 kg/hr 63 kg/hr

EPA Export 25-07-2013:20:50:41 K 6-7 112 kg/hr

K 4- 5 123 kg/hr

K 3 90 Meters 137 kg/hr

K 1-2 274 kg/hr 15Meters 30 Meters K8

For inspection purposes only. 83 kg/hr Consent of copyright owner required for any other use.

K Block Steam Supply

EPA Export 25-07-2013:20:50:41 Appendix H Quotes for Steam System

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EPA Export 25-07-2013:20:50:41 Appendix I IBEC in response to a new EU Green Paper on Energy Policy.

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EPA Export 25-07-2013:20:50:41 Appendix J Week No. 52 Electrical Energy Usage

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EPA Export 25-07-2013:20:50:41 Appendix K SEI Domestic Fuel Cost Sheet

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EPA Export 25-07-2013:20:50:41 Appendix L BEMS Software Functions

BEMS Software Functions

Network Hardware

The network hardware consists of a cable linking outstations, terminal unit controllers and central terminals together, and network cards or components at each item connected. On some systems, other intermediate components may also be required. The type of cable and components varies somewhat from system to sys tem, but network hardware identical to that used to connect personal computers is often used.

Common Software functions

The central terminal and outstations are programmable, that is, they are capable of following a logical set of instructions. Without the programs, however, they can do very little. Described below are some of the more important software control programs, and their functions. The network software forms an integral part of the network, and is used to enable the connected items to communicate with one another. The language, or protocol, used to communicate between components is usually proprietary to each manufacturer, but is probably the most rapidly changing aspect of BEMS at present. Several international standard protocols are under development, which will enable outstations, terminal unit controllers, and central terminals from competing manufacturers to easily communicate with each other.

Direct Digital Control

For inspection purposes only. Direct digital control refers to Consentthe so off copyrighttware ownerroutines, required forwhich any other are use. available for application to a control loop. There are three basic types of modulating control.

These are: 1. Proportional (P) control 2. Proportional Integral ( PI) control 3. Proportional Integral Derivative (PID) control

Without going into detail, each level of control usually provides successively more accurate and responsive control, with better comfort levels and lower energy consumption. Often, PID control will be used where this would not have been cost effective in traditional control systems

Time Based Control

Time based control programs simply switch plant on and off according to a time schedule. They replicate, but improve on, a seven day time clock. They allow different on and off times each day, or multiple on and off times each day. They allow for Saturdays

EPA Export 25-07-2013:20:50:41 and Sundays and holidays. Usually, holidays can be programmed in well in advance. These programs can run in the central terminal and in the outstations. Some terminal unit controllers with their own time clock can also run time based control programs independently of the rest of the system.

Event Based Control

Event based control means control where things have to happen in a strict order to work properly, like the flow of traffic through traffic lights. As a driver, one waits for the lights to turn green before proceeding and stops when the lights turn red. A boiler in a central boiler plant, similarly, never comes on before the pumps are running, and always goes off if the pumps fail. The control is governed by logical steps called 'Boolean logic' programmed into the outstation, using 'IF',' AND',' OR', and other similar statements e.g. 'IF' the pump stops, switch off the boiler. More complex logic is often programmed into the system e.g. 'IF the time schedule is calling for heating, AND the outdoor temperature is below 16'C, AND at least two room temperature sensors are calling for heat, then start up the heating plant pumps. IF the flow of water is subsequently proven (after a suitable time delay), start the boiler.

Optimum Start/Stop

Optimum start software calculates the latest time for each item of heating & cooling plant so controlled to come on, taking into consideration indoor and outdoor temperatures, occupancy schedules, desired indoor temperature at occupancy, and capacity of the plant. In modem BEMS, the system is self tuning, teaching itself about the characteristics of the building, even if they change. These programs can save significant amounts of energy and save on plant maintenance by only running the plant for the shortest time possible. The programs can, if desired, also be used to switch plant off a little before occupancy ends, taking advantage of the lag between For inspection plant purposes going only. off and conditions becoming Consent of copyright owner required for any other use. uncomfortable.

Sub-Metering and Meter Pulse Counting

When appropriate electricity, gas, oil, or other meters are installed, then software can monitor consumption of electricity, gas, or oil by any sub-metered part of a building, or the building as a whole. The software records the energy used at any interval required, for example hourly or daily. This information can be used both in End User Energy Use Calculation and in Recording & Reporting for undertaking energy consumption Monitoring and Targeting, to reduce overall energy costs.

Maximum Demand Limiting/Load Shedding

In many medium and large buildings, the E.S.B. or Electrical Utility charges for electricity using a tariff called a Maximum Demand Tariff. With this tariff, the total charged for electricity used in the building is based not only on the number of units used, but also on the peak rate of usage. This peak rate charge is called the demand charge.

EPA Export 25-07-2013:20:50:41 1

14 Orlagh Lodge, Orlagh Grove, Scholarstown Road, Templeogue, Dublin 16.

Date: 10th-May-2005

Client Cadburys Ire. Ltd. Coolock, Malahide Road Dublin 5

Title CHP Feasibility Study

SEI Ref. No. CHP/S/04/004

Report By. Patrick Duke

For inspection purposes only. Consent of copyright owner required for any other use.

Signed By.

EPA Export 25-07-2013:20:50:41 2

Content Page No. List of Tables 3

List of Diagrams 4

Acknowledgement 5

1.0 Introduction 6

2.0 Energy Costs 7

3.0 Summary & Conclusions 10

4.0 Previous CHP Study 12

5.0 Pre-Audit Work 14

6.0 Review of Low Temperature Heating Demand 15

7.0 Boilers/Make-Up Water Meters Monitoring Programme 19

8.0 Review of Cooling Loads 26

9.0 Preliminary Costs for CHP Unit 27

Appendices 30 For inspection purposes only. Consent of copyright owner required for any other use. Appendix A.1: Electrical Tariff Analysis 2004 31 Appendix A.2: Natural Gas Tariff analysis 2004 32 Appendix B.1: Site Plan of Gas Pipe Distribution System 33 Appendix B.2: List of Boilers 33 Appendix: B.3: Schematic of Gas Meters Layout 33 Appendix B.4: Extract from Meter Monitoring System 33 Appendix C.1: Details of Hour Run & Make-Up Water Meter Readings 34 Appendix C.2: Boiler Operation Hours & Make-Up Water Use 36 Appendix C.3:Historical Data on Make-Up Water Usage 38 Appendix C.4: Boilers Output & Make-Up Water Demand 40 Appendix C.5: Total Boilers & Make-Up Water kW Demand 42 Appendix D: Absorption Cooling Correspondence 45 Appendix E: F4 Energy Preliminary Pricing Report 47 Appendix F: EPA Correspondence 55

References 56

EPA Export 25-07-2013:20:50:41 3

List of Tables

Table 1. Annual Energy Consumption 2004

Table 2. Natural gas & Electricity Energy Consumption 1996 to 2004

Table 3. Cost of CHP v’s Current System based on 2002 Energy Costs

Table 4. Percentage Gas Consumption of Specific Areas

Table 5. Boiler Hour Run & Make-Up Water Meters Usage

Table 6. Percentage Boiler Operation & Actual Boiler Make-Up Water par Hour

Table 7. Historical Make-Up Water Meter Readings

Table 8. Boiler kW Demand per Hour & Make) up Heating Demand (kW)

Table 9. Total Kilowatt Demand & % CHP Utilisation for each area

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EPA Export 25-07-2013:20:50:41 4

List of Diagrams

Fig. 1 Average unit cost c/kWh of Electricity 2004

Fig. 2 Average unit cost c/kWh of Natural Gas

Fig.3 Energy Usage 1996 to 2004

Fig. 4 Boiler Make-Up Water Meter Reading

Fig. 5 Boiler make-Up Water Meter Readings

Fig. 6. Proposed CHP Design

Fig.7 Effect of Air Pre-heating on Boiler Efficiency

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EPA Export 25-07-2013:20:50:41 5

Acknowledgement

The author would like to thanks the following Cadburys personnel from the engineering department for their assistance while undertaking this feasibility study, Mr. Tom Byrne, Mr. John Todd, Mr. Brendan Clane and Norman Briggs.

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EPA Export 25-07-2013:20:50:41 6

1.0 Introduction

At the request of Mr. Tom Byrne, Energy Manager, Cadbury's Ire. Ltd, Integrated Engineering Consultancy carried out a feasibility study to identify the potential energy cost savings by installing of a micro-Combined Heat & Power (CHP) unit at their Coolock plant. The survey was grant aided by Sustainability Energy Ireland (SEI) through their Combined Heat and Power (CHP) feasibility study scheme.

Cadbury's have a directive from Senior Management to achieve a 1% energy reduction per tonne of product produced over the next five years. The aim of the feasibility study is to identify suitable thermal and/or cooling loads which can be supplied cost effectively from a small scale CHP unit/s.

For inspection purposes only. Consent of copyright owner required for any other use.

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2.0 Energy Costs

The cost of supplying electricity and natural gas to the site in 2004 is giving in table 1.

Table 1 Annual Energy Consumption and Cost 2004

Useful Energy Consumption % Cost cost Type kWh % use Cost Euro Cost cent/kWh cent/kWh

Electricity 22,629,484 38.76 1,634,441 70.52 7.2226 7.2226

Natural Gas 35,754,310 61.24 683,202 29.48 1.9108 2.72971

Total 58,383,794 2,317,643 1 Useful cost of natural gas calculated at 70% boiler thermal efficiency

The average unit cost of electricity is 265% greater that the average unit of thermal energy provided by natural gas. The lower the units cost of natural gas and the greater the differential between it and the unit cost for electricity makes CHP a more economical to install.

Appendix A.1 contains a breakdown of the electrical energy cost for 2004. The average unit cost is calculated for each month. Fig. 1 shows a rising trend in the average unit cost. Over the twelve month period the average unit cost of electricity has increased by 25%.

For inspection purposes only. Fig.1 Ave UnitConsent Cost of c copyright/kWh ofowner El erequiredctric iforty any 2004 other use.

9.0 8.0 7.0 h 6.0 kW /

c 5.0 t 4.0 Cos t i 3.0 n

U 2.0 1.0 0.0 123456789101112 Months of the Year

Appendix A.2 contains a breakdown of the natural gas costs for 2004. The average unit cost is calculated for each month. Fig.2 shows a rising trend in the average unit

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cost over the year. Over the twelve month period the average unit cost of natural gas has increased by 18%.

Fig.2 Average Unit Cost Natural Gas 2004

h 2.5 W /K t 2 n Ce

t 1.5 s

Co 1 t i n

U 0.5 0 123456789101112 Months of the year

Historical the overall energy consumption has been relative steady. Table 2 show the natural gas and electricity consumption from 1996 to 2004. The trend in total energy consumption has been reasonable flat over this period as shown by Fig.3 but there has been a slight increase in natural gas over time.

Fig. 3Energy Usage 1996 to 2004

80,000,000 70,000,000 For inspection purposes only. Gas 60,000,000 Consent of copyright owner required for any other use.

h Electricity 50,000,000 kW e Total

us 40,000,000 gy r

e 30,000,000 n E 20,000,000 10,000,000 0 1996 1997 1998 1999 2000 2001 2002 2003 2004 Time: Year

For the purpose of this study the average unit cost for electricity and natural gas are taken as 8.242 c/kWh and 2.418 c/kWh respectively. Theses unit costs are base on the most recent available invoices.

Table 2 Natural Gas and Electrical Energy Consumption 1996 to 2004

Year Natural Gas kWh Electricity kWh Total kWh 1996 38,390,910 24,548,000 62,938,910

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1997 38,001,448 23,776,000 61,777,448 1998 31,167,516 21,588,000 52,755,516 1999 34,803,332 21,732,000 56,535,332 2000 37,168,790 21,730,000 58,898,790 2001 39,882,112 22,924,529 62,806,641 2002 45,385,030 24,804,681 70,189,711 2003 36,893,420 23,472,215 60,365,635 2004 35,754,310 22,629,485 58,383,795

2.1 Overview of Thermal Energy Usage

Natural gas is used for steam raising, process heating and space heating requirements. Gas usage can vary from 4,500,000 kWh in winter time to 2,000,000 kWh in the summer time, but this is also very much depends on production demand. The approximate percentage breakdown of natural gas usage as identified in the 2002 Energy Audit1 is as follows;

• Steam Boilers 58% • Ovens 17% • Space/Process/Domestic Heating 25%

Space/process/domestic heating is provided throughout the site over 100 separate units. These units can be categories as follows;

• Gas fired boilers, • Small steam to water heat exchanges, • Electrical immersion heating. For inspection purposes only. Consent of copyright owner required for any other use. As part of the requirement of a pilot study for the technical agreement component of the proposed Irish Government climate change agreement the potential for large scale CHP was investigated. A brief summary of the findings are contained in section 4.0 of this report.

For the purpose of this study large scale CHP is taken to be in the region of 1 MWe and small scale CHP in the region of 100 kWe.

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3.0 Summary & Conclusions

The main findings of the survey are outlined below;

• Although the CHP feasibility study has identified a number of suitable heating loads which can be supplied efficiently by a micro CHP unit the investment cost is outside the normal criteria for economic pay back.

• Gas and electricity cost have increased in the past number of months but their differential is not sufficiently large enough in favour of natural gas to provide a reasonable payback period.

• Cadburys are charged at a reasonable low unit cost for electrical energy when compared to other smaller organisation because they are a high tension user. Also the structure of the electrical tariff system means that there are a number of fixed charges built into the cost. These fixed costs will remain even if there is a reduction in the number of kilowatt hours of electricity. Both these factors militate against achieving a lower payback period.

• The reduction in carbon dioxide charges due to the installation of the CHP unit has had very little effective on the simple payback. Although government organisations encourage the use of CHP the carbon reduction scheme is offering very little incentive to industry in terms of installing CHP systems.

• There are no incentives for industry to invest in this technology. A high charge for carbon would make this more attractive to CHP users but this would penalise other business where CHP would not be applicable and make them less competitive in the market place.

• A more proactive approach For inspectionwould purposes be only.to allow companies who are on the Consent of copyright owner required for any other use. emission trade scheme a higher carbon reduction, say a factor of three to four time their actual carbon reduction, to make it more economical for them to install a CHP system. These companies are more likely to have the electrical/thermal load profile that warrant a CHP installation. This would also help in achieving the national target in CHP growth.

• The EPA formula3 (See also Appendix F) for calculating tonnes of carbon reduction is based on the highest power generation efficiency (Combined Cycle) and on burning natural gas. In reality this is not the case. Based on the current power generation stock the efficiency would be lower, estimated at 35%. Also the tonnes of carbon produced should be based on the actual fuel mix, rather than natural gas. For example the EPA formula uses 0.206 tCO2/ MWh for natural gas whereas SEI’s4 report gives a value for electricity of 0.776 tCO2/ MWh in 2003. Taking the lower efficiency and the higher carbon content of the fuel into consideration this would increase the carbon reduction industrial companies would receive by installing CHP and thus improve their payback through lower carbon emission charges.

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• One of the aims of the EPA is to reduce carbon emissions form fossil fuels and although the Emissions Trade Scheme may seem to penalise companies, i.e. it is based on thermal installed load rather than actual utilisation, and the CHP set-aside scheme for carbon reduction is based on best generation efficiency and clean burning technology i.e. natural gas, it must be seen in the overall national context of trying to achieve a reduction in CO2 emissions and also the scheme is not to complex to operate. Therefore a greater penetration of CHP from the industrial sector could be stimulated by a grant scheme. The scheme could operate in the context of what the national target for CHP is and to make funds available to the industrial/commercial sectors to help achieve these targets if these are not been met by investment from the business sector.

For inspection purposes only. Consent of copyright owner required for any other use.

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4.0 Previous CHP Study2

A previous energy study undertaken by Integrated Engineering Consultancy in January 2002 outlined the potential savings by installing a CHP system. The following is a summary of the findings.

As the site has an all year round thermal demand the installation of a CHP system should be considered in the future when the stand-by steam boiler needs to be replaced. It is unlikely that a gas turbine will be a viable option unless there is a significant increase in steam demand or an agreement is made to supply steam to some of the local companies such as Tayto, Chivers or a district heating system was installed to provide space heating to a local housing estate. This is most unlikely to occur unless there was government funding for such a scheme. Therefore a gas engine using a waste heat boiler to generate steam and utilising the low temperature hot water (LTHW) from the engine to provide process/space/domestic hot water heating would be a more economical option.

The electrical demand various from a base load of 1 MW at weekends and often peaks at 2 MW during the working week. Therefore a 1 MWe gas engine would best suit the electrical demand profile provided use can be made of the waste heat.

Typical breakdown of electricity and heat from engine;

Electricity 1,005 kW Steam (Waste heat boiler) 504 kW LTHW 850 kW

Total 2,359 kW

Gas input 3,000 kW For inspection purposes only. Consent of copyright owner required for any other use. Overall Engine Efficiency 78.6%

Table 3 compares the supply of a fixed energy demand from the existing electricity tariff system, steam and low temperature hot water based on the natural gas tariff structure, to a CHP unit assuming that all the waste heat is utilised. Steam and hot water boiler efficiency are taken at 70% and the analysis is based on 8,000 hour of operation per annum.

The simple analysis shows a saving of Euro 381,260 assuming all of the available heat from the CHP is utilised. In reality this may not be the case. The estimated cost of a CHP unit is Euro 1,300,000 giving a simple pay back in 3.41 years. This analysis does not take into consideration the cost of installing the hot water distribution system which is essential for efficient operation. Appendix B.1 shows a site plan outlining the location of the gas fired heating boiler. It can be seen a very extensive and comprehensive hot water distribution system would be required for the waste heat to be utilised. Taking this into consideration, a lower utilisation of the waste heat, lower hours of operation and a reduction in carbon dioxide charges then the payback would more than likely increased to a period of 8 years.

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Table 3 Cost of CHP v’s Current System based on 2002 Energy Costs

Current Cost Demand kW Unit Cost Hours Total cost c/kWh Euro Electricity 1,0005 0.0649 8,000 521,796 Steam 540 0.0247 8,000 106,704 LTHW 850 0.0247 8,000 167,960 796,460 CHP Cost 3,000 0.0173 8,000 415,200

Savings 381,260

The reported concluded that a more detailed study is required on the potential savings with a more accurate cost on the CHP installation and this should be re-evaluated at a future time when the stand-by boiler needs to be replaced.

An alternative CHP strategy is the use of a micro-turbine, i.e. a small scale CHP unit. These units have that advantage in that they can be installed local to the heating demand without any major construction requirements or piping distribution systems and allow simple connection to the electrical distribution system.

A micro-turbine is recommended than a gas engine for the following reasons;

• A simpler heat recovery system • Can operate for long periods of time without any major maintenance work other than minor work such as filter/oil change • Good operation efficiency Forwhen inspection operated purposes only. at fixed load conditions Consent of copyright owner required for any other use. • Fewer moving part when compared to an engine • Higher specification and more expensive technology which gives longer component life and better reliability

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5.0 Pre-Audit Work

Prior to undertaking the CHP study a number of site visits where undertaken to existing CHP installations. The purpose of the visits was to demonstrate to Cadburys engineering personnel that the installation of micro-CHP system can be easily integrated into the existing electrical and heating distribution system safety without causing any reliability problems and at the same time reduce energy costs.

Two site visits where undertaken as follows;

1. Trinity Capital Hotel, Pearse Street, Dublin 1;

This consisted of a micro turbine CHP system mounted in an enclosure on the roof adjacent to the hotels heating boilers. The CHP unit has a 175 kW thermal output which would suit the type of heating demand in Cadburys. The visit was arranged with Mr. Aidan McDonnell of F4 Energy the supplier of the CHP unit. After the site visit Mr. McDonnell visited the Cadbury plant and discussed the type of heat loads and investigated a number of possible locations for the CHP unit.

2. Dublin Airport Authority.

Although this site consists of a number of large scale CHP units the main purpose of the visit was to visit the absorption unit which provides cooling from heat supplied form the CHP unit. This visit was arranged with Mr. Eddie O’Connor, Energy Manager, Dublin Airport Authority.

The Cadburys personnel who undertook the site visits were Mr. John Todd (Mechanical) and Mr. Brendan Clane (Electrical) from the project departments. In terms of electrical installation there were no reservations. Some points were raised in relation to heating systems in Cadburys as follows; For inspection purposes only. Consent of copyright owner required for any other use. 1. In the hotel part of the hot water return system is diverted through the CHP heat recovery unit before returning to the boiler. As the Cadburys heating systems are pressurised and consists of numerous individual boiler how will the heat recovery system be design to operate with the CHP unit.

2. Unlike the hotel heating system Cadburys process heating system is provides by over 100 separate small boilers which are individually matched to a specific heating load, whereas in the hotel the three boilers provided heat to a common distribution system.

3. The temperature required for process heating is low in the region of 450C compared to 800C/700C flow and return respectively from the CHP unit. There are reservations that the process heat demand will be to low from the individual boiler to match the heat available from the CHP system.

Section 7.6 of this report addresses the first two points in the design of the CHP system. A number of heating load have been identified which can utilized the heat demand of the CHP unit and this is outlined in section 7.5.

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6.0 Review Low Temperature Heating Demand

A review was undertaken of the low temperature heating systems to identify suitable clusters of space/production/domestic heating loads which are also located within easy reach of local main electrical distribution.

6.1. Gas & Heating Distribution System

Appendix B.1 contains a site plan with an overlay of the main gas pipe distribution system. This includes the location of the process/space heating & domestic hot water heating boilers, and the main gas meters. The gas main splits into two main distribution pipe line which supply meter No. 4 & 5 adjacent to A Block, meters No 3 which supplies K block and meter No 2 which supplies the steam boilers.

Appendix B.2 contains a list of each boiler giving its location, boiler manufacture and its thermal input and output in kilowatt (kW). There is a total of 114 process/space and domestic hot water heating boilers excluding the two main steam boilers.

Appendix B.3 contains a schematic of the gas meter layout. This shows a total of 19 gas/gas sub-meters. The schematic diagram is not sufficiently detailed to indicate which boilers are supplied from each meter. As part of the survey the gas meter schematic layout was updated based on tracing the gas main in specific areas to indicate which boiler are monitored by which meter. The schematic in appendix B.3 has been updated to reflect these changes.

Appendix B.4 contains an extract for week No.37 (second week of September) from the site automatic meter reporting system. As part of the survey this was updated to indicate which loads are supplied by specific gas meters.

For inspection purposes only. It can be seen from appendixConsent B.4 ofthat copyright Time owner Out required 2 forOven any other (TO use. 2), A Thurly (direct fired hot air heater in A block), E Block, the Office Heating and Canteen had little or not usage. Excluding the boiler house (steam boilers) and TO1 oven/snack (as this is mostly a measure of the gas oven consumption), the main areas of usage are, B Block, C&E Block and K Block. Table 4 shows the percentage breakdown of gas usage for 2002, week No. 9, No. 41 and No.42 in 2004 for these areas.

Table 4 Percentage Gas Consumption of Specific Areas

Location 2002 Week No.9 Week No.41 Week No.42 B Block 5.38 10.98 3.54 4.5 0 C&E Block 7.65 14.70 5.58 7.21 K Block 4.40 5.71 2.91 5.49 Total 17.43 31.39 12.03 17.2

In section 2.1 an Overview of Thermal Energy Usage it was outlined that the average annual demand for Space/process/domestic heating throughout the site is approximately 25% of the total gas consumption. The three locations in Table 4 show

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that theses are accounting on average for 20% of the total gas consumption. Therefore theses three locations were selected to identify which boiler are included in the gas consumption figures as shown in table 4. The purpose of this was to try and identified suitable clusters of boiler which could be supplied from the CHP unit.

6.2 Review of Specific Heating Demands

Before undertaking a review of the heating demand a number of site visit were undertaken to inspect existing CHP installations. This is detailed in section 4.0. Based on these site visits it was decided to base the study on identifying suitable heating loads to match the thermal output form a CHP unit with 175 kW thermal output. The site heating loads identified therefore needs to be capable of utilising this amount of heat at a continuous rate. Consideration therefore needs to be taken of the utilisation factor of such process heating loads so as to ensure that no heat is dumped to atmosphere from the CHP unit and this would reduce the system overall efficiency.

6.2.1 K Block

The site plan in appendix B.1 shows that meter No.3 measures the gas usage for K Block. Based on the boiler location in K Block and the boiler rating as giving in appendix B.2 the following boiler were selected;

Boiler K8 Pump House 63.7 kW Boiler K1 Tank Heating 90 kW Boiler K2 Tank Heating 90 kW

Total 243.7 kW

For inspection purposes only. These were selected based Consenton their of copyright type owner of requiredheating for any load, other use. i.e. process heating which has an all year round heat demand, the heating load is quite large, i.e. these boilers provide process heating to a number of large storage tanks and also the boiler are in reasonable proximity to each other. Also a possible location for the CHP unit was identified beside the cooling towers (water tanks) behind the pump house of boiler K8. Another advantage of this site is that it is located close to the boiler house and therefore provides another possible heat source by pre-heat the boiler make-up water. This is a significant advantage as this can be used as a heat sink when the demand for process heating is low.

6.2.2 B Block

Meter No. 11 from the site plan in appendix B.1 was identified as the meter supplying the boiler heating systems on the east side of B Block. This pipeline was traced from the meter and a total of thirteen branch lines were identified before it reached the end of the line where it branched into a boiler house which housed five boilers at the north end of B Block. These five boilers were selected as to their heating demand is process related and they are all located in the one area. Their details are as follows;

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Boiler B9 Process Heating 50 kW Boiler B10 Process Heating 50 kW Boiler B11 Process Heating 52.5 kW Boiler B12 Process Heating 72 kW Boiler B13 Process Heating 48.8kW

Total 272.3 kW

The total output of the five boilers exceeds the thermal load from the CHP unit. At a 50% utilisation factor the process load would only be 136 kW and therefore not all the heat from the CHP unit would be utilised.

From the site plan in appendix B.1 it can be seen that there are four boilers located on the North –West corner of A Block adjacent to the five boilers in B Block. The details of these boilers output are as follows;

Boiler A6 Process Heating 44 kW Boiler A7 Process Heating 73.3 kW Boiler A8 Process Heating 20 kW Boiler A9 Process Heating 43 kW

Total 180.3 kW

This gives a total output for the two locations of 452.6 kW. In this case a 50% utilisation would utilise all the heat from the CHP unit.

6.2.3 C&E Block For inspection purposes only. Consent of copyright owner required for any other use. No suitable heating load could be identified in this location which could utilise the heat from the CHP unit. Any potential heat loads identified had a mix of process and space heat, and thus reducing the utilisation of the CHP heat in the summer time.

6.2.4 Wash House

Although not initially identified from table 4, the Wash House has a high demand for hot water for tray and container washing. Also there are two heating boilers beside the Wash House which provide process heating for the two 5 Tonne Chocolate tanks and the UK No.11 tanks. The details of theses boilers are as follows;

Boiler B2 Process Heating 48.8 kW Boiler B3 Process Heating 43 kW

Total 91.8 kW

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Although the boiler ratings are small compared to the heat available from the CHP it is the heating demand of the tray and container wash which could make this an option for the CHP unit.

6.3 Review of Findings

A meeting and discussion was undertaken with Mr. Tom Byrne, Energy Manager to review the initials survey findings.

It was agreed that K Block showed good potential to utilise the heat from the CHP unit provided that boiler water make-up was included. A water meter is installed on the make-up water supply which allows for an accurate measurement of the water demand over time. Also the boiler log book contains historical data on boiler make-up water consumption. Based on these findings K Block boilers and the boiler make-up water were identified as having a good potential for heat recovery from the CHP unit and were therefore included in a monitoring programme.

The five boilers in B Block showed good potential for utilising the heat from the CHP unit. Some reservations were made about the amount of heat that the four boilers in A Block could provide. During the survey it was identified that gas meter No. 9 most likely supplied these boiler. There are three branch pipeline taken off the main gas pipe line after meter No. 9 before it reaches the boilers in A Block. The site gas meter report indicates that the gas consumption of meter No. 9 is low. Therefore it was decided not to include the four boilers in A Block in any monitoring programme and concentrate on the five boilers in B Block. It the results from the monitoring programme showed that B Block boilers have a good potential to utilise the heat from the CHP system, then the Boilers in A block will be included in the design of the heat recovery system.

For inspection purposes only. The majority of the Wash HouseConsent ofheating copyright owneris provided required for any by other steam. use. The water meter which supplies the cold water to the tray wash is not operating at present and therefore details on water usage cannot be monitored. Also a heat recovery system from the oil injected screw compressor has recently being installed to pre-heat the water for the tray wash. (This was identified during the 2002 Energy Audit). Taking the above point into consideration it was decided not to include Wash House at this time in any monitoring programme but it should be review at a later date when the water meter is repaired.

Therefore the three boilers in K Block including the boiler make –up water and the five boilers in B Block were the two areas identified for monitoring. The cost of installing gas meters including compensating equipment was prohibited so it was decided to install hour run meters on each boiler and monitor there usage over time. The heating demand would then be based on the boiler operating time and the boilers rated output.

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7.0 Boilers/Make-Up Water Monitoring Programme

7.1 Measuring Boilers/Make-Up Water Profile

Hour run meters were installed and set operating on both set of boiler as follows;

• B Block boilers Saturday 19th. February at 17.00 hours. • K Block boilers Saturday 26th. April at 17.00 hours.

To obtain an accurate load profile hourly readings were undertaken over a period of 24 hours from Thursday 7th to Friday 8th April. Appendix C.1 contains details of the hour run and the make-up water meters readings. A second meter down stream of the main boiler make-up water meter at the boiler feed tank was also monitored to act as a check meter. Table 5 shows the percentage hour run for each boiler since the meters were installed. Also the amount of make-up required over the 24 hours was also monitored on both meters. Boiler make-up water accounted for 60 cubic meters over the 24 hour period. The hours the boilers operated in B Block varied from 10% to 78%. Boilers K1 and K8 in K Block have both operated for approximately 65% of their time since the meters were installed.

Table 5 Boiler Hour Run & Make-Up Water Meters Usage

Water meter Readings per % Hour Run Boilers Operated since Hour Meters Installed Day K Block Hour Run B Block Hour Run Meters Meters Water Meter m3

For inspection purposes only. B8 Consent of copyright owner required for any other use. (Pump M1 M2 B9 B10 B11 B12 B13 K1 K2 Hse) (BH) (BFT)

20.43 9.96 44.08 77.74 11.11 63.83 1.42 65.88 60.00 58.36

Appendix C.2 shows the boiler operation per hour for each boiler over the 24 hour monitoring period. Similar data is provided for both water meters. Table 6 summaries this information based on average, maximum and minimum percentage hours run.

It can be seen from table 6 that boiler B 9 never operated during the 24 hour monitoring period although it has operated 20.43 percent of its time since the hours run meters have been installed as shown in table 5. In general only boiler B12 in B Block has operating with any great frequency as shown in tables 5 and 6.

Boiler K1 and Boiler K 8 in K Block had an average demand of 70% and 88% respectively over the monitoring period. As already outlined both boilers have operated approximately 65% of the time.

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Table 6 Percentage Boiler Operating & Actual Boiler Make-Up per Hour

Ave. water use Boiler Operation Per Hour per hour Water Meter B Block Boilers K Block Boilers m3 M2 M1 (BFT B9 B10 B11 B12 B13 K1 K2 K8 (BH) )

Ave. = 0.0 0.62 0.50 0.95 0.11 0.70 0.15 0.88 2.63 2.55 Max = 0.0 0.70 0.60 1.0 0.20 0.80 0.40 1.0 3.50 3.40 Min = 0.0 0.40 0.40 0.90 0.10 0.50 0.00 0.68 0.65 0.65

On the day the boiler and water meters were monitored the condensate pump from K Block was not working and under repair. Appendix C.3 contains historical water meter readings from the boiler house log book. These are summarised in table 7. It can be seen that the average water use is about 33% lower that that measured during the monitoring period.

Table 7 Historical make-Up Water Meter Readings

2004 2005 kg/se 3 3 3 3 m /day m /hour c For inspection purposes only. m /day m /hour kg/sec Consent of copyright owner required for any other use. Ave = 36.94 1.54 0.43 Ave = 40.63 1.69 0.47

Although not part of the feasibility study it can be seen from the historical and current water meter readings that the make-up water is approximately 20 m3 greater per day due to the condensate pump not operating in K Block. Based on a condensate return temperature of 800C and an average make-up temperature of 120C this equates to a loss of 66 kW and is equal to financial loss of Euro 1.32 per hour or Euro 31.64 per day or Euro 11,547 per annum.

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7.2 Analysis of the Boiler/Make-Up Demand

Appendix C.4 shows the kilowatt (kW) output from each boiler based on the boiler rating and the hours run per boiler as measured during the monitoring period. The boiler make-up is based on heating the boiler make-up water by 320C and is base on 66% of the measured water flow rate as outlined from the historical data from table 7.

Table 8 summarised this data bases on the average, maximum and minimum demand (kW) and provides similarly data for the make-up water.

Note: If a temperature difference higher then 320C was selected then the boiler feed water tank (BFT) could absorb more heat from the CHP unit.

Table 8 Boiler kW Demand per Hour and Make-Up Heating Demand (KW)

B Block Boilers kW K Block Boilers kW BFT Make-Up kW

B9 B10 B11 B12 B13 K1 K2 K8 Deta T @ 32oC

Ave. 0.00 27.32 24.60 62.60 5.20 49.29 10.79 46.95 64.59

Max. 0.00 30.80 29.28 68.86 9.60 56.00 28.00 60.17 85.97

Min. 0.00 17.60 19.52 50.08 4.80 35.00 0.00 32.82 15.97

For inspection purposes only. 7.3 Equating the Heating DemandConsent of copyright to CHP owner requiredSystem for any other use.

Appendix C.5 shows the hourly total kilowatt (kW) demand and the percentage of the CHP utilised, based on a thermal load of 175 kW from the CHP unit, for B Block Boilers, K Block Boilers and K Block Boilers plus the boiler make-up water.

This information is summarised in Table 9 showing the average, maximum and minimum demands. It can be seen that B- Block cannot utilise all the heat available from the CHP unit even at maximum conditions. Similarly K- Block boilers alone will only utilise 80% at maximum conditions. It is only when the boiler make-up water is combiner with the boilers from K-Block that there is potential for all the heat from the CHP unit to be utilised. At minimum conditions, the make-up water could be used as a heat sink to dump an excess heat not taken by the K-Block boilers.

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Table 9 Total Kilowatt Demand & % CHP Utilisation from each Area

Total kW Demand form each % of CHP Thermal Output (175 Area kW) K Block K Block Boilers + Boilers + B Block BFT Make- K Block B Block BFT Make- K Block Boilers Up Boilers Boilers Up Boilers

Ave. 119.72 171.63 107.03 71.69 102.77 64.09

Max. 133.74 212.83 137.17 80.08 127.44 82.14

Min. 92.00 97.79 80.29 55.09 58.55 48.08

For inspection purposes only. Consent of copyright owner required for any other use.

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7.4 Detailed Measurement of the Make-Up Water Demand

The potential of the boiler make-up water to provide a heat sink for the CHP system is therefore critical for efficient operation of the system. Two set of five minute interval reading were taken of the boiler make-up water meter during the monitoring period. This information is contained in appendix C.6 and shown in Fig. 4 and Fig .5. It can be seen that the boiler make-up water pump operates approximately forty minutes in every hour. Therefore this needs to be taken into consideration in the design of the heat recovery system.

Fig. 4 Boiler Water Make-Up Meter Reading

0.40

s 0.35 e t

u 0.30 n i 0.25 M

e/ 5 0.20 ag

s 0.15 U

r 0.10 e t a 0.05 W 0.00 12.45 12.50 12.55 13.00 13.05 13.10 13.15 13.20 13.25 13.30 13.35 Time: Friday 8th. April

Fig. 5 Boiler Make-Up Water Meter Readings

0.45 For inspection purposes only. 0.40 Consent of copyright owner required for any other use.

te 0.35 u n i 0.30 m

5 0.25 / g

a 0.20 e s 0.15 U r 0.10 te a

W 0.05 0.00 15.15 15.20 15.25 15.30 15.35 15.40 15.45 15.50 15.55 16.00 16.05 Time: Friday 8th April

7.5 Summary of Findings

From monitoring the boiler hour run and boiler make-up water meters it has identified K Block Boilers K1 and K3 plus the make-up water as the best potential for heat recovery from a micro-CHP unit.

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The system needs to be designed so as to ensure that all the available heat from the CHP unit can be utilised. As shown in Fig. 4 and 5 the boiler make-up water flow is not constant. Therefore some form of storage system needs to be incorporated into the design of the heat recovery system to provide a heat sink when there is no demand for boiler make–up water and also for periods when there is a low/no demand for heat from boilers K1 and K3.

7.6 CHP System Design

Fig.6 outlines a proposed CHP installation. Fundamental to the design is that the boiler make-up water storage tank as it acts as a heat sink when the demand from the boilers and/or boiler make up-water is low. A circulating pump is installed at the make up tank. It purposes is to circulate the boiler make-up water back through the plate heat exchanger when there is no/reduced demand. This will increase the boiler feed water temperature and hence reduce the gas usage of the steam boilers. This will result in the boiler make-up temperature fluctuating over time but ensuring minimum heat is dump to atmospheres from the CHP unit.

Fig.6 Proposed CHP Design

Boiler Boiler K1 Boiler K1 K8 Boiler K8 Plate Heat Plate Heat Exchanger Exchanger

Boiler K1 Boiler K8 Heating Heating Demand Demand

For inspection purposes only. Consent of copyright owner required for any other use.

CHP Unit

Boiler Feed Tank Make-Up Break Make-Up Tank Plate Heat Exchanger

Other design considerations are as follows;

• The CHP system is designed to operate with an 800C flow and 700C return. Therefore the boiler thermostat should be set at a maximum of 600C to provide sufficient dead-band between the two systems operating temperatures.

• The boiler plate heat exchangers are installed on the boiler return from the process heating demand. This is an indirect heating system and therefore it will have no effect on the boiler pressurising system.

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8.0 Review of Cooling Loads

It became quite evident early on in the study that absorption cooling would be a very expensive option. Details are contained in appendix D of contact made with Thames Valley University in London where an absorption chiller is installed. The following are the main points;

• The coefficient of performance of an absorption chiller is approximately 1.0. From contact with Irish/British suppliers the minimum size absorption unit is approximately 500 kW. This means that three CHP unit would need to be installed to match the absorption unit. This far exceeds the cooling load in Cadburys.

• The cost of a 500 kW absorption unit and associated equipment is estimated at Euro 100,000.

• The main chiller is located outside B Block and has a maximum electrical rating of 45 kW. An electrical load profile taking during January indicated that the unit rarely operated as the ambient condition at that time of year provide the cooling demand.

These finding were discussed with Mr. Tom Byrne, Energy Manager. It was decided to ignore the cooling load demand and to concentrate on the thermal demand.

For inspection purposes only. Consent of copyright owner required for any other use.

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9.0 Preliminary Costing for CHP Unit.

F4 Energy was contacted in relation in providing a costing for installing a CHP unit and associated heat recovery system based on the study findings. A detail of this proposal is contained in appendix E. A summary of the proposal is outline below;

Option 1.CHP Plant providing heat to boiler feed make-up only

CHP Unit Capital Cost Euro 127,000

Net CHP savings Euro 16,903 CO2 Cost reduction (See Appendix F) Euro 2,040

Simple Payback 6.7 years

Option 2. CHP Plant providing heat to boiler feed make-up & K 8 Boiler

CHP Unit Capital Cost Euro 135,000

Net CHP savings Euro 19,275 CO2 Cost reduction (See Appendix F) Euro 2,040

Simple Payback 6.3 years

Both options show long simple paybacks and are outside the normal criteria for investment.

Fig.7 shows the potential savings by increasing the combustion air temperature. A 0 For inspection purposes only. 20 C increase in combustionConsent air temperature of copyright owner requiredincrease for any boiler other use. efficiency by 1%.

Option 3 below outlines the potential savings based on 2004 gas consumption based on ducting the hot air from the CHP unit located in the boiler house to the burner combustion air inlet and also providing heat to the boiler feed make-up water.

Ventilation air is required for the CHP unit and this is measured at a rate of 0.8 ms/s at a temperature of 200C to 300C depending on the ambient air inlet temperature. The average steam demand and gas consumption are base on the energy audit in 2002.

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Fig.7 Effect of Air Preheating on Boiler Efficiency

2004 Gas Consumption 35,754,310 kWh For inspection purposes only. Steam Boiler Use (58% 2002Consent study) of copyright owner required for any other use.20,737,500 kWh Main Steam Boiler (95% 2002 study) 19,700,625 kWh Ave. unit cost 1.9108 c/kWh Annual Cost of Main Boiler Euro 376,440

Average Boiler Gas Consumption (2002 study) 292 m3/hr Air required for combustion (20% excess air) 3,504 m3/hr

Ventilation air from CHP Unit 2,880 m3/hr @ 250C Percentage of Combustion air supplied by CHP unit 82% @ 250C Average Ambient Temperature 150C

Potential Savings = 25-15/20 * 0.82 = 0.41%

Assume 0.30 % Saving Euro 1,130

Even making use of the hot air from the CHP unit has very little effect on the pay back as outlined below. The extra cost of ducting the hot air to the combustion air inlet is estimate to be Euro 1,000.

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Option 3. CHP Plant providing heat to boiler feed make-up & pre-heating combustion air

CHP Unit Capital Cost Euro 127,000

Net CHP savings Euro 16,903 CO2 Cost reduction (See Appendix F) Euro 2,040 Combustion air-preheat saving Euro 1,130

Simple Payback 6.3 years

Options 3 shows that making use of the hot air from the CHP unit to pre-heat the combustion air for the steam boiler has slightly improved option 1 simple payback.

For inspection purposes only. Consent of copyright owner required for any other use.

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Appendices

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Appendix A.1 2004 Electrical Tariff

Max. Imported Network Capacity Night Network DUOS DUS Capacity (MIC) Day Units Units capacity MIC Day Units Night Day Night Period MW kVA kWh kWh Charge Charge Charge Charge Charge Charge Jan. 04 4.374 4,800 1,298,302 753,862 5,844.24 6,528.00 70,679.56 28,646.76 8,413.00 723.71 Feb. 04 4.432 4,800 1,275,668 740,885 5,921.74 6,528.00 69,447.37 28,153.63 8,266.33 711.25 Mar. 04 4.261 4,800 1,323,333 764,843 5,693.26 6,528.00 77,467.91 31,320.32 8,575.20 734.25 Apr. 04 3.888 4,800 1,168,108 689,970 5,194.88 6,528.00 68,381.04 28,254.27 7,569.34 662.37 May. 04 3.811 4,800 1,162,850 687,170 5,092.00 6,528.00 68,073.24 28,139.61 7,535.27 659.68 Jun. 04 3.942 4,800 1,035,416 594,171 5,267.03 6,528.00 60,613.25 24,331.30 6,709.50 570.40 Jul. 04 3.838 4,800 1,199,356 702,899 5,128.08 6,528.00 70,210.30 28,783.71 7,771.83 674.78 Aug. 04 3.804 4,800 906,594 532,888 5,082.65 6,528.00 53,072.01 21,821.76 5,874.73 511.57 Sep. 04 3.898 4,800 1,240,416 735,433 5,208.24 6,528.00 72,613.95 30,115.98 8,037.90 706.02 Oct. 04 3.942 4,800 1,210,632 743,488 5,267.03 6,528.00 70,870.40 30,445.83 7,844.90 713.75 Nov. 04 4.165 4,800 1,299,536 768,183 5,564.99 6,528.00 93,878.48 38,739.47 8,420.99 737.46 Dec. 04 4.080 4,800 1,122,442 673,039 5,451.42 6,528.00 81,085.21 33,941.36 7,273.42 646.12 3.804

Sub 14,242,65 8,386,83 Totals 3 1 64,716 78,336 856,393 352,694 92,292 8,051 22,629,48 Total Units = 4 % night = 37.06

TUOS TUS Day Night Standing Total Cost Total Units Ave Unit Period Charge Charge Charge PSO Levey Euro Discount Net Cost kWh Cost c/kWh Jan. 04 8,612.26 3,717.57 185.84 4,032.00 137,383 343.46 137,039 2,052,164 6.67780 Feb. 04 8,462.12 3,653.57 185.84 3,996.00 135,326 338.31 134,988 2,016,553 6.69397 Mar. For inspection purposes only. Consent of copyright owner required for any other use. 04 8,778.30 3,771.72 185.84 3,996.00 147,051 367.63 146,683 2,088,176 7.02446 Apr. 04 7,748.62 3,402.49 185.84 3,996.00 131,923 329.81 131,593 1,858,078 7.08221 May. 04 7,713.74 3,388.69 185.84 3,996.00 131,312 328.28 130,984 1,850,020 7.08013 Jun. 04 6,868.41 2,930.07 185.84 3,996.00 118,000 295.00 117,705 1,629,587 7.22298 Jul. 04 7,955.90 3,466.25 185.84 3,996.00 134,701 336.75 134,364 1,902,255 7.06340 Aug. 04 6,013.87 2,627.87 185.84 3,996.00 105,714 264.29 105,450 1,439,482 7.32555 Sep. 04 8,228.27 3,626.69 185.84 3,996.00 139,247 348.12 138,899 1,975,849 7.02983 Oct. 04 8,030.70 3,666.41 185.84 3,996.00 137,549 343.87 137,205 1,954,120 7.02132 Nov. 04 8,620.45 3,788.19 185.84 3,996.00 170,460 426.15 170,034 2,067,719 8.22325 Dec. 04 7,445.70 3,319.00 185.84 3,996.00 149,872 374.68 149,497 1,795,481 8.32631

94,478 41,359 2,230 47,988 1,638,537 4,096 1,634,441 22,629,484 7.223

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Appendix A.2 2004 Natural Gas Tariff

Unit Gas Transp. Commid. Charge Capacity Total c/kWh Month Usage IPE Swing Fixed UK Commid. Shrink. Tranmis. Jan. 3,892,088 66,399.02 0.00 0.00 1,011.94 1,440.07 778.42 11,797.00 81,426.45 2.0921 Feb. 3,830,188 56,725.08 0.00 0.00 1,034.15 1,417.17 804.34 11,797.00 71,777.74 1.8740 Mar 4,259,852 50,649.64 0.00 0.00 1,150.16 1,576.15 809.37 11,797.00 65,982.32 1.5489 Apr 3,109,186 34,574.15 0.00 0.00 870.57 1,150.40 684.02 11,797.00 49,076.14 1.5784 May 2,635,486 26,644.76 606.16 2,002.97 737.94 975.13 553.45 11,797.00 43,317.41 1.6436 Jun 2,109,166 22,336.07 485.11 1,708.42 590.57 780.39 400.74 11,797.00 38,098.30 1.8063 Jul 2,237,408 24,947.10 514.60 1,812.30 626.47 827.84 447.48 11,797.00 40,972.80 1.8313 Aug 1,684,387 19,673.64 387.41 1,364.35 471.63 623.22 404.25 11,797.00 34,721.51 2.0614 Sep 2,449,238 27,872.33 563.32 1,983.88 685.79 906.22 685.79 11,797.00 44,494.33 1.8167 Oct 2,941,596 41,888.33 676.57 2,235.61 411.82 882.48 764.81 10,642.00 57,501.62 1.9548 Nov 3,426,352 61,571.55 788.06 2,604.03 479.69 1,027.91 548.22 10,642.00 77,661.45 2.2666 Dec 3,179,363 61,902.20 731.25 2,638.87 445.11 953.81 858.43 10,642.00 78,171.67 2.4587

35,754,310 495,184 4,752 16,350 8,516 12,561 7,739 138,099 683,202 1.9108

For inspection purposes only. Consent of copyright owner required for any other use.

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Appendix B.1: Site Plan of Gas Pipe Distribution System Appendix B.2: List of Boilers Appendix: B.3: Schematic of Gas Meters Layout Appendix B.4: Extract from Meter Monitoring System

For inspection purposes only. Consent of copyright owner required for any other use.

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Appendix C. 1 Hour Run Meter Readings

Cadburys CHP Study Thursday 7th. to Friday 8th. April Water meter Readings Hour Run Meter reading per hour per hour K Block Hour Run Time B Block Hour Run Meters Readings Meters Readings Water Meter m3

B5 B4 B3 B2 B1 K1 K2 K8 M1 (BH) M2 (BFT)

16.30 235.4 99.8 495.7 871.6 125.4 198.2 1.1 201.4 67,600.70 59,235.66

17.30 235.4 100.4 496.2 872.6 125.5 198.9 1.2 202.3 67,604.20 59,239.06

18.30 235.4 101.1 496.7 873.7 125.6 199.7 1.2 203.1 67,606.80 59,241.66

19.30 235.4 101.8 497.2 874.7 125.7 200.4 1.2 204.0 67,609.70 59,244.41

20.30 235.4 102.4 497.7 875.6 125.8 201.0 1.2 204.7 67,612.00 59,247.01

21.30 235.4 103.0 498.2 876.6 125.9 201.7 1.2 205.5 67,614.80 59,249.32

22.30 235.4 103.6 498.7 877.5 126.0 202.3 1.3 206.3

23.30 235.4 104.3 499.2 878.6 126.1 203.1 1.6 207.3

0.30 235.4 104.9 499.8 879.6 126.2 203.8 1.8 208.3

1.30 235.4 105.5 500.3 880.6 For inspection 126.3 purposes only.204.4 2.1 209.2 Consent of copyright owner required for any other use.

2.30 235.4 106.1 500.8 881.6 126.5 205.1 2.4 210.2

3.30 235.4 106.7 501.3 882.5 126.6 205.8 2.7 211.2

4.30 235.4 107.4 501.9 883.6 126.7 206.5 3.1 212.2

5.30 235.4 108.1 502.4 884.6 126.8 207.3 3.4 213.3

6.30 235.4 108.6 502.9 885.6 126.9 208.0 3.8 214.1

7.30 235.4 109.2 503.4 886.5 127.0 208.6 4.1 214.8

8.30 235.4 109.9 503.9 887.5 127.1 209.4 4.4 215.8 67,645.57 59,279.36

9.30 235.4 110.5 504.4 888.5 127.2 210.1 4.6 216.6 67,646.80 59,280.50

10.30 235.4 111.1 504.9 889.5 127.3 210.8 4.7 217.4 67,647.53 59,281.15

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11.30 235.4 111.8 505.4 890.7 127.4 211.6 4.8 218.3 67,649.60 59,283.07

12.30 235.4 112.3 505.9 891.6 127.5 212.3 4.8 218.9 67,650.25 59,283.81

13.30 235.4 112.9 506.4 892.7 127.7 213.1 4.8 219.0 67,653.30 59,286.81

14.30 235.4 113.6 506.9 893.7 127.8 213.8 4.8 220.6 67,656.17 59,290.00

15.30 235.4 114.0 507.3 894.5 127.9 214.3 4.8 221.2 67,657.70 59,291.33

16.30 235.4 114.7 507.8 895.6 128.0 215.1 4.8 222.0 67,660.70 59,294.02 % on since installed 20.43 9.96 44.08 77.74 11.11 63.83 1.4 65.88 60.00 58.36

For inspection purposes only. Consent of copyright owner required for any other use.

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Appendix C.2 Boilers & Make-Up Water use per hour

Ave. water use per Time Boiler Operation Per Hour hour

Time B Block Boilers K Block Boilers Water Meter m3 K8 (Pump M1 B9 B10 B11 B12 B13 K1 K2 Hse) (BH) M2 (BFT)

16.30

17.30 0.00 0.60 0.50 1.00 0.10 0.70 0.10 0.90 3.50 3.40

18.30 0.00 0.70 0.50 1.10 0.10 0.80 0.00 0.80 2.60 2.60

19.30 0.00 0.70 0.50 1.00 0.10 0.70 0.00 0.90 2.90 2.75

20.30 0.00 0.60 0.50 0.90 0.10 0.60 0.00 0.70 2.30 2.60

21.30 0.00 0.60 0.50 1.00 0.10 0.70 0.00 0.80 2.80 2.31

22.30 0.00 0.60 0.50 0.90 0.10 0.60 0.10 0.80 3.08 3.00

23.30 0.00 0.70 0.50 1.10 0.10 0.80 0.30 1.00 3.08 3.00

0.30 0.00 0.60 0.60 1.00 0.10 0.70 0.20 1.00 3.08 3.00

1.30 0.00 0.60 0.50 1.00 0.10 0.60 0.30 0.90 3.08 3.00

For inspection purposes only. Consent of copyright owner required for any other use. 2.30 0.00 0.60 0.50 1.00 0.20 0.70 0.30 1.00 3.08 3.00

3.30 0.00 0.60 0.50 0.90 0.10 0.70 0.30 1.00 3.08 3.00

4.30 0.00 0.70 0.60 1.10 0.10 0.70 0.40 1.00 3.08 3.00

5.30 0.00 0.70 0.50 1.00 0.10 0.80 0.30 1.10 3.08 3.00

6.30 0.00 0.50 0.50 1.00 0.10 0.70 0.40 0.80 3.08 3.00

7.30 0.00 0.60 0.50 0.90 0.10 0.60 0.30 0.70 3.08 3.00

8.30 0.00 0.70 0.50 1.00 0.10 0.80 0.30 1.00 3.08 3.00

9.30 0.00 0.60 0.50 1.00 0.10 0.70 0.20 0.80 1.23 1.14

10.30 0.00 0.60 0.50 1.00 0.10 0.70 0.10 0.80 0.73 0.65

11.30 0.00 0.70 0.50 1.20 0.10 0.80 0.10 0.90 2.07 1.92

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Ave. water use per Time Boiler Operation Per Hour hour

Time B Block Boilers K Block Boilers Water Meter m3 K8 (Pump M1 B9 B10 B11 B12 B13 K1 K2 Hse) (BH) M2 (BFT)

12.30 0.00 0.50 0.50 0.90 0.10 0.70 0.00 0.60 0.65 0.74

13.30 0.00 0.60 0.50 1.10 0.20 0.80 0.00 0.10 3.05 3.00

14.30 0.00 0.70 0.50 1.00 0.10 0.70 0.00 1.60 2.87 3.19

15.30 0.00 0.40 0.40 0.80 0.10 0.50 0.00 0.60 1.53 1.33

16.30 0.00 0.70 0.50 1.10 0.10 0.80 0.00 0.80 3.00 2.69

Ave.= 0.00 0.62 0.50 0.95 0.11 0.70 0.15 0.88 2.63 2.55 Max = 0.00 0.70 0.60 1.00 0.20 0.80 0.40 1.00 3.50 3.40

Min = 0.00 0.40 0.40 0.90 0.10 0.50 0.00 0.68 0.65 0.65

BH = Boiler House BFT = Boiler Feed Tank M1 = Meter No.1 M2 = Meter No.2

For inspection purposes only. Consent of copyright owner required for any other use.

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Appendix C.3 Boiler –Make-Up Water Historical Data

2004 2005 m3/day m3/hour kg/sec m3/day m3/hour kg/sec 37 1.54 0.43 34 1.42 0.39 55 2.29 0.64 39 1.63 0.45 50 2.08 0.58 25 1.04 0.29 20 0.83 0.23 30 1.25 0.35 22 0.92 0.25 45 1.88 0.52 40 1.67 0.46 31 1.29 0.36 100 4.17 1.16 64 2.67 0.74 63 2.63 0.73 57 2.38 0.66 54 2.25 0.63 Ave = 40.63 1.69 0.47 47 1.96 0.54 50 2.08 0.58 30 1.25 0.35 50 2.08 0.58 53 2.21 0.61 51 2.13 0.59 50 2.08 0.58 50 2.08 0.58 50 2.08 0.58 61 2.54 0.71 37 1.54 0.43 43 1.79 0.50 42 1.75 0.49 51 2.13 0.59 28 1.17 0.32 28 1.17 0.32 35 1.46 0.41 48 2.00 0.56 For inspection purposes only. 40 1.67 Consent0.46 of copyright owner required for any other use.

45 1.88 0.52 40 1.67 0.46 32 1.33 0.37 34 1.42 0.39 43 1.79 0.50 40 1.67 0.46 16 0.67 0.19 16 0.67 0.19 40 1.67 0.46 45 1.88 0.52 37 1.54 0.43 38 1.58 0.44 37 1.54 0.43 26 1.08 0.30 40 1.67 0.46 20 0.83 0.23 30 1.25 0.35 35 1.46 0.41 42 1.75 0.49

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50 2.08 0.58

2004 m3/day m3/hour kg/sec

31 1.29 0.36 15 0.63 0.17 40 1.67 0.46 7 0.29 0.08 7 0.29 0.08 22 0.92 0.25 40 1.67 0.46 40 1.67 0.46 29 1.21 0.34 38 1.58 0.44 30 1.25 0.35 33 1.38 0.38 30 1.25 0.35 20 0.83 0.23 39 1.63 0.45 43 1.79 0.50 34 1.42 0.39 19 0.79 0.22 19 0.79 0.22 35 1.46 0.41 37 1.54 0.43 30 1.25 0.35 51 2.13 0.59 45 1.88 0.52 45 1.88 0.52 5 0.21 0.06

5 0.21 0.06 For inspection purposes only. 41 1.71 Consent0.47 of copyright owner required for any other use.

20 0.83 0.23 32 1.33 0.37 36 1.50 0.42 43 1.79 0.50 40 1.67 0.46 31 1.29 0.36 38 1.58 0.44 23 0.96 0.27 48 2.00 0.56 24 1.00 0.28 21 0.88 0.24 67 2.79 0.78 48 2.00 0.56 53 2.21 0.61 41 1.71 0.47 33 1.38 0.38 29 1.21 0.34 35 1.46 0.41 26 1.08 0.30

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Ave = 36.94 1.54 0.43

Appendix C.4 Ave. Boilers & Make-Up Water Hourly Demand (kW)

BFT Water Make-Up B Block Boilers (kW) K Block Boilers (kW) (kW)

K8 (Pump Deta T @ Time B9 B10 B11 B12 B13 K1 K2 House) 32oC

16.30 0.00 26.40 24.40 62.60 4.80 49.00 7.00 49.23 85.97

17.30 0.00 30.80 24.40 68.86 4.80 56.00 0.00 43.76 63.87

18.30 0.00 30.80 24.40 62.60 4.80 49.00 0.00 49.23 71.23

19.30 0.00 26.40 24.40 56.34 4.80 42.00 0.00 38.29 56.50

20.30 0.00 26.40 24.40 62.60 4.80 49.00 0.00 43.76 68.78

21.30 0.00 26.40 24.40 56.34 4.80 42.00 7.00 43.76 75.66

22.30 0.00 30.80 24.40 68.86 4.80 56.00 21.00 54.70 75.66

23.30 0.00 26.40 29.28 62.60 4.80 49.00 14.00 54.70 75.66

0.30 0.00 26.40 24.40 62.60 4.80 42.00 21.00 49.23 75.66

For inspection purposes only. 1.30 0.00 26.40 24.40Consent of62.60 copyright owner9.60 required 49.00for any other use.21.00 54.70 75.66

2.30 0.00 26.40 24.40 56.34 4.80 49.00 21.00 54.70 75.66

3.30 0.00 30.80 29.28 68.86 4.80 49.00 28.00 54.70 75.66

4.30 0.00 30.80 24.40 62.60 4.80 56.00 21.00 60.17 75.66

5.30 0.00 22.00 24.40 62.60 4.80 49.00 28.00 43.76 75.66

6.30 0.00 26.40 24.40 56.34 4.80 42.00 21.00 38.29 75.66

7.30 0.00 30.80 24.40 62.60 4.80 56.00 21.00 54.70 75.66

8.30 0.00 26.40 24.40 62.60 4.80 49.00 14.00 43.76 30.21

9.30 0.00 26.40 24.40 68.86 4.80 49.00 7.00 43.76 17.93

10.30 0.00 30.80 24.40 62.60 4.80 56.00 7.00 49.23 50.85

EPA Export 25-07-2013:20:50:42 40

11.30 0.00 22.00 24.40 62.60 4.80 49.00 0.00 32.82 15.97 BFT Water Make-Up B Block Boilers (kW) K Block Boilers (kW) (kW)

K8 (Pump Deta T @ Time B9 B10 B11 B12 B13 K1 K2 House) 32oC

12.30 0.00 26.40 24.40 68.86 9.60 56.00 0.00 32.82 74.92

13.30 0.00 30.80 24.40 62.60 4.80 49.00 0.00 32.82 70.50

14.30 0.00 17.60 19.52 50.08 4.80 35.00 0.00 60.17 37.58

15.30 0.00 30.80 24.40 68.86 4.80 56.00 0.00 43.76 73.69

Ave. 0.00 27.32 24.60 62.60 5.20 49.29 10.79 46.95 64.59

Max. 0.00 30.80 29.28 68.86 9.60 56.00 28.00 60.17 85.97

Min. 0.00 17.60 19.52 50.08 4.80 35.00 0.00 32.82 15.97

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:42 41

Appendix C.5 Total Hourly Boiler & Make-Up Demand

Total kW Demand % of CHP Output (175 kW) K Block K Block Boilers + Boilers + B Block BFT K Block B Block BFT Make- K Block Time Boilers kW Make-Up Boilers Boilers kW Up Boilers

16.30 118.20 191.20 105.23 70.78 114.49 63.01

17.30 128.86 163.63 99.76 77.16 97.98 59.74

18.30 122.60 169.46 98.23 73.41 101.48 58.82

19.30 111.94 136.79 80.29 67.03 81.91 48.08

20.30 118.20 161.54 92.76 70.78 96.73 55.54

21.30 111.94 168.42 92.76 67.03 100.85 55.54

22.30 128.86 207.36 131.70 77.16 124.17 78.86

23.30 123.08 193.36 117.70 73.70 115.78 70.48

0.30 118.20 187.89 112.23 70.78 112.51 67.20

1.30 123.00 200.36 124.70 73.65 119.97 74.67

2.30 111.94 200.36 124.70 67.03 119.97 74.67 For inspection purposes only. Consent of copyright owner required for any other use. 3.30 133.74 207.36 131.70 80.08 124.17 78.86

4.30 122.60 212.83 137.17 73.41 127.44 82.14

5.30 113.80 196.42 120.76 68.14 117.61 72.31

6.30 111.94 176.95 101.29 67.03 105.96 60.65

7.30 122.60 207.36 131.70 73.41 124.17 78.86

8.30 118.20 136.97 106.76 70.78 82.02 63.93

9.30 124.46 117.69 99.76 74.53 70.47 59.74

10.30 122.60 163.08 112.23 73.41 97.65 67.20

11.30 113.80 97.79 81.82 68.14 58.55 48.99

12.30 129.26 163.74 88.82 77.40 98.05 53.19

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Total kW Demand % of CHP Output (175 kW) K Block K Block Boilers + Boilers + B Block BFT K Block B Block BFT Make- K Block Time Boilers kW Make-Up Boilers Boilers kW Up Boilers

13.30 122.60 152.32 81.82 73.41 91.21 48.99

14.30 92.00 132.75 95.17 55.09 79.49 56.99

15.30 128.86 173.45 99.76 77.16 103.86 59.74

Ave. 119.72 171.63 107.03 71.69 102.77 64.09

Max. 133.74 212.83 137.17 80.08 127.44 82.14

Min. 92.00 97.79 80.29 55.09 58.55 48.08

For inspection purposes only. Consent of copyright owner required for any other use.

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Appendix C.6 Boiler Make-Up 5 minutes Interval readings

Use cubic M1 (Boiler Use cubic meters/5 M1 (Boiler meters/5 Time House) min. Time house) min.

12.40 67650.25 15.10 67,657.02

12.45 67650.54 0.29 15.15 67,657.02 0.00

12.50 67650.90 0.36 15.20 67,657.02 0.00

12.55 67651.18 0.28 15.25 67,657.28 0.26

13.00 67651.18 0.00 15.30 67,657.70 0.42

13.05 67651.18 0.00 15.35 67,657.95 0.25

13.10 67651.18 0.00 15.40 67,658.31 0.36

13.15 67651.18 0.00 15.45 67,658.68 0.37

13.20 67651.55 0.37 15.50 67,658.98 0.30

13.25 67651.89 0.34 15.55 67,659.33 0.35

13.30 67652.24 0.35 16.00 67,659.40 0.07

For inspection purposes only. Consent of copyright owner required for any other use. 13.35 67652.60 0.36 16.05 67,659.40 0.00

16.10 67,659.40

Total 2.35 2.35 Total 2.38 2.38 Ave kg/s = 0.65 Ave kg/s = 0.66

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Appendix D Absorption Cooling Correspondence

Pat

The project which coupled the single Turbec T100 at an Abo was at Thames Valley University in London.

The Abo was a Cogenie unit, by Thermax – they do a range of smaller chillers. If you visit www.termaxindia.com, you should be able to find out who the Irish distributor is – I suspect that Europe is covered from the UK.

I am no expert, but I believe that the COP is around 0.7 on these units – you need a cooling tower or adiabatic cooler as part of the system, which is where you lose the efficiency.

Only other comments I would make is that the Cogenie unit is just about what you would expect from something made in India and also that the Absorption Chilling option tends to kill payback periods. The cost of the Abo system at Thames Valley was circa £70,000!

Hope this helps, any other queries please give me a shout.

Cheers.

REGARDS

Nick Lewis For inspection purposes only. Tel 00 44 (0)1270 768040 Consent of copyright owner required for any other use. Fax 00 44 (0)1270 768048 Mob 00 44 (0)7767 408963

-----Original Message----- From: Pat Duke [mailto:[email protected]] Sent: 14 February 2005 11:35 To: [email protected] Subject: CHP/Chilling

Hi Nick,

Aidan McDonnell, F4 Energy, gave me your contact details.

I work as an energy consultant and I am currently investigating the possibility of CHP at an industrial plant in Ireland. Aidan mentioned that you were involved in a CHP installation which included absorption chilling. I made some enquirers in Ireland and find it difficult to identify an absorption unit small enough that would match the micro turbine.

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First could I check with you if I am correct to say that the COP of absorption system is approximately 1, i.e. if you have 167 kW waste heat (as in the micro turbine), you can provide 167 kW of cooling.

Secondly can you purchase an absorption unit in that size range, or in your installation is there are a number of CHP units, say 4, giving 668 kW of waste heat to match to a absorption system of similar rating i.e. 668 kW.

I would appreciate any help you can give me on this.

Regards

Pat Duke

00 353 1 4944 390 (Home/office)

00353 86 816 25 36 (mobile)

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EPA Export 25-07-2013:20:50:43 46

Appendix E F4 Energy Preliminary Costing

F4energy

Combined Heat and Power

Preliminary Pricing Outline

Cadburys Manufacturing Facility

Coolock, Dublin

For inspection purposes only. Consent of copyright owner required for any other use. Date: May 9th, 2005

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Introduction

Following a site visit to Cadbury’s manufacturing facility, and the subsequent collection of thermal demand data at selected boiler locations, the following preliminary pricing and estimated energy cost savings have been drawn up with respect to the installation of a Combined Heat and Power Microturbine solution at Cadburys.

This document sets out the CHP Energy Savings and Investment Payback applicable to the installation of a Microturbine CHP plant at the Cadbury’s Facility.

Two installation scenarios are examined; a CHP plant servicing the Steam Boiler Feed Water only and, a CHP plant servicing the Steam Boiler Feed Water together with the K8 Pumphouse Boiler.

For inspection purposes only. Consent of copyright owner required for any other use.

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Option 1: CHP Plant providing heat to Boiler Feed Make-Up water (Steam Boiler)

Location: (Steam) Boilerhouse

Overview A single Microturbine CHP plant would be installed inside the existing Steam BoilerHouse. An insulated, 3000litre buffer tank would be installed (external) on the Boiler Make-Up Water Feed line, before the (steam) Boiler Feed tank. The CHP plant would pump LPHW from this tank through the CHP plant’s integral heat exchanger and back into the buffer tank. This installation would provide 105KW synchronized electrical supply to the Cadbury’s switchgear, and up to 175kW thermal output (depending on the Boiler Feed flow requirements) to the Steam Boilerhouse. An additional energy efficiency option would be to duct the clean, cooling air exhaust (c. 30kW) from the CHP plant into the Steam Boiler combustion intake, thereby improving the Steam Boiler’s energy efficiency.

For the purposes of conservative energy savings calculations, it is assumed that only 90% of the 175kW thermal output of the CHP plant will be transferred to the Steam Boiler system (allowing for low boiler feed water demand periods).

Installation considerations There are no technical barriers to the CHP installation. External area would need to be allocated for the 3000litre buffer storage tank.

Boiler Feed Tank

For inspection purposes only. Consent of copyright owner required for any other use.

Steam Boiler

CHP Plant Make-Up

Buffer Tank

Boiler Feed Make-Up Supply

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OPTION 1: ESTIMATED ENERGY COST SAVINGS

The following spreadsheet details the energy costs savings projected for the CHP Plant.

CHP Running Regime Variables 15 hrs Daytime Running Hours 0 hrs Nightime Running Hours 105 kW CHP Electrical Output 0 kW CHP Nightime Electrical Output 4206 hrs Annual Daytime Operating Hours (assume 20% weekends) 0 hrs Annual Nightime Operating Hours 0.02418 € Cost of Gas per kWh (Bord Gais D & C 2 Tariff) 175 kW CHP Heat Output Daytime 0 kW CHP Heat Output Nightime 350 kW CHP Gas Consumption Daytime 0 kWh CHP Gas Consumption Nightime 30% CHP Electrical Efficiency 50% CHP Thermal Efficiency 90% Thermal Load Factor (i.e. amount of CHP Heat used by Cadburys)

Energy Centre Ouput: CHP Heat and Electricity Production 1,472,016 kW kW Gas consumed 35,593 € Cost of gas 662,407 kWh Quantity of heat provided to Cadburys 883,210 kWh Derating Factor For Existing Burner Efficiency (75% assumption) 21,356 € Value of Heat provided to Cadburys 441,605 kWh of Electricity produced annually

Net Energy Cost Savings Produced by CHP Energy Centre Per Year 36,397 € D ay Fortime inspection El purposesectric only.ity Value (@ 8.242c/kWh) Consent of copyright owner required for any other use. 0 Nightime Electricity Value 36,397 € Electricity Value Total 21,356 € Value of CHP Heat Provided to Cadburys (90%) 57,753 € Total Gross Energy Savings -35,593 € Minus Costs of Natural Gas -5,257 € Minus CHP Maintenance Costs 16,903 € YEAR Nett CHP Cost Savings

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OPTION 1: CHP INVESTMENT PAYBACK SUMMARY

Capital Purchase Appraisal Summary Total Euro CHP Capital Investment Cost €127,000 (includes Capital Cost of Supply Items)

Net CHP Savings € 16,903

Simple Payback Period 7.5 Years

Investment Cashflow Statement Years 1 -10

Net Present Value Calculation Discount Factor r 4%

Year 1 Year 2 Year 3 Year 4 Year 5 Net cash flow -€ 110,097 € 18,022 € 19,212 € 20,479 € 21,826 Discount factor 0.96 0.92 0.89 0.85 0.82 PV -105,863 16,662 17,080 17,505 17,939 NPV -105,863 -89,201 -72,121 -54,615 -36,676

Year 6 Year 7 Year 8 Year 9 Year 10 Net cash flow € 23,259 € 24,782 € 26,402 € 28,124 € 29,956 Discount factor 0.79 0.76 0.73 0.70 0.68 PV 18,382 18,832 19,292 19,760 20,237 NPV -18,295 538 19,829 39,589 59,826

For inspection purposes only. Consent of copyright owner required for any other use. Additional Non-Capital Costs

Misc Installation materials, labour & Commissioning Costs € 13,000

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Option 2: CHP Plant for Steam Boiler Feed Tank & K8 Pumphouse Boiler

Overview Depending on the volume of top-up water supplied to the Boiler Feed tank, the additional heat sink of the K8 Pumphouse Boiler will further ensure that the CHP plant thermal output is fully leveraged. In this installation scenario, a single Microturbine CHP plant would be installed inside the existing Steam BoilerHouse. An insulated, 3000litre buffer tank would be installed (external) on the Boiler Make-Up Water Feed line, before the (steam) Boiler Feed tank. The CHP plant would pump LPHW from this tank through the CHP plant’s integral heat exchanger and back into the buffer tank. In addition, flow and return LPHW line would be piped to a 50kW heat exchange plate located in the K-Block Boilerhouse, which would govern the transfer of CHP heat to the K8 boiler circuit. This installation would provide 105KW synchronized electrical supply to the Cadbury’s switchgear, and up to 175kW thermal output (depending on the Boiler Feed flow requirements) to the Steam Boilerhouse and K8 Boiler circuit. Due to the nature of the two individual, distributed boiler systems the CHP thermal supply to the boilers would need to be provided via a Heat Exchange skid (with associated pumps (primary & secondary), actuator and temp controls) feeding off a CHP header to the K8 circuit configuration.

Given the connection of two heat sinks in this installation scenario, it is assumed that 100% of the 175kW thermal output of the CHP plant will be transferred to these circuits for the purposes of conservative energy savings calculations.

Installation considerations There are no technical barriers to the CHP and district heating connection installation. For inspection purposes only. Consent of copyright owner required for any other use.

K8 Boiler Feed Tank

Steam Boiler CHP Plant Make-Up Buffer Tank

Boiler Feed Make-Up Supply

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OPTION 2: ESTIMATED ENERGY COST SAVINGS

The following spreadsheet details the energy costs savings projected for the CHP Plant

CHP Running Regime Variables 15 hrs Daytime Running Hours 0 hrs Nightime Running Hours 105 kW CHP Electrical Output 0 kW CHP Nightime Electrical Output 4206 hrs Annual Daytime Operating Hours (assume 20% weekends) 0 hrs Annual Nightime Operating Hours 0.02418 € Cost of Gas per kWh (Bord Gais D & C 2 Tariff) 175 kW CHP Heat Output Daytime 0 kW CHP Heat Output Nightime 350 kW CHP Gas Consumption Daytime 0 kWh CHP Gas Consumption Nightime 30% CHP Electrical Efficiency 50% CHP Thermal Efficiency 100% Thermal Load Factor (i.e. amount of CHP Heat used by Cadburys)

Energy Centre Ouput: CHP Heat and Electricity Production 1,472,016 kW kW Gas consumed 35,593 € Cost of gas 736,008 kWh Quantity of heat provided to Cadburys 981,344 kWh Derating Factor For Existing Burner Efficiency (75% assumption) 23,729 € Value of Heat provided to Cadburys 441,605 kWh of Electricity produced annually

Net Energy Cost Sav i ngs Pr For oducedinspection purposes by only. CHP Energy Centre Consent of copyright owner required for any other use. Per Year 36,397 € Daytime Electricity Value (@ 8.242c/kWh) 0 Nightime Electricity Value 36,397 € Electricity Value Total 23,729 € Value of CHP Heat Provided to Cadburys (90%) 60,126 € Total Gross Energy Savings -35,593 € Minus Costs of Natural Gas -5,257 € Minus CHP Maintenance Costs 19,275 € YEAR Nett CHP Cost Savings

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OPTION 2: CHP INVESTMENT PAYBACK SUMMARY

Capital Purchase Appraisal Summary Total Euro CHP Capital Investment Cost €135,000 (includes Capital Cost of Supply Items)

Net CHP Savings € 19,275

Simple Payback Period 7.0 Years

Investment Cashflow Statement Years 1 -10

Net Present Value Calculation Discount Factor r 4%

Year 1 Year 2 Year 3 Year 4 Year 5 Net cash flow -€ 115,725 € 20,537 € 21,879 € 23,305 € 24,822 Discount factor 0.96 0.92 0.89 0.85 0.82 PV -111,274 18,988 19,450 19,921 20,402 NPV -111,274 -92,286 -72,836 -52,915 -32,513

Year 6 Year 7 Year 8 Year 9 Year 10 Net cash flow € 26,434 € 28,148 € 29,970 € 31,906 € 33,965 Discount factor 0.79 0.76 0.73 0.70 0.68 PV 20,891 21,390 21,899 22,417 22,945 NPV -11,622 9,768 31,667 54,084 77,029

Additional Non-Capital Costs

Misc Installation materials, labour For inspection & Commissioning purposes only. Costs € Consent of copyright owner required for any other use. 20,000

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Appendix F EPA Correspondence

EPA Response on Carbon Reduction due to CHP Operation

Depending on the start date of the project the projected emissions arising from the CHP plant would be based on the following approach as recommended in the NAP: Using "Best New Entrant" CCGT power plant (CER 2004), on the assumption that the operator to runs the plant continuously.

(Gross electrical output MWh / BNE efficiency for CCGT of 53.4%) x (number of hours per year, 8760 x CER recommended capacity availability, 90.87%) x (Emission factor for natural gas, 57.26 tCO2/TJ / conversion factor of MWh to TJ, 277.778).

To give the following:

1. Gross rated output as mWh / 53.4% = Nx mWh 2. 8760 hrs x 90.87 % = 7960.212 hours run 3. 57.26 / 277.778 = 0.206

However, it is noted that the plant would run to a total of 441.605 mWh so the equation would be

1. 441.605 / 53.4% = 826.979 mWh displaced 2. 57.26 / 277.778 = 0.206

= 170 tCO2

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References

1 Cadburys Ireland Ltd., September 2002, Energy Audit, Integrated Engineering Consultancy Ltd.

2 Cadburys Ireland Ltd., February 2003, Pilot Study as part of the Technical Agreement of the Governments Climate Change Strategy, Integrated Engineering Consultancy Ltd.

3 www.epa.ie

4 Profiling Energy Consumption & CO2 Emissions in Industry, October 2003, Sustainable Energy Ireland

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EPA Export 25-07-2013:20:50:43 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:44 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:44 EFFLUENT RESULTS FOR 2006 Date Daily Flow Temperature pH BOD COD Suspended Solids Oils/Fats/Greases Phosphate MBAS (m3/day) (C) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l)

Licence 700 42 6 - 10 3,000 6,000 1,500 600 50 100 05-Jan 253 7 to 18C 6 800 1295 570 152 3 0.88 17-Feb 140 7 to 18C 6 1261 2450 596 257 5 0.0 16-Mar 148 7 to 18C 6 1680 2820 344 14 5 0 26-Apr 224 7 to 18C 6 2,188 2785 340 116 5 0.3 04-May 254 7 to 18C 6 4884 7230 600 95 7 0.05

EFFLUENT RESULTS FOR 2005 Monitor 1 and 2 Date Daily Flow Temperature pH BOD COD Suspended Solids Oils/Fats/Greases Phosphate MBAS (m3/day) (C) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l)

Licence 700 42 6 - 10 3,000 6,000 1,500 600 50 100 No results for Jan No results for Feb 30-Mar 270 22 7 2,718 3,450 940 51 9 6.5 28-Apr 222 15 7 2479 3720 635 130 6 0.2 25-May 98 19 7 3994 4190 1335 154 14 0.2 23-Jun 177 8 7 4625 4,700 55 152.0 11 0.0 21-Jul 128 18 6 4,645 5,590 1,967 182 14 0.02 22-Aug 120 6 to 22C 7 4645 5590 1967 182 14 0.2 08-Sep 343 6 to 22C 7 2988 3715 1188 260 11 0.2

08-Dec 291 7 to 18C 6 2271 3100 220 33 1 0.05 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:44

SITE NOTICE APPLICATION TO THE ENVIRONMENTAL PROTECTION AGENCY FOR A LICENCE

Address: Cadbury Limited Malahide Road Coolock Dublin 5

Site Location: Cadbury Limited Malahide Road Coolock Dublin 5

Section 7.8 (a) of the Protection of the Environment Act 2003 “Treatments or processes for the purposes of the production of food products from:

a) Animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day”.

All relevant information rela ting to theFor inspection effects purposes on the only. environment in support of this Consent of copyright owner required for any other use. Application will be submitted to the Agency with this Application.

A copy of the Application for the Licence may be inspected or obtained from the headquarters of the Agency as soon as practicable after the receipt by the Agency of the Application for the Licence.

EPA Export 25-07-2013:20:50:44 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:44

Dublin City Council Ground Floor Block 4 Planning Registery Civic Offices Wood Quay Dublin 8. 2006-09-11

Dear Sir/Madam I wish to drawn your attention to the fact that we are required to apply for an IPPC Licence with the EPA. I attach a copy of the advertisement which will appear in the Independent News Paper and the Evening Herald on Tue 12th Sept. I also attach a copy of the site notice which will be erected on the site on Tue 12th Sept. Should you have any queries please do not hesitate to contact me at Ph 8480000.

For inspection purposes only. Consent of copyright owner required for any other use.

Sincerely Yours.

Environmental and Site Safety Manager

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. ENVIRONMENTAL MANUAL

SECTION NO. ENVIRONMENTAL MANAGEMENT REVISION NO. DATE PAGE 1.2 4 SYSTEM REQUIREMENTS 19-Apr-2006 2 of 25

4.2 ENVIRONMENTAL POLICY

4.2.1 The management of Cadbury Ireland Ltd (Coolock). has adopted a policy of operating an Environmental Management System which complies in every respect with the requirements of ISO 14001. It is corporate policy to continuously operate to this standard.

4.2.2 It is also corporate policy to use the management system to quality for certification to the ISO14001 standard.

4.2.3 Cadbury Ireland Ltd. will ensure that this policy statement is clearly understood, implemented and maintained at all levels of the company, is not publicly available and is applicable to all its activities and products and their associated environmental impacts.

4.2.4 Cadbury Ireland Ltd is committed to a policy of continual assessment and improvement of it's environmental performance as measured by the quantified objectives and aims to reduce impacts on the environment to levels corresponding to those which would arise from the economically viable application for the best technology available.

For inspection purposes only. Consent of copyright owner required for any other use. 4.2.5 The management of the company will do all in its power to ensure adequate equipment, personnel, training and facilities are available for creating, sustaining and improving quality in the company's working environment. 4.2.6 The environmental policy statement is reproduced in the following page of this section. All employees have been familiarised with the contents of the statement during training sessions.

4.2.7 The Company is committed to the prevention of pollution.

Originated By: Thomas Byrne. Approved By:

Signature: Signature:

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Title

Dublin Factory

Cadbury Ireland Ltd.

2006.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

1. Factory Energy Usage. 2. Aqueous Discharges. 3. Total Packaging / Solid Waste. 4. Hazardous Materials. 5. Occupational Exposure to Noise & Chemicals. 6. Site Water Usage. 7. No-Mould Water Usage. 8. Use of Contractors. 9. Cooling Towers & Legionella. 10. Domestic Water Systems & Legionella. 11. Emissions to Atmosphere. 11b. Supply Chain Activities 12. Product / Packaging Design. 13. Visual Impact of Site 14. Hazardous Waste 15. Environmental Noise.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Identification of Aspects and Ranking system.

The decision as to whether an aspect is significant or not lies solely with the Environmental Manager in consultation with Cadbury management. The determination of the significance of an environmental aspect is based on simple risk assessment methodology or failure mode and effect analysis The Frequency of Occurrence of the aspect is denoted by the letter F and a numerical value between one (i.e. rare) and ten (i.e. regular/consistent, e.g. discharges) is assigned. The Likelihood of Loss of Control is denoted by the letter L. A numerical value between one and ten is assigned, where a value of one indicates control loss is highly unlikely and a value of ten indicates control loss is highly likely.

The Severity of Consequences of each environmental aspect is denoted by the letter C and is assessed using the following decision making criteria: (1.) to (v1): Legislative and Regulatory compliance Community/Employee sensitivity Impact on air, land or water Cost benefit reasons, e.g. insurance liability, strategic concern Potential for resource depletion Potential for an Accident to occur.

A score for Severity of Consequences (C) is calculated for each Aspect by assigning a score under each criterion in the following manner:

Legislative and Regulatory compliance: Not regulated / no legislative requirement = 1 point Moderately regulated and compliant = 2 points Strictly regulated / legislated and compliant = 3 points Strictly regulated / legislated and occasionally non-compliant = 4 points Strictly regulated / legislated and consistently non-compliant = 5 points

Community / Employee Sensitivity: No observed reaction = 1 point Sporadic complaints For inspection purposes only. = 2 points Consent of copyright owner required for any other use. Widespread complaints = 3 points Vigorous community / employee action = 4 points Permanent injury or death caused = 5 points

Impact on Air, Land and Water: No measurable impact on environmental media = 1 point Local nuisance, e.g. odour, dust = 2 points Short term adverse impact on environmental media e.g. fish kill = 3 points Long term adverse impact on environmental media, = 4 points Permanent damage to environmental media or ecosystem, e.g. irrevocable = 5 points damage to potable groundwater sources.

Cost Benefit Reasons: Major financial saving to the company = 1 point Minor financial saving to the company = 2 points No financial cost to the company = 3 points Minor financial cost to the company = 4 points Major financial cost to the company = 5 points

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Potential for Resource Depletion: No depletion of natural resources = 1 point Some depletion of renewable natural resources, e.g. paper/water usage = 2 points Some depletion of non-renewable natural resources e.g. gas, oil usage = 3 points Large scale depletion of renewable natural resources = 4 points Large scale depletion of non-renewable natural resources, = 5 points

Potential for Accidents to take place: Very slight risk of having an accident. = 1 point There is a chance of having a minor accident as a result of activity = 2 points Risk of having an accident is real but will not result in a major incident = 3 points The potential for having an accident which will require a full investigation = 4 points and possibly lead to a claim or prosecution being made. Will result in emergency response with strong implications for the firm. = 5 points

The sum of the decision making criteria scores for each environmental aspect is deemed to be the numerical value for the C factor which represents the potential Severity of Consequences.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Calculation of Significant Rating.

Impact Environmental Impact Frequency Liklihood Severity of Significance Number Of Of Consequences Rating. And Occurance Control S Rank. Loss. C = Sum of Criteria. S = FxLxC 1 – V1 1 Factory Energy Usage. 10 10 5 3 5 5 5 3 2600

2 Aqueous Discharges. 10 9 5 4 5 5 5 2 2340 3 Total Packaging / Solid 10 9 4 4 4 5 5 2 2160 Waste 4 Hazardous Materials 10 9 3 5 4 5 3 3 2070

5 Occupational exposure 10 7 5 5 5 5 3 5 1960 to noise and chemicals

6 Site Water Usage 10 9 4 3 4 4 4 1 1800

7 No – Mould Water 10 7 4 5 4 5 4 1 1610 Usage 8 Use of Contractors 10 7 4 2 4 5 4 3 1260

9 Cooling Towers & 10 5 2 5 4 5 3 5 1200 Legionella 10 Domestic Water Systems 10 5 4 2 3 5 4 4 1100 and Legionella

11 Emissions to 10 6 5 1 1 5 5 1 1080 Atmosphere

11b Supply Chain Activities 10 6 4 4 4 3 2 1 1080

For inspection purposes only. 12 Product – packaging Consent of copyright 7 owner required 5 for any other3 use. 3 3 5 5 1 700

Design

13 Visual Impact of Site 10 3 2 3 4 4 3 2 540 14 Hazardous Waste 7 3 3 2 4 5 3 3 420

15 Environmental Noise 4 3 2 2 1 2 1 1 108

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 1 Activity: Energy 1.0 The main energy sources used by Cadbury Ireland are Electricity, Gas, Oil and water. The total energy consumed by Cadbury Ireland Ltd in 2005 was 57.8 Gwh based on the total consumption of Gas and Electricity. Energy and water is measured weekly and reported by the environmental manager in the environmental files records every four weeks. There is now an automatic update file for electricity and gas, the records are kept on a computer database for each area such as “A”,”B”, “C” and K Block and site services. The figures are compared to the previous years in terms of total Kwh per ton output and charts are updated accordingly. These charts and data are made available to the appropriate stakeholders as deemed necessary by the environmental manager. All of these records are kept on lotus123 and Excel files. Actions to reduce power wastage and water conservation are identified in the management objectives manual, which is based on the aspects as identified in this register. There was an energy audit carried out in 2002 the first since the Niffes report of 1997 and the breakdown of energy consumption as identified in that report has been completed. However the new energy audit conducted in 2002 has outlined a new strategy to save 1% per annum. A new Carbon Tax was introduced in Ireland at the end of 2004 which will add extra cost to our energy bill. We will continue to engage with S.E.I. through in 2006 to find ways to reduce the impact of this tax.

1.1 Oil Supply. Oil is supplied to site as required and it is delivered directly to the main storage tank located beside the boiler house. Both boilers are now running on Natural Gas and there is still a facility to run the boilers on oil if the need arises. The boilers will be fired on oil every month to ensure For inspection purposes only. their availability when theConsent need of copyright arises owner and required a reco for anyrd otherwill use. be kept in the boiler-house log. Little oil

was used or consumed in 2003 and this will be repeated in 2005.

1.2 Water Supply. Mains water is supplied to Cadbury Ireland by Dublin City Council and it is charged at € 0 .789 per M3. Water is used in some of our processes such as Caramel Making, Crème making and washings of moulds and floors etc. It is also used for heating systems and for cooling towers make-up. DCC carried out a mass balance use of water on the Cadbury site during 2002 and the results show areas where savings can be made. The report is kept by the environmental manager and its findings will be included in the management programme for 2003 to 2006.

EPA Export 25-07-2013:20:50:44 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5 Evaluation Of Impacts. Energy and water is considered the first most significant impact under the following headings.

Aspect : Energy usage relates directly to the burning of fossil fuels and the depletion of natural resources

Associated Impacts Air pollution, land and water pollution as a result of spent fossil fuels and leaking condensate lines.

Score Frequency, F F = 10 Energy is used daily, 365 days of the year in the factory.

Likelihood of Loss of Control, L L = 10

There is the possibility of loss of control of energy usage especially at weekends when plant and machinery is left running when there is no production. This is evident from the amount of energy consumed in the plant, there are often two or more air compressors running to keep up with leakage demand.

Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 5 There is currently no legislation governing the us of energy within the European Union. For inspection purposes only. Save 11, is the most recent EU nonConsent technica of copyrightl prog ownerram aimrequireded forat anyprom otheroting use. the rational use of energy within the community. Implications for Cadbury Ireland is that it is a voluntary program in which companies may participate in if they wish. A summary of the SAVE program is included in the Legal register, section 7 pages 2 to 4. A Co2 tax will be introduced in 2004.

Community/Employee Sensitivity All of the energy sources being used by Cadbury Ireland Ltd are being used throughout the community and would not generate any great concern amongst employees or the local community.

However under commitment 3 in the Cadbury Schweppes GEM we are to “adapt programs to ensure efficient use of raw materials and natural resources across all segments of our business and 3 to minimize the quantify of waste pollutants associated with our activities. In 2001 John Brock issued an instruction to all CS business units to save 1% energy per annum over a 10 year period.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5 Impact on Air, Land and Water 5

The use of electricity, oil and gas results in the generation of smoke, CO2, CO, Nox, and SO2. which cause the following negative impacts on air. • Smoke - Visibility Impairment. • CO - Air Quality. • Nox & SO2 - Acid Rain • CO2 -Greenhouse Gas. For steam generation Cadbury Ireland Ltd is using natural gas which is a clean and convenient fuel. Both Boilers are now fully automated and are controlled by Hamworthy controls for better efficiency.

Cost Benefits 5 Excessive usage and waste of these resources will result in increased costs to Cadbury Ireland Ltd. Electricity usage in 2002 cost the company €1610218, and gas usage cost €805318- A one percent saving in each of these fuels would save the company £24155- per annum based on current costs.

Potential for Resource Depletion 5 .There is a substantial usage of oil, natural gas and other natural resources used in the generation of power and heat. Therefore it is important that these be used efficiently and only as required.

Accidents and Emergency. 3 Not a major issue with this aspect.

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 26 Significance Ratings S = F x L x C S = 2600

Management For inspection purposes of only. this activity by: Consent of copyright owner required for any other use. Objective No.:1 To reduce energy usage by 1% in 2003 Procedure(s): EP 17.01 & EP 09.01, EP.07.01 Monitoring & In accordance with procedure EP09.01 Measurement:

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 2 Aqueous Discharges Activity The factory uses a lot of water for washing & cleaning plant on an ongoing basis, we have been issued with a licence from Dublin City Council and we must remain within the set parameters.

Aspect Process and washdown water from various parts of the factory enters the foul waste drains and is routed through the monitoring stations located at the Cocoa Blocks. The only treatment carried out on the effluent is within the various grease traps. Bacteria is fed into the traps on a daily basis and air is pumped to help the bugs to live and to operate at optimal efficiency. This treatment helps with Ph correction and the reduction of the loads within the traps. Two of the plants which place most of the load on the traps are Eclairs and Boost which cook caramel.

Associated Impacts DCC are particularly sensitive with regards to Ph being below 6 and above 10 our licence limits and have instructed us to correct the levels. Large amounts of water lead to higher effluent treatment charges and wastage associated with it.

Score Frequency, F F = 10 Water is used on an ongoing basis and the frequency is awarded a factor of ten.

For inspection purposes only. Likelihood of Loss of Control, LConsent of copyright owner required for any other use. L = 9

Untreated effluent leaves the plants especially when there are wash-downs and during CIPs. The effluent will pass through a grease trap on the line of discharge and then through one of the two monitors. The likely-hood of loss of control; can be quite high as there is a high dependence upon the operators not to dump product in tanks etc. Since operators have not had any training yet there is a higher likelihood of fugitive emissions.

Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 5 Discharges must comply with the parameters as laid down ing the effluent discharge licence. Dublin City Council (Water Pollution) Acts 1997 and 1990.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Community/Employee Sensitivity 4 Records are kept by the Environmental Manager and are returned to the DCC offices where they are kept on file. The public office files are open to the public and can be viewed on request, adverse publicity could result if we exceed our licence levels.

Impact on Air, Land and Water 5 Excessive levels of effluent will result in fines or prosecution.

Cost Benefits 5 Prevention of loss to the drains will save significant levels of money.

Potential for Resource Depletion 5 There is the potential for losses of water, ingredients, energy and detergents during wash-downs.

Accidents and Emergency 2 No significant danger of accidents.

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C =26 Significance Ratings S = F x L x C S = 2340 Management of this activity by:

For inspection purposes only. Objective No.: 3 3 Consent of copyright owner required for any other use.

Procedure(s): EP.27.01 Monitoring & Measurement:

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 3 Total Packaging Waste / Solid Waste. Activity Total Packaging Waste. Description : Packaging and Solid waste arises as a result of the activities in the Coolock Factory. Seven hundred and eighty tons are generated which have to be handled and dealt with. Aspect Packaging waste is a particularly sensitive issue in Ireland at present and landfill sites are being reduced in number which is resulting in increased costs. The Waste management act 1996 is rigorously implemented and pursued by the authorities. The main packaging generated on site are, Cardboard, Plastic, Timber, Metal, Glass etc.

Associated Impacts Litter nuisance has a high visual impact on the public and can result in complaints from the local authorities etc.

Score Frequency, F F = 10 Waste is generated at about 55 tons per week including packaging waste, canteen waste, shell waste and animal feed. Packaging waste is segregated in the new recycle centre etc. Likelihood of Loss of Control, L L = 9 Solid waste is collected by a number of licensed contractors and transported to the various waste outlets. There is always the possibility of spillage which could result in a non compliance complaint etc. For inspection purposes only. Consent of copyright owner required for any other use. Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 4 The waste management act 1996, the litter act 1997 and all of the instruments place the onus on the producer to comply fully with laws. To reduce the likelihood of a prosecution in this regard, Cadbury Ireland carry out an audit of the various contractors annually

Community/Employee Sensitivity 4 Any litter spills associated with the handling, removal and transport of packaging waste from site and during all of the process stages, segregation etc could generate a nuisance for all of our stakeholders. Impact on Air, Land and Water 4 Leaking landfills could lead to leaching of toxins and other pollutants etc. Most of the Cadbury waste being sent to landfill consists of Oven Dross, and canteen waste, everything

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Tom Byrne Signed by Environmental Manager.------Revision Number 5 else is being recycled.

Cost Benefits 5 The handling, segregation and processing of waste is expensive business but landfilling is no longer an option as costs are increasing at an alarming rate. By segregating at source there are large savings to be made in future against these rising costs. Potential for Resource Depletion 5 With packaging waste there is a high likelihood of depleting resources due to the composition of the materials and the use of special inks. Accidents and Emergency 2 There is little chance of accidents in the use of packaging materials.

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 24 Significance Ratings S = F x L x C S = 2160 Management of this activity by: Objective No.: 2 Procedure(s): EP.28.01 Monitoring & Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 4 Hazardous Materials. Activity Hazardous materials are stored on site some of which are used during the production process, a full list of materials are kept by the laboratory manager and an MSDS register is also kept. A variety of laboratory chemicals are stored on site in small quantities, pesticides by the gardeners and some refrigeration gases are kept and used for product cooling purposes etc.

Many of the chemicals used in the plant are classified as hazardous materials, and due care is required in handling these materials. Adequate facilities for the storage of these materials is in place and all hazardous materials are kept within the compound. Chem-store units were specifically purchased for the storage of hazardous materials and the keys for the units are located in the engineering stores, with security and the site services manager.

Associated Impacts The proper storage of these materials is essential to ensure against accidents and fugitive emissions of these materials which could pollute the river.

Score Frequency, F F = 10 Hazardous materials are handled on a daily basis by stores staff and other operators across the factory. On this basis a score of nine has been awarded to this aspect

Likelihood of Loss of Control, L For inspection purposes only. L = 9 Consent of copyright owner required for any other use. Without the proper bunded storage facility there is a strong likelihood that an accidental spillage can happen either by something being knocked over, or during emptying or filling containers etc.

Severity of Consequences, C Sub-Totals Legislative and Regulatory 5 The dangerous substances act which relates to the storage on site and use by activities of dangerous substances. Cadbury Ireland must take all practical steps to prevent risk of injury to persons or property from such substances being stored, handled or transported on site. A comprehensive summary of the relevant act and amendments is contained in the legal register.

Community/Employee Sensitivity 5 The incorrect handling, storage or treatment of hazardous materials could constitute an occupational Health and safety risk to employees. This could be manifested in inhalation, skin irritation, eye contact or as a carcinogen etc.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Impact on Air, Land and Water Any spillage of such materials would mainly arise under emergency conditions. Better storage 4 and tighter control procedures are required to ensure against pollution to land, air & water.

Cost Benefits 5 An accident on site could result in an insurance liability and or prosecution by the Local Authority.

Potential for Resource Depletion 3 Three is some scope for resource depletion but not to any great extent through over-use or leakage etc.

Accidents and Emergency 3 The handling and use of detergents or chemicals could lead to an accident if personnel were not trained or were not wearing the appropriate safety clothing and protection gear. Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 25 Significance Ratings S = F x L x C S = 2025 Management of this activity by: Objective No.: 4 To ensure that all hazardous materials are stored safely in the Hazmat – compound. Procedure(s): EP 15.01 & EP 16.01, EP.26.01 Monitoring & Weekly inspections. For inspection purposes only. Measurement: Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 5 Occupational Exposure to Noise and Chemicals. Activity The main occupational exposure issues identified by the company in the safety statement as follows, (1) Occupational Exposure to noise. (11) Occupational Exposure to chemicals. Aspect Noise. Areas within the factory have been identified with noise levels above 90dB, notices for the compulsory wearing of ear protection have been posted. Chemicals. There are a number of areas within the factory where chemicals being used have an associated risk for example in the Hazardous materials store. Associated Impacts Noise levels within the factory are being reduced systematically and on an ongoing basis, the introduction of head sets with built in radios is one such example. Where chemicals are being used personal protective clothing is provided, however training in the handling of these chemicals could be improved. Score Frequency, F F = 10 Some staff are either exposed to constant noise or the handling of chemicals or detergents on a regular basis.

Likelihood of Loss of Control, L For inspection purposes only. L = 7 Consent of copyright owner required for any other use. Noise exposure is a greater risk than exposure to chemicals as chemicals are used in-frequently but the background noise effect is continuous. Likelihood of loss of control is not a major concern due to the procedures which are in place. Hearing tests are being carried out on all staff in 2006.

Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 5 There is lots of legislation in place to cover the occupational hazard of being exposed to both noise and chemicals. Community/Employee Sensitivity High noise levels are irritating to staff having to work in such areas and require regular monitoring to 5 ensure compliance with regulations. Any accidents concerning chemicals would also attract a wide audience especially if there was a serious accident. Impact on Air, Land and Water Any chemical spills would give cause for concern, but chemicals are covered by procedures. 3 Internal noise pollution does not attract any notice from the community at present.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Cost Benefits Good applied procedures could help offset costly litigation from persons affected in hearing or chemical 5 burns. Potential for Resource Depletion Chemical usage necessitates the use of valuable resources. 3

Accidents and Emergency Any accidents arising out of chemical handling will result in at least an internal inquiry or if serious 5 enough from an external body such as the HSA. Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 26 Significance Ratings S = F x L x C S = 690 Management of this activity by: Objective No.: Procedure(s): EP.07.01, EP.10.01, EP.14.01, EP.15.01, EP.18.01, EP.19.01 EP.22.01 EP.26.01 Monitoring & Noise monitoring on an annual basis. Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 6 Site Water Usage. Activity : Water is used across the factory for domestic use cleaning in place, toilets, washing, Cooling towers make-up and for the hot-well make up at the boiler house. Aspect : The use of water whether hot or cold adds to the loading on the effluent discharges as well as adding cost to the Utilities site-wide. Associated Impacts Hot water usage contributes to Co2 emissions and will in future represent higher costs etc. Score 1 to 10 Frequency, F F = 10 Water is used every day on plants across the factory Likelihood of loss of control, L L = 9 Water hoses are left running frequently and sometimes there are fugitive emissions from the plants. Severity of Consequences, C Score I to 5 Sub-Totals Legislative and Regulatory Control. 4 Effluent discharges are subject to the conditions attached to our effluent trade licence. Community/Employee Sensitivity 3 All of our effluent results are sent to the offices of the Dublin City Council and can be inspected by members of the public if requested. Impact on Air, Land and Water 4 Polluted water has to be treated at the new facility at Ringsend Dublin by DCC at a cost to us, hot water For inspection purposes only. uses energy and contributes to Co2Consent pollution. of copyright owner required for any other use.

Cost Benefits : 4 All energy sources are expensive and this adds cost to the supply chain for the business. Potential for Resource Depletion 4 Clean water is a precious resource and the effluent leads to waste of resources in the treatment chemicals etc. Accidents and Emergency 1 Hot water can burn people or unlagged pipe associated with hot water can lead to an accident. Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 20 Significance Ratings S = F x L x C S = 1800 Management of this activity by: Objective No.: 5 Procedure(s): EP17.01 Monitoring & As stated in procedure EP 17.01 Measurement:

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 7. No – Mould Water Usage Activity Water consumption within the No – Mould Plant is excessive and most of it goes to waste whilst it used to maintain vacuum on the cooker.

Aspect Water wastage on the scale of the eighty cubic meters per day is costly to the tune of €20000 per annum to buy and another € 11200 per annum for treatment costs. The loading of this on the drains puts strain on the interceptor to which we add bacteria for the correction of Ph. Associated Impacts Precious resource depletion and added cost to the facility.

Score Frequency, F F = 10 Water is used each day the plant is run Likelihood of Loss of Control, L L = 7 If water being left running when the plant is stopped then this plant suffers from loss of control. (1) Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 4 Little legislative control over this water as it runs to drain clear. Community/Employee Sensitivity Community is becoming more sensitive to waste water as it is expensive to prepare by the 5 For inspection purposes only. authorities. Consent of copyright owner required for any other use.

Impact on Air, Land and Water When the water is contaminated by the process then it can add to water pollution and treatment. 4 Cost Benefits Waste water is expensive we pay for the water and we pay DCC for treating the waste water. 5

Potential for Resource Depletion The potential for resource depletion is high even though it is a renewable resource. 4

Accidents and Emergency 1 There is little opportunity for accidents with the water as it is at supply temperature.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 23 Significance Ratings S = F x L x C S = 1610 Management of this activity by: Objective No.: 7 Procedure(s): EP.27.01 Monitoring & Indications via the monitors on site. Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 8 Use of Contractors Activity Use of Contractors. Cadbury Ireland uses contractors on some of the new large projects and for general installations. Aspect There is a likelihood that any contractor can through accident or otherwise cause an environmental incident. There is also the possibility that a contractor could introduce a prohibited material that could cause a pollution incident through fugitive emissions etc.

Associated Impacts Any fugitive emission could lead to an incident which could draw the company into a pollution incident etc.

Score Frequency, F F =10 Contractors attend the factory on a daily basis, they are frequently used in different functions.

Likelihood of Loss of Control, L L = 7 There is an average chance of the likelihood of the loss of control while using contractors. Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 4 Little chance of regulatory control as all contractors are briefed and indoctrinated on site conditions.

Community/Employee Sensitivity For inspection purposes only. 2 Consent of copyright owner required for any other use. Little or no impact here. Impact on Air, Land and Water 4 Any dumping of materials down drains could lead to water pollution.

Cost Benefits 5 Pollution could prove very costly. Potential for Resource Depletion 4 Materials are frequently being used by contractors which does lead to the depletion of resources.

Accidents and Emergency 3 There is seldom accidents with contractors but there is always the possibility of one

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 22 Significance Ratings S = F x L x C S = 1200

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5 Management of this activity by: Objective No.: 9 Procedure(s): EP.13.01 Monitoring & Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 9 Cooling Towers & Legionella. Activity There are nine Cooling towers installed in the factory for supplying cooled water to refrigerant plants which cool the product. Within each tower there is the potential for the growth of bacteria and other water based bugs etc, these can grow out of control if they are not effectively maintained and treated.

Aspect : The possibility of Legionella outbreaks from the towers exist which could prove detrimental to staff and public health. This could result in the closure of the factory and lead to a major investigation by the health authority in conjunction with the National Disease Surveillance Centre.

Associated Impacts Bad publicity and possible close – down of the business could result from a outbreak of legionnaires disease. Score Frequency, F F = 10 Cooling Towers are used all of the time processes are running, so the potential for problems exist at all times.

Likelihood of Loss of Control, L L = 5 There is a rigorous treatment and maintenance regime in place which reduces the chance of any Legionella within the towers. Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 2

There is a new guide line which has only been For put inspection in place purposes by the only. N.D. S.I. this guideline places the onus Consent of copyright owner required for any other use. on the operators and owners of such equipment to protect it against Legionaires Disease. Community/Employee Sensitivity 5 Community awareness of Legionella is low at present, but this will increase in time with the increased reporting of such outbreaks. Impact on Air, Land and Water 4 Chemical dosing can cause pollution through spillage etc. Cost Benefits 5 Treatment and maintenance of towers is expensive, but an outbreak would be disastrous and extremely costly. Potential for Resource Depletion 3 Both chemicals and water are used in cooling towers which are natural resources.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5 Accidents and Emergency At present there is little potential for accidents from the towers or the chemicals being used. 5

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 24 Significance Ratings S = F x L x C S =1200 Management of this activity by: Objective No.: 6 Procedure(s): EP 29.01, EP.26.01 Monitoring & Monthly testing for Bug count & four times per annum for Legionella. Measurement: Weekly testing by Lab for TVCs.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 10 Domestic Water systems & Legionella Activity Water systems are installed in almost every building and pre-fabs, systems which are fed by storage tanks are particularly at risk of harbouring Legionella in any of its forms. The systems feed shower heads are of particular concern as it is these systems which contribute to a large proportion of outbreaks of Legionella among the public. Aspect. Stagnant water covers a number of risk factors such as the build up of solids in the water as sludge. Legionella can grow in sludge and can be harboured against disaffection unless it is conducted correctly. At risk are shower heads which aerate the water into aerosol sprays etc. In this form unsuspecting persons especially the weak, very young or old persons can catch Legionella. Almost 50% of all cases of Legionella are related to persons catching it whilst on holidays, it is therefore essential to have a proper documented system in place to prove you have taken every precaution to protect your staff and the public at large. Associated Impacts With the establishment of the National Disease Surveillance Centre in Ireland any outbreak within a 2 Mile radius of the factory would tend to focus the attention of the national response team. It is a distinct possibility that they would focus on factories firs and put the onus on the site to prove that they are not responsible for the outbreak. Score Frequency, F F = 10 Hot and cold water systems are used on a continuous basis, there is the potential for a problem at any time.

Likelihood of Loss of Control, L L = 5 A contract exists between GE Betz and Cadbury for the sterilization and monitoring of these systems. For inspection purposes only. Consent of copyright owner required for any other use. In-house maintenance of shower heads and showers is also being set up on a formal basis to help reduce risk. Severity of Consequences, C Sub- Totals Legislative and Regulatory Control The N.D.S.I guide lines place the obligation on Cadbury to ensure that all risks are minimised or 4 eliminated. Community/Employee Sensitivity Community awareness of Legionella in Ireland is low at present, but with the recent case in Waterford 2 resulting in a death it is likely to change. Impact on Air, Land and Water He treatment of water to eliminate the risk of Legionella must be carried out under control; 3 conditions to prevent pollution to water-ways.

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Tom Byrne Signed by Environmental Manager.------Revision Number 5

Cost Benefits 5 A single death resulting from a Legionella outbreak would extinguish any treatment cost concerns.

Potential for Resource Depletion Chemicals used for treatment and water usage are both valuable resources. 4

Accidents and Emergency While good control and treatment of the towers is in progress there is little risk fir accidents. 4

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 22 Significance Ratings S = F x L x C S = 1100 Management of this activity by: Objective No.: Procedure(s): EP.29.01 Monitoring & Annual checks in place and annual sterilization. Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 11 Emissions to Athmosphere Activity The principle emissions to atmosphere are combustion gases from boilers. These consist of: 1. The main boiler plant which houses two gas fired steam boilers which can be converted to run on oil, should the need arise. Space Heaters for the factory, office block HWS boilers and a range of gas boilers used to heat the various processes and jacketed pipe-work.

Aspect Both main boilers used for steam generation are within emission limit values as set out in T.A. Luft, the German Air Quality Standard based on the last test carried out sa part of the Niffe audit.Both of our Steam Boilers are fully automatic and are run on natural gas. Both of the steam generating boilers are within the TA Luft standard and are running automatically. All of the gas boilers are run continuously and use natural gas.

Associated Impacts The boilers emit flue gases such as Sox, Nox, CO2 etc. from the first of Jan 2005 Carbon tax will be applied to the running of the Cadbury sites in Europe. Cadbury Ireland has obtained a permit but not the final emission level of CO2 This will not be finalised until mid Summer 2004. Score Frequency, F The boilers are used most of the year and burn fuel for making steam, hot water or for keeping F = 10 jacketed lines warm. The main steam boilers run at 82% efficiency which is excellent based on their age and size. For inspection purposes only. Consent of copyright owner required for any other use.

Likelihood of Loss of Control, L A close eye is kept on the energy usage at the Dublin Site. L = 6

Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 5 The T.A. Luft quality air standard remains the standard for air monitoring from flue stacks. New permits pursuant to the Directive 2003/87/EC applies in the pilot phase from Jan 2005. Community/Employee Sensitivity 1 Communities are not very sensitive to pollution at this time.

Impact on Air, Land and Water To comply with the Kyoto agreement Cadbury Ireland will continue to reduce energy consumption . 1

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Tom Byrne Signed by Environmental Manager.------Revision Number 5 Cost Benefits Energy is continually rising in cost whether in Natural gas supply or electricity costs, any savings will 5 help our competitiveness. Once the new permit system is put in place any exceedences will result in the purchase of Carbon Credits at the market price.

Potential for Resource Depletion The use of natural gas and fossil fuels for the generation of energy results in the depletion of natural 5 resources. Energy conservation is essential to help in the reduction of this loss.

Accidents and Emergency There is little risk associated with this aspect provided all safety procedures are adhered to at all times. 1

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 18 Significance Ratings S = F x L x C S = 1080 Management of this activity by: Objective No.: 1. Procedure(s): EP 17.01, EP.26.01 Monitoring & As per the procedure above. Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 11b Supply Chain Activities. Activity: Supply Side Activities. Suppliers are those companies, which supply goods or services to the company. The goods supplied include processed foods, chemicals, fuels, packaging, lubricants etc.

Aspect : Services rendered include the means by which these companies execute their responsibilities including the disposal of waste, transportation of goods and other aspects of the business.

Associated Impacts The environmental impacts of companies engaged in the manufacture of raw materials which they supply to us are indirect impacts for Cadbury Ireland. Ongoing impacts can only be partially assessed through regular (every 3 years) environmental questionnaires being sent to suppliers for completion.

Score Frequency, F F = 10 The supply of materials to Cadbury Ireland is a daily event.

Likelihood of Loss of Control, L L = 6 Most of our suppliers have had initial approaches made regarding their environmental policies. On at least two occasions we have been approached Forby inspectionlocal authorities purposes only. concerning illegal dumping by these Consent of copyright owner required for any other use. suppliers. Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 4 This is now at a level of high priority with enforcement agencies and local authorities.

Community/Employee Sensitivity 4 At an all time high where litter pollution is concerned, heightened sensitivity due to fines and waste charges being implemented.

Impact on Air, Land and Water 4 Badly maintained transport, illegal dumping on land or in water could have a detrimental effect on land air or water or a combination of these. Cost Benefits 3 The cost of a pollution incident could be high, the associated adverse publicity could be higher.

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Potential for Resource Depletion 2 All materials used have an effect on resource depletion.

Accidents and Emergency 1 Slight risk associated with the delivery and transport streams

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C =18 Significance Ratings S = F x L x C S = 1080 Management of this activity by: Objective No.: 8 Procedure(s): EP 15.01, EP 16.01 Monitoring & Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 12. Product Design. Activity: Product/ Packaging Design & Disposal. New products and especially packaging are designed to enhance the sale of product from the factory. The selection of materials for these products can have an impact on the environment especially when it comes to disposing of them. Aspect Food produce is normally manufactured for consumption and any waste is disposed through the animal feed chain. Packaging and canteen waste is different and must be segregated for recycling or for land-filling. Metal and machinery waste must be dealt with in a different way and must be channelled through the right stream for disposal. All new projects are reviewed under the GEM RAM review method for environmental impacts. (Guideline 16, RAM Signoff) Associated Impacts Air, Water, Noise and Land pollution are all possible consequences of irresponsible handling of waste and indeed the running of new processes. Vigilance is required when designing a new product, process or packaging material, and the end of life of the materials must be taken into account at the design stages. Score Frequency, F F = 7 New designs are reasonably frequent in Ireland and very frequent in Ireland.

Likelihood of Loss of Control, L L = 5 Loss of control is less likely than instances in For the inspection past due purposes to the only. checks which are in place under the Consent of copyright owner required for any other use. guidelines of the GEM Manual.

Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 3 All aspects of new process design, waste materials, hazardous materials and their disposal are legislated for and the controls are rigorous.

Community/Employee Sensitivity 3 Community and employee sensitivities are high where waste is concerned and the transport of waste. Impact on Air, Land and Water 3 Waste has a big impact on the environment as mentioned in aspet 2 earlier in this manual.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Cost Benefits 5 The better thought out the design the more cost effective the finished product, haste makes waste and there is no waste only raw materials misplaced.

Potential for Resource Depletion 5 There is always a great potential for resource waste if the design of a process, product or packaging is done in haste, or if it is not thought through fully.

Accidents and Emergency 1 There is no excuse these days for a hazardous process, or plant without all of the safety implications being taken into account.

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 20 Significance Ratings S = F x L x C S = 720 Management of this activity by: Objective No.: 10 Procedure(s): EP 11.01 Monitoring & Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 13 Visual Impact. Activity The Cadburys plant at Coolock is maintained to a very high standard and blends into the surrounding area. It is company policy to incorporate all Cadbury plants in a garden type environment and the importance of this is imparted to new employees on induction. During construction extreme care was taken in both the selection of the site and the colour schemes for the buildings so that facilities would fit as naturally as possible into its environment. Extensive landscaping has been completed and the buildings and grounds are maintained to the highest standards. Extensive planting on the perimeter of the site has helped to screen the developments. Much effort has been made to provide stable habitats for a variety of flora and fauna. The visual impact of the plant enhances the environmental performance of Cadburys. Cadburys Dublin have received many awards in recognition of the excellent visual impact of the plant. The land surrounding the plant is zoned for industrial development and is occupied by other industries. Aspect Any spillages, paper litter or untidiness would draw the attention of the Dublin City Council which would result in an inspection being carried out.

Associated Impacts We could be prosecuted for litter nuisance or pollution to the Santry River either events could result from the site being untidy and from spillages. Score Frequency, F Materials are handled across the yard hourly and on a daily basis, there are opportunities for spillage F = 10 For inspection purposes only. or for accidents to happen. Consent of copyright owner required for any other use.

Likelihood of Loss of Control, L Loss of control could happen if operators were not trained in environmental matters, 65% of all L = 3 operators are still not trained. Severity of Consequences, C Sub-Totals Legislative and Regulatory Control Spillages, pollution to Rivers and litter nuisances are all comprehensively covered by legislation. 2

Community/Employee Sensitivity Litter and river pollution draw the attention from both the employees and the public at large. 3

Impact on Air, Land and Water 4 There is a high impact associated with pollution, water pollution is prosecutable in the courts, litter pollution is also high on the regulators agenda.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5 Cost Benefits Clean ups and fines can run very expensive 4

Potential for Resource Depletion Resource depletion from this aspect is generally low, unless you have a major disaster on your hands. 3 Accidents and Emergency Low risk generally. 2

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 18 Significance Ratings S = F x L x C S = 320 Management of this activity by: Objective No.: Procedure(s): EP.26.01 Monitoring & Weekly inspections. Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:45 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 14 Hazardous Waste. Activity Sources The main sources of hazardous waste are spent laboratory chemicals, fluorescent light tubes and waste oil and deodoriser fats from the Cocoa Block.

Register of Impacts Wastes are generally stored in controlled areas prior to movement off-site. Only licensed and approved hazardous waste contractors are used to remove hazardous waste off site for recovery, reuse, recycling or disposal. Waste chemicals from the laboratory mainly arise from the chemical oxygen demand test materials which contains chromic, mercuric, chloride, silver, sulphate. A consignment note or C1 form for the consignment of toxic and dangerous waste must be used when disposing of the material off site. Deodoriser fats are collected in UN approved containers and stored safely prior to disposal. Shannon Environmental Services or another licensed contractor takes this material once sufficient quantities have built up. Waste oil from plant machinery, etc. is taken off-site by licensed waste disposal contractors for recycling Copies of permits for the contractor are retained on file. Atlas Oil is the waste oil contractor used by Cadbury Ireland Ltd. Detailed examination of all waste streams generated on site is necessary to confirm correct disposal methods are being used in all cases.

Aspect Hazardous Waste is a direct environmental impact of Cadburys and the environmental impact of waste is considered under the following headings: For inspection purposes only. • Waste Oils. Consent of copyright owner required for any other use.

• Deodoriser fats / contain impurities. • Chemical / toxic waste. • Spent containers. If any of these were to be disposed of incorrectly there could be major implications, political as well as financial. There could also be adverse publicity as a result of improper disposal.

Associated Impacts Public awareness of illegal dumping by waste contractors have added to the whole paradigm surrounding hazardous waste.

EPA Export 25-07-2013:20:50:46 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5 Score Frequency, F F = 7

Hazardous waste materials are handled on a regular basis by trained operatives engineering stores staff such as waste oil, waste oil cloths, flourescent tubes, chemicals and waste detergents etc.

Likelihood of Loss of Control, L L = 3

There is always the odd chance of a mishap when handling waste materials, especially oil based products.

Severity of Consequences, C Sub-Totals Legislative and Regulatory Control 3 Hazardous waste is generated from wastes due to the production activities in the factory and must be disposed of in accordance with the waste management act of 1996 translated into law in 1998. A summary of the relevant acts and instruments is shown on page 7 section 3, in the register of environmental legislation and a full outline of the various acts in pages 1 to 62 of the register. The register is in agreement with the Cadbury Gem Manual section, 1 1.1-5 to 1.1-9. Both of these registers are located with the environmental manager.

Community/Employee Sensitivity 2 Incorrect handling, treatment or storage of hazardous waste could lead to an occupational health and safety risk to employees such as inhalation of fumes or skin contact. This could lead to an For inspection purposes only. accident which could involve the HConsent S A ofa ncopyrightd possible owner litigation.required for any other use.

Impact on Air, Land and Water 4 An accidental discharge of hazardous waste at the site could have consequences for the quality of surface water discharged from site. This would be considered a pollution incident and would then come under the Water Pollution Act 1977. The implications for Cadbury Ireland Ltd is to ensure that all pollutant matter is contained on site, including that arising from emergency situations, accidents or spillage’s.

Cost Benefits 5 An accident involving the transportation of hazardous waste might involve an insurance liability, in addition the onus is on Cadbury Ireland Ltd to ensure that the waste contractor is operating in an appropriate manner.

EPA Export 25-07-2013:20:50:46 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5 Potential for Resource Depletion. 3 Where possible Cadbury Ireland Ltd will recycle all recyclable hazardous in accordance with the BATNEEC EU directive and in line with commitments 4&5 Cadbury Schweppes corporate environmental policy. Failure to so would result in a resource depletion and unnecessary use of raw materials such as solvents etc. Accidents and Emergency 3 Tight control in accordance with the relevant legislation is required to ensure against accidents.

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 20 Significance Ratings S = F x L x C S = 420 Management of this activity by: Objective No.: Procedure(s): EP 19.01, EP.03.01, EP.07.01, EP.26.01 Monitoring & Measurement:

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 25-07-2013:20:50:46 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

Environmental Aspect No. 16 Environmental Noise. Activity Sources: There are no external noise sources audible at the Plant boundary. Register of Impacts: Boundary noise levels were measured in Aug 2002 in accordance with ISO 1996. The results are presented in the TMS report ref 00116A Rev 0. Which is held by the environmental manager.

Aspect Sources: There are no external noise sources audible at the Plant boundary. Register of Impacts: Boundary noise levels were measured on the 9th Aug 2002 in accordance with ISO 1996. The results are presented in the TMS report ref 00116A Rev 0. Which is held by the environmental manager. Associated Impacts A noise is liable to disturb people and provoke complaints when its level exceeds the pre- existing ambient level by a certain margin or when it attains a particular absolute value.

For inspection purposes only. People’s reactions to noiseConsent may of copyrightbe influenced owner required by for anyfactors other use. such as:

(a) Noise level; (b) Noise character; (c) Habituation; (d) Degree of control over the noise; (e) Personal sensitivity to noise; (f) Attitude to the source; (g) State of personal health; (h) Activity engaged in; (i) Time of day or night; (j) Character of area; (k) Visibility or otherwise of the noise source; and Seasonality of the operation.

EPA Export 25-07-2013:20:50:46 Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager.------Revision Number 5

The area around the plant is an area with heavy road traffic and much local industry, both of which would contribute to the ambient noise level, a further audit will be carried out in 2004. Score Frequency, F There is little background noise associated with the plant at the perimeter of the factory. F = 4

Likelihood of Loss of Control, L There is little likelihood of loss of control at present, vigilance with regard to the installation of new L = 3 plant must be maintained. Severity of Consequences, C Sub-Totals Legislative and Regulatory Control EU Directive 2004/49/EC the Assessment and Management of Environmental Noise. 2 EPA Act 11992(Noise) Regulations, 1994 (SI No.179 of 1994). Community/Employee Sensitivity Community sensitivity can be acute especially were there a noise keeping them awake at night. 2

Impact on Air, Land and Water Not significant 1 Cost Benefits Not significant 2 Potential for Resource Depletion For inspection purposes only. Consent of copyright owner required for any other use. Not significant 1

Accidents and Emergency Deafness calaims could be significant 1 Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C C = 9 Significance Ratings S = F x L x C S = 108 Management of this activity by: Objective No.: Procedure(s): EP.06.01 Monitoring & Every two to three years by an independent consultant, or in response to an Measurement: enquiry from the EPA.

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