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Bailie Foods Limited Bailieboro, Co Bailie Foods Limited Bailieboro, Co. Cavan, Ireland Telephone +353-42-969 4200 Fax +353-42-966 5534 www.lakeland.ie PO Box 3000, Johnstown Castle Estate, Co. Wexford. January 2012. Dear Sir/Madam, Re: Application For a Technical Amendment by IPPC Licence No. PO406-03 Bailieboro Foods Limited and Bailie Foods Ireland Limited. Bailieboro Foods Limited and Bailie Foods Ireland Limited formally request a technical amendment to IPPC Licence No. PO406-03. As part of the consultation process of requesting the For inspection purposes only. Consent of copyright owner required for any other use. technical amendment, consultation with Ms. Mary Sheehan (EPA Inspector), Mr. Patrick Byrne (EPA Office of Climate, Licensing & Resource Use), Ms. Allison Treanor (Senior Environmental Scientist of Cavan County Council) and Ms. Marice Galligan (Senior Planner of Cavan County Council) was carried out. ExistinP Situation On Site: At present on site, septic tanks service the domestic wastewater requirements of the different areas of the site. After entering the septic tanks, domestic wastewater enters a number of pump sumps. The domestic wastewater is mixed with the process wastewater and is pumped up to Lakeland Dairies Co-operative Society Limited Registered in Ireland. Reg. No. 4622R. EPA Export 17-10-2012:23:24:08 the existing wastewater treatment works (WWTP) and treated in the WWTP on site with the final discharge entering the River Lear. Reason For Technical Amendment Request: As part of the improvements/upgrade of the process WWTP, which is currently ongoing the recycling of the process wastewater cannot have domestic wastewater mixing with process wastewater. It is for this reason that an application for planning permission was submitted to Cavan County Council to install 2 new treatment systems and percolation areas with the 2 new pumping mains. There is also a smaller treatment system and percolation area proposed to service the 2 operatives at the Wastewater Treatment Plant, however the toilet facilities at this location may be removed avoiding the installation of another treatment system and soil polishing filter. Site Assessor to carrv out site suitabilitv assessments in accordance with EPA Guidelines We have contracted Nevin Traynor of Traynor Environmental Ltd who is EPA/FAS Certified to carry out EPA Site suitability assessments. Traynor Environmental Ltd are on the approved panel For inspection purposes only. Consent of copyright owner required for any other use. of site assessors for Cavan County Council. Nevin Traynor of Traynor Environmental Ltd has liased with Ms. Allison Treanor - Environment Section of Cavan County Council and Ms. Marice Galligan Senior Planner with Cavan County Council throughout the project. Nevin has also contacted Mr. Noel Mc Gloin Senior Fisheries Environmental Officer of the Inland Fisheries Office to discuss the proposed works which are outlined below. Lakeland Dairies Co-operative Society Limited Registered in Ireland. Reg. No. 4622R. EPA Export 17-10-2012:23:24:08 Proposed Works It is proposed that the new domestic wastewater treatment systems and percolation areas/soil polishing filters will be constructed in accordance with EPA Guidelines 2009 Code of Practice: Wastewater Treatment Systems for Sinnle Houses and EPA Treatment Svsterns for Small Communities, Business, Leisure Centres and Hotels. From the EPA Site Suitability Assessments which were carried out, it is evident that the site in the areas which were identified as having verv good percolation characteristics, effluent can be treated adequately in accordance with the 2009 Code of Practice Wastewater Treatment and Disposal Systems Serving Single Houses and EPA Guidelines Treatment Systems for Small Communities, Business, Leisure Centres and Hotels. it is proposed to install Treatment Systems which are fully compliant with EN12566- 3:2005 in accordance with Section 5.1 of the above Code of Practice. The expected level of treatment and the expected effluent quality after the proposed Treatment Systems is detailed in Table 1 below. Discussions have taken place with 2 Wastewater Treatment System Suppliers to date namely Mr. PJ Finn of Hydro International and Mr. Diarmuid 0 Reilly of 0’ Reilly Oakstown Ltd. Both treatment systems are fully compliant with EN 12566-3. Table 1- Treatment Efficiency Prior to Soil Polishing Filters in accordance with EN 12566-3 Parameter Efficiency % Effluent Quality For inspection purposes only. Consent of copyright owner required for any other use. COD 93.0% 46mg/l BODS 97.5% 8mg/l NH4-No 61.0% 13mg/l Suspended Solids 96.7% 12mg/l Proposed Amendment Bailieboro Foods Limited and Bailie Foods Ireland Limited is now seeking an amendment to IPPC Licence PO406-03 to install the 2 No. Treatment Systems which are fully EN 12566-3 Certified Lakeland Dairies Co-operative Society Limited Registered in Ireland. Reg. No. 4622R. EPA Export 17-10-2012:23:24:08 and associated soil polishing filters constructed in accordance with EPA Guidelines 2009 as detailed above. The final treated effluent will discharge to ground waters at Lear, Bailieborough, Co. Cavan. Should you require any further information please do not hesitate to contact me. Yours sincerely, Kathryn 0’ Flynn Environmental & Functions Manager For Bailie Foods Ltd For inspection purposes only. Consent of copyright owner required for any other use. Lakeland Dairies Co-operative Society Limited Registered in Ireland. Reg. No. 4622R. EPA Export 17-10-2012:23:24:08 Bailie Foods Limited Bailieboro, Co. Cavan, Ireland Telephone +353-42-9694200 Fax +353-42-9665534 www.lakeland.ie Environmental Protection Agency Office of Climate, Licensing and Resource Use, PO Box 3000, Johnstown Castle Estate, COWexford. Register No. PO406-03 Company Name: Bailieboro Foods Limited Dear Sir/Madam, Re: Application For a Technical Amendment by IPPC licence No. PO406-03 Bailieboro Foods limited and Bailie Foods Ireland limited. For inspection purposes only. Bailieboro Foods Limited and BailieConsent Foods of copyrightIreland owner Limited required formally for any other requestuse. a technical amendment to IPPC Licence No. PO406-03. ExistinP Situation On Site: It has come to our attention that there is a potential anomaly in the permitted air emission volume from the combined heat and power (CHP) plant due to the operation of supplementary firing of the exhaust gases. The data for proposing emission limit values (ELVs) for air emissions from the CHP plant used information provided by the gas turbine manufacturer and were normalised under the following conditions: 273K, 101.3kPa, dry gas and 15% oxygen as required under condition 4.2 of IPPC Licence Register No.PO406-03. When the turbine is operating without supplementary firing there is no issue, as the oxygen concentration in the exhaust gases from the turbine are in range of 15% oxygen and the oxygen correction factor has no significant impact on the air emission volume. Lakeland Dairies Co-operative Society Limited Registered in Ireland. Reg. No. 4622R. EPA Export 17-10-2012:23:24:08 Reason for Technical Amendment Request: The CHP plant at Lakeland Dairies incorporates supplementary firing before the waste heat recovery boiler. Supplementary firing involves combusting natural gas (to produce more heat to generate additional steam) utilising the residual excess oxygen in the turbine exhaust gases and is fired without the introduction of additional combustion air. The only air used for combustion during supplementary firing is the exhaust air from the CHP turbine. This Supplementary firing process further improves the already high efficiency of the CHP and is much more energy efficient compared to a conventional boiler running at low fire to generate the same quantity of steam. As a result of this supplementary firing process, the exhaust gas has a reduced oxygen content depending on the plant heat demand and rate of Supplementary firing. The oxygen concentration can range between 15.2% at low supplementary firing to 11.9% at maximum supplementary firing. The volume of combustion gases created by supplementary firing are small (approximately 900 Nm3/hr at STP) and within the licensed emissions. However, it was not recognised until now that the reduction in oxygen concentration due to supplementary firing could create a very significant calculated increase in volume corrected to 15% oxygen as required under condition 3.2. (Note: All compliance monitoring completed to date indicates compliance with the ELVs.) This is explained by way of an example: 60,000 m3/hrat 273K, 10?.3kPa, dry gas and 15.2% oxygen becomes 58,000 Nm3/hr at STP, dry and 15% oxygen. 61,000 m3/hr at 273K 101.3kPa, dry gas and 1 1.9% oxygen becomes 92317 Nm3/hr at STP, dry and 15% oxygen. For inspection purposes only. Consent of copyright owner required for any other use. The requirement to correct to 15% oxygen as required by condition 4.2 is to prevent artificial reduction of a high pollutant concentration by adding dilution air i.e. as may be indicated by oxygen concentrations in excess of 15% oxygen. &,a@lqpd &,a@lqpd Dairies recognises that the application of oxygen correction is also applied to the concentration of NOx in the exhaust gas and in applying the oxygen correction factor to both concentration and volume, it causes equal and opposite corrections to concentration and volume with no net increase in the mass emission rate of the pollutant. Lakeland Dairies Co-operative Society Limited Registered in Ireland. Reg. No. 4622R. EPA Export 17-10-2012:23:24:08 NOx Volume Emission NOx 02 Corrected to H20 Conected % Emission Case Corrected DRY DRY, 15% to DRY, Nm3/hr to DRY % VIV 02 15% 02 Wet mg/Nm3 GT Only 60,000 290 6.6 15.2 300 54,172 16.25 GT + 100% SF 61,000 290 8.7 11.9 191.2 84,468 16.15 At 100% supplementary firing a large increase in licensed volume emission corrected to 15% oxygen would be needed when applying the specific requirements of condition 4.2.
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