II 1 ""iron mental f . .' P&c tionf

? Agency ' DEC 2014 Timoleague West Cork Ireland

Tel 023 88461 28 Fax 0238846066

M s Ann Kehoe

Administration Officer, Email info@stauntonfoods le

Office of Climate, Licensing & Resource Use,

Environmental Protection Agency,

P.O. Box 3000,

Johnstown Castle, Co. Wexford

11 December 2014

Re: PO947-01

Dear Ann

I write in response to the Agency's request for information relating to our application

for an Integrated Pollution Prevention and Control Licence as prescribed in Regulation

9 of the EPA (Industrial Emissions)(Licensing) Regulations, 2013.

Please the requested information in the attached files, of which I include one signed

original and 1 copy in hardcopy format and two copies of files in electronic searchable

PDF format on CD- ROM

Yours Sincerely

W Don O'Leary

Environment Manager

Registered in Ireland No: 226927: Registered: Spital Cross, Tirnoleague, Bandon, West Cork, Ireland

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Staunton 'Foods Ltd Timoleague, Bandon, Co. Cork

PO947-01

Review of Compliance with Best Available Techniques

December ~2014 ;. . . . ..

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Cleaner Production Promotion Unit, School of Engineering,

. University College Cork www.ucc.ie/cppu

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10 December2014 PO947 BestAvailable Technique Review

Compliance with Best Available Techniques

11) Ref Ref. #’*’ 5.1.1 BAT is to do all of the following:

1. use an environmental management system

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2. provide training

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3 use a planned maintenance programme

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4. apply dedicated metering of water consumption ’

5.- separate process and non-process waste water . >

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6. remove all running water hoses and repair dripping taps and toilets

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7. fit and use drains with screens and/or traps to prevent solid material from entering the waste water

8. dry clean installations and transport by-products dry , followed by A

pressure cleaning using hoses fitted with hand-operated triggers and where necessary hot water supplied from thermostatically controlled steam and water valves ,..

Page 2 of 16

1. The facility has a written environmental management system in place. Following licensing this system shall be reviewed and revised within six months to reflect the requirements of the licence.

2 . The facility has a substantial training programme in place including environmental procedures. Following licensing a

. ,review of environmental training needs shall be undertaken within six months to reflect the requirements of the licence. I

3. A comprehensive preventative maintenance programme is in place - the content of which has been drawn up in consultation with the relevant suppliers/manufacturers.

4. Water is metered at departmental level ~

5. Rainwater and cooling water are discharged directly to the river; Process water is sent for treafment to the WWTP

6. The use of water hoses is minimised within the plant. ‘ Dripping taps etc. are repaired as part of the plant’s

maintenance programme 7. Grease traps at in place on all drains, drains in the

slaughter hall have screens, Cowls are being installed on all drains (by March 2015)

8. All cleaners are trained to, and procedures require dry cleaning prior to washing; Where possible nozzles are fitted. Water is supplied around the factory in a ring main system. Nozzles are set to spray the minimum amount of water but hygiene / food safety remains main factor in quantity of water being used. Triggered controlled hoses are fitted in factory. 45OC, 65°C & cold water all on all switched off by a master timer switch or manually when not required

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9. apply overfilling protection on bulk storage tanks ‘ L e ... - i -

10. provide and use bunds for bulk storage tanks , 11. implement energy management systems ,

12. implement refrigeration management systems *,

13. operate controls over refrigeration plant running times 14. fit and operate chill room door closing switches

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15. recuperate heat from refrigeration plants . - ,. . . . , .. I I . .

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16. use thermostatically controlled steam and water blinding valves

17. rationalise and insulate steam and water pipework

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18. isolate steam and water services 19. implement light management systems 1

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20. store animal by-products for short periods and possibly to refrigerate them . . . . .. .. . . . : , ’ I .

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2 1. audit odour 8 ,

22. design and construct vehicles, equipment and premises to ensure that they I . are easy to clean I

!3. clean materials storage areas frequently

Page 3 of 16

PO94 7 Best A va ilable Tech 11 i y 11 e Re vie 1.v

9. There is a high level sensor on the diesel tank. For other I bulk storage Staff are trained to avoid risk of overfilling.

10. Bunding (or double skinned tanks) is in place as required 11. As discussed in the following table on energy efficiency,

phased implementation of an energy management system (EnMS) is on-going with a target implementation date of Nov 2015

management system 12. The aforementioned EnMS will include a refrigeration

13. Refrigeration plant runs 24 hours per day 14. Door closing switches are not considered necessary -

currently ‘curtains’ are in place on chill room and when not in use the doors are closed manually

15. Feasibility of heat recovery from refrigeration plant will be -> investigated as part of the environmental management +

programme (EMP) once the plant is licensed - - 16..Thermostatically controlled blending are used in the steam

tunnel .~ 17. This has not been carried out in a systematic fashion to

date, i t is proposed that this be investigated as part of the EMP once the plant is licensed

18. Isoiate values are in place 19. The aforementioned EnMS will include a light management

20. By-products are stored for short periods and refrigerated system

as deemed necessary. The majority of waste collected daily and the rest is collected weekly.

21. There have been no odour issues at the facility to date - an odouraudit will be is not considered necessary

22. Designing for ease of cleaning is inherent in the practice of the plant owning to the nature of the plant as a food production facility and requirements of the onsite DAFM Veterinary Inspectors

a t the facility using food grade chemicals. 23. A comprehensive cleaning programme is performed daily

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10 December2014 PO947 Best Available Technique Review

5.1.1.1

24. implement a noise management system 24. Noise audits have been conducted - and a noise reduction I

25. See previous point

plan is being implemented G T

26. Liquid Petroleum gas (LPC) is used onsite

27. In so far as practical animal by-products are enclosed during transport, loading/unloading and storage

28. Blood is stored in a refrigerated 'blood unit' directly on collection

29. This is not feasible due to the location of the facility

The facility has a written environmental management system in place. This is actively being develop to meet the needs of Origin Green initiative of 'which Staunton Foods are members and to anticipate the requirements of the industrial emissions

25. reduce noise at, e.g. roof extract fans, balance lagoon blowers and refrigeration plants

26. replace the use of fuel oil with natural gas, where a natural gas supply is available

27. enclose animal by-products during transport, loadinglunloading and storage ~

28. where it is not possible to treat blood before its decomposition starts to cause odour problems and/or quality problems, refrigerate it as quickly as possible and for as short a time as possible, to minimise decomposition

29. export any heat and/or power produced which cannot be used on-site BAT is to implement and adhere to an Environmental Management System (EMS) that incorporates, as appropriate to individual circumstances, the following features:

definition of an environmental policy for the installation by top management (commitment of the top management is regarded as a precondition for a successful application of other features of the EMS) planning and establishing the necessary, procedures implementation of the procedures, paying particular attention to: structure and responsibility; training, awareness and competence; communication; employee involvement; documentation; efficient process control; maintenance programme; emergency preparedness and response; safeguarding compliance with environmental legislation. checking performance and taking corrective action, paying particular attention to: monitoring and measurement; corrective and preventive action; maintenance of records; independent (where practicable) internal auditing in order to determine whether or not the environmental management system conforms to planned arrangements and has been

licence. Following licensing this system shall be reviewed and revised within six months to fully reflect the requirements of the licence.

5.1.2 . Slaughterhouses and/or animal by-products installations, operating on the Not applicable

5.1.3 same site . I t I

BAT is to seek collaboration with upstream and downstream partners, to create a chain of environmental responsibility, to minimise pollution and to

Collaboration with suppliers (farmers, ingredient producers, chemical suppliers, etc.) and customers (supermarkets,

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10 December 201 4

5.1.4

5.1.5

protect the environment as a whole

For the cleaning of slaughterhouses and animal by-products installations, BAT

1. manage and minimise the quantities of water and detergents consumed

I . is to do the following: . .

2. select those detergents which cause minimum impact on the environment without compromising the efficacy of cleaning

3. avoid, where possible, the use of cleaning and disinfectant agents containing active chlorine

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4. where the equipment‘is suitable, operate a cleaning-in-place system . For the treatment of waste water from slaughterhouses and animal by- , products,installations, BAT is to do the following: 1. prevent waste water stagnation

2. apply an initial screening of solids using sieves at the slaughterhouse or animal by-products installation

3. remove fat from waste water, using a fat trap

4. use a flotation plant, possibly combined with the use of flocculants, to remove additional solids

5. use a waste water equalisation tank 6 . provide a waste water holding capacity in excess of routine requirements 7. prevent liquid seepage and odour emissions from waste water treatment

tanks, by sealing their sides and bases and either covering them or aerating them ,

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PO947 Best Available Techiiiyue K t l ’ / /ew ’

wholesalers, etc.) is an integral part of Staunton Foods Business m,odel - as part ofthis we strive to minimise environmental impacts e.g., in the selection of cleaning detergents .

1. All hoses are fitted with trigger operated jets, detergent , concentrations are as per manufacture advice. The

company is working with chemical suppliers to reduce the usage of chemical without effecting the hygiene.

2. The company works with its chemical supp!ier to select * effective detergents that have minimum impact on the environment

3. We minimise the use of chlorinated products wherever possible, for food safety purposes, production water is. chlorinated - there are currently only two chemicals used that contains chlorine, for which we are activaley seeking alternatives

4. The steam tunnel tray washer and pan wash have CIP systems. All other cleaning is carried out manually.

1. I All drainage pipework has sufficient . I gradient to avoid’ stagnation

2. There is an preliminary screen at the WWTP

3. There are two sumps on the drains to the WTTP with fat traps

4. A dissolved air flotation (DAF) piant is used in the WWTP to remove fats ,

5 . There is a balancing tank of 390 m3 on site 6. See previous point 7. The base and sides of tanks are’sealed, the activated sludge

basins are aerated

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10 December 201 4

(l’) Refe Ref:#

5.2

8. subject the effluent to a biological treatment process.

9. remove nitrogen and phosphorus.. 10. remove the sludges produced and subject them to further animal by-

11. use CH4 gas produced during anaerobic treatment for the production of

12. subject the resulting effluent to tertiary treatment and 13. regularly conduct laboratory analyses of the effluent composition and

In addition to the general measures in Section 5.1, for all slaughterhouses BAT is to do all of the following: 1. dry scrape delivery vehicles and prior to cleaning with a high- pressure

hose 2. avoid carcase washing and where this is not possible to minimise it,

combined with clean slaughter techniques 3. continuously collect by-products dry and segregated from each other,

along the length of the slaughter-line, combined with optimising bleeding and the collection of blood and segregating the storage and handling of different kinds of by-products ’

4. operate a double drain from the bleed hall 5. collect floor waste dry

product uses. x .

heat and/or power

maintain records

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. . 6. remove all unnecessary taps from the-slaughter-line 7. insulate and cover knife sterilisers, combined with sterilising knives using

low-pressure steam 8. operate hand and apron cleaning cubicles, with a “water off” default

9. manage and monitor compressed air use

10. manage and monitor ventilation use 11. use backward bowed centrifugal fans in ventilation and refrigeration

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PO947 Best Available Technique Review

8. The plant operates a comprehensive WWTP comprising: Screens; balance tank; dissolved air floatation (DAF) system; 2x activated sludge aeration basins; Anoxic tank; UV system, clarified, sludge press

9. An anoxic tank is used prior to aeration for N removal 10. WWTP sludge is land spread in accordance with a nutrient

management plant 11. Not applicable

12. See previous point on anoxic tank 13. A comprehensive monitoring analysis regime is in place ’ for both the WWTP operation and the quality of its effluent

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1. Dry scraping of delivery vehicle floor material is carried ” out prior to washing 2. Staff are highly skilled and trained in clean slaughter

techniques 3. There is continuous dry segregation collection of the by ’

. products along the length of the slaughter hall

4. There is a double drain at the blood channel. 5. Waste is collected from all floors using dry methods prioi-

to washing . 6. There are no unnecessah taps in ;he slaughter hall ’

7. Two knife technique used with insulated container with slots for knives

B. ‘Dead man controls’ are in place for hand and apron cleaning

3. Variable speed drives are installed on compressed’air motors which control demands

10. Ventilation is part of maintenance programme 11. Backward bowed centrifugal fans are not in use in

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10 December 201 4

5.2.1

systems 12. manage and monitor the use of hot water

13. trim all hide/skin material not destined for tanning immediately after removal from the animal, except if there is no outlet for the use/valorisation of the trimmings.

In addition to the general measures in Sections 5.1 and 5.2, for all large animal slaughterhouses, BAT is to do all of the following; . 1. stop feeding animals 12 hours prior to slaughter, combined with

minimising the animals' time in the slaughterhouse to reduce manure production . ,

2. apply demand-controlled drinking water 3. shower pigs using water saving timer controlled nozzles 4. dry clean the lairage floor and to periodically clean it with water 5. use a squeegee for the initial cleaning of the blood collection trough

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6. steam scald pigs (vertical scalding) I I

7. in those existing slaughterhouses, where it is not yet economically viable to change to steam scalding, insulate and cover pig scalding tanks and control

, the water level in those tanks 8. re-use cold water within pig de-hairing machines and replace irrigation

pipes with flat jet nozzles 9. re-use, cooling water from pig singeing kilns 10. recover heat from pig singeing exhaust gases, for preheating water

11. shower pigs after singeing, using flat jet nozzles

12. replace irrigation pipes with flat jet nozzles for rind treatment in pig

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PO947 Best Available Technique Keyiew

ventilation and refrigeration systems

master switch 12. The use of hot water is monitored and managed using a

13. Skin material is trimed as requied

1. I t is a requirement for the animals to come onsite with empty stomachs; pig delivery times are staggered throughout the day to ensure no pigs are too long waiting in the yard or lairage.

2. Demand-controlled drinking water is used in lairage 3. Pigs are showered for ca. 20 minutes with manual controls. 4. Dry cleaning is conducted in lairage with periodic washing 5. The blood is mixed with an anti-coagulant in the blood

bath so there is no congealed blood left in it. I t is cleaned with a hot water power hose. In the event of congealed blood, the blood is shovelled out into .askip'as the congealed blood would block the pipework

6. Pigs are steam scalded, the temperature and timer are monitored by a trained Operative

7. Not applicable \

8. Water is re used within the pig de-hairing units. Some of the sprays have nozzles (final carcass washer). All the' other carcass washers have opened sprays.

9. The cooling water from pig singeing is reused. , 10. Heat recovery from pig singeing exhaust gasses is used to

preheat water 11. Flat n,ozzles are fitted in the carcass washer with a

12. Nozzles replaced as required

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. diameter below two millimetres and pressurised water

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10 December 201 4

13. sterilise chest-opening saws in a cabinet with automated hot water nozzles 14. regulate and minimise the water used for moving intestines 15. use either water-spray/mist-cooling or blast-chilling/shock-cooling tunnel

16. not shower pigs before they are chilled in,a chilling tunnel

17. empty stomachs dry 18. collect the contents of small intestines dry, whether or not they are

19. regulate and minimise the water consumption during small and large

20. regulate and minimise the water consumption during rinsing of tongues

21. use a mechanised fat trap for removing fat from water 22. process fresh hides and skins as far as they are available.

to cool pigs

intended to be used for casings

intestine washing

and hearts

23. when it is impossible to process hides and skins before 8,- 12 hours, with the actual range depending on local conditions, to immediately store hides betweenlOand15oC

hours and 5 - 8 days, with the actual ranges depending on local conditions, to immediately refrigerate hides a t 2 OC

25. always immediately drum-salt all hides and skins, if they have to be stored for longer than 8 days, e.g. if they have to be transported overseas, combined with the drv collection of salt residues

24. when it is impossible to process hides before a period of between 8 - 12

P0947BestAvailable Technique Review

13. The saw is sterilised using automated hot watey nozzles 14. Water is set to minimum manually 15. Water spray used to cool pigs

16. There is no washing before veterinary inspection - carcasses are therefore washed before chilling

17. Contents are removed before washing stomach 18. Finishing machine used to remove mucosa coat and any

loose mucosa that remains in the intestine 19. The volume of water is controlled by levers operated and

monitored by trained Operative 20. Water consumption is controlled by trained Operative

during the 'Pluck' wash (Pluck heart, liver & lungs) 2 1. Fats traps are in places on the drains to WWTP 22. Skins are send off site for processing on a regular basis (as

23. Not applicable, see previous point category 3 waste it is collected daily)

24. Not applicable, see previous point

25. Not applicable, see previous point ' .

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,

10 December 2014 PO947 Best Available Technique Review . . . . I ,

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incorporates, as appropriate to the local circumstances, all of the following features (see Section 2.1. Theletters (a), (b), etc. below, correspond those'in Section 2.1):

a) commitment of top management (commitment of the top management is regarded as a precondition for the successful application of energy efficiency management)

b) definition of an energy efficiency policy for the installation by top management c) , planning and establishing objectives and targets (see BAT 2 , 3 and 8) d) implementation and operation of procedures paying particular attention to: i)

structure and responsibility ii) training, awareness and competence (see BAT 13) iii) communication iv) employee involvement v) documentation vi) effective control of processes (see BAT 14) vii) maintenance (see BAT 15) viii) emergency preparedness and response ix) safeguarding compliance with energy efficiency-related legislation and agreements (where such agreements exist).

-T e) benchmarking: the identification and assessment of energy efficiency indicators over time (see BAT 8), and the systematic and regular comparisons with sector, national or regional benchmarks for energy efficiency, where verified data are available (see Sections 2.l(e), 2.16 and BAT 9)

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Green initiative an energy management system (EnMS) is being put in place a t Staunton Foods on a phased basis. Current

Performance targets have been

An Energy Policy has been adopted by top management place;

established using 2013 as a reference year and An eSIP energy monitoring system has been installed and operational on site

The phased implementation of the EnMS (which will meet the requirement of 4.2.2.1) is planned to be in completed by Nov 2015

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f) checking performance and taking corrective action paying particular attention to: i) . monitoring and measurement (see BAT 16) ii) corrective and preventive action iii) . I , , x

, maintenance of records iv) independent (where practicable) internal auditing in , , order to determine whether or not the energy efficiency management system conforms to planned arrangements and has been properly implemented and maintained (see BAT 4 and 5)

g) review of the ENEMS and its continuing suitability, adequacy and effectiveness by top I

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management . _ BAT is to continuously minimise the environmental impact of an installation by planning actions and,investments on an integrated basis and for the short, medium and long term, considering the cost-benefits and cross-media effects.

Staunton Foods is committed to tracking energy performance based on 2013 figures As discussed above, phased implementation

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4.2.2.2

4.2.2.2

4.2.2.2

4.2.2.2

BAT is to identify the aspects of an installation that influence energy efficiency by carrying out an audit. I t is important that an audit is coherent with a systems approach.

When carrying out an audit, BAT is to ensure that the audit identifies the following aspects (see Section 2.11): a. energy use and type in the installation and its component systems and processes b. energy-using equipment, and the type and quantity of energy used in the installation c. possibilities to minimise energy use, such as: controlling/reducing operating 'times, e .g. switching off when not in use (e.g. see Sections 3.6, 3.7,3.8, 3.9,3.11) ensuring insulation is optimised, e.g: see Sections 3.1.7,3.2.11 and 3.11.3.7 optimising utilities, associated systems, processes and equipment (see Chapter 3) d. possibilities to use alternative sources or use of ene,rgy that is more efficient, in particular energy surplus from other processes and/or systems, see Section 3.3 e. possibilities to apply energy surplus to other processes and/or systems, see Section 3.3 f. possibilities to upgrade heat quality (see Section 3.3.2).

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BAT is to use appropriate tools or methodologies to assist with identifying and quantifying energy optimisation, such as:. , energy models, databases and balances (see Section 2.15) a technique such as pinch methodology ( see Section 2.12) exergy or enthalpy analysis (see Section 2.13), or thermoeconomics (see Section 2.14) estimates and calculations (see Sections 1.5 and 2.10.21. BAT is to identify opportunities to optimise energy recovery within the installation, between systems within the installation (see BAT 7) and/or with a third party (or parties), such as

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of 4.2.2.1) is-on-going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on- going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on- going and it is planned to be in place by Nov 2015

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Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on- going and it is planned to be in place by Nov 2015 ' .

Phased implementation of an EnMS (which will meet the requirement of 4.2.2.2) is on-

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4.2.2.3

4.2.2.4

4.2.2.5

4.2.3

those described in Sections 3.2,3.3 and 3.4. _. .<

BAT is to optimise energy efficjency by taking a systems approach to energy management in the installation. Systems to be considered for optimising'as a whole are, for example:

process units (see se,ctor BREFS) heating systems such as: steam (see Section 3.2); hot water, cooling and vacuum (see the ICs BREF) motor driven systems such as: compressed air (see Section 3.7); pumping (see Section 3.8) lighting (see Section 3.10) drying, separation and concentration (see Section 3.11). .

BAT is to establish energy efficiency indicators by carrying out all of the following: a) identifying suitable energy efficiency indicators for the installation, and where necessary,

individual processes, systems and/or units, and measure their change over time or after the implementation of energy efficiency measures (see Sections 1.3 and 1.3.4)

b) identifying and recording.appropriate boundaries associated with the indicators (see Sections 1.3.5 and 1.5.1)

c) identifying and recording factors that can cause variation in the energy efficiency of the relevant process, systems and/or units (see Sections 1.3.6 and 1.5.2). I

BAT is to carry out systematic and regular comparisons with sector, national or regional benchmarks, where validated data are available. L -

BAT is to optimise energy efficiency when planning a new installation, unit or system or a significant upgrade (see Section 2.3) by considering all of the following: the energy efficient design (EED) should be initiated a t the early stages of the conceptual design/basic design phase, even though the planned investments may not be well-defined. The EED should also be taken into account in the tendering process the development and/or selection of energy efficient technologies (see Sections 2.1 (k) and

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PO947 Best Available Technique Review

going and it is planned to be in place by Nov 2015 '

Phased implementation of an EnMS (which will meet the requirement of 4.2.2.3) is on- going and it is planned to be in place by Nov 2015

Phased implementation of an EnMS (which will meet the re-quirement of 4.2.2.4) is on- going and it is planned to be in place by Nov 2015

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Phased, implementation of an EnMS (which will meet the requirement of 4.2.2.5) is on- going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.3) is on- going and it is planned to be in place by Nov 2015

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4.2.4

4.2.5

4.2.6

2.3.1) additional data collection may need to be carried out as part of the design project or- separately to supplement existing data or fill gaps in knowledge the EED work should be carried out by an energy expert the initial mapping'of energy consumption should also address which parties in t h e project organisations influence t he future energy consumption, and should optimise the enefgy efficiency design of the future plant with them. Forexample, t h e staff in the (existing) installation who may be responsible for specifying design parameters.

.

BAT is to seek to optimise the use of energy between more than one process or system (see Section 2.4), within the installation or with a third party.

BAT is to maintain the impetus of the energy efficiency programme by using a variety of- techniques, such as: '

a) implementing a specific energy eff ic ienj management system (see Section 2.1 and BAT 1)

b) accounting for energy us age based o n real ( metered) values, which places both the obligation and credit for energy efficiency on the user/bill payer (see Sections 2.5, 2.10.3 and 2.152)

c) the creation of financial profit centres for energy efficiency (see Section 2.5) d) benchmarking (see Section 2.16 and BAT 9) ,

e) a fresh look a t existing management systems, such as using operational excellence (see Section 2,s)

f ) using change management techniques ( also a feature of operational excellence, see Section 2.51.

I ,

BAT is to maintain expertise in energy efficiency and energy-using systems by using techniques such as:

a) recruitment of skilled staff and/or training of staff. Training can be delivered by in- house staff, by external experts, by formal courses or by self-study/development (see

- I

PO947 BestAvailable Technique Review

Phased implementation of an EnMS (which will meet the requirement of 4.2.4) is on- going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.2.5) is on- going and it is planned to be in place by Nov 2015

I . .

I _ . . . . ! . . . . . . ... ... ...

. . . . . . . . , ' . ,. ? : -I . . . . . . . . . . . . .

Phased implementation of an EnMS (which will meet the requirement of 4.2.6) is on- going and it is planned to be in place by Nov 2015

Page 12 of 16

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10 December 2014

4.2.7

4.2.8

4.2.9

Section 2.6) b) taking staff off-line periodically to perform fixed term/specific investigations ( in their

original installation or in others, see Section 2.5) c) sharing in-hou,se resources between sites (see Section 2.5) d) use of appropriately skilled consultants for fixed term investigations ( e.g. see Section

e) outsourcing specialist systems and/or functions (e.g. see Annex 7.12) 2.11)

BAT is to ensure that the effective control of processes is implemented by techniques such as: I a). having systems in place to ensure that procedures are known, understood and

b) ensuring that t he key performance parameters are identified, optimised for energy efficiency and monitored (see Sections 2.8 and 2.10)

c) 'documenting or recording these parameters (see Sections 2.l(d)(vi), 2.5,2.10 and .2.15).

complied with (see Sections 2.l(d)(vi) and 2.5) : , *

BAT is to carrysout maintenance a t installations to optimise energy efficiency by applying all of the following:

a) clearly allocating responsibility for the planning and execution of maintenance b) establishing a'structured programme fo; maintenance based on technical descriptions

of the equipment, norms, etc. a s well a s any equipment failures and consequences. Some maintenance activities may be best scheduled for plant shutdown periods

c) supporting the maintenance programme by appropriate record keeping systems and diagnostic testing

d) identifying from routine maintenance, breakdowns and/or abnormalities possible ' losses in energy efficiency, or where energy efficiency could be improved

e) identifying leaks, broken equipment, worn bearings, etc. that affect o r control energy usage, and rectifying them a t the earliest opportunity.

.

BAT is to establish and maintain documented procedures to monitor and'measure, on a regular basis, the key characteristics of operations and activities that can have a significant

Page 13 of 16

PO947 Best Available Technique Review

Phased implementation of an EnMS (which will meet the requirement of 4.2.7) is on- *going and it is planned to be in place by*Nov 2015

Phased implementation of an EnMS (which will meet the requirement of 4.2.8) is on- going and it is planned to be in place by Nov 2015 - 1 , p

I >

r * I

r' ~.

Phased implementation of an EnMS (which will meet the requirement of 4.2.9) is on-

. .

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10 December 201 4

T m p a c t on energy efficiency. Some suitable techniques are given in Section 2.10.

4.3.1 BAT is to optimise the energy efficiency of combustion by relevant techniques such as: those specific to'sectors given in vertical BREFs those given in Table 4.1. (See EAP Document for more information)

4.3.2 BAT for steam systems - . is to optimise the energy efficiency by using techniques such as: -

those specific to sectors given in vertical BREFs those given in Table 4.2 d .

- 4.3.3 BAT is to maintain the efficiency of heat exchangers by both: monitoring the efficiency

periodically, and preventing or removing fouling See Section 3.3.1.1.

4.3.4 BAT is to seek possibilities for cogeneration inside and/or outside the installation (with a third party)

, -

4.3.5 BAT is to increase the power factor according to the requirements of the local electricity distributor by using techniques such as those in Table 4.3, according to applicability (see Section 3.5.1). BAT is to check the power supply for harmonics and apply filters if required (see Section 3.5.2). '

.

4.3.5

PO947 Best Available Technique Review

going and it is planned to be in place by Nov 2015 An eSIP energy monitoring system has been installed and operational on site Phased implementation of an EnMS (which will meet the requirement of 4.3.1) is on- going and it is planned to be in place by Nov 2015 . / I

I

Phased implementation ofan EnMS (which will meet the requirement of 4.3.2) is on- going and it is planned to be in place by Nov 2015

Phased implementation of an EnMS (which will meet the requirement of 4.3.3) is on- going and it is planned to be,in place by Nov 2015 Heat recovery of steam boiler - excess steam used to heat sterilisers in slaughter hall Phased implementation of an EnMS (which will meet the requirement of 4.3.4) is on- going and it is planned to be in place by Nov 2015 Pased implementation of an EnMS (which will meet the requirement of 4.3.5) is on-going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.3.5) is on-

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EPA Export 15-12-2014:23:30:27

10 December 201 4 PO947 Best Available Technique Review

4.3.5

p.3.6

4.3.7

4.3.8

BAT is to optimise the power supply efficiency by using techniques such as those in Table 4.4, according to applicability:

. . . . . , . . . . . . . . . . .

BAT is to optimise electric motors in the following order (see Section 3.6): optimise the entire system the motor(s) is part of (e.g. cooling system, see Section 1.5.1) then optimise the motor(s) in the system according t o t h e newly-determined load requirements, by applying one or m ore o f t he techniques in Table 4.5, according t o applicability (See EPA Document for more information) when the energy-using systems have been optimised, then optimise the remaining (non- optimised) motors according to Table.4.5 and criteria such as: prioritising the remaining motors running more than 2000 hrs per year for replacement with EEMs electric motors driving a variable load operating a t less than 50 % of capacity more than 20 % of their operating time, and operating for more than 2000 hours a year should be considered for equipping with variable speed drives.

.

BAT is to optimise compressed air systems (CAS) using the techniques such as those in Table 4.6, according to applicability: (See Table 4.6 in the Appendices)

1 ,

BAT is to optimise pumping systems by using the techniques in Table 4.7, according to applicability (see Section 3.8): Note that throttle control is less energy wasteful than bypass control or no control. However, all are wasteful of energy and should be considered for replacement according to size of the pump and how frequently it is used.

Page 15 of 16

going and it is planned to be in place by Nov 2015 Phased implementation of an EnMS (which will meet the requirement of 4.3.5) is on- going and it is planned to be in place by Nov 2015. Phased implementation of an EnMS (which will meet the requirement of 4.3.6) is on- going and it is planned to be in place by Nov 2015

,

c - 3

Phased implementation of an EnMS (which will meet the requirement of 4.3.7)'is on- going and it is planned to be in place by Nov 2015 Variable speed drives are installed on compressed air motors which control demand

Phased.implementation of an EnMS (which will meet the requirement of 4.3.8) is on- going and it is planned to be in place by Nov 2015

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10 December 201 4

4.3.10

4.3.11

Chapter 5

AT is to optimise heating, ventilation and air conditioning systems by using techniques such as

for ventilation, space heating and cooling, techniques in Table 4.8 according t o applicability for heating, see Sections 3.2 and 3.3.1, and BAT 18 and 19

for cooling, chilling and heat exchangers, see the ICs BREF, as well as Section 3.3 and BAT 19 (in this document).

for pumping, see Section 3.8 and BAT 26 . .

See Table 4.8 Heating, Ventilation and Air Conditioning System Techniques to Improve Energy Efficiency in the Appendices. BAT is to optimise artificial lighting systems by using the techniques such as those in Table 4.9 according to applicability (see Section 3.10):

_ .

BAT is to optimise drying, separation and concentration processes by using techniques such as those in Table 4.10 according to applicability, and to seek opportunities to use mechanical separation in conjunction with thermal processes:

PO947 Best Available Technique Review

will meet the requirement of 4.3.9) is on- going and it is planned to be.in place by Nov 2015 i

Phased implementation of an EnMS (which will meet the requirement of 4.3.10) is on- going and it is planned to be in place by Nov 2015 Not applicable

Emerging Techniques for Energy Efficiency 5.1 Flameless combustion (flameless oxidation) Not applicable

Not applicable 5.2 Compressed Air Energy Storage L1 '

' . . I ,. : 7 ) . _ . . .

. . . . . . . . . . . . . .

. . . . . .. ~. . .

\

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. .c -.

Staunton Foods Ltd . Timoleague; Bandon West Cork

Report on the Requiren ent for a Base ine Assess lent

. .

November 2014

DixonBrosnan .

noise & ecology specialists

d ixon brosnan .corn

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I I . .

I .

F

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. .

. .

. . .

. .

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. .

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Staunton Foods Ltd. Timoleague, Bandon West Cork

Report on the Requirement for a Baseline Assessment

Contents

1

2

Introduction ...; ............................................ ................................... ...................... 4 I . I Background ................................. ~ .......................................... ............. 4

Requirements for a Baseline Report' .............................. ~ ................................... 5 2. I European Legislation .................. .; ....................................................... 5 .

. 2.2 Irish Legislation ........................... :..; ................................... 1 .................. 9 ' 2.3 . Chemicals handled atStaunton-Foods Ltd ...................................... . .

3 . Discussion ....................................................................................... ......: .......... 24 4 Conclusion ..................................................................................................... ;.25

~.

I I . .

3 .:,

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Staunton Foods Ltd.

IED Site Report

1 Introduction

This report has been prepared following a request by the Agency dated

February 19th, 2014. The report sets out to meet the requirements of Article

22(2) of the Industrial Emissions Directive (201 0/75/EU) by considering the

requirement for a full baseline study.

1 .I Background

Staunton Foods Ltd. was founded in Timoleague in the 1950's by the Staunton

family, commercialising the family's experience with slaughtering pigs for a ,

small number of local customers. The company is now a division of Barryroe

Co-operative Society Ltd., trading as Staunton Foods Ltd.

Staunton Foods Ltd. has applied to the Environmental Protection Agency

(EPA) for an. Industrial Emissions Licence (reference number- PO947-01) in

respect the following classes of activity: .

4

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. . , .

. . . I . .. ~. . - . ,-. . . . . - . .

. : .

i

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Staunton Foods Ltd.

IED Site Report

This report is in response to a request for further information from the. Agency

in respect of this application.

2 Requirements for a Baseline Report 2.1 European Legislation

The Industrial Emissions Directive (2010/75/EU) also referred to as IED

entered into force on the 06/01/2011. The aim of the IED is to integrate the

IPPC Directive and the Waste Incineration Directive and five other directives in

a single Directive on emissions. For industrial activates falling under IED, like

Staunton Foods Ltd facility, Article 22(2) of chapter I t of the IED states:

“Where the activity involves the use, production or release of relevant

hazardous substances and having regard to the possibility of soil and

groundwater contamination at the site of the installation, the operator shall

prepare and submit to the competent authority a baselihe report before starting

operation of an installation or before a permit for an installation is updated for

the first time afler 7 January 2013. The baseline report shall contain the

information necessaty to determine the state of soil and groundwater

contamination so as to make a quantified comparison with the state upon

definitive cessation of activities provided for under paragraph 3. ”

The European Commission provides Guidance concerning baseline reports

under Article 22(2) of Directive 201 0/75/EU on industr/al emissions (2014/C

136103). The scope of the guidance provides information on the legal

5

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Staunton FoodsLtd.

IED Site Report

provisions concerning a baseline report and covers the following elements of

Article 22 of the IED that should be addressed in the baseline report:

i. - Determining whether a baseline report is required to be produced;

ii. Designing baseline investigations; I

iii. Designing a sampling strategy;

iv. Developing the baseline report.

There are eight stages in preparing a full Baseline Report as outlined below in

Table 1 ; this report addresses the first three stages identification of hazardous

substances, determination of which are ‘relevant’ and assessment of site-

specific pollution possibility, following which a determination is made whether a

baseline report is required or not.

Table ‘1 Stages of IED Baseline Report

Activity 0 bjective

1. Identify which hazardous substances Determine whether or not

are currently used, produced or

released at the installation

hazardous substances are

used, produced or released

in view of deciding on the

need to prepare and submit

a baseline report.

2. Identify the relevant hazardous . To restrict further

Identify, quantify and document such

hazardous substances.

substances consideration to only the

Identify which of the hazardous relevant hazardous

substances in view-of substances from Stage 1 are

‘relevant hazardous substances’ (see

Section 4.2). Discard those

deciding on the need to

prepare and submit a

baseline report. hazardous substances that-are

incapable of contaminating soil or

groundwater. Justify and record the ‘

.

- decisions taken to exclude certain

hazardous substances.

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I '

~ :

Staunton Foods Ltd.

IED Site Report

3. Assessment of the site-specific To identify which of the

pollution possibility relevant hazardous

For each relevant hazardous

substance brought forward from

Stage 2, identify the actual possibility

for soil or groundwater contamination

at the site' of the installation, including

the probability of releases and their

substances represent a

potential pollution risk at

the site based on the

likelihood of releases of

such substances occurring.

For these substances,

information must be consequences, and taking particular

account of: included in the baseline

report. the quantities of each hazardous

substance or groups of similar

hazardous substances

concerned;

how and where hazardous . .

substances are stored, used and

to be transported around the

installation;

where they pose a risk to be

released;

In case of existing installations

also the measures that have

been adopted to ensure that it is

impossible in practice that

contamination of soil or

groundwater takes place.

4. Provide a site history. Consider available

data and information:

Identify potential sources

which may have resulted in

In relation to the present use of

the site, and on emissions of

hazardous substances which have

the hazardous substances

identified in Stage 3 being

already present on the site

occurred and which may give rise

to pollution. In particular, consider

accidents or incidents, drips or

spills from routine operations,

of the installation.

7

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Staunton Foods Ltd.

IED Site Report

changes in operational practice,

site surfacing, changes in the

hazardous substances used.

Previous uses of the site that may

have resulted in the release of

hazardous substances, be they

the same as those used, produced

or released by the existing

installation, or different ones.

0 Review of previous investigation

reports may assist in compiling

this data.

I '

5. Identify the site's environmental setting

including: substances may go if

Determine where hazardous .

Topography; released and where to look

Geology;

Direction of groundwater flow; . environmental media and ,

Other potential migration pathways receptors that are potentially

for them. Also identify the . L

such as drains and service

channels; . other activities in the area

at risk and where there are

Environmental aspects (e.g: which release the same I

particular habitats, species,

protected areas etc.); and

hazardous substances and

may cause them to migrate

Surrounding land use. onto the site.

6. Use the results of Stages 3 to 5 to Identify the location, nature

describe the site, in particular

demonstrating the location, type, extent

and quantity of historic pollution and

potential future emissions sources noting

the strata and groundwater likely to be

affected by those emissions - making links

between sources of emissions, the

pathways by which pollution may move and

the receptors likely to be affected

and extent of existing

pollution on the site and to

determine which strata and

groundwater might be

affected by such pollution.

Compare with potential future i

emissions to see if areas are

coincident.

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Staunton Foods Ltd.

IED Site Report

7. If there is sufficient information to

quantify the state of soil and groundwater

pollution by relevant hazardous substances

on the basis of Stages (1) to (6) then go

directly to Stage 8. If insufficient information

exists then intrusive investigation of the site

will be required in order to gather such

information. The details of such

investigation should be clarified with the

competent authority.

Collect additional information

as necessary to allow a

quantified assessment of soil

and groundwater pollution by

relevant hazardous

substances.

8. Produce a baseline report for the Provide a baseline

installation that quantifies the state of

soil and groundwater pollution by

report in line with the

IED.

relevant hazardous substances.

2.2 lrish Legislation

Article 22(2), as part of Chapter II of the IED, was transposed into lrish national

law on April 23rd, 2013 by the European Union (Industrial Emissions)

Regulations 2013 (S.I. No. 138 of 2013) and resulting amendments to the

Environmental Protection Agency Act 1992. Section 86B of the Environmental

Protection Agency Act 1992, as amended, states that 4

(1) Where an industrial emissions directive activity involves the use, production

or release of relevant hazardous substances, and having regard to the

possibility of soil and groundwater contamination at the site of an installation

,concerned, the Agency shall require an applicant under this Part for a licence

or review of a licence or revised licence relating to the activity, including such a

9

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Staunton Foods Ltd.

IED Site Report

review by the Agency of its own volition, to furnish to the Agency a baseline

report in accordance with regulations under section 89.

(2) In relation to an installation, a baseline report shall contain the information

necessary to determine the state of contamination of soil and groundwater'at

I ' the time the report is drawn up in order that a quantified comparison may be

made to the state of the site upon the permanent cessation (including cessation

1~ by abandonment) of the industrial emissions directive activity concerned and

the applicant in preparing the baseline report shall. include any information

prescribed in regulations under section 89.

(3) Notwithstanding the generality of subsection (2), a baseline report shall

include at least the following information-

(a) The current use and, where available, the past use of the site,

(b) Any available information-

i. On soil or groundwater measurements that reflect the state of the site at the

time that the baseline report is drawn up, or

.. . 1 1 . On new soil and groundwater measurements, having regard to the possibility

of soil and groundwater contamination by the hazardous substances proposed

to be used, produced or released by the installation concerned.

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. . . . -

. .

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Staunton Foods Ltd.

IED Site Report

2.3 Chemicals handled at Staunton Foods Ltd.

Chemicals utilised at Staunton Foods Ltd. relate to production process,

cleaning and maintenance operations, laboratory testing and quality

compliance, and wastewater treatment testing. A detailed list of chemicals used

onsite was assessed in accordance with Article 3 of Regulation (EC) No.

1272/2008 and the hazardous chemicals identified.

Table 2 below outlines these hazardous chemicals, which were brought

forward and assessed to determine the likelihood of release. As part of the

assessment, onsite controls and containment with respect to delivery, storage,

I and use of the chemicals, standard operating procedures, and other relevant

prevention measures, were reviewed.

. .

11

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Y

~ .. , .-I ' , , , I . ,

,. .. ' . i.. ' .' .

, .. . ... !

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EPA Export 15-12-2014:23:30:28

Slaunton Foods Lld October 2014

IED Site Report

Table 2 Determining Substances Which May Represent a Pollution Risk

Stage 3 Site Specific Characterisbcs Assessment Stage 2 Chemicals Characteristics 6 Toxicity Stage I Chemicals Handled

Ref

- Stale S-Solid 1-Liquia

L

- L

- L

Potenbal pollution nsk I likelihood of releases

Hazarp'ous substance under Stage 2 YedNo Yes

gelivery, Slorage, and Environmental 3ntro/s

Environmental /Ecologica/ Behaviour

No Informabon Available

Annual Usage (Tonnes)

440

0 025

0 025

100

25

1

0 7

QuanWy Stored (Tonnes)

,270 '

i'isk Phrases /Risk ?ategory

[his product is not iassified according IC i U legislabon

Substance Area of Use ;AS No.

'2623-859 As a result of the controls ir place to contain and preven any spillage of compressor oil the nsk of release to tht envlronment of this substance: is considered negligible and I is not considered to be 2 potenbal nsk to thf envlronment

Compressor Oil .

D Stored wthin a bunded containei within the Compressor Room

B Spill kit present within the vianity 0 the compressor room

D All bunds are inspected on a regulai basis lo ensure integnty and drair any rainwater Should a spill occur all drains coven are available and all drains within the area drain to the site WWTP

n An Emergency response team is present onsite in the unilkely even1 that a spill may occur

NIA (no further information required)

D

1 Pefro Canada Compressor oil reno 68A

NIA (no further information required).

Lubricant No 0.050 Water Pollubon Class WGK 1 Slightly water endangering (Classificabon according to German VwVwS from May, 1999) Avoid the contaminabon of soil and water

No relevant data

VIA . 2 Tunnosynfh 2000

NIA (no further informatior required).

N/A (no further information required) 0.025

0.02

Compressor Oil

No castrol Compressor oil aircol mr46

3

NIA (no further informabon required) NIA (no further informatior required).

will biodegrade Not likely to harm Aquabc environment

Production No S2, S25 MA Meat Marking Paint

4

Avoid release to the environment.

4s a result of the controls in place to prevent and contain any spillage of producbon ;hemicals , the nsk of release to the envlronment of these substances is considered negligible and they are not ansidered to be a potenbal nsk lo the envlronment

I Stored within bunded containers I Chemical spill kits are wthin the

vlcinity in the unlikely event that a spill may occur All bunds are inspected on a regular basis An Emergency response team is present onsite in the unilkely event that a spill may occur In the unlikely event that the above

Yes 7647-14-5 Production BrineSan . 5 . .

No relevant 0 2

0 05

Yes

Yes, '

T,FRWR25, SlW38, S41/45/61 R3WR371R38 '

Production

Production

cure P2

Sodium Ascorbate

6

7. data Possibly hazardous short term degradabon products are not likely However, long term

134-03-2

12

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EPA Export 15-12-2014:23:30:28

Staunton Foods Ltd October 2014

IED Site Report

8

9

10

11

12

13

14

15

Phosphate fesf kif

Phosphate test kit mob reagent Phosphate test kif reagent vials Phosphate fesf kit sodium hydroxide 1.54N

Ammonia Test kif

Ammonia tesf kit Cyanurate reagent .

C.O.D. Vials

Nitrate test kit

HR Hydrogen Peronde Reagent

Total Nitrogen Test kit

Broxo Salt

7664-939,

7803-556

7727-24-1

231-791-2,

L 54-21-7 6132-04-3 610624-7 14402-89-2

L 6132-04-3 6106-24-7 131065-2 2893-78-9

7732-18-5 L 7732-18-5

766493-9 10294-26-5 7783-35-9

133582.0

1333-82-0

S 7757-79-1

7681-57-4 231-791-2 215-185-5 207-8304 7681-57-4 7631-86-9 129-964 57-1 3 6 7647-598-3

ROE-22- 3&'37/3& R35 S22-24-26 S37

0, Xn, Xi R20-25

R3W37, R8-22! 36/37/38/ 4m43,

C,R35 R35, R36/38 S26, s45, s37/37, S37l37 R22, R37

C, Xn, 0, Xn, Xi,,N, R08-22- 32-36/37-5053

R33, R35, R2ORlR2 C, R35 R4 1 T, N, R26/27/28 33- 5053 0, Cam, T+, T,R9-45- 46,R62-R26, 62-26.

R4R43R50R53 0, R8

R48R23-R35

Xn, XI, R2241-31

C,R35 XI,R36 Xn, Xi, R2241-31

WWTP Laboratory

W P Laboratory

WWTP Laboratory

W P Laboratory

W P leboratory

WWTP Laboratory

WWTP Labobtory

W P

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes .

Yes

degradation products may anse No lnformabon Avalable .

No Information Available.

No Information Available.

No Information Available.

Releases of Ibis material may confaminafe !he environment

No Information Available

No Information Available

. .

No Information Available

No environmental data Available Do no1 allow to enter into surface water or drains

50 Vials

50 Vials

150 Vials

125 Vials

150 Vials

100 Vials

250 Wals

250 Vials

1000 Vials

375 Wals

3,300 Wals

500 Vials

15

controls fail any chemical that may leak will flow to the WWTP

Small quantities of fhe reagenfs are used as part of the eff7uent plan! festing Small spill trays are presenl within the laboratory lo prevent fhe pofential for spills to be released from the laboratory

place and all laboratotypersonnel are

A chemical spill procedure IS in place

In the unlikdy event fhat a spills

All dreins are conveyed fo fhe W P Used wals are stored in a (light- sensdive) closed box, or within individual comparfmenfalised Styrofoam boxes unfrl sufficient quantities are present to required disposed using a licenced hazardous waste contractor ,

A chemical handling procedure is in

trained

af fhe site

occurs it will be cleaned up

See above

The salf IS sfored Mhin a designafed area within fhe W P Mhin in bags and IS solid in nature

These chemicals are used in small amounts and sorted in a designated place wlthin the waste water treatment laboratory Owing lo the controls in place, the nsk of release to the environment of these substances is considered negligible and they are not considered to be a potenbal nsk to the enwronment

See above

As the salt is stored wlthin the WWTP there is negligible potenbal for this to be released to the enwronment, any spillages would be easily deaned up therefore it is not considered likely that this substance would be released to

13

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. .

. . . . . .,

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I

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EPA Export 15-12-2014:23:30:28

Staunton Foods Ltd October 2014

IED Site Report

- L

~~~

All delivenes are SuDervised bv the enwronment

W P

W P

W P

WWTP

WWTP W P

W P

W P

W P

W P

W P

W P

Factory deaning

WGK 2 water endangering

No lnformabon Available No infonabon Available Large discharges may contnbute to the alkalisabon of water and may be fatal to fish and other aquabc life Bioaccumulabve Water Soluable No eqenmental Toxlcity values available Should not be allowed In waterways Product mcderatel y increases pH - value in Aqueous solubon

Topxlaty EC50 Daphnia magna >100mg Acute toxlcity values Acute LC50 for fathead minnow is > 1 OOmgn EC50 for manne mussel abra alba is > 100mgA EC50 for Daphnia Magna is > 100mgA TONG to aquabc organisims Decomposes in Water or Soil Not expected to bioaccumlate No lnformabon Available

10

52

52

10

45 15

25

1 3

I 50

3

0 025

0 025

0 05

75150-29-7 68213-230 64742-46-7 7446-70-0

7446-70-0 42751-791 1310-73-2

64-1 7-5 42751 -79-1

144-55-8

R51153 R41/50 R65 C,R36,R38 .

Yes.

Yes

Yes

1 16

17

18 '

trained personnel Stored wth a bunded units within tht WWTP area Bunds onsite provide minimum of 110% capaaty of the largest vessel or 25% of total capacity of tanks within the bund (whichever requires the greatest volume) All IBC's are adequately bunded and checked for leaks on a regular basis as per the requirements of internal envlronmental procedure Visual bund inspecbons are undertaken regularly Bund Inspechons. and integnty tesbng are programmed as part of preventabve maintenance are undertaken on a regular basis to ensure that they are intact Rainwater is empbed from the bund to ensure there is adequate capaclty to contain any potenbal spillages Chemical usage at the WWTP is managed and scheduled to ensure that only the amount required IS accepted at the ate Spill kits are available within Re area in the unlikely event that a spill may occur All drains within the vicinity of the flow to the WWTP

To date there has not been any inadent in the handling of chemicals at the WWTP

As a result of the controls in place, the nsk of release to the envlronment of these substances is considered negligible and they are not considered to be a potenbal nsk to the envlronment

L

L -

Remphos A 13

CellnOC A2013

Caudic Soda

1

. ' C,R36 R30 R35, S24l25 L Yes 1 19

20 21

22

23

24

L L -

- S

F, R11, S7-16 XI, R36

Yes Yes

Yes

Yes

Yes

2 1

Alcohol Cellfloc C5

See above

Sodium Bicarbmate

2

L R36, R38 S24, S25, S36

0.125

0.150

Defoam V20

Defoam 60 L

L

No CAS number for Defoam 60

7681-52-9

500-220-1

231-781 -8

215-185-5

7681-52-9

Chloropol R36,R38 0.25

L Yes ,

Yes

Yes

0 05.

0 05

0 1

Turbo

Persulfate Reagent

Xi,R41 Small quanbbes used onsite Contained within the WWTP laboratory wthin a bunded container A chemical handling and spill response procedure is in place and WWTP are bained in the correct use All chemicals used for factory

UA (no further information equired).

L

C,R35 ,

Neat product is dangerous to the

Chloman .hese chemicals are used in a mtrolled manner athin the . .

14

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. .

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EPA Export 15-12-2014:23:30:28

. .

Staunton Foods Ltd October 2014 IED Sile Report

Environment if discha!ged direct to

deaning and maintenance operabons are stored in designated areas on bunds within the building A chemical handling and spill response procedure is in place Spill kits are available within the building in the unlikely event there is a spillage Visual bund inspecbons are undertaken regularly All drains within the factory flow to the site WWTP Should a spill occur all drains covers are available and all drains within the area drain to the site WWTP

factory All chemicals are storei in a designated place within the factory on bunds h n g to the controls in place, the nsk of release to the environment of these substances IS considered negligible and they are not considered to be a potenbal nsk to the enwronment

watercourses. This product is not dassified as environmentally hazardous.

29 Yes Xi, R38, R41

xi R36/38 M7 Hand Soap Factory

deaning 0.04

0.02

0 52

0 1

15

5

200

0 05

0 600

Perbac Factory deaning 30

Yes

S26, R20122 S36137139 Xn, C, 0, R20/22, S45. S51. R35. R7

79-21-0

Maxifoam Plus Factory Cleaning

Yes

Yes

Large or frequent spills can have a harmful or damaging effect on the environment This mixture is not dassified as t o m to aquabc organisms Not expected to

Bioaccumulate Phosphates are plant nutnent and as such may contribute to the growth of phytopanctons in water Inorganic product, which cannot be eliminated from water by biological purificabon process Not regarded as

dangerous to the environment

2 31 32

d a wc Anti Zoagulant Thermphos

Blood Unit 0.4

Xn, R22, R3i Sodium Irish Casings perservative

Yes 2 Helabisulphate

See above)

See above) L 35 4lkfoam i l l - 7 6 2 Xn, XI, R36138, R20121122 XI, R36/38 F, R i 1 XI, R36, R68 XI, R36138 F, R i l , R36, R68, XI C, R35 XI, R36138

Cleaning factory

Yes - ' 0.025

21 5-1 85-5 221-416-0

L Yes . 36 Xn, Xi, N,R21.R22. '

R37138,R50 3romotech 52-51-7 Cooling tower 0.300 Not regarded as

dangerous for the environment

50,96 Hrs. FISH mgn >loo mgn (Bluegill sunfish),

15

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I .

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EPA Export 15-12-2014:23:30:28

Staunton Fwds Ltd October 2014

IED Site Report

37

38

39

40 , .

h l t e c h

-armsan

Vopac

PP44

Multitech '

'632-00-0

I31 073-2

1, T, N, RB,R25,R50

01, XI, R22 ;, R35 ;, R34 (n N. R20/21 ;,R34, S24/25,526, I6137/39,545.S60

lot Classified

2, R35

Cooling tower

Factory Cleaning

Cleaning factory

Cleaning factory

Steam boiler

les

les

res

Yes

(Oncorhynchus mykiss) EC 50,48 Hrs, DAPHNIA, mgn 4 6mgn (Daphnia) IC 50, 72 Hrs. ALGAE, mgn 1 9 9 3 mgn ( N w

The substance has a low potenhal for bio- accumulahon Dangerous to the environment Very toxlc to aquahc organisms Not expected to Bioaccumulate

This product is not dassified as environmentally hazardous However, this does not exdude the possibility that large or frequent spills canhave a harmful or damaging effect on the environment Acute Fish Toxlcity Fish toxlaty LCO >1600mgn (Goldorfen, 48 h) Bactenal Toxlaty EC50 >iooomgn (OECD 209) LC 50,96 Hn, Fish myl >IO00

mykiss) EC 50,48 Hrs,

(Onchorilynchus

Daphnia, mgn 485 IC 50,72 Hrs, Algae, mgn> 1000 Bioaccumulabve potenbal Concentabons

3.300

3.025

3 025

3 1 .

D 600

3 125

D 075

0 5

500

(See above)

(See above)

(See above)

See above)

16

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, ,!

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EPA Export 15-12-2014:23:30:29

Slaunton Foods Ltd.

IED Site Recod

October 2014

.- , Steam Boiler les 300 ' greater than 10

ppm, especially in fresh water or a pH value equal to or greater than 10 5 may be fatal to fish and other aquabc organisms Can cause damage to aquabc plants When used for its intended purpose should not cause adverse affects in the environment

Harmful to aquabc life in low concenbabons No data available

No data available No data available No data

f i , Xi, R22,R41,R31 '681-57-4

18955-555 1.01

1.300

0 1

0 600

0 025

0 5

0 025

0 025

0 025

0 025

0 05

XJ, N. R38, R41,R50

C.R35 C. R31, R34

Xn, R22 R31

Factory :leaning

les 12 1 lomestos

Steam Boiler les '631-90-5 13 iorrotech CPN

S24125, S36, 537. SI, S60

les Maintenance Water Soflener Lubncant Maintenance Maintenance

Maintenance

'647- 14-5 14 '- inderol H I High erformance food rade inderol C-NRT I

'LUS 100 FG iassida fluid 'P100 llba food beanng

1025

11

102

I 004

1025

1025

Non Haz UA

1 1-486

15

16

47 .

18

19

50

51

Xn les

les R22

Non Haz

Non Haz

da available No data

lrease '

Mina oil 917 Ja Maintenance \lo

rl0 Maintenance ila

4IA ,

8955-555

ihell Cassida oil 50 :ream Cleaner

Iomestos

avalable No data available When used for its intended purpose should not cause adverse affects in the

Factory Cleaning

Non Haz

Xi, N, R38, R41,R50 Factory Cleaning

1.001 0.01

0.050

environment. When used for C,R35 Factory

Cleaning ,

Yes 131073-2

i68!-52-9

its intended purpose should notcause . adverse affects in the environment Not expected to Bioaccumulate Release of alkaline or acid solubon klling p H sensibve

C. R31, R34

Factory Cleaning

res D.025

C,Xi,RH, R37 3834-92-0 3cef 52

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* .

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EPA Export 15-12-2014:23:30:29

E D Site Report

microbes in the 5011, breaks down soil structure, contaminates groundwater, raises total dissolved solids concentrabon

53 TWS L Xi, R 3 M 8 Factory Yes Not expected to 0 25 Cleaning Bioaccumulate

Holquat Cleaning Bioaccumulate

C, R36138 L 131073-2 C. R35 Factory Yes Not expected to 0 375

68131-395 XI, N, R41. R50, s24125

55 Oven and Utensil L 63449-41-2 Xn, C, N, R21122 Factory Yes Large or 0 4 Cleaner M6 S26, S37 Cleaning frequent spills

have a harmful 131073-2 C or damaging

effect on the environment

can

56 Auto AL L 1310-58-3 C. Xn, R35, R22, S26, Factory Yes This product 0 025 s45. Cleaning consists solely of

inorganic matenals for which bicdegradabon assessment is not applicable

classified as hazardous to the enwronment

57 Drysan L 1312-76-1 XI. R38,R41,S24125 Factory Yes This product is 0 04 7320-34-5 XI, R36 S36,37, Cleaning

39,S60 67-630 F XI, R l l , R36,R67,

S25, S26. S51,s49 58 07440-37-12 0, PAS, S9, 523 Maintenance

Argon Gas 14m3 G Yes No ecological 1 X 14 m3

59 Argon Gas 14m3 G 07440-37-12 0, RAS, Maintenance Yes No ecological 1 X 1 4 m3

damage caused by this product

damage caused by this product

60 LPG G 101-97-8 F, R12, S9, S9, S16 Factory Yes NIA No known ecological damage caused by this product

18

. .

0 65

2 6 Extensive nehvork of process drains Due to controls in place it IS not within the site should any of the chemicals spill Faality has a rolling inspecbon and test programme in place for all process pipelines

Any spills wlll be deaned up following standard operatmg procedures All personnel using chemicals are trained in the sites chemical handling procedure Spill bts are available Whin the factory should any spills occur All drains in the area flow to the sites WWTP See above

considered that this chemical will have the potenbal to be released to the enwronment

2 Stored within a bunded unit Due to controls in place it is not considered that these chemicals will have the Potenbal to be released to the enwronment

0 025

See above

0 255

Stored within the plant in a designated area mthin a pressunsed vessel

the safe use of the gas

Control measures are in place with respect to storage and use of the gas and the nsk of

Maintenance operabve are trained in release IS considered negligible

24 m3

5 6 m3

400 LPG is stored in a protecbve cylinder Control measures are in place and is inspected be a by a qualified with respect to storage and use technician as required to ensure the of the gas and the nsk of valves, connecbons, piping, and release to the environment is hoses are free of leaks considered negligible A release valve is present which emits the gas controlled manner to prevent the cylinder from exploding due to over-pressunzabon The is regularly S ~ M C ~ S as part of a preventabve maintenance programme

For

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EPA Export 15-12-2014:23:30:29

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EPA Export 15-12-2014:23:30:29

Staunton Foods Ltd

IED Site Report

Propane gas cylinder

Diesel

Ammonia

Freon 404A

101-97-8

64742467

7664-41-7

354-33-6

:, R12

61, N, R20, R38, 765, R51I53.

',T,C,N R10. R23, 734, R50

R36,R37

Factory

T N C ~ 8 forklifl

Refngeranl

Refngerant

t'es

les

les

Yes

No known ecological damage is caused by this product

Oil contaminates soils in the area, and subsequent conlaminabon of groundwater

Release of toxic gas lo the environmen t

R-404A is a gas at rwm temperature, therefore, it is unlikely to remain in water

1

2

?/a

1260

1

200

1

0.260 1

October2014

Stored in a Well-ventilated and dr fire resistant locabon and away fror electncal urcuits Stored within a pressunsed vessel The vessels are regularly inspecte by trained personnel to ensure th: the regulators, pressure relief valve and cylinder connections are entac and they are free of wrrosior leakage, pi lng, dents or gouges Diesel is stored wlthin a double slunned tank All refuelling operabons take place oi a hardstanding area and are supervised by site personnel

0 A spill kil is present in the unlikely event of a spill area Drains in the area flow to via an oil interceptor prior to discharging to the sile Water Treatment Plant

Ammonia is conlained within

Refngerabon system is mamtained enclosed system

by expenenced external professionals Alarm system in place to detect if ammonia leak occurs Stored wilhin a pressunsed vessel Used in small quanbties

The likelihood of occurrence is considered negligible, a vehicles are anended dunng refuelling, a hardstand is provided in the refuelling area and all liquids falling are routed through an oil interceptor before discharge - the collected matenal is stored in lhe waste oil bunded tank before being sen1 for treabnent

Due to controls in place and the fad thal is gas at rwm temperature it is not considered to present a fhreat to surface and groundwater

Used in small quantities and stored within a designaled location within the facility Due to controls in place and the fact thaf is gas a! m m temperafure it is not considered to p s e n t e threat lo surface and groundwater

i

I The Freon 404A has not been replaced since plant became oper?tional

i a I "

. .

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... , , i -

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EPA Export 15-12-2014:23:30:29

October 2014 Staunton Foods Ltd

IED SI - teport

Refrigerant L

- L

- S

- s

N/A (no further information required) WGK Germany 1 Low hazard to waters Product is not a bio- ammulator - biological half- life is less than 3 hours Biodegradabon This product is water soluble and moves readily in soil and water

322 ' N/A

120

30007

-

NIA (no further informabon required)

j7-55-6 ' Glycol 65 '

Pig Stunning When discharged in large quantities may contribute to the greenhouse effect. . No data

available. ,

3

1.0005

N/A (no further informahon required)

0. Ras.SS 1

1

CO2 Gas is stored in pressunsed vessels All personnel are trained in the correct operabon and use

56 CO2 gas

les NIA (no further informabon required)

102.954 xn, R22 Micro Lab 1 Used in a small quanbbes within the Micro Lab

1 Present in a solid state so not potenbal for leaking to drain

1 Specific training is provlded for those personnel who are involved in handling chemicals as part of their daily dubes

I NI waste plates are removed from the laboratory by approved hazardous waste contractors

N/A (no further informabon required)

57 V@d Agar

IO plates rl0 NIA (no further informabon required)

N/A (no further informahon required)

don Haz Micro Lab Blood Agar 68

69 N/A (no further informabon required) No ecological problems are to be expected when handled wth due care

No data available

No data available

?O ml Micro Lab vo Baallus Subhlis

300 ml

1005

1005

1005

I 2 litres

1005

NIA (no further information required) 3.0005 . NIA (no further informabon required)

NIA (no further informabon required)

I is considered there is no nsk if these chemicals being eleased to the enwronment Iue to the controls in place Should spillages occur they ould be easily swept up herefore not considered to be a iotenbal nsk

Micro Lab don Haz

lon Haz

'447-47-8

Plate count agar 70

NIA (no furlher informabon required)

Present in a solid state so not potenbal for leaking to drain All personnel are trained in the correct use and disposal of this matenal All waste matenal is stored in a designated area and removed from the laboratory by approved hazardous waste contractors

1.0005

1.0005

Micro Lab rl0

les

Maximum recovery diluents Baird parker agar

71

72 Xn, Xi, R22/36/38 Nodata . available. Bio Lab

les j00 ml '790-58-1 T. Xi, R25136I38

xn, w 2

Egg yolk tellurite

Chromocull tbx

73 No data available

No data available.

Bio Lab

S Bio Lab les 102-95-4 1.0005 . 74

20

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I . . , . - 1

I I . - I .

. . , .

1 .

, ..

. I

I . . . I .

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Staunton Foods Lld October 2014

206-132-7

7647-01-0

7789-00-6

7601-54-9

9001-75-6

N/A

IED Site Rewrl

Xn

C, XI, R34. R37

T.N, R36/37/38. R43, R50153

R36138

XI, R36137138/42,

Non Haz S22-24-26-36-37

Non Haz

Non Haz

HCL 37% 71 Potassium Chromate

pH Test Agar 8 0

Pepsin

pH Test Agar 6 0

Enwrochedt contact 5

Brain heart brote I

Bio Lab

Bio Lab

Yes

Yes

Bio Lab

Bio Lab

Bio Lab

Bio Lab 1 No

No data 1 available

No data 2 available

No data 0 00052 available . No data 0 005

available. , 0.0005

110 plates

0 0005

Spill kits are located in the area and employees are trained in response control

0 05 I

0 005 NIA (no further informabon required)

NIA (no further informabon required)

NIA (no furlher informabon required)

plates

Bio Lab I No

required)

required)

required)

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Staunton Foods Ltd. October 2014

IED Site Report

3. Discussion

As can be seen from Table 2 a robust system of environmental control is

exercised with respect to hazardous chemicals from delivery, storage and use

through to spill response and pollution prevention measures.

Procedures are in place to risk assess any new chemicals to the facility to

ensure that controls are put in place to ensure environmental protection. All

deliveries of chemicals to the facility are supervised by trained staff members.

All hazardous chemicals are stored on bunded units which are regularly

inspected and where necessary emptied of rain water. A programme of

integrity testing is in place at the site to ensure containment and supervision of

deliveries is undertaken by trained site personnel. Spillages and leaks from

mobile tankers, or drums during movement around site, if they were to occur,

would be detected and the potential for contamination would be mitigated by

way of site emergency procedures. In the unlikely event that there is a spillage,

of chemicals, spill kits are available and detailed emergency procedures are in

place and will be enacted.

The WWTP at Staunton Foods is run efficiently and is closely monitored to

ensure that the plant operates within the emission limit values. Freeboard is

always maintained in the balance tank to ensure unexpected hydraulic loads

can be balanced. The WWTP is also fitted with a high level alarms in place.

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. -

Staunton Foods Ltd. October 2014

IED Site ReDort

3 Conclusion

The hazardous chemicals, which have the potential to have an adverse impact

on the environment, have' been identified as part of the IED site report.

Potential chemical pathways have been comprehensively assessed at the

Staunton's Food Ltd. facility through critical evaluation of current activities and

site environmental management.

Owing to the storage and processes undertaken at the site and environmental

performance, the potential for releases of such substances is considered low

due to the controls in place. The control measures in place at Staunton Foods

Ltd. ensure that hazardous chemicals do not present a risk to the environment.

Site environmental management were found to be proactive I in their

performance in environmental management and the facility has a strong

compliance record with their CCC Licence.

For these reasons, based on the assessment details in table 2, we conclude

that there is no requirement for a full baseline study for the site.

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