integrated pollution control licensing annual ... · all plant and equipment used within the...

Farragh Proteins Annual Environmental Report 2010 IPPC Licence No. P0025-04

1

Integrated Pollution Control Licensing

Annual Environmental Report

2010

Farragh Proteins Crossdoney, Co. Cavan

Licence Reg. No. P0025-04 Prepared by: Farragh Proteins Date: March 2011


2

Table of Contents

1. Introduction………………………………………….…………...………….…......……3

1.1 Site Details…………………………………………………….………..….…..….3

2. Site description……………………………………………………………..…....……...4

2.1 Environmental Policy…………………………………………………...….…….6

2.2 Company Organization Chart…………………………………………...….…….7

3. Summary Information…………………………………………………….…....……….9

3.1 Monitoring of Final Treated Effluent……………………………….…...….….…9

3.2 Atmospheric Emissions ………….…...………………………………..…..…….11

4. Waste Management……………………………………………………….…...….……13

5. Resource Consumption summary ……….……………………………….…...….….…14

5.1 Fuel Consumption……………………………………………………..……..…...14

5.2 Electricity Consumption…….……………………………………….…..….…….14

5.3 Water Consumption……………………….……………………….….….….……15

6. Combustion Efficiency Results………………………………….……..….….…………15

7. Environmental Incidents and Complaints…………………………….……….…....…...16

7.1 Environmental Incidence……………………...……………………….…..….….16

7.2 Environmental Complaints…………………………………………………....….16

8. Ambient monitoring………………………………………………….……….……...…17

9. Summary Data……………………………………….…………………..………..….…18

10. Environmental Management Programme…………………………………....……..….22

10.1 Environmental Management Programme, Report for 2010…………..….….….23

10.2 Environmental Management Programme, Proposal for 2011………….…….....25

11. Efficient use of raw materials in the process and the reduction in waste generated…...33

12. Statement of measure in relation to prevention of environmental damage and

remedial actions (Environmental liabilities)………..………………………….…..….34

13. Residuals management plan…………………………………………………......….….46

14. Environmental Liabilities Risk Assessment Review with Financial Provisions….........50

15. Tank and pipeline testing and inspection report………………………………………..51

16. Noise Monitoring Report Summary……………………………………………………51


3

1. Introduction This Annual Environmental Report is for the year ending December 2010 in

compliance with IPPC Licence Reg. No P0025-04. It has been prepared in accordance

with EPA Guidance Notes for Annual Environmental Report Submission.

This report summarises the companies environmental performance for the 12 months

of 2010. Since the report frequently refers to conditions and schedules contained in

the IPPC Licence, it is recommended that the reader have a copy of the IPPC licence

No P0025-04 available.

1.1 Site Details

Site Name and Address

Farragh Proteins, Monery, Crossdoney, Co. Cavan

Licence Reg No.

P0025-04

Coordinates of Location

-7.4485 53.9677

Irish Grid Reference

E236239 N302 180

River Basin District

GBNIIENW

NACE Code

1011

Class No

7.7.1


4

2. Site Description The site extends over an area of 24,375m2 approximately 2km from Crossdoney

village. The factory is situated adjacent to the River Erne on predominately soil of

gley origin. The entire factory is within a bunded area.

The processing of animal by-products commenced at the site in Crossdoney, Co.

Cavan in 1951. Formerly known as Monery by-Products it came under new owner

ship in December 2004. It has been relicenced as a Category 3 plant since 7th

December 04, and since then has been collecting and processing raw material derived

from this category. The site is currently known as Farragh Proteins, a Category 3

rendering plant. The facility employs 20 personnel on a full time basis and operates 24

hours a day, 6 days a week. Buildings include the production area, loading area, raw

material intake area, a boiler house, housing for the Thermal Oxidisation unit,

laboratory building, changing area, work shop with stores area, a canteen and the

main office block

Since January 2005 there has been substantial investment on the site. The facility has

been upgraded to become a modern production plant, which has incorporated the best

technology available into each operation on the site. This saw the implementation of

a more energy efficient production system and improvements in pollution abatement

systems.

The site is designed so that it is easy to keep clean and tidy. All staff are encouraged

to keep good housekeeping and working practices.

Production

All plant and equipment used within the facility is of a high specification and

specifically designed to achieve complete processing of raw materials, while ensuring

minimum energy consumption. All products produced meet the EU 1774/2002 EU

Regulation. All raw material processed is regulated by HACCP. This food safety

system is based on the seven HACCP principals that incorporates IS 343 and IS 3219.

The company employs Best Available Technology (BAT) to ensure maximum

environmental performance.

The company manufactures Processed Animal Protein (PAP) and tallow. These

products are used in the manufacture of Pet food and as an ingredient for the animal

feed industry.


5

Production process requires the operation of on-site services including:

* The waste water treatment system

* The thermal oxidiser and steam boiler

* The biofilter odour abatement system

* Water

* Air

* Electricity

Heat required for cooking process is supplied by the on site waste heat boiler attached

to the TEAP unit. Farragh Proteins has two standard shell and tube steam boilers

which operate at 10 bar pressure on a duty/stand by arrangement.

The Thermal Exhaust Air Purification system (TEAP) oxidises the vapours from the

cookers. This is a process by which volatile organic compounds contained in the process

exhaust air are destroyed at temperatures in excess of 850oC.

Both the process and the WWTP are controlled by a computerised control system. This

system ensures that all processes are readily monitored and controlled thus minimising

any impact on the environment through human error.


6

2.1 Environmental Policy Farragh Proteins is committed to protecting all aspects of the environment as well as

the health and safety of its employees.

We provide all personnel with a safe, reliable, and responsive work environment that

is environmentally sensitive. We believe that a sound environmental policy

contributes to our competitive strength and benefits our customers, suppliers, and

employees by contributing to the overall well being and economic health of the

community we serve. We will strive rigorously to ensure that the facility is fully

compliant with its IPPC Licence requirements.

The company is committed to:

Complying fully with the letter and spirit of environmental laws and regulations.

Continually improving process design and reviewing recycling and waste

treatment technologies to reduce chemical usage, waste production and

environmental impact.

Work continuously to improve the effectiveness of our environmental

management.

Provide appropriate environmental training and educate employees to be

environmentally responsible in their job.

Monitor our environmental performance regularly through rigorous evaluations.

Manage water and wildlife resources in an environmentally sensitive manner.

Use energy efficiently throughout the plant.

Re-use and recycle whenever possible.

Use environmentally preferred materials.

Work co-operatively with others to further common environmental objectives.

Communicate and reinforce this policy throughout the company.


7

2.2 Company Organisation Chart Chief Executive Officer

John Gilroy

The Chief Executive Officer is responsible for the overall management of the facility,

including all environmental activities, business activities and approval of the

company’s environmental policy statement. The chief executive officer along with the

Plant Manager is responsible for developing the company’s environmental objectives

and targets in addition to defining the methods to be used to achieve these.

Supply Chain Manager

Ita Brady

The Supply Chain Manager is responsible for day to day management of the transport,

all environmental activities and business activities. She is also responsible for the

intake of raw material onto site.

Plant / Production Manager

Joe Cushnahan

The Production manager has overall responsibility for the management of on-site

operations including abatement systems. He is also responsible for developing the

company’s environmental targets and objectives and defining the methods used to

achieve these.

Production Unit Manager

John Gormely

Is responsible for the management of the process operations and for the maintenance

of production and services facilities. He is responsible for overall environmental

controls that are in place on the site.

Environmental Officer

Mariola Purgal

Is responsible for carrying out on site environmental analysis and measurement of

emissions from the activity. She also maintains contact with the EPA relative to

requirements of the IPPC licence.


8

Environmental Research Assistant

Lisa Clarke

Is responsible for the holiday cover of the Environmental Officers, research into new

technologies/projects, licence applications and commissioning of new equipment. She

also is responsible for ensuring environmental controls are operating correctly.

Figure 1: Company organisation chart.


9

3. Summary Information The Integrated Pollution Prevention and Control Licence (IPPC) as issued by the EPA

in 2007 specifies emission limit value’s (ELV’s) relevant to each particular emission

arising on site. The IPPC Licence specifies monitoring requirements and the

appropriate frequency for monitoring of emissions on site.

Regular monitoring as in compliance with IPPC Licence P0025-04 is carried out on

emissions to the atmosphere, water, waste, odour and noise. This report contains

summaries for the results obtained for the period 01st January to 31st December 2010.

3.1 Monitoring of Final Treated Effluent The treated effluent from the plant, which has been destined for release into the

receiving waters of the River Erne, is called Final Treated Effluent.

Regarding Schedule C.2.2 (Monitoring of Emissions to Water) of the IPPC licence

regular monitoring is carried out on a daily basis. The monitoring frequency and

methods used are outlined below:

Parameter Monitoring Frequency Analysis Method/Technique

Flow Continuous (Daily) On line flow meter with recorder

Temperature Weekly Temperature Probe

pH Weekly pH electrode/meter

Biochemical Oxygen Demand Weekly Standard Method

Suspended Solids Weekly Standard Method

Nitrates (as N) Weekly Standard Method

Total Ammonia (as N) Weekly Standard Method

Total Phosphorous (as P) Weekly Standard Method

Oils Fats & Greases Monthly Standard Method Table 1: Monitoring of FTE.


10

Mass emissions to receiving waters for the reporting period are summarised in Table 2

below:

Parameter ELV 2009 2010

Flow (m3) 87 600 40 582 57 061

BOD (Kg/year) 1 752 449.2 646.4

Suspended Solids (Kg/year) 2 190 457.9 784.6

Nitrates (Kg/year) 1 314 224.7 245.4

Ammonia (Kg/year) 2 190 134.5 293.5

Total Phosphorous (Kg/year) 175.2 41.0 37.7

Oils Fats & Grease (Kg/year) 1 314 122.9 311.9 Table 2: Summary of emission of FTE to receiving waters Emission Point Reference No. SW - 1

In year 2010 the average daily flow was 156.3 m3.

As can be seen from table 2 the mass emissions from the discharge of effluent are

well below the permitted Emission Limit Value. The percentage by which the mass

emission was below the ELV (emission limit values) for the reporting year can be

seen in table 3 below:

Parameter

% Below Permitted

ELV (2010)

Flow (m3) 34.9

BOD (Kg/year) 63.1

Suspended Solids (Kg/year) 64.2

Nitrates (Kg/year) 81.3

Ammonia (Kg/year) 86.6

Total Phosphorous (Kg/year) 78.5

Oils Fats & Grease (Kg/year) 76.3 Table 3: Percentage by which mass emissions were below the emission limit value as permitted by IPPC Licence P0025 – 04.


11

3.2 Atmospheric Emissions Emissions to the atmosphere from the woodchip biofilters were monitored in

compliance with Schedule C of the IPPC Licence No.: P0025-04. The mass emissions

are presented below:

Parameter ELV (kg/year)

Mass emissions 2009

(kg/year)

Mass emissions 2010

(kg/year)

Ammonia 37 778 0.5 0 Amines 3 576 0.9 0 Hydrogen sulphide &

Mercaptans 7 606 6.5 10.3 Table 4: Summary of emissions from Biofilters for year end December 2010

As can be seen in Table 4 the Biofilters have been fully compliant with the Emission

Limit Values.

Emissions to the atmosphere from the TEAP unit (Emission Point Reference No: A1-

1) and Boilers (Emission Point Reference No: A1-2 and A1-3) were controlled and

monitored as in compliance with Schedule C.1.1 and C.1.2 of the IPPC Licence No.

P0025-04. Mass emissions were based on Emission Limit Value for the Oxidiser and

Boilers regarding Schedule B.1 of the IPPC Licence. Mass emissions to Air for the

reporting period are summarised against Limit Values in Table 5 and 6 below:

TEAP unit Emissions

TEAP ELV

(tonnes/year)

Mass emissions

2009 (tonnes/year)

Mass emissions

2010 (tonnes/year)

Oxides of sulphur 148.86 4.64 10.09

NOx 88.50 25.56 37.22

Particulates 36.20 11.71 12.56 Table 5: Summary of ELV and mass emissions for TEAP unit for years: 2009 and 2010.


12

Boiler Emissions

Boilers ELV

(tonnes/year)

Mass emissions

2009 (tonnes/year)

Mass emissions

2010 (tonnes/year)

Oxides of sulphur 198.66 10.72 14.09

NOx 87.60 37.89 35.26

Particulates 46.70 22.05 16.16 Table 6: Summary of ELV and mass emissions for Boilers for years: 2009 and 2010.

Mass emission for each parameter was well under the ELV. The table below

summarised combined total mass emissions to the atmosphere for years: 2009 and

2010:

Parameter

ELV

(kg/year)

Mass emissions 2009

(kg/year)

Mass emissions 2010

(kg/year)

SOx 347 520 15 359.4 24 179.8

NOx 176 100 63 451.9 72 477.1

Particulates 82 900 33 752.9 28 722.4

CO N/A 2 410.8 9 331.2

CO2 N/A 4 319 130 7 578 530

TOC N/A 246.9 1 068.4

Ammonia N/A 152.4 34.0

Amines 3 576 0.9 0

Hydrogen Sulphide

& Mercaptans 7 606 6.5 10.3 Table 7: Mass emissions to the atmosphere for years: 2009 and 2010.


13

4. Waste Management Wastes for disposal and recovery arising from on site activities comprise of the

following:

1. Utilities waste oil, laboratory waste and florescent tubes.

2. Other wastes for disposal or recovery: domestic and canteen waste, general office

and factory waste, dewatered WWTP sludge.

No direct disposal of waste is carried out on site. When wastes are disposed of to

landfill, an approved and licensed contractor is used to collect the wastes and they are

only disposed of at a properly licensed facility.

For the year-end December 2010 the waste that went off site for recovery or disposal

included the following:

Table 8: Quantities of waste generated on site for years 2009 and 2010.

A waste record is maintained on site and is available for inspection at all times.

Company name and address Waste EWC 2009

(tonnes)

2010

(tonnes)

Mixed metals 17 04 07 21.2 30.4

Felix Gormley Used Metal Disposals,

Monery, Crossdoney, Co. Cavan

Ferrous metals 16 01 17 1.18

Iron and steel 17 04 05 16.8

Wood 17 02 01 1.04

Wilton Waste Disposal & Recycling,

Kiffa, Crosserlough, Co. Cavan

Plastic 17 02 03 2.0

Municipal waste 20 03 01 76.7 44.88

College Proteins,

College Road, Nobber, Co. Meath

Effluent sludge from

on-site treatment

02 02 04 1481.87 1760.76

Enva Ireland Limited, Clonminam

Industrial Estate, Portlaoise, Co. Laois

Waste oil 13 02 08 1.5


14

5. Resource consumption summary

5.1 Fuel Consumption There are two types of fuel used for steam generation at Farragh Proteins: Heavy Fuel

Oil and Tallow Fuel Oil. Electricity is required for motive power.

The TEAP unit was purchased with a duel fuel burner for Heavy Fuel Oil and Tallow.

Tallow has been the fuel of choice on site and is burned in both boilers and TEAP

unit. The summary of fuel usage is presented below:

Year Tallow Used

(tonnes) HFO Used (tonnes)

Total Fuel Used (tonnes)

2009 3 524.98 1 378.05 4 903.03

2010 2 576.32 2 417.98 4 994.30

Table 9: Fuel consumption summary for years: 2009 and 2010.

Despite of rising fuel usage figures for 2010 the company has reduced fuel

consumption by 15.5% for each tonne of Raw Material comparing with 2009.

Management of energy resources is a priority for the company. This involves

monitoring and targeting to highlight issues which can be addressed.

5.2 Electricity Consumption Electricity usage on the site has increased by 589,747 kWh due to a number of

environmental changes that occurred on the site during the reporting period.

Comparing with 2009 the company reduced the electricity usage by 6.1% for each

tonne of raw material processed on site.

Summary of electricity usage is outlined below:

Year Electricity usage (kWh)

2009 4 387 508

2010 4 977 255

Table 10: Electricity usage for the years: 2009 and 2010.


15

5.3 Water Consumption Water consumption for the reporting period was 54,276 m³. This is an average of

148.7 m³ per day. The increase in water consumption is compensated by reduction in

both electricity and fuel usage per each tonne of raw material.

Summary of water usage is presented below:

Year Water usage (m³)

2009 39 921

2010 54 276

Table 11: Water usage for the years: 2009 and 2010.

6. Combustion Efficiency Results A combination of tallow and heavy fuel oil is used in the boilers and the Oxidiser.

The combustion efficiency from the boilers and TEAP stacks was carried out as per

Schedule C.1.2 of the Licence. The results are presented in table 12 below:

Emission point Oxidiser (A1-1) Boiler 1 (A1-2) Boiler 2 (A1-3)

Total running

hours in 2010

4433 1246 3159

Combustion

Efficiency (%)

89.0 83.8 88.2

Table 12: Combustion Efficiency in 2010.


16

7. Environmental Incidents and Complaints

7.1 Environmental Incidence

Date Nature of the incident Corrective action

18/12/2010

Valve on the vapour ducting to the

Thermal Oxidiser frozen resulting in

vapour leak at the gaskets.

Process stopped when the leak was detected. Restarted when the valve was defrosted and gaskets fixed.

31/12/2010 ESB mains power failure.

Safety measures explored to reduce

the risk of reoccurrence. Table 13: Summary of incidents.

7.2 Environmental Complaints

Complaints received in this reporting period:

Complaint class

Noise Odour Water Dust Procedural Misc. Total

Total None 2 None None None None 2

Complaints received in year 2009

Complaints received in year 2010

JANUARY 2 0 APRIL 0 0 JUNE 0 0 AUGUST 0 0 SEPTEMBER 0 0 OCTOBER 0 0 NOVEMBER 0 0 DECEMBER 0 2 TOTAL 2 2

Table 14: Summary of complaints received during years: 2009 and 2010.

The company continues to use the Best Available Technology for the Rendering

Industry to eliminate the possibility of odour emissions from the site.

Odour surveys are carried out each day to ensure that the abatement system is

functioning and that we are not causing a nuisance beyond the factory boundary.

Following on from this odour survey a site inspection is also carried out in order to

evaluate any potential fugitive emission.


17

8. Ambient monitoring Ambient monitoring is carried out regarding the Schedule C.6 of the IPPC licence.

Farragh Proteins is under an obligation to monitor groundwater on a regular basis.

The results are outlined below:

Groundwater monitoring Date 15/03/2010 06/09/2010 pH ( at 20°C ) 6.8 6.9 TOC (mg/l ) 1.5 5.1 Ortho- Phosphate (mg/l ) 0.01 0.01 Nitrates (mg/l ) 2 1.7 Total Ammonia (mg/l ) <0.05 0.0 Total Nitrogen (mg/l ) 1.5 3.9 Conductivity (μS/cm at 25°C) 972 750

Table 15: Ambient monitoring for year end December 2010.


18

9. Summary Data Summary Of Emissions Company Farragh Proteins Address Monery, Crossdoney, Co. Cavan Contact Name Mariola Purgal Telephone 049 4337107 E-mail [email protected] GPS Co-ordinates(4N,4E) E236 230 N302 180 IPC Register Number P0025-04 IPC Class A23 IPPC Class 7.7.1 NOSE-P Code NACE CODES Section C Sub-Section 1011 Division Group Class

Process Emissions to Waters If Emissions to Waters do not apply to your license, please tick here

Indicate Yes if emissions are to: Freshwater or Sewer or Sea

Yes No No Parameter Unit Max. Licensed Emission per year 2007 2008 2009 2010 Volume M3/yr 87600 27492 44267 40582 57061 Suspended Solids Kg/yr 2190 267.4 689.9 457.9 784.6 BOD Kg/yr 1752 265.1 480.6 449.2 646.4 COD Kg/yr N/A 2043.8 1367.3 2221.4 Total Dissolved Solids Kg/yr Total Nitrogen Kg/yr Phosphate Kg/yr 175.2 34.96 61.1 41.0 37.7 Toxicity Max. TU Hg Kg/yr Cd Kg/yr Pb Kg/yr Cr Kg/yr As Kg/yr Zn Kg/yr Cu Kg/yr Ni Kg/yr % Compliance % 100 98.65 99.7 100 Number of samples 52 53 53 52


19

Energy Usage

Energy Consumption Sulphur Content Unit 2007 2008 2009 2010 Heavy Fuel Oil 1.00% T/yr 399.49 2 993.59 1 378.05 2 417.98 Light Fuel Oil M3/yr 0 0 0 0 Natural Gas M3/yr 0 0 0 0 Electricity MWhr 2 708.46 4 091.01 4 387.51 4 977.26 Coal Kg/yr 0 0 0 0

Environmental Complaints 2007 2008 2009 2010 Complaints received 0 18 2 2

Complaints requiring corrective action 0 18 2 2

Categories of complaint 2007 2008 2009 2010 Odour 0 18 2 2

Water Unit 2007 2008 2009 2010 On-site groundwater use m3/yr On-site surface water use m3/yr Municipal water use m3/yr

Accreditation EMAS (Yes/No) No ISO 14000 Series (Yes/No) No Certification Pending (Yes/No) No


20

Information on each waste stream

Euopean Waste

Catalogue Code Hazardous (Yes/No)

Description of Waste

Quantity (t/year)

Disposal/ Recovery Code

Location of Disposal/ Recovery

Name of Waste Disposal Recovery Contractor

02 02 04 No

Effluent sludge from on-site treatment 1760.76 D10

College Road, Nobber, Co. Meath College Protein

17 04 07 No Mixed metals 30.4 R4

16 01 17 No Ferrous metals 1.18 R4

17 04 05 No Iron and steel 16.8 R4

Monery, Crossdoney, Co. Cavan

Felix Gormley Used Metal Disposals

17 02 01 No Wood 1.04 R12

17 02 03 No Plastic 2.0 R3

20 03 01 No Municipal Waste 44.88 D13

Kiffa, Crosserlough, Co. Cavan Wilton Waste Disposal & Recycling

13 02 08 Yes Waste oil 1.5 R9

Clonminam Industrial Estate, Portlaoise, Co. Laois Enva Ireland Limited


21

Waste 2005 2006 2007 2008 2009 2010 Total quantity of waste produced in calendar year(Tonnes) 11272 1308.69 461.79 1593.95 1579.77 1858.56 total quantity of waste disposed of on-site 0 0 0 0 0 0 total quantity of waste disposed of off-site 11228.83 1239.63 420.59 1564.47 1558.57 1805.64 total quantity of waste recovered on-site 0 0 0 0 0 0 total quantity of waste recovered off-site 44 69.06 41.20 29.48 21.2 52.92 2005 2006 2007 2008 2009 2010 Quantity of non-hazardous waste produced in calendar year 11272 1308.69 461.79 1593.95 1579.77 1857.06 quantity of non-hazardous waste disposed of on-site 0 0 0 0 0 0 quantity of non-hazardous waste disposed of off-site 11228.83 1239.63 420.59 1564.47 1558.57 1805.64 quantity of non-hazardous waste recovered on-site 0 0 0 0 0 0 quantity of non-hazardous waste recovered off-site 69.06 41.20 41.20 29.48 21.2 51.42 2005 2006 2007 2008 2009 2010 Quantity of hazardous waste produced in calendar year (Tonnes) 0 0 0.02715 0 0 1.5 quantity of hazardous waste disposed of on-site 0 0 0 0 0 0 quantity of hazardous waste disposed of off-site 0 0 0.02715 0 0 0 quantity of hazardous waste recovered on-site 0 0 0 0 0 0 quantity of hazardous waste recovered off-site 0 0 0 0 0 1.5


22

10. Environmental Management Programme The Environmental Management Programme is to ensure maintenance of the process of managing the environmental issues associated with the facilities activities. In general the aim of it is to encompass all the activities and technologies necessary to manage environmental performance. It includes an updated 5-year timetable for targets and objectives. The targets and objectives of the EMP are in place to enable the company to conduct its activities while having a formal managed programme by which to ensure continued using of cleaner technology, cleaner production, reduction and minimisation of waste, growth and development in the areas of environmental protection against a realistic timeframe and also to serve as a record of the targets that have been met by the company within the last year. When establishing and reviewing objectives, the following is considered: 1. Compliance with all conditions and schedules of the IPPC Licence 2. Significant environmental aspects 3. Technological Options 4. Financial, Operational and Business Requirements 5. Further develop management and employee commitment to the protection of the

environment, with clear assignment of accountability and responsibility 6. Provide appropriate and sufficient resources, including training to achieve targeted

performance levels on an on-going basis 7. Maintenance of emergency preparedness and response programme 8. Establishment of a system of operational control and maintenance of the

programme to ensure continuing high levels of system performance 9. Evaluate environmental performance against the policy, objectives and targets and

seek improvement where appropriate 10. Maintain appropriate communications with internal and external interested parties 11. Recording and reporting to the EPA 12. Control and attenuation of emissions 13. Contingency plan for the prevention of incidents. Annual EMP shall address as a minimum the following:

*Maintenance and calibration of control and monitoring equipment *Prevention of incidents with the potential for environmental consequences and

the preparation and implementation of contingency plans in the event of an incident

*Savings in water, energy and material usage *Improvements in treatment/ abatement systems to reduce emissions *Improvements in equipment cleaning procedures resulting in reduced

materials usage or alternative materials usage *Improved process control (equipment and management) to reduce waste *Relevant employee training *Reduction, reuse and recycling of waste.

This Environmental Management Programme details the immediate and long-term objectives and targets of the company and their method of achievement. This document details in particular how the programme will function over the forthcoming five years.


23

10.1 Environmental Management Programme - Report for 2010 As per condition 2.2.2.3 of our IPPC License, Farragh Proteins is required to prepare a report on our environmental management programme, including the success in meeting agreed targets and to submit it to the Agency as part of our AER. This report is presented below. 10.1.1. Environmental Management System Achievements The programme has been updated to satisfy Condition 2.2 of IPPC licence No.P0025-04 and details of the programme proposed herein require the approval of the Environmental Protection Agency (EPA). Over the last number of years Farragh Proteins has been developing and updating its Environmental Management System (EMS). The HACCP system has been implemented to ensure controls are in place at all levels of operation. Environmental Management Systems has become part of the daily management programme where all relevant environmental issues are circulated in house. This includes:

Process performance and management parameters Biofilters and Waste Water Treatment Plant performance Oxidiser and Boiler efficiency Water and Energy efficiency Other extraordinary observations and maintenance

10.1.2 Energy Conservation Achievements 1. Comparing with 2009 Farragh Proteins has reduced the consumption of fuel by 15.5% and electricity by 6.1% for each tonne of raw material processed on site. This is mainly due to modification on Production Lines and installation of the Evaporator Plant. 2. All records for energy use and costs in relation to product output are kept on site as well as the energy audit with recommendations. 3. Employees have been trained on energy consumption and the importance of energy savings. 10.1.3 Waste Management Achievements 1. Plastic drums/ containers, cardboards, paper, scrap metal, toners, wooden pallets are sent for recycling. 2. Empty IBC’s are returned to our suppliers.


24

3. The waste has been labelled and segregated. 4. Employees have been trained in Environmental Awareness and the importance of recycling and segregating recyclable waste. 10.1.4 Minimisation of Atmospheric Emissions and Reduction of Fugitive

Emissions Achievements 1. All Emission Points have been monitored on a regular basis. 2. The Company has maintained the biofilters and ensured that all buildings which handle odorous material are under negative pressure at all times. 3. A programme for monitoring and reduction of fugitive emissions has been forwarded to the Agency and maintained. 4. An external contractor is maintaining the air conditioners to prevent greenhouse gases (F-gas) fugitive emission. 5. The Production Lines were modified; more gentle rendering process which prevents high volatile fats being created and thus preventing odour. The upgrade also reduces CO2 emission. 6. Evaporator Plant on the Production Lines was installed. It uses the vapours from the cooking process. 7. Concrete balance tank has been ducted to the WWTP biofilter thus emission from this tank is eliminated. 8. Continuous monitoring of boiler chambers has been introduced. 9. New roof sheeting has been installed on the Raw Material intake building thus possibility of fugitive emission has been reduced. 10. Farragh Proteins started installation of the air lock system on the raw material intake area. 10.1.5 Upgrading of the Waste Water Treatment Plant Achievements 1. New energy efficient compressor was installed. 2. New aeration system was installed in Tank 3. 3. Concrete balance tank has been ducted to the waste water treatment plant biofilter. 4. New laboratory for the waste water and final discharge analysis was built in August 2010. 10.1.6 Water Conservation Achievements 1. Boiler and TEAP unit feed water has been controlled to reduce water loss through blow downs. 2. Employees have been trained in Environmental Awareness and the importance of efficient water usage.


25

3. The flow meters have been installed on the boiler and thermal oxidiser feed water to help control and reduce water consumption. 10.1.7 Improving Quality Control in the laboratory Achievements 1. The company participates in the Agency’s intercalibration programme and thus has improved the quality of on–site water testing.

10.2 Environmental Management Programme – Proposal for 2011 Schedule of Environmental Objectives and Targets In line with the licensee’s objective to minimise the environmental impacts of the Farragh Proteins facility, the following Objectives and Targets have been drawn up. Environmental Objectives and Targets

Objective Target Management of the Activity

To continue to strive to develop and expand on the existing E.M.S.

Energy Conservation

To reduce energy consumption, set –up Energy Management System (Monitor Energy Consumption).

Reduction of Fugitive Emission Reduction of complaints

Conduct monitoring as required by P0025-04 Licence. To ensure the facility causes no nuisance odour outside the site boundary.

Waste Management To increase amount of recycling on site. Support the use of renewable fuel types

To eliminate the use of Heavy Fuel Oil on the site.

Minimisation of atmospheric emissions To continue to use carbon neutral fuel types instead of fossil fuels.

Upgrading of Waste Water Treatment Plant

Complete works and improve treatment process.

Environmental Awareness Training Maintain training documents and use it to conduct in house environmental training sessions.

Reductions in water usage To reduce water consumption Installation of an airlock system To reduce fugitive emissions from the raw

material intake area. Restructuring of feed water to the Boilers and Oxidiser

To introduce a new sand filtering system and improve softening and storage process.


26

10.2.1 Environmental Management System Farragh Proteins is committed to continued implementation of a full environmental management system under the IPPC Licence No.P0025-04. Method In order to implement an effective environmental management system, staff are continually trained and support from external experts is used to supervise and drive projects where the expertise is not to be found in house. Targets

1. To continue to strive to develop and expand upon the existing Environmental Management System.

2. To continue updating EMS on regular basis but at least annually. An important aspect of Farragh Proteins EMS is to ensure that its environmental programmes are consistent with its environmental policy. Benefits Benefits include an improved understanding of environmental impacts arising from the activities on all levels of the organisation. Through the implementation of the EMS, improved control over emissions as well as a better resource management will be achieved, thus preventing incidents and minimising resource consumption. Responsibilities Responsibility for the implementation of the programme shall rest with Senior Management at Farragh Proteins, in particular with the Plant/Production Manager, Supply Chain Manager and Production Unit Manager. The Environmental Officer will deal with day to day operations and maintenance of the IPPC license requirements.

10.2.2 Support the use of renewable fuel types Reasons The European Commission has cut Ireland’s permitted carbon emissions by 6.4% to 21.15 million for the period 2008-2012. In accordance with the EU Emissions Trading scheme for compliance with the Kyoto Protocol, Ireland is obliged to meet its carbon emissions. Benefits Bio Heating Oil is a carbon neutral fuel as it is composed of vegetable oil and tallow. Using renewable energy resources helps:

* use an indigenous renewable fuel and reduce CO2 emissions

* reduce reliance on expensive fuel imports Target To eliminate the use of Heavy Fuel Oil on site and use Bio Heating Oil instead.


27

Responsibilities The Supply Chain Manager and Plant/Production Manager have overall responsibility for the implementation of this project. 10.2.3 Energy Conservation Reason Reduction in energy consumption will save money and help to comply with government regulations. Targets 1. To analyse energy consumption and fuel usage against production data. 2. To involve Process Operators in Energy Awareness Programme. 3. To reduce consumption of energy supply. 4. Reduce steam consumption by 5% through an energy management system. 5. Further reduction of electricity usage by 2% through monitoring and targeting of process equipment. 6. To carry out regular steam trap surveys to ensure all traps are working correctly. To improve steam trapping and air venting on steam distribution systems. 7. To install an accumulator for steam to maintain a more constant steam pressure. 8. To assess efficiency of new equipment and streamlined production versus new technology. 9. To relocate the boilers closer to the factory to reduce heat loss and increase energy efficiency. 10. To further modify Production Line to be more energy efficient. It will mainly results in fuel saving. 11. To replace the two existing boilers with a single larger capacity high efficiency boiler. 12. To carry out the Resource Efficiency Assessment by external advisor. Responsibilities The Plant/Production Manager and Production Unit Manager have over all responsibility for all process and structural changes. 10.2.4 Installation of air lock on the raw material intake area. Reasons Installation of an airlock system to the raw material intake building is to ensure that negatives pressure shall be maintained throughout this building where animal by- products are off loaded in the first stage of the process. This will ensure that there is no significant escape of odours and ensures compliance with Condition 3.23 of IPPC Licence Reg. No. P0025-04. Targets To complete installation of the air lock system.


28

To fully eradicate the possibility of the escape of fugitive emissions from the raw material intake area caused by a fall in negative pressure within the building due to the entrance/exit of lorries. Responsibilities The Plant/Production Manager shall be responsible for organising the implementation of this target.

10.2.5 Waste Management Reason Each year the facility try to reduce the amount of waste generated as minimisation of waste will preserve resources and reduce environmental impacts associated with the storage, transport, treatment and disposal of generated waste. Segregation of waste ensures increased amount of recycling and reduced amounts of waste going to landfill. The reuse and recycling of waste material on site can also result in financial savings through reduced waste disposal costs. Targets 1. To reduce waste production by 25% by means of reusing and recycling waste materials from the site 2. To continue to return used plastic drums and IBC’s to the suppliers. 3. To maintain continued training of all personnel on the importance of segregating waste generated on site. 4. To give a person responsibility for the management of waste on site. 5. To continue to send all used computer cartridges, mobiles and PDA’s to recycling appeals. 6. To continue collecting used batteries for safe disposal and recycling. 7. To continue awareness for the need for waste minimisation and recycling and to reduce the amount of waste going to landfill. 8. To improve waste segregation. 9. To carry out a waste audit to determine any other materials that could be recycled or reused. 10. To carry out the Resource Efficiency Assessment by external advisor. Responsibilities The Plant/Production Manager, Environmental Officer and Production Unit Manager shall be responsible for organising the implementation of this target. 10.2.6 Minimisation of Atmospheric Emissions Reason To continually ensure that Farragh Proteins has the minimum possible effect on its surrounds.


29

Targets 1. To keep 100% compliance with our atmospheric limits. 2. To reduce mass emissions to the atmosphere. 3.To continue using indigenous renewable fuel types and thus reduce carbon footprint. 4. To start using Bio Heating Oil and replace HFO by BHO, carbon neutral fuel. 5. To complete installation of air lock to the raw material intake building. 6. To reduce the CO2 emission by modifying existing Cat 3 Line. 7. To install a new Biofilter and thus to increase the volume of air extracted from the process building by up to 40,000 m³/h. This will also decrease fugitive emission. 8. To replace the two existing boilers with a single larger capacity high efficiency one. 9. To move the boiler house closer to the factory thus to reduce the fuel and steam usage. 10. To reorganise the existing ducting to the Thermal Oxidiser and biofilters. Responsibilities The Plant/Production Manager and Production Unit Manager are responsible for minimisation of atmospheric emissions. 10.2.7 Upgrade of Waste Water Treatment Plant Reasons Farragh Proteins have planned to carry out a series of environmental improvements to the WWTP. Targets 1. Area to be re-concreted and reorganised as part of a house keeping improvement. 2. Mild Steel tanks to be replaced with stainless steel to minimise the possibility of leaks. 3. Upgrade the drainage system for the waste water treatment plant and make sure that all foul drains are clearly marked. 4. To investigate energy and time saving in the WWTP operation. 5. To introduce new efficient backwash system for the sandfilter. Responsibilities The Production Unit Manager and Plant/Production Manager shall be responsible for the implementation of the above objectives. 10.2.8 Awareness and training Reasons Although Farragh Proteins operate one of the premier rendering plants in the country and have a team of management and employees who have many years of experience of operating rendering facilities, with the majority of the senior management team having worked at the site since the 1970’s, it is very important to ensure all employees are informed and trained in any changes in the Environmental section of Farragh proteins.


30

Description Prior to any staff commencing work on site, they will be required to attend a site induction course. This course will cover the following issues: establish the management structure, roles and responsibilities and the necessary

communication pathways; the importance of compliance with the conditions of the IPPC license; the potential environmental impact of the work activities and the consequences of

departing from the specified operating procedures; the environmental benefits of improved performance and the content of documentation relating to the licensed activities and its location. Target 1. To ensure continuous training of all relevant staff in the prevention and identification of all environmental aspects. 2. To register of all staff who have attended a course, maintain the register and update it when required. 3. To continue to identify environmental awareness training where relevant. A relevant issue can include:

Implementation of new piece of environmental legislation with important impact on the company’s operations.

Revision of the licence and change in its attached conditions Major incidents experienced on site Exceedence of licence requirements Major or frequent irregularities in following established standard operating

procedures Significant decrease in environmental performance

Responsibility It will be the responsibility of the Plant/Production Manager to provide suitably qualified staff and to ensure that the staff are given adequate training to enable them to fulfil their duties. 10.2.9 Reduction of Fugitive Emissions Reasons In compliance with Condition 5.7 of IPPC Licence No. P0025-04, the Company maintains a programme of monitoring of fugitive emissions to air. Targets 1. To minimise of fugitive emission to air by monitoring potential source of fugitive emission from the installation. 2. To ensure the facility causes no nuisance odour outside the site boundary and that there are then no complaints regarding the facility. 3. To reduce the creation of high volatile fats by modifying existing Cat 3 Line. 4. To construct new chemical store regarding condition 3.6.2 of the Licence.


31

Responsibility Plant/Production Manager, Production Unit Manager and Environmental Officer are responsible for reduction of fugitive emission. 10.2.10 Water Conservation Reason Reduction in water usage is an important issue for the company. It helps to reduce cost and minimises loading impact on the water treatment process thus as a consequence the minimisation of possible environmental impacts. Targets

1. To continue awareness training of all relevant staff to ensure that there is responsible usage of all water on site.

2. To maintain a cleaning programme for the process and yard areas that helps to minimise waste loads arising from treatment in the wastewater discharging from the areas.

3. To examine installation of a high pressure wash system for washing in the factory. The existing low pressure wash system is not an efficient use of water compared to a high pressure system.

4. To identify opportunities for reduction in the quantity of water used on site including recycling and reuse initiatives.

5. To continue maintaining pipes, tanks and associated appliances carrying water on the site.

6. To continue carrying out a visual inspection for leaks on all above ground storage areas, pipes, valves and flanges on regular basis.

7. To continue monitoring the boiler and TEAP units feed water and control on boiler blow downs.

8. To install flow meters on biofilter feed water. 9. To introduce new high pressure wash system for lorry washing.

Responsibility The Plant/Production Manager and Production Unit Manager shall be responsible for the implementation of the above objectives. 10.2.11 Reduction of Complaints Reason Despite series of improvement there were still 2 odour complaints for the reporting year. The complaints were associated with incidents on the site (see page 16 of the report for details) and bad weather condition in late December. It is a priority for the company to strive to ensure there are zero complaints. Targets 1. To carry out extensive odour survey on site.


32

2. To ensure the facility causes no nuisance odour outside the site boundary and that there are then no legitimate complaints regarding the facility. 3. To continuous investigate and identify areas that have the potential to have environmental significance Responsibility The Production Unit Manager and Environmental Officer are responsible for the implementation of the above objectives. 10.2.12 Restructuring of feed water to the Boilers and Oxidiser Reasons Currently feed water for the boilers is taken from the River Erne. This water is filtered through a sandfilter prior to chemical treatment in order to ensure all suspended solids are removed. It is proposed that when relocating the boilers nearer to the processing area, the sandfilter shall be upgraded. This shall help ensure continued high quality feed water going forward to the boilers. Targets 1. To improve storage system for the river water by installing new storage tank inside the factory building. The tank will be a benefit specially in winter time. 2. To introduce a new sand filtering system for the treating off river water feeding the boilers. 3. To improve softening of boiler feed water. 4. To ensure reduction in boiler treatment chemicals. Responsibilities The Plant/Production Manager and Production Unit Manager are responsible for the improvement.


33

11. Efficient use of raw materials in the process and the reduction in

waste generated.

Raw materials like tallow and steam are very important in the process. Tallow is a

carbon neutral fuel and is used as an energy source in Farragh Proteins to power the

boilers and the TEAP unit. The tallow produced in Farragh Proteins is dispatched

however Farragh proteins takes tallow from College Proteins to use as fuel.

Streamline steam generation is being examined. The use of a steam accumulator for the

boilers would aid more streamline operation of the boiler steam usage thus reducing the

waste of steam and energy.

Fuel, electricity and chemical usage is checked daily in order to ensure efficient usage.

The Resource Efficiency Assessment is to be carried out this year by external advisor.

Minimisation of water demand and the volume of trade effluent discharge.

Currently in Farragh Proteins river water supplies boilers, water for washing and the

cooling of gear boxes. There is also a well however it has only domestic uses. The water

from the river to the boilers is currently passing through a filter and a softener to reduce

total suspended and dissolved solids in the feed water this in turn reduces the blowdown

time and water loss from the boilers.


34

12. Statement of measure in relation to prevention of environmental damage and remedial actions (Environmental liabilities) 12.1 DESCRIPTION In accordance with condition 2.2 and condition 9 of our IPPC licence, emergency response procedures have been developed and documented to cater for breakdown of equipment in specified areas of this activity and to cover serious accidents on the site. ERP provides details of the action required in the event of an emergency situation arising at the facility. Various aspects of the plant have been examined and where appropriate, procedures implemented and in the case of major breakdown have been prepared. In all cases where a breakdown of critical equipment associated with an emission abatement system, which could lead to an accidental emission, does occur a report sheet, containing the information outlined below, will be completed and retained on site. In the event of an incident notification the following details are required: * Name, address and Registration Number of the company * Category of the incident * Contact person’s name, address and telephone number * Location of the incident and its duration * Date and time when the incident happened and when it was discovered * Details of the occurrence * Type of incident (i. e. fire, spillage, leaking, process control malfunction) * Materials emitted / type of pollution and its source * Environmental significance of the incident * Weather conditions, i.e. rain, wind * Vulnerable receptors (i.e. river, road, town land) * Whether emergency services were contacted * What other bodies were contacted including Local Authority and Regional Fisheries Boards * The steps taken to minimise the emissions, prevent the continuation and avoid recurrence * Determine the likelihood of a reoccurrence All incidents and corrective actions taken are recorded on the company incident register (EMS 16). A separate Emergency Response Report will be completed for each emergency that may arise at the activity.


35

12.2 ENVIRONMENTAL INCIDENCE A report on the occurrence must be entered into the Incident Register Log. For emergencies occurring outside the normal working hours, i.e. 8.00 am to 5.00 pm and on weekdays, the Plant Manager has authority to contact key personnel/senior Management as deemed necessary. Two types of accidental emissions are deemed to be possible in the event of an emergency, namely: Accidental Emissions to Atmosphere, Accidental Emissions to Waters. 12.2.1 Accidental Emissions to Atmosphere The company will implement the following procedure in the event of an accidental emission to atmosphere from this activity. Procedure in the event of Accidental Emission to Atmosphere from this Activity: An accidental emission is most likely to occur as a result of a breakdown of some equipment at the factory. Some unavoidable breakdown may occur on the site and in such an event the following procedures will be implemented:

1. The breakdown will be reported to the factory manager by the person observing the breakdown,

2. The factory manager will ensure that the faulty equipment is identified, made safe and repaired, or replaced, as appropriate without undue delay.

3. The likely impact of the breakdown will be assessed, taking into consideration the time the equipment may be out of service and the likelihood of odour nuisance occurring.

4. The Environmental Protection Agency will be notified as well as the Local Authority.

5. If the equipment is a critical part of the process plant and a significant odour nuisance is likely to occur processing will be discontinued until the fault has been rectified.

12.2.2 Accidental Emissions to Waters In the event that an accidental emission to waters the following procedure would be implemented: Procedure in the event of an Accidental Emission to Waters: The following procedure will be implemented in the case of a breakdown, which could lead to an accidental emission from the wastewater:

1. The breakdown will be reported to the senior person responsible for the operation of wastewater treatment plant and to the general manager.

2. The faulty equipment will be identified, made safe and repaired, or replaced, as appropriate without undue delay.

3. The likely impact of the breakdown will be assessed; taking into consideration the time the equipment may be out of service and the likelihood of an unacceptable discharge occurring.

4. The Environmental Protection Agency will be notified of the breakdown.


36

5. Where possible the operation of the treatment system will be modified to counteract the likely effects of the breakdown until the relevant equipment is repaired or replaced.

6. If an unacceptable discharge is likely to occur the discharge from the treatment process will be discontinued.

7. The storm drain SW1 is sealed and if contamination occurs, it is possible to suck the contaminated water out and send it back through the waste water treatment plant.

8. The Personnel ensure that, firewater does not enter the River Erne. 9. If there are no open floor drains in the surrounding area, a foul manhole

should be opened and the spent firewater directed down this drain to the effluent plant.

10. The following Emergency Response Agencies will be informed: Northern Regional Fisheries Board, Local Authority.

SPILLAGE ON SITE Definition: A spill can be considered to be any liquid spillage over 5 litres in the case of non-hazardous liquids and 1 itre in the case of hazardous liquids (e.g. acids). In the event of a spill occurring which has the potential to have a significant environmental effect, the Production Manager and the Environmental Officer on site/on call must be informed. If required, the necessary emergency services should be requested. Action required: * Inform the Production Manager and the Environmental Officer *Consult the relevant Material Safety Data Sheets to determine if protective equipment can be worn when dealing with the spill. * Where possible prevent the spill from entering any storm water drains or road gullies using the spill kit and absorbent padding and booms kept in the fire compound. * Cordon off the area and keep personnel and vehicles away from the area * In the case of a spillage from a vehicle move the vehicle to a place where the spill can be more easily dealt with * In the event of a spillage effecting neighbouring property the relevant people should be informed by the CEO. * The Environmental Officer shall inform the local authority and the EPA if deemed necessary. A report on the occurrence must be entered into the Emergency Response Report Log. Procedure to Contain Spills: This procedure covers all spills with the potential to adversely affect the environment. It is the responsibility of the Plant/Production Manager and the Production Unit Manager to ensure that they are correctly implemented. Action to be taken: * The shift supervisor must be informed immediately. * Where possible, prevent the spill from entering any foul or storm water drains, i.e. ensure that SW1 is sealed.


37

* Determine the category of the spill from the Chemical Spill Handling List and ascertain whether the spill is Category 1, 2 or 3. Category 1: Hazardous, e.g. acids, biocides Category 2: Non-hazardous but presents an environmental risk, e.g. oil Category 3: Non-hazardous and no environmental risk, e.g. tallow * Put on the appropriate protective equipment, e.g. for Category 1 Spills heavy gloves, goggles. * Refer to the MSDS (which are kept in the lab) to determine what protective equipment is necessary. * Absorb spill-using material from spill kits located at the chemical storage. * Deposit residue in container provided and identify as ‘chemical waste’ with date and name of chemical. * Wash contaminated area with floor washer or similar, disposing of washings to the nearest foul drain * Store container in a designated area at the fire stores for disposal. TRANSPORT SPILLAGE In the event of a transport spillage the following procedure will take place: * The driver stops the lorry * The Supply Chain Manager is informed of the spillage * An emergency clean up team will be on call and equipment ready to be used at any time. * The team will use the company pick up to collect any spillage material. * The driver of the vehicle receives a verbal warning. DAMAGED TANK The company has installed a highly advanced PLC system which controls almost all of the plant and equipment on the site. All tanks have been constructed with the best materials for use in WWTP.

Electronic pressure sensors are fitted on all tallow tanks, heavy fuel oil and vegetable oil tanks. In addition high-level alarms are also fitted so that in the unlikely event that a tank may be in danger of overflowing the alarm will be raised in the admin process building to notify the relevant personnel. The logic control system will stop any pumps that may be pumping to the tank until such time that the level has lowered below the danger point.

Bund walls have been built around all storage tanks and other oil tanks. The bund inspection is carried out on a weekly basis. The bunds contain 110% of the contents of any tank that may discharge. The bund walls also prevent any accidental contact with the tanks by forklifts or other machinery thus reducing the risk of spillage further.

Damaged Tank Response: *The shift supervisor must be informed immediately of the damaged tank. *All flows to the tank must be stopped. * An assessment of the situation must be made to assess the contents of the tank are securely contained within the tank bunding.


38

* If there is no bunding as in the case of the WWTP tanks the EPA and the Fisheries Board must be informed immediately. * Slurry tankers will be called in to collect the contents of the tank. *The contents of the tank will then be discharged into another contained tank. DAMAGED PIPE In the construction of the plant all pipe work was installed to the correct specifications. In addition all pipes are of sufficient diameter to prevent blocking by any accidental spillages of tallow or other substance. This has prevented any possible blockages occurring. Once a week all pipe work, valves and connections are leak checked to prevent any possible fugitive emissions. Damaged Pipe Response Procedures: *When a damaged pipe in identified, the site plant manager or the shift supervisor should be informed. * The pipe damage will be assessed. * The cause of the leak will be identified, corrosion, vibration or accidental impact. * The site plant manager will assess the damage and instruct the relevant personnel to carry out a replacement or repair of the pipe or the whole pipeline. 12.3 ELECTRICAL FAULT / EXPLOSION Farragh Proteins operates a high technology processing plant. A central programmable logic controller controls and functions almost all the plant and machinery. This controller is operated from a PLC screen in the main process building. In the main administration building there is a back up system for all operating controls in the main production building. The plant operates on a continuous basis. The likelihood of a prolonged power failure is unlikely and the plant will require resetting in the event of a power failure. So no emissions are likely to occur in the event of power failure.

Manual operating of machinery is kept to an absolute minimum. This is also the case for the WWTP. Therefore the interaction of electrical energy and personnel is limited largely to qualified electricians. In addition to this all screws and operating equipment have their own isolation switches. All switch gear and control boards are housed in a central control room in the main process building. Any maintenance work or adjustments are carried out by trained personnel.

Electrical Fault Response Procedures: *In the event of an electrical fault being identified a qualified person must be informed immediately. * The machine or electrical line in question must be isolated immediately. * The source of the fault must be identified and repaired immediately.


39

* In the event of an uncontrolled electrical explosion the main power line into the plant must be shut down. This switch is located in the transformer room labelled “TRIP OFF”. * In the event of an equipment failure a range of essential spares are maintained by the Maintenance Manager 12.4 NOTIFICATION The license requires that the EPA is notified in writing of any incident which occurs at the facility. Procedures for notification are as follows: Time of Incident Contact

Person/ Section in EPA

Type of Contact

Required

Latest time by which Contact should be made

During Business Hours

EPA Inspector or Senior Inspector,

Telephone, Fax

As soon as practicable but not later than 10.00 am on the following working day after the occurrence of the incident

Outside Business Hours

EPA Headquarters

Telephone, Fax

Message to be left on 24 hour answering service

EPA Inspector The following information as a minimum must be made available at the time of notification: 1. The name of the contact person and phone and fax numbers; 2. The date, time and place of any incident; 3. The nature, source and cause of the incident; 4. Whether the source has been isolated; 5. Whether environmental pollution has been caused; 6. The measures taken to minimise the effects of the incident; 7. The measures put in place to prevent recurrence; and remedial actions taken. Additional information should be provided, where applicable, if the emergency services or other regulatory bodies were contacted. A report detailing the circumstances of the incident and any actions taken should be forwarded to the EPA as soon as practicable, but within five working days of the occurrence of the incident. If further action is taken after the date of the written notification of an incident, a report must be forwarded to the EPA detailing the actions within 10 days of the actions being initiated. 12.5 CLASSIFICATION OF ENVIRONMENTAL INCIDENTS The categorisation of incidents is based on their effect or potential effect to the environment. All incidents reported to the EPA and other relevant bodies are categorised into one of the categories:


40

Category 1 An environmental incident, which is causing, has caused or could have caused Significant Environmental Damage or Significant Environmental Risk or hazard to the public or to the general environment. The incidents have at least one of the following: * Significant effect on water quality (e.g. disruption of down stream WWTP, drinking water supplies) * Significant effect on air quality (e.g. major fire resulting in environmental pollution) * Major damage to an ecosystem (e.g. significant impact on fish population, major fish kill) * Closure of potable water extractors * Reduction of amenity value of the area (e.g. disruption to users of amenity areas) * Damage of agriculture or commerce * Impact on local residents or community (e.g. danger as a result of environmental pollution) * Urgent remedial action necessary (e.g. major fire) * Gross environmental pollution Corrective action required: * Activation of the Emergency Response Procedure * Notable deployment of resources to control and mitigate the incident * Significant level of public and inter Agency contacts * Notification to the EPA by phone and fax and other relevant bodies as an urgent environmental pollution incident * Recording the incident as an urgent environmental pollution incident with details and corrective action taken * Alert to the public by publication of public notices locally * Preparation of an incident room. Category 2 A minor environmental incident with following impacts: * Local limited impact to water or land * Notification to, and precautionary short-term closure of potable water extractors required * Effect on air quality as evidenced by odour complaints Corrective action required: * Records of details and corrective action taken * Incident report forwarded to the appropriate Regional Office of the OEE * Notification to the EPA by phone and fax and other relevant bodies as an urgent environmental pollution incident * Notification of Local Authority and Northern Fisheries Board ( in case of impact to water) Category 3 An environmental incident without any damage injury or significant risk or exposure to hazard to the public or the general environment: * Minor fires that are dealt with on-site


41

* Minor spills that are fully removed or contained on site in bunds or tanks * Not significant non-compliance with licensed emissions * Thermal Oxidiser bypasses * Odour complaints (unless indicate more significant pollution problems) * Acts of vandalism with no environmental impact Corrective action required: * Records of details and corrective action taken * Incident report forwarded to the appropriate Regional Office of the OEE as a non-urgent environmental incident. 12.6 EMERGENCY RESPONSE PROCEDURES Emergency Response Procedures have been documented for areas where it is deemed that accidental emissions could possibly occur under in the event of an emergency on the site. The following procedures will be implemented in the event of an incident that might lead to an accidental emission to the environment from the specified areas of this activity. These procedures are included in the Environmental Management Programme so as to minimise the risk to the environment and to minimise impact of any unavoidable accidental emission on the relevant receiving system. Procedures are established to identify the potential for and response to accidents and emergency situations. These are as follows:

Emergency Response Procedures (relating to emergencies, incidents and accidents) details the company’s response to situations involving actual or potential damage to the environment.

In the event of chemical spillage details of the steps to be followed to ensure safety and prevent pollution can also be found in the Emergency Response Procedures.

Where an incident occurs the Environmental Contact Procedures outlines the responsibility for and the mechanism by which regulatory authorities are informed.

The activities associated with fire prevention are documented in the procedure titled Fire Prevention and Response.

In the event of an emergency occurring on site the Environmental Officer is required to:

Contact all the Emergency Response Agencies and the EPA to communicate the incident details

Be available to take calls regarding the emergency Keep appraised of the on-going situation in order to determine the

appropriate level of response from staff Provide and support the technical response to the emergency Ensure that suitable safety precautions are in place regarding any on-site

response Provide and support the monitoring and analytical response Advice on notification to the public and other Agencies


42

Advice on remedial action necessary including preventative action i. e. potable water supplies

Ensure compliance with the incident notification conditions of the licence.

The following emergency response procedures have been developed and documented: TEAP Breakdown: In the event of breakdown at the TEAP unit the following procedures will be implemented:

1. The breakdown will be reported to the senior person responsible for the process area.

2. The faulty part or equipment will be identified, made safe and then repaired, or replaced, as appropriate without undue delay.

3. The likely impact of the breakdown will be assessed; taking into consideration the time the equipment may be out of service and the likelihood of an unacceptable emission resulting from the breakdown.

4. The person responsible for the operation or control of pollution abatement systems will be informed of the problem and given an estimate of the likely down time.

5. Where appropriate the operation of the abatement system will be modified to counteract any likely adverse environmental impact and minimise the risk of an unacceptable discharge.

6. The Environmental Protection Agency will be notified of the breakdown and its potential environmental impact.

7. Where possible the operation of the process equipment will be modified to counteract the likely effects of the breakdown until the relevant equipment is repaired or replaced:

* Vapours are sent to the air cooled condensers. * There is an automatic switch over for the vapours that are going to the TEAP unit, to the air cooled condensers. * The change over takes place via an automatic diversion valve this prevents any fugitive emissions to the atmosphere. * The air cooled condensers condense the vapours to a condensate which is then treated in the WWTP. * If an oxidizer breaks down all Biofilter fans automatically ramp to full speed as the combustion air for the TEAP unit comes from the raw material building. * The biofilters will be given extra irrigation adjusted by the environmental officer after this period as the increased fan speed dries out the media. * Trained staff are always at hand to ensure a speedy repair of the fault. * Farragh Proteins also have a contract with Saacke whom supply a 24 hr call out service for TEAP maintenance.

Boiler Breakdown: In the event of breakdown at the boiler the following procedures will be implemented:

1. The breakdown will be reported to the senior person responsible for the process area.


43

2. The faulty part or equipment will be identified, made safe and then repaired, or replaced, as appropriate without undue delay.

3. The likely impact of the breakdown will be assessed; taking into consideration the time the equipment may be out of service and the likelihood of an unacceptable emission resulting from the breakdown.

4. The person responsible for the operation or control of pollution abatement systems will be informed of the problem and given an estimate of the likely down time.

5. Where appropriate the operation of the abatement system will be modified to counteract any likely adverse environmental impact and minimise the risk of an unacceptable discharge.

6. The Environmental Protection Agency will be notified of the breakdown and its potential environmental impact.

7. Where possible the operation of the process equipment will be modified to counteract the likely effects of the breakdown until the relevant equipment is repaired or replaced.

Fire: The company exercises all due care to protect its staff and equipment from fire. This includes regular and careful operation and maintenance of all electrical equipment, implementation of an appropriate electrical safety requirements and prohibition of smoking, except in designated areas of the site, containment of wastes and litter and regular disposal of such wastes. The requirements of the Fire Officer for the area have been ascertained and will be implemented in the event of a fire within the activity. In addition the following procedures will be implemented to minimise the potential environmental impact:

1. The person detecting the fire will raise the alarm immediately. 2. The fire Service will be notified immediately. 3. If the fire is likely to result in a spill of materials the waste water treatment

plant operator, or in his/her absence the laboratory technician will ensure that containment booms are put in place to contain the spillage while taking care not to endanger staff or fire fighters.

4. The Environmental Protection Agency will be notified of the fire and its potential environmental impact.

5. Where possible the operation of the pollution abatement equipment will be modified to counteract the emissions likely to arise from the fire.

6. As far as is practicable fire-water will be retained and treated prior to discharge.

7. The process area will be shut down if necessary immediately. 8. When the fire is extinguished the Plant Manager should satisfy himself that no

further danger exists and that it is safe to return to work. Power Cut: The site is provided with two power supplies: one active and one standby. In the event of the power cut the site can change over to the second supply. Also a standby


44

generator can be used to enable essential equipment to continue to operate. In the event of a power cut occurring the following procedure will be put in place:

1. The breakdown will be reported to the factory manager or, if unavailable to the nominated person in charge.

2. The generator will be brought into service to enable essential equipment to continue to operate on the site. This essential equipment includes pollution abatement equipment.

3. The fault will be notified to the Electricity Supply Board with a request that it be attended to without delay.

4. Farragh Proteins has two incoming electrical power supplies so if one is faulty the second automatically takes over.

Other Emergency Situations: It is recognised that other emergency situations may also occur and not all of these can be identified or predicted. In the event of such an emergency arising the following procedures will be put in place:

1. The person observing the emergency will raise the alarm and notify the factory manager, or other senior member of staff, immediately.

2. The appropriate outside services will be notified immediately. 3. The factory manager, or other senior member of staff will initiate a suitable

response to protect staff, neighbours of the activity, the environment and equipment.

4. Where the relevant emergency situation is likely to lead to an accidental emission to the environment the Environmental Protection Agency will be notified.

12.7 REPORTING TO THE EPA, LOCAL AUTHORITY AND FISHERIES BOARD

Definition: Any incident with the potential for environmental contamination of surface water or ground water, or posing an environmental threat to air or land, or requiring an emergency response by the Local Authority. EPA During Business Hours In case of an incident inform the EPA immediately by phone: 094 9048400 and by fax: 094 9048499. Also notify Local Authority and Northern Regional Fisheries Board. Outside Business hours Notification of environmental incidents can be made by telephone to the EPA headquarters on telephone number: 053 9160600 or by telephoning the Local Inspectorate on telephone number: 094 9048400. Leave a message on the answering service. In the event of any line fault call the Wexford office directly.


45

At the start of the next business day, inform their Licensing and Control Officer by telephone. LOCAL AUTHORITY Inform the Environmental Section of Cavan County Council immediately by telephone: 049 4331799 or if outside of business hours leave a message on their answering service and at the start of the next business day make contact with them. Post an incident report on the follow address:

Cavan County Council, Courthouse,

Farnham Street, Cavan, Co. Cavan

NORTHERN REGIONAL FISHERIES BOARD Inform the Northern Regional Fisheries Board Telephone No. 0494337174 or if outside business hours leave a message on their answering service and at the start of the next business day make contact with them. Post an incident report on the follow address:

Northern Regional Fisheries Board, Station Road,Ballyshannon,

Co. Donegal


46

13. Residuals management plan Site Decommissioning If the site has to be decommissioned the following procedure would be implemented; Planned Cessation

1. The Company would stop accepting raw material from suppliers

2. The Environmental Protection Agency would be notified

3. Arrangements for the diversion of raw material would be implemented.

4. All raw materials on site would be processed.

5. All end products produced would be dispatched.

6. All processing plant equipment would be thoroughly disinfected, removed,

sold or dispatched as scrap.

7. All unused material on-site (including chemicals) would be returned to the

suppliers or sent for disposal to approved contractors.

8. All waste water on site would be fully treated and discharged or landspread

and any remaining sludge would be disposed of by approved procedure

through an approved contractor.

Sudden or Enforced Cessation

1. The reason for the sudden or enforced cessation would be identified as soon as

possible.

2. Upon identification the emergency would be dealt with in accordance with

relevant procedures.

3. If the emergency is outside of procedures outlined in the emergency response

procedure manual it shall be dealt with the utmost consideration to safety to

staff and the environment.

In the event of a permanent cessation of process it is unlikely that any potentially

polluting residuals would be present due to the fact that all areas within the factory are

bunded and as such would not be a post closure treat to the environment.


47

Decommissioning methods It is envisaged that the type of closure expected is a clean closure- upon cessation of

the operations and subsequent decommissioning at the facility there will be no

remaining environmental liabilities. Decommissioning involves the following:

No. Plant Decontamination methods

1 Thermal oxidiser The thermal oxidisers will be thoroughly cleaned, removed and sold for second hand

reuse.

2 2 Boilers The boilers will be thoroughly cleaned, removed and sold for second hand reuse.

3 3 Cookers The cookers will be thoroughly washed, disinfected, removed and sold for second hand

reuse.

4 3 Presses The presses will be thoroughly cleaned, disinfected, dismantled, removed and sold for

second hand reuse.

5 5 sterilizer The steriliser will be cleaned, washed, disinfected, removed and sold for second hand

reuse.

6 3 Mills The mill will be washed, disinfected, removed and sold for second hand reuse.

7 3 Meal coolers The meal cooler will be cleaned, disinfected, removed and sold for second hand reuse.

8 2 Crushers The crushers will be thoroughly, steam cleaned, disinfected, removed and sold for second

hand reuse.

9 Tallow decanter The tallow decanter will be dismantled, cleaned, thoroughly disinfected, reassembled

removed and sold for second hand reuse.

10 Air cooled condensers The air cooled condensers will be cleaned, removed and sold for second hand reuse.

11 Drain hopper The drain hopper will be thoroughly cleaned, disinfected, removed and sent for scrap or

recycling.

12 Numerous storage tanks The storage tanks will be thoroughly caustic washed by a power ball, removed and sold

for second hand reuse or dismantled and sent for recycling

13 Lorries & Trailers Lorries will be sold and the trailers will be steam cleaned, disinfected and sold or

scrapped.

14 Fork trucks The forktrucks are leased and will be steam cleaned & returned to the company.

15 Teleporter and cherry

picker

The teleporter and cherry picker will be steam cleaned and sold.

16 Biofilter The media from the biofilters will be removed, washed and sent for recycling. The

concrete walls will be demolished and removed of site to licensed centers.

17 Fresh water treatment

systems i.e. 1 Softeners,

The fresh water treatment systems would be sold.

18 Hydrolyser The hydrolyser will be thoroughly cleaned, disinfected removed and sold for reuse.

19 Ducting The ducting would have the decontamination steps applied and be removed and sent off

site for recycling.

20 Hoppers The hoppers would have the decontamination steps applied before being removed and

recycled or scrapped.

21 Weigh bridge The weigh bridges would be thoroughly cleaned, removed and C&D waste sent for

disposal.

23 Transport systems e.g

screws, conveyors.

Removed, decontamination steps applied and sold.


48

Site wastes Site wastes Decontamination requirements

Raw materials All raw materials on site would be processed.

Meat & bone meal, tallow and poultry

oil.

All end products produced would be dispatched.

Processing plant equipment All processing plant equipment would be thoroughly

disinfected, removed, sold or dispatched as scrap.

Unused materials on site e.g. chemicals,

diesel, heavy fuel oil, pumps, steel.

All unused material on-site would be returned to the suppliers or sent for disposal to approved contractors or disposed of in a manner to eliminate any impact on the environment.

Waste water All waste water on site would be fully treated and discharged or

land-spread and any remaining sludge would be disposed of by

approved procedure through an approved contractor.

Biofilter media Would be removed by an approved contractor.

Concrete Removed to an approved C&D waste facility.

Waste steel & metals Removed to an approved scrap facility.

Cladding The cladding would be removed to an approved C&D waste

facility.

Removal of infrastructure & services

All drainage and associated services including sumps to be carefully removed. For Environmental and health & safety reasons all entries and holes in the ground will be sealed and stabilised.

Our energy provider would be contacted with regard to the electrical isolation of plant, keeping minimum power requirements for fire alarm systems, security, lighting etc.

Management would take out new security contract on site until such time that site activity is disposed of.

All roads and other infrastructure to be removed when demolition has ceased.

Criteria for successful closure Successful clean closure will be expected to be achieved when it can be demonstrated

that there are no remaining environmental liabilities at the site. In practice this will

require demonstration that the following criteria have been met:

All plant will be safely decontaminated using standard procedures and

authorised contractors.


49

All Wastes will be handled, packaged, temporarily stored and disposed or

recovered in a manner which complies with regulatory requirements.

All relevant records relating to waste and materials movement and transfer or

disposal will be managed and retained throughout the closure process.

The soil /groundwater will be monitored at the time of closure (if required).

The Environmental Management System will remain in place and will be

actively implemented during the closure period.

In the event of a permanent cessation of process it is unlikely that any

potentially polluting residuals would be present due to the fact that all areas

within the factory are bunded and as such would not be a post closure threat to

the environment.

The overall objective is to achieve clean closure of the site with no environmental

liabilities or constraints.


50

14. Environmental Liabilities Risk Assessment (ELRA) with

financial provisions

The site was determined to be a category 3 risk and a clean closure is envisaged. The

company would aim to decommission, remove for disposal or recovery any earth,

buildings, plant or equipment, wastes, materials or any other substances that may

result in environmental pollution following termination of operations at the site. The

environmental risks have been identified and assessed and sufficient mitigation

measures are in place to monitor and quantify these potential risks. Financial

provision has been made to cover these potential eventualities.

The closure of the factory is not projected in near future however the EPA will be

given three months notice and six months notice of any partial or full closures

respectively. In the event of closure, environmental monitoring during

decommissioning will take place. An Environmental Exit Audit of the site will be

carried out following the announcement of closure and prior to actual

decommissioning and closure operations taking place.

The risk management programme allows Management to continuously monitor and

assess environmental risks and mitigation measures in order to reduce the unknown

environmental liabilities at the facility. A review of the Risk Assessment and financial

provision is carried out on an annual basis.

The Environmental Liability Risk Assessment (ELRA) and financial provision has

been reviewed independently by Vexiva Limited in accordance with Condition 12.2

of the IPPC licence. No significant changes on the site were made.


51

15. Tank and pipeline testing and inspection report Regarding conditions 3.19 and 6.15 of the Licence the company carries out the testing

at least once every three years. The bunds and tanks/hoppers were integrity tested in

December 2009. All bunds and tanks passed the integrity test. The drainage system

was tested in January 2010. The results obtained demonstrated that all drains and

manholes are in good order and within the limits for water tightness. Results of the

tests were forwarded to the Agency in AER 2009.

16. Noise monitoring report summary

As per condition 6.20 of the IPPC Licence the company carries out a noise survey

biennially. Noise monitoring was carried out for the site in September 2009 and the

report was included in the AER 2009. All readings are within licence limits for both

day and night as set by condition B.4.

integrated pollution control licensing annual ... · all plant and equipment used within the...

Documents