nutricia infant nutrition ltd castleview, macroom, co. cork · page 4 section c: control &...

Environmental Lynch

Nutricia Infant Nutrition Ltd

Castleview, Macroom, Co. Cork

Application Form and supporting information

submitted to the Environmental Protection Agency for

Review of IPPC licence, Reg. No. P0792-02

Matthew Lynch

February 2012

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Introduction

Integrated Pollution Prevention and Control

(IPPC)/Waste Licensing

Review Form and Guidance

Note

for the purposes of

EC Environmental Objectives (Surface Waters) Regulations

2009

Environmental Protection Agency

P.O. Box 3000, Johnstown Castle Estate, Co. Wexford

Lo Call: 1890 335599 Telephone: 053-9160600 Fax: 053-9160699

Web: www.epa.ie Email: [email protected]

EPA Reg. No: (Office use only)

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mailto:[email protected]

Contents

INTRODUCTION

This Form is for the purposes of a review of an IPPC/Waste Licence in order to ensure that all authorisations under the EPA Act 1992 to 2007 and the Waste

Management Acts 1996 to 2010 having discharges liable to cause water pollution are in compliance with the EC Environmental Objectives (Surface Waters)

Regulations 2009. While every effort has been made to ensure the accuracy of the material

contained in the Review Form, the EPA assumes no responsibility and gives no guarantees, undertakings and warranties concerning the accuracy, completeness

or up-to-date nature of the information provided herein and does not accept any liability whatsoever arising from any errors or omissions.

The Review Form and all supporting information shall be submitted to the Headquarters of the Agency in a format of a signed original, one hardcopy and

two copies on CD-Rom. In cases where an Environmental Impact Statement (EIS) is required in support of the Review Form, a signed original, one hardcopy plus 16 copies (or 18 copies if the activity is within Energy sector) on CD-Rom

shall be submitted.

All pages, including maps/drawings/plans, shall be no larger than A3 size. All files on CD-Rom shall be submitted in searchable PDF format and be no larger

than 10MB each in size. All CD-Roms shall be labelled with the Licensee’s name, Licence Register Number, address of the activity and name of the file (i.e. Review Form).

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Introduction

CONTENTS

SECTION A: GENERAL........................................................... 1

SECTION B: EMISSIONS ...................................................... 3

SECTION C: CONTROL & MONITORING ................................ 4

SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE

ACTIVITY .........................................................6

SECTION E: STATUTORY REQUIREMENTS ............................ 8

SECTION F: APPROVED ADJUSTMENTS & CONDITIONS ....... 9

SECTION G: DECLARATION ... ERROR! BOOKMARK NOT DEFINED.

ANNEX 1: TABLES/ATTACHMENTS ..................................... 11

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SECTION A: GENERAL

A.1 Licensee

Name*: Nutricia Infant Nutrition Ltd

Address: Castleview

Macroom

Co. Cork

Tel: 026 41302

Fax: 026 42223

e-mail: [email protected]

* This should be the name of the Licensee which is current on the date this IPPC/Waste

Licence Review Form is lodged with the Agency. It should be the name of the legal entity

(which can be a limited company or a sole trader). A trading/business name is not

acceptable.

Name and Address for Correspondence

Only documentation submitted by the Licensee and by the nominated person will be deemed to

have come from the Licensee.

Name: As above

Address:

Tel:

Fax:

e-mail:

Address of registered or principal office of Body Corporate (if applicable)

Address: 70, Sir John Rogerson’s Quay

Dublin 2

Company

Register

No.

384474

Tel: As above

Fax: As above

e-mail: As above

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A.2 Location of Activity

Name: Nutricia Infant Nutrition Ltd

Address*: Castleview

Macroom

Co. Cork

Tel: As above

Fax: As above

Contact Name: Michael Herlihy

Position: EHS Manager

e-mail: [email protected]

* Include any townland.

National Grid Reference

(12 digit 6E,6N) 134664E 69935N

Location maps (no larger than A3), appropriately scaled, with legible grid references should be enclosed in Attachment No A.2. The site boundary must be outlined on the map in red colour.

Geo-referenced digital drawing files (e.g. AutoCAD files) in Irish Grid projection of the site

boundary and overall site plan, including labelled emission points to surface water and

their monitoring and sampling locations, are also required.

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SECTION B: EMISSIONS

B.1 Emissions to Surface Waters &/or Ground

Describe the nature of emissions from the activity to receiving surface waters and/or

ground. Specify which of these emissions are process discharges and storm/surface water

discharges.

Tables B.1(i) and B.1(ii) should be completed.

The applicant should address in particular any emission point where the substances listed

in the Schedule of S.I. No. 394 of 2004 are emitted.

Please note that monitoring of the discharge(s) for the purposes of Table B.1(ii) shall be

undertaken for the list of parameters listed in Table D.1(i) as appropriate. Where other

relevant substances have been identified, during the Assessment of Impact on Receiving

Surface Water requested under Section D.1 of this Review Form, monitoring of the

discharge upstream and downstream for the relevant parameters shall also be included.

A summary list of the emission points, together with maps/drawings (no larger than A3)

and supporting documentation should be included as Attachment No B.1.

There is only one emission point from the activity to surface waters (SW-1). There is no

emission to ground waters. The emission point to surface waters is shown on the

attached location maps. The emissions consist mainly of treated wastewaters arising from

normal wash-downs of process equipment.

B.2 Tabular Data on Emission Points to surface water

Licensees should submit the following information for each emission point to surface

water:

Point Code Easting Northing Verified Emission

SW-1 135024E 70749N N All emissions

to waters

* SW = Surface Water

An individual record (i.e. row) is required for each emission point. Acceptable file formats

include Excel, Access or other upon agreement with the Agency.

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SECTION C: CONTROL & MONITORING

Describe the proposed technology and other techniques for preventing or,

where this is not possible, reducing emissions from the installation/facility.

C.1 Treatment, Abatement and Control Systems

An overview/summary of treatment/abatement systems for effluent emissions should be

included together with schematics as appropriate.

For each Surface Water Emission Point identified complete Table C.1(i).

Supporting information should form Attachment No C.1.

An overview of effluent treatment/abatement systems, along with a detailed

account of improvements and upgrades to the WWTP in recent years is given in

Attachment No. C.1

Normal operation and variations for start-up and shutdown should be described.

Anticipated malfunctions and known problems associated with the treatment should be

highlighted.

Proposed monitoring to be undertaken for influent(s) to treatment plant, and in-

treatment monitoring required for the management of the treatment plant should be

detailed.

C.2 Monitoring and Sampling Points

Identify monitoring and sampling points and outline proposals for monitoring emissions to

surface water bodies.

Table C.2(i) should be completed (where relevant) for emissions to surface water.

Where ambient environment monitoring is carried out or proposed, Table C.2(ii) should

be completed as relevant for each environmental medium and at least 12 samples should

be taken at regular intervals.

Include details of monitoring/sampling locations and methods.

Supporting information should form Attachment No C.2.

Monitoring has been carried out on an ongoing basis at the only emission

point (SW-1) in accordance with licence conditions. Details of ambient

monitoring are given in Table C.2 (ii), Table D.1 (i) and Section D (dealing

with the assessment of the Assimilative Capacity of the river).

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C.3 Tabular Data on Monitoring and Sampling Points

Licensees should submit the following information for each monitoring and sampling

point:

Point Code Point Type Easting Northing Verified Pollutant

SW-1 M

=Monitoring

S

=Sampling

(both)

135024E

70749N N = GPS

not used

List of

parameters

as per

Licence

Conditions

An individual record (i.e. row) is required for each monitoring and sampling point.

Acceptable file formats include Excel, Access or other upon agreement with the Agency.

Point source monitoring/sampling refers to monitoring from specific emission points (e.g.

from a wastewater treatment plant). Ambient monitoring includes monitoring of river

quality upstream/downstream of an effluent discharge.

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SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

D.1 Assessment of Impact

Describe the existing environment in terms of water quality with particular reference to

environmental quality objectives and standards as specified in the EC Environmental

Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009. Table D.1(i) should

be completed as appropriate.

Indicate whether or not the activity complies with the requirements of the EC

Environmental Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 and

the EC Environmental Objectives (Groundwater) Regulations 2010 S.I. No. 9 of 2010.

The Licensee should conduct an assessment of impact of discharge(s) from the

installation/facility on receiving surface water and/or groundwater. In undertaking this

assessment the Licensee shall have particular regard to substances used in the

manufacturing processes likely to result in discharges. The licensee shall have regard for

the environmental quality objectives and standards specified for protected areas and/or

the standards specified in the Schedules of the EC Environmental Objectives (Surface

Waters) Regulations 2009 S.I. No. 272 of 2009. When completing any assimilative

capacity calculations have regard to the Water Services Training Group ‘Guidance to

Applicant – Discharge to Surface Waters’ available at

http://www.wsntg.ie/publications/index.asp and other standard guidance.

If the process discharges are to coastal, transitional waters or lakes, the assessment may

require a modelling study. The modelling study shall include estimates on what the

resultant concentrations of the permitted substances in the receiving water body will be

upon discharge at the current licence limits.

Regardless of the receiving water body type, determine the maximum allowable

discharge concentrations to achieve compliance with the 95%ile good status limits. N.B.

If the discharge is to a water body that is already achieving high status, or if the

discharge is to waters draining to the surface water bodies identified under the First

Schedule of the EC Environmental Objectives (Freshwater Pearl Mussel) Regulations

2009, compliance must be with 95%ile high status limits.

State distance from the process discharges to a nearest downstream water dependent

Protected Area. Include the name and code of this Protected Area.

Full details of the assessment, including a copy of an Environmental Impact Statement if

it was required for the purposes of obtaining planning permission(s), should be submitted

as Attachment No D.1.1.

Where necessary, the Licensee should supply detailed information on the proposals to

comply with the requirements of the EC Environmental Objectives (Surface Waters)

Regulations 2009 S.I. No. 272 of 2009 including a detailed timeframe for any proposed

works in Attachment No D.1.2.

See Attachment No. D.1.1

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D.2 Environmental Considerations and Best Available Techniques (BAT)

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

Review Form.

Describe any environmental considerations which were made with respect to the use of

cleaner technologies, waste minimisation and raw material substitution.

Describe the measures proposed or in place to ensure that:

(a) the best available techniques are or will be used to prevent or eliminate or, where

that is not practicable, generally reduce an emission from the activity;

(b) no significant pollution is caused;

(c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15

July 1975 on waste; where waste is produced, it is recovered or, where that is

technically and economically impossible, it is disposed of while avoiding or reducing

any impact on the environment;

(d) energy and other resources are used efficiently;

(e) the necessary measures are taken to prevent accidents and limit their

consequences; and,

(f) the necessary measures are taken upon definitive cessation of activities to avoid

any pollution risk and return the site of operation to a satisfactory state.

This section should present a statement on energy efficiency at the site to include, where

appropriate, an energy audit with reference to the EPA Guidance document on Energy

Audits. Licensees should have regard to Section 5 of the EPA Acts 1992 and 2003 in

selecting BAT and in particular the following:

• The use of low-waste technology;

• The use of less hazardous substances;

• The furthering of recovery and recycling of substances generated and used in

the process and of waste where appropriate;

• Comparable processes, facilities or methods of operation, which have been

tried with success on an industrial scale;

• Technological advances and changes in scientific knowledge and

understanding;

• The nature, effects and volume of the emissions concerned;

• The commissioning dates for new or existing facilities;

• The length of time needed to introduce the BAT;

• The consumption and nature of raw materials, including water, used in the

process and their energy efficiency;

• The need to prevent or reduce to a minimum the overall impact of the

emissions on the environment and the risks to it;

• The need to prevent accidents and to minimize the consequences for the

Environment; and,

• The information published by the Agency in the form of sectoral BAT

Guidance documents and the relevant BREF documents published by the EC

(available for download at http://eippcb.jrc.es/ and at www.epa.ie).

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Environmental Considerations and Best Available Techniques (BAT)

All activities on the Nutricia site follow best environmental practice and incorporate

BAT as defined in the EPA’s BAT Guidance Note for the Dairy Processing Sector. See

Attachment D.2 illustrating the implementations of BAT at the Nutricia site.

SECTION E: STATUTORY REQUIREMENTS

E.1 Best Environmental Practices – Compliance with Legislation

Demonstrate if the best environmental practices are in place for control of diffuse

emissions from the installation/facility as set out in the following legislation:

(a) a specification prepared by the Agency in accordance with Section 5 of the

Environmental Protection Agency Act 1992 as amended by Section 7 of the

Protection of the Environment Act 2003;

(b) the Urban Waste Water Treatment Regulations 2001 (S.I. No. 254 of 2001)

as amended by the Urban Waste Water Treatment (Amendment)

Regulations 2004 (S.I. No. 440 of 2004) or any future amendment thereof;

(c) the European Communities (Good Agricultural Practice for Protection of

Waters) Regulations 2009 (S.I. No. 101 of 2009) or any future amendment

thereof;

(d) the Local Government (Water Pollution) Act, 1977 (Control of Cadmium

Discharges) Regulations 1985 (S.I. No. 294 of 1985);

(e) the Local Government (Water Pollution) Act, 1977 (Control of

Hexachlorocyclohexane and Mercury Discharges) Regulations 1986 (S.I. No.

55 of 1986);

(f) the Local Government (Water Pollution) Acts, 1977 and 1990 (Control of

Carbon Tetrachloride, DDT and Pentachlorophenol Discharges) Regulations

1994 (S.I. No. 43 of 1994); and,

(g) measures or controls identified in a pollution reduction plan for the river

basin district prepared in accordance with Part V of the EC Environmental

Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 for the

reduction of pollution by priority substances or the ceasing or phasing out of

emissions, discharges and losses of priority hazardous substances.

This Section requires the applicant to demonstrate if the best environmental practices

are in place for control of diffuse emissions from the installation/facility as set out in the

seven pieces of legislation and statutory specifications or measures listed in the

Guidance Note. Diffuse emissions, which typically arise from agricultural, mining or

forestry operations, do not arise in this case. All emissions arising here are from point

sources. The need to demonstrate best environmental practices for control of diffuse

emissions therefore does not arise.

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SECTION F: APPROVED ADJUSTMENTS & CONDITIONS

Where the Office of Environmental Enforcement (OEE) of the Agency has agreed any

variations or adjustments to the conditions of the existing licence, the licensee must

supply a schedule detailing these agreed variations and adjustments to the existing

licence conditions. An updated, scaled drawing of the site layout (no larger than A3)

providing visual information on such adjustments or variations where appropriate should

be included.

In the case of once-off assessments/ reports required under conditions of the existing

licence the licensee must supply a schedule detailing those assessments/ reports that

have been completed and agreed with the Office of Environmental Enforcement (OEE) or

as otherwise agreed.

Attachment No F1 shall include the schedule of variations and/or adjustments together

with the updated drawing.

Condition

No.

Existing

Condition

Proposed Wording

(where

appropriate)

OEE

Agreement

Reference

Description

Attachment No. F1 contains details of a Technical Amendment issued by EPA on 17

October 2011 amending the original (2007) IPPC licence.

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ANNEX 1: TABLES/ATTACHMENTS

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TABLE B.1(i): EMISSIONS TO SURFACE WATERS (One page for each emission)

Emission Point:

Emission Point Ref. No.: SW-1

Source of Emission: All wastewater and surface waters from the site

Location : River Lee/Carrigadrohid Reservoir, opposite Coolcower House (see attached Map)

Grid Ref. (12 digit, 6E,6N): 135024E 70749N

Name of receiving waters: River Lee/Carrigadrohid Reservoir

Flow rate in receiving waters: N.A. m3.sec-1 Dry Weather Flow

0.86 m3.sec-1 95%ile flow

Emission Details:

(i) Volume to be emitted

Normal/day N.A. m3 Maximum/day 2,400 m3

Maximum rate/hour 100 m3

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

to be included):

Periods of Emission (avg) 60 min/hr 24 hr/day 365 day/yr

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TABLE B.1(ii): EMISSIONS TO SURFACE WATERS - Characteristics of the emission (One table per emission point)

Emission Point Reference Number: SW-1

Parameter Prior to treatment As discharged % Efficiency

Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)

kg/day kg/year Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)

kg/day kg/year

BOD 15 36

COD 70 168

Suspended Solids 25 60

Orthophosphate 1.0 2.4

Total phosphorus 1.5 3.6

Total Oxidised

Nitrogen

15 36

Ammonia 2 4.8

Oils, fats & greases 10 24

Mineral oils 1 2.4

Note: Historical emission data are not relevant to the emissions that will arise when the current extension is completed, as provided for under the

existing licence. The above Table is therefore completed on the basis of anticipated emissions when the extension, which is currently under

construction, is fully operational. See also Attachment No. D.1.1 in respect of this.

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


Control 1

parameter

Equipment 2 Equipment

maintenance

Equipment

calibration

Equipment

back-up

Monitoring to

be carried out 3

Monitoring

equipment

Monitoring

equipment

calibration

Flow Flow meters Yes Yes Yes Flow Flow meters Annual

calibration

Inlet COD Hach Lab

equipment

Yes Yes Yes COD Hach Annual

calibration

pH in balance

tank

pH meter Yes Yes Yes pH pH probes and

meters

Annual

calibration

Oxygen in

balance tank

and oxidation

ditch

DO probe &

meter

Yes Yes Yes DO DO probe &

meter

Annual

calibration

Flows through

the WWTP

plant

Pumps Yes Yes Duty and

standby pumps

Flows Flow meters Annual

calibration

Operation of

aerators

Aerators and

motors

Yes Yes Duty and

standby

equipment

Aerator depth

and speed of

rotation

Gauges and

meters

Annual

calibration

Phosphate

removal

Dosing pumps Yes Yes Duty and

standby

equipment

Total P Lab equipment Annual

calibration

MLSS Lab equipment Yes Yes Yes MLSS and SVI Lab equipment Annual

calibration

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

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TABLE C.2(i): EMISSIONS MONITORING AND SAMPLING POINTS (One table per monitoring point)


Parameter Monitoring frequency Accessibility of Sampling

Points

Sampling method Analysis method/

technique

Flow

Continuous Good Flow meter with recorder Standard method

Temperature

Continuous Good On-line temperature

probe

Standard method

BOD

Weekly Good Standard method Standard method

COD

Daily Good Standard method Standard method

SS


Orthophosphate


Total P

Weekly Good Standard method Standard method

NH3-N


Total Nitrogen


OFG

Monthly Good Standard method Standard method

Mineral oils

Monthly Good Standard method Standard method

Toxicity

As required Good Standard method Standard method

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16

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

Monitoring Point Reference Number: N.A. (See Note below) _________

Parameter Monitoring frequency Accessibility of

Sampling point

Sampling method Analysis method/

technique

Note: There are no requirements in the licence for monitoring of phsico-chemical parameters in the receiving water. Such monitoring

has, however, been carried out from time to time and reported to EPA as required by the Agency, e.g. the Report by Malone O’Regan in

June 2010. See also the results of river water monitoring for the purpose of this licence review, in Attachment No. D.1.1.

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17

Table D.1(i) RECEIVING WATER SURFACE WATER QUALITY

Monitoring Point/Grid Reference: _____Lee Bridge (Upstream)____________________________

Parameter Results 1

(mg/l)

Sampling

method

(grab, drift

etc.)

Normal

Analytical

Range

Analysis

method/

technique

Date Date Date Date Date Date Date Date Date Date Date Date

pH

Temperature

Electrical

conductivity EC

Ammonia (as N)

Chemical oxygen

demand

Biochemical

oxygen demand

Dissolved oxygen

DO

Total Nitrogen

(as N)

Nitrite (as N)

Nitrate (as N)

Total Phosphorous

(as P)

OrthoPhosphate

(as P)

1 At least 12 samples should be taken at regular intervals.

Provide summary of the monitoring results: See note on previous Table and results in Attachment No. D.1.1.

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Attachment No. C.1

Description of wastewater treatment plant (WWTP) (extracted from AER prepared for Nutricia by Malone O’Regan and submitted to EPA March 2011)

WWTP layout and performance The main characteristics of the WWTP are summarised below: • The Nutricia WWTP is an extended aeration activated sludge plant with simultaneous nitrification and denitrification, i.e. both reactions taking place in the aeration tank. • A Dissolved Air Flotation (DAF) unit removes fat from the screened influent and the effluent discharges to the aerated balance tank. • The pH is adjusted in the balance tank and the effluent discharges to the oxidation ditch. • Ferric sulphate is dosed at a constant rate as a coagulant in order to remove Ortho-phosphates. • Tertiary sand filters polish the effluent before it is discharged to the river Lee. • The treatment plant performs well when dealing with organic loading from the production plant, as measured by effluent COD and Suspended Solids. • The influent to the WWTP is fluctuates significantly, both in terms of volumes and COD/Nutrient concentrations. • Washing events in the process area generate shock loads generally characterized by elevated volumes and high COD and Nitrogen concentrations in the influent. • At winter time (usually between November and January), a seasonal three months stoppage of some production processes results in a dramatic fall in COD loading to the treatment plant (as low as 100mg/l compared with typically 1000-2000mg/l)

Investigations and upgrades to the WWTP A significant amount of work, resources and investment has been expended to improve the performance of the onsite WWTP. In 2009 the following upgrades were implemented: • The anoxic area in the oxidation ditch was relocated from the east to the west section in order to enhance the denitrification process; • A tracking system for the usage of caustic and nitric acid in the balance tank was put in place in order to improve control of the consumption of these

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chemicals and the resulting pH values of the water pumped to the oxidation ditch; • Portable DO, ORP and pH meters were purchased in order to monitor these parameters at different locations at the WWTP, thus allowing an improved understanding of the behaviour of the plant at any time; • A second pump was installed in order to increase the recycling of activated sludge to the oxidation ditch. The rate of activated sludge recycling was therefore increased from 50 to 90-100m3/hr; • A 100m3 divert tank was commissioned in October 2009 to hold shock loads from washings and other process outputs resulting in more stable feeding to the balance tank and onwards to the oxidation ditch during high COD loading. The release of influent from the divert tank to the balance tank is now regulated by automatic control from the process building; • The concentration of Mixed Liquor Suspended Solids (MLSS) in the oxidation tank, which is an indicator of the bacterial population undertaking the carbon and nutrients removal, was increased from typically 2000-2500mg/l to 3000mg/l; • In order to compensate for the fall in COD loading occurring at winter time, as described above, a system of dosage of molasses was implemented in order to provide the carbon necessary to the nitrification/denitrification processes; • The pump transferring the effluent from the balance tank to the oxidation ditch was upgraded from a constant pumping rate to an adjustable speed setting. This allows the optimisation the treatment plant based on parameters such as the COD load in the influent and the mixing conditions in the balance tank; • Extensive testing was carried out between mid-August and mid-December 2009 in order to characterise the three main streams which compose the inlet to the WWTP and assess the efficiency of the divert tank in reducing the shock loads to the WWTP. Daily volumes and COD concentrations were recorded for each of the effluents from the milk intake & dairy, the preparation area and the evaporator. This investigation is on-going, but the results available to date indicate that the effluent from the preparation area represents only a small fraction of the load, while the contribution of effluent from the milk intake & dairy to the total load decreases drastically during the winter months. In addition, the load generated by the evaporator is very fluctuating, with significant peaks corresponding to the process washing events; and • In instances of elevated levels of COD in the influent, the cut off set point for DO was increased to 0.4 mg/l in the oxidation ditch in order to ensure that sufficient oxygen is available to the bacterial population. Following the implementation of the items listed above, improvements of the results achieved by the WWTP were recorded, together with a reduction of the COD shock loads to the plant. In 2010 further investment and resources were made available in order to further investigate and improve the performance of the WWTP. In 2010 the following upgrades/improvements were implemented: • The timings for the addition of caustic and acid were adjusted to allow a longer

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mixing time; • Inlet waste streams were analysed in order to identify sources of NH3, COD and TON as requested by the EPA; • A level control system was installed at the balance tank which ensures efficient mixing of caustic and/or nitric acid and also aids in the buffering process and reduces the risk of shock loads to the ditch; • The recirculation of wastewater through the oxidation ditch was further increased to 150m3 from 100m3 giving further opportunity for nitrification and denitrification; • A new variable speed drive for the oxidation ditch rotor was installed which eliminated interference with the pH signal which was occurring; • An assimilative capacity assessment was undertaken to determine the impact of the non-compliances on the existing water quality; • A dual pH control system was installed. There are now two probes installed in a recirculation tank. The probes are alarmed and will alarm if the pH differs by more than 0.5; • The target oxygen in the oxidation ditch was set as 0.8mg/l (up from 0.4mg/l); • Automation and interlocking of dosing pump. This measure ensures that if the circulation pump stops that the dosing pump also stops; • An additional control valve installed in the feed line from the bulk caustic tank to prevent leakage of caustic through the system; • Acid washes are carried out every two weeks to prevent a scale build up on the conductivity probe which can lead to inaccurate readings and overdosing of caustic; • A pH alarm was installed in the control room for the pH of the balance tank. If the pH goes above 9.5 for 1 hour an alarm will activate in the control room; • Nitrifying bacteria were added to the oxidation ditch; • CCTV was installed in the CIP rooms which allows production leaks to be detected quickly; and • The WWTP operator attended a 5 day wastewater treatment accredited course. In total, over the years 2008, 2009 and 2010 approximately €315,000 was invested in

upgrading and improving the performance of the WWTP. This has resulted in a very high

level of compliance with IPPC licence Conditions since June 2010.

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Attachment No. D.1.1

Section D. Existing environment and impact of the activity

D.1 Assessment of impact on receiving water

D.1.1 Introduction

This Section describes the existing surface water environment in terms of water quality, with

particular reference to the environmental quality standards specified in the European Communities

Environmental Objectives (Surface Waters) Regulations 2009 (SI No. 272 of 2009), presents an

assessment of the impact of discharges from the Nutricia plant at Macroom on the receiving water

and indicates whether or nor the activity complies with the Surface Waters Regulations.

D.1.2 Relevant river monitoring and wastewater discharge data

In order to assess the impact of the discharge from Nutrica on the receiving water (the River

Lee/Carrigadrohid Reservoir) a monitoring programme was carried out in the river upstream of the

outfall point as required by the Application form. The analyses were done at an accredited

laboratory. Table D.1.2.1 presents the results for the key parameters monitored:

Table D.1.2.1. Upstream monitoring results (at Lee Bridge)

Date BOD (mg/l) Total Ammonia

(mg/l as N)

Orthophosphate

(mg/l as P)

16/12/ 2011 1.73 0.020 0.006

20/12/2011 1.57 0.058 0.009

10/1/2012 1.57 0.016 <0.003

11/1/2012 1.50 0.017 <0.003

12/1/2012 1.30 0.020 <0.003

16/1/2012 1.30 0.022 0.003

17/1/2012 1.31 0.039 <0.003

18/1/2012 1.70 0.026 0.005

23/1/2012 1.39 0.022 0.004

24/1/2012 1.51 0.031 0.004

26/1/2012 1.65 0.030 0.006

Average 1.50 0.027 0.004

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Monitoring of the treated wastewater discharge from the Nutricia is ongoing in accordance with the

requirements of the IPPC licence. The monitoring results are sent to EPA as required and are

summarised annually in the AER. Apart from some issues in the early months of 2010, which have

already been dealt with extensively in correspondence between EPA and the company, the discharge

monitoring results are in general compliance with the ELVs in the IPPC licence. For the purpose of

assessing the assimilative capacity, therefore, this application references the ELV and volume limits

set in the IPPC licence, as set out in Table D.1.2.2. The Table also shows that in all cases except for

BOD and Ammonia there is a direct correspondence between the concentration ELVs and the mass

emission ELVs at a volume of 2,400 m3/day.

Table D.1.2.2 Wastewater discharge limits in IPPC licence (SW-1)

Volume: Maximum in any one day: 2,400 m3

(Note: an increase over the 2007 maximum discharge

volume of 1,500 m3/day was permitted only with the agreement of the EPA following successful

completion of the test programme as required by Condition 6.3 of the licence, based on increased

production capacity.)

Parameter Emission limit Values

Temperature 25oC (max)

pH 6 - 8.5

Other parameters mg/l kg/day Concentration

(based on 2400

m3/day)

corresponding to

mass emission

ELV limit (mg/l)

Mass emission

(based on 2400

m3/day)

corresponding to

concentration

ELV (kg/day)

BOD

15 24 10 36

COD

70 168 70 168

Suspended Solids

25 60 25 60

Orthophosphate

1.0 2.4 1.0 2.4

Total Phosphorus

1.5 3.6 1.5 3.6

Total oxidised

Nitrogen

15 36 15 36

Ammonia (as N)

2 2.7 1.125 4.8

Oils, fats and greases

10 24 10 24

Mineral oils

1.0 2.4 1.0 2.4

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The standards in the licence are based on a maximum discharge volume of 2,400 m3/day. The

lack of correspondence between the concentrations and mass emissions of BOD and Ammonia arises

from an objection made by the company to the Proposed Determination (PD) in December 2007 and

a consequent amendment of the PD by an EPA Technical Committee in June 2008. The PD had

proposed an ELV of 10 mg/l for BOD and 0.5mg/l for Ammonia. After considering the company’s

objection, the Technical Committee raised the BOD concentration ELV to the present value of 15

mg/l but retained the mass emission ELV of 24 kg/day (which was based on a concentration limit of

10 mg/l) as proposed in the PD.

In respect of Ammonia the company had objected to the proposed ELV of 0.5 mg/l and the

corresponding mass emission of 1.2 kg/day. The Technical Committee agreed to the company’s

request to raise the Ammonia ELV to 2 mg/l, but restricted the mass emissions to 2.7 kg/day. The

basis for the amended mass emission ELV was EPA’s estimate of the assimilative capacity of the

receiving water. This in turn was based on EPA’s estimate of 0.11 m3/s as the 95%ile flow in the

receiving water, as opposed to the company’s estimate (based on the EIS) of 0.83 m3/s. As a

consequence, while the EIS estimated the assimilative capacity for Ammonia as 69.02 kg/day, EPA

estimated it as only 9.3 kg/day. The issue of the 95%ile flow in the receiving water is discussed in

detail in Section D.1.3 of the present Application.

D.1.3. The flow in the receiving water

In order to assess the impact of the wastewater discharge from Nutricia on the receiving water it is

essential that an accurate assessment be made of the flow in the receiving water. This presents a

challenge, because, as was observed by the EPA Inspector (Maeve McHugh) in her Inspector’s

Report on Nutricia’s IPPC licence application in October 2007: There is a dearth of appropriate

available hydrometric data in the locality for the calculation of the assimilative capacity of the water

body. The hydrometric challenge is complicated by the fact that the discharge point is located in the

upper reaches of the Carrigadrohid Reservoir, albeit in the main channel of the River Lee, between

the main Reservoir and the Gearagh further upstream.

There are in fact no operating hydrometric gauges to record river or reservoir flows in the

vicinity of the discharge point. As recorded in the EPA Register of Hydrometric Stations, as well as

in the EIS prepared by Fehily Timoney & Co. which was submitted to EPA in connection with the

IPPC licence application in 2007, and in the Report by Malone O’Regan submitted to EPA in June

2010, there are two staff gauges operated by the ESB at Lee Bridge (1.3 km upstream of the

discharge point, measured along the centre the channel) and at Bealahaglashin Bridge

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(0.75 km downstream, also measured along the centre the channel). But these record water levels

only. Neither of them records water flows.

The absence of local hydrometric data has led to a number of different approaches to

estimating river flows, with varying results. This submission will focus on the 95%ile flows, which

EPA requires to be used for assessing the assimilative capacity of the receiving water. The

submission will review briefly the approaches taken in previous documents, and the results arrived

at, in estimating the 95%ile flows. It will then set out the approach and results used in the present

application for review of the IPPC licence.

In the EIS prepared by Fehily Timoney in 2007 two methods were used to estimate the

95%ile flow at the discharge point. One of them, called Method 1, was eventually adopted, as being

the more conservative figure, for calculating the assimilative capacity for the Nutricia discharge. It

involved calculating the specific 95%ile flows (the 95%ile flows per square kilometre) at other

gauging stations in the River Lee catchment and outside it. An average value was taken from these

calculations to derive the 95%ile flow in the river at the Nutricia outfall. The gauging stations used

were at Ballymullen (Station No. 23012) and Inchigeela (Station No. 19043) both stated to be

upstream of the Nutricia outfall, and at Inniscarra (Station No. 19013) and Leemount (Station No.

19011) downstream of the outfall. (It should be clarified here that Ballymullen Station is not

upstream of the Nutricia outfall. It is on the other River Lee, near Tralee in Co. Kerry, but this does

not necessarily invalidate the use of its 95%ile flow per square kilometer for comparison purposes).

Fehily Timoney noted that the flows at Inniscarra and Leemount were regulated by the ESB, which

could affect the 95%ile flows recorded at those stations. They also noted that the 95%ile flow per

square kilometre at Inchigeela was much lower than the corresponding figures for the other three

stations (it was only about one fifth of the average of the other three) and for that reason they

excluded it from their calculations. The average 95%ile flow thus arrived at was 3.29 l/s/ km2. They

applied this to the catchment area at the Nutricia outfall, which they estimated as 252 km2. The

resulting estimated 95%ile flow at the outfall was 0.83 m3/s.

The EPA Inspector (Maeve McHugh) in her Report on Nutricia’s IPPC licence application in

October 2007 took a different approach to estimating the 95%ile flow at the outfall. She estimated it

on the basis of the data from the hydrometric stations at Coolcaum (Station No. 19023, catchment

area 29.9 km2) on the River Toon and at Inchigeela (Station No. 19043, catchment area 111.7 km

2)

on the River Lee, making an unspecified ‘adjustment’ of the resulting flow to take account the

additional ungauged area to the outfall. She took the 95%ile flow at Coolcaum as 0.005 m3/s and at

Inchigeela as 0.08 m3/s. It will be recalled that Fehily Timoney in the EIS had rejected the use of the

95%ile flow figure for Inchigeela as being anomalously low. The corresponding figure for Coolcaum

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is much lower still: it is only 0.167 l/s/km2, compared with 0.717 l/s/km

2 for Inchigeela. The

Coolcaum flow figure per square kilometer is therefore only about one twentieth of the

corresponding figures used in the EIS. This wide difference in data selection inevitable has a major

bearing on the resulting 95%ile flow estimated at the Nutricia outfall.

The EPA Inspector did not give details of her calculations, but it is assumed that in

‘adjusting’ the measured flows to allow for the larger catchment area at the outfall she used the same

flows per square kilometre as applied at the gauging stations she used. The figure she arrived at for

the 95%ile flow at the outfall was 0.11 m3/s, about one eighth of the 95%ile flow estimated by Fehily

Timoney. The main reasons for the very different results are the selection and processing of data

from different hydrometric stations with very different flows per unit area. The 95%ile flow

estimated by the EPA Inspector for the river at the Nutricia outfall corresponds to only 0.45 l/s/km2,

which is little more than one eighth of the 3.29 l/s/km2

estimated by Fehily Timoney at the same

location.

Malone O’Regan in their Report to EPA in June 2010 adopted the same approach as the EPA

inspector in calculating the 95%ile flow at the outfall. They used the data from the same two

hydrometric stations as EPA and scaled up the resulting flow for an area of 243 km2, which is the

catchment area to the Lee Bridge above the outfall. The figure Malone O’Regan arrived at for the

95%ile flow was 0.146 m3/s, very slightly higher than EPA’s figure.

This brief summary of previous work on the 95%ile flows at the Nutricia outfall highlights

the different approaches taken and the very different outputs arising from the selection of different

input flow data and methodologies for the calculations. It also highlights the need for a more

scientific and systematic methodology for deciding on the input flows to be used to estimate 95%ile

flows at ungauged locations such as the Nutricia outfall. Input flows need to be taken from river

catchments and river segments in those catchments which are sufficiently closely related to the

ungauged location in terms of such features as catchment area, topography, climatology (particularly

rainfall), subsoil permeability, slope, hydrogeology, soil characteristics, vegetation and land use and

other physical characteristics. In the present case, the input flow data used should be from a location

or locations whose characteristics are closely related to those of the Rivers Lee and Toon above the

Nutricia outfall. The challenge is to ensure this.

Fortunately, the methodology needed to ensure it is already available in the form of EPA’s

on-line Hydrotool ([email protected]), which was designed specifically for this purpose and is

extensively used in the implementation of River Basin Management Plans under the Water

Framework Directive. The Hydrotool was referenced by EPA as a source of river flow data for the

current review of IPPC licences (Presentation by Loretta Joyce, EPA, at public briefing on IPPC

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Licence reviews, May 2011). An extract from the EPA News of Autumn 2010 describes the main

features and applications of the Hydrotool.

Extract from EPA News, Autumn 2010

Estimation of flow for ungauged catchments

River flow data is essential in order to provide information for the assessment, development and

management of water resources and the water-related environment. Whilst Ireland has an extensive

hydrometric programme, with approximately 850 gauges, it is impractical to monitor every

waterbody. Consequently, there was a need to develop a method to predict flow characteristics for

catchments where flow for ungauged catchments – that is, those not directly monitored.

A procedure called “Region of Influence” has been applied to the estimation of river flows in

ungauged catchments in Ireland. The method is based on the similarity of the catchment

characteristics of sites where flow is monitored, to those of an unmonitored site and has been

prepared by the EPA in conjunction with the ESBI and Compass Informatics - as a web-based GIS

application. The application can be accessed at http://193.1.208.39/HydroTool

A summary of the flow regime of a catchment in the form of a flow duration curve (FDC) was

prepared from 145 hydrometric gauging stations (Local Authority/EPA and OPW hydrometric

stations) together with their catchment characteristics. These stations were chosen as they were

representative of a wide range of catchment types throughout the country. The FDC summarises

the flow regime of a river as a graphical plot of flow against the percentage of time that flow is

exceeded.

This application allows the user to select a target site of interest on a river, and to identify the

catchment boundary and characteristics such as catchment area, rainfall, stream length, drainage

density and slope (the average surface topographic slope across the catchment).

The database of catchment characteristics from the 145 master set of hydrometric gauging stations

is queried, and three representative stations are chosen from this master set, whose catchment

characteristics are ‘closest’ to the target site characteristics. The average FDC of this group of three

catchments is then calculated and applied to the ungauged catchment area. A seven page report is

generated that provides the user with catchment maps, catchment descriptors and the estimated

flow duration curve for the target site.

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http://193.1.208.39/HydroTool

27

The application is unsuitable for use in catchments that contain a high proportion of conduit karst,

limestone geology, lakes, upstream abstractions and regulation of the river flow by dams or sluices,

because it is impossible to predict the flow characteristics in such catchments.

This methodology has been applied in studies of abstractions and emissions throughout Ireland for

the 2010 River Basin Management Plans.

Figure 1. EPA description of Hydrotool methodology

The Hydrotool methodology is clearly applicable to the estimation of the ungauged flow at

the Nutricia outfall. It is applied in two ways in the following paragraphs: Method A follows a

similar approach to that previously used in estimating the 95%ile flow at the outfall: it takes the

Hydrotool-estimated flows from the two main rivers (the Lee and the Toon) at the closest segments

upstream for which the estimates are available, and scales up those flows to take account of the

additional catchment area between there and the Nutricia outfall; Method B is based on the well-

developed Hydrotool procedure of examining the 95%ile flows of similar catchments, calculating the

corresponding flows per square kilometre and applying the result to estimate the 95%ile flow at the

Nutricia outfall. The results of the two Methods are then compared.

Method A is as follows: The Hydrotool output gives the catchment characteristics and Flow

Duration Curve for the segment of the River Lee upstream from where it enters the Gearagh to just

above Hydrometric Station No. 19014 (Dromcarra). A copy of the Hydrotool output is attached. The

catchment area is 176.1 km2 and the 95%ile flow is 0.636 m

3/s, with 95% confidence limits of 0.424

to 0.954 m3/s. The Hydrotool also gives the catchment characteristics and Flow Duration Curve for

the segment of the River Toon just upstream from where it enters the Gearagh to about 0.9 km above

Toon Bridge. A copy of the Hydrotool output is attached. The catchment area is 49.5 km2 and the

95%ile flow is 0.171 m3/s, with 95% confidence limits of 0.114 to 0.256 m

3/s.

The rivers Lee and Toon are adjoining rivers with similar rainfall patterns and similar

physical catchments. It is therefore to be expected that their Flow Duration Curves would be broadly

similar and that their 95%ile flows would occur at about the same time. This expectation indeed

underlies the previous assessments of river flows discussed earlier. It is therefore assumed for the

purpose of the present assessment that the 95%ile flows can be combined and scaled up in order to

estimate the 95%ile flow at the Nutricia outfall, as was done in previous assessments. Table D.1.3.1

presents the calculations involved. The calculations result in an estimated 95%ile flow of 0.87 m3/s at

the Nutricia outfall. This flow is very close to the 0.83 m3/s estimated by Fehily Timoney in the 2007

EIS, but is almost eight times the 0.11 m3/s used by EPA in determining the Nutricia IPPC licence.

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Table D.1.3.1 Calculation of 95%ile flow at Nutricia outfall

River segment Catchment area to

river segment (km2)

95%ile flow (m

3/s)

95%ile flow

per unit area

(l/s/km2)

River Lee entering

the Gearagh

176.1 0.636 3.612

River Toon entering

the Gearagh

49.5 0.171 3.455

Combined Rivers

Lee and Toon

entering the Gearagh

225.6 0.807 3.577(1)

River Lee -

Carrigadrohid

Reservoir at Nutricia

outfall

244.4(3)

0.874 3.577

(1) Weighted average flow per unit area

(2) The combined river catchment at Lee Bridge is 243 km

2 but there is an estimated further catchment area of 1.4 km

2

from Lee Bridge down to the outfall, bringing the total to 244.4 km2. The 2007 EIS was based on a total catchment area

of 252 km2 at the outfall, while EPA and Malone O’Regan’s calculations were based on the catchment area of 243 km

2 to

Lee Bridge.

The second method of calculating the 95%ile flow at the Nutricia outfall, Method B, is also

based on the Hydrotool methodology. It involves examining the 95%ile flows of similar catchments,

calculating the flows per square kilometre in those catchments and applying the result to estimate the

95%ile flow at the Nutricia outfall. The first set of data to be considered is that used by EPA itself in

estimating the 95%ile flows for the Rivers Lee and Toon as discussed in Method A. The EPA input

data for the Hydrotool was drawn from a master set of 145 hydrometric stations where flow

measurements were considered well-established. A ‘Region of Influence’ approach, similar to that

used in the UK, was applied by EPA to choose catchments that were similar to the catchment to be

gauged. These ‘analogue’ catchments were chosen based on a weighted set of catchment descriptors

including rainfall, topography, soils, etc. The ‘analogue’ catchments are referred to in the Hydrotool

outputs as ‘Stations in Pooling Group’.

For the purpose of estimating the 95%ile flows for the segments of interest in the Rivers Lee

and Toon, EPA adopted the following Stations in the ‘pooling group’, their locations, catchment

areas and 95%ile flows as shown in Table D.1.3.2.

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Table D.1.3.2. Hydrometric Stations used by EPA in estimating 95%ile flows in the Rivers

Lee and Toon. Rivers

whose flow

is to be

estimated

Rivers used

as

‘analogues’

in ‘pooling

group’

Station

No.

Name and

location of

Station

Catchment

area to

Station(1)

(km2)

95%ile

flow (m

3/s)

(2)

95%ile

flow per

unit area

(l/s/km2)

Lee Newport

River

32012 Newport weir,

Co. Mayo

146.2 0.779 5.32

Lee River Flesk 22006 Flesk (Laune),

Co. Kerry

328.8 1.44 4.38

Lee River Finn 01042 Dreenan, Co.

Donegal

430.8 0.419 0.97

Toon Bandon

River

20002 Curranure, Co

Cork

423.7 0.8 1.89

Toon Stream 22043 Toormore

Bridge weir,

Co. Cork

3.4 NA NA

Toon River

Blackwater

18006 CSET (Sugar

factory)Mallow

1,054.8 3.5 3.32

Notes: (1) From EPA Register of Hydrometric Gauges in Ireland

(2) Source: EPA Summary of low flow statistics at selected hydrometric stations, June 2011.

It is apparent from the Table that none of the hydrometric stations in the ‘Pooling Group’ are

located within the catchments of the Rivers Lee or Toon. This suggests that the hydrometric stations

within the two river catchments themselves do not necessarily provide the most suitable data for

estimating the 95%ile flows in the segments of interest in those rivers. The nearest ‘analogue’ river

referred to is the River Bandon at Curranure, where the 95%ile flow is 1.89 l/s/km2. It is worth

noting that the EPA Inspector’s Report on Nutricia’s IPPC licence application in 2007 used the

median (50%ile) flow records from that hydrometric station to calculate the median flow at the

Nutricia outfall. If the Report had also used the 95%ile flow (1.89 l/s/km2) from the same Station to

calculate the 95%ile flow at the outfall, the result arrived at would have been four times greater, 0.46

m3/s instead of 0.11m

3/s.

The 95%ile values per unit area in the Table vary considerably, but the average value is 3.176

l/s/km2, which is not very different from the 3.577 l/s/km

2 arrived at using Method A, or from the

3.29 l/s/km2

arrived at in the EIS by Fehily Timoney, but is very different from the 0.45 l/s/km2 used

by EPA in estimating the 95%ile flow at the Nutricia outfall.

Before concluding with Method B it is worth comparing the 95%ile flow of two other rivers

close to the Rivers Lee and Toon, with catchment areas, rainfall and other physical characteristics

similar to those two rivers. They is the Sullane River, which flows roughly parallel to and just north

of the other two rivers and the Buingea River which flows into the Carrigadrohid Reservoir about 3.5

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km south-east of Bealahaglashin Bridge. The Hydrotool estimate (print-out attached) for the 95%ile

flow in the Sullane segment north of the Nutricia outfall is as follows:

Catchment area: 211 km2

95%ile flow: 1.09 m3/s

95%ile flow per unit area: 5.17 l/s/km2

This flow per unit area is at the upper end of the range of values in Table D.1.3.2. The Hydrotool

estimate (print-out attached) for the 95%ile flow in the Buingea River at its entry to the Reservoir is

as follows:

Catchment area: 28.9 km2

95%ile flow: 0.105 m3/s

95%ile flow per unit area: 3.63 l/s/km2

Taken together with all the other data and analysis in this submission, the flow figures for the Sullane

and Buingea, the two rivers nearest to the Lee and Toon, illustrate that by any appropriate analysis

the 95%ile flow calculated in the EPA Inspector’s Report for the Nutricia outfall is not supported by

the available EPA data.

The question then is what figure can be justified on the basis of the evidence. Nine sets of

relevant EPA estimates have been presented in the Tables and discussion of Methods A and B. The

results are remarkably consistent given their diverse origins (Table D.1.3.3).

Table D.1.3.3. Summary of 95%ile flows per unit area.

River segment 95%ile flow

per unit area

(l/s/km2)

River Lee entering the

Gearagh

3.612

River Toon entering the

Gearagh

3.455

Newport River 5.32

River Flesk 4.38

River Finn 0.97

Bandon River 1.89

River Blackwater 3.32

Sullane River 5.17

Buingea River 3.63

Mean value

3.53

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It is therefore proposed that the mean value from this data-set can be used with a high level of

confidence to calculate the 95%ile flow at the Nutricia outfall. The mean value from the data-set 3.53

l/s/km2. The catchment area at the outfall is 244.4 km

2. The estimated 95%ile flow at the outfall is

therefore 0.86 m3/s. This flow, which is very close to the 0.83 m

3/s used in the EIS but nearly eight

times that used by the EPA Inspector, will be used to calculate the assimilative capacity of the

Nutricia discharge in the present submission.

D.1.4. Assessment of assimilative capacity

The assimilative capacity of the receiving water at the discharge point is calculated using the

EPA-recommended method and the mass balance formula used in the Water Services Training

Group publication ‘Application for a Licence to Discharge to Surface Waters: Guidance to

Applicants, Appendix C – Assimilative Capacity and Mass Balance Calculations’.

The total assimilative capacity, expressed in kg/day, is the difference between the background

concentration in the river and the maximum permissible concentration at the 95%ile flow. The

formula used is:

Assimilative Capacity = (Cmax – Cbackground) * F95 * 86.4 kg/day

Where:

* is a multiplication sign

Cmax = maximum permissible concentration (mg/l)

Cbackground = background concentration (mean value) (mg/l)

F95 = the 95%ile flow in the river at the discharge point (m3/s)

To apply this formula to the Nutricia discharge, the maximum permissible concentrations

must be determined. These are the water quality standards for Good status set in the environmental

Objectives (Surface Waters) Regulations 2009. They are:

Parameter Water quality

objectives for

Good status (mg/l)

BOD ≤ 2.6 (95%ile)

Total Ammonia (as N) ≤ 0.140 (95%ile)

Orthophosphate) (as P) ≤ 0.075 (95%ile)

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The other required input to the formula is the background concentration of the relevant pollutants,

BOD, Ammonia and Orthophosphate, in the river just upstream of the outfall. They are given in

Table D.1.2.1 as follows:

BOD (mg/l) Total Ammonia

(mg/l as N)

Orthophosphate

(mg/l as P)

1.50 0.027 0.004

The assimilative capacity of the receiving water is therefore as follows:

BOD: (2.6 – 1.5) * 0.86 * 86.4 kg/day = 81.73 kg/day

Ammonia: (0.14 – 0.027) * 0.86 * 86.4 kg/day = 8.40 kg/day

Orthophosphate: (0.075 – 0.004) * 0.86 * 86.4 kg/day = 5.28 kg/day

These assimilative capacities may be compared with the ELVs in the IPPC licence as follows (Table

D.1.4.1):

Table D.1.4.1 Comparison of current ELVs and assimilative capacities

Parameters ELV

(mg/l)

ELV

(kg/day)

Assimilative

capacity

(kg/day)

Concentration

(based on 2400

m3/day)

corresponding to

mass emission ELV

limit (mg/l)

Mass emission

(based on 2400

m3/day)

corresponding

to

concentration

ELV (kg/day)

BOD

15 24 81.73 10 36

Ammonia (as N)

2.0 2.7 8.40 1.125 4.8

Orthophosphate

1.0 2.4 5.28 1.0 2.4

Based on Table D.1.4.1, the mass emission ELVs in the current IPPC licence represent the

allocation of the following percentages of the respective total available assimilative capacities:

BOD: 29%

Ammonia: 32%

Orthophosphate: 45%

These can be considered fairly conservative allocations of the available assimilative capacity

in the particular circumstances of the discharge from Nutricia. That discharge is the only significant

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one in the near vicinity, and there is a further considerable increase in river flow, which should

increase assimilative capacity, a short distance downstream where the River Lee is joined by the

Rivers Sullane and Buingea.

A good case can therefore be made for accommodating, within the context of the current

licence review, a discharge from Nutricia in which the permitted mass emissions correspond to the

permitted concentrations. This would mean keeping the existing concentration limits but bringing the

mass emission limits into line with them. The result would be ELVs for mass emissions as indicated

in the right-hand column of Table D.1.4.1. These are compared with the current mass emissions in

Table D.1.4.2:

Table D.1.4.2. Comparison of existing and proposed mass emissions

Setting ELVs as indicated in Table D.1.4.1 would result in the following allocations of total

assimilative capacities:

BOD: 44%

Ammonia: 57%

Orthophosphate: 45% (same as the % allocation based on the current ELV)

The proposed ELVs still represent BAT and they still afford good protection to the receiving

waters without absorbing an excessive proportion of the available assimilative capacity, even at the

95%ile flow at which they were calculated. By setting ELVs in terms of mass emissions EPA could

allow the company to decide whether it could, if necessary to support possible future expansion,

increase water usage and discharge volumes without increasing mass emissions. Such mass emission

ELVs would therefore allow some scope for the future development of the Nutricia site in keeping

Parameters Current

ELV

(mg/l)

Proposed

ELV

(mg/l)

Current

ELV

(kg/day)

Proposed

ELV

(kg/day)

BOD

15 15 24 36

Ammonia

(as N)

2.0 2.0 2.7 4.8

Orthophosphate

(as P)

1.0 1.0 2.4 2.4

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with national strategy for the development of the food industry as envisaged in Government policy

under Harvest 2020.

It is therefore suggested that EPA amend the current licence to bring the mass emissions

ELVs into line with the concentration ELVs as indicated above.

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Attachments to Section D.1.3.

EPA Hydrotool Outputs for Rivers Lee, Toon, Sullane and Buingea

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Attachment D.2. Implementation of BAT

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All aspects of BAT are in place on site. The following are some illustrations:

Generic Measures: Implement an environmental management system

ISO 14001:2004 implemented at Nutricia site

Waste minimisation, Raw Materials Use & Selection of Materials:

Substituted or reduced the use of materials, especially chemicals, to minimise the environmental

impact. Waste minimisation and good housekeeping programme in place. Processes optimised on an ongoing

basis to optimise inputs, handling, storage and effluent generation.

Water Use Management

Water use is monitored, metered and managed, reducing usage to a level consistent with best practice

for product quality and safety. Leaks and overflows are eliminated as soon as possible. CIP systems

are used to optimise water use. Cooling water is reused where possible. The results of water

conservation programmes are presented in the AERs

Energy Efficiency

Energy is a very significant cost element in the manufacturing process. There is therefore a very

strong focus on energy management and conservation. A comprehensive energy monitoring system

is in place. The AERs present annual details of consumption of electricity, heavy fuel oil and

propane. With the change-over from Heavy Fuel Oil to natural gas that focus on energy efficiency

will continue. Heat recovery systems are used on the spray dryer stack to pre-heat the air input and

on the evaporator. Other projects are in hand or planned.

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Wastewater treatment

The quantity and load of wastewater generated is minimised. Primary, secondary and tertiary

treatment are provided, as well as nutrient (N and P) removal. Surplus sludge is disposed of as

necessary in accordance with Nutrient Management Plans. Treated wastewater complies with the Table

of EPA’s BAT-Associated Emission Levels for Discharges to Water* (next page):

BAT-Associated Emission Levels for Discharges to Waters

*

All values refer to daily averages based on a 24-hour flow proportional composite sample, except where

stated to the contrary and for pH, which refers to continuous values. Levels apply to effluent prior to

dilution by uncontaminated streams, e.g. storm water, cooling water, etc.

* Temperature measured downstream of a point of thermal discharge must not exceed the unaffected

temperature by more than 1.5o

C in salmonid waters and 3o

C in cyprinid water (Freshwater Fish Directive

79/659/EEC).

Note 1: The number of toxic units (TU) = 100/x hour EC/LC50

in percentage vol/vol so that higher TU

values reflect greater levels of toxicity. For test regimes where species death is not easily detected,

immobilisation is considered equivalent to death.

Note 2: Total Nitrogen means the sum of Kjeldahl Nitrogen, Nitrate N and Nitrite N.

Note 3: Reduction in relation to influent load.

Note 4: Limits will depend on the sensitivity of the receiving waterbody.

Note 5: Any relevant polluting substances as specified in Schedule to S.I. No. 394 of 2004: EPA

(Licensing)(Amendment) Regulations, 2004.

Constituent Group or Parameter Emission Level Notes

pH 6 - 9

Number of Toxicity Units (TU) 5 1

BOD5 >90% removal

3

, or 20 - 40mg/l

COD >75% removal3

, or 125 - 250mg/l

Suspended Solids 50mg/l

Total Ammonia (as N) 10mg/l

Total Nitrogen (as N) >80% removal3

, or 5 - 25mg/l 2,4

Total Phosphorus (as P) >80% removal3

, or 2 - 5mg/l 4

Oils, Fat and Grease 10 - 15mg/l

Mineral Oil (from interceptor) 20mg/l

Mineral Oil (from biological

Treatment) 1.0mg/l

Other -- 5

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Attachment No. A.2 Location maps

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Attachment No. F1. Technical Amendment issued by EPA on 17 October 2011

amending the original (2007) IPPC licence.

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