«Application Details Name and address of activity Iropharm Plc. Vale Road, Arklow, Co. Wicklow Class of activity: 5.6 Manufacture of pharmaceutical or ...»
1.4 kg/hr NO2 compared with 6.4 kg/hr from Schering Plough Avondale and up to 98 kg/hr from IFI.
By-pass of thermal oxidiser A by-pass event was modelled for the proposed thermal oxidiser. The assessment was conducted on the basis of the expected maximum average VOC loading of the waste gas stream of 7.35 kg/hr. However, the thermal capacity of the TO is based on the maximum short term peak VOC loading in the waste gas stream of 32.13 kg/hr. This peak value on the inlet to the TO is expected to occur infrequently and to be of durations of less than 1 hour. The maximum 1 hour ground level concentration was predicted also for this event, however it is unlikely to reflect a realistic situation.
Results of the maximum average VOC loading (7.35 kg/hr) predicted are less than the relevant Irish OEL/40 for individual components. Taking the additive combined effects of all the compounds, the threshold limit values do not exceed unity. Results for maximum short term peak (32.13 kg/hr) predicted are less than the relevant Irish OEL/40 for individual components. However taking the additive combined effects of all the compounds, the threshold limit values exceed unity. As stated above this event is likely to be infrequent and less than one hour. The model prediction is based on this emission occurring on a continuous basis through out the year. Condition 5.12 of the PD requires that the plant be shut down for any bypass in excess of one hour’s duration.
Effluent Discharge to surfacewater The existing IPC licence sets limit values for discharge to the Avoca river until June 01 2002. From June 02 2002 more stringent limits have been applied in the existing licence. The company have requested that the volume limit be increased from 144 m3/day to 240 m3/day to account for future proposed increases in production and seven day plant operation (current plant operation is 5 day). However the company also submitted a projected maximum flow of 225 m3/day. This flow value has been applied in the PD. Allowing a further increase to 240 m3/day does not encourage waste minimisation. The company request similar limits to the existing licence up to the June 2002 deadline and these limits have been included in the PD with the exception of toxicity which has been reduced from 20 TU to 10 TU. The new WWTP, designed to meet more stringent limits being applied from June 2002, has already been installed and is being commissioned; this should enable the company to achieve the tighter toxicity limit. The limits for chloride and sulphate have also been reduced to the maximum values reported by the company to date and taking account of the increased volume.
The company is currently commissioning a new secondary WWTP. This system consists of 2 pH correction chambers, segregation precipitation tank, aerated balance tank with odour scrubber, sequential batch reactor basin, final effluent buffer tank, emergency tank and waste sludge processing system. The company have requested that reduced limits based on secondary treatment not be applied until June 2002. This is to allow for detailed investigation to be conducted on ammonia streams and measures to reduce ammonia, to conduct detailed assessment of individual waste streams, to conduct pilot trials, and to source a suitable outlet for sludge disposal. The company further requested that existing licence limits set from 2002 be applied. They stated that they are not requesting an increase in mass emissions (to be applied from June 2002) even though the volume will increase from 144 m3/day to 225 m3/day. They have submitted projected data for quality of effluent discharge from 2002. However the company have also requested (in the emissions table) emission limit values which are higher than the projected values, no justification is included for these increased figures and they have not been included in the PD. The limit values included in the existing licence from June 2002 (consistent with projected values submitted by the company) have been included in the PD with the exception of volume flow which has been increased to 225m3/day and BOD load which has been increased from 170 kg/day to 250 kg/day (50% removal) and ammonia from 7.2 kg/day to 12 kg/day. However a further reduction in BOD to 120 kg/day (75% removal) has been applied from June 2003. Chloride and sulphate limits have been reduced for reasons discussed above.
Impact of Effluent Emissions Recent monitoring data for the Avoca River show that water quality is similar to quality conditions when the existing licence was issued in 1997. The biological quality rating of the river is 1. Existing and proposed orhophosphate limits for effluent discharge would cause an increase in river orthophosphate concentration of 7 µg/l PO4 as P and 6 µg/l PO4 as P. There are only three orthophosphate values recorded for the river upstream of the discharge point in the last year and these range from 0.098 µg/l PO4 as P to 0.036 µg/l PO4 as P.
In accordance with the regulations, median concentrations should be determined on the basis of a minimum of ten samples taken at intervals of four weeks or longer in twelve consecutive months. The water quality standards for phosphorus regulations require that seriously polluted rivers achieve a minimum quality standard of moderately polluted (70 µg/l PO4 as P) by 2007. The waste assimilative capacity of the river for ammonia as N (based on salmonid quality) is approximately 87 kg NH3 N /day. While achieving BATNEEC the limit from 2002 has been increased from 7.2 kg/day to 12 kg/day due to increased volumes associated with increased production. The company is required to address in the EMP the reduction of ammonia and nitrogen emissions with the aim of achieving BATNEEC to ensure that limits applied from 2002 are achieved. The waste assimilative capacity of the river for BOD (based on salmonid river quality) is in excess of 580 kg /day BOD. The PD sets a limit of 250 kg /day BOD from June 2002 to June 2003 and a limit of 120 kg/day BOD from June 2003.
Surfacewater A proposal to construct a firewater retention pond has been agreed with the Agency. Condition 9.2.3 requires the licensee to submit details on the operation of the diversion system, including a detailed plan of the firewater system and associated drainage and diversion systems, within six months of the date of grant of the licence, as details have yet to be finalised. A continuous TOC monitor has been installed on surfacewater discharge, W 2.
The handling of hazardous and non hazardous wastes is carried out in accordance with the existing IPC licence, some additional waste contractors have been agreed with the Agency. Waste sludge from the WWTP has been included with non hazardous wastes for disposal.
The company states that one of the reasons that thermal oxidation was chosen was to provide the option, at a later date, for the economic reuse of clean solvents streams generated on-site to recover the high inherent energy potential. The company has not requested that the use of solvent as a fuel in the thermal oxidiser, be considered in this review. Therefore it is not considered in the PD and condition 7.2 states that waste solvent streams or solvents shall not be used as an alternative fuel for the thermal oxidiser. This can be assessed at a later date if requested by the company. However the company are required to address in the schedule of environmental objectives and targets, the on-site reuse of waste solvent for energy recovery under class 11.
Groundwater monitoring conducted at the site, as a requirement of the existing IPC licence, shows that 1,2 dichloroethane concentrations have ranged from 600 to 900 ug/m3 and chlorobenzene, toluene, xylene, ethylbenzene, alkylbenzenes, napthalene, styrene and chloroform have also been detected in trace concentrations. No discrete points of entry for the contaminants into the subsurface have yet been identified and the use of 1,2 DCE was discontinued circa 1989. The company propose, through the use of consultants, to conduct a detailed assessment of the site and the magnitude and distribution of contamination and prepare a report including a semi-quantitative risk assessment and corrective action strategy. This has been included as condition 9.3.3 of the PD. Additional monitoring boreholes constructed by the company have also been included in the monitoring schedule.
There has been no change in limits for noise levels off-site, from the existing licence. Limits on noise sources have been removed from the licence. If noise surveys show a problem with noise the company can address reduction of noise from relevant sources where required. No complaints have been received in relation to noise from this activity.
There was 1 submission received from Duchas on this application. They state that they have no objections to the application. However they recommend that precautions be put in place to prevent leaks and spills. The “Arklow Town” pNHA site no 1931 is downstream of the site.
Conditions relating to bunding, and the loading and unloading of materials in a manner to prevent spills have been included in the PD.
There were no complaints received in relation to this activity.
Summary of enforcement.
Iropharm have been in non-compliance for combined emissions to atmosphere for organics. The existing scrubber system is incapable of achieving the limits set. The company proposes the installation of a thermal oxidiser to ensure compliance with emission limit values. An effluent sample taken in 1998 exceeded toxicity limits. The company conduct microtox tests on raw effluent streams to establish toxicity and treatability. The company also moved forward plans to install a WWTP, which is being commissioned at present. Toxicity tests conducted in 1999 were in compliance with licence limits. There were two bursting disc ruptures reported for 1999 and one to date for 2000. There was an elevated COD and pH recorded for surfacewater discharge. An automatic diversion system has been installed to divert contaminated streams to the WWTP. Work is due to begin on a firewater retention pond. Contaminated streams will be automatically diverted to this pond. Contaminants have been detected in groundwater. This is discussed in detail in the groundwater section above. The TOC monitor on surfacewater malfunctioned twice in 1999.
Corrective and preventative action was taken. On a recent site visit it was noted that chemical drums were unbunded. A request for information has been sent to the company in relation to this.
That the proposed determination as submitted be approved by the Board.
Signed Annette Prendergast References 1 November 1991, Society for Clean Air in the Netherlands (Vereninging