«enryB kcirtaP :MORF 5002 lirpAht7 :E T A D Application for review of licence Reg. No. 41 from Dublin Products :ER Limited, Tornant Lower, Dunlavin, ...»
FO EC IFFO
& GNI SNECIL
E CNADIU G
rebmeM draoB hcaE
:E T A D
Application for review of licence Reg. No. 41 from Dublin Products
:ER Limited, Tornant Lower, Dunlavin, County Wicklow, Reg. No. 709
Class of activity: 7.7.1 The disposal or recycling of
animal carcasses and animal waste
with a treatment capacity exceeding
10 tonnes per day.
Note: Previously licensed under Class 7.7 “The rendering of animal by-products” of First Schedule of EPA Act 1992 Section 85(1)b notice sent: 06/05/04 Information under Section 85(1)(b) 04/06/04
Notices under Article 17(2) issued: 05/07/04 Information under Article 17(2) received: 08/10/04, 11/01/05 Clarification sought under Article 17(3): 17/02/05 Response to Article 17(3): 23/02/05 Notice under Sections 82(8) and 83(5) 09/09/04
Information under Sections 82(8) and 83(5) 11/01/05, 04/03/05
Submissions received: None Site visits: 18/06/04 1 of 12 Company Dublin Products was granted its original licence on the 23/07/1997 (Reg. No. 41).
The activity is located in a rural area approximately 700 metres south west of the village of Dunlavin. The activity is engaged in the rendering of animal by-products.
The activity was commenced at the current site in 1973 and currently provides employment for c.50 people and operates 24 hours a day 6 days a week. The company have undertaken a number of developments on-site since the grant of licence reg. no. 41, only the construction of the air emission stack associated with the thermal oxidiser (TO) required planning permission (planning reference 9136/98).
The company prior to the grant of Licence Reg. No. 41 and for sometime after grant of the licence was the cause of considerable local complaint as a result of odours emitted from the facility. Odour complaints associated with operation of the activity have reduced significantly over the past number of years, however there continues to be occasional odour nuisance reported. The company installed biofilters to treat the odourous gases and more recently (2001) installed a Thermal Oxidiser (TO) to treat the most odourous gases. The company undertook an expansion project in 2000 and 2001 which saw an increase in processing capacity and major improvements in pollution abatement systems and cessation of effluent discharges to surface water. The company currently have capacity to process c.
125,000 tonnes of raw product, the inspectors report for Licence Reg. No. 41 stated that they had a capacity to process 2000 tonnes of raw material per week i.e.
104,000 tonnes per year.
Reason for review The Agency agreed to a request from Dublin Products Ltd. to have their Licence (Reg. No. 41) reviewed for the following reasons; the change in raw material processed as a result of Dublin Products Ltd. application to the Department of Agriculture Food & Rural Development to have the facility designated as a Category 1 plant (as defined by EU Regulation 1774/2002); and the changes in the licensing legislation as provided for in the Protection of the Environment Act, 2003.
Process Description The activity receives two types of animal by-products, (a) soft offal and (b) fat and bone, the two types of waste are handled through two separate process lines referred to as Wicklow Proteins and Dublin Products respectively. The two separate process lines operate in parallel and each line follows the following stages. The raw material is delivered to the activity in covered lorries, skips, wheelie bins and a small quantity is delivered in plastic bags (from butchers etc) which must be emptied prior to processing. The raw material is crushed in the raw material building and transferred to the continuous cookers (2 associated with each line) and cooked by the transfer of heat by steam. The cooked material exits the cookers and is transferred to a screw press (3 associated with each process line) which separates the tallow from the greaves (meat and bonemeal). The tallow undergoes centrifugation and sterilisation before been pumped to dedicated storage tanks within a bunded tank farm. The greaves are discharged from the press to temporary storage after which the material is sterilised, cooled and milled. Milled meat and 2 of 12 bonemeal (MBM) is loaded within a dedicated building into trailers for transport off site. There is limited MBM storage available on-site.
The odourous air arising on site is directed to the TO or to one of the 3 bio-filters.
Since the installation of the TO the company have reduced their loading to the waste water treatment plant (WWTP) and the company have been able to recycle all effluent from the WWTP to the biofilters and elsewhere on-site as wash water. The majority of the organic wastes arising on-site are returned to the raw material intake buildings and reprocessed.
Use of Resources Fuel The activity requires the generation of significant quantities of steam, the steam is generated by the combustion of either medium fuel oil (MFO) or tallow oil in the TO and one of the three boilers on-site. There are three boilers on-site however the licensee only requires operation of one boiler to supplement the stream generated by the TO. The use of MFO or tallow has been based on the relative cost/value of the MFO and tallow. The company have a program of improvements to reduce fuel usage.
Diesel oil is used on site to fuel trucks, tractors, forklifts and space heating.
Electricity Electricity usage on-site is primarily to operate pumps, augers, lighting etc. The company aim to reduce electric consumption by installation of capacitors, assessment of current production methods, installation of correctly sized motors and use of the most efficient lighting.
Water The water supply to the activity is from two on-site wells. The average consumption is c. 24,000m3/yr. Waste water from the WWTP is recycling where possible to reduce the quantity of fresh water required.
While the company have made efforts to reduce energy and raw material usage the RD includes a condition which requires the licensee to undertake an energy efficiency audit of the activity within twelve months of the date of grant of licence.
The audit shall be repeated at intervals as required by the Agency.
IPPC Directive This installation falls within the scope of category 6.5 “Installations for the disposal or recycling of animal carcasses and animal waste with a treatment capacity exceeding 10 tonnes per day” of Annex Ι of Council Directive 96/61/EC concerning integrated pollution prevention and control.
The Recommended Determination (RD) as drafted takes account of the requirements of the Directive. In particular, Condition 7 Resource Use and Energy Efficiency provides conditions dealing with water, energy and raw materials use, reduction and efficiency on site. Condition 10 Decommissioning and Residuals
BAT A final Bref document for this sector was completed in November 2003. BAT is taken to be represented by the operation of a TO for the treatment of the most odourous gases.
European Communities (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2000 (SI 476 of 2000) The activity is not covered by the Seveso regulations.
Directive 2000/76/EC of the European Parliament and of the Council of 4
December 20000 on the Incineration of Waste:
Dublin Products have, like most rendering activities used tallow oil as a substitute fuel to operate their boilers and thermal oxidisers. Tallow oil had been regarded as a substitute fuel and therefore used to replace MFO. Animal waste regulated by Council Directive 90/667/EEC (laying down the veterinary rules for the disposal and processing of animal waste, for its placing on the market and for the prevention of pathogens in feedstuffs of animal or fish origin) was excluded from the scope of Directive 2000/76/EC (Waste Incineration Directive (WID)). However EC Regulation 1774/2002 (laying down health rules concerning animal by-products not intended for human consumption) which amends 90/667/EEC specifies that Directive 2000/76/EC (WID) does not apply to incineration plants if the waste treated consists solely of animal carcases. Dublin Products incinerates tallow oil, which is a by-product of animal carcases therefore the WID does apply.
Dublin Products are required to comply with the requirements of WID as from 28 December 2005 in relation to the incineration of tallow oil. Dublin Products have confirmed that there TO and boilers will not be capable of complying with the requirements of the WID, i.e. retention time of 2 seconds etc. therefore it is proposed in the RD to require the licensee to cease the use of tallow oil as an alternative fuel source in the TO and boilers by the 28 December 2005 unless otherwise agreed with the Agency.
The RD includes conditions which control the operation, monitoring and control of the TO and boilers while operating on tallow oil and/or medium fuel oil. In particular the operation of the TO shall achieve a minimum temperature of 850oC and a retention time of at least 0.8 seconds, prior to treatment of odourous air streams.
Raw Material Acceptance and Handling:
The RD includes a number of conditions in relation to the acceptance and handling of raw materials delivered to the facility for processing. The conditions aim to ensure there is no loss of raw materials to the environment and also to minimise 4 of 12 odourous emissions. The licensee has informed the Agency that they have applied to the Department of Agriculture to be allowed process Category 1 material, as defined under EC Regulation 1774/2002. The licensee has stated that all measures required to process Category 1 material in accordance with Annex V of EC Regulation 1774/2002 are currently in place. The RD requires the licensee to satisfy the Agency one month prior to the commencement of processing of Category 1 material that it has obtained the written consent of the Department of Agriculture and Food.
Odourous air emissions to atmosphere have traditionally resulted in a large number of complainants against the rendering sector including the licensee. This activity, similar to other rendering facilities in Ireland, have installed biofilters (three installed on-site) to treat the odourous air from the process buildings and a TO to treat the most odourous air from the cooking process and process buildings.
Prior to the installation of the TO the evaporated air stream from the cookers were directed to condensers associated with each of the two process line. In the condensers the condensable gases were converted to liquid and directed to the WWTP. This liquid was typically highly odourous as well as having high organic and ammonia concentrations. The non-condensable gases which were typically the most odourous air stream arising in the process were directed from the condensers to the biofilters. This air stream could contain peaks of odourous components which may pass through the treatment medium without any significant reduction or may be inhibitory to the biological activity in the biofilter medium. The condensers have been retained as a back-up to the TO.
The installation of the TO resulted in the activity being able to thermally oxidise gaseous streams arising from the cooking process. The system thermally oxidises moisture laden vapours which arise from the cooking process (condensable and noncondensable gases) and some of the odourous air from the processing buildings.
The TO performs the dual function of thermal oxidation of odourous air streams and the generation of steam to heat the cookers and other systems on-site. The installation of the TO reduces the odourous air load on the biofilters and reduces the condensable liquid load to the WWTP.
The TO on-site has to date been fired on either MFO or tallow oil, as discussed above the TO will not be capable of achieving the requirements of the WID and therefore the use of tallow oil will cease by 28 December 2005. The system
thermally destructs odours when the following parameters are maintained:
temperature of at least 850oC; a retention time of at least 0.8 seconds; and sufficient turbulence to promote adequate mixing of the process gases to be combusted. The general operating temperature is c. 900oC. Down stream of the combustion chamber a waste heat recovery boiler is installed which is designed to raise steam for the rendering process. The exhaust gas is cooled to c. 380oC before passing to atmosphere.
Steam consumption on-site generally runs at c. 40,000lbs/hr, the TO is capable of generating c.34,390lbs/hr. The shortfall in steam generation capacity and process start up steam is supplied by one of the 3 boilers. Only one boiler is operated at any one time to supplements the TO, the 3 boilers are retained to provide back-up steam should the TO boiler be out of commission. The RD requires that only one boiler 5 of 12 may be operated at the same time as the TO, and the RD requires the licensee to establish a log of TO and boiler usage (on/off times), including fuel and tallow oil usage.
Odourous Air Emissions:
Treatment of Process Gases on-site is between the TO and the three biofilters, the following is a summary of the processing capacity of each and the source of the odourous air streams.
The TO treats odourous air emissions from the cookers (18,000kg/hr) and air streams from the process areas (20,885kg/hr);
Biofilter 1 treats odourous air from the Dublin Products (fat and bone processing) Building (c.28,450 m3/hr) Biofilter 2 treats odourous air from the Wicklow (soft offal) and Dublin Products intake buildings and the Wicklow proteins processing building (c. 80,000 m3/hr).
Biofilter 3 treats odourous air from the sterilisation and milling building (c.