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«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, ...»

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The licensee has undertaken a dispersion model of the odourous emissions from the facility in 2001 after the installation of the TO. The results of the assessment identified that the nearest dwelling house (c. 5 meters from the boundary of the site) would be between 5-10 odour units. The dwelling houses to the south west of the facility would be between 2-5 odour units, the dwelling houses to the north east of the facility would be between 1-2 odour units. The dwelling houses on the outskirts of Dunlavin village would be exposed to less than 1 odour unit. As an existing activity the licensee is required to undertake measures on-site to achieve an emission limit value (ELV) for odour measured at the nearest odour sensitive receptors of ≤ 5.0 ou E/m3 – 98-percentile of –hourly average concentration, above that of recorded background concentrations1. Therefore the RD requires the licensee to assess further odour abatement measures as part of the objectives and targets, in addition the RD includes conditions to control and minimise odour emissions.

The RD requires that: “All off gases arising from the on-site cookers shall be diverted to the thermal oxidiser for treatment. Off gases shall only be directed to alternative treatment options temporarily with the prior agreement of the Agency.” The licensee was required to have the integrity of all buildings assessed, this was completed in July 2004, the report identified only minor structural repairs as been necessary. The RD requires that the integrity of all buildings be maintained and an assessment of building integrity undertaken every twelve months, recommendations implemented and reported in the AER. The RD requires the licensee to propose and install an air lock system at the entry to the intake buildings to avoid the loss of odourous air when raw material is delivered to the activity. The RD requires the licensee to fully investigate and report on all complainants made by local residents.

Emissions to Atmosphere:

The applicant has undertaken air dispersion modelling, using AERMOD, of the air emissions from the TO and the operation of one of the boilers to provide BAT Guidance Note On Best Available Techniques for the Slaughtering Sector, October 2004 6 of 12 supplementary steam. The model assumes operation of the TO is for 18hrs/day and the boiler 2.5hrs/day. The emissions used in the model are based on the maximum measured emissions from the TO and boiler. The model was run a number of times to establish the impact associated with operation of the TO and boiler on tallow or

MFO, the four scenarios are:

• Thermal oxidiser running on tallow oil and boiler running on tallow oil;

• Thermal oxidiser running on MFO and the boiler running on MFO;

• Thermal oxidiser running on tallow oil and the boiler running on MFO; and

• Thermal oxidiser running on MFO and the boiler running on tallow oil.

Operation on tallow oil generates slightly less emissions of SO2 and NO2 but more CO than operation on MFO. The worst case air dispersion model results, based on the applicants air dispersion modelling are presented in the table below along with relevant air quality standards.

–  –  –

The above results indicated that the operation of the TO on tallow and the boiler on MFO will not result in a breach of any air quality standards. Operation of the TO and boiler on MFO will result in lower emissions and therefore lower ground level concentration based on the modelling provided. The RD limits the licensee to the operation of the TO and only one boiler at any one time unless agreed in writing with the Agency. The modelled maximum emission rates are included as the emission limit values in the RD from both the TO and boilers.

Operation of the TO and boiler on tallow oil is limited to the 28 December 2005 as the plant on site are not capable of meeting the requirements of the WID which are 7 of 12 applicable for this activity if they are incinerating tallow oil from that date.


Effluent Emissions to Waters:

As a result of the installation of the TO the activity generates significant less waste water. The current waste water feed to the WWTP is from wash water and contaminated surface waters (storm water) which is collected in an underground sump at the centre of the site. The quantity of water collected is dependant on rainfall and the licensee estimates that maximum load amounts to c. 120m3/day.

Following collection the waste water passes through the WWTP. The WWTP onsite was designed to accept a significantly greater loading i.e. when condensable effluent from the cookers required treatment.

The WWTP process includes dissolved air floatation, effluent balancing, activated sludge, nutrient removal (anoxic zone and precipitation of phosphorus) and final clarification. The effluent following treatment in the WWTP is stored on-site and re-used to water the bio filters, as wash water and may, if available, be used as boiler feed water (following pre-treatment). The licensee has not had to discharge waste water from the WWTP to surface water since the TO became fully operational. All sludges generated/removed from the WWTP are returned to the raw material intake and reprocessed.

The licensee requests that the provision to discharge waste water to the surface water be maintained in the revised licence to provide for situations where the TO may not be operational for an extended period of time. The adjoining river into which the effluent previously discharged is a tributary of the River Greese. The licensee submitted a copy of a report on the assimilative capacity of the River Greese, dated June 1996. This report identified that two local authority waste water treatment plants discharge to the receiving water and that the combined loading from these two plants consume in excess of 1.5 times the available waste assimilative capacity (BOD loading) in the Greese River. The EPA publication, The Biological Survey of River Quality 2000 states that “the Greese River was again seriously polluted by suspected sewage and industrial discharges in the Dunlavin area and it was in a highly eutrophic condition at each of the other seven locations surveyed in late August 2000”. The Quality (Q) Ratings for the river in 2000 awards a rating of 3 upstream of the Dunlavin local authority discharge and a Q rating of 2 immediately downstream of the discharge. The Q rating further downstream recovers to 3 and 3-4. Biological monitoring of the Greese River was repeated in September 2003 and the results of this monitoring indicate some improvement in the upper reaches of the Greese River, improvement from Q 2 to Q3. The report notes that serious pollution had abated in the upper reaches, however the river remains nowhere near satisfactory. It is noted that the Greese River is a hardwater river and therefore is sensitive to changes in water quality.

Based on the assessment of assimilative capacity and the biological surveys of the river it is highly commendable that the licensee has ceased to discharge to the river since January 2001. A resumption of effluent discharge to the river from Dublin Products Ltd would have a negative impact on the Greese River. Therefore the discharge of effluent to the Greese River shall only occur in exceptional circumstances and for limited periods, following agreement with the Agency. Any 8 of 12 agreed discharge shall be subject to the emission limit values specified in the RD.

Surface Water Emissions:

There is one surface water discharge from the activity, the water discharged arises from building roofs, concreted lorry and skip holding yard at the rear of the site and underground site drainage of the rear of the site. The surface water discharge is unlikely to be contaminated from activities on-site as most movement of lorries is within yard areas where the surface water is collected and directed to the WWTP.

The RD requires the licensee to visually examine the surface water discharge daily and monitor it monthly. The surface water discharge is to the field drain adjoining the site which is a tributary of the Greese River.

All tallow oil is stored within a bunded tank farm, MFO is stored within a dedicated bunded area and chemicals are stored on mobile spill pallets which are generally stored in a locked chemical storage building. The RD includes the standard condition in relation to the bunding requirements for all tanks and drums.

A Firewater retention study has been completed by the licensee under existing IPC Licence Reg. No. 41, the recommendations of this study have been implemented onsite.

Emissions to groundwater:

There are no emission to ground water associated with the activity. All processes are to be undertaken within the buildings on-site and all vehicular movement takes place on concrete yards. There are two deep wells on-site which are the supply wells for the activity.

Monitoring conducted under the requirements of Licence Reg. No. 41 since 2001 indicate that nitrate levels in the groundwater have increased slightly to 12mg/l in 2004 from c.9mg/l in 2001. This is assumed by the licensee to be due to agricultural practices. The TOC results since 2001 have also indicated a slight increase from 5mg/l to 13 –28mg/l in the two wells in 2004.

The RD requires the groundwater extracted from these two deep wells to be monitored bi-annually for pH, TOC, Nitrate, Total ammonia, Total nitrogen and conductivity. In addition the water usage (flow rate) shall be monitored daily and recorded on-site.


Organic wastes, other than meat and bonemeal or tallow, arising on-site are returned to the raw material intake building and passed through the rendering process. The organic wastes which are re-processed include greaves, sludges, partly processed material, contaminated tallow, skip wash down water etc.

Hazardous and non-hazardous wastes are sent off-site for disposal or recovery by licensed/permitted contractors. The RD requires the licensee to agree any changes to the contractors used for the disposal/recovery of waste with the Agency.

Tallow generated as part of the process is currently is used on-site as a replacement for MFO for the TO and boilers. Tallow oil not used in the TO or boilers is transported off site under the supervision of the Department of Agriculture. An increased quantity of tallow oil will be transferred off-site. The meat and bonemeal generated on-site is transported off site under the supervision of the Department of Agriculture.

9 of 12


Noise monitoring was undertaken on the 1 st and 2nd of March 2004 under the requirements of Licence Reg. No. 41. The monitoring was undertaken at three locations, at the nearest dwelling house (5m from the site boundary), second nearest dwelling house (200m south of the factory entrance) and at the nearest house to the north of the site (500m north at the edge of the village). The noise monitoring results indicate compliance with the emission limit values (55/45dBA daytime/night time) at the nearest residence. The emission limit values are exceeded at the other two monitoring points however the source of noise is noted to be predominantly road traffic noise. No tonal or impulsive noises were noted.

The standard noise emission limit values are maintained in the RD and the licensee is required to undertake an annual noise monitoring survey which shall include proposals to reduce noise, where necessary.

Habitats The installation site is located in a rural area in west Wicklow close to the village of Dunlavin. The licensee has identified Dunlavin Marches (north east of the installation) which is classified as a proposed National Heritage Area as the closest habitat to the installation. In addition Wicklow County Council’s development plan identifies trees for preservation, architectural conservation areas, protected structures and areas of archaeological potential/importance within 10 km of the facility. None of the sites will be impacted by the continued operation of the activity.

Compliance Record:

The OEE undertook an audit of Dublin Products Ltd. on the 08/06/04 against their existing IPC Licence Reg. No. 41. The audit raised four non compliances and

fourteen observations. The audit non compliances were in respect of the following:

• The licensee did not notify the Agency of a substantial spill of oil to the oil tank bund;

• The underground tank and pipeline assessment did not address the integrity of the underground tanks and pipelines associated with the biofilters;

• The integrity and water tightness of all bunded structures and their resistance to penetration by water or other materials stored therein was not tested and demonstrated to the satisfaction of the Agency; and

• The shipment of asbestos waste taken from the site on C1 form was not approved by the Agency.

The observations noted as part of the audit related to the following: extent of changes on-site since grant of Licence Reg. No. 41; programme for public information is not satisfactory; tallow tank and IBCs not bunded; complaints record was not satisfactory; the Emergency Response Procedure should be amended; all abatement equipment should be labelled; install a protective barrier around the effluent tank and pipework; noise surveys should take into account additional factors; pungent odour noted at Aeration Tank 2; summary waste records should be maintained; integrity of buildings report was unavailable; the AER should contain an organisational chart; completed objectives and targets should be removed from 10 of 12 the EMP; and the air extraction system and floor in the meal transfer building was in poor condition.

The licensee has submitted a response to the OEE in relation to the audit report dated the 31/01/05, the OEE have not confirmed that this letter addresses all the points raised in the audit report.

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