OFFICE OF LICENSING & GUIDANCE

Transcription

1 OFFICE OF LICENSING & GUIDANCE TO: REPORT OF THE TECHNICAL ASSESSOR ON OBJECTIONS TO LICENCE CONDITIONS Directors FROM: Technical Assessor - LICENSING UNIT th DATE: 24 April 2007 RE: Objection to Proposed Decision/Determination for R&A Bailey & Company, IPC Reg: P Application Details Class(s) of activity: 7.8 Treatments or processes for the purposes of the production of food products from (a) animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day. Location of activity: Nangor Road, Western Estate, Dublin 12. Licence application received: 14th September 2006 PD issued: 21 st December 2006 First party objection received: 26 th January 2007 Objection forwarded to Sanitary Authority 29 th January 2007 Response from Sanitary Authority Third Party Objection received Submissions on Objections received: Additional Information received: Company The application from R & A Bailey & Company relates to a cream liqueur manufacturing plant located at Nangor Road, Western Estate, Dublin 12. The activity falls under the scope of Class 7.8(a) of the Environmental Protection Agency Acts 1992 and 2003:- Treatments or processes for the purposes of the production of food products from (a) animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day. In this case the raw material is cream. 1

2 The specified date for the making of an IPPC licence application for this class of existing activity was 12th September 2006, as set out in the Environmental Protection Agency Act 1992 (Established Activities) Order 2006 (S.I. No. 279 of 2006). The most significant environmental aspect of the production activities on-site is the generation of a highly biodegradable food grade effluent, which undergoes ph balancing on-site prior to discharge under consent to the South Dublin County Council sewer system, for treatment at Ringsend Wastewater Treatment Plant. One submission was received in relation to the application from the Health Service Executive, which was considered at Proposed Determination (PD) stage. Consideration of the Objection As the Technical Assessor for this objection, I have considered all of the issues raised in the Objection. This report details my comments and recommendations following the examination of the Objection together with discussions with the inspector, Aoife Loughnane, who also provided comments on the points raised. The Agency sector expert for Class 7 Food & Drink, Senior Inspector Pat Byrne, was also consulted. The Sanitary Authority, in this case South Dublin County Council was forwarded a copy of the objection as it included issues relating to emissions to sewer. No response was received however South Dublin County Council Sanitary Section was contacted by phone. This report considers the first party objection to the Proposed Determination from R & A Bailey & Company. No third party objections were received. First Party Objection The applicant, R & A Bailey & Company has submitted an objection, which in summary comprises objections to Condition 3.7 and to Schedule C.3.2. (Monitoring of Emissions to Sewer), a clarification with regard to Schedule C.1.1 (Control of Emissions to Air) and additional information in relation to trade effluent to sewer. 1. Objection to Condition 3.7 Condition 3.7 of the PD states that within six months of the date of grant of this licence, the licensee shall decommission and/or render safe for an agreed alternative use, the two disused oil storage tanks on-site. First Party Objection: An objection is made to the timescale of six months for Condition 3.7, which is considered to be not appropriate. The disused tanks are intact; in a bunded area and are not considered to pose an environmental risk. 2

3 Also there is a possibility that the tanks could be used as part of a solution for the firewater or the containment/ bunding, risk assessments to be carried out. These proposals are required within the first 12 months of date of issue of the licence and time would be required to deliver on recommendations from these reports. It is requested that the condition be removed or altered to within 3 years of the date of the licence. Condition 3.6 of the PD (Tank, Container and Drum Storage Areas) includes a requirement that all bunding shall be in place within twelve months of the date of grant of licence. Also Condition 3.11 (Firewater Retention) requires a risk assessment report to be submitted within six months of grant of licence to determine if a firewater retention facility is required. Based on information provided by the applicant it is noted that the disused tanks may be used as part of a solution to either of the above requirements. Considering this and the fact that the tanks are intact, empty and not in use it is proposed to extend the timescale for decommissioning and/or rendering safe for an agreed alternative use, the tanks in question. A revised timescale of 2 years is considered sufficient to allow the requirements of the condition to be met. In addition it is noted that the condition used the text render safe for an agreed alternative use : this may not require removal of the tanks as feared by the applicant. Recommendation: Condition 3.7 should be amended to read as follows: Within two years of the date of grant of this licence, the licensee shall decommission and/or render safe for an agreed alternative use, the two disused oil storage tanks on-site. 2. Objection to Schedule C.3.2 (Monitoring of Emissions to Sewer) First Party Objection: The frequency of monitoring proposed for BOD, COD, Suspended Solids, Sulphates, Phosphates, Detergents and Oils, Fats and Greases (OFG) is objected to. The monitoring required in the PD is Daily for these parameters (i.e. on any day when emissions are taking place). The frequency is objected to on two grounds as follows: The requirements under the current discharge licence, is to take a 24-hour composite sample no less than 12 times per calendar year. The proposed frequency would represent a 30-fold increase on previous requirements. The associated costs are beyond what is considered reasonable for an emission to sewer of this nature. In the Inspectors Report it states that daily monitoring is required for parameters, which have daily mass load limits. However under the current 3

4 discharge licence such limits are in place and monthly monitoring has been adequate. It is proposed that the monitoring frequency for Suspended Solids, Sulphates, Phosphates, Detergents and Oils, Fats and Greases be 1 sample per week. Also for COD it is proposed that daily analysis be carried out (as specified in the PD). The analysis is proposed to be done on-site with a weekly external analysis for verification. It is proposed that BOD be calculated daily from COD using a known BOD: COD ratio. This is as there is a great deal of variability and lack of repeatability with the BOD test on the typical Baileys effluent. In respect of discharge to sewer, South Dublin County Council as the Sanitary Authority specified Consent Conditions for the trade effluent discharge from the installation. In relation to monitoring frequency, daily monitoring is specified for COD with weekly monitoring for BOD, suspended solids, sulphates, oils, fats and greases (OFG), phosphates and detergents. In relation to limit values, limits were specified for the above parameters as loadings (Daily Mean Loading in kg/day) rather than concentration limits. For COD, BOD and suspended solids limits were also specified for Mean Weekly, Mean Monthly and Mean Annual Loads (in kg/day). When the consent conditions were being taken into consideration for the PD the frequency of monitoring in Schedule C.3.2 for certain parameters was set at daily. This was to allow for the requirement for daily mean loadings limits. Following discussions with representatives from the Sanitary Authority and the Licensing Inspector it is considered that a variation in the specified daily monitoring for certain parameters would be considered reasonable for the discharge to sewer. It is recommended to reduce the monitoring frequency for the parameters sulphates, OFG, phosphates, and detergents from daily to weekly as originally set out in the Section 99E response received from the Sanitary Authority. Also an inconsistency exists for the parameters BOD and suspended solids, where limits are set for both a Mean Daily Load and Mean Weekly Load and only weekly monitoring is specified. Therefore it is not possible to calculate both a daily and a weekly load. For BOD it is recommended to reduce the monitoring frequency from daily to weekly, however BOD (as mg/l and kg/day) shall be calculated and reported daily based on the daily COD analysis. This is to be done by first establishing a correlation between the parameters i.e. the BOD: COD ratio for the discharge, which shall be agreed with the Agency. With regard to suspended solids the frequency of daily monitoring as specified in the PD is to remain. This will allow mean daily and mean weekly loads for suspended solids (as kg/day) to be calculated as specified by the Sanitary Authority. 4

5 Recommendation: Schedule C.3.2 Monitoring of Emissions to Sewer should be amended to read as follows: Emission Point Reference No.: SE-1 Parameter Monitoring Analysis Method/Technique Frequency Flow Continuous On-line flow meter with recorder Temperature Continuous On-line temperature probe with recorder ph Continuous ph electrode/meter and recorder Biochemical Oxygen Demand (BOD) Note 1 Note 2, Weekly Note 3 Standard Method Chemical Oxygen Demand (COD) Note 1 Daily Note 2 Standard Method Suspended Solids Note 1 Daily Note 2 Gravimetric Sulphates (as SO 4 ) Note 1 Weekly Note 2 Standard Method Phosphates (as PO 4 -P) Note 1 Weekly Note 2 Standard Method Detergents (as MBAS) Note 1 Weekly Note 2 Standard Method Oils, Fats & Greases Note 1 Weekly Note 2 Standard Method Total Nitrogen (as N) Note 1 Monthly Note 2 Standard Method Total Phosphorus (as P) Note 1 Monthly Note 2 Standard Method Note 1: Parameters shall be measured in mg/l and the licensee shall calculate and report the mass emission (kg/day), based on daily volumetric flow. Note 2: All samples shall be collected on a 24 hour flow proportional composite sampling basis. Note 3: In addition to the weekly BOD analysis, BOD (in mg/l and kg/day) shall be calculated daily using COD daily monitoring results and an established BOD: COD ratio, which shall be agreed with the Agency. 3. Clarification on Schedule C.1.1 Control of Emissions to Air First Party Objection: As a clarification with regard to Schedule C.1.1, it is understand that monitoring of the bag filter integrity and air flow are to continue to be conducted as per the current practice. With regard to Schedule C.1.1, it is confirmed that in relation to Control of Emissions to Air monitoring may continue to be conducted as per the current practice. Recommendation: No change. 5

6 3. Additional Information with regard to Emissions to Sewer Additional information was submitted in relation to the nature of the effluent emitted to the Sanitary Authority sewer. Attachment 1 as previously submitted to South Dublin County Council describes the rationale for an increase in licence limits, on-site effluent pre-treatment issues, and parameters of concern for measurement. The additional information does not result in any changes to the PD as issued. Recommendation: No change. Third Party Objections No Third Party Objections were received. Overall Recommendation It is recommended that the Board of the Agency grant a licence to the applicant (i) (ii) and (iii) for the reasons outlined in the proposed determination and subject to the conditions and reasons for same in the Proposed Determination, subject to the amendments proposed in this report. Signed Marian Doyle Technical Assessor 6