Sector Guidance Note IPPC S6.13. www.environment-agency.gov.uk. General Guidance for the Dairy and Milk Processing Sector

Sector Guidance Note IPPC S6.13 www.environment-agency.gov.uk General Guidance for the Dairy and Milk Processing Sector

Commissioning Organisation Environment Agency Rio House Waterside Drive Aztec West Almondsbury Bristol BS32 4UD Tel 01454 624400 Fax 01454 624409 Environment Agency First Published 2001 ISBN 0 11 3101740 This document is Environment Agency copyright. We specifically allow the following: Internal business or personal use. You may use this document for your own private use or for use within your business without restriction. Giving copies to others. You may do this without restriction provided that you make no charge. If you wish to use this document in any way other than as set out above including in particular for commercial gain, for example by way of rental, licence, sale or providing services you should contact: Liz Freenland Data and Information Exploitation Manager Environment Agency Rio House Waterside Drive Aztec West Almondsbury Bristol BS32 4UD This is an uncontrolled document. To ensure you are using the latest version please check on any of the websites listed within the references. Table 0.1: Record of changes Version Date Change Template Version Issue 1 October 2003 V5 Written comments or suggested improvements should be sent to Mark Maleham at the Environment Agency by email at mark.maleham@environment-agency.gov.uk or at: Environmental Protection National Service Environment Agency Block 1 Government Buildings Burghill Road Westbury-on-Trym Bristol. BS10 6BF Telephone 0117 914 2868 Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 i

Executive summary This guidance has been produced by the Environment Agency for England and Wales with the Scottish Environment Protection Agency (SEPA) and the Northern Ireland Environment and Heritage Service (EHS). Together these are referred to as the Regulator throughout this document. Its publication follows consultation with industry, government departments and non-governmental organisations. What is IPPC This Guidance and the BREF The aims of this Guidance Integrated Pollution Prevention and Control (IPPC) is a regulatory system that employs an integrated approach to control the environmental impacts of certain industrial activities. It involves determining the appropriate controls for industry to protect the environment through a single Permitting process. To gain a Permit, Operators will have to show that they have systematically developed proposals to apply the Best Available Techniques (BAT) and meet certain other requirements, taking account of relevant local factors. This UK Guidance for delivering the PPC (IPPC) Regulations in this sector is based on the BAT Reference document BREF (see Ref. 1) produced by the European Commission. The BREF is the result of an exchange of information between member states and industry. The quality, comprehensiveness and usefulness of the BREF is acknowledged. This guidance is designed to complement the BREF and is cross-referenced to it throughout. It takes into account the information contained in the BREF and lays down the indicative standards and expectations in the UK (England and Wales, Scotland and Northern Ireland). The reader is advised to have access to the BREF. The aims of this Guidance are to: provide a clear structure and methodology for Operators to follow to ensure they address all aspects of the PPC Regulations and other relevant Regulations minimise the effort by both Operator and Regulator in the permitting of an installation by expressing the BAT as clear indicative standards improve the consistency of Applications by ensuring that all relevant are addressed increase the transparency and consistency of regulation by having a structure in which the Operator's response to each issue, and any departures from the standards, can be seen clearly and which enables Applications to be compared To assist Operators in making applications, separate, horizontal guidance is available on a range of topics such as waste minimisation, monitoring, calculating stack heights and so on. Most of this guidance is available free through the Environment Agency, SEPA or EHS (Northern Ireland) websites (see References) key environmental The key environmental for this sector are: Water use Effluent management Accident risk Hygiene Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 ii

Contents 1 Introduction...1 1.1 Understanding IPPC...2 1.2 Making an application...5 1.3 Installations covered...6 1.4 Timescales...7 1.4.1 Permit review periods... 7 1.4.2 Upgrading timescales for existing plant... 7 1.5 Key...9 1.6 Summary of releases...11 1.7 Technical overview...12 1.8 Economics...13 1.8.1 Sector costs... 14 2 Techniques for pollution control...16 2.1 The main activities and...17 2.1.1 In-process controls... 17 2.1.2 Materials, unpacking, storage... 20 2.1.3 Pasteurisation, Sterilisation and UHT... 21 2.1.4 Evaporation... 22 2.1.5 Drying...23 2.1.6 Centrifugation and Bactofugation... 25 2.1.7 Membrane Separation... 26 2.1.8 Ion Exchange... 27 2.1.9 Filtration...28 2.1.10 Churning... 29 2.1.11 Cooling and Chilling... 30 2.1.12 Freezing and Blast Cooling... 31 2.1.13 Mixing, Blending and Homogenisation... 32 2.1.14 Filling... 34 2.1.15 Fermentation/Incubation Process... 35 2.1.16 Cleaning and sanitation... 36 2.2 Abatement of point source...41 2.2.1 Abatement of point source to air... 41 2.2.2 Abatement of point source to surface water and sewer... 46 2.2.3 Abatement of point source to groundwater... 61 2.2.4 Control of fugitive to air... 62 2.2.5 Control of fugitive to surface water, sewer and groundwater... 65 2.2.6 Odour... 67 2.3...69 2.4...72 2.4.1 selection... 72 2.4.2 minimisation... 74 2.4.3 Water use... 77 2.5...82 2.6...83 2.7 Energy...85 2.7.1 Basic energy requirements (1)... 86 2.7.2 Basic energy requirements (2)... 87 2.7.3 Further energy-efficiency requirements... 89 2.8 Accidents...90 2.9 Noise...94 2.10 Monitoring...96 2.10.1 Emissions monitoring... 96 2.10.2 Environmental monitoring (beyond installation)... 99 Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 iii

2.10.3 Monitoring of process variables... 100 2.10.4 Monitoring standards (Standard Reference Methods)... 101 2.11 Closure...103 2.12 Installation...105 3 Emission benchmarks...106 3.1 Emissions inventory...106 3.2 Emission benchmarks...108 3.2.1 Emissions to air associated with the use of BAT... 108 3.2.2 Emissions to water associated with the use of BAT... 109 3.2.3 Standards and obligations... 109 3.2.4 Units for benchmarks and setting limits in permits... 110 3.2.5 Statistical basis for benchmarks and limits in permits... 111 3.2.6 Reference conditions for releases to air... 111 3.3 Biochemical oxygen demand...112 3.4 Chemical oxygen demand...114 3.5 Halogens...115 3.6 Heavy metals...116 3.7 Nitrogen oxides...117 3.8 Nutrients (phosphates and nitrates)...118 3.9 Particulate and suspended solids...120 3.10 Sulphur dioxide...121 3.11 Volatile organic compounds...122 4 Impact...123 4.1 Impact assessment...123 4.2 Licensing Regulations...125 4.3 The Habitats Regulations...126 References...127 Abbreviations...130 Appendix 1: Some common monitoring and sampling methods...131 Appendix 2: Equivalent legislation in Scotland & Northern Ireland...135 Appendix 3: Groundwater Regulations 1998 Sechdule of listed substances and recommendations for List I (DEFRA)...137 List of figures Figure 1.1: Overview of the activities within the milk processing sector... 12 Figure 2.1: Cleaning-in-place chemical recovery membrane system... 76 Figure 2.2: Example of four-stage counter-flow system based on pea cannery... 81 List of tables Table 1.1: Specific timescale improvements... 8 Table 2.1: Process monitoring and control equipment... 19 Table 2.2: Abatement options for specified pollutants... 44 Table 2.3: Abatement options information... 45 Table 2.4: Water treatment for the Food and Drink sector... 57 Table 2.5: Summary of aerobic and anaerobic treatment processes... 58 Table 2.6: Membrane bio reator (MBR) - activated sludge (AS) comparison... 60 Table 2.7: material substitutions... 74 Table 2.8: Potential use for waste... 84 Table 2.9: Example breakdown of delivered and primary energy consumption... 86 Table 2.10: Example format for energy efficiency plan... 88 Table 2.11: Monitoring of process effluents released to watercourses... 97 Table 2.12: Monitoring of process effluents released to sewer... 98 Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 iv

Table 2.13: Monitoring substances released from sources... 98 Table 2.14: Monitoring of process variables... 100 Table 3.1: Biochemical oxygen demand: water quality objectives in England, Wales and Northern Ireland... 112 Table 3.2: Biochemical oxygen demand: water quality objectives in Scotland... 112 Table 3.3: Halogen standards... 115 Table 3.4: Benchmark emission values... 115 Table 3.5: Heavy metal standards... 116 Table 3.6: Heavy metal benchmark emission values... 116 Table 3.7: Nitrogen oxides benchmark emission values... 117 Table 3.8: Nutrients:water quality objectives in England, Wales and Northern Ireland... 118 Table 3.9: Nutrients:water quality objectives in Scotland... 118 Table 3.10: Particulate and suspended solids in water... 120 Table 3.11: Particulate and suspended solids: benchmark emission values... 120 Table 3.12: Sulphur dioxide: benchmark emission values... 121 Table 3.13: Volatile organic compounds: benchmark emission values... 122 Table 4.1: Measurement methods for common substances to water... 131 Table 4.2: Measurement methods for other substances to water... 132 Table 4.3: Measurement methods for air... 134 Table 4.4: Equivalent legislation... 135 Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 v

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Summary of releases Technical overview Economics 1 Introduction The status and aims of this Guidance This Guidance has been produced by the Environment Agency for England and Wales, with the Scottish Environment Protection Agency (SEPA) and the Environment and Heritage Service (EHS) in Northern Ireland - each referred to as the Regulator in this document. Its publication follows consultation with industry, Government departments and non-governmental organisations. It aims to provide Operators and the Regulator s officers with advice on indicative standards of operation and environmental performance relevant to the industrial sector concerned, to assist the former in the preparation of applications for PPC Permits and to assist the latter in the assessment of those Applications (and the setting of a subsequent compliance regime). The use of quoted in the guidance and the setting of emission limit values at the benchmark values quoted in the guidance are not mandatory, except where there are statutory requirements from other legislation. However, the Regulator will carefully consider the relevance and relative importance of the information in the Guidance to the installation concerned when making technical judgments about the installation and when setting Conditions in the Permit, any departures from indicative standards being justified on a site-specific basis. The Guidance also aims (through linkage with the Application Form or template) to provide a clear structure and methodology for Operators to follow to ensure they address all aspects of the PPC Regulations and other relevant Regulations, that are in force at the time of writing. Also, by expressing the Best Available Techniques (BAT) as clear indicative standards wherever possible, it aims to minimise the effort required by both Operator and Regulator to apply for and issue, respectively, a Permit for an installation. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 1

Introduction Techniques Understanding Understand- IPPC ing IPPC Making an application Installations covered Timescales Key Summary of releases Technical overview Economics 1.1 Understanding IPPC IPPC and the Regulations Integrated Pollution Prevention and Control (IPPC) is a regulatory system that employs an integrated approach to control the environmental impacts of certain listed industrial activities. It involves determination by the Regulator of the appropriate controls for those industries to protect the environment, through a single permitting process. To gain a Permit, Operators have to demonstrate in their Applications, in a systematic way, that the they are using or are proposing to use, are the Best Available Techniques (BAT) for their installation, and meet certain other requirements, taking account of relevant local factors. The essence of BAT is that the selected to protect the environment should achieve an appropriate balance between environmental benefits and the costs incurred by Operators. However, whatever the costs involved, no installation may be permitted where its operation would cause significant pollution. IPPC operates under The Pollution Prevention and Control Regulations (for equivalent legislation in Scotland and N Ireland see Appendix 2). The three regional versions of the PPC Regulations implement in the UK the EC Directive on IPPC (96/61/EC). Further information on the application of IPPC/PPC, together with Government policy and advice on the interpretation of the English & Welsh Regulations, can be found in IPPC: A Practical Guide published by the Department for Environment, Food and Rural Affairs (Defra). Equivalent guidance on the Scottish Regulations is provided in PPC Regulations: A Practical Guide (Part A Activities), published by the Scottish Executive and SEPA. The Department of the Environment, Northern Ireland has published equivalent guidance on its Regulations. Installation based, NOT national emission limits Indicative BAT Standards The BAT approach of IPPC differs from regulatory approaches based on fixed national emission limits (except where General Binding Rules or Standard Permits are issued). The legal instrument that ultimately defines BAT is the Permit, and Permits can only be issued at the installation level. Indicative BAT standards are laid out in national guidance (such as this) and, where relevant, should be applied unless a different standard can be justified for a particular installation. BAT includes the technical components, process control, and management of the installation given in Section 2, and the benchmark levels for identified in Section 3. Departures from those benchmark levels can be justified at the installation level by taking into account the technical characteristics of the installation concerned, its geographical location and the local environmental conditions. If any mandatory EU emission limits or conditions are applicable, they must be met, but BAT may go further (see BAT and EQS below). Some industrial sectors for which national guidance is issued are narrow and tightly defined, whilst other sectors are wide and diffuse. This means that where the guidance covers a wide variety of processes, and individual are not described in detail, the (and their associated emission levels) which might constitute BAT for a particular operation, are more likely to differ, with justification, from the indicative BAT standards than would be the case for a narrow, tightly-defined sector. BAT and EQS The BAT approach complements, but differs fundamentally from, regulatory approaches based on Environmental Quality Standards (EQS). Essentially, BAT requires measures to be taken to prevent - and measures that simply reduce are acceptable only where prevention is not practicable. Thus, if it is economically and technically viable to reduce further, or prevent them altogether, then this should be done irrespective of whether or not EQSs are already being met. The BAT approach requires us not to consider the environment as a recipient of pollutants and waste, which can be filled up to a given level, but to do all that is practicable to minimise from industrial activities and their impact. The BAT approach first considers what emission prevention can reasonably be achieved (covered by Sections 2 and 3 of this Guidance) and then checks to ensure that Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 2

Introduction Techniques Understanding Understand- IPPC ing IPPC Making an application Installations covered Timescales Key Summary of releases Technical overview Economics the local environmental conditions are secure (see Section 4 on page 123 of this Guidance and also Guidance NoteIPPC Environmental Assessments for BAT). The BAT approach is therefore the more precautionary one because the release level achieved may be better than that simply required to meet an EQS. Conversely, if the application of indicative BAT might lead to a situation in which an EQS is still threatened, a more effective technique is required to be BAT for that installation. The Regulations allow for expenditure beyond indicative BAT where necessary, and, ultimately, an installation will only be permitted to operate if it does not cause significant pollution. Further advice on the relationship between BAT, EQSs and other related standards and obligations is given in IPPC: A Practical Guide, its Scottish equivalent, and also in Section 3. Assessing BAT at the sector level Assessing BAT at the installation level The assessment of indicative BAT takes place at a number of levels. At the European level, the European Commission a BAT reference document (BREF) for each main IPPC sector. It also horizontal BREFs for a number of general which are relevant across a series of industrial sectors. The BREFs are the result of an exchange of information between regulators, industry and other interested parties in Member States. Member States should take them into account when determining BAT, but they are allowed flexibility in their application. UK Sector Guidance Notes like this one take account of information contained in relevant BREFs and set out current indicative standards and expectations in the UK. At national level, that are considered to be BAT should represent an appropriate balance of costs and benefits for a typical, well-performing installation in the sector concerned. They should also be affordable without making the sector as a whole uncompetitive, either within Europe or world-wide. When assessing applicability of sectoral indicative BAT standards at the installation level, departures may be justified in either direction. Selection of the technique which is most appropriate may depend on local factors and, where the answer is not self-evident, an installation-specific assessment of the costs and benefits of the available options will be needed. The Regulator s guidance IPPC Environmental Assessments for BAT and its associated software tool may help with the assessment. Individual installation or company profitability (as opposed to profitability of the relevant sector as a whole) is not a factor to be considered, however. In the assessment of BAT at the installation level, the cost of improvements and the timing or phasing of that expenditure, are always factors to be taken into account. However, they should only be major or decisive factors in decisions about adopting indicative BAT where: the installation s technical characteristics or local environmental conditions can be shown to be so different from those assumed in the sectoral assessment of BAT described in this guidance, that the indicative BAT standards may not be appropriate; or the BAT cost/benefit balance of an improvement only becomes favourable when the relevant item of plant is due for renewal/renovation (eg. change to a different design of furnace when the existing furnace is due for a rebuild). In effect, these are cases where BAT for the sector can be expressed in terms of local investment cycles; or a number of expensive improvements are needed. In these cases, a phasing programme may be appropriate - as long as it is not so drawn out that it appears to be rewarding a poorly performing installation. In summary, departures by an individual installation from indicative BAT for its sector may be justified on the grounds of the technical characteristics of the installation concerned, its geographical location and the local environmental conditions - but not on the basis of individual company profitability, or if significant pollution would result. Further information on this can be found in IPPC: A Practical Guide and IPPC Part A(1) Installations: Guide for Applicants, or the equivalent Scottish Guidance. Innovation The Regulators encourage the development and introduction of innovative that advance indicative BAT standards criteria, ie. which have been developed on a scale which reasonably allows implementation in the relevant sector, which are technically and economically viable Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 3

Introduction Techniques Understanding Understand- IPPC ing IPPC Making an application Installations covered Timescales Key Summary of releases Technical overview Economics and which further reduce and their impact on the environment as a whole. One of the main aims of the PPC legislation is continuous improvement in the overall environmental performance of installations as a part of progressive sustainable development. This Sector Guidance Note describes the indicative BAT standards at the time of writing but Operators should keep up-to-date with improvements in technology - and this Guidance note cannot be cited as a reason for not introducing better available. The technical characteristics of a particular installation may also provide opportunities not foreseen in the Guidance, and as BAT is determined at the installation level (except in the case of General Binding Rules (GBRs)), it is a requirement to consider these even where they go beyond the indicative Standards. New installations Existing installations - standards Existing installations - upgrading timescales Indicative BAT standards apply, where relevant, to both new and existing installations, but it will be more difficult to justify departures in the case of new installations (or new activities in existing installations) - and for new activities, which meet or exceed indicative BAT requirements should normally be in place before operations start. For an existing installation, it may not be reasonable to expect compliance with indicative BAT standards immediately if the cost of doing so is disproportionate to the environmental benefit to be achieved. In such circumstances, operating that are not at the relevant indicative BAT standard may be acceptable, provided that they represent what is considered BAT for that installation and otherwise comply with the requirements of the Regulations. The determination of BAT for the installation will involve assessment of the technical characteristics of the installation and local environmental considerations, but where there is a significant difference between relevant indicative BAT and BAT for an installation, the Permit may require further improvements on a reasonably short timescale. Where there are departures from relevant indicative BAT standards, Operators of existing installations will be expected to have upgrading plans and timetables. Formal timescales for upgrading will be set as Improvement Conditions in the Permits. See Section 1.4.2 on page 7 for more details. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 4

Introduction Techniques Understanding IPPC Making Making an an application application Installations covered Timescales Key Summary of releases Technical overview Economics 1.2 Making an application A satisfactory Application is made by: addressing the in Sections 2 and 3 of this guidance; assessing the environmental impact described in Section 4 (and in England and Wales Environmental Assessment and Appraisal of BAT (IPPC H1)); demonstrating that the proposed are BAT for the installation. In practice, some Applicants have submitted far more information than was needed, yet without addressing the areas that are most important - and this has led to extensive requests for further information. In an attempt to focus application responses to the areas of concern to the Regulator, Application forms (templates) have been produced by the Environment Agency, by SEPA and by EHS in N Ireland. In addition, as the dates for application have approached, the operators in most industrial sectors in England and Wales have been provided with Compact Discs (CDs) which contain all relevant Application Forms, technical and administrative guidance, BREFs and Assessment tools, hyper-linked together for ease of use. For Applicants with existing IPC Authorisations or Licences, the previous applications may provide much of the information for the PPC application. However, where the submitted Application refers to information supplied with a previous application the Operator will need to send fresh copies - though for many where there is a tendency for frequent changes of detail (for example, information about the management systems), it will be more appropriate simply to refer to the information in the Application and keep available for inspection on site, up-to-date versions of the documents. For further advice see IPPC Part A(1) Installations: Guide for Applicants (for England and Wales) or PPC Part A Installations: Guide for Applicants (for Scotland) or the equivalent Northern Ireland guide for Applicants. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 5

Introduction Techniques Understanding IPPC Making an application Installations Installations covered covered Timescales Key Summary of releases Technical overview Economics 1.3 Installations covered This Guidance relates to installations containing the activities listed below, as described in Part A(1) of Schedule 1 to the The Pollution Prevention and Control Regulations. The schedules of listed activities are slightly different in Scotland and Northern Ireland so for their equivalent Regulations see Appendix 2 Section 6.8 (e) Treating and processing milk, the quantity of milk received being greater than 200 tonnes per day (average value on an annual basis). The installation includes the main activities as stated above and associated activities which have a technical connection with the main activities and which may have an effect on and pollution. They include, as appropriate: milk reception Pasteurisation Cheesemaking Butter Yogurt production Packing Cleaning Refrigeration the control and systems for to all media; the power plant The installation will also include associated activities which have a technical connection with the main activities and which may have an effect on and pollution, as well as the main activities described above. These may involve activities such as: the storage and of raw ; the storage and despatch of finished products, waste and other ; the control and systems for to all media; waste treatment or recycling. Environment Agency advice on the composition of English or Welsh installations and which on-site activities are to be included within it (or them) is given in its guidance document The Pollution Prevention and Control Regulations (SI 2000 No. 1973) (www.hmso.gov.uk).. Operators are advised to discuss the composition of their installations with the Regulator before preparing their Applications. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 6

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Timescales Key Summary of releases Technical overview Economics 1.4 Timescales 1.4.1 Permit review periods Permits are likely to be reviewed as follows: for individual activities not previously subject to regulation under IPC or Licensing, a review should be carried out within four years of the issue of the PPC Permit for individual activities previously subject to regulation under IPC or Licensing, a review should be carried out within six years of the issue of the IPPC Permit However, where discharges of Groundwater List I or List II substances have been permitted, or where there is of any matter that might lead to an indirect discharge of any Groundwater List I or II substance, a review must be carried out within four years as a requirement of the Groundwater Regulations. These periods will be kept under review and, if any of the above factors change significantly, they may be shortened or extended. 1.4.2 Upgrading timescales for existing plant Existing installation timescales Unless subject to specific conditions elsewhere in the Permit, upgrading timescales will be set in the Improvement Programme of the Permit, having regard to the criteria for improvements in the following two categories: 1 Standard good-practice requirements, such as, management systems, waste, water and energy audits, bunding, housekeeping measures to prevent fugitive or accidental, good waste facilities, and adequate monitoring equipment. Many of these require relatively modest capital expenditure and so, with studies aimed at improving environmental performance, they should be implemented as soon as possible and generally well within 3 years of issue of the Permit. 2 Larger, more capital-intensive improvements, such as major changes to reaction systems or the installation of significant equipment. Ideally these improvements should also be completed within 3 years of Permit issue, particularly where there is considerable divergence from relevant indicative BAT standards, but where justified in objective terms, longer time-scales may be allowed by the Regulator. Local environmental impacts may require action to be taken more quickly than the indicative timescales above, and requirements still outstanding from any upgrading programme in a previous permit should be completed to the original time-scale or sooner. On the other hand, where an activity already operates to a standard that is close to an indicative requirement a more extended time-scale may be acceptable. Unless there are statutory deadlines for compliance with national or international requirements, the requirement by the Regulator for capital expenditure on improvements and the rate at which those improvements have to be made, should be proportionate to the divergence of the installation from indicative standards and to the environmental benefits that will be gained. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 7

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Timescales Key Summary of releases Technical overview Economics The Operator should include in the Application a proposed programme in which all identified improvements (and rectification of clear deficiencies) are undertaken at the earliest practicable opportunities. The Regulator will assess BAT for the installation and the improvements that need to be made, compare them with the Operator s proposals, and then set appropriate Improvement Conditions in the Permit All improvements should be carried out at the earliest opportunity and to a programme approved by the Regulator. Any longer timescales will need to be justified by the Operator. Table 1.1: Specific timescale improvements Improvement By whichever is the later of: minimisation audit in accordance with Section 2.4.2 on page 74 A review of water use (water efficiency audit) in accordance with Section 2.4.3 on page 77 Activities under Section 6.8di (see Section 1.3) Animal raw 31 August 2005 or one year from the issue of the Permit 31 August 2005 or one year from the issue of the Permit Activities under Section 6.8dii and 6.8e (see Section 1.3) Vegetable raw and milk 31 March 2006 or one year from the issue of the Permit 31 March 2006 or one year from the issue of the Permit The Applicant should include a proposed timetable covering all improvements. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 8

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Key Summary of releases Technical overview Economics 1.5 Key An assessment of the indicates that there are no areas where there is a fundamental clash between good environmental practice and good business practice. However the implementation of pollution prevention and control measures represents a balance between environmental protection and costs incurred by the operators and will not always result in cost savings for the operator. minimisation Commercial considerations mean that the controls of parameters such as process yield and product wastage are usually understood. These parameters are also key pollution prevention as product loss accounts for a significant proportion of the sectors environmental impact. Water use The sector is a significant water consumer, the vast majority of which is used for cleaning, both manually and in CIP (cleaning in place) systems, which are widely used throughout the industry. In addition to minimising the use of a raw material, measures to optimise water use will be important pollution prevention measures relating to effluent management. There are a number of opportunities to either reuse water (for example low-grade wash waters) or to recycle water from for example membrane systems (also see Hygiene and Food Safety). Releases associated with energy use The industry is a major energy user. There remain significant opportunities for reduction of caused by energy use and choice of energy source (CO2, SOx, NOx, etc. contributing in particular to global warming and acidification). The dairy industry has entered into a Climate Change Levy Agreement with the Government, dated the 6th March 2001. The applicability of and standards for IPPC is explained in Section 2.6. Emissions to air It is an inherent factor within the food, drink and dairy industries that of VOC and odour arise, for example from drying and other processes, including effluent treatment. Emissions of dust and particulate material can also be a factor from milk powder drying and the transfer of. Odour can be problematic, not only because of the sometimes subjective nature of the problem, but as tend to be fugitive. Other fugitive considerations include those potentially arising from refrigeration, cooling and effluent treatment systems. Effluent management The composition of the effluent within the dairy industry is very highly variable, dependant on the activity, working patterns, product wastage and cleaning systems. Of these the most important is keeping raw, intermediates, product and by product out of the wastewaters, by controlling product wastage and cleaning processes. Accident risk All types of milk, cream and most other dairy products have a very high oxygen demand and spills and leaks into the water environment are serious events. In addition to normal spills and process leaks, they typically arise from for example, overfilling of vessels and failure of containment, wrong drainage connections and blocked drains. Hygiene and food safety Health and safety and product quality apply to industry as a whole, but hygiene and food safety is of fundamental importance to the dairy sector. Consequently particular attention must be given to these considerations when specifying particular, especially in relation to pollution prevention Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 9

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Key Summary of releases Technical overview Economics measures, in for example measures relating to water use, cleaning and reuse and recycling of water. Industry experience of managing risk in relation to hygiene and food safety is a sound basis for environmental management. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 10

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Summary Summary of of releases releases Technical overview Economics 1.6 Summary of releases SOURCE RELEASES Storage and of raw Cutting and Mixing and blending (powders and Mixing, blending and homogenisation (solid/liquid) Oxides of sulphur - - - - - - - - - A - Oxides of nitrogen & carbon - - - - - - - - - - - Particulate/TSS AW W AW W W AW AW AW - A W COD/BOD W W - W W W W W - - W Odour A AW W A AW A A A - A A Biocides - W - - - - W - - - W Dispersants & surfactants - - - - - - W - - - - Phosphates & nitrates - - - - - W - - - - Refrigerants - - - - - - - AW W W Pasteurisation and sterilisation Drying and evaporation Cleaning and sanitisation Storage and dispatch of finished Cooling and refrigeration Boiler and Combustion plant Effluent plant (Note 1) Ammonia, HCFC, Glycol Sludges - - - - - - - - L KEY A Release to Air, W Release to Water, L Release to Land Note: 1. Most of the other releases to water pass through the effluent treatment plant (ETP). Included here are only those which arise as a direct result of the operation of the ETP. 2. Releases to air usually result in a subsequent, indirect emission to land and can therefore affect human health, soil and terrestrial ecosystems. 3. Releases identified above to water can all also appear in the effluent treatment sludge (see Section 2.5 on page 82). Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 11

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Summary of releases Technical Technical overview overview Economics 1.7 Technical overview Figure 1.1: Overview of the activities within the milk processing sector Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 12

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Summary of releases Technical overview Economics Economics 1.8 Economics The food and drink industry is an important part of the manufacturing industry in the UK. It is the largest industrial sector in turnover terms: with a market value in excess of 90 billion.. It is a large and diverse sector and accounts for about 9% of manufacturing output and a commensurate fraction of the jobs available in UK manufacturing. Table 1-1 shows a breakdown of the main activities by SIC code and it is clear that a wide range of activities is represented. Almost half of the milk sold to first-hand buyers under wholesale contract is used to supply the liquid market, with the remainder being processed into a widening range of milk products. Much of the this manufactured product is sold to consumers (e.g. as cream, butter or cheese) but large quantities are also used by food manufacturers as ingredients in the production of a vast range of foods. At one time, much of the by-product (such as skim milk and whey) was of minimal value and was fed to livestock, particularly at times of seasonal surplus. However, such end-uses have diminished as the industry has sought to extract the maximum value from each litre of milk produced and as quotas have sharply reduced milk output. As a result, the vast majority of milk leaving the farm is now destined for human consumption. However, as the table below suggests, there is a mix in size of the dairy companies within England and Wales, with around 38% of them processing in excess of 30 million litres/year, although many more smaller companies processing up to 30 million litres/year. Size Band No. of Companies Percent of Total (million litres/year) processing milk 1 and under 15 13.3% Between 1 and 10 35 31.0% Between 10 and 30 19 16.8% Between 30 and 100 23 20.4% Over 100 21 18.6% TOTAL 113 100% The dairy industry is extremely complex and can be characterised as follows: there are a wide range of unit operations some of the unit operations such as pasteurisation, are not well known outside of the immediate industry the consumer market is becoming more sophisticated and demanding there is a continual need for process innovation plant and equipment needs to be flexible to respond to changes in demand quality of production is paramount (and is matched only by pharmaceutical standards) These factors contribute to making the plant and equipment of dairy food production increasingly complex. Associated equipment needs to be equally flexible and adaptable. There is a potential reluctance to invest in large capital plant when it may be made redundant by a change in the production process, however, changes in the process are opportunities for environmental investment. The food and dairy market-place is characterised by: Short time-to-market and competitiveness, where the time between product conception and delivering the product to the market-place is continually reducing; against a background of increasing competitiveness and reduced margins, the emphasis during product development is on the production process itself. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 13

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Summary of releases Technical overview Economics Economics Product innovation with more and more product variations available now to the consumer; this implies that existing products face stiffer competition and product lifetimes become shorter, with the result that manufacturing processes and production lines require change more frequently. Product complexity with the introduction of new flavours, mixtures and combinations of products, pre-prepared products, new packaging, etc.. The production runs also become shorter as tastes change more frequently. are generally natural and are therefore more variable than other sectors. All of these factors contribute to the dynamic and complex nature of dairy food production. While this can imply the potential for more frequent upgrade of processing equipment, it has the drawback of providing a degree of instability. With the end of the end of the Milk Marketing schemes in 1994, the milk market in the UK was opened up for greater competition, both for producers selling their milk and for the processors buying the milk. However, the price ex. farm has dropped significantly over the past few years, as the table below shows: YEAR UK Farm Gate Prices, pence per litre (including bonus payments) 1995 24.94 1996 25.02 1997 22.12 1998 19.37 1999 18.35 2000(1) 16.89 N.B.: Data from Dairy Facts and Figures see Ref. 8. 2000 data based on January to November only This highlights the drop in revenues experienced by the farmers, which has also resulted in a drop in milk prices at the supermarkets. The current (December 2001) cost of a 4-pint polybottle (2.27 Litres) is 93pence, which equates to a cost of c. 40 pence per litre to the consumer. This means that the simple milk processing companies, those who take farm milk for liquid consumption in either polybottles for the supermarkets or glass for the declining doorstep delivery market operate at low margins. This requires them to be very efficient in all manner of production, not least in wastage of raw. The most successful companies are therefore the most efficient. Considering the manufacturing companies, there is more scope for adding value to their products and hence profit margins are greater. 1.8.1 Sector costs Costs, both capital and revenue, for effluent treatment at dairy plants are site specific, and can vary markedly depending on effluent volumes and loadings, as well as ancillary items such as: Landscaping, fencing or planting requirements Access roadways Ground conditions (e.g., piling requirements) However, in order to provide some specific information, some example projects and costs are provided below. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 14

Introduction Techniques Understanding IPPC Making an application Installations covered Timescales Key Summary of releases Technical overview Economics Economics Project Total Cost at 2001 prices Crude Effluent Final Effluent Plant Outline Volume m3/day Loading kgcod/ d A 660,000 300 1,000 40:60 Primary screening, 4,800m 3 HDPE-lined lagoon, 8.5m diameter settlement tank B 2.8 million 1,230 5,240 20:30:5 Anoxic tank, 13,000m 3 N.B.: Costs assume 2001 base, with inflationary increases of 5%pa. In all cases, it is recommended that competent professional assistance is sought to provide a detailed design specification, against which prospective contractors can quote. This provides for competitive quotations on a like-for-like basis. For revenue costs, again the actual costs will be site specific but as a guideline, the following figures provide a reference: Conventional Activated sludge = 16pence/kgCOD treated Conventional filtration plants = 12pence/kgCOD treated MBR activated sludge = 19pence/kgCOD treated These costs are based on electricity and sludge only. concrete tank, 15m diam settlement tank and sand filters C 1.0 million 1,800 6,720 25:25 Retrofit to existing plant, including 3,000m 3 aeration tank, 1,000m 3 balance tank, 2 settlement tanks D 200,000 500 2,000 25:40:25 Retrofit to remove old technology filter plant, replace with activated sludge E 160,000 1,000 N/A N/A Pump sump and fat trap, 300m 3 balance and 50m 3 divert tank and control equipment As a comparison, the average cost of discharging dairy effluent to sewer for treatment at a local sewage works by the Water Service plc will be 56 pence/kgcod, assuming 3,000 mg/l COD and 800 mg/l TSS. This is based on the standard Trade Effluent Charging tariffs and does not include the Scottish water companies. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 15

Economics The main activities and Abatement of point source Energy Accidents Noise Monitoring Closure Installation 2 Techniques for pollution control BAT Boxes to help in preparing applications To assist Operators and the Regulator s officers in respectively making and determining applications for PPC Permits, this section summarises the indicative BAT requirements (i.e. what is considered to represent BAT for a reasonably efficiently operating installation in the sector). The indicative BAT requirements may not always be absolutely relevant or applicable to an individual installation, when taking into account site-specific factors, but will always provide a benchmark against which individual Applications can be assessed. Summarised indicative BAT requirements are shown in the BAT boxes, the heading of each BAT box indicating which BAT are being addressed. In addition, the sections immediately prior to the BAT boxes cover the background and detail on which those summary requirements have been based. Together these reflect the requirements for information laid out in the Regulations, so raised in the BAT box or in the introductory section ahead of the BAT box both need to be addressed in any assessment of BAT. Although referred to as indicative BAT requirements, they also cover the other requirements of the PPC Regulations and those of other Regulations such as the Licensing Regulations (see Appendix 2 for equivalent legislation in Scotland and Northern Ireland) and the Groundwater Regulations, insofar as they are relevant to PPC permitting. For further information on the status of indicative BAT requirements, see Section 1.1 on page 2 of this guidance or Guidance for applicants. It is intended that all of the requirements identified in the BAT sections, both the explicit ones in the BAT boxes and the less explicit ones in the descriptive sections, should be considered and addressed by the Operator in the Application. Where particular indicative standards are not relevant to the installation in question, a brief explanation should be given and alternative proposals provided. Where the required information is not available, the reason should be discussed with the Regulator before the Application is finalised. Where information is missing from the Application, the Regulator may, by formal notice, require its provision before the Application is determined. When making an Application, the Operator should address the indicative BAT requirements in this Guidance Note, but also use the Note to provide evidence that the following basic principles of PPC have been addressed: The possibility of preventing the release of harmful substances by changing or processes (see Section 2.1 on page 17), preventing releases of water altogether (see Section 2.2.2 on page 46), and preventing waste by reuse or recovery, have all been considered, and Where prevention is not practicable, that that may cause harm have been reduced and no significant pollution will result. This approach should assist Applicants to meet the requirements of the Regulations to describe in the Applications and measures to prevent and reduce waste arisings and of substances and heat - including during periods of start-up or shut-down, momentary stoppage, leakage or malfunction. Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 16

The The main main activities activities and and Abatement of point source Energy Accidents Noise Monitoring Closure Installation 2.1 The main activities and (includes directly associated activities in accordance with the PPC Regulations) Indicative BAT requirements: 1 See each subsection of this section 2.1. 2.1.1 In-process controls Improved process control inputs, conditions,, storage and effluent generation will minimise waste by reducing off-specification product, spoilage, loss to drain (for example, fitting a level switch, float valve, or flow meter will eliminate waste from overflows), overfilling of vessels, water use and other losses. Product loss or wastage is a significant benchmark for the dairy industry and is a useful guideline for an operator to assess the performance of the installation against industry standards. In assessing the wastage efficiency of milk processing sites, two co-efficients are used to measure milk loss and water usage: %COD (or milk) loss to effluent (measured as COD) Effluent:Milk Intake Ratio (or Water:Milk Intake Ratio) These have been used for many years, and have proven themselves much more accurate than trying to assess %milk loss using yield calculations or mass balances, which are used by the majority of the dairy companies in the UK. Mass balance or yield figures often give negative variances (milk is gained instead of lost which is clearly impossible), whereas this never occurs when actually measuring the loss to effluent using %COD loss. To calculate the %COD loss to effluent, the procedure is to use effluent loadings and compare this against the milk intake, converted to kgcod, as follows: Effluent Load, kgcod %COD loss = x 100 Milk Intake, as kgcod To do this we usually consider the COD equivalent of milk as 220 kgcod/m 3, or 220,000 mg/l, although this can vary depending on butterfat content, SNF ratios, etc. As an example, consider a site with a the following conditions: Milk intake:650,000 lpd Effluent volume:1,200 m 3 /day Guidance for the Dairy and Milk Processing Sector IPPC S6.13 Issue 1 Modified on 26 October, 2003 17