glanbia INGREDIENTS
Ireland I Tracey Berney Administration Omcer Office of Climate, Licensing & Resource Use P.O. Box 3000 Johnstown Castle Estate Co. Wexford
12th March, 2008
Dear Ms. Berney,
Further to your letter of 15th January 2008 please find below information requested by the Agency to pr-s our request for technid amendment to license register no. P0359/02.
1.
2.
Attached please find updated Air Dispersion Model Assessment Report from Envimon which assesses the impact of dust emissions from the plant for 2008 and 2009 production season. Abatement equipment will be fitted on all the stacks by 2009. Attached also are results from the Ambient PMlO monitor which was installed in 2007. The results show that the national air quality standards are k i n g complied with. The average PMlO concentration from September to January was 13.7pg/m3.
Request for Amendment of Condition 4. Glanbia request that CondItIon 4.2.2 of Licence PO359-02 be modified to give the correct oxygen reference level relevant for exhaust gases from a CHP plant of 15% O2 as follows: - Temperature 273K Pressure 103.1 kPa, dry gas; 3% oxygen fur kqud and gas fuels; 15% mygen for CHP pknt
Results obtained from manual emission monitoring carried out bi-annually (Quarter 2 and 4 periods) during 2007 using portable combustion analysers give results for NO, expressed as NO1 at the mndard reference condition of 15%:-
CHP 1 ( Al-1) = 120 mg/Nm3 (Q2) and 138 mg/Nm3 (Q4) for Dv/ 15% 02
CHP 2 ( AI-2) = 133 mg/Nm3 (Q2) and 139 mg/Nm3 (44) for Dry/ 15% O2
A) To convert equivalent emission concentration at the reference condition of 3% O2 currently specified in Condition 4.2.2., a factor to account for the difference in the 2 reference conditions ie 3%: 15% is applied a5 follows:-
eg. 120 mg/Nm3 x ( 20.9-3)/(20.9-15) = 120 x (17.9/5.9) = 120 x 3.03 = 364 mg/Nm’
[ factor = ( 20.9- Ref %)/(20.9-Current%) ]
Registered OHcw
Glenbia House. klkenny, Ireland. Registered in Ireland Numbsr 4 W 4 R
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CHPl (Al-I) = 364 mg/Nm3 (42) and 419 mg/Nm3 ( 44) for Dry/30/o02
CHP2 (Al-2) = 403 mg/Nm3 (Q2) and 421 rng/Nrn3 ( Q4) for Dw/3%02
The calculated NQ ( as N01) emission concentmtions are much higher (by a factor of about 3) compared to those calculated for the correct reference condition relevant to CHP combustion of 15% Oz.
B) To convert to actual discharge emission concentrations, ie. wet and at the measured oxygen concentration the calculations are as follows:-
Step I: measured %02 (dv) = 12.9%, for Al-1 stack (Q2)
Step 2: convert %02 dry to % 0, wet (Assume 7% molsture for natural gas combustion) = 12.9 x [moisture correction factor] = 12.9 x [100-7/l(lOO] = 12.9 x 0.93 = 12%
Step 3: convert NO, concentration of 120 mg/Nm3 at 15940 02 to 12% 01 wet discharge conditions :-
NO, = 120 mg/Nm3 (drj/l5%O2)
NO, = 120 x [oxygen correction factor] x [moisture content correction factor]
NO, = 120 x [(20.9-12)/(20.9-15)] x [loo-7/100] = 120 x [8.9/5.9] x r0.931 = 168 ma/Nm3
For CHP 1 (Al-1)
Q2 = 120 mg/Nm3 (drj115%02) = 168 mdNm3 (wetldischarge conditions) [measured dry 02 = 12.9%/ 74bmoistureI
44 = 138 rng/Nm3 (dry/l5%01) = W malNm (wevdischarge conditions) [measured dry O2 = 16.2%, 7%moisture]
For CHP 2 (Al-2)
Q2 = 133 mg/Nm3 (dry/lS% 02) = 185 ma/Nm3 (wevdischarge conditions) [measured dry Oz = 13.0%, 7%molsture]
Q4 = 139 rng/Nrn3 (diy/15%02) = 177 mg/Nm3 (wet/discharge conditions) [measured dry 02 = 13.8%,7%moisture]
The ELV specified in Schedule B of Licence PO359-02 relating to NO, (as NO2) for Al-1 and A1-2 is 200 mg/Nm3 . The reference condition for these ELV‘s should be Drjll5% O2 and not as currently given in Condition 4.2.2. The revision of this Condition will then conform with the referem conditions specified in other IPPC Licences issued for CHP plant in Inland such as PO404-02 and PO35-04.
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3. It is proposed to transfer spa^ vdumetric capcity from SW2 to M I .
SW1 has been used to discharge condensate from the p d u c t evaporators. However, -use of compliance issues with ammonia in condensate at SW2 it was decided to utilise the spare capacity in the Wwrp to treat condensate and remove it from SW2 outlet during 2007.
The spare capacity at SW1 was built into the previous license review of 2005 to accommodate future growth in milk supply and production changes which will give rise to additional waste water volumes. SW2 compliance has improved dramatically in 2007 as a result of transferring the condensate to the Wwrp without any negative effects on the WWTP. However, volumes from the WWrP at SW1 have been exceeded on two occasions in 2007. To accommodate this and future waste water volumes from mllk supply increases it is proposed to tmnsfer 1500m3 of the SW2 license volume to SW1. Milk supply is expected to increase at a rate of 3% per year. It ts proposed to keep the ovemll ma55 emissions for all parameters a5 per the misting licensed discharge, reconfigured as per the table below.
Existing Schedule B.2
Emission Point Ref. No. Name of Receiving Waters: tocation: Sampling Chamber Volume to be emitted - Mamum in any one day - Mamum rate per hour
SWI (histing) River Nom
12000rns 500m3
SWl Pammeber
Temperatm
Toxicity PH
BOD COD Suspended Solids Nitrate (as N) Ammonia (as N) Total Phosphorous (as P> Ortho-Phosphate (as P)
Oils, Fats & Grease Sulphate (as So,) Detergentr (as MBAS) Chloride (as Cl) Residual Chlorine
Emisdon UmltValue
2PC 6-9 1
mg/l 10 80 15 10
1.75 0.8 1.1 10 500 0.2 1000 0.02
U kalday
120 960 180 120 21
10.5 6.6
120 6000 2.4 6000 0.24
Emlssion Polnt Ref. No. Name of Receiving Wakrs: mt ion : Sampling Chamber Volume to be emitted - Maximum in any one day - Maxdmum rate PY hour
SW 2 (Existing) Rlver Nore
3500m3 145m3
sw2 Emission
Limit Value Temperature
Toxi . 1 TU kg/day
35 BOD COD Suspended Solids Nitrate (as N) Ammonia (as N) Total Phosphorous (as P)
Ortho-Phosphate (as P> Oils, Fats & Grease Sulphate (a5 W) Detergents (as MBAS) Chloride (as Ct> Residual Chlorine
mg/l 10 50 30 10 0.8 0.5 0.2 10 100 0.2 900 0.02
175 105 35
2.8 1.75 0.7 35 350 0.7
3150 0.07
TOTAL FLOW
15,500rn3
TOTAL MASS
Kgs/day 155
1135 285 155 23.8 12.25 7.3 155 6350 3.1
9150 0.31
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mg/l 10
76.7 16.67 10
1.64 1.75 1.1 10
455.56 0.2 1000 0.02
kg/day 135 1035 225 135 22.2 11.25 6.9 135 6150 2.7 6000 0.2
Proposed Schedule
Emission Point Ref. No. Name of Receiving Waters: Location: Sampling Chamber Volume to be emltted - Maximum in any one day - Maximum rate per hour
SWI (histing) River Nore
13500m3 562.5m3
S W l
Emission Point W. No. Name of Receiving Waters: Lcat jon : Sampling Chamber Volume to be emltted - Maximum in any one day - Maximum rate pw hour
SW 2 (Existing) River Nore
2000m3 145m3
sw2
TOTAL FLOW 15,500
m3
Parameter TOTAL MASS
EmiaEson Limit Value 2PC 6-9
Emission Limit Value
28T 6-9
Temperature PH Toxicjty
Temperature PH Toxicity 1
me/l 10 50 30 10 0.8 0.5 0.2 10 100 0.2
1575 0.02
U kg/day
20 100 60 20 1.6 1.0 0.4 20 200 0.4 3150 0.04
kg6I-Y 155 1135 285 155 23.8 12.25 7.3 155
6350 3.1
9150 0.31
BOD COD Suspended Solids Nibate (as M) Ammonia (as N) Total Phosphorous (as P) Ortho-Phosphate (as P) Oils, Fats & Grease Sulphate (as So,) ktergents (as MBAS) Chloride {as Cl) Residual Chlorine
BOD COD Suspended *lids Nitrate (as N) Ammonia (as N) Tom1 Phosphornus (as P) Ortho-Phosphate (as P) Oils, Fats & Grease Sulphate (as W,) Detergents (a5 MEAS) Chloride (as Ct) Residual Chlorine
The table below shows the 2007 performane for 2007 for both SW1 and SW2. Average median and max values are shown for both circumstanE and mass emissions for at1 parameters.
S W l MASS EMISSIONS 2007
Parameba* Average Average 2007 Emission Umlt Value
12,000mS 27T 6-9
Median Max
Flow Temperature PH Toxicity
8497m3 9349m3 120681~13
7.53 7.5 8.25 1
mg/l 10
76.7 16.67
10 1.64 1.75 1.1
10 455.56
0.2 io00 0.02
U J!!li&X
135 1035 225 135 22.2 11.25 6.9 135 6150 2.7
6000 0.2
mg/l 3.59
mp/l 3.30
mg/l 9.52
kg f day 31 171 40 20
ks/day 29 161 2s 14 0 6 5
kq/day 105 530 160 93 15 10 7
0 2799
0 2216 0
Boo COD Suspended Solids Nitrate (as N)
19.39 4.51 2.53 0.14 0.63 0.45
0 151.25 0
149.83 0.01
19.00 3.00 1.07 0.06 0.65 0.48
0 142.5 0
157.5 0.01
45.00 15.00 10.00 1.69 1.62 1 .o 0 170 0
225 0.02
Ammonla (as N) Total Phosphorous (as P) Ortho-Phosphate (as P>
1 5 4
Oils, Fats & Grease Sulphate {as So,) Detergents (a5 MBAS) Chloride (as Cl) Residual Chlorine
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2007 MASS EMISSIONS sw2 Pammeter Average Medlan 4 2007 Emission
Urn& Value 3500rn 3
28OC 6-9
Average
7.28
mg/l 4.11 32.8 16.69 2.61 0.38 0.13 0.06
0 36.25
0 9442.08 0
Max
1225m3 Flow Temperature PH Toxicity
BOD COD Suspended Solids Nibate (as N) Ammonia (as N) Total Phosphornus (as P) Ortho-Phosphate (as P) Oils, Fats & Grease Sulphate (as 50,) Detergentr (a5 MBAS) Chloride (as Ct) Residual Chlorine
7.28 I 8.13 1
mg/l IO 50 30 10 0.8 0.5 0.2 10 100 0.2 900 0.02
U ka/dav
35 175 105 35 2.8 1.75 0.7 35 350 0.7
3150 0.07
&/day kq/ dny 1.88 1.58 15.0 13.86 7.62 6.41 1.3 0.91 0.18 0.13 0.05 0.03 0.02 0.01
kqlday 7.25
34.0 18.0 2.6 0.35 0.08 0.02
0 34.5
0 878 0
50.0 29.5 7.3 0.8 0.65 0.4 0
63.0 0
1400 0.02
60.03 27.69 6.45 0.75 0.51 0.18
0 28.16
0
870.9 0.01
The period from May to September is also presented separately as this represents the peak period for discharge from SW1 and SWZ.
May to September
S W l May to September 2007 MASS EMISSIONS 2007Ernis&n 1 Parameter Median Max Median
10774m
AW2-e
10772m3
Max
1 2 0 ~ ~ 1 3
Average
Flow Temperature PH Toxlcity
27OC 6-9 7.68 7.72 8.25 1
mg/l 10 80 15 10
1.75 0.8 1.1 10
500 0.2 1000 0.02
L kdday
120 960 180 120 21
10.5 6.6 120
6000 2.4 6000 0.24
mg/l 9.52
45.00 15.00 7.00 1.42 1.03 0.65
0 270 0 176 0.02
kslday 38.43 214.96 46.67 14.05 1.9 6.38 4.56
0 56.82
0 49.8 0.01
ks /day 35.99 200.36 35.8 10.53 0.79 6.68 5.03
0
kalday 105.03 530.42 159.98 174.66 14.92 10.36 6.6
0 2798.55
0 2216.35 0.21
ma/l 3.57 19.92 4.31 1.3
0.18 0.59 0.42 0
162 0
141 0.01
J E Q L 3.32 19.00
3.25 1.00 0.07 0.62 0.47 0
165 0
140 0.01
BOD COD Suspended Solids Nitrate (as N) Ammonia (as N) Total Phosphorous (as P) Ortho-Phosphate (a5 P) OIls, Fats & Grease Sulphate (as 5q) Detergents (as MBAS) Chloride (as Cl> Residual Chlorine
0
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Flow Temperature PH Toxicity
15.11 7.32
mS/l 4.21 32.97 18.2 1.73 0.42 0.16 0.07 0
44.8
943 0.01
BOD COD Suspended Solids Nitrate (as N) Ammonia (as N) Total Phosphorous (a5 P) Ortho-Phwphate (as P)
15.3 7.37
mg/l 4.2 35.0 19.0 1.7
0.42 0.12 0.05
0
49.0
934 0.01
Oils, Fats & Grease Sulphate (as !h4) Detergents (as MBAS) Chloride (as Ct) Residual Chlorine
sw2 2007 Emission
UmR Value
28% 6-9 1TU
mg/l kglday 10 35 SO 175 30 105 10 35
0.5 1.75 0.2 0.7 10 35 100 350 0.2 0.7 900 3150 0.02 0.07
0.8 2.8
May to September 2007
Avemge I Median
19.1 7.7
x 7.5
50.0 29.0 7.44 0.8 0.65 0.4 0
63.0
1050 0.02
MASS EMISSIONS
Average
467m3
kg/day 1.93 15.28 8.45 0.83 0.2 0.03 0.07
0 0.59
12.77 0
Median
434m 3
kg/day 1.79 13.88 7.79 0.72 0.17 0.02 0.06 0 0
0 0
Proposed Change SW2 Flow has been reduced to 1500m3/day.
The max rate per hour remains at 145rn3/hr and this is to accommodate Intermittent peak flows when filter beds are backwashing.
Temperature and concentration limits on all other parameters with the exception of chloride remain the same with resultant reductions in daily mass emission values. The chloride concentration has been increased to 1,575mg/l to keep the daily mass emission from SW2 at 3,150 kgs.
Max
1204m3
A9k&F!Y 4.89 37.95 27.89 3.13 0.63 0.17 0.31
0 28.16
476.85 0.01
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sw1 Flow rate has been increased to 13,50Dm3/day. Max rate per hour is 562.5
There is no change in temperature.
The reduction in mass emissions on all parameters on SW2 with the acception of chloride, transferred to SW1. This results in slight changes in concentration values as follows at SW1:
BOD COD Suspended Solids Nitrate Ammonia Total Phosphorous
Ortho Phosphorous Oil, Fats & Grease Sulphate Detergent as Mbas Chloride
Residual Chlorine
No change Reduced from 80 to 76.67 mg/l Increased from 15 to 16.67 mg/l No change Reduced from 1.75 to 1.64 mg/l Not to exceed 11.25 kgs/day subject to max conc. of 1.75mg/I No to exceed 6.9 kgslday subject to a max conc. of 1.1 mg/l No change. Reduced from 500mg/l to 455.56mg/l No change No change - Not to exceed 6,000kgs/day subject tot a rnax 1,00Omg/l No change in concentration
The above proposed schedules result in no change to the licensed mass emissions from the site. The impact of these ma55 emissions on the receiving waters have been assessed as part of the license review application (Appendix 1.2.1 Biological Water Quality Assessment 2005 and 2004 - Pascal Sweeney) submitted to the Agency in August 2005.
If you require arty further information please do not hesitate to contact me.
Yours sincerely,
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ENVIROCON LTD. OLD ROAD KILCARN BRlDG E NAVAN, CO. MEATH fel: (046) 9074135 Fax: 4046) 9074055 e-ma it: [email protected]
ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON
AIR QUALITY IMPACT OF
FROM DAIRY PRODUCTION PLANT (IPPC TECHNICAL AMENDMENT)
GLAN8lA INGREDIENTS BALLYRAGGET, CO. KILKENNY
PARTICULATE EMISSIONS (PMia)
I I * Y - - I
- - - - - - - - - ENVIROCON ENVIROCON ENViROCOH ENWROCON ENVIROCON ENVIROCON ENVIROCON
AIR POLLUTION AND
ENVIRONMENTAL CONSULTANCY
ENVIROCON ENWROCON ENVIROCON ENVlROCON ENVIROCON ENVIROCOPI ENVIROCON ENVIROCON ENVIROCON ENVIRQCQN ENVIROCON
Date: 10 MARCH 2008 Report By: Michael L. Bailey
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1.0 INTRODUCTION
Glanbia (Ballyragget) Ltd. is requesting a Technical Amendment to the IF’PC Licence ( Reg No PO359-02) issued on 26 July 2006. The €PA requested on 15 January 2008, that the following information should be provided in relation to changes in emissions of particulates from the process vents at the Ballyragget facility.
“Provide an updated air dispersion modelling assessment repout CO demonstrate the impact of the requwtedultwuhns b p r u c w erniwions on local air qualify. n e assessment shall show how the requirements of the Air Quality Sbndards Regulations 2002 (SI No 271 of 2#02) are being mer, and shall be supporied by ambient air monitoring re~ul~v. Information UT xuhrnitied in ihhe uppliculinon for IPPC Licence Reg No PO3S9-02 should be updated CIS required to ensure that all current operations on site are udequureiy addressed”
This technical amendment provides for 2 operational emission scenarios. The first is for an increase in the exhaust airflow, from the current limit of 10,000 N m 3 h to 15,000 Nm3/hr, for the Casein Atbition Drier ( U - 9 ) in 2008. The second emission scenario is for the instailation of a filter bag-house to control particulate emissions from Niro 2 (A2-3) and the Fluidised bed exhaust vent (A2-12) in 2009 and the combined flows to be exhausted via the existing A2-3 vent.
An air quality dispersion modelling study was undertaken to evaluate the predicted impact of the PMlo emissions (particles with a mean aerodynamic diameter of less than 10 m) arising from these proposed modification in particulate emissions. The predxted concentrations downwind of the facility boundary were compared with the National Air Quality Standard limit values specified in the Air Quality Standards Regulations 2002 (SI: No 271 of 2002).
2.0 EMISSION SOURCES
Emission data for the process exhaust stacks of the Niro driers and secondary particulate emission vents were supplied by the company. The exhaust gas volume flows and exit velocities from the stacks are based on maximum load. The fraction nf the particulates emitted from each process vent assumed to be PMIu material is bwcd on manual sampling programmes undertaken by Teagasc Dairy Products Research Centre.
The emission parameters for each of the process exhaust vents are gven in Table 1 for the 2008 and 2009 scenarios. The emission rates from each vent are based on the emission limit value and the exhaust volume flow rates specified in the Schedule Bl.2 of the IPPC Licence.
EIUVIROMN LTD., CiLANBIA IPC LICENCE 7TCHNtCAL AMENDMENT- PMlo -03mR
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3.0 MODEL REQUIREMENTS
3.1 Introduction
The ADMS4 (Atmospheric Dispemion Modelling System Version 4.0, June 2007) air quality dispersion mode1 was used to predict ground level concentrations within 1.5 km of the boundmy of the facility. This model has been developed by CERC (Cambridge Environmental Research Consultants) and is the fatest version of the ADMS modelling software u d in the impact modelling reports submitted in 2005 as part of the IPPC Licence Review [Envirocon 09108105- Air Quality Impact of Particulate Emisions (PMlo) from Dairy hduct ion Plant (TPC Licence Review)]
3 3 Model input requirements
33.1 Emission source chrrncteristicr
Data relating to the stack laeight, stack &meter, exit velocity and temperature and particulate emission rates (PMlo) were calculated for the vents of the 3 Niro driers (A2-1, A2-3 and A M ) and other casein and lactose pmms exhaust vents for the planned 2008 and 2009 emission scenarios. Maximum continuous emissions from dl the process emission vents were assumed in this modelling study.
3.2.2 Building wake effecta
The effect of buildings on the dispersion of emission plumes from nearby stacks can have a significant effect on predicted downwind ground LveI concentrations, under cerrain weather conditions. The presence of a building creates turbulence around the structure, which can result in the emission plume being caught in this m a of turbulence. This zone consists of a recirculating flow region or cavity near the building with a diminishing turbulent wake further downwind. The plume is entrained in the cavity region, bringing it down to ground level, which results in a significant increase in predicted ground level concentrations.
Buildings that are more than 30% of the stack heights being examined should be included in the ADMS4 model. A Preliminary evaluation of the building hyout within the Glanbia Ballyragget facility was undatatEea, based on digital plans and elevations of the various buildings to asses$ building wake effects. The Nim 1 building, which h s a mof height of 24,3m, is the dominant building structure affecting emissions h m the Nim 1 (A2-1) vent. The. djacent Casein plant buildings with a roof height of 9m and the Casein Powder Building with a roof height of 1Sm also contribute to building wake turbulence and affect plume dispersion from tbe smaller Casein drier, powder mill and tmmfer vents (AZ-S,M-h, A2-7, A2-9, A2-10, A2-11 a d A2-13).
For the vents on top of the Niro2/3 building complex (Niro 2 (U-31, Niro 3(A2-4), Lactose drier (A2-8) and the Fluidised bed (A2-12) the emissions will k affected by the turbulence around the whole structure. The maximum roof height for the Niro 3 building is 34.Sm above local ground level and for the N h 2 building it is 27.5111. The adjacent Whey building, which has a lower roof height of 16m, was aIso incIuded in the building wake calculations for the model.
E N W R O O N LTD, GLANBTA IPC LICENCE TECHNlCAL AMENDMENT- PMiu 43/W
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The dimensions of the structures used in the ADMS4 model are as follows:-
rn Niro 1 Drier Building p Height =24.3m, Length = 26m, Width = 1% Casein Powder Mill Building p Height = 15.3~11, Length= 38m, Width=l7m Casein Plant Buildings p Height =h, Length = 86m, Width = 76m N b 3 Drier Building p Height =34.5m, Length = 1 Sm, Width = 21 m Nim 213 Drier Buildings p Height =27.Sm, Length = 42m, Width = 72m Whey Production Building p Height =16m, Length = 47m, Width = 41m
The sides of the buildings designated as the &en@% at an angle o f about 345 degrees from true north.
3.23 Climatological data
Sequential hourly dimatological data from the meteorological station at KiIkenny were used in predicting the ground level concentrations near the G M i a plant. Three- years of climatological data (1990,2006 and 2007) was used so that year to year variations in wind speed and direction we= taken into account in the modelIing, instead of relying on ground level concentration resdts for just one year.
The meteorological station at Kilkenny was automat& in 1991 and so only historical climatological data are available in relation to cloud cover data. After this date, only hourly wind spddirection and temperature data are availabk for Kilkenny. This information is necessary to calculate the degree of turbulence in the lower air layers and it is used in the ADMS model. Input parameters for wind speed, direction, cloud cover and air temperature provide values to enable the degree of atmorrpheric turbulence, or srability within the bwer air layers to be calculated.
Hourly chnatological data for 1990 at Kilkenny were used for the IPPC Licence Review modelling undertaken in 2005. However, due to the historical nature of these records, being now 18 years old, recent data were also used for modelling the impact of process emissions from the Glanbia facility. Hourly cloud data from Casement Aerodrome were combined with the wind speedldktion and air temperature data from Kilkenny for 2006 and 2007. Wind mses for the years 1990,2006 and 2007 are given in Figum 1 , which give the frequency of certain wind direction sectom and indication of wind speeds associated with these wind sectors.
32A Sudace Roughnas
The vatiwl wind profite above the gound is an important parameta in determining the structure of the atmospheric boundary layer near the ground. The Monin-Obukhov length provides a measure of the relative importance of buoyancy genepated by heating of the ground and mechanica1 mixing generated by the frictional effect of the earthfi surface. This fictiond effect is related both to the surface roughness length and wind speed and it is used in calculating the boundary layer structure, which affects the rate o f dispersion of an emission plume. A surface roughness length value of 0.3m, which approximates to agricultural mas, was used in the ADMS4 to represent conditions in the Ballyragget locality.
ENVIROCON LTD., GLANBIA 1PC LICENCE TECHNICAI, AMEN1)MEm- PMlo -03mR
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3.25 Receptor Grid
A receptor grid was used with a regular spacing of45x45 receptor points. The grid covered an area around the site with a grid reference of 242750N, 171585E at the SW corner extending to 244aON, 172950E at the NE corner of the grid.
33.6 Terrain
The effect of local topography on the dispersion of particulate emissions was included in the modelling study. The elevation above sea-level within the extent of the modelling area was manualIy exwactd from a digital cuntour map obtained from the Ordnance Survey. Terrain data based on a 32 x 32 grid matrix were processed for lnput into the ADMSA
4.0 RESULTS OF MODELLING STUDY
4.1 Introduction
The results of the modelling studies are shown as ground leve1 concentration contour plots in terms of PMlo concentrations. The predicted values are based on the maximum percentile statistic obtained at each of the receptor points within the modelled area over the three sepmte chnatological data-sets used in the study. Emissions of particulates are based on a tworst-cax&pemtional scenario with no diurnal or seasonal variation in the pduction patterns of the 3 Niro driers and the other smaller emission vents in the casein and lactose production areas.
Table 2 National Air Quality Standards for PMIO
Criteria
Daily p 90.4% (Stage- 1) (not to be exceeded more than 35 times per year) Annual average (Stage 1) Daily p 98.1% (Stage 2) (not to be exceeded more than 7 times per year) Annual average (Stage 2)
40 50
Comphnce Date
1 Jan 2005
1 Jan 2UO5 1 Jan2010
1 Jan2010 Smrce: Air @dip Stundud Reguluiions 2002 (SI No 271 of 2002)
The predicted ground level corncentrations of PMlo are compared with the National Air Quality Standards (NAQS) values specified in the Air Quality Standards Regulations 2002 (SI: No 271 of 2002) (Table 2).
4.2 Predicted impact
4.2.1 2008 Scenarios - Current and Increase in emission rate for A2-9
KNWROWN 111'11, GI.AFIRIA IPC LICENCE TECHNICAL AMENDMENT- P M l p 43rW
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42.1.1 Daily
The pattern of predicted 90.4 percentile daily PMM concentrations based on the existing emission scenario is shown in Figure 2. The results indicate that at the nearest houses to the north of the facility boundary, the maximum predicted 90.4 percentile is 35-40 g/m3. The highest concentrations beyond the site boundary are prehcted to occur near the NE corner, close to the N77 road that borders the eastern boundary of the Glanbia plant. Apart from the N77 carriageway and verge, the lands to the East of the facility are also within the land owned by Glanbia. The maximum 90.4 percentile concentration near the roadside is about 65-70 8/m3. This area of high ground level concentrations is due to the effects of the Niro 1 building wake on the dispersion pattern of particulate emissions from the Niro drier vent and those from the other vents located on top of the Casein building. The maximum 90.4 percentile concentrations to the south and west of the Glanbia facility are predicted to be below 25 glrnj.
Fibwe 3 shows the predicted 98.1 percentile contour plot of daily PMro concentrations based on the current emission scenario. The area beyond the Glanbia boundary where the fiture Stage 2 NAQS is exceeded occurs to the North and NE of the plant. The highest prediction concentrations, which are based on continuous maximum emissions from all process vents occur along the N77 road corridor zone near the NE boundary. The lands to the e a t of this road are within the ownership of Glanbia and include the effluent treatment plant. At the nearest houses to the mrth of the site, the predicted 98.1% concenimtions are 48-57 @m3.
With the planned increase in the maximum exhaust airflow horn the vent A2-9, Trom 10,000 to 15,000 Nm3/hr, this will increase maximum permitted emissions from a current total particulate rate of 0.14 g/s to 0.21 g/s based on the emission limit value of 50 mg/Nm3. The predicted daily 90.4 and 98.1 percentile concentrations due to continuous maximum emissions based on this minor modification to the Casein process vents are shown in Figures 4 and 5. Due to the very small change in PMlo emissions, there is no sigolficant difference in the maximum levels predicted bepnd the boundary compared to the results based on the current operation. The ground level concentration contour patterns for both the 90 -4 and 98.1 percentile levels are identical to those predicted based on the current emission scenario.
4.2.1.2 Annual
The predicted annual average PMlo concenkations based on the 2008 emission scenario is presented in Figures 6. The results indicate that the maximum annual average PMlo concentration beyond the facility boundary, is predicted to be about 27 ugh3. This predicted value is based on continuous maximum emissions h m all process vents. It occurs close to the eastern boundary, adjacent to the N77 road corridor. At the nearest houses, the predicted annual average is calculated to be 10-12
g/m3 or 30% of the current annual NAQS of 40 gm3. No significant change in the range o f concentrations and contour pattern was identified with the modification of vent A2-9 emissions for 2008.
ENWROWN LTD, GLANBJA IPC LICENCE TECHNICAL AMENDMENT- PMIO 43/08
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4.2.2 2009 Scenario (Bag-house installation on AI-3 and A2-12)
4.2.2.1 Daily
The predicted 90.4 percentile of daily PMlo ground level concentrations based on the planned installation of the bag-house for Niro 2 drier and combination of the Fluidised Bed (A2-12) from vent A2-3 is given in Figure 7. The particulate emission concentration for the A2-3 is 20 m o r n 3 and the PMlo emission rate is calculated to be 0.5 gh. This sharp reduction in emissions from vent A2-3 results in a correspondmg large improvement in pmcted concentrations beyond the boundary. The predicted 90.4 daily levels are below the NAQS beyond the facility boundary, with the highat camenhation of 48 g/m3 found alongside the N77 road near the NE boundary. The hlghest 90.4 daily concentration at the nearest house is about 10-14
dm3, which is equivalent to 2028% of the current NAQS.
The maximum 98.1 percentile of daily PMlo levels beyond the site boundary occurs over the N77 road corridor and within the lands to the east of the road owned by Glanbia. There is a very small area where predicted daily levels exceed the future daily NAQS, with a maximum PM10 concentration of 50-60 g/m3 alongside the eastern side of the N77. The results presented in Figure 8 show that at the nearest houses to the facility boundary the predicted concenmtions are less than 20 g/m3, or 40% of the Stage 2 daily NAQS. These results are basad on continuous maximum particuiate emissions from all the process vents and so observed levels are Iikely to be sibvificantly lower that the predicted values and so well below the future NAQS.
4.2.2.2 Annual
The predicted annual average PMlo concentrations, based on maximum continuous emissions in 2009, is shown in Fig 9. The results indicate that the predicted Philo levels are about 2-5 g/m3 at the nearest houses, which are located io the North of the site. Near the NE site boundary, adjacent to the N77 road corridor, the annual average is predicted to be about 10-20 dm3, or 50% of the current annual NAQS. These predicted concentrations at the nearest houses are also well below the future Stage 2 annual limit value.
5.0 CONCLUSTO N
The air quality dispersion modelling study carried out demonstrates that the planned change in the maximum hourly exhaust airflow for vent A2-9, with a corresponding marginal increase in particulate emission rates, will result in a negligible impact on local air quality compared to the present emission scenario.
With the planned installation o f filter bag house on Niro 2 in 2009 there will be a substantial hpmvement in the predicted P M ~ O ooncentrations downwind of the site boundary. Compared to the current emission scenario, the predicted 90.4 percentile of daily PMIO concentrations will decrease from 3540 g/m3 at the nearest houses to 10- 14 g/m3. The maximum 90.4 percentile of daily PMIO levels is predicted to be less than the present NAQS and the highest levels are predicted to only occur w i h a very small area near the NE site boundary, adjacent to the N77 road. The
ENVIROCON LTD., GLANBIA IPC LICENCE TECHNlCAL AMENDMENT- PMlo -03W
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corresponding 98.1 percentile daily levels at the nearest houses is also predicted to less than 40% of the future Stage 2 NAQS of SO dm’ based on the 2009 emission scenario.
There is an area near the NE site boundary and close to the N77 road where predicted PMlo ground level concentrations based on the 2009 emission scenario marginaly exceeds the future daily NAQS. However, this area Is very small and is witbin the road corridorlverge or the lands on the eastern side of the road that are also within the ownershp of Glanbia.
The predicted annual average PMlo concentrations for both the 2008 and 2009 emission scenarios are less tban 32% of the current and the future Stage 2 NAQS at the nearest houses. The maximum annual average occurs close to the eastern boundary and near the N77 roadside. For 2008, this is predicted to be 67% of thc current annual NAQS. The corresponding maximum annual average, based on the 2009 emission scenario, is significantly lower with a predicted concentration of 50% of the current NAQS.
The exposure risk to health by the local community is demonstrated to be very low as there are no properties within the area near the NE site boundary where the highest PMIO concentrations are predicted. Moreover, the duration of exposure lo these emissions by any passing pedestrians along the N77 is very low. At the nearest houses to the boundary, bolh the predicted daily and annual PMlo concentrations are well below the current and future NAQS for the 2009 emission scenario. Therefore, no significant impact on the health of the local community or surrounding environment is predicted due to the planned changes in particulate emissions from the facility requested by Glanbia in the Techcal Amendment to IPPC Licence PO359-02.
ENWROWN LTD., GLANBIA IPC LICENCE TECHNICAL AMENDMUTT- PMio -03/08 8
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FIGS 1-0 KILKENNY WIND ROSE
AND AIR QUALITY DISPERSION
MODELLING CONTOUR PLOTS
ENVIROCON LTD., GLANBIA IPC LICENCE TECHNICAL AMENDMINT- PMio -03108
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L.
1990 2006
2007
FIGURE I : WIND ROSE FOR KiLKENNY METEOROLOGICAL STATION FOR 1990,2006 AND 2007 BASED ON HOURLY OBSERVATIONS
ENVIROCON LTD.. GLANBIA mC LICENCE TEECIINICAL AMENDMENT- PMIO -0- 10
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FIGURE 2 - PREDICTED 90.4 PERCENTILE OF DAILY PMlo GROUND LEVEL CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS VENTS BASED ON CURRENT SCENARIO (uglrn31.
ENVIROCON LTD., GLANBIA IPC LICENCE TECHNICAL AMENDMENT- PMlo 43/08 11
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FIGURE 3 - PREDICTED 98.1 PERCENTILE OF DAILY PMlo GROUND LEVEL CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS VENTS BASED ON CURRENT SCENARIO (Vglm’).
EWROCON LTD., GLANBIA IPC LICENCE TECHWICAL AMENDMENT- PMio 43M8 11
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FIGURE 4 - PREDICTED 90.4 PERCENTILE OF DAILY PM10 GROUND LEVEL CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS VENTS BASED ON 2008 SCENARIO WITH REVISED FLOW RATE FOR VENT A2-9 (rgirn').
ENVIROCON LTD., G L M I A IPC LICENCE TECHNICAL AMENDMENT- PMm 43/08 13
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FIGURE 5 - PREDICTED 98.1 PERCENTILE OF DAILY PMlo GROUND LEVEL CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS VENTS BASED ON 2008 SCENARIO WITH REVISED FLOW RATE FOR VENT A2-9 (vglrn9).
ENWROCON LTD.. GLANBIA IPC LICENCE TECHNICAL AMENDMENT- PMno -03W 14
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FIGURE 6 -PREDICTED ANNUAL AVERAGE PMio GROUND LEVEL
BASED ON 2008 SCENARIO WITH REVISED FLOW RATE FOR VENT A2- CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS VENTS
9 olglm3b
ENVIROCON LTD., GLANBIA IPC LICENCE TECHNICAL AMENDMENT- PMlu 43/08 I5
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FIGURE 7 - PREDICTED 90.4 PERCENTILE OF DAILY PMlo GROUND
VENTS BASED ON 2009 SCENARIO. NtRO 2 (A2-3) ENllSSlON LIMIT = 20 LEVEL CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS
mglNmS AND COMBINED EMlSStONS FOR NlRO 2 AND VENT A2-I2 W m 3 )
ENWROCON LTD., GLANBIA IPC LICENCE TECHNICAL AMENDMENT- PMio -03/08 16
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FIGURE 8 - PREDICTED 98.1 PERCENTILE OF DAILY PMlp GROUND LEVEL CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS VENTS BASED ON 2009 SCENARIO. NlRO 2 (A2-3) EMISSION LIMIT mglNd AND COMBINED EMISSIONS FOR NlRO 2 AND VENT A242 ( IJ 9 Im
20
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c
FIGURE 9 - PREDICTED ANNUAL AVERAGE PMio GROUND LEVEL
BASED ON 2009 SCENARIO. NlRO 2 (AZ-3) EMISSION LIMIT = 20 CONCENTRATIONS DUE TO EMISSIONS FROM PROCESS VENTS
mglNrn3 AND CO MBlNEO EMISSIONS FOR NlRO 2 AND VENT A24 2 (crslm3)
ENVIROCON LTD., GLANBIA mC LICENCE TECHNICAL AMENDMENT- PMio 43/08
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