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United Fish Industries IPPC Licence Application ATTACHMENT C MANAGEMENT OF THE INSTALLATION Contents Attachment C.1 Site Management & Control Attachment C.2 Environmental Management System (EMS) Attachment C.3 Hours of Operation

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United Fish Industries IPPC Licence Application ATTACHMENT C.1 SITE MANAGEMENT AND CONTROL Contents Chart of on-site management structure including responsibility levels Details of management structure for the operation of on-site abatement/treatment systems, including details of personnel training and qualifications

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Attachment C.1 – Site Management & Control This attachment details the management structure of the operation, specifically in relation to on-site abatement/treatment systems, and includes details of personnel training and qualifications. Figure C.1(i) Company organisation chart for environmental management

John Healy , Managing Director, has overall responsibility for the environmental management of the site. Frank Trearty , Quality Director, is responsible for the day-to-day management of the activity from an environmental point of view in conjunction with the Production Manager and the Plant Engineer. The Quality Director is the point of contact with the EPA, with the Plant Engineer and Managing Director as support contacts. The responsibilities of the Quality Director include:

• Management of all compliance sampling and analysis; • Compliance reporting to the EPA; • Reporting major accidents and incidents to the EPA; • Reporting objectives and targets and updating the Environmental Management Plan

(EMP); • Management of all incidents and complaints including record keeping; • Liaison with senior management on all environmental issues.

John Hennigan , Production Manager, has responsibility for operation of the Dissolved Air Flotation (DAF) plant and any effluent monitoring equipment used on site (e.g. pH meters, flow meters, etc.). The Production Manager also has responsibility to deal with any environmental incidents along with the Quality Director and Plant Engineer. Brendon Green , Plant Engineer, has responsibility for the maintenance of all related effluent equipment and also for input of any capital equipment relating to the environment. The table over provides a summary of the key qualifications and level of experience that are available to the UFI management team.

J Healy Managing Director

Brendon Green Plant Engineer

Frank Trearty Quality Director

John Hennigan Production Manager

5 Laboratory Technicians

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Personnel Role Experience J. Healy Managing Director 25 Year experience in Factory

Management in various industries. F. Trearty Quality Director MSc in Environmental Protection, BSc in

Microbiology & Immunology. 12 years employed with both Aqualab and United Fish Industries.

J Hennigan Production Manager 28 years with company, Production manager for 8 years IOSH certified,

B. Green Engineering Manager B eng (Hons), 11 years with the company, IOSH certified

Geraldine Fox Lab Manager PhD in Marine Zoology, 13 years employed with Aqualab.

Niamh Kennedy Health & Safety Manager 18 years with the company, NEBOSH Certificate, FETAC level 6 on Employment law, Diploma in Human Resource management.

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United Fish Industries IPPC Licence Application ATTACHMENT C.2 ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) Contents Details of Environmental Management System including relevant standard and mechanism for on-going assessment of environmental performance Copy of Accreditation Certificate

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Attachment C.2 - Environmental Management System (EMS)

This attachment includes a copy of UFI’s Environmental Management System Manual for the Killybegs Fishmeal Plant. The EMS has been prepared to meet the ISO 14001 standard and undergoes bi-annual audit to ensure the highest levels of compliance. This is the key manual that sets the framework for environmental management at the site and sets out the environmental policy and the procedures for the principle issues on site such as:

• Environmental aspects • Legal and other requirements • Environmental objectives and targets • Management programme • Structure and responsibility • Training, awareness and competence

The EMS manual is supplemented by a wide range of additional procedures and documentation that have not been included in this application but are available on request.

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United Fish Industries ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL

2011

Frank Trearty

United Fish Industries

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CODE:

REVISION: A

ISSUED BY: QD PAGE: i 0F ii

Environment Manual DATE ISSUED: 02/02/11

Issue Date: 2011 Page i of ii EMS Manual

TABLE OF CONTENTS

1.0 PURPOSE.................................................................................................

2.0 SCOPE......................................................................................................

3.0 ISSUE AND UPDATE ...............................................................................

4.0 ENVIRONMENTAL POLICY .....................................................................

5.0 ENVIRONMENTAL ASPECTS..................................................................

6.0 LEGAL AND OTHER REQUIREMENTS...................................................

7.0 ENVIRONMENTAL OBJECTIVES AND TARGETS..................................

8.0 ENVIRONMENTAL MANAGEMENT PROGRAMME................................

9.0 ORGANISATIONAL STRUCTURE AND RESPONSIBILITY ....................

10.0 TRAINING, AWARENESS AND COMPETENCE .....................................

11.0 COMMUNICATION ...................................................................................

12.0 ENVIRONMENTAL MANAGEMENT SYSTEM DOCUMENTATION.........

13.0 DOCUMENT CONTROL...........................................................................

14.0 OPERATIONAL CONTROL ......................................................................

15.0 MONITORING AND MEASUREMENT......................................................

16.0 NONCONFORMANCE AND CORRECTIVE AND PREVENTIVE ACTION

17.0 RECORDS ................................................................................................

18.0 ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT .............................

19.0 MANAGEMENT REVIEW .........................................................................

20.0 RECORD OF REVISIONS ........................................................................

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CODE:

REVISION: A

ISSUED BY: QD PAGE: ii 0F ii


Issue Date: 2011 Page ii of ii EMS Manual

APPENDICES ISO 14001 Initial Environmental Review Audit Abbreviations EMS: Environmental Management System PM: Project Manager EC: Environmental Coordinator ET: Environmental Team ETL: Environmental Team Leader BATNEEC: Best Available Technology Not Entailing Excessive Cost BAT: Best Available Technology EMP: Environmental Management Programme

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REVISION: B

ISSUED BY: QD PAGE: 1 0F 19


Issue Date: February 2011 Page 1 of 20 EMS Manual

1.0 Purpose

This manual defines the scope of United Fish Industries Environmental Management System (EMS).

The principal elements of the system described in this manual are:

• Environmental Policy • Environmental Aspects & Impacts • Legal and Other Requirements • Environmental Objectives and Targets • Environmental Management Programme • Organisational Structure and Responsibility • Training, Awareness and Competence • Communication • Document Control • Operational Control • Monitoring and Measurement • Non conformance and Corrective and Preventive Action • Records • Environmental Management System Audit • Management Review

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2.0 Scope & Validity

United Fish Industries EMS provides a mechanism for environmental management at the facility in Killybegs, Co. Donegal. The environmental management system is designed to cover environmental aspects which the operational facility can control and directly manage, and those it does not control or directly manage but can be expected to have an influence on.

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3.0 Distribution, Revision and Control

The control of this Manual is in accordance with United Fish Industries procedure – Document Control Procedure. The Environmental Manager (EM) for the EMS will conduct the distribution of this manual manually. There will be a “Master Copy” in hard copy form maintained by the EM. This copy will have the signature of the site operations manager and be stored in the EMS folder kept with the Environmental Manager (EM). The current Environmental Manager is Frank Trearty.

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4.0 Environmental Policy

Welcon Group management endorses United Fish Industries Environmental Policy. The policy covers all on-site Fishmeal and Fishoil production and associated activities. The Policy includes a commitment to continual improvement and prevention of pollution, as well as a commitment to meet or exceed relevant environmental legislation, regulations and other requirements. The Policy will be reviewed annually by management, communicated to all employees and made available to the public at our site office. Reference Material ISO 14001 Standard (4.2)

ENV - 001

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5.0 Environmental Aspects & Impacts

United Fish Industries Environmental Team (ET) identifies the environmental aspects, which the site controls and over which it may be expected to have an influence, and determines which of those aspects are considered significant. The current ET for UFI is as follows: Managing Director, Environment Manager, H&S manager, Engineering manager. These aspects are to be reviewed at least annually or when there is a new or changed activity. The Environmental Manager (EM) maintains ET minutes and other records. Reference Material ISO 14001 Standard (4.3.1) ENV - 002

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6.0 Legal and Other Requirements

UFI has established an environmental procedure for the purpose of identifying, accessing and communicating legal and other requirements that are applicable to the office. National & local regulations are identified, accessed and communicated by the Environmental Manager with the aid of staff working in the areas. The list of legal requirements will be reviewed annually by the Environmental Manager, which will include a review of the most current national, regional, provincial, state and local legal and other requirements as applicable to United Fish Industries.

Reference Materials

ISO 14001 Standard (4.3.2) ENV - 003

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7.0 Environmental Objectives and Targets

The Environmental Team has developed objectives and targets for each significant environmental aspect. These objectives (long term) and targets (short term) define:

1. The performance objectives (Investigate/Study, Control or Improve) for each significant environmental aspect;

2. The specific, quantified targets which define the performance objectives; and

3. The planned deadlines for the accomplishment of those targets. Objectives and targets are developed considering significant environmental aspects, legislative requirements, views of interested parties and the principle of Best Available Technology (BAT). Reference Material ISO 14001 Standard (4.3.3) ENV -004

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8.0 Environmental Management Programme

An environmental management programme (EMP) has been developed as a means for achieving objectives and targets. This programme defines the actions to be taken, those responsible and target times for implementation. It is the management’s responsibility to:

• Select & support the Environmental PM • Establish environmental policy • Provide resources to implement and maintain the Environmental

Management System • Approve & annually review the EMS

The EMP is developed by the ET and approved by the EC.

Reference Material: ISO 14001 Standard (4.3.4) ENV -005

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9.0 Organisational Structure and Responsibility

Environmental Management System roles, responsibilities and authorities are defined at relevant functions and levels within the company. The Management Team provides the resources essential to the implementation and control of the environmental management system, including: training, personnel, specialty services, and financial resources, technical and informational services. The Environmental PM has primary responsibility for establishing, operating and maintaining the EMS. Reference Material ISO 14001 Standard (4.4.1) ENV -006

10.0 Training, Awareness and Competence United Fish Industries recognises that staff training on all aspects of the environmental management system is required for successful implementation of the system from management down. A staff training and awareness programme will form part of the sites objectives and targets. The Health & Safety manager is responsible for maintaining employee training records. Appropriate records are monitored and reviewed on a scheduled basis. Competency is determined by the annual report on the EMS’s targets. Reference Material ISO 14001 Standard (4.4.2) ENV -007

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11.0 Communication

United Fish Industries has established and will maintain a procedure for internal and external communications regarding environmental aspects and the EMS. Reference Material ISO 14001 Standard (4.4.3) ENV -008

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12.0 Environmental Management System Documentation

This Manual identifies all documents relevant to the EMS. A copy of EMS documents and spreadsheets can be obtained from the Environmental Manager. These shall be stored in the EMS folder and are listed in the below procedure. Reference Material ISO 14001 Standard (4.4.4)

Reference Material Description ENV 001 Environmental Policy ENV 002 Significant Aspect Evaluation Guide ENV 002B Register of Environmental Aspects ENV 003 Register of Environmental Legislation and

Regulations ENV 004 Environmental Objectives and Targets for 2011 ENV 005 Environmental Management Plan ENV 006 Organisational Structure ENV 007 Training, Awareness and Competence ENV 008 Register of Internal and External EMS Queries ENV 009 Monitoring and Measuring Schedule 2011 ENV 010 Corrective and Preventative Action Form

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13.0 Document Control

United Fish Industries has established a procedure for controlling all documents related to the environmental management system. This procedure describes document locations and how and when they are reviewed. The procedure ensures that current versions are available and that obsolete documents are promptly removed from use or are suitably identified. Controlled documents are obtainable from the Environmental PM or EC. Reference Material ISO 14001 Standard (4.4.5)

14.0 Operational Control

The management team is responsible for identifying operations and activities associated with significant environmental aspects that require controls in work practices or environmental management programme. These documents define the mechanisms for the establishment, implementation and maintenance of the EMS and ensure that the system is maintained in accordance with the environmental policy and objectives. Reference Material ISO 14001 Standard (4.4.6)

ENV 0009 Monitoring & Measuring

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15.0 Monitoring and Measurement

United Fish Industries has established environmental procedures to monitor and measure the key characteristics of its activities that can have a significant impact on the environment. United Fish Industries has established an Environmental Regulatory Compliance Programme. Procedure ENV -009 outlines the requirements of the programme to periodically review regulatory compliance and report results to management on a yearly basis. Reference Material ISO 14001 Standard (4.5.1) ENV -009 Monitoring & Measuring

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16.0 Nonconformance and Corrective and Preventive Action

The United Fish Industries has an environmental procedure for defining responsibility and authority for handling and investigating non-conformance, for taking action to mitigate impacts, and for initiating and completing corrective and preventive actions. Any changes in procedures resulting from corrective and preventive actions are implemented and recorded. The Environmental Coordinator maintains these records, which are based on our Quality Management System. Reference Material ISO 14001 Standard (4.5.2)

ENV -010 Corrective and Preventative Action Form

17.0 Records

United Fish Industries has an environmental procedure for the identification, maintenance and disposal of environmental records. These records include training records and the results of audits and reviews. They are easily retrievable and protected against damage, deterioration and loss. The ET’s maintain their own environmental records. Record and document retention is also specified in the procedure. Reference Material ISO 14001 Standard (4.5.3)

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18.0 Environmental Management System Audit

Bi-annual system audits are conducted to ensure that the environmental management system has been properly implemented and maintained. The results of these audits are provided to management. Audits are performed according to a schedule, which is based on the environmental importance of an activity, the results of previous audits and the audit schedule. All auditors are suitably trained and audit records are kept on file. Reference Material ISO 14001 Standard (4.5.4)

19.0 Management Review

The senior management reviews all elements of the EMS annually to ensure its continuing suitability, adequacy and effectiveness. Meeting minutes record these reviews and are kept by the Environmental PM in the EMS folder. Reference Material ISO 14001 Standard (4.6)

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20.0 Record Of Revisions Revision Date Description (Who) Sections Affected

29/01/11 Initial draft – Frank Trearty All

20/3/11 Update of Draft All

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United Fish Industries IPPC Licence Application ATTACHMENT C.3 HOURS OF OPERATION Contents Hours of operation Proposed hours of any construction and development works and timeframes

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Attachment C.3 – Hours of Operation The plant is fully operational and all times listed are based on normal current operations. The plant operates on a cyclical basis and is based on seasonal demand with peak production in the period from January to April. At other times of the year the plant operates at reduced capacity or is not in production. The plant has two separate processing streams and the hours of operation of each differ as follows:

• The Steam Drying (SD) plant - typically operates 18 hours per day, 4 days per week and for 20 weeks per year.

• The Low Temperature (LT) plant

- typically operates 21 hours per day, 5 days per week and for 40 weeks per year.

Production is totally dependent on the availability of raw material and therefore dependant on national fishing stocks. In 2010, the availability of raw material was reduced and therefore production figures have dropped (60,989 tonnes of raw material processed). Based on projected changes in the fishing industry there is predicted to be significant increases in the availability of raw material to the UFI plant in future years. As such, in future years it may be possible that the plant will operate on some capacity throughout the year and/or may operate on a continuous 24 hour operation at peak times.

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United Fish Industries IPPC Licence Application ATTACHMENT D INFRASTRUCTURE & OPERATION Contents Attachment D.1 Operational Information Requirements

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United Fish Industries IPPC Licence Application ATTACHMENT D.1 OPERATIONAL INFORMATION REQUIREMENTS Contents Details of the plant, methods, processes, ancillary processes, abatement, recovery and treatment systems, and operating procedures Process flow diagrams Outline of all unit operations Development and operational history of the site

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Attachment D – Operational Information Requirements D.1 Plant Location and Description United Fish Industries (UFI) is the main supplier of fishmeal and fish oil to the Irish aquaculture industry. The plant was built in 1957 and produces low temperature and steam dried fishmeal which is supplied to fish feed producers. The plant is located on a 1.699 hectare site on the Donegal Road (R263), approximately 1 km north of the town centre of Killybegs. The site is bounded to the west by the Donegal Road and to the east by Killybegs Harbour. The plant accepts fish trimmings and whole fish from the fish industry across Ireland and recovers fishmeal and fish oil. The plant has the capacity to process approximately 800 tonnes of raw material per day. Currently the plant processes approximately 50,000 to 80,000 tonnes of raw material per annum, and recovers approximately 10,000 to 18,000 tonnes of fish meal and 3,000 to 5,000 tonnes of fish oil per annum. Production is totally dependent on the availability of raw material and therefore dependant on national fishing stocks. In 2010, the availability of raw material was reduced and therefore production figures have dropped (60,989 tonnes of raw material processed). Based on projected changes in the fishing industry there is predicted to be significant increases in the availability of raw material to the UFI plant in future years. Fishmeal is manufactured by cooking, pressing, drying and grinding fish and fish trimmings to produce a stable end product. The fishmeal is produced mainly for use in aquaculture, with limited quantities going to the agriculture sector. This application for licence review relates to the current plant with a series of planned improvements through a three stage process. Stage 1 relates to the existing conditions on the site. Stage 2 is based on a slightly modified plant coupled with a rerouted sewer discharge to the Donegal County Council sewer outfall in the outer harbour. Stage 3 is based on a modified plant with significantly reduced pollutant loadings and a planned increase in production from 800 to 1200 tonnes of raw material processed per day to account for the projected increased availability of raw material. This application is based on the existing plant undergoing production changes through the three stages as outlined above. Planning consent has been granted for the existing plant and the proposed changes are sub-threshold for planning so no new planning application will be required. However, UFI may decide to undertake major infrastructural works to increase the plant capacity from 800 to 1200 tonnes. In this instance a planning application and EIA will be required and UFI will inform the EPA of this process not later than the 1st January 2014 (i.e. 2 years in advance of the Stage 3 date). D.2 Overview of Operation Fishmeal is manufactured by cooking, pressing, drying, evaporation, separation and grinding fish and fish trimmings to produce a stable end product. The fishmeal is produced mainly for use in aquaculture, with limited quantities going to the agriculture sector. For this purpose, and to provide a standardised product, the raw material must be dried to below 10% moisture content. The fish and fish trimmings, prior to processing, have a water content of around 75 to 80%, and an oil content of between 3 to 10%.

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The plant operates two separate processing lines, both housed in the main production building:

• The Steam Drying (SD) Plant - uses indirect steam in the drying system and has a production capacity of 15 tonnes of raw material per hour.

• The Low Temperature (LT) Plant

- uses hot air in the drying system and has a production capacity of 20 tonnes of raw material per hour. Produces a higher digestible quality product that the SD system.

The main elements of both process lines are presented in the form of a flow charts in the attached figures. Raw Material Intake Raw material (fish and fish trimmings) is delivered in lorries and trailers by road from the fish processors within Killybegs, and from other fish processors throughout the island of Ireland. The raw material is accepted at the intake area transferred by enclosed bucket lift to the raw material storage silos. Cooking The raw material is conveyed to continuous indirect steam cookers where is it cooked for approximately 30 minutes. The cooked material is then passed through a strainer system, at which stage free liquids are separated. From this phase of the process the material enters into either the liquid or solid phase of the process. Solid Phase The solid, cooked material is conveyed to twin-screw presses where excess liquid is removed under pressure. At this point, the moisture content of the solid material is approximately 50%. The pressed material is conveyed to either the SD or LT driers where is it partially dried to a moisture content of less than 10%. Finally, the material is cooled and ground and conveyed to the fishmeal storage area. Liquid Phase Liquids, from both the strainer system and the twin-screw presses, enter centrifugal decanters where most of the solids (grax) are removed and diverted to the solid phase (before the drying process). The decanted liquid enters a high speed centrifugal separation system at which stage crude fish oil is separated from the water and the remaining solids. This high quality crude fish oil is stored in enclosed tanks. The separated water is diverted to an evaporation system. The water is evaporated until the concentration of solids in the liquid goes from approximately 9% to 35%. The resulting concentrate is diverted to the solid phase of the process (before the drying process). D.3 Site Layout All of the main processing operations, as well as the storage of fishmeal, are housed in the main production building. Other key infrastructure on the site is listed below:

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• Office and administration buildings • Raw material storage silos • Tank farm (fish oil, diesel, heavy fuel oil, tallow, water) • DAF building – A double dissolved air flotation (DAF) unit is used to treat the process

effluent prior to discharge to the Donegal County Council sewer network. • Laboratory – The plant operates a laboratory for ongoing water quality analysis

requirements. The laboratory is operated by five technicians and is fully accredited with INAB (Registration Number 075T).

• Maintenance building The layout of the site, including the location of the key infrastructure, can be seen in many of the maps which form part of this application. D.4 Abatement Systems There are four principle abatement systems in operation on the site:

• A DAF unit to treat process effluent to sewer; • A particle washer and cyclones for discharges to water; • Bag filters for mitigation of particulate emissions to water; and • Odour scrubbing of emissions to atmosphere.

DAF Unit The Dissolved Air Flotation (DAF) unit is situated on the south east corner of the site and is used to treat process waters from the following sources prior to discharge to the Donegal County Council sewer at SE1:

• Washings from the lorry wash-down area; • Washing from general plant area wash-down activities; • Separator flushings; • Washings from general cleaning in place (CIP); • Pump cooling water; • Rainwater.

The DAF process clarifies wastewaters, removing suspended matter such as oil or solids. Air is dissolved in the wastewater under pressure and then comes out of solution at atmospheric pressure in a flotation tank. The released air forms very fine bubbles which adhere to the suspended matter bringing it to the surface of the water where it can be removed with a skimming device. This system was installed in 1999 (by the manufacturer Nijhuis Water Technology) following agreement with Donegal County Council in relation to treating the wastewater from the plant prior to discharge. The DAF plant is designed to treat a discharge of 25m3/hour. Particle Washer In 2010, UFI installed a particle washer downstream of the dryer in the SD Plant to minimise particle emissions in the surface water emission (discharged to the Harbour), thereby reducing the BOD & ammonia loading discharged via SW1. The system essentially ‘washes’ the vapour from the dryers and any material collected is returned to the process, thereby both facilitating recovery of lost product and reducing BOD and ammonia emissions to surface waters. Cyclones and Bag Filters Both plants include a number of cyclones and/or bag filters that are designed to filter out particles in the process air prior to discharge through the burner/boilers via the scrubbers. The bag filters

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and cyclones are also employed to reduce product loss by reducing the particle fraction in the process air prior to scrubbing so thereby reducing the potential for particle loss to SW1 in the scrubber water and the resultant BOD discharge to the harbour. Odour Abatement Process and headspace air, which is high in amine, ammonia and other vaporous gases, is captured and routed through a wet scrubber where the condensable gases (amines, ammonia) are captured in the vapour stream. The non-condensable exhaust air is then routed through the boiler, as make-up air, where any residual odorous gases (hydrogen sulphide, mercaptans) are combusted and oxidised prior to discharge from the boiler emission stacks. D.5 – Development & Operational History of the Site Fishmeal processing operations have been in operation at the current site since the late 1960s. The earliest planning records date from 1970. A record of the planning history for the site is presented more fully in Attachment B.5 and is summarised below (where planning permission was granted only): 1970-1980 Extension of the factory

Replacement of chimney stack Extension of storage accommodation Re-siting of access road and entrance Laying pipe and submersible pump Siting oil storage tank

1980-1990 Erection of storage tank for cooling water Erection of 4 storage bins and elevator Erection of workshop sub-station Erection of R&D centre, laboratory, administrative building and sub-station

1990-2000 Erection of vehicle garage Extension of laboratory and welfare facilities Extension of fishmeal storage area Erection of 4 fish storage silos and intake pit Erection of new dryer, boiler house and relocation of ESB substation.

2000-present Erection of chimney stack for boiler Retention of extension to tank farm Retention of extension to goods inwards The existing IPPC licence (Register Number P0416-01) was granted in October 1999 with a Technical Amendment granted in November 2005 and a further Technical Amendment granted in November 2009. This application is based on the existing plant undergoing production changes through the three stages as outlined above. Planning consent has been granted for the existing plant and the proposed changes are sub-threshold for planning so no new planning application will be required. However, UFI may decide to undertake major infrastructural works to increase the plant capacity from 800 to 1200 tonnes. In this instance a planning application and EIA will be required and UFI will inform the EPA of this process not later than the 1st January 2014 (i.e. 2 years in advance of the Stage 3 date). Further details are presented in Attachment B.8.

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United Fish Industries IPPC Licence Application ATTACHMENT E EMISSIONS Contents Attachment E.1 Emissions to Atmosphere Attachment E.2 Emissions to Surface Waters Attachment E.3 Emissions to Sewer Attachment E.5 Noise Emissions Attachment E.6 Tabular Data on Emission Points

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United Fish Industries IPPC Licence Application ATTACHMENT E.1 EMISSIONS TO ATMOSPHERE Contents Summary list of all emission points Maps/drawings of all emission points Plans of emission elevations, relevant roof heights etc Detailed descriptions and schematics of abatement systems Details of planned programme of improvement

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Attachment E.1 – Emissions to Atmosphere E.1.A Details of all point emissions to atmosphere The proposed combustion emissions to atmosphere will remain unchanged from the previous IPPC licence (Register No. P0416-01), apart from the upgrading of one previously minor emission point to a main emission point – a sea-water scrubber adjacent to the tank farm (A2-1).

• There are two boiler emissions (A1-1, A1-2), formerly B1(a) and B1(b), and one burner emission (A1-3), formerly B2.

• There is one main emission point, the sea-water scrubber treating the foul air from the

coolers/grinders (A2-1). • There are 19 minor emissions to atmosphere. • There are 3 main sources of fugitive emissions.

Boiler and main emission points As the boilers and main emission points are linked through production and emission, they are discussed together in this section. The details of the boiler/main emission points are presented in Table E.1.A.1. A site plan indicating the locations of the boiler emission points and main emission points is included in this attachment (Map E.1(i)). Also included is an elevation drawing of the facility indicating the heights of the emission points and surrounding buildings and infrastructure (Map E.1(ii)). Table E.1.A.1: Details of key boiler and main emission points on site

Source Designation Reference Diameter (m) Height (m) Temp. ( 0C) Flow (Nm 3/hr)

Boiler B1A Boiler A1-1 0.86 30 200 22,000

Boiler B1B Boiler A1-2 0.86 30 200 22,000

Burner B2 Boiler A1-3 0.79 26 320 14,000

Odour Scrubber Stack Main A2-1 0.5 10 25 19,000

The boilers and burner are tested on an annual basis for total particulate matter, ammonia, amines, amides, hydrogen sulphide, sulphides, mercaptans, sulphur dioxide and nitrogen dioxide. The limits presented in Schedule 1(i) of the existing IPPC Licence (Register P0416-1) are the same or more stringent than the limits presented in Table 6.1 of the BAT Guidance Note for the Manufacturing of Fish Meal and Fish Oil. Ongoing monitoring of these boiler emissions indicates full compliance with the current IPPC limits. These boiler emissions will remain unchanged throughout stages 1, 2 and 3 of this application and fully comply with BAT. A dispersion model of the impacts of these boilers is presented in Attachment I.1 . The main emission point (A2-1) is not currently tested under the existing IPPC licence regime but periodic monitoring of ammonia emissions from this stack indicates levels compliant with BAT. It is proposed that emissions from this stack will comply with the BAT limits for odours.

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If the proposed plant capacity upgrade goes ahead for Stage 3 of this application, there may be the requirement for a new boiler emission point (A1-4). However, if this capacity upgrade proceeds the planning application, impact assessment and licence review will document the impact of this boiler. This exercise is not carried for this application as the details, location and height of the boiler are unknown until a detailed design is progressed. The existing boilers and burner emit the following polluting substances listed in S.I. 394 of 2004: • Sulphur dioxide and other sulphur compounds • Oxides of nitrogen and other nitrogen compounds • Carbon monoxide • Dust

There are no other pollutants listed in S.I. 394 of 2004 emitted to atmosphere from the plant. Details of the boiler emissions are presented in Table E.1(i) of the main application form.

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Minor emission points There are 20 minor emissions to atmosphere including vents and steam exhausts from the process as well as fume cabinets from the laboratory. These are presented in Table E.1.A.2. Table E.1.A.2: Details of Minor Emission Points on Site

Source Designation Reference Abatement

Mill Room Air Vent Minor A3-1 None

Cooling Tower SD Plant Minor A3-2 None

Cooling Tower LT Plant Minor A3-3 None

Steam Vent SD Plant Minor A3-4 None

Air Compressor Outlet Minor A3-5 None

Lab Fume Hood 1 Minor A3-6 None


Laminar Flow Cabinet Minor A3-8 None

Generator at Raw Material Intake

Minor A3-9 None

LT Condensate Tank Vent Minor A3-10 None

Boiler Blowdown Vent Minor A3-11 None

Boiler Feed Tank Vent Minor A3-12 None

Relief Valve 1 Minor A3-13 None








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Fugitive and potential emissions Currently all process air is captured in an enclosed foul air system and routed through a series of cyclones and odour scrubbers as well as through boilers and burners. As such, there are no fugitive odours from the enclosed processing lines in the plant. However, in the areas where raw materials and products are stored, and in the wider processing area, there is the potential for fugitive odours to escape from the building. The nature of the odours is fishy and ammonia/amine-like and has given rise to one odour complaint in 2008 and another in 2009. The fugitive and potential odours on site are listed in Table E.1.A.3. Table E.1.A.3 Details of Fugitive Emission Points on Site

Source Designation Reference Material

Raw Material Intake Fugitive A4-1 Odour

Raw Material Silos (x 3) Fugitive A4-2 Odour

Meal Storage Areas Fugitive A4-3 Dust

It should be noted that there is ongoing odour management work being undertaken at the site with a view to improving the performance of the plant and mitigating fugitive odours. In early 2011, UFI purchased a set of carbon filters to be installed on the raw material silos during the summer of 2011. These filters will mitigate the potential for fugitive odours from the headspace air in these silos (emission reference A4-2). In order to mitigate other odours effectively, a complete retro-fit of the building structure would be required to seal sections the building such as the raw material intake (emission reference A4-1) and mitigate the potential for emissions as outlined above. This proposed retro-fitting of the building is proposed for stage 3. While there is a low number of odour complaints recorded at the facility (one in 2008 and one in 2009), it is a requirement of BAT to contain odours (Section 5.2.3 of BAT Note) for treatment prior to discharge:

Enclose all odour generating process activities using negative pressure extraction units in such processing, handling and storage areas; contain potentially odourous materials in enclosed containers, maintain short storage times, and use cold storage as deemed necessary; clean material storage areas frequently (see BREF Section 4.1.31); and cover WWTP (see BREF Section 4.1.43.12)

To deliver this level of abatement will require considerable capital expenditure and production downtime. It is not feasible to carry out retrofitting of the existing plant as part of stage 2 but UFI commit to the delivery of BAT measures as outlined above by stage 3. The proposed odour abatement system and emission concentrations shall be designed to meet the requirements of BAT. A detailed description of the design of the proposed abatement measures is not available at the time of this application. However, these will be submitted at least 6 months in advance of the stage 3 commencement date for Agency approval.

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E.1.B Abatement There are three separate systems of abatement at the facility that consists of two and three stage abatement. Each of the sources stages and levels of abatement are summarised below and discussed in greater detail in Attachment F.1 .

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System 1 – Abatement of foul air from the main process This abatement process takes the foul air from the key processing stages – cooking, straining, decanting, pressing and evaporating - and routes it through a direct sea water scrubber (primary treatment) and then diverts it to the boilers (A1-1 and A1-2) as make-up air. In the scrubbing stage, the condensable fraction of gases (amines, ammonia, etc.) is condensed in the sea water and diverted to the process water streams and the non-condensable fraction (H2S, mercaptans, sulphides, etc) is routed to the boilers where it undergoes combustion/oxidation (secondary treatment) prior to being discharged to the atmosphere. A schematic flow chart of this process is presented below.

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System 2 – Abatement of foul air from the dryers This abatement process takes the foul air from the dryers and routes it through either cyclones or bag filters depending on the process line (primary treatment) to remove any particulates. Following this, the exhaust air is routed to a direct sea water scrubber (secondary treatment) followed by diversion to the burner (A1-3) (tertiary treatment) as make-up air. In the scrubbing stage the condensable fraction of gases (amines, ammonia, etc.) is condensed in the sea water and diverted to the process water streams and the non-condensable fraction (H2S, mercaptans, sulphides, etc) is routed to the burner where it undergoes combustion/oxidation prior to being discharged to the atmosphere. A schematic flow chart of this process is presented below. LT Plant

SD Plant

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System 3 – Abatement of foul air from the coolers/grinders This abatement process takes the foul air from the coolers and grinders and routes it through bag filters (primary treatment) to remove any particulates. Following this, the exhaust air is routed to a direct sea water scrubber (secondary treatment) followed by diversion to the burner (tertiary treatment) as make-up air. In the scrubbing stage, the condensable fraction of gases (amines, ammonia, etc.) is condensed in the sea water and diverted to the process water streams. The exhaust air is emitted to atmosphere through the new main emission point A2-1. A schematic flow chart of this process is presented below.

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E.1.C Emission Limit Values The following combustion gas emission limit values will apply to the boilers/burner for Stages 1 to 3 of the review application. The air dispersion model presented in Attachment I.1 model has demonstrated that the operation of the plant at these emission limits will not have an adverse impact on air quality or human health in the area.

Parameter Limit Type A1-1 A1-2 A1-3

Volume Flow Volume Flow

(Nm3/hr) 22,000 22,000 14,000

Nitrogen Oxides Concentration (mg/m3)

1,000 1,000 1,400

Nitrogen Oxides Mass Emission (kg/hr)

22.00 22.00 19.74

Sulphur Oxides Concentration

(mg/m3) 1,080 1,080 1,560

Sulphur Oxides Mass Emission

(kg/hr) 23.80 23.80 22.00

Carbon Monoxide Concentration (mg/m3)

100 100 100

Carbon Monoxide Mass Emission (kg/hr)

1.10 1.10 0.70

Particulates Concentration

(mg/m3) 50 50 50

Particulates Mass Emission

(kg/hr) 2.20 2.20 1.41

The following odour gas emission limit values will apply to the boilers/burner and the main emission point for Stages 1 to 3 of the review application. The air dispersion model presented in Attachment I.1 model has demonstrated that the operation of the plant at these BAT emission limits will not have an adverse impact on air quality or human health in the area.

Parameter Limit Type A1-1 A1-2 A1-3 A2-1

Volume Flow Volume Flow

(Nm3/hr) 22,000 22,000 14,000 19,000

Concentration (mg/m3)

30 30 30 30

Ammonia Mass Emission

(kg/hr) 0.15 0.15 0.15 0.15


5 5 5 5

Amines and Amides Mass Emission

(kg/hr) 0.11 0.11 0.07 0.09


5 5 5 5 Total hydrogen Sulphide, sulphides

and mercaptans (expressed as S)

Mass Emission (kg/hr) 0.015 0.015 0.015 0.015


50 50 50 50 Total Organic Carbon (as C) Mass Emission

(kg/hr) 0.50 0.50 0.50 0.50

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Site Boundary

Site Boundary

Site Boundary

A2-1(e)

A1-3(e)

A1-2(e)

A1-1(e)

Drawing Number

Drawing Status Sheet Size

Client

Rev

Drawing Scale

Amendment / IssueNo.

Project

Title

A3

/DateDrawn By Checked By Approved By

Date App

MDE1003DG0005F01.dwg

T +353 1 4882900F +353 1 2835676W www.rpsgroup.com/irelandE [email protected]

West PierBusiness CampusDun LaoghaireCo. Dublin, Ireland

1. Verifying Dimensions.The contractor shall verify dimensions against such otherdrawings or site conditions as pertain to this part of the work.

2. Existing Services.Any information concerning the location of existing servicesindicated on this drawing is intended for general guidance only. Itshall be the responsibility of the contractor to determine and verifythe exact horizontal and vertical alignment of all cables, pipes, etc.(both underground and overhead) before work commences.

3. Issue of Drawings.Hard copies, dwf and pdf will form a controlled issue of thedrawing. All other formats (dwg, dxf etc.) are deemed to be anuncontrolled issue and any work carried out based on these files isat the recipients own risk. RPS will not accept any responsibilityfor any errors arising from the use of these files, either by humanerror by the recipient, listing of un-dimensioned measurements,compatibility issues with the recipient's software, and any errorsarising when these files are used to aid the recipients drawingproduction, or setting out on site.

NOTES

4. Datum: Ordnance Survey Datum, Malin Head

UnitedFish Industries Ltd.,Killybegs

INTEGRATED POLLUTIONPREVENTION CONTROL APPLICATION

Ordnance Survey IrelandLicence No. EN 00050 11©Ordnance Survey Ireland andGovernment of Ireland

Map Number

10m SCALE 1:1000

E.1(i)

Emissions to Atmosphere

Final 1:1,000 @ A3

MDE1003 DG0005 F01

10/06/11P. ChadwickK. MurphyD. Byrne

F01 FINALDBKM

PC

Killybegs, Co. Donegal

LOCATION PLAN - 1:12,500

UNITED FISH INDUSTRIES LTD. SITEKillybegs,Co. Donegal

EMISSION POINTS:Symbol Key -Emissions to Atmosphere

A1-1(e),etc

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United Fish Industries IPPC Licence Application ATTACHMENT E.2 EMISSIONS TO SURFACE WATERS Contents Summary list of all emission points, including surface water runoff and storm water drains Map of all surface water emission points Specific information in relation to emissions of substances listed in the Schedule of S.I. No. 394 of 2004 Detailed descriptions and schematic of abatement systems For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system Details of planned programme of improvement

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Attachment E.2 – Emissions to Surface Waters E.2.A Details of all emissions to surface water There are five emission points to surface waters on the site including one discharge of sea water used in the process and four discharges of surface water run-off. Sea water discharge (SW1) The main emission to surface water is the sea water discharge. This discharge is comprised mainly of the sea water used to condense process vapours but it also includes the condensate from the evaporation process, drier vapours and water from the vacuum pumps. This emission point is presented below:

• SW1 - (formerly W1) surface water discharges into Killybegs Harbour at a point east of the plant.

The location of this emission point is illustrated in Maps E.2(i) and E.2(ii). Information on the baseline condition of the receiving water is included in Attachment I.2 . Surface water is monitored on a continuous basis for pH, flow and temperature. Monitoring is carried out on a weekly basis for BOD, suspended solids and ammonia (as N) on a fortnightly basis for fats, oils and greases and on a monthly basis for nitrates (as N) and phosphate (as P). Monitoring is carried out on a bimonthly basis for detergent (as MBAS) and as agreed with the EPA for toxicity. Historical compliance issues have been recorded for BOD and ammonia from this discharge. These compliance issues relate to the use of concentration limits on a non-uniform batch process where mass loading limits which are more applicable to this discharge. Following a Technical Amendment of the IPPC licence granted in November 2009, whereby BOD and ammonia limits are defined as mass emissions rather than concentrations (up to 31st December 2011), compliance issues relating to this discharge were significantly reduced in 2010. However, it should be noted that production and the subsequent discharges are totally dependent on the availability of raw material and therefore dependant on national fishing stocks. In 2010, the availability of raw material was reduced and therefore production levels have dropped (60,989 tonnes of raw material processed). Accordingly, the associated tonnage processed per day has reduced. This would be a contributory factor to the high levels of compliance achieved in 2010. Based on projected changes in the fishing industry there is predicted to be significant increases in the availability of raw material to the UFI plant in future years. As such, the levels of discharge to SW1 may increase on the 2010 levels, so the limits sought for Stages 1 and 2 of this application are identical and based on the existing IPPC license limits for SW1 in addition to the Stage 2 mass loading limits sought under the Technical Amendment request in 2009. These limits are presented in Section E.2.B of this attachment. This emission to surface water contains the following polluting substances listed in S.I. 394 of 2004 (EPA Licensing Regulations):

• Materials in suspension; • Substances which contribute to eutrophication (in particular, nitrates and phosphates); • Substances which have an unfavourable influence on the oxygen balance (and can be

measured using parameters such as BOD, COD, etc.).

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There are no List I substances listed in the Annex to EU Directive 76/464/EEC (as amended), in the emissions to surface waters from the plant. The following List II substances are present in the discharge:

• Inorganic compounds of phosphorus and elemental phosphorus; • Substances which have an adverse effect on the oxygen balance, particularly ammonia and

nitrites.

Programme of improvement While the discharges from SW1 are typically in compliance with the limits presented in Schedule 2(i) of the Technical Amendment, these limits are not in line with the limits expressed in Table 6.2 of the BAT Guidance. Therefore, a planned programme of improvement is proposed, in three stages, to achieve the limits expressed in the BAT Guidance: Stage 1 : The plant will operate as per the current IPPC limits (Licence Register P0416-01) and the mass emission limits requested for Stage 2 (BOD and Ammonia) in the request for Technical Amendment in 2009. These limits are presented in Section E.2.B of this attachment. It is proposed that this will be the case up to the end of 2011 as per Schedule 2(i) of the Technical Amendment. Stage 2 : The plant will operate as per the current IPPC limits (Licence Register P0416-01) and the mass emission limits requested for Stage 2 (BOD and Ammonia) in the request for Technical Amendment in 2009. There is a slight reduction in the Ammonia mass flow limit from Stage 1 to reflect the impact of the diverted streams. The limits are largely similar to Stage 1 (with the exception of the Ammonia mass flow limit) to allow for the regularisation of this emission point when predicted production increases occur during Stage 2. Some improvement may be achieved by re-routing some of the process water streams (condensate from evaporation and vacuum pump water) from SW1 to the DAF plant which discharge to sewer SE1 (formerly S1, refer Section E.3). This is reflected in the reduced Ammonia mass loading limit but the other limits remain as per Stage 1. It is proposed that the limits will apply to the discharges to water from SW1 (W1) from the 1st January 2012 until the stage 3 improvements are in place on 1st January 2016. Stage 3 : The emission to surface water from SW1 (W1) will comply in full with the emission levels for discharges to water as specified in Table 6.2 of the BAT Guidance Note for the Manufacturing of Fish Meal and Fish Oil. This will be achieved through process modification whereby the sea water which is currently contaminated through direct scrubbing will instead be used for indirect scrubbing (thus removing the direct contact between sea water and process air condensing and vapour) ensuring that the sea water is discharged at the same quality as when it was taken into the process, though with a temperature difference. The planned infrastructural works will require significant financial resources and time to implement and therefore it is proposed that the BAT limits apply from 1st January 2016. A hydrodynamic model of the Stage 3 scenario is included in Attachment I.2 and demonstrates compliance with water quality standards established under the umbrella of the Water Framework Directive. Full details of the characteristics of the emission to water from SW1 at each stage are presented in Table E.2(i) and (ii). The limits for each stage are presented in Section E.2.B of this attachment.

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Abatement In 2010 UFI installed a particle washer downstream of the steam dryer to reduce the amount of organic particulate matter in the sea water discharge, thereby reducing the BOD loading. The system essentially washes the vapour from the dryer and any particles recovered are returned to the process. A schematic of this abatement system is included below. Further details of abatement are presented in Table F.1(i) in the main application document. The net efficiency and impact of this particle washer has yet to be fully established as low production figures in 2010 have resulted in the low utilisation of this line.

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Surface water runoff discharges (SW2 – SW5) The four additional discharges to surface water are comprised of uncontaminated rainwater run-off from the buildings and hard standing areas. Seven discharges are noted in Schedule 5(i) of the current licence but three of these discharges (W5, W6 and W7) have been discontinued. The remaining discharges are: • SW2 (formerly W2); • SW3 (formerly W3); • SW4 (formerly W4); • SW5 (formerly W8);

The discharges are into Killybegs Harbour at points around the perimeter of the site. The location of these emission point are illustrated in Map E.2(i). Information on the receiving water is included in Attachment I.2 . Quarterly monitoring of pH, COD and conductivity at these discharges indicates full compliance with the limits presented in Table 6.2 of the BAT Guidance. No pollutants listed in List I and List II substances of the Annex to EU Directive 76/464/EEC (as amended) or the Schedule of the EPA (Licensing)(amendment) Regulations, 2004 (S.I. No. 394 of 2004) are discharged from these points. Details of all emission points are presented in Tables E.2(i) and (ii). Abatement No additional abatement is required beyond continued good practice at the site.

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E.2.B Emission Limit Values for Discharges to Surface Water The table presented below presents the proposed emission limits values for SW1 through the three stages of the review application. The three stages show a planned program of improvements to meet the BAT limits for discharges to surface water by Stage 3. There are no proposed emission limit values for the surface water runoff emission points (SW2 to SW5). Periodic grab sampling will be carried out on these discharges.

Parameter Stage 1 Stage 2 Stage 3

Commencement Date Grant of Final Determination 1st January 2012 1st January 2016

Volume (m3/day) 10,000 10,000 36,000

Temperature (0C) 40 40 40

pH 6 to 9 6 to 9 6 to 9

BOD (kg/day) 500 500 -

BOD (mg/l) - - 40

Oils, Fats and Greases(mg/l)

15 15 15

Suspended Solids(mg/l) 100 100 50

Ammonia (as N) (kg/day) 250 200 -

Ammonia (as N) (mg/l) - - 10

Phosphate (as P) (mg/l) 2 2 2

Detergents (mg/l) 100 100 100

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Site Boundary

Site Boundary

Site Boundary

SW1(e)

SW2(e)

SW3(e) SW4(e)

SW5(e)

Drawing Number


Client

Rev

Drawing Scale


Project

Title

A3


Date App







NOTES





Map Number

10m SCALE 1:1000

E.2(i)

Emissions to Surface Water

Final 1:1,000 @ A3

MDE1003 DG0007 F01


F01 F01DB

KMPC




EMISSION POINTS:Symbol Key -Emissions to Surface Water

SW2(e),etc.

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United Fish Industries IPPC Licence Application ATTACHMENT E.3 EMISSIONS TO SEWER Contents Map of emission point For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system Details of planned programme of improvement

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Attachment E.3 – Emissions to Sewer E.3.A Details of emission to sewer There is one emission to sewer, SE1 (formerly S1). The current location of this emission is illustrated in Map E.3(i). The location marked “existing sewer connection” is that currently employed and will be employed for Stage 1 of this application. The location marked “proposed sewer point” will be the new location for the connection to the Donegal County Council sewer network for Stages 2 and 3 of this application. This emission is comprised of all process water from the operation including:

• Washings from the lorry wash-down area; • Washing from general plant area wash-down activities; • Separator flushings; • Washings from general cleaning in place (CIP); • Pump cooling water; • Rainwater.

The process water is currently collected, routed through a double DAF plant on site, and discharged to Donegal County Council’s foul sewer which enters Killybegs waste water treatment plant. Further information on the waste water treatment plant is included in Attachment I.3 . The emission to sewer is monitored on a continuous basis for pH, flow and temperature. Monitoring is carried out on a daily basis for suspended solids and ammonia (as N), a weekly basis for BOD, a fortnightly basis for fats, oils and greases and a monthly basis for nitrates (as N) and phosphate (as P). Monitoring is carried out on a bimonthly basis for detergent (as MBAS) and as agreed with the EPA for toxicity. Monitoring at this discharge indicates historical compliance issues, principally in relation to BOD and ammonia (as N). As with the surface water emission, a factor in the number of instances of non-compliance is the application of emissions limits in the form of concentrations where mass limits are more applicable (due to the non-uniform batch nature of the activity). Following the granting of the Technical Amendment in November 2009, Schedule 3(i), the concentration limit for BOD and ammonia (as N), has been removed and so the mass loading limit applies. Since granting the Technical Amendment, the level of compliance from this discharge has greatly increased. However, as noted throughout this application this may be also associated with a reduced throughput in the plant in 2010. This emission to sewer contains the following polluting substances listed in S.I. 394 of 2004:

• Materials in suspension; • Substances which contribute to eutrophication (in particular, nitrates and phosphates); • Substances which have an unfavourable influence on the oxygen balance (and can be

measured using parameters such as BOD, COD, etc.).

There are no List I substances listed in the Annex to EU Directive 76/464/EEC (as amended), in the sewer emissions. The following List II substances are present in the discharge:

• Inorganic compounds of phosphorus and elemental phosphorus; • Substances which have an adverse effect on the oxygen balance, particularly: ammonia,

nitrites.

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Programme of Improvement This planned improvement is set out in three distinct stages as outlined below: Stage 1: The plant will operate according to the current conditions specified in Schedule 3(i) of the Technical Amendment to Licence Register P0416-01. The current abatement (double DAF Unit) will remain in operation and the location of the discharge point will remain unchanged. It is proposed that situation will continue up to the end of 2011. UFI have agreed limits for this discharge with Donegal County Council and these are presented in Section E.3.B of this attachment. Stage 2: Once Donegal County Council’s long sea outfall is operational, the emissions will be discharged further south in the outer harbour where the dilution capacity is greater, and consequently the potential impact is lower. Hydrodynamic modelling of the potential impact of the discharge at this location has been used by Donegal County Council to demonstrate that the emission would not severely impact the outer harbour and to set emission limit values for all plants discharging to this sewer. There is a planned increase in emissions to SE1 from the UFI plant as a result of the diversion of some of the SW1 streams to SE1. A set of limits for Stage 2 have been agreed with Donegal County Council and these are presented in Section E.3.B of this attachment. It is proposed that the long sea outfall (currently under construction) will be operational by the end of 2011 and that the stage 2 limits will take effect from January 2012. Stage 3: The emissions to sewer for stage 3 will increase from the stage 2 scenario for two key reasons, the increased diversion of the SW1 streams and proposed increases in capacity of the plant. A set of limits for Stage 3 have been discussed with Donegal County Council and have yet to be fully agreed and these are presented in Section E.3.B of this attachment. Details of process effluent at the various stages are provided in Tables E.3(i) and E.3(ii).

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Abatement Below is a schematic of a sample DAF system. Additional details on the state of the art Nijhuis double DAF system employed at the UFI facility is supplied in Attachment F.1 .

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E.3.B Emission Limit Values for Discharges to Sewer The table presented below presents the proposed emission limits values for SE1 through the three stages of the review application. There is a cumulative increase throughout the three stages for two key reasons:

• The diversion of SW1 streams to SE1 during both Stage 2 and Stage 3. This changes the emission point of this discharge from the inner harbour with limited dilution to the outer harbour with a significantly increased dilution capacity and reduced impact.

• The planned increase in capacity at the plant from 800 tonnes or raw material per day to

1200 tonnes. UFI have been engaged in discussions with Donegal County Council to agree a set of limits for the three stages. UFI have presented flow and load calculations to demonstrate the loading to SE1 during the stages. Donegal County Council have generated a hydrodynamic model of the long sea outfall to determine total acceptable loading in the sewer. This total loading is treated as a cap and Donegal have identified an agreeable share of this loading from the UFI plant to generate a set of limits. Limits have been agreed for Stages 1 and 2 and the limits for Stage 3 are largely agreed between the parties with formal agreement yet to be reached. The proposed limits are presented in the table below.

Parameter Stage 1 Stage 2 Stage 3

Commencement Date Grant of Final Determination

1st January 2012 1st January 2016

Volume (m3/day) 1200 1500 2000

Temperature (0C) 25 30 30

pH 6 to 9 6 to 9 6 to 9

BOD (kg/day) 1200 3500 5750

Oils, Fats and Greases(mg/l)

15 100 150

Nitrates (mg/l) 50 70 120

Suspended Solids(mg/l) 100 150 200

Ammonia (as N) (kg/day) 60 300 540

Phosphate (as P) (mg/l) 100 150 105

Detergents (mg/l) 100 150 100

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Site Boundary

Existing Sewer Connection

Proposed Sewer Point

Drawing Number


Client

Rev

Drawing Scale


Project

Title

A3


Date App







NOTES





Map Number

10m SCALE 1:1000

E.3(i)

Emissions to Sewer: Ex. & Prop. Points

Final 1:1,000 @ A3

MDE1003 DG0008 F01


F01 FINALDBKM

PC




SEWER POINTS:Symbol Key -Existing Sewer Point


Existing Sewer Point


UFI SITE

TO

SIT

E

manhole near the graveyard

outside the fence near Garage

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United Fish Industries IPPC Licence Application ATTACHMENT E.5 NOISE EMISSIONS Contents Details of the source, location, nature and level of noise emissions and the periods during which the noise emissions are made Map of locations of noise emissions For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system Details of planned programme of improvement

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Attachment E.5 – Noise Emissions E.5.A Details of all noise emissions There are 12 sources (some are doubles – such a two driers, etc)of noise emissions on the site: • Seawater tank; • Seawater tank pump; • Scrubber plant; • Tank farm; • DAF plant, • Steam vent (LT Dryer); • Cooling tower; • LT Plant – MVR Fan (Internal); • LT Plant – dryer kiln (Internal); • LT Plant – fans (Internal); • LT Plant – grinders Fan (Internal); • Raw Material Intake Conveyor The locations of these noise emissions are illustrated in Map E.5(i). Details in relation to noise levels and noise quality are listed in Tables E.5.1 and E.5.2. It should be noted that the Raw Material Intake Conveyor (N12) was not operational during the noise source assessments carried out at the plant so there is no source or tonal information available on this source.

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Table E.5.1 Main Noise Source Data.

Reference Source LAeq [dB]

LAFmin [dB]

LAFmax [dB]

LAF10 [dB]

LAF90 [dB]

Notes

N1 Seawater Tank 66.9 65.9 67.7 67.3 66.5

Continuous gush of sea water from flume to tank. Pump also clearly audible

N2 Seawater Tank Pump 81.4 80.1 82.2 81.8 81.0

Load and tonal noise from sea water pump. No other sources audible

N3 Scrubber Plant 79.7 79.0 80.6 80.1 79.4 Low drone from pumps at seawater scrubbers N4 Tank Farm 74.5 73.8 75.0 74.8 74.3 High pitch from pump on Tank Farm N5 DAFF Plant 71.0 69.2 73.3 71.9 69.9 Low drone but Seawater pump clearly audible N6 Steam Vent (LT

Dryer) 82.2 77.7 85.4 83.7 79.9 Steam vent on south façade of LT Plant (measurement from 10m)

N7 Cooling Tower 72.2 68.7 73.8 72.9 71.3

Cooling tower to south of LT Plant (enclosed in acoustic barrier)

N8 LT Plant – MVR Fan (Internal) 98.4 97.6 99.3 98.8 98.0

Measurement B at 1m to 2 internal MVR Fans to LT Dryer Plant

N9 LT Plant - Drier Kiln (Internal) 86.5 85.7 87.9 87.0 86.1

Measurement at 1m of main dryer kiln for LT Plant

N10 LT Plant - Fans (Internal) 96.8 95.5 97.6 97.2 96.3 Measurement at 1m to fans (1st floor)

N11 LT Plant - Grinders (Internal) 95.0 93.8 96.2 95.7 94.3 Measurement at 1m to grinder (1st floor)

N12 Raw Material Intake Conveyor 80.9 - - - - Measurement at 1m from drag link

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Table E.5.2 Tonal Noise Source Data. Source Referen

ce Sound Pressure

31.5Hz 63Hz 125Hz 250Hz 500Hz 1KHz 2KHz 4KHz 8kHz Impulsive/Tonal Period of Emission

Seawater Tank

N1 66.9 - - 36.4 43 54.2 58.8 55.1 50.3 42.9 Tonal Continuous

Seawater Tank Pump

N2 81.4 - 32.9 42.8 57.7 68.4 71.5 71.0 62.2 47.5 Tonal Continuous

Scrubber Plant


Tank Farm N4 74.5 - 36.3 42.9 51.8 60.3 60.0 61.3 63.4 63.4 Tonal Continuous DAFF Plant


Steam Vent (LT Dryer)


Cooling Tower


LT Plant – MVR Fan


LT Plant - Drier Kiln


LT Plant - Fans


LT Plant - Grinders


Raw Material Intake Conveyor

N12

80.9 - - - - - - - - - No Continuous

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In December 2010, a noise survey was carried out by Environmental Efficiency Consulting Engineers. The survey was carried out during the peak production period. General weather conditions and low wind speeds were ideal for noise measurement, however, there was residual snow/sludge on the ground which may have impacted the background levels. The results of the survey are presented in Table I.7(i) in the main application document and a full copy of the report is included in this attachment. A summary of the noise levels recorded is presented in Table E.5.3 below: Table E.5.3: Summary results of annual noise survey 2010

Ref Location Daytime (LAeq)

Daytime (LA90)

Night time (LAeq)

Night time (LA90)

NSL1 NSL 1 (Parkhead Housing Estate)

60.1 51.1 58.1 50.4

NSL2 N2 (Super Value car park) 73.9 57.4 68.0 58.3 NSL3 N3 (Breslin’s Shop) 68.0 51.4 69.2 60.1

IPPC Limit 55 - 45 - The monitoring demonstrates that during daytime hours the LAeq levels are above the emission limit (55dBA). However, this is due to short term noise sources such as traffic on the public roads. T LA90 value is more representative of the continuous noise coming from the plant. The LA90 level results indicate that at noise receptor NSL1, the UFI facility is in full compliance with the daytime limits expressed in Condition 9.2 of the IPPC licence (Register No. P0416-01), including the sensitivity limits expressed in Condition 3.4.1. However, at night the LA90 levels at NSL1 are above the night-time limit (45dBA). The report notes that plant noise was audible at this location when measurements were being taken. In addition, while no impulsive noises are noted, there is an identified tonal component to the noise from the plant. A follow up daytime survey carried out by RPS in February 2011 verified these results. The results of the RPS survey are presented in Table E.5.4. It should be noted that these surveys were halted to eliminate, insofar as possible, short term traffic noise and this accounts for the variation in the LAeq between the surveys.

Table E.5.4: Summary results of follow up survey in 2011. Location Daytime (LAeq) Daytime (LA90)

NSL 1 (Parkhead Housing Estate) 53.2 50.3 NSL2 (Super Value car park) 55.8 52.0

IPPC Limit 55 - Again, during the RPS survey a tonal component was noted arising from the UFI facility and the main sources of audible noise were the steam vent release valve on the outer walls of the LT Plant (hissing sound) and the general plant noise from the LT plant (low drone). It should be noted that the steam vent on the LT Dryer Building (N6) is due to be removed in the summer of 2011 as part of the ongoing noise management plan at the facility. The principle sources of noise noted on the site and the key noise criteria are listed in Table E.5.1. In addition, the tonal data for these sources is presented in Table E.5.2. These noise sources were identified on-site on the 14th February 2011 and represent the key sources on site. Noise sources that were internal are noted as such in both tables.

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Programme of improvements and abatement Details of the proposed planned programme of improvements are included in the form of a noise management and mitigation report included in Attachment I.7 . This report outlines the key measures that should be adopted to manage on-site noise and meet BAT requirements during Stages 2 and 3 of this application. Committed measures include the following:

• Removal of the steam vent on the LT Dryer Building (N6) during the summer of 2011.

• Localised abatement around the raw material intake conveyor system (N12) to the eastern boundary of the plant, closest top the sensitive receptors.

• Ongoing operational changes at the site such as material acceptance procedures,

maintenance schedules, etc. to reduce the potential for noise. Further details are presented in Attachment I.7 .

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Page 1 of 14Tel: 353 1 276 1428 Fax: 353 1 276 1561 Email:[email protected]

www.enviro-consult.com

Registered Office as above. Registered Number 243 412

Environmental Noise Survey

For

United Fish Industries Document Number: 1297-01

Version 2.00

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United Fish Industries Environmental Noise Survey 2010

Environmental Efficiency Consultants (Ire) Ltd. Page 2 of 14 Document No1297-01 v2.00

QF 1. v2 Document Lead Sheet Document Title Environmental Noise Survey Project No. 1297 Document No. 1297-01 Client United Fish Industries Address Donegal Rd, Killybegs, Co. Donegal

Signed for and on behalf of Issue Status Date Author Environmental

Efficiency Client

1.00 Approved 22/12/2010 EF

2.00 Approved 16/05/2011 EF

Where it is a requirement that this report be issued to a regulatory or other authority,

then the client should sign the appropriate place in the above table and, unless

specifically agreed in writing to the contrary, forward copies to the appropriate

authority (e.g. EPA).

EEC Project Manager: Bob Sutcliffe, CEng, MIMechE

EEC Document Author: Enda Flood, B Ag Sc, PgC Green Tech

Conditions relating to the issue of this report:

1. No alteration to this report by third parties is permitted

2. Where this report is reproduced, it shall only be reproduced in full.

3. Reports remain the property of Environmental & Efficiency Consultants

(Ireland) Limited until paid for in full.

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Table of Contents

1. INTRODUCTION...................................................................................................................4

2. NOISE......................................................................................................................................4

3. SUMMARY .............................................................................................................................4

4. SAMPLING METHODOLOGY AND ANALYTICAL TECHNIQUES...............................5

4.1 INSTRUMENTATION USED..................................................................................................5 4.2 NOISE SURVEY PERSONNEL...............................................................................................5 4.3 METEOROLOGICAL CONDITIONS........................................................................................5 4.4 MEASUREMENT POSITIONS................................................................................................6 4.5 MEASUREMENT LOCATIONS..............................................................................................6

5. NOISE SURVEY .....................................................................................................................7

6. DISCUSSION ........................................................................................................................ 10

7. CONCLUSION...................................................................................................................... 10

Figure 5-1 Day Time Noise survey results ................................................................. 9 Figure 5-2 Night Time Noise Survey ......................................................................... 9

Table 4-1: Equipment Used to Conduct Noise Monitoring Surveys ........................... 5 Table 4-2 Day Time Weather Conditions................................................................... 6 Table 4-3 Night Time Weather Conditions ................................................................ 6 Table 4-4 Description of monitoring locations ........................................................... 6 Table 5-1: Environmental Noise Monitoring Results – Day time ............................... 8 Table 5-2: Environmental Noise Monitoring Results – Night time............................. 8

Appendix 1 Report Terminology ..............................................................................11 Appendix 2 Certificates of Calibration......................................................................12

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1. Introduction

United Fish Industries has an IPPC licence, P0416-1. This licence requires annual

environmental noise monitoring. Environmental Efficiency Consultants Limited was

commissioned by United Fish Industries to carry out this monitoring.

This environmental noise survey carried out on 26/11/2010 has been undertaken in

accordance with the EPA publication ‘Environmental Noise Survey Guidance

Document’ (2003) and relevant standard BS 4142 ‘Method for Rating Industrial Noise

Affecting Residential and Industrial areas’ (1997).

2. Noise

Excessive noise from development and commercial sites can have a significant

adverse effect on those living in close proximity to such sites. In Ireland, there are no

statutory limits for noise emissions or ambient noise levels; however the

Environmental Protection Agency (EPA)1 has produced noise guidelines, which

define the levels of acceptability in relation to noise from industrial/commercial

operations. The EPA endorse limit values of a maximum of 55 dB(A) during daytime

hours2 and night-time values of 45 dB(A). These values should be measured at the

identified noise sensitive locations (NSLs). A Noise sensitive location is described by

the EPA as follows: -

‘Any dwelling, hotel or hostel, health building, educational establishment, place of

worship or entertainment, or any other facility or area of high amenity, which for its

proper enjoyment requires the absence of noise at nuisance levels3’.

3. Summary The noise levels recorded at the identified noise sensitive locations i.e. nearest

residential dwellings are determined to be below the specified emission limit values

during the day, but to exceed the emission limit values during the night.

1 EPA (2006) Guidance Note for Noise in Relation to Scheduled Activities. 2nd Edition 2 Daytime hours (08.00-22.00): Night-time hours (22.00-08.00) 3 Guidance Note for Noise in Relation to Scheduled Activities, 2nd Ed. (2006) EPA

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4. Sampling Methodology and Analytical Techniques

4.1 Instrumentation Used

For a description of noise source type and other terminology used please refer to

Appendix 1. The following equipment was used during the noise assessment:

Table 4-1: Equipment Used to Conduct Noise Monitoring Surveys

Equipment Model (Cirrus) Serial No. EEC Lab ID.

Sound Level Meter (SLM) (Type 1) CR: 811B C16569FD LEN 002

Microphone MK: 224 20020028 N/A

Calibrator CR: 511E 035066 LEN 003

Tripod N/A N/A N/A

The noise measurements were ‘A’ weighted and the time-weighting ‘Fast’ was

applied (to equate to human ear hearing). The SLM were calibrated to 93.7 dB (A) on-

site immediately before measurement and reassessed on completion. No drift in

calibration level was recorded. See Appendix 2 for certificate of calibration. The

noise survey was carried out in accordance with EEC Standard Operating Procedure -

SOP 1.28.

The noise monitoring and report have been undertaken in accordance with the EPA

publication ‘Environmental Noise Survey Guidance Document’ (2003) and relevant

standard BS 4142 ‘Method for Rating Industrial Noise Affecting Residential and

Industrial areas’ (1997).

4.2 Noise Survey Personnel

The noise survey was undertaken by Environmental Efficiency Consultants (Ire) Ltd.,

environmental consultant, Richard McElroy, BEng, Env Eng

4.3 Meteorological Conditions

Information on temperature, wind speed and wind direction was taken using an

anemometer and compass (SOP 1.29). Weather conditions during the monitoring

periods were considered appropriate for surveying purposes and therefore did not

affect the readings i.e. conditions were dry and wind speed was less than 5 m/s (the

normal upper limit for taking measurements). The Sound Level Meter was also fitted

with a windshield to minimise interference from potential meteorological conditions,

in keeping with good practice. The meteorological conditions for each noise survey

undertaken are provided in Table 4-2.

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Table 4-2 Day Time Weather Conditions

Location Ref.

Date Time Max windspeed m/s

Average windspeed m/s

Wind direction

Temperature

NSL 1 26/11/2010 17:45 1.6 0.8 NW 10C

N2

Supervalu 26/11/2010 18:18 2.1 1.3 NW 00C

N3

Breslin’s 26/11/2010 18:38 0.9 0.6 NW 00C

Table 4-3 Night Time Weather Conditions

Location Ref.

Date Time Max windspeed m/s

Average windspeed m/s

Wind direction

Temperature

NSL 1 26/11/2010 22:00 1.2 0.9 NW 00C

N2 26/11/2010 22:22 2.2 1.0 NW 00C

N3 26/11/2010 22:38 1.8 0.9 NW 00C

4.4 Measurement Positions

All measurements were taken at between:

• 1.2 – 1.5 m height above local ground level

• 1 - 5 m away from reflective surfaces

4.5 Measurement Locations

The locations of noise monitoring points are described in Table 4-4. All readings were

taken during daytime operating hours when the facility was in operation and all

equipment was in use.

Table 4-4 Description of monitoring locations

Reference Location Description NSL 1 Entrance to Residential property opposite facility

N2 Entrance to Super Value Car park N3 Beside Breslin’s Shop at facility boundary

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5. Noise Survey The measurement results for the monitoring locations at United Fish Industries are

available below. Associated particulars such as a description of the noise recorded in

each location are also provided. A graphical representation of the average noise level

(dB(A) –LAeqt) over each monitoring period is provided in Figure 5.1.

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Table 5-1: Environmental Noise Monitoring Results – Day time

Parameter & result dB(A) Location

No. Time Leq (15)

L 90

Description of On-site Noise

Sources

Description of Off-site Noise

Interference On site tonal component?

On site impulsive

component?

Adjustment rating level

LRE

NSL 1 17:54 60.1 51.1 Process Equipment Traffic on N56 Slush on road caused by previous snow fall

Yes (Process Noises)

No 56.1

N2 18:18 73.9 57.4 Process Equipment

Traffic on N56 Traffic entering/leaving Super Value Car park Slush on road caused by previous snow fall


No 62.4

N3 18:38 68.0 51.4 Process Equipment

Traffic on N56 Slush on road caused by previous snow fall Traffic at shop


No 56.4

* Emission limit values as specified in the EPA (2003) Environmental Noise Survey Guidance Document

Table 5-2: Environmental Noise Monitoring Results – Night time

Parameter & result dB(A) Location

No. Time Leq (15)

L 90

Description of On-site Noise

Sources

Description of Off-site Noise

Interference On site tonal component?

On site impulsive

component?

Adjustment rating level

LRE

NSL 1 22:00 58.1 50.4 Process Equipment Traffic on N56 Slush on road caused by previous snow fall


No 55.4

N2 22:22 68.0 58.3 Process Equipment Traffic on N56 Slush on road caused by previous snow fall


No 63.3

N3 22:38 69.2 60.1 Process Equipment Traffic on N56 Slush on road caused by previous snow fall


No 65.1

* Emission limit values as specified in the EPA (2003) Environmental Noise Survey Guidance Document

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Noise Monitoring Day-Time 26th November 2010

-

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

NSL1 N2 N3

Noise Monitoring Location References

dB

(A)

LAeq

L90

L90 + tonal penalty

55dB

57dB

Figure 5-1 Day Time Noise survey results

Noise Monitoring Night-Time26th November 2010

0

10

20

30

40

50

60

70

80

NSL1 N2 N3

Noise Monitoring Location References

dB

(A)

LAeq

L90

L90 + tonal penalty

45dB

47dB

Figure 5-2 Night Time Noise Survey

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6. Discussion

There is one Noise Sensitive Location (NSL) for this site and therefore it is subject to a limit of 55 dBA + 2 dBA during the day and 45 dBA + 2 dBA during the night. There are two other monitoring locations but these are not NSLs and therefore limits do not apply. At NSL1 the day time reading for LAeq(15) was 60.1 dBA and therefore exceeded the limit of 55 dBA. However, due to recent snowfalls turning to slush there was considerable background noise due to traffic. L90 is therefore a more realistic measure of the noise from the site. The L90 reading was 51.1 dBA. This value is below the limit. However, there was also tonal noise detected at NSL1 and a 5 dBA penalty has to be added as per EPA Guidance. Thus the daytime noise level at NSL1 is 56.1. This value is below the 55 dBA limit + 2 dBA allowance. At NSL1 the night time reading for LAeq(15) was 58.1 dBA and therefore exceeded the limit of 45 dBA. However, due to recent snowfalls turning to slush there was considerable background noise due to traffic. L90 is therefore a more realistic measure of the noise from the site. The L90 reading was 50.4 dBA. In addition, there was also tonal noise detected at NSL1 and a 5 dBA penalty has to be added as per EPA Guidance. Thus the night time noise level at NSL1 is 55.4. This value exceeds the 45 dBA limit + 2 dBA allowance. For both N2 and N3, L90 has again been used as a more representative measurement of site noise. Adding the penalty for tonal noise causes the resulting noise levels to be above the respective day and night time limits. However, these are not noise sensitive locations so the limits are no applicable.

7. Conclusion

The results for NSL 1 are below the limits set for this facility for day time but above the limits for night. The noise measurements have been adjusted for the presence of tonal noise.

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Appendix 1 Report Terminology

Noise Monitoring Parameters

dB(A) This is the unit used to quantify noise measurements. "dB" stands for decibel and the "A" indicates that the noise reading is A-weighted and therefore is a measurement of noise audible to the human ear. The scale is logarithmic.

dB(A) –LAeq(t) This parameter is measured on-site using a noise meter for a specified time period (in this case 15 minute and one hour). It represents the average noise level that occurred over that period.

L 10 and L90

The L10 and L90 are both statistical noise levels. L10 indicates that for 10% of the monitoring period, the sound levels were greater than the quoted value. L90 indicates that for 90% of the monitoring period, the sound levels were greater than the quoted value. The L90 indicates the background noise levels if short-term, intermittent noise sources were ignored e.g. a passing car. The L10 can be used to determine the effect to which these short-term noise sources effect the overall average reading i.e. if the L10 is very different to the L90, then intermittent noise is a significant source of noise

Continuous Noise produced without interruption.

Impulsive Noise A noise of short duration (typically less than one second), the sound pressure of which is significantly higher than the background; brief and abrupt

Intermittent Noise Noise produced on discontinuous basis e.g. equipment operating in cycles or events such as single passing vehicle or aircraft.

Tonal Noise Noise, which contains a clearly audible, tone i.e. a distinguishable, discrete or continuous note (whine, hum, drone, screech, etc.).

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Appendix 2 Certificates of Calibration

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Site Boundary

Site Boundary

Site Boundary

N6(e)

N1(e)

N5(e)

N2(e)

N4(e)

N3(e)

N8(e)

N11(e)

N10(e)

N9(e)

N7(e)

N12(e)

Drawing Number


Client

Rev

Drawing Scale


Project

Title

A3


Date App







NOTES





Map Number

10m SCALE 1:1000

E.5(i)

Noise Emissions

Final 1:1,000 @ A3

MDE1003 DG0009 F01


F01 FINALDBKM

PC




EMISSION POINTS:Symbol Key - Noise Emissions N2(e), etc

Point being repaired -30th June 2011

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United Fish Industries IPPC Licence Application ATTACHMENT E.6 TABULAR DATA ON EMISSION POINTS Contents Tabular data on emission points (paper and CD-Rom)

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Attachment E.6 – Tabular Data on Emission Points Table E.6.1 Tabular data on emission points Point Code Point Type Easting Northing Verified A1-1 E 172238.79 377532.97 No A1-2 E 172234.57 377537.17 No A1-3 E 172235.75 377619.20 No A2-1 E 172244.00 377542.00 No SE1 (Stage 1) E 172045.00 377245.00 No SE1 (Stage 2 and 3) E 172170.00 377467.00 No SW1 (Stage 1 and 2) E 172320.07 377411.00 No SW1 (Stage 3 - extended outfall location) E 172288.27 377057.69 No SW1 (Stage 3 - landing pier location) E 171629.89 376570.66 No SW2 E 172216.31 377436.84 No SW3 E 172284.73 377491.63 No SW4 E 172292.87 377525.21 No SW5 E 172216.52 377463.61 No N1 E 172216.52 377463.61 No N2 E 172224.00 377476.00 No N3 E 172237.24 377473.40 No N4 E 172247.00 377509.00 No N5 E 172244.55 377538.54 No N6 (being repaired - 30 June 2011) E 172243.03 377607.49 No N7 E 172244.70 377608.30 No N8 E 172256.13 377608.30 No N9 E 172253.04 377616.51 No N10 E 172246.31 377616.51 No N11 E 172251.72 377610.63 No N12 E 172210.37 377548.00 No

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