Re. Glenmore Biogas Ltd.: Reg. No. P1004-02 Response to FI ... · Re. Glenmore Biogas Ltd.: Reg. No. P1004-02 – Response to FI Letter In response to your letter dated 5th May 2015,

ENVEST ENVIRONMENTAL LTD. Innovation in Business Centre, GMIT, Westport Road, Castlebar, Co. Mayo. www.envest.ie Registered in Ireland (Company Reg. No: 517536 / Company Tax Reg. No.: 9841869R, Directors: M. Keegan, C. Staunton)

Ref: ENV-1367/CS/08 Date: 11th May 2015 Ms Elizabeth Leacy Administration Officer Office of Climate, Licensing and Resource Use Environmental Protection Agency Johnstown Castle Estate County Wexford Dear Elizabeth,

Re. Glenmore Biogas Ltd.: Reg. No. P1004-02 – Response to FI Letter

In response to your letter dated 5th May 2015, the following provides a response to the

queries raised.

FI dated 05/05/20152015 – Regulation 9 of SI 137 of 2013

Q1 Provide an amended drawing (Drawing No. Figure B1) showing the SuDS

drainage area within the red line boundary of the installation, as confirmed in

response to Question 13a of the Regulation 10 Notification dated 12th February

2015. [Regulation (9)(2)(g)]

R.1 Please find attached amended drawing (Figure B1) showing the SuDS drainage

area within the red line boundary of the installation.

Q.2 Outline the procedure to be followed in the event that a batch of digestate fails

the test against the quality standard including in situations where the digestate

is being stored off site. [Regulation (9)(2)(g)].

R.2 It is proposed to transfer stable digestate from the AD plant to the proposed

lagoon facility for temporary storage prior to end use proposals (application to

land as OF/SI on agricultural and forestry lands). The digestate will be tested

for conformance with an accepted and known quality standard at the AD plant

prior to being transported to the storage lagoon. Digestate for testing will be

dispensed from the secondary digester to a dedicated 25,000 litre batch

holding tank located within the feedstock reception building. From here a

sample will be taken and sent for analysis. Sampling of digestate will be

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representative of the portion of production sampled (see attached flow

schematic and layout drawings [001 & 009] showing location of digestate

holding /testing tank). In addition continuous monitoring of conditions and

parameters will be undertaken in advance of dispensing digestate from the

secondary digester for testing /transfer to the storage lagoon. Forward

knowledge of parameters such volatile fatty acids (VFA) of digestate in the

system will give indicative results as to expected residual biogas potential

(RBP) of the digestate.

Treated waste that fails to meet the quality standard for digestate (i.e.

Maximum Respiration Activity, Pathogenic Organism Content Limits, Impurity

Content Limits and Organic Matter Content Limit) will either be recycled to the

process or treated as waste. Treated waste that fails to meet the criteria for

metal concentration limits will be treated as a waste and not recycled to the

process. Treated waste which fails to meet the quality standard and is sent

off-site for disposal at a waste licensed facility will be transported only by an

authorised waste contractor. A record of all non-conforming batches will be

kept and will be available for inspection.

In the event of a failure to meet the digestate quality standard, a review and

evaluation of feedstock and /or process changes relevant to the sampled batch

of material prior to the sampling date will be undertaken. Corrective actions

will be undertaken which will include re-sampling, recycling of material and

increase to the frequency of digestate batch testing until such time that

conditions /digestate is deemed to be stable and in compliance. Once

digestate is deemed to be compliant and the corrective actions have been

completed, the normal digestate monitoring programme will be reinstalled.

We also wish to inform you that planning permission was granted by Donegal County

Council on the 7th May to Glenmore Biogas Limited for development as set out under

planning permission ref 14/51399.

Yours sincerely,

Colm Staunton

Director For and on behalf of Envest Environmental Ltd.

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Attachments

Amended Layout Drawing Showing Red Line Boundary (Ref. Figure B1)

Amended Site Layout Drawing (Ref. 001)

Amended Feedstock Building Layout Drawing (Ref. 009)

Amended Process Flow Schematic, v1.4

Revised Non Technical Summary

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CO2 Building

Access Road

Reception Building

Control BuildingBiogas Purif ication & Bottling Plant

Pump House Building& Anaerobic Digestors

Flare Stack

CHP Engine

Reception Building OCU Stack

207800

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208000

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Client:Glenmore Biogas Ltd.

Project:Anaerobic Digestion, CHP Plant & Biogas Purification Plant.

Prepared by:Envest Environmental Ltd.www.envest.ie

Project Number:ENV-1367

Drawing Title / Scenario:Site Location Mapshowing Redline Boundary.

Drawing Number:Figure B1

Scale : 2,500:1 @ A3

07.05.15

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Digester 2

Digester 1

Digester 4

Digester 3

Feed

Building

Control

Building

Pre Pit

CO2

Compression

Building

Compressor

Gas Purification

and Bottle Plant

Pump

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Building

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overflow /

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100m3

Washwater

Storage Tank

CHP Unit

132.708 m

133.000 m

133.000 m

133.000 m

133.000 m

133.145 m

135.000 m

133.174 m

130.242 m

123.500 m

123.500 m

123.500 m

124.500 m

123.549 m

123.500 m

123.500 m

123.500 m

123.500 m

123.500 m

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123.500

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127.300 m

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Carbon Filter

and Stack for

Odour Control

Lorry Loadin Area

Digester Draindown/

Tankering Area

Bunded Fuel

Storage Tank

Area designated for

quatantine skip

11m3 covered and sealed

RO RO quarantine skip

Digestate

Quarantine Tank

Quarantine Tank

Liquid Feedstock

Tanks

Pasturisation Tanks

Holding / Isolation Tank

Date:

Scales:

Project Title:

Drawing Title:

Client/Architect:

Drawn by:

Checked by:

Approved by:

DRAWING

Status. Date. By. Check. Drawing Status Details. Appr.

Sheet Size:

Revision:Project Number:

Drawing Number:

Orig. Zone. Level. Type. Disc. Number.

E

Glenmore AD Plant

-

Site Layout

PRELIMINARY

WIS

SKL

LAM

141051

NOV 2014

1:200

A0

DC 00 ZZ GA C 001

Rev Date By Details Check Appr

- 25-7-14 SKL First issue - LAM

A 8-8-14 SKL Buildings Amended - LAM

B 19-8-14 SKL Prepit and CHP Building relocated - LAM

C 17-11-14 SKL Buildings relocated and Layout revised - LAM

D 18-11-14 SKL Odour Control Added - LAM

E 10-3-15 SKL Pipework, Drainage and Structures amended - LAM

1 : 200

Site Layout

1

Note:-

1. This drawing to be read in conjuction with all relevant

Engineers Drawings and documentation.

2. All levels in metres to Malin Ordnance Datum.

3. All dimensions in mm unless noted otherwise.

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35175

21040

1

GA-C-009

2

GA-C-009

Feed Stock Area

Feed Stock Area

Feed Hopper

Feed H

opper

Pasturisation Tank Pasturisation Tank

Liquid

Feedstock

Tank

Liquid

Feedstock

Tank

Liquid

Feedstock

Tank

Heat Exchangers

Services Pit

Access Door

Access Door

Roller Shutter

Doors

Quarantine

Tank

Holding / Isolation

Tank

Feed Stock Area

Decontamination

Room

1500

2500

AREA

DESIGNATED FOR

QUARANTINE

SKIP

11m3 SEALED

AND COVERED

RO RO

QUARANTINE

SKIP

Digestate

Quarantine

Tank

SFL 123.500

Ground Floor Level

2500

500

300

6847

Tegral Profile 6R sheeting

to roof and walls

Reinforced Concrete Wall

Roller Shutter Doors

SFL 123.500

Ground Floor Level

50

0

6847


to roof and walls


SFL 123.500

Ground Floor Level

30

0

Vent Openings


to roof and walls

Pedestrian door


SFL 123.500

Ground Floor Level

300

Vent Openings


to roof and walls

Pedestrian door

SFL 123.500

Ground Floor Level

FFL 134.800

Eaves

7453

50

0

20

00

Feed Hopper

Pasturisation

Tank

Feed Hopper Pump

Digestate

Quarantine

Tank

SFL 123.500

Ground Floor Level

FFL 134.800

Eaves

Stock Feed Area

Date:

Scales:

Revision:

Project Title:

Drawing Title:

Client/Architect:

Drawn by:

Checked by:

Approved by:

Project Number:

DRAWING

Drawing Number:

Sheet Size:



E

Glenmore

AD Plant

Feed Stock

Reception Building

PRELIMINARY

WIS

SKL

141051

Varies

A1

DC 00 ZZ GA C 009


- 25-7-14 GD First issue SKL LAM

A 28-7-14 GD Foundation Amended SKL LAM

B 05-8-14 GD Details amended SKL LAM

C 26-8-14 GD Pedestrian doors added. 1.5m high exterior concrete wall

added. Strip foundation size amended

SKL LAM

D 18/11/14 JIH Extra bay added and roof levels revised SKL LAM

E 04-3-15 GD Isolation joint removed from perimeter 250 wall. Extra bay

added to 300mm thick retaining wall structure

SKL LAM

1 : 100

Floor Layout

1 : 200

Elevation Front

1 : 200

Elevation Back

1 : 200

Elevation Left

1 : 200

Elevation Right

1 : 200

Section 1

1

1 : 200

Section 2

2

Note:-



2. All levels in metres to Ordnance Datum.


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Glenmore Biogas Ltd Attachment A

ENV-1367 (May 2015) A-1

Attachment A

Non-Technical Summary

(May 2015)

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ENV-1367 (May 2015) A-2

Table of Contents 1 GENERAL .......................................................................................... 3

2 PROPOSED SITE LOCATION ................................................................. 3

3 MANAGEMENT OF THE INSTALLATION ................................................... 4

4 INFRASTRUCTURE AND OPERATION ...................................................... 5

5 EMISSIONS AND IMPACT ON THE ENVIRONMENT .................................. 14

5.1 Atmospheric ........................................................................................... 14 5.2 Surface Waters ....................................................................................... 14 5.3 Sewer .................................................................................................... 14 5.4 Ground .................................................................................................. 14 5.5 Noise ..................................................................................................... 14

6 CONTROL AND MONITORING ............................................................. 15

7 RESOURCE USE AND ENERGY EFFICIENCY ........................................... 15

8 ACCIDENT PREVENTION AND EMERGENCY RESPONSE ........................... 16

9 REMEDIATION, DECOMMISSIONING, RESTORATION AND AFTERCARE ...... 17

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ENV-1367 (May 2015) A-3

1 GENERAL

Glemore Biogas Limited (formerly Glenmore Estate Aghaveagh NW Ltd.) was granted

planning permission (Ref. 13/51569) in July 2014 to construct a commercial centralised

anaerobic digester for the production of renewable energy and fertiliser. The

development will involve the construction of four primary digesters with collection

domes, a co-joining pump room and other structures associated with the operation of an

anaerobic digester system including the following: feedstock reception building, feed

hoppers, pre pit, CHP building, gas compression & carbon dioxide compression building,

flare and biogas purification and bottling unit.

A subsequent application (Ref. 14/51399) for planning permission and retention planning

was granted permission in May 2015 by the planning authority. .

The primary products generated at the site are biogas and digestate. The biogas will be

captured, cleaned and bottled and sold on for use as a bio-fuel and /or used to combust

in the on-site CHP to produce electricity and heat. It is expected that no more than 20

tonnes of biogas will be stored on the site at any one time (<7.5tonnes purified biogas -

biomethane). Carbon dioxide will also be recovered from the biogas and sold to the food

industry. The proposal will also produce up to 90,000 tpa of digestate which will be used

for fertiliser on agricultural and forestry lands.

2 PROPOSED SITE LOCATION

The proposed AD plant will be located on 0.72 hectares located within the south-western

area of lands known as the Glenmore Estate. The site is situated in the townland of

Aghaveagh which is situated along the River Finn half way between Donegal town and

Letterkenny, approximately 30km from each. The site is also approximately 30km west

of Strabane in the north of Ireland. The twin towns of Ballybofey and Stranorlar are

nearest to the proposal site approximately 6km to the east. The proposal site is located

a short distance from the R252 Glenfin Road west of Ballybofey. The R252 is a rural road

that connects the N56 in western Donegal to the N13/15 corridor in the east of the

County (Donegal Town to Letterkenny). The surrounding area of Aghaveagh is primarily

rural and agricultural. Small-scale farms and rural dwellings are most common with

some large-scale farming operations also present throughout the Finn Valley.

The site slopes downwards from south to north and away from the point of access.

Access to the site is via an existing laneway through the Estate from the R253 road. A

portion of the R253 road between the entrance to the estate and the R253’s junction

with the R252 Glenfin Road has been included within the site boundary because two

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ENV-1367 (May 2015) A-4

passing bays and minor alteration of road levels are proposed to facilitate the proposed

development.

The proposed site layout is shown on engineering drawing 141051-DC-00-ZZ-GA-C-001.

The site is accessed from the R253 road via a laneway through Glenmore Estate

3 MANAGEMENT OF THE INSTALLATION

Glenmore Biogas Ltd will have the ultimate responsibility for health, safety and

environmental issues relating to the operation of the facility. A suitably qualified and

technically competent Operations and Maintenance (O&M) Contractor, with previous

experience operating and maintaining power plants will be contracted by Glenmore

Biogas Ltd. The O&M Contractor will have responsibility for the day to day operation and

maintenance of the plant as well as environmental monitoring and reporting. The

contract between the Operator and the O&M Contractor will specify health and safety

and environmental obligations and responsibilities.

The plant manager will report directly to Glenmore Biogas Ltd. Site specific management

systems and operating procedures will be developed. The systems and procedures will

be continuously reviewed and developed by the operator and O&M contractor in

accordance with the principles of continuous improvement. The Plant Manager will be

directly responsible for the implementation of the Operators Health and Safety; all other

site personnel will have varying degrees of responsibility for their implementation.

Operations will be carried out in accordance with legislative requirements and the

conditions of the IE Licence and Planning Permission.

All personnel will be technically competent and suitably qualified to undertake their

assigned tasks. Training records will be maintained on site, available for inspection.

Personnel with responsibilities for operations, maintenance, health and safety and the

environment will receive task specific technical training, as required. A training needs

programme and matrix will be developed and updated on a regular basis. The

programme will take account of any incidents, amendments to site licence conditions,

changes to legislation, operations, operating procedures, emergency response and best

practice guidelines.

A site specific EMS will be developed and implemented for the facility in accordance with

ISO14001:2004 in due course. The EMS will provide the framework for environmental

management, ongoing assessment of environmental performance and continual

improvement at the power plant. The implementation of the EMS will include regular

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ENV-1367 (May 2015) A-5

cross-functional management reviews and will be subject to both internal and external

audits.

4 INFRASTRUCTURE AND OPERATION

The digestion system is a Continuously Stirred Tank Reactor (CSTR) type plant and will

be semi continuously fed with consistent pasteurised feedstock. Digested material will

be removed in batches representing a proportion of the total digester content.

Associated engineering drawings, civil and structural, are attached to Appendix D. Table

1 lists the main components of the facility and associated details.

Table 1 Details of the Proposed Facility Components

Item Details Weighbridge 1 no. at secured site entrance Feedstock Reception Building 1 no. for reception of all wastes Quarantine Area 1 no. beside feedstock reception building (sealed skip) Feedstock Bays 3 no. within feedstock reception building Pasteurisation Tanks and Heat Exchangers

2 no. within feedstock reception building (50m3 each)

Holding Tank 1 no. within feedstock reception building. To facilitate microbial testing /verification

Liquid Feed Tank 3 no. within feedstock reception building within delivery connection on western (front) side of building

Feed Hoppers 2 no. within feedstock reception building Digestate batch holding tank 1 no. within feedstock reception building Services Pit 1 no. within feedstock reception building containing

quickmix unit and macerator Pre-Pit 1 no. of 190m3 capacity Pump House Building 1 no. located between digestion tanks. Contains

delivery pipework, pasteurisation pumps and heat exchangers

Digestion Tanks 2 no. Primary and 2 no. Secondary

4 no. of 3,886m3 capacity each

Containerised CHP 1 x combined heat and power (CHP) containerised unit Gas Purification and Bottling Plant and Carbon Dioxide Compression Building

Containing; • Buildings • Containerised compressors (2 no.) • Storage tanks (2 no.) • CApureTM system & associated plant • Cooling tower (1 no.) • Truck filling point • Gas trailer areas (2 no.)

Control Building 1 no. containing; • Electrical substation areas containing bunded

electrical transformers • Welfare facilities – toilet and shower • Canteen • Storage room – bunded chemicals • Generator room • Panel room • SCADA /Control room

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ENV-1367 (May 2015) A-6

Item Details • Laboratory • 17.5m height stack (from ground level)

Gas Flare 1 no. for emergency use at 17.5m above ground level Odour Control System 1 no. on the feedstock reception building. Odorous

gases from the feedstock reception building areas will be extracted by fans and discharged into the impregnated carbon filter (ICF). From the outlet of the ICF the treated gas is finally discharged to atmosphere via an exhaust stack mounted directly on the carbon filter. The stack will be 17.5m above ground level (4.5m above roof of the tallest building on site)

Vehicle Wash Down Area 1 no. outdoor area -steam clean wash Process Drainage Recovering and containing contaminated waters and

effluents from process areas (e.g. CHP) Storm Water Drainage Separate isolated storm drainage system to manage

stormwater from non-risk areas to be designed in consideration of SuDS

Lighting Fencing and Security Gates

Along roads and around site perimeter

A description of the main items of plant and infrastructure proposed is as follows:

Weighbridge A weighbridge will be installed at the site entrance to provide for recording of material

inputs and outputs. This is important for both regulatory compliance and to effectively

manage the operation.

Waste (feedstock) Reception Building A reception building for the solid feedstock will be installed to receive the feedstock,

check the quality of feedstock, pre-treat the feedstock and process it through the plant.

The structural design of the waste reception building will be conventional structural steel

supported on reinforced concrete foundations. Steel columns will be fire protected as

necessary to comply with the building regulations. A 1.5m high reinforced concrete wall

will form external walls area (excluding openings) Tegral 6R sheeting used to sheet

remaining walls areas and roof area. Three (3 no.) fast acting roller shutter doors will be

provided for access and egress by delivery and other vehicles on the western side of the

building. Pedestrian access doors are also provided on the southern and northern sides

of the building.

A feedstock acceptance agreement will be completed by both the plant operator and the

feedstock supplier and the feedstock acceptance agreement will be kept on file for each

supplier of feedstock, both ABP and non-ABP, to the plant. The plant will follow a first-in

first-out (FIFO) procedure whereby older deliveries of waste are removed before newer

waste has been deposited for use.

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ENV-1367 (May 2015) A-7

It is not proposed to source or accept wastes containing packaging and other such

contaminants. Therefore there will be no requirement for screening for plastics and

other unsuitable materials.

The reception of waste feedstock will be carried out in an enclosed building which will be

kept under negative air pressure; this along with automatic door management and the

use of an air curtain, will significantly reduce the likelihood of fugitive emissions,

including noise, dust and odour. Exhaust air from the reception hall will be treated prior

to discharge to atmosphere. The reception building will provide adequate space to allow

control over waste delivery in order to minimise the amount of time that feedstock is

stockpiled before being processed.

The operating areas for unloading, preparing and processing feedstock will be

undertaken on an impermeable paved surface (i.e. to prevent the transmission of liquids

beyond the pavement surface) designed to the relevant British Standard. The surface

will be designed to be suitable to accommodate all of the static and dynamic loads

imposed by the vehicles, stored materials, machinery and process plant within the

proposed facility. The design, construction and maintenance of the pavement surface

will accommodate movements, reversing and tipping of vehicles, the use of unloading

areas for storage of waste, the use of mechanical shovels on the floor to move waste,

water containing contaminants dripping from vehicles and the washing down of the floor

for cleaning purposes. Feedstock unloading and preparation areas will be finished with a

proprietary finish to provide sufficient resistance to chemicals and abrasion for the stated

design life. The surface will have appropriate skid resistance and be suitable for

pressure jet washing.

Cleaning and wash down will be collected into gullies which will drain to the pre-pit for

use within the process. The self-contained drainage system within the reception building

will prevent any spillage entering the storage systems or escaping off-site. A vehicle

wash down area including wheel-wash facilities is located to the south of the reception

building for washing and disinfecting (steam wash) delivery vehicles on exit from the

reception hall. The provision of water and steam will be used to allow for cleaning of

vehicles and other transport equipment following delivery.

The air extraction system on the reception will be designed to ensure three (3 no.) air

changes per hour equivalent to 13,488m3/h based on the volume of the building. The

system will be designed to allow higher numbers of air changes within the building where

there is possibility of higher or more acute odour release; e.g. the system will be capable

of ramping up to 43,200m3/h when a roller shutter door is open. Any air movement will

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ENV-1367 (May 2015) A-8

be controlled to ensure air flows are from low odour areas to high odour areas. A

proposed stack height of 17.5m (4.5m above the highest roof level) is proposed which

will be mounted onto a carbon bed to abate odours from the waste reception building.

The reception area must be designed appropriately for the properties of the anticipated

feedstock inputs and it includes sufficient space and flexibility to manage changes in the

volume and properties of feedstock and vehicles that could occur over the lifespan of the

facility.

Three feedstock bays (4.55m wide) are included within the reception building where

feedstock deliveries are required to be offloaded for inspection and acceptance sampling

prior to pre-treatment. These bays will be managed to ensure waste is not stored for

more than 5 days and will be cleaned weekly. Should the inspection or analysis indicate

that the wastes fail to meet the acceptance criteria, then such loads will be stored in a

dedicated quarantine area within the reception building and dealt with appropriately.

Liquid feed-stocks will be received into three fully enclosed tanks within the reception

building by means of closed pipes. The liquid waste will be delivered via closed pipework

to the to the pasteurisation units from here.

Manure produced from the five adjoining cattle sheds will be transported by pipeline

from the below ground storage tanks beneath the sheds to the plant in order to avoid

disease risks associated with vehicles returning from the plant to the farm.

At the waste reception stage, the feedstock material will remain in storage for the least

time possible. The operator will empty the bunkers periodically (at least once a week) to

prevent a build-up of older waste in the bunker. This is because a high proportion of

waste is putrescible and will degrade aerobically and depending on the depth,

anaerobically, generating odour and leachate.

Two pasteurisation tanks (50m3) will be provided within the reception building.

Pasteurisation (pre digestion) will be carried out on all waste materials being processed

by the facility. An application for Stage 1 Approval of a Type 1 plant from the

Department of Agriculture Food and the Marine is currently being prepared.

The plant will be equipped with e.g. macerators capable of reducing the particle size of

the feedstock to the required size (<12mm) prior to entering the pasteurisation unit.

Batches of feedstock will be pasteurised at 70oC for 60 minutes.

The pasteurisation units will be equipped with sufficient temperature probes to provide

evidence that all the material is kept above the minimum temperature for the required

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ENV-1367 (May 2015) A-9

period of time. The plant will be equipped with recording equipment that will allow a

live, real-time thermograph to be produced from the temperature probe readings. The

probes, recording system and the thermographs produced will be tamperproof.

Pre Pit Process effluents generated at the site will be collected and discharged to a pre-pit

(190m3 capacity) prior to being pumped and processed within the waste reception

building and AD process. The pre-pit will receive process effluent collected by internal

drains (e.g. within the reception building and pump house building) and drainage from

external risk areas; i.e. external areas that have the potential for causing contamination

of surface drain water will be separated from the overall surface water drainage and

discharged to the enclosed pre-pit.

Digesters Four (4 no.) primary digesters all with a 27.6m diameter and capacity of 3,886m3 will be

installed at the site. The total capacity of the digester tanks is of 15,544m3. Following

the pasteurisation process, feedstock will be fed to the digesters where it will be retained

for about 63 days. This is sufficient time for it to digest and for as much gas as possible

to be extracted in order to maximise the revenue stream. The outputs from the

digestion phase are digestate and gas. It is proposed that the treated digestate from the

facility will be transported off-site to an approved Department of Agriculture Food and

Marine (DAFM) nearby storage facility. Biogas generated will be purified on site and

used in the bottling plant and the combined heat and power (CHP) plant to produce heat

and electricity for house load (the excess will be fed back to the electricity grid). It is

proposed that purified bottled biogas will be transported off site for utilisation in gas

engines on industrial sites.

Gas Flare A gas flare stack will be installed near the southern boundary of the site. The flare will

only be required in exceptional /emergency circumstances; e.g. when excess biogas

cannot be utilised by the CHP plant or the bottling plant.

Gas Purification and Bottling Plant Biogas Treatment will primarily consists of the following processes

• Dewatering;

• Removal of H2S (potentially corrosive to engines);

• Removal of oxygen and nitrogen (where present);

• Removal of ammonia;

• Removal of siloxanes (if treating Sewage Sludge) ;

• Removal of particulates; and

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ENV-1367 (May 2015) A-10

• Removal of CO2 (for upgrading to biomethane).

• Gas bottling

The techniques used in biogas treatment to remove these different elements are outlined

below

• Dewatering

Biogas leaving the digester is saturated with water and this may condense in gas

pipelines. The condensate will be contaminated and may cause corrosion. It is important

that wet gas transmission pipes and storage vessels can be drained to prevent them

from becoming flooded with condensate. Water removal plant and traps /taps will be

provided.

• Desulphurisation

The main sulphur compound in biogas is hydrogen sulphide (H2S). H2S is formed during

microbial reduction of sulphur containing compounds (sulphates, peptides, amino acids).

It is reactive with most metals and the reactivity is enhanced by concentration and

pressure, the presence of water and elevated temperatures.

H2S can cause corrosion problems in gas engines. Hydrogen sulphide has an energy

value and burns readily. When combusted, it forms SO2 leading to acidic conditions in

the presence of moisture formed when methane is burned. The presence of H2S in the

gas may also result in more frequent oil changes being required. Gas engine

manufacturers set limits on H2S tolerances (typically below 500 ppm).

H2S concentrations in the biogas can be decreased by precipitation in the digester or by

treating the gas either as a stand-alone treatment or as part of carbon dioxide removal.

At the Glenmore Biogas plant, desulphurisation will be undertaken by absorbing H2S on

inner surfaces of engineered activated carbon with defined pore sizes. The addition of

oxygen (in the presence of water) oxidises H2S to elemental sulphur that binds to the

surface. Activated carbon is either impregnated or doped with permanganate or

potassium iodide (KI), potassium carbonate, or zinc oxide (ZnO) as catalysers. Due to

limits on oxygen levels in biomethane, oxidisation of sulphur is not a suitable technique

where the gas is intended for grid injection or use as vehicle fuel. Use of KI-doped

carbon or permanganate impregnated carbon is used to effect oxidation without the

need for oxygen. ZnO impregnated carbon is expensive but extremely efficient. H2S

concentrations of less than 1 ppm can be achieved.

• Oxygen and Nitrogen

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ENV-1367 (May 2015) A-11

Oxygen is not normally present in biogas as it will be consumed by facultative aerobic

microorganisms in the digester. If air is present in the digester then nitrogen will also be

present in biogas. Oxygen and nitrogen can be removed with activated carbon,

molecular sieves or membranes.

These gases will be removed to some extent in a desulphurisation process or in some

upgrading techniques. Both gases are difficult (expensive) to remove, and their presence

should be avoided if the gas is to be upgraded. The presence of oxygen and nitrogen is

less of a concern if the gas is used for CHP or boilers as air is added to the gas during

the combustion process.

• Ammonia

Levels of ammonia present in biogas depend on the digester substrate composition and

pH within the digester. High concentrations of ammonia are a problem for gas engines,

and are often limited by manufacturers (typically up to 100 mg Nm-3). The combustion of

ammonia leads to the formation of nitrous oxide (NOx) in the exhaust. Ammonia is

usually separated when the biogas is dried by cooling, as its solubility in water is high,

and most upgrading technologies are also selective for the removal of ammonia,

therefore a separate removal step is not normally required.

• Siloxanes

They are found in sewage treatment plants and landfill gas but are not usually found in

biogas generated from slurry or pure food waste. Most manufacturers of gas engines set

maximum limits for siloxanes in biogas.

Siloxanes form a highly abrasive white powder of silicon oxide when burned, which can

create problems in gas engines. Silicaceous deposits on valves, cylinder walls and liners

are the cause of extensive damage by erosion or blockage. Silicon compounds may also

reach the lubrication oil requiring more frequent oil changes.

Siloxanes can be removed by gas cooling, and adsorption on activated carbon. This

method is very effective but can be expensive since spent carbon needs to be replaced.

Another method for removing the compounds is absorption in a liquid mixture of

hydrocarbons, activated aluminium or silica gel, or by absorption in liquid mixtures of

hydrocarbons. Siloxanes may also be removed during a hydrogen sulphide removal

process.

• Particulates

Particulates may be present in biogas and can cause mechanical wear in gas engines and

turbines. All biogas plants must be equipped with some kind of filter and/or cyclone for

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ENV-1367 (May 2015) A-12

reduction of the amounts of particles in the biogas. Filters not only remove particulates

but also remove droplets of water or oil. Filters with a 2–5 micron mesh size are

normally regarded as appropriate for most downstream applications.

• Carbon dioxide (CO2) Removal

It is proposed to use Purac CApureTM technology for the removal of carbon dioxide. This

is done by a chemical absorption process as CO2 reacts with the absorption liquid.

CApureTM is a trade name for a special amine composition designed for CO2 removal. The

amine solution is mixed with 50% high purity water and is re-circulated in a completely

closed system. The CO2 removal unit consists of two absorption columns and a stripper

column.

The raw-gas enters the absorption column from the bottom and flows upwards. The

amine solution enters the column from the top and flows downwards and meets raw-gas.

The column is filled with surface enlarging packing to give a large contact surface

between raw-gas and amine solution.

The chemical absorption process takes place as the raw-gas meets the amine solution in

the counter current adsorption column. The upgraded biogas leaves the column from

the top and the CO2 enriched amine solution liquid at the bottom.

The enriched amine solution is pumped to the stripper column for desorption of the CO2

by heating to the boiling point, >105 °C depending on stripper pressure design. The

amine solution enters the stripper column from the top and flows downwards through

surface enlarging packages. The boiling of the liquid takes place in the lower part of the

column and the rising gas phase strips CO2 from the amine solution.

The enriched amine solution entering the stripper column is pre-heated by the hot

returning lean liquid stream. The remaining energy to raise the temperature above the

boiling point is transferred directly from steam or hot water to the lower part of the

stripper.

The CO2 leaves the stripper column at the top after being cooled in a condenser. The

CO2 stream has a very high purity and thereby a commercial value. The CO2 can be

used as cooling agent, in greenhouses or in beverage applications after further

treatment.

The upgrading process is adjusted to minimize the energy consumption through the use

of internal energy recovery. The heat energy recovered from the amine solution process

and condenser can be used for external heating purposes. The recovered energy is often

used for the heating of substrates entering the anaerobic digesters.

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ENV-1367 (May 2015) A-13

Incoming pressure to the upgrading unit can vary between 30 mbarg to 4 barg which

makes the technique easily adaptable to different local conditions.

The upgraded gas exits the treatment system with nominal pressure, and is saturated

with water. The gas is cooled down to 5°C before chemical drying. The gas is dried to a

dew point less than – 65°C @ 4 barg with a Thermal Swing Dryer (TSA) drier.

Figure 1 Biogas Treatment Process

• Gas Bottling Plant

The compression of the gas greatly reduces the volume of gas and reduces the number

of road movements required to ship it. C The gas will be pumped into a standard

containerised unit for transportation to the customers identified.

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ENV-1367 (May 2015) A-14

5 EMISSIONS AND IMPACT ON THE ENVIRONMENT

5.1 Atmospheric The proposed development site is located in a rural area with few sensitive locations in

the immediate vicinity of the proposed development location. During the operation of the

development there is the potential for atmospheric emissions from the combustion of

biogas and odours from the reception and processing of feedstock. It is proposed to

construct and operate an AD plant in which the majority of the biogas produced by the

AD process will be combusted in an on-site CHP plant used to power the facility and

export electricity to the National Grid and the remainder will be bottled in a Gas

Purification & Bottling Plant. Approximately 9 lorry movements will be delivering material

to the facility each day during normal operating hours. This waste will be accepted in to

the Waste Reception Building immediately to minimise the potential for generation of

fugitive odours.

The scheduled emission points in the proposed Anaerobic Digestion and CHP plant will be

regulated through the EPA Licensing process. This Odour and Air Quality Impact

Assessment has demonstrated that the emissions from the will not result in an air quality

impact in accordance with the Air Quality Standards Regulations 2011 (S.I. No. 180 of

2011). It was recommended that a stringent odour target value of C98, 1-Hour 1.5 ouE/m3,

relevant to potentially highly offensive odours, should be achieved at the surrounding

sensitive receptors. This is based on EPA and Environment Agency criteria as well as the

experience of the air quality specialist. The dispersion modeling indicates that based on

worst-case odour emission concentrations the existing odour dispersion experienced in

the vicinity of the site allows for the sites odour emissions to achieve the stringent odour

target value of C98, 1-Hour 1.5 ouE/m3.

5.2 Surface Waters There will be no discharges to surface waters from the activity.

5.3 Sewer There will be no discharges to sewer from the activity.

5.4 Ground There will be no discharges to ground from the activity.

5.5 Noise This noise impact assessment has compared the measured noise levels in proximity to

the nearest noise sensitive properties to the relevant guideline noise limits outlined in

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ENV-1367 (May 2015) A-15

the World Health Organisation (WHO) Guidelines for Community Noise and the EPA Guidance

Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled

Activities (NG4). The measured noise levels at the noise monitoring location are in

accordance with the relevant guideline noise limits outlined in the World Health

Organisation (WHO) Guidelines for Community Noise and the predicted noise levels at the

nearest residential properties are in accordance with the WHO Guidelines for Community

Noise during daytime and night-time.

The worst-case assessment of operational noise from the proposed fixed plant and traffic

movements associated with the proposed development has indicated that the EPA’s “Area

of Low Background Noise” limit criteria will not be exceeded at the nearest residential

properties. No site specific noise mitigation measures are deemed necessary. However,

as part of an Environmental Improvement Programme for the site, the developer will

focus on reducing noise breakout off site where possible and aim to improve noise

attenuation measures on the site.

6 CONTROL AND MONITORING

It is proposed that quarterly stack monitoring is undertaken from the CHP stack and

odour control abatement stack. Ambient noise monitoring (annual) at two locations and

surface water (quarterly) monitoring at one location on the River Finn is also proposed.

7 RESOURCE USE AND ENERGY EFFICIENCY

The site operator and manager will regularly review and assess all raw materials that are

used on site to ensure that they are most appropriate for use and reflect best practice

and BAT. The consumption of raw materials will be optimised and opportunities for the

reduction in raw material usage, where appropriate, will be implemented. The

availability of new and alternative raw materials with a reduced environmental impact

will be regularly reviewed. Should the operator wish to change any of the raw materials

used at the plant the EPA will be notified and invited to comment prior to the new

product being purchased.

It is proposed to process up to 90,000 tonnes of feedstock at the facility. This will result

in the following;

• 65,730 (MWh) of biogas recovered

• The annual house load will be 10,140(MWhe)

• The annual thermal load will be 6,548 (MWht)

• The maximum amount of compressed gas (biomethane) stored on site at any one

time will be less than 7.5tonnes.

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ENV-1367 (May 2015) A-16

• The maximum amout of recovered carbon dioxide stored on site at any one time

will be 100m3.

In accordance with the techniques for achieving BAT presented in Chapter 4 of Best

Available Techniques (BAT) for the Waste Treatment Industries 2006, 1 x combined heat

and power (CHP) containerised unit will be installed at the facility to convert biogas into

heat and electricity. The CHP plant will generate a consistent electrical supply and the

plant will be a net power producer with the excess electricity from the CHP engines

exported to the national grid via a substation incorporating transformers.

Heat will be recovered from the CHP engine and utilised to heat water, which will then be

used to raise and maintain the temperature of the pasteurisation and digestion tanks as

well as to dry digestate to reduce the total volume that requires export from the site. No

excess heat will be produced.

It is proposed that of the total volume of biogas generated in the digesters a portion of

this will be compressed and bottled in the Gas Purification and Bottling Plant, and

transported off site for utilisation elsewhere where it can be used in gas engines at

industrial sites.

8 ACCIDENT PREVENTION AND EMERGENCY RESPONSE

Glenmore Biogas Ltd will develop, implement and maintain a list of Health and Safety

documentation and Environmental plans, policies and procedures to achieve

Environmental, Health and Safety excellence. This commitment will be the responsibility

of management and employees in all functions.

The following list is a framework that Glenmore Biogas will develop, implement and

maintain on site.

• Company Health and Safety Management System including policies and procedures

• Environmental Management System which will be accredited to the international

standard ISO 14001

• Accident prevention and emergency incident response plan, policies and procedures

• Fire emergency response plan

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ENV-1367 (May 2015) A-17

9 REMEDIATION, DECOMMISSIONING, RESTORATION AND AFTERCARE

A Closure Restoration and Aftercare Management Plan and Environmental Liabilities Risk

Assessment have been prepared for the activity. It is recommended that this is

reviewed and updated in advance of commencement of operations at the site. The

assessments were prepared in accordance with the ‘Guidance on Assessing and Costing

Environmental Liabilities’ published by the EPA in 2014.

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Digester 2

Digester 1

Digester 4

Digester 3

Feed

Building

Control

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Pre Pit

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132.708 m

133.000 m

133.000 m

133.000 m

133.000 m

133.145 m

135.000 m

133.174 m

130.242 m

123.500 m

123.500 m

123.500 m

124.500 m

123.549 m

123.500 m

123.500 m

123.500 m

123.500 m

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RO RO quarantine skip

Digestate

Quarantine Tank

Quarantine Tank

Liquid Feedstock

Tanks

Pasturisation Tanks

Holding / Isolation Tank

Date:

Scales:

Project Title:

Drawing Title:

Client/Architect:

Drawn by:

Checked by:

Approved by:

DRAWING


Sheet Size:

Revision:Project Number:

Drawing Number:


E

Glenmore AD Plant

-

Site Layout

PRELIMINARY

WIS

SKL

LAM

141051

NOV 2014

1:200

A0

DC 00 ZZ GA C 001


- 25-7-14 SKL First issue - LAM

A 8-8-14 SKL Buildings Amended - LAM

B 19-8-14 SKL Prepit and CHP Building relocated - LAM

C 17-11-14 SKL Buildings relocated and Layout revised - LAM

D 18-11-14 SKL Odour Control Added - LAM

E 10-3-15 SKL Pipework, Drainage and Structures amended - LAM

1 : 200

Site Layout

1

Note:-



2. All levels in metres to Malin Ordnance Datum.


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Documents

Re. Glenmore Biogas Ltd.: Reg. No. P1004-02 Response to FI ... · Re. Glenmore Biogas Ltd.: Reg. No. P1004-02 – Response to FI Letter In response to your letter dated 5th May 2015,