SANITARY AUTHO'IlrTY RESPONSE Name of Sanitary Authority: Drogheda Borough Couricil

Conseiit granted subject to the conse~it conditions outlined below. YGS

I Consent &ranted without conditions. Consent refused Nota'1.

Address: Corporadon Offlees Fair Street Dro&h&da

c ir Name of Facility: Olanbiu Foo

Address:

Currsent: Indicite Yes to one of the follo

the process effluent and to take smples of &e process efflueiit. IW

5. All automauc monitors and samplers shall be functioning at tlll rims (except during I . - maintenance and calibration) when the activity is being carried on unless atEtermtivc: sampling or moniroring has been agreed in writing by the Agency for a limited period. In the event of the malfunction of any continuous monitor. the licensee shall contact h e Agency as soon as practicabble, and altmnutive sampling and monitoring facilities shall be put in place. Prior written agreemen1 for the we of altemtive equipment, other than in rmzrgency situations, shall be obtained fiom the Agency.

6. The licensee shall record all sampling, analyses, measurements, examinations, calibmtiom and maintenance carried out in trccordance with tbe requirements of this licence.

7. The licensee shall provide safe and permanent access to all on-sire sampling and monitoring points and off-site points os required by the Agency

8. The licensee shall at no lime discharge or permit to bc discharged into %e sewer any liquid matter or thing that is or may be liable to set or congeal at avcrage sewer temperature or is capable of giving off any inflamnable or explosive gas or any acid, alMi or other substance in sufficienr concentration 10 cause corrosion to sewer pipes, penstock and sgwcr fittings or the general integrity of the sewer.

9. In the event of any incident which relates to discharges TO sewer, having taken place, rhe l i cmee shall notify the Agency, Local Authority and Sanitary Authority as soon as practicable

Ye -- YES YES

%

YES after thc incident. - . _. 4

Page 2 of7 S93E-2Z.dur

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ADDITIONAL GENERAL CONSENT CONDITJIONS In respect of discharges or emissions to sewers, in accordance with Section Y Y E

of the Envirouinekltnl Protection Agency Acts 1992 and 2003 (Specib, ifrcquirEd)

t

P8T9L86-TPESTT ’20 :ZT 900Z/ZT/ZZ

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... ... . . . . . .

-~

Suspended Solids

PR lemperatwe

Limit Values for Process Emucnt to Sewer

1700 I 4.0 - 9-0 32OC MAX

Schedule B: Emission Limits

.-

Emission point iefereixe no: -1 Enission to (rmrri/cxriprriorr); PUWC 5 d E S

Volume to be emitted : Miucin-rum in any one day : m3 Maxitiiunirate perhour : 50 1n3

600 450 M “/d A J w e E

W

5T/S0 39Ud

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Frequency of Monitoring Process Effluent to Sewer

Schedule C

Emission point reference no:-,SG 0 I

(if rwrrired)

n Signed on behalf of Sanitary Authority:

,Note 1 Daily monitoring of the BOD is required to alllblish a rclatiomship with COB, This daily monitoring &ull be c d e d 0111 for g period of 3 nionlhs to csthlish this rcluiowhip. Oncc this relationship is est&]kihed tbe iuonitoring frequency for BOD is to rWett to wee&’ monitoring. AU BOD niooitoring shall bo based on the 24- llour tlow proporliollnl composif~ srunplii1g. The moiiitarh~ of Lht BOD shdl be on h weekly rotational whedule, i.e. Monday in week 1. l’uasday in week 2, etc,

monitoring Prequcocy for thc COD will bc daily on continuous flow and composite sampling. T h e COD can be checked ugahst the UOD composir3 smpiing 10 unsure the COD value t\;lTlains rwprsecntativc o f the ogmic cuntent in the effluenl.

.- .- ..-

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EPA Export 25-07-2013:20:55:02

,APPENDIX A

Drogheda Borough Council Clunbia IPPC Licence Application Additional Conditions & Issues

requiring Purther Clarification

In addition to the nine draft General Consent Conditions already listed Drogheda Borough Council request chat the applicant is conditioned to provide;

Additional draft Consent Conditions attached to the IPPC Licence Application

1. A Summary Reporr of the results of analysis of effluent discharged to the public sewer shall be provided to the Sanitary Authority on a monthly basis.

' I 2. The applicant shall enter into a Reserve Capacizj~ Agreement based on the Model Farm of Agreement for Wastewater Services developed by the Department of the Environment, Heritage and Local Governnient (March 2002).

3. Uncontaminated surface water run-off shall be piped directly to the public storm water sewer.

4. All trade effluent shall be discharged directly to the Public Sewer at one location to the rear ofthe plant.

5. All Cleaning in Place (CIP) chemical storage tanks to be provided with adequate bund walls complete with impervious bases to protect against loss by spillage. All filling and take-off points, where practicable, to be located within bund walls. Licensee shall ensure that filling and emptying of all chemical storage tanks, particularly those with filling andor take-off points outside bund walls, are carried out under the strict control and supervision of responsible operatives.

6. The Licensee shall take all necessary measures to ensure that acids, bases and/or substancedchernicals used within the premises are safely stored and cannot enter the public sewers.

7. The Licensee shall have an appropriate cut-off system incorporated in the drainage system in the premises to ensure that in the event o f a spillage the contaminated matter cw be prevented from reaching the public sewers.

8. The Licensee shall notify both Drogheda Borough Council and the Operator ofthe Municipal Waste Water Treatment Plant, immediately of any accidental discharges, spillages or deposits of any polluting matter which enter or are likely to enrer the public sewers, which may lead to a breach o f licence, to allow remedial action to be taken at rhe W WTP.

9, The Licensee shall provide continuous load monitoring of the effluent discharges to allow management of their discharge and to ensure, via the installation of

P819f86-TPESTT 50 :ZT. 900Z/ZT/ZZ

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1

51/80 39Ud

appropiiate cut-off systems incorporated in the drainage network, that loads in excess o f the discharge limits are not permitted to enter into the public sewers.

10.The Licensee shall carry out automatic and continuous flow proportional measuremenVrecording and sampling of the effluent prior LO discharge to the public sewers. The applicant shall maintain daily records o f the volume of effluent discharges and shall provide these to the Sanitary Authority on a monthly basis.

1 1. The applicant shall submit details of the water mains layout serving the premises and indicate the location o f all take off points, fire hydrants, sluice valves and water meters. The applicant shall provide details of the existing ground water well supply, including the meter location and the water supply arrangements between the ground water supply and the public water supply. The applicant shall ensure that there is no possible cross contamination (backfeed) between the public water supply and the ground warer well supply. The applicant shall maintain daily records of the water usage from both the public water supply a d the ground water wall supply and shall provide details of the times in operatiodprofile o f use of the both the public water supply and the LTound water well supply and submit these records to the Sanitary Authority on a monthly basis in the Surnniaty Report,

12. The applicant shall collect a 24-hour flow proportional composite sample every day and this sample shall be preserved for a further 24 hours to ensure that EPA Licence Enforcement Staff will have it available during any unannounced spot inspection.

13. In the event of any spillage of contaminating materials entering the sewer, the conipany may render itself liable to prosecution. Furthermore, if, in the opinion of Drogheda Borough Council andor EPA, such spillage warrants urgent measures to be taken to abate any effects caused by such spillage the licensee shall either: (i) at his own expense, remedy any effects caused by such a spillage and/or (ii) shall defray any cost incurred by Drogheda Borough Council in remedying any eflects caused by such a spillage.

PJK/MidCilunbia - LPPC Liceim Applkrtiotl Conditions & Clariiisdoo of I n f o r m e h

38CI ld3a 9NIt133NI9Nt

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APPENDIX B

Issues that require Further Clarification &: Consideration

1. The applicant shall provide details of the provisions that are in place to protect against any spilldges in the main yard area/plant from entering into the storm water sewers - cut-off available and provision for removal of spill and disposal accordingly.

2. With reference to Point 5 above - Please be advised that there is run-off hiom the plant out onto the public footpaWroad dong the front (Dublin Road) where the bulk milk lorries connect up to the plant. There is an existing ‘Aco’ type channel running along the front o f the plant in this location that is not operating adequately or is not picking up the total run-off from the area in question.

3. What will be the interim conditions and arrangements pending The proposed implementation of the IPPC Licence conditions?

4. Glanbia have declared in their IPPC Licence Application an mud usage of 30 tonnes of nitric acid (60% strength). However, the declared nitrate concentration of 10mg/l N is not consistent with the declared annual use rate. This issue needs to be addressed, In addition the declared annual mass emission to sewer of Nitrates of 1.642tonnes (Table E3(ii) of IPPC Licence Application) needs further clarification.

5. Glanbia should provide details o f the projected Kjeldahl nitrogen content of the emuent discharge - this has not been mentioned in the iPPC Licence Application.

6. Appropriate limit values need to be placed on Total Nitrogen and Kjeldahal nitrogen in the emuent discharges. A limit value of 75mdl has been proposed for Total Nitrogen in the attached Table of Limit Values.

7 , Efficiency of the Plant - The average daily effluent load figures anticipated in the application appear to assume a level of losses below I % against these production figures. The applicant does not provide any bases for this claim, which should be clarified, having regard to the actual production and loss efficiencies at similar plants in the country.

8. Product Returns - Clarification is needed on the proccdms and safeguards for product returns, and out-of -spec product, how it is to be disposed of, and how the disposal route is to be verified. In particular, it must not be possible to discharge effluent LO any manhole downstream of the flow measuring and sampling point, and in particular to Point SE 01 shown on the Drawing appended to Attachment E.

*

9. Odour Control - Since the introduction ofthe flow balancing tank at Glanbia in mid-2005, foul; odours have bean experienced. These odour problems have been reported in the vicinity of the plant and along the Bryanstown foul sewer to which Glanbia discharge. From discussions with Glanbia, the residence time in thc

PJPCIMisCICrlanbia - WYC Licence Applicnuon Conditiohs & Cluific&c-afioP of Informution

P819f86-TPE511 50 :Z1 900Z/Zl/ZZ

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EPA Export 25-07-2013:20:55:02

balancing rank is in the region of 12 hours. During hot weather conditions, it would appear that septicity and sour product has lead to odour complaints in the area. The applicant needs to address this issue with odour scrubbing, stabilised discharge to the public sewer or similar processes be adopted.

IO. COD Limits - As there is a relationship between COD and BOD, it is requested thar a COD discharge limit is established to aid with monitoring and quicker testing of the eftluent being discharged. In this regard it is requested That continuous monitoring be implemented on Flow to Sewer and composite sampling of COD. 24-hour flow proportional composite sampling of BOD would also be advised on a weekly basis to ensure that the COD value has not become unrepresentative of the organic content in the effluent. It is proposed that this BOD sampling be on a weekly rotational schedule, i.e. Monday 011 week 1 , Tuesday on week 2, etc.

1 1. The Borough Council have experienced problems with ‘hard‘ COD at the WWTP which is not amenable to breakdown in the biological process. As such, initial COD testing should be carried our in accordance with the procedures set out in Schedule 2 of the Urban Waste Water Treatment Regulations in conjunction with any other inaans of testing to establish as to whether ‘hard’ COD is being discharged from the Glanbia plant. If ‘hard’, COD is identified then Glanbia shall make provision for its treatnienthemoval prior to discharge to the public sewer.

12. It would appear that from the licence applicarion and the 2006 data provided by Glanbia, that they are proposing to maintain their current discbarge levels, well in excess of the capacity reserved for rhem at the Droghcda Waste Water Treatment Plant. The reduced discharge limits proposed in this submission, which may require Pre-Treatment & Biological Treatment to be provided by Glanbia, must be observed, because of the load constraints on the niunicipal WWTP.

13, T o achieve the proposed discharge limits, it will be necessary for Glanbia to provide some forin of pre-treatment and biological treatment of effluenr prior to discharging it into the public sewer. In this respect, it is envisaged that BATNEEC will be the requirement of B pre-treatment & biological treatment process, so that some discussion needs to take place on what constitutes a pre-treatment CYL biological treatment technology that gives a significant reduction in effluent strength and load, but which does nor entail excessive cost.

PJPUMkdGImbin - IPPC I.iwiicz Applic-alion Conditions & Clarificurion UT Inl’omintion

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APPENDIX C

Extract from Tobin Consulting Engineers Report outlining the history of the Discharge Limits

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2.0 DlSCHAMX LIMH'S

--,I.

.I .. -I-.

COD Suspended Solids ...,

2.1 Discussions were held with Glanbia, formally Avowmore ancl Wum-jurd Group, and their I-cprcscntatives in February 1998 on the capacity lhey required to have reserved for then? at the r)roghcdn Wastewater Trcatmerit Plant (Phase 1 - 67,000pe). The reserved capacity agreed between Droghecla Borough Council and Avorznzorc Wciterford Gruup are as outlined in Table No. 1

Reserved Capacity nt Droglicda WWTP

Reserved Capacity 191 m3/doy

2,500 nig/l, 477..5 kdday 4,500 mdl, 860 kg/day

2,00Orndl,382 kg/day I

- LC.. . ..-

-

Table No. 1 Agrecd Reserved Capacity at Wastewater Treatment Works for Glaabia

Parameter t- Volme

~ - 'Reserved Capacity

600 m3/day in a i y 24 hr period.

In contrast Lo this resewed capacity, the discharge limits on their existing discharge licence arc much greater, a listed in 'I'abla No. 1 below

BOD Siispended Solids

Max. Temperature -*

Oil, Grease, U Fats Sulphatcs Arnrnonia . -

Ortho-Phosphate Nitrates

Chlorides

p H Range

ST/ZT 39Vd

50 w 3 h maxiinuni discharge 3,000 mg/l 1,700 11115/1

6.0 - 9.0 32°C

500 mg/i 250 m d l

10 m d l (N) 30 mg/l (P) 10 m d l (N)

250 mg/l (Cl)

Y

-.. -

Table No. 2 Discharge limits listed under existing discharge liceuce

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Corrtinuution Sirset 2

Volume

What Glanhia reserved at the Treatiiient Works, as listed in T'able No. 1, is what they have con tracied with Drogheda Borough Council to have treated at the Treatment Works, with associated capital and operitional charges based ori this reserved capacity.

450rn3/day average, 50 m3/hr maximum discharge, 600 m3/day

On Ihc other hand, thc discharge limiu listed in Table No. 2 were conservative limits adopted by Gli~nbia to give sufficimt latitude to ensurc that the stayed within the limits o f heir licence.

BOD

Suspended Solids ... Oil, Grease, Fats

Sulphates Ammonia

Ortho-Phosphate Nitrates

Chlorides

2.3, Proposed Discharge Limits The discharge limits proposed in this current IPPC Licence application are almost identical to the limit values iii the cxisting Jicencc. Table No. 3 outlines these proposed discharge limits.

maximum discharge 3,000 mgA

1,350 kg/day 1,700 mdl 500 mg/l 250 mg/l

10 mg/l (N) 30 mg/l (P) 10 mg/l @I)

250 mdl (Cl)

Table No. 3 Proposed Discharge Limits under current application

I ' Parameter I Reserved Catlacitv

The loading data provided by tilrillbia for the period from the 2'Id of January 2OOG to the 1 gLh of July 2006 is outlined in Table No. 4

9 l / & l 39Vd b8l9L86-tbESII 90 :Zt 900Z/ZT/ZZ

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Tablc No. 4

I,oadiag Data from Glanbitl from 02/01/06 to 15/07/06

-- --. -._. ,.. Parameter . .- --.I Average Flow .- 3 26.8 m3/day BOD 2037.8 nldl

,". ... 599.3 kg/day Suspended Solids . .- 1201 .O mg/l

Oils, Grease & Fats 215.6 mg/l Sulphate 129.2 .a mg/l Anirnonia 6.5 mg/l

-- Nitrates 3.8 mg/l

. .

d

Ortho-Phosphate 14.5 indl

93.3 mg/l Chlorides 7 - r .

90"' percentile _. ,: 402.0 1113/day

2579.7 mg/l 751.0 kg/day 1548.0 mg/l 393.0 mdl 238.6 mdl

25.4 mg/l

1 17.6 mg/l

-.--

.-

... 10.9 mg/l L C

5.7 nigl .- I.

With ,the exception of Ammonia, the loading data provided by Glmbia ofthe discharge from the Glanbia complex for the period from January to July of 2006 would suggest tlut they are in line with the discharge limits proposed under the current liccnce application.

However, these values are much larger than the capacity allocated to Glanbia in the design of the upgaded Wastewater Tredtment Plant, and is therefore not pemiissible by Drogheda Borough Council. 'With regard to the previously agreed reserved capacity, Table No. 5 below indicates what level of discharge the Drogheda Wastewater Treatment Plant would be in a position to accept fiom Glanbia.

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- -_ .. . . _ _ . __ . _ _ . . . .. . . .. .- . . .~ ... . _ . . . . . . .

Y -. BOD

S us p elided So 1 ids

Oil, Grease, Fats Sulphates Ammonia

Ortho-Phosphate Nilrbtes

Chlorides

b

P

iliaximuin discharge, 600 m3/day maxim uni discharge

500 kg/d 1,700rng4

-n 250 mg/l

I.

190 3f3Qmg/l _r

10 mg/I (N)

I.. 10 mg/lW) 150 mg/l (Cl)

30 mg/l (P)

Table No. 5

Acceptable Lbischarge Limits from Glahbia

.-.. e...-.

Parameter Volume

Note: However rhe combination of volrcwte and concentradon. the BOD load to be dbcharged ra the Wastewaler lreatment Plant must no[ exceed 500 k&d.

To achieve these discharge limits, it may be necessary for Glanbia to provide some form ofpre- treatment: of effluent on site prioi- to discharging it into the sewer. hi this respect, i t is envisaged that BATNEEC will be the requiremenl of a pre-treatment process, so that some discussion needs to take place on what coiislitutes a pre-trcalment technology that gives a signifi,c*mt reducrion in effluent strength and load, but which does not entail excessive cost.

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