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IPC Application Form V2/15 ATTACHMENT E: EMISSIONS Attachment E.1: Emissions to Atmosphere This attachment contains the following: E.1.1: Drawing 5 Location of Emission Points to Atmosphere For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 25-08-2016:02:11:53

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  • IPC Application Form V2/15

    ATTACHMENT E: EMISSIONS

    Attachment E.1: Emissions to Atmosphere

    This attachment contains the following:

    E.1.1: Drawing 5 Location of Emission Points to Atmosphere

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Location of Emission points to Atmosphere

    20.08.2016

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  • IPC Application Form V2/15

    Attachment E.2: Emissions to Surface Water

    This attachment contains the following:

    E.2.1: Drawing 6 Location of Emission Point to Surface Water

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Location of Emission Points to Surface Water

    20.08.2016

    1:1250

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  • IPC Application Form V2/15

    Attachment E.3: Emissions to Sewer

    This attachment contains the following:

    E.3.1: Drawing 7: Location of Emission Point to Sewer

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Location of Emission Points to Sewer

    20.08.2016

    1:1250

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  • IPC Application Form V2/15

    Attachment E.4: Emissions to Ground

    This attachment contains the following:

    E.4.1: Drawing 8: Location of Emission Points to Ground

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Location of Emission Points to Ground

    20.08.2016

    1:1250

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  • IPC Application Form V2/15

    Attachment E.5: Noise Emissions

    This attachment contains the following:

    E.5.1: Drawing 9: Noise Monitoring Locations

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Noise monitoring locations

    20.08.2016

    1:1250

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  • IPC Application Form V2/15

    ATTACHMENT F: CONTROL & MONITORING

    Attachment F.2: Emissions Monitoring

    This attachment contains the following:

    F2.1: Drawing 10: Monitoring Locations for Emissions to Atmosphere

    F2.2: Drawing 11: Monitoring Locations for Emissions to Surface Water

    F2.3: Drawing 12: Monitoring Locations for Emissions to Sewer

    F2.4: Drawing 13: Noise Monitoring Locations

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Monitoring locations for Emissions to Atmosphere

    20.08.2016

    1:1250

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Monitoring Locations for Emissions to Surface Water

    20.08.2016

    1:1250

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Monitoring Locations for Emissions to Sewer

    20.08.2016

    1:1250

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Noise monitoring locations

    20.08.2016

    1:1250

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  • IPC Application Form V2/15

    ATTACHMENT G: RESOURCE USE & ENERGY EFFICIENCY

    There are no attachments associated with Section G.

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  • IPC Application Form V2/15

    ATTACHMENT H: MATERIALS HANDLING

    Attachment H.1: Raw Materials, Intermediates and Product Handling

    This attachment contains the following:

    H.1.1: Drawing 14: Main Areas and Storage Locations

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  • Revisions Date ClientJob

    Title

    Drawn

    Checked

    Drawing No. Rev

    Scale @ A3

    20 Cruises street

    Limerick,

    V94 R6P9, Ireland

    tel

    (061) 312 249

    e-mail: [email protected]

    63 Fitzwilliam sq

    Dublin 2

    D02 N938, Ireland

    tel

    (01) 670 7677

    e-mail: [email protected]

    DateIPC licence review submission Analog Devices

    Noise monitoring locations

    20.08.2016

    1:1250

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  • IPC Application Form V2/15

    ATTACHMENT I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

    Attachment I.1: Assessment of Atmospheric Emissions

    This attachment contains the following:

    I.1.1: Air Dispersion Modelling Study

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  • Byrne Ó Cléirigh, 30a Westland Square, Pearse Street, Dublin 2, D02 PN76, Ireland. Telephone: + 353 – 1 – 6770733. Facsimile: + 353 – 1 – 6770729. Email: [email protected]. Web: www.boc.ie

    Directors: LM Ó Cléirigh BE MIE CEng FIEI FIMechE; TV Cleary BE CEng FIEI FIChemE; LP Ó Cléirigh BE MEngSc MBA CEng MIEI;

    ST Malone BE MIE CEng MIEI; JB FitzPatrick FCA. Registered in Dublin, Ireland No. 237982.

    Air Dispersion Modelling Report

    In support of an application for the review of Licence P0224-02

    Prepared for:

    Analog Devices

    Ref: 431-X0013 R0

    18th August 2016

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  • Byrne Ó Cléirigh Consulting i Air Dispersion Modelling Study for Analog Devices

    431-X0013 R0 18th August 2016

    DISCLAIMER

    This report has been prepared by Byrne Ó Cléirigh Limited with all reasonable skill, care and diligence within the terms of the Contract with the Client, incorporating our Terms and Conditions and taking account of the resources devoted to it by agreement with the Client.

    We disclaim any responsibility to the Client and others in respect of any matters outside the scope of the above.

    This report is confidential to the Client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies upon the report at their own risk.

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  • Byrne Ó Cléirigh Consulting ii Air Dispersion Modelling Study for Analog Devices

    431-X0013 R0 18th August 2016

    Contents

    1 INTRODUCTION ................................................................................................................... 1

    2 SITE DESCRIPTION ................................................................................................................ 2

    2.1 Production Activities ...................................................................................................... 2

    2.2 Emission Sources ........................................................................................................... 3

    2.3 Adjacent Licensed Facilities ............................................................................................ 5

    2.4 Site Environs .................................................................................................................. 5

    3 DISPERSION MODELLING SCENARIOS ................................................................................... 8

    3.1 Overview ....................................................................................................................... 8

    3.2 Inorganic Substances ..................................................................................................... 8

    3.3 Organic Substances ........................................................................................................ 8

    3.4 Combustion Emissions ................................................................................................... 9

    4 DISPERSION MODEL ........................................................................................................... 10

    4.1 Modelling Programmes ................................................................................................ 10

    4.2 Input Data ................................................................................................................... 10

    4.3 Background Concentrations ......................................................................................... 13

    4.4 Modelling Outputs ....................................................................................................... 16

    5 ASSESSMENT CRITERIA ....................................................................................................... 17

    5.1 Introduction ................................................................................................................ 17

    5.2 Inorganic Substances ................................................................................................... 19

    5.3 Organic Substances ...................................................................................................... 20

    5.4 Combustion Products ................................................................................................... 21

    6 ASSESSMENT OF RESULTS .................................................................................................. 22

    6.1 Introduction ................................................................................................................ 22

    6.2 Inorganics Substances .................................................................................................. 22

    6.3 Organic Substances ...................................................................................................... 27

    6.4 Combustion Emissions ................................................................................................. 29

    6.5 Cumulative Impact Assessment .................................................................................... 32

    6.6 Protection of Vegetation .............................................................................................. 34

    7 SENSITIVITY STUDY ............................................................................................................ 36

    7.1 Overview ..................................................................................................................... 36

    7.2 Results ........................................................................................................................ 37

    8 CONCLUSIONS ................................................................................................................... 38

    8.1 Overview ..................................................................................................................... 38

    8.2 Inorganic Substances ................................................................................................... 38

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  • Byrne Ó Cléirigh Consulting iii Air Dispersion Modelling Study for Analog Devices

    431-X0013 R0 18th August 2016

    8.3 Organic Substances ...................................................................................................... 39

    8.4 Combustion Emissions ................................................................................................. 39

    8.5 Overall Site Impact ...................................................................................................... 40

    APPENDIX 1: SITE LAYOUT

    APPENDIX 2: WIND ROSES

    APPENDIX 3: CONTOUR PLOTS

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  • Byrne Ó Cléirigh Consulting 1 Air Dispersion Modelling Study for Analog Devices

    431-X0013 R0 18th August 2016

    1 INTRODUCTION

    This report by Byrne Ó Cléirigh describes an air dispersion modelling assessment for Analog Devices (AD), Limerick in support of an application to the Environmental Protection Agency (EPA) for a review its Integrated Pollution Control (IPC) licence, Register No. P0224-02. The application for the review relates to the extension of the production area of the site which will introduce three new boiler emission points to atmosphere and five new process emission points to atmosphere. Both the boiler emission points and the process emission points are similar in scale and emissions to the existing emission points at the site. The modelling predicted the ground level concentrations for the following parameters:

    • total fluorides (as HF)

    • total acids (as HCl)

    • total bromides (as HBr),

    • TA Luft inorganic dust particulates class II

    • TA Luft inorganic dust particulates class III

    • total particulate matter

    • TA Luft organics Class I

    • TA Luft organics Class II

    • total organic carbon (as C)

    • nitrogen oxides (as NO2)

    • carbon monoxide (CO)

    The modelling was conducted in accordance with the EPA’s Air Dispersion Modelling from Industrial Installations Guidance Note (AG4) and the predicted ground level concentrations were assessed in the context of ambient quality standards and guidance values, taking into consideration background concentrations.

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  • Byrne Ó Cléirigh Consulting 2 Air Dispersion Modelling Study for Analog Devices

    431-X0013 R0 18th August 2016

    2 SITE DESCRIPTION

    2.1 Production Activities AD designs, develops, manufactures and markets high-performance analogue, mixed-signal, and digital signal processing (DSP) integrated circuits (IC) used in signal processing applications. The core manufacturing process carried out at the Limerick facility is wafer fabrication. In wafer fabrication, integrated circuits are fabricated on a wafer (a thin disc of silicon). Between 100 and 3,000 IC are fabricated on a single wafer, with the actual number of chips per wafer dependent on the complexity and size of the chip.

    Wafer fabrication involves the processing of pure silicon wafers through various process steps (layering, patterning, doping) using a variety of chemicals (acidic solutions, etchants, silicon oxide, adhesives, emulsions, developing solutions, activators, dopants), followed by the finishing processes (probing, testing, branding and assembly).

    The wafer fabrication process begins with a wafer of silicon. Several steps change the electronic structure of the wafer according to a precise plan. The process of fabricating a wafer is complex, comprising between 250 and 350 individual steps, depending on the type of device being fabricated. However, despite the number of steps that may be required to produce a particular type of IC, only three basic operations are performed on a wafer:

    • layering, in which thin layers of different materials are grown on or added to the wafer surface

    • patterning, in which portions of the thin layers are selectively removed from the wafer

    • doping, in which the resistivity and conductivity type of selected regions of the wafer are changed by the addition of dopants

    To support the manufacturing operations on the site, a number of utilities are required to provide the raw materials, special conditions and services necessary for the manufacturing process. These include:

    • bulk compressed & liquefied gas storage & distribution (argon, nitrogen, oxygen, hydrogen)

    • chemical management systems

    • compressed air distribution

    • drainage systems (including acid and solvent waste drainage systems)

    • electricity distribution

    • exhaust systems (acid and solvent exhausts)

    • fire & gas detection

    • heating, ventilation and air conditioning (HVAC)

    • hot water generation & distribution

    • natural gas distribution

    • sprinkler system

    • telecoms

    • vacuum systems

    • waste management

    • wastewater treatment plant

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  • Byrne Ó Cléirigh Consulting 3 Air Dispersion Modelling Study for Analog Devices

    431-X0013 R0 18th August 2016

    • water treatment & distribution (de-ionised, chilled, closed loop)

    In addition, AD operates a number of systems to treat the emissions to atmosphere and the discharges to sewer from the site. The main abatement, treatment and recovery systems are:

    • vertical packed bed wet scrubbers

    • a packed bed wet scrubber

    • a horizontal packed bed wet scrubber

    • scrubber for treatment of emissions to atmosphere from the effluent plant

    • individual abatement systems for individual tools in which exhaust gases from the process are combusted with natural gas before being discharged to atmosphere via one of the main emission points

    • pH correction / adjustment of aqueous waste from production discharged to sewer

    2.2 Emission Sources

    2.2.1 Boiler Emissions

    There are currently five boiler emissions to atmosphere associated with five natural gas fired boilers providing space heating to the production, office and ancillary areas across the facility. The construction of the new production area will introduce three new boilers and three new emission points to atmosphere. These emission points are listed in Table 1 (the new emission points are marked with an asterisk).

    Table 1: Boiler Emission Points

    Designation Description

    A1-1 Boiler 3 at G3 plant area

    A1-2 Boiler 2 at G3 plant area

    A1-3 Boiler 1 at G3 plant area

    A1-4 Boiler 1 at G3 plant room extension

    A1-5 Boiler 2 at G3 plant room extension

    A1-6* IPD boiler no. 1

    A1-7* IPD boiler no. 2

    A1-8* IPD boiler no. 3

    2.2.2 Process Emissions

    There are currently twelve main emission points to atmosphere serving the existing production areas of the site, as summarised in Table 2.

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  • Byrne Ó Cléirigh Consulting 4 Air Dispersion Modelling Study for Analog Devices

    431-X0013 R0 18th August 2016

    Table 2: Current Main Emission Points to Atmosphere

    Designation Description

    A2-1 6” FAB scrubber no. 4

    A2-2 6” FAB scrubber no. 3

    A2-3 Pumped exhaust from FAB

    A2-4 6” FAB scrubber no. 1

    A2-5 6” FAB scrubber no. 2

    A2-6 6” FAB scrubber

    A2-10 Aqua Regia scrubber

    A2-11 Effluent plant scrubber

    A2-12 Solvent exhaust 6” FAB No. 3

    A2-13 Solvent exhaust 6” FAB No. 1

    A2-14 Solvent exhaust 6” FAB No. 2

    A2-15 Solvent exhaust 6” FAB No. 4

    Emission points A2-1, A2-2, A2-4, A2-5 and A2-6 are the discharges from abatement systems that treat the emissions from the production areas. The parameters that are discharged from these emission point include inorganic acids, inorganic dust particulates, and total particulate matter.

    Emission point A2-3 also discharges via a scrubber unit, with the emissions comprising inorganic acids, inorganic dust particulates, and total particulate matter. Due to the nature of the production processes and the materials that are used in the processes that ultimately discharge via this emission point, the licensed parameters include total bromides and TA Luft class II inorganic dust particulates.

    The developments at the site include the introduction of five new main emission points to atmosphere as set out in Table 3. Three of the five new emission points will discharge inorganic acids (total fluorides, total bromides and total acids), class III inorganic dusts and total particulates. Each of the emission points will discharge via a new abatement system (one scrubber for each of the emission points). The fourth and fifth new main emission points will discharge organic substances (solvents) similar to those discharged from the existing emission points A2-12, A2-13, A2-14 and A2-15.

    Table 3: New Main Emission Points to Atmosphere

    Designation Description

    A2-7 IPD scrubber 1

    A2-8 IPD scrubber 2

    A2-9 IPD scrubber 3

    A2-16 IPD solvent exhaust no. 1

    A2-17 IPD solvent exhaust no. 2

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    2.2.3 Stack Parameters

    The substances discharged to atmosphere from the existing and new emission points to atmosphere are shown in Table 5, together with the stack height, stack diameter and volumetric flow rate.

    2.3 Adjacent Licensed Facilities The closest licensed facilities to AD are listed in Table 4 (those within 5 km of the site), with the closest of these located approximately 0.3 km from the site. Three of the facilities are licensed to discharge similar substances to atmosphere as those that arise at AD. In light of the proximity of these sites to AD and the EPA’s guidance on conducting cumulative impact assessments, the emissions from the adjacent facilities have been included in this air dispersion modelling study.

    Table 4: Adjacent Licensed Facilities

    Reg. No. Site Distance from AD (m) Licensed Emissions to

    Atmosphere

    P0023-03 Howmedica International S.de R.L. Trading As Stryker Orthopaedics

    286 Inorganic class II

    Inorganic class III

    Total particulates

    Total organic carbon

    P0029-03 Irish Cement Limited (Limerick) 3,124 -

    P0329-01 James McMahon Limited 3,218 -

    P0452-01 Adhesives Research Ireland Limited 921 Total organic carbon

    P0991-01 Regeneron Ireland 616 Nitrogen oxides

    Carbon monoxide

    W0082-02 Starrus Eco Holdings Limited (Dock Road) 2.7 -

    2.4 Site Environs The AD facility is located in Raheen Industrial Estate approximately 5 km south-west of Limerick City. The site comprises seven buildings within the park, including the main wafer fabrication building. The site is surrounded by a combination of other industrial buildings, open car parking and residential housing areas. In 2014, a new building comprising office accommodation, engineering design offices, laboratories, a canteen and ancillary facilities – the European Research and Development Centre – was constructed to the northwest of Building 1.

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    Table 5: Boiler & Main Emission Stack Parameters

    Ref. Diameter (m) Flow Rate (Nm3/h)

    Temp. (K)

    Stack Height

    (m)

    Concentration (mg/Nm3)

    Fluorides (HF)

    Bromides (HBr)

    Total Acids (HCl)

    Inorganics Class II

    Inorganics Class III TPM

    Organics Class I

    Organics Class II TOC NO2 CO

    A1-1 0.70 1,300 405 19.5 - - - - - - - - - 140 35

    A1-2 0.70 1,700 400 19.5 - - - - - - - - - 145 20

    A1-3 0.48 1,400 420 19.5 - - - - - - - - - 160 20

    A1-4 0.60 3,200 430 19.5 - - - - - - - - - 140 50

    A1-5 0.60 4,000 420 19.5 - - - - - - - - - 130 5

    A1-6* 0.70 2,750 415 19.5 - - - - - - - - - 140 50

    A1-7* 0.70 2,750 415 19.5 - - - - - - - - - 140 50

    A1-8* 0.70 2,750 415 19.5 - - - - - - - - - 140 50

    A2-1 1.48 64,800 289 19.5 0.2 - 5 - 0.5 20 - - - - -

    A2-2 1.48 64,800 289 19.5 0.2 - 5 - 0.5 20 - - - - -

    A2-3 0.65 15,000 289 19.5 0.4 5 5 0.01 0.5 20 - - - - -

    A2-4 1.48 64,800 289 19.5 0.2 - 5 - 0.5 20 - - - - -

    A2-5 1.48 64,800 289 19.5 0.2 - 5 - 0.5 20 - - - - -

    A2-6 1.48 64,800 289 19.5 0.2 - 5 - 0.5 20 - - - - -

    A2-7* 1.48 64,800 289 19.5 0.2 5 5 - 0.5 20 - - - - -

    A2-8* 1.48 64,800 289 19.5 0.2 5 5 - 0.5 20 - - - - -

    A2-9* 1.48 64,800 289 19.5 0.2 5 5 - 0.5 20 - - - - -

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    Ref. Diameter (m) Flow Rate (Nm3/h)

    Temp. (K)

    Stack Height

    (m)

    Concentration (mg/Nm3)

    Fluorides (HF)

    Bromides (HBr)

    Total Acids (HCl)

    Inorganics Class II

    Inorganics Class III TPM

    Organics Class I

    Organics Class II TOC NO2 CO

    A2-10 0.60 6,000 289 12.75 0.4 5 10 - - - - - - - -

    A2-11 0.15 1,545 293 11.5 5 - 5 - - - - - - - -

    A2-12 0.62 9,216 292 17.8 - - - - - - 15 80 75 - -

    A2-13 0.62 9,216 290 17.8 - - - - - - 15 80 75 - -

    A2-14 0.62 9,216 291 17.8 - - - - - - 15 80 75 - -

    A2-15 0.62 9,216 293 17.8 - - - - - - 15 80 75 - -

    A2-16* 0.62 9,216 289 19.5 - - - - - - 15 80 75 - -

    A2-17* 0.62 9,216 289 19.5 - - - - - - 15 80 75 - -

    Note 1: Emission points marked with an asterisk (*) are the new emission points associated with the site development.

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    3 DISPERSION MODELLING SCENARIOS

    3.1 Overview The development of the site will give rise to changes in the emissions to atmosphere. The demolition of the existing building to the east of the main production building and the construction of the extension will alter the downwash structures which could potentially influence the atmospheric dispersion of the emissions to atmosphere. Secondly, the development will introduce the new boiler and main emission points to atmosphere. Therefore, in order to assess the impact of the emissions to atmosphere from the site, the following scenarios have been modelled:

    1. Existing case: the impact from existing emissions to atmosphere for each of the licensed parameters at the respective licence limits

    2. Future case: the impact from the combination of the existing emissions and the new emissions for each of the licensed parameters at the respective licence limits

    These scenarios are described in the following sub-sections.

    3.2 Inorganic Substances Table 6 summarises the emission rates (in grams per second) for the inorganic substances that are discharged from the existing main emission points and those that will be discharged from the new main emission points.

    Table 6: Summary of Inorganic Substances Discharged to Atmosphere (g/s)

    Ref. Description HF HBr HCl Class II Class III TPM

    A2-1 6” FAB scrubber no. 4 0.0036 0 0.090 0 0.0090 0.36

    A2-2 6” FAB scrubber no. 3 0.0036 0 0.090 0 0.0090 0.36

    A2-3 Pumped exhaust from FAB 0.0017 0.0208 0.021 0.00004 0.0021 0.08

    A2-4 6” FAB scrubber no. 1 0.0036 0 0.090 0 0.0090 0.36

    A2-5 6” FAB scrubber no. 2 0.0036 0 0.090 0 0.0090 0.36

    A2-6 6” FAB scrubber 0.0036 0 0.090 0 0.0090 0.36

    A2-7* IPD scrubber 1 0.0036 0.0900 0.090 0 0.0090 0.36

    A2-8* IPD scrubber 2 0.0036 0.0900 0.090 0 0.0090 0.36

    A2-9* IPD scrubber 3 0.0036 0.0900 0.090 0 0.0090 0.36

    A2-10 Aqua Regia scrubber 0.0007 0 0.017 0 0 0

    A2-11 Effluent plant scrubber 0.0021 0 0.002 0 0 0

    3.3 Organic Substances Table 7 summarises the emission rates (in grams per second) for the organic substances that are discharged from the existing main emission points and those that will be discharged from the new main emission points:

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    Table 7: Summary of Organic Substances Discharged to Atmosphere (g/s)

    Ref. Description Organics Class I Organics Class II TOC

    A2-12 Solvent exhaust 6” FAB No. 3 0.04 0.20 0.19

    A2-13 Solvent exhaust 6” FAB No. 1 0.04 0.20 0.19

    A2-14 Solvent exhaust 6” FAB No. 2 0.04 0.20 0.19

    A2-15 Solvent exhaust 6” FAB No. 4 0.04 0.20 0.19

    A2-16* IPD solvent exhaust no. 1 0.04 0.20 0.19

    A2-17* IPD solvent exhaust no. 2 0.04 0.20 0.19

    3.4 Combustion Emissions Table 7 summarises the emission rates (in grams per second) for the combustion substances that are discharged from the existing boiler emission points and those that will be discharged from the new boiler emission points; the emission rates for the new boilers are conservative estimates based on the monitoring results from the existing boilers.

    Table 8: Summary of Combustion Substances Discharged to Atmosphere (g/s)

    Ref. Description NO2 CO

    A1-1 Boiler 3 at G3 plant area 0.051 0.013

    A1-2 Boiler 2 at G3 plant area 0.068 0.009

    A1-3 Boiler 1 at G3 plant area 0.062 0.008

    A1-4 Boiler 1 at G3 plant room extension 0.124 0.044

    A1-5 Boiler 2 at G3 plant room extension 0.144 0.006

    A1-6* IPD boiler no. 1 0.107 0.038

    A1-7* IPD boiler no. 2 0.107 0.038

    A1-8* IPD boiler no. 3 0.107 0.038

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    4 DISPERSION MODEL

    4.1 Modelling Programmes The following proprietary software packages were used to conduct and assess the air dispersion modelling:

    • BREEZE AERMOD, a dispersion modelling system that simulates essential atmospheric physical processes and provides refined concentration estimates over a wide range of meteorological conditions and modelling scenarios. Ground level concentrations are determined for specified averaging periods; e.g. 1-hour.

    • BREEZE AERMAP, a terrain pre-processor used to prepare the terrain information required by AERMOD for complex terrain scenarios.

    • BREEZE BPIP (Building Profile Input Programme), which is used to model the effects of building downwash on the emission from the stack.

    • BREEZE 3D Analyst, a post-processing package used to analyse the raw data from the dispersion modelling programme.

    The latest versions of each of the modelling packages were used. The model was run for the scenarios as described in Section 3.

    4.2 Input Data

    4.2.1 Site Buildings & Structures

    The length, width, height and the co-ordinates of the buildings and building structures across the site were entered into the model. In addition, large off-site buildings with the potential to impact on the building downwash were entered into the model, including the building used by Provincial Flooring adjacent to Ballynoe Road and the BS&B building adjacent to Cloghkeating Avenue.

    4.2.2 Emissions & Emission Rates

    The emission parameters set out in Table 5, Table 6, Table 7 and Table 8 were entered into the model.

    4.2.3 Emission Durations & Frequencies

    As set out in the EPA’s guidance, each of the emission points has been modelled on the basis of 24 hour per day, 365 day per year operation as each of the emission points could be operational at any time of the year. However, in practice, the emission points do not operate on a continuous basis for 365 days of the year.

    4.2.4 Stack Heights

    As part of the development of the site, the heights of several of the existing stacks are being increased. For the purpose of this air dispersion modelling study, the planned stack heights have been used to assess the off-site ground level concentrations of the respective parameters.

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    4.2.5 Meteorological Data

    The meteorological station at Shannon airport is the closest Met Éireann weather station to the site. However, the Shannon station does not record upper air meteorological data, which is used to calculate parameters such as the mixing height; the closest station that records upper air meteorological data is the Valentia observatory weather station.

    The EPA’s guidance requires a minimum of three years of meteorological data to be used, with the most recent year of the three year dataset to be within ten years of the date of the dispersion modelling study.

    For this study, AERMOD-ready meteorological data from the Shannon and Valentia weather stations for the three years from 2008 to 2010 has been used. In order to model the deposition of particulate matter discharged to atmosphere, rainfall data from the Shannon meteorological station over the same period (2008 to 2010) has also been used, with the data available from Met Éireann.

    The wind roses for the three years 2008 to 2010 are included in Appendix 2.

    4.2.6 Digital Terrain Data

    Digital terrain data for the site and the surrounding area was provided by the Ordnance Survey of Ireland on a 10 m grid. The elevations of each co-ordinate of the model grid were extracted from this data and entered into the model via the AERMAP pre-processor. Buildings entered in the model at specific co-ordinates were automatically assigned an elevation based on the terrain data.

    4.2.7 Surface Roughness

    The location of the site is rural as per the EPA’s guidance on determining whether a source is located in an urban or rural setting, namely that the urban option should be selected if greater than 50% of the area within a 3 km radius of the source (site) is either industrial, commercial or compact residential. As shown on the site layout in Appendix 1, the majority of the land within 3 km of AD is rural, with approximately 25% to 30% falling within the definition of an urban setting. Therefore, the urban option in AERMOD has not been selected and the surface roughness data from the AERMOD-ready meteorological data files has been used.

    4.2.8 Receptor Points

    Two Cartesian grids of receptor points around the site and its environs were set up in the model. The first grid (Grid 1) extends a minimum of 750 m in each direction from the perimeter of the site, while the second grid (Grid 2) was set at a finer resolution in the immediate vicinity of the site. Table 9 provides the details for the two grids.

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    Table 9: Receptor Grids

    Grid 1 Grid 2

    Length 2,000 m Length 1,000 m

    Width 2,500 m Width 1,250 m

    Grid spacing 100 m Grid spacing 25 m

    Number of receptor points 546 Number of receptor points 2091

    The grid used in the model contained the maximum ground level concentrations for all of the modelled parameters. It extends beyond the site boundary to each of the neighbouring areas described in Section 2.4.

    4.2.9 NO2 / NOX Chemistry

    The EPA’s guidance notes that during combustion processes, a mixture of both nitric oxide (NO) and nitrogen dioxide (NO2) is released to atmosphere, following which a series of chemical reactions take place. During these reactions, a portion of the nitric oxide reacts with ozone (O3) and is converted to nitrogen dioxide. In turn, nitrogen dioxide can react with sunlight to form nitric oxide and ozone, with the reactions ultimately resulting in a quasi-equilibrium ratio of NO2 to NOX.

    There are a number of methods available within AERMOD to model the dispersion of oxides of nitrogen. The EPA’s guidance notes that the Plume Volume Molar Ratio Method (PVMRM) shows better agreement with monitoring data than the other options in AERMOD, and therefore this method was selected in the air dispersion modelling study. The input parameters required for the PVMRM are:

    • the background concentration of ozone (O3) (refer to Section 4.3.6)

    • the NO2 / NOX equilibrium ratio (a value of 0.9)

    • the in-stack NO2 / NOX ratio (a value of 0.1)

    4.2.10 Particulate Matter

    The particulate matter discharged from AD is expressed in terms of total particulate matter and TA Luft organics class II and class III particulates. As part of the air emissions monitoring programme, the TA Luft inorganic particulates are analysed for the individual constituents, as summarised in Table 10.

    Table 10: TA Luft Inorganic Particulates

    Class II Class III

    Cobalt Chromium

    Lead Copper

    Nickel Manganese

    Selenium Tin

    Tellurium Vanadium

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    Previous analysis of the particulate matter discharged to atmosphere shows that the PM10 fraction is approximately 26%. As there are no air quality standards or other assessment levels for particulate matter greater than PM10, the particulate emissions have been modelled based on the PM10 fraction and assessed against the corresponding assessment criteria (refer to Section 5).

    AERMOD provides two methods for modelling the dispersion of particulate matter. The first method (method 1) requires data on the particulate size distribution and the average density of the particulates, while the second method (method 2) requires data on the mean particulate diameter and the fine mass fraction (the fraction of particulates with a diameter less than 2.5 m). Method 2 is generally used when the particulate size distribution is not well known and when a small fraction (less than 10% of the mass) is in particulates with a diameter of 10 m or larger. As a significant proportion of the particulates discharged from AD are larger than 10 m, Method 1 has been applied. In this case, the modelled emission rates (expressed in PM10) are taken as 26% of the licensed emission rate.

    4.3 Background Concentrations

    4.3.1 Overview

    In order to assess the overall contribution of the emissions to atmosphere from a site in the context of the air quality standard (or guidance value), the background concentration of the particular parameter must also be considered. The EPA maintains a number of ambient monitoring stations throughout the country for a range of parameters, which record background data on an hour-by-hour or a day-by-day basis.

    The EPA provides guidance on the methods for combining the predicted process contribution with the available background data in order to calculate the overall predicted environmental concentration (PEC). It is conservatively assumed that the maximum background concentration from a particular station overlaps spatially with the maximum predicted process contribution, and therefore it is appropriate to use such background data for the purpose of estimating the PEC.

    It is also assumed that the background concentrations will be greatest during stable atmospheric conditions. Where the maximum predicted process contribution also occurs during periods of stable atmospheric conditions, it is necessary to adopt a conservative approach to combine the process contribution and the background contribution. One method for combining these data, as identified by the EPA, is that set out in the UK Department for Environment and Rural Affairs (DEFRA) Local Air Quality Management Technical Guidance document. The methods for estimating the total contribution of nitrogen dioxide and particulate matter (for which DEFRA and the Environment Agency have produced guidance) are set out in Sections 4.3.5 and 4.3.3, respectively.

    In terms of accounting for the contribution of existing emissions on the background concentrations, the EPA’s guidance notes that monitoring is not an effective method to obtain information on the impact of an existing industrial installation, particularly when emissions are mainly from stacks. In light of this the background concentrations of the parameters are conservatively assumed not to include the existing contribution from the site.

    4.3.2 Monitoring Locations

    Limerick is located in a Zone C air quality zone, covering cities (other than Dublin and Cork) and large towns. Historically, the EPA has operated air quality monitoring stations in Limerick City at Cathedral Place and Park Road. Monitoring at Cathedral Place (at the fire station) was carried out between

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    January and November 2000 utilising a mobile laboratory which monitored for carbon monoxide, sulphur dioxide, oxides of nitrogen, particulate matter, benzene, lead and other metals. The report on the monitoring programme (Ambient Air Monitoring in Limerick City: January 26th 2000 – 13th November 2000) determined that:

    No limit values were exceeded during the measurement period

    The report also noted that:

    Concentrations of carbon monoxide, sulphur dioxide, nitrogen dioxide, benzene and lead were below their respective lower assessment thresholds. Levels of PM10 exceeded the upper assessment threshold for this parameter.

    The Park Road station was located at the Limerick City Council laboratories (over 5.5 km to the northeast of the AD site) and monitored for ozone and nitrogen oxides; monitoring at the station ceased at the end of 2011. The most recent results (2011) for oxides of nitrogen showed that the one hour limit of 200 g/m3 was exceeded on 25 occasions during the year compared to a limit of 18 times per year. The annual average concentration of oxides of nitrogen over the period was 20.3 g/m3 compared to a limit value of 40 g/m3. The most recent results (2011) for ozone showed that over the period the eight hour average exceeded 120 g/m3 on five occasions against a limit of 25 occasions (it satisfied the air quality requirements).

    The closest current monitoring station is Shannon Estuary, located in Ballysteen, approximately 20 km to the west of the AD site. The monitoring station is located in a Zone D air quality zone and therefore the results from this station are not considered to be representative of the area in the vicinity of the AD site. In the absence of recent data on background concentrations from the Limerick monitoring station, the data from other Zone C monitoring stations has been utilised, with the stations at Galway and Waterford considered to be the more representative as their populations are closest to those of Limerick.

    4.3.3 Inorganic Substances

    The EPA does not maintain monitoring stations to monitor for background (ambient) concentrations of total fluorides, total bromides or total acids and therefore background concentrations for these parameters have not been included within this study. Similarly, the EPA does not maintain monitoring stations for background concentrations of TA Luft inorganic particulates (either class II or class III).

    The background concentration of particulate matter (as PM10) in the vicinity of the site was estimated based upon the results of the EPA’s air quality monitoring programme for the Galway (Bodkin) monitoring station over the period 2007 to 2014. The background data is summarised in Table 12.

    Table 11: Summary of Background Data for Particulate Matter (PM10)

    Parameter Station Averaging Period Average Background Value

    Particulate Matter

    (as PM10) Bodkin, Galway

    90.4th percentile, 24-hour 28.7 g/m3

    Annual average 16.6 g/m3

    The data was not used directly within the model, but rather was used in the analysis of the results and the assessment of the impact of the emission from the site in the context of the overall air

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    quality for the vicinity of the site, based upon the requirements of the Air Quality Standards Regulations (2011).

    The total contribution of PM10 (background and process) has been estimated using the method set out in the Appendix E of the EPA’s guidance. Using this approach, the 90.4th percentile of total 24-hour mean PM10 is equal to the maximum of:

    a) 90.4th percentile 24-hour mean background PM10 + annual mean process contribution

    or

    b) 90.4th percentile 24-hour mean process contribution PM10 + annual mean background PM10

    4.3.4 Organic Substances

    The EPA does not maintain monitoring stations to monitor for background (ambient) concentrations of TA Luft organic substances or of total organic carbon, and therefore background concentrations have not been included within this study.

    4.3.5 Combustion Parameters

    The background concentration of nitrogen oxides (as NO2) in the vicinity of the site was estimated based upon the results of the EPA’s air quality monitoring programme for the Limerick (Park Road) monitoring station over the period 2008 to 2011. Similarly, the background concentration of carbon monoxides in the vicinity of the site was estimated based upon the results of the EPA’s air quality monitoring programme for the Waterford (the Mall) monitoring station over the period 13th January 2007 to 18th February 2008. The background data is summarised in Table 12.

    Table 12: Summary of Background Data for Nitrogen Oxides & Carbon Monoxide

    Parameter Station Averaging Period Average Background Value

    Nitrogen oxides

    (as NO2) Park Road, Limerick

    99.8th percentile, 1-hour 82.7 g/m3

    Annual average 15.6 g/m3

    Carbon monoxide The Mall, Waterford 8-hour average 1.91 mg/m3

    The data was not used directly within the model, but rather was used in the analysis of the results and the assessment of the impact of the emission from the site in the context of the overall air quality for the vicinity of the site, based upon the requirements of the Air Quality Standards Regulations (2011).

    In assessing the combination of the short-term (1-hour) ground level concentrations of nitrogen dioxide and the background concentrations, the approach set out in Appendix E from the EPA’s guidance has been adopted. Using this approach, the 99.8th percentile of total nitrogen dioxide is equal to the minimum of:

    a) 99.8th percentile hourly background total oxidant (O3 & NO2) plus 0.05 × 99.8th percentile process contribution

    or the maximum of

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    b)

    (i) 99.8th percentile process contribution NOX + 2 × annual mean background NO2

    or

    (ii) 99.8th percentile hourly background NO2 + 2 × annual mean process contribution NOX

    Thus, in order to estimate the total concentration of NO2 (background plus process), the background concentration of ozone (O3) must also be considered (refer to Section 4.3.6.

    4.3.6 Ozone

    The background concentration of ozone in the vicinity of the site was estimated based upon the results of the EPA’s air quality monitoring programme for the Limerick (Park Road) monitoring station over the period 2008 to 2011. The background data is summarised in Table 12.

    Table 13: Summary of Background Data for Ozone

    Parameter Station Averaging Period Average Background Value

    Ozone Park Road, Limerick 99.8th percentile, 1-hour 118.7 g/m3

    Annual average 47.1 g/m3

    The annual average background concentrations has been entered in the PVMRM method (Plume Volume Molar Ratio Method) in the AERMOD model, as set out in the EPA’s guidance, while the 99.8th percentile 1-hour value is used in the assessment of the ground level concentration of nitrogen oxides (refer to Section 6.4.1).

    4.4 Modelling Outputs The BPIP programme was run to calculate the building downwash for the model. The AERMOD programme was then run to calculate the resultant ground-level concentrations (raw data) for each of the receptor points over each of the three years of meteorological data.

    The raw data from AERMOD was subsequently analysed in 3DAnalyst. The relevant maximum concentrations for each receptor point for each of the three years over which the model was run were extracted from this raw data. These results are assessed in Section 6 against the criteria described in Section 5.

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    5 ASSESSMENT CRITERIA

    5.1 Introduction

    5.1.1 Overview

    The Air Quality Standards Regulations 2011 (SI 180 of 2011) transpose several directives relating to ambient air quality into Irish law and provide air quality standards for the following pollutants:

    • sulphur dioxide

    • nitrogen dioxide

    • benzene

    • carbon monoxide

    • lead

    • PM10 (particulate matter)

    In the absence of air quality standards, the EPA’s guidance identifies other sources for air quality standards and guidelines:

    • Danish C-values (as a 99th %ile) outlined in Danish EPA’s Environmental Guidelines No. 1, 2002, Guidelines for Air Emission Regulation - Limitation of air pollution from installations.

    • Instructions on Air Quality Control - TA Luft from the German Federal Ministry for Environment, Nature Conservation and Nuclear Safety

    • Environmental Assessment Level (EAL) based on the Health & Safety Authority publication 2007 Code of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations 2001 (S.I. No. 619 of 2001). The EAL should be derived using the approach outlined in Appendix D of UK Environment Agency “IPPC H1 -IPPC Environmental Assessment for BAT”.

    • Appendix D of the UK Environment Agency IPPC H1 - IPPC Environmental Assessment for BAT (Environment Agency, 2003).

    • World Health Organisation (WHO) Air Quality Guidelines Global Update (2005) and WHO Air Quality Guidelines for Europe (2000) for those pollutants not covered in the 2005 publication.

    • US EPA National Ambient Air Quality Standards

    5.1.2 Danish Guidelines for Air Emissions Regulation

    The Danish Ministry of Environment and Food’s Guidelines for Air Emissions Regulation (Nr. 1, 2002) sets out mass flow limits, emission limit values, and contribution values (C-values) for emissions to atmosphere. Mass-flow values and emission limit values form the basis for determining whether it is necessary to clean the air discharged to atmosphere, with limit values for emissions stipulating the maximum concentrations after abatement (or other treatment) of the emission.

    The C-value is a limit value for how much each installation may contribute to air pollution, with the hourly average contribution not permitted to exceed the C-value for more than 1% of the time (equivalent to a 99th percentile, 1-hour average). The guidelines are not binding but are intended to offer advice to the authorities on how to process cases concerning the limitation of air pollution. A more comprehensive list of C-values is set out in the Danish EPA’s publication B-værdivejledningen -

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    Oversigt over B-værdier (Nr. 2, 2002), which was updated by the Supplement til B-værdivejledningen 2008 (Nr. 1252, 2008).

    5.1.3 TA Luft Guidelines

    The TA Luft Guidelines were originally published in 1986 and were substantially revised in 2002. In TA Luft 2002, emission limit values (concentration in mg/m3) and threshold mass flow rates are assigned to individual classes of substances. TA Luft also contains immission values, which correspond with the level of a pollutant that may be present in the air outside a plant. It is usually taken at 1.5 m above ground level. The immission values in TA Luft are limited to a few pollutants.

    5.1.4 Environmental Assessment Levels

    The method identified in the EPA’s guidance is ultimately based on the UK Environment Agency’s guidance, and while the EA’s method was updated in 2008 and 2010, it was withdrawn on 1st March 2016 and replaced by Guidance on Risk Assessments for Your Environmental Permit. Part of the new assessment approach comprises guidance on Air Emissions Risk Assessment for Your Environmental Permit, which includes specific guidance on assessing the risks of:

    • air emissions

    • emissions to groundwater

    • emissions to surface water (from hazardous pollutants)

    The new guidance on assessing the risk of air emissions sets out the steps for completing the assessment. As part of the process, it requires that the process contribution and predicted environmental concentration of each substance emitted to atmosphere (and that cannot be screened as an ‘insignificant’ emission) are compared against relevant environmental standards. In this context, the guidance identifies the following environmental standards for air emissions:

    • ambient air directive limit values (for benzene, carbon monoxide, nitrogen dioxide, particulates and sulphur dioxide)

    • ambient air directive target values

    • UK air quality strategy objectives

    • environmental assessment levels (EAL)

    Although the EA provides EAL for a large number of substances, including some of those licensed at AD, it does not provide an exhaustive. In the absence of specific EAL, the approach set out in the EA’s previous H1 guidance on deriving EAL from occupational exposure limits is considered to be appropriate provided that sufficient data is available on the proportions of the individual substances discharged to atmosphere.

    5.1.5 World Health Organization

    The WHO Air Quality guidelines were originally published in 1987 and were revised in 2000. They contain a number of guideline values for the European region for both organic and inorganic substances. In 2005, the WHO published updated values for particulate matter, ozone, nitrogen dioxide and sulphur dioxide, applicable globally and replacing the guideline values for these parameters contained in the 2000 Air Quality Guidelines for Europe.

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    The primary aim of the guidelines is to provide a basis for protecting public health from adverse effects of air pollution and for eliminating, or reducing to a minimum, those contaminants of air that are known or likely to be hazardous to human health and wellbeing. The guidelines are intended to provide background information and guidance to governments in making risk management decisions, particularly in setting standards, but their use is not restricted to this.

    5.1.6 US EPA National Ambient Air Quality Standards

    Under the Clean Air Act, last amended in 1990, the US EPA is required to set National Ambient Air Quality Standards (NAAQS) for pollutants considered harmful to public health and the environment. The Clean Air Act identifies two types of national ambient air quality standards: primary standards provide public health protection, including protecting the health of sensitive populations such as asthmatics, children, and the elderly; and secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.

    The US EPA has set NAAQS for six principal pollutants (criteria air pollutants), with the standards periodically reviewed and updated. The six pollutants for which NAAQS have been set are subject to equivalent standards under the Irish Air Quality Standards Regulations and therefore the NAAQS do not provide any further sources of guideline value.

    5.2 Inorganic Substances

    5.2.1 Total Fluorides

    There are no Irish or European air quality standards for total fluorides. The most recent short term and long term assessment criteria for total fluorides were published by the Environment Agency in 2016 and are shown in Table 14.

    Table 14: Assessment Criteria for Total Fluorides (as HF)

    Source Value ( g/m3) Averaging Period

    Environmental Agency EAL 160 1 hour average

    16 Monthly average

    5.2.2 Total Bromides

    There are no Irish or European air quality standards for total bromides. The most recent assessment criteria for total bromides were published by the Environment Agency in 2016 and is shown in Table 15.

    Table 15: Assessment Criteria for Total Bromides (as HBr)

    Source Value ( g/m3) Averaging Period

    Environmental Agency EAL 700 1 hour average

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    5.2.3 Total Acids

    There are no Irish or European air quality standards for total acids. The most recent short term assessment criteria for total acids were published by the Environment Agency in 2016 and is shown in in Table 16

    Table 16: Assessment Criteria for Total Acids (as HCl)

    Source Value ( g/m3) Averaging Period

    Environmental Agency EAL 750 1 hour average

    5.2.4 TA Luft Inorganics

    There are no Irish or European air quality standards for TA Luft inorganics and there are no air quality guidelines for TA Luft inorganics. Although the individual TA Luft inorganic substances are analysed for as part of AD’s air emissions monitoring programme, the results are typically less than the respective limit of detection for the particular substances. Therefore, it is not possible to estimate the proportion of each individual substance that contributes to the overall emission of inorganic substances and compare it against an individual assessment criterion. For the purpose of this air dispersion modelling study, the emissions of inorganic substances are assessed in the context of total particulate matter (modelled as PM10).

    5.2.5 Total Particulate Matter

    The assessment criteria applicable to particulate matter (as PM10) are shown in Table 17. Although PM10 is not a licensed parameter, the assessment of this parameter can be used to provide context for the discharge of particulate matter (and inorganic particulate matter) from the site.

    Table 17: Assessment Criteria for Total Particulate Matter (as PM10)

    Source Value ( g/m3) Averaging Period

    SI 180 of 2011 50

    40

    90.4th percentile daily

    Annual average

    5.3 Organic Substances

    5.3.1 TA Luft Organics

    As in the case of TA Luft inorganics, there are no Irish or European air quality standards for TA Luft organics, and although the emissions of organic substances are speciated as part of the air emissions monitoring programme, the results are typically less than the limit of detection and are recorded as zero. Therefore, it is not possible to estimate the proportion of each individual substance that contributes to the overall emission of organic substances and compare it against an individual assessment criterion. For the purpose of this air dispersion modelling study, the emissions of organic substances are assessed in the context of total organic carbon (refer to Section 5.3.2).

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    5.3.2 Total Organic Carbon

    There are no air quality standards for total organic carbon. The Danish EPA identifies two C-values for TOC, the first of which is set out in the context of emissions from thermal and catalytic oxidation of organic solvents, rather than emissions of organic solvents from processes such as those carried out at AD. The guidelines note that:

    As a basis, calculations of dispersion co-efficient should use a C-value of 0.1 mg TOC/m3. This C-value should take into account the fact that unknown, harmful substances such as aldehydes are formed during combustion. However, at effective combustion plants, most of the substances emitted will be light hydrocarbons such as methane, ethane and propane. If it is possible to confirm that most of the TOCs emitted comprise these light hydrocarbons, the C-value may be increased to 1 mg/m3.

    As the individual organic substances discharged to atmosphere are known (based on the known inputs of organic solvents), as they do not arise from thermal or catalytic oxidation of organic solvents, and as they are not aldehydes the C-value of 0.1 mg/m3 is not considered to be appropriate and therefore the C-value of 1 mg/m3 should apply.

    5.4 Combustion Products The Air Quality Regulations set out the standards for nitrogen dioxide and carbon monoxide and are summarised in Table 18.

    Table 18: Assessment Criteria for Nitrogen Dioxide and Carbon Monoxide

    Substance Value ( g/m3) Averaging Period

    Nitrogen dioxide 200

    40

    99.8th percentile, 1-hour

    Annual average

    Carbon monoxide 10,000 Daily 8-hour average

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    6 ASSESSMENT OF RESULTS

    6.1 Introduction The results from the air dispersion models are summarised in the following subsections. The plots showing the impacts to the surrounding area are shown in the contour maps in Appendix 3. In assessing the results from the model, the highest off site ground level concentrations have been used. As shown in the contour maps, the highest concentrations occur in close proximity to the site, with the concentrations at adjoining sites significantly less than the highest off site ground level concentrations.

    As required under the EPA’s guidance, in assessing the process contribution (PC) from the site against the overall assessment criteria, the maximum allowable process contribution (PC) has been calculated in terms of the air quality guidance (the assessment criteria) (AQG) and the background concentration (BC) as follows:

    In the case of nitrogen oxides and particulate matter (as PM10), the EPA’s guidance sets out a more detailed approach to combining process contributions and background concentrations, as described in Sections 4.3.5 and 4.3.3, respectively.

    6.2 Inorganics Substances

    6.2.1 Total Fluorides

    The results from the air dispersion model for total fluorides are summarised in Table 19 and the contour plots for the future cases (the highest predicted ground level concentrations for the short term and long term averaging periods) are shown in Appendix 3. The process contributions for both the short term and long term averaging periods are shown in Figure 1 compared to the air quality guideline and the maximum allowable process contribution (PC). The highest concentrations arise in the immediate vicinity of the site boundary, with the offsite concentrations decreasing beyond the site boundary.

    Table 19: Predicted Off-site Ground Level Concentrations of HF (μg/m3)

    Averaging Period -> Short Term

    (1-hour)

    Long Term

    (1-month)

    Year Existing case Future case Existing Case Future case

    2008 4.76 6.06 0.53 0.86

    2009 4.28 5.64 0.50 0.70

    2010 4.99 6.36 0.63 0.85

    Highest 4.99 6.36 0.63 0.86

    Assessment criteria 160 160 16.0 16.0

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    Figure 1: Predicted Ground Level Concentrations of Total Fluorides

    6.2.2 Total Bromides

    The results from the air dispersion model for total bromides are summarised in Table 20 and the contour plot for the future case (the highest predicted ground level concentration) is shown in Appendix 3. The process contribution for the short term averaging period is shown in Figure 2 compared to the air quality guideline and the maximum allowable process contribution (there is no long term air quality guideline). The highest concentrations arise in the immediate vicinity of the site boundary, with the offsite concentrations decreasing beyond the site boundary.

    Table 20: Predicted Off-site Ground Level Concentrations of HBr (μg/m3)

    Averaging Period -> Short Term (1-hour)

    Year Existing case Future case

    2008 10.0 50.9

    2009 9.5 46.9

    2010 9.7 50.2

    Highest 10.0 50.9

    Assessment criteria 700 700

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    Figure 2: Predicted Ground Level Concentrations of Total Bromides

    6.2.3 Total Acids

    The results from the air dispersion model for total acids are summarised in Table 21 and the contour plot for the future case (the highest predicted ground level concentration) is shown in Appendix 3. The process contribution for the short term averaging period is shown in Figure 3 compared to the air quality guideline and the maximum allowable process contribution (there is no long term air quality guideline). The highest concentrations arise in the immediate vicinity of the site boundary, with the offsite concentrations decreasing beyond the site boundary.

    Table 21: Predicted Off-site Ground Level Concentrations of HCl (μg/m3)

    Averaging Period -> Short Term (1-hour)

    Year Existing case Future case

    2008 111.6 144.2

    2009 100.0 135.1

    2010 117.0 151.3

    Highest 117.0 151.3

    Assessment criteria 750 750

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    Figure 3: Predicted Ground Level Concentrations of Total Acids

    6.2.4 TA Luft Inorganic Particulates

    The results from the air dispersion model for TA Luft inorganics class II (as PM10) are summarised in Table 22 and for TA Luft inorganics class III (as PM10) are summarised in Table 23.

    Table 22: Predicted Off-site Ground Level Concentrations of TA Luft Inorganics Class II (as PM10) (μg/m3)

    Averaging Period ->

    Short Term

    (99th %ile 1-hour)

    Short Term

    (90.4th %ile daily)

    Long Term

    (annual average)

    Year Existing case Future case Existing case Future case Existing case Future case

    2008 4.6 × 10-7

    Note 1

    1.9 × 10-7

    Note 1

    6.6 × 10-8

    Note 1 2009 4.5 × 10-7 1.6 × 10-7 5.9 × 10-8

    2010 4.3 × 10-7 1.4 × 10-7 4.3 × 10-8

    Note 1: There are no new emissions of TA Luft class II inorganics under the future case and therefore the results for the future case are the same as those for the existing case.

    Table 23: Predicted Off-site Ground Level Concentrations of TA Luft Inorganics Class III (μg/m3)

    Averaging Period ->

    Short Term

    (99th %ile 1-hour)

    Short Term

    (90.4th %ile daily)

    Long Term

    (annual average)

    Year Existing case Future case Existing case Future case Existing case Future case

    2008 4.1 × 10-4 5.6 × 10-4 1.7 × 10-4 2.5 × 10-4 6.0 × 10-5 8.5 × 10-5

    2009 4.1 × 10-4 5.8 × 10-4 1.6 × 10-4 2.2 × 10-4 5.5 × 10-5 7.9 × 10-5

    2010 4.0 × 10-4 5.6 × 10-4 1.3 × 10-4 1.8 × 10-4 4 × 10-5 5.7 × 10-5

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    6.2.5 Total Particulate Matter

    The results from the air dispersion model for total particulate matter (modelled as PM10) are summarised in Table 24 and the contour plots for the future cases (the highest predicted ground level concentrations for the short term and long term averaging periods) are shown in Appendix 3. The process contributions for both the short term and long term averaging periods are shown in Figure 4 compared to the air quality guideline and the maximum allowable process contribution (PC). The highest concentrations arise in the immediate vicinity of the site boundary, with the offsite concentrations decreasing beyond the site boundary.

    Table 24: Predicted Off-site Ground Level Concentrations of Total Particulate Matter (as PM10) (μg/m3)

    Averaging Period -> Short Term

    (90.4th %ile daily)

    Long Term

    (annual average)

    Year Existing case Future case Existing case Future case

    2008 0.0070 0.0098 0.0024 0.0034

    2009 0.0063 0.0086 0.0022 0.0031

    2010 0.0050 0.0073 0.0016 0.0023

    Highest 0.007 0.010 0.002 0.003

    Assessment criteria 50 50 40 40

    Figure 4: Predicted Ground Level Concentrations of Total Particulate Matter (PM10)

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    Applying the calculation method for combining short term, ground level process contributions with long term background concentrations of PM10 as set out in Section 4.3 (and Appendix E of the EPA’s guidance), yields the total contribution of PM10 as summarised in Table 25.

    Table 25: Calculation of 90.4th percentile PM10 (Process Contribution plus Background) (in μg/m3)

    Ref. Parameter / Calculation Current Future

    1 90.4th %ile 24-hour mean background PM10 28.7 28.7

    2 Annual mean background PM10 16.6 16.6

    3 90.4th %ile 24-hour mean process contribution PM10 0.0070 0.0098

    4 Annual mean process contribution PM10 0.0024 0.0034

    - Calculation (a) (1) + (4) 28.707 28.710

    - Calculation (b) (2) + (3) 16.602 16.603

    - Calculated 90.4th % total 24-hour mean 28.707 28.710

    The results show that the 90.4th percentile total ground level concentration of PM10, taking into account both the process contribution and the background contribution, does not exceed the daily air quality standard of 50 μg/m3. Furthermore, the total ground level concentration is less than 75% of the air quality guidance value and therefore, as indicated in Appendix E to the Agency’s guidance document, a more detailed investigation is not required to assess the impact of the short term emissions of PM10.

    The maximum allowable process contribution, calculated in accordance with the method set out in the EPA’s guidance, yields a maximum allowable process contribution of 14.2 μg/m3, based upon the annual average background concentrations of PM10. The results show that the process contribution is significantly less that the maximum allowable process contribution.

    6.3 Organic Substances

    6.3.1 TA Luft Organics

    The results from the air dispersion model for TA Luft organics class I are summarised in Table 26 and for TA Luft organics class II are summarised in Table 27.

    Table 26: Predicted Off-site Ground Level Concentrations of TA Luft Organics Class I (μg/m3)

    Averaging Period ->

    Short Term

    (1-hour)

    Short Term

    (99th %ile, 1-hour)

    Long Term

    (annual average)

    Year Existing case Future case Existing case Future case Existing case Future case

    2008 77.6 95.5 40.9 50.9 4.7 6.2

    2009 72.0 88.7 37.5 45.8 4.3 5.7

    2010 79.4 97.9 39.9 49.9 3.7 4.8

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    Table 27: Predicted Off-site Ground Level Concentrations of TA Luft Organics Class II (μg/m3)

    Averaging Period ->

    Short Term

    (1-hour)

    Short Term

    (99th %ile, 1-hour)

    Long Term

    (annual average)

    Year Existing case Future case Existing case Future case Existing case Future case

    2008 414 509 218 272 25.3 33.0

    2009 384 473 200 244 22.9 30.5

    2010 424 522 213 266 19.4 25.8

    6.3.2 Total Organic Carbon

    The results from the air dispersion model for total organic carbon are summarised in Table 28 and the contour plot for the future case is shown in Appendix 3. The process contribution is shown in Figure 1 compared to the air quality guideline and the maximum allowable process contribution (there is no long term air quality guideline). The highest concentrations arise along the boundary of the site, with the offsite concentrations decreasing beyond the site boundary.

    Table 28: Predicted Off-site Ground Level Concentrations of TOC (mg/m3)

    Averaging Period -> Short Term (99th %ile, 1-hour)

    Year Existing case Future case

    2008 0.204 0.255

    2009 0.188 0.229

    2010 0.200 0.249

    Highest 0.204 0.255

    Assessment criteria 1.0 1.0

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    Figure 5: Predicted Ground Level Concentrations of Total Organic Carbon

    6.4 Combustion Emissions

    6.4.1 Nitrogen Oxides

    The results from the air dispersion model for total organic carbon are summarised in Table 28 and the contour plots for the future cases (the highest predicted ground level concentrations for the short term and long term averaging periods) are shown in Appendix 3. The process contributions for both the short term and long term averaging periods are shown in Figure 6 compared to the air quality guideline and the maximum allowable process contribution (PC). The highest concentrations arise in the immediate vicinity of the site boundary, with the offsite concentrations decreasing beyond the site boundary.

    Table 29: Predicted Off-site Ground Level Concentrations of Nitrogen Dioxide (μg/m3)

    Averaging Period -> Short Term

    (99.8th %ile, 1-h