diageo - epawebapp.epa.ie

Ot’ficc of Climate, Licensing & Resource Use, Eiivironineiital Protection Agency, PO Box 3000, Johns town Cast 1 e Est ate, CO. WEXFORD.

DIAGEO GLOBAL SUPPLY

Waterford Brewery 9 Mary Street Waterford

Tel: 00 353 51 845800 Fax: 00 353 51 845821

3 1’‘ March 201 1

Re: IFPC Licence No. PO449-02 Application for Technical Amendment

Protection Agency

Dear Sir/Madain,

We enclose an application to the Agency for a Technical Amendment to our IPPC Licence Register No. PO449-02 in respect of the emission limit value for carbon monoxide from the Roasting Plant afterburner, emission point A2- 1. We have informed our Licensing Inspector that we are submitting this application.

Three hard copies of the application arc enclosed, ref. document 287-XI 56, together with a pdf copy on compact disc.

If you have any queries on the application or require any further information, please do not hesitate to contact me.

Yours faithfully,

Crioiia Harrington Operations Manager

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DIAGEO Protection Agency -

0 4 APR 2816 :I

DIAGEO WATERFORD BREWERY

Application to EPA for Technical Amendment to IPPC Licence

for new Emission Limit Value for Carbon Monoxide

Licence Register No. PO449-02

Document Ref: 287-X 156 Date: 30th March 201 1

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Diageo Waterford Brewery IPPC Licence Register No. PO449-02

Application to EPA for Technical Amendment

TABLE OF CONTENTS

1 Introduction 1

2 Background 1

3 Historical Emission Levels of Carbon Monoxide 2

4 BAT Associated Emission Levels for Carbon Monoxide 3

4.1 3

4.2 Other EPA BAT Guidance Notes 4

4.3 T A Luft 2002 4

4.4 Assessment of BAT Associated Emission Levels for CO 5

5 Options for Maintaining Compliance with Limit Values 5

EPA Guidance Note on BAT for the Brewing Sector

6 Dispersion Modelling Study 6

6.1 Dispersion Model 6

6.2 Assessment Criteria 7

6.3 Assessment of Results 7

7 Application for Increase in Emission limit Value 9

Appendix 1 : Dispersion Modelling Study Report

1 March 201 1 287-X156

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Diageo Waterford Brewery lPPC Licence Register No. PO449-02

Application to EPA for Technical Amendment to Licence

1 INTRODUCTION

This application for a Technical Amendment to IPPC Licence Register No. PO44-02 is made by Diageo Waterford Brewery in respect of the emission limit value for carbon monoxide (CO) in the emissions from the Roasting Plant afterburner, emission point reference no. A2-1. The current limit on CO emissions from this source is 100 mg/Nm3. This submission sets out the case for an increase in the emission limit value to 350 mg/Nm’.

2 BACKGROUND

Diageo Waterford Brewery produces BBAs (Beverage Blending Agents) for the export market at its plant in Waterford City. The BBA production process is similar to a standard brewing process except that the brewed products are concentrated up in an evaporator. These concentrates are then used in the manufacture of products such as Guinness stout at other Diageo sites.

The main emissions to atmosphere from production operations at Diageo Waterford Brewery are the emissions from the afterburner on the Roasting Plant, which is one of the main unit operations on the site. The afterburner is a recuperative thermal oxidizer and is an integral part of the Roasting Plant, which was designed and supplied by the German company, Barth.

In the Roasting Plant, the grains (barley) are heated in a rotating drum to -200°C on a batch basis to produce the colour and flavour required for the subsequent brewing stage of the process. The batch cycle is -2% hours and the Roasting Plant currently operates 24 hoursiday, 5% dayslweek. Depending on stock levels, the Roasting Plant may be run for up to 6% dayslweek.

The off-gases from the Roasting Plant, which include dust and volatiles as well as carbon monoxide and nitrogen oxides from the roasted grains, pass through a cyclone which removes the particulate matter from the air stream. From the cyclone, the air stream passes through the afterburner where the volatiles are removed. The afterburner currently operates at a temperature of 750°C. A pre-heat section on the afterburner recovers the bulk of the heat from the flue gases. The clean air from the afterburner is discharged to atmosphere via emission point A2-1.

The licensed parameters in the emission to atmosphere from the afterburner are: flow rate, total organic compounds (TOC) (as carbon), nitrogen oxides (as NO?), and carbon monoxide. The current emission limit values (ELVs) for these parameters are:

Volumetric flow rate Total organic compounds Nitrogen oxides Carbon monoxide

5,000 Nm’/h 50 mg/Nm3 200 mgmrn3 (see note) 100 m@m3

Note: The ELV for nitrogen oxides was changed by Technical Amendment B to the licence from 100 to 200 mg/Nm3 in April 2006.

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300

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200

150

0 I I I I I I I I I I I I1 I I I I I~

A feature of the afterburner's design is the provision of a catalyst material in the discharge stack from the afterburner. This catalyst, which is a platinum coated ceramic bed, facilitates the oxidation of CO to CO? prior to final discharge. As mentioned earlier in this section, CO is one of the off-gases from the roasting process itself and is not solely generated in the oxidation chamber in the afterburner.

I I1 I I I

3 HISTORICAL EMISSION LEVELS OF CARBON MONOXIDE

Historically, the levels of CO emissions from the afterburner have been close to the emission limit value of 100 mg/Nm3 and in 2009 the limit value was exceeded on a number of occasions. The historical values are summarised in Figure 1.

Figure I : Monitored CO Emissions from Afterburner Stack A2-I, 2005 to 2011 (mg/Nm3)

400

350

8 CO

Q 1 Q2 0 3 Q4 Q 1 Q2 Q3 Q4 Q 1 Q2 Q3 Q4 Q 1 Q2 Q3 Q4 Q 1 Q2 0 3 Q4 Q 1 Q2 Q3 Q4 Q 1 '05 '05 '05 '05 '06 '06 '06 '06 '07 '07 ' 07 '07 '08 '08 '08 '08 '09 '09 '09 '09 '10 '10 '10 '10 '11

In 2009, following the incidences of high CO values in the first and second quarter monitoring rounds, Diageo Waterford Brewery, in conjunction with the afterburner manufacturer, undertook a detailed review of the operation of the afterburner and carried out a series of inspections to try to understand the increase in the CO emissions and to rectify the matter. These actions were notified to the Agency as and when they took place. Based on the outcome of the investigations and inspections, the following works were undertaken by Diageo Waterford Brewery in 2009:

an additional half layer of catalyst was added to the catalyst bed in the stack from the afterburner; a new replacement tube bundle was installed in the afterburner;

the combustion temperature of the afterburner was increased from 680 to 750'C.

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The works were completed in December 2009. The emission surveys carried out since the new tube bundle was commissioned show that, with the exception of the result for the 4‘h quarter 201 0, the CO emissions have reduced to the level of the emission limit value (1 00 mg/Nm3) and below. See Table 1.

Table 1 : Quarterly Emissions Monitoring Results for Afterburner since December 2009

TOC ( r n g ~ r n ~ ) 50 13 40 24 34 33 18

NOX (m@rn3) 200 106 84 93 96 101 83

CO (rngNrn’) 100 100 16 81 99 229 98

Following the elevated value for CO in the December 2010 monitoring round, the tube bundle on the heat exchanger was removed for inspection, and both the tube bundle and the catalyst were cleaned (the tube bundle is cleaned routinely every 6 to 8 weeks). There was nothing from the inspection or operation of the afterburner to explain the elevated CO value. On the process (roasting) side, the main difference from the operating conditions during the previous monitoring survey was a change in the batch of barley that was being roasted.

The results in Table 1 show that, despite the very significant works carried out on the afterburner in 2009 and the continuing routine inspection and cleaning of the afterburner, the emissions of CO are too close to the emission limit value to have confidence that the current limit value will not be breached in future monitoring surveys.

Even with the new tube bundle in the afterburner, Diageo Waterford Brewery has to run the afterburner at an elevated temperature (750’C) in order to maintain the CO level within the emission limit value. This has implications for the energy costs of the roasting operation and for the working life of the afterburner tube bundle as discussed later.

4 BAT ASSOCIATED EMISSION LEVELS FOR CARBON MONOXIDE

4.7 EPA Guidance Note on BAT for the Brewing Sector

The EPA’s publication BAT Guidunce Note on Best Available Techniquesfor the Brewirig. Multing and Distilling Sector is the relevant guidance note on BAT for Diageo Waterford Brewery’s operations. This guidance note is closely linked to the European Commission’s BREF Note on Best Avuiluble Techniques in the Food, Drink und Milk Industries.

Section 4.2.3 of the EPA’s guidance note refers to emissions to air. It identifies SO,, NO,, CO:, CO and particulates as emissions from energy generation in the brewing industry, and also refers to emissions to air from the afterburners from roasting processes. In relation to minimising and treating emissions to air, the guidance note, in Sections 4.4.1 and 5.4.1, refers to the use of appropriate abatement technology to reduce emissions to air from the grain roasting process.

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Diageo Waterford Brewery Application to EPA for

In Table 6.1 of the guidance note, BAT associated emission levels for emissions to air are listed for two parameters only: total particulate matter and total organic compounds. There is no BAT associated emission level listed for CO in the guidance note.

This is in line with the guidance in the BREF Note for the Food, Drink and Milk Industries. In the section on Additional BAT,for the Coffee Roasting Sector - which is the process operation most akin to the grain roasting operation in the BREF Note - the BREF Note provides emission limit values for total particulate matter and TOC but makes no mention of CO emissions. There is no mention of CO emissions in the Additional BATfbr Drinks Manufacturing or in Additional BAT,for Brewing in the BREF Note.

4.2 Other EPA BAT Guidance Notes

BAT associated emission levels for CO are contained in some of the other BAT Guidance Notes published by the EPA.

The BAT Guidance Note for Non;ferrous Metals and Galvanising Sector gives a CO emission level of 350 mg/Nm3; the BAT Guidance Notefi,a the Energy Sector (Large Combustion Plant) gives a CO emission level in the range of 30 to 150 mg/Nm3 for liquid fuel fired plant. Other guidance notes, such as those for the Initial Melting and Production oflron and Steel Sector, General Inorganic Chemicals Sector and the Manufacture of Integrated Circuits give a CO emission level of 100 mg/Nm3 with the added qualifier that it applies to “thermal or catalytic post combustion facilities”. This is a term which is used also in T A Luft 2002, which is discussed in Section 4.3.

4.3 T A Luft 2002

Section 5.2.4 of T A Luft 2002 provides emission limits for Inorganic Gaseous Substances. Under Class IV Substances, it lists sulphur oxides (SO,) and Nitrogen Oxides (NO,) and gives an emission concentration limit of 350 mg/Nm3 for each parameter. It further states that in waste gases generated by thermal or catalytic post-combustion facilities, nitrogen oxides may not exceed a mass concentration of 200 mg/Nm3; and, simultaneously, carbon monoxide may not exceed a mass concentration of 100 mg/Nm3. T A Luft, in Section 5.2.4, does allow for nitrogen oxides emission levels to be established on a case-by-case basis where the gases that are fed into the post-combustion system [italics added] contain concentrations of nitrogen oxides or other nitrogen compounds that are not low, in which case the nitrogen oxides emissions may not exceed 350 mg/Nm3.

T A Luft contains special provisions for certain types of installation, and in Section 5.4.7 29/30, it covers inter alia installations for roasting cereals. In this section, it states that Section 5.2.4 shall apply, provided that nitrogen oxides in the waste gas do not exceed the mass flow of 1.8 kg/h or the mass concentration of 350 mg/Nm3, if possible. There is no limit specified for CO emissions in the section of TA Luft that covers roasting of cereals.

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4.4 Assessment of BAT Associated Emission Levels for CO

It is clear from the EPA’s BAT Guidance Note for the Brewing, Malting and Distilling Sector and the section of T A Luft that deals specifically with the roasting of cereals that emission levels of CO are not an issue for these processes compared with emissions of say, particulates, TOC and NO,. T A Luf? allows for a case-by-case assessment where the NO, levels in the infeed gas to a post-combustion facility are high. This is the case with the infeed gas to the afterburner at Diageo Waterford Brewery, where the infeed gas contains elevated levels of both NO, and CO which are generated in the upstream roasting process. It would be reasonable to adopt a case-by-case assessment for CO emissions also where these emissions were an issue.

5 OPTIONS FOR MAINTAINING COMPLIANCE WITH LIMIT VALUES

As can be seen from the monitoring data in Section 3, the recent emissions of CO from the afterburner at Diageo Waterford Brewery are very close to the emission limit value when in compliance. It is a challenge for the Brewery to maintain compliance on a consistent basis, year-on-year, because of the natural variations in the grains being processed.

Typical sources of the variations in the barley delivered to Diageo Waterford Brewery for roasting are: supplier, barley variety, growing season (winter or spring barley), weather conditions at harvesting, storage conditions, and degree of mechanical handling. Some of these parameters can have a significant impact on the dust levels in the barley. The variations in the characteristics of the barley mean that the roasting profile has to be adjusted to achieve the required characteristics of the roasted product, such as adjustments to the duration of the roast cycle and to the roast temperature. These variations result in changes in the profile of the off-gases from the roaster to the afterburner, which include CO.

The afterburner on the roaster is currently operated at its optimum level for minimising CO emissions, but this is at the expense of increased energy costs, increased carbon footprint and a reduced life span for the tube bundle on the afterburner (both are due to the higher combustion chamber temperature at which the afterburner has to operate).

There are many factors which influence the CO level in the final emission from the afterburner and the main ones are:

i. The CO level in the off-gases from the roasting process; ii. The combustion chamber temperature in the afterburner; iii. The surface area of the catalyst bed in the discharge stack from the afterburner; iv. The cleanliness of the tube bundle in the afterburner and the catalyst bed in the stack.

The CO level in the off-gases from the roasting process depends inter alia on the type and the source of the grains being processed and, therefore, it is a variable which is mainly outside the operational control of the Brewery.

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The combustion chamber temperature and the surface area of the catalyst bed are controllable within certain constraints, and these have been optimised to minimise the emissions of CO. Adjustments to these two parameters impact also on NOx levels in the final discharge from the afterburner and, since adjustments that reduce CO emissions may increase NOx emissions, it is a question of balancing the impact of any change on these two emission parameters.

In the case of the cleanliness of the tube bundle and the catalyst bed, these are cleaned regularly as part of a planned maintenance programme, and the cleaning frequency is based on routine checking of the differential pressure across the afterburner.

It is the opinion of Diageo Waterford Brewery that, with the new tube bundle installed and with the current operational settings and maintenance procedures in place, the CO emissions from the afterburner are optimised in respect of minimising these emissions. However, this optimisation may not be sufficient to maintain compliance with the current emission limit value on a consistent basis because of natural variations that occur in the raw materials.

A higher emission limit value for CO would allow Diageo Waterford Brewery to maintain compliance on a consistent basis while, at the same time, by operating at a lower combustion chamber temperature, it would reduce energy consumption on the site, prolong the life of the afterburner tube bundle, and allow better optimisation of NOx emissions.

The environmental impact of the current CO emissions from the site and the impact of an increase in the emission limit value were assessed by way of a dispersion modelling study, which is discussed in the following section.

6 DISPERSION MODELLING STUDY

6.1 Dispersion Model

A dispersion modelling study was carried out by Consultants Byrne 0 Cleirigh on behalf of Diageo Waterford Brewery to determine and assess the impact of CO emissions at ground level at different emission limit values. A full report on the study is contained in Appendix 1 and a summary is provided in this section of the submission.

The dispersion modelling study was carried out in accordance with current EPA guidance, viz: Air Dispersion Modelling from Industrial Instullutions Guidance Note (AG4). Three emission scenarios were modelled:

Scenario 1 Scenario 2 Scenario 3

: CO concentration of 100 mg/Nm3 in afterburner stack : CO concentration of 200 mg/Nm3 in afterburner stack : CO concentration of 350 mg/Nm3 in afterburner stack

In each case, the emissions were modelled at the volumetric flow limit value of 5,000 Nm3/h.

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Diageo Waterford Brewery IPPC Licence Register No. P0449-02


The 200 mg/Nm3 value for Scenario 2 was selected to correspond to the current limit value for NOx emissions from the afterburner. The 350 mg/Nm3 value for Scenario 3 was selected to correspond to the emission limit values for CO and NOx contained in the EPA BAT guidance note and TA Luft 2002 as noted in Section 4 of this submission.

The CO emissions from the two gas-fired boilers on the site were also considered. The results of the routine flue-gas analyses carried out on these boilers indicate that the CO levels in the flue gases are negligible - historical combustion efficiency surveys indicate values of zero for CO in the flue gases. For the purpose of the modelling study, and to err on the conservative side, a value of 5 mg/Nm3 was taken for the CO emissions from the boilers.

6.2 Assessment Criteria

The predicted ground-level concentrations of CO from the dispersion modelling exercise were assessed against the ambient air quality standard for CO from SI No. 271 of2002 Air Qziulity Standard Regulutions. This standard for CO is a maximum daily 8-hour mean concentration. The assessment took into account the ambient CO levels in Waterford City as determined in the most recent air quality survey undertaken by the EPA in the city, which was in 200712008.

6.3 Assessment of Results

The results from the dispersion modelling study are summarised in Table 2 and in Figures 2 & 3. The contour plots from the dispersion modelling runs are contained in the report in Appendix 1.

Table 2: Summary of Results from Dispersion Modelling Study

1 100 0.019 1.98 2.00 10

2 200 0.038 1.98 2.02 10

3 350 0.067 1.98 2.05 10

The Process Contribution (PC) in Table 2 is the maximum predicted value, for each scenario, of the daily 8-hour mean concentration of CO outside the boundary of the Diageo Waterford Brewery, at ground level, over the three years of weather data used in the modelling study. The contour plots from the dispersion modelling are contained in the report in Appendix 1.

The Background Concentration (BC) in Table 2 is the maximum value of the daily 8-hour mean concentration of CO measured by the EPA during the ambient air monitoring survey conducted in Waterford City in 200712008.

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Diageo Waterford Brewery TPPC Licence Register No. PO449-02


The Predicted Environmental Concentration (PEC) in Table 2 is the sum of the Process Contribution and the Background Concentration. It should be noted that in the case of Scenario 1, the Process Contribution for this scenario, which is the ongoing Process Contribution from Diageo Waterford Brewery for the current CO emission of 100 mg/Nm3, is a component of the measured Background Concentration since it is the existing emission.

However, to err on the conservative side, this Process Contribution has been added to the Background Concentration in the analysis of the results from the modelling study.

The dispersion modelling results indicate the following:

1 . The impact of an increase in the CO emissions from the afterburner to 200 or to 350 mg/Nm3 would be negligible in each case. This is in the context of the background concentration of CO and the ambient air quality standard for CO (see also Figure 2).

2. An increase in the emission limit value to 350 mg/Nm3 would add a maximum of 3% to the background concentration - a background level which itself, at its maximum, is only 20% of the ambient air quality standard (see also Figure 3).

3. The maximum Process Contribution would be only 0.067 mg/Nm3 (an incremental Process Contribution of 0.048 mg/Nm3). This is in the context of a maximum allowable Process Contribution of 5.33 mg/Nm3 under the EPA’s Guidance Note AG4 (see dispersion modelling study report in Appendix 1).

Figure 2: Comparison of Predicted Environmental Contributions with Air Quality Standard

100%

90%

10%

0%

Predicted Environmental Contribution of Carbon Monoxide (CO) from DiageoWaterford Brewely

,n the confen of the &how Ambrent A#rQualrty Standard (10 mg/m3) and the Background Concentranon

0 2% 0 7%

AQS Scenano 1 bcenario L Scenario 3 100 mglm3 200 mglm3 350 mglm3

I Barkgroundconrentration I Proce i i Contrtbulion

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Figure 3: Background Levels of CO in Waterford City

8Hour Average Carbon Monoxide Background Concentration (BC) -Waterford Clty

EPA Monmrmg Survey 2007.2008

12

Limitvalue for Protechon of Human Hcalm (1 0 mgim') 10

12

10

8

8 4 4

2 2

7 APPLICATION FOR INCREASE IN EMISSION LIMIT VALUE

On the basis of the data and assessments presented in this report, Diageo Waterford Brewery requests an increase in the emission limit value for CO from the afterburner emission point A2-1 from 100 to 350 mg/Nm3.

This increase will enable Diageo Waterford Brewery to maintain compliance with its license limits while accommodating natural variations in the quality of feed raw materials. It will provide a considerable saving in energy costs on the site. It will extend the working life of the tube bundle in the afterburner and it will allow for better optimisation of NOx emissions from the afterburner.

An increase in the emission limit value to 350 mg/Nm3 will not contravene BAT guidance for the malting, brewing and distilling sector and, even under a worst case scenario, it will have only an imperceptible impact on the ground-level value of CO in the context of the ambient air quality standard for this parameter.

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Diageo Waterford Brewery IPPC Licence Register No. P0449-02


Appendix 1 : Dispersion Modelling Study Report

287-X156 I March 201 1

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B Y R N E

AIR DISPERSION MODELLING OF CARBON MONOXIDE EMISSIONS

FROM DIAGEO WATERFORD BREWERY

BOC Ref.: 287-X153 FBS: 287:07.01.04 December 20 10

Byrne 0 Cleirigh Ltd., 30a Westland Square, Pearse Street, Dublin 2, Ireland. Telephone: + 353 (0)l 6770733. Facsimile: + 353 (0)l 6770729. Web: www.boc.ie

Registered in Dublin, Ireland No 237982

Directors LM 6 CIelrlgh. BE. MIE, C Eng, FIEI, FI Mech E A J Clarke. BE. C Eng, FIE1 TV Cleaty BE, C Eng. FIEI, F I Chem E JB Fltzpatrlck. FCA LP 6 Cleirigh, BE. MEngSc, MEA, C Eng, MlEl

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This report has been prepared by Byrne 0 Clgirigh Limited with all reasonable skill, care and diligence within the terms of the Contract with the Client, incorporating our Ternis and Conditions and taking account of the resources devoted to it by agreement with the Client.

We disclaim uny responsibility to the Client und 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 thirdparties to whom this report, or any part thereof; is made known. Any such party relies upon the report at their own risk.

BOC Ref. 287-X 153 December 20 10

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TABLE OF CONTENTS

EXECUTIVE SUMMARY .................................................................................................................................. 1

1 INTRODUCTION ....................................................................................................................................... 3

2 SITE OPERATIONS .................................................................................................................................. 3

2.1 PROCESS .......................................................................................................... 3 2.2 SITE ENV ........................................... ................................................ 3

3 DISPERSION MODEL .............................................................................................................................. 4

3.1 MODELLING PROGRAMMES ...................................... ............................... 4 ................................................................................................................... 4 s & Structure ................................................... ................................................ 4

Emissions & Emission Rates ........................................................................................................... 4 3.2.2 3.2.3 Stack Heights ................................................. ............................... 6 3.2.4 Meteorological Data., .................................... ............................... 6 3.2.5 Digital Terrain Data ................................................. ...................................................... 6 3.2.6 Receptor Points .............................................................................................................. .. 6 3.2.7 Background CO Concentration _ _ . _ ........................................................................................ 7

3.3 O U T P ~ J T FROM MODEL.I,ING RUNS ........................................... .......................... 7

4 ASSESSMENT CRITERIA ....................................................................................................................... 8

5 ASSESSMENT OF RESULTS ................................................................................................................... 8

5.1 DISPERSION MODELLING RESLJLTS ................................................................................................. 8 5.2 BACKGROUND CONCENTRATION ....................... ....................................... 8

6 SENSITIVITY STUDY ............................................................................................................................ 10

7 CONCLUSIONS ....................................................................................................................................... 12

APPENDIX A: SITE LAYOUT

APPENDIX B: WIND ROSES FOR ROSSLARE

APPENDIX C: CONTOUR PLOTS FROM DISPERSION MODEL

APPENDIX D: BACKGROUND CONCENTRATION 01' CARBON MONOXIDE

QUALITY STANDARD APPENDIX E: ASSFSSMENT OF GROIJND-LEVEL CARBON MONOXIDE CONCENTRATION AGAINST AIK


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Byrne 0 Cleirigh Dispersion Modelling Assessnient of' CO Eniissions from Diugeo Wuterford Brewery

EXECUTIVE SUMMARY

This report by Byrne 0 Cleirigh covers an air dispersion modelling study carried out for Waterford Brewery, Mary St., Waterford. The air dispersion modelling study was conducted to predict ground-level concentrations of Carbon Monoxide (CO) arising from the discharges from the roaster afterburner and two gas-fired boilers at the site. The objective of the study was to assess these predicted concentrations in the context of ambient CO air quality standards as set out in SI 27 1 of 2002 Air Quality Standards Regulations. The results were also assessed in the context of data from an ambient air monitoring survey conducted by the EPA in Waterford City between January 2007 and February 2008.

The model was conducted using BREEZE AERMOD software together with related BREEZE software packages for processing meteorological data and building downwash data. The model incorporated digital terrain data and was run for three years of weather data for Rosslare weather station (2002 to 2004).

The modelling was conducted in accordance with the Agency's Air Dispersion Modelling from Industrial Installations Guidance Note (AG4), and included a sensitivity study of the main input factors used in the model (volume flow, building downwash, terrain data and surface roughness).

Three emissions scenarios were selected for dispersion modelling, each comprising the afterburner and the two boilers. The CO emissions from the afterburner were modelled at:

Scenario 1 : Scenario 2: Scenario 3:

Afterburner CO emission of 100 mg/Nm3 at 5,000 Nm3/h Afterburner CO emission of 200 mg/Nm3 at 5,000 Nm3/h Afterburner CO emission of 350 mg/Nm3 at 5,000 Nm3/h

Scenario 1 corresponds to the current licence limit for CO from the afterburner. Scenarios 2 and 3 show the impact of emissions from the afterburner at emission concentrations of 200 and 350 mg/Nm3, respectively.

The afterburner emission was set in the model to run continuously, 24 hourdday, 7 daydweek, to reflect the worst case conditions of the plant operating at the maximum site capacity. The emission rates from the boilers, used in the modelling scenarios, were based on measurements of the boiler emissions over the firing ranges and conservative emission concentrations of CO The emissions from the boilers were set in the model to run continuously, 24 hourdday, 7 daydweek, at combinations of mid- and high-fire to reflect the worst case conditions of the plant operating at the maximum site capacity.

The output data from the modelling runs were analysed to determine the maximum 8-hour average ground-level concentration at various receptors. The results from the model were combined with the background concentration of CO from the Agency's monitoring programme, converted to the same averaging period, in order to assess the overall impact on air quality from the site. The results from this analysis are shown graphically in Figure (i).

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Byrne 0 Clkirigh Dispersion Modelling Assessment of’ CO Emissions froni Diageo Waterford Brewer-y

Figure (i): Predicted Environmental Contribution of CO from Diageo Waterford Brewery

100%

90%

- 80%

9

5 70%

U

v)

3 60%

$ 50%

- -

I

a : 400h

0’ 30%

2 0 $ 20%

10%

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Predicted Environmental Contribution of Carbon Monoxide (CO) from Diageo Waterford Brewery

i n the context of the &hour Ambient Air Quality Standard (10 mg/m3) and the Background Concentration

AQS

0 4% 0 7%

AQS Maximum Allowable PC Scenario 1 Scenano 2 100 mgim3 200 mgim3

Scenario 3 350 mgim3

Background Concentration ProcessContribution

The main conclusions from the air dispersion modelling study are:

The maximum predicted, 8-hour average, ground-level CO concentrations outside the site are significantly less than the air quality standard of 10,000 pg/m3 in the Regulations. This finding applies to all three model scenarios for each of the three years.

The process contribution from the Brewery towards the overall environmental contribution of ground level CO is not significant, with a maximum contribution of 0.7% of the Air Quality Standard (occurring under Scenario 3 using 2004 meteorological data).

Increasing the concentration of Carbon Monoxide in the emission from the afterburner on the roasthouse from the current limit of 100 mg/m3 to 350 mg/m3 would not result in a significant impact on the air quality in the vicinity of the site. It would increase the maximum predicted ground-level concentration from 19 to 66 pg/m3 compared with a Maximum Allowable Process Contribution of 5,350 pg/m3.

The sensitivity analysis demonstrates that the inputs to the model and the assumptions on which the study was conducted are conservative, yielding higher ground-level concentrations of CO that would arise from simpler model inputs.

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Byrne 0 Cle'irigh Dispersion Modelling Assessment of CO Emissions from Diugeo Waterford Brewery

1 INTRODUCTION

This report by Byrne 0 Clkirigh describes an air dispersion modelling assessment for Diageo Waterford Brewery, Mary St., Waterford. The air dispersion modelling was conducted to predict ground-level concentrations of Carbon Monoxide (CO) arising from the discharges from a roaster afterburner and two gas-fired boilers at the site. The predicted ground-level concentrations were assessed in the context of ambient CO air quality standards as set out in SI 27 1 of 2002: Air Quality Standards Regulations, 2002.

2 SITE OPERATIONS

2.7 Process

The Waterford Brewery produces BBAs (Beverage Blending Agents) for the export market. The BBA production process is similar to a standard brewing process except that the brewed products are concentrated up in an evaporator. These concentrates are then used in the manufacture of products such as Guinness stout at other Diageo sites.

The sources of CO emissions to atmosphere from the site are the afterburner in the roast house and two gas-fired boilers. These emissions are the focus of this study.

In the roasting plant, the grain (barley) is heated in a rotating drum to c. 200°C on a batch basis. The batch cycle is c. 2% hours and the plant currently operates 24 hours/day, seven daydweek. An afterburner installed in the roast house thermally treats the pollutants in the off-gas from the roaster. The two boilers provide steam to the process units on the site.

2.2 Site Environs

The layout of the Brewery is shown in Appendix A. The site is also shown in relation to its environs in the separate contour plots contained in Appendix E.

The elevation of the lowest point on site is approximately 3.0 metres (ref. OS Datum Malin Head). The topography of the area rises sharply to the south and west of the site. The highest points in the vicinity are 73 mOD, approximately 700 m west-southwest of the site, and 84 mOD, approximately 500 m north of the site on the northern bank of the River Suir.

The Brewery site stands at the western edge of Waterford City's commercial district. The site adjoins private dwellings on Mary Street. The site is bordered to the north by the River Suir and to the east and south by private residences and commercial properties on Mary Street, Suir Street, Dyehouse Lane and Rockfield Park. To the west, the site backs onto a steep cliff. The nearest residences are approximately 140 metres from the afterbumer emission point.

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Byrne 0 Cle'irigh Dispersion Modelling Assessnient of CO Emissions fronz Diageo Waterford Brewery

3 DISPERSION MODEL

The dispersion modelling was carried out in accordance with the EPA's Air Dispersion Modelling from Industrial Installations Guidance Note (AG4).

3. I Modelling Programmes

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

0 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. 8-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.

0

0

0

The latest versions of each of the modelling packages were used.

The model was run for three scenarios as described in Section 3.2.2.

3.2 Input Data

3.2.1 Site Buildings & Structure

The length, width, height and the co-ordinates of the buildings, silos and tanks on the site were entered into the AERMOD model.

3.2.2 Emissions & Emission Rates

Three emission scenarios were selected for dispersion modelling:

1. A Carbon Monoxide concentration in the emissions from the roaster afterburner of 100 mg/Nm3 (the current IPPC licence limit).

2. A Carbon Monoxide concentration in the emissions from the roaster afterburner of 200 mgmm3.

3. A Carbon Monoxide concentration in the emissions from the roaster afterburner of 350 mg/Nm3.

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Byrne 0 Clkirigh Dispersion Modelling Assessment of CO Eniissions ,from Diugeo Waterford Brewery

The exhaust temperature of the afterburner emissions was taken at 340°C for all three scenarios, and the afterburner emission was set to run continuously, 24 hourdday, 7 daydweek, to reflect the worst case conditions of the plant operating at the maximum site capacity.

The volumetric flow rate from the afterburner was taken as 5,000 m3/hour (the IPPC licence limit), and represents the maximum mass emission rate. As part of the sensitivity analysis conducted in this assessment, the models were also run with a volumetric emission rate equivalent to 75% of the licence limit (3,750 m3/hour).

The data used to model the emissions from the boilers is based on a number of sources in order to ensure a sufficiently representative, but conservative, emission.

The two boilers were run on a 24 hour per day, 7 day per week basis in the model for all three scenarios.

Boiler No. 1 was run on the basis of high fire operation, which provides the highest volumetric emission.

Boiler No. 2 was run on the basis of medium fire operation, which provides a lower volumetric emission.

The operating modes for the boilers (high fire and medium fire) is representative of the operating pattern at the Brewery.

The temperature of the boiler emissions was taken from the latest boiler efficiency test reports.

The latest monitoring of the boiler emissions indicated that there was no detectable emission of CO from either boiler. In order to adopt a more conservative modelling approach, a CO concentration of 5 mg/Nm3 was allocated to each boiler emission (this was based on results from the monitoring of boiler emissions from a similar site).

Table 1 summarises the data used in the model. Additional data were used in carrying out the sensitivity study, which is discussed in more detail in Section 0.

Table 1: Data Used in Dispersion Modelling Scenarios


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3.2.3 Stack Heights

The actual stack heights of the afterburner and boiler emission points were used.

3.2.4 Meteorological Data

Waterford City does not have a full weather station. Historically, the Met Eireann weather stations at Rosslare and Kilkenny have been the closest stations to the city. The Rosslare weather station is continuously manned, and full data was recorded at this station until 2008. The Rosslare station is coastal, and according to Met Eireann Waterford City would be classified as semi-coastal. We were advised that of the two closest weather stations, the Rosslare meteorological data would be the most representative of that experienced in Waterford City.

The Met Eireann station at Rosslare has been closed since 2008, replaced by the meteorological station at Johnstown Castle. However, the Johnstown Castle station does not record cloud cover data, which is an essential input for air dispersion modelling. Therefore, in the absence of complete weather data for the Johnstown Castle site, complete, historical weather data from the Rosslare site were used in this assessment.

The Agency’s guidance on air dispersion modelling sets out the criteria for selecting the meteorological data for use in air dispersion modelling studies. The selection of the weather station is based upon the annual mean wind speed for the site to be studied, with the weather station with a similar annual mean wind speed (between 90% and 110% of that for the site in question) selected. In this regard, the meteorological station at Rosslare meets the requirements of the Agency’s guidance in relation to the dispersion modelling study for the Waterford Brewery.

The Agency’s guidance document also 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. The meteorological data from the Rosslare weather station for the three years 2002 to 2004 were used in this modelling study; the most recent year of this three year dataset is less than 10 years old.

3.2.5 Digital Terrain Data

Digital terrain data for the Waterford area was provided by the Ordnance Survey of Ireland on a 50 m grid. The elevations of each co-ordinate of the model grid were extracted from these 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.

3.2.6 Receptor Points

A Cartesian grid of receptor points around the site and its environs was set up in the model. The grid had the following parameters:

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Byrne 0 ClPirigh Dispersion Modelling Assessment of CO Emissions ,fioin Diugeo Wuterford Brewery

Table 2: Receptor Points

Length 1,300 m

Width 1,000 m

Grid Line Interval

Number of Receptor Points

The grid used in the model contained the maximum ground level concentration of CO for all three scenarios. It extends beyond the site boundary to each of the neighbouring areas describe in Section 2.2.

3.2.7 Background CO Concentration

The background concentration of CO for Waterford was estimated based upon the results of the EPA’s air quality monitoring programme for the city over the period 1 St January 2007 to 1 sth February 2008. The data, presented in Appendix C, 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 Brewery in the context of the overall air quality for the vicinity of the site, based upon the requirements of the Air Quality Standards Regulations (2002).

The basis for assessing ground-level CO concentration is the highest 8-hour average concentration. Therefore, in order to convert the raw background CO concentration into an equivalent time period, a running 8-hour average (as required by the Air Quality Standards Regulations) was calculated and the highest 8-hour average over the 14 month period of the ambient data set was selected as the worst case, conservative background concentration of CO, equivalent to a ground level concentration of 1.98 mg/m3.

3.3 Output from Modelling Runs

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 maximum daily 8-hour average concentrations for each receptor point for each of the three years over which the model was run were extracted from this raw data.

The results from the model based upon the meteorological data for 2004 (which is the year’s data that gives rise to the highest ground-level concentrations of Carbon Monoxide) were plotted for each of the three scenarios and are included in Appendix B to this report.

The results from the modelling were also assessed against the background concentration of CO for Waterford city (described in Section 3.2.7). This analysis is discussed in more detail in Section 5, and shown graphically in Appendix C.


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Byrne 0 Clkirigh Dispersion Modelling Assessment of CO Emissions ,from Diageo Waterford Brewery

Year* Scenario 1

2002 14.5

2003 17.3

2004 19.0

(100 pg/m3)**

4 ASSESSMENT CRITERIA

Scenario 2 Scenario 3 (200 pg/m3) (350 pg/m3)

29.0 50.8

34.5 60.5

38.0 66.5

The results of the air dispersion model, including the contribution of the background concentration of CO, were assessed in the context of the Air Quality Standards Regulations, 2002 (SI 27 1 of 2002). The Regulations require that:

The maximum daily 8-hour mean concentrations of carbon monoxide in ambient air for the protection of human health shall be assessed in relation to the indicative action levels specijied in Schedule 6 and in relation to the upper and lower assessment thresholds specijied in that Schedule.

Schedule 6 of the Regulations specifies the limit value for the protection of human health at 1 o mg/m3 (1 O,OOO pg/m').

The Regulations also set an upper assessment threshold of 7 mg/m3 and a lower assessment threshold of 5 mg/m3. These assessment thresholds are used to determine the extent of any air quality management (monitoring) that may be required within particular zones; they are not thresholds for assessing compliance with the limit for the protection of human health.

5 ASSESSMENT OF RESULTS

5.1 Dispersion Modelling Results

The results from the air dispersion models for each of the three scenarios and for each of the three individual years are summarised in Table 3 in terms of the highest 8-hour ground-level concentration of CO outside the Waterford Brewery property boundary.

I Highest I 19.0 38.0 66.5 I I I *year of weather data **CO concentration in afterburner emission

The highest predicted, 8-hour ground-level concentration from the model is 66.5 pg/m3. This corresponds to Scenario 3, which models the emission from the afterburner in the roast house at a concentration of 350 pg/m'.

5.2 Background Concentration

In order to assess the overall impact of the emissions from the Waterford Brewery, the results of the air dispersion model were assessed taking into consideration the background CO concentrations (refer to Section 3.2.7). The data from the Agency's monitoring survey,

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Byrne 0 Clkirigh Dispersion Modelling Assessment qf CO Emissions ,from Diugeo Wuterford Brewery

Parameter

PC

BC

PEC

AQS*

converted to 8-hour running averages in order to allow comparison with the limit value for CO, is shown in Appendix C.

Scenario 1 Scenario 2 Scenario 3 (100 pg/m3) (200 pg/m3) (350 pg/m3)

19.0 38.0 66.5

1,980 1,980 1,980

1,999 2,018 2,047

10, 000 10, 000 IO, 000

The assessment of the emission from the Waterford Brewery was conducted in accordance with the method set out in the Agency’s guidance document, in which the Process Contribution (PC), the Background Concentration (BC) and the Predicted Environmental Concentration (PEC) are compared against the limit value. In this case, the Predicted Environmental Concentration is equal to the sum of the Background Concentration (as the highest 8-hour average) and the Process Contribution (the highest 8-hour average ground- level concentration, for each of the three scenarios), as shown in Table 4.

Table 4: Predicted Environmental Concentration (PEC)

In accordance with the Agency’s guidance document on air dispersion modelling, the maximum allowable Process Contribution was also calculated, as follows:

AQS - BC Maximum Allowable PC =

1.5

This yields a maximum allowable Process Contribution of 5,347 pg/m3, which is over 80 times higher than the highest Process Contribution calculated from the dispersion model (under Scenario 3).

The results of this analysis are summarised graphically in Appendix D.

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Byrne 0 CIPirigh Dispersion Modelling Assessment of CO Emissions ,from Diugeo Waterford Brewery

6 SENSITIVITY STUDY

In accordance with the guidance set out in Section 6.1 1 of the Agency’s Guidance Document, a sensitivity analysis of the parameters used in the dispersion modelling study was carried out. Table 5 summarises the parameters that were considered for the sensitivity analysis.

Table 5: Parameters Considered for Sensitivity Analysis

Parameter

Meteorological Data

+ Surface Parameters

I Urban Option

Data Used in Model

Three years of meteorological data from the Met Eireann station at Rosslare, for the years 2002,2003 and 2004.

The maximum licensed volume flow was used for each of the scenarios modelled.

Full, digital terrain data was used within the model.

The model was run y& building downwash.

The default parameters were used for Surface Roughness, Albedo and Bowen Ratio. A surface roughness of 1 m, being the US EPA Regulatory default option, was used in the model.

The urban option was selected, based upon the population of Waterford city.

The actual stack heights were used.

Breeze AERMOD was used to run the model.

Requirement for Sensitivity Analysis

The meteorological data from the Rosslare station is the most complete, representative data for the Waterford Brewery site and therefore there was no requirement to consider weather data from alternative locations (refer to Section 3.2.4).

75% of the maximum licensed volume flow was used to assess the momentum effect o f the emissions.

The model was also run using flat terrain.

The sensitivity analysis included the tnodel without building downwash, as required by the Agency’s guidance document.

Surface Roughness values of 0.5 m and 2 m were used in the sensitivity analysis. No sensitivity analysis was conducted for Albedo or Bowen Ratio as the default values are considered appropriate for the site.

The sensitivity of the urban option was assessed by varying the surface roughness (described above) from 0.5 m to 2 in.

No sensitivity analysis was required for this parameter.

No alternative models were used totest the model sensitivity as the scenario is not considered to be complex.

The results of the sensitivity analysis are summarised in Table 6. The analysis was conducted for Scenario 3 using the meteorological data for 2004, as this combination yielded the highest 8-hour average ground level concentration of CO. Sensitivity analysis of the volumetric flow rate was only conducted for the afterburner; the contribution from the boilers is negligible. For each parameter analysed for its sensitivity, all other parameters were maintained as per the Scenario 3 model.

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Byrne 0 Cliirigh Dispersion Modelling Assessment of CO Emissions ,from Diageo Waterford Brewery

Table 6: Summary of Sensitivity Analysis

Parameter

Volume Flow

Terrain

Building Downwash r I Surface Parameters

Sensitivity Analysis

Volumetric Flow Rate: Max. 8-Hour Average GLC:

Volumetric Flow Rate:

5,000 m’ihour (1 00% of licence limit) 66.5 pg/m’

3,750 m’ihour (75% of licence limit) Max. 8-Hour Average GLC: 54.7 pgi”’

Digital Terrain Max. 8-Hour Average GLC:

Flat Terrain Max. 8-Hour Average GLC:

With Building Downwash Max. 8-Hour Average GLC:

Without Building Downwash Max. 8-Hour Average GLC:

Surface Roughness: Max. 8-Hour Average GLC:

Surface Roughness: 0.5 m Max. 8-Hour Average GLC:

Surface Roughness: 2.0 m Max. 8-Hour Average GLC:

66.5 pgim’

50.3 pgim’

66.5 pgini’

66.5 pgiim’

1 .O m (default) 66.5 pg/m’

66.6 pgim’

66.5 pgim’

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Byrne 0 Clkirigh Dispersion Modelling Assessment of CO Emissions ,from Diageo Waterford Brewery

7 CONCLUSIONS

The following are our conclusions from the air dispersion modelling study.

1.

2.

3.

4.

5.

6.

7.

8.

9.

The study was conducted in accordance with the Agency’s Air Dispersion Modelling from Industrial Installations Guidance Note (AG4).

The highest maximum 8-hour ground-level concentration of Carbon Monoxide is 66.5 pg/m3, corresponding to Scenario 3 and the meteorological data for 2004.

The predicted maximum 8-hour average ground-level concentrations of Carbon Monoxide for each of the three scenarios that were modelled, and for each of the three years of meteorological data, are significantly less than the air quality standard of 10,000 pg/m3.

The predicted maximum 8-hour average ground-level concentrations of Carbon Monoxide for each of the three scenarios that were modelled, and for each of the three years of meteorological data, are significantly less than both the upper (7,000 pg/m3) and the lower (5,000 pg/m3) assessment thresholds specified in the Air Quality Standards Regulations.

The background concentration of Carbon Monoxide in Waterford City over the period of the Agency’s monitoring programme was less than the lower assessment threshold of 5,000 pg/m3. The maximum 8-hour average concentration over this period was 1,980 pg/m’.

The combined Process Contribution from the Brewery and Background Contribution in Waterford City, expressed as maximum 8-hour averages, are significantly less than the air quality standard of 10,000 pg/m3, for each of the three scenarios in each of the three years.

The maximum predicted Process Contribution from each of the three scenarios in each of the three years are significantly less than the Maximum Allowable Process Contribution (5,350 pg/m3), as calculated in accordance with the Agency’s guidance.

The sensitivity analysis of the relevant modelling parameters shows that the results on which this assessment are based are the most conservative, being the highest predicted ground-level concentrations of Carbon Monoxide.

Increasing the concentration of Carbon Monoxide in the emission from the afterburner on the roasthouse from the current limit of 100 mg/ m3 to 350 mg/m3 would not result in a significant impact on the air quality in the vicinity of the site. It would increase the maximum predicted ground-level concentration from 19 to 66 pg/m3 compared with a Maximum Allowable Process Contribution of 5,350 pg/m3.

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Byrne 0 Cleirigh Dispersion Modelling Assessment of CO Emissions From the Waterford Brewery

APPENDIX A

SITE LAYOUT


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3w

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Byrne 0 Cl6irigh Dispersion Modelling Assessment of CO Eniissions From the Waterford Brewery

APPENDIX B

WIND ROSES FOR ROSSLARE: 2002,2003 AND 2004


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Byrne 0 ClPirigh Dispersion Modelling Assessment of CO Eniissions From the Waterford Brewery

w

S

N

Wind Speed (mi s )

18 00

E

Wind Rose for Rosslare - 2002

w

S

N

E

Wind Speed (rnls)

7 00

0 8u

8 23

5 1 4 6

3 09

1 54

0 00 ,I 0”b)


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N

Wind Speed ( t T l / S )

15 00

W

S

E

5 14

3 09

1 54 I 0 00 1: '1%)

4 .



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Byrne 0 ClBirigh Dispersion Modelling Assessnzent of CO Emissions Frvni the Waterford Brewery

APPENDIX C

CONTOUR PLOTS FROM DISPERSION MODEL

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Byrne 0 Clbirigh Dispersion Modelling Assessnient of CO Emissions From the Wuterford Brewery

APPENDIX D

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Byrne 0 Cleirigh Dispersion Modelling Assessment of CO Emissions From the Waterford Brewerv

APPENDIX E

ASSESSMENT OF GROUND-LEVEL CARBON MONOXIDE CONCENTRATION

AGAINST AIR QUALITY STANDARD

BOC Ref. 287-X 153 December 2010

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