.

Submission Re Increased Stack Heiaht

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Client Project No:

PM Project No:

Document No:

File No:

100811

100811-22.RP-002

100811-22

Kerry Ingredients, Listowel

Boiler Emissions

Report on Stack Height Increase

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Kerry ingredients, Listowel 10081 ‘l-22-RP-002 Issue B Boiler Emissions 7” April 2005

1.

2.

3.

4.

0 5..

6.

INTRODUCTION 3

PREVIOUS REPORT RECOMMENDATIONS

2.1 Preferred Option

2.2 Kerry Ingredients Commitments

,

AIR QUALITY STANDARDS 6

BOILER OPERATIONS

4.1 Predicted Worst Case Boiler Use Profile

4.2 Actual Boiler Usage

AMBIENT AIR MONITORING RESULTS

5.1 Discussion on the Monitoring Results

IPC LICENCE ISSUES 9

6.1 Dispersion Modelling 9

6.2 Stack Height Increase 9

6.3 Boiler Operation 9

6.4 Revision to Emission Limit Values 9

6.5 IPC Licence Review 10

4

4

4

6

8

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Kerry Ingredients, Listowel Boiler Emissions

100811-22-RP-002 Issue 6 7” April 2005

1.

Kerry Ingredients, Listowel requested PM to prepare a follow-on report to the Boilers Emissions Study Report (Dot. No. 100448-22-RP-001) submitted to the EPA in June / July 2002.

The main purpose of this follow-on report is to provide details of the work undertaken at the site since June 2002 and to argue the case for a revision to some of the recommendations made in the above report.

The main revision being requested is in relation to the recommendation to increase the boiler stack heights (Al-l to Al-5) to 35m. This is now considered unnecessary and the argument and back-up information to support this revision is provided in this report.

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Kerry Ingredients, Listowel 10081 I-22-RP-002 Issue B Boiler Emissions 7th April 2005

2. PREVIOUS REPORT RECOMMENDATIONS

2.1 Preferred Option

Based on the various technological options and the modelling results an engineering, economic and environmental evaluation was carried out on 8 No. options. This evaluation ranked the options in order of suitability from 1 to 8.

The preferred option was identified as follows:

. Install new burners and burner management system (BMS) on all 5 HFO boilers.

. Depending on the oil boiler usage use a mixture of HFO and gas oil on the various boilers. Because of the significant difference in cost between HFO (cl % sulphur) and gas oil (approximately 40% in terms of atonne) further modelling was undertaken to determine at what times gas oil would be required based on a worst case annual operating profile for the boilers.

The results of this exercise showed that depending on the number of HFO boilers required to be in operation at any one time it is possible for some boilers to operate with gas oil and others with HFO thereby reducing the net increase in operating costs.

. Increase the stack heights of the five HFO boilers to 35m. The preference would be to install one new stack with the five individual stacks located inside it - all discharging separately.

A timescale for implementing the preferred option was provided to the EPA in a separate letter sent by Kerry Ingredients (dated 20th June 2002). This letter also identified Kerry Ingredients commitments to reducing the impact of emissions on the surrounding environment - see Section 2.2 below.

2.2 Kerry Ingredients Commitments

On the 20” June 2002 Kerry Ingredients submitted a letter and report (Dot. No. 100448-22-RP-001) to the EPA in relation to the issue of stack emissions from the 5 No. heavy fuel oil boilers located on-site.

As part of this letter Kerry Ingredients committed to do the following work:

?. Install an ambient air monitor,

Kerry Ingredients has, in fact, installed two ambient air monitors -the locations of which are to the north-east and south-east of the site. These locations were chosen based on the air dispersion modelling results.

2. installation of a wind direction and speed recording sysfem.

This has been installed and is located on-site by the coal boiler.

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Kerry Ingredients, Listowel 100811-22-RP-002 Issue B Boiler Emissions 7” April 2005

3. Record NO, and SO, emissions from the heavy fuel oil boilers on a daily basis.

This was worded incorrectly. What should have been stated is that hourly readings of NO, and SO, levels at the ambient air monitors would be taken and recorded.

Kerry Ingredients maintains a record of all hourly readings from the two ambient monitors.

Also as part of this letter Kerry Ingredients proposed a phased approach to the introduction of the following modifications:

. Verification of existing boiler emissions - work complefed.

. Installation of new burners on the existing Heavy Fuel Oil Burners complete with a new burner management system - work comD/eted.

. Installation of a light fuel oil storage and distribution system to enable burners to operate on either Heavy Fuel oil or Light fuel oil - J&C comdefed.

However, it should be noted that heavy fuel oil is still the main fuel used in the 5 boilers on-site.

. Increase to boiler stack heights - not carried out as vef.

In relation to the last bullet point above this report details the reasons why it is considered that the increase in stack heights is not now necessary and that the continued use of heavy fuel oil will not create any significant offsite impact.

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dk rry Ingredients, Listowel Boiler Emissions

0 l a 10081 I-22-RP-002 Issue B

7” April 2005

3. AIR QUALITY STANDARDS

Both NO2 and SO;! are measured at the two offsite ambient monitoring locations. The Air Quality Standards relevant to NO* and SO:! measured ground level concentrations (GLCs) are summarised in Table 3.1.

Table 3.4 - Air Quality Standards

PoHufant R@gUiafiOn Limit Type Margin of Tolerance Limit Value - 2003 Limit- Value - 2004 Limit Value-2010

Nitrogen 1999/30/EC Hourly limit for protection of human 50% until 2001 270 pg/m3 NO* 260 pg/m3 NO;! 200 pg/m3 NOa Dioxide

(SINo. 271 health - not to be exceeded more reducing linearly to

of2002) than 18 times/year 0% by 2010

Annual limit for protection of human 50% until 2001 54 pg/m3 NO* 52 pg/m3 NO1 40 pg/m3 NOL, health reducing linearly to

0% by 2010

Annual limit for protection of None 30 pg/m3 NO + NO2 30 pg/m3 NO + NO* 30 pg/m3 NO + vegetation NO2

Polluthf Regulation Limit Type Margin of Tolerance Limit Value - 2003 Limit Value.- .2004 .’ Limit Value-2005

Sulphur 1999/30/EC Hourly limit for protection of human 43% until 2001 410 pg/m3 380 yglm3 350 pg/m3

Dioxide (SI No. 271of health - not to be exceeded more reducing linearly until

2002) than 24 timeslyear 0% by 2005

Daily limit for protection of human None 125 pg/m3 125 pg/m3 125 pg/m3 health - not to be exceeded more

than 3 times/year

Annual &Winter limit for the None 20 pg/m3 20 pg/m3 20 pg/m3 protection of ecosystems

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EPA Export 25-07-2013:14:49:41

Kerry Ingredients, Listowel 100811-22-RP-002 Issue B Boiler Emissions 7” April 2005

4. BOILER OPERATIONS’

4.1 Predicted Worst Case Boiler Use Profile

In Section 6.4.1 of the Boiler Emissions Study Report (Dot. No. 100448-22-RP- 001) a worst case boiler use profile was provided for a typical year - see Table 4.1 below.

Table 4.7 - Boiler Use Profile - Worst Case

From this table the following can be stated:

Case I: Approximately two months of the year (January & December) only one HFO boiler is required and the preference is to utilise Boiler No. 4.

Case 2: For the months of February and November there is a requirement to operate 3 HFO boilers and the preference is for boilers 2, 4 & 5.

Case 3: For the month of March four HFO boilers are required with either Al-3 or Al-5 not being used.

Case 4: For the month of June all five HFO boilers may be required.

Case 5: For the remaining months either Boiler 3 or 5 is used in conjunction with the solid fuel boiler.

4.2 Actual Boiler Usage

For the months April to November 2003, Figure 4.1 identifies the boiler use profile for the heavy fuel oil boilers and the solid fuel boiler for the Listowel site.

This profile is typical for the site.

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Kerry Ingredients, Listowel 10081 I-22-RP-002 Issue I3 Boiler Emissions 7fi April 2005

5. AMBIENT AIR MONITORING RESULTS

Ambient monitoring results for the two offsite locations were made available to PM for the period April - December 2003. Figures 5.1 to 5.6 show plots of the measured NO:! and SO2 ground level concentrations (GLCs).

For each plot the measured levels have been compared against the relevant Air Quality Standard for the year 2003.

The final Air Quality Standard that will be applied in 2005 for SO2 and 2010 for NOs has also been included on the plots.

5.1 Discussion on the Monitoring Results

. All results are within the Air Quality Standards that applied in 2003 and that will apply in 2005 for SO* and 2010 for NO*.

. The NO2 hourly results are well below the 2010 Air Quality Standard (on average cl 0%).

. The SO* daily results are well below the 2005 Air Quality Standard (on average <4%).

. The SO* hourly results are mainly well below the 2005 Air Quality Standard (on average ~3%).

. While some of the SOS hourly ground level concentrations came close to breaching the Air Quality Standard (2005) it should be noted that in accordance with the Regulations there is an allowance of a maximum of 24 exceedances in any one year.

b The hourly results at Monitoring Location No. 1 for both SOn and NO;! would indicate that peaks in the measured GLCs occurred at the same time as the highest period of boiler usage (mid-June to early July).

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Kerry Ingredients, Listowel 10081 I-22-RP-002 Issue I3 Boiler Emissions 7+J’ April 2005

I) 6. IPC LICENCE ISSUES

6.1 Dispersion Modelling

Based on the modelling results (PM Report, 100448-22-RP-001(A)) it was concluded that an increase in stack heights to 35m would be necessary to ensure that the Air Quality Standards for NO;! and SO* would be met at all offsite locations.

As with all computer modelling packages it is well known that the results provided would be well in excess of those that would be expected from actual monitoring due to various built in safety factors. For this reason Kerry Ingredients undertook to install two offsite ambient monitoring stations, as discussed in Section 2 above.

6.2 Stack Height Increase

l Based on the results provided’in Section 5 it has now been proved that the impact of the emissions from the five heavy fuel oil boilers on the surrounding environment is minor when the results are compared with the relevant Air Quality Standards.

Therefore, the recommendation of increasing the stack heights to 35m made in the Boiler Emissions Study Report is now deemed to be unnecessary. It is considered that the existing stack heights and locations are sufficient to meet the required Air Quality Standards.

As well as the Boiler Emissions Study Report recommendation it is an IPC Licence condition (Schedule l(i)) that the stack heights of all five oil boilers be increased by July IS’ 2003. This condition has not been implemented and it is intended to request the EPA to remove this licence condition in any future IPC Licence review.

6.3 Boiler Operation

Currently, under the terms of the existing IPC Licence (Condition 5.13) Kerry Ingredients is unable to operate all five heavy fuel oil boilers at the same time. Based on the monitoring results to date it has been shown that the operation of all five boilers simultaneously would not have any significant impact on the surrounding area and would be well within the relevant air quality standards.

Therefore, it will be requested as part of an IPC Licence review, that this condition be removed from the licence and that all five boilers may operate simultaneously.

6.4 Revision to Emission Limit Values

As part of any future IPC Licence review it will be proposed to revise the emission limit values in the existing IPC Licence (Reg. No. 393). The intention would be to seek values similar to those proposed in Table 6.1 below.

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Kerry Ingredients, Listowel 100811-22-RP-002 IssueB Boiler Emissions 7fiApril2005

Tab/e 6-j - Proposed Emission Limit Values

Boiler / Stack NO.

Al-l

Al-2

Al-3

Al-4

Al-5

Al-l

Al-2

Al-3

Al-4

Al-5

Al-l

Fiowrate (Nm3/hr)

Existing Licence Future Licence Review

5,000 18,000

4,900 18,000

11,800 25,000

8,400 22,500

11,000 25,000

NO2 fLV.(mg/Nm3)

Existing Licence Future Liqence Revfew

900 900

900 900

900 900

900 900

900 900

SO, EL V (mg/Nm3)

Existing Licence Fufure Licence Review

1,700 1,700

6.5 IPC Licence Review

Kerry Ingredients intend to seek an IPC Licence review during 2005 and it is recommended that the issues raised and discussed in this report should be included as part of that Licence Review.

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EPA Export 25-07-2013:14:49:41

Kerry Ingredients, Listowel Boiler Emissions

10081 I-22-RP-002 Issue B 7ti April 2005

FIGURES ’

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Figure 4.1:- Operational Times of Boilers

100 I2 2 a0 I ? 60 z”

40

EI No. 1

q No.2

II No. 3

•I No. 4

n No.5

Date

Figure 5.1:- Ambient Monitoring Location No. 1 - NO, Houqly Results

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Figure 5.2~ Ambient Monitoring Location No. 2 - NO2 Hourly Results

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Figure 5.3: -Ambient Monitoring Location No. 1 - Hourly SO, Results

Date

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Figure 5.4:- Ambient Monitoring Location No. 2 - SO2 Hourly Results

350 n f 300

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Figure 5.5:- Ambient Monitoring Location No. 1 - DeilySOzAverage

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