Agency NOV 2013 - epawebapp.epa.ie

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Environmental Licensing Programme (ELP) Environmental Protection Agency, P.O. Box 3000 Johnstown Castle Estate Co. Wexford. Agency 0 5 NOV 2013 RE: EPA Response (3011 011 3) to IDL’s Submission LR005286 “Low Temperature Cooking Process” Dear Sir1Madam Regarding IDL IPPC Licence PO442-02, please find enclosed IDL’s submission for a Technical Amendment request. The attached document (Attachment 2) was previously submitted to the EPA’s OEE in the first instance requesting a Condition 1.4 Submission. In light of the response received from Linda Dalton (OEE) on 30th Oct 2013, a copy of which is enclosed as Attachment 1, IDL now wish to re submit the “Low Temperature Cooking Process“ documentation enclosed in Attachment 2 to the ELP seeking a Technical Amendment. Please note that any reference within the attached documents of Attachment 2 seeking a Condition 1.4 Approval should now be regarded as a request for a “Technical Am endment” . The OEE’s response has requested IDL to submit the following information: 1. “Details of the requested change(s)” Details of requested changes are provided in detail within the enclosed RFA Form and the associated Attachment A, included as Attachment 2 to this correspondence. 2. “Reasons for the change(s) requested Reasons for the changes requested are provided in pages 1 and 2 of the enclosed RFA Form included within Attachment 2 to this correspondence. 3. “Details of any increase or changes in emissions resulting from the change(s)” Details of changes in emissions resulting from the changes are outlined in pages 5 and 6 of the RFA Form and Table E.l(iv) of Attachment A.2 included within Attachment 2 to this correspondence. For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 26-04-2017:03:15:03

Transcript of Agency NOV 2013 - epawebapp.epa.ie

Environmental Licensing Programme (ELP) Environmental Protect ion Agency, P.O. Box 3000 Johnstown Castle Estate Co. Wexford.

Agency

0 5 NOV 2013

RE: EPA Response (3011 011 3) to IDL’s Submission LR005286 “Low Temperature Cooking Process”

Dear Sir1Madam

Regarding IDL IPPC Licence PO442-02, please find enclosed IDL’s submission for a Technical Amendment request. The attached document (Attachment 2) was previously submitted to the EPA’s OEE in the first instance requesting a Condition 1.4 Submission.

In light of the response received from Linda Dalton (OEE) on 30th Oct 2013, a copy of which is enclosed as Attachment 1, IDL now wish to re submit the “Low Temperature Cooking Process“ documentation enclosed in Attachment 2 to the ELP seeking a Technical Amendment.

Please note that any reference within the attached documents of Attachment 2 seeking a Condition 1.4 Approval should now be regarded as a request for a “Technical Am end m en t” .

The OEE’s response has requested IDL to submit the following information:

1. “Details of the requested change(s)”

Details of requested changes are provided in detail within the enclosed RFA Form and the associated Attachment A, included as Attachment 2 to this correspondence.

2. “Reasons for the change(s) requested

Reasons for the changes requested are provided in pages 1 and 2 of the enclosed RFA Form included within Attachment 2 to this correspondence.

3. “Details of any increase or changes in emissions resulting from the change(s)”

Details of changes in emissions resulting from the changes are outlined in pages 5 and 6 of the RFA Form and Table E.l(iv) of Attachment A.2 included within Attachment 2 to this correspondence.

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4. “An assessment of the likely impacts of any increasekhanges in emissions”

Please refer to Attachment 2 of this correspondence, within which, Attachment A . l (page 5 of Attachment A) provides a description of the proposed Dust Suppression System and high separation efficiency filter to be installed as part of the new hammer mill process.

Attachment A. 1 also provides an assessment against BAT Associated Emission Levels whereby the total particulates discharged to atmosphere at 10 mg/Nm3 is less than or equal to 20% of the BAT AEL (page 6 of Attachment A).

Attachment A . l further details that performance of the high separation efficiency filter will be guaranteed by monitoring differential pressure across the filter and installing alarms for high and low differential pressure to ensure that filter failures are captured by IDL’s SCADA system, thus preventing uncontrolled emissions to atmosphere.

I trust that we have interpreted the requirements for the Technical Amendment submission correctly.

Yours sincerely ,

Aidan Curran Environmental & Energy Manager

Enclosed:

Attachment 1 : OEE’s Correspondence to IDL 30th October 201 3

Attachment 2: IDL’s RFA Form & Attachment A (A. l to A.3 inclusive)

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Attachment 1

OEE’s Correspondence to IDL 30th October 2013

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Correspondence Received from the EPA 30th Oct, 2013 a t 16.25

“Dear M r Curran,

I refer to your submission LR005286, “Low Temperature Cooking Process“.

The approval is sought under Condition 1.4 of the IPPC Licence PO442-01 for an alteration to your installation/facility that results in a material change in the processes and the number of emission points on site.

The proposed emission point is considered a major emission as the particulates concentration of the un-abated emission will exceed the mass threshold of 200g/hr, and so abatement is required in order to meet the subsequent BAT concentration limits for particulates. As such, this proposed change cannot be accommodated under Condition 1.4 of your licence. A Technical Amendment or a Review of your licence will be required to provide for the proposed changes.

To determine if the proposed change can be accommodated by Technical Amendment you should submit the following information to the Agency’s Environmental Licensing Programme (ELP), EPA, P.O. Box 3000, Johnstown Castle Estate, Co. Wexford:

Details of the requested change(s) 0 Reasons for the change(s) requested

Details of any increase or changes in emissions resulting from the change(s) An assessment of the likely impacts of any increase/changes

in emissions

I f the alteration is considered to be a significant change and cannot be accommodated by a Technical Amendment, the ELP will notify you of the process for applying for a Review.

Yours sincerely, Linda Dalton Office of Environmental Enforcement, Cork”

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Attachment 2

IDL’s RFA Form & Attachment A (A.l to A.3 inclusive)

(All reference within the attached RFA Form and Attachment A to “Condition 1.4 Request” to now be regarded as a request for a

“Tech n i ca I Am end m e n t”)

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RFA Form A .a W" I-

Summary Guidance:

Page 1 of 8

i) Onlv those requests for approval that are required bv either Condition 1.2 or 1.4 of your IPPC / Waste Licence should be included in this form.

ii) Where additional information is being included with regard to new emission points and/or new substances being emitted from the facility: the information should be submitted on the RFA Form A Attachment.

:%

iii) Section 1 is a summary of the information that you shou in more detail in the relevant parts of

Sections 2 & 3.

iv) In the case where the OEE consider that the pr under the conditions of the existing IPPC Office of Licensing and Guidance.

Summary of proposed changes/amendment

Provide below a brief summary of the

nts cannot be accommodated will be forwarded to the licence, the info

i) nt indicating the urgency of the

will extend from le 12/6485) is a critical path project required to

Planning Permission

Information on the new exte time of the IPPC Licence Review under Condition 1.4 of the existing IPPC Licence PO442-02.

ting Brewhouse system was not available in sufficient detail a t the n submitted in July 2012 and therefore IDL is now seeking approval

Record of Previous EPA correspondence/references regarding Brewhouse Extension and New Brewhouse

As part of the IPPC Licence Review Application process in 2012/2013, the EPAs Inspector's Report of 23rd Jan

2013 noted:

"Planning permission for a further extension to the existing Brew House was applied for on 5'h December 2012

(Planning File Ref: 11/6485) and is due to be decided by Cork County Council on 7th February 2013. No new main emissions will result from this Brew House extension and any change of location of minor emissions should be submitted to OEE under Condition 1.4. The Brew House expansion will not, on its own, yield additional

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RFA Form A a @E!.. L 1 c 3

production capacity due to downstream constraints.”

Page 2 of 8

New Brewhouse:

“There is one new main emission point from a combi cleaner (cleans barley/malt grains), A3-30. There is an existing Buhler screen combi cleaner, A3-19 which was assessed as a minor emission under Condition 1.2 of the

current licence. However, both emissions are considered as main emission points in the proposed RD.”

Consequently A3-30 and A3-19 were included in Schedule C.1.2. of the revised IPPC Licence.

As part of the Final Determination, the EPA Technical Committee Report from 20th June 2013 noted:

“Planning permission for a further extension to the existing Brew House was applied for on the Sth December

Overview of extension to existing Brewhouse

and milling equipment venting to atmosphere via existi d minor emissi

installed to replace the existing continuous c silos) and the malt handling, milling and prep

weighing and from the malt hammer mill will CO

extract vent via A3-12.

As part of the new low temp 18,000 kg/hr complete with a -

, particulate emissions from the malt

naldson dust suppression unit and

ith a design milling rate of

Buhler high efficiency dust collection filter will described in more detail in Attachment A.

Other new mino steam vents from th

preparation tank, lique

Attachment A provides a com

em which will be made redundant in lieu of the new mash

rview of the proposed extension including a revised Table E.l(iv) eric emissions - Continuous Brewing, a revised atmospheric

Priority for licensee? Urgent High U Routine U

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,.- - .". I . , , . I

RFA Form A a @@a.* _I

. . I

Page 3 of 8

Licensee Name Licensee Address

SECTION 1 - Summary Details I IPPC /Waste Licence Number I PO442-02

Irish Distillers Ltd. Midleton Distilleries, Midleton, Co. Cork

Reason for request

I Date of Approval Request I 26'h September 2013 I

Tick as appropriateN1' ' A. New or altered abatement, treatment or recovery B. New Processes X (altered process)

Will any Condition and/or Emission limit value in the existing licence be breached?

Predicted Impact on Environment .k L ,

If Yes, give details:

Is the proposed amendm conditions of your current

ided for under the

If Yes, where in the licence is the proposed change provided for?

Is the proposed amendment / change a listed activity in the first schedule to the Environmental Protection Agency Acts, 1992 to 2011 /third or fourth scehule of the Waste Management Acts 1996?

I

Condition 1.4 - subject to EPA approval.

No

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RFA Form A Page 4 of 8 a eg,.

c l t -

If Yes, is the activity provided for in the existing IPPC/Waste Licence?

SECTION 2

Change type

- New emission point

- Increased emissions to air

- Increased emissions to waterhewer

- New substance being emitted

- New abatement equipment

- New waste outlet / waste c

If “other” please provide b

of the new/altere

Will the new or altered ac

In the case where an increase in emissions is expected you should complete Section 3 below.

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RFA Form A Page 5 of 8 a W" t.l

" . I *_

' 3. Nature and Quanti g Proposed Waste Outlets

I

Emission Air Water 0 Sewer 0 Waste 0 I - - - - . - - . . . "

/. . L e I ' p L S G 2, L f L *

Tf Air, Water or Sewerprovide details in Section E.l, - I

if Waste provide detaiis in Section E.2 L .

, Where'additidnal information is being'sub&tted please use the format / I i provided in Attachments 1-4

Emission( s) .'f & 'li

Emission Point(s) where

Provide name(s) of newkhanged substance(s)

to be emitted

Substance(s) being altered

ELV in current licence

In the case where the proposed discharge is to

pour and Particulates

El Currently Limited in Licence? Yes 0 No

Substance I Value I Units N/A

Letter of approval/consent received?Y 0 N 0

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RFA Form A Page 6 of 8 a T2. L- I

sewer has a letter of consentlapproval been

Name of Sanitary Authority?

received from the relevant Sanitary Authority Copy of Letter of approvalkonsent attached? Y 0 N 0

I . ~ . . . . . _ . . _I . . . . . . . ....... - .......... ~ ... .*., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I , ' , . . . , .

. . . . . I

. . . . . . . . . . 4 . . L . . . . . I

:.', . ,Current-Situatiori .,. :I .r,

. _ r ..> ,. , - ' r. . . . .

I .

. - , . . :,- ' '

Substance (e.g. ammonia, TOC, suspended solids, etc)

Receptor Current Licensed Emission Limits (air,

water, Conc. Mass Emission (conc x vol) etc)

Particulates (6,000 N m3/ h r)

Method of quantification of emission:

Details of quantification of emission(s) (e.g. in-house trial, supplier data, library

Conc.

10 mgmm3

Mass Emission (conc x vol)

473.8 kg/yr (based on operating >47 wks per yr)

l.4 Measured I s t i m a t e d w a l c u l a t e d

Supplier data on high performance filter bags

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RFA Form A a @@a. c-

data, etc).

Page 7 of 8

Further details attached

Change to Waste Streams

Waste type

Waste Quantities (kg/weekjj €3:

In the case of a new waste

waste stream to an on-s WTTP?

.

If Yes to the above please provide the following information:

New

Increased

0 0

If Yes, provide details regarding changed emissions in Section 3.1

i) For activated sludge WWTP, submit the results of respirometry testing, where available (using relevant sludge sample)

ii) For a non-activated sludge WWTP, submit the results of an assessment of the capacity of the existing WWTP to adequately treat the waste stream where available

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RFA Form A a e??,

I certify that the information given in this application is truthful, accurate and complete.

I

Page 8 of 8

Signed: %&& QaLrL

Print signature name:

ental Enforcement consider that proposed ce, the information r their information.

1 Please refer to Attachment A

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ATTACHMENT A

Attachment A.l Continuous Brewing: New Low Temperature Cooker -

Process Description

Attachment A.2 Revised Table E.l(iv) Emissions to Atmosphere - Continuous Brewing

Attachment A.3 Revised Brewhouse and Brewhouse Extension - Atmospheric Emission

Points Drawing No. 3

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. . I

Attachment A.l Low Temperature Cooker - Process Description

A description of the Continuous Brewing process was provided in the IPPC Licence Review Application as submitted to the EPA in July 201 2, Reference attachment D, Section D3.2 “SP-02 Continuous Brewing”.

The following PFD and process description now replaces in full the continuous brewing description provided in Section D3.2 within the review application submitted in July 2012.

The attached, Emissions to Atmosphere Table E.l (iv) included as Attachment A.2 and the Emissions to Atmosphere drawing included as Attachment A.3 have been revised to reflect the proposed changes associated with the new low temperature cooker.

D3.2 SP-02 Continuous Brewing (Rev 1)

A process flow diagram of the new continuous brewing system is provided overleaf. Refer to the revised Table E.l (iv) Emissions to Atmosphere in Attachment A.2 which identifies the new minor emission points to atmosphere

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Cold Pros.,, W.b.

r

U)

3

A3-17

-1

To Dnln MVR I

Condenlab

Figure A.l.l SP-02 Continuous Brewing (Rev 1) (IPPC Licence Review Application Reference SP-02)

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Low Temperature Cooker - Process Description

The new Low Temperature Cooker plant replaces the existing continuous cooker plant, excluding the maize handling system (elevators and silos) and the malt handling, milling and preparation system. The existing low temperature cooker vessel will be utilised as the new Pre-Saccharification vessel.

Screened maize from the storage silos is weighed and conveyed into a hammer mill (design milling rate of 18,000 kg/hr) with i t s associated dust extraction system (further details on dust extraction system provided below). From here the milled corn is discharged into a Mash Preparation Tank where it is mixed with hot water and process additives.

Hot Mash is subsequently pumped to the liquefaction tank where the temperature is increased by the addition of steam. The Liquefaction stage liquefies the starch from the milled maize. This tank's contents are circulated and agitated and the viscosity of the contents is reduced before it is forwarded to the primary energy recovery system.

Mash is pumped to a multi-stage flash vessel No. 1 where the temperature is reduced. Vacuum is provided via a liquid ring vacuum pump. Flash vapours exiting flash vessel No. 1 heat up mash water in the vertical mixing condenser. The heated mash water is used for mixing in the mash preparation tank. Non condensed vapours exiting the mixed condenser are further cooled in vent condenser No. 1 using cooling water. Non-condensable gases are routed to atmosphere via the vacuum pump and condensed liquid is collected as mash water in the water balance vessel to be subsequently forwarded to the mash preparation tank.

In parallel with this, malted barley from the storage silos is weighed and milled via a hammer

mill and fed to the malt slurry tank where it is mixed with process water and additives, this is an existing process step and no changes are proposed to this.

Mash exiting the flash vessel is mixed with malt slurry and pumped to the Pre- Saccharification tank (this was originally the low temperature cooker vessel) where the

conversion to fermentable sugars begins.

The outlet from Pre-Saccharification Tank is pumped to the secondary energy recovery system. Vacuum is provided via a liquid ring vacuum pump in flash vessel No. 2. Mash exiting Flash Vessel No. 2 is routed to the corn fermenters. Flash vapours heat up mash water in the vertical mixing condenser No. 2. The heated mash water is used either as feed water for mash preparation or cooling water for MVR condensate when the condensate exiting the MVR Plant is being used for mash preparation. Non condensed vapours exiting mixed condenser No. 2 are further cooled in vent condenser No. 2 'using cooling water. Non- condensable gases are routed to atmosphere via vacuum pump and condensed liquid is

collected as mash water to feed the water balance vessel or cool MVR condensate as above.

Process Control

Temperature, vacuum control and residence time are the critical parameters of control in the low temperature cooker. Direct steam is used and cold process water is used for temperature and mixing requirements. Exchanging heat by condensing flash vapours is the principle of the primary and secondary heat recovery systems. Cooling water is also used for

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final coolers. The entire process is controlled by the site’s SCADA system and is overseen by production personnel on a 24 hour basis.

Dust Suppression System

The new low temperature cooker will include a new corn hammer mill and associated Buhler high separation efficiency filter which is integral to the milling process. The filter equipment for the corn mill consists of a Buhler supplied high pressure MVRU filter with a design flow rate of 6,000 Nm3/hr which will be directly mounted on to the mill under the hopper. Initial dust separation within the unit is by centrifugation, the subsequent filtering of the dust- laden gas by the filter elements produces a very high purity of the cleaned gas (99.95 %

removal efficiency) and maximizes the percentage of dust (corn flour)/raw material for use in the process.

Performance of the filter will be guaranteed by monitoring differential pressure across the filter and installing alarms for high and low differential pressure to ensure filter failures are captured by the Scada system and uncontrolled emissions to atmosphere are prevented.

c 2 1

4

‘1 I

- MAIZE GRIST

Figure A.1.2 Extract from Buhler P&ID “Fine Grinding System Drawing No. 3-LND-2103 (Rev

02)

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Emission Category

The EPA defines an emission point as a main or minor emission point by virtue of the following:

“Main Emissions will include all emissions of environmental significance. Where a mass emission threshold is used in the BAT Guidance Note (e.g. 3 kg/h), all emissions greater than 20% of such a threshold are regarded as significant. (In some cases emissions below 20% of a threshold can sti l l be significant and will qualify as Main Emissions.)”

The Relevant mass emission threshold from “BAT Guidance Note on Best Available Techniques for the Brewing, Malting & Distilling Sector ( 1 s t Edition), EPA 2008” are outlined

in Table A . l .

Table A.1 - BAT Associated Emission Levels (AEL) for Discharges to Air

Parameter Emission Level (mg/m“) Mass Threshold (g/hr) ’ Total Particulate Matter 5-50 >200 (including emissions from material handling)

150 At mass flow up to 200

Note 1: The Mass Flow Threshold is calculated in glhr or kg/hr and is determined to be the maximum emission, which can occur over any one-hour period of plant operation. Where the Mass Flow in the raw gas exceeds the mass flow threshold given in the Table, abatement will be required to reduce the emission to below the appropriate emission level or mass flow threshold.

As per Note 1 above, the expected mass flow in the raw gas is > 200 g/hr, therefore the relevant BAT AEL for the emission point is considered to be 5-50 mg/Nm3.

The remaining total particulates from the corn hammer mill associated MVRU filter are discharged e /= 10 mg/Nm3. 20% of the BATAEL is 10 mg/Nm3 (i.e. 20% of 50 mg/Nm3= 10 mg/Nm3) and therefore, in accordance with EPA guidance the emission point should not be

considered significant and should be classified as a minor emission point.

There will be no new raw materials associated with the extension, there will be an increase in material requirements to facilitate the increased corn throughput from 12,500 kg/hr to a design milling rate of 18,000 kg/hr . The existing storage silos for the maize and malt are sufficiently sized for future production volumes associated with continuous brewing. There will be no new types of waste material generated as part of this process. Buhler Filters will be replaced approximately every two years.

Due to the new technology associated with the new low temperature cooking primary and secondary energy recovery system, there will be an 84% reduction in steam usage for the low temperature cooker.

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- .~ . _. ." - . , , . , , . . .. . , . 1 I

Emissions Durinq Normal Operations

Atmospheric

Sewer

There are a number of minor emission points associated with the new continuous brewing process. These are identified in the revised Table E.l(iv) of Attachment A.2.

Similar to the old continuous brewing system, there are emissions to the WWTP drainage system from floor washngs and the on-site Cleaning In Place (CIP) regime. CIP in this area is typically completed once every 7-10 days.

The use of cavern cooling water will cease upon completion of installation of the new continuous brewing system.

To Waters

I Waste I Minimal waste from floor spillages, process line blockages.

Noise There will be no main noise source equipment associated with the new low temperature cooker system as all equipment will be located indoors.

Minor Atmospheric Emission Points - Continuous Brewinq

A3-14 Mash preparation tank vent A3-15 Liquefaction tank vent A3-16 Flash vessel no. 1 vent A3-17 Vacuum pump vent A3-18 Pre-saccharification tank vent A3-23 Flash vessel no. 2 vent A3-24 Corn hammer mill vent

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. .

Attachment A.2

Revised Table E.l(iv) Emissions to Atmosphere - Grains Intake & Storage, Continuous Brewing & Batch Brewing

All new emission points and changes as a result of the new continuous brewing process are denoted in red font

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TABLE E.l(iv): EMISSIONS TO ATMOSPHERE - Minor atmospheric emissions

Grains In take 81 Storage

Existing Licensed Emission Pt

Existing Licensed Emission Pt

Emission point I Description I Emission details' I Abatement system employed

Dust Suppression Unit

Dust Suppression Unit -

Reference Numbers I

A3-9

A3-10

Imaterial

Barley Storage Bin Vent Particulates

Maize Storage Bin Vent Particulates

A3-71 I Grain Intake Hoppers Vent I Particulates

A3-11

A3-2 I Barley Elevator Vent I Particulates

Maize Silo Vent Pa rti cu I a tes

A3-3 I Malt Elevator Vent I Particulates

Existing Licensed Emission Pt

A3-4 I Maize Elevator Vent I Particulates

None

A3-5 * Redundant emission pt.

Redundant emission pt.

A3-7 I Barley Crossover Conveyor Vent I Particulates

A3-8 I Malt Storage Bin Vent I Particulates

Existing Licensed Emission P t I Dust Suppression Unit

Existing Licensed Emission Pt I Dust Suppression Unit

-1% . . . .

Existing Licensed Emission Pt I None

Existing Licensed Emission P t I None

Existing Licensed Emission P t I None

Existing Licensed Emission P t I None

1 The maximum emission should be stated for each material emitted, the concentration should be based on the maximum 30 minute mean. 2 Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0°C101.3kPa). Wet/dry should be clearly stated. .Include

reference oxygen conditions for combustion sources.

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EPA Export 26-04-2017:03:15:03

TABLE E.l(iv): EMISSIONS TO ATMOSPHERE - Minor atmospheric emissions

Brew House (Continuous Brewing)

Emission point Description

Reference Numbers

A3-12 Donaldson Extract Vent

Redundant, this is an air intake vent.

A3-14 Mash Preparation Tank I Vent

A3-15 Liquefaction Tank Vent

A3-16 Flash vessel 1 Vent

A3- 17 Primary and Secondary Heat Recovery Vacuum Pump Vent

A3-18 Pre Saccharification Tank Vent

material

Particulates

Water vapour

Water vapour

Water vapour

Water vapour

Water vapour

Emission details' Abatement system employed

mg/Nm3(2) I kg/h. I @/year

Existing Licensed Emission P t - emissions from Malt Hammer Mill Vent and Malt Weigher Existing Corn mill emissions taken off and new corn hammer mill filter now exhausting separately to atmosphere via A3-24

Malt hammer mill is vented via the Donaldson extract vent A3-12

Dust Suppression Unit

I None

New Licensed Emission Pt (replaces Corn Slurry Tank Vent)

New Licensed Emission Pt None (replaces Low Temperature Cooker - Vent 1)

New Licensed Emission P t None (replaces Low Temperature Cooker - Vent 2)

New Licensed Emission P t None (replaces Steam Ejector / Vacuum Pump Vent)

New Licensed Emission Pt None (replaces Cooker Converter Vent)

1 The maximum emission should be stated for each material emitted, the concentration should be based on the maximum 30 minute mean.

reference oxygen conditions for combustion sources. 2 Concentrations should be based on Normal conditions of temperature and pressure, (Le. 0°C101.3kPa). Wet/dry should be clearly stated. Include

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EPA Export 26-04-2017:03:15:03

TABLE E.l(iv): EMISSIONS TO ATMOSPHERE - Minor atmospheric emissions

Brew House (Continuous Brewing)

Emission point

Reference Numbers

A3-23

A3-24

Description

Flash Vessel 2 Vent

New Corn Hammer Mill Filter Vent (6,000 N m 3/h r) New Licensed Emission Pt Where corn hammer mill emissions are no longer routed to Donaldson Unit i.e. A3-12

. -

material

Water vapour

Particulates

Emission details' I Abatement system employed I( New Licensed Emission Pt. (Converter A Vent A3-23 made redundant)

473.8*

None

New Buhler high separation efficiency dust filter on exhaust

* based on operating 47 wks per Y r

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EPA Export 26-04-2017:03:15:03

TABLE E.l(iv): EMISSIONS TO ATMOSPHERE - Minor atmospheric emissions

Brew House (Batch Brewing - Existing)

Emission point Description Emission details'

Reference Numbers material mg/Nm3 kg/h. W y e a r (2)

A3-19 Buhler Screen Vent Particulates Existing Licensed Emission Pt

Abatement system employed

Dust Suppression Unit

A3-20

A3-21

I Redundant,

Rubble Bin Vent Particulates Existing Licensed Emission Pt Dust Suppression Unit

Malt / Barley Weigh Bin Particulates Existing Licensed Emission Pt Dust Suppression Unit

A3-25

Steam with 3% caustic

A3-27 I None New Licensed Emission Pt

- Redundant, - Redundant,

7 Redundant, now a CIP vent

CIP vent

Existing Licensed Emission Pt

I Redundant, I - None A3-22

- Redundant,

Bub tanks - common vent CO2

I- 1 The maximum emission should be stated for each material emitted, the concentration should be based on the maximum 30 minute mean. 2 Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0°C101.3kPa).

reference oxygen conditions for combustion sources. Wet/dry should be clearly stated. Include

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EPA Export 26-04-2017:03:15:03

I .

Description Emission details'

. . ,

. .-

Abatement system employed

TABLE E.l(iv): EMISSIONS TO ATMOSPHERE - Minor atmospheric emissions

mg/Nm3(*)

20

7

7

Brew House Expansion (Batch Brewing - New Process) (Previously Supplied to the EPA under a Condition 1.2 Notification 2012 and IPPC Licence Review Application 2012/2013)

kg/h. kg/year

0.108 785 Dust filter on exhaust

0.0133 97 Dust filter on cyclone exhaust

0.0406 295 Dust filter on cyclone exhaust

Emission point

A3-30

-

A3-31

392 2.85E+ None - tank vented directly to 06 atmosphere

11 A3-33

Tank Venting

II A3-34

None - tank vented directly to atmosphere

A3-35

Weak Wort Tank Vent II A3-37 Product Vapours

Tank Venting

Combi Cleaner Vent (5,400 Nm3/hr)

Malt Mill - Cyclone Vent (1,900 Nm3/hr)

Barley Mill - Cyclone Vent (5,800 Nm3/hr)

None - tank vented directly to atmosphere

material

Particulates

Particulates

Particulates

Mashing-In Vessel Vent

Mash Tun No. 1 - vent

Steam

Steam

Mash Tun No. 2 - vent

Strong Wort Tank Vent

Steam

Product Vapours

I 70 5.09E+ None - tank vented directly to

105 I atmosphere

2.85E+ None - tank vented directly to I 392 I 0 6 I atmosphere

1 The maximum emission should be stated for each material emitted, the concentration should be based on the maximum 30 minute mean. 2 Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0°C101.3kPa). Wet/dry should be clearly stated. Include

reference oxygen conditions for combustion sources.

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EPA Export 26-04-2017:03:15:03

Attachment A.3 Revised Brewhouse and Brewhouse Extension - Atmospheric Emission

Points Drawing No. 3

14

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EPA Export 26-04-2017:03:15:03

FER M EN TE R S

U

0

0 0

0 0 1 I / 0

' H F DRAWlNC WAS -

kr I J ' ETTED USING: AuloCAD

I I

/A'-8 L3- 2

A2-3

/

L

1 Om

LEGEND

Al-OO 0 BOILER EMISSION POINT

A2-00 Q MAIN EMISSION POINT

AJ-00Q MINOR EMISSION PMNT

A 6 0 0 Q POTENTIAL EMISSION PMNT

AS-00 0 FUClTlK EMISSION POINT

BREW HOUSE AN0 BREW HOUSE EXTENSO4 ATMOSPHWC DRAWNG EMISSION NO. 3 POINTS

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EPA Export 26-04-2017:03:15:03