Attachment D.1 Unit Operations & Processes. D.1.1 Overview & Summary of Unit Operations and Processes

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1 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Attachment D.1 Unit Operations & Processes D.1.1 Overview & Summary of Unit Operations and Processes This section outlines the existing plant and the unit operations and processes. Also included are the elements of Project ICE and details of elements that have already been installed/upgraded, and those planned for the near future. The elements of the site are as follows: Warehousing Offices Canteen Laboratories Wet Process Area Dry Ingredients Area Evaporators & Evaporator Tower Drier Towers Canning and Filling Area Blending and Powder Silos Engineering Offices Bulk Storage Area Boilers Refrigeration Plant Water Treatment Plant Wastewater Treatment Plant Main Switch Room and Emergency Generator River Water Pump House Security Hut Milk, Oil and Syrup Intake Building The principal unit processes at the facility can be divided into the following areas: Wet Process Ingredient Intake, Blending, Heating, Mixing, Homogenisation and Chilling Pasteurisation and Evaporation Dry Process Drying & Powder Storage Canning/Packaging D.1 - Page 1 EPA Export :03:43:40

2 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Process Flow diagrams for the main processes are included as part of this attachment. The ancillary processes and operations are as follows: Laboratory Operations Refrigeration Plant/Chilled Water System Water Treatment Waste Water Treatment Power & energy Supply Compressed Air Bulk Nitrogen and Carbon Dioxide Storage and Distribution Cleaning in Place (CIP) Fire Protection Offices Support Facilities Warehousing & Bulk Storage Waste Management The total footprint of the production facility, including the wet and dry process, warehouse and offices is 16,555 m 2. The overall block Process Flow Diagram is shown on Drawing AIC D.1 - Page 2 EPA Export :03:43:40

3 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited D.1.2 Materials Handling, Ingredient Intake, Storage and Preparation Materials handling, storage and preparation involves the receipt, storage and internal conveying of raw materials, intermediate products and final products and preparation of materials for wet processing. D Skim Milk Skim milk is transported to the intake bay on site by bulk road tanker. Milk is sourced from local and national dairies. Following quality assurance (QA) checks the road tanker contents are unloaded to one of six skim milk silos or one dual silo. A dual silo can hold either milk or product. There are two milk intake lines, which allow two road tankers to be unloaded simultaneously. Each intake line is equipped with a centrifugal pump, de-aerator and milk cooler. Milk is unloaded at approximately 55,000 l/hr. If the milk temperature exceeds 6 C the milk is cooled to 4 C and if it exceeds 7 C the road tanker is rejected. Each load of milk is metered into a silo and each load is followed by a water flush. Cleaning in Place (CIP) of the milk intake lines is carried out at a minimum of once every 24 hours. After a road tanker is emptied, it is cleaned before being collected by the milk supplier. Typically, four to five loads of milk are required to make up a batch. All silos have a working capacity of 130,000 litres. Once a silo is full, its contents are analysed. The analysis is used to determine other ingredient additions required and takes approximately 30 minutes. Skim milk is transferred from the silo to the wet process. The milk intake and storage process flow diagrams are shown on drawings AIC and AIC D Oil and Syrup Intake Storage & blending Vegetable oil and syrup are delivered to the intake bay on site in road tankers. Following QA checks, the oil or syrup is transferred to one of twelve oil/syrup silos. Dedicated silos are provided for different oils/syrup. There are two intake lines, one for oil and one for syrup. These two lines are charged with nitrogen when not in use. The lines are equipped with positive displacement pumps and pigging systems. During intake, the line is temperature controlled using heat tracing. Once intake is completed, the line is evacuated using the pigging system. The propellant for the pig is nitrogen, and when the line is empty it is charged with nitrogen, thus maintaining an inert atmosphere. Prior to commencing oil blending, the exact amount of oil required is determined based on the batch size and the results of the chemical analysis of the milk. Oils are metered from their respective silos to the blend tank. Following blending of bulk oil, non-bulk oils and other ingredients (vitamins and minerals) are added to the oil blend tank. The mix is then agitated for a set time prior to release for addition to the wet process. D.1 - Page 3 EPA Export :03:43:40

4 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited The oil and syrup intake and storage process flow diagrams are shown on drawings AIC and AIC D Dry Ingredients Sucrose is generally delivered by bulk road tanker to the site and is unloaded to a bulk storage silo - bagged sucrose is also maintained to cover bulk delivery failure. All other dry powdered ingredients are delivered in bags of various weights. There are two big bag discharge stations whereby ingredients are transferred from the big bag station to dedicated storage silos which are sized to hold numerous batch loads. The powdered ingredient intake and storage process flow diagram is shown on drawing AIC D.1.3 Wet Process - Blending, Heating, Mixing, Homogenisation and Chilling The purpose of the wet process stage is to mix the streams of skim milk, blended oil, syrup and bulk dry materials. The wet process production process involves blending and heating liquid and/or powdered skim milk with ingredient water, sucrose, vegetable oils, syrup, flavouring, vitamins, minerals and other powdered foodstuff ingredients. The quantities of ingredient vary according to the product being produced. Some minor ingredients are added manually. Minor liquid ingredients are also dosed to the process from IBC s. There are two independent wet process systems, which are used for mixing, blending, heating, homogenisation and chilling of the product. As part of Project ICE wet process 1 was upgraded so that it is now identical to the existing wet process 2. Each existing wet process system has its own dedicated oil blend tank. As part of Project ICE, an additional third oil blend tank has been installed in the wet process area to allow oil blends to be made and tested off-line. This is so that neither wet process has to wait for an oil blend to be prepared. This decreases the wet process down time and increases wet process capacity and efficiency. The oil blending process flow diagram (including new third oil blend) is shown on drawing AIC The third oil blend system can also be seen on Plate 1. As temperature affects mixing performance, the wet process system is heated up using warm water prior to the addition of dry ingredients and oils. Once heat-up is complete, skim milk is pumped to the process and water removed. The wet process circulates on milk for a time ensuring the temperature reaches the required solubilisation temperature. Once the setpoint is established, the dry ingredients, oils and syrup are added. The wet process is finished when the milk silo is empty. The dry ingredients are added under vacuum to avoid foaming and are emulsified by the action of the shear pump on the bottom of the high shear mixing vessel. As oil and milk are immiscible, the oil is added to a partial milk stream, which is then homogenised and blended back in with the main stream. This minimises the size of the homogeniser and thus energy requirements. D.1 - Page 4 EPA Export :03:43:40

5 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited After wet processing the product is transferred to a product silo where the temperature is maintained at 4ºC. Prior to release to the evaporator the product is analysed and water-soluble vitamins are added and the ph is adjusted as required. When the results of the final analysis are satisfactory the batch is released to the evaporator. Two product families are produced i.e. finished powder Type 1 which does not contain flavouring and finished powder Type 2 which does contain flavouring. A process flow diagram for both wet processes can be seen on AIC D.1.4 Pasteurisation and Evaporation The liquid mixture produced in the wet process area must be pasteurised and evaporated. The purpose of pasteurisation is to apply heat to the product to reduce bacterial and enzyme activity. Incoming skim milk is pasteurised prior to arrival on site. However, following addition of the oil blend and the dry ingredients the product needs to be pasteurised once more. Heat regeneration is used to heat incoming product from the product silos from 5 o C to 50 o C. Product from is then pasteurised in a heat treatment group (HTG) where Direct Steam Injection is used to heat the product to 121ºC for 3-6 seconds (product dependant). Following pasteurisation the product is transferred to the multiple-effect evaporator. The purpose of evaporation is to significantly reduce the water content and increase solids content. Removing water in the evaporation process is more cost effective than in the drying process and hence it is desirable to remove as much water as possible in the evaporation process. The evaporation process uses steam energy to increase the solids concentration in the product by boiling off some of the water in the product. As milk products are sensitive to heat, it is necessary to work at low temperatures. This is achieved by using a vacuum. The evaporator has four effects and as the product is passed through each effect it becomes more concentrated. A thermal vapour recompressor (TVR) is also used to minimise steam usage. Product released from wet processing varies in total solids content (TS) depending on the product, from 13-22% Total Solids (TS). Following evaporation, TS is increased to as high as 55% TS. The evaporator concentrate is then pumped to the dryer feed tank. Milk water condensate from the evaporation process is routed to the dryer heating coil where heat is recovered from the condensate and the condensate is cooled. Depending on product type, milk water condensate can then be routed to either the effluent plant or the storm drain. Water condensate from finished powder type 1 (low COD, no flavouring) is ideally routed to storm drain as it is of a higher quality than that produced by the effluent plant. Condensate from finished powder type 2 (flavoured powder) is all routed to the effluent treatment plant due to its high BOD content. At present all condensate (finished powder D.1 - Page 5 EPA Export :03:43:40

6 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited type 1 and type 2) is routed to effluent plant while TOC metering for monitoring of condensate from finished powder type 1 is investigated. There are currently two driers and associated evaporators on site. An additional evaporator will be installed at the site, however this addition has not yet been finalised. Planning permission has been obtained for a building to house the additional evaporator. The location of the proposed 3 rd evaporator is shown in Plate 2. The evaporator tower will tie into the northern elevation of the existing drier tower. A process flow diagram for the existing evaporators (including the potential third evaporator) can be seen on drawing AIC Routing for the milk condensate stream can be seen on drawing AIC D.1.5 Drying and Powder Storage Once the liquid product has been evaporated and pasteurised it is then pumped via high pressure pumps to two dryers. Drying involves the application of heat under controlled conditions to remove water in order to produce solid product. The dryer feed tank provides steady state pumping conditions to the dryer. The product is heated to 75 o C in a concentrate pre-heater and then a high-pressure pump is used to transfer to the dryer. Concentrate is atomised as it enters the top of the drying chamber. The dryers draw in ambient air via intake fans and heat the ambient air to high temperature via steam heated heat exchangers. The hot air is in direct contact with the atomised product as it falls. The heat transferred from the hot air to the product causes water evaporation. Once powder forms at the bottom of the chamber it is fed to a fluidised bed dryer in which further drying and cooling of the product takes place. Hot exhaust air is discharged via exhaust fans through an exhaust duct. There is a bag house filter prior to each exhaust dust to capture dust and this dust is expelled from the filters and captured for disposal in FIBC bags. In the interests of noise minimisation there is a sound attenuator on each exhaust duct. In the interest of energy efficiency there is a heat recovery unit on each exhaust duct to capture heat from hot exhaust air which in turn is used to preheat intake air. The process flow diagram for the existing dryers are included on drawings AIC and AIC After drying, the moisture content in the powder is approximately 2%. In addition, some batches of powder are agglomerated during the drying process to improve reconstitution. Once product is dried in the dryers it can be bagged off directly at the dryers or conveyed to finished powder silos. Dense phase conveying is used to transfer powder from the dryer to finished powder silos. Diverter valves are used to automatically establish the route from dryer to silo. The powder is stored in a silo pending request from one of the packing lines. D.1 - Page 6 EPA Export :03:43:40

7 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited There are sixteen 80 m 3 finished powder silos and three 50 m 3 finished powder silos on site. These silos supply powder either directly to the 2 existing packing lines (Packing Line 1 and Packing Line 2) or to two dry powder ribbon blending systems for additional ingredient addition and then onwards to the packing lines. See AIC for details regarding finished powder storage and conveying to canning. The dryers need to idle when evaporator buffer tanks and dryer feed lines are being cleaned in place (CIP d). As part of project ICE, evaporator buffer tank and drier feed line CIP s for both dryers were re configured for CIP s to run in parallel rather than in series thus shortening the time to CIP the overall evaporator system and thus increasing Dryer up time. In addition a second feedline and 120 kw high pressure pump was installed on Dryer 2 meaning that this feedline and pump set can be cleaned off line with Dryer 2 running thus further reducing the CIP time and increasing the uptime on Dryer 2. This feedline and pump set is clean and available to run as soon as it is needed. The new high pressure pump will ultimately be dedicated to operate with the third evaporator. This will allow an entire evaporator, buffer tank, pump and feedline system to be cleaned off line and be available to operate with either of the 2 dryers when required thus eliminating any lost dryer time associated with evaporator CIP. Drawing AIC shows the configuration of feedlines and high pressure pumps. See Plates 3 and 4 for new feedlines and pump. D.1.5 Canning/Packaging The objective of the packaging process is to ensure that the product is appropriately contained, protected and preserved so that it reaches the consumer as it left the production plant. The product is filled into a variety of can/container types and sizes depending on market requirements. A de-palletiser feeds containers to a scoop addition system. The empty containers are inverted and jet-blast cleaned on the transfer conveyor system, as they enter the scoop addition room. A scoop is dropped into each container and the containers are then transferred by conveyor to the filler for powder filling. The containers are filled with powder and are then transferred to a gas box (gas flushing system). The function of the gas boxes is to evacuate air from the containers and replace it with an inert gas mixture of Nitrogen (N 2 ) and Carbon Dioxide (CO 2 ). This ensures that the residual oxygen levels do not exceed specified levels, thus extending the shelf life of the product. Following gas flushing the container is sealed and inverted. Pre-printed labels are applied to the top of the container or to the top of the plastic over-cap. The full containers are checked, packaged into cardboard cases, palletised and stretch-wrapped. A weighing system checks and rejects cans that are outside of pre-defined weight limits. D.1 - Page 7 EPA Export :03:43:40

8 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Alternatively, at Packing Line 2 powder can be packed using an existing bulk FIBC bag off system to pack powder into bulk bag or 25 kg bags rather than cans/containers. Pallets of full containers are transferred by forklift truck, off the out-feed conveyor, for stacking in the designated aisles within the warehouse awaiting distribution. Bulk products are transported for packaging off-site. As part of Project ICE, a new additional bulk FIBC bag off system will be installed. This will be located in the Packing Area and will operate independently of either packing line. This bagging facility will allow for additional bulk bagging, such that product can be packed in bulk bags without impacting either Packing line 1 or Packing Line 2 i.e. simultaneous bulk bagging along with running two packing lines. Packing Line 1 will also be upgraded such that it can deliver product to bulk bags rather than to cans/containers i.e. to have the same packing capability as current Packing Line 2. A third packing line will be installed in the future. Details regarding finished powder blending and canning lines can be seen in associated process flow diagrams AIC , AIC , AIC Plate 5 also shows a graphical representation of the proposed bagging system. D.1.6 Ancillary Operations Laboratory Operations The laboratory is made up of two key areas: (1) Microbiology - microbiological testing of raw materials, intermediates and products is carried out in accordance to standard procedures. (2) Analytical - physical and chemical analysis is carried out on raw materials, intermediates, products and water. A supply of argon gas is piped to this laboratory from a 200L bulk container in the utilities area. In addition, there is a separate wastewater laboratory for the testing of wastewater samples. Refrigeration Plant/Chilled Water System Chilled water circulation pumps circulate chilled water to the necessary processes, including product cooling, temperature maintenance of liquid milk and liquid product silos and air conditioning. Chilled water is circulated by centrifugal pumps with variable frequency drives (VFD) to ensure efficiency. The refrigeration plant is chlorofluorocarbon (CFC) free; the primary refrigerant is ammonia. The refrigeration plant is fully automated. D.1 - Page 8 EPA Export :03:43:40

9 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited An upgrade to the refrigeration plant was completed in July 2010 as part of Project ICE resulting in an increase in thermal capacity of the water chilling plant from 2300 kw to 3500 kw. The key components of the upgraded system are as follows: Removal of an Ice Bank, which was configured as an inefficient chiller and excessively large buffer tank; Replacement of Ice Bank with an additional plate to plate heat exchanger (evaporator) and a smaller hot/cold well buffer tank; Use of primary and secondary chilled water circuit circulation pumps via small hot/cold well buffer tank rather than a single chilled water circuit via large Ice Bank buffer tank. The new primary pump skid contains two VFD driven pumps in a duty standby arrangement. An additional new VFD driven secondary pump has been installed in parallel with the existing two VFD driven circulation pumps in a duty/duty/standby arrangement; Replacement of 796 kw (cooling capacity) refrigerant compressor with new 1700 kw screw compressor complete with VFD; New additional evaporative condenser; and New smaller ammonia receiver and chilled water buffer tank, allowing volume of ammonia to be significantly reduced (reduction of 1.72 tonnes of ammonia). The upgraded plant offers greater redundancy so that the key processing activities are not interrupted in the event of any one chilling plant component failure. The process flow diagram for the system can be on seen AIC Plate 6 shows the completed upgraded refrigeration plant. Water Treatment Existing System The water treatment process currently has a treatment capacity of 1800 m 3 /day. River water enters the system and is dosed with polyaluminiumchloride to form initial floc particles. Water is then dosed with polymer (coagulant) to build on the floc particles and then moves forward to a plastic media clarifier and then on to a sand filtration step containing manganese oxide media. Water is then disinfected with ozone and further filtered through a granulated activated carbon (GAC) filter. Following this step water is forwarded to a 150 m 3 storage tank and on to a secondary ultra filtration system (UF) and is finally disinfected with ultraviolet light and chlorine gas. Water ph can be adjusted as appropriate. The water then moves forward to two 150 m 3 storage tanks and onwards to the factory on demand. The filter/clarifier, GAC filter and UF plant are regularly backwashed with treated un-chlorinated water and this backwash water/waste sludge is then routed to the effluent treatment plant. The UF plant is occasionally washed with a chemically enhanced backwash (CEB) consisting of sodium hypochlorite (NaOCl) and hydrochloric acid (HCl). This CEB stream is sent to the effluent treatment plant. D.1 - Page 9 EPA Export :03:43:40

10 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited The process flow diagram for the existing water treatment plant is as shown on AIC New System As part of Project ICE, the water treatment plant is currently being upgraded to allow generation of an additional 900 m 3 /day (45 m 3 /hr), which will provide a total capacity of 2700 m 3 /day. The new plant is stand alone and can operate independently of the existing water treatment plant and as such enhances redundancy in that the water supply to the factory will not be interrupted in the event of any one water system failure. The new water treatment plant will generate an additional backwash volume of 140 m 3 /day (current back wash volume is 366 m 3 /day). The new plant differs from the old plant in that it uses UF for primary rather than for secondary treatment. Sodium hypochlorite (NaOCl) rather than chlorine gas is used for disinfection/chorination. As part of the upgrade, there will be an additional 150 m 3 potable water storage silo. The river water is pumped through an automatic back-washable micro-strainer with 30 μm screen to remove particulate matter and to remove algae. This strainer is regularly backwashed with river water (12m 3 per day) and it is intended to return this river water to storm drain. This water can also be routed to the effluent treatment plant if necessary. Before the water enters the UF plant, it is dosed with coagulant. The water is then forwarded to the UF plant. The UF permeate is then injected with ozone and forwarded to GAC filters. The water is then disinfected with UV and chlorinated using sodium hypochlorite NaOCl and pumped to the new 150 m 3 storage tank. Periodically backwashes (with potable water) and chemically enhanced backwashes are conducted on the system. The backwash (140m 3 /day) is discharged to the waste water treatment plant. Back wash chemical cleaning is conducted with Hydrochloric acid HCl, sodium hypochlorite NAOCl and sodium hydroxide NaOH. ph adjustment is achieved using NaOH and HCl. Process flow diagram AIC shows the upgraded plant. Process flow diagram AIC also shows how the existing and new plants are connected. Process flow diagram AIC shows the ingredient water distribution system. Wastewater Treatment The process flow diagram for the effluent plant can be seen on AIC Raw Influent Inlet Works All the waste produced in the manufacturing facilities on site, both production and domestic wastes, combine in an existing collection manhole located beside the D.1 - Page 10 EPA Export :03:43:40

11 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited raw influent pumping station. The existing inlet works consists of a fat trap followed by a macerator prior to discharging into the raw influent pump sump. Also included in the inlet works is an overflow facility to a production dump tank. The new works includes the provision of an automatic fine screen to remove any screenings greater than 6 mm from the incoming flow. The new screen will be a channel mounted screen and will be installed in the existing inlet channel upstream of the fat trap. An auto bagging unit and collection bin will also be provided that will collect and contain any screenings produced in an enclosed area thus eliminating any risk of foul odours. The existing channel from the fat trap to the raw influent sump currently represents a hydraulic restriction to the incoming flows, therefore to cater for the increased hydraulic requirements a new channel will be constructed downstream of the new screen to the influent sump. The existing macerator and fat trap will be removed from the system as it will be redundant due to the new screening facility. For any flow in excess of the expected 210 m 3 /hr arriving at the inlet works, the excess flows will overflow to the existing production dump tank as currently happens. Any overflows will be kept aerated using the existing air blowers and returned to the influent sump via the existing pumps when peak flows have moderated. Raw Influent Pumping Facility All flows from the inlet works gravitate to the influent pump sump from where all flows are pumped to the wastewater treatment facility. The existing pumping facility consists of two no. self priming end suction pumps capable of pumping a maximum flow of 160 m 3 /hr when operated in a duty/standby configuration. To cater for the increased hydraulic requirements the existing self priming end suction pumps will be replaced and an additional pump added to provide a combined duty assist capacity of 210 m 3 /hr. The pumps will operate on a duty / assist / standby basis and will provide 50% standby capacity at peak flow conditions. The additional pump will be provided with a variable speed drive in order to control the flow to 210m 3 /hr thereby, minimising the energy required to pump to the wastewater treatment plant and thus reducing operating costs. Production Dump Facility Currently there is an existing COD (Chemical Oxygen Demand) monitor in the existing influent pump sump. When the COD reading for the incoming influent reaches a preset value a control valve diverts the pumped raw influent to an existing production dump tank. The existing production dump tank currently has aeration facilities to prevent the contents going septic. Duty/Standby progressive cavity pumps return the production dump to the influent sump at a low rate when the COD of the incoming influent has receded. This production dump facility will continue to be operated under the current control philosophy as part of the upgraded works. Raw Influent Balancing Facility D.1 - Page 11 EPA Export :03:43:40

12 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Currently there are two raw influent buffer tanks on site. Buffer tank no. 1 has a capacity of 800m 3 and buffer tank no. 2 has a capacity of 1000 m 3 giving a total combined capacity of 1800 m 3. As part of the upgrade an additional balance tank (buffer tank 3) with a capacity of 1400 m 3 will be provided. This combined with the volumes of the existing balance tanks equates to a total volume of one days production at the new design flow rate. There is an additional existing 700 m 3 oxidation ditch and it is planned to use this as an emergency storage and processing area for influent. This oxidation ditch has aeration facilities to prevent the contents going septic. Buffer tank No. 1 will overflow to this oxidation ditch during emergencies. Buffer tank 3 consists of a glass lined steel tank with a GRP cover. The tank will be provided with two submersible mixers installed in a duty/standby configuration each with the capacity to keep the contents of the tank mixed. The tank will be connected to the existing odour control system with the air flow from each balance tank balanced via dampers in the ductwork from each tank. The tank will be provided with an aeration facility to ensure that the contents of the tank are maintained fresh and do not go septic. The air supply for this aeration system will be taken from existing air blowers dedicated to the existing outlet buffer tank. Raw influent will be pumped into buffer tank no. 1, from where it will be pumped to the new buffer tank (tank no. 3), the flow will then gravitate to the existing buffer tank no.2, from where it will be pumped to the biological reactors. The new buffer tank no. 3 will be maintained full at all times and will act as a dedicated biological load balancing facility. Hydraulic buffering capacity will be provided in buffer tank no. 1 and buffer tank no. 2. These tanks will be operated at reduced levels to allow the required hydraulic buffering. All process returns and domestic waste will be pumped to a combination of both buffer tank no.1 and buffer tank no.2 thereby providing the best opportunity to blend all the returns with the incoming flows and allowing the best possible consistency of load be pumped forward to the biological reactors. ph Correction The incoming influent will be mixed and blended in both influent buffer tanks no. 1 and no. 3, and as a result any large peak variations in the influent ph will be balanced out. Continuous ph measurement will be provided in influent buffer tank no. 2, and ph correction chemicals will be administered as necessary to maintain the contents of this buffer tank at a ph suitable for biological treatment. Providing the ph correction at this final stage of influent buffering will minimise any wastage of chemicals that would otherwise occur due to spikes in ph. Two chemicals are provide for ph correction, Sodium Hydroxide will be dosed in the event that the ph in the buffer tank is too low and needs to be increased and Sulphuric Acid will be dosed in the event that the ph in the buffer tank is too high and needs to be reduced. Biological Treatment Feed Pumps The existing SBR feed pumps will be reused to transfer the influent from influent buffer tank no. 2 to the biological reactor. The forward flow rate to the biological D.1 - Page 12 EPA Export :03:43:40

13 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited reactors will be circa 145 m 3 /hr consisting of the design plant flow and return supernatant from the sludge process. D.1 - Page 13 EPA Export :03:43:40

14 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Process Treatment Train: The Process train is as follows: Biological Treatment Secondary Clarification Actiflo Hydrotech Biological Treatment One of the existing SBR tanks will be converted into an anoxic biological reactor (reactor 1) and the other SBR tank will be converted into an aerobic reactor (reactor 2). The reactors will operate at an MLSS of approximately 3,500 mg/l, providing a sludge age of 5 days in each reactor. Reactor 1 will operate in simultaneous denitrification mode with the anoxic duration in the reactor being controlled using the existing Nitrate monitor in the reactor. Reactor 2 will operate as an aerobic reactor however the existing Nitrate monitor in this reactor will be used to monitor the nitrate level in the reactor. If the Nitrate level goes above a preset value then the reactor will change to simultaneous de-nitrification mode until the Nitrate level reduces and the reactor reverts to aerobic mode. From the existing WWTP, the aeration system, the 2 no. aeration diffusers and the air blowers, will be reused. Even under peak conditions the existing air blowers will provide 50% standby capacity. The operation of the air blowers will be controlled using the existing DO and Nitrate instruments in the aeration tank with the existing submersible mixers keeping the tank contents in suspension. The contents of the anoxic tank will be kept in suspension using the existing submersible mixers. The design includes for the facility to operate either biological reactor in anoxic or aerobic configuration. This provides exceptional flexibility in the operation of the system, if additional nitrates are present in the influent, additional anoxic volume can be provided by small modifications to the aeration control in the aerobic reactor. If additional biological load is present in the influent, then additional aerobic volume can be provided by enabling the existing aeration system in the anoxic tank. In the event that there is a catastrophic failure of the diffused aeration system in the aeration tank, then the configuration of the biological reactor is simply reversed by altering the position of manual valves and changing the duty aeration tank on the control system. The equipment necessary for the operation of the biological reactors in their current form as SBR reactors will be maintained as this will allow the biological reactors to be converted back to SBR reactors during periods of low flow or to allow maintenance to be completed on the secondary clarifier. When the biological reactors are converted back to SBR reactors the decant effluent will gravitate to the existing final effluent sump and will be pumped through the existing tertiary sand filters as is currently the modus operandi. In this SBR mode sludge will be wasted from the biological reactors to the existing Picket Fence Thickener, with the sludge being pumped to the Thickened Sludge Storage Tank, from where it will be pumped onto the Decanter Centrifuge for dewatering. This interchanging ability and flexibility gives the greatest security and confidence that the plant will operate under all foreseeable conditions. In addition the new plant can be commissioned off-line and can be operated after D.1 - Page 14 EPA Export :03:43:40

15 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited commissioning in SBR mode until such time as it is appropriate to convert SBR s to dedicated anoxic and aerobic reactors. As the incoming influent may be deficient in ammonia an external source of ammonia is required and urea dosing will be provided on the inlet feed line to the anoxic tank. To control the ammonia dose an ammonia monitor will be installed in the anoxic tank, this instrument will be used to ensure that the ammonia in the final effluent is within the specification required. Controlling the urea dose on this basis is the most efficient and economical method as it minimizes the chemical consumption and any aeration requirements associated with nitrification of excess ammonia. In the event that phosphorous is deficient in the influent a Phosphoric Acid dosing system is provided for that will dose into the inlet feed line to the anoxic tank. It may be necessary to dose a source of carbon i.e. Molasses and other nutrients i.e. Ammonia (Urea) and Phosphorus (Phosphoric Acid). During shut down periods Waste Milk Powder Tailings may also be added to each of the Biological Reactors through an eductor system as an external carbon source for the biomass. Secondary Clarification Following the biological treatment of the influent, secondary clarification is necessary to separate the sludge produced in the biological treatment process from the continuation flow. A new secondary clarifier will be provided which is rated at 0.85 m 3 /hr, with a side wall liquid depth of 3.5 meters to allow efficient separation of the biomass from the continuation flow. The clarifier will be provided with all the necessary accessories such as the scraper bridge, outlet launder and scum board. In the event that the settleability of the sludge produced is poor, provision has been included for the addition of polymer prior to the clarifier inlet. However, it is expected to be necessary only in very exceptional circumstances. The new clarifier will be provided with 2 no. centrifugal pumps controlled via variable speed drives to return activated biomass (RAS) to the process and to waste excess biomass (WAS) from the process. The pumps will be installed in a duty / duty configuration but will have an automatic hydraulic link to provide standby capacity in the event that one pump fails. The RAS pump will have the facility to pump to either biological reactor with the pumped flow controlled via a dedicated flowmeter. The WAS pump will have the facility to pump to the gravity belt thickener with the pumped flow controlled via a dedicated flowmeter. To maximise the reduction in the level of MRP in the final effluent, the soluble phosphorus in the wastewater must be precipitated into a solid form. It is not sufficient to coagulate the soluble phosphorus in one location of the process only and several locations have been included for coagulant dosing. Coagulant dosing is applied at the inlet to the aeration tank and also at the inlet to the secondary clarifier. Actiflo The Actiflo process is used to further reduce MRP and to precipitate the soluble phosphorous out of solution. The Actiflo has an excellent track record worldwide D.1 - Page 15 EPA Export :03:43:40

16 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited and is a fit for purpose technology with several references available where Actiflo Technology has been specifically and successfully used as tertiary treatment to reduce the levels of phosphorous in final effluent. The Actiflo comprises a Coagulation Tank, Flocculation Tank fitted with a Turbomix unit, a Clarification zone fitted with a Sludge hopper, Inclined Plates, a Hydrocyclone Feed Pump, a Static Hydrocyclone, Polymer dosing and a Sludge Recirculation / Thickening System. The unit contains Microsand which is kept in suspension by the Turbomix unit prior to entering the Clarification zone. The Actiflo process operates as follows: Coagulant is injected into the coagulation tank where there is sufficient time for the influent to coagulate and flocculate. Polymer which is injected into both the Hydrocyclone and Turbomix chamber coating the Microsand which in turn causes the floc generated during the Coagulation/Flocculation stage to adhere to it. On entering the Clarification zone, the Microsand settles (referred to as Ballasted Clarification) and is withdrawn by means of a Recirculation Pump and is pumped to a Static Hydrocyclone where a separation of Sludge and Microsand takes place. The design of the Hydrocyclone is such, that what is known as the cut, is selected as being 80:20 i.e. 80% of the feed is sludge (overflow) and the 20% is returned back to the system. The latter contains Microsand. With the Sludge Recirculation / Thickening System, a percentage of the overflow is recirculated to the recirculation pump which allows concentration of the waste sludge. The percentage of the overflow re-circulated is controlled by monitoring the suspended solids of the clarified effluent. The fluid mass in the Clarifier rises through inclined plates and clarified water emerges. Online phosphorous monitoring will be provided on the influent to the secondary Clarifier which will allow the calculation of the required coagulant dose for phosphorous precipitation. Hydrotech A Hydrotech tertiary filter is used to further remove the MRP and soluble phosphorous from solution. The clarified water from the Actiflo process is coagulated and flocculated prior to the Hydrotech tertiary filter. The Hydrotech Tertiary Filter operates as follows; The water flows by gravity into the centre of the drum and into the filter segments. Solids are separated from the water by the microscreen cloth mounted on two sides of the disc segments. The build up of captured solids increases the head loss across the Discfilter and as a result the inlet water level rises. At a predetermined level a backwash cycle is initiated which results in Discfilter rotation presenting clean filter elements in to the flow path and at the same time cleaning the filter elements with high-pressure water jets. The backwash water is collected in a trough within the centre of the Discfilter and flows away by gravity. After backwash cycle, the rotation of the drum and the backwash pump is stopped. Filtration is, of course, continuous even during the backwash cycle and the effluent water quality is also the same throughout the backwash cycle. Backwash water is transferred back to the influent balancing tank no. 1. D.1 - Page 16 EPA Export :03:43:40

17 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited The existing online Phosphorous monitor will be reused to monitor the phosphorous on the Hydrotech filtered water. Existing Sand Filters: The existing sand filters will be kept in their current configuration and will be available for use at their current capacity as an emergency back up with the activated sludge process in conventional mode or in SBR mode. Sludge Thickening & Dewatering: Sludge generated by the Actiflo process will be continuously pumped to the existing Picket Fence Thickening Tank, where it will be thickened and discharged to the existing Thickened Sludge Storage Tank (TSST). Supernatant from this thickening process will gravitate to the existing supernatant sump, from where it will be pumped back to buffer tank 1. Waste Activated Sludge is pumped directly from the secondary clarifier to a new Gravity Belt Thickener (GBT) unit, located on the first floor of the existing Sludge Dewatering building. Thickened sludge from the GBT is pumped to the existing TSST, where it is blended with thickened sludge from the Actiflo process. Polymer solution is prepared in a new polymer preparation unit and dosed to the feed sludge upstream of the GBT flocculation tank. Filtrate from the GBT gravitates to the existing filtrate sump, from where it is pumped back to balancing tank 1. The new polymer preparation unit will supply polymer to the Actiflo process, hydrotech tertiary filter (and secondary clarifier if necessary). The polymer will be a low to medium molecular weight cationic polymer; actual polymer type will be confirmed during site trials and commissioning. A new high-efficiency Decanter Centrifuge will be installed within the existing Sludge Dewatering building. Sludge is pumped to the Centrifuge from the TSST via new duty / standby progressive cavity pumps. Dewatered sludge cake will be transferred to a sealed sludge skip located on the ground floor of the existing Sludge Dewatering building by means of a progressive cavity sludge cake pump. Polymer solution will be supplied by the existing Filter Press automatic polymer preparation unit, with new progressive cavity polymer dosing pumps. Filtrate from the dewatering process will gravitate to the existing filtrate sump, from where it is pumped back to the balancing tank. In order to provide the necessary building space for the new thickening polymer preparation system and Dewatering equipment, the existing sludge dryer unit will be decommissioned & removed. Final Effluent Buffering & Sampling The final effluent from the Hydrotech Tertiary Filter will gravitate to the existing final effluent outlet manhole from where it will gravitate to the existing outfall. The existing final effluent monitoring and sampling equipment will be reused. Power & Energy Supply Boilers D.1 - Page 17 EPA Export :03:43:40

18 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Steam is produced on site using gas oil burning boilers for the following processes: - indirect heating of the dryers - pasteurisers - heating the evaporators - calorifier (ingredient water heating) - clean-in-place (CIP) systems - process plate heat exchangers There are three gas oil boilers each with a capacity of 27 tonnes of steam per hour and a maximum output of 17 MW. The boilers are also configured to operate on pressurised natural gas as an alternative to gas oil. The boiler plant, which is semi-automated, includes a dedicated de-aerator, a soft-water treatment plant and fuel oil feed system. Propane gas, from a bulk cylinder in the utilities area, is used to ignite the boilers. The steam distribution for the facility is shown on process flow diagram AIC No additional boilers will be required as part of Project ICE. However, as part of the increased capacity of the facility, the fuel consumption will increase by ca. 25% overall. The boilers have heat recovery economisers fitted to their exhausts in the interests of conserving energy. More detail on the fuel use and energy consumption is provided as part of Section G of this application Energy Efficiency. Electricity Electrical power is supplied to the site by the Electricity Supply Board (ESB). There are two parallel 20 kv supplies connected to the site. The 20 kv is distributed to 5 transformers which in turn feeds the 380 V power distribution to the site. Typical site load is approximately 4 MW. Two emergency 2,000 kva diesel generators provide back-up power to the site. The generators start automatically on mains supply failure and are capable of maintaining the site in normal production. Compressed Air There are four main oil free air compressors at the site.all compressors use the oil free rotary compression technique. Compressed air is filtered, dried in refrigerant and dessicant dryers and filtered again before discharge to the compressed air system. The compressed air distribution system for the facility is shown on process flow diagram AIC D.1 - Page 18 EPA Export :03:43:40

19 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited In addition there are local air compressors as follows: 3 compressors for sand filters, 1 compressor at inlet works, 1 compressor for sprinkler system, 3 compressors on standby for smoke vent system and 1 compressor for inflation finished product bag stablisers in trailers. Bulk Nitrogen and Carbon Dioxide Bulk nitrogen (N 2 ) and carbon dioxide (CO 2 ) are stored in two storage tanks at the site. Each has dedicated vapourisers and piping systems. A mixture of N 2 /CO 2 is used in the packing operation of the product. N 2 is also used in the vegetable oil system, syrup storage system and finished powder silos for blanketing and pipe purging/flushing. Both gases are to food grade specifications and purity. The gas storage and distribution system is as shown on process flow diagram AIC CIP Clean in Place CIP of road tankers, skim milk silos, product lines etc., is carried out from a centralised CIP station located in a dedicated contained area where any spills are diverted to drains leading to the waste water treatment plant. The CIP sequence is the same regardless of the type of plant or equipment being cleaned. However, the duration of the CIP process varies. The sequence starts with an initial water rinse (using recovered water from previous rinses), followed by caustic (recirculated), middle water rinse, dilute nitric acid (re-circulated) and final water rinse (recovered to use as initial water rinse for later cleans). The CIP station is located in a dedicated contained area at the back of the dryer towers. Solutions are made up to the required strength from the bunded bulk caustic and acid storage station located close to the CIP station. Process flow diagram AIC and AIC show the Wet Process and Dryer CIP systems respectively. Process flow diagram AIC shows the bulk caustic and acid system. Fire Protection Firewater is supplied to the site from the Dromore River and distributed over the site to hydrants via a ring main. Sprinklers are installed in the main warehouse. A deluge system is also located within the dryers. During induction, staff will be trained on evacuation procedures. Emergency response teams will be identified and trained appropriately. Offices The office areas on site are: Administration/Finance Human Resources D.1 - Page 19

20 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Manufacturing Quality Assurance Development Engineering Materials Support Facilities The main support facilities on site are: Cafeteria Medical centre Security Warehousing & Bulk Storage Packaging, Minor Ingredients and Materials All incoming packaging materials (cans, containers, cases, scoops, lids, etc.) and dry ingredients and other minor ingredients are stored in the warehouse. This department has responsibility for the receipt of all materials from suppliers, together with the storage, recording and issuing of these materials to the appropriate production department. All materials are logged into a computerised system for inventory control purposes. Storage of Hazardous Liquids and Gases The utilities bund contains the following: 2 x gas oil tanks (150 m 3 each) 1 x separately bunded 10.6 m 3 polyaluminiumchloride tank. 1 x separately bunded 30 tonne bulk caustic tank 1 x separately bunded 27 tonne m 3 bulk nitric acid tank Process flow diagram AIC shows caustic and acid storage on site. The utilities area contains the following: 1 x m 3 bulk nitrogen storage vessel 1 x m 3 CO 2 bulk storage vessel 1 x 2.27m 3 propane gas vessel (for starting boilers) 1 x 200 litre argon vessel (for laboratory use) Within the Utilities area, there are also the following storage areas: D.1 - Page 20

21 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited - Storage area for various gas bottles containing argon, acetylene, helium, hydrogen, Carbon dioxide, nitrogen and oxygen - A housed bunded area for a poly make up unit - 2 no. housed areas for generation of oxygen/ozone - A chlorine room containing gas bottles of chlorine - 2 no. bunded cabinets containing NaOH, NaOCl and HCl - 2 no. housed areas containing bunds for NaOH, NaOCl and HCL. Ammonia is the main refrigerant used on site and is stored in the refrigeration area. No storage of ammonia occurs on site; all ammonia used is contained within the refrigeration system. The external CIP Area has a dedicated contained area (with drain to effluent treatment plant) contains the following: 1 x 30,000 litre Dilute Nitric acid tank 1 x 18,000 litre Dilute Nitric acid tank 1 x 30,000 litre Dilute Caustic tank 1 x 18,000 litre Dilute Caustic tank These tanks are fed from bulk caustic and nitric tanks and made up to the required strength as required. The waste water treatment area contains the following: 1 x Bulk Ferric-sulphate tank (11.9m 3 ) in dedicated bund 1 x Bulk caustic tank (11.9m 3 ) in dedicated bund 1 x Bulk Sulphuric acid tank (16.8 m 3 ) in dedicated bund 1 x Bunded IBC containing 1 m 3 molasses 1 x Bunded IBC containing 1 m 3 urea 2 x Bunded IBCs each containing 1 m 3 phosphoric acid Waste oil containers in bunded section of SBR blower room Powdered poly stored in racking in waste water treatment stores A housed bunded area for poly make up unit A 98 m 3 diesel tank is located in the emergency diesel generators area in the waste water treatment area. Other: D.1 - Page 21

22 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited There are two m 3 diesel tanks located in a bund alongside the diesel pumps in the raw water intake building at the factory entrance to supply diesel to the emergency sprinkler pumps. Containers of waste oil are held in a dedicated bunded area adjacent to the CIP area. Various different lubricating oils are used on site in drummed quantities. Liquid flavouring is stored in IBC s in a dedicated store. This store has a drainage system that drains to an underground sump with a high level alarm. Any leaks or spills are diverted to the waste water treatment plant under controlled conditions. The site also contains local split HVAC units, refrigerators and a freezer for storage of temperature sensitive food oils. Small containers of chemicals are stored in a separate room dedicated to laboratory chemicals. Accidental releases will be minimised on site through procedural control and personnel training. A spill prevention and control procedure has been developed for accidental spills on site. See Section F Control and Monitoring for more detail. The storage areas on site are shown on Drawing No. 009 Ref: 21029/CD009. Storage of Raw Ingredients Vegetable oil, syrup and skim milk is supplied to the site in bulk tankers and stored in bulk storage silos. The storage provisions are as follows: Vegetable oil is 10 x 36.5m 3 stainless steel bulk silos Syrup - 2 no. 137 m 3 stainless steel bulk silos Skim milk/processed milk - 14 no. 136 m 3 stainless steel bulk silos Dry ingredients - 9 no. silos (as well as on dedicated warehouse racking in various bag sizes) The vegetable oil, syrup and milk silos have high-level alarms. In the event of a spill/leak vegetable oil, syrup or milk drains to foul drains which divert to the onsite wastewater treatment plant. Process Flow Diagrams AIC , AIC , AIC and AIC show storage of milk, syrup and vegetable oil. Process Flow Diagram AIC shows dry ingredient storage. The following table details the volumes and numbers of bulk storage silos for ingredients and products at the site: D.1 - Page 22

23 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Material Total Capacity (litres) (Total No. of Silos) Skim milk 816,000 (6) Dual (skim milk or process) 136,000 (1) Process 952,000 (7) Syrup 274,000 (2) Vegetable oil 365,000 (10) Powder ingredient Type 1 150,000 (3) Powder Ingredient Type 2 100,000 (2) Powder Ingredient Type 3 50,000 (1) Powder Ingredient Type 4 50,000 (1) Powder Ingredient Type 5 9,400 (2) Powder Ingredient Type 6 6,000 (1) Finished Powder Type 1 560,000 (7) Finished Powder Type 2 150,000 (3) Finished Powder Type 2 720,000 (9) Blender Vacuum Pot Finished Powder Type 1 & 12,000 (2) 2 Blend Vessel Finished Powder Type 1 & 2 12,000 (2) Blender Surge Hopper Finished Powder Type 1 & 24,000 (2) 2 Temperature sensitive ingredients are also stored locally in local refrigerators and a freezer. The warehousing department is responsible for the shipment of product to customers and the disposal and recycling of packaging wastes. Waste Management Non Hazardous Waste Management All recyclable wastes are segregated on site and collected for recycling by permitted waste contractors. General non-hazardous waste are compacted on site and collected for disposal by a licensed waste disposal contractor. All documentation is retained on site in accordance with legislative requirements and the ISO certified Environmental Management System accredited to the site. Hazardous Waste Management All hazardous waste is labelled appropriately, covered where necessary and stored in contained areas on site before being collected by a permitted hazardous waste contractor and brought to a licensed facility for disposal, recovery or recycling. This includes laboratory wastes, empty hazardous containers and waste oils. All documentation is retained on site in accordance with legislative requirements and the ISO certified Environmental Management System accredited to the site. D.1.7 Process Control D.1 - Page 23

24 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited The plant is controlled by a network of programmable logic controllers (PLCs - generally of Siemens manufacture). Most of this PLC network is in turn linked and controlled by a network of PCs running supervisory control and data acquisition software (systems such as InBatch, InSQL, InTouch and ifix). Operator interface and maintenance troubleshooting is generally via these PCs or via dedicated operator interface panels at key control points. The system has various levels of password protection to prevent unauthorised access. D.1 - Page 24

25 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited The plates and flow diagrams included with this attachment are as follows: Plates Plate 1 3 rd Oil Blend Plate 2 3 rd Evaporator Plate 3 High Pressure Pumps Plate 4 High Pressure Pumps Plate 5 Bag Off System Plate 6 Refrigeration Plant Plate 7 Water Treatment Plant Drawings Drawing No. AIC Overall Plant Process Flow Diagram Drawing No. AIC Milk Intake Bay Process Flow Diagram Drawing No. AIC Milk & Product Storage Silos Process Flow Diagram Drawing No. AIC Oil Intake, storage & Blending Process Flow Diagram Drawing No. AIC Bulk Powder Ingredients Process Flow Diagram Drawing No. AIC Syrup Intake and Storage Process Flow Diagram Drawing No. AIC Wet Process 1 & 2 Process Flow Diagram Drawing No. AIC Evaporators 1, 2 & 3 Process Flow Diagram Drawing No. AIC Dryer 1 Process Flow Diagram Drawing No. AIC Dryer 2 Process Flow Diagram Drawing No. AIC Finished Powder Storage & Conveying to Canning Process Flow Diagram Drawing No. AIC Powder Blending Process Flow Diagram Drawing No. AIC Canning Line P1 Process Flow Diagram Drawing No. AIC Canning Line P2 Process Flow Diagram Drawing No. AIC Bulk Caustic & Acid Process Flow Diagram Drawing No. AIC Wet Process CIP Station Process Flow Diagram Drawing No. AIC Dryer CIP Station Process Flow Diagram Drawing No. AIC Compressed Air System Process Flow Diagram Drawing No. AIC Chilled Water System Process Flow Diagram Drawing No. AIC Steam & Condensate Distribution Process Flow Diagram Drawing No. AIC Carbon Dioxide & Nitrogen Distribution Process Flow Diagram Drawing No. AIC Water Treatment Plant Process Flow Diagram Drawing No. AIC Ingredient Water Distribution Process Flow Diagram Drawing No. AIC Effluent Plant Process Flow Diagram D.1 - Page 25

26 Abbott Cootehill - EPA IPPC Licence Review Application Attachment D.1 Unit Operations & Processes Plates D.1

27 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Plate 1-3 rd Oil Blend System Installed D.1

28 Abbott Cootehill - EPA Waste Licence Review Application AWN Consulting Limited Plate 2 Location of 3 rd Evaporator D.1

29 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Plate 3 2 nd Feedline on Dryer 2 D.1

30 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Plate 4 New Pump Installed for 2 nd Feedline on Dryer 2 D.1

31 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Plate 5 Proposed Bag Off Bulk Bagging System D.1

32 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Plate 6 Refrigeration Upgrade Complete D.1

33 Abbott Cootehill - EPA IPPC Licence Review Application AWN Consulting Limited Plate 7 Water Treatment Plant (Upgrade) D.1