Unsolicited Additional Information - Re Planning - Part 2 - EPA

monitoringIRELANDODOUR & ENVIRONMENTAL ENGINEERING CONSULTANTSUnit 32 De Granville Court, Dublin Rd, Trim, Co. MeathTel: +353 46 9437922Mobile: +353 86 8550401E-mail: info@odourireland.comwww.odourireland.comSCREEN 3 MODELLING OF EMISSIONS FROM BOILER EXHAUST POINT LOCATED INEUROFARM FOODS, DULEEK, CO. MEATH.PERFORMED BY ODOUR MONITORING IRELAND ON THE BEHALF OF RME ENVIRONMENTAL LTD.For inspection purposes only.Consent of copyright owner required for any other use.REPORT PREPARED BY:REPORT VERSION:Dr. Brian SheridanDocument Ver. 1ATTENTION:Mr. Raphael McEvoyDATE: Ogth Mar 2008REPORT NUMBER: 2008A72( 1 )REVIEWERS:EPA Export 26-07-2013:17:03:31

Report Number 2008A72(1)RME Environmental LtdTABLE OF CONTENTSSectionTABLE OF CONTENTSDOCUMENT AMMENDMENT RECORD1. IntroductionPaqe numberiii12. Materials and methods 22.1 Screen 3 Dispersion model 22.2 Conversion factors from I-hour ground level concentrations to 8 and 24hour and Annual average ground level concentration 32.3 Input data 32.4Air Quality Guidelines for classical pollutants in Ireland and Europe 42.5 Existing Baseline Air Quality 53. Results 73.1 Screen 3 dispersion-modelling outputs 73.2 Conversion from I-hour maximum ground level concentrations toaveraging periods 114. ConclusionsFor inspection purposes only.Consent of copyright owner required for any other use.12info@odourireland .corniEPA Export 26-07-2013:17:03:31

Report Number 2008A72(1)RME Environmental LtdDocument Amendment RecordClient: RME Environmental LtdPROJECT: Screen 3 modelling of emissions from boiler exhaust point located in Eurofarmfoods Ltd, Duleek, Co. Meath.'IFor inspection purposes only.Consent of copyright owner required for any other use.Project Number: 2008.A72(1)2008A72(1) I Document for review I B.A.S.IIDocument Reference: Screen 3modelling of emissions from boilerexhaust point located in Eurofarmfoods Ltd,.Duleek, Co. Meath.JMC I 0.A.S [ 09/03/2008III I I , IRevision 1 Purpose/Description I Originated 1 Checked I Authorised 1 DateinfoC0odourireland .corniiEPA Export 26-07-2013:17:03:31

Report Number 2008A72(1)RME Environmental Ltd2. Materials and methodsThis section describes the materials and methods used throughout the survey.2.1 Screen 3 Dispersion modelThe SCREEN model was developed to provide an easy-to-use method of obtaining pollutantconcentration estimates based on the screening procedures document. SCREEN can performall of the single source, short-term calculations in the screening procedures document,including estimating maximum ground-level concentrations and the distance to the maximumconcentration incorporating the effects of building downwash on the maximum concentrationsfor both the near wake and far wake regions, estimating concentrations in the cavityrecirculation zone, estimating concentrations due to inversion break-up and shorelinefumigation and determining plume rise for flare releases. The model can incorporate theeffects of simple elevated terrain on maximum concentrations, and can also estimate 24-houraverage concentrations due to plume impaction in complex terrain using the VALLEY model24-hour screening procedure. Simple area sources can be modeled with SCREEN using anumerical integration approach. The SCREEN model can also be used to model the effects ofsimple volume sources using a virtual point source procedure. The area and volume sourcealgorithms are described in Volume II of the ISC model user's guide (EPA, 1995b). TheSCREEN model can also calculate the maximum concentration at any number of userspecifieddistances in flat or elevated simple terrain, including distances out to 100km forlong-range transport.SCREEN examines a full range of meteorological conditions, including all stability classesand wind speeds to find maximum impacts, whereas to keep the hand calculations tractableonly a subset of meteorological conditions (stability classes A, C, and E or F) likely tocontribute to the maximum concentration are examined. The use of a full set ofmeteorological conditions is required in SCREEN because maximum concentrations are alsogiven as a function of distance, and because A, C, and E or F stability may not be controllingfor sources with building downwash (not included in the hand calculations). SCREENexplicitly calculates the effects of multiple reflections of the plume off the elevated inversionand off the ground when calculating concentrations under limited mixing conditions. Toaccount for these reflections, the hand calculation screening procedure increases thecalculated maximum concentrations for A stability by a factor ranging from 1.0 to 2.0. Thefactor is intended to be a conservative estimate of the increase due to limited mixing, and mayFor inspection purposes only.Consent of copyright owner required for any other use.be slightly higher (about 5 to 10 percent) than the increase obtained from SCREEN using themultiple reflections, depending on the source. SCREEN handles the near neutrallhigh windspeed case by examining a range of wind speeds for stability class C and selecting themaximum. In contrast, the hand calculations are based on the maximum concentrationestimated using stability class C with a calculated critical wind speed and a 10 meter windspeed of 10 mls. This difference should result in differences in maximum concentrations ofless than about 5 percent for those sources where the near neutrallhigh wind speed case iscontrolling. The SCREEN model results also include the effects of buoyancy-induceddispersion (BID), which are not accounted for by the hand calculations (except for fumigation).The inclusion of BID in SCREEN may either increase or decrease the estimatedconcentrations, depending on the source and distance. For sources with plume heights belowthe 300 meter limit of the hand calculations, the effect of BID on estimated maximumconcentrations will usually be less than about f 10 percent. For elevated sources withrelatively large buoyancy, the inclusion of BID may be expected to decrease the estimatedmaximum concentration by as much as 25 percent.Screen 3 has traditionally been used to ascertain if a ground level concentration issue werelikely to happen. If such an issue were identified then advanced dispersion modelling wouldbe performed with the Gaussian steady and non steady state models ISC 3, AERMOD Primeand Calpuff.2EPA Export 26-07-2013:17:03:31

Report Number 2008A72(1)RME Environmental Ltd2.2 Conversion factors from I-hour ground level concentrations to 8 and 24 hourand Annual average ground level concentrationScreen 3 outputs maximum I-hour ground level concentrations utilising worst-casemeteorological dispersion estimates. In order to allow comparison with SI 271 of 2002 forCarbon monoxide, Oxides of nitrogen and Sulphur dioxide, conversion from I-hour groundlevel concentrations to 8 and 24 hour and Annual averages must occur. This is performedusing established conversion factors published by the USEPA and Environment agency, UK.The U.S. EPA recommends a maximum I-hour to maximum annual conversion factor of 0.08for both point and area sources within its procedures for assessing risks. This value issupported by recent studies, researching the dispersion from point sources that undergo initialmixing, which have reported values within the range of 0.06 - 0.20. A conversion factor of0.20 was used in this study - being on the upper end of the range of the values published, itproduces the most conservative results (Ontario Regulation 346).The Environment agency recommends a maximum I-hour to maximum 8 hour and 24 hourconversion factors of 0.70 and 0.59 for point sources (EA, 2002; Turner 1994).These conversion factors were utilised to allow for comparison of maximum I-hour groundlevel concentrations with averaging period contained in SI 271 of 2002.2.3 lnputdataTable 2.7 illustrates the input data utilised within the Screen 3 dispersion model for Scenarios1 and 2. This was utilised in conjunction with the Screen 3 dispersion model to estimate themaximum ground level concentration at down wind receptors in the vicinity of the site.Emission concentration data was provided by Eurofarm foods Ltd and used in conjunctionwith source and building characteristics. A worst case meteorological screening file containedwithin Screen 3 model was utilised to determine worst-case ground level concentration. Aworst-case detected emission concentration was utilised within the dispersion model.For inspection purposes only.Consent of copyright owner required for any other use.3EPA Export 26-07-2013:17:03:31

nl000r-nlv)Ucm27-rYa3.-2m0-m6LaC0a,>UU.-c2bF.-033Wa,5c30mrn.-c0--!2m>eE3crnUcm3W.-L-:a,m+Ij1m-m00cvUa,n;+-CmiL30c00cnCcC.-r?a,Ca,a,R-.-ce-0z8a,C0zrna,X0UCma,0n.- 3UCa,Oeai06c.-cX0L3cQ3 ._-cnLgL-eInzgFor inspection purposes only.Consent of copyright owner required for any other use.EPA Export 26-07-2013:17:03:31

Report No. 2008A72(1)RME Environmental Ltd2.5 Existing Baseline Air QualityThe EPA has been monitoring national Air quality from a number of sites around the country.This information is available from the EPAs website. The values presented for SOz, NOz, andCO give an indication of expected urban and suburban emissions of the compounds listed inTable 2.2. Table 2.3 illustrates the baseline data expected to be obtained from suburban area.Since Eurofarm foods Ltd site is located in a suburban area, it would be considered located ina Zone C area according to the EPAs classification of zones for air quality. Traffic andindustrial related emissions would be medium.For inspection purposes only.Consent of copyright owner required for any other use.info@odourireland.com 5EPA Export 26-07-2013:17:03:31

For inspection purposes only.Consent of copyright owner required for any other use.hv rNz0 N8a,c0c?v)mzeh0a,C0s5ecC30IrD0N0cd0cv: Q20).- CL..- 9CE2Wv)a,c0Ca,Ur0z j1EPA Export 26-07-2013:17:03:31

Report No. 2008A72(1)RME Environmental Ltd3. Results and discussionCarbon monoxide Oxides of nitrogenDistance to Scenario I-Existing Scenario 1 - Existingreceptor (m) emission point 8 emission point 1 hourhour GLC (pglm’) GLC (pglm’)Max predictedconc (m)Sulphur dioxideScenario 1 - Existingemission point 1 hourGLC (pg/m3)792.8 (21 m) 365.9 (21 m) 827.7 (21 m)For inspection purposes only.Consent of copyright owner required for any other use.Table 3.2. Predicted maximum I-hour maximum ground level concentrations of emissionexhaust point for Scenario 2.Distance toinfoC3odourireland corn 7EPA Export 26-07-2013:17:03:31

Report No. 2008A72(1)RME Environmental LtdExisting emission point characteristics - Carbon monoxide.For inspection purposes only.Consent of copyright owner required for any other use.-Figure 3.2. Output results from Screen 3 dispersion modelling assessment for Scenario 1 -Existing emission point characteristics - Oxides of nitrogeninfo@odourireland.comaEPA Export 26-07-2013:17:03:31

Report No. 2008A72(1)RME Environmental Ltdfa1 an (ugm3) at 12 m slack neigh1Figure 3.5. Output results from Screen 3 dispersion modelling assessment for Scenario 2 -Proposed emission point characteristics - Oxides of nitrogenFor inspection purposes only.Consent of copyright owner required for any other use.ralm (uym3) aI 12 m 61ac~ hsgn!IFigure 3.6. Output results from Screen 3 dispersion modellincr - assessment for Scenario 2 -Proposed ernision point characteristics - Sulphur dioxide.info0odourireland corn 10EPA Export 26-07-2013:17:03:31

Report No. 2008A72(1)RME Environmental Ltd3.2 Conversion from I-hour maximum ground level concentrations to averagingperiodsTable 3.3 and 3.4 illustrates 8 hour, 24 hour and Annual average ground level concentrationsfor Carbon monoxide, Oxides of nitrogen and Sulphur dioxide for Scenarios 1 and 2. Themaximum 8-hour, 24-hour and annual averages are calculated using the conversion factors0.70, 0.59 and 0.20, respectively (USEPA 1996; EA 2002).Table 3.3. Predicted maximum averaging ground level concentrations of emission exhaustpoint for Scenario 1.Distance toreceptor (m)I Carbonmonoxide I Oxides of nitroaen I SUlDhUr dioxideScenario l(pg/m3) Scenario I (pg1m3) Sceiario I (pg/m3)hour I Annual 1 hour GLC I AnnualGLC24 hour I AnnualGLC9001000Max predictedconc (21 m)17.11 4.89 I 11.28 2.26 15.05 5.1014.85 4.24 9.79 1.96 13.07 4.43554,96 158.56 365.90 73.18 488.34 165.54Table 3.4. Predicted maximum averaging ground level concentrations of emission exhaustpoint for Scenario 2.For inspection purposes only.Consent of copyright owner required for any other use.Tables 3.3 and 3.4 illustrate the maximum ground level concentrations for the 8-hour, 1 hour,24 hour and Annual averaging period for Carbon monoxide, Oxides of nitrogen and Sulphurdioxide. The results of two Scenarios are presented, Scenario 1 - Existing stack height of 7metres, Scenario 2 - Proposed stack height of 11 metres. As a result of building wake effects,the existing stack height will result in breaches of the SI 271 of 2002 impact criterions forOxides of nitrogen and Sulphur dioxide (see Table 3.3 and Table 2.2). In order to reduce theeffects of building wake effects, the existing stack height was increased to 11 metres. As canbe observed in Table 3.4, significant reductions in ground levels concentrations are achievedinfo@odourireland corn 11EPA Export 26-07-2013:17:03:31

Report No. 2008A72(1)RME Environmental Ltdas a result of this increase of stack height. When baseline values contained in Table 2.3 andpredicted maximum ground level concentrations contained in Table 3.4 are combined, theoverall impact of Carbon monoxide, Oxides of nitrogen and Sulphur dioxide for the presentedaveraging periods are within the impact criteria contained in SI 271 of 2002 (see Table 2.2).Taking into account this source characteristic optimisation (both efflux velocity and emissionpoint height), the use of worst case dispersion meteorological data (from Screen 3), use ofworst case emission rate, assumption that emission occurs 24/7/365 days per year, theoverall predicted GLC’s are significantly conservative to provide protection to the public atlarge.4. ConclusionsIt was concluded that the following mitigation strategies should be implemented in the shortterm (2 to 4 weeks). These include:1. Currently, significant building wake effects are occurring with the existing stack heightof 7 metres resulting in breach of the impact criteria contained in SI 271 of 2002 (seeScenario 1).2. Following an increase of stack height to a height of 11 metres, the overall effects ofbuilding wake effects are significantly reduced. When baseline values contained inTable 2.3 and predicted maximum ground level concentrations contained in Table 3.4are combined, the overall impact of Carbon monoxide, Oxides of nitrogen andSulphur dioxide for the presented averaging periods are within the impact criteriacontained in SI 271 of 2002 (see Table 2.2).For inspection purposes only.Consent of copyright owner required for any other use.info@odourireland.com 12EPA Export 26-07-2013:17:03:31