f I Initials: . ___ For attention of Ms. Aoife Loughnane -

Environmental Licensing Programme, Office of Climate, Licensing & Resource Use, Environmental Protection Agency, McCumiskey House, Richview, Clonskeagh Road, Dublin 14

27th June 20 12

DIAGEO GLOBAL SUPPLY

Re: Application for Technical Amendment to IPPC Licence PO301-02 for Emission Limits to Sewer

Dear Ms. Loughnane,

Further to the issue of the Final Determination for the Diageo Ireland St. James's Gate Brewery's revised IPPC licence, register number PO301 -02, and following our discussion with the Agency prior to the publication of the Proposed Determination in relation to the limits on emissions to sewer, we wish to apply to the Agency for a Technical Amendment to our licence in relation to the limits on emissions to sewer from the site.

This application for a Technical Amendment arises following a detailed review of our effluent profile in light of the water reduction initiatives implemented at the Brewery in recent years, and a review of our level of compliance with the current licence limits. As a result of a significant reduction in water consumption at the site, the profile of the effluent discharged to sewer via SE-1 has altered since the original licence was granted, with a general increase in concentration of BOD and COD, and a comparatively smaller increase in effluent load. As a result of this increase in effluent concentration, our level of compliance

our compliance with the limits on effluent load has remained high. A summary of our compliance in 201 1 is shown in Attachment A to this application.

with the conditions of our licence in relation to effluent concentration has decreased, although /

In this regard, we have engaged with the Local Authority (Dublin City Council) with a view to amending the licence limits for BOD and COD concentration. In addition, as part of our engagement with DCC, we understand that one of the key parameters affecting the operation of the municipal wastewater treatment plant is effluent load, and therefore we also request an amendment to our limit for load in order to facilitate DCC's operation of its plant.

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drinkaware.ie

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Table 1 summarises our request for amendment to our licence limits. The changes, highlighted in bold, in relation to the mean concentration of BOD and COD of our effluent arise from operational requirements at the Brewery in light of our significant water reduction initiatives to date and our pursuit of further water reduction initiatives. The changes, again highlighted in bold, in relation to the mean daily loading for BOD and COD are to facilitate DCC’s operation of its treatment plant. Table 1: Request for Amendments to Licence Limits at SE-1

Mean Concentration (mg/l)

Current Requested

Parameter Mean Loading (kg/day)

Current Requested

7,500 m3 7,500 m3 Volume to be emitted (max. in any one day)

BOD Daily

Weekly

Monthly

Annual

COD Daily

Weekly

Monthly

Annual

6,000

4,900

4,000

3,600

12,000

9,800

8,000

7,200

45,000 35,000

22,500 22,500

18,750 18,750

15,000 15,000

90,000 70,000

45,000 45,000

37,500 37,500

30,000 30,000

6,000

3,000

2,500

2,000

12,000

6,000

5,000

4,000

As can be seen from Table 1, we request an increase in the limits on BOD and COD concentration averaged on a weekly, monthly and annual basis. However, given the nature of the activity at the site and the effluent profile, this increase in concentration does not necessitate a corresponding increase in load. In relation to the licence limit for the daily mean concentration of BOD and COD, we do not request any change in these limits, but request a reduction in the limit on the daily mean load, as discussed with and indicated by DCC.

These amendments will enable Diageo St. James’s Gate Brewery to comply with the conditions of our licence while continuing to pursue the opportunities to achieve further water usage reductions across the site, consistent with Condition 7.3 of our licence (P0301- 02) which requires the identification of opportunities for a reduction in the quantity of water used at the site. As part of the implementation of our Environmental Management Programme, and in light of this condition, further water reduction initiatives have already been identified.

We are also progressing our on-site effluent management strategy in accordance with Condition 5.4.1 of our licence, with this application for a Technical Amendment and our engagement with Dublin City Council in relation to the licence limits forming part of our strategy.

Attachment A to this letter provides more detailed information in support of our application. I trust that the above summary, together with the supporting information, contains all of the information required by the Agency to consider our request for a Technical Amendment to

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our licence. If you require any clarification or further information, do not hesitate to contact the undersigned.

Yours sincerely,

Marsha Donnelly, Environmental Manager, Diageo St. James’s Gate Brewery

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Attachment A - Supporting Information

1 BACKGROUND

The Brewery’s IPPC licence (PO301-02) sets limits on the effluent discharged to sewer from the single licensed emission point to sewer for the following parameters:

Temperature

PH Flow

BOD concentration and load

COD concentration and load

Suspended solids concentration and load

Sulphates (as SO,) concentration and load

Detergents (as MBAS) concentration and load

Fats, oils and grease concentration and load

The discharge from SE-1 consists of process effluent and surface water run-off and is screened and then pH-adjusted in the on-site Effluent Neutralisation Plant before being discharged to the Dublin City Council sewer for final treatment in the Ringsend Wastewater Treatment Plant.

2 CURRENT LICENCE LIMITS

In our application for a review of our IPPC licence, we set out the rationale for amending the limits on effluent discharged from the site via SE-1, in terms of BOD and COD concentration and load, following a detailed review of our effluent profile, and discussion with Dublin City Council. However, in its consent for the review of our IPPC licence, Dublin City Council retained the limit values for SE-1 from the first issue of the IPPC licence, as summarised in Table 2.

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Table 2: Current Licence Limits for Discharges to Sewer at SE-1

Parameter Period Concentration Load

( m g 4 (Wday)

Flow (m3/day) Daily 7,500

Daily 6,000 45,000

BOD Weekly

Monthly

3,000

2,500

22,500

18,750

Annual 2,000 15,000

COD

Daily 12,000 90,000

Weekly 6,000 45,000

Monthly 5,000 37,500

Annual 4,000 30,000

Suspended Solids Daily 1,400 10,500

Sulphates (as SO4) Daily 400 3,000

Detergents (as MBAS) Daily IO0 750

Fats, oils, grease Daily 100 750

As can be seen from the table, the limits on BOD and COD concentration and load apply over four averaging periods (daily, weekly, monthly and annual), with a reducing limit value in each case. It can also be seen that the limits on BOD and COD are directly related for each of the averaging periods, with the limits for COD (concentration and load) twice those of BOD.

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3 COMPLIANCE WITH LICENCE LIMITS

The level of compliance at SE- 1 for the twelve month period 1 st January 20 1 1 to 3 1 st December 201 1 against the conditions of the licence is summarised in Table 3 for flow, BOD concentration and load, and COD concentration and load.

Table 3: Summary of Licence Compliance at SE-1 for 2011

Period

Flow (m3/day)

BOD Concentration

(mg/l)

COD Concentration

(mg4

Period

Daily

Daily

Weekly

Monthly

Annual

Daily

Weekly

Monthly

Annual

Daily

Weekly

Monthly

Annual

Daily

Weekly

Monthly

Annual

Note 1 : Assessed in accordance with 1

Licence Limit # Compliant YO Maximum Results Note Compliance

7,500 365 of 365 100% 4,397

6,000 365 of 365 100% 5,502

3,000 27 of 52 52% 4,64 1

2,500 0 of 12 0% 3,684

2,000 Oof l 0% 3,082

45,000 365 of 365 100% 15,470

22,500 52 of 52 100% 12,798

18,750 12 of 12 100% 10,308

15,000 1 o f 1 100% 8,365

12,000 365 of 365 100% 8,885

6,000 52 of 52 100% 6,546

5,000 11 of 12 92% 5,517

4,000 Oof l 0% 4,694

90,000 365 of 365 100% 20,869

45,000 52 of 52 100% 17,011

37,000 12 of 12 100% 14,970

30,000 1 of1 100% 12,809

mdition 3.3.2 of the licence.

As can be seen from Table 3 , the discharges to sewer for each of the parameters other than weekly, monthly and annual BOD concentration, and monthly and annual COD concentration (which is related to BOD concentration) were compliant with the conditions of the licence.

However, while the weekly, monthly and annual mean concentrations of BOD, and the monthly and annual mean concentrations of COD have been greater than the licence limits during the period, the total flow and the total BOD and COD loads for the respective periods have remained substantially below the licence limits, as shown in Figure 1.

For the concentration of BOD discharged via SE- 1, there have been 25 non compliances with the weekly mean limit, and 12 non compliances with the monthly mean limit, while the annual mean concentration is also greater than the licence limit. The level of compliance for weekly, monthly and annual BOD concentration at SE-1 is shown in Figure 2, Figure 3 and Figure 4, respectively. In the case of COD, the monthly concentration for October 20 1 1 was greater than the licence limit, while the annual mean concentration of COD was also greater than the licence limit.

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Flow, BOD load & COD load v. licence limit 35,000

30,000 Licence Limit

* U 3 25,000 +5

a U

a 2005 n 2 20,000 2006

gl2007 a

s Licence Limit I 2 0 0 8

8 2009 5 15,000

8 2010

2011

n

U - > U % m

t Licence Limit G I

.E 10,000

5,000

0

Figure 1: I

Flow BOD Load COD Load

istorical Flow, BOD Load and COD Load (daily data averaged on an annual basis)

Weekly Mean BOD Concentration (mg/l) at S E 1 - 0 1 Jan 2011 to 3 1 Dec 2011 8,000 8,000

7,000 7,000

5 6,000 E - c

f 5,000

4 8

c.

4,000 0 I c I

I j I

I I I ' i i ' i 3,000 E ,

6,000

5,000

4,000

t 3,000 i

I 1

1 2,000

~ 1,000

0 Jan11 F e b l l M a r l 1 A p r l l May11 Jun11 Jul l l Augl l Sepl l O c t l l N o v l l D e c l l

-BOD Concentration -Licence Limit

Figure 2: Weekly Mean BOD Concentration at SE-1 (January 2011 to December 2011)

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Monthly Mean BOD Concentration (rng/l) at SE1 - 0 1 Jan 2011 to 3 1 Dec 2011 8,000 8,000

7,000 7,000

- 5 6,000 6,000 E - .- 6

:

2

5,000 5,000

E 4,000

C

p 3,000 > - 5 g 2,000

1,000

0

4,000

0

3,000

2,000

1,000

Jan11 F e b l l M a r l 1 A p r l l May11 Jun11 l u l l 1 A u g l l S e p l l O c t l l Nov11 D e c l l

II BOD Concentration - Ltcence Limlt

Figure 3: Monthly Mean BOD Concentration at SE-1 (January 2011 to December 2011)

Annual Mean BOD Concentration (rng/l) at S E 1 - 01 Jan 2005 to 31 Dec 2011

8,000 8,000

7,000 7,000

1 < 6,000 - 6,000

c .- c *I 2 5,000 5,000

8 8 4,000 4,000

1,000

0

3,000

r" - m c 2 2,000

a

0

2005 2006 2007 2008 2009 2010 2011

II BOD Concentratton - Ltcence Limit

3,000

2,000

1,000

Figure 4: Annual Mean BOD Concentration at SE-1 (2005 to 2011)

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4 FLOW, CONCENTRATION & LOAD

4.1 Overview

Under the current licence limits, the limits for flow and for concentration and load for a particular parameter (such as BOD or COD) are interlinked, with a change in any two elements giving rise to a change in the third element. For example, the licence places a limit of 7,500 m3/day on flow from SE-1 and a daily mean limit of 6,000 mg/l on BOD concentration. The limit on daily mean load is calculated as the product of these two limits, yielding a daily mean limit on BOD load of 45,000 kg.

However, as the peak flow and peak concentration results do not typically occur contemporaneously, the link between flow, concentration and load is not a necessity in establishing amended limits on emissions to sewer, as discussed further in Section 4.4.

4.2 Flow

In recent years, the Brewery has implemented a range of water savingheduction programmes, which have resulted in an overall decrease in water consumption at the site. This reduction in water usage in the production process has resulted in a reduction in the annual volume of effluent discharged via SE- 1, as shown in Figure 5.

1,600 I f 0 E 1,400

1,200

1,000

800

2006

Annual Effluent Volume Discharged via SE-1

I I 2007 2008 2009 2010

I 2011

Figure 5: Annual Effluent Volume Discharged via SE-1

The reduction in effluent volume has arisen during a period of relatively consistent production output between 2006 and 2010. As can be seen from Figure 5, the volume of effluent discharged over the period 2006 to 2010 reduced significantly. In 201 1, the volume of effluent was similar to that discharged in 201 0, despite an increase in production levels at the site of approximately 13%.

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Production activity at the site is expected to increase and, while we continue to identify water reduction and water efficiency measures across the site, it is expected that the increase in production volume will result in an increase in effluent volume. However, as illustrated above, and in light of the reduction in specific water consumption at the site, it is expected that the effluent will be of a higher concentration of both BOD and COD.

4.3 BOD & COD Concentration

Figure 6 shows the annual average BOD concentration at SE-1 and Figure 7 shows the annual average COD concentration. As can be seen from these figures, as the volume of effluent discharged from the site has reduced, through implementation of the water reduction initiatives and during a period of relatively consistent production output, the concentration of BOD and COD has increased.

Similar trends are evident when the daily, weekly and monthly average BOD and COD concentrations are examined over the same period, with a generally increasing trend, particularly in relation to weekly and monthly average concentrations since 2007.

6,000

5,000

= \ i!

4,000 .Q E

8

a

E

5 3,000 P - m E 5 2,000 (0 s

1,000

0

Mean Annual BOD Concentration a t SE-1

Ill11 2006 2007 2008 2009 2010 2011

Figure 6: Annual BOD Concentration at SE-1

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6,000

5,000

1,000

0

2006

Mean Annual COD Concentration at SE-1

2007 2008 2009

Figure 7: Annual COD Concentration at SE-1

2010 2011

However, while the annual average BOD and COD concentrations are greater than the current licence limits, the daily average BOD and COD concentrations are typically less than the licence limit, as shown in Figure 8 and Figure 9, respectively.

Daily Mean BOD Concentration (rng/l) at SE1 - 01 Jan 2011 to 31 Dec 2011 8,000 8,000

7,000 7,000

7 - I - - -

P

Jan11 F e b l l M a r l 1 A p r l l May11 Jun 11 Jul11 A u g l l S e p l l O c t l l Nov11 D e c l l

-BOD Concentration -Licence Limit

Figure 8: Daily Mean BOD Concentration (January to December 2011)

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Daily Mean COD Concentration (mg/l) at SE1 - 01 Jan 2011 to 3 1 Dec 2011 16,000 16,000

14,000 14,000

- 12,000 12,000 c I E C

8 10,000 10,000 L +

8 8,000 8,000

U

Jan11 F e b l l M a r l 1 A p r l l May11 Jun 11 Jul11 Aug11 S e p l l O c t l l N o v l l D e c l l

W CODConcentration -Licence Limit I

Figure 9: Daily Mean COD Concentration (January to December 2011)

As production activity at the site increases, it is expected that the current BOD and COD concentrations will not be reduced as we continue to pursue opportunities to improve the efficiency of water consumption and to identify water reduction initiatives. Therefore, while the daily average BOD and COD concentrations are expected to remain below the current licence limits, the annual average BOD concentration is expected to remain above the current licence limit, while the annual average COD concentration may, on occasion, exceed the current licence limit. It is also anticipated that the weekly and monthly average BOD and COD concentrations will increase above the current levels, potentially approaching the current licence limits.

In order to maintain compliance with the conditions of our licence in the context of the environmental initiatives that have been pursued at the site, we request an increase in the licence limits for the weekly, monthly and annual average BOD and COD concentrations. Our submission on the proposed amendments to the licence limits is set out in Section 5.

4.4 BOD & COD Load

As outlined in Sections 4.2 and 4.3, there has been a general reduction in effluent volume and a general increase in BOD and COD concentration in recent years. This particular combination resulted in a general reduction in both BOD and COD load between 2006 and 2009, with a subsequent increase in both BOD and COD load between 2010 and 201 1, as shown in Figure 10 and Figure 1 I , respectively.

The increase in load in 201 0 and 20 1 1 coincided with an increase in production activity at the site (a 4% increase in 2010 and a 13% increase in 201 1). Therefore, as production activity continues to increase, the BOD and COD loads are expected to increase. However, as the current effluent loads are considerably less than the current licence limits for load, this

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production related increase in load is not expected to give rise to an exceedance of the limits and therefore the Brewery does not require an increase in the limits for load.

6,000 U

! c I-

5,000

U 0

0 A

P

s - m C

B U 0

0 A

P

s - m 3 E

3,000

2,000

Annual BOD load Discharged via SE-1

1,000 0 11111 5,000

4,000

3,000

2,000

1,000

0

2006 2007 2008 2009 2010

Figure 10: Annual BOD Load at SE-1 (2011)

Annual COD load Discharged via SE-1 6,000 G

! c

I 2006 2007 2008 2009

Figure 11: Annual COD Load at SE-1 (20

2010

2011

2011

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5 SUBMISSION FOR AMENDMENT TO LICENCE LIMITS

5.1 Overview

In light of the current wastewater characteristics at the Diageo St. James’s Gate Brewery, the current level of licence compliance, the changes that have taken place at the site since the licence was first granted, anticipated increases in production activity at the site, and our discussions with Dublin City Council, we request the following amendments to the licence limits on effluent from SE-1:

0 An increase in the mean weekly, monthly and annual limit on BOD & COD concentrations at SE- 1.

A decrease in the daily limit on BOD & COD load at SE-1.

A decoupling of flow, BOD & COD concentration and BOD & COD load at SE-1 (the proposed increase in the mean limits on BOD & COD concentrations does not require a corresponding increase in the mean limit on the respective loads for these parameters).

Our submission on amended licence limits is set out in more detail in Sections 5.2, 5.3 and 5.4.

5.2 Flow

In relation to flow, the current mean daily flow via SE-1 (averaged over a 12-month period) is in the order of 3,000 m3/day, although the actual daily flow via this emission point can vary depending upon the level of production activity at the site and the extent of any rainfall. In recent years, the flow has varied between 700 m3/day and 6,000 m3/day and therefore, in anticipation of increased production activity at the site, it is not feasible to reduce the current limit on volume flow at SE-1 while ensuring compliance with the conditions of the licence. Therefore, the Brewery requests that the current limit of 7,500 m3 per day is maintained.

5.3 Concentration

Implementation of our water efficiency and water reduction programmes has resulted in a change in the concentration of BOD and COD in the effluent discharged via SE- 1. We have analysed the results for BOD concentration for the most recent complete year (201 l), which is considered to be the most representative set of data for the nature of the effluent. This shows that the mean daily BOD concentration during 201 1 was in the order of 3,000 mg/l (the annual average concentration).

In recent years, as we have progressed our water reduction programmes, the annual average BOD concentration has increased from 2,203 mg/l in 2007 to 3,082 mg/l in 201 1. Therefore, in order to cater for a further increase in BOD concentration through the continuance of our water reduction initiatives, while maintaining compliance with the licence, we request an increase in the limit on BOD concentration, as an annual average, to 3,600 mg/l. In addition, in order to cater for this anticipated increase in BOD concentration over the shorter averaging

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periods (weekly and monthly), we also request increases in these limits, to 4,900 mg/l for the weekly period, and 4,000 mg/l for the monthly period.

As shown in Table 2, the ratio of COD to BOD within the current licence limits is set at 2: 1, with the limits for COD parameters (concentration and load) set at twice the corresponding limits for BOD. An analysis of the COD to BOD ratio for recent years indicates that the ratio has not changed significantly and that the 2: 1 ratio remains appropriate. Therefore, in light of our request to increase the limits on the daily, weekly and annual average BOD concentrations to 4,900 mg/l, 4,000 mg/l and 3,600 mg/l, respectively, we also request an increase the limit on the corresponding limits for COD concentration to 9,800 mg/l, 8,000 mg/l and 7,200 mg/l, respectively.

As the daily concentrations of BOD and COD in the effluent remain below the licence limits, and no exceedances of the current licence limits for either parameter have occurred in recent years and are not expected to occur, even with further reductions in water usage at the site, the we consider that the current daily limits of 6,000 mg/l for BOD and 12,000 mg/l for COD remain appropriate and we request that they are maintained.

5.4 Load

As set out in Section 4.4, while there has been an increase in BOD and COD load in recent years following an increase in production activity at the site, the loads remain less than the current licence limits. Therefore, we consider that the current limits on daily and annual load remain appropriate and we propose that they are maintained. However, in light of our discussions with Dublin City Council, we understand that one of the key parameters affecting the operation of its treatment plant is effluent load, and therefore we request a decrease in the limit on daily BOD and COD load in order to assist DCC in its operation of the plant.

In light of these requests to increase limit on the annual average concentration for these parameters (in Section 5.3), and to reduce the daily load, the direct relationship between flow, concentration and load will be removed. This decoupling can be accommodated by virtue of the variability of the flow and BOD and COD concentration.

5.5 Summary of Submission for Amended Limits

Table 4 summarises our submission to amend the licence limits relating to effluent volumes, concentrations and loads. The changes from the current licence limits are highlighted in bold in the table.

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Table 4: Submission for Amendments to Licence Limits at SE-1

Current

6,000

3,000

2,500

2,000

Parameter

Requested

6,000

4,900

4,000

3,600

Volume to be emitted (max. in any one day)

BOD Daily

Weekly

Monthly

Annual

Current

7,500 m3

45,000

22,500

18,750

15,000

COD Daily

Weekly

Monthly

Annual

Requested

7,500 m3

45,000

15,000

Mean Concentration (mg/l)

90,000

45,000

37,500

30,000

90,000

30,000

12,000

6,000

5,000

4,000

12,000

9,800

8,000

7,200

Mean Loading (kg/day)

6 APPLICATION FOR AMENDMENT TO LICENCE LIMITS

On the basis of the data and assessment presented in the previous sections, Diageo St. James’s Gate Brewery requests that limits on the discharge of effluent from the site via emission point SE-1 are amended as set out in Table 4, with an increase in the limits for the daily, weekly and annual average concentration of BOD and COD, and a reduction in the daily mean load for BOD and COD.

These amendments to our licence limits will enable Diageo St. James’s Gate Brewery to comply with the conditions of our licence while continuing to pursue the opportunities to achieve further water usage reductions across the site, consistent with Conditions 5.4.1 and 7.3 of our licence (PO301-02).

* * * * *

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