ENVIRONMENTAL PROTECTION AGENCY - EPA · 2014. 4. 1. · 5. EPA Air Emissions Monitoring Report. 6....

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ENVIRONMENTAL PROTECTION AGENCY

Office of Environmental Enforcement

INVESTIGATION REPORT UNDER S83 OF EPA ACTS 1992 AS AMENDED, FOR CONSIDERATION AS PART OF THE LICENCE APPLICATION FOR BRANDON

PRODUCTS LTD (REG. NO. P0957-01 (APPLIED))

To: ELP (LICENCE APPLICATION P0957-01)

From: OEE Regional Enforcement, Cork

Date: 14th January 2014

Introduction

In July 2012, OEE Regional Enforcement were approached by the then licensing inspector for Brandon Products Ltd. (Reg. No. P0957-01 (applied)) Seán O’Donoghue, to assist him in trying to verify odour complaints from residents in the vicinity of the Brandon Products Ltd. installation. Due to the intermittent nature of the complaints, independent verification by the Agency had been proving difficult. This report and attachments detail the result of the OEE’s investigations to date, to be considered, as part of the licensing application, under S83 of the EPA Acts 1992 as amended.

Documents Included:

The following documents are enclosed for consideration as part of determining the licence application.

1. The Agency’s Statement of Odour Assessments on occasions when odours and/or health impacts were verified.

1. Odour 2012-09-05JD1 2. Odour 2012-09-05JD2 3. Odour 2012-11-27 JD1 4. Odour 2012-11-27 JD2 5. Odour 2013.04.24 PC 6. Odour 2013-04-24 7. Odour 2013.04.30PC 8. Odour 2013-05-01nod 9. Odour 2013-05-01 10. Odour 2013.05.01 PC 11. Odour 2013-06-19 12. Odour 2013-06-20

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13. Odour 2013-06-21 14. Odour 2013-07-31ml 15. Odour 2013-10-08ml 16. Odour 2013-10-30ml

2. Heath Impact Notes

1. Health Impact Note 24/4/13

2. Health Impact Note 30/4/13

3. Ambient Monitoring Results from the 17/09/13 to 15/10/13 and 15/10/13 to 05/11/13.

4. Report on comparison of ambient monitoring results with guideline limits for ambient air monitoring undertaken from the 17/09/13 to 15/10/13.

5. EPA Air Emissions Monitoring Report.

6. Modelling of bioaerosols emissions as a result of EPA air monitoring of bioscrubber.

7. Minutes of meetings held between Brandon Products Ltd and the Agency on the 21/05/13 and the 08/11/13.

8. HSE letter to the Director General, EPA, dated 13/12/13.

9. Log of odour complaints received directly by OEE to date (14/01/14).

OEE Comments:

1. The facility’s activities are currently unregulated.

The operators of the facility carry on an activity that involves a chemical process that is, and was at the outset, licensable. The activities certainly appear to OEE to be outside the scope of their Planning Permission, which does not provide for the chemical process.

The operator's application for Planning Permission was received by the Planning Authority on 22 August 2006. It is noted that

a. the application form received by Kerry County Council (KCC) 22nd August 2006 specifies the nature of the development as civil works associated with the conversion of a creamery to a boiler house/store (i.e. without mention of the chemical process to be undertaken at the facility);

b. the application form received by KCC 22nd August 2006 stated in response to Q13: “Does the development comprise or is it for the purposes of an activity in relation to which an Integrated Pollution Licence or Waste Licence is required?” Response: No.

c. the application form received by KCC 22nd August 2006 stated in response to Q14: “Is the development of a class requiring the

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preparation of an Environmental Impact Statement prescribed in Schedule 5 of the Planning Regs 2001?” Response: No.

It is noted that Schedule 5 of S.I. No. 600/2001 - Planning and Development Regulations, 2001 contains

6. Integrated chemical installations, i.e. those installations for the manufacture on an industrial scale of substances using chemical conversion processes, in which several units are juxtaposed and are functionally linked to one another and which are-

(c) for the production of phosphorous, nitrogen or potassium based fertilisers (simple or compound fertilisers),

d. Notes relating to planning application, Orpheus Eng. & Design Ltd. 21 August 2006: "The only emissions to air will be from a chimney from the steam boiler and steam from a cooling tower. The enclosed production system is vented to a sealed tank and any vapours cooled and condensed before being recycled into the process."

e. On the basis of the application, Kerry Co. Co. Env Dept Memorandum dated 3/10/2006 stated that “the application for a seaweed processing facility near Asdee states that there will be no emissions to air other than steam and boiler emissions. No air pollution licence is necessary”. This view does not seem to have been reconsidered by Kerry Co. Co. at any time since the nature of the process and emissions and environmental impacts therefrom became evident to them.

Consequently, OEE considers that the facility is operating without an appropriate authorisation and without any environmental control parameters.

2. Inaccurate and/or out of date application and EIA information submitted to the Agency: Based on Agency monitoring carried out on 17th September 2013 (Point 4 below) and recent odour modelling by the applicant viewed by OEE, the information submitted as part of the licence application and EIA is incomplete and / or inaccurate. The licensee was informed at a meeting with OEE on the 8/11/13 (minutes attached) that contact should be made with ELP without delay in order to bring ELP up to date with the current situation, and also that the application and EIA documents should be updated. At the time of writing this Memo, these tasks do not appear to have been met. More detail about OEE’s view with regard to the deficiencies in the information contained in the application at present is provided in point 5 below.

3. Odour Nuisance: OEE considers that Brandon Products Ltd. is causing an odour nuisance offsite as evidenced by numerous odour assessments undertaken in the vicinity of this facility; to date, 16 odour assessments on 11 separate occasions (including multi-person visits), out of a total of 25 assessments on 17 occasions, detected nuisance level odour from this facility. Statements of these odour assessments are attached.

OEE is satisfied, on the basis of information supplied by residents living in the vicinity of the facility and the contents of the Kerry Co. Co. Planning and

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Enforcement Departments’ files in relation to the facility, kindly supplied to us by Kerry Co. Co., that odour nuisance has been associated with the facility’s activities virtually since commencement of activities.

4. Health Symptoms: The residents have consistently described the noxious and offensive nature of the odour and have also consistently reported that the health of their families and themselves has been affected. Two OEE inspectors experienced acute respiratory health symptoms as a result of exposure to these odours; health impacts on inspectors have been recorded 7 times on 6 separate occasions. At this point, it would appear that these effects have been transient.

The health impact suffered by the Agency’s inspectors was noted as a Safety, Health & Welfare incident.

The offensive odour and the health impacts reported by residents and suffered by OEE personnel has led the OEE to determine that the emissions from the facility are causing or are liable to cause Air Pollution.

5. Agency Air Emissions Monitoring: Following the health impacts experienced by OEE inspectors at the facility, and to provide information on the nature of the emissions, OEE commissioned Catalyst Environmental Ltd., to carry out air monitoring on emissions from the bioscrubber and olfactometry testing in a number of areas within the Brandon Products Ltd. installation. This monitoring was conducted on 17/09/13. It is noted that there were no odour complaints that day and no offsite odours were observed by OEE personnel. While most parameters measured were at low concentrations on that occasion, the following parameters were at a level of concern which requires further investigation by the applicant as a result of this monitoring event:

A Hydrogen Fluoride result of 1.7mg/m³ (measured over 7 hours). To put this in some kind of context the daily average limit in Indaver’s licence is 1mg/m³. Hydrogen Fluoride is not mentioned as a raw material or emission in the IPPC licence application form for P0957-01. OEE understands that HF may be a side-product of fertiliser production.

Bioaerosols: Preliminary modelling by the Agency of the bioaerosol results indicate some potential risk of exceeding a level of 1,000 cfu/m3 during specific meteorological conditions; this is the Environment Agency’s guidance limit for composting sites and applies at the boundary of such sites. It must be noted that this assessment is preliminary, and is subject to considerable uncertainty at this stage: terrain and building effects may significantly alter the downwind concentrations, while further analysis of the bioaerosol composition may alter the way in which the emissions are modelled (i.e. as a gas or particulate phase).

Notwithstanding this, details of the bioaerosol composition may help in determining the likely loss of viable micro-organism after release from the stack, as some organisms are more resistant than others in this regard. It was noted that at the time of monitoring that the licensee was having difficulties in relation to moisture leaving the stack, which was operating at

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around 11,000 m³/hr during the monitoring; this apparently flushed out the biomass, resulting in the observed high bioaerosol emissions.

Bioaerosols are not mentioned as part of the emission in the application documents. Brandon Products were informed of the bioaerosols levels at our meeting of the 8/11/13 and were apprised of the modelling and assessment requirements.

Since this monitoring event, the licensee has installed a mist eliminator and a cone at the top of the stack. OEE was informed during a meeting with the operator on the 08/11/13 that the installation of the mist eliminator had led to a 90% reduction in moisture leaving the stack, thereby reducing the potential for bioaerosol emissions. The applicant also reported that the installation of a cone at the top of the stack had resulted in a narrower exit point and hence an increasing efflux velocity. These items remain to be demonstrated.

OEE considers that an assessment of the impact of bioaerosol and hydrogen fluoride emissions should be addressed as part of the licence application.

3. Ambient Air Monitoring: Ambient air monitoring was undertaken at 5 locations in the area of Brandon Products Ltd. over two four-week periods between September and November 2013. The parameters measured were acid gases, ammonia and hydrogen sulphide. Hydrogen Fluoride was the only parameter where the results are slightly elevated; observed levels were within the California EPA’s long term exposure limit of 30ug/m3, but exceeded the Canadian EPA’s 30-day reference level for Hydrogen Fluoride (for protection of vegetation) of 0.4 µg/m³.

4. Odour Modelling: The operator conducted new modelling of odour emissions from their facility in 2013. A copy of this report has not been seen by OEE, but this modelling was discussed at the meeting held on the 08/11/13. In summary, the modelling showed that, with the current stack (14.8m), odour at nuisance intensities could occur at receptors. The operator informed the Agency during the meeting that they intend seeking planning permission from the local authority to increase the height of the stack; the original stack was designed by the operator to be exempt from Planning.

The new odour modelling information has not been submitted as part of the licence application, despite the licensee being informed of the urgent requirement to do so.

5. HSE Public Health Department (PHD): As a result of information received from residents regarding chronic health impacts being attributed to Brandon Products Ltd., the Public Health Department in the HSE was contacted by OEE in July 2013. The PHD carried out an initial health inquiry and submitted a letter to the EPA’s Director General dated 13/12/13. This letter summarises the findings of this inquiry and made a number of recommendations for actions by the EPA. A response to this letter was sent by OEE on 24/12/2013.

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PHD forwarded the letter of 13/12/2013 as a submission to licence application P0957-01.

6. Interactions with the operator: Since the OEE began engaging with the issue, first via a Section 63 Investigation by the OEE Air Thematic Unit and subsequently by Cork Regional Licence Enforcement Team following the ELP request in July 2012, OEE RLE team has met with the operator on a number of occasions, both at the site during odour assessment visits and at formal meetings. The latter meetings have been held as follows:

a. 21/05/13, 11:00am, Inniscarra; ELP were also in attendance;

b. 08/11/13, 10:00am, Richview and Inniscarra by Videolink.

In addition, the operator has engaged in correspondence with the Agency and, most recently, with HSE.

7. Interactions with the residents:

OEE has met regularly with a number of residents who have complained to the Agency since our first being informed of odours and pollution from the facility. This was by means of the Section 63 complaint received in May 2011 from 18 signatories who signed themselves “residents of Kilcolman affected by smells, odours, 2009, 2010, 2011”. The evidence of the complainants regarding their experience of the effects of the facility’s emissions dates back to March 2009, when they made a similar collective complaint to Kerry Co. Co., and includes odour logs, notes of correspondence with the Council, personal testimonies and in several cases reports of health impacts suffered by themselves or their families. The complainants described their difficulties receiving proper acknowledgment, in those years, about the credibility of their consistent reports of nuisance and health effects.

OEE is satisfied, on the basis of our discussions with them and our own independent observations, that the complainants are credible and that they have suffered nuisance and pollution since 2009 as a result of the emissions from this facility.

8. Changes made by the operator since the OEE’s intervention: the operator has made the following known changes to their air emissions abatement infrastructure in response to the ongoing complaints.

a. Installed a 14.8m stack on the bioscrubber.

b. Installed a mist eliminator and cone on the bioscrubber stack thereby reducing exit point diameter.

c. Increased the flow rate through the bioscrubber.

d. Installed extra cooling in the process.

e. Connected formulation tanks to the bioscrubber.

Since the completion of the works outlined under point 7 above, OEE has received and verified nuisance level odours from the Brandon Products Ltd. Installation.

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Summary

The OEE investigations would indicate:

1. That information submitted in the licence application and EIA is incomplete and/or inaccurate and requires updating;

2. Emissions from the facility need to be more fully categorised. The significance and impacts of the emissions must be fully assessed by the applicant;

3. An appropriate managed and controlled abatement system is not as yet in place, at the site, to prevent odorous emissions.

The OEE Regional Enforcement Team, Cork submits this report under S83 of the EPA Acts 1992 as amended, for consideration as part of the licence application for Brandon Products Ltd.

Should ELP require any clarifications in relation to any of the items above, please contact Peter Cunningham, Maria Lenihan or Niamh O’Donoghue of OEE Regional Enforcement, Cork.

Statement of Odour Assessment _______________________________________________

Brandon Products Limited

Kilcolman

Asdee

County Kerry

________________________________________________________________ Licensee: Brandon Products Limited Registration Number: P0957-01 (Applied)

Date of odour assessment: 05 September 2012 Start time: 11:55 hrs. Finish time: 13:30 hrs.

Date of issue of this statement: 28 November 2012

This document’s reference number: Odour 2012-09-05 JD1

This odour assessment was undertaken by: John Doheny, Office of Environmental Enforcement, Cork

________________________________________________________________

As per the criteria stated above I carried out an odour assessment in accordance with EPA Air Guidance

document AG5 (Odour Impact Assessment Guidance for EPA Licensed Sites). The Field Record Sheet that was

completed during the odour assessment has been copied in full and is attached to this Statement of Odour

Assessment, together with a map showing the monitoring locations.

Due to the findings of the odour assessment it is the opinion of this Inspector that the activities occurring on the

premises of Brandon Products Limited resulted in odours beyond the site boundary, namely at -------------------.

Please quote the above document reference number in any future correspondence in relation to this report.

Signed:

Name (print): John Doheny

Title: Inspector, Office of Environmental Enforcement, Environmental Protection Agency, Inniscarra, Cork.

Date: 28 November 2012

EPA Air Guidance document AG5 is available online at www.epa.ie

(Field record sheet and monitoring location map attached)

http://www.epa.ie/

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Environmentat Enforcement

-General-· Licensee/ Facility:

Procedu_ /. Site Inspection; Assessment of Odour In~t '----'

Field Record Sheet

Doc. Ref. No.: FP011-001

Revision No.: 00

Issue Date: 26/02/2007

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Precipitation - dry, rained recently, drizzle, raining, foggy Temperature- cold, cool, warm, hot · ·

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Strong Gale Slight structural damage occurs (chimney pots and slates removed) ----~-------------~----------------------------

Created by: Alan Stephens Revised by: Alan Stephens Approved by: Keiran 0 Brien, Programme Manager Signature: Date:

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Kilcolman

Asdee

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Date of odour assessment: 05 September 2012 Start time: 14:30 hrs. Finish time: 16:05 hrs.




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Due to the findings of the odour assessment it is the opinion of this Inspector that the activities occurring on the

premises of Brandon Products Limited resulted in odours beyond the site boundary, namely on the road opposite

the Brandon Products premises (at old shop).


Signed:

Name (print): John Doheny





http://www.epa.ie/

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Environmental Enforcement

Procedure .:.-.:51te Inspection; Assessment of Odour Impacr-'

Field Record Sheet


Revision No.: DO


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Strong Gale Slight structural damage occurs (chimney pots and slates removed)

Created by: Alan Stephens Revised by: Alan Stephens Approved by: Keiran 0 Brien, Programme Manager Signature: Date:


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Asdee

County Kerry


Date of odour assessment: 27 November 2012 Start time: 08:45 hrs. Finish time: 10:20 hrs.




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Due to the findings of the odour assessment and the subsequent post assessment site visit to your facility, as

presented in the attached Field Record Sheet, it is the opinion of this Inspector that the activities occurring on

the premises of Brandon Products Limited resulted in odours beyond the site boundary, namely at the entrance

to -------------------------.


Signed: _______________________ Name (print): John Doheny





http://www.epa.ie/

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Envimnrnenta\ Enfor<ement

Procedure - Site Inspection; Assessment of Odour Impact

Field Record Sheet

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Revision No.: 00


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Note 1: Observation point sensitivity (~ssuming detectable, if not then 0) Note 3: Weather Conditions

" "' .Q!: 1i) .2

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/D(?..-·b ~{ I Remote (no housing, commercial/industrial pr!:mises or public area wtthin 500m of observation point) 2 Low sensitivity (no housing, commerciaVindusfrial premises or public area within lOOm of observation point) 3 Moderate sensitivity (housing commercial/industrial premises or public area within lOOm of observation

Precipitation {_{rY)aine4tecentl~e,raining, .. Joggy Temperature ~cool,warm;-hot

"' Q) Q) "' -.o 0 0

j 4

5

point) High sensitivity (housing, commercial/industrial premises or public area within area of observation point) Extra sensitive (complaints arising from residents, business and users of pub He areas within area of

Note 4: Odour Persistence ··-·---·--------···,

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observation point)

Note 2: Wind Strength

0 1 2 3 4 5 6 7 8

9

Calm Light air Light Breeze Gentle Breeze Moderate Breeze Fresh Breeze Strong Breeze Near Gale Gale

Smoke rises vertically Direction of wind shown 'by smoke drift, but not wind vanes Wind felt on face; leaves hJ.stle, ordinary vane moved by wind Leaves and small twigs in constant motion Ralses dust and loose pap·er; small branches are moved Small trees in leaf begin to sway Large branches in motiori; umbrellas used with difficulty against the wind Whole trees in motion; iriconvenience felt when walking against wind Twigs break off trees; progress generally impeded

.... _ __ _ Slight structural damage Occurs (chimney pots and slates removed) Strom' r.-::.lP.

0 'NoOdour 1 Intermittent (detected intermittently during the period of assessment) 2 Persistent (detected throughout the period ?f ass_essment)

Note 5: Odour Intensity

0 No Detectable Odour .. ,_, _ 1 Faint Odour (barely detectable, need to stand-still and inhale· facing into wind) 2 Moderate Odour (easily detectable while walking and breathing normally,

possibly offensive) 3 4

Strong Odour (bearable but offensive- inight make clothes I hair smell?) Very Strong Odour (unbeaqble, difficult to remain in area a.ti:ected by odour)

. ------ --.- -·- ----- --- ----- -- -·-· -·- --------·--· I Created I:Jy: Alan_§_tephEms _ _I Revisecjb_y: Alan__Stephens I

Approved by: Keiran 0 Brien, Programme Manager 1 Page 1 of 2 Uncontrolled Once Printed Signature: Date:

·--i

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Observer Location

Name of household/commercial

i site (describe so that location can be easily identified again by a third party, inc. map ref.)

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o~~tD o~"tm -om• ...... -o ....... o ..... oo...S~ 0 E --~

Doc. Ref. l'Jo. FPO!l-001-00

Odour Description . " ---------·- ----- ------ -·--····--·-Comments (Description of any odours, source of odours, complaints received etc)

Gulde:ATocatlOnwhere the scciremeeis or "E " --- <: 3 jg g> 0 s -- --- --- 1 or 2 " 2 exceeds all the threshold values may be :5 "5 -;;; ':ii c-- u o deemed subject to nuisance/significant

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0 <: 1mpac , frequency and duration of odours.

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Revised by: Alan Stephens

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Page 2 of2 Uncontrolled Once Printed

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Kilcolman

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County Kerry


Date of odour assessment: 27 November 2012 Start time: 14:40 hrs. Finish time: 17:00 hrs.




________________________________________________________________





Due to the findings of the odour assessment and the pre assessment site visit to your facility, as presented in the

attached Field Record Sheet, it is the opinion of this Inspector that the activities occurring on the premises of

Brandon Products Limited resulted in odours beyond the site boundary, namely at the entrance to -----------------

-------- on 27 November 2012.


Signed: _______________________ Name (print): John Doheny





http://www.epa.ie/

Cf25? Environmental Enforcement

Field Record Sheet~ "' "\ i· ") ~---/ vf "----

Revision No.: 00


General i Licensee/ Facility: Licence Reg. No. Odour Assessment by Date of inspection Announced/Un-announced

c: ~:8 ·-"' ':"-" "' _a. a.e a.

·-·---~~---·-~-.-~---------~·- -------·---------~---~-

.~ n . () , Y~"hJ\;;o-:, 'V(![)2>.Jc:tf rdv "?fft,..::_~ , Observer. is lreetrom -- ! Observer- abstiiieilce~c3o min)

medical conditions (cold, i from smoking, fiavoured drinks, sore throat, sinus i scented toiletries and trouble)? , deodorisers?

Procedure sec 7.2.1 ! Procedure sec 7.2.1

------~.------------------

• \ i ~ ( ./ \. ~~-~ 7r;>.J "-- ' {) li:='A-' 1 R.eason-loroctour- f assessment- Complaint verification; targeted weather/process; routine visit; other (specify).

__ , ··-·-·----·--· -------··-- ------~----·····--·--

27- 1 I· IL-. I

LLJ.iTN¥Jcn .. ~rJ~~ Map- Has an area map showing assessment locations been attached?

Procedure sec 7.2.3

.. ------ ... "."' ---·-···-·- . -. ---

Has the observer received training in the use of this procedure?

If so, insert date of training

. Procedure sec 7 .2.2 ~

r;~~=-~=-, ·=0J~····-=--~--- G{t~'1'ic!._1 __ ~~--.--· --~~-~--~----~ C~----~-----~~ i Weather Conditions Note 3 Do any of the odours experienced · What processes were occurring at the licensed facility during -.:: ..

" "' ~" -o "'0

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i (record wind info on page 2) ' on-site match in character those the course of the survey? Provide details if possible.

----=-~~L~~~~=-~-~--~-:=--=~~~1/;~t; ~~~:YJ.\~~1-=-=~J;~~~~-==-~=-----~----=----===-- ---------: Note I: Observation point sensitivity (assuming detectable, ifnot then 0) · Note 3: Weather Conditions

" "' .oC:

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1 Remote (no housing, commerciallindustrial premises or public area within 500m of observation point) 2 Low sensitivity (no housing, commerciallindustrial premises or public area within 1OOm of observation point) 3 Moderate sensitivity (housing cornmercial!industrial premises or public area within 1OOm of observation

point)

Precipitation- dry, rained recently, drizzle, raining, foggy Temperature-- cold, cool, warm, hot

"' " " "' -"" 0 0 ! 4 c::"C, ~ 5

High sensitivity (housing, commerciallindustrial premises or public area within area of observation point) Extra sensitive (complaints arising from residents, business and users of public areas within area of observation point)

Note 4: Odour Persistence Q) (ii ; ~t::1a 1

cn~Q.IQ.I Q)-.:L: -c::-Q) o·-C'l> Z en c:: o

-E:wm ""--"" "' Q."' :..e-"' 0

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0 No Odour

Note 2: Wind Strength

I Intermittent {detected intermittently during the period of assessment) 2 Persistent {detected throughout the period of ass.essment) ----~----

Note 5: Odour Intensity ·-·--~--~---------~'

0 I 2 3 4 5 6 7 8 9

Calm Light air Light Breeze Gentle Breeze Moderate Breeze Fresh Breeze Strong Breeze Near Gale Gale

Smoke rises vertically Direction of wind shown by smoke drift, but not wind vanes Wmd felt on face; leaves rustle, ordinary vane moved by wind Leaves and small twigs in constant motion Raises dust and loose paper; small branches are moved Small trees in leaf begin to sway

Strong (1:;-Jp_

Large branches in motion; umbrellas used with difficulty against the wind Whole trees in motion; inconvenience felt when walking against wind Twigs break off trees; progress generally impeded

~ Slight structural damage occurs (chimney pots and slates removed)

0 No Detectable Odour 1 Faint Odour (barely detectable, need to stand still and inhale-facing into wind) 2 Moderate Odour (easily detectable while walking and breathing normally,

possibly offensive) 3 Strong Odour (bearable but offensive- might make clothes/ hair smell1) 4 Very Strong Odour (unbe~Ie, difficult to remain in area affected by odour)

--- .. .--·· ·-- ·-- --·- ·--·- - -- . ---· ·-----·~- --

Revised by: Alan Stephens rcA~p~p~ro~v~e~d~b~y~:~K~e~i~~n~O~B~n~.e-n-.~P-ro_g_r-am~m-e~M~a-n_a_po-c----------~~~~ "''8''"'"'e: ~ · ·· - --o~i~"'~· I Page 1 of 2 Uncontrolled Once Printed

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Name of household/commercial site (describe so that location can be easily identified again by a third party, inc. map ref.)

Wind

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Odour Rating : Odour Description --.. ·---··-·-.. _ .. _ f-comments ______ .. - ... ··-·-· ··- ·---·

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············- ···--·-·--iGuide~A locatioriwiiere.thescori;meets or

1 or 2 I " 2 1 exceeds all the threshold values may be I deemed subject to nuisance/significant i interference, particularly if the observations i are supported by public complaints on ! impact, frequency and duration of odours. ' I

. ·-- .. ••• ,• -····-•·•·•·•·•····•'''··--" •·--·---·••••·--""'---- -···-·---·-• .--·-·-••• -- ~---·--·-••··- -··-2-••••- .---- <""-··~·-T-----~--- o

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Statement of Odour Assessment _______________________________________________ Contact name Mr. Jerry O’Mahoney

Business name Brandon Products Ltd

Licence Reg No. P0957-01 (applied- no licence in place)

Address Kilcolman

Address Asdee

Address Co. Kerry

________________________________________________________________

Business: Brandon Products Ltd Licence Registration Number: P0957-01 (applied)

Date of odour assessment: 24/04/13 Start time: 07:50

Date of issue of this statement: 16/05/13 Finish time: 13:40

This document’s reference number: Odour 2013.04.24 PC

This odour assessment was undertaken by: Peter Cunningham, Senior Inspector, OEE

________________________________________________________________

As per the criteria stated above an odour assessment was undertaken in accordance with EPA Air

Guidance document AG5 (Odour Impact Assessment Guidance for EPA Licensed Sites). The Field

Record Sheet that was completed during the odour assessment has been copied in full and is attached

to this Statement of Odour Assessment.

Due to the findings of the odour assessment, which detected very strong and objectionable odours

which caused health impact, and the subsequent post assessment site visit to your facility, as presented

in the attached Field Record Sheet, it is the opinion of this Inspector that the activities occurring on

the premises of Brandon Products were causing the odours detected off-site, which in the opinion of

this Inspector constitutes Air Pollution. The odours and health impacts detected off-site and

experienced on-site are of very serious concern to the Agency.

The following is a brief outline of events on the day of the odour assessment:

Statement of Odour Assessment: Brandon Products Ltd, Astee, Co Kerry 24/04/2103

Page 2 of 5

Inspector Maria Lenihan and I visited the vicinity of the Brandon Products Ltd facility on the morning of 24 April 2013 to evaluate complaints of noxious odours causing health impacts on residents that have been received by the Agency.

Our odour assessments were conducted simultaneously but independently and commenced at 07:50 (according to my watch; note that I did not synchronise my watch with Inspector Lenihan’s). As recorded in my Odour Assessment Log (attached), I did not observe any unusual odour at any of the first seven locations, which were located upwind or crosswind from the facility. At the next location, a sensitive receptor labelled “D” (-------------------------) and lying approximately 200m from the facility (commenced 09:00), I noted what I describe as a “very unpleasant, horrible” odour with a significant ammonia character. I ascribed a Persistence of 1 (1.5) (“intermittent [to semi-persistent”]) and an Intensity of 4 (“Very strong”) to the odour. It was evident to me that this odour originated at the Brandon Products Ltd facility which was directly upwind at that time.

I recorded the following voice note on my phone at location “D” (-------------------------):

“We’re… myself and Maria Lenihan are standing outside -------------------------, point “D”, directly downwind of Brandon Products, probably 200m? (ML: “Yes”) down, directly downwind, and we’re in the course of a five-minute odour observation and I think it’s important to record that the odour is strong; its halfway between intermittent and persistent, not continual but it is certainly not occasional either. Its strong, it’s got a strong ammonia flavour to it; it is, ah… I could see this as being nauseous and I could see it as being very intolerable if you were exposed to it on a continual basis. Yeah, a very… very unpleasant odour, I would say there would appear to be ammonia in it, and something else in the way of seaweedy type odours as well. I get a taste in my mouth. Yes, its, ah… very unpleasant. I will leave it at that, coming on 09:05.”

After completing that observation, we visited five other locations, all either upwind or crosswind of BP, and then arrived at location “O” (-------------------------) and started observations at 10:02. At that time, the location was directly downwind lying approximately 200m directly downwind of the facility, I again noted what I describe as a “very unpleasant, horrible” odour with a significant ammonia character. I ascribed a Persistence of 2 (“Persistent throughout the observation”) and an Intensity of 4 (“Very strong”) to the odour.

I recorded the following voice note on my phone at location “O” (-------------------------):

“This is 24 April again, the time is around five past ten or so. We are at point “D” [error reading map – actually point “O”], directly downwind now from Brandon Products, probably about 150 to 200 metres from (obscure), and ah, the wind is at the north west now so as I say we are directly downwind at this point. Ohhh, the odour is very strong and it is very persistent on this occasion, and it’s very unpleasant; it catches in the throat and eh, really I have been feeling the nausea since the last time we encountered the smell about 20 or 30 minutes ago - this is probably stronger here now if anything. It’s hard…, it’s hard to be here I would say. Ohhh, deeply, deeply unpleasant, ammonia in…, you can feel it in the back of the throat. Makes you cough, nausea, ah…, not…, not tolerable, (coughs) it’s not easily (coughs) tolerated. Not easy to tolerate this, would not… em, in my view if one was to experience this on a regular basis this would clearly be nuisance if not more; this is verging on health impact I would have thought, rather than just, ah, just disturbance factor. I will pause it at that…”.


Page 3 of 5

During this observation, Maria and I both noted an employee of Brandon Products Ltd, who I understand was Ms Mary O’Driscoll, walking past the entrance to O’Sullivan’s Agricultural Supplies yard. I believed, because of the clipboard in her hand, that this employee was possibly conducting an odour assessment. However, she did not stop to assess the odour that we were experiencing. We were not in clothing identifying ourselves as EPA officers at that time, since this was an unannounced odour assessment.

Following this observation, we proceeded to the front apron of the Brandon Products Ltd facility. We conducted an odour observation there, finding the same ammonia-based odour as we had noted at locations “D” and “O”, with a Persistence of 2 (“Persistent throughout the observation”) and an Intensity of 4 (“Very strong”). It was evident that the facility was the source of the odour we had encountered earlier.

We then visited ------------------------- as previously arranged, to meet them and also -------------------------. We had a discussion about their experiences with odour and associated health impacts that they considered to be caused by emissions arising from the Brandon Products facility.

We recommenced the odour assessment at 11:25 at location “D” (-------------------------). At this time, the wind was slightly weaker and remained from the North West, so the facility was no longer directly upwind of this location (at the previous visit to this location, the wind was from the west). No odour was detected.

We then proceeded to location “O” (-------------------------), commencing at 11:35. At this time, we again independently observed the same ammonia-based odour as we had noted earlier, though on this occasion slightly lower strength. I ascribed a Persistence of 2 and an Intensity of 3-4 to the odour I observed. Once more, it was evident that the facility was the source of the odour. I again noted the same impact on my health and wellbeing.

We invited a number of the complainants to join us at this location to obtain their opinions about the odour. ------------------------- attended at 11:38 and confirmed that “the odour is the same as that which they experience and causes them nuisance and health effects” (I subsequently visited the home of ------------------------- again at 14:00, where Jerry informed me that he visited the yard soon after that and he also confirmed to me that the odour was the same).

We left location “O” (-------------------------) and visited another private residence (-------------------------) on information from ------------------------- that odour had been experienced there earlier that day. When we attended, we noted that the facility was crosswind at that time, and no odour was detected.

We then visited the facility, entering the premises at 12:00 at the invitation of Mr Jerry O’Mahoney, Production Manager. We informed him that we were conducting an odour assessment and had detected very strong and sickening odour from the facility at several offsite locations and on the facility itself. We confirmed to him our view that the odour constituted air pollution contrary to the Air Pollution Act 1987.


Page 4 of 5

A meeting took place during which the plant’s activities and processes, the planning status, functioning and performance capabilities of the bioscrubber, additional odour sources and related matters were discussed.

We informed Mr O’Mahoney that we had observed Ms O’Driscoll passing along the road outside location “O” (-------------------------) during our first assessment at that location (10:02 – 10:07), commenting that she did not stop to make an odour observation despite the very strong and offensive odour that we were both encountering. We asked to see the facility’s odour record, and noted that the record for that day indicated that no odour had been observed; instead, the record showed a series of observations of zero odour at all of the sites visited by Ms O’Driscoll. We commented that this could not but impair the confidence that could be ascribed to the facility’s odour record as a whole. We discussed the operator’s odour assessment procedure, noting that it did not closely conform to the Agency’s guidance in this regard, especially regarding desensitisation by previous exposure on site before conducting the odour assessment.

We then accompanied Mr O’Mahoney on a tour of the facility, commencing at 12:40. We went first to the side of the building where we saw a covered container used for storing solid production wastes. There were no evident issues with this container. We then moved to the rear of the building to view the external services units including the bioscrubber. We stood immediately adjacent to the ground level exit point of the bioscrubber, from which a gentle and slightly warm (I estimate “mid 20”s °C) air flow was being emitted. The air had a musty, “nutrient broth” / “culture medium” type odour that was not particularly pleasant but was nonetheless fairly mild in intensity. There was no trace of the sickening odour we had encountered offsite earlier in the day. Mr O’Mahoney suggested that this may reflect the fact that production had been completed for the day, and confirmed that production nearly always takes place between 08:00 and 13:00, occasionally extending to 14:00. He also confirmed that the bioscrubber odour was much stronger during production than we were currently observing.

He said that today was a slower than normal one because of a problem with a seal on one of the “cooking vessels” several days prior to our visit, that had been repaired the day previous, involving a leak of gas directly into the building interior, of which some escaped to the exterior through holes. He confirmed that smoke tests had been conducted and that some of the gaps had been filled, but this work was not complete.

We agreed that the leak event was not likely to have been related to the odour observed offsite during our present odour assessment.

We then toured the interior of the building, and viewed the production area (cooking vessels, centrifuge, filling and product storage areas). We then entered the evaporator room. In this space, I noted an odour similar to that we observed offsite though much less intense. However, this was nonetheless repellent, particularly to Maria. Mr O’Mahoney suggested that, since the evaporators were enclosed structures, the odour in the evaporator room probably derived from “washwater” at the bottom of the room which probably contained process liquids at the time, or odour that had entered from the adjacent filling area.


Page 5 of 5

This concluded the site tour. We then thanked Mr O’Mahoney for his courtesy and his time and exited the facility at 13:40.

Please quote the above document reference number in any future correspondence in relation to this

Statement.

Signed: ________________________

Peter Cunningham

Senior Inspector, Office of Environmental Enforcement

Dated: 16 May 2013


Attachments

Assessment of Odour Impact Field Record Sheet for 24 April 2013

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Issue Date: 07/0412009

Announced/Un-Announced ( U"'"'l -4t"/l•"'\.J:) C/YI._CA.. /

Observer is free from I Observer abstinence (30 Reason for odour---:::::::---~ Map- Has a map medical conditions min) from smoking, flavoured assessmen~ showing assessment

Have you been trained in the use of this procedure? If so, insert training

Weather Conditions Note 3 ;

{record wind info on\ (cold, sore throat, drinks, scented toiletries and verification; targeted locations been attached? page 2): · sinus trouble)? \ deodorisers? weatherlprocess; routine

visit; other (~nAr:ifv\ Procedurt

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I Remote (no housing, commercial/industrial premises or public area wirhin 500m of observation point} 2 Low sensitivity (nO housing,. commercial/industrial premises or public area within iOOm of observation point) 3 Moderate sensitivity (housing commercialfmdustrial premises or public area within iOOm of observation point) 4 High sensitivity (housing, commercial/industrial premises or public area within area of observation point) 5 Extra sensitive (complaints arising from residents, business and users of public areas within area of observation

point)

Note 2: Wind Strength 0 Calm Smok¢ rises vertically l Light air Direction of wind shown by smoke drift, but not wind vanes 2 Light Breeze Wind felt on face; leaves rustle, ordinary vane moved by wind 3 Gentle Breeze Leaves and small tw:igs in consrant motion 4 Moderate Breeze Raises dust and loose paper, small branches are moved 5 fresh Breeze Sma!l trees in leaf begin to sway 6 Strong Breeze Large branches in motion; umbrellas used with difficulty against the wind 7 Near Gale Whole trees in motion; inconvenience felt when walking against wind 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structural damage occurs (chimney pots and slates removed)

Precipitation- dry, rained recently, driZ?Je, raining, foggy Temperature- cold, cool, warm, hot

Note 4: Odour Persistence 0 NoOdour 1 lntcrmitt.::nt (detected imcrminently during the period of assessment) 2 Persistent (detected throughout the period of assessment)


0 No Detectable Odour I Faint Odour (barely detectable, need to stand still and inhale facing into wind) 2 Moderate Odour (easily detectable while walking and breathing normally.

possibly offensive} 3 Strong Odour (bearable but offensive- might make clothes I hair smell?) 4 Very Strong Odour (unbearable, difficult to remain in area affected by odour)

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Time on: I Do any of the, odours experi-enced on-s, ite match in llist .a. reas ~. pecjed: /] , '1{' ~What processes were. occurring dur.ing cha;acter tho9e recorded durin)l the surv.ey? j- • E·";' v<-~4,£:._,_~ "'""'-.)'/ the off-site odour assess,meflll.. 'B.Iuf(rvS k.v- £?<~! r, 1-"\..o • ~lort(rv :t-e..--... c-0 /'1o-.t~ {/()o{'-Cf7CI-/'- ' ~ ,,~''lv""-<--) L clO.[,Vf-: W~ . f c,~,L(vv-7 1~ ~ COod ~fa/) (.:_lfr.'l_l-· '.1' t'vo-11? (l n··>l <> r - }7~ (c..-- '-' vv~~ '(< ~ '.1 Y · · --. ' _ 7

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1 ~ 0 :!'! I 6 Slmng Bceeze Large bmnches in motion; ombcellas used with dHllcu!ty against dre wind 4 Very Strong Odour (unbearable, difficulrro remain in oceaolTcerod by odou') C ~ 7 NearC',.Ie Whole trm in motion: inconvenience felt when walking against wind

8 Gale Twigs br~:ak off trees; progress gcnc:ally impeded 1 9 Strong Gale Slight structural damage occurs (chimney pots and slates removed)

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I : Alan Stephens

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Note 1: Observation point sensitivity (assuming detectable, if not then 0)/ ~

N~;~~: Weather Conditions cvi'~Y_<( ~-., "' Prec · itation- dty, rained recently, drizzle, raining, foggy

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"' ~ > 4 High sensilivity (housing, commercial/industrial premises or public area \\iiliin area of observation point) 0 No Odour

i .cQ.O ... E~ 5 Extra sensitive (complaints arising from residents, business and users of public areas within area of observation I lntenninent (detected intennittently during the period of assessment)

·= 0 ..0 ______p!Jint) 2 Persistent (detected throughout the period of assessment) • coct~ 0 .S Note 2: Wind Strength Note 5: Odour Intensity : ,gEt: ct.~ OQ)Q)C: 0 C"m Smoke rises vertically z'U)~.Q I Light air Direction of wind shown by smoke drift, but not wind vanes 0 No Detectable Odour ,.. -

0 "' ~ 2 Ught Breeze Wind felt on fuec; leaves rustle, ordinary vane moved by wind I Faint Odour (barely detectable, need to stand still and inhale facing into wind) C) .. c: c: .. "' 3 Gentle Breeze Leaves and small twigs in constant motion 2 Modernte Odour (easily detectable v.hile walking and breathing nonnally, _,.,

4 Moderate Breeze Raises dust and loose paper; small branches are moved possibly offensive} "'~"' c: .0 0 5 Fresh Breeze Small trees in Ieafbegin to sway 3 Strong Odour (bearable but offensive- might make doilies I hair smell?) ~ .... ., QJCI)Q.) 6 Strong Breeze Large branches in motion~ umbreHas used with difficulty against the wind 4 Very Strong Odour (unbearable, difficult to remain in area affected by odour) J::::ll.i: 7 Near Gale Whole trees in motion; inconvenience felt when walking against wind .,_E 8 Gale Twigs break off trees; progress generally impeded

/c . . /

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9 Strong Gale Slight structural damage occurs (chimney pots and slates removed)

Time on: Do any of the odours experienced on-site match in List areas Inspected: What processes were occurring during character those recorded during the survey? · the off-site odour assessment?

........ -:::;- p . ( ·;; ::1 c: j vf ·- 0 Q) > -o E i _;::. 0 .. -~.,

Duration of Licensee's representativet(si met on site: v !'::Q)Q) Potential on-site odour sources identified: u.,., "< 0 visit: u._<

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Created by:AiarlStephens Revised by: Nicholas Kenny

Page 1 of2 Uncontrolled Once Printed Approved by.fG:·· ·eran '?'Brien. Programme Manager. S1gnature: f ./0' Date: -/7 ; /_/ <.

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Observer Location Wind (nd = if not detectable) Time Odour Rating_ Odour Descr_iE!ion Comments Name of household I Description of any odours, other source of odours

~ commercial site E "' etc, (Also note variable weather conditions etc) · ~ (d 'b th t 0 > " c Q) Qi escn eso a >- .J;:::-o c ,_ mo 0 o E location can be easily :=:= c £ .g m ..c E '3 0 :.c c >. ~ . . . :6. ... Q~ 22:-- 0, i=~ -a~ ._2 ._:=! ra Identified aga1n by a ·ro _ m 0 ..c ~ c ~ g c N t :::1 .Q ru ::1 -~ _,......._ v ::1 ~ ~1.0 . a. th' d rty · c !.0 ....... C> -~ > <ll ..c -- (l) ~t~ ~ ,_ 00 o .._ N <ll o <l.l r <t> ; 1r pa ,me. map m • o .=..co ·c: 0 o .bO E..,. w..a -a moo -o-oo ·

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Guide- A location where the score meets or ' .§ 31 ~ "' -- <: 3 - -g 5: ~ -- -- - 1 or 2 ?: 2 exceeds all the threshold values may be deemed ] 8 ~ ~ ~ ~ "g 2 subj_ect to n~isance/signifi?8nt impairment, ;

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l Assessment of Odour Impact Field Record Sheet '


F G

Astee, Co. Kerry

B

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1

Statement of Odour Assessment _______________________________________________ Contact name Mr. Jerry O’Mahony

Licensee name Brandon Products

Address Kilcolman

Address Asdee

AddressCo.Kerry

________________________________________________________________

Licensee: Brandon Products Licence Registration Number: P0957-01

Date of odour assessment: 24/04/13 Start time: 07:50 Finish time: 13:40

Date of issue of this statement: 17/05/13

This document’s reference number: Odour 2013-04-24

This odour assessment was undertaken by: Maria Lenihan

________________________________________________________________





Due to the findings of the odour assessment and the subsequent post assessment site visit to your

facility, as presented in the attached Field Record Sheet, it is the opinion of this Inspector that the

activities occurring on the premises of Brandon Products were causing the odours detected off-site.

The odours detected off-site and experienced on-site are of very serious concern to the Agency.

Below is an outline of the areas where I detected odour off-site.

• Inspector Cunningham and I began an odour assessment in front of -------------------------

(marked D in the map and associated odour assessment field sheet) at 08:59am. I

immediately got an unbearable sickening odour which was chemical in nature. This odour

was detected intermittently throughout the observation period. I felt nauseous and also felt a

pain in my lower chest. The wind was westerly in direction and downwind of Brandon

2

Products facility during Products facility during the five minute time period of this

observation. For this observation period I noted an odour persistence of 1 and odour intensity

of 4 on the attached Assessment of Odour Impact Field Record Sheet.

• Inspector Cunningham and I began an odour assessment at ------------------------- (Marked O in the

map and associated odour assessment field sheet) at 10:02 am. I got an immediate unbearable

sickening smell which was chemical in nature. This odour was detected throughout the observation

period and I felt nauseous and experienced pain in my lower chest. The wind direction was

northwest in direction and downwind of Brandon Products facility during the five minute time

period of this observation. For this observation period I noted an odour persistence of 2 and odour

intensity of 4 on the associated Assessment of Odour Impact Field Record Sheet.

• Inspector Cunningham and I began an odour assessment outside Brandon Products facility at

10:10am. I experienced the same unbearable sickening odour that I had detected off-site

intermittently during this observation period. I felt nauseous and felt like there was a lump in my

lower chest. The wind direction was northwest in direction and downwind of Brandon Products

facility during the five minute time period of this observation. This assessment confirmed that the

odours I experienced off-site were associated with the Brandon Products facility. For this

observation period I noted an odour persistence of 1 and odour intensity of 3 on the associated

Assessment of Odour Impact Field Record Sheet.

Inspector Cunningham and I met with complainants ------------------------- at 10:30am and informed

them we had confirmed odours off-site, that we had confirmed that the odours were associated with

the Brandon Products facility and that we both felt unwell after experiencing the odours.

• Inspector Cunningham and I carried out another odour assessment at ------------------------- (Marked

O in the map and associated odour assessment field sheet) at 11:35am. I got an immediate

unbearable sickening smell which was chemical in nature. I felt nauseous and experienced pain in

my lower chest. The wind direction was north to northwest in direction and downwind of Brandon

Products facility during the five minute time period of this observation. During this time period ---

---------------------- and ------------------------- joined us and confirmed that this odour was the odour that

they are experiencing albeit not as strong. For this observation period I noted an odour persistence

of 1 and odour intensity of 3 on the attached Assessment of Odour Impact Field Record Sheet.

Inspector Cunningham and I arrived at the Brandon Products facility at 12:00am and met with the

Production Manager Mr. Jerry O’Mahoney. I informed Mr. O’Mahoney that the Agency had received

3

a number of complaints in the last week in relation to the Brandon Products facility. I also informed

Mr. O’Mahoney that Inspector Cunningham and I had verified odours off-site at both ---------------------

---- and ------------------------- and that we both felt unwell after exposure to these odours. Mr. Jerry

O’Mahoney expressed his surprise that we had detected odour off-site and that I had recorded an

intensity of 4 on my attached Assessment of Odour Impact Field Record Sheet. I reviewed the odour

assessment carried by Brandon Products employee Ms. Mary O’Driscoll that morning and noted the

following:

1. The odour assessment began at the Brandon Products facility which is not in accordance with

Agency guidance AG5 and no odour was recorded.

2. The period of odour assessment at each location was one minute instead of the recommended

minimum five minute duration as per Agency guidance AG5.

3. No odour was recorded during this odour assessment. Inspector Cunningham and I were

experiencing an odour intensity of 4 at ------------------------- around the time Ms. Mary

O’Driscoll recorded an odour intensity of 0 at the facility and again at the crossroad (marked

E on the map and associated odour assessment field sheet). ------------------------- is located

between Brandon Products facility and this crossroad.

Based on the above the Agency deems that the odour assessments undertaken by facility employees

are unreliable and may be attributed to odour adaption.

Inspector Cunningham informed Mr. Jerry O’Mahoney that the odours being generated on-site are

causing nuisance off-site, that this is of serious environmental concern and needs to be addressed

straight away. A site tour was undertaken and this included the interior of the production building

which comprises three pressure vessels (cookers), a solids/liquid separation tank, a centrifuge, a fill

station, an evaporation room, ducting to the bioscrubber, raw material storage and final product

storage. I noted an odour in the area of the evaporator room, Mr. Jerry O’Mahoney stated that the

evaporator was fully enclosed but agreed that the odour may be emanating from the fill station

adjacent to the evaporator room and accumulating in the evaporator room. I had to move away from

the area as I starting getting a headache. At the back of the facility building Inspector Cunningham

and I viewed the cooling towers and the bioscrubber. Mr. Jerry O’Mahoney confirmed that the light

green coloured tank at the back of the facility is a cooling tower. The odour emanating from the

bioscubber at this time was of a musty bacterial nature and was not attributed to the odour detected

off-site. Mr. Jerry O’Mahoney confirmed that production had ceased and that the bioscrubber was not

in operation at this point in time. Mr. Jerry O’Mahoney stated that the odour emanating from the

bioscrubber during production was completely different in nature. I took a sample of the bioscrubber

liquid with the assistance of Mr. Jerry O’Mahoney and Mr. Jerry O’Mahoney signed the sample field

4

sheet for me. Inspector Cunningham and I also viewed the waste skip at the side of the facility which

is vented to the bioscrubber. Inspector Cunningham and I left the facility @13:40.


report.

Signed: ________________________ Name (print): Maria Lenihan

Title: OEE Inspector

Dated:


(Field Record Sheet Attached)

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point} 2 Persistent (detected throughout the period of assessment)

Note 2: Wind Strength Note 5: Odour Intensity 0 Calm Smoke rises vertically 1 Light air Direction ofwind shown by smoke drift, but not wind vanes 0 No Detectable Odour 2 Light Breeze Wind felt on face; leaves rustle, ordinary vane moved by wind 1 Faint Odour {barely detectable, need to stand sti!l and inhale facing into wind) 3 Gentle Breeze Leaves and small !Wigs in constant motion 2 Moderate Odour (easily detectable while walking and breruhing normally, 4 Moderare Breeze Raises dust and loose paper, small branches are moved possibly offensive) 5 Fresh Breeze Small trees in leafbegin to sway 3 Strong Odour (bearable but offensive- might make clothes I hair smell?) 6 Strong Breeu Large branches in motion; urnbre!las used with difficulty against the wind 4 Very Strong Odour (unbearable, difficult to remain in area affected by odour) 7 Near Gale Whole trees in motion; inconvenience felt when walking agalnst wind 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structural damage occurs (chimney pots and slates removed)

Time on: Do any of the odours experienced on-site match in List areas Inspected: What processes were occurring during character those recorded during the surveyJ the off-site odour assessment?

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Astee, Co. Kerry

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Address Kilcolman

Address Asdee

Address Co. Kerry

________________________________________________________________






________________________________________________________________





Due to the findings of the odour assessment, which detected moderate to strong, unpleasant odours

which caused health impact, as presented in the attached Field Record Sheet, it is the opinion of this

Inspector that the premises of Brandon Products was the source of the odours detected off-site, which

in the opinion of this Inspector constitutes Air Pollution. The odours and health impacts detected off-

site and experienced on-site are of very serious concern to the Agency.


I visited the locality of the Brandon Products facility at 16:30 on Tuesday 30 April 2013 to carry out an odour assessment. I noted that the weather conditions at the time were sunny and breezy,


Page 2 of 3

though the wind strength fell from around F 3-4 at the start of the exercise at 16:45 to F 1-2 at 17:15; I considered that this was partly due to differences in exposure of the different locations assessed.

I first undertook observation at four points located upwind and crosswind of the facility, commencing at Point “L” on the Beale Road. I observed no odour at any of these locations. I then proceeded to Point “D” (-------------------------), which was directly downwind of the facility at that time, 17:15. I immediately detected a “seaweedy” type odour; this was unpleasant and objectionable but not noticeably pungent. The odour was persistent and was mainly Moderate though occasionally Strong in intensity. I began to experience unpleasant sensations in my chest as a result of my exposure to the odour.

During that observation, I recorded a video clip on my phone. The images show the Brandon Products facility as filmed from the roadway outside -------------------------. In the course of that observation, I recorded the following commentary:

“You can see that there, its now, just about a quarter past five, Tuesday 30 April. I am standing outside ------------------------- in Astee, Co Kerry. I am just about 200m from the Brandon Products facility, and I’m on the coast road down to the beach. The wind is blowing directly from Brandon Products to me; I am detecting a characteristic kind of seaweedy type odour from the facility. I’d put the strength as Moderate, its pretty much persistent, its easily detected. Yeah, there it goes… you can smell it all the time, but it comes… it varies in strength; that was quite a whiff there now, I would put that as a Strong. So it’s Moderate to Strong, on the moderate, mainly Moderate score I would say. I’m not detecting any ammonia, but otherwise, it’s a… quite a characteristic seaweedy smell, kind of a... kind of an alginate type smell. The facility itself, it does not look like there is any activity going on there, one or two vehicles at it but otherwise nothing appears to be ongoing there at the moment, no trace of any emissions, very little noise. Oohh, there it goes again. So, I would say ------------------------- is right in the path, so…that would be a… that would be an unreasonably strong odour, this far off site, 200 metres. That would be… I would consider a non-compliant odour. I will pause this now, seeing one minute to go (inaudible) point five”.

Having satisfied myself that the source of the odour was the Brandon Products facility, I left the area at 17:20.

I returned to this Point “D” (-------------------------) 1.5 hours later, and repeated my observation, commencing 18:50; wind conditions were similar to the earlier visit to this location. The odour was similar in character to that noted at 17:15; it was intermittent on this occasion and varied between Faint and Moderate in intensity.

During the 18:50 observation, I recorded a video clip on my phone. The images show the Brandon Products facility as filmed from the roadway outside -------------------------. In the course of that observation, I recorded the following commentary:

“Now it’s ten minutes to seven on the same evening, 30 April 2013, and I’m back at Brandon Products. The same odour is present. There is now an individual standing outside the building, just walking around, I‘m not sure where exactly. When I walk up and down at ------------------------- again; as I walk up and down, the same odour once again, and this time its weaker than the last


Page 3 of 3

time, still easily detected, so I suppose I’m talking about a 1 to 2. Mmm, now that’s definitely a 2 at this point. I’ll pause it…”.

I then called to -------------------------. ------------------------- was also present. They described the nuisance and impact of the smell and expressed their frustration at how long the problem has been allowed to continue to affect them. They confirmed that both they and their family have been reporting the impacts of their health to their GPs and other health professionals.

I left ------------------------- at 19:15, at which time the odour was still evident.

Shortly afterwards, while I was en route to Ballybunion to spend the night, I stopped the car to make a note of the health impact symptoms I was feeling as a result of both exposures to the odour. I wrote “I am now experiencing a dry cough and a feeling of tightness in my chest in the region of my breastbone. The odour appeared less strong than that we experienced last Wednesday but the unpleasant impact on my health doesn’t seem that much less. I also have the odour in my nose again, despite having left the site around 10 minutes ago”.

For the rest of the evening, both these symptoms and the sensation that the odour was stuck onto me persisted.


Statement.

Signed: ________________________

Peter Cunningham


Dated: 16 May 2013


Attachments

Assessment of Odour Impact Field Record Sheet for 30 April 2013

http://www.epa.ie/

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Revision No.: 01

Issue Date: 07/04/2009 Enviruomenta! f~for~emcnt

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Observer is free from medical conditions (cold, sore throat, sinus trouble)?

Observer abstinence (30 Reasbn for odour min) from smoking, flavoured assessment- Complaint drinks, scented toiletries and verification; targeted deodorisers? weather/process; routine

Map- Has a map showing assessment locations been attached?

Procedure sec 82.3

Have you been trained in the use of this procedure? If so, insert training date ..

Weather Conditions Note 3 l

(record wind info on~ page 2): l

visit; other (specify). Procedure sec8.1.1 Procedure sec 8.2.1 Procedure sec 8.2.1

. .. . (Yes •. No J'u- ''-V\. 0' .... ~-·-\ /~ " ) (

Yes, No (Yes)_ No 11\j VI c. I rJ; TY / Yes No ate:- ·~ra. T-'j f---.N6te 1: ObServation poiilt<ensitivity (assuming detectable, if not then 0) "----~

1 Remote (no housing, commercial/industrial premises or public area wilhin SOOm of observation point) 2 Low sensitivity (no housing. commercial/industrial premises or public area within lOOm of observation point) 3 Moderate sep.sitivity (housing commercial/industrial premises or public area within lOOm of observation point) 4 High sensitivity (housing, commercial/industrial premises or public area within area of observation point) 5 ~ Ex:tra-~itive {complaints arising from residents, business and users of public areas within area of observation

point)

Note 2: Wind Strength 0 Calm Smoke rises vertically 1 Light air Direction ofwind shown by smoke drift, but not wind vanes 2 Light Breeze Wmd felt on face; leaves rustle, ordinary vane moved by wind 3 Gentle Breeze Leaves and small twigs. in co!\Stant motion 4 Moderate Breeze Raises dust and loose paper~ small branches are moved 5 Fresh Breeze Small trees in leaf begin to swey 6 Strong B~ Large branches in motion~ umbrellas used with difficulty against the wind 7 Near Gale Whole treeS in motion; inconvenience felt when walking against wind 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structura1 damage occurs (chimney pots and slates removed)

"Note 3: Weather Conditions Precipitation -dry, rained recently, drizzle, raining, foggy Temperature- cold, cool, warm, hot

Note 4: Odour Persistence 0 No Odour l Intermittent (detected intermittently during the period of assess:nent) 2 Persistent (detected throughout the period of assessment)


0 No Detectable Odour I Faint Odour (barely derecrable, ru:ed to stand still and inhale facing into wind) 2 Moderate Odour (easily detectable while walking and brearhing normally,

possibly offensive) 3 Strong Odour (bearable but offensive- might make clothes I hair smell?) 4 Very Strong Odour(unbearable, difficult to remain in area affected by odour) ' l

i

l (

Time on: I Do any of the odours experienced on-site match in character those recorded during the survey?

List areas Inspected: What proces~..were occurringduring l _ ... - 1- the·ofFSliecidour assessment? !

Duration of J Licensee's representatives(s) met on site: visit:

Created bv: Alan Steohens Approved by:_ !9eran q;~rien, Programme Manager.

Signature: k""" J!~ Date: ?Jtf./ 0

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Potential on-site odour sources identified:·

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Assessment of Odour Impact Field Record Sheet Page 2 of 2 Uncontrolled Once Printed

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Licensee Contact name: Mr. Jerry O’ Mahoney

Licensee name: Brandon Products Ltd

Address: Kilcolman

Address: Asdee

Address: Co.Kerry

________________________________________________________________

Licensee: Brandon Products Licence Registration Number: P0957-01(applied)



This document’s reference number: Odour 2013-05-01nod

This odour assessment was undertaken by: Niamh O’Donoghue

________________________________________________________________





Due to the findings of the odour assessment and the subsequent post assessment site visit to the


activities occurring on the premises of Brandon Products Ltd were causing the odours detected off-

site. The odours detected off-site and experienced on-site are of very serious concern to the Agency.

2


• Inspector Cunningham, Inspector Lenihan and I began an odour assessment in front of ----------------

--------- (marked D in the map and associated odour assessment field sheet) at 0856. I immediately

got an offensive odour which was musty in nature. This odour was detected persistently

throughout the observation period. The wind was west-southwest in direction and ---------------------

---- was downwind of the Brandon Products Ltd during the five minute time period of this

observation. For this observation period I noted an odour persistence of 2 and odour intensity of 3

on the attached Assessment of Odour Impact Field Record Sheet.

• Inspector Cunningham, Inspector Lenihan and I began an odour assessment in the field directly

behind Brandon Products facility at 0913. Mr. Trevor Montgomery Consultant for Brandon

Products Ltd accompanied us during this odour observation period. I experienced the same

offensive musty odour that I had detected at ------------------------- throughout this observation period.

The wind direction was west-southwest in direction and I was situated directly downwind of

Brandon Products Ltd. facility during the five minute time period of this observation. This

assessment confirmed that the odours I experienced off-site were associated with the Brandon

Products Ltd facility. For this observation period I noted an odour persistence of 2 and odour

intensity of 3 on the associated Assessment of Odour Impact Field Record Sheet.

Inspector Cunningham, Inspector Lenihan, Mr. Trevor Montgomery and I went to the bio-scrubber at

approximately 0915 and experienced the same offensive odour that I had noted earlier offsite and

were satisfied that the source of the offsite offensive odours experienced during the odour assessment

was the bio-scrubber.

Inspector Cunningham, Inspector Lenihan, Mr. Trevor Montgomery and I entered the Brandon

Products Ltd. facility at 09:30am and met with the Production Manager Mr. Jerry O’Mahoney. Peter

Cunningham informed Mr. Jerry O’Mahoney and Mr. Trevor Montgomery at the opening meeting of

the purpose of our visit, to follow up on odour complaints, and that the odour detected offsite, which

we were satisfied were emanating from their facility, on the 24/04/13 was deemed significant air

pollution by the Agency and requested information on the processes carried out on site and especially

3

in relation to the 24/04/13. Peter Cunningham also informed Mr. Jerry O’Mahoney and Mr. Trevor

Montgomery of the health effects on both him and Inspector Lenihan following the site visit on the

24/4/13, their subsequent Doctor’s visits and notification to the HSA. Inspector Cunningham also

informed Mr. Jerry O’Mahoney that he detected odours off-site at approximately 1715 and 1900 on

the 30/04/13.

Mr. Jerry O’Mahoney stated that the same basic production process is undertaken every day; that they

are cooking seaweed to which additions are made. He asked if they could put up a stack to disperse

the odour but, Mr. Cunningham informed him that we did not have the ability to give such

permission. Mr. Trevor Montgomery informed all present that the flow rate through the bio-scrubber

was modelled and operates around 6,000m3/hr; they turn on the associated fan every morning and it is

turned off when production ceases.

There are no written procedures in place for the maintenance of the bioscrubber on-site. Mr. Trevor

Montgomery informed all present that when the bio-scrubber was commissioned no records of any

control parameters were maintained. The ammonia levels were high in the bioscrubber liquid and that

the bioscrubber was optimised based on odour patrols. Mr. Trevor Montgomery informed all present

that sampling of the bio-scrubber is undertaken weekly for the total bacteria count at 22oC, ammonia

(which they try to maintain at <40mg/l), TKN (which they try to maintain between 80-100mg/l), and

occasional monitoring for BOD is done, levels of which are usually <100mg/l. Daily checks are

conducted for pH, O2 and temperature. There is no documented procedure for sampling and bio-

scrubber control.

Mr. Peter Cunningham informed Mr. Jerry O’Mahoney and Trevor Montgomery that an odour with a

persistence of 2 and an intensity of 2 is not an acceptable odour.

Mr. Jerry O’Mahoney described the processes carried out on-site. It is a batch process. The base raw

material is seaweed to which water or occasionally potassium carbonate is added and this is cooked at

150oC. It is an alkaline hydrolysis process. This occurs between 0930 and 1200 each day and the

material stays in the ovens overnight. At approximately 0800 the next morning, the cookers are

emptied into process tank 1 using compressed air; the material is pumped through a cooling system.

It is then pumped to process tank 2 through a sand separator and then through a clarifier to a storage

tank. The process finishes between 1200 and 1330 each day. The solid material goes to an onsite

skip which is sent for composting. Liquid waste from the clarifier goes back into the process for re-

use. Every second day and occasionally 2 days in a row the product is evaporated and concentrated

(now referred to as 9% base extract). The vapours are condensed and the hot water re-used in the

boiler. The product is then stored in the concentrate tank external to the building. This product is

either filled as concentrate or converted to different formulations based on customer requirements.

4

Mr. Jerry O’Mahoney stated that there are no vapours from the formulations aspect of the process as it

is a cold mix process.

I undertook a review of the records for the operation of the evaporator. In January 2013, it operated

on the 03, 09, 28 (not clear in records), and 29. In April 2013, it operated on 02, 03, 04, 05, 09, 10,

12, 15, 16, 17, 18, 19, 23, 25 and 30.

At approximately 1100 Inspector Cunningham, Inspector Lenihan and I detected a stronger odour in

the meeting room and asked Mr. Jerry O’Mahoney and Mr. Trevor Montgomery if any particular

process was starting on-site. They both answered no and could not detect the stronger odour that the

Agency inspectors detected at that time.

The Odour was discussed in further detail and Mr. Jerry O’Mahoney and Mr. Trevor Montgomery

were informed by the team that we felt there were 2 types of odour associated with the facility; one

musty odour as experienced that day and a second more pungent odour experienced by Inspectors

Cunningham and Lenihan on the 24/4/13. I informed Mr. Jerry O’Mahoney and Mr. Trevor

Montgomery that the difference between these odours and there source onsite needs to be understood

by the site management in order to be controlled. Inspector Lenihan informed Mr. Jerry O’Mahoney

and Mr. Trevor Montgomery that the residents sometimes link the odour to when there is steam from

the cooling towers; however; Mr. Trevor Montgomery stated that the cooling system is non-contact

with the product and any leaks would be noted as they would result in a black colour on the towers.

Mr. Jerry O’Mahoney was asked of the possibility of odours being generated from the formulation

process and I reviewed the records to identify which formulations were being conducted on the 22nd

and 23rd April around the time the Agency received odour complaints. Examples of the formulations,

in 250ml bottles) were brought into the meeting by Mr. Jerry O’Mahoney and their odour was

assessed. I had the following assessment:

1. Triple 30 (Concentrate only) = no significant odour

2. 14-0-0 + 0.5% fe = Very strong pungent offensive odour

3. Maerit (concentrate) + Fe = no significant dour

4. 18-0-0 = organic type odour mildly offensive

At 1145 the meeting ended and Inspector Cunningham, Inspector Lenihan, Mr. Trevor Montgomery

and I went to the bio-scrubber and I noted a strong odour, musty in nature. At 1155 we entered the

production room and I got a strong odour as soon as I entered. Mr. Trevor Montgomery gave us a

tour of the production area. Inspector Lenihan noted holes in a number of doors in the production and

evaporator areas of the building and pointed these out to Mr. Trevor Montgomery as a source of

fugitive emissions. One of the roller doors to the west of the building had a gap at the bottom of the

5

roller door there was a gap in the roof area of the evaporator room where a pipe was situated to pump

out wash water from the sump within the evaporator room. Wash water from the production

floor/formulation area runs via an open drain to a sump in a corner of the evaporator room. I found

the odour in the evaporator room very pungent especially over the open drain area. Inspector Lenihan

had to leave this area and as she stated the odour made her nauseous; both Inspector Cunningham and

I left very soon afterwards due to the intensity of the odour.

A closing meeting was held and all were present as in the opening meeting. Mr. Peter Cunningham

informed all present that he was feeling unwell after the visit and while it looked like the bio-scrubber

is the main source of the odour, there are also fugitive emissions from the site contributing to the

odour issue from this facility. Mr. Peter Cunningham also stated that due to the nature of the odour

action would have to be taken very quickly by the facility to deal with the issue and the Agency may

also take action via a Section Notice. Mr. Trevor Montgomery stated the facility would have a

proposal into the Agency the following week in relation to the odour situation. Inspector

Cunningham, Inspector Lenihan and I left the facility at 1225.


report.

Signed: ________________________ Name: Niamh O’Donoghue

Title: OEE Inspector,

Dated: _________________________



http://www.epa.ie/

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Time on: J Do any of the odours e_ xperienced on-site match in list areas Inspected: I What processes were occurring during : character those recorded during .the survey? the off-site odour assessment?

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Contact name Mr. Jerry O’ Mahoney


Address Kilcolman

Address Asdee

AddressCo.Kerry

________________________________________________________________






________________________________________________________________








The odours detected off-site and experienced on-site are of very serious concern to the Agency.

2


• Inspector Cunningham, Inspector O’Donoghue and I began an odour assessment in front of ---------

---------------- (marked D in the map and associated odour assessment field sheet) at 08:56am. I

immediately got a pungent odour which was musty in nature. This odour was detected

intermittently throughout the observation period. The wind was west-southwest in direction and

downwind of ------------------------- during the five minute time period of this observation. For this

observation period I noted an odour persistence of 1 and odour intensity of 3 on the attached


• Inspector Cunningham, Inspector O’Donoghue and I began an odour assessment in the field

directly behind Brandon Products facility at 09:13am. Mr. Trevor Montgomery Consultant for

Brandon Products accompanied us during this odour observation period. I experienced the same

pungent musty odour that I had detected off-site throughout this observation period. The wind

direction was west-southwest in direction and directly downwind of Brandon Products facility

during the five minute time period of this observation. This assessment confirmed that the odours

I experienced off-site were associated with the Brandon Products facility. For this observation

period I noted an odour persistence of 2 and odour intensity of 3 on the associated Assessment of

Odour Impact Field Record Sheet.

Inspector Cunningham, Inspector O’Donoghue, Mr. Trevor Montgomery and I moved towards the

bioscrubber. As I approached the bioscrubber I got a seaweed/musty smell and the odour emanating

directly from it was at an odour intensity of 4. I had to move away from the bioscubber due to the

odour impact.

Inspector Cunningham, Inspector O’Donoghue, Mr. Trevor Montgomery and I entered the Brandon

Products facility at 09:30am and met with the Production Manager Mr. Jerry O’Mahoney. Inspector

Cunningham informed Mr. Jerry O’Mahoney and Mr. Trevor Montgomery at the opening meeting

that the odour detected on the 24/04/13 was deemed significant air pollution by the Agency and

requested information on the processes carried out on site on the 24/04/13. Mr. Jerry O’Mahoney

stated that the same process is undertaken every day, that they are cooking seaweed and adding raw

materials. I confirmed to Mr. Jerry O’Mahoney that I deemed the intensity of the odour at a level of 4

at the outlet from the bioscrubber and that I deemed the intensity of the odour at a level of 3 at ----------

--------------- on this date (01/05/13).

Inspector Cunningham informed Mr. Jerry O’Mahoney that he and I felt unwell on the afternoon and

night of the 24/04/13 and that both of us went to the doctor as a result due to our concern regarding

3

our health. Inspector Cunningham also informed Mr. Jerry O’Mahoney that he detected odours off-

site at @17:30 and 19:00 on the 30/04/13.

Mr. Trevor Montgomery informed all present that the flow rate through the biosrcubber is always

around 6,000m3/hr, that they turn on the associated fan every morning and that this fan is turned off

when production ceases. There are no written procedures in place for the maintenance of the

bioscrubber on-site. Mr. Trevor Montgomery informed all present that when the bioscrubber was

commissioned the ammonia levels were high in the bioscrubber liquid and that the bioscrubber was

optimised based on odour patrols. Mr. Peter Cunningham informed Mr. Jerry O’Mahoney and Trevor

Montgomery that an odour with a persistence of 2 and an intensity of 2 is not an acceptable odour.

Mr. Jerry O’Mahoney described the processes carried out on-site to all present. The formulations

used on site are based on customer requirements and Mr. Jerry O’Mahoney stated that there are no

vapours from the formulations aspect of the business as it is a cold mix process. At 11:00am

Inspector Cunningham, Inspector O’Donoghue and I detected a stronger odour in the meeting room

and asked Mr. Jerry O’Mahoney and Mr. Trevor Montgomery if any particular process was starting

on-site. They both answered no and could not detect the stronger odour that the Agency inspectors

detected at that time.

I stated during the meeting that the bioscrubber may not be the only odour source on-site. At 11:57am

Inspector Cunningham, Inspector O’Donoghue, Mr. Trevor Montgomery and I went to the

bioscrubber and I noted a strong odour which was musty in nature. At 11:57am we entered the

production room and I got a strong odour as soon as I entered the production room. I noted holes in a

number of doors in this area of the building, one of the roller doors to the west of the building had a

gap at the bottom of the roller door and I noted a gap in the roof area of the evaporator room where a

pipe was situated to pump out wash water from the sump within the evaporator room. Wash water

from the production floor/formulation area runs via an open drain to a sump in a corner of the

evaporator room. I found the odour here nauseating and I got a headache. I had to leave this area and

I noted that I still had a headache at 12:18am after leaving this area. I pointed out the gaps in the

doors and roof to Mr. Trevor Montgomery and stated that these were sources of fugitive emissions

from the processes undertaken on-site.

A closing meeting was held with all present as at the opening meeting. Mr. Peter Cunningham

informed all present that he was feeling unwell after the visit and while it looked like the bioscrubber

is the main source of the odour there are also fugitive emissions from the site contributing to the

odour issue from this facility. Mr. Peter Cunningham also stated that they could be looking at a

temporary suspension in relation to this matter. Inspector Cunningham, Inspector O’Donoghue and I

left the facility at 12:26am.

4


report.



Dated: _________________________



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Issue Date: 0710412009

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Precipitation- dry, rained recently, drivJe, raining, fo&.ny I Re-mote (no housing, commerciallinJustrial premises or public area within 500m of observation point) Temperature- cold. cool. warm, hot 2 Low sensitivity (no housing, commerciaVindustrial premises or public area within lOOm of observation point)

Note 4: Odour Persistence 3 Moderat~ sen$itivity (ho~ing commercial/industrial premises or public art!a within lOOm of observation point) 4 High sensitivity (housing, commerciaVindusuial premises or public area within area ofobseiVation point) 0 No Odour

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Note 2: Wind Strength Note 5: Odour Intensity 0 Calm Smoke rises vertically 1 Light air Din:ction of wind sho.,.,'Jl by smoke drift, but not wind vanes 0 No Detectable Odour 2 Light Breeze Wind fc:lt on tace; leaves rustle. ordinary vane moved by wind 1 faint Odour (barely detectable, ne~:d to stand still and inhale tacing imo wind) 3 Gentle Brec·zc leaves and small twigs in constant motion 2 Modt!ratc Odour (easily detectable while walking and breathing normally, 4 Moderate Brcez~ Raises dust and loose paper; small branches are moved possibly offensive) 5 Fr~h Breeze Sma11 trees in leaf begin to sway 3 Strong Odour (bearable but offensive- might make clotht::s I hair smell?)

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Time on: Do any of the odours experienced on-site match in List areas Inspected: What processes were occurring during

character those recorded during the survey? tJo.fc.JcA-6~. the off-site odour assessment?

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Address Kilcolman

Address Asdee

Address Co. Kerry

________________________________________________________________






________________________________________________________________





Due to the findings of the odour assessment, which detected very strong and objectionable odours

which caused health impact, and the subsequent post assessment site visit to your facility, as presented

in the attached Field Record Sheet, it is the opinion of this Inspector that the activities occurring on

the premises of Brandon Products were causing the odours detected off-site, which in the opinion of

this Inspector constitutes Air Pollution. The odours and health impacts detected off-site and

experienced on-site are of very serious concern to the Agency.


Inspectors Maria Lenihan, Niamh O’Donoghue and I visited the vicinity of the Brandon Products Ltd facility on the morning of 01 May 2013 to evaluate complaints of noxious odours causing health


Page 2 of 5

impacts on residents that have been received by the Agency and to visit the facility to observe production processes and activities at the facility and to review records maintained by the operator.

Our odour assessments were conducted simultaneously but independently, and commenced at 08:00 (according to my watch; note that I did not synchronise my watch with those of Inspector Lenihan or Inspector O’Donoghue). As recorded in my Odour Assessment Log (attached), I did not observe any unusual odour at any of the first six locations, which were located either upwind or crosswind from the facility. At the next location, a sensitive receptor labelled “D” (------------------------) and lying approximately 200m directly downwind from the facility at that time (commenced 08:57), I noted what I describe as a “seaweedy, objectionable smell”. I also noted noise from the facility. I ascribed a Persistence of 1 (1.5) (“intermittent [to semi-persistent”]) and an Intensity of 2-3 (“Moderate to Strong”) to the odour. It was evident to me that this odour originated at the Brandon Products Ltd facility which was directly upwind of my position at that time.

After completing that observation, we went to the Brandon Products facility. As we arrived at the facility, we met Mr Trevor Montgomery of Montgomery EHS Ltd. We moved to the rear of the facility, accompanied by Mr Montgomery and performed individual odour assessments commencing at 09:15. We positioned ourselves directly on the line between the facility and ------------------------- which was directly downwind of us at that time. I again noted what I describe as a “seaweedy, odour, no pungency like last week’s but very sickening nonetheless”. I ascribed a Persistence of 2 (“Persistent throughout the observation”) and an Intensity of 2-3 (“Moderate to Strong”) to the odour I observed at this location.

I recorded a video clip on my phone at the rear of the Brandon Products facility, commencing 09:15. I recorded the following commentary:

“This is the morning of the first of May, Wednesday 1st of May 2013. We are on… in the vicinity of the Brandon Products facility right now, and we are just standing at the rear of the facility, probably about 20 to 25 metres from the nearest point, and we are getting… I am getting, oohh, a moderate to strong, seaweedy, “biomassy”, rotting biomassy type of an … oohh, odour that doesn’t again have the same pungent ammonia nose that I had previously, but its still strong, well, moderate to strong, but, ah, objectionable odour from the facility, from possibly the rear; the bioscrubber appears to be in operation as I passed it, there was vapour emanating from it, the smell was slightly different there though, it has this smell but something else as well. So clearly, clearly this is the source of the objectionable odour we were getting at -------------------------. (Inaudible)… Trevor Montgomery”.

We concluded the odour assessment at 09:20, and then moved to the location of the bioscrubber, where Mr Montgomery outlined the system and how it was designed to operate.

We then entered the Brandon Products facility at 09:30. We were met by Mr Jerry O’Mahoney, Production Manager. A meeting took place during which I expressed the Agency’s view that, as evidenced by the noxious and sickening emissions observed by Agency inspectors on the previous Wednesday, 24th April, the previous evening, 30th April and that morning, the facility’s operations were causing Air pollution in contravention of the Air Pollution Act 1987.


Page 3 of 5

I stated that the purpose of this visit was to establish what production activities were ongoing at the time of the noxious odours / emissions from the facility that were detected by Agency inspectors, and to review production records and related documentation. I also asked for details of the commissioning and testing of the air abatement system. Mr O’Mahoney stated that the main production process was always the same, varying only slightly depending on business needs. Mr Montgomery described the commissioning of the bioscrubber to deal with emissions from the process; previously, these had been released with no abatement. He confirmed that no control parameters had been documented regarding the optimal operation of the abatement system, and stated that standard operating parameters had been established during the commissioning phase which were used to control the operation. The temperature of the bioscrubber solution is however continuously monitored and maintained above 14°C.

Mr O’Mahoney then described a typical production campaign in fine detail, and outlined the time schedule for each part of the process leading to the main “base” product, a liquid concentrate derived from the high pressure cooking of granulated seaweed. Two forms are made according to requirements, “Aqueous” from an initial feedstock of seaweed granules and water, and “Alkaline”, to which Potassium Carbonate is also added.

The base products may be sold as they are or may be used in formulation of additional products by the addition of chemicals according to customer requirements.

It was noted that vapour / air emissions arise from a number of steps in the process, including high pressure cooking, centrifugation and evaporation steps. Formulation is also a potential source of odour. Variability from day to day is mainly in the formulation aspect of the activity, the basic process is similar from day to day. Inspector Lenihan commented that the bioscrubber odour was in her view not the only noxious odour emanating from the facility and that there is also a fugitive component. Inspector O’Donoghue stressed that the operator must understand the nature and origin of all noxious odours before these can be successfully controlled.

Inspector O’Donoghue then discussed the range of chemicals listed in the licence application documentation as being used on site. Mr O’Mahoney commented on the use of each. Many were noted to be ingredients of recipes specified by various customers.

Mr O’Mahoney presented bottles containing a selection of formulations. We all sniffed the bottles; one in particular, “14-0-0 + 0.5% Iron”, had a very pungent and noxious smell, while several others had little or no odour.

I reviewed the production records for 2013; these agreed with the statement that the main production process did not vary significantly from day to day.

I requested copies of the production records for 2013 and an excerpt from the formulation record (the batch numbers include the date of formulation), which were supplied by Mr O’Mahoney. I confirmed to Mr O’Mahoney that details contained in company records that we were taking offsite were considered to be commercially confidential and would not be published or made available to any third party.


Page 4 of 5

At 11:55, a site tour commenced. We first visited the bioscrubber to verify its operational status. It was found to be exhausting an odour which I found intolerable, increasing my sense of being unwell.

We toured the inside of the production building and looked at the various parts of the infrastructure, including the process control board. We viewed the formulation area (no activity), and entered the Evaporator room; the Evaporator was not in operation. Possible sources of fugitive emissions were noted in the evaporator room, including a washwater sump for the main process area, and several breaches of the structure (walls and doors) were also observed.

I noted a strong odour in the evaporator room, as did my colleagues. We agreed to terminate the site tour at that point.

A brief closing meeting was held. I reviewed our observations, and commented that we considered there were at least two odour issues at play, the bioscrubber exhaust and a fugitive element. I stated the Agency’s position that the company was not entitled to operate in a manner that caused air pollution, and that we were considering the options open to us in response. I stated that it was in the company’s interests to immediately implement significant measures to address the problem.

Mr Montgomery undertook to make a submission to the Agency within one week with the operator’s proposals.

We thanked Mr O’Mahoney for his courtesy and for his time and likewise Mr Montgomery, and left the premises at 12:30.

I remained in the area for several hours conducting other business, and carried out a final downwind odour check at 16:05 at location “E”, the “Store” premises. At that time the wind was light and was blowing directly from the facility to me. I noted a “seaweedy / biomass / bacterial broth type odour”. I ascribed a Persistence of 1 (“Intermittent”) and an Intensity of 2 (“Moderate”) to the odour I observed at this location.

As before, on the journey home after the visit, I continued to experience a sense of being unwell, with chest discomfort and moderate nausea. Again, I found the smell from the facility to be “stuck in my nose”, and I continued to perceive it for most of the afternoon and evening. However, by next morning I felt better and decided not to return to my GP on that occasion.


Statement.

Signed: ________________________

Peter Cunningham


Dated: 16 May 2013


Page 5 of 5


Attachments

Assessment of Odour Impact Field Record Sheet for 01 May 2013

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Licensee/Facility: Reg. No:--\ Assessment by f.) [/ I A. A - .' 1\ m;;,11\ I Date offnspection Announced/Un-Announced i

Iii"'~ '()rdvcb Observer is free from medical conditions (cold, sore throat, sinus trouble)?

If Ui>t 17a~:~~~;~ctor(s)\~::~): u;1"Z:,7I(vo~C>l ol/o)/2<J~ UN ·!l Observer abstinence. (30 Reason for odour / Map- Has a map Have you been min) from smoking, flavoured assessment- Complaint showing assessment trained in the use drinks, scented toiletries and verification; targeted locations been attached? of this procedure? deodorisers? weather/process; routine If so, insert training

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No Ye!l) No C....'Ti o r-J Yes No Ui/{rc "';+-Note 1: Observation poinriensitivity (assuming detectable, if not then 0)

1 Remote (no housing, commerciaVindustrial premises or public area within 500m of observation point) 2 Low sensitivity (no housing, commercial/industrial premises or public area within lOOm of observation point) 3 Moderate sensitivity (housing commercialfmdustrial premises or public area within lOOm of observation point) 4 High sensitivity (housing, commercial/industrial premises or public area within area of observation point) 5 ~ Exna-.s;ensitive (complaints arising from residents, business and users of public areas within area of observa.tion

point)

Note 2: Wind Strength 0 Calm Smoke rises vertically 1 Light air Direction of wind shown by smoke drift, but not wind vanes 2 Light Breeze Wind felt on face~ leaves rustle, ordinary vane moved by wind 3 Gentle Breeze Leaves and small twigs in constant motion 4 Moderate Breeze Raises dust and loose paper; small branches are moved 5 Fresh Breeze Small trees in leafbegin to f>W'iJ:y 6 Strong Bi:eeze Large branches in motion; umbrellas used with difficulty against the wind 7 Near Gale Whole trees in motion; inconvenience felt when walldng ~"<i!IlSI: wind 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structural damage occurs (chimney pots and slates removed)

Note 3: Weather Conditions Precipitation- dry, rained recently, drizzle, raining,. foggy Temperature- cold. cool, warm. bot

Note 4: Odour Persistence 0 NoOdour I Interminent (detected intermittently during the period of assessment) 2 Persistent (detected throughout the period of assessment)


0 No Detectable Odour 1 Faint Odour (barely detectable, need to stand still and inhale facing into w:ind) 2 Moderate Odour (easily detectable while walking and brea!hing normally,

possibly offensive) 3 Strong Odour (bearable but offeruive- might make clothes I hair smell?) 4 Very Strong Odour (unbearable, difficult to remain in area affected by odour)

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Time on: I Do any of the odours experienced on-site match in character those recorded during the survey?

List areas Inspected: - What processes were occurring during ;

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Guide- A location where the score me.ets or ' -os ' .,., - 2:3 - "" -- - - 1 or 2 2:2 exceeds all the threshold values may be deeme~ ~:;.sB .s.a-:::0 0 0 co: s= S X O.!!J subject to nuisance/significant impairmen~ ; ~ o.~:: 1QC:O particularly if the observations are supported by l, (t)-"0- C:'-'-(J) ._ ca c ::::1 ~o.o-

pubflc complaints on impact, frequency and j .:::.:::-c 0 0. ~ , ... - o«= duration of odours. !

'

I );} i(rr~{ + u·vJ W)vJ 2 ()!l':o <; 0 0 \

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Brief details of any meeting with local residents/complaints received during assessment (include names/addresses/telephone numbers etc): . ~lf?<-'t o-d-. ~~-~ ~

- c"1 [;,__;pf-PJ ct·· CI_/. , C ( C C.. /r ~-4-i { ...... ./}----{ '~ i..,_L v, -c-1 .:'..J[ P, ,, v ,, ') ) >

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~~:g-.!CO> >., E ,a.o "' =;~ ";::: .. "'< ., u._<

~ Doc. Ref. No.: FP011-001 Procedure- Site Inspection; Assessment of Odour Impact

0QQ9 Revision No.: 01 Field Record Sheet

Issue Date: 07/04/2009 Env .. ronment~l Enf<><Ce.-.ent

licensee/Facility: Reg. No. Assessment by Date of in~ection Announced/Un-Announced 1

'brCf\J.c.<V\ ':jr. ro 7>r-- Your name: :~ (JSP-ff'J CN ('f-"VF>'"l-1 , (other lnspector(s)prese II): rjs;)/}fJf) U?-1 - .4.

Observer is free from Observer abstinence (30 Reason for odour Map- Has a map Have you been Weather l

medical conditions min) from smoking, fiavoured assessment- Complaint showing assessment trained in the use Conditions Note 3 ! (cold, sore throat, drinks, scented toiletries and verification; targeted locations been attached? of this procedure? (record wind !nfo on} sinus trouble)? d eod orisers? weather/process; routine If so, insert training page 2). ,

visit; other (specify). Procedure sec 8.2.3 dat., . j

Procedure sec 8.2.1 Procedure sec 8.2.1 Procedure sec 8.1.1 f"Yy' No C:"V(<'Vj r' ~ 5 .,[ "'-"'-1 CicJA Yes; No Yes', No jjc:..Jl c)r,_J Yes No Date:

['-N'ote 1: Observation poihk(;nsitivity (assuming detectable, if not then 0) Note 3: Weather Conditions i: Precipitation- dry, rained recently, drizzle, raining, foggy I

I Remote (no housing, commercial!industriai premises or public area within 500m of observation point) Temperature- cold, cool, wann, hot i 2 Low sensitivity (no housing, commercial/industrial premises or public area within lOOm of observation point)

Note 4: Odour Persistence ~( 3 Moderate sensitivity (housing commercial/industrial premises or public area within lOOm of observation point) 4 High sensitivity (housing,. C<lmmercialrmdustrial pronises or public area within area of observation point) 0 No Odour \ i

5 -,El¢a~sitive {complaints arising from·residents, business and users of public areas within area of observation I Intermittent (detected intermittently during the period of assessment) t point) 2 Persistent (detected throughout the period of assessment) f Note 2: Wind Strength Note 5: Odour Intensity ! 0 Calm Smoke rises vertically ~ 1 Liglrrair Direction of wind shown by smoke drift, but not v.'ind vanes 0 No Detectable Odour f 2 Light Breeze Wind felt on face~ leaves rustle, ordinary vane moved by wind I Faint Odour {barely de[eCtabJe, need to stand still and inhale facing into wind) I 3 Gentle Breeze Leaves and small twigs iD constant motion 2 Moderate Odour (easily detectable while walking and breathing nonnally, ' ' 4 Moderate Breeze Raises dust and loose paper; small branches are moved possibly offensive) ·,

l 5 Fresh Breeze Small trees in leaf begin to swey 3 Strong Odour (bearable but offensive- might make clothes I hair smell?) l 6 Strong Bieeze Large branches in motion; umbrellas used wilh difficulty against the wind 4 Very Strong Odour (unbearable, difficult to remain in area affected by odour) I· 7 Near Gale Whole uees in motion; inconvenience felt when walking against wind 8 Gale Twigs break off trees; progress generally impeded I 9 Strong Gale Slight structural damage occurs (chimney pots and slates removed)

Time on: Do any of the odours experienced on-site match in list areas Inspected: What processes were occurring during \ character those recorded during the survey? · the off-site odour assessment? t

.-------~~! l -··' -·· -··- --~·--··· I -~--·

Duration of Licensee's representaliYes(sfmet on site: Potential on-site odour sources identified: visit: .- --·····

.-' --~--------

_...--

-.... -· r ' Created bv: Alan Stephens Revised bv: Nicholas Kenn

Approved by;_ ~eran <?Jlrien, Programme Manager. Signature: k>v>.. rJI~ Date: 7/ ?/

0 Y Pagel of2 Uncontrolled Once Printed

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N

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Doc. Ref. No. FPO l HJO l-0 I Observer location Wind (nd; if not detectable) Time Odour Ratin~ Odour Description Comments '

Name of household I Description of any odours, other source of odouns

~ commercial site E "' etc, (Also note variable weather conditions etc) : l!l (describe so that

0 c:> z c: "' i

~~ "'" 0 " " :0 0 ~ E'l 015 c:

E location can be easily ·-"' :0 ·:; 0 3: me:.-.. £ ·-" 2 "' z ~ Ol 1--oo "0~ 3 '(j) -...r,o ~ identified again by a :o:;..C(/) ~"'"' ~"' "' ·Ci5-m c:CI);:: C:N t:5 .g m ~-- v Q.

third party, inc. map c:<n~ fL.Q ~ -~ .0 13 ~2 (\)Z o~Nw o~"'f<D "' • 0 -= ..c 0 QOrn ~ 0

05~ "'"' -om •o -o ....... o ......

ref.) (f) ~z 03::0 ~~ (f)z CLo 0 o.. Sz 0 E --~

-os Guide- A location where the score meets or l

! Cl) 't:l - ;,3 - "' -- - - 1 or2 "2 exceeds all the threshold values may be deeme~ :!2:i.S8 .so-..:o _gori~ S X O .l!J subject to nuisance/significant impaimnen~ ,

Cl) (,) ·- c.o •OC:O particularly if the observations are supported by I Q,) .... "0- C:'-'-(l) 'I... as c ::s ~a.. 0-

public complaints on impact, frequency and l .:=£-c 0 a. ~ a..: duration of odours. '

store: 4- ~C-J ppcJ 1-L {6~o) j i z_ ':J.eec ~~1tfc r -' · ·/_.,. _ _..~I · td.f.- • I

,r 0'-~r::,.-- I t~kr,-v--J ~'1. r !

i

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"' ' ~ ' ' " I

"' .0 0 "0 a; u::

Brief details of any meeting with local residents/complaints received during assessment (include names/addresses/telephone numbers etc):

' ' '


F G

Astee, Co. Kerry

B

A

P

C

D

E

H

I

J

K

O

L

M

R

1




Address Kilcolman

Address Asdee

AddressCo.Kerry

________________________________________________________________






________________________________________________________________








The odours detected off-site are of very serious concern to the Agency.

2

Below is an outline of the area where I detected odour off-site.

• During odour assessments at ------------------------- (marked D in the map and associated odour

assessment field sheet) between 12:54 and 12:59, between 13:19 and 13:30 and between 14:15 and

14:20 odour was detected intermittently. The wind was predominantly west-southwest in direction

and downwind of Brandon Products facility during the observation periods. For these observation

periods I noted an odour persistence of 1 and odour intensity of 2 on the attached Assessment of

Odour Impact Field Record Sheet.

I entered the Brandon Products facility at 14:23 and met with the Production Manager Mr. Jerry

O’Mahoney and consultants Trevor Montgomery and Guy Meredith. Trevor Montgomery informed

me that two cooks were completed that day and of the following works completed and planned to

address odours being detected off-site:

1. A new stack was installed on Monday 17/06/13 (there were no process operations on that day).

2. Two ozone units are now both discharging into the stack generating 6.8g of ozone per unit.

3. Work had been completed with regard to sealing the doors; a temporary repair has been completed on the doors while they await the delivery of new doors.

4. A contractor has been engaged to spray foam all the internal cladding and this work will be carried out during the week of the 24th June 2013.

5. The operating temperature of the decanter has been reduced from 70oc to 50oc.

6. The diameter of the top of the stack is going to be reduced from 600mm to 300mm and a new fan has been ordered. The purpose of this is to increase the velocity of emissions through the stack. The fan is due to arrive on the 11th July.

I informed all present that I had detected odour at ------------------------- intermittently with an intensity

of two that day. I also informed all present that I had got a call from ------------------------- on the

18/06/13 to inform me that the smell was unbearable, that ------------------------- had detected the odour

at 12:00pm that night and that I had received a text message from ------------------------- that morning

(19/06/13) at 10:26am to say that the smell was as bad as ever.

Trevor Montgomery informed me that he had carried out a number of odour assessments at night time

and that he had never detected odours off-site. I informed all present that Inspector Cunningham had

detected odours after 19:00 in the area.

3



Dated: 26/06/13



http://www.epa.ie/

General

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Observer is free from medical conditions (cold, sore throat, sinus trouble)?


Field Record Sheet


Revision No.: 01

Issue Date: 0710412009 - -

Reg. No. Assessment by Date of inspection Announced/Un-Announced

fo1Js7-ol Your name:/Y/PJt.io.. ~·Aot1 1 (other lnspector(s) present): !9/ot/13 ti;"Z-A/Ino"'l"la.,(

Observer abstinence (30 Reason for odour Map Has a map Have you been }, Weather min) from smoking, flavoured assessment- Complaint showing assessment trained in the use ConditiOns Note 3 i drinks, scented toiletries and verification; targeted locations been attached? of this procedure? {record wind info oni deodorisers? weather/process; routine If so, insert training page 2): ' ! visit; other (specify). Procedure sec 8.2.3 5~<ate.

Procedure sec 8.2.1 Procedure sec 8.2.1 Procedure sec 8.1.1 ~ No

M...n t-d.<if . Yes) No Yes) No ~,.,,/..,£ 1/t,<.rfi~J,i,-, Ye§) No Date: ::.~/o'f.foq Note 1: Observation point sensitivity (assuming detectable, if not then 0) Note 3: Weather Conditions

Precipitation- dry, rained recently, drizzle, raining, foggy i

1 Remote (no housing, commercial/industrial p;emises or public area within 500m of observation point) Temperature- cold, cool, warm, hot 2 Low sensitivity (no housing. commerciaVindustrial premises or public area within 1OOm of observation point)

Note 4: Odour Persistence f 3 Moderate sensitivity (housing comrnerciallindusrrial premises or public area within lOOm of observation point) 4 High sensitivity (housing, commercial/industrial premises or public area within area of observation point) 0 NoOdour ' 5 Extra sensitive (complaints arising from residents, business and useiS of public areas within area of observation 1 Intermittent (detected intermittently during the period of assessment) ;

point) - 2 Persistent (detected throughout the period of assessment)

Note 2: Wind Strength Note 5: Odour Intensity 0 Calm Smoke rises vertically 1 Light air Direction of wind shovm by smoke drift, but not wind vanes 0 No Detectable Odour 2 Light Breeze Wind felt on face; leaves rustle, ordinary vane moved by wind l Faint Odour (barely detectable, need to stand still and inhale facing into wind)

3 Gentle Breeze Leaves and small twigs in constant motion 2 Moderate Odour (easily detectable while walking and breathing normally.

4 Moderate Breeze Raises dust and loose paper; small branches are moved possibly offensive)

5 Fresh Breeze Small trees in leafbegin to sway 3 Suong Odour (bearable but offensive- might make clothes I hair smel!?)

6 Strong Breeze Large branches in motion; umbrellas used with difficulty against the wind 4 Very Srrong Odour (unbearable, difficult to remain in area affected by odour)

7 Near Gale Whole trees in motion; inconvenience felt when walking agalnst wind 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structural damage occurs (chimney pots and slares removed)

Time on: Do any of the odours experienced on-site match in List areas Inspected: What processes were occurring during

111-: :;2.3 character those recorded during the survey? J IV/A the off-site odour assessment?

/J.r /_u..i..ud -''- --.J;?l ,<c oft' J /:.. of ./",/,£,(! t>1f:F.,. 'UJ.. <>',./ ,.,{tff' _.._,.-u

Duration of Licensee's r~resentatives(s) met on site: Potential on-site odour sources idenf1fied:

visit: tAv..<. ;?7.,. •'"-""(f . tfl..o,...~du ----;;- 0, /"l~h•£ -

th.Ly JIZ..~.t: t .

i

Doc. Ref. No. FPOII-001-01 . - .

Observer Location Wind (nd =if not detectable) Time Odour Rating Odour Description Comments "-, Name of household I Description of any odours, other source of odours

~ commercial site . E '" etc (Also note variable weather conditions etc) ' 2 ( 'b t'h 0 > "' c Q) • • m descn e so at >- .;:: u c L m u 0

u E ....... c o ID Eo .._ -- c "' location can be easily :2 5 ·;; ~ ~ ~ £ ·- d o 1il 2 £ ~ . 'fi ' ....... "'""" -- ...... ..... Ol 1-cr:: '"0 2: .... (/l ,_ ca ldenttted agam by a ·oo -. m 0 £ <n c ::g i::. c N t 5 .Q Q) ::J ·Ul -. ~ ::J ~ 910 a. third party, inc. map § U? 0 -~ E ~ -~ Q T5 ~ ~ ~; Ql ~ .g aJ 6 '* .g -E o -5

ref.) Cl) Sz 0 3::0 0 --~ Cl) z {f)£::. a.. o 0 a.. .._z 0 _ -z .

Guide- A location where the score meets or · -l!l"' " --- > 3 -- u ~ ~ -- -- -- 1 or 2 2:2 exceeds all the threshold values may be deemeiJ o ~ ~ g - ~ ';; o -:il subject to nuisance/significant impainment. ; ~ ~ :S ~ C. 2 ~ ~ particularly lf the observations are supported by i .;: ~ .5 ~ 3 §:

0 1D public complaints on impact, frequency and

1- ..... 8 <C u duration of odours.

O.o lf-l4.l~,v, R.d ll , 1 j ., ff 0 R.fS I Q (';r) 'T f,J-.-f tftJM-" 1 /2: 3/ S • "" ... ~.t .;, k~<lv 3 I . J I ' - 11 " '.. g s 0 0 i

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. . " !o_ n " 3 Jlf.:!> s I :?.. IJ'~. ' Brief detailS or any meeunr w 11 " .nr~l rPc:.i<l.onrc:/rnmnhint<:. rf'l'PivPri rinrino:r ~<:<:P.<:.<:.ment (include name_c:/arldreso;;es/telenhone numbers etc):

,f.ftc/ fJJ. /._ ',t_-h.~~£ ft._ ;,..,dl J l:l.:"ol'."" /.-rf ,..,,~J.:I.,- . ~-,;-.A£ f1J. fk s-~ wPr u;'>~-..Jk. !:'1"':£""';/. tJ ~ ,JJ ... ,..,._._,! ,.,.._ :!i-" fl s-~ lvrl "''1~..1 ct' el/u... J fp;/)!)N"J f},-. ~.c./l'CJ ·;:; ,;.k #!"' ~V>T I' , I

!f•··-" o:l it. iN ""'-1 o-'ke/ ;>7..._1;,. d.;! li_ f-~6~ ~ ~ ~"''if .P~/Tl . . I ' '

\ Assessment of Odour Impact Field Record Sheet Page 2 of2 Uncontrolled Once Printed ---- -- -- ]I

F G

Astee, Co. Kerry

B

A

P

C

D

E

H

I

J

K

O

L

M

R

1



Address Kilcolman

Address Asdee

AddressCo.Kerry

________________________________________________________________


Date of odour assessments: 20/06/13 Start time: 15:00 Finish time: 21:54




________________________________________________________________

As per the criteria stated above odour assessments were undertaken in accordance with EPA Air


Record Sheets that were completed during the odour assessments have been copied in full and is

attached to this Statement of Odour Assessment.

Due to the findings of the odour assessments as presented in the attached Field Record Sheets, it is the

opinion of this Inspector that the activities occurring on the premises of Brandon Products were

causing the odours detected off-site. The odours detected off-site are of very serious concern to the

Agency.

Below is an outline of the area where I detected odour off-site during the odour assessment I carried

out between 15:00 and 16:58.

• During an odour assessment at ------------------------- (marked D in the map and associated odour assessment field sheet) between 15:36 and 15:41 odour was detected intermittently, varied in intensity between 1 and 3 and was musty in nature. The wind was southwest in direction and downwind of Brandon Products facility during the observation period. For this

2

observation period I noted an odour persistence of 1 and odour intensity of between 1 and 3 on the attached Assessment of Odour Impact Field Record Sheet.

After experiencing odour at ------------------------- as described above I experienced a slight tightness in

my chest and did not go to the Brandon Products facility to confirm the source of this odour for health

and safety reasons. In addition my previous experience of this odour has confirmed that the source of

the odour is from the Brandon Products facility.

Below is an outline of the area where I detected odour off-site during the odour assessment I

completed between 18:46 and 19:47.

• While walking on the road between ------------------------- (marked D in the map and associated

odour assessment field sheet) and ------------------------- (marked R in the map and associated

odour assessment field sheet) as part of an odour assessment I detected intermittent odours

varying in intensity between 1 and 2. I walked into the field located at the back of the

Brandon Products facility. As I walked towards the back of the Brandon Products facility I

detected odour intermittently varying in intensity between 1and 2. The wind was west-

southwest in direction and downwind of Brandon Products facility during the observation

period.


report.



Dated: 26/06/13



http://www.epa.ie/

~ I l Procedure- Site Inspection; Assessment of Odour Impact .. er,a ! . I ReviSIOn No.: 01

r:;;:;," · ! Field Record Sheet . '"''""""'"' I Issue Date. 07/04/2009 Cntorcc~ncc.~ ~ l

Doc. Ref. No.: FP011-Q01

1 General I Licensee/Facility: Reg. No. Assessment by Date of inspection Announced/Un-Announced

I ~.....,.tl' ~ . .L-.t Po<J$7-ol Your name:f7~..<; .. ,ft;,,}.gl) #.o/ut/13 lLr.- ff/U>o,.,-,t:e..t:l (other lnspector(s) present):

I§" Observer is free from I Observer abstinence (30 Reason for odour Map- Has a map Have you been Weather medical conditions min) from smoking; flavoured assessment- Complaint showing assessment trained in the use Conditions Note 3 i

, Eo

1

(cold, sore throat, drinks, scented toiletries and verification; targeted locations been attached? of this procedure? (record wind info on( I ".., " " sinus trouble)? deodorisers? weather/process; routine \ Procedure sec 8.2.3

If so, insert training page 2); e ~ I " " visi~ other {specify). date. I"" <t" Procedure sec 8.2.1 Procedure sec 8.2. 1 Procedure sec 8.1.1 Yes) No ;;!f{-) dJ<Jz.~~ . Q,C: I ~ -=-JO..

Yes/ No Yes)_ No (;,.,JJJ~,d- ~,.h~~ ~Yes/ No Date: :;,. /" lf. I olj_ i I 'Note 1: Observation point sensitivity (assuming detectable, if not then 0) ~ Note 3: Weather Conditions

"' " Precipitation- dry, rained recently, drizrJc:, raining, foo.:£Y I -5 i: '1? 1 Remote (no housing, commercia1/industrial premis~ or public area within SOOm of observation point) Tempera:rure- cold. cool, wai;m, hot J c rn .9! ' 2 Low sensitivity (no housing,. commercia1fmdustrial premises or public area within lOOm_ of observation point)

Note 4: Odour Persistence ! I g § Cii 3 Moderate sensitivity (housing commercialfmdusrricl premises or public area within lOOm of observation point) \ !1l 2 ~ 4 High sensitivity (housing, commerciaVindusrrial premises or public area v.ithin ~of observation point) 0 No Odour . ~ ~ _! S Extra sensitive (complaints arising from residents, business and users of public areas within area of observation I lntenninent (detected intermittently during the period of assessment) ' .: 0 ..0 POint) 2 Persistent (detected throughout the period of assessment) ' t {/,1 0 s . Note 5: Odour Intensity .3 E c UJ Note 2: Wmd Strength ! o ,g ~ g 0 Calm Smoke rises vertically

0 No Delectable Odour , Z ~ 3: :;: 1 Light air Direction of wind shown by smoke drift. but not wind vanes ' 0 ~ ~ 2 light Breeze Wind felt on face; leaves rustle, ordinary vane moved by wind 1 Faint Odour (barely detectable, need to stand still and inhale facing into wind) ~ ~ c:;o 3 Gentle Breeze Leaves and small tw:igs in constant motion 2 Modemte Odour (easily detectable while walking and bresthing nonnally.

".i: c» ~ 4 Moderate Breeze Raises dust and loose paper, small branches are moved possibly offensive) § ..a O 5 Fresh Breeze Small trees in leaf begin to sway 3 Strong Odour (bearable but offensive- mlght make clothes I hair smell?) ~.,. 0 :9 6 Strong Breeze Large branches in motion; umbrellas used with difficulty against the wind 4 Very Strong Odour(Lmbearnble, difficult to remain in area affected by odour) ~ g ~ 7 Near Gale Whole trees in motion;. inconvenience felt when walking against wind ~ - 8 Gale Twigs breakoff trees; progress generally impeded [

9 Strong Gale Slight structural damage occurs (chimney pots and slates removed) ·i Time on: I Do any of the odours experienced on-site match in List areas Inspected: What processes were occurring during I character those recorded during the survey? the off-site odour assessment?

!1i5'g i

-00) I ~(3 E '

~ (ll ' ::;m Duration of Licensee's representaiives(s) met on site: Potential on-site odour sources identified: ! " "' "' Ill:~~ visit

I i I I

Created by: Alan Stephens Revised by: Nicholas KenQY_ Approved by:_l)leran 0,'§\rien, Programme Manager. Stgnature: Kd .... j):{__,__ Date: 7 ; 1 /,(,

Pagel of2 Uncontrolled Once Printed

Doc. Ref. No. FPO!l-001-0l - -- --- - -

Observer Location Wind (nd =if not detectable) Time Odour Rating Odour Desc~ion Comments l \ Name of household I Description of any odours, other source of odours 1

I ~ commercial site E "' etc, (Also note variable weather conditions etc) • 1 2 (describe so that 0 c> " c (!) . I

I " ~ ~~ 0 ~ Q)U 0 " E location can be easily "> ·- <ll .c t=S 0~ c ~ ~ 0 3: <UC:- 0, ·-U QJ

I ideniified again by a ::::. ..... :o::;...C::U) -mz. !--~ -o> ~v; ~ ·w -<0 rn ·ro-ru COJ t6 0 ~ :::i·- v I a. g_g;:: c Ul·-

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<ll ' 0 6~:§ "'~ m.o b~ 2.~ -o-oo I 0 Q.~ -0 -v

ref.) (f) ::=. z (f)Z (/)f!. D..o 0 .E-z

i I "0~ Guide- A location where the score meets or ' !

"'-, - "3 - Q) -- - - 1or2 "2 exceeds all the threshold values may be deemed I ~:;.e~ .s 0 ..... :0 0 0 Itt t: ~X 0!'! subject to nuisance/significant impairment, ~ Q .£ ~ • 0 c u particularly if the observations are supported by : f-;-g·s c ._ '- a) ;: a.o- - ' .:c..c-c: 0 a. ~ public complaints on impac~ frequency and ,_.~

o<e duration of odours.

e.J!.iwr;or> Rl tS~I(j\ )f. Wed lc,.fl,.wtf (J,.,,~J If l~:oo 5. 0 0

I

l!P~.f. L j (AI 3 ls • .llwa-1. /).._ ..,.) If )t.s:o& s 0 D / : .

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"' § $ " n 3-'t- /$:2.$ s (I <V o.t ..... v..-,! ,p,.., ~ '""""''~of 1-3 ~-'k. ~ I s ,, " 3-LJ. /S: 3£ s l 1._ -..3.. t-t.. ~ -~. m. ,_,f"" ,_,_ 1: 6

._ u: ...

' " IJcn'·'A""JJ "' ~') 5. H 3 IS>Sif .s t) 0 ,.0 ' I 0 r~ ~ 6.J.1''f"t-. ...... ~ '"' () () . .-~ 6N( 1-c

r \ s I ! /J•wtlwJ/1 ~ 3 0 j]! ! )) /t:Z:> s i) d- <ZJ: <?- /1'1.. ~ ""&- 17/ bb /1 '3 ~<::Jf

lu. ... ) 5 n lh!N'/";WI~J 3 I 6 ::ss 5 I I

(/ (/ I

I I ' -I ~ n I).WIJM/>J 3 /6: If/ s\ 0 0

I lc..., ... .....e t«.k sr-. I s I ' $" tJ.d /)..-11"-/lt>l. If- ft:lf7 ~ 0 I lrJ. ..,1./-f.f,J.J/£) Brief details of any meeting with local residemslcomnl::~inr': r~c-~ived during assessment (include names/addresses!teiephone numbers etc):

.A1,"6: A.f/u. k.,'j_ ~ J , f .fdQ "' r~ ~~ ,,..,_ c.k,-t::_ > {Jq.f - IJ...,..,......J If- £6: SJ S I I

'

I

' j Assessment of Odour Impact Field Record Sheet '


I General

i I

~~c

~ eQ9

Et.vi:o.om~n,~: :nmr<:~~~~"'

Licensee/Facility:

fo95 7- of Observer is free from medical conditions (cold, sore throat,


Field Record Sheet


Revision No.: 01


Reg. No. Assessment by Date of insoection Announced/Un-Announced

PoCJ51-0f Your name: (lj.,.,(;.. ,4,.rtf""'

i (other lnsoectoris'\ oresent: J.o J•t je, U, _fJ,.,.oWit< j Observer abstinence (30 Reason for odour Map- Has a map Have you been Weather ' min) from smoking, flavoured assessment- Complaint showing assessment trained in the use Conditions Note 3 i drinks, scented toiletries and verification; targeted locations been attached? of this procedure? (record wind info on;

f (ij~ \u sinus trouble)? deoclorisers? weather/process; routine If so, insert training page 2): f " ~ <11"' visi~ other (specify). Procedure sec 8.2.3 date. ' I~~ Procedure sec 8.2.1 ;,a. Procedure sec 8.2.1 Procedure sec 8.1.1

IQ:eS) No \ll;- i>-¢4{. ~

Jl. j(l'es) I ~eS) (;p,j#/.v,.t V!/.th<..fi •n 1.1\'es r Date: :l.•/•4/ o q No No No

I Note 1: Observation point sensitivity (assuming detectable, if not then 0) '-PNote 3: Weather Conditions

I "' " Precipitation- dry, rained recently, drizzle, raining, foggy ' ~ :5 '; l Remote (no housing, commerciallindusnia! premis~ or public area within 50 0m of observation point) Temperature-cold. cool. warm,. hot ' ' ! i

, c t» ~ 2 Low sensitivity (no housing,. commercialfmdusoi.al premises or public area 'i>Jithin lOOm of observation point) Note 4: Odour Persistence I ~ Ji Qi 3 Moderate sensitivity (housing commerciaJJindustrial premises or public area within lOOm of observation point)

I Q) .E! ~ 4 High sensitivity (housing, commetciallindusoi.al premises or public area within area of observation poinr:) 0 No Odour ' I ,S ~ .2 5 Extra sensitive (complaints arisingfrnm residents, busin= "ld "''""of public areas within area of obsmation I Intenninent (detected intennittently during the period of assessment) 2 Persistent (detected throughout the period of assessment) ' ..E o .c point)

O.l!J Note 5: Odour Intensity m E ::: GO Note 2: Wind Strength I o $ _g g 0 Calm Smoke rises vcrrically 0 No Detectable Odour Z ~ 3: +: I I Light air Direction of wind shown by smoke drift. but not wind vanes

0 -g ~ 2 Light Breeze Wmd felt on face; leaves rustle, ordinary vane moved by wind 1 Faint Odour (barely detectable. need to stand still and inhale facing into wind) ;? 0 Ol 3 Geo.Ue Breeze Leaves and sm.al1 twigs in constant motion 2 Modernte Odour (easily detectable whlle walking and breathing nonnally, 32 ; ,.2 4 Moderate Breeze Raises dust and loose paper, small branches are moved possibly offensive) ~ .c o 5 Fresh Breeze Small trees in leafbegin to sway 3 Srrong Odour (bearahle but offensive- might make clothes I hair smem) 1... 1i) ::E 6 Strong Bree:z:e Large branches in motion; umbrellas used with difficulty against the wind 4 Very Strong Odour (Wlbearable, difficult to remain in area affected by odour) ~ ~ ~ 7 Near Gale Whole trees in motion; incor.venience felt when walking against wind ""- - 8 Gale Twigs break o!Tttees; progress generally impoded

9 Srrong Gale Slight structural damage occurs (chimney pots and slares removed)

Time on: Do any of the odours experienced on--site match in List areas Inspected: What processes were occurring during character those recorded during the survey? the off-site odour assessment?

..,.1-:o:;"

:i5~ > "0 "' .&:- 0 iii =~m Duration of Licensee's representaiives(s) met on site: Potential on-site odour sources identified: 0 0::: Cf.l "'<( <11 visit: u._<

' -I Created by: Alan Stephens I Revised bv: Nicholas Kenn

i Approved by." .. l)ieran o:Sl,rien, Programme Manager. . .I Page 1 of2 Uncontrolled Once Printed J Signature: /-G.,..-~ r£~~ Date: 7 j 1 1" (,

Doc. Ref. No. FPO!J-OOl-0! I Observer Location l Name of household I

~ i commercial site -1

~ 1\ (describe so that

1 g location can be easily i ~ 1 tdentified agam by a ' o. I ihird party, inc. map I ' 1 I ref.)

II ~ 'C 1 ~-s.a8· I .co cat=

1 cno~«< I ~(G-o.!2 I ..c..c·S" c l lr--

k)l /L!IJ,_,.,., fl./ £S5!/J)

·o

.0 ·;;;

~221' <]) ' 0 (j) =::..z

:;,3

Wind (nd = if not detectable)

E T "' g"O , c> c£ ! Qt 2 ~ U)\1 1§ ~ >: " c ~ a>Q;: mm= ..... ..c 0 ._.0·-0 ~:a 0 Q_~

-os " .so ...... JS S X 0 2

I Q C Q r- '- I- /l) ~D.. 0 ...... 0 "- <])

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(/)Z

Time

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Odour Rating

<])

" c Q)

~u;

5"§N! "'0 Q) ' 0 0 0.. S.z

1 or 2

.0 :J "ijj -<o OC-q-a> -o26o OE-z

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1{.../f./....J. (/l 3 0 ()

Odour Description Comments -I Description of any odours, other source of odours ! etc, (Also note variable weather conditions etc) 1

Guide- A location where the score meets or exceeds all the threshold values may be deemed subject to nuisance/significant impairment, ' particularly if the observations are supported by \ public complaints on impact, frequency and : duration of odours.

I l

~ c 0

~ 5 3 (J 0 ---Q) ~ .0

~~ I~ 1"\

fp

£)

;.,:;1tfr-'1s) I

s 1 ] I la .. ,.,,li 3-lfi.n=to 1 s 1 o 1 [J

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7!'

" a..., ..., ... .t\ 3 JN-fl_ I s I o I 0

\

. Brief details of any meeting with local residents/complain to::. received during assessment (include names/addresses/telephone zwmbers etc): 1 _,~_ L._ # 1;_., :Z \ / k..JL __

;U>i "'-""!kiAq Y~ en-d.. /;Cf4< /e:h"'-zi..d' /~r:i7'7ViV o~U '_)tv<>.. .

I""' lld/. fl.../~ ~ kJ'~"~ ~ ~c.W i?~ ~#ed=;: ~ 1~9.. .

I -

Assessment of Odour Impact Field Record Sheet Page 2 of 2 Uncontro//eri Once Printed

~ epa ~ Ofii:c ;f.

i:nv''""''"'"t.:i <mur<~oo~c.::

I General \ Licensee/Facility: I

~f&~r.u~otV PII!~#Vt.?"IS' I

\ Lfo"JS7-of

lc ! Observer is free from

I "' <:: 1 medical conditions


Field Record Sheet

Reg. No. 1 Assessment by

0 I ! Your name:;"l1...;.. .L,;;.,

f/~>"1 S1- ! (other lnspector(s) present):


Revision No.: 01


Date of inspection Announced/Un-Announced

;I.e> jo{ /;3. Un-4.noW1tL£ Observer abstinence (30 Reason for odour Map Has a map Have you been Weather min) from smoking, flavoured assessment- Complaint showing assessment trained in the use Conditions Note 3 ;

' " 0 I {cold, sore throat, drinks, scented toiletries and verification; targeted locations been attached? of this procedure? (record wind info on) I ti;·-! tl)~ sinus trouble)? deodorisers? weather/process; routine If so, insert training page 2): ' "' ~ I "' " visi~ other (specify). Procedure sec 8.2.3 date. 1"'0. <l:" Procedure sec 8.2.1 Procedure sec 8.2. i Procedure sec 8.1.1

·~ {);<JZ?. ~.) -Fo} , ~ No ' IJ> 0.. jO: ~

y~ No 'Yes) No I Yes) No Date: ;zof6'f/O'f ( Note 1: Observation point sensitivity (assuming detectable, if not then 0) Note 3: Weather Conditions

' "' "' Precipitation- dry, rained recently. drizzle, raining, foggy l -5 :5 ~ l Remote (no housing. corrunercial/industrial premises or public area within 500m of observation point) Temperature- cold. cool, warm, hot ' 1 c Ol,.!!:! 2 Low sensitivity (no housing, conunercial/indllSll'ia! premises or public azea within 1OOm of observation point)

Note 4: Odour Persistence ' i g :§ t 3 Moderate se.'lSitivity (housing commercia1/"md~ prem]ses or public area within lOOm of observation point) l en $. ~ 4 High ~tivity (housing, conunerciallindllSll'ial premises or public area within area of observation poiru) 0 No Odour ' ! :6 g- 41 5 Extra sensitive (complaints arising from r<!Sidents, business and users of public aree:s within area of observation 1 Intermittent (detected intennittently during the period of assessment) i .= 0 :c -point} 2 Persistent (detected throughout the period of assessment} \ ,.,oJ!I N ° W"dS h Note 5: Odour Intensity 41 E .c: tr.l _ ote -= m trengt

0 2 ~ g l 0 Calm Smoke rises venically ' 1 Z ~ 3: ~ I 1 Light air Direction of wind shown by smoke drift. but not wind vanes 0 No Detectable Odour

Q) ~ ~ 2 Light Breeze Wmd felt oo fuce; leaves rustle, ordinary vane moved by wind 1 Faint Odour (barely detectable, need to Stand still and inhale facing imo wind) ~ "' ell 3 Gentle Breeze Leaves and small twigs in coosranr motion 2 Modernte ()door (easily detectable while walking and bre£!!hing normally, .'

~ ; ~ 4 Moder.tt.e Breeze Raises dust and loose paper. small branches are moved possibly offensive) ' ; .c O 5 Fresh Breeze Small tiees in leaf begin to swey 3 Strong Odour (beamhle but offensive- might make clothes I ha.lr smell1) '- 1;; !!. 6 Strong Breeze Large branches in motion; um.brellas used with difficulty against the wind 4 Very Strong Odour (unbearable, difficl.llt to remain in are:! affected by odour) ~ ~ ~ 7 Near Gale Whole trees in motion; inconvenience felt when walking against wind

, ~ 8 Gale Twigs break offtrees; progress generally impeded

I 9 Strong Gale Slight structural damage occurs (chimney pots and slares removed) i

I Time on: \ Do any of the odours experienced on..site match in List areas Inspected: What processes were occurring during

I I character those recorded during the survey? the off-site odour assessment? j~~:o--:;-

E!o(i; > 'C E .Jl-0 "' =:u~ Duration of Licensee's representatives(s) met on site: Potential on-site odour sources identified: 0 0:::: tr.l

~!i< visit:

I I I

' Created by: Alan Stephens

Pagel of2 Uncontrolled Once Printed I Approved bY~--·eran C?,'~rien, Programme Manager. I S1gnature: ./; .r'J;/ Date: 7 1 '!. c. ' / 0--... t !JI2r-~ r / er. r) ~

- --·--

Revised by: Nicholas Kennv

I

I I

Doc. Ref. No. FPO ll-00 1-0 l I I Observer Location Wind (nd =if not detectable) Time Odour Rating Odour Descfii>tion Comments I I Name of household I Description of any odours, other source of odours

I ~ commercial site E "' etc, (Also note variable weather conditions etc) : " I (describe so that ~~ c> " " "' " -"" 0 ~ <l)U 0 <.>

\

E location can be easily ·-"' .<: E9 0~ c

I !!! -;:; o:S \ro2:- 0, ·-U 2 a

identified again by a :;::: ...-- U..cm c~.c r-~ "'"' ~"' :S ·oo .-.10

"' "ii.i-(1) eN -eil 0 ~ :::3·-...-..'<t

I n. 0 ·- ·-"' 0 ~"' Q) og"'fiD 1 third party, inc. map c"' ~ -~ ::c ~ -~ .0 ~ <D " "'" ~"' "' ' 0 1"'-a <ll.o "OQ)•- u-oo

0 ;: :01 0 !2..@ ~~

0 D.. 2.~ ! I f.) (/) :::.. z [J)Z [J)f:!. o_ 0 OE-z . I i rer.

I "' \ I Guide- A location where the score meets or '

~~~"'~ - "3 - TIS "' -- - - 1 or 2 "2 exceeds all the threshold values may be deemed -:::3,_.0 -~ 0 ...... :a subject to nuisance/significant impairment. ' 0 0 ~ c S x og ~0~~ I Q C () particularly if the observations are supported by \ ' Q)-"0- I C1-'-<D

''-~t:::J! 5:o.o--).!:J:·-c

I a. "' public complaints on impact frequency and \i- ..... 8~ "0 duration of odours.

~L.,;." £,l'f-,.,(k.' J.f. s..Jl...uf I i¥""' 11-" 3 :;.o:JI-7 5 (J (J I

' I• 1/.>:S/ (f \ /f ~.D--fi U.,v'"J 3 0 ' ,.. ;;l.b: s s s: 0 I

.RJ.h Ll. {.II~ 3 rJ.,.,d- \ Ow~~>•'Nf 3 iZI' aS s 0 0 I '• jj

~ '/ g SeJ/1..4 /2wll<.nuJ:. 3 :u::Z.'(; 5 tJ 0 ' "' I ~ '

r c~ 1{ k:;jj,..j( aii"IJ{,.N,£ 3 w:?s 5 0 (J '

ll ' 'o) 5 'Do.Jl..af /)r.n~wJ~ 3 :ZI: tf;Z 5 0 0

,~ !?.' 5 kJl..,f aw~-1 1 3 ~:f'f s D 0 I,

\

i

I I I

I Brief details of any meeting with local residents/complaints received during assessment (include names/addresses/telephone numbers etc):

! Assessment of Odour Impact Field Record Sheet ) Page 2 of 2 Uncontrolled Once Printed

F G

Astee, Co. Kerry

B

A

P

C

D

E

H

I

J

K

O

L

M

R

1



Address Kilcolman

Address Asdee

AddressCo.Kerry

________________________________________________________________






________________________________________________________________





Due to the findings of the odour assessments and the subsequent post assessment visit to the facility,

as presented in the attached Field Record Sheets, it is the opinion of this Inspector that the activities

occurring on the premises of Brandon Products were causing the odours detected off-site. The odours

detected off-site are of very serious concern to the Agency.



• While walking on the road between ------------------------- (marked D in the map and associated

odour assessment field sheet) and ------------------------- (marked R in the map and associated

odour assessment field sheet) as part of an odour assessment I detected intermittent odours

2

varying in intensity between 1 and 2. The wind was westerly in direction and downwind of

Brandon Products facility. I met Trevor Montgomery and Guy Meredith in the area of ---------

---------------- and informed them that I had detected odours on the road between Eamonn -------

------------------ and -------------------------. Trevor Montgomery confirmed that he had also

detected intermittent odours in the same area this morning. Trevor Montgomery, Guy

Meredith and I walked back down the road and I detected odours intermittently varying in

intensity between 1 and 3 and highlighted these odours as I detected them to both Trevor

Montgomery and Guy Meredith.



• During an odour assessment at ------------------------- (marked D in the map and associated odour assessment field sheet) between 10:18 and 10:23 odour was detected intermittently and varied in intensity between 1 and 3. The wind was southwesterly in direction and downwind of Brandon Products facility during the observation period. For this observation period I noted an odour persistence of 1 and odour intensity of 1-3 on the attached Assessment of Odour Impact Field Record Sheet. I felt a slight tightness in my chest during the observation period.

• During an odour assessment at ------------------------- (marked D in the map and associated odour assessment field sheet) between 10:54 and 10:59 odour was detected intermittently and was caustic in nature. The wind was southwesterly in direction and downwind of Brandon Products facility during the observation period. For this observation period I noted an odour persistence of 1 and odour intensity of 3 on the attached Assessment of Odour Impact Field Record Sheet. During this observation period ------------------------- called me over to a front window of ------------------------- house. ------------------------- had told ------------------------- that the smell had come in ------------------------- when ------------------------- opened the window.

• I walked through the field located at the back of Brandon Products facility and towards the

bioscrubber. The wind was southwesterly in direction and downwind of Brandon Products

facility during the observation period. For this observation period I noted an odour

persistence of 1 and odour intensity of 2 on the attached Assessment of Odour Impact Field

Record Sheet.

------------------------- asked me to come into his farmyard at 12:00am as the smell had been bad in his

yard. I did not detect the smell when l arrived in the yard. I met a person in the yard who did not want

to give his name but informed me that the smell was unbearable as he went into the yard. While

talking to him we both detected the odour intermittently at an intensity of 1. He compared the smell

to nitrogen fertiliser when it gets wet.

3

I entered the Brandon Products facility at 12:35 and met with the Production Manager Jerry

O’Mahoney and consultants Trevor Montgomery and Guy Meredith. As I entered the building I

detected the same odour in the hallway and meeting room that I had detected off-site and informed all

present of this. Jerry O’Mahoney confirmed that no formulations were undertaken this week, that 2

cookers were in operation on Wednesday, 3 cookers were in operation on Thursday and that 3 cookers

were in operation on Friday. Standard hydrolysis methodology was utilised during the week. I

informed all present of my odour assessment findings on the 20/06/13 and on the 21/06/13 as well as

details of the complaints that I had received during the week regarding odours from the facility. Jerry

O’Mahony stated that as the odours were intermittent this week that this indicated that the works

undertaken to date were leading to an improvement in odours. I informed Jerry O’Mahoney that even

if the odours are intermittent, they are still at nuisance level in intensity and that this situation is

unacceptable for the residents being impacted by these odours.


report.



Dated: 26/06/13



http://www.epa.ie/

J:.

Doc. Ref. No.: FP011-001 ~ Procedure- Site Inspection; Assessment of Odour Impact Revision No.: 01

\ 8Q9 Field Record Sheet Issue Date: 0710412009 i;Miro~meFital

Eniarce""'"!

General Licensee/Facility: Reg. No. Assessment by Date of inspection Announced/Un-Announced /!"""£"" /L • .t~.ii D>l fotJs7-of Your name: P7f¥i"" k/J,~

;J..,t /o &/13 Ul"-.n/10"¥1 ~ tl .(other lnspector(s) present):

'E Observer is free from Observer abstinence (30 Reason for odour Map Has a map Have you been Weather :

" " medical conditions min) from smoking, flavoured assessment- Complaint showing assessment trained in the use Conditions Note 3 l Eo (cold, sore throat. drinks, scented toiletries and verification; targeted locations been attached? of this procedure? {record wind info ani Ul:W 00 ~ sinus trouble)? deodorisers? weather/process; routine If so, insert training page 2): [ " ~ 00 ~

visit; other (specify). Procedure sec 8.2.3 dill!>. ' ooc. <" Procedure sec 8.2.1 Procedure sec 8.2.1 ' ~ Procedure sec 8.1.1 . (f!!Y No [7'1, c.-.1 "a. ~

n. Yes) Yes} {,," 1..-d" ,..,.,.f/ J."" r-Yes )

••

No No No Date:P.<>/blf/0(/ Note 1: Observation point sensitivity (assuming detectable, if not then 0) Note 3: Weather Conditions '

00 " Precipitation- dry, rained recently, driZ7Je, raining, foggy i

.S..c:c I Remote (no housing, commerciaVindustrial premises or public area within SOOm of observation point) Temperature- cold, cool, warm, hot ' 0- ~

" "' " 2 Low sensitivity (no housing, commercial/industrial premises or public area within I OOm of observation point)

""" Note 4: Odour Persistence ~ :z ~ 3 Moderate sensitivity (housing comrnerciaVmdustrial premises or public area within 100m of observation point)

~o..o 4 High sensitivity (housing, commerciallindustrial premises or public area within area of observation point) 0 No Odour !

-e~ 5 E~)sensitive (complaints arising from residents, business and users of public areas within area of observation I Intermittent (detected intermittently during the period of assessment) .s 0 .c. _point 2 Persistent (detected throughout the period of assessment)

ctl(f.lo,g Note 2: Wind Strength Note 5: Odour Intensity '

Q) E s:: oo O.,e!g 0 Calm Smob:e rises vertically Z~;t;:; I Light air Direction of wind shown by smoke drift, but not wind vanes 0 No Detectable Odour

00 "0 ~ 2 Light Breeze Wind felt on face; leaves rustle, ordinary vane moved by wind I Paint Odour (barely detectable, need to stand still and inhale facing into wind) "' " 1: 3 Gentle Breeze Leaves and small twigs in constant motion 2 Moderate Odour (easily detectable while walking and breathing normally, c " " -"" 4 Moderate Breeze Raises dust and loose paper, small branches are moved possibly offensive) "'".c " .c 0 5 Fresh Breeze SmaU trees in leaf begin to sway 3 Strong Odour (bearable but offensive- might make clothes I hair smell?) 1!--o 6 Strong Breeze Large branches in motion~ umbrellas used with difficulty against the wind 4 Very Strong Odour (unbearable, difficult to remain in area affected by odour) ,_ ~~~ 7 Near Gale Whole uees in motion; inconvenience felt when walking against wind :t;.E 8 Gale Twigs break off trees; progress generally impeded

9 Strong Gale Slight structural damage occurs (chimney pots and stares removed)

Time on: Do any of the odours experienced on-site match in List areas Inspected: What processes were occurring during character those recorded during the survey? the off-site odour assessment?

..... "":;:;-·;; ::J c ·- 0 Q) >"" E J:-0 (/) =~~ Duration of Licensee's representatives(s) met on site: Potential on-site odour sources identified: 0 ;t! 00 ~ < 00 visit: u.. -<

I _(;re_ated by: Alan Stephens Revised by: Nicholas Kenny

Page 1 of 2 Uncontrolled Once Printed I. Approved by~ .. ·eran O.'?lrien, Programme Manager. S1gnature: ;, .-1;: Date: 7 11 /, c:

/'1 ~ lY!r--:t-~ I/ ..._ () :/

Doc. Ref. No. FPO!I-001-01 Observer Location Wind (nd =if not detectable) Time Odour Rating Odour Description Comments I

Name of household 1 Description of any odours, other source of odours

\ ~ commercial site E "' etc, (Also note variable weather conditions etc) : 2 0 c> " c (!)

" (describe so that ,J="O <JJO 0 u .c c·S a~ E location can be easily ·- (!) ES 0 'f~ c ·;;;

0 " - > .c (!) .c i ~ rn~- 0, --0

~ identified again by a :.;:::; ~ +='..,efl) ~Q.l.C ~--~ "0(: ~05 ~ ·;;.; --I() ~ ·ro .-... ru ~-~ ~ CN til .§ ~ ::I-- ~

0. - Cf.l·-0 ~ Nru o:ii""fw third party, inc. map c>D- -~ .Q ~ "'• (!) ' 0 6~:§ ~- (1JI

Q)_Q "'OQ) , ...... u-oo (SOrn -0 (;)~ 0 0... e.~ ref.) Cl} ~2 -~ C/JZ CLo OE-z

Guide- A location where the score meets or "-o --- :e:3 -- "0~ (!) -- -- - 1 or 2 :e:2 exceeds all the threshold values may be deemed ,.,_<l)Q)

.so ...... ::c Q:J..._.O subject to nuisance/significant impairment, \ ..c:::oms:: ~xOJ'l U)o.~: ' 0 c 0 particularly if the observations are supported by i, Q) ..... '0 ·- c .... ,_ Q)

J.... CIJ t: :J :;:a.o-~:.s·-s: oa.. .g public complaints on impact, frequency and o<C duration of odours.

18.-lfJJ"""" 12./. (J<. Jf s.,;/1-. L~ .. L 3 J3:~S t;:tfo C) D I V".lv.N<-'f'iOio.l ~

I k.J. f. /IrA. 1+ lt;!i J-...,""rd I _a /3:Lf1 \ I <". :·do.. A<"e&A. {G) IJ:If)f 0 tJ aH ""~,( 1!-4f~ ..... " 4 :; • .A:J..

{pHio./lf<J 3 J;r:S I 6:>b 0 0 I

"' Ao ... l.. (F) lwu,..f, c i •·1ff llJ..,...Awll"lJ

I 0

3 /3:S1 I I ' ~ s l_M. 5 ' ~ I

" (<-] s.fi (),,_,z...,,, J 2 0 0 i

"' s .....-f tq.:t 0 !5 ' .0

0

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5 s:..f/.. lht.v/1 J,./i/1) 3 tq.: '35 5 0 {) -- ,a-6

Brief details of any meeting with local residents/complaints received during assessment (include names/addresses/telephone numbers etc):

'

I Assessment of Odour Impact Field Record Sheet Page 2 of 2 Uncontrolled Once Printed

F G

Astee, Co. Kerry

B

A

P

C

D

E

H

I

J

K

O

L

M

R

1



Address Kilcolman

Address Asdee

AddressCo.Kerry

________________________________________________________________




This document’s reference number: Odour 2013-07-31ml


________________________________________________________________





Due to the findings of the odour assessments and the subsequent post assessment visit to the facility,

as presented in the attached Field Record Sheets, it is the opinion of this Inspector that the activities

occurring on the premises of Brandon Products were causing the odours detected off-site. The odours

detected off-site are of very serious concern to the Agency.

Below is an outline of the areas where I detected odour off-site during the odour assessment I carried


• During an odour assessment at ------------------------- (marked C in the map and associated odour assessment field sheet) between 15:10 and 15:15 odour was detected intermittently at an intensity of 2. The wind was southwesterly in direction and this property was downwind of Brandon Products facility during the observation period. For this observation period I noted an odour persistence of 1 and odour intensity of level 2 on the attached Assessment of Odour Impact Field

2

Record Sheet. I would describe the odour as a musty unpleasant odour. ------------------------- was present during the observation period and witnessed the odour.

• During an odour assessment at ------------------------- (marked C in the map and associated odour assessment field sheet) between 15:30 and 15:35 odour was detected intermittently and varied in intensity between level 2 and level 3. The wind was southwesterly in direction and this property was downwind of Brandon Products facility during the observation period. For this observation period I noted an odour persistence of 1 and odour intensity at a level of 2-3 on the attached Assessment of Odour Impact Field Record Sheet. I noted two odours during this observation period, a musty unpleasant odour and an odour that I can only compare to an antiseptic TCP. ------------------------- was present during the observation period and witnessed the odour. He compared the musty unpleasant odour to the smell from Distemper, which was an early type of whitewash used many years ago.

• During an odour assessment at ------------------------- (marked R in the map and associated odour

assessment field sheet) between 15:40 and 15:47 odour was detected intermittently and varied in intensity between a level of 2 and 3. The wind was southwesterly in direction and this property was downwind of Brandon Products facility during the observation period. For this observation period I noted an odour persistence of 1 and odour intensity of a level 2-3 on the attached Assessment of Odour Impact Field Record Sheet. ------------------------- was present during the odour assessment and witnessed the smell. ------------------------- described the odour ‘like burning protein’.

• While walking on the road between ------------------------- (marked D in the map and associated odour

assessment field sheet) and ------------------------- (marked R in the map and associated odour assessment field sheet) I detected a strong odour varying in intensity at a level between 1 and 2. I stopped and carried out an odour assessment between 16:07 and 16:17. The odour reminded me of the antiseptic TCP. ------------------------- approached me ------------------------- and stopped on the road to talk to me. I asked him to ------------------------- confirm whether he detected an odour. His immediate reaction was that the odour was like Jeyes fluid and then agreed that it was like TCP. The wind was southwesterly in direction and the location was downwind of Brandon Products facility.

I entered the Brandon Products facility at 16:25 and met with the Production Manager Jerry

O’Mahony and consultant Trevor Montgomery. I informed all present of my odour assessment

findings on the 31/07/13 as well as details of complaints that I had received before and during the

odour assessment regarding odours from the facility. I went to the location of the stack and confirmed

that the odour I was detecting in the area of the stack was the same musty odour that I detected offsite

during the odour assessment. Jerry O’Mahony and Trevor Montgomery was surprised to hear that I

had detected an odour that I compared to the antiseptic TCP and I was informed that disinfectants are

not used onsite. Trevor Montgomery accompanied me back to the location where I had detected this

type of odour @ 16:45 and this odour was not detectable at this time.

3


report.



Dated: 06/08/13



http://www.epa.ie/

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I Remote (no housing, commercial/industria! premises or public area wilhin 500m of observation point} Temperature- cold, cool, warm, hot 2 Low sensitivity (no housing, commerciaVindustrial premises or public area wilhin 1OOm of observation point)

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Note 2: Wind Strength Note 5: Odour Intensity 0 crum Smoke rises venically I Light air Direction of wind shown by smoke drift, but not wind vanes 0 No Detectable Odour 2 Light Breeze Wind felt on face; leaves rus!lc, ordinary vane moved by wind I Faint Odour (barely detectable, need to stand still and inhale facing into wind) 3 Gentle Breeze Leaves and small twigs in constant motion 2 Moderate Odour (easily detectable while walking and breathing normally, 4 Moderate Breeze Raises dust and loose paper; small branches are moved possibly offensive} 5 Fresh Breeze Small trees in !eafbegin to sway 3 Strong Odour (bearable but offensive- might make clolhe:s I hair smell?) 6 Strong Breeze Large branches in motion; urnbreHas used with difficulty against the wind 4 Very Strong Odour {Wibearable, difficult to remain in area aff~ted by odour) 7 Near Gale Whole trees in motion; inconvenience felt when walking against wind 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structural damage occurs (chimney pots and slares removed)

Time on: Do any of the odours experienced on-site match in List areas Inspected: What processes were occurring during character those recorded during the survey?

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Sfc..c..k ~ the off-site odour assessment?

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Potential on-site odour sources identified:

: Nicholas Kenn

i Page 1 of2 I


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i Assessment of Odour Impact Field Record Sheet I

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F G

Astee, Co. Kerry

B

A

P

C

D

E

H

I

J

K

O

L

M

R

1




Address Kilcolman

Address Asdee

Address Co. Kerry

________________________________________________________________

Licensee: Brandon Products Licence Registration Number: P0957-01(applied)





________________________________________________________________





Due to the findings of the odour assessment, as presented in the attached Field Record Sheet, it is the



Agency.

2


• I began an odour assessment in front of ------------------------- (marked D in the map and associated

odour assessment field sheet) at 13:00. I immediately got a pungent odour which was musty in

nature. This odour was detected intermittently throughout the observation period. The wind was

westerly in direction and I was downwind of Brandon Products Ltd. facility during the five minute

time period of this observation. For this observation period I noted an odour persistence of 1 and

odour intensity varying between 2 and 3 on the attached Assessment of Odour Impact Field

Record Sheet. I met ------------------------- who informed me that the odour was also bad last Friday

04/10/13, that -------------------------. ------------------------- left again to go indoors because of the smell

and ------------------------- coughed intermittently while speaking to me.

• I began an odour assessment in front of ------------------------- (marked R in the map and associated

odour assessment field sheet) at 13:08. The wind direction was west-northwest in direction and I

was downwind of Brandon Products Ltd. facility during the twelve minute time period of this

observation. ------------------------- was present during this observation period and verified the odour.

For this observation period I noted an odour persistence of 1 and odour intensity of 3 on the

associated Assessment of Odour Impact Field Record Sheet.

• I began an odour assessment on the road between ------------------------- and ------------------------- at a

signpost marked ‘Asdee Community Alert’ at 13:38. The wind direction was west-northwest in

direction and I was downwind of Brandon Products facility during the five minute time period of

this observation. Trevor Montgomery was present during this observation period. For this

observation period I noted an odour persistence of 1 and odour intensity of 3 on the associated


I informed Trevor Montgomery of my findings during this odour assessment. I spent some additional

time in the area of the signpost marked ‘Asdee Community Alert’ and observed the back of the

Brandon Products Ltd. facility. I noted that when steam was very evident in the air from the cooling

towers, the odour was present. I discussed this observation with Trevor Montgomery and questioned

the possibility of this odour coming from the cooling towers. Guy Meredith joined us during this

observation period.

During an odour assessment at ------------------------- (marked P on the attached map), I met ----------------

--------- who informed me that the odour was bad in the backyard of his house on the 07/10/13 at 12:30

and also at the gap of the field on the road adjoining the Brandon Products facility on a day the

previous week.

3

I left the area at 14:00pm. My chest was affected resulting in slightly laboured breathing and

coughing. These symptoms lasted for about 2 hours.

This issue of odours emanating from your installation is of very serious concern to the Agency.


report.



Dated: _________________________



http://www.epa.ie/

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Field Record Sheet


Revision No.: 01


License elF ac ility: Reg. No. Assessment by I Date of inspection I Announced/Un-Anno],lnced i

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Weather Conditions Note 3 (

(record wind info on[ page 2): .:

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I Remote (no housing, commerciaVindustria! premises or public area within"'soOm of observation point) 2 Low sensitivity (no housing, commercialfindustria! premises or public area within lOOm of observation point) 3 Moderate sensitivity (housing commercialfindustria! premises or public area within lOOm of observation point) 4 High sensitivity (housing, commercial/industria! premises or public area within area of observation point) 5 Extra sensitive (complaints arising from residents, business and users of public areas within area of observation

~oint)

Note 2: Wind Strength 0 Calm Smoke rises vertically 1 Light air Direction of wind shown by smoke drift. but not wind vanes 2 Light Breeze Wind felt on face; leaves rustle, ordinary vane moved by wind 3 Gentle Breeze Leaves and small twigs in COilStant motion 4 Moderate Breeze Raises dust and loose paper; small branches are moved 5 Fresh Breeze Small trees in leaf begin to sway 6 Strong Breeze Large branches in motion; umbrellas used with difficulty against the wind 7 Near Gale Whole trees in motion; inconvenience felt when walking against wind 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structural damage occurs (chimney pots and slates removed)

Precipitation- dry, rained recently, drizzle, raining, foggy Temperature- cold, cool, wann, hot

Note 4: Odour Persistence 0 NoOdour I Intermittent (detected intermittently during the period of assessment) 2 Persistent (detected throughout the period of assessment)


0 No Detectable Odour l Faint Odour (barely detectable, need to stand still and inhale facing into wind) 2 Moderate Odour ( ea>ily detectable while walking and breathing normally,

3 4

possibly otiensive) Strong Odour (bearable but offensive- might make clothes I hair smell?) Very Strong Odour (unbearable, difficult to remain in area affected by odour)

Time on: I Do any of the odours experienced on~site match in List areas Inspected: What processes were occurring during the off-site odour assessment? character those recorded during the survey?

Duration of I Licensee's representatives(s} met on site: visit:

Created ~ Alan Stephens Approved by:)Sieran o,:e_rien, Programme Manager. Signature: 4_, . . r/K Date: 7"/1, 1 , (j .J·'l (-t~...r;.t L. !~'1.4-\,~ ~/ ·rt C,J /


Revised by: Nicholas Kenny

Page 1 of2 Uncontrolled Once Printed

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\Page 2 of2 Uncontrolled Once Printed l

F G

Astee, Co. Kerry

B

A

P

C

D

E

H

I

J

K

O

L

M

R

1



Address Kilcolman

Address Asdee

AddressCo.Kerry

________________________________________________________________






________________________________________________________________





Due to the findings of the odour assessments as presented in the attached Field Record Sheet, it is the



Agency.

Below is an outline of the areas where I detected odour off-site during the odour assessment I carried

out between 14:11 and 16:01:

• During an odour assessment at ------------------------- (marked D in the map and associated odour

assessment field sheet) between 14:25 and 14:30 odour was detected intermittently at an intensity level of 2. The wind was south to southwest in direction and this property was downwind of Brandon Products facility during the observation period. For this observation period I noted an

2

odour persistence of 1 and odour intensity level of 2 on the attached Assessment of Odour Impact Field Record Sheet.

• While walking on the road between ------------------------- (marked D in the map and associated odour assessment field sheet) and ------------------------- (marked R in the map and associated odour assessment field sheet) I detected an odour. I stopped and carried out an odour assessment between 14:49 and 14:54 at a gap to the entrance of the field adjacent to Brandon Products Limited. For this observation period I noted an odour persistence of 1 and odour intensity level of 1 on the attached Assessment of Odour Impact Field Record Sheet. I met ------------------------- and he informed me that he got the smell at ------------------------- (------------------------- marked D on the map) at @13:15. He described the smell as musty and at an intensity level of 4. He informed me that he was feeling sick and had a headache since he experienced the smell.

• During an odour assessment at ------------------------- (marked D in the map and associated odour assessment field sheet) between 14:55 and 15:00 odour was detected intermittently at a varying intensity of between level 1 and level 2. The wind was southwest in direction and this property was downwind of Brandon Products facility during the observation period. For this observation period I noted an odour persistence of 1 and an odour intensity level of 1 to 2 on the attached Assessment of Odour Impact Field Record Sheet.




report.



Dated: 01/11/13



http://www.epa.ie/

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General j LicenseeiFacility: !6',0o.£D,o h~.L><~Yj I /:f&(. ! Observer is free from


Field Record Sheet

Reg. No. Assessment by

f?o9S"7-0l Your name: H~i::-- ~rjo/1 (other lnspector{s)-presen'i): ·


Revision No.: 01


Date of inspection Announced!Un-Announced

?c /;o/;3 {[, - /J .-7/J o:.r; 0?: d Observer abstinence (30 Reason for odour Map Has a map Have you been Weather )c

. ~ " i medical conditions ' min) from smoking, flavoured assessment- Complaint showing assessment trained in the use Conditions Note 3 ; f Eo I (cold, sore throat, I """

drinks, scented toiletries and verification; targeted locations been attached? of this procedure? (record wind info on~

"' " sinus trouble)? deodorisers? weather/process; routine If so, insert training page2): I " ~ ' " " I Procedure sec 8.2.3 visi~ other {specify). d;>te. l~c.. l Procedure sec 8.2.1 I '«:" Procedure sec 8.2.1

l£<t Procedure sec 8.1.1 ~ No S,Ae s .. {o;-vU<S'

'...- - ' ' Yes) No I "(es ) No &1'>";,-?.i...,r:C vu..-f;·c..d;· .. ;; !(Yes) No Date:~o.o,.f-. o9 &,t.

Note 1: Observation point sensitivity (assuming detectable, if not then 0) Note 3: Weather Conditions Precipitation- dry, rained recently, drizzle, raining. foggy

C' l Remote (no housing,. conunercialfmdustrial premises or public area wimin 500m of observation point) Temperarure- cold, cool, warm,. hot " " 1 Low sensitivity (no housing,. commercialrmdustrial premises or public area within I OOm of observation point) ;::

3 Moderate sensitivity (housing commercial!indumicl premises or public area within lOOm of observation point) Note 4: Odour Persistence " > 4 High sensitivity (housing, commercial/industrial premises or public area v..ithin Bml. of observation point) 0 No Odour 0

" 5 E'dl'a sensitive (complaints arising from residents,. business and users of public areas \\ithin area of observation t Intennittent (detected intennittently during the period of assessment) :0 ;mint} 2 Persistem (detected throughout the period of assessment) 2

Note 2: Wind Strength Note 5: Odour Intensity ~ I 0 Calm Smoke rises vertically ,gl 1 Light air Direction of wind shOwn by smoke drift, but not wlnd vanes 0 No Detecffible Odour

"' ' 2 Light Bri!eZe Wind felt on face; lC2-ves rusde, ordinary vane moved by wind 1 Faint Odour (barely del:ectable, need to stand still and inhale facing into wind) > ,

jl 3 Gentle Breeze Leaves and small twigs in coasrant motion 1 Moderate Odour (easily detectable while walking and bre:athing normally, 4 Moderaie Breeze Raises dust and loose paper; small branches are moved possibly offensive)

o I 5 Fresh Breeze Small m:es in leaf begin to sway 3 Strong Odour (bearable but offensive- might make clothes I hair smell?}

~I 6 Strong Breet!: Large branches in motion~ u.>nbrellas used with difficulty against the wind 4 Very Strong Odour (unbearable, difficult to remain in area affected by odour) 7 Near Gale Whole treeS in motion~ incor:venience felt when walking ~crainst v.ind

""-E 8 Gale Twigs break off trees; progress generally impeded 9 Strong Gale Slight structural damage OCCtil"S (chimney pars and slates removed)

I Time on: Do any of the odours experienced on-site match in I character those recorded during the survey? · List areas Inspected: I What processes were occurring during

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Duration of VISit

Licensee's representatives(s) met on site:

I I

I Created by: Alan Stephens Approved by~;yeran C{~rien, Programme Manager. Signature: 1x.. J.%: Dare: -/.,; / , 1 .

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the off-site odour assessment?


Revised bv: Nicholas Kenn

Page I of 2 Uncontrolled Once Printed

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Doc. Ref. No. FPOli-001-0i ! Observer Location

\Name of household 1 j ~ ' commercial site

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Odour Description Comments I Description of any odours, other source of odours l etc, (Also note variable weather conditions etc) · I

Guide- A location where the score meets or exceeds all the threshold values may be deemed subject to nuisance/significant impainnent, \ particularly jf the observations are supported by '; public complaints on impac~ frequency and ; duration of odours.

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: Assessment of Odour Impact Field Record Sheet i Page 2 ojl Uncontrolled Once Printed

F G

Astee, Co. Kerry

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P Cunningham Page 1 of 4 29/04/2013 16:57

Health Impact Note

Visits to Asdee, Co Kerry, on Wednesday 24 April 2013 and Tuesday and

Wednesday 30 April and 01 May 2013 to evaluate complaints of noxious

odours causing health impacts on residents neighbouring the Brandon

Products Ltd facility, Kilcolman, Asdee (license application P0957-01

received 24/01/2012)

10 May 2013

During odour assessment work on three recent occasions at a currently unlicensed facility (an

application has been received by the Agency), I felt unwell as a clear result of exposure to emissions

from the facility. The health impacts that I experienced during and after these exposures included

nausea, tightness of the chest and discomfort in the throat. They closely correlated with the health

effects reported by a number of residents of the locality.

I consider that the health impacts I experienced during odour assessment activities in the vicinity of

this facility amount to a health and safety incident.

I consider that the Agency’s Odour Assessment Procedure should be modified to require that staff or

contractors who experience health effects or unreasonably noxious odours in the course of odour

assessments should respond to such conditions either by reducing the duration of the assessments

below the standard 5 minute test period or where appropriate by terminating the test observation.

The details of the odour assessments and the health impacts I experienced are set out below.

Odour Assessment 24 April 2013

Maria Lenihan and I visited the vicinity of the Brandon Products Ltd facility to evaluate complaints of

noxious odours causing health impacts on residents that have been received by the Agency over the

last year or so; this was the fifth such visit by OEE staff.

Our odour assessments, conducted simultaneously but independently, commenced at 07:50. I did

not observe any unusual odour at any of the first seven locations, which were located upwind or

crosswind from the facility. At the next location, labelled “D” (Eamonn McElligott’s) and lying

approximately 200m from the facility (commenced 09:00), I noted what I describe as a “very

unpleasant, horrible” odour with a significant ammonia character. It was evident to me that this

odour originated at the Brandon Products Ltd facility which was directly upwind at that time.

I recorded the following voice note on my phone at “D” (Eamonn McElligott’s):

“We’re… myself and Maria Lenihan are standing outside Eamonn McElligott’s, point “D”,

directly downwind of Brandon Products, probably 200m? (ML: Yes”) down, directly downwind,

and we’re in the course of a five-minute odour observation and I think it’s important to record

that the odour is strong; its halfway between intermittent and persistent, not continual but it is


certainly not occasional either. Its strong, it’s got a strong ammonia flavour to it; it is, ah… I could

see this as being nauseous and I could see it as being very intolerable if you were exposed to it on

a continual basis. Yeah, a very… very unpleasant odour, I would say there would appear to be

ammonia in it, and something else in the way of seaweedy type odours as well. I get a taste in my

mouth. Yes, its, ah… very unpleasant. I will leave it at that, coming on 09:05.”

After completing that observation, we visited five other locations, all either upwind or crosswind of

BP, and then arrived at location “O” (Eamonn McElligott’s) and started observations at 10:02. At that

time, the location was directly downwind lying approximately 200m directly downwind of the

facility, I again noted what I describe as a “very unpleasant, horrible” odour with a significant

ammonia character.

I recorded the following voice note on my Blackberry phone at “O” (Eamonn McElligott’s):

“This is 24 April again, the time is around five past ten or so. We are at point “D” [error reading

map – actually point “O”], directly downwind now from Brandon Products, probably about 150 to

200 metres from (obscure), and ah, the wind is at the north west now so as I say we are directly

downwind at this point. Ohhh, the odour is very strong and it is very persistent on this occasion,

and it’s very unpleasant; it catches in the throat and eh, really I have been feeling the nausea

since the last time we encountered the smell about 20 or 30 minutes ago - this is probably

stronger here now if anything. It’s hard…, it’s hard to be here I would say. Ohhh, deeply, deeply

unpleasant, ammonia in…, you can feel it in the back of the throat. Makes you cough, nausea,

ah…, not…, not tolerable, (coughs) it’s not easily (coughs) tolerated. Not easy to tolerate this,

would not… em, in my view if one was to experience this on a regular basis this would clearly be

nuisance if not more; this is verging on health impact I would have thought, rather than just, ah,

just disturbance factor. I will pause it at that…”.

We continued the odour assessment with stops at upwind and crosswind locations, before returning

to location “O” (Eamonn McElligott’s), commencing at 11:35. At this time, we again independently

observed the same ammonia-based odour as we had noted earlier, again persistent though on this

occasion slightly lower strength. Once more, it was evident that the facility was the source of the

odour. We again noted the same impact on our health and wellbeing.

We invited several of the complainants to join us at this location to obtain their opinions about the

odour. Eamonn McElligott’s attended at 11:38 and confirmed that “the odour is the same as that

which they experience and causes them nuisance and health effects”. Subsequently, Eamonn

McElligott’s informed me that he visited the yard soon afterwards and he also confirmed to me that

the odour was the same.

Maria and I entered the Brandon Products premises at 12:00 and met with the Production Manager,

Mr Jerry O’Mahoney. We undertook a tour of the site which concluded at 13:40. During that time, I

felt unwell, though this may have been related to the earlier exposure rather than any additional

exposure during the visit.

I returned to the home of one of the complainants for about an hour, and then left for home at

around 15:00. On the way and for the rest of that day, I felt nausea, a tightness of the chest and a

chemical sensation in the back of my throat. In addition, I had the sense that the smell was still “in

my nose” – I continued to perceive it throughout the journey and all of that evening.


I was still feeling the effects, though to a lesser extent, the next day, Thursday 25th April. Accordingly,

I visited my GP that afternoon. He examined me and recommended that I attend for an X-ray, which

I did the day after. I understand that Maria, who attended the same doctor, was also recommended

to attend for an X-ray and did so. Thankfully, I am informed that no lasting impact was found in my

case, and I believe Maria’s X-Ray showed the same result.

Odour Assessment 30 April 2013

I visited the locality of the Brandon Products facility at 16:30 on Tuesday 30 April 2013 to carry out

an odour assessment. I noted that the weather conditions at the time were sunny and breezy,

though the wind strength fell from around F 3-4 at the start of the exercise at 16:45 to F 1-2 at

17:15; this was partly due to differences in exposure of the different locations assessed.

I first undertook observation at four points located upwind and crosswind of the facility,

commencing at Point “L” on the Beale Road. I observed no odour at any of these locations. I then

proceeded to Point “D” (Eamonn McElligott’s), which was directly downwind of the facility at that

time, 17:15. I immediately detected a “seaweedy” type odour; this was unpleasant and

objectionable but not noticeably pungent. I considered that the odour was persistent and was

mainly Moderate though occasionally Strong in intensity. I began to experience unpleasant

sensations in my chest as a result, in my view, of the odour.

I returned to this Point “D” (Eamonn McElligott’s) several hours later, and repeated my observation,

commencing 18:50; wind conditions were similar to the earlier visit to this location. The odour was

similar in character to that noted at 17:15; it was intermittent on this occasion and varied between

Faint and Moderate in intensity.

I then called to the home of Eamonn McElligott’s (Point “D”); Eamonn McElligott’s was also present.

They described the nuisance and impact of the smell and expressed their frustration at how long the

problem has been allowed to continue to affect them. They confirmed that both they and their

family have been reporting the impacts of their health to their GPs and other health professionals,

and agreed to request details of this for our information and use.

I left their home at 19:15, at which time the odour was still evident.

Shortly afterwards, while I was en route to Ballybunion to spend the night, I stopped the car to make

a note of the health impact symptoms I was feeling as a result of both exposures to the odour. “I am

now experiencing a dry cough and a tightness in my chest in the region of my breastbone. The odour

appeared less strong than that we experienced last Wednesday but the unpleasant impact on my

health doesn’t seem that much less! I also have the odour in my nose again, despite having left the

site around 10 minutes ago”.

For the rest of the evening, both these symptoms and the sensation that the odour was stuck onto

me persisted.


Odour Assessment 01 May 2013

I visited the locality of the Brandon Products facility at 07:30 on Wednesday 01 May 2013 to carry

out an odour assessment. I was met there by Maria Lenihan and Niamh O’Donoghue; all three of us

intended to carry out an unannounced audit of the facility later in the day.

I noted that the weather conditions at the time were sunny and a light breeze. I detected no odour

at either upwind or crosswind locations, but again I detected Moderate to Strong odours downwind

of the facility, Point “D” (Eamonn McElligott’s). The odour was the same as that I detected the

previous evening, that is, a “seaweedy” type odour that was unpleasant and sickening but again was

not noticeably pungent.

I felt unwell for the rest of the day at Astee and during the journey home afterwards. I did not visit

my GP the next day, however, as I felt generally better at that point.

Peter Cunningham

10 May 2013

(Note: I have not had an opportunity to transcribe the details of recordings I made during the odour

assessments on 30 April and 1 May; these will be added to the document shortly)


Brandon Products Ltd P0957-01 (applied)

Health Impact during Odour Assessment 30 April 2013

I visited the locality of the Brandon Products facility at 16:30 on Tuesday 30 April 2013 to carry out

an odour assessment. I noted that the weather conditions at the time were sunny and breezy,

though the wind strength fell from around F 3-4 at the start of the exercise at 16:45 to F 1-2 at

17:15; this was partly due to differences in exposure of the different locations assessed.

I first undertook observation at four points located upwind and crosswind of the facility,

commencing at Point “L” on the Beale Road. I observed no odour at any of these locations. I then

proceeded to Point “D” ((---------------------), which was directly downwind of the facility at that time,

17:15. I immediately detected a “seaweedy” type odour; this was unpleasant and objectionable but

not noticeably pungent. The odour was persistent and was mainly Moderate though occasionally

Strong in intensity. I began to experience unpleasant sensations in my chest as a result, in my view,

of the odour.

I returned to this Point “D” ((---------------------) several hours later, and repeated my observation,

commencing 18:50; wind conditions were similar to the earlier visit to this location. The odour was

similar in character to that noted at 17:15; it was intermittent on this occasion and varied between

Faint and Moderate in intensity.

I then called to the home of (--------------------- (Point “D”); (--------------------- was also present. They

described the nuisance and impact of the smell and expressed their frustration at how long the

problem has been allowed to continue to affect them. They confirmed that both they and their

family have been reporting the impacts of their health to their GPs and other health professionals,

and agreed to request details of this for our information and use.

I left their home at 19:15, at which time the odour was still evident.

Shortly afterwards, while I was en route to Ballybunion to spend the night, I stopped the car to make

a note of the health impact symptoms I was feeling as a result of both exposures to the odour. “I am

now experiencing a dry cough and a tightness in my chest in the region of my breastbone. The odour

appeared less strong than that we experienced last Wednesday but the unpleasant impact on my

health doesn’t seem that much less! I also have the odour in my nose again, despite having left the

site around 10 minutes ago”.

For the rest of the evening, both these symptoms and the sensation that the odour was stuck onto

me persisted.

(A dhdsion of Gradko rnternational Ltd .)

St. Martins House, 77 Wales St reel \-\ inchester, Ha mpshire S0 23 ORH tel.: 019h2 860JJ I fax: 01'.162 8-'1339 c-mail:dil'fusion@gl'adko.ro.uk

LABORATORY ANALYSIS REPORT DETERMINATION OF ACID GASES IN DIFFUSION TUBES BY ION CHROMATOGRAPHY

REPORT NUMBER Y3235R

BOOKING IN REFERENCE No Y3235

DESPATCH NOTE No SOR013994

CUSTOMER Environmental Protection Agency Richview Dublin 14, Ireland

DATE SAMPLES RECEIVED 11/11/2013

GRADKO LAB REF GIN 7376-7381

DETERMINATION OF ACID GASES IN DIFFUSION TUBES BY ION CHROMATOGRAPHY

Tube Identification Date On Date Off

233686 15/ 10/13 05/11 /13 233685 15/10/13 05/11/13 233684 15/10/13 05/11/13 233683 15/10/13 05/11/13 233682 Junction R551 15/ 10/13 05/11 /13

Extra 1 15/10/13 05/11 /13

Lab Blank

(RESULTS ARE BLANK CORRECTED)

Tubes reported as <L.O.D. are below the limit of detection. Extra tube was received and maximum exposure time used.

OVERALL M.O.U ±14.9%

Analysed on Dionex ICS 11 00 ICU 1 0 ANALYST SIGNATURE

CHLORIDE AS HCL

Exposure p.gCI J,LQCI2 • HCI

(hrs) Total Blank p.g/m3•

503.72 <LO.D. <LO.D. <LO.D. 503.83 <L.O.D. <L.O.D. <LO.D. 503.83 <L.O.D. <LO.D. <LO.D.

503.83 <L.O.D. <LO.D. <LO.D.

503.83 <LO.D. <LO.D. <LO.D.

503.83 <LO.D. <LO.D. <LO.D.

0.06

LIMIT OF DETECTION

ANALYST NAME

2187

HCL

•ppb

<LO.D.

<LO.D.

<LO.D.

<LO.D.

<LO.D.

<LO.D.

o.14J..lg cr

B. Gregory

fhe Ditlu~ion Tul.11.'' have heen (e,lt'cl '' ithin lhe ~cope of Gntdko lnte r nutiuual Ltd. l.uburulnl") Qualit} l'roccdures calcu lation~ and ~~~~cssmenb imohing the e"\posur(' procedures and prriod!> pro\idcd h) the rlienl are nul 11ithinthe scope of our l 1-. \1) accrctlitation. Those results obtained using e"\posure data shall he intlicatcd h~ an a~teri;,k. All) 4ueries cuncerniltg the daht in thh rt'po..t ,(wuld he directed to the Laburatnr) \ la nager Gradkn lnterualional Ltd. 1 his report is not tu lw reproducecl. except in full, '' ilhout lht' n ritten pet·mhsinn of (;radko I nternational Ltd.

Form LQF..'2h hsuc 4 - Septl'mhe•· 2012 Report Number Y3235R Page 1 of 5

J REPORT OFFICIALLY CHECKED Gradko lntemntioual Ltd

This signatu re confirms tbe authenticity of these results

Signed. ..................... ~~ ........................... ............. . L. Gates, Laboratory Supervisor

radko environmental

(A division of Gradko Interna tiona l Ltd .)

St. 1\ lar ti ns House, 77 Wales Street \ \inrhcslcr. Ha mpshire S023 llRH tel.: 01962 860.H I fax: lll %2 841339 e-mail :diffu<;[email protected]..

LABORATORY ANALYSIS REPORT

DATE OF ANALYSIS 26/11/2013 DATE OF REPORT

ANALYSIS HAS BEEN CARRIED OUT IN ACCORDANCE WITH IN-HOUSE METHOD GLM3


233686

233685

233684

233683 .

Tube Identification

233682 Junction R551

Extra 1

Lab Blank


Date On

15/10/13

15/10/13

15/10/13

15/10/13

15/10/13

15/10/13

Date Off

05/11 /13

05/11 /13 05/ 11/13

05/ 11/13 05/11 /13

05/11/13

Tubes reported as <L.O.D. are below the limit of detection.

Extra tube was received and maximum exposure t ime used.

Exposure

(hrs)

503.72

503.83

503.83

503.83

503.83

503.83

Results may be higher than expected due to coelution of unknown compound.

OVERALL M.O.U. ±14.9%

Analysed on Dionex ICS 1100 ICU1 0 ANALYST SIGNATURE

DATE OF ANALYSIS 26/11 /2013

FLUORIDE AS HF

~F ~F - HF

Total Blank ~fm3*

0.07 0.06 0.98

0.06 0.04 0.69

0.07 0.05 0.88

0.06 0.04 0.72

0.08 0.06 1.10

<l.O.D. <l.O.D. <l.O.D.

0.02

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT



Tube Identification Date On Date Off Exposure

(hrs)

~gBr

Total

BROMIDE AS HBr

~Br

Biank

2187

27/ 11/2013

HF

ppb*

1.10

0.77

0.98

0.81

1.23

<l.O.D.

0.05~g F

B. Gregory

27/11/2013

HBr

ppb*

llw l>itfu,inn Tuhe' ha1 e lwcn lC,!t!tl '' ithin the <copt' of <;radko lnternalinnal Ltd. l .ahoratnr~ Qnulil,l l'rurtdures calculation' anct a~~e:.snwnts inHJhing tht· C'\posure prOtl'durcs ancf pel'iod~ pn11illcll h) lh'l di(•nt are not 1\ithin the \WJll' ol our l K \S actreditation. l'lwsc results obtuincd U\ing e'JWSut·e dahl shall bt· indicat\'d In 1111 a\h:ri\k. An~ tJUCrie., ct•nccruing the dnh1 in thi~ report ~lwuld he directed tu the l.nhnratnr) ,\lanagcr c:radku International Ltd. Thi~ report is nut h) bt• n:produccd. ~'ccpl in full \\ithnul tlw 11ritten permb!-inn uf(: radko lnlernatiunal Ltd.

Furm LQJ•J2b h!>uc ..J - Scptem het· 2011 Report Numher Y3235R Page 2 of 5

REPORT OFFICIALLY CHECKED 1 Gradko lntemotiooal Ud Tbls signature confinns the authenticity of these rewlls

Signed ...................... ~~ ........................................ . I-. Gates, Laboratory Supervisor

(A di vision of Gnulko lnternntional Ltd.)

St. \ 1artins House, 77 Wales Street \-\ ind wstcr. Ha mpshire S02J OR H lei.: 0 1962 8603.\1 rax: 01962 841339 e-mail :diffusinu (rog,·adkn.cn.ul\


233686 15/10/13 05/ 11/13 233685 15/10/13 05/11/13 233684 15/10/13 05/11/13 233683 15/10/13 05/11/13 233682 Junction R551 15/10/13 05/11/13

Extra 1 15/10/13 05/ 11 /13

Lab Blank


Tubes reported as <LO.D. are below the limit of detection. Extra tube was received and maximum exposure time used.

Bromide results are not within the scope of our UKAS accreditation.

OVERALL M.O.U. ±14.9%

Analysed on Dionex ICS1100 ICU10 ANALYST SIGNATURE

DATE OF ANALYSIS 26/11/2013

503.72 <LO.D. <LO.D <L.O.D. 503.83 <LO.D. <LO.D. <LO.D. 503.83 <L.O.D. <LO.D. <LO.D. 503.83 <LO.D. <LO.D. <LO.D.

503.83 <LO.D. <LO.D. <LO.D.

503.83 <LO.D <LO.D. <LO.D.

0.001

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT



233686

233685

233684

233683

Tube Identification


Extra 1

Lab Blank


Date On

15/10/13 15/ 10/13

15/10/13

15/10/13

15/10/13

15/ 10/ 13

Date Off

05/11 /13

05/ 11 /13

05/11/13

05/11 /13

05/11 /13

05/11 /13

Tubes reported as <LO.D. are below the limit of detection.

Extra tube was received and maximum exposure time used.

Exposure

(hrs)

503.72

503.83

503.83

503.83

503.83

503.83

PHOSPHATE as H3P04

~Pol ~Pol· HsPO.

Total Blank ~1m3

<LO.D. <L.O.D. <LO.D.

<L.O.D. <L.O.D. <LO.D. <L.O.D. <L.O.D. <l.O.D

<LO.D. <LO.D. <L.O.D.

<l.O.D. <LO.D. <L.O.D.

<l.O.D. <l.O.D. <L.O.D.

0.002

2187

<LO.D

<LO.D

<LO.D. <LO.D.

<LO.D.

<LO.D.

0.031Jg Br'

B. Gregory

27/11 /2013

H3P04

ppb

<LO.D.

<LO.D. <LO.D.

<l.O.D.

<l.O.D.

<LO.D.

llw Oitlu~inn l uhe~ ha\E' lw~n tcstcd ''ithinthe 'copt· "' (;radku lult•rmttioJtal Ltd LuhuntluJ') Qualil~ Pru~:l'dttrt-s cukuhHiuH'\ untla~w\smeut' imnhinl( the t''\posure procedure'iund pcriucl' tlrtl\idcd h~ tlw dlt• tH arr n111 within I he ,t·ope ufour l K \S :tl'l'f't•ditaliun. Tlww r·e,ull~ nhlained U'\iug e'\po~u•·c dllta ~hall be indiratt'd h.l an a\t('rhk. \n) querie' cunccrning the datu in lhb •·epurl o;huuld he dircrlcd tu the Lahm·atun \lanaget· (;radku lntennllionaJJ hJ. rhb l't'plll'l i!-1101 10 ht• rcprodUCI.'d. C\('1!(>1 in fuJI, 11itfwut the lll'illl'll penlli~silln ul'(;nufku lnlcl'mlliunuJI.td.

~unn L()l·J2b Issue 4 - Septcmhc• 1011 Report Nnmhcr Y 3235R Page 3 of 5

REPORT OFI'ICIALLY CHEOOJJ ] Gradko International U d

Tbls signature coormns tbe autbeotkity of these results

Signed ...................... ~~ ....................................... .. L. Gates, Laboratory Supervisor

(A dh ision of Gradko r nternntional Ltd. )

St. :\lartins House, 77 Wales Street Winchester. Hampshire S0 2J ORH tel. : 01962 8603J1 fax: 111962 8413JIJ e-ma i l : d i ffu~ion@gradko. l'u.uk

LABORATORY ANALYSIS REPORT Phosphate results are not within the scope of our UKAS accreditation.

2187

OVERALL M.O.U ±14.9% LIMIT OF DETECTION 0.0911g Po/· Analysed on Dionex ICS1100 ICU10

ANALYST SIGNATURE ANALYST NAME

DATE OF ANALYSIS 26/ 11/2013 DATE OF REPORT



233686

233685

233684

233683

Tube Identification


Extra 1

Lab Blank (RESULTS ARE BLANK CORRECTED)

Date On

15/10/13

15/10/13

15/10/13

15/10/13

15/10/13 15/10/13

Date Off

05/11 /13

05/11 /13

05/11/ 13

05/11/13

05/ 11/13

05/11 /13



Exposure

(hrs)

503.72

503.83

503.83

503.83

503.83 503.83

NITRIC ACID as N03

J.19 on Tube J.19 - Blank JLQ/m3•

Total

<LO.D. <LO.D. <LO.D.






0.01

B. Gregory

27/11/2013

ppb

<L.O.D.

<LO.D.

<LO.D.

<LO.D.

<LO.D.

<LO.D.

OVERALL M.O.U. ±14.9% LIMIT OF DETECTION 0.0911g N03.

Analysed on Dionex ICS1100 ICU10 ANALYST SIGNATURE ANALYST NAME B. Gregory

DATE OF ANALYSIS 26/11/2013 DATE OF REPORT 27/11/2013


DETERMINATION OF ACID GASES IN DIFFUSION TUBES BY ION CHROMATOGRAPHY 1 ht ll ilfusion 1 uhe., ha\e h«><'ll tc.,t~!l "ithin the 'rupt uf (;ntdku lnh·rnatinnal l .td l . ahuntlnr~ QuHiit) l 'rottdur<'~ t•akula timh and !"'es'>nu.>nh imnh ing the «''-JI••sure pr ocedure-. and Jll'riud~ pnn idt•cl h) lht• dit' lll an• not 11 ithin tlw 'cop~ nl our l K.\S acrrcditatiun. f hose re~ulh nhhtin~:d u'ing c'\pu~n rt• clata ,hall he indkatecl h~ au asteri ~k. \n.1 queril'' cuncenting till' datu in thh, n•pnrt -;hnuld he d irected to lht l.ahuratur~ \ lannger (;radko lntematioual l. ttl . !'hi~ rrpnrl is nut tu he r«>produt:td except in full , " ilhtlll l th1• \Hitt t•n perrnis~inn of c;radku lntern;•tionull. ld.

h orm t.QFJ2b hsue 4 Scptcmher 21112 Report Number Y 3235R Page 4 of 5 Gradko International U d

WORT OFfiCIALLY CHECKED This signature confirms the authenticity of these resull.s

Signed. ..................... ~~ ....................................... .. L. Gates, Laboratory Supeoisor

(A division of Gmdko International Ltd .)

St. 1\ lartins House, 77 \Vales Street Winchester. Hampshire S0 23 ORH t el. : 01 962 860331 fax: OJ 9fi1 8-'1339 c-mail:diffusion@gr adko.co.uk


p.g S04 p.g S04 p.g H2S04

Tube Identification Date On Date Off ' Exposure Total (·)Blank

(hrs)

233686 15/ 10/13 05/11/13 503.72 <LO.D. <LO.D. <LO.D.

233685 15/10/13 05/11 /13 503.83 <LO.D. <LO.D. <l.O.D.

233684 15/ 10/13 05/11 /13 503.83 <L.O.D. <LO.D. <l.O.D.

233683 15/10/13 05/ 11/13 503.83 <LO.D. <LO.D. <LO.D. 233682 Junction R551 15/10/13 05/11/13 503.83 <l.O.D. <LO.D. <L.O.D.

Extra 1 15/10/13 05/11/13 503.83 <LO.D. <l.O.D. <L.O.D.

Lab Blank 0.02




OVERALL M.O.U. ±14.9% LIMIT OF DETECTION

Analysed on Dionex ICS1 1 00 ICU1 0

ANALYST SIGNATURE ANAL VST NAME

DATE OF ANALYSIS 26/11 /2013 DATE OF REPORT


H2S04

p.g/m3•

<LO.D.

<LO.D.

<LO.D.

<LO.D.

<LO.D.

<LO.D.

0.1 OJ19 So/·

B. Gregory

27/11 /2013

I hl· l>ill'u~inn I ul11" h<lH hecn ~~~~tctl 11 ithin the '>l'U(Jt' oH, ntdku lnl!!t'llltlional l.ld . I a lwrnlur~ ()unlit) Pwc~dtll'l'' calcullttioll' uml u~sc;,~meuh imohing the n.pnsurc pr111'l'flurc1> and p!! riuds pn"idecl h~ tlw dit•nt are not 11ilhin lh r 'copt• nl nur l K \S m·t·reditatiun. fhose re.-.1111' nbtailwd u.,iug 1!\J)OMtn' data ~hall be ioulkatcd hy an '"lt·ri-.k. \n) 4lll!rlt•\ t'tmcernin~.: the dalll in this report -;lwuld he diretl!'d to the l.nhoraton \htnaget' c:radkn International Ltd I' his l'{'pnrt is nullo h!' repruduted. ('\{'tpt in full , II it hnul t he \1 ritten permi .. sinn of (:radkn ln lemational Ltrl.

F·nrml Qf.\2h hsut -l Septcmher 1012 Report Number Y32J51:{ Pagt• 5 of 5

REffiRT OFFICIALLY CHECKED J Gradko International Ltd This signature coolinns tbe authenticity of tbese mulls

Signed ... ""'''"""''""~'~ ....................................... .. L. Gates, Laboratory Supervisor

(A division of Gradko International Ltd.)

St. \lartin' House, 77 \\ales Street \\ indte~ter, Hampshire l;j0 23 ORH trl.: 01962 8603.31 fax: 111962 8-tl U9 t!-mail:diffu<oion0'gradku.co.uk

LABORATORY ANALYSIS REPORT AMMONIA ANALYSIS BY ION CHROMATOGRAPHY

Report No Y3237R

Booking In Reference No Y3237

Despatch Note Number SOR013994

Customer Environmental Protection Agency Attn.: Maria Lenihan lnniscarra, County Cork Ireland

Gradko Lab Reference No DICF5630-5635

Date Received 11/11/2013

233706 233705 233704 233703

Location

233702 Junction R551 233701 Extra tube

Lab Blank

Date On

15/10/2013 15/10/2013 15/10/2013 15/10/2013 15/10/2013

NB: Results are blank subtracted

Date Off

05/ 11 /2013 05/11 /2013 05/11/2013 05/11 /2013 05/11/2013

Exposure Jl9 NH4+ Jl9 NH3 (hours) Total

503.92 0.23 0.21 503.83 0.26 0.25 503.83 0.34 0.32 503.83 0.43 0.41 503.83 0.22 0.21 503.92 0.19 0.18

0.02 0.02

Jl9 NH3 • Blank

0.19 0.23 0.30 0.39 0.19 0.16

Tube 233701 was received but not listed on the exposure sheet. Maximum exposure time was used.

2187

TOTAL

NH3 NH3 IJQ/m3* (ppb)*

2.38 3.36 2.80 3.94 3.65 5.15 4.74 6.68 2.36 3.32 1.92 2.70

Overall M.U. ±5.8% Limit of Detection 0.114(.19 NH4 • on tube Analysed on Dionex ICS11 00

Analyst Signature Analyst Name M.Witek

Date of Analysis 15/11/2013 Date of Report 21 /11/2013

Analysis carried out in accordance with documented in-house Laboratory Method GLMS

I ht• Uillu,ion I ulu.•-. huH~ hN•n te-.tcfl "ithin the \ \:llfX' of (.rudkn lnll·rcwtiunal ltd. I ahtwalur 1 ()ualil~ l'rurrdurl'\takulalinn\ uml a""'''n•~·nl-. ill\ 11h 111~ llw ~''lltl'ure procedure' multwriud-. pnl\ ided h) tlw dit•nl nn• nul 11 ilhin the ~cupe ul nut l k. \~ :tl'lT~!dilalion. rtwse rc,ulh uhtuin~·d u'ing t'\llti'•IITI' data \hall he im.licuh·d h~ 1111 a\lcl bk. \n) 4ucril'' t:ontt•rning the data in thi.., report 'huuld hl' din:dcd to the I uhnralon \l;lnagt•r Cnulkn lntcrnullnnal I tel. This report I~ tltll tube n •pro<luced, t.''\t:t•pl in full, \\ lthnul the written pcrmb~inn nf (;radku l nternatinnull.td

f<utm l.()l l2h "'"t' ~ -'icptcrnhct WJ2 Report Number Y32.,7R Page 1 of 1

RHffiRT OFfiCIALLY CHECKED J C radJco lutemational Ud This signature confinns the authenticity or these resull$

Signed. .. " ................. ~~ ...................................... .. L. Gales, Laboratory So~or

ervi (A division of Gradko International Ltd.}

St. Martins House, 77 Wales Street Winchester, Hampshire S023 ORH tel.: 01 962 860331 fax: 01962 841339 e-mail :diffusion@'gradl..o.co.uk

2187

LABORATORY ANALYSIS REPORT HYDROGEN SULPHIDE IN DIFFUSION TUBES BY U.V.SPECTROPHOTOMETRY

Report number Y3236R

Booking in reference No Y3236

Despatch note No SOR013994

Customer Environmental Protection Agency Attn.: Maria Lenihan lnniscarra Cork, Ireland

Date samples received 11/11/2013

233696 233695 233694 233693

Location

233692 Junction R551 Travel Blank

Lab Blank

Results are blank subtracted

Overall M.O.U

Date of Analysis

Date Date exposed finished

15/10/2013 05/11/2013 15/10/2013 05/11/2013 15/10/2013 05/11/2013 15/10/2013 05/1 1/2013 15/10/2013 05/11/2013

13.53% +/-

12/11/2013

Exposure hours

503.83 503.83 503.83 503.83 503.83 503.83

~9 H2S ~9 H2S- H2S H2S Total Blank ~91m3* ppb*

<0.04 <0.04 <0.123 <0.087 <0.04 <0.04 <0.123 <0.087 <0.04 <0.04 <0.123 <0.087 <0.04 <0.04 <0.123 <0.087 <0.04 <0.04 <0.123 <0.087 <0.04 <0.04 <0.123 <0.087

0.02

Limit of detection 0.04~19

Analyst name S. Nock

Date of report 21/11/2013

Analysis carried out in accordance with documented in-house Laboratory Method GLM5

I he t>ilfusinn Tubes haH been tt·~lcd \\ilhin the ~cope ofGradko Jnrernational l td. LaboratOr) Quality Procedures calculation~ and assessments inwh ing the C\posure procedures and periods provicted b) the client arc not \\ithin the scope of ou r U KAS accreditation. Those rc~ults obtained using c'posurc data shall be indicated b.~ an asterisk. \ n) querie\ coneernin~ the data in this report should be directed to the Laborator) Manager Gradko lnteruational Ltd. Thh report is not to be reproduced. e\ccpt iu full. without the 'nitten permh~ion of G rudko International ltd.

Fm m I Ql :Uh hsue 4 September 2012 Report Number Y3236R Page l of l

I RRI'ORT OFfiCIALLY CHECKED I Gradko lnleroatiooal Ltd This signature coonnru the •ulbentldty or these ruulu

Signed - ~~ ·--· L. Gates, Laboratory Supa"\'isor

( \ d hisiun of<; radkn I ntt.>rnatwna l Ltd )

St . \tart in' Ilouw, 77 Wa l(·s Stnet \\ inr hester, Uamrshire S02J ORH tel.: 01962 860JJ I hl\: 11 1%2 R.tiJJ9 e- mail:diflw.ion agradko.co.uk

LABORATORY ANALYSIS REPORT DETERMINATION OF ACID GASES IN DIFFUSION TUBES BY ION CHROMATOGRAPHY

REPORT NUMBER Y3004R

BOOKING IN REFERENCE No Y3004

DESPATCH NOTE No SOR013463

CUSTOMER Environmental Protection Agency lnniscorra, Cork

DATE SAMPLES RECEIVED 21/1012013

GRADKO LAB REF GIN 6678-6683 JOB REFERENCE


Tube Identification Date On Date Off Exposure (hrs)

203457 Junction R551 (Ballybunion Rd) 17/09/13 15110/13 670.92 203462 17/09/13 15/10/13 670.83 203461 17/09/13 15/10/13 671 .00 203460 17/09/13 15/10/13 671 .08 203459 17/09/13 15/10/13 671 .00 203458 17/09/13 15/10/13 671 .00

Lab Blank (RESULTS ARE BLANK CORRECTED)

OVERALL M.O. U :t14.9% Analysed on Dionex ICS1100 ICU10

ANALYST SIGNATURE


flOC I Total

0.27 0.28 0.21 0.22 0.31 0.26

0.06

CHLORIDE AS HCL JlQCb • HCI Blank J1Qim3,.

0.20 3.94 0.22 4.23 0.15 2.91 0.16 3.14 0.25 4.86 0.20 3.88

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT



FLUORIDE AS HF Tube Identification Date On Date Off Exposure

(hrs) J19F JlQF . HF Total Blank J19fm3,.

203457 Junction R551 (Ballybunion Rd) 17/09/13 15/10/13 670.92 0.21 0.20 2.54 203462 17/09/13 15/10/13 670.83 0.26 0.25 3.20 203461 17/09/13 15/10/13 671 .00 0.21 0.19 2.45 203460 17/09/13 15/10/13 671.08 0.19 0.17 2.23 203459 17/09/13 15110/13 671 .00 0.23 0.21 2.71 203458 17/09113 15/10/13 671 .00 0.27 0.25 3.25

Lab Blank 0.02 (RESULTS ARE BLANK CORRECTED) Results may be higher than expected due to coelutlon of unknown compound.

HCL •ppb

2.60 2.80 1.92 2.08 3.21 2.57

o.14~g cr

B. Gregory

05/1112013

HF ppb*

2.85 3.59 2.75 2.50 3.04 3.64

I ht IIIIIU>iun I uhB ha.t h•~n l~">h•tl \Hihln lht• 't'flll\ ul (.radJ..u lnh•r u.tlicm.tl I td I .thul.tfllt \ (.)u till\ l ' a un rim t'~ t•akul:tlion' anrl a'" '~ 1111·11h im oh mg tlw t':\1"""' t• trrun•dutt s •HHIJ•~ • iuch JIH•\ ltlttl b.' llw cliC'rtl .11 <' nllt \\ ithlu th•• "·0111' o l out I 1, \S .H'CI l'dil .tlinu. l how r••,ulh uht.alnt•cl U\lu :.: t'\ftO,IItl tl:rt.t ' hall ht• ln tlk:th d h\ .m :t\lt·fi ,k \n) 'llll'rli·~ l<JIIl't•r nin~ lht 1l:rl ;1 in Jill- n'JIOI t 'lwultl lw <lit'l'l1l'tl tu til!' I allnr:tl nr) :\l:nr:tgn (.r~Hiku l nfl•rn;Hinnall Ill I h i ~ rrpott h tt tlllo Ill' n•pruclun•cl,l•lo:n•Jlllnlull. \\llhotlllhr \\tltrc·tt lll' r nth,fnn otl:radkn ltr trrrmtioual I trl.

Fottlll (.)1 Jlh l"u'·-' c;,.,H('fuh"' lUI! Rt· poJ'( umlu.•J' \ JUII..tl{ Pllgc 1 of J Gradko lntematlonal Ltd

moRT OFfiCIALLY CHECKED This signature confirms tbe authenticity or these results

Signed ....... '"'-""'"'~~··-·········· .. ·············-·····-L . Gates, Laboratory Supervisor

(\division ofGradko International L td.)

S1 . .2\ lartins rio usc, 77 Wales Stret>t Winch estH, liampshit·t' S023 ORI l td .. 01962 860331 fax: 01962 8-t1J39 c-mail : diffusioll '~ grndko.co.uk

LABORATORY ANALYSIS REPORT OVERALL M.O.U.

ANALYST SIGNATURE

DATE OF ANALYSIS

:1:1 4.9% Analysed on Dionex ICS1100 ICU10

28/1012013

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT




203457 Junction R551 (Ballybunion Rd) 17/09/13 15/10/13 670.92 203462 17/09/13 15/10/13 670.83 203461 17/09/13 15/10/13 671.00 203460 I 17/09/13 15/10/13 671.08 203459 ' 17/09/13 15/10/13 671.00 203458. 17/09/13 15/10/13 671 .00

Lab Blank (RESULTS ARE BLANK CORRECTED) Tubes reported as <L.O.D. are below the limit of detection. Bromide results are not wHhln the scope of our UKAS accreditation. OVERALL M.O.U. ±14.9%


DATE OF ANALYSIS 28/1012013

BROMIDE AS HBr J!QBr J!QBr • HBr Total Blank J.LQfm'4

<L.O.D. <L.O.D. <L.O.D. <L.O.D <L.O.D <L.O.D. <L.O.D. <L.O.D <L.O.D. <L.O.D. <L.O.D. <L.O.D. <l.O.D. <L.O.D <L.O.D. <L.O.D. <L.OD <L.O.D.

0.001

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT




203457 Junction R551 (Ballybunion Rd) 17/09/ 13 15/10/13 670.92 203462 17/09/13 15/10/13 670.83 203461 17/09/13 15/10/13 671 .00 203460 17/09/13 15/10/13 671.08 203459 17/09/13 15/10/13 671 .00 203458 17/09/13 15/10/13 671 .00

Lab Blank (RESULTS ARE BLANK CORRECTED) Tubes reported as <L.O.D. are below the limit of detection. Phosphate results are not within the scope of our UKAS accreditation. OVERALL M.O.U ±14.9%



PHOSPHATE as H3P04 JotgPO/' ~-t9Po.3• H3PO•

Total Blank J1Qim3

<l.O.D. <L.O.D <L.O.D. <L.O.D <L.O.D. <L.O.D. <L.O.D. <L.O.D. <L.O.D. <L.O.D. <L.O.D <L.O.D. <L.O.D <L.O.D. <L.O.D. <L.O.D. <l.O.D <l.O.D.

0.001

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT


B. Gregory

05/1112013

HBr ppb*'

<L.O.D. <L.O.D. <L.O.D. <L.O.D. <L.O.D. <L.O.D.

0.03~g Br'

B. Gregory

05/1 112013

H3PO• ppb

<LO.D <L.O.D. <L.O.D. <L.O.D. <L.O.D <L.O.D.

o.o9~g Po.~

B. Gregory

05/11/2013

I ht· l>il lu,ion J uht-~ ha' e hH'II le~ll'd "itllill till' \C'OJil' ol (; radh.u lntcrualional I hi. I abo1 a101' Qualit.' P roct llur t>s cakula lrom a u d a~'"'~mt•uts im oh in~ tlw C'\(JO,urt• J11'Uc<'l.lun•\ and (W I' iOih 111 u\'itlt'd h) lht' dit'nl arr not\\ ilhil1 lht scojH' ol ou1 I " \~ arct Nlitation. r ho'(' r('\ Ui h ohlahwll u~ing I'XJlu'ut r data 'hall b'· indk.ttul b~ .m a'lrrhl-. \n~ IJUfil'lrs CfiOC'l·r niug lh<· 1la1a ilr thh r11porl "houlll b1• dlr<'rti·JI to th<' L:'tboratOQ \LIII.Jl:''r ( : r.ulh.o lnh•rn:tlionall Ill fhl\ rf'll'lrlls nol ro b€' r ('pro!lllr('d , nr€'pt In fnll, "ithonrrJw \\dlt<'n pPrmh~ion of c:radko lntt·rnallonal l td

Form! QI J2h h 'uc4- St•tJit>n lh€'r .W12 Rt.•port 'Htlllhl•l' \'JOIU R ]>ugt: 2 ut' 3

I REPORTO~CMLLYCHECKED Gradko International Ltd

This signa ture confirms I be authenticity of these resulls

Signed. .................. -.~~ ...................................... ,_ L. Gales, Laboratory Supervisor

(A divisil)n oi' G radko Internat ional Ltd .)

St. \ fartin~ House, 77 \\ a les Sti'N'f \\'inrhc~tcr, lia mpshire 8023 ORH tel. : 01 962 R6033 J fax: 01962 841339 e-mail:tlin'usiolllci'gradko.co.uk




203457 Junction R551 (Ballybunion Rdl 17/09/13 15/10/13 670.92 203462 17/09/13 15/10/13 670.83 203461 17/09/13 15/10/13 671.00 203460 17/09/13 15/10/13 671 .08 203459 17/09/13 15/10/13 671 .00 203458 17/09/13 15/10/13 671.00

Lab Blank (RESULTS ARE BLANK CORRECTED) Tubes reported as <L.O.D. are below the limit of detection. OVERALL M.O.U. ±14.9%



1'9 on Tube Total

<l.O.D. <l.O.D. <L.O.D. <l.O.D. <L.O.D <L.O.D.

0.01

NITRIC ACID as N03 1'9 · Blank J19/m3•

<L.O.D <L.O.D. <l.O.D <L.O.D. <L.O.D <L.O.D. <L.O.D <L.O.D. <L.O.D. <L.O.D <l.O.D <L.O.D.

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT



ppb

<L.O.D. <L.O.D. <L.O.D. <L.O.D <L.O.D. <L.O.D

B. Gregory

05/11/2013

SULPHATE as H2S04 Tube Identification Date On Date Off Exposure

(hrs)

203457 Junction R551 (Ballybunion Rd) 17/09/13 15/10/13 670.92 203462 17/09/13 15/10/13 670.83 203461 17/09/13 15/10/13 671.00 203460 17/09/13 15/10/13 671.08 203459 17/09/13 15/10/13 671 .00 203458 17/09/13 15/10/13 671 .00

Lab Blank (RESULTS ARE BLANK CORRECT ED) Tubes reported as <L.O.D. are below the limit of detection. OVERALL M.O.U. ±14.9%

Analysed on Dionex ICS11 00 ICU10 ANALYST SIGNATURE


J1QS04 119 S04 119 H2S04 Total (-) Blank

<L.O.D. <L.O.D <L.O.D. <L.O.D. <L.O.D <L.O.D. <l.O.D. <LO.D <L.O.D. <L.O.D. <L.O.D. <L.O.D <l.O.D. <L.O.D <L.O.D. <L.O.D <L.O.D <l.O.D.

0.02

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT


H2S04 J19im3o

<L.O.D. <L.O.D. <L.O.D <L.O.D. <L.O.D. <L O.D

o.1o~g so/·

B. Gregory

05/11/2013

H2S04 ppb

<L.O.D. <L.O.D. <L.O.D <L.O.D <L.O.D <l.O.D.

I ft,. l)llfusion luh .. ~ h:l\(' hnn lt·siNl \\i!hlnlht- \tOp£• ol (.t'<Hlko lnl<>rna1ional l ld Labomlor ~ Ouahl~ P roct.'dur t>s l":tkulatlons arHI ' I\Sl'\\lllt-111!1 invohin:.:·tlw <'\(JO~un· prt~<"rdurc.>' and (Jrdod' llrO\ h ll·tl b) thl' di<·nl :ll'l' not\\ ilhiu the sCOJll' of ou1 I ' K\S accH·•Iif;llion. I h osl' l't"sult~ obl:linNI u~ing rxpomre rla1<1 ~hall hl' indk:ll{'(l b~ ''" :1\h•ri\k. \u~ I(Ul'J'li.>~ COIIH'I'ning tlu· !lata in this t'C(lOrl 'hnuld lw dh·l'df'd to the l.abor:.tor) \l:lll:t~t•r Ct':'Hikr, lnh'l'llation.tll hi rlth r•·Jtort h not rn bl' r11pr01hrrl'd. <'"'''Plio full, nl1hont thC' \Hitfc>o p!'rmh,ion of Cr:utl,o ltltC'rnrtlional l td.

l'(•rrn I (.)1 Jlh l ~sue4-S~JJIE'mber !012 Rt'!HH't ~tuul•t'l' \ '3UU4H. Page 3 ofJ Gradko International Ltd

Tbis signature confinns the auUlenticity of these results

Signed ...................... ~.~ ....................................... .. L. Gates, Laboratory Supervisor

(.\ di,i o;iun uf( ;r;u.JI.:n lnlt' t nationa l L td . )

St. \hu·tin' l lou,t, 77 \\ale« Slrert \\ inrlu·st('r, Hampshirr SOU Ill~ I I trl.: 0 1962 H60JJ I Ia \: 111\Jhl 8~1JJ9 r -ma il:dill'u, ion u gradko.w.uk

LABORATORY ANALYSIS R F. PORT AMMONIA ANALYSIS BY ION CHROMATOGRAPHY

Report No Y3003R

Booking In Reference No Y3003

Despatch Note Number SOR013780

Customer Environmental Protection Agency

lnniscarra, County Cork Ireland

Gradko Lab Reference No DICF5184-5189 Job Reference 046827

Date Received 21/10/2013

Location Date On Date Off

222182 Junction R551 17/09/2013 15/10/2013 222187 17/09/2013 15/10/2013 222186 17/09/2013 15/10/2013 222185 17/09/2013 15/10/2013 222184 17/09/2013 15/10/2013 222183 17/09/2013 15/10/2013

Lab Blank

NB: Results are blank subtracted Missing black overcaps. Results may be compromised.

Overall M.U. ±5.8% Analysed on Dionex ICS11 00

Analyst Signature

Date of Analysis 28110/2013

Exposure (hours)

670.92 670.83 671 .00 671 .08

671 .00 671 .00

1-19 NH/

0.80 0.55

0.73 0.55

0.56 1.09

0.04

~o~g NH3 Total

0.76 0.52 0.69 0.52

0.53 1.03

0.04

IJg NH3-Blank

0.72 0.48 0.65 0.49 0.49 0.99

6.63 4.41

6.00 4.46 4.49 9.09

TOTAL

NH3 (ppb)•

9.35 6.22 8.46 6.29 6.34 12.82

Limit of Detection 0.1141J9 NH4 • on tube

Analyst Name M.Witek

Date of Report 30/10/2013

Analysis carried out in accordance with documented in-house Laboratory Method GLMS

I Ill' Dillusiuu I uht•s h:" < hl'en h si<·•J \\ lllun lhl' \\'OJH' ol t.a .1dko hllt'tll.t l1011:1l l.lcl. L.thm 1Im' (}u.tlll~ l ' t llHIIUil'\ l.llculalion'> .uul.tHt """'llh

im ohing tlw C\f!O\Urt' Jll ocl'dUt "' .trlll fll'tloth flro' id('d b~ tb(' dirnt at< not nit hill lhl' ~CIIJil •Jiout l J, \S arr1 c·,Jit.llion l'ho\e results ohl.tln('(l u~lng <''\PihUn· d11la \hall hl' illltlt.tll'll h) 1n a\H·rbk. \n) quc·t it·s wnr.·tnin~ lht· d •• ta In thh rt'JIIIrl s huultl ht• tlil'l't'lrtl tu tlw Lah•walnt y \l.m:tgl'l C:r:11lko lnh•t nnllnnall tel I hh 1 ('Jtn•·l 1~ nul tn bl' r1rwot1m·t·d, ("\l"l'fll In lull," llhuul lh l' 1\lltlt'll JH'rtuh~ftm nf ( :mdko lntrrrmllonal I Ill

ltllllii.QIJ2hi\\U('.f-"l'flll'lllhl'l 11112 nt'fHII't '\umh<•t• \JOO.ln Pagl·l ufl Gradko International Ud

UfORT OfFICIALlY CHECKED This signature conlinns the authenticity of these results

Signed. ........... - ....... /:~!!;;.~ ........................................ . L. Gates, Laboratory Supervisor

(A division ofGradko lnternational Ltd.)

St. Martins House, 77 Wales Street Winchester, Hampshire S0 23 ORII tel.: 01 962 860331 fax: 01962 841339 e-mail:diffusionla'gradko.co.uk

LABORATORY ANALYSIS REPORT HYDROGEN SULPHIDE IN DIFFUSION TUBES BY U.V.SPECTROPHOTOMETRY

Report number Y3002R

Booking in reference No Y3002

Despatch note No SOR013780

Customer Environmental Protection Agency lnniscarra Cork

Date samples received 21/10/2013

Location

222171 Junction R551 222177 222176 222175

222174 222173

Lab Blank

Results are blank subtracted

Overall M.O.U

Date of Analysis

Date Date exposed finished

17/09/2013 15/10/2013 17/09/2013 15/10/2013 17/09/2013 15/10/2013

17/09/2013 15/10/2013

17/09/201 3 15/10/201 3 17/09/2013 15/10/201 3

13.53% +/-

31/10/2013

Exposure hours

670.92 670.83 671 .00

671.08

671.00 671.00

J.l9 H2S J.l9 H2S • H2S H2S Total Blank J.1Qim

3* ppb*

<0.04 <0.04 <0.092 <0.065 <0.04 <0.04 <0.092 <0.065 <0.04 <0.04 <0.092 <0.065

<0.04 <0.04 <0.092 <0.065

<0.04 <0.04 <0.092 <0.065 <0.04 <0.04 <0.092 <0.065

0.03

Limit of detection 0 .04~l9

Analyst name S. Nock

Date of report 01/11/2013

Analysis carried out in accordance with documented in-house Laboratory Method GLM5

The Diffusion lubes ba"e been tc~tcd 11ithin th~ scope of Gradko lnlcrnnlionlll Ltd. Laborntof) Quality Procedures calculat ions and asse~smcnls imoh ing the e\posurc procedures nnd periods pro1 ided by the client ar ·e not ~ithin the scope of our UKAS nccrcd itat ion. Those results obtained using exposure data sha ll be indicated b~ an nstel'isk. Any querie~ concerning the data in this report ~hould be directed to the Laboratot')' Manager Gradko International Ltd. This report is not to be reproduced, except in fu ll , n ithout the written per·mission uf Grudko International Ltd.

Form LQFUb Issue 4 - Septcmbet· 2012 Report Number Y3002R Page I of 1

I REffiRT OfFICIALLY CHECKED I Sipd-

Gradlto l olematioual Ltd Thl5 iigualure ronnnns I be autbentlclly or lbae results

~~ _..;._..._, ___________ _ L. GattS, Labontory Supenisor

From: Ken Murphy

Sent: 15 November 2013 16:23 To: Peter Cunningham; Niamh O'Donoghue; Maria Lenihan

Cc: Ian Marnane Subject: Brandon Products - Diffusion Tubes Comparison with Guideline Limits

Hi All, I have attached a table with the diffusion tubes results compared against the Environment Agency’s Environmental Assessment Level (EAL) guidelines (& World Health Organisation (WHO) guidelines where available). All results have been blank corrected. Link to E.A. EAL guidelines: http://a0768b4a8a31e106d8b0-50dc802554eb38a24458b98ff72d550b.r19.cf3.rackcdn.com/geho0410bsil-e-e.pdf HBr, Nitric Acid & Sulphuric Acid were all <LOD and so were omitted. All results are below short term & long term EAL’s. In terms of HF, the results do look slightly elevated. Ian provided me with details of a California EPA long term exposure limit of 30 ug/m3 and the results are within this limit. The Canadian EPA have set a 30 day reference level for HF (for protection of vegetation) of 0.4 micrograms/m3, the results reported from the HF tubes are above this level. Link to the California EPA study: http://www.epa.gov/airtoxics/hlthef/hydrogen.html) Link to the Canadian EPA report: http://www.bape.gouv.qc.ca/sections/mandats/ap50_rio_tinto_alcan/documents/DQ3.1.1.pdf Looking back at the main monitoring report the HF result also appears elevated. Catalyst tested for HF as part of the main monitoring and the result was 1.7mg/m3 (measured over 7 hours), to put this in some kind of context the daily average limit on Indaver’s licence is 1mg/m3. Regards, Ken

http://a0768b4a8a31e106d8b0-50dc802554eb38a24458b98ff72d550b.r19.cf3.rackcdn.com/geho0410bsil-e-e.pdf

http://a0768b4a8a31e106d8b0-50dc802554eb38a24458b98ff72d550b.r19.cf3.rackcdn.com/geho0410bsil-e-e.pdf

http://www.epa.gov/airtoxics/hlthef/hydrogen.html

http://www.bape.gouv.qc.ca/sections/mandats/ap50_rio_tinto_alcan/documents/DQ3.1.1.pdf

Location Ammonia Result

WHO Guideline Human Health (24 hr average)

WHO Guideline Odour Nuisance (30 min average)

Long Term EAL (annual mean)

Short Term EAL (1 Hour mean)

Junction R551 6.63µg/m3 N/A N/A 180 µg/m3 2500 µg/m3

4.41 µg/m3 N/A N/A 180 µg/m3 2500 µg/m3

6 µg/m3 N/A N/A 180 µg/m3 2500 µg/m3

4.46 µg/m3 N/A N/A 180 µg/m3 2500 µg/m3

4.49 µg/m3 N/A N/A 180 µg/m3 2500 µg/m3

9.09 µg/m3 N/A N/A 180 µg/m3 2500 µg/m3

Location H2S Result





Junction R551 <0.092 µg/m3 0.15mg/m3 7 µg/m3 140 µg/m3 150 µg/m3

<0.092 µg/m3 0.15mg/m3 7 µg/m3 140 µg/m3 150 µg/m3





Location HCl Result





Junction R551 3.94 µg/m3 N/A N/A 20 µg/m3 800 µg/m3

4.23 µg/m3 N/A N/A 20 µg/m3 800 µg/m3

2.91 µg/m3 N/A N/A 20 µg/m3 800 µg/m3

3.14 µg/m3 N/A N/A 20 µg/m3 800 µg/m3

4.86 µg/m3 N/A N/A 20 µg/m3 800 µg/m3

3.88 µg/m3 N/A N/A 20 µg/m3 800 µg/m3

Location HF Result




California EPA Long Term Exposure level

Canadian EPA (30 day Ref Level for Protection of Vegetation)

Junction R551 2.54 µg/m3 N/A 16 µg/m3 160µg/m3 30µg/m3 0.4 µg/m3

3.20 µg/m3 N/A 16 µg/m3 160µg/m3 30µg/m3 0.4 µg/m3





(Prepared on behalf of the EPA by Catalyst Environmental-

EMISSIONS REPORTEPA AIR EMISSIONS COMPLIANCE MONITORING

-

T: 0800 328 1821

Brandon ProductsKilcolman

AsdeeCounty Kerry

Report Written by

James Harmer

5th November 2013Report Date

TE1 TE2 TE3 TE4MM 03 156

MCERTS Level 2Technical Manager

Regional Manager

TE1 TE2 TE3 TE4MM 03 200

MCERTS Level 2

Barry Grant

Report Approved by

Dates of the Monitoring Campaign

EP-Bio Scrubber

Version

E: [email protected]

Stack Emissions Testing Report Commissioned by

17th September 2013

Job Reference NumberP0957-01SAR13-01

EPA Office of Environmental Enforcement

Installation Name & Address

Your Catalyst Contact: Barry Grant (07826 916 683)

Stack Reference

Irish EPA IPPC Licence: P0957-01 (Pending)

Signature of Report Approver

Version 2

Unit 18 Tallaght Business Centre, Whitestown Business Park, Tallaght, Dublin 24

TITLE PAGE

CONTENTS

EXECUTIVE SUMMARY

Monitoring Objectives

Monitoring Results

Monitoring Dates & Times

Process Details

Monitoring & Analytical Methods

Summary of Method Deviations

Sampling Location

Plant Photos / Sample Points

APPENDIX 1 - Monitoring Personnel & List of Equipment

APPENDIX 2 - Raw Data, Sampling Equations & Charts

2

Opinions and interpretations expressed herein are outside the scope

of Catalyst Environmental Ltd's UKAS accreditation.

This version of the test report supersedes the previous version of the

test report. Please destroy all previous versions to ensure no

confusion arises from having multiple test reports in existence.

9

3

5

6

8

This test report shall not be reproduced, except in full, without the

written approval of Catalyst Environmental Ltd.

CONTENTS

7

4

7

CAT-RT (Version BB)

Page 2 of 64

Brandon Products

County Kerry

EP-Bio Scrubber

Job Number: P0957-01SAR13-01, Version 2

Sample Date/s: 17th September 2013


Overall Aim of the Monitoring Campaign

Special Requirements

Target Parameters

Catalyst Environmental Ltd were commissioned by EPA Office of Environmental Enforcement to carry out stack emissions

testing for Brandon Products on the EP-Bio Scrubber at County Kerry.

The aim of the monitoring campaign was to demonstrate compliance with a set of emission limit values (ELVs) as specified in

the Site's Permit.

There were no special requirements.

Hydrogen Sulphide,Diethylamine , Dimethylamine , Ethanolamine , Methylamine , Trimethylamine , Ethyl Mercaptan ,

Methyl Mercaptan , N-Butyl Mercaptan ,Total VOCs (as Carbon), Oxides of Nitrogen (as NO₂), Sulphur Dioxide, Carbon

Monoxide, Hydrogen Chloride, Hydrogen Fluoride, Ammonia, Odour, Bioaerosols

MONITORING OBJECTIVES

Executive Summary(Page 1 of 9)

Brandon Products, County Kerry

EP-Bio Scrubber

17th September 2013

CAT-RT (Version BB)

Page 3 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




where MU = Measurement Uncertainty associated with the Result

Parameter

Hydrogen Sulphide ¹ < <

Diethylamine ¹ < <

Dimethylamine ¹ < <

Ethanolamine ¹ < <

Methylamine ¹ < <

Trimethylamine ¹ < <

Ethyl Mercaptan ¹ < <

Methyl Mercaptan ¹ < <

N-Butyl Mercaptan ¹ < <

Total VOCs (as Carbon) ¹ - -

Oxides of Nitrogen (as NO₂) ¹ - -

Sulphur Dioxide ¹ - -

Carbon Monoxide ¹ - -

Hydrogen Chloride ¹ - -

Hydrogen Fluoride ¹ - -

Ammonia ¹ - -

Oxygen Wet Dry

Water Vapour

Stack Gas Temperature

Stack Gas Velocity

¹

²

NOTE: VOLUMETRIC FLOW RATE DATA TAKEN FROM THE PRELIMINARY VELOCITY TRAVERSE.

¹ Reference Conditions (REF) are: 273K, 101.3kPa, without correction for water vapour content.

Parameter

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Odour ²

Where CI stands for Confidence Interval (or Uncertainty associated with the result)

² Reference Conditions (REF) are: 293K, 101.3kPa, wet gas

783 355 1729

238 108 525 ouE/s 727 329 1606

271 123 599 ouE/s 829 375 1830

184 83 405 ouE/s 561 254 1240

347 157 766 ouE/s 1060 480 2341

256 116 566 ouE/s

1046 474 2311 ouE/s 3199 1449 7066

367 166 811 ouE/s 1122 508 2479

238 108 525 ouE/s 727 329 1606

Odour - Stack - Bag 1










Odour - Formulation

Odour - Evaporation Room

ouE/m³

ouE/m³

ouE/m³

ouE/m³

ouE/m³

ouE/m³

ouE/m³

ouE/m³

3.2 0.79 -

mg/m³ 0.31 0.08 - g/hr 3.2 0.79 -

mg/m³ 0.31 0.08 - g/hr 3.2 0.79 -

189 86

184 83

332 150

1240

94

561 254

418

Volumetric Flow Rate (REF)

-

% v/v

Volumetric Flow Rate (REF)

°C

Concentration

ouE/s

20.2

% v/v

262

ouE/s405

732

Mass Emission

1014 459

1277ouE/m³

CI CI

12.6

- 0.52 -

5.33

mg/m³

0.66mg/m³

Units Result LOWER UPPER Units Result LO CI HI CI

10962

m³/hr

1.26

20.8

m/s

0.13

15.8

g/hr

m³/hr

0.74

4.0

0.71

7.6

ouE/m³

2239

636


17th September 2013

+/-

Units Result

Concentration

MU

-

-0.72

mg/m³

mg/m³

mg/m³

mg/m³

mg/m³

g/hr

Result MU Limit

+/-

EP-Bio Scrubber

Executive Summary

Units

mg/m³

Limit

6.3

Mass Emission

MONITORING RESULTS (Page 1 of 2)

0.05

2.1

288 1405

mg/m³ 0.31 0.08 - g/hr

0.28

mg/m³

ouE/m³

Volumetric Flow Rate (ACTUAL)

578

m³/hr 11007

208

1.2

g/hr

41.1 7.3

g/hr

-

-

-

4.0

mg/m³ g/hr0.39

0.73

g/hr

g/hr

mg/m³

-

-

0.76 -0.39 7.8

0.18

2.1

2.1

2.1

2.1

4.0

6.2 6.8

mg/m³ 1.8

ouE/m³ 459 ouE/s

-

17.2-

-

-

7.3 12.9

0.07

(Page 2 of 9)

1.7

mg/m³

g/hr

-0.61

0.52

0.52

0.52

0.52

g/hr

g/hr

g/hr

g/hr

5.33

5.33

5.33

0.61

% v/v

2.7

10256

7.9

ouE/s

5.33

-

-

-

-

-

21.5

21.5

21.5

21.5

21.50.52 -

-

-

-

-

g/hr

ODOUR SAMPLING DETAILS

CAT-RT (Version BB)

Page 4 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




where MU = Measurement Uncertainty associated with the Result

Parameter

Total Bacteria Odour ¹ - -

Fungi ¹ < - < -

Gram Negative ¹ - -

¹ Reference Conditions (REF) are: 273K, 101.3kPa, without correction for water vapour content.

11419227194

60571994426


MONITORING RESULTS (Page 2 of 2)


EP-Bio Scrubber

17th September 2013

BIOAEROSOLS SAMPLING DETAILS Concentration Mass Emission

Units Result Units Result

1080369

1502423

cfu/hr

cfu/m³

cfu/hrcfu/m³ 5273819

cfu/m³

135 cfu/hr

1604348

31.8

MU

328659

+/-

MU

+/-

3473843105

353760

18426606424

ELV

ELV

CAT-RT (Version BB)

Page 5 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Parameter

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 < <

R2 < <

R3 < <

R1 - -

R1

R1 - -

R1 - -

R1 - -

R1 - -

R1 - -

R1 - -

TIME 1: 09:52 - 09:56, 10:42 - 10:46, 11:43 - 11:47

TIME 2: 12:30 - 12:34, 13:10 - 13:14, 13:55 - 13:59

TIME 3: 14:54 - 14:58 - 15:39 - 15:43, 16:20 - 16:24, 16:40 - 16:44

g/hr 3.2 17/09/2013 TIME 2

N-Butyl Mercaptan mg/m³ 0.31 g/hr 3.1 17/09/2013 TIME 3

3.2 17/09/2013 TIME 2 12

Methyl Mercaptan mg/m³ 0.31 g/hr 3.1 17/09/2013 TIME 3 12

N-Butyl Mercaptan mg/m³ 0.32 g/hr 3.3 17/09/2013 TIME 1

3.3 17/09/2013 TIME 1

Ethyl Mercaptan mg/m³ 0.31 g/hr 3.2 17/09/2013 TIME 2

Ethyl Mercaptan mg/m³ 0.31 g/hr 3.1 17/09/2013 TIME 3

TIME 2 12

12

17/09/2013

12

17/09/2013

17/09/2013

12

12

12

12

12

12

Date(s)

Mass Emission

17/09/2013

TIME 1 12

Diethylamine mg/m³ 2.08 g/hr 21.3 17/09/2013 TIME 2 12

Diethylamine mg/m³ 2.06 g/hr 21.2 17/09/2013 TIME 3

2.06

TIME 3

mg/m³ 0.32 g/hr

09:00 - 16:00mg/m³

0.8

g/hr

g/hr

09:00 - 16:00

g/hr

mg/m³

20.8

09:00 - 16:00

TIME 1

2.08 g/hr 21.3

mg/m³

mg/m³

0.7

mg/m³ 2.06 g/hr 21.2

21.2

4.0

mg/m³ 2.08 g/hr 21.3 17/09/2013

420

420

420

420

420

420

% v/v

0.1

1.7 g/hr

g/hr

0.6

1.2

mg/m³

22.0 17/09/2013

2.06

09:00 - 16:00

g/hr

Sampling

Times

Executive Summary


2.06 g/hr

mg/m³ 2.08 g/hr

mg/m³

0.54

13:45 - 14:25

12:06 - 13:06

09:06 - 10:06

17/09/2013

17/09/2013

17/09/2013

0.72

21.2

TIME 1

Duration

mins

5.9

5.6

Units Concentration Sampling

MONITORING DATE(S) & TIMES (Page 1 of 2)

EP-Bio Scrubber

17th September 2013

(Page 4 of 9)

Ethanolamine

09:00 - 16:00

09:00 - 16:00

Ethanolamine

Methylamine g/hr

Trimethylamine mg/m³

Trimethylamine mg/m³ 2.15 g/hr

Units

7.4

mg/m³ 2.15 g/hr 22.0 17/09/2013

21.3 17/09/2013 TIME 2

mg/m³

mg/m³

12

40

60

60

Diethylamine

Ethanolamine

Dimethylamine

Dimethylamine

g/hr

g/hr

g/hr

g/hrHydrogen Sulphide

Hydrogen Sulphide

Hydrogen Sulphide 0.57

mg/m³

g/hr

mg/m³

Trimethylamine

Ethyl Mercaptan

g/hr

Methylamine mg/m³ 2.15 g/hr

Methylamine mg/m³ 2.08 g/hr

2.15

mg/m³

mg/m³

mg/m³ 2.15

mg/m³

Ammonia

Carbon Monoxide

Oxygen

Sulphur Dioxide

g/hr

Oxides of Nitrogen (as NO₂) mg/m³

12

12

12

12

12

17/09/2013

17/09/2013

22.0

17/09/2013

17/09/2013

17/09/2013

17/09/2013

21.2

3.3

Total VOCs (as Carbon)

Hydrogen Chloride

Hydrogen Fluoride

Dimethylamine

Methyl Mercaptan mg/m³ 0.32 g/hr

Methyl Mercaptan mg/m³ 0.31 g/hr

N-Butyl Mercaptan mg/m³ 0.31

17/09/2013 TIME 3

TIME 2

17/09/2013

41.1

7.3

7.8

17.2

0.7

09:00 - 16:00

22.0

TIME 2

TIME 3

09:00 - 16:00

17/09/2013

21.3

12.6

22.0 17/09/2013 TIME 1

17/09/2013

TIME 1

TIME 3

TIME 1

17/09/2013

17/09/2013

17/09/2013

6.2

420

420

12

12

12

12

12

CAT-RT (Version BB)

Page 6 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Parameter

B1 -

B2 -

B3 -

B4 -

B5 -

B6 -

B7 -

B8 -

B9 -

B10 -

B1 -

B1 -

R1 -

R2 -

R1 -

R2 < <

R1 -

R2 -

R1

All results are expressed at the respective reference conditions.

cfu/hr 973218 20/09/2013 14:38 - 14:58 20

Gram Negative cfu/m³ 9218700 cfu/hr 1.08E+11 21/09/2013 11:22 - 11:42 20

Gram Negative cfu/m³ 1328937 cfu/hr 1.35E+10 22/09/2013 14:38 - 14:58 20

7.11E+09

Total Bacteria cfu/m³ 1552043 cfu/hr 1.57E+10 18/09/2013 14:38 - 14:58 20

Fungi cfu/m³ 174 cfu/hr 2031627 19/09/2013 11:22 - 11:42 20

4

17/09/2013 11:22 - 11:42 20

184 11:43 - 11:47

Velocity & Volumetric Flow Rate 09:00 - 09:1017/09/2013

13:10 - 13:14

13:05 - 13:09

ouE/m³ 256

ouE/s

ouE/s

ouE/s 829ouE/m³ 271

12:30 - 12:34

13:28 - 13:48

208 09:52 - 09:56

ouE/m³

ouE/m³

14:03 - 14:23

ouE/m³

ouE/m³ 184 16:20 - 16:24

ouE/m³

367

4

4

4

4

636

578

1014

4

ouE/m³

ouE/m³ 332

ouE/m³

1046

ouE/m³ 347 16:40 - 16:44

15:39 - 15:43

14:54 - 14:58

189 10:42 - 10:46

96

Odour - Stack

Odour - Stack

Odour - Stack

Odour - Stack

Odour - Stack

Odour - Stack

Odour - Stack

Odour - Stack

Odour - Stack

Odour - Formulation

Odour - Stack

238

ouE/m³ 238

17/09/2013

17/09/2013

17/09/2013

17/09/2013

3199

1122 17/09/2013

783

ouE/s

ouE/s

ouE/s

ouE/s

ouE/s

ouE/s

ouE/s

ouE/s

Total Bacteria cfu/m³ 608695 cfu/hr

Fungi cfu/m³

17/09/2013

17/09/2013

17/09/2013

561

1060

Odour - Evaporation Room

ouE/s

17/09/2013 20

20

727

727

561

4

4

4

4

17/09/2013

17/09/2013

17/09/2013

17th September 2013

Units Concentration Units Mass Emission Sampling Sampling Duration


MONITORING DATE(S) & TIMES (Page 2 of 2)


EP-Bio Scrubber

Date(s) Times mins

CAT-RT (Version BB)

Page 7 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Standard Operating Conditions

Bio Scrubber


Value

Feedstock (if applicable)

EP-Bio Scrubber

17th September 2013

Production of phosphate based, nitrogen based & potassium based

fertilisers

Full Capacity

Process Status

None Visible

Capacity (of 100%) and Tonnes / Hour

Continuous or Batch Process

N/A

On

Continuous / Batch

PROCESS DETAILS

Parameter

(Page 4 of 7)

Executive Summary

Seaweed

Fuel

Plume Appearance

Abatement System

Abatement System Running Status

CAT-RT (Version BB)

Page 8 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




All

UKAS Accreditation Number: 1549

0.01 mg/m³

Due to the platform's restricated access, 2 points were sampled at in the duct instead of all 4 sample points. It is not

thought this would have had too much of an effect on the final result.

Yes

BS EN 13284-1 CAT-TP-04

VDI 4257 Blatt 2 CAT-TP-36 CAT

TGN M22

CAT-TP-22(b)

QD01

CATYes

CAT-TP-22(b)

FTIR by ProtIR 204M

CAT

Yes

Yes

Yes

Yes

CAT-TP-22(b)

BS EN 12619:2013

CAT

No SAL No 0.307 mg/m³

N-Butyl Mercaptan 0.307 mg/m³

0.1 % v/v

Ethyl Mercaptan BS EN 13649 CAT-TP-16 No N/A In House GC/MS(TD) No SAL No 0.307 mg/m³

Methyl Mercaptan BS EN 13649 CAT-TP-16 No N/A In House GC/MS(TD)

BS EN 13649 CAT-TP-16 Yes CAT

The water vapour content of the stack was much higher than expected, in fact the gas strema was saturated with

water droplets. This made it impossible to take direct tubes samples for amines and mercaptans, even when tyring

to perform dynamic dilution with Mass Flow Controllers and a cylinder of Nitrogen. When back at the office, part of

the stack gas in each of the stack sourced odour bags was decanted into 3 fresh bags and a known volume from

these bags were then passed over the tubes and sent off for analysis.

HF failed the test of residuals which means that there may be something else in the sample affecting the result for

HF (and leading to a higher value being reported). The results reported should therefore be taken as a "worst case"

value.

0.06 %

Yes CAT

Olfactometry

CAT-TP-05 YesBS EN 14790

FTIR by ProtIR 204M

Amines & Mercaptans All

Hydrogen Fluoride 1

Bioaerosols (Total Bacteria, Fungi

& Gram Negative)

Pitot Tube and Thermocouple

CAT-TP-22(b)

Yes

CAT

FTIR by ProtIR 204M

FTIR by ProtIR 204M

Oxygen

Yes

IC Yes

IC Yes RPS Yes

RPS Yes

Lab

BS EN 13649 CAT-TP-16 No N/A In House GC/MS(TD) No SAL No

2.066 mg/m³

2.066 mg/m³

2.066 mg/m³

2.066 mg/m³

2.066 mg/m³

BS EN 13649 CAT-TP-16 Yes IC Yes RPS Yes

A1(U) IC Yes RPS Yes

BS EN 13649 CAT-TP-16 Yes CAT A1(U) IC Yes RPS Yes

BS EN 13649 CAT-TP-16 Yes CAT

RPS Laboratories Ltd (RPS)

OdourNet UK Ltd (ODO)

Scientific Analysis Laboratories Ltd (SAL)

Trimethylamine

CAT A1(U)

Diethylamine

Dimethylamine

Ethanolamine

Methylamine

BS EN 13649 CAT-TP-16 Yes CAT A1(U)

Analysis

Procedure

Analytical

Technique

Analytical

M120

Analysis

17th September 2013


EP-Bio Scrubber

A1(U)

Executive Summary

Testing

Monitoring

Parameter

Yes 0.21 mg/m³CAT-TP-20

CAT Yes

CAT

Yes 0.599 mg/m³

BS EN 13725

Water Vapour

30 ouE/m³

Technical

Analysis

RPS

Yes

Hydrogen Sulphide US EPA M11 Yes

Procedure

LODTesting

BS EN 14789 CAT-TP-33

MCERTS

Testing Lab (Average)

UKASUKAS

YesYes

SpecphotometryCAT-TP-15 Yes CAT

CAT-TP-22(b)

CAT-TP-22(b)

Yes

CAT-TP-30 Yes ODO

(Page 5 of 7)

TGN M22

TGN M22

CAT

Flame Ionisation Detection by Sick 3006 FID

CAT

TGN M22

Dry Paramagnetic Cell by Servomex 5200MPCAT

Yes

Standard

Yes

TGN M22

Run


TGN M22

SUMMARY OF SAMPLING DEVIATIONS

Parameter

Odour

CAT

CAT

Catalyst Environmental Ltd (CAT)

0.05 mg/m³

0.05 mg/m³

0.92 mg/m³

0.03 mg/m³

0.37 mg/m³

N/A

Yes

Yes




Yes

GravimetricCAT-TP-05

Yes

Yes

FTIR by ProtIR 204M

Velocity & Vol. Flow Rate

FTIR by ProtIR 204M

Deviation

Yes

ANALYSIS LABORATORIES(with short name reference as appears in the table above)

MONITORING & ANALYTICAL METHODS

Sulphur Dioxide

Oxides of Nitrogen (as NO₂)

Bioaerosols

Health & Safety Laboratory (HSL) UKAS Accreditation Number: N/A

Ammonia

OPMIC30 Colony Counting No HSL No 91 cfu/m³

Hydrogen Fluoride

Hydrogen Chloride

Carbon Monoxide

CAT-RT (Version BB)

Page 9 of 64

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County Kerry

EP-Bio Scrubber




Duct Characteristics Location of Sampling Platform

Platform Details

Sampling Location / Platform Improvement Recommendations

BS EN 15259 Homogeneity Test Requirements

Sampling Plane Validation Criteria (from BS EN 13284-1)

Platform has 2 levels of handrails (approx. 0.5m & 1.0m high)

Criteria in BS EN 13284-1

Yes

-

Compliant

Yes

8

Pa

Platform has chains / self closing gates at top of ladders

Units

Area

-

Permanent

Lowest Differential Pressure

(Page 6 of 7)

m

-

General Platform Information

--

Required

Vertical

No

m/s

Yes

-

-

-

IEDth

Permanent / Temporary Platform

Inside / Outside

SUITABILITY OF SAMPLING LOCATION

Units

-7.91

Value

m²

m

All platforms should be designed in accordance with the requirements in the Environment Agency's Technical Guidance Note

M1 and BS EN 15259.

4" BSP

-

-

Sample Port Size

There is no requirement to perform a BS EN 15259 Homogeneity Test on this Stack.

6.63

-

Orientation of Duct

Irish EPA Technical Guidance Note AG1 / BS EN 15259 Platform Requirements

Value

Port Depth

0.70Depth

Yes

Traverse 1

Executive Summary

Circular

Platform has vertical base boards (approx. 0.25m high)

-

-

-

Mean Velocity

Outside

-

Value

-

Safe Access Available

-

- > 5 Pa Yes

- -

m/s

Easy Access Available

37.3

-

Sufficient working area to manipulate probe and operate the measuring instruments

Yes

Parameter

There are no obstructions present which hamper insertion of sampling equipment

-

0.38

-

-

-

-

--m/s

Maximum Angle of Swirl

cm

Yes

-

Lowest Gas Velocity

- -

Yes

Yes

0.00

Yes

-

Type

-

Yes

< 15°

Highest Gas Velocity 9.68

-

-

-

< 3 : 11.46

°

-

-

No Local Negative Flow

0.00

-

4

0.00Ratio of Above : 1 0.00

CAT-RT (Version BB)

Page 10 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Executive Summary

SAMPLE POINTS

(Page 7 of 7)

where = isokinetic point sampled at

= isokinetic point not sampled at

= combustion gases sample point

= non-isokinetic sample point

Line A

Line B

Line C

CAT-RT (Version BB)

Page 11 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




APPENDIX 1 - Stack Emissions Monitoring Personnel, List of Equipment & Methods and Technical Procedures Used

APPENDIX 2 - Summaries, Calculations, Raw Data and Charts

APPENDIX CONTENTS

APPENDICES

CAT-RT (Version BB)

Page 12 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




4279

m CERTS .................. "''"''~ ---

Ethyl Mercaptan BS EN 13649 CAT-TP-16

Methyl Mercaptan BS EN 13649 CAT-TP-16

N-Butyl Mercaptan BS EN 13649 CAT-TP-16

Control Box DGM

Miscellaneous Items

Name

CAT 7.24

Equipment I.D.

Position

Equipment I.D.

Extractive Sampling

LIST OF EQUIPMENT

Digital Manometer (1)Horiba PG-250

MCERTS Accreditation MCERTS Number Technical Endorsements

Team Leader Patrick O'Brien

Team Leader Rob Sidebotham MCERTS Level 2 MM 10 1075

Hydrogen Sulphide

Servomex 4900

Digital Temperature MeterEco Physics CLD 822Mh

CAT 3.58

Instrumental Analysers

-

Umbilical

CAT 4.137

CAT 24.6

CAT 21P.65

CAT 5.3

CAT 21S.42

Easylogger EN-EL-12 Bit

CAT 19.6

-

S-Pitot (1) JCT JCC P1 Cooler

S-Pitot (2)

-

Equipment TypeEquipment Type

John Glennon

TE1 TE2 TE3 TE4

Technician MCERTS Level 1 MM 10 1074 None

Equipment I.D.

STACK EMISSIONS MONITORING PERSONNEL

APPENDIX 1

MCERTS Level 2 MM 08 922 TE1 TE2 TE3 TE4

Team Leader James Harmer MCERTS Level 2 MM 03 156 TE1 TE2 TE3 TE4

CAT 4.453

-

Callipers

Laboratory Balance

CAT 3.51

Last Impinger Arm -

CAT 6.45

Velocity & Vol. Flow Rate

METHODS & TECHNICAL PROCEDURES USED

1m Heated Line (2)500g Check Weight

Heated Head Filter CAT 12.12

BS EN 14789

Carbon Monoxide

Hydrogen Chloride

Hydrogen Fluoride

Odour

Water Vapour

US EPA M11

Bernath 3006 FID

Sulphur Dioxide CAT-TP-22(b)

CAT-TP-22(b)

CAT-TP-33


CAT 17.1

CAT 17.1

1m Heated Line (3)

CAT 1.18 / 1.18a 20m Heated Line (1)

Technical Procedure

BS EN 13649

Parameter

Dimethylamine

Ethanolamine

Methylamine BS EN 13649

BS EN 13649

BS EN 13649

Diethylamine

CAT 20.28

15m Heated Line (2)

CAT 16.13

Ammonia CAT-TP-22(b)

CAT-TP-22(b)

CAT-TP-22(b)

BS EN 13649

BS EN 13284-1 CAT-TP-04

Mass View (1) CAT 25.36

Mass View (2) CAT 25.37

Dual Channel Heater Controller

CAT-TP-22(b)

CAT-TP-16

CAT-TP-16

CAT-TP-16

CAT-TP-16

CAT-TP-16

BS EN 14790

BS EN 13725

TGN M22

TGN M22

TGN M22

TGN M22

TGN M22

TGN M22

CAT-TP-15

CAT-TP-20

CAT-TP-05

CAT-TP-30

BS EN 12619:2013

Bioaerosols

-

-

CAT 11.14

CAT 3.73

Equipment Type

CAT 4.412

Tubes Kit Thermocouple CAT 4.439

15m Heated Line (1) -

Tape Measure

Mass Flow Controller (1) CAT 6.44

CAT 8.15

5m Heated Line (1)

Testo 350 XL

CAT 3.73-

-

1m Heated Line (1)

Stack Thermocouple (2)

Stack Thermocouple (1)

Box Thermocouples

-

Servomex 5200MP

CAT 3.58

FT-IR Sampling System

Barometer

Digital Manometer (2)

Probe

Oven Box

-

CAT 14.53Stopwatch-

FT-IR

CAT 13.22

L-Pitot

CAT 4.345

-

CAT 23.11

VDI 4257 Blatt 2 CAT-TP-36

Mass Flow Controller (2)


Trimethylamine

Oxygen

Standard

1Kg Check Weight

CAT-RT (Version BB)

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EP-Bio Scrubber




General Stack Details

Stack Gas Composition & Molecular Weights

CO₂ (Estimated)

O₂

Moisture (H₂O) (Estimated)

NOTE: Moisture has been estimated as no moisture test was performed on the date(s) of testing

Where: p = M / 22.41

pi = r x p

Calculation of Stack Gas Densities

Where: P STD = sum of component concentrations, kg/m³ (not including water vapour)

P STW = sum of all wet concentrations / 100 x density, kg/m³ (including water vapour)

P Actual = P STD x (TSTP / (PSTP)) x ((Pstatic + Pb) / Ta)

P ActualW (at each sampling point) = P STW x (Ts / Ps) x (Pa / Ta)

Calculation of Stack Gas Volumetric Flowrate, Q

Gas Volumetric Flowrate (STP, Dry)

Gas Volumetric Flowrate (STP, Wet)

Gas Volumetric Flowrate (Actual)

Gas Volumetric Flowrate (from Traverse)

Stack Diameter / Depth, D

Average Stack Gas Temperature, Ta

0.054

m²

-

Units

PRELIMINARY STACK SURVEY: CALCULATIONS

Conc

0.38

0.06

kg/m³

Volume Conc

0.00118

mmH₂O

0.06

Stack Area, A

APPENDIX 2

mStack IEDth, W

15.8

Average Barometric Pressure, Pb

m

Stack Details (from Traverse)

kPa

kPa

0.84

Value

0.70

°C

Dry

Average Stack Static Pressure, Pstatic

-Average Pitot Tube Calibration Coefficient, Cp

0.8037 0.02157

20.79 32.00

20.0

Actual

ppm kg/m³

Average Stack Gas Pressure 5.5

101.3

kg/m³

kPa

100.2

1.204

Wet Density (STP), P STW

-

20.23

p pi

Mass

Component

m³/hr

Result

M

Wet

r% v/v

kg/m³

m³/hr

Total Pressure

Fraction

Density

Result

1.9635

Molar Conc

Gas Volumetric Flowrate REF ¹

Gas Volumetric Flowrate REF ² 11007

2.68 2.68

Units

0.0

Conc

15.8

100.3

9981

Units

-

°C

kg/m³

0.7915 28.01

Determinand

10256

1.192

Dry Density (Actual), P Actual

m³/hr

REF ²

101.3

Temperature

N₂

Average Wet Density (Actual), P ActualW

2.68

79.15 0.98928

1.287

77.03

Dry Density (STP), P STD

18.02-

%

-

0.0268

0.2079

Units

2.68

kg/m³ 1.274

% v/v

Moisture

0.0006

-

1.2498

44.01

m³/hr

REF ¹

m³/hr

Duct gas flow conditions

10256

10962

1.4277 0.29678

CAT-RT (Version BB)

Page 14 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Parameter Parameter

Date of Survey Initial Pitot Leak Check

Time of Survey Final Pitot Leak Check

Atmospheric Pressure Orientation of Duct

Stack Static Pressure Pitot Tube, Cp

Type of Pitot Used Number of Lines Available

Are Water Droplets Present? Number of Lines Used

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

4 2 3 2

-

1.192

-

-

-

-

(1 of 1)

Vertical

-

-

-

-

-

-

-

-

-

-- - - --

-

-

-

Units

Pa 0.84

Wet Density

Pass

3

1

-

15.8

-

7.5

Velocity

-

6.5

-

-

PRELIMINARY STACK SURVEY: VELOCITY TRAVERSE

-

Swirl Point (taken at the sampling points used during testing)

1No

APPENDIX 2

Pass

Value

9.31

Depth

S-Type Pitot

0.11

kPa

-

-

-

-

4

-

100.2

2

-

0.25

54 -

-

Units

--

09:00 - 09:10

m/s

∆P

mmH₂O

1.192

-

Angle of Swirl (°)

-

m

0.04

Temp

8.1 -

17/09/2013

Value

-Traverse

Sampling Line A

6.6

-

-

1.192

1.192

7.60

15.8 -

- -

5.0

-

- -

-6.631.192

-

-3.8

-

-

7.91

-

15.8

-

-

-

-

-

-

8.74

-

-

-

1.192

8.67

-

15.8

-

-

-

15.8

15.8

-

-

-

-7.37 - -

-

-

15.8

-

1.192

-

6.89

- -

-

15.8

--

-

-

-

-

-

- -

-

-

Mean

-

-°C

1.192

-

-

-

-

-

-

7

-

-

-

-

-

-

-

-

-

- -

--

-

-

-

0.67

-

- -

10

-

-

9.68

-

-

-

- -

1

1.192

15.80.18

--

-

-

6.63

0.46

15.8

5.0

kg/m³Point

- -

-

-

- -

-

-

-

-

-

-

-

-

-

-

-

-

-

7.60

-

-

-

-

-

5.5

-

-

15.8

--

-

0.32

-

-

- -

-

-

-

4.7

3.8

- -

-

- -

- -

- -

-

-

-

-

- -

-

-

-

-

-

-

-

-

--

-

9

-

-

-

-

- -

-

- - -

-

-

-

-

-

0.60

-

- --

- -

- -

-

-

-

-

-

- - -

-

-

-

-

-

-

-

-

0.53 -

-

1.192

-

-

-

1.192

5

-

4.1 -

-

8

-

-

0.396

-

-

-

-

-

--

--

- -

-

- -

- -- -

-

-

-

--

-

-

-

-

-

-

-

-

-

-

-

--

-

- -

-

-

-

-

-

-

-

-

-

-

- -

-

-

- -

--

-

-

-

-

-

-

-

-

- -

-- -

-

-

- - -

-

-

- - -

-

-

-

- -

- - - -

-

-

-

-

-

-

-

-

-

-

-

- -

-

-

-

-

-

-

-

-

-

-

-

-

- -

-

-

- -

- -

-

- -

-

-

- -

-

-

-

-

- --

-

--

--

-

--

-

-

--

-

-

-

--

-

- - -

- - - -

-

-

- -

CAT-RT (Version BB)

Page 15 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Sample Runs

- - - -

< < < <

- - - -

< < < <

- - - -

- - - -

- - - -

- - - -

Blank Runs

- -

< <

General Sampling Information

FORMAT: Number Used / Number Required


Reference Conditions

Reference Conditions are: 273K, 101.3kPa, without correction for water vapour content.

Standard

Mass Emission g/hr 5.9

Probe Material Titanium

Filter Housing Material N/A

Impinger Material

Filter Size and Material N/A

5.6 7.4

0.12±% v/v

Sample Point I.D.'s A2

Number of Sampling Lines Used 1 / 1

Number of Sampling Points Used 1 / 1

Water Vapour % v/v 2.47 2.79 2.79 2.68

Maximum

0.13

NOTE: Where water droplets are present (See the Quality Assurance page), the Water Vapour concentration as found in Annex A of BS EN 14790 has been

reported instead of the calculated value.

Borosilicate Glass

Absorption Solution Zinc Acetate Solution

Positioning of Filter N/A

6.3

Uncertainty

Parameter Units Blank 1

0.5 0.5 0.6 0.5

NOTE: Where the maximum Blank concentration is higher than the Sample concentration, the Blank concentration has been reported.

Parameter

0.54

0.72 0.61

Uncertainty ±mg/m³ 0.05 0.05 0.06

Concentration

Units Run 1 Run 2 Run 3

±g/hr

US EPA M11

Technical Procedure CAT-TP-15

0.05

mg/m³

Analytical Laboratory's Procedure M120

UKAS Accredited Analysis?

Name of Analytical Laboratory RPS

EP-Bio Scrubber

Parameter Units Run 1 Run 2 Run 3 Mean

Concentration mg/m³ 0.57 0.54

Mean

Uncertainty 0.14 0.14

0.54

Parameter Value

26/09/2013Date of Sample Analysis

Yes

HYDROGEN SULPHIDE: RESULTS SUMMARY


APPENDIX 2

CAT-RT (Version BB)

Page 16 of 64

Brandon Products

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EP-Bio Scrubber




Sample Runs

< < <

<

- - -

-

< < <

<

< < <

< < <

Where: DGM stands for Dry Gas Meter

Blank Runs

<

-

<

<

Parameter Units Blank 1

Blank Dates - 17/09/2013

Average Volume Sampled (REF) m³ 0.5510

Laboratory Result for Impingers µg/ml 1.00

Volume in Impingers ml

Total Mass Collected µg 298.9

Calculated Concentration mg/m³ 0.54

298.9

Calculated Water Vapour % v/v 33.24 13.10 11.75

Total Mass Collected µg 354.1 311.6 299.7

Calculated Concentration mg/m³ 0.57 0.51 0.72

Liquid Trap Start Mass g 3419.9 3445.5 3445.8

Liquid Trap End Mass g 3653.0

Volume in Back Impinger ml 110.6

Silica Trap End Mass g 850.4 855.7 857.8

Total Mass Of Water Vapour g 241.9 72.4 43.3

3512.6 3487.0

Mass in Front Impingers µg 243.5 311.6 299.7

Laboratory Result for Front Impingers µg/ml 1.00 1.00 1.00

Laboratory Result for Back Impinger µg/ml 1.00

Volume in Front Impingers ml 243.5 311.6 299.7

Mass in Back Impinger µg 110.6

Silica Trap Start Mass g 841.6 850.4 855.7

Volume Sampled (STP, Wet) m³ 0.6208 0.6154 0.4168

Volume Sampled (REF) m³ 0.6208 0.6154 0.4168

Sample Flow Rate l/min 10.88 10.88 11.11

Barometric Pressure kPa 100.2 100.2 100.2

DGM Start Volume m³ 1.8625 2.9462 3.6085

Volume Sampled (STP, Dry) m³ 0.6054 0.5983 0.4052

DGM End Volume m³ 2.5220 3.6057 4.0574

DGM End Temperature

End ∆H mmH₂O 14.0 14.0 14.0

DGM Yd - 0.9900 0.9900 0.9900

Start ∆H mmH₂O 14.0 14.0 14.0

Sampling Dates - 17/09/2013 17/09/2013 17/09/2013

Sampling Device

Parameter Units Run 1 Run 2 Run 3

APPENDIX 2

HYDROGEN SULPHIDE: SAMPLING DETAILS

°C 21.0 21.0 21.0

DGM Start Temperature °C 16.0 23.0 26.0

- DGM DGM DGM

Duration mins 60 60 40

- 09:06 - 10:06 12:06 - 13:06 13:45 - 14:25Sampling Times

CAT-RT (Version BB)

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County Kerry

EP-Bio Scrubber




Sample Runs

0 0 0 0

Blank Runs

Method Deviations

1 2 3

wx wx wx

- - - - -

- - - - -

- - - - -

There are no deviations associated with the sampling employed.

Allowable Leak Rate l/min 0.20

Leak Test Acceptable - Yes

Nature of Deviation Run Number

(x = deviation applies to the associated run, wx = deviation also applies to the concurrent water vapour run)

Blank Acceptable - N/A

Validity of Blank vs ELV Units Blank 1

Post-Sampling Leak Rate l/min 0.04

Allowable Blank mg/m³ N/A

Test Conditions Units Run 1 Run 2 Run 3

Ambient Temperature Recorded? - Yes Yes Yes

Leak Test Results Units Blank 1

Expected Sampling Rate l/min 10.00

Pre-Sampling Leak Rate l/min 0.04

MU Acceptable % Yes Yes Yes

Silica Gel (Concurrent Water Vapour) Units Run 1 Run 2 Run 3

Less than 50% Faded % Yes Yes Yes

MU (Concurrent Water Vapour) Units Run 1 Run 2 Run 3

Measurement Uncertainty (MU) % 5.0 5.0 5.0

Allowable MU % 20 20 20

Absorption Efficiency Acceptable -

Water Droplets Units Run 1 Run 2 Run 3

Are Water Droplets Present - Yes Yes Yes

N/A

Absorption Efficiency Units Run 1

Absorption Efficiency % 100.0

Allowable Absorption Efficiency % N/A

Post-Sampling Leak Rate l/min 0.02 0.03 0.03

Allowable Leak Rate l/min 0.22 0.22 0.22

Leak Test Acceptable - Yes Yes Yes

Mean Sampling Rate l/min 10.88 10.88 11.11

Pre-Sampling Leak Rate l/min 0.02 0.03 0.03

APPENDIX 2

HYDROGEN SULPHIDE: QUALITY ASSURANCE

Leak Test Results Units Run 1 Run 2 Run 3

CAT-RT (Version BB)

Page 18 of 64

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EP-Bio Scrubber




Sampled Volume (Actual)

Sampled Gas Temperature

Sampled Gas Pressure

Sampled Gas Humidity

Leak

Laboratory Result

Oxygen Content

Sampled Volume (Actual)

Sampled Gas Temperature

Sampled Gas Pressure

Sampled Gas Humidity

Leak

Laboratory Result

Oxygen Content

Sampled Volume (STP)

Leak

Laboratory Result

Factor for O₂ Correction


Leak

Laboratory Result


Combined uncertainty

Expanded uncertainty (95% confidence)

Expanded uncertainty (95% confidence), estimated with Method Deviations

Reported Uncertainty




% 8.3 8.4 8.4

% 8.3

0.02 0.03

mg/m³ 0.05 0.05 0.06

mg/m³

% 8.3 8.4 8.4

0.05 0.05 0.06

mg/m³

Measured Quantities Units Run 1 Run 2 Run 3

8.4 8.4

mg/m³ 0.015 0.014 0.018

mg/m³ 0.0006 0.0009 0.0011

mg/m³ 0.0194 0.0184 0.0244

mg/m³ N/A

O₂,m % v/v N/A N/A N/A N/A N/A N/A

Uncertainty in Result

0.05 0.05 0.06

N/A N/A


mg/m³ 0.02

L mg/m³ 0.001 0.001 0.001 1.00 1.00 1.00

Lr mg/m³ 0.019 0.018 0.024 1.00 1.00 1.00

Uncertainty in Measurement Units Sensitivity Coefficient

Measured Quantities Symbol Units Run 1 Run 2 Run 3 Run 1 Run 2 Run 3

Vm m³ 0.6054 0.5983 0.4052 0.94 0.91 1.77

% 0.18 0.28 0.27 ≤2%

% 3.40 3.40 3.40 No Requirement

% N/A N/A N/A ≤5%

% 0.69 0.68 0.67 ≤1%

% 0.50 0.50 0.50 ≤1%

% 1.00 1.00 1.00 ≤1%

Uncertainty as a Percentage

Measured Quantities Units Run 1 Run 2 Run 3 Requirement of Standard

% 2.00 2.00 2.00 ≤2%

Lr 3.40 3.40 3.40 uLr % - - -

O₂,m N/A N/A N/A uO₂,m % v/v N/A N/A N/A

Hm 0.0 0.0 0.0 uHm % v/v 1.0 1.0 1.0

L 0.18 0.28 0.27 uL % - - -

Tm 291.5 295.0 296.5 uTm K 2.0 2.0 2.0

ρm 100.2 100.2 100.2 uρm kPa 0.5 0.5 0.5

Vm 0.6595 0.6595 0.4489 uVm m³ 0.0132 0.0132 0.009

APPENDIX 2

HYDROGEN SULPHIDE: MEASUREMENT UNCERTAINTY CALCULATIONS

Value Standard uncertainty

Measured Quantities Symbol Run 1 Run 2 Run 3 Symbol Units Run 1 Run 2 Run 3

CAT-RT (Version BB)

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Sample Runs

- - - -

< < < <

< < < <

< < < <

< < < <

< < < <






2.1

2.1

2.1

2.1

2.1 2.1

Dimethylamine

Ethanolamine

Methylamine

Trimethylamine

mg/m³

mg/m³

mg/m³

mg/m³

2.1 2.1

2.1

2.1

2.1

2.1

2.1

2.1

2.1

2.1


Diethylamine mg/m³ 2.1 2.1 2.1 2.1

Silica Gel



Value

Sample Point I.D.'s C1

Dynamic Dilution Employed Yes


Standard BS EN 13649

Parameter

AMINES : RESULTS SUMMARY


EP-Bio Scrubber

Probe Material Stainless Steel

Name of Analytical Laboratory RPS

APPENDIX 2

Analytical Laboratory's Procedure A1(U)

UKAS Accredited Analysis? Yes

Date of Sample Analysis 25/09/2013

Sample Tube Type

CAT-RT (Version BB)

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Where: MV stands for Mass View (Mass Flow Controller Technology)

< < - < <

< < - < <

< < - < <

< < - < <

< < - < <



APPENDIX 2

N₂ to Stack Gas Dilution Ratio

AMINES : SAMPLING DETAILS

Parameter Units Value

Duration mins

m³ 0.0009

RUN 1

30

6.5: 1

Lab Result

(Front)

µg

Diethylamine

Sampling Times -09:52 - 09:56, 10:42 - 10:46, 11:43 -

11:47

Sampling Dates

Lab Result

(Back)

µg

Lab Result

(Total)

µg

Reported

LOD

mg/m³

Adsorption

Efficiency

%

Ethanolamine 1.0 1.0 2.0 1.0

- 17/09/2013

Sampling Device - MV

Volume Sampled (REF)

Trimethylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.1 2.1 2.1 100.0

Concentration

mg/m³

Reported

Concentration

(Blank Reviewed)

mg/m³

LOD

(Front)

µg

LOD

(Back)

µg

LOD

(Total)

µg

Parameter

1.0 2.0 2.1 2.1 2.1

1.0 1.0 2.0 1.0 1.0 2.0 2.1 2.1 2.1 100.0

Dimethylamine 1.0 1.0 2.0 1.0 1.0

100.0

Methylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.1 2.1 2.1 100.0

2.0 2.1 2.1 2.1 100.0

CAT-RT (Version BB)

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< < - < <

< < - < <

< < - < <

< < - < <

< < - < <



Trimethylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.1 2.1 2.1 100.0

Volume Sampled (REF) m³ 0.0010

Parameter Lab Result

(Front)

µg

Lab Result

(Back)

µg

Lab Result

(Total)

µg

LOD

(Front)

µg

LOD

(Back)

µg

LOD

(Total)

µg

Concentration

mg/m³

Reported

Concentration

(Blank Reviewed)

mg/m³

Reported

LOD

mg/m³

Adsorption

Efficiency

%

100.0

RUN 2


Sampling Times -12:30 - 12:34, 13:10 - 13:14, 13:55 -

13:59

Sampling Dates -

Dimethylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.1 2.1

17/09/2013


Duration mins 30

N₂ to Stack Gas Dilution Ratio

2.1 2.1 2.1 100.0

Methylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.1 2.1 2.1 100.0

2.1

Diethylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.1 2.1 2.1 100.0

: 1 6.2

1.0 1.0 2.0Ethanolamine 1.0 1.0 2.0

APPENDIX 2


CAT-RT (Version BB)

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< < - < <

< < - < <

< < - < <

< < - < <

< < - < <



Trimethylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.0 2.1 2.0 100.0

Ethanolamine 1.0 1.0 2.0 1.0 1.0 2.0 2.0 2.1 2.0 100.0

Methylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.0 2.1 2.0 100.0

Diethylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.0 2.1 2.0 100.0

Dimethylamine 1.0 1.0 2.0 1.0 1.0 2.0 2.0 2.1 2.0 100.0

N₂ to Stack Gas Dilution Ratio : 1 5.9



(Front)

µg

Lab Result

(Back)

µg

Lab Result

(Total)

µg

LOD

(Front)

µg

LOD

(Back)

µg

LOD

(Total)

µg

Concentration

mg/m³

Reported

Concentration

(Blank Reviewed)

mg/m³

Reported

LOD

mg/m³

Adsorption

Efficiency

%

APPENDIX 2


RUN 3


Sampling Times -14:54 - 14:58 - 15:39 - 15:43, 16:20 -

16:24, 16:40 - 16:44

Sampling Dates - 17/09/2013


Duration mins 30

CAT-RT (Version BB)

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< < - <

< < - <

< < - <

< < - <

< < - <



17/09/2013




(Front)

µg

Lab Result

(Back)

µg

Lab Result

(Total)

µg

2.1

APPENDIX 2

Diethylamine

Methylamine 1.0 1.0 2.0 2.1

Trimethylamine 1.0 1.0 2.0 2.1


BLANK 1


Sampling Dates -

Concentration

mg/m³

1.0 1.0 2.0 2.1

Dimethylamine 1.0 1.0 2.0 2.1

Ethanolamine 1.0 1.0 2.0

CAT-RT (Version BB)

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Sample Runs

0.004

Run 2

Adsorption Efficiency Units

0.200

Leak Test Results Units

0.000 0.000

Yes Yes

100.0 100.0

100.0

Leak Test Acceptable

Methylamine

%

100.0 100.0 100.0

100.0

100.0

l/min

Run 1

100.0

Allowable Leak Rate 0.004

%

100.0

Mean Sampling Rate

Run 3

100.0

100.0%

%

0.000

0.000

0.200

Yes

l/min

-

%

Diethylamine %

Run 2 Run 3

APPENDIX 2

AMINES : QUALITY ASSURANCE

0.200

Test Conditions Units

YesYes

l/min

Post-Sampling Leak Rate 0.000

Run 1

(PAGE 1 OF 2)

Yes

Pre-Sampling Leak Rate

0.004

Trimethylamine

100.0

0.000

Yes

40

Temperature Acceptable - Yes Yes

20 20 20

- Yes

Dimethylamine

Temperature

Temperature at Sample Tubes Units Run 1 Run 2 Run 3

95 95

l/min

100.0 100.0Ethanolamine

°C

Yes

40

Adsorption Efficiency Acceptable

Yes

Allowable Adsorption Efficiency

Run 1 Run 2 Run 3

Allowable Temperature °C 40

95

-Ambient Temperature Recorded?

CAT-RT (Version BB)

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Blank Runs

Method Deviations

1 2 3

x x x

- - - - -

- - - - -

- - - - -

2.1 N/A

2.1 N/A

2.1 N/A

mg/m³ 10.3 N/A

Allowable for Dimethylamine

Allowable for Ethanolamine

2.1 N/A

0.200

Allowable for Methylamine

Allowable for Trimethylamine

Blank 1 Allowed

2.1 N/A

Nature of Deviation

Allowable for TOTAL

mg/m³

mg/m³

mg/m³

Expected Sampling Rate

APPENDIX 2

AMINES : QUALITY ASSURANCE(PAGE 2 OF 2)

Sampling Leak Rate

Allowable Leak Rate

Leak Test Results

l/min

(x = deviation applies to the associated run)


mg/m³

l/min

Units Blank 1

0.004l/min

Allowable for Diethylamine mg/m³

0.000

Run Number

Validity of Blank vs ELV Units


CAT-RT (Version BB)

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Leak

Laboratory Result

Oxygen Content


Leak

Laboratory Result

Oxygen Content


Leak

Laboratory Result



Leak

Laboratory Result









NOTE: Uncertainties reported in mg/m ³ are based upon the summation of all Speciated VOCs Measured.

24.8 24.8 24.8

Run 2 Run 3

2.661 2.576

% 24.8 24.8

2.560

1.314

Run 1

mg/m³ 0.0000 0.0000 0.0000

Symbol Units

mg/m³

Run 1 Run 3

1.2978 1.2899

mg/m³

mg/m³

mg/m³

0.00

O₂,m

0.0010

Run 1 Run 2Run 1

2.661

Run 1

11821

0.000 0.000 0.000

2.00

0.00

mg/m³ 1.3407

%

N/A N/AN/A uO₂,m % v/v

N/A N/A

0.00

% v/v


mg/m³

-

12.50

Measured Quantities Symbol

%

Vm uVm

Run 1

%uLr

APPENDIX 2

12.50

Run 2 Run 3

m³ 0.0 0.00.0009 0.0009

- -

Symbol Units Run 1

1.00

L

N/A N/A

2.576

24.8

Run 2

AMINES : MEASUREMENT UNCERTAINTY CALCULATIONS


Run 3 Requirement of Standard

% 2.00

0.000

Measured Quantities

Vm

N/A

12.50

0.00.0010

12.50

Uncertainty in Measurement Units

Lr

-

1.00

Lr

N/A

2.00

Measured Quantities

≤2%

% 12.50

Run 3

Sensitivity Coefficient

% N/A N/A

Run 3

1.00

N/A

Measured Quantities

% 24.8

O₂,m

1.00

≤5%

Run 3

m³ 0.0009 0.0009

1.00

1.341

Units

0.000 0.000

1.290

N/A N/A

11077 10481

mg/m³

12.50

N/A

2.661 2.576

2.560

24.8 24.8

mg/m³ 1.358 1.306

1.298

2.560

1.00

Parameter Units

0.2145 0.2077 0.2064

Units

Run 2

N/A

%

Run 2

L mg/m³

N/A

≤2%

N/A

-

No Requirement

uL

Run 2


-

CAT-RT (Version BB)

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Sample Runs

- - - -

< < < <

< < < <

< < < <







Sample Point I.D.'s C1

Name of Analytical Laboratory SAL

Analytical Laboratory's Procedure In House

UKAS Accredited Analysis? No

Date of Sample Analysis 02/10/2013


Sample Tube Type Molecular Sieve

Dynamic Dilution Employed Yes


Methyl Mercaptan mg/m³ 0.32 0.31 0.31 0.31

Parameter Value



Ethyl Mercaptan mg/m³ 0.32 0.31 0.31 0.31

EP-Bio Scrubber


APPENDIX 2

MERCAPTANS : RESULTS SUMMARY


N-Butyl Mercaptan mg/m³ 0.32 0.31 0.31 0.31

CAT-RT (Version BB)

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< < - < <

< < - < <

< < - < <



N-Butyl Mercaptan 0.1 0.1 0.1 0.1 0.1 0.1 0.32 0.32 0.32 100.0

Reported

LOD

mg/m³

Adsorption

Efficiency

%

Ethyl Mercaptan 0.1 0.1 0.1 0.1 0.1 0.1 0.32 0.32 0.32 100.0

Methyl Mercaptan 0.1 0.1 0.1 0.1 0.1 0.1 0.32 0.32 0.32 100.0


Duration mins 20




(Front)

µg

Lab Result

(Back)

µg

Lab Result

(Total)

µg

LOD

(Front)

µg

LOD

(Back)

µg

LOD

(Total)

µg

Concentration

mg/m³

Reported

Concentration

(Blank Reviewed)

mg/m³

APPENDIX 2

MERCAPTANS : SAMPLING DETAILS

RUN 1


Sampling Times -09:52 - 09:56, 10:42 - 10:46, 11:43 -

11:47


CAT-RT (Version BB)

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< < - < <

< < - < <

< < - < <






(Front)

µg

Lab Result

(Back)

µg

Lab Result

(Total)

µg

LOD

(Front)

µg

LOD

(Back)

µg

LOD

(Total)

µg

Concentration

mg/m³

Reported

Concentration

(Blank Reviewed)

mg/m³

Reported

LOD

mg/m³

Adsorption

Efficiency

%

Ethyl Mercaptan 0.1 0.1 0.1 0.1 0.1 0.1 0.31 0.31 0.31 100.0

Sampling Times -12:30 - 12:34, 13:10 - 13:14, 13:55 -

13:59



Duration mins 20



APPENDIX 2


RUN 2


CAT-RT (Version BB)

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< < - < <

< < - < <

< < - < <




Ethyl Mercaptan 0.1 0.1 0.1 0.1 0.1 0.1 0.29 0.31 0.29 100.0





(Front)

µg

Lab Result

(Back)

µg

Lab Result

(Total)

µg

LOD

(Front)

µg

LOD

(Back)

µg

LOD

(Total)

µg

Concentration

mg/m³

Reported

Concentration

(Blank Reviewed)

mg/m³

Reported

LOD

mg/m³

Adsorption

Efficiency

%

APPENDIX 2


RUN 3


Sampling Times -14:54 - 14:58 - 15:39 - 15:43, 16:20 -

16:24, 16:40 - 16:44



Duration mins 20

CAT-RT (Version BB)

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< < - <

< < - <

< < - <



Methyl Mercaptan 0.1 0.1 0.1 0.31

N-Butyl Mercaptan 0.1 0.1 0.1 0.31





(Front)

µg

Lab Result

(Back)

µg

Lab Result

(Total)

µg

Concentration

mg/m³

Ethyl Mercaptan 0.1 0.1 0.1 0.31

APPENDIX 2


BLANK 1


CAT-RT (Version BB)

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Sample Runs

Test Conditions Units Run 1 Run 2 Run 3

Ambient Temperature Recorded? - Yes Yes Yes

Temperature °C 20 20 20

Allowable Temperature °C 40 40 40

Temperature Acceptable - Yes Yes Yes

Allowable Adsorption Efficiency % 95 95 95

Adsorption Efficiency Acceptable - Yes Yes Yes

Temperature at Sample Tubes Units Run 1 Run 2 Run 3

Ethyl Mercaptan % 100.0 100.0 100.0

Methyl Mercaptan % 100.0 100.0 100.0

N-Butyl Mercaptan % 100.0 100.0 100.0

Allowable Leak Rate l/min 0.002 0.002 0.002

Leak Test Acceptable - Yes Yes Yes

Adsorption Efficiency Units Run 1 Run 2 Run 3

Mean Sampling Rate l/min 0.100 0.100 0.100

Pre-Sampling Leak Rate l/min 0.000 0.000 0.000

Post-Sampling Leak Rate l/min 0.000 0.000 0.000

APPENDIX 2

MERCAPTANS : QUALITY ASSURANCE(PAGE 1 OF 2)

Leak Test Results Units Run 1 Run 2 Run 3

CAT-RT (Version BB)

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Blank Runs

Method Deviations

1 2 3

x x x

- - - - -

- - - - -

- - - - -



0.31

Allowable for TOTAL mg/m³ 0.92 N/A

Nature of Deviation Run Number

0.31 N/A

N/A

Allowable for N-Butyl Mercaptan mg/m³

Sampling Leak Rate l/min 0.000

Allowable Leak Rate l/min 0.002


Validity of Blank vs ELV Units

Allowable for Ethyl Mercaptan mg/m³

Blank 1 Allowed

(PAGE 2 OF 2)

Leak Test Results Units Blank 1

Expected Sampling Rate l/min 0.100

Allowable for Methyl Mercaptan mg/m³

0.31 N/A

APPENDIX 2

MERCAPTANS : QUALITY ASSURANCE

CAT-RT (Version BB)

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Leak

Laboratory Result

Oxygen Content


Leak

Laboratory Result

Oxygen Content


Leak

Laboratory Result



Leak

Laboratory Result









NOTE: Uncertainties reported in mg/m ³ are based upon the summation of all Speciated VOCs Measured.

% 24.8 24.8 24.8

% 24.8 24.8 24.8

% 24.8 24.8 24.8

mg/m³ 0.237 0.230 0.228

mg/m³ 0.237 0.230 0.228

mg/m³ 0.237 0.230 0.228

mg/m³ N/A N/A N/A


mg/m³ 0.121 0.117 0.117

mg/m³ 0.0191 0.0185 0.0184

mg/m³ 0.0000 0.0000 0.0000

mg/m³ 0.1197 0.1158 0.1151

O₂,m % v/v N/A N/A N/A N/A N/A N/A


Measured Quantities Units Run 1 Run 2 Run 3

L mg/m³ 0.000 0.000 0.000 1.00 1.00 1.00

Lr mg/m³ 0.120 0.116 0.115 1.00 1.00 1.00

Uncertainty in Measurement Units Sensitivity Coefficient

Measured Quantities Symbol Units Run 1 Run 2 Run 3 Run 1 Run 2 Run 3

Vm m³ 0.0003 0.0003 0.0003 3138 2941 2783

% 0.00 0.00 0.00 ≤2%

% 12.50 12.50 12.50 No Requirement

% N/A N/A N/A ≤5%


Measured Quantities Units Run 1 Run 2 Run 3 Requirement of Standard

% 2.00 2.00 2.00 ≤2%

Lr 12.50 12.50 12.50 uLr % - - -

O₂,m N/A N/A N/A uO₂,m % v/v N/A N/A N/A

Vm 0.0003 0.0003 0.0003 uVm m³ 0.0 0.0 0.0

L 0.000 0.000 0.000 uL % - - -

APPENDIX 2

MERCAPTANS : MEASUREMENT UNCERTAINTY CALCULATIONS


Measured Quantities Symbol Run 1 Run 2 Run 3 Symbol Units Run 1 Run 2 Run 3

CAT-RT (Version BB)

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Sample Runs

- -

- -

- -

- -

- -







Filtration Type / Size 0.1µm Glass Fibre


EP-Bio Scrubber

Uncertainty

A1

Heated Head Filter Used Yes

Span Gas Start Pressure (bar) 145

Gas Cylinder Concentration (ppm)

TOTAL VOCs (as CARBON): RESULTS SUMMARY

Parameter Units Run 1 Mean

BS EN 12619:2013


Standard

81.5

Span Gas Uncertainty (%) 2

28/04/2014

Synthetic Air (5 Grade)

1 / 1

Span Gas Expiry Date

Number of Sampling Lines Used

APPENDIX 2

Mass Emission

Concentration

180°C

Uncertainty

1.8

Parameter

1.23

1 / 1

Heated Line Temperature

CYL 1.0044

12.6 12.6

Span Gas Reference Number

Sample Point I.D.'s

g/hr

Value

1.23mg/m³

0.18±mg/m³ 0.18

Number of Sampling Points Used

1.8±g/hr

Zero Gas Type

CAT-RT (Version BB)

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Graphical Trend of Data

APPENDIX 2

TOTAL VOCs (as CARBON): DATA TREND

COVER ME WITH CHART/S

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

09

:00

09

:10

09

:20

09

:30

09

:40

09

:50

10

:00

10

:10

10

:20

10

:30

10

:40

10

:50

11

:00

11

:10

11:2

0

11

:30

11

:40

11

:50

12

:00

12

:10

12

:20

12

:30

12

:40

12

:50

13

:00

13

:10

13

:20

13

:30

13

:40

13

:50

14

:00

14

:10

14

:20

14

:30

14

:40

14:5

0

15

:00

15:1

0

15

:20

15

:30

15

:40

15

:50

16

:00

Co

nce

ntr

atio

n (

mg/

m³)

Total VOCs At Reference Conditions

- Run 1

CAT-RT (Version BB)

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Sampling Details

Quality Assurance

Zero Drift 0 0 0

Span Drift 0 0 0

Method Deviations

1

x

- - -

- - -

- - -

- - -

- - -

09:00 - 16:00

CA

L 1

CA

L 1

Instrument Range ppm 100

Span Drift

0.00

Run 1

TOTAL VOCs (as CARBON): SAMPLING DETAILS & QUALITY ASSURANCE

Parameter

- Yes

-

0.10

Sampling Dates

APPENDIX 2

17/09/2013

4.08

ppm 81.20

Units

Run Number

ppm -2.70

Span Drift Acceptable -

Run 1

Yes

ppm 78.50

± ppm

Span Down Sampling Line (Pre)

Zero Drift

ppm 0.10

Units

ppm

Sampling Times -

ppm

Zero Down Sampling Line (Post) ppm

Units Run 1

Allowable Span Drift ± ppm 4.08

Span Down Sampling Line (Post)

Nature of Deviation


81.5

Units Run 1

Test Conditions

Zero Down Sampling Line (Pre)

Span Gas Value

Allowable Zero Drift

Zero Drift Acceptable


Run Ambient Temperature Range °C 14 - 19

CAT-RT (Version BB)

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MCERTS Certified Range of Analyser

Operational Range of Analyser

Measured Reading

Nonlinearity

Temperature Dependent Zero Drift

Temperature Dependent Span Drift

Cross-Sensitivity

Leak

Calibration Gas Uncertainty

Mass Flow Controllers (dilution) Uncertainty

Parameter








Individual Errors as Standard Uncertainties

ppm

ppm 0.00

0.06

0.018

ppm

ppm

ppm

100.0

ppm 0.01

Units

Run 3

0.037

ppm

APPENDIX 2

%

0.00

Run 1

ppm

Measured Quantities Units

0.027

0.11

Run 3

ppm

Run 3Run 2

%

0.11

Run 2

Run 1

%

Run 1 Run 2

ppm 0.027

ppm

Units

ppm

ppm 0.8

9.3

TOTAL VOCs (as CARBON): MEASUREMENT UNCERTAINTY CALCULATIONS

Value

Measured Quantities

14.5

ppm

0.11

14.5

14.5

CAT-RT (Version BB)

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Sample Runs

- -

- -

- -

- -

- -




References Used in Analytical Algorithm Application




Standard TGN M22

Check Gas Expiry Date

40

7.3

CYL 12.0009

Transportable

Concentration of References

10ppm

Uncertainty ±g/hr

0.72

Sample Cell Pressure (mbar)

Analysis Areas (Wave Number Limits) 1851 - 1864

Check Gas Type NO

Type of Reference

406.8

Check Gas Uncertainty (%)

1 / 1


180°C


Check Gas Start Pressure (bar)

2


Check Gas Reference Number

Heated Head Filter Used


Sampling System Path Length (m) 6.4

Sample Cell Temperature (°C)

996.77

Technical Procedure CAT-TP-22(b)

180

Mean

Parameter Value

APPENDIX 2

OXIDES OF NITROGEN (AS NO₂): RESULTS SUMMARY


EP-Bio Scrubber

Parameter Units Run 1

Concentration mg/m³ 4.01

Uncertainty ±mg/m³

7.3

0.72


4.01

41.1

10/12/2014

Yes

Heated Line Temperature


Zero Gas Type Nitrogen (5 Grade)

CAT-RT (Version BB)

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APPENDIX 2

OXIDES OF NITROGEN (AS NO₂): DATA TREND

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0

18.0

20.0

09

:00

:24

09

:10

:23

09

:20

:21

09

:30

:20

09

:40

:19

09

:50

:17

10

:00

:15

10

:10

:14

10

:20

:12

10

:30

:11

10

:40

:09

10

:50

:08

11

:00

:07

11

:10

:05

11

:20

:04

11

:30

:02

11

:40

:01

11

:49

:59

11:

59:5

8

12

:09

:56

12

:19

:55

12

:29

:53

12

:39

:52

12

:49

:50

12

:59

:49

13

:09

:47

13:

19:4

6

13

:29

:45

13

:39

:44

13

:49

:42

13

:59

:40

14

:09

:39

14

:19

:38

14

:29

:36

14

:39

:35

14

:49

:33

14

:59

:32

15

:09

:30

15

:19

:29

15

:29

:28

15

:39

:26

15

:49

:25

15

:59

:24

Co

nce

ntr

atio

n (

mg/

m³)

Oxides of Nitrogen (as NO₂) At Reference Conditions

- Run 1

CAT-RT (Version BB)

Page 41 of 64

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Lack of Fit

Zero Drift

Span Drift

Sensitivity to Atmospheric Pressure

Sensitivity to Sample Gas Pressure

Sensitivity to Ambient Temperature

Sensitivity to Electrical Voltage

Interferents

Standard Deviation of Repeatability at Zero

Standard Deviation of Repeatability at Span

Uncertainty of Certified Reference Material

Combined Uncertainty

Expanded Uncertainty (ppm)

Expanded Uncertainty (%age of Reading)

- t-distribution (k=2) - - 0.35


2.00 normal 2 0.020 0.02

- normal - - 0.17

-0.33 rectangular √3 0.149 -0.03

-2.00 rectangular √3 0.100 -0.12

0.12 normal 1 0.100 0.01

N/A normal 1 N/A 0.00

2.00 rectangular √3 0.100 0.12

N/A rectangular √3 N/A 0.00


1.80 rectangular √3 0.036 0.04

NOx (as NO₂) Range (ppm) 10

Source of Uncertainty Value (±%) Probability Distribution Divisor Conversion Factor ui | ppm

1.20 rectangular √3 0.020 0.01

0.50 rectangular √3 0.100 0.03

RUN 1 Measured (ppm) 1.95

Oxides of Nitrogen (as NO₂) NOx (as NO₂)

OXIDES OF NITROGEN (AS NO₂): MEASUREMENT UNCERTAINTY CALCULATIONS

APPENDIX 2

CAT-RT (Version BB)

Page 42 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Sample Runs

- -

- -

- -

- -

- -







0.1µm Glass Fibre

Check Gas Type

1.26

CAT-TP-22(b)

Check Gas Uncertainty (%) 2

SO₂

Probe Material


Heated Line Temperature 180°C

Stainless Steel

Filtration Type / Size

Check Gas Reference Number CYL 12.0009

Check Gas Expiry Date 10/12/2014

Check Gas Start Pressure (bar)

Parameter Value

7.3


40

Gas Cylinder Concentration (ppm) 101.2

APPENDIX 2


180

Sample Cell Pressure (mbar) 996.77

1 / 1


Concentration

Standard TGN M22

Technical Procedure


Type of Reference Concentration of References


0.71

Uncertainty ±g/hr 12.9 12.9

Sampling System Path Length (m)

Transportable 10ppm

mg/m³ 0.71

1.26

6.4



EP-Bio Scrubber

Parameter Units Mean

SULPHUR DIOXIDE: RESULTS SUMMARY


Run 1

CAT-RT (Version BB)

Page 43 of 64

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County Kerry

EP-Bio Scrubber





SULPHUR DIOXIDE: DATA TREND

APPENDIX 2

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0

18.0

20.0

09

:00

:24

09

:10

:23

09:

20:2

1

09

:30

:20

09

:40

:19

09

:50

:17

10

:00

:15

10

:10

:14

10

:20

:12

10

:30

:11

10:

40:0

9

10

:50

:08

11

:00

:07

11

:10

:05

11

:20

:04

11

:30

:02

11

:40

:01

11

:49

:59

11

:59

:58

12

:09

:56

12

:19

:55

12

:29

:53

12

:39

:52

12

:49

:50

12

:59

:49

13

:09

:47

13

:19

:46

13

:29

:45

13

:39

:44

13

:49

:42

13

:59

:40

14

:09

:39

14

:19

:38

14

:29

:36

14

:39

:35

14

:49

:33

14

:59

:32

15

:09

:30

15

:19

:29

15

:29

:28

15

:39

:26

15:

49:2

5

15

:59

:24

Co

nce

ntr

atio

n (

mg/

m³)

Sulphur Dioxide At Reference Conditions

- Run 1

CAT-RT (Version BB)

Page 44 of 64

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County Kerry

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Lack of Fit

Zero Drift

Span Drift





Interferents







- normal - - 0.22



√3 0.100 0.18

0.12 normal 1 0.100 0.01


2.00 normal 2 0.002 0.00

√3 N/A 0.00


-1.90 rectangular √3 0.036 -0.04

0.30 rectangular √3 0.149 0.03

Divisor Conversion Factor ui | ppm

1.28 rectangular √3 0.002 0.00

0.50 rectangular √3 0.100 0.03

2.00 rectangular √3 0.100 0.12


Sulphur Dioxide SO₂ SO₂ Range (ppm) 10

APPENDIX 2

SULPHUR DIOXIDE: MEASUREMENT UNCERTAINTY CALCULATIONS

Source of Uncertainty Value (±%) Probability Distribution

N/A rectangular

3.10 rectangular

CAT-RT (Version BB)

Page 45 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Sample Runs

- -

- -

- -

- -

- -







Mean

Check Gas Type CO

APPENDIX 2

CARBON MONOXIDE: RESULTS SUMMARY




Concentration mg/m³

Uncertainty

6.4

±g/hr 4.0 4.0

Parameter Value

Standard TGN M22

Technical Procedure

0.76


Transportable 10ppm




180

Sample Point I.D.'s


A1



10/12/2014

2

Sample Cell Pressure (mbar)


996.77

±mg/m³ 0.39

EP-Bio Scrubber


Check Gas Uncertainty (%)

CAT-TP-22(b)


CYL 12.0009

Check Gas Expiry Date

Check Gas Start Pressure (bar) 40

0.39

7.8

Uncertainty

Check Gas Reference Number

0.76


CAT-RT (Version BB)

Page 46 of 64

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County Kerry

EP-Bio Scrubber





APPENDIX 2

CARBON MONOXIDE: DATA TREND

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0

18.0

20.0

09

:00

:24

09

:10

:23

09

:20

:21

09

:30

:20

09

:40

:19

09

:50

:17

10

:00

:15

10

:10

:14

10

:20

:12

10

:30

:11

10:

40:0

9

10

:50

:08

11

:00

:07

11

:10

:05

11

:20

:04

11

:30

:02

11

:40

:01

11

:49

:59

11:

59:5

8

12

:09

:56

12

:19

:55

12

:29

:53

12

:39

:52

12

:49

:50

12

:59

:49

13

:09

:47

13

:19

:46

13

:29

:45

13

:39

:44

13

:49

:42

13

:59

:40

14

:09

:39

14

:19

:38

14

:29

:36

14

:39

:35

14

:49

:33

14

:59

:32

15

:09

:30

15

:19

:29

15

:29

:28

15

:39

:26

15

:49

:25

15

:59

:24

Co

nce

ntr

atio

n (

mg/

m³)

Carbon Monoxide At Reference Conditions

- Run 1

CAT-RT (Version BB)

Page 47 of 64

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County Kerry

EP-Bio Scrubber




Lack of Fit

Zero Drift

Span Drift





Interferents







- normal - - 0.16



-0.01

1.70 rectangular √3 0.100 0.10

0.16 normal 1 0.100 0.02


2.00 normal 2 0.006 0.01

Conversion Factor ui | ppm

CARBON MONOXIDE: MEASUREMENT UNCERTAINTY CALCULATIONS

0.12


APPENDIX 2

1.66 rectangular √3 0.006 0.01

0.50 rectangular √3 0.100 0.03

2.00 rectangular √3 0.100


-0.12 rectangular √3 0.036 0.00

-0.15 rectangular √3 0.149


Carbon Monoxide CO CO Range (ppm) 10

Source of Uncertainty Value (±%) Probability Distribution Divisor

CAT-RT (Version BB)

Page 48 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Sample Runs

- -

- -

- -

- -

- -













0.1µm Glass Fibre



Transportable


Value

EP-Bio Scrubber

Parameter Units


10ppm

83.39

±g/hrUncertainty



CYL 12.0009Check Gas Reference Number

0.7

Parameter

0.74


APPENDIX 2

HYDROGEN CHLORIDE: RESULTS SUMMARY

7.6


6.4

Sample Cell Temperature (°C) 180

Check Gas Type C₃H₈

7.6

0.74

Standard TGN M22




0.7Mass Emission g/hr


Run 1 Mean


CAT-RT (Version BB)

Page 49 of 64

Brandon Products

County Kerry

EP-Bio Scrubber





APPENDIX 2

HYDROGEN CHLORIDE: DATA TREND

0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0

10.0

09

:00

:24

09

:10

:23

09

:20

:21

09

:30

:20

09

:40

:19

09

:50

:17

10

:00

:15

10

:10

:14

10

:20

:12

10

:30

:11

10:

40:0

9

10

:50

:08

11

:00

:07

11

:10

:05

11

:20

:04

11

:30

:02

11

:40

:01

11

:49

:59

11:

59:5

8

12

:09

:56

12

:19

:55

12

:29

:53

12

:39

:52

12

:49

:50

12

:59

:49

13

:09

:47

13

:19

:46

13

:29

:45

13

:39

:44

13

:49

:42

13

:59

:40

14

:09

:39

14

:19

:38

14

:29

:36

14

:39

:35

14

:49

:33

14

:59

:32

15

:09

:30

15

:19

:29

15

:29

:28

15

:39

:26

15:

49:2

5

15

:59

:24

Co

nce

ntr

atio

n (

mg/

m³)

Hydrogen Chloride At Reference Conditions

- Run 1

CAT-RT (Version BB)

Page 50 of 64

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Lack of Fit

Zero Drift

Span Drift





Interferents










2.00 normal 2 0.000437548 0.00

- normal - - 0.23

3.20 rectangular √3 0.036055513 0.07

-0.20 rectangular √3 0.1 -0.02

3.10 rectangular √3 0.1 0.18

0.14 normal 1 0.1 0.01

2.00 rectangular √3 0.1 0.12




Hydrogen Chloride HCl HCl Range (ppm) 10


HYDROGEN CHLORIDE: MEASUREMENT UNCERTAINTY CALCULATIONS

1.63 rectangular √3 0.000437548 0.00

0.50 rectangular √3 0.1 0.03

APPENDIX 2

CAT-RT (Version BB)

Page 51 of 64

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EP-Bio Scrubber




Sample Runs

- -

- -

- -

- -

- -







83.39









Transportable

EP-Bio Scrubber

Parameter Units

mg/m³ 1.7 1.7



0.39






0.39

Concentration

Parameter Value

17.2

1 / 1

Standard TGN M22


4.0

APPENDIX 2

HYDROGEN FLUORIDE: RESULTS SUMMARY


Check Gas Type C₃H₈

10ppm


Uncertainty ±g/hr 4.0

Mean

0.1µm Glass Fibre



Run 1


CAT-RT (Version BB)

Page 52 of 64

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EP-Bio Scrubber





APPENDIX 2

HYDROGEN FLUORIDE: DATA TREND

0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0

10.0

09

:00

:24

09

:10

:23

09

:20

:21

09

:30

:20

09

:40

:19

09

:50

:17

10

:00

:15

10

:10

:14

10

:20

:12

10

:30

:11

10:

40:0

9

10

:50

:08

11

:00

:07

11

:10

:05

11

:20

:04

11

:30

:02

11

:40

:01

11

:49

:59

11:

59:5

8

12

:09

:56

12

:19

:55

12

:29

:53

12

:39

:52

12

:49

:50

12

:59

:49

13

:09

:47

13

:19

:46

13

:29

:45

13

:39

:44

13

:49

:42

13

:59

:40

14

:09

:39

14

:19

:38

14

:29

:36

14

:39

:35

14

:49

:33

14

:59

:32

15

:09

:30

15

:19

:29

15

:29

:28

15

:39

:26

15:

49:2

5

15

:59

:24

Co

nce

ntr

atio

n (

mg/

m³)

Hydrogen Fluoride At Reference Conditions

- Run 1

CAT-RT (Version BB)

Page 53 of 64

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County Kerry

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Lack of Fit

Zero Drift

Span Drift





Interferents







HYDROGEN FLUORIDE: MEASUREMENT UNCERTAINTY CALCULATIONS

APPENDIX 2

Source of Uncertainty Value (±%) Probability Distribution Divisor


Hydrogen Fluoride HF HF Range (ppm) 10

Conversion Factor ui | ppm

2.00 rectangular √3 0.03 0.03

0.50 rectangular √3 0.10 0.03

2.00 rectangular √3 0.10 0.12



3.00 rectangular √3 0.04 0.06

0.33 rectangular √3 0.15 0.03

4.00 rectangular √3 0.10 0.23

1.00 normal 1 0.10 0.10


2.00 normal 2 0.03 0.03


- normal - - 0.29


CAT-RT (Version BB)

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Sample Runs

- -

- -

- -

- -

- -









Parameter Value



Units Run 1 Mean


Uncertainty ±mg/m³ 0.66 0.66

g/hr 6.2 6.2

Uncertainty ±g/hr 6.8 6.8

Check Gas Type SO₂

Mass Emission


AMMONIA: RESULTS SUMMARY


EP-Bio Scrubber

Parameter




APPENDIX 2

0.1µm Glass Fibre



Standard TGN M22





1 / 1




Transportable 20ppm

899 - 969Analysis Areas (Wave Number Limits)

CAT-RT (Version BB)

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APPENDIX 2

AMMONIA: DATA TREND

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

09

:00

:24

09

:10

:23

09

:20

:21

09

:30

:20

09

:40

:19

09

:50

:17

10

:00

:15

10

:10

:14

10

:20

:12

10

:30

:11

10:

40:0

9

10

:50

:08

11

:00

:07

11

:10

:05

11

:20

:04

11

:30

:02

11

:40

:01

11

:49

:59

11:

59:5

8

12

:09

:56

12

:19

:55

12

:29

:53

12

:39

:52

12

:49

:50

12

:59

:49

13

:09

:47

13

:19

:46

13

:29

:45

13

:39

:44

13

:49

:42

13

:59

:40

14

:09

:39

14

:19

:38

14

:29

:36

14

:39

:35

14

:49

:33

14

:59

:32

15

:09

:30

15

:19

:29

15

:29

:28

15

:39

:26

15:

49:2

5

15

:59

:24

Co

nce

ntr

atio

n (

mg/

m³)

Ammonia At Reference Conditions

- Run 1

CAT-RT (Version BB)

Page 56 of 64

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EP-Bio Scrubber




Lack of Fit

Zero Drift

Span Drift





Interferents






Expanded Uncertainty (%age of Reading) - t-distribution (k=2) - - 109.14

- normal - - 0.49


3.60 rectangular √3 0.200 0.42

0.40 normal 1 0.200 0.08


2.00 normal 2 0.009 0.01



-1.90 rectangular √3 0.072 -0.08

-0.29 rectangular √3 0.299 -0.05


-1.70 rectangular √3 0.009 -0.01

0.50 rectangular √3 0.200 0.06

2.00 rectangular √3 0.200 0.23

Ammonia NH₃ NH₃ Range (ppm) 20


APPENDIX 2

AMMONIA: MEASUREMENT UNCERTAINTY CALCULATIONS

CAT-RT (Version BB)

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Sampling Details

Quality Assurance

0 0

0 0

Method Deviations

1

x

- - -

- - -

Interference Check

Run Number

Yes

Allowable ADC Saturation %

Background / Zero Calibration Check Units Value

Acceptable Background?

ADC Saturation % 39.53


(PAGE 1 OF 2)

Sampling Date 17/09/2013

09:00 - 16:00

CA

L 1

-Sampling Times

P

F

Nature of Deviation


HF failed the test of residuals which means that there may be something else in the sample affecting the result for HF (and leading

to a higher value being reported). As the reported value is very low at less than 1 mg/m³, it is not thought this residual test failure

will have much effect on the result, and the results reported may be taken as a "worst case" value.

PHydrogen Chloride

Hydrogen Fluoride

Ammonia P

where "P" = Pass and "F" = Fail

> 20

-

APPENDIX 2

M22 FTIR SAMPLING DETAILS & QUALITY ASSURANCE

-

Test Conditions Units Run 1

Run Ambient Temperature Range °C 14 - 19⁰C

DAY 1


Sulphur Dioxide

Carbon Monoxide

Target Parameter

P

P

CAT-RT (Version BB)

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Difference 0 0 0 0 0

0

Difference 0 0 0 0

Drift

NOTE: Drift correction will be automatically applied to the data if the maximum check gas drift is between 2 - 5%.

CA

L 1

Yes Yes Yes

Check Gas Check - Post Test

-0.3

14.2

14.8

ppm

Check Gas Acceptable

-4.6

C₃H₈

ppm

Units

Allowable Difference

APPENDIX 2

M22 FTIR SAMPLING DETAILS & QUALITY ASSURANCE

HCl

17

/09

/20

13

CA

L 1

144

(PAGE 2 OF 2)

200

Yes Yes

Check Gas Value

20.3± ppm 5.1

SO₂

101.2ppm 83.4

83.1

s

s

Allowable Response Time s

Response Time Acceptable -

190

160

200

Yes

(performed against decreasing H₂O)

ppm

Allowable Drift

C₃H₈

%

-0.6 -0.4

1.2 -1.9

-

190

5.0 5.0

Response Time, T₉₀

Reverse Response Time, RT₉₀

± %

-Drift Acceptable

5.0

NO

17/0

9/2

01

3 Check Gas Reading - Pre Test

Check Gas Reading on Analyser

NO

-1.2 -0.7

Yes

5.1

Yes

404.9 95.2 100.1 82.5 13.8

4.9 -1.8 -1.2

Check Gas Reading - Post Test ppm

Check Gas Reference Number -

400.0

406.8

5.0

CO SO₂

0.7

YesYes Yes

HCl

Yes

400.0 97.0 101.3 83.1 14.2

N/A

N/A

CYL 12.0009 CYL 12.0009 CYL 12.0009 CYL 8.0035

97.0

-0.6

CYL 12.0009

46

101.3

0.1-6.8

System Lag Time [ASC T₉₀ - T₉₀] s

Response Time from ASC, ASC T₉₀ s 180

10

4.2

ppm

Check Gas Check - Pre Test Units CO

101.6

144

46

190

200

Yes

180

10

REACTIVE

GAS CHECK

190

200

N/A

N/A

Yes

CAT-RT (Version BB)

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EP-Bio Scrubber




Results Summary

- - - - -

- - - - -

- - - - -

- - - - -

- - - - -

- - - - -

- - - - -





Reference Conditions are: 293K, 101.3kPa, wet gas

Sampling & Result Information

CAT-1197-

scrubber-B2

CAT-1197-

scrubber-B3

CAT-1197-

scrubber-B4

171

Reference Odourant Used -

Accepted Reference Value Used ppb 40

25⁰C ± 3⁰C

EO.9008

n-butanol in N₂

Analysis Result from Laboratory ouE/m³ 30 30 30 51 171

Analysis Result including Dilution

FactorouE/m³ 208 189 184 332 1046

Upper CI ouE/s 1405 1277 1240 2239 7066

ID of Olfactometer -

Calculated Panel Threshold ouE/m³ 30 30 30 51

CAT-1197-

scrubber-B5

Units

See Irish EPA

Temperature of Olfactometric Lab -

Special Process Conditions -

17/09/2013 17/09/2013 17/09/2013

Sample ID -CAT-1197-

scrubber-B1

Calculated Dilution Factor : 1

4 4


Parameter Bag 1 Bag 2 Bag 3 Bag 4 Bag 5

Sampling Times


Sample Point I.D.'s N/A

- 09:52 - 09:56 10:42 - 10:46 11:43 - 11:47 12:30 - 12:34 13:10 - 13:14

4

Parameter Value




Lower CI

18/09/2013

Times of Ofactometric Measurement - 12:28 12:40 14:21 14:34 15:05

Odour Presentation Mode Forced Choice Mode

Equipment Used Dynamic Dilution

Calibration Status of Olfactometer 0.213

Oxygen Content of the Stack Gas

6.9 6.3 6.1 6.5 6.1

Lower CI ouE/m³ 94 86 83 150 474

Mass Emission ouE/s 636 578 561 1014 3199

Upper CI ouE/m³ 459 418 405 732 2311

APPENDIX 2

ODOUR: RESULTS SUMMARY


ouE/s 288 262 254 459 1449

Release Point 1 - Stack

Parameter Units Bag 1 Bag 2 Bag 3 Bag 4 Bag 5

Concentration ouE/m³ 208 189 184 332 1046

Stac

k

Date of Olfactometric Measurement - 18/09/2013 18/09/2013 18/09/2013 18/09/2013

Sampling Dates - 17/09/2013 17/09/2013

% v/v 20.8 20.8 20.8 20.8 20.8

Oxygen Content of the Odour Bag % v/v 3.0 3.3 3.4 3.2 3.4

Duration mins 4 4

CAT-RT (Version BB)

Page 60 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Results Summary

- - - - -

- - - - -

- - - - -

- - - - -

- - - - -

- - - - -

- - - - -







- - - - -Bag 6 Bag 7 Bag 8 Bag 9 Bag 10

30 60

n-butanol in N₂


Analysis Result from Laboratory ouE/m³ 60 40 40 30 60


FactorouE/m³ 367 238 238 184 347

Reference Odourant Used -

Date of Olfactometric Measurement - 18/09/2013

1122Mass Emission

Probe Material

Value

BS EN 13725

CAT-TP-30

Stainless Steel

Odour Presentation Mode


20.8 20.8 20.8

Oxygen Content of the Odour Bag

1 / 1


0.213

1 / 1

Upper CI ouE/s

Parameter

Standard

Technical Procedure

4 4 4

% v/v 3.4 3.5 3.5 3.4 3.6

Calculated Dilution Factor : 1 6.1 5.9 5.9 6.1 5.8

Special Process Conditions - See Irish EPA

Lower CI ouE/s 329 329 254 480

60 40 40

ouE/s 727 727 561 1060

508

2479 1606 1606 1240 2341

Equipment Used

Calibration Status of Olfactometer


Forced Choice Mode

Dynamic Dilution

Temperature of Olfactometric Lab - 25⁰C ± 3⁰C

ID of Olfactometer - EO.9008

Calculated Panel Threshold ouE/m³

CAT-1197-

scrubber-B7

CAT-1197-

scrubber-B8

CAT-1197-

scrubber-B9

CAT-1197-

scrubber-B10

Duration mins 4

Parameter Units

Sampling Times -

18/09/2013 18/09/2013 18/09/2013 18/09/2013

Times of Ofactometric Measurement - 15:15 15:26 15:38 15:48 16:00

4

Oxygen Content of the Stack Gas % v/v 20.8 20.8

Release Point 1 - Stack

Parameter Units Bag 6 Bag 7 Bag 8 Bag 9 Bag 10

Concentration ouE/m³ 238 238 184 347

766

367

166

811

APPENDIX 2



Stac

k

13:05 - 13:09 14:54 - 14:58 15:39 - 15:43 16:20 - 16:24 16:40 - 16:44

Sampling Dates - 17/09/2013 17/09/2013 17/09/2013 17/09/2013 17/09/2013

Sample ID -CAT-1197-

scrubber-B6

Upper CI ouE/m³ 525 525 405

Lower CI ouE/m³ 108 108 83 157

CAT-RT (Version BB)

Page 61 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Results Summary

-

-

-

-

-

-

-







Reference Odourant Used - n-butanol in N₂


Analysis Result from Laboratory ouE/m³ 256


FactorouE/m³ 256

Times of Ofactometric Measurement - 12:03



Calculated Panel Threshold ouE/m³ 256

Calculated Dilution Factor : 1 1.0

Special Process Conditions - Formulation Area


Duration mins 20

Oxygen Content of the Stack Gas % v/v 20.9

Oxygen Content of the Odour Bag % v/v 20.9



Form

ula

tio

n

Parameter Units Bag 1

Sampling Times - 13:28 - 13:48


Sample ID -CEK-1197-

Ambient 1-B1





Equipment Used Odour Barrel



Lower CI ouE/s 355

Upper CI ouE/s 1729

Parameter Value

Lower CI ouE/m³ 116

Upper CI ouE/m³ 566

Mass Emission ouE/s 783

APPENDIX 2

Concentration



Release Point 2 - Formulation

ouE/m³ 256


CAT-RT (Version BB)

Page 62 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Results Summary

-

-

-

-

-

-

-







Reference Odourant Used - n-butanol in N₂


Analysis Result from Laboratory ouE/m³ 271


FactorouE/m³ 271

Times of Ofactometric Measurement - 12:15



Calculated Panel Threshold ouE/m³ 271

Calculated Dilution Factor : 1 1.0

Special Process Conditions -


Duration mins 20

Oxygen Content of the Stack Gas % v/v 20.9

Oxygen Content of the Odour Bag % v/v 20.9



Evap

ora

tio

n R

oo

m


Sampling Times - 14:03 - 14:23


Sample ID -CEK-1197-

Ambient 2-B1





Equipment Used Odour Barrel



Lower CI ouE/s 375

Upper CI ouE/s 1830

Parameter Value

Lower CI ouE/m³ 123

Upper CI ouE/m³ 599

Mass Emission ouE/s 829

APPENDIX 2



Release Point 3 - Evaporation Room


Concentration ouE/m³ 271

CAT-RT (Version BB)

Page 63 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




Method Deviations

- - - - -

- - - - -

- - - - -

ALL

x

APPENDIX 2

ODOUR: METHOD DEVIATIONS


All Release Points

Nature of Deviation Bag Numbers

(x = deviation applies to the associated bag/s)


CAT-RT (Version BB)

Page 64 of 64

Brandon Products

County Kerry

EP-Bio Scrubber




ISOKINETIC SAMPLING CALCULATIONS

Parameter

Absolute pressure of stack gas, Ps

Volume of water vapour collected, Vwstd

Gas meter correction factor, Yd

RESULTS SUMMARY Volume of gas metered dry, Vmstd

Emissions Results Volume of gas metered wet, Vmstw

Volume of gas metered wet @ X% O₂, Vmstw@X% O2

Volume of gas metered dry @ X% O₂, Vmstd@X% O2

Stack Gas CO₂ Content (Dry) Measured

Reference Conditions are: Stack Gas O₂ Content (Dry) Measured

Molecular weight of dry gas stream, Md

SAMPLING RUN & BLANK INFORMATION GENERAL SAMPLING INFORMATION Molecular weight of wet gas stream, Ms

Parameter Parameter Pitot tube velocity constant, Kp

Standard Pitot Tube Calibration Coefficient, Cp

Technical Procedure Average of velocity heads, ∆Pavg

Probe Material Average stack gas temperature, Ts

Impinger Material Velocity of stack gas, Vs

Sampling Equipment Total Flow of Stack Gas [ACTUAL]

< Number of Sampling Lines Used Conversion factor (K/mm.Hg), Cf

Number of Sampling Points Used Total Flow of Stack Gas [DRY]

Lab LOD / sample Sample Point I.D.'s Total Flow of Stack Gas [WET]

Total Flow of Stack Gas [WET, O₂]

QUALITY ASSURANCE INFORMATION ANALYSIS LABORATORY INFORMATION Total Flow of Stack Gas [DRY, O₂]

Parameter Parameter Nozzle diameter, Dn

Result of Leak Check Analytical Laboratory Nozzle area, An

Compliant Flow Rate through Impinger Lab Standard Operating Procedure Total sampling time, q

Result of Isokinetic Variation Analytical Technique % Isokinetic

Samples Analysed within 24 hrs UKAS Accredited Analysis

Samples kept at 5˚C ± 3˚C UKAS Number of Analytical Lab QUALITY CONTROL FIELD BLANK REQUIREMENTS

Parameter

MEASUREMENT UNCERTAINTY (MU) CALCULATIONS Mean Total Bacteria

Parameter Mean Fungi

Mean Gram Negative

Sampled Volume

Sampled Gas Temp. WEATHER &SAMPLE RECOVERY

Sampled Gas Pressure Parameter

Sampled Gas Humidity Weather Conditions

Leak Location of Sample Recovery

Lab Result Total Bacteria

Lab Result Fungi DATE & TIME OF ANALYSIS

Lab Result Gram Negative Parameter

Oxygen Content Date of Analysis

Time of Analysis

STACK DIMENSIONS

Combined MU Parameter

Expanded MU, 95% CI Shape of Duct

Expanded MU, 95% CI, estimated with deviations Orientation of Duct

Reported MU Stack Diameter

MU for Lab Result entered as zero whilst ongoing trials are performed to ascertain a value to attach to this part of the result's Measurement Uncertainty. Stack Width

Stack Area

N/A m

0.38 m²

METHOD DEVIATIONS

1 Due to the platform's restricated access, 2 points were sampled at in the duct instead of all 4 sample points.

2

N/A 41.0 23.5 N/A 2804393 30.4 N/A 0.70 m

Circular -

185169 30.4 - 41.0 23.5 - 2804393 30.4 - Vertical -

185169 30.4 - 41.0 23.5 - 2804393 30.4 -

- 20.9 - - 1430813 - - Value Units

10:35

Total Bacteria Fungi Gram Negative

cfu/m³ % Result % at ELV cfu/m³ % Result % at ELV cfu/m³ % Result % at ELV

1411025.5 1.0 1411025.5 Value

% v/v N/A % v/v N/A % 0.00 N/A - 0.0 N/A - 0.0 N/A - 0.0 17/09/2013

% 15.3 cfu - % 15.3 - - -

-93167.6 1.0 93167.6 - -

- - -

- - -

% 11.7 cfu - % 11.7 - - - 20.4 1.0 20.4 - - -

% 15.3 cfu - % 15.3

Value

% v/v 0.0 % v/v 1.0 % 1.00 Raining - no shelter

% 0.00 % - % 0.00 0.0 1.0 0.0 0.0 1.0 0.0 0.0 1.0 0.0 In warehouse under cover

0.3732 466 4.5 0.3732 24699318 237133.920

K 297.7 K 2.0 % 0.67

- - -kPa 100.3 kPa 0.5 % 0.50

m³ 0.4138 m³ 0.0083 % 2.00 0.3732 1630854 15657.6

PASS cfu/plate

Units Value Units Value Units Value Value Value Value Value Value Value Value Value Value 1.0 3 PASS cfu/plate

Result Standard MU MU as %age In Units Sensitivity In Result In Units Sensitivity In Result

Yes - PASS - N/A

Value Allowed Result Units

101.5 95 - 115 PASS % Microbiological Plating & Colony Counting 101.5 %

Yes - PASS - No

0.06 0.32 PASS l/min Health & Safety Laboratory (HSL) 37.33 mm²

20.5 16 - 30 PASS l/min INPUT 20 min

N/A m³/hr

N/A m³/hr

Value Allowed Result Units Value 6.89 mm

Mean Gram Negative Lab Result 3533333 100 cfu 2 / 4 11374.2 m³/hr

33 cfu A1 & A2 11680.2 m³/hr

Isokinetic Manual Sampling Train 12757.6 m³/min

Mean Fungi Lab Result 67 33 cfu 1 / 1 0.3592 -

Mean Total Bacteria Lab Result 233300 133 cfu

22.0 °C

Probe Rinse I.D. Number RINSE-5 RINSE-8 - Borosilicate Glass 9.21 m/s

Impinger I.D. Number 5 8 - Titanium

0.85 -

Volume Sampled [REF] 0.3833 0.3833 m³ CAT-TP-36 7.02 mmH₂O

Sampling Date 17/09/2013 17/09/2013 - VDI 4257 Blatt 2

273K, 101.3kPa, Wet 20.80 % v/v

28.84 g/gmol

28.56 g/gmol

Sampling Run Blank Units Value 34.97 -

Gram Negative 9218700 2804393 - 107676224278 32755863124 - 0.06 % v/v

Fungi 174 41.0 - 2031627 478369 - N/A m³

Total Bacteria 608695 185169 - 7109678243 2162814019 - N/A m³

Sampling Times 11:22 - 11:42 N/A m³

0.9900 -

0.3732 m³

Result [cfu/m³] Uncertainty (±) ELV [cfu/m³] Result [cfu/hr] Uncertainty (±) ELV [cfu/hr] 0.3833 m³

PART 2: SUPPORTING INFORMATION - APPENDIX 1 - BIOAEROSOLS: RESULTS, CALCULATIONS & MEASUREMENT UNCERTAINTY

Release Point Bio Scrubber

Run Number 1 Value Units

Sampling Date 17/09/2013 751.9 mmHg

Total Bacteria Fungi Gram Negative 1.3 3 PASS cfu/plate

94474 -

185169 30.4

In Units Sensitivity In Result 0.3 3

CAT-GT (Version A)

Copyright © 2013 Catalyst Environmental Ltd.

CEK-1197 Brandon Products Bioaerosols Datasheet (with results) Version 2

ISOKINETIC SAMPLING CALCULATIONS

Parameter

Absolute pressure of stack gas, Ps

Volume of water vapour collected, Vwstd

Gas meter correction factor, Yd

RESULTS SUMMARY Volume of gas metered dry, Vmstd

Emissions Results Volume of gas metered wet, Vmstw

Volume of gas metered wet @ X% O₂, Vmstw@X% O2

< < Volume of gas metered dry @ X% O₂, Vmstd@X% O2

Stack Gas CO₂ Content (Dry) Measured

Reference Conditions are: Stack Gas O₂ Content (Dry) Measured

Molecular weight of dry gas stream, Md

SAMPLING RUN & BLANK INFORMATION GENERAL SAMPLING INFORMATION Molecular weight of wet gas stream, Ms

Parameter Parameter Pitot tube velocity constant, Kp

Standard Pitot Tube Calibration Coefficient, Cp

Technical Procedure Average of velocity heads, ∆Pavg

Probe Material Average stack gas temperature, Ts

Impinger Material Velocity of stack gas, Vs

Sampling Equipment Total Flow of Stack Gas [ACTUAL]

< < Number of Sampling Lines Used Conversion factor (K/mm.Hg), Cf

Number of Sampling Points Used Total Flow of Stack Gas [DRY]

Lab LOD / sample Sample Point I.D.'s Total Flow of Stack Gas [WET]

Total Flow of Stack Gas [WET, O₂]

QUALITY ASSURANCE INFORMATION ANALYSIS LABORATORY INFORMATION Total Flow of Stack Gas [DRY, O₂]

Parameter Parameter Nozzle diameter, Dn

Result of Leak Check Analytical Laboratory Nozzle area, An

Compliant Flow Rate through Impinger Lab Standard Operating Procedure Total sampling time, q

Result of Isokinetic Variation Analytical Technique % Isokinetic

Samples Analysed within 24 hrs UKAS Accredited Analysis

Samples kept at 5˚C ± 3˚C UKAS Number of Analytical Lab QUALITY CONTROL FIELD BLANK REQUIREMENTS

Parameter

MEASUREMENT UNCERTAINTY (MU) CALCULATIONS Mean Total Bacteria

Parameter Mean Fungi

Mean Gram Negative

Sampled Volume

Sampled Gas Temp. WEATHER &SAMPLE RECOVERY

Sampled Gas Pressure Parameter

Sampled Gas Humidity Weather Conditions

Leak Location of Sample Recovery

Lab Result Total Bacteria

Lab Result Fungi DATE & TIME OF ANALYSIS

Lab Result Gram Negative Parameter

Oxygen Content Date of Analysis

Time of Analysis

STACK DIMENSIONS

Combined MU Parameter

Expanded MU, 95% CI Shape of Duct

Expanded MU, 95% CI, estimated with deviations Orientation of Duct

Reported MU Stack Diameter

MU for Lab Result entered as zero whilst ongoing trials are performed to ascertain a value to attach to this part of the result's Measurement Uncertainty. Stack Width

Stack Area

N/A m

0.38 m²

METHOD DEVIATIONS

1 Due to the platform's restricated access, 2 points were sampled at in the duct instead of all 4 sample points.

2

Vertical -

472223 30.4 N/A 22.6 23.6 N/A 404341 30.4 N/A 0.70 m

472223 30.4 - 22.6 23.6 - 404341 30.4 -

Value Units

472223 30.4 - 22.6 23.6 - 404341 30.4 - Circular -

240930 - - 11.5 - - 206296 - -

10:35

Total Bacteria Fungi Gram Negative

cfu/m³ % Result % at ELV cfu/m³ % Result % at ELV cfu/m³ % Result % at ELV

- - 203408.7 1.0 203408.7 Value

% v/v N/A % v/v N/A % 0.00 N/A - 0.0 N/A - 0.0 N/A - 0.0 17/09/2013

% 15.3 cfu - % 15.3 - - -

-% 15.3 237557.6 1.0 237557.6

-

- - - - -

% 11.7 cfu - % 11.7 - - - 11.3 1.0 11.3 - - -

% 15.3 cfu -

Value

% v/v 0.0 % v/v 1.0 % 1.00 Raining - no shelter

% 0.00 % - % 0.00 0.0 1.0 0.0 0.0 1.0 0.0 0.0 1.0 0.0 In warehouse under cover

K 300.0 K 2.0 % 0.67

- - -kPa 100.3 kPa 0.5 % 0.50

Value Value Value Value Value Value PASS cfu/plate

m³ 0.3724 m³ 0.0074 % 2.00 0.3328 4662987 40170.8 0.3328 289 2.5 0.3328 3992683 34396.227

Units Value Units Value Units Value Value Value Value

Total Bacteria Fungi Gram Negative 3 PASS cfu/plate

Result Standard MU MU as %age In Units Sensitivity In Result In Units Sensitivity In Result In Units Sensitivity In Result 3 PASS cfu/plate

Yes - PASS - N/A

Value Allowed Result Units

104.9 95 - 115 PASS % Microbiological Plating & Colony Counting 104.9 %

Yes - PASS - No

0.06 0.32 PASS l/min Health & Safety Laboratory (HSL) 37.33 mm²

18.4 16 - 30 PASS l/min INPUT 20 min

N/A m³/hr

N/A m³/hr

Value Allowed Result Units Value 6.89 mm

Mean Gram Negative Lab Result 456667 100 cfu 2 / 4 9816.0 m³/hr

33 cfu A1 & A2 10134.2 m³/hr

Mean Total Bacteria Lab Result 533333 133 cfu Isokinetic Manual Sampling Train 11170.3 m³/min

Mean Fungi Lab Result 33 33 cfu 1 / 1 0.3592 -

Impinger I.D. Number 7 8 - Titanium 24.7 °C

Probe Rinse I.D. Number RINSE-7 RINSE-8 - Borosilicate Glass 8.06 m/s

Sampling Date 17/09/2013 17/09/2013 - VDI 4257 Blatt 2 0.85 -

Volume Sampled [REF] 0.3436 0.3436 m³ CAT-TP-36 5.32 mmH₂O

273K, 101.3kPa, Wet 20.80 % v/v

28.84 g/gmol

28.50 g/gmol

Sampling Run Blank Units Value 34.97 -

N/A m³

Gram Negative 1328937 404341 - 13467764573 4097687851 - 0.06 % v/v

Fungi 96 22.6

Result [cfu/m³] Uncertainty (±) ELV [cfu/m³] Result [cfu/hr] Uncertainty (±) ELV [cfu/hr] 0.3436 m³

Total Bacteria 1552043 472223 - 15728776144 4785620848 - N/A m³

0.3

1.0 3

1.3

- 973218 229220 -

Release Point Bio Scrubber

Run Number 2

PART 2: SUPPORTING INFORMATION - APPENDIX 1 - BIOAEROSOLS: RESULTS, CALCULATIONS & MEASUREMENT UNCERTAINTY

Value Units

0.3328 m³

Sampling Date 17/09/2013 751.9 mmHg

Sampling Times 14:38 - 14:58 N/A m³

0.9900 -

CAT-GT (Version A)

Copyright © 2013 Catalyst Environmental Ltd.

CEK-1197 Brandon Products Bioaerosols Datasheet (with results) Version 2

Brandon Products: Results of Bioaerosol Modelling exercise: 100%ile (Worst Case)

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Brandon Products: Results of Bioaerosol Modelling exercise: 100%ile (Worst Case)

-1500 -1000 -500 0 500 1000 1500

Metres

-1500

-1000

-500

0

500

1000

1500

Metr

es

Summary Report on Modelling of Brandon Products Bioaerosol Emissions

Inputs:

2011 hourly meteorological data for Shannon Airport.

Stack Height: 14.8metres, diameter: 0.7 metres, exit velocity: 7.9 m/s, temperature: 15.8 oC.

No terrain data included.

No building data included.

Average gram negative bacteria concentration from two sampling runs = 5,273,819 cfu/m3.

Volumetric flow = 2.84 Nm3/s. Mass emission of gram negative bacteria = 15,024,524 cfu/s.

Total bacteria values were not used as the gram negative results were the highest reported.

The model assumes continuous emissions over the full year. From the point of view of the

annual average concentration plot below this will obviously overestimate the average

concentration, however it is an appropriate approach to determine the likely worst-case 1

hour concentration at any time over the year.

Note, the viability of the bacteria is not considered in the modelling, there is assumed to be no loss

between release from the stack and arrival at the relevant downwind location.

The bioaerosols are modelled as a gas based on an assumed small particle size. However, further

analysis of the composition of the bioaerosols may indicate different micro-organisms with different

particle sizes and also organisms which may tend to agglomerate and form larger particles. At

present the data is not available to carry out a more detailed assessment based on the bioaerosol

composition.

The model was set up to calculate downwind concentrations on an approximate 50 x 50 metre grid.

1-hour average concentrations were calculated in units of cfu/m3.

Outputs:

See three plots below of the annual average, 100th percentile (i.e. single worst hour in the year) and

98th percentile (values exceeded for 2 % of hours in the year).

Preliminary Conclusions:

The results indicate some potential risk of exceeding a level of 1,000 cfu/m3 during specific

meteorological conditions. Consideration of terrain and building effects may significantly alter the

downwind concentrations, while further analysis of the bioaerosol composition may alter the way in

which the emissions are modelled (i.e. as a gas or particulate phase). Details of the bioaerosol

composition may also help in determining the likely loss of viable micro-organism after release from

the stack, as some organisms are more resistant than others in this regard. The operator should

assess the impact of bioaersol emissions as part of the licence application.

Average concentrations of bioaersols for 2011 met data:

-1500 -1000 -500 0 500 1000 1500

Metres

-1500

-1000

-500

0

500

1000

1500

Me

tre

s

/ v-10

--~ to...._ -.......

( ........... 20--- "'o

~(C~ ~ J / .._to.-"' '_.../

01\..._. <;{ "'

J"'o

100th percentile concentrations for 2011 meteorological data:

-1500 -1000 -500 0 500 1000 1500

Metres

-1500

-1000

-500

0

500

1000

1500

Metr

es

98th percentile concentrations for 2011 meteorological data:

-1500 -1000 -500 0 500 1000 1500

Metres

-1500

-1000

-500

0

500

1000

1500

Metr

es

of 3

Meeting Record

Title Brandon Products Limited P0957-01: IPPC licence application and odour issue

Meeting Date & Time

Friday, 08/11/13, 10:00am.

Venue EPA office, Richview, Clonskeagh, Co. Dublin

Video conference link to EPA office, Inniscarra, Co. Cork

Name and Address

Reg. No. of the Licensee

Brandon Products Limited, Kilcolman, Asdee, Co.Kerry

P0957-01

Name of Facility Brandon Products Limited

Present at meeting

Office of Environmental Enforcement – Peter Cunningham (Senior Inspector, OEE, Cork), Ian Marnane (Manager Air Thematic Unit, Dublin), Niamh O’Donoghue (Team Leader, Cork), Maria Lenihan (Inspector, Cork).

Licence Applicant Representatives – Mr. Jerry O’Mahony (Operational Director, Brandon Products Ltd), Mr. Trevor Montgomery (Montgomery EHS Ltd.), Mr. Fergal Callaghan (AWN Consulting) and Mr. Ed Porter (AWN Consulting).

Fergal Callaghan introduced the main topic of the meeting, recent developments re modelling of the emissions from Brandon Products Ltd.

Ed Porter: starting point: existing situation o Catalyst monitoring July 2013: Aerox trial o Odour monitoring result after the bioscubber was 2000 OUe/m³ o Modelled on additional 50% therefore assuming 3000 OUe/ m³ o Collate results of modelling with complaints log

Complaint log o 50 to 60 complaints in a year o Assumptions on worst case receptor (WCR) and 3hours duration of nuisance

odour Model run

o With stack 14.8m (current), modelling showed odour at receptors o At 25m, odour units reduced significantly, the maximum odour concentration

is < odour guideline value. Installation of a mist eliminator to stack

o Reduced exit point diameter to 0.3m Exit velocity now 40m/s With this measure, 98%ile odour concentration reduced by about half With higher stack of 20m, even max ambient at WCR below odour

guideline value of 1.5 OUe/ m³ Building downwash a significant factor at the present stack height.

of 3

Brandon Products Ltd. are willing to apply for planning for an increase in the height of the stack.

Ian Marnane: what is basis of a 3000 OUe/m³ modelled emission?

Ed Porter: 3000 as a constant value is considered a high conservative value

Ian Marnane: what about the operational status of the bioscrubber?

Trevor Montgomery: all operational control parameters managed in real time by Brandon Products Ltd. Bacteriological testing is undertaken every day. The bioscrubber was working well when Catalyst undertook monitoring in July 2013.

Peter Cunningham: To reiterate OEE did not agree any actions with Brandon Products Ltd. at a previous meeting held in May 2013. The abatement in place and proposed will be reviewed by licensing as part of the licence application. There is a concern that monitoring may not be representative if there is no nuisance on the day. The odour complaints log of approximately 60 complaints may or may not be representative of all complaints.

Ed Porter: model will show relative improvement that will be delivered by the proposed development.

Abatement system o Ed Porter: Two stage abatement: bioscrubber and stack

Worst case: o 3000 OUe/m³

Ed Porter: the 25 m provides cover up to 15000 OUe/m³, giving a margin of error.

Planning: Two strands (possible avenues): o Ask EPA to “condition in” the increase under section 105, thus bypassing

public process – though public could comment by submission to the licence application? Would EPA have the power to disregard planning rights?

o Direct planning application to the Local Authority

Maria Lenihan: Has Brandon Products Ltd. sought planning permission from the local authority for an increased stack height?

Fergal Callaghan: Brandon Products Ltd. will apply for planning permission as well and will be looking for a pre-planning meeting with the local authority within the next 2 weeks.

Trevor Montgomery: did the recent EPA monitoring give any higher odour emission values than the 3000 OU/em³ modelled?

Ian Marnane: no, around 1040 OUe/m³

Recent infrastructure developments o Mist eliminator: 90% reduction in moisture since installation therefore

effectively reducing potential for bioaerosol emissions o Narrower exit point: Increases efflux velocity

Niamh ODonoghue: Due to changes onsite the licence application is out of date and Brandon Products Ltd will need to discuss this with licensing.

Fergal Callaghan: want to include all available data; will the EPA air monitoring report be made available? Would be useful e.g. for planning application.

Ian Marnane: Results still being assessed and monitoring results indicate high bioaerosols.

Peter Cunningham: If Brandon Products Ltd. wish to make a submission on why we should make results from Agency sponsored monitoring available pro bono, they may do so.

of 3

Licensing of Brandon Products Ltd. and competitors o Brandon operating without a licence and causing off site impacts, so on

OEEs agenda o Other related companies currently without licences – not on OEE agenda as

no complaints being received o Matter for anyone who wishes to make submission on sites they consider

may be operating without a licence.

Summary remarks o Matter for Brandon to operate their facility without causing off site impact. o Results of Ed Porter’s modelling look like a positive contribution .

Signed: Maria Lenihan Date: 14/11/13

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Meeting Record

Title Brandon Products Limited P0957-01 IPPC licence application and odour issue

Meeting Date & Time

Tuesday, 21/05/13, 11:00am.

Venue EPA office, Inniscarra, Co.Cork

Name and Address

Reg. No. of the Licensee

Brandon Products Limited, Kilcolman, Asdee, Co.Kerry

P0957-01

Name of Facility Brandon Products Limited

Present at meeting

Office of Environmental Enforcement – Peter Cunningham (Senior Inspector, OEE, Cork), Maria Lenihan (Inspector).

Office of Climate Licensing and Resource Use – Ann Marie Donlon (Inspector, Cork) Licence Applicant Representatives – Dr. Henry Lyons (Founding Director and chairman of the board), Mr. Jerry O’Mahoney (Operational Director), Mr. Trevor Montgomery (Consultant) and Mr. Fergal O’Callaghan (AWN Consulting).

Fergal O’Callaghan stated the following at the opening meeting:

Brandon Products Ltd. are looking to put a stack in place. They are confident that they will get planning for this under an exemption as it will be attached to an existing piece of equipment.

They are in the process of putting in place an ozonation system as a step along the way to further abatement.

Brandon Products Ltd. acknowledges that there are complaints regarding noxious, odours despite investment in technology and commented that the complaints appear to be only coming from certain areas. Brandon Products Ltd. have read the Agency odour statements issued to them via correspondence dated 17/05/13 and have concerns regarding the health issues raised. As a result Brandon Products Ltd have asked the HSA to come to the facility and have also engaged an occupational health doctor from Limerick to assess employees working on-site.

Brandon Products Ltd have a full REACH dossier that gives a profile of the materials used on-site.

On-site a natural substance is cooked up, there is a reaction, a musty odour is being

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generated but odours are being scrubbed and he is trying to rationalise this.

Odours are subjective and a person can feel psychologically that an unpleasant odour is having a health impact.

Ann Marie Donlon asked Fergal O’Callaghan why the bioscrubber is emanating an odour. Fergal O’Callaghan stated that biomass is growing in the bioscrubber but that this does not generate an unpleasant odour. Later in the meeting Maria Lenihan asked Fergal O’Callaghan had he verified odours from the bioscrubber before it had been cleaned out, sterilised and reactivated with bacteria in recent weeks and Fergal O’Callaghan confirmed that he was not present at the bioscrubber before this work was completed.

Peter Cunningham responded to the opening remarks by Fergal O’Callaghan and stated the following:

He considers that a company that operates by law and common fairness does not cause distress to neighbours. Brandon Products Ltd cannot achieve this at present.

The Agency has been receiving complaints about odours from this facility since 2011. The complainants have not felt that they can speak to the company directly regarding odour issues.

He is of the opinion that there is a credible significant air pollution issue here and that the complainants are credible, because we have direct evidence of this.

OEE has seen other situations where residents do not choose to make complaints about odour, noise or other forms of nuisance; people are not obliged and cannot be made to complain. However, this cannot be taken as evidence that there are no significant issues.

Mr. Jerry O’Mahoney confirmed that they began operations at the current site with one cooker (@ 6 tonnes).

Mr. Trevor Montgomery confirmed that the bioscrubber was sized for the operations currently on-site with a flow rate of 6,000m³/hr. Peter Cunningham asked if there was a potential for carryover of odour and Fergal O’Callaghan confirmed that it could be possible.

Maria Lenihan stated that she has experienced two types of odours, a musty type odour and a chemical-caustic type odour. Maria Lenihan also stated that as well as the bioscrubber there is also an issue with fugitive emissions as the building is not a negative pressure building. Fergal O’Callaghan stated that Brandon Products Ltd. are currently addressing the gaps in existing doors, the incomplete closing of the roller door and any gaps in the walls and roof area.

Fergal O’Callaghan asked what Brandon Products Ltd. can do practically to address this issue, that there is more that can be done and that they want an IPPC licence. Peter Cunningham stated that it is his opinion that the current abatement system is not sufficient and that they need to put in place an appropriate abatement system that will address odour issues on-site.

Henry Lyons spoke about the REACH register. He stated that the board are taking this odour issue very seriously, the board are meeting tomorrow night and that environment and health will be the main issue discussed. He stated that the Board were very surprised to learn in the

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last few weeks of reports of health impacts resulting from exposure to the emissions from the facility, and that they had not been informed of such complaints before that. He has worked in this area for many years and has never been impacted health wise from this. Brandon Products Ltd. want to address the health issues raised and while he finds it difficult to understand the subjectivity of odours, with a chemistry background he is used to dealing with units, he takes on board what he is being informed of by the Agency.

Peter Cunningham confirmed that this is a very significant problem and that the complaints have been consistent in relation to health impacts.

Ann Marie Donlon advised that the bioscrubber chosen to treat the odours seemed to be generating an odour in itself and that the emissions from the installation should be without a significant odour element. It is Brandon Products Ltd role to demonstrate to the Agency that they are not having a nuisance odour impact and that extensive guidance exists to ensure that the correct abatement system is put in place.

Peter Cunningham stated that the crux of the matter is what Brandon Products Ltd. is going to do in the interim. At present Brandon Products Ltd. is causing air pollution and has no IPPC licence to carry out the licensable activity on-site. The Agency is not in a position to allow this operation to continue without appropriate abatement in place without an IPPC licence in place.

Fergal O’Callaghan stated that the Brandon Products Ltd. was an employer and an exporter and that Brandon Products Ltd. had spent a lot of money trying to fix the problem. Brandon Products Ltd. have acknowledged this issue and have made an investment of 300,000 euros addressing this issue. Brandon Products Ltd. is part of a research programme and that the Agency must be cognisant of this.

Peter Cunningham acknowledged the remarks made by Fergal O’Callaghan with regard to the company, commended the company on this and stated that the Agency supports sustainable development where possible. However, if Brandon Products Ltd. cannot operate without causing air pollution, continuing to operate in this circumstance is a situation that the Agency cannot accept. Brandon Products Ltd. must have a licence in place to operate and must be able to comply with that licence. Brandon Products Ltd. must eliminate odorous emissions to eliminate the risk of causing air pollution and this must be dealt with as part of the IPPC licence application. An IPPC licence must be in place before operation resumes.

Fergal O’Callaghan again spoke about the subjectivity of the odour, people’s perception of odour and that complaints are only coming from one particular area and not all the time. Maria Lenihan pointed out that the complaints were verified, that both Inspector Cunningham and herself had experienced the health impacts that the residents has described and that people may be experiencing odour but are not complaining. For e.g. on the 24/04/13 at Tom O’Sullivan Agri stores both Inspector Cunningham and Maria Lenihan experienced an unbearable smell during an odour assessment however, the Agency has never received a complaint directly from this occupier of this store.

Trevor Montgomery stated that he has tried to engage with the complainants and that he has met with residents in other areas that have no issue with odours. Peter Cunningham replied that this did not in any reduce the reliability of the complaints that we have received and which we have verified in all respects.

Trevor Montgomery stated that a second ozone unit will be installed in a number of days and confirmed that Brandon Products Ltd. have been in operation again with the last week. He

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asked if there had been any complaints associated with this period of operation. Maria Lenihan confirmed that yes there had been complaints about impact from the facility in the last week.

Brandon Products Ltd. has engaged fully with the Agency, applied for an IPPC licence and have an open door policy. Peter Cunningham said that it does not appear that residents want to deal directly with the operator, which is their right, and reiterated that the current abatement system on-site is not suitable.

Fergal O’Callaghan spoke about a framework to address this issue with short term and long term steps.

Henry Lyons agreed to look at formulations as an ammonium salt is used.

Mr. Jerry O’Mahoney stated that there were a professional outfit and asked for a timeframe for a decision on the IPPC licence application. Ann Marie Donlon stated that an Environmental Impact Statement has yet to be submitted by the applicant and that once submitted a statutory time frame of 2 months exists for a decision or indeed a request for further information could be made. Ann Marie Donlon also stated that her office has resource constraints at present.

Peter Cunningham again expressed OEE’s view that operation of the facility with its current level of abatement capability could not be done without a risk of causing air pollution, and confirmed that it a matter for Brandon Products Ltd. to propose measures to the Agency to address the emissions issues as part of the IPPC licence application.

Signed: Maria Lenihan Date: 27/05/13

Department of Public Health, HSE South (Cork and Kerry),

Floor 2, Block 8, St. Finbarr’s Hospital, Douglas Road, Cork

Tel: 021 4927601 Fax: 021 4923257

[email protected]

13th December 2013 Ms. Laura Burke, Director General of the Environmental Protection Agency, PO Box 3000, Johnstown Castle Estate, Wexford. Re: Concerns regarding possible public health effects associated with emissions

from Brandon Products Ltd. Kilcolman, Asdee, Co. Kerry. Dear Ms. Burke, On the 23rd of July 2013, I was contacted by Ms. Maria Lenihan, Office of Environmental Enforcement, EPA, with regard to suspected public health effects associated with Brandon Products Limited. As requested I carried out an initial inquiry as per the “Protocol for the investigative approach to serious animal/human health problems”1 and I find that there is some substance to the concerns. This initial health enquiry indicates there is a completed pathway of exposure to odorous gases from Brandon Products Ltd. to the public downwind of the facility, using ATSDR methodology2. Initial indications are that all of the permanent residents downwind (of the prevailing wind) have made complaints of odours, ranging in intensity from mild up-to and including frequent complaints of intolerable odours at Level 4 of EPA Odour Impact Assessment Guidance for EPA Licensed Sites (AG5)- “Very Strong Odour (unbearable, difficult to remain in area affected by odour”. Odour complaint information and logs suggest that: sometimes people at public exposure points perceive no odours; sometimes milder odours that are merely offensive are experienced; but that sometimes the levels of odour are so irritant that they are intolerable. The proportion of days affected by odour appears to be about 1 in 3. 1 Protocol for the investigative approach to serious animal/human health problems. (See http://www.lenus.ie/hse/bitstream/10147/283234/1/EPA_protocol_investigation_animal_human_health.pdf ) 2 ATSDR Public Health Assessment Guidance Manual (2005 Update), Chapter 6. Exposure evaluation: evaluating exposure pathways (See http://www.atsdr.cdc.gov/hac/PHAManual/ch6.html#6.1 )

EPA inspectors have also experienced odours at Level 4, experiencing acute health effects lasting more than a day, such that they attended their medical practitioner. The limited information on emissions from the facility indicates that toxic gases may be emitted at some times. I believe a variety of processes may occur, so emissions may vary depending on processes carried out by the facility at any one time. However, there is no data on the concentrations of any gases at public exposure points and especially when Level 4 odours are apparent at these points. Since the initial health enquiry was requested, a 14.8 metre stack has been installed at the facility, but odour complaints have been received and verified since installation. Independent monitoring of emissions at the facility was carried out on 17th September 2013 for the EPA. In that report the measured concentrations of bioaerosols reported appear to be elevated and this requires further investigation. However it is doubtful that the emissions reported are representative of odorous gases perceived at public exposure points because:

I have been informed that no odours were detected at exposure points that day The bioaerosols measured are not closely related to odour

Of the eight residents downwind of the facility, in the direction of the prevailing wind, six have chronic respiratory disease or symptoms. It is not possible to say that any of these illnesses are directly attributable to odorous gases. But it should be noted that, in general, people who are more vulnerable to respiratory disease should avoid exposure to respiratory irritants. Therefore, additional caution is required in relation to air quality. Several residents report significant stress because of the on-going nature of this problem (4-5 years) and their inability to achieve a solution. This appears to have had a very significant adverse impact on their quality of life. Residents are aware that complaints were made about this company at its previous site(s) and that for this reason the facility was moved to its current location. The county council has verified there were complaints about this company at previous site(s). An Environmental Impact Statement was submitted to the EPA on 3rd of July 2013. It states that in relation to the impact on human beings, “particular regard is given to the potential impact of the existing operation on the local communities” and notes that “the company has received odour complaints which they have addressed”. The EIS report doesn’t indicate awareness that odour and health complaints are on-going and these issues are not addressed in the EIS. Based on the information available at present the following scenarios are possible:

1. Odour without toxicity - odorous gases perceived do not reach toxic levels at any time and that the effects of the gases are nuisance and stress, but have no physical effects

2. Odour with toxicity - odorous gases reach toxic levels sometimes and so may cause acute and / or chronic health effects as well as nuisance and stress

3. Toxicity without odour - gases such as bioaerosols that may not be associated with odour could have potential for acute and/or chronic health effects.

Based on the initial health inquiry, there is insufficient data to identify which scenarios are, or are not, occurring. Therefore it is impossible to reassure residents with regard to possible health effects associated with odorous or other gases. According to the EPA Air Guidance Note 5, “odour nuisance= pollution” and IPPC licensees are expected to ensure that “odours do not give rise to nuisance at the facility or in the immediate area of the facility”. This indicates that residents should not be obliged to be exposed to odorous gases on an on-going basis. Authorities in other jurisdictions indicate a similar view. For example, in New South Wales (NSW) one of the principles in planning is that “all avoidable risks should be avoided”3. The NSW Department of Planning points out that acceptability of risk should be taken into account and that people “are far less tolerant of risks imposed on them and over which they have little control, unless they consider the risks as negligible”. NSW authorities also note “that risks and benefits tend to be unevenly distributed”. Public Health England also has the view that residents should only rarely be exposed to mild odour nuisance. Residents should not continue to be exposed to odorous gases such that they experience acute health effects. Of interest to this initial health inquiry, the NSW Department of Planning give toxic exposure criteria: “toxic concentrations in residential and sensitive use areas should not cause irritation to eyes or throat, coughing or other acute physiological responses in sensitive members of the community over a maximum frequency of 50 in a million per year”. Reports from residents and EPA inspectors indicate that this recommended maximum frequency is far exceeded in this case. As you are aware, the Department of Public Health has no authority/responsibility to control this issue, but our role is to provide advice. My recommendations to the EPA are:

1. Comprehensive independent environmental monitoring, taking consideration of worst case scenarios and consequent public health effects, should be prioritised by the EPA. Monitoring should take account of variation in gases produced and emitted at the facility and measurable at public exposure points.

2. I endorse the recommendations of our specialist environmental advisors at

Public Health England who said “We recommend modelling of stack emissions is undertaken to predict likely ground level concentrations downwind of the factory. This modelling should consider a range of meteorological conditions especially those likely to restrict dispersion of stack emissions”.

3. The EPA should commission a comprehensive Environmental Impact

Assessment paying particular attention to the impact on human beings including health impacts if any.

3 Risk Criteria for Land Use Safety Planning. January 2011. (See http://www.planning.nsw.gov.au/Portals/0/HIPAP%204%20Final%202011.pdf )

4. A system for early recognition of health complaints and effects should be set

up across agencies. Residents say they have been complaining to authorities for 4-5 years without any effective action being taken.

5. If there are gaps in legislation such that the health of the public is not

protected, the EPA might make the case for improved legislation to legislators. 6. A system to protect confidentiality of personal health information should be

instituted by the EPA so that lack of confidentiality is not a barrier to health complaints. The name and personal health information of one of the residents is on her GP’s submission with regard to licensing of this facility, and is in the public domain on the EPA website. While this person may have given permission to have her personal health information available to the public on the EPA website, another resident identified this as a barrier for them to make health complaints to the EPA. This may have been a barrier to others as personal health information is generally considered to be very sensitive information.

7. The approach to the assessment of odour complaints should be reviewed. A

precautionary approach would suggest one should rule out evidence of toxicity associated with odour.

I recommend this matter for your attention. If you need more information, please do not hesitate to contact me. Yours sincerely, ___________________ Dr. Ina Kelly, MB BCh, MPH, FFPHMI Medical Council Registration Number: 011181 Specialist in Public Health Medicine cc: Prof. Elizabeth Keane, Director of Public Health, HSE South (Cork and

Kerry) Dr. Mary O’Mahony, Consultant in Public Health Medicine, HSE South (Cork and Kerry) Dr. Kevin Kelleher, Assistant National Director, Health & Wellbeing – Public Health and Child Health, Health Service Executive and EPA Health Advisory Committee Dr. John Cuddihy, Consultant in Public Health Medicine, EPA Advisory Committee Mr. Peter Cunningham, Office of Environmental Enforcement, EPA Ms. Maria Lenihan, Office of Environmental Enforcement, EPA

Complaint log for Brandon Products

OEE RE Cork Page 1 of 11 04/09/2013 17:32

# DATE &

TIME

Complaint Name Details of complaint Name of person

who dealt with the

complaint

1 18/05/11 Section 63 complaint from 18 residents

Odours for a number of years. PAE 2011/75 (Section 63 complaint from 18 residents) See Note 1.

Kieran Fahey

2 10/08/11 Bad odour, described as a dead animal smell

Kieran Fahey

3 22/06/12 Bad odour from the facility and seeking an update on the licence application for Brandon Products Ltd.

Pamela MacDonnell

4 28/08/12 Telephone call to Maria Lenihan regarding odour.

Maria Lenihan

5 06/09/12 12:25pm

Text message on Maria Lenihan’s phone stating that ‘south westerly wind brings the most intense noxious intense stomach wrenching smell to us here’.

Maria Lenihan

6 23/11/12 08:45am

Voice mail on Maria Lenihan’s phone to say that the smell is very bad at 08:45am.

Maria Lenihan

7 23/11/12

12:00am

Telephone call to Maria Lenihan at 10:00am to say that the smell was very 8bad between 08:45am and 11:15am but has eased now.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

8 23/11/12

11:15am

Telephone call to Maria Lenihan at 11:15am to say that the smell was still there and was worse than ever. Described the smell like rotten fish and that the complainants wife had to leave the house for the day.

Maria Lenihan

9 27/11/12

12:03pm

Telephone call to Maria Lenihan to say that the smell was very bad at ---------------------.

Maria Lenihan

10 06/12/12 12:38pm

Telephone call to Maria Lenihan at 12:38am to say that the smell was very bad with the last week and the smell was very bad with the last half an hour.

Maria Lenihan

11 09/01/13 18:10pm

Message on phone at 18:10, rang complainant back at 18:30. Complainant stated that odour from the facility desperate today and also last week.

Maria Lenihan

12 28/01/13 10:52am

Message on Maria Lenihan’s phone at 10:52, rang complainant back at 11:45. The complainant stated that odour from the facility desperate @10:00am this morning, still bad during the phone call.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

13 31/01/13 12:28pm

Message on Maria Lenihan’s phone from complainant at 12:28, rang complainant back at 12:50. Complainant stated that very bad odour noted from the facility @11:00am and 12:00am this morning. Complainant also stated that they are putting up with this smell for 4 years and want to know when the licence would be finalised.

Maria Lenihan

14 20/03/13 08:40am

Text message on Maria Lenihan’s phone from complainant at 08:40am stating that ‘We have odour very bad at the moment ---------------------

Maria Lenihan

15 16/04/13 10:20am

Telephone call to Maria Lenihan at 10:20am to say that the smell is very bad at ---------------------. Complainant left the yard at 10:15am as the smell was so bad that the complainant got a pain in the head. Complainant’s wife got a very bad smell at their house around the same time last Friday (12/04/13).

Maria Lenihan

16 18/04/13 08:40am

Text message on Maria Lenihan’s phone at 08:40am stating that the smell was very bad at the moment.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

17 18/04/13 11:25am

Telephone call to Martin O’Reilly from a complainant at 11:25am; the complainant has been back home for the last half hour and says the smell is very bad again.

Marin O’Reilly

18 19/04/13 10:15am

Telephone call to Maria Lenihan from complainant at 10:15am today to say that the smell is awful today and has been all week. They are putting up with the smell for four and a half years and can’t understand why nothing is being done. The complainant referred to the fact that John Doheny was out before Christmas and verified the odour and that the complainant had people calling today who would be getting the smell.

Maria Lenihan

19 19/04/13 11:00am

Telephone call to Maria Lenihan from complainant @11:00am. The complainant is very upset and spoken about the impact on their health both physically and mentally from this on-going odour issue.

Maria Lenihan

20 23/04/13 10:13am

Missed call from a complainant on Maria Lenihan’s phone on 23/04/13 at 10:13am

N/A



# DATE &

TIME


who dealt with the

complaint

21 23/04/13 11:57am

Missed call from a complainant on Maria Lenihan’s phone on 23/04/13 at 11:57am. Peter Cunningham rang the complainant regarding the odour complaint received.

Peter Cunningham

22 23/04/13 @12:00

Sean O’Donoghue received a call from a complainant regarding odour from the facility. Peter Cunningham rang the complainant back regarding the odour complaint received.

Peter Cunningham

23 14/05/13

14:55pm

ML and PC rang a complainant on the 14/05/13 at 14:55. The complainant stated that the smell was terrible on the 13/05/13 at 17:00 and on the 02/05/13 the smell was as bad as the complainant had ever witnessed.

Maria Lenihan & Peter Cunningham

24 16/05/13

10:34am

Complainant rang Maria Lenihan at 10:34. The smell was present this morning.

Maria Lenihan

25 22/05/13

15:11

Phone call from --------------------- at 15:11 to say he got an odour at a level of between 2 and 3 on the road between --------------------- and --------------------- at 13:00 today

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

26 27/05/13 11:03am

Phone call from --------------------- this morning to say that between 10:30am and 11:00am he noted a bad smell on --------------------- at a level of between 2-3. The wind is westerly at the moment and it is a high wind. He stated that the problem at Brandon Products was far from sorted. I asked him to log it as a submission on the website

Maria Lenihan

27 27/05/13 ML received a call from --------------------- to say that the smell was as bad as ever at ---------------------. He was there between 10:00am and 10:10am and whatever they are doing to address the matter must not be working. ML asked him to log it as a submission on the website.

Maria Lenihan

28 11/06/13 11:00am

ML received a call from --------------------- to say that the smell is back again and that the wind direction was not towards his house with the last few weeks.

Maria Lenihan

29 18/06/13 ML received a call from --------------------- to say that the smell was unbearable at her house and that --------------------- had got a smell at 12:00pm the night before.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

30 19/06/13 10:26

Test message from --------------------- to say that ‘smell as bad as ever’.

Maria Lenihan

31 20/06/13 12:36

ML received a call from --------------------- to say that the smell was very bad around 12:00 at this house.

Maria Lenihan

32 20/06/13 ML received a call from --------------------- to say that the smell is very bad at his house at the moment and that he had got a smell at 21:30 on Monday night (18/06/13) even though the wind was northwesterly in direction

Maria Lenihan

33 25/06/13 17:58

ML received a call from --------------------- to say that the smell was very bad at the moment and had to bring --------------------- in from ---------------------. The smell was persistent and while he had detected the smell at 17:00 in --------------------- it was not too bad but that now it is terrible.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

34 03/07/13 11:00am

ML received a voice message from --------------------- to say that the smell was just lethal at 11:00am at --------------------- and had travelled ---------------------. ML rang him back at 13:20 and he confirmed that the smell was persistent and had lasted at least half an hour. He also confirmed that the smell he got at 21:30 on the 18/06/13 was from the Brandon Products facility and that he told --------------------- that it was from the Brandon Products facility

Maria Lenihan

35 12/07/1312:00am

ML received a call from --------------------- at 12:00 to say that the smell was intermittent and at a level of 2 at 11:30am and 12:00am.

Maria Lenihan

36 16/07/1310:08am

ML received a call from --------------------- at 10:08am to say that the smell was persistent and at a level of between 2 3 at 10:00am.

Maria Lenihan

37 18/07/13

12:19

ML rang --------------------- at 12:19 and he informed her that the smell was very bad in the farmyard yesterday between 10:00am and 10:30am. He described it as an intensity of 3.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

38 25/07/13 14:06

Persistent odours at an intensity of 2+ on --------------------- at 13:49 on the 25/07/13 but while speaking to him at 14:06 the odour was no longer in ---------------------. He informed the Agency that the wind direction in the area is very changeable today.

Maria Lenihan

39 29/07/13 Intermittent odours at --------------------- of an intensity of 2 at 16:22 on 29/07/13

Maria Lenihan

40 31/07/13 Intermittent odours 3+ on --------------------- property at 14:00 on 31/07/13 describes the smell like distemper

Maria Lenihan

41 01/08/13 Odour at Kilcolman Intensity 3 / 4

Submission No 11 to Licence App File P0957-01, 28/08/13

42 02/08/13 Odour at Kilcolman Intensity 3 / 4


43 09/08/13

14:30

Odour present at a level of 2 when in --------------------- yard at 12:00 on 09/08/13

Maria Lenihan

44 09/08/13 Odour at Kilcolman Intensity 2/4


45 09/08/13

14:35

Intermittent odours all day from @08:30am on the 02/08/13 at a level of between 3 and 4.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

46 14/08/2013 13:35

Smell bad at level 4 at the yard, not bearable.

Martin O’Reilly

47 19/08/2013 14:25

Smell detected again at level 2.

Martin O’Reilly

48 19/08/13 Odour at Kilcolman “Awful”, Intensity 3 / 4


49 26/08/13 Awful Odour at ---------------------, Kilcolman Intensity 4/4


50 09/08/13 Odour at Kilcolman Intensity 3/4 all day today


51 08/10/13

09:36

ML received a text from --------------------- stating that the odour was present at his house at level 2.

Maria Lenihan

52 08/10/13

--------------------- rang ML at 09:55am today to say that the smell is up the road, it is persistent and that it is worse

Maria Lenihan

53 08/10/13 --------------------- rang ML at 10:16am today to say that the smell was the worst he had ever experienced at his house, that they had the smell the previous Friday (04/10/13) and that ---------------------.

Maria Lenihan



# DATE &

TIME


who dealt with the

complaint

54 08/10/13 --------------------- rang ML at 11:43am today to say that the smell was very bad at her house and on the road

Maria Lenihan

55 30/10/13 --------------------- rang ML at 13:21 to say that the smell was quite bad at her house at the time.

Maria Lenihan

56 07/11/13 Text from --------------------- to say that the ‘smell was now at my house’

Maria Lenihan

57 15/11/13 During an odour assessment at --------------------- informed the Agency that he got a moderate smell varying between 1 and 2 an hour earlier in ---------------------

Maria Lenihan

Note 1: While this issue was being dealt with under a Section 63 Investigation the Agency asked the complainants to keep odour logs and to always in the first instance report nuisance smells to the LA. Therefore, the Agency did not get details of all complaints during the period June 2011 to January 2012.

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