The Mews, 23 Farnham Street, Cavan, CLW Envirotunental Planners Ltd. Co. Cavan Phone: 049-437144 7/9 Fax: 049-4371451 E-mail: [email protected] Ms Eve O'Sullivan Office of Licensing, Climate and Resourse Use, Environmental Protection Agency, P.O. Box 3000, Johnstown Castle Estate, Co. Wexford 1 10 h July 2014 Re: Mr. John McCabe Licence Application Reg. No. P0956-0l Dear Eve, I refer to previous Agency correspondence of 1ih February last. Further to a review of Regulation 9 of the EPA (Industrial Emissions)(Licensing) Regulations 2013 a number of areas were identified that may require additional information. Please find the response to these issues outlined below which should ensure that the application now address all requirements; 1. Please refer to attached table regarding BAT recommendations. 2. The existing/proposed activity does For inspection not involve purposes only. the use, production and/or release of a hazardous Consent of copyright owner required for any other use. substance. 3. Please find enclosed copies of revised public, site and Local Authority Notice. 4. Revised Activity Class description- Activity Class (i.l (a) 'The r;earing of po¥Jtry in instaijations where the capacity exceeds 40,000 places.". Please also find enclosed a revised non-technical summary. If you require any additional information please contact this office. Directors: S. Clarke, 0. Leddy B.Agr.Sc., P. Fay B.Agr.Sc. V.A.T. Re!!. No. 8277204J EPA Export 01-08-2014:23:43:30 The Mews, 23 Farnham Street, Cavan, CLW Envirotunental Planners Ltd. Co . Cavan Phone: 049-437144 7/9 Fax: 049-4371451 [email protected] CONCLUSIONS ON BAT in respect of EXISTING POULTRY FARM located at Brandrum, Monaghan, Co. Monaghan. Prepared on behalf of the Applicant John McCabe For inspection purposes only. Consent of copyright owner required for any other use. by CLW Environmental Planners Ltd. The Mews, 23 Farnham Street, Cavan, Co. Cavan Mobile : 087-6794459 Phone:049-4371447/9 Fax: 049-4371451 E-mail: [email protected] sth July 2014 Directors: S. Clarke, 0. Leddy B.Agr.Sc., P. Fay B.Agr.Sc. V.A.T. Ree:. No. 8277204J EPA Export 01-08-2014:23:43:30 Licence Application -John McCabe BAT Conclusions Review Conclusions on BAT Integrated Pollution Prevention and Control (/PPCl Reference Document on Best Available Techniques for Intensive Rearina of Poultr'i. and Pi as - Jul't. 2003 BAT Reference No. BAT Statement A12,12,licable Pro12,osal 5.1 Good agricultural 12,ractice in the intensive rearing of pigs and Yes Already lm12,lemented poultry 1) Training register to be maintained on-site. 1)identify and implement education and training programmes 2) Water, energy, feed and waste records already for farm staff maintained, organic fertiliser moved off-site by 2)keep records of water and energy usage, amounts of livesto< k contractor. feed, waste arising and field applications of inorganic fertiliser 3) Emergency response and Corrective Action and manure procedures to be put in place. 3) have an emergency procedure to deal with unplanned 4) Repair and Maintenance programme continuously emissions and incidents Carried out. Houses are well maintained, thus 4) implement a repair and maintenance programme to ensure requiring minimal repairs. that structures and equipment are in good working order and 5) All activities planned so as to minimize traffic and any that facilities are kept clean Potential disruption. 5) plan activities at the site properly, such as the delivery of 6) Organic fertilsier moved off-site by contractor and used For inspection purposes only. materials and the removal of products and waste,Consent and of copyright owner required for any other use.In compost production or by farmers as an organic fertilizer 6) plan the application of manure to land properly. In accordance with 51 31 of 2014 5.3.1 Nutritional Techniques Yes Already lm12,lemented BAT is to apply feeding measures A number of diets (c.4) used throughout cycle to match bird requirements. Nand P excretion minimized by using high quality ingredients, low protein formulations and phytase enzyme. 5.3.2 Air Emissions from Poultry Housing Yes Already lm12,lemented BAT is the well-insulated fan ventilated house with a fully littered floor and equipped with nonleaking drinking systems (YEA-system) C.L. W. Environmental Planners Ltd. Page No.1 EPA Export 01-08-2014:23:43:30 Licence Application-John McCabe BAT Conclusions Review 5.3.3 Water Yes Already Implemented BAT is to reduce water usage by doing all of the following; l)cleaning animal housing and equipment with high-pressure 1) Houses cleaned down with high pressure washers after cleaners at the end of each batch of livestock. It is important each batch. to find a balance between cleanliness and using as little water 2) Drinkers provided with drip cups to catch any leakage . as 3) Records of water use maintained on a daily basis. possible 4) Houses checked daily for any signs of leakage. 2) regularly calibrating the drinking-water installation to avoid spill 3) keeping record of water use through metering of consumption, and 4) detecting and repairing leakages. 5.3.4 Energy Yes Already Implemented BAT is to reduce energy usage by doing all ofthe following; 1) Houses well constructed and maintained with high 1) insulating buildings in regions with low ambient insulation standards. temperatures (U-value 0.4 W/m2/"C or better) 2&3) The ventilation is fitted with high output efficient 2) optimising the design of the ventilation system in each fans. house to provide good temperature control and to achieve All ducts and fans to be regularly cleaned. minimum ventilation rates in winter 4) The houses are fitted with energy efficient lights. 3) avoiding resistance in ventilation systems through frequent inspection and cleaning of ducts and fans, and 4) applying low energy lighting. 5.3.5 Storage For inspection purposesNo only. No Manure Storage On-site Consent of copyright owner required for any other use. BAT is to design storage facilities for poultry manure with sufficient capacity until further treatment or application to land can be carried out. The required capacity depends on the climate and the periods in which application to land is not possible. (As per S.l. 31 ot20141 this period is deemed to be 26 weeks.} If manure needs to be stored, BAT is to store dried poultry manure in a barn with an impermeable floor and with sufficient ventilation. --- C.L W. Environmental Planners Ltd. Page No.2 EPA Export 01-08-2014:23:43:30 Licence Aoolication -John McCabe BAT Conclusions Review 5.3.6 On-farm manure processing No Not proposed on-site. In general, on-farm processing of manure is BAT only under certain conditions (conditional BAT). The conditions in on- farm manure processing that determine if a technique is BAT are related with conditions such as the availability of land, local nutrient excess or demand, marketing possibilities 5.3.7 Techniques tor landspreadinq poultrY, manure No Note: Spreading of poultry manure not carried out by/or on behalf of Licensee. All manure allocated to customer farmers for use in accordance with Sl 31 of 2014 and/or for compost production. - - -- For inspection purposes only. Consent of copyright owner required for any other use. C.L. W. Environmental Planners Ltd. Page No.3 EPA Export 01-08-2014:23:43:30 Licence Application -John McCabe BAT Conclusions Review Integrated Pollution Prevention and Control Reterence Document on Best Available Technigues on Emissions from Storage - July_ 2006 BAT Reterence No. BAT Statement Applicable Proe_osal 5.1 Storage of Liquids Yes Already Jme_lemented BAT is for a proper design, Inspection, Maintenance etc. Dedicated soiled water tanks provided. Integrity to be I assessed every 5 years and maintenance carried out as I required. 5.2 Transfer and handling of liquids and liquefied gases Yes Integrity of soiled water network to be assessed every 5 BAT is to apply a tool to determine proactive maintenance plans years and maintenance carried out as required. and to develop risk-based inspection plans such as, the risk and reliability based maintenance approach 5.3. Storage of Solids No. No Manure Storage On-site. Enclosed Storage - BAT is to apply enclosed ·storage by using, for example, silos, bunkers, hoppers and containers. Where silos are not applicable, storage in sheds can be an alternative. This is, e.g. the case if apart from storage 5.4 Transfer and handling of solids Yes Already lme_lemented BAT is to prevent dust dispersion due to loading and unloading activities in the open air, by scheduling the transfer as much as Loading to be carried out at the end of every batch by possible when the wind speed is low. However, and taking For inspection purposes only. experienced operatives. Waiting trailers to be parked Consent of copyright owner required for any other use. into account the local situation, this type of measure cannot be close to door of poultry house to minimise transport generalised to the whole EU and to any situation irrespective of distance. the possible high costs. Where possible tailer to be covered prior to transport off- Discontinuous transport (e.g. shovel or truck) generally site. generates more dust emissions than continuous transport such as conveyors. BAT is to make transport distances as short as possible and to apply, wherever possible, continuous transport modes. For existing plants, this might be a very expensive measure. C.L. W. Environmental Planners Ltd. Page No.4 EPA Export 01-08-2014:23:43:30 Licence Application -John McCabe BAT Conclusions Review When applying a mechanical shovel, BAT is to reduce the drop height and to choose the best position during discharging into a truck While driving, vehicles might swirl up dust from solids spread on the ground.