IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
SECTION A: NON-TECHNICAL SUMMARY
1.0 INTRODUCTION
Dunbia (Slane) is part of the Dunbia Group which is a family owned business by two brothers Jim and Jack Dobson. Dunbia (Slane) is a producer and processor of beef products. This site takes in live cattle and produces sides and quarters for further processing at other Dunbia Group sites or direct sale.
Dunbia (Slane) is located in a rural location off the N2, approximately 4.5km south of the village of Slane, Co. Meath. The site of the abattoir was originally a farmyard where on-farm slaughter of cattle was undertaken. The facility at Slane was acquired by the Dunbia Group (then Dungannon Meats) in 2001 and initially traded as Newgrange Meats before rebranding in 2006 as Dunbia.
Prior to planning approval (Ref: LB/140803), the average daily processing figure for Dunbia (Slane) was approximately 200 cattle. The facility employs 77 full time equivalents, not including third party and seasonal contractors.
Typical operating hours are as follows: Slaughter Process 7.00am - 19.30pm Lairage Area & Yard Area Potentially 24hours
The days of operation for the site are Monday to Friday with an occasional Saturday during peak times of year.
On the 05th March 2010, Dunbia (Slane) received their Integrated Pollution Prevention and For inspection purposes only. Control Licence (IPPC), RegisterConsent Number: of copyright P0811 owner required-01. for Thisany other was use. undertaken in order to meet the requirements of the IPPC directive (96/61/EC) which was transposed into Irish Law in 2003 with the enactment of the Protection of the Environment Act (PoE) 2003.
This licence was amended, titled “Technical Amendment A”, on the 14th January 2013 under Section 96(1)(c) of the Environmental Protection Agency Acts, as amended.
The sites IPPC Licence was technically amended to an Industrial Emissions Licence based upon the provisions of the Industrial Emissions Directive (2010/75/EC) on the 18th December 2013.
Dunbia (Slane) is licenced to carry out the following activity, as per the First Schedule of the EPA Act 1992, as amended:
7.4.1 The operation of slaughterhouses with a carcass production capacity greater than 50 tonnes per day.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
1.1 SITE DESCRIPTION
The existing processing plant comprises several buildings and structures and associated hard- standing areas, office and welfare facilities, car parking areas as well as two lined wastewater storage lagoons to the rear (north) of the plant. The lagoons are used for the storage of wastewater from the meat processing plant pending transfer off site for treatment at municipal wastewater treatment plants.
The application site covers an area of 11.5ha. The existing buildings and structures have a total plan footprint of 2,374 M2 (0.24ha) while the lined wastewater storage lagoons and associated access road cover an area of 7,200 M2 (0.72ha). The external paved surfaces around the plant cover an area of approximately 4,240 M2 (0.42ha) while the car parking area to the north-east of the plant covers an area of approx. 1,300 M2 (or 0.13ha). The layout of the existing facility is shown in Attachment B.2 of this application.
The agricultural field to the north-east of the existing plant is set as grassland. The field boundary is delineated by hedgerows on three sides and by a post and wire fence along its southern boundary. There are three groundwater supply wells located in this field and together they provide a secure, high quality water supply to the plant.
At the present time, staff and visitor parking is located in front of the existing temporary site offices and on an area of unpaved hardstanding in front (south) of the existing farmhouse.
For inspection purposes only. Consent of copyright owner required for any other use.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
1.2 PROCESS DESCRIPTION
i. Delivery of cattle, typically in articulated HGVs between 07:00 and 17:00 hours. Some additional deliveries are also made between 17:00 and 02:00 hours for operational, welfare or veterinary reasons. ii. Collection of animal „Passports‟ prior to unloading. iii. Intake and holding of cattle in lairage pens. iv. Slaughtering. v. Bleeding. vi. Removal of the horn, hoof, hide and head. vii. Trimming and evisceration. viii. Carcass splitting. ix. Chilling. x. Green offal washing in a proposed new unit to be constructed at the plant. xi. Dispatch.
2.0 LICENCE REVIEW
Dunbia is planning to intensify operations, increasing kill number to 350 animals per day by speeding up the kill line speed. Dunbia are also planning to make other ancillary changes which are consequent to the recent planning approval or intended to improve efficiencies at the site.
Dunbia (Slane) made an application to Meath County Council on 10th September 2014 [LB/140803 as per Appendix B.6(d)] requesting the following: For inspection purposes only. Consent of copyright owner required for any other use. (i). Intensification of livestock slaughtering activities to 350 animals per day, (ii). Demolition and removal of existing offices as required under Condition no 3 of planning permission SA/140210, (iii). Construction of 2l0 m2 of new offices, staff welfare and storage facilities at the location of the demountable structure referred to in (ii) above, (iv). Change of use of an existing farmhouse from residential use to office use (153 m2) (outside current IE licence boundary), (v). Construction of 112 m2 of additional lairage facilities, (vi). Construction of a 18 m2 green offal processing room abutting the main factory building, (vii). Construction of an external gantry to support a stomach press (20 m2), (viii). Construction of a 4 m2 pump house (outside current IE licence boundary), (ix). Addition of 5 no. new ancillary car parking spaces (outside current IE licence boundary).
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
Due to the request to intensify livestock slaughtering activities to 350 animals per day, an Environmental Impact Statement (EIS) [Appendix B.6(b)] was also required to be submitted with the planning application.
On 22nd January 2015 Meath County Council granted approval (Ref: LB/140803) for the above works. This approval was appealed to An Bord Pleanála and upon review approval was granted by An Bord Pleanála on 22nd June 2015.
Due to the requirement for the completion of an EIS as part of the planning application, consultation with the EPA confirmed that a review of the sites IED licence would be required upon planning approval.
Construction of 112 m2 additional lairage as outlined in LB/140803 will be outside of the current installation site boundary as defined by Condition 1.3 of licence P0811-01, therefore, a change to the existing IE licence site boundary would be required.
The change to the site boundary would include lands adjacent to the existing facility and within the ownership of Dunbia (Slane) comprising the grassland field containing 3 no. groundwater supply boreholes, farmhouse and ancillary carpark (c. 4.5 hectares). The new licence boundary would contain a total area of approximately 11.5 hectares, including; the main production facility, offices and external yard (c. 1 hectare), HDPE Lagoon area and decommissioned ICW area (c. 5 hectares), access road with security hut and weighbridge.
There will be no change to the listed activities, as there is no intention to add additional production activities at this time.
There will be provision of storm water attenuation from the HDPE lagoon area and the For inspection purposes only. farmhouse and carpark, with rainwaterConsent of copyright harvesting owner required for facility any other use. to complement existing water supplies.
An existing farmhouse will be refurbished to an office building, including addition of 5 no. car-parking spaces and use of existing septic tank.
There will be no additional emission points arising at Dunbia (Slane) due to intensification of slaughter process.
Any increased emissions as a result of this intensification, such as waste and effluent, will be captured in the relevant sections of this application.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
3.0 BAT AND BREF GUIDANCE DOCUMENTS
Relevant BAT guidance document: BAT Guidance Note on Best Available Techniques for the Animal Slaughtering Sector
Relevant BREF document: BREF for the Slaughterhouses and Animal By-Products Industries (05.05) BREF for Energy Efficiency (02.09) BREF on Emissions from Storage (07.06)
The BAT guidance notes on the Best Available Techniques for the slaughtering sector (EPA Final draft October 2006) were reviewed to ensure that the appropriate preventative measures are taken against pollution. Water and energy consumption are monitored to ensure efficiency.
Attachment I.8 Details the site‟s compliance with relevant BAT and BAT Conclusions documents. BAT compliance is also detailed in relevant attachments of this application.
4.0 MANAGEMENT
Dunbia (Slane) operates an Environmental Management System in accordance with Condition 2 of the site‟s IED Licence. Operational Procedures for start-up and shutdown of the site are in place. The site has an emergency response procedure for leaks, spillages and malfunctions.
The site has a Closure, Restoration and Aftercare Management Plan in place. This is detailed For inspection purposes only. in attachment K of this application.Consent of copyright owner required for any other use.
The site will assess the feasibility of achieving external certification of its EMS upon review of its IED Licence.
5.0 DETERMINATION OF EMISSIONS LEVELS
Emission levels stated in this application have been determined by sampling and analysis using accepted best practice methods by competent persons.
5.1 ACCIDENTS AND THEIR ENVIRONMENTAL CONSEQUENCES
Dangerous substances are not present on site in quantities that exceed thresholds specified in Schedule 1 to the EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations 2006. Attachment J of this application details the Accident Prevention & Emergency Response Procedure.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
6.0 EMISSIONS AND THEIR CONTROL
The site carries out monitoring as required by Schedules B & C of its IED Licence and will continue to do so after review of the Licence. Measurement results are submitted to the EPA via ALDER and included in the AER.
6.1 EMISSIONS TO AIR
6.1.1 Point Source
There are two main sources of emissions to air, the Boiler plant and Generator plant. There are currently three abatement technologies used for the reduction of point source emissions to air:
(i). Boiler fuel changed from oil to LPG in 2014. (ii). Preventative Maintenance programme for the Generator and Boiler to ensure expected efficiencies are met and that the emissions to air are minimized. (iii). The use of an appropriate stack height for the boiler.
Air emissions levels stated within the application form are determined through use of a Portable Flue Gas Monitor and combustion analysis.
6.1.2 Fugitive Emissions
Attachment B.6(b) EIS, Chapter 7, Section 7.128 details the dust mitigation measures For inspection purposes only. implemented at the site. Consent of copyright owner required for any other use.
Attachment B.6(b) EIS, Chapter 7, Section 7.133 details the odour mitigation measures implemented at the site.
Refrigeration gas and Maintenance Aerosols are used on the installation.
The pipe work is regularly checked within the preventative maintenance system and any required repairs documented and completed in a timely manner. Maintenance Aerosols are used and are applied direct to plant and machinery where air emissions are released; these are kept to a minimum and used when required.
LPG is used for the main combustion equipment within the installation thus reducing potential emissions.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
6.2 EMISSIONS TO WATER
The only release to surface water from the site is roof and yard run-off (storm-water). Runoff from the clean and dirty areas of the site is separated to reduce any suspended solids and hydrocarbons in runoff from the site. Runoff from the dirty areas is directed to the process effluent collection system.
Surface water runoff and storm water runoff from the site is managed and controlled by an existing IED Licence (Ref. No P0811-01). Surface water is collected in existing drains and treated via a silt trap and hydrocarbon interceptor prior to its discharge off-site.
Surface water discharge analysis results stated within the application form are determined through grab sampling and analysis.
As a result of an incident on 4th March 2016 (EPA Ref No: INCI009773), Dunbia (Slane) were requested by the Office of Environmental Enforcement (OEE) of the EPA, to carry out an impact assessment on the local surface water; “Incident Impact Assessment Report”, Report Ref IAR_16_8488, dated 01st April 2016.
The assessment considered the potential impacts from the incident upon the following sensitive receptors; Existing ecological and physicochemical quality of the catchment, Existing groundwater quality, Visual amenity of the area, Staleen Water Treatment Plant abstraction from the River Boyne.
It was concluded that there was no significant impact upon the existing groundwater, visual For inspection purposes only. amenity or use of the catchmentConsent upon of copyrightthe Staleen owner required Water for any Treatment other use. Plant. Evidence of acute impacts upon the ecological quality in sections of the Painestown Stream was identified, with no indications of on-going effects.
Recommendations regarding onsite infrastructure and management were made as part of the report, which were implemented as a matter of priority at the Dunbia (Slane) facility.
Ground-water analysis results in this application form have been determined through grab sampling and analysis.
Process and foul effluent is collected and stored in lined lagoons and undergoes primary treatment (screening) and secondary Dissolved Air Floatation (DAF) solids removal. There is no discharge to surface or ground water from the wastewater storage lagoons.
Water from the lagoons is tankered off site for disposal at a licensed wastewater treatment plant (monitoring location SE-2 of this application). Wastewater is sampled once per week by grab sample from a tanker.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
In the current IE licence for Dunbia (Slane), SW1 is designated as the discharge point from an Integrated Constructed Wetland System. As the ICW system ponds were decommissioned in 2015, the discharge point and monitoring location SW1 is no longer applicable.
It is intended to retain the existing emission point SW3 (Emission from Proposed WWTP to ICW), renamed as SW3 (Emission from Proposed WWTP), in order to provide for a potential future discharge to surface water from the site, following provision of further waste water treatment infrastructure.
There will be an increase in groundwater supply required for the increase in animal slaughtering and processing at the plant. This increased supply will be met from the three No. existing groundwater supply wells and by rainwater harvesting measures which are to be implemented at the site.
The harvesting of rainwater will reduce the required groundwater supply and water treatment requirements. These two sources of water supply (groundwater and rainwater) will complement each other and will be used as and when conditions permit.
The hydrogeological investigation undertaken in February 2014 for the third supply well indicates that the zone of contribution around the well is limited and therefore the groundwater drawdown in the well will not impact on groundwater flow or other groundwater supplies in the immediate area.
The installation has a number of storage vessels and tanks with substances varying from Fuels, Blood, Effluent, Chemicals (Cleaning and Maintenance). These are all bunded or stored on hardstanding and linked to a foul drainage system to ensure that fugitive emissions are mitigated as best possible. The wastewater lagoons are designed to EPA standard with For inspection purposes only. Geo-synthetic Clay Liner (GCL)Consent and ofa copyrightHDPE owner liner required to forensure any other structural use. integrity.
The sections of the application site where potentially contaminating activities occur, such as vehicle movements, loading / unloading, lairage etc. are paved with an impermeable surface which inhibits infiltration to groundwater.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
6.3 NOISE AND VIBRATION
The potential impact from noise emissions from the intensification of the operation phase are the increased volume of traffic generated by the site and the increased volume and frequency unloading / holding of cattle in the lairage.
Noise generated by the lairage area at the closest noise sensitive location is predicted to be more than 10dB below the existing ambient noise levels measured during both the day and night-time periods. Therefore it would have no impact on ambient noise levels. The predicted level is more than 10dB below the night-time noise limit detailed in the IED Licence so would not increase any site related noise above the existing limit.
The heavy goods vehicle traffic generated by the proposed intensification of slaughter activities would, in the worst case, have a minor, barely perceptible, impact on the existing ambient noise levels at the closest noise-sensitive receptors.
Attachment B.6(b) EIS, Chapter 8, Section 8.74 details the noise mitigation measures implemented at the site.
Noise emission levels have been determined through noise impact assessment surveying and a predictive noise impact assessment.
7.0 MATERIALS, SUBSTANCES, PREPARATIONS, FUELS AND ENERGY For inspection purposes only. PRODUCED OR UTILISEDConsent of copyrightIN ACTIVITY owner required for any other use.
Inputs: (i) Livestock – proposed capacity of 350 head per day. (ii) Water – proposed increase from 120 M3/day to 175 M3 /day. (iii) Electricity for production and office areas (iv) LPG for heating and forklifts (v) Diesel for vehicles (vi) Small amounts of chemicals/disinfectant
Outputs: (i) Sides - proposed capacity of 350 head per day. (ii) Wastewater, to increase to 175 M3/day. (iii) Sludge from within lagoons (iv) Blood – to increase by approximately 75% (v) Waste and animal by-product waste increase is detailed in attachment H.2
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
8.0 ENVIRONMENTAL CONDITION OF THE INSTALLATION
There are three soil types at the site. These are Rendzinas / Lithosols in the north and north- west, Regosols / Lithosols in the north-east and Grey Brown Podzolics / Brown Earths to the south west, south and south-east. Much of the site is underlain by bedrock at or close to the surface with glacial till composed primarily of Carboniferous Limestone material occurring in the south-eastern corner of the site.
The application site is underlain by the Trim groundwater body, while the Donore groundwater body is located to the east of the large regional NNW – SSE trending fault that crosses the eastern corner of the site. On-going groundwater monitoring both up and downstream of the site indicates influence from agricultural sources.
The application site at Painestown is located within the catchment of the River Boyne and the sub-catchment of the Roughgrange River. All surface water run-off from building roofs and paved „clean‟ yard areas around the plant is collected by a stormwater drainage system which falls to a low point beyond the south-western corner of the plant, at which point it is passed through an existing settling tank and hydrocarbon interceptor before being discharged off-site to the Painestown Stream which is a tributary of the Roughgrange River. 2015 Surface-water monitoring showed no exceedances of site IED ELVs.
The application site and surrounding area fall into Air Quality Zone D categorised as rural locations throughout Ireland. The site conducts annual environmental noise monitoring. The site is compliant with limits set in the IED Licence regarding noise.
9.0 EXISTING AND PROPOSED EMISSIONS FROM THE INSTALLATION For inspection purposes only. Consent of copyright owner required for any other use. There are no current or proposed emissions to soil from the site. All operational areas are paved. Spreading of lagoon sludge is carried out in accordance with SI 31 of 2014. NMPs are completed by each farmer and submitted to EPA for approval prior to use.
There are no emissions to groundwater. Groundwater monitoring takes place biannually at the site as per IED Licence requirement Condition C.6. The proposed intensification will not result in emissions to groundwater.
Clean surface water from the site is discharged to the Painestown Stream. Off-site discharges are monitored and controlled in accordance with the existing IED licence issued by the EPA. The new drainage infrastructure to be installed consequent to the granting of planning permission provides for additional treatment and attenuation of surface water from paved areas and will reduce development related impacts on surrounding watercourses and the local drainage network.
The site is not a significant source of air emissions. Mitigation measures for odour and dust are in place, as detailed in the attached EIS. It is not anticipated that the intensification will significantly alter the noise emissions from the site. Noise mitigation measures are in place, as detailed in the attached EIS.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
10.0 ALTERNATIVES
The site is already in existence and production methods, techniques and technologies are to industry standard. No change to the existing licenced activities is proposed as part of this application.
For inspection purposes only. Consent of copyright owner required for any other use.
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IED Licence Review Application May 2016
Dunbia (Slane), Greenhills, ATTACHMENT A Beauparc, Navan, Co Meath
11.0 SUMMARY OF THE LIKELY SIGNIFICANT EFFECTS OF THE ACTIVITY
Environmental Likely effects identified Brief description of effect Mitigation measures Factor proposed to control effect
Potential nuisance impact Attachment B.6(b) EIS, Noise to nearest sensitive Chapter 8, Section 8.74 locations Potential nuisance impact Attachment B.6(b) EIS, Human Beings Dust to nearest sensitive Chapter 7, Section 7.128 locations Potential nuisance impact Attachment B.6(b) EIS, Odour to nearest sensitive Chapter 7, Section 7.133 locations
Flora and fauna N/A N/A N/A
Contamination with spilled fuel, engineering oil, Attachment B.6(b) EIS, Soil Contamination cleaning chemicals or Chapter 5, Section 5.64 process / foul wastewater Soil NMPs completed for each Contamination from farmer. Soil Contamination spreading of sludge from Sludge spread in lagoons on agricultural land accordance with SI 31 of 2014 Contamination with spilled Attachment B.6(b) EIS, Surface water fuel, engineering oil, Chapter 6, Section 6.145 – Contamination cleaning chemicals or 6.154 process / foul wastewater NMPs completed for each Contamination from farmer. Surface water Water spreading of sludge from Sludge spread in Contamination lagoons on agricultural land accordance with SI 31 of For inspection purposes only. 2014 Consent of copyrightContamination owner required for any with other use.spilled Attachment B.6(b) EIS, Groundwater fuel, engineering oil, Chapter 6, Section 6.155 – Contamination cleaning chemicals or 6.157 process / foul wastewater Attachment B.6(b) EIS, Depletion of groundwater Groundwater Volumes Chapter 6, Section 6.158 – resource 6.160
Air See Human Beings N/A N/A
Climate N/A N/A N/A
Attachment B.6(b) EIS, Impact to visual Landscape Visual impact Chapter 9, Section 9.85 – amenity of area 9.86
Minor increase in traffic Attachment B.6(b) EIS, Material Assets Road infrastructure volume on local roads Chapter 12, Section 12.153
Potential impact on Attachment B.6(b) EIS, Cultural Heritage Archaeological Impact unrecorded archaeological Chapter 10, Section 10.56 features or finds
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