Kepak Athleague Reg No P0168

Kepak Athleague AER 2017

Kepak Athleague

Reg No P0168 – 02

Annual Environmental Report 2017

Kepak Athleague AER 2017

Table of Contents Page Number

1.0 Company Details 4 2.0 The Environmental Policy of Kepak Athleague 5 3.0 Environmental Management 6 3.1 Environmental Management Structure 7 3.2 Environmental Progress Meetings 7 4.0 Emissions from the Installation 8 4.1 Emissions to Waters 8 4.1.1 WWTP Discharge Performance 9 4.1.2 Surface Water Parameters 10 4.1.3 Groundwat er 11 4.2 Emissions to Atmosphere 12 4.2.1 Stack Monitoring 12 4.2.2 Fugitive Emissions 12 5.0 Waste Management and Recycling 13 5.1 Off -Site Waste 13 5.2 Nutrient Management Plan 14 5.2.1 Storage of Organic Waste 14 6.0 Resource Management 15 7.0 Environmental Incidents and Non -Compliances 16 7.1 Summary of Incidents 16 8.0 Complaints Summary 16 9.0 Objectives and Targets 17 10.0 Environmental Man agement Programme Report on 201 6 28 11.0 Environ mental Management Programme 201 7 29

Tables Page Number Table 1 – Discharge 8 Table 2 – Monitoring Point AS -2 10 Table 3 – Monitoring Point AS -3 10 Table 4 – Monitoring Point AS -4 10 Table 5 – MW -1 11 Table 6 – MW -2 11 Table 7 – MW -3 11 Table 8 – Stack Monitoring Results 12 Table 9 – Waste Produced from 201 0-201 7 13 Table 10 – Contractors and Destination of Waste 13 Table 11 – Offsite Storage Facilities 14 Table 1 2 – Resource Consumption 15 Table 13 – Summary of Inci dents 16 Table 14 – Breakdown of Non -Compliances 16 Table 15 – Summary of Complaints 16 2

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Table 16 – Breakdown of Complaints 16 Table 17 – Objectives and Targets 201 6-20 20 17 Table 18 – Summary of 201 7 EMP 18 Table 19 – EMP 201 8 19

Appendix 1 - PRTR Details Appendix 2 - Air monitoring Report Summaries – full reports available on request

Kepak Athleague AER 2017

1.0 Company Details

Company Name: Kepak (Athleague) Ltd.

Reg No: P0168-02

Address: Athleague Co Roscommon

Plant Manager: Michael Geoghegan

Environmental Manager: Sharon Corcoran

Sector: Sector 7.4.2 Slaughter of Animals

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2.0 The Environmental Policy of Kepak Athleague

Kepak Athleague operates a sheep and cattle slaughter facility and a boning hall. Kepak Athleague recognises that we have a responsibility to demonstrate sound environmental awareness and believe that responsible environmental management is good business practice. The company is regulated by the Environmental Protection Agency under licence registration number P0168-02.

We wish to operate all activities through monitoring, communication and training all employees on environmental issues. Kepak Athleague is committed to continually improving environmental performance. Kepak Athleague accepts the responsibility to minimise the risk of environmental pollution. Responsible environmental management enhances the quality of our meat products and is in keeping with regulatory and customer requirements.

Kepak Athleague aim to implement the principles of the Environmental Policy by the following:

• The environmental standard of the site will be maintained at the highest level through implementation of the Environmental Management System (EMS). The EMS will detail the environmental procedures with which the company adheres to, to successfully maintain an environmental conscious business • An environmental manager is appointed and actively promotes environmental awareness among employees at all levels and contractors through appropriate communication and training programmes • The environmental awareness programme ensures all employees and contractors are aware of the potential impact inappropriate actions may have on the environment and are aware of the preventative and/or corrective actions required to minimise the impact. • We will make available to the public and customers information on our environmental performance on request. • We will comply with and co-operate with all environmental regulations as laid down by all regulatory bodies and customers. • We will aim to meet all objectives and targets as set out in the EMS and the annual Environmental Management Programme • Site response procedures are in place to prevent accidental emissions of materials or energy on the site. In addition procedures will be put in place on the event of detection of non compliance with this policy • This policy, together with the Environmental Management System will be reviewed on an annual basis and improved where required • All new activities, products and processes shall be assessed to identify possible environmental impacts • Management are dedicated to the monitoring and management of waste generation, water consumption and energy consumption, minimising usage where possible

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3.0 Environmental Management

The General Manager, has the overall responsibility for the factory and the environmental management team as a whole. The General Manager approves capital expenditure for the environmental systems on- site

Environmental matters will be dealt with by the both the Technical Manager and Environmental Manager, with the Environmental Manager responsible for the Environmental Management System as a whole.

Environmental Manager Responsibilities include the following (this list is not exhaustive):

Ensuring the Environmental Management System is maintained

Ensuring Kepak Athleague meets the specific requirements of the IPPC licence, other relevant legal requirements and customer requirements

Managing the efficient operation of the WWTP and ensuring effluent analysis is carried out as per requirement

Liaising with regulatory bodies including EPA, Inland Fisheries Ireland, County Councils

Ensuring full compliance to the conditions of the licence

Maintaining good environmental practices on site

Carrying out environmental training for on-site personnel

In the absence of the Environmental Manager, the Assistant Site Manager will take responsibility for environmental management. In the event that both the Environmental Manager and the Assistant Site Manager are both off-site the Technical Manager will take responsibility for environmental management.

It is the responsibility of the WWTP operator to operate the WWTP efficiently and within the licence limit values. The results of the effluent analysis are reviewed on a daily basis to assess the WWTP performance and to operate the WWTP as required.

It is the responsibility of the Assistant Site Manager, to ensure that the production process does not has an adverse effect on the environment and to inform the production managers of environmental issues affected by the process.

The production managers and supervisors aim to reduce water usage, energy usage, resource usage and waste during the production process.

Maintenance Manager Responsibilities include the following (this list is not exhaustive):

Energy efficiency

To maintain critical equipment affecting the WWTP

To assist the environmental manager with any maintenance issue that may have an effect on the environment

To inform the environmental manager of any equipment malfunction, on the production line or WWTP, that has an effect on the environment

To minimise the use of resources including water and LFO It is the responsibility of the hygiene room operative and night wash staff to keep water usage as minimal as possible and not to over use chemicals so as to have a negative effect on the WWTP.

Kepak Athleague AER 2017

3.1 Environmental Management Structure

General Manager

Assistant Site Manager

Environmental Maintenance Slaughter Hall Manager/ Boning Manager Manager Hall Manager

WWTP Operator

3.2 Environmental Progress Meetings

On a regular basis management on site have an environmental meeting. The purpose of this meeting is to discuss the environmental performance of the site, the quality if water emissions, air emissions, energy management, resource usage, issues relating to the application of waste to land, IPPC licence issues and customer requirements.

Actions and responsibilities are drawn up and target dates set for achieving the actions. A review of the actions is then carried forward to the next meeting. This ensures improvements are regularly monitored to ensure continuous improvements.

Meetings also take place regularly with Kepak’s consultant company, Rowan Engineering Consultants.

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4.0 Emissions from the Installation

4.1 Emissions to waters

Kepak discharges treated effluent into the River Suck, a tributary of the River Shannon. The River Suck drains large areas of Roscommon and Galway, flowing over limestone terrain and is joined by ten tributaries along its route. It rises in Lough O’Flynn, north of Castlerea, at Shannonbridge. The River Suck is part of the on going Lough Derg/Lough Ree catchments monitoring and management programme.

4.1.1 WWTP Discharge Performance

Under the IPC Licence, the following discharge limit values have been applied to treated water emissions from Kepak Athleague. All results are based on the results from the external laboratory.

Table 1 – 2016 Discharge

Licensed Discharge Limits 2017 Discharge Parameter mg/L Kg/day Kg/year Kg/day Kg/year COD 125 112.5 41,062 26.71 7094 .24 BOD 25 22.5 8,212 0.55 287 .31 Suspended Solids 35 31.5 11,497 3.76 999 .85 Total Nitrogen as N 15 13.5 4,927 5.06 1343 .88 Total Ammoni a as N 10 9.0 3,285 0.17 44.69 Total Phosphorus as P 2.0 1.8 657 0.27 71.45

Effluent was analysed on a daily basis throughout 2017 internally. Samples were sent to an external laboratory on a weekly basis for BOD and on a quarterly basis for F,O & G’s. ALT were contracted and are accredited to ISO 17025.

During 2017 Kepak Athleague discharged 238,149 cubic meters of final treated effluent to the River Suck.

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4.1.1.1 BOD Loading Discharged

The BOD loading for 2017 was 287.31kgs compared to 397.3kgs in 2016. There were no breaches to the licence, the results have been consistently good and have not breached the 85% limit.

4.1.1.2 COD Loading Discharged

The COD loading for 2017 was 7094.24kgs compared to 7866kgs in 2016. There were no breaches to the licence, the results have been consistently good and have not breached the 85% limit.

4.1.1.3 Total Phosphorus Loading Discharged

The Phosphate loading for 2017 was 71.45 compared to 73.7kgs in 2016. There were no breaches to the licence, the results have been consistently good and have not breached the 85% limit.

4.1.1.4 Total Nitrogen Loading Discharged

The Total Nitrogen loading for 2017 was 1343.88kgs compared to 1933kgs in 2016. Results on rare occasions have breached the 85% limit but there were no breaches to the licence.

4.1.1.5 Ammonia Loading Discharged

The Ammonia loading for 2017 was 44.69kgs compared to 23.66kgs in 2016. There were no breaches to the licence, the results have been consistently good and have not breached the 85% limit.

4.1.1.6 Suspended Solid Loading Discharged

The Suspended Solids loading for 2017 was 999.85 compared to 1272.1kgs in 2016. There were no breaches to the licence, the results have been consistently good and have not breached the 85% limit.

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4.1.2 Surface Water Parameters

Surface water visual assessment is carried out on a daily basis. AS-2 was sampled on a monthly basis with the exception of where the sample point was inaccessible due to flooding. AS-3 and AS- 4 were sampled on a quarterly basis as per licence requirement.

Table 2 - Monitoring Point AS-2

Total Nitrogen COD mg/l Ammonia mg/l Conductivity µs/cm mg/l Jan 29 2.9 1.068 96 Feb 26 3.2 0.804 78 Mar 30 6.1 0.888 90 Apr 27 7.6 0.696 93 May 29 7.8 0.792 92 Jun 32 9.8 1.152 1021 Jul 33 9.2 1.056 1009 Aug 30 8.8 0.828 927 Sep 32 10 1.188 395 Oct submerged submerged submerged submerged Nov 30 9.5 1.044 729 Dec 27 10.4 0.816 868

Table 3 - Monitoring Point AS-3

COD mg/l Total Nitrogen mg/l Ammonia mg/l Conductivity µs/cm

Q1 Q2 Q3 Q4

Table 4 - Monitoring Point AS-4

COD mg/l Total Nitrogen mg/l Ammonia mg/l Conductivity µs/cm

Q1 12 2.9 0.132 795 Q2 11 6.6 0.204 941 Q3 11 4.9 0.036 945 Q4 16 5.7 0.144 826

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4.1.3 Groundwater

Ground water samples were taken from MW-1, MW-2 and MW-3 on a quarterly basis throughout the year.

Table 5 - MW-1

Parameter Q1 Q2 Q3 Q4 COD mg/l 26 32 13 17 Nitrate mg/l 4.1 6.7 2.35 3.2 Ammonia mg/l 0.024 0.108 0.096 0.060

Table 6 - MW-2 Parameter Q1 Q2 Q3 Q4 COD mg/l 17 10 2 3 Nitrate mg/l 2.8 1.9 0.2 0.4 Ammonia mg/l 0.072 0.06 0.108 0.072

Table 7 - MW-3

Parameter Q1 Q2 Q3 Q4 COD mg/l 32 39 11 14 Nitrate mg/l 1.7 2.9 2.42 1.5 Ammonia mg/l 0.132 0.138 0.12 0.084

Kepak Athleague AER 2017

4.2 Emissions to Atmosphere

4.2.1 Stack Monitoring Analysis of stack emissions was carried out bi-annually by Air Scientific. Kepak Athleague operates two boilers, namely Cochran/Thermax 6800 and Yorkshireman 6000 (Boiler 2). Light fuel oil is used to operate the boilers. The results are provided in Table 8.

Table 8 – Stack Monitoring Results

Boiler 1

Parameter Round 1 Round 2 Particulates (mg/m 3) 87.81 95.35

3 NO x (mg/m ) 566 478.7 3 SO x (mg/m ) 539.65 740.85 CO (mg/m 3) 8.88 7.8 Boiler 2

Parameter Round 1 Round 2 Particulates (mg/m 3) 62.52 204.44

3 NO x (mg/m ) 605 472.2 3 SO x (mg/m ) 644 883.6 CO (mg/m 3) 11.27 10.31

4.2.2 Fugitive Emissions

There were two odour complaints in 2017.

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5.0 Waste Management and Recycling Kepak Athleague is now a zero to landfill site and very aware of the environmental benefits of recycling. Kepak Athleague has employed AES to remove mixed municipal waste for recovery and incineration. All clean cardboard, plastic and used poly rope is collected by a recognised waste recycling company. Waste paper is shredded and collected for recycling. Old and broken pallets are returned for repair and reuse, the pallets that are gone beyond repair are sent for recycling. Ink cartridges are collected and recycled. Prevention is the key to avoiding waste. The less amount of waste being produced the less amount of waste to dispose of.

5.1 Offsite Waste The total amount of waste disposed of in 2017 was Tonnes.

Table 9 - Waste Produced from 2012 – 2017

Tonnes Tonnes Tonnes Tonnes Tonnes Tonnes Waste Product 2012 2013 2014 2015 2016 2017 Offal & Bone 896 3938 8643 8635 7693 11735.56 Sludge 1,965 2027 2195 2363 2693 3625.12 Bellygrass 1,471 2022 1616 2311 2630 3268.13 Blood 1,856 1703 2115 1408 1207 1058.04 Recyclables (plastic, paper, cardboard) 30.9 28 27 32 45.47 60 SRM 9,172 5687 4177 3728 3522 4270.81 Landfill 54.82 60 69 96 0 0 Organic 1.73 2 1.7 0.83 0.585 0.12 Metal 0 0 0 0 0 6.2 Total 15,450 15,468 18847 18574 17791 24024

Table 10 - Contractors and Destination of Waste

EWC Disposal Company Approval/Licence Waste Haulier Approval/License No. Destination Code Name Number

Refuse (Non- 200302 AES W0104-02 Bord na Mona Main St. Newbridge Co Kildare NWCPO – 08-10601-05 Hazardous Waste) Wood 200139 AES W0104-02 AES Tullamore Co Offaly W0104-02 150101 Recyclables 150102 AES W0104-02 AES Tullamore Co Offaly W0104-02 150103 Organic waste 200108 AES W0104-02 AES Tullamore Co Offaly W0104-02

Metals 200140 OCR WCP-MO-09-0618-01 OCR Roxborough Co Roscommon WCP-MO-09-0618-01

Timber 200103 OCR WCP-MO-09-0618-01 OCR Roxborough Co Roscommon WCP-MO-09-0618-01

Kerosene 11O113 Safety Kleen CW 056 Safety Kleen Tallaght Dublin 24 W0099-01

Chemical Vials 160507* Indaver Ireland WCP-DC-08-1121-01 Indaver Ireland Dublin Port Dublin 1 W0036-02

Blood 020202 Powers Licence No. 597 College Proteins Nobber Co Meath P0037-03

Approval No. SRM004 College Proteins Nobber Co Meath SRM 020202 Donohues Licence No. 1026.00 P0037-03 R9 11

Waste Permit No: CW104 Approval No. SRM004 Soft Offal / Bone 020202 Donohues Licence No. 1026.00 Farragh Proteins Crossdoney Co Cavan P0025-04 R921 Waste Permit No: CW104 Organic Waste 020204 (Sludge) Gannon

Organic Waste Transport & Approval No. NWCPO-12- Gannon Transport & 020202 Keelogues, Creggs, Co Galway Annual NMP (Bellygrass) Environmental 11038-01 Environmental Services

Organic Waste Services 020204 (Lairage)

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5.2 Nutrient Management Plan All of the lands in the landbank were surveyed, including extensive soil sampling and analysis for available P, desktop hydrogeological surveying, outline of the proposed spreading areas and exclusion zones, meeting with the participating farmers, training and signing of landspreading agreements. Kepak Athleague produced 3625m 3 of Wastewater Treatment Plant (WWTP) sludge annually from their abattoir. Kepak Athleague also produced 3268m3 of bellygrass from slaughtered animals and an estimated 2,198m 3 of separate lairage. The sludge, bellygrass and lairage contain significant levels of major and minor nutrients, primarily nitrogen and phosphorus. It is proposed that all organic material will be stored and landspread in accordance with this NMP by approved contractors, Gannon Transport and Environmental Services Ltd. (NWCPO-12-11038-01) throughout 2017. Landbanks No. 1-31 have previously been approved by the Agency for landspreading during 2014, 2015 and 2016. Landbanks Nos. 32 and 33 were included in 2017 and approved by the Agency.

5.2.1 Storage of Organic Waste There are currently 10 offsite storage facilities in close proximity to the landbanks and Kepak Athleague which provide 168% of the required 18 weeks storage capacity. A summary from the proposed storage locations is provided in the table below.

Table 11 – Off-Site Storage Facilities

Kepak Athleague AER 2017

6.0 Resource Management

In 2014 Kepak Athleague became the first in the beef industry to received certified accreditation to the Energy Standard ISO50001. In 2016, there was a change in run time in the lamb abattoir due to a DAFM requirement therefore the line ran for a longer period of time therefore increasing the volume of hot water used thus increasing LFO usage. In 2016, there were an number of equipment changes to the both slaughter line introducing additional sterilisers therefore increasing water and LFO usage.

Table 12 - Resource Consumption

Energy Unit 2016 2017 Difference Consumption per Tonne 273.13 ltr /MT 2017 Light Fuel Oil (LFO) Litres 1,328,610 1,183,358 -10.93% 338.52 ltr/MT 2016 174.75, kWh/ MT 2017 Electricity KWh 7,649,639 7,397,695 +3.41% 163.70,kWh/ MT 2016 5.11 m3/ MT 2017 Water Usage m3 238,579 254,826 -6.38 % 6.02 m3/ MT 2016

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7.0 Environmental Incidents and Non Compliances 7.1 Summary of Incidents Table 13 – Summary of Incidents

Year 2017 2016 2015 2014 2013 2012 WWTP Equipment 0 0 0 0 0 0 Malfunction WWTP Parameter including 0 0 0 0 0 1 external results Power Cut 2 0 0 0 0 1 Testing and Monitoring 0 0 0 0 0 0 equipment Off-Site Spillages 0 0 0 0 0 0 Odour 0 0 0 0 0 0 Total 0 0 0 0 0 2 Table 14 - Breakdown of Non-compliances Non-Compliance At the time of the site visit on 22/06/2017 it was noted that there was discoloration of the grass (it appeared dead) at the storm water discharge point AS4, this was highlighted in SV12283 and the licensee was asked to investigate. After investigation by the licensee (LR030372) the source was traced back to a leak of chlorine in the pump house which had occurred in week 3 of May 2017. This leak allowed chlorine to be discharged through AS4. There was no notification of the incident to the Agency at the time that the leak occurred. Corrective Action Required: All incidents must be notified to the Agency in order to be compliant with condition 11.1 and as outlined in 'Guidance to Licensees/COA holders on the Notification, Management and Communication of Environmental Incidents'. 8.0 Complaints Summary Table 15 - Summary of Complaints

Year 2017 2016 2015 2014 2013 2012 2011 Odour 2 1 1 1 0 0 5 Noise 2 0 0 0 3 0 0 Noise & Odour 0 0 0 0 0 0 0 Total 4 1 1 1 3 0 5 Table 16 – Breakdown of Complaints Odour

Date Source Corrective Action 30/05/2017 Neighbour Investigation carried out on site to identify the odour. It was noted that a door on the balance tank had gotten stuck open which was causing a strong odour on the site. Maintenance fixed the door as soon as the issue was identified. As a further corrective action the drains, by product trailers and truck wash sump received additional cleaning. Following the identification and correction of the issue the complainant was contacted again to inform him of the issue. The complainant stated that the odour had improved significantly and is happy that the site is handling the situation. 07/07/2017 Neighbour/ At the time of the complaint corrective action was already being undertaken due to an site issue noted on site at the time. A trailer left the front yard to go to the weigh bridge in the loading bay yard, the security guard noted that the CAT 3 trailer was not sealed fully and material was spilling out the back door. The security guard immediately contacted the Technical Manager to report the issue and did not permit the driver to leave the site until instructed by the technical manager. The technical manager met the driver in the loading bay yard to make him aware of the issue and to investigate why the back of the trailer was not sealed correctly. The driver informed him that he was not able to close the back of the trailer himself and required assistance which he

Kepak Athleague AER 2017

was going to ask for before he left the site. The technical manager informed him that he should not have left the front yard until the trailer was sealed correctly and should have asked for assistance. The technical manager proceeded to show the driver the spillage that was caused. With assistance the driver proceeded to seal the back of the trailer correctly and was asked to move through the yard to ensure the back was sealed correctly and no material spilling during movement. The trailer was not permitted to leave the site until the technical manager was satisfied that it was no longer leaking. A clean-up crew was organised to clean the roadway in front of the factory and both yards ensuring all spillages were directed to WWTP drains through the use of drain blockers. As the evening was particularly hot and the wind was blowing in the direction of the complainant’s house, the spillage did cause an odour. The owner of the company contracted to remove animal by-product waste from the site was contacted and made aware of the situation. A meeting was also held with him to ensure he fully understands the seriousness of the issue and to ensure all his drivers are aware of their responsibilities.

Noise

Date Source Corrective Action 23/08/2017 Neighbour The complainant contacted by staff member the following day to arrange a meeting however, he did not want a meeting and they discussed the issue over the phone. The complainant had made some suggestions regarding the use of the shunter to over trailers onto the loading bays and staff member took note of this and met with the loading bay operatives that evening to review practices during night time loading 01/12/2017 Neighbour Issue investigated as the time was particularly unusual. Out of the ordinary production activity being carried out due to an internal issue. The supervisor of the area was met with and informed of issue and was made aware of local issues with noise and to ensure all staff were aware that if they are working during the night time that noise levels must be kept to a minimum and only internal storage areas can be used to eliminate the need for fork truck being used externally.

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Objectives & Targets Table 17 – Objectives & Targets 2016 – 2020 (The 5 year objectives and targets plan has been amended in line with the Kepak Group Origin Green Plan with 2015 figures used as the baseline for setting targets ) The plan was amended in line with the change in the production plan within Athleague and the Kepak Group

Objective Method for Achievement Responsibility Timescale Monitoring information from energy Reduce electricity usage monitoring system, identifying high use Energy Team 2020 overall by 10% areas and potential opportunities during. Monitor information from monitoring 2020 Reduce total emissions by system and identify high use items and Energy Team 10% potential opportunities. SEU’s identified on each site. 2020 Reduce boiler electricity Opportunities registers in place Energy Team usage by 10% identifying potential energy saving projects Achieved in 2016

Reduce landfill waste to Review with waste contractor to be Energy Team Zero removed off site for incineration

Monitoring information from water 2020 monitoring system, identifying high use areas and potential opportunities. . Reduce water Implement and quantify improvements Energy Team consumption by 10% and methods of continuous improvement and embed system within the site. Through continued implementation of Zero complaints EMS procedures particularly in relation Environmental Manager Continuous to odour and noise procedures Through continued implementation of Reduction of EMS procedures particularly in relation Environmental Manager Continuous Environmental Incidents to WWPT management and operation Through continued implementation of Zero non-compliances Environmental Manager Continuous EMS procedures and EPA requirements

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9.0 Environmental Management Programmes Report on 2017 Targets were outlined in the EMP 2017 to improve the environmental performance of the factory. The progress of these targets was as follows:

Table 18 – Summary of 2017 EMP

Target Achieved Comments Water Discharge Continue to produce consistent Yes quality in water discharged from There were no breaches to the licence for effluent discharge in 2015

WWTP Reduce volume of water discharged Increase due to increase in volume slaughter and kill times run time due No by 2% to regulatory compliance Water Reduce water consumption by 2% Yes Decrease of 6.38% Environmental Incidents and Non- Compliances Reduce number of on-site incidents No 2 incidents in 2017 – both power cuts Reduce number of non-compliances No 1 notification of non-compliance received please refer to Table 14 above to zero Reporting Submit AER Yes Submit NMP Yes Complete and submit PRTR Yes Complete and submit RBME Yes Complaints Zero Complaints No 2 odour and 2 noise complaints received Waste Reduce landfill waste to zero Yes Increase recycling by 5% Yes Increase of 31.96% Energy Usage Reduce energy usage by 1% No Increase of 3.4% Emissions Reduce electricity carbon emissions Yes 31.58% decrease by 2% CO2 Electricity & Boiler kg/MT Reduce boiler energy by 2% kWh/MT Yes 12.97% decrease

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11.0 Environmental Management Improvement Programme for 2018

Kepak Athleague is committed to the responsible environmental management and the operation of its business activities in an environmentally responsible manner. The company is committed to fulfilling its environmental obligations and being responsible to the community in which it operates. Kepak Athleague believes that responsible environmental management is good business practise.

The following is the EMP for 2018. The targets set out in the 2018 EMP are based on the Kepak Group Origin Green Plan using 2015 figures as the baseline.

Table 19 – EMP 2017

Target Means Responsibility Timeframe Water Discharge • Continue to follow laboratory and WWTP Manual guidance Continue to produce • Continue daily meetings with environmental Environmental consistent quality in water On-Going manager and WWTP operator Manager discharged from WWTP • Continue participation in EPA Intercalibration scheme • Reduction in volume of water used during Reduce volume of water production Energy Team On-Going discharged by 2% • Promote further awareness of water and resource usage with operatives Water Usage • Monitoring information from water monitoring system, identifying high usage areas and potential opportunities Reduce water consumption • On-line meetings with operatives and training December Energy Team by 2% m3/MT • Introduction of a number of water reduction 2018 projects including reduction in 85 degree water usage, additional storage and tanks. Reduction in water in sterilisers Environmental Incidents & Non-Compliances • Daily environmental audits Reduce number of on-site Environmental December • Quarterly environmental meetings incidents Manager 2018 • Continuous implementation of EMS • Daily environmental audits • Quarterly environmental meetings • Continuous implementation of EMS • Environmental awareness training Reduce number of non- Environmental December • Continuous implementation of Odour Control compliances to zero Manager 2018 Procedure • Continuous implementation of Noise Reduction Programme • WWTP management and control

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Target Means Responsibility Timeframe Reporting Environmental Submit AER • Submit AER March 2018 Manager Environmental December Submit NMP • Submit NMP Manager 2017 Environmental Complete and submit PRTR • Complete and submit PRTR March 2018 Manager Environmental Complete and submit RBME • Complete and submit RBME April 2018 Manager Complaints • Continuous implementation of Odour Control Procedure Environmental December Zero Complaints • Continuous implementation of Noise Reduction Manager 2018 Programme • Daily odour assessments Waste • Waste contractor moved from landfill to Environmental December Reduce landfill waste to zero incineration Manager 2018 • Continue to segregate waste & identify Increase recycling by 2% additional areas for improvement Environmental December KG/MT • Compare recycling currently undertaken on Manager 2018 other sites and trial similar procedures Energy Usage • Monitoring information from energy monitoring Reduce energy usage by 2% system, identifying high use areas and potential December Energy Team kWh/MT opportunities. 2018 • Review energy projects on site Emissions • Monitor information supplied from monitoring Reduce electricity carbon system and identify high usage items and December emissions by 2% CO potential opportunities Energy Team 2 2018 Electricity & Boiler kg/MT • Introduction of a number of projects and investigate large scale projects • Monitor information supplied from monitoring system and potential opportunities for reduction Reduce boiler energy by 2% December • Introduction of a number of fuel reduction Energy Team kWh/MT 2018 projects and investigate alternative fuel solutions

Kepak Athleague AER 2017

Appendix 1

PRTR

Kepak Athleague AER 2017

Appendix 2

Air Monitoring Reports 2017

Kepak Athleague AER 2017