Brandon Products Ltd, Kilcolman, Asdee, Co. Kerry

21st June 2012

Ann Kehoe, Administration Officer, Office of Climate, Licensing & Resource use. Environmental Protection Agency Newcastle West P.O. Box 3000 Co Limerick Johnstown Castle Estate Tel 069 66796 Co Wexford Mob 087 2390421 Email: [email protected]

REF: IPPC LICENSE APPLICATION FOR BRANDON PRODUCTS, REG NO: P0957-01

Dear Sir/Madam,

Please find enclosed a response to the Article 11 request date 28th of March 2012. Which includes include 1 hard copies and 2 electronic copies) submitted on behalf of Brandon Products Ltd respect of the site seaweed processing operation at Kilcolman, Asdee, Co. Kerry

The request was in relation to the following 1. An Appropriate Assessment for the Site (Attachment 1) For inspection purposes only. 2. Best Available TechnologiesConsent (BAT) of copyright Assessment owner required (Attachment for any other use. 2)

3. Updated Non-Technical Summary (attachment 3)

Included is an updated Air Dispersion Model examining a discharge stack on the existing Bio-Scrubber, Attachment 4.

Please contact me if you require further information on the matter.

Yours sincerely

Trevor Montgomery, Post Grad Dip, BSc, Dip Mgmt, Dip Poll Ass & C, Cert Envn Mont, Cert HSWW Environmental and Health & Safety Consultant.

EPA Export 26-07-2012:23:56:2626-05-2014:23:41:29 Attachment 1 An Appropriate Assessment for the Site

For inspection purposes only. Consent of copyright owner required for any other use.

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Brandon Products Ltd

Appropriate Assessment for Brandon Products Ltd, Kilcolman, Asdee, Co. Kerry

For inspection purposes only. April 2012 Consent of copyright owner required for any other use.

Montgomery EHS 2 Beechwood Gardens Newcastle West. Co. Limerick

Tel: 069 66796 Mob 087 239 0421 Email: [email protected]

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Appropriate Assessment Screening

Disclaimer

This document has been prepared on behalf of and for the exclusive use of Brandon Products Ireland Ltd by Montgomery EHS on the basis of an agreed scope of work to respond to an EPA request for further information.

Conclusions and recommendations contained in this Document are based on information supplied by the Client and others. Unless expressly stated otherwise, information provided by Third Parties has not been verified by Montgomery EHS.

Montgomery EHS & Brandon Products Ireland Ltd accepts no liability or responsibility whatsoever in respect of any use of or reliance upon all or part of this Document by any third party.

For inspection purposes only. Document No. P012-012-01 Consent of copyright owner required for any other use.

Rev MEHS Description Origin Review Changes/Amendments Date Approval

1 Draft report TM MM TM 28/03/12 Review document 2 Draft 2 TM MM TM 03/04/12 Issued 3 Modified TM MM TM 27/4/12 Issued 4 Final TM MM TM

Montgomery EHS, Registered 2 Beechwood Gardens, Newcastle West, Co Limerick Tel: 069 66796 Email: [email protected]

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Brandon Products Ltd, Kilcolman, Asdee, Co. Kerry

Appropriate Assessment Screening

April 2012

Contents

Non-Technical Summary ...... 5

1. Introduction ...... 6 1.1 Background ...... 6 1.2 Survey Methods ...... 6 1.3 Survey Limitations ...... 7 1.4 Purpose and Structure of the Written Submission ...... 7 1.5 Qualifying Species and Conservation Objectives – Scope of AA ...... 7 1.6 The Purpose of Appropriate Assessment ...... 7 1.7 Overview of Appropriate Assessment Process ...... 8 1.8 The Purpose of this Report ...... 9

2.0 Brief Description of the Project ...... 10 2.1 Consultation ...... 10 2.2 European sites that may be affected ...... 10 2.3 Existing legislation, plans and proposals ...... 14 2.3.1 Convention on Biological Diversity (CBD) ...... 14 2.3.2 Kerry County Council County Development Plan 2009 – 2015 (Kerry CC, 2009) 14 2.3.3 Kerry County Council, Heritage & Bio-diversity Actions 2008 – 2012 ..... 17 2.3.4 National Sustainable Development Strategy ...... 18

2.3.5 Long-term Strategy For of inspection the Environmental purposes only. Protection Agency (EPA) ...... 18 2.3.6 Shannon RiverConsent Basin of copyright Management owner required for anyPlan other ...... use...... 18

2.3.7 National Biodiversity Plan ...... 19 2.4 Scoping of the study/Literature Review ...... 19 2.4.1 NPWS Site Synopsis ...... 19

3.0 Baseline Data...... 22 3.1 Methodology ...... 22 3.2 Constraints ...... 22 3.3 Flora ...... 22 3.4 Fauna ...... 24 3.4.1 Mammals ...... 24 3.4.2 Birds...... 25 3.4.3 Amphibians ...... 25 3.4.4 Invertebrates ...... 25

4.0 Screening Matrix ...... 26 4.1 Brief description of the project ...... 26 4.2 Brief description of the Natura 2000 site ...... 26 4.3 Assessment criteria ...... 26 4.4 Describe any likely changes to the site arising as a result of: ...... 28 4.5 Describe any likely impacts on the Natura 2000 site as a whole in terms of: ...... 28

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5.0 Finding of no significant effects report matrix ...... 29 5.1 Name of project or plan ...... 29 5.2 Name and Location of Natura 2000 sites ...... 29 5.3 Description of the project or plan ...... 29 5.4 Is this project directly connected with or necessary to the management of the sites (provide details)? ...... 29 5.5 Are there other projects that together with the project or plan being assessed could affect the sites (provide details)? ...... 29 5.6 The assessment of significance of effects ...... 30 5.7 Explain why these effects are not considered significant...... 30 5.8 List of agencies consulted ...... 30 NPWS ...... 30 5.9 Response to consultation...... 30 5.10 Data collected to carry out the assessment ...... 30 5.11 Level of assessment completed ...... 30 5.11.1 Where the full results of the assessment can be accessed and viewed? ...... 31

6.0 Assessment of Likely Significant Effects ...... 31

7.0 Conclusion ...... 31

8.0 Bibliography ...... 32

For inspection purposes only. Consent of copyright owner required for any other use.

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Non-Technical Summary

In 2011 Brandon Products Ltd applied for a IPPC License from the EPA as the site falls under the scope of the EPA Act and the Protection of the Environment Act.

A Habitats Directive Assessment (HDA) is the process of assessing the impacts from a proposed development or plan on the surrounding Natura 2000 sites. If the impacts identified at the screening stage of the HDA process indicate likely significant effects on any of the Natura 2000 sites, an Appropriate Assessment (AA) is required. The assessment includes an assessment of the effects in combination with other plans and projects where these could combine to affect a Natura 2000 site. The first phase of an Appropriate Assessment is the screening phase to determine if an Appropriate Assessment is required.

The screening process has indicated that the proposed development does have the potential to affect the qualifying features of interest of the three Natura 2000 sites, the River Shannon and River Fergus Estuaries SPA, the Lower River Shannon SAC and the Stack's to Mullaghareirks, West Limerick Hills and Mount Eagle SPA.

However, on examination it is clear, that due to combinations of the proposed mitigation measures, the magnitude of impacts and the positive changes from the current situation, the proposed activities will not have an adverse effect on the integrity of the site or the qualifying features of the For inspection purposes only. Consent of copyright owner required for any other use. conservation objectives of the Natura 2000 sites. Therefore significant impacts are not likely to occur

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1. Introduction

This is an Appropriate Assessment Screening - in line with the requirements of Article 6(3) of the EU Habitats Directive (Directive 92/43/EEC) – for the EPA to assess the IPPC License Application under Article 10 of the Licensing Regulations.

This report was prepared in compliance with the European Communities (2002) Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC - the Screening matrix and the finding of no significant effects report matrix has been taken from Section 4 and 5 (Figures 1 to 6).

1.1 Background

The Site is an operating production facility at Kilcolman, Asdee, Co. Kerry

1.2 Survey Methods

The site was surveyed on the 15th and 23rd of March 2012. The survey on the 15th commenced at 08:30 hrs and finished at 11:00 hrs and the 23rd of March 2012 the survey took place on 10:30 hrs and 12:30 hrs and weather conditions on both days were dry.

For inspection purposes only. The aim of the survey was to evaluateConsent of copyrightthe ecological owner required forstatus any other of use. the site. This involved studying the

types of habitats, flora and fauna present so as to determine the ecological diversity of this area. The site and surrounding area was walked with species and habitats recorded.

The survey method involved the following. 1. The site was walked and photographed with observations recorded. 2. The species of flora, fauna including avian species encountered were recorded. 3. Habitats were checked for evidence of mammals. 4. The diversity of habitats present was recorded. 5. Habitats were classified in accordance to the standard recommended by The Heritage Council (Fossitt 2000).

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1.3 Survey Limitations

Every effort has been made to provide an accurate assessment of the situation pertaining to the site at Kilcolman, Asdee, Co. Kerry at the time of the study.

1.4 Purpose and Structure of the Written Submission The purpose of this Written Submission is to summarise the Appropriate Assessment Screening Report to be submitted to the EPA. The submission addresses the impact of the existing site and and associated infrastructure at Kilcolman, Asdee, Co. Kerry. The site is not within but approx. 1.9 km away from an SPA.

1.5 Qualifying Species and Conservation Objectives – Scope of AA

The subject site itself is not designated under any Regional, National or European Environmental Designation. It does not therefore require assessment under the Wildlife (Amendment) Act 2000 (S.I. No. 38 of 2000) or the European Communities (Natural Habitats) Regulations, 1997 (S.I. No. 94 of 1997). But the Site is located approx 1.9 kilometres from a SAC / SPA and is detailed in the Site Synopsis for the River Shannon (site Code: 002162) and is included in Appendix 1

For inspection purposes only. Consent of copyright owner required for any other use.

1.6 The Purpose of Appropriate Assessment The Directive 92/43/EEC on the Conservation of Natural Habitats and Wild Flora and Fauna – the ‘Habitats Directive’ provides legal protection for habitats and species of European importance. Article 2 of the Habitats Directive requires the maintenance or restoration of habitats and species of interest to the EU in a favourable condition. The Directive was transposed into Irish law by the European Communities (Natural Habitats) Regulations, SI 94/1997.

Articles 6(3) and 6(4) of the Habitats Directive require an Appropriate Assessment of plans to prevent significant adverse effects on European sites, also known as SAC or Natura 2000 sites. In this particular case the purpose of Appropriate Assessment is to assess the potential impacts of a land-use plan on the conservation objectives of European sites. The assessment must determine whether the plan would have significant adverse effects upon the integrity of each site in terms of its nature conservation objectives. The integrity of the site has been defined as “the coherence of the

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site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and/or populations of species for which the site is or will be classified”. Where negative effects are identified other options should be thoroughly examined to avoid any potential damaging effects prior to implementing the plan.

The Natura 2000 network is a European network of ecologically important sites (SPAs and SACs) that have been designated for protection under either the Habitats Directive (Council Directive 92/43/EEC) or the Birds Directive (Council Directive 79/409/EEC). The statutory agency responsible for these designated areas is the National Parks & Wildlife Service of the Department of Environment, Heritage and Local Government.

Plans can only be permitted after having ascertained that there will be no significant adverse effect on the integrity of the site in question. Components within a plan, such as objectives or proposals, can be adjusted or removed to avoid significant adverse impacts prior to implementation. The plan may also proceed if sufficient mitigation or compensation measures are in place to ensure the overall integrity of the site.

1.7 Overview of Appropriate Assessment Process In the preparation of this assessment reference has been made to the following documents: European Commissions: Managing Natura 2000 Sites. The provisions of Article 6, of the ‘Habitats’

Directive 92/43/EEC For inspection purposes only. Consent of copyright owner required for any other use.

This screening should be based on any ecological information available to the authority and an adequate description of the plan and its likely environmental impacts. This should take into account any policies that will set the terms for future development. The results of the screening should be recorded and made available to the public.

In any case where, following screening, it is found that the project may have an impact on the conservation objectives of a Natura 2000 site or that such an impact cannot be ruled out, adopting a precautionary approach an appropriate assessment of the project must be carried out.

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The European Commission’s Methodological Guidance recommends a 4 stage approach: Stage 1 Screening: Determining whether the plan ‘either alone or in combination with other projects’ is likely to have a significant effect on a European site. Stage 2 Appropriate Assessment: Determining whether, in view of the site’s conservation objectives, the plan ‘either alone or in combination with other projects’ would have an adverse effect (or risk of this) on the integrity of the site. If not, the plan can proceed. Stage 3: Assessment of Alternative Solutions: Where it has not been proven that measures considered will not avoid or mitigate the adverse affect on the Natura 2000 site, then an assessment of the alternatives will be required; and if none are acceptable then stage 4 is required to be considered. Stage 4 Assessment where no Alternative Solutions Exist and where Adverse Impacts Remain This will involve assessment where the Plan is considered to result in adverse impacts on the Natura 2000 site and no alternative solutions remain – the imperative reasons of overriding public interest (IROPI) test must be met before authorisation, permission or adoption of the Plan is agreed. This includes the agreement of compensatory measures.

This report covers Stage 1 of Appropriate Assessment -Screening.

For inspection purposes only. Consent of copyright owner required for any other use. 1.8 The Purpose of this Report This Screening Report will be used to identify whether the existing operation and associated infrastructure at Kilcolman, Asdee, Co. Kerry either alone or in combination with other plans or projects -is likely to have a significant effect on a European site. This report will include recommendations, if necessary, to avoid any significant adverse effects at the earliest possible stage in decision making. This report follows European Commission (2001) guidance which recommends that screening should:  Determine whether the proposed development is directly connected with or necessary to the management of the site – if it is not, then no further assessment is necessary  Describe the proposed and other plans and projects that, ‘in combination’, have the potential to have significant effects on a European site  Identify the potential effects on the European site and  Assess the significance of any effects on the European site

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2.0 Brief Description of the Project

The site is an operating company manufacturing seaweed based bio-stimulants at Kilcolman, Asdee, Co. Kerry. The site has been in place for over 40 years and that been modified in line with planning permission granted by Kerry County Council in 2008. The site is a producer of seaweed based bio-stimulants which are sold predominantly outside Ireland in high value crops.

The site is approximately 1.9 km away from the River Shannon and River Fergus SPA.

2.1 Consultation Montgomery EHS consulted with the National Parks and Wildlife Service (hereafter NPWS) regarding the designated sites in the vicinity of the Brandon Products.

2.2 European sites that may be affected One European site which may potentially be affected by the existing development has been identified namely the:  River Shannon and River Fergus SPA (Site Code 004077) 1.9 km  Lower River Shannon SAC (Site Code 002165) 5.4 km  Tarbery Bay pNHA (Site Code 001386) 15.8 km  Bunnaruddee Bog NHA (Site Code 001352) 9.6 km

For inspection purposes only.  Cashen River Estuary (SiteConsent ofCode copyright 001340) owner required for any other use. 9.0 km

 Ballylongford Bay pNHA (Site Code: 001332) 6.9 km  St. Senan’s Lough pNHA (Site Code: 001025) 14.5 km  Scattery Island pNHA (Site Code: 001911) 7.3 km

A ‘sphere of influence’ of 10 kilometres was assessed, this being deemed as an area which the existing site may affect, either alone or in combination with other plans. The location of the European sites is illustrated in Table 1 outlines each European site, and their qualifying features, that could potentially be affected by the Brandon Products facility at Kilcolman, Asdee, Co. Kerry

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Tarbert Bay pNHA (Site Code: 001386) The Tarbert Bay pNHA is located directly to the east of the Brandon Plant. The site consists of a sandy intertidal bay fringed by saline vegetation and also includes some deciduous woodland. The site is important for wintering waterfowl.

Lower River Shannon SAC (Site Code: 002165) The site is a candidate SAC selected for lagoons and alluvial wet woodlands, both habitats listed on Annex I of the EU Habitats Directive. The site is also selected for floating river vegetation, Molinia meadows, estuaries, tidal mudflats, Atlantic salt meadows, Mediterranean salt meadows, Salicornia mudflats, sand banks, perennial vegetation of stony banks, sea cliffs, reefs and large shallow inlets and bays all habitats listed on Annex I of the EU Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive – Bottle-nosed Dolphin, Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Atlantic Salmon and Otter. There are also a number of species present within the site that are rare and listed in the Irish Red Data Book (1985) in addition to species protected under the Flora Protection Order (1999).

River Shannon and River Fergus Estuaries SPA (Site Code: 004077) This site is of great ornithological interest, being of international importance on account of the numbers of wintering birds it supports. It also supports internationally important numbers of three species, i.e. Dunlin, Black - tailed For inspectionGodwit purposes and only. Redshank. In addition, there are 16 species Consent of copyright owner required for any other use. that have populations of national importance. For several of the bird species, it is the top site in the country. Also of note is that three of the species which occur regularly are listed on Annex I of the E.U. Birds Directive, i.e. Whooper Swan, Golden Plover and Bar-tailed Godwit. The site is most effectively censused from the air and this is carried out in most winters. Stacks to Mullaghareirks, West Limerick Hills and Mount Eagle SPA (Site Code: 004161). The site is a Special Protection Area (SPA) under the EU Birds Directive, of special conservation interest for Hen Harrier. This SPA is a stronghold for Hen Harrier and supports the largest concentration of the species in the country. A survey in 2005 resulted in 40 confirmed and 5 possible breeding pairs, which represents over 29% of the national total. A similar number of pairs had been recorded in the 1998-2000 period. The mix of forestry and open areas provides optimum habitat conditions for this rare bird, which is listed on Annex I of the EU Birds Directive.

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Short-eared Owl, also listed on Annex I of the E.U. Birds Directive and very rare in Ireland, has been known to breed within the site. Merlin, a further E.U. Birds Directive Annex I species, also breeds but the size of the population is not known. Red Grouse is found on some of the unplanted areas of bog and heath – this is a species that has declined in Ireland and is now Red-listed.

Bunnaruddee Bog NHA (Site Code: 001352) Bunaruddee Bog NHA is a site of considerable conservation significance comprising as it does a raised bog, a rare habitat in the E.U. and one that is becoming increasingly scarce and under threat in Ireland. This site supports a diversity of raised bog microhabitats, including hummock/hollow complexes, as well as a number of scarce plant species. The bog is located in Kerry in the south-west extreme of the geographical range of raised bog habitat in Ireland.

Ballylongford Bay pNHA (Site Code: 001332) Ballylongford Bay is an inlet on the southern side of the Shannon Estuary and runs northwards from the town of Ballylongford in County Kerry. The scientific interest of the area lies in the large concentrations of waterfowl that feed on the mudflats there.

St. Senan’s Lough pNHA (Site Code: 001025) This is an acidic lake with a significant marsh habitat. The presence of open water marsh including Sphagna, and cutaway bog indicate that this is a valuable site. Peat is being formed here in this very wet moss-rich marsh For. inspection As such purposes this only. is a thriving habitat and is going through a Consent of copyright owner required for any other use. long term process which was once very common in this Country. Elsewhere in the site there is abundant evidence of cutaway bog, some still being cut.

Clonderalaw Bay pNHA (Site Code: 000027) The site includes all of the intertidal mudflats of the bay. In 1973 a number of isolated patches of Cordgrass (Spartina spp.) occurred on the mudflats. The edges of the estuary had some small strips of saltmarsh vegetation. The site is an important bird site, as it is part of the internationally important Shannon-Fergus estuarine complex.

Scattery Island pNHA (Site Code: 001911) Scattery Island is located near the mouth of the Shannon estuary, about 3 kilometres from Kilrush.

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Much of the island is grassland, which is generally species rich. Saltmarsh habitat is also present. The island is owned largely by the Office of Public Works and was acquired mainly for its early Christian to Medieval ecclastical structures. Further work is required to assess the ecological importance of the island.

For inspection purposes only. Consent of copyright owner required for any other use.

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2.3 Existing legislation, plans and proposals

2.3.1 Convention on Biological Diversity (CBD) The protection of biodiversity is enshrined in the CBD to which Ireland is a signatory. As part of its commitment to this international treaty Ireland, as part of a wider European Union initiative, is committed to the halt in loss of biodiversity by the year 2010. The National Biodiversity Plan (Dúchas, 2002), published in 2002, states that “each local authority is to prepare a local biodiversity action plan”. All Local Authorities are or have completed the process of drawing up its first Biodiversity Action Plan. Kerry County Council have produced a Biodiversity actions plan 2008 to 2012. In addition, the Department of the Environment, Heritage and Local Government is currently preparing the second National Biodiversity Plan.

The plan aims to provide a framework for the conservation of nature and wildlife within the County, which will tie together the policy of national government with the issues that most affect us locally. Its implementation will contribute to achieving national and international targets for the conservation of biodiversity. This is in the context of constantly accelerating rates of species extinction and habitat loss globally.

2.3.2 Kerry County Council County Development Plan 2009 – 2015 (Kerry

CC, 2009) For inspection purposes only. Chapter 11 of the Kerry CountyConsent Development of copyright owner Planrequired 20 for 09any -other201 use.5 sets out the Local

Authority’s position on biodiversity.

It is an objective of the Council to: EN 11-1 Take all necessary measures to prevent pollution in order to maintain the quality of the environment of County Kerry. EN 11-2 Ensure that policies to counter global warming and climate change are incorporated into the policies and the development management system of Kerry County Council. EN 11-3 Take all necessary measures to ensure that the Natural Environment of the County is managed and protected in a sustainable manner.

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SAC’s and SPA’s together form part of the ‘Natura 2000’ network of sites throughout Europe. The SAC’s, SPA’s and NHA’s designated throughout the County at time of publication are marked on Maps 11.1 - 11.3

Natural Heritage Areas EN 11-22

(a) Ensure that development likely to have serious adverse effects on the areas listed will not normally be permitted. The designation of sites does not imply a total restriction on all development. Applicants must demonstrate that the proposed development will not have a negative impact on the fauna, flora or habitat being protected through an Appropriate Assessment under Article 6 of the Habitats Directive which is a requirement for development proposals affecting European Sites.

(b) Ensure that any development proposal in the vicinity of or affecting in any way a designated European Site or NHA provides sufficient information showing how its proposals will impact on the designated site. Appropriate mitigation measures must be indicated.

For inspection purposes only. (c) Support and promote measuresConsent toof copyright control owner and required manage for any other the use. presence of alien/ invasive species and weeds in consultation with the National Parks and Wildlife Service.

Special Areas of Conservation 11.2.4 In 1992 the Council of the European Communities adopted the Habitats Directive (92/43/EEC), on the conservation of natural and semi-natural habitats and species of flora and fauna. It is the responsibility of each member state to designate Special Areas of Conservation (SACs) to protect habitats and species. The Commission of the European Union calls the sites ‘candidate sites’ because they are currently under consideration.

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Special Areas of Conservation EN 11-23 Maintain the conservation value of those sites as defined in the Planning & Development Act 2000 (Special Areas of Conservation, Special Protected Areas or Lands Proposed for inclusion in such sites) identified by The National Parks and Wildlife Service of the Department of Environment, Heritage & Local Government, as well as any other sites that may be so designated during the lifetime of this plan.

Biodiversity It is the policy of Kerry Council County to EN 11-26 (a) Promote biodiversity throughout the County and implement the recommendations of the National Biodiversity Plan when made available. (b) Support the preparation of a county-wide Habitat Mapping survey subject to consultation with the National Parks and Wildlife Service – Department of the Environment Heritage and Local Government, the Heritage Council and other relevant statutory and non statutory nature conservation interest groups. (c) Facilitate the maintenance and development of an ecological network where necessary through the planning process. (d) To consider the preparation of a Wetland Survey of the County subject to consultation with the National Parks and Wildlife Service – Department of the Environment Heritage

For inspection purposes only. and Local Government, the HeritageConsent of copyrightCouncil, owner Waterways required for any other Ireland use. and other relevant statutory and non statutory nature conservation interest groups. EN 11-27 Ensure that development does not have a significant adverse impact, on plant or animal (including bird) species protected by law. EN 11-28 Consult with the National Parks and Wildlife Service and take account of any licensing requirements when undertaking, approving or authorizing development which is likely to affect plant, animal or bird species protected by law. EN 11-29 Ensure that proposals for development protect and enhance biodiversity, wherever possible, by minimizing adverse impacts on existing habitats and by including mitigation and /or compensation measures ,as appropriate, which ensure that biodiversity and landscape character is maintained.

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Environment The Local Agenda 21 Partnership Fund provides for projects on the theme of Biodiversity, as it is a fundamental part of sustainable development. Control of permits and licencing for waste disposal by this section, as well as enforcement, helps protect sensitive habitats. Provision of better information for the section on the location of locally important habitats would avoid habitat damage and loss and so avoid costly clean-up bills.  To protect natural heritage sites designated in National and European legislation. This includes sites proposed to be designated or designated as Special Areas of Conservation (SAC), Natural Heritage Areas (NHA), Special Protection Areas (SPA) Nature Reserves and Wildfowl Sanctuaries. This protection will extend to any additions or alterations to sites that may arise during the lifetime of this plan.  To assess all proposed developments (individually or in combination with other proposals, as appropriate) which are likely to impact on designated natural heritage sites or those sites proposed to be designated.  To consult with the prescribed bodies and relevant government agencies when assessing developments which are likely to impact on designated natural heritage sites or those sites proposed to be designated. For inspection purposes only.  To ensure that any developmentConsent of copyright in orowner near required a designatedfor any other use. natural heritage site will

avoid any significant adverse impact on the features for which the site has been designated.  To require an appropriate environmental assessment in respect of any proposed development likely to have an impact on a designated natural heritage site, or those sites proposed to be designated.

2.3.3 Kerry County Council, Heritage & Bio-diversity Actions 2008 – 2012 Kerry County Council has produced a document Heritage and Bio-diversity Action Plan 2008 to 2012, which has three key objectives:  Key Performance Areas - Education and Access  Key Performance Areas - Research  Key Performance Areas - Management

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2.3.4 National Sustainable Development Strategy The 2002 document: ‘Making Ireland’s Development Sustainable’ (DOEHLG, 2002) highlights “respect for ecological integrity and biodiversity” as a core theme, while the associated principle is that: “the diversity of wildlife, habitats and species should be maintained and improved”. An update to this document is to be published. 2.3.5 Long-term Strategy of the Environmental Protection Agency (EPA) In 2007 the EPA published ‘2020 Vision: Protecting and Improving Ireland’s Environment’ (EPA, 2007) and identified the protection of soil and biodiversity as one of six environmental goals.

2.3.6 Shannon River Basin Management Plan The Plan, produced in response to the EU Water Framework Directive 2000/60/EC (WFD) requires all waters to have ‘good status’ (unless classified as heavy modified in which case they must achieve ‘good ecological potential’ by 2015) and deterioration in existing water quality status is not acceptable. The Shannon IRBD is the largest in Ireland at more than 18,000 km2 in area. It stretches from the source of the River Shannon in the Cuilcagh Mountains in counties Cavan and Fermanagh to the tip of the Dingle peninsula in north Kerry.

For inspection purposes only. As well as the natural Consentdrainage of copyright basin owner of required the forShannon any other use. river itself, which drains an

extensive area of central Ireland, it also includes coastal parts of Kerry and Clare which drain to the sea. It drains 18 local authority areas and is also an international district as a small portion of County Fermanagh in Northern Ireland drains underground to the source of the Shannon where it rises to the surface at the Shannon Pot in County Cavan. The Shannon IRBD is a largely rural district with many protected sites that depend on water (54% of rivers have protected areas associated with them). Water is critical to the economy of the Shannon IRBD, generating and sustaining wealth though activities such as agriculture, forestry, aquaculture, power generation, industry, services, transport and tourism. However, water is a fragile resource that needs to be protected. The River Basin Management Plan for the Shannon RBD sets out a number of

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measures to achieve ‘good status’. Fish, aquatic invertebrates and aquatic plants all contribute to the ‘biology’ component of the ecological classification system.

2.3.7 National Biodiversity Plan

This sets out Ireland’s biodiversity strategy in response to Article 6 of the Convention on Biological Diversity 1992. Its main goal is to secure conservation (and where possible enhancement) and sustainable use of biological diversity in Ireland and contribute to conservation and sustainability of biodiversity globally. It includes the statement that environmental policy in Ireland is now based on ‘the precautionary principle’ and includes key objectives to conserve habitats, species and genetic diversity.

2.4 Scoping of the study/Literature Review There is a good depth of specific information regarding the SAC/SPA/NHA/ but the site has had no ecological survey over the past 5 years. However the ‘site synopsis’ for the SPA, SAC and NHA (see Appendix 1) and there is a significant volume of published data on the distribution and status of protected species and, to a lesser extent, habitats in this area.

The Environmental Protection Agency (EPA) maintains a nationwide biological

For inspection purposes only. water monitoring programmeConsent of copyright and information owner required for isany availableother use. for the area.

2.4.1 NPWS Site Synopsis Information regarding the sites is available through site synopsis reports. These are reproduced as appendices to this report. To date, a management plan has not been published for the SAC, SPA or NHA’s.

The Shannon River sites largely consist of Sandy beaches, upland forestry, Improved grassland but also encompassing important areas of riparian, tidial and woodland habitats. These habitats support a number of species of conservation concern. The site is bounded by the SAC as shown by Figure 5.

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Table 1 Conservation aspects of the Protected Site Around Brandon Likelihood of Level of Protection Relevance Potential Impacts Habitats Directive Alluvial wet woodland (code: 91E0) No None Annex I priority Petrifying springs with tufa No None formation (code: 7220) Habitats Directive Atlantic salt meadows (code: 1330) No None Annex I Mediterranean salt meadows (code: No None 1410) Old oak woodlands (code: 91A0) No None Eutrophic tall herbs (code: 6430) No None Floating river vegetation (code: No None 3260) Estuary (code: 1130) No None Salicornia mudflats (code: 1310) No None Dry heath (code: 4030) Yes None Tidal mudflats (code: 1140) No None Habitats Directive Sea Lamprey Petromyzon marinus No None Annex II Brook Lamprey Lampetra planeri No None Semi-aquatic snail Vertigo No None moulinsiana Habitats Directive River Lamprey Lampetra fluviatilis No None Annex II, V Freshwater Pearl Mussel For inspection purposes only. No None Margaritifera margaritifera Consent of copyright owner required for any other use. Likelihood of Level of Protection Relevance Potential Impacts Freshwater Crayfish No None Austropotamobium pallipes Twaite Shad Alosa fallax fallax No None Habitats Directive Atlantic Salmon Salmo salar No None Annex II, V Otter Lutra lutra No None Habitats Directive Killarney fern Trichomanes Annex II, IV; Flora No None speciosum Protection Order, 1999 Habitats Directive Daubenton’s bat Myotis daubentoni Annex IV; Wildlife No None Act, 2000 Habitats Directive Irish hare Lepus timidus hibernicus No None Annex

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V; Wildlife Act, 2000 Common frog Rana temporaria Yes None Greenland white-fronted goose No None Anser albifrons flavirostris Golden plover Pluvialis apricaria No None Birds Directive Annex I; Wildlife Whooper swan Cygnus cygnus No None Act 2000 Kingfisher Alcedo atthis No None Perigrine Falco perigrinus No None Bewick’s swan Cygnus columbianus No None bewickii Habitats Directive Killarney fern Trichomanes Annex II, IV; Flora No None speciosum Protection Order, 99

Relevance is interpreted as meaning the likely presence of the habitat/species in the study

area and is taken from relevant literature sources. The likelihood of impact is based on the potential presence of habitats from site visit and aerial photography, showing the presence of suitable habitats for different species.

For inspection purposes only. Consent of copyright owner required for any other use.

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3.0 Baseline Data

3.1 Methodology A site visit was carried out on 15th and the 23rd of March 2012. The site was surveyed in accordance with the Heritage Council’s draft Habitat Survey guidelines (Heritage Council, 2002) and the ‘Guidelines for Baseline Ecological Assessment’ from the Institute of Environmental Assessment (IEA, 1995). Habitats were identified in accordance with Fossitt’s ‘Guide to Habitats in Ireland’ (Fossitt, 2000). A species list for each habitat was compiled and target notes were made.

3.2 Constraints The survey took place in March 2012 which is early in the growing season. It was therefore reasonable to expect that some floral species will not be apparent or will be difficult to identify.

3.3 Flora

Improved Grassland GA 1 In areas around the site comprises of improved agricultural grassland. The land has been reseeded and treated with fertilisers improving the soil condition. The land in summary is good grazing land. Vegetation is dominated by perennial rye grass (Lolium perenne). For inspection purposes only. Consent of copyright owner required for any other use.

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Photo 1 Photo looking west, showing improved agricultural land to the north and east of the plant.

For inspection purposes only. Consent of copyright owner required for any other use.

Photo 2 Photo looking south with improved grassland and the Brandon Products Site to the rear of the photo

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3.4 Fauna 3.4.1 Mammals Since a dedicated fauna survey was not carried out, the presence of various species is deduced from the existence of suitable habitat and this is shown in Table 2. Otter Lutra lutra could occur along the rivers and within waterbodies. Badger Meles meles no droppings were recorded in during the site visit. While the Badger is protected under the Wildlife (Amendment) Act, 2000 it is not mentioned in the Habitats Directive.

Table 2 Mammals known from the Asdee Area and for which there is suitable habitat (Harris & Yalden, 2008).

Level of Protection Habitat Annex II & IV Habitats Otter Lutra lutra Directive; Wildlife Rivers and wetlands (Amendment) Act, 2000 Gardens, parks and Whiskered bat Myotis mystacinus riparian habitats Natterer’s bat Myotis nattereri Woodland Open areas roosting in Leisler’s bat Nyctalus leisleri attics Brown long-eared bat Plecotus Annex IV Habitats Woodland auritus Directive; Wildlife Leisler’s bat Nyctalus leisleri (Amendment) Act, 2000 Woodlands and buildings For inspection purposes only. Common pipistrelle PipistrellusConsent of copyright owner required for any other use. pipistrellus Farmland, woodland and Soprano pipistrelle Pipistrellus urban areas pygmaeus Daubenton’s bat Myotis Woodlands and bridges daubentonii associated with open water Annex B Habitats Irish hare Lepus timidus Directive; Wildlife Wide range of habitats hibernicus (Amendment) Act, 2000 Hedgehog Erinaceus europaeus Woodlands and hedgerows Woodlands, heathland, and Pygmy shrew Sorex minutus wetlands Red squirrel Sciurus vulgaris Wildlife (Amendment) Woodlands Irish stoat Mustela erminea Act, 2000 Wide range of habitats hibernica Farmland, woodland and Badger Meles meles urban areas

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3.4.2 Birds Incidental recordings of birds were made and include many typical countryside species and these are detailed in table 3. No dedicated bird survey was carried out and so this list is not exhaustive. Nearly all bird species and their nests are protected under the Wildlife (Amendment) Act, 2000. This species is listed under the Annex I of the Birds Directive.

Table 3 – Incidental records of birds observed during the survey

Conservation Latin Name English Name Status

Ardea cinerea Grey heron Green Corvus frugilegus Rook Green Erithacus rubecula Robin Green Motacilla cinerea Grey wagtail Green Turdus merula Blackbird Green

Conservation status is derived from BirdWatch Ireland’s list of Birds of Conservation Concern in Ireland (Lynas et al., 2007) where green = low concern; amber = medium concern; and red = high concern. For inspection purposes only. Consent of copyright owner required for any other use.

3.4.3 Amphibians Neither Common frog Rana temporaria nor Smooth newt Triturus vulgaris were recorded although they could breed in the marginal areas of the wetlands in the surrounding area, where wetland vegetation has developed. Both are protected under the Wildlife (Amendment) Act, 2000 while the frog is also protected under Annex V of the Habitats Directive.

3.4.4 Invertebrates A large number of insects are likely to be present in the area and all habitats present are suitable for a wide range of species. It is unlikely that protected species occur.

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4.0 Screening Matrix

4.1 Brief description of the project The existing site at Kilcolman, Asdee, Co. Kerry consists of a boilerhouse, warehouse and production area at Kilcoman, Asdee, Co. Kerry

4.2 Brief description of the Natura 2000 site The Site is 1.9 kilometres from the River Shannon and Fergus SAC is of considerable conservation significance for the occurrence of good examples of habitats and of populations of plant and animal species that are listed on Annexes I and II of the E.U. Habitats Directive respectively

A National Parks and Wildlife Service (NPWS) site synopsis for this site is given in Appendix 2 and the location is presented in Figure 4, 5 & 6

4.3 Assessment criteria  Describe the individual elements of the project (either alone or in combination with other projects) likely to give rise to impacts on the Natura 2000 site. o The continued use of the Brandon Products Site at Kilcoman, Asdee, Co Kerry and associated infrastructure and will have a no impact on the designated habitats. For inspection purposes only. Consent of copyright owner required for any other use.

 Describe any likely direct, indirect or secondary impacts of the project (either alone or in combination with other plans or projects) on the Natura 2000 site by virtue of: o size and scale; (a) Direct impacts None (b) Indirect None (c) Secondary None

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 Land-take; o No land take, site in existence

 Distance from the Natura 2000 site or key features of the site; o The nearest relevant site is over 1.9 kilometres away.  Resource requirements (water abstraction etc.); o The well on-site is used to supply process and potable water

 Emissions (disposal to land, water or air); o The site has emission to air from the boiler and bio-scrubber. The site has no discharge to surface waters. The domestic effluent is treated in an approved on-site treatment system.

 Excavation requirements; o All necessary works are already in place.

 Transportation requirements; o All materials and resources for construction are presently on site. Items

for routine maintenance For inspection and repair purposes willonly. be transported using existing Consent of copyright owner required for any other use. roads. The chemicals and raw materials required for the process and products from the process are transported using existing roads.

 Duration of construction, operation, decommissioning, etc.; o No construction works will take place; operation is in place, which includes periodic maintenance activity.

 Other o None

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4.4 Describe any likely changes to the site arising as a result of:

 Reduction of habitat area: o No, existing fencing and boundary will be retained

 Disturbance to key species; o None

 Habitat or species fragmentation; o The site is in place and no habitat or species fragmentation has occurred as the development has taken place. The site has been in existence for over 40 years as a creamery and was dormant for many years, the purchase and development is a sustainable option with local jobs.

 Reduction in species density; o None

 Changes in key indicators of conservation value (water quality etc.); o No change as the production facility and infrastructure is already in place

For inspection purposes only.  Climate change. Consent of copyright owner required for any other use.

o None

4.5 Describe any likely impacts on the Natura 2000 site as a whole in terms of:  Interference with the key relationships that define the structure of the site; o The site is over 1.9 km from the River Shannon and Fergus SAC, therefore the impact of the existing production plant will be none.

 Interference with key relationships that define the function of the site. o None

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5.0 Finding of no significant effects report matrix

5.1 Name of project or plan Brandon Products Ireland Ltd Kilcolman Asdee, Co. Kerry

5.2 Name and Location of Natura 2000 sites  River Shannon and River Fergus SPA (Site Code 004077)  Lower River Shannon SAC (Site Code 002165)  Fergus Eustuary and Inner Shannon pNHA (Site Code 002048)  Bunnaruddee Bog NHA (Site Code 001352)

See Figures 1 to 6.

5.3 Description of the project or plan The site is constructed with planning permission granted by Kerry CoCo to produce seaweed based products.

5.4 Is this project directly connected with or necessary to the management of the sites (provide details)? The Brandon Products facility and design includes objectives to protect, conserve and manage in a prudent and sustainable manner. The development consisted of the retention of For inspection purposes only. Consent of copyright owner required for any other use. an old building and the construction of new buildings. This aided to reduce the visual impact of the site.

5.5 Are there other projects that together with the project or plan being assessed could affect the sites (provide details)? The operation at Brandon Products, Kilcolman, Asdee, Co Kerry has been formulated to ensure that uses, developments and effects arising from the operation shall not give rise to adverse impacts on the integrity of the SAC or protected sites in the area.

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5.6 The assessment of significance of effects Describe how the project (alone or in combination) is likely to affect the SAC. The Brandon Products site has been designed to ensure that uses, developments and effects arising from the existing development shall not give rise to adverse impacts on the integrity of any SAC or protected sites in the area.

5.7 Explain why these effects are not considered significant. The Brandon Products facility was developed from the existing creamery which had been on the site for over 40 years. The current site has been developed to anticipate and avoid the need for impacts that would be likely to adversely affect the integrity of any SAC or Protected sites. The site is currently operational and every effort is made to ensure compliance with relevant regulatory provisions for the prevention of pollution, nuisance or other environmental effects likely to significantly and adversely affect the integrity of any SAC or protected site.

5.8 List of agencies consulted NPWS

5.9 Response to consultation. Consultation was held with NPWS For inspection purposes only. Consent of copyright owner required for any other use. 5.10 Data collected to carry out the assessment  Who carried out this assessment? o Trevor Montgomery & Miriam Montgomery  Sources of data Documents supplied by o Planning system of Kerry County council o IPPC License application

5.11 Level of assessment completed Site Visit and desktop study

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5.11.1 Where the full results of the assessment can be accessed and viewed? This screening report is to be submitted to the EPA as part of a request for further information to the IPPC License application. The operation on the site falls under the EPA act.

6.0 Assessment of Likely Significant Effects

The operations at Brandon Products, Kilcolman, Asdee, Co Kerry is over 1.9 km way from the SAC / SPA. The site is operational on a site which has been in the area for over 40 years and continues to be used. The continued operation is in line with good practice as the reuse of the existing facility rather than a new greenfield site which would have a larger environmental impact. The site has no significant effects on any protected site or the surrounding area as the SAC/SPA is over 1.9 kilometre away and is surrounding by agricultural land.

7.0 Conclusion

The outcome of the screening process is that there is no need therefore to proceed to stage

2 and ascertain the effect on site integrity For inspection or invepurposesstigate only. mitigation measures or Consent of copyright owner required for any other use. alternative solutions. Therefore, in accordance with the European guidance on Appropriate Assessment (European Commission Environment Division’s Assessment of plans and projects significantly affecting Natura 2000 sites, 2001) it is concluded that an Appropriate Assessment (AA) is not required before the EPA considers the application in full.

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8.0 Bibliography

Bang, P. & Dahlstrom, P. (2001) Animal Tracks and Signs. Oxford University Press, Inc., New York.

Blamey, M. & Fitter, R.(1980) Wild Flowers. Collins and Co., Glasgow.

Cabot D. 2004. Irish Birds. Collins.

Clapham, Tutin and Warburg (CUP), Excursion Flora

Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora Council Directive 2000/60/EC of the European Parliament and of the Council establishing a framework for the Community action in the field of water policy – more commonly known as the Water Framework Directive

Croft P.S. 1986. A Key to the Major Groups of British Freshwater Invertebrates’. Field Studies Council.

Curtis T.G.F.& McGough H.N. 1988. The Irish Red Data Book 1: Vascular Plants. Stationary Office.

Department of Environment, Heritage and Local Government, 2002. Making Ireland’s Development Sustainable

Dúchas. 2002. National Biodiversity Action Plan. Department of the Arts, Heritage, Gaeltacht and the Islands.

Elliott J.M., Humpesch U.H. & Macan T.T. 1988. Larvae of the British Ephemeroptera: A Key with Notes. Freshwater Biological Association. For inspection purposes only. Consent of copyright owner required for any other use.

Fitter R., Fitter A. & Farrer A. 1984. Grasses, sedges, rushes and ferns of Britain and Northern Europe. Collins.

Fitter, R., Fitter, A. & Blamey, M. (1974) The Wild Flowers of Britain and Northern Europe. Collins, London.

Fossitt J. 2000. A Guide to Habitats in Ireland. Heritage Council.

Greenhalgh M. & Ovenden D. 2007. Freshwater Life. Collins.

Harris S. & Yalden D.W. 2008. Mammals of the British Isles: Handbook, 4th Edition. The Mammal Society.

Hendry K. & Cragg-Hine D. 2003. Ecology of the Atlantic Salmon. Conserving Natura 2000 Rivers Ecology Series No. 7. English Nature, Peterborough.

Heritage Council. 2002. Draft Habitat Survey Guidelines. The Heritage Council.

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Hickie D. 2004. Irish Hedgerows: Networks for Nature. Networks for Nature.

IEEM. 2006. Guidelines for Ecological Impact Assessment in the United Kingdom. Institute of Ecology and Environmental Management.

Institute of Environmental Assessment, 1995. Guidelines for Baseline Ecological Assessment’ JNCC, 1993, Handbook for phase I habitat survey – a technique for environmental audit NRA. 2006. Guidelines for Assessment of Ecological Impacts of National Road Schemes. National Roads Authority.

Olsen L., Sunesen J. & Pedersen B.V. 2001. Small Freshwater Creatures. Oxford University Press.

Oxford Brookes University. 2001. Assessment of plans and projects significantly affecting Natura 2000 sites. Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. European Commission, Environment DG.

Philips, R. (1980) Grasses, Ferns, Mosses and Lichens of Great Britain and Ireland. Pan Books, London.

Preston C.D., Pearman D.A. & Dines T.D. 2002. New Atlas of the British & Irish Flora. Oxford University Press.

Scannell M.J.P. & Synnott D.M. 1987. Census catalogue of the Flora of Ireland. Stationary Office.

Stace, C., 1999, New Flora of the British Isles by).

Treweek J., 1999. Ecological Impact Assessment, Blackwell Science. Walters, M. (1997) The Pocket Guide to Birds of Britain and Europe. Parkgate Books, London. For inspection purposes only. Consent of copyright owner required for any other use. Kerry County Council. 2009. Kerry County Development Plan 2009 to 2015.

Kerry County Council, 2008 Heritage & Biodiversity Plan 2008-12

Webb D.A., Parnell J. & Doogue D. 1996. An Irish Flora. Dundalgan Press.

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 SITE SYNOPSIS

SITE NAME: STACK’S TO MULLAGHAREIRK MOUNTAINS, WEST LIMERICK HHILLSILLS AND MOUNT EAGLE SPA

SITE CODE: 004161

The Stack’s to Mullaghareirk Mountains, West Limerick Hills and Mount Eagle SPA is a very large site centred on the borders between the counties of Cork, Kerry and Limerick. The site is skirted by the towns of Newcastle West, Ballydesmond, Castleisland, Tralee and Abbeyfeale. The mountain peaks included in the site are not notably high or indeed pronounced, the highest being at Knockfeha (451 m). Other mountains included are Mount Eagle, Knockanefune, Garraunbaun, Taur, Rock Hill, Knockacummer, Mullaghamuish, Knight’s Mt, Ballincollig Hill, Beennageeha Mt, Sugar Hill, Knockanimpuba and Knockathea, amongst others. Many rivers rise within the site, notably the Blackwater, Owentaraglin, Owenkeal, Glenlara, Feale, Clydagh, Allaghaun, Allow, Oolagh, Galey and Smerlagh.

The site consists of a variety of upland habitats, though almost half is afforested. The coniferous forests include first and second rotation plantations, with both pre-thicket and post-thicket stands present. Substantial areas of clear-fell are also present at any one time. The principal tree species present are Sitka Spruce ( Picea sitchensis ) and Lodgepole Pine ( Pinus contorta ). A substantial part (28%) of the site is unplanted blanket bog and heath, with both wet and dry heath present. The vegetation of these habitats is characterised by such species as Ling Heather ( Calluna vulgaris ), Bilberry ( Vaccinium myrtillus ), Common Cottongrass ( Eriophorum angustifolium ), Hare’s-tail Cottongrass ( Eriophorum vaginatum ), Deergrass ( Scirpus cespitosus ) and Purple Moor-grass ( Molinia caerulea ). The remainder of the site is mostly rough grassland that is used for hill farming. This varies in composition and includes some wet areas with rushes ( Juncus spp.) and some areas subject to scrub encroachment.

The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation interest for Hen Harrier.

This SPA is a stronghold for Hen Harrier and supports the largest concentration of the species in the country. A survey in 2005 resulted in 40 confirmed and 5 possible breeding pairs, which represents over 29% of the national total. A similar number of pairs had been recorded in the 1998-2000 period. The mix of forestry and open areas provides optimum For habitat inspection purposes conditions only. for this rare bird, which is listed on Annex Consent of copyright owner required for any other use. I of the E.U. Birds Directive. The early stages of new and second-rotation conifer plantations are the most frequently used nesting sites, though some pairs may still nest in tall heather of unplanted bogs and heath. Hen Harriers will forage up to c. 5 km from the nest site, utilising open bog and moorland, young conifer plantations and hill farmland that is not too rank. Birds will often forage in openings and gaps within forests. In Ireland, small birds and small mammals appear to be the most frequently taken prey.

Short-eared Owl, also listed on Annex I of the E.U. Birds Directive and very rare in Ireland, has been known to breed within the site. Nesting certainly occurred in the late 1970s and birds have been recorded intermittently since. The owls are considered to favour this site due to the presence of Bank Voles, a favoured prey item. Merlin, a further E.U. Birds Directive Annex I species, also breeds but the size of the population is not known. Red Grouse is found on some of the unplanted areas of bog and heath – this is a species that has declined in Ireland and is now Red-listed.

The main threat to the long-term survival of Hen Harriers within the site is further afforestation, which would reduce and fragment the area of foraging habitat, resulting in possible reductions in breeding density and productivity. The site has a number of wind farm developments but it is not yet known if these have any adverse impacts on the Hen Harriers.

Overall, the site provides excellent nesting and foraging habitat for breeding Hen Harrier, and is considered to be among the top two sites in the country for the species.

21.5.2007 EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 SITE SYNOPSIS

SITE NAME: RIVER SHANNON AND RIVER FERGUS ESTUARIES SPA

SITE CODE: 004077

The estuaries of the River Shannon and River Fergus form the largest estuarine complex in Ireland. The site comprises all of the estuarine habitat west from Limerick City and south from Ennis, extending west as far as Killadysert and Foynes on the north and south shores respectively of the River Shannon (a distance of some 25 km from east to west). Also included are several areas in the outer Shannon estuary, notably Clonderalaw Bay and Poulnasherry Bay, as well as the intertidal areas on the south shore of the Shannon between Tarbert and Beal Point.

The site has vast expanses of intertidal flats. The main macro-invertebrate community present is a Macoma-Scrobicularia-Nereis community which provides a rich food resource for the wintering birds. Other species occurring include Common Cockle (Cerastoderma edule ), Lugworm ( Arenicola marina ), the polychaete Nepthys hombergii , the gastropod Hydrobia ulvae and the crustacean Corophium volutator . Eelgrass ( Zostera spp.) is present in places, along with green algae (e.g. Ulva spp. and Enteromorpha spp.). Salt marsh vegetation frequently fringes the mudflats and this provides important high tide roost areas for the wintering birds. Characteristic species occurring include Common Saltmarsh-grass ( Puccinellia maritima ), Sea Aster ( Aster tripolium ), Thrift ( Armeria maritima ), Sea-milkwort (Glaux maritima ), Sea Plantain (Plantago maritima ), Red Fescue (Festuca rubra ) and Saltmarsh Rush (Juncus gerardi ). In the innermost parts of the estuaries, the tidal channels or creeks are fringed with species such as Common Reed ( Phragmites australis ) and club-rushes

(Scirpus maritimus, S. lacustris subsp. For inspection tabernaemontani) purposes only. . Also found is the nationally Consent of copyright owner required for any other use. rare Triangular Club-rush ( Scirpus triqueter ). Elsewhere in the site the shoreline comprises stony or shingle beaches.

The site is the most important coastal wetland site in the country and regularly supports in excess of 50,000 wintering waterfowl (mean of 59,183 for the 4 seasons 1996-97 to 1999/00), a concentration easily of international importance. The site has internationally important populations of Dunlin (14,987), Black-tailed Godwit (706) and Redshank (1,983) - all figures are average peaks for 3 of the 5 seasons in the 1995/96-1999/00 period. A further 16 species have populations of national importance, i.e. Cormorant (148), Whooper Swan (141), Greylag Goose (88), Shelduck (895), Wigeon (3,025), Teal (1,558), Pintail (40), Shoveler (56), Scaup (76), Golden Plover (4,073), Grey Plover (564), Lapwing (13,007), Knot (686), Bar-tailed Godwit (481), Curlew (1,231) and Greenshank (33). The site is among the most important in the country for several of these species, notably Dunlin (11% of national total), Grey Plover (7.5% of total), Lapwing (6.5% of total), Redshank (6% of total) and Shelduck (6.0% of total). The site is also used by Oystercatcher (363), Ringed Plover (70), Brent Goose (135), Great Crested Grebe (47), Red-breasted Merganser (14), Mallard (247), Turnstone (71), Mute Swan (54), Grey Heron (25), Black-headed Gull (1,233) and Common Gull (194).

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 The Shannon / Fergus system was formerly frequented by a Greenland White- fronted Goose population but this declined during the 1980s and 1990s and the birds now appear appear to have abandoned the area. The site provides both feeding and roosting areas for the wintering birds. Habitat quality for most of the estuarine habitats is good. Some species, particularly Whooper Swan and Greylag Goose, utilise areas outside of the site for feeding.

Apart from the wintering birds, large numbers of some species also pass through the site whilst on migration in spring and/or autumn. Regular species include Black- tailed Godwit, Whimbrel and Greenshank.

Much of the land adjacent to the rivers and estuaries has been reclaimed and improved for agriculture and is protected by embankments (especially along the River Fergus estuary). Further reclamation, especially near to the urbanised and industrial areas continues to pose a threat. The site receives pollution from several sources, including industry and agriculture, but it is not known if this has any significant impacts on the wintering birds. Aquaculture occurs in some areas of the site – future increases in this activity could cause disturbance to the habitats and the associated birds. Common Cord-grass ( Spartina anglica ) is well-established and may threaten some of the estuarine habitats. Some disturbance occurs from boating activities.

This site is of great ornithological interest, being of international importance on account of the numbers of wintering birds it supports. It also supports internationally important numbers of three species, i.e. Dunlin, Black-tailed Godwit and Redshank. In addition, there are 16 species that have populations of national importance. For several of the bird species, it is the top site in the country. Also of note is that three of the species which occur regularly are listed on Annex I of the E.U. Birds Directive, i.e. Whooper Swan, Golden Plover and Bar-tailed Godwit. The site is most effectively censused from the air and this is carried out in most winters.

For inspection purposes only. Consent of copyright owner required for any other use.

1.4.2005

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 SITE SYNOPSIS

SITE NAME : LOWER RIVER SHANNON

SITE CODE : 002165

This very large site stretches along the Shannon valley from Killaloe to Loop Head/ Kerry Head, a distance of some 120 km. The site thus encompasses the Shannon, Feale, Mulkear and Fergus Estuaries, the freshwater lower reaches of the River Shannon (between Killaloe and Limerick), the freshwater stretches of much of the Feale and Mulkear catchments and the marine area between Loop Head and Kerry Head. The Shannon and Fergus flow through Carboniferous limestone as far as Foynes, but west of Foynes Namurian shales and flagstones predominate (except at Kerry Head, which is formed from Old Red Sandstone). The eastern sections of the Feale catchment flow through Namurian Rocks and the western stretches through Carboniferous Limestone. The Mulkear flows through Lower Palaeozoic Rocks in the upper reaches before passing through Namurian Rocks, followed by Lower Carboniferous Shales and Carboniferous Limestone. The Mulkear River itself, immediately north of Pallas Green, passes through an area of Rhyolites, Tuffs and Agglomerates. Rivers within the sub- catchment of the Feale include the Galey, Smearlagh, Oolagh, Allaughaun, Owveg, Clydagh, Caher, Breanagh and Glenacarney. Rivers within the sub-catchment of the Mulkear include the Killeenagarriff, Annagh, Newport, the Dead River, the Bilboa, Glashacloonaraveela, Gortnageragh and Cahernahallia.

The site is a candidate SAC selected for lagoons and alluvial wet woodlands, both habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for floating river vegetation, Molinia meadows, estuaries, tidal mudflats, Atlantic salt meadows, Mediterranean salt meadows, Salicornia mudflats, sand banks, perennial vegetation of stony banks, sea cliffs, reefs and large shallow inlets and bays all For inspection purposes only. habitats listed on Annex I ofConsent the E.U. of copyright Habitats owner required Directive. for any other Theuse. site is also selected for the following species listed on Annex II of the same directive – Bottle-nosed Dolphin, Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Atlantic Salmon and Otter.

The Shannon and Fergus Estuaries form the largest estuarine complex in Ireland. They form a unit stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of the Shannon estuary (considered to be a line across the narrow strait between Kilcredaun Point and Kilconly Point). Within this main unit there are several tributaries with their own ‘sub-estuaries’ e.g. the Deel River, Mulkear River, and Maigue River. To the west of Foynes, a number of small estuaries form indentations in the predominantly hard coastline, namely Poulnasherry Bay, Ballylongford Bay, Clonderalaw Bay and the Feale or Cashen River Estuary.

Both the Fergus and inner Shannon estuaries feature vast expanses of intertidal mudflats, often fringed with saltmarsh vegetation. The smaller estuaries also feature mudflats, but have their own unique characteristics, e.g. Poulnasherry Bay is stony and unusually rich in species and biotopes. Plant species are typically scarce on the mudflats, although there are some Eel-grass beds (Zostera spp.) and patches of green

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 algae (e.g. Ulva sp. and Enteromorpha sp.). The main macro-invertebrate community, which has been noted from the inner Shannon and Fergus estuaries, is a Macoma-Scrobicularia-Nereis community.

In the transition zone between mudflats and saltmarsh, specialised colonisers of mud predominate: swards of Common Cord-grass (Spartina anglica) frequently occur in the upper parts of the estuaries. Less common are swards of Glasswort (Salicornia europaea agg.). In the innermost parts of the estuaries, the tidal channels or creeks are fringed with species such as Common Reed (Phragmites australis) and Club- rushes (Scirpus maritimus, S. tabernaemontani and S. triquetrus). In addition to the nationally rare Triangular Club-rush (Scirpus triquetrus), two scarce species are found in some of these creeks (e.g. Ballinacurra Creek): Lesser Bulrush (Typha angustifolia) and Summer Snowflake (Leucojum aestivum).

Saltmarsh vegetation frequently fringes the mudflats. Over twenty areas of estuarine saltmarsh have been identified within the site, the most important of which are around the Fergus Estuary and at Ringmoylan Quay. The dominant type of saltmarsh present is Atlantic salt meadow occurring over mud. Characteristic species occurring include Common Saltmarsh Grass (Puccinellia maritima), Sea Aster (Aster tripolium), Thrift (Armeria maritima), Sea-milkwort (Glaux maritima), Sea Plantain (Plantago maritima), Red Fescue (Festuca rubra), Creeping Bent (Agrostis stolonifera), Saltmarsh Rush (Juncus gerardi), Long-bracted Sedge (Carex extensa), Lesser Sea- spurrey (Spergularia marina) and Sea Arrowgrass (Triglochin maritima). Areas of Mediterranean salt meadows, characterised by clumps of Sea Rush (Juncus maritimus) occur occasionally. Two scarce species are found on saltmarshes in the vicinity of the Fergus Estuary: a type of robust Saltmarsh-grass (Puccinellia foucaudii), sometimes placed within the compass of Common Saltmarsh-grass (Puccinellia maritima) and Hard-grass (Parapholis strigosa).

Saltmarsh vegetation also occurs around a number of lagoons within the site. The two For inspection purposes only. which have been surveyed asConsent part of of copyright a National owner required Inventory for any other use.of Lagoons are Shannon Airport Lagoon and Cloonconeen Pool. Cloonconeen Pool (4-5 ha) is a natural sedimentary lagoon impounded by a low cobble barrier. Seawater enters by percolation through the barrier and by overwash. This lagoon represents a type which may be unique to Ireland since the substrate is composed almost entirely of peat. The adjacent shore features one of the best examples of a drowned forest in Ireland. Aquatic vegetation in the lagoon includes typical species such as Beaked Tasselweed (Ruppia maritima) and green algae (Cladophora sp.). The fauna is not diverse, but is typical of a high salinity lagoon and includes six lagoon specialists (Hydrobia ventrosa, Cerastoderma glaucum, Lekanesphaera hookeri, Palaemonetes varians, Sigara stagnalis and Enochrus bicolor). In contrast, Shannon Airport Lagoon (2 ha) is an artificial saline lake with an artificial barrier and sluiced outlet. However, it supports two Red Data Book species of Stonewort (Chara canescens and Chara cf. connivens).

Most of the site west of Kilcredaun Point/Kilconly Point is bounded by high rocky sea cliffs. The cliffs in the outer part of the site are sparsely vegetated with lichens, Red Fescue, Sea Beet (Beta vulgaris), Sea Campion (Silene maritima), Thrift and Plantains (Plantago spp.). A rare endemic Sea Lavender (Limonium recurvum subsp.

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 pseudotranswallinum) occurs on cliffs near Loop Head. Cliff-top vegetation usually consists of either grassland or maritime heath. The boulder clay cliffs further up the estuary tend to be more densely vegetated, with swards of Red Fescue and species such as Kidney Vetch (Anthyllis vulneraria) and Bird’s-foot Trefoil ( Lotus corniculatus).

The site supports an excellent example of a large shallow inlet and bay. Littoral sediment communities in the mouth of the Shannon Estuary occur in areas that are exposed to wave action and also in areas extremely sheltered from wave action. Characteristically, exposed sediment communities are composed of coarse sand and have a sparse fauna. Species richness increases as conditions become more sheltered. All shores in the site have a zone of sand hoppers at the top and below this each of the shores has different characteristic species giving a range of different shore types in the pcSAC.

The intertidal reefs in the Shannon Estuary are exposed or moderately exposed to wave action and subject to moderate tidal streams. Known sites are steeply sloping and show a good zonation down the shore. Well developed lichen zones and littoral reef communities offering a high species richness in the sublittoral fringe and strong populations of Paracentrotus lividus are found. The communities found are tolerant to sand scour and tidal streams. The infralittoral reefs range from sloping platforms with some vertical steps to ridged bedrock with gullies of sand between the ridges to ridged bedrock with boulders or a mixture of cobbles, gravel and sand. Kelp is very common to about 18m. Below this it becomes rare and the community is characterised by coralline crusts and red foliose algae.

Other coastal habitats that occur within the site include the following:

• stony beaches and bedrock shores - these shores support a typical zonation of seaweeds (Fucus spp., Ascophyllum nodosum and kelps). For inspection purposes only. • shingle beaches - the moreConsent stable of copyright areas owner of required shingle for any support other use. characteristic species

such as Sea Beet, Sea Mayweed (Matricaria maritima), Sea Campion and Curled Dock (Rumex crispus). • Sandbanks which are slightly covered by sea water at all times – there is a known occurrence of sand/gravel beds in the area from Kerry Head to Beal Head. • sand dunes - a small area of sand dunes occurs at Beal Point. The dominant species is Marram Grass (Ammophila arenaria).

Flowing into the estuaries are a number of tidal rivers.

Freshwater rivers have been included in the site, most notably the Feale and Mulkear catchments, the Shannon from Killaloe to Limerick (along with some of its tributaries, including a short stretch of the Kilmastulla River), the Fergus up as far as Ennis, and the Cloon River. These systems are very different in character: the Shannon being broad, generally slow-flowing and naturally eutrophic; the Fergus being smaller and alkaline; while the narrow, fast-flowing Cloon is acid in nature. The Feale and Mulkear catchments exhibit all the aspects of a river from source to mouth. Semi-natural habitats, such as wet grassland, wet woodland and marsh occur by the rivers, however, improved grassland is most common. One grassland type of

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 particular conservation significance, Molinia meadows, occurs in several parts of the site and the examples at Worldsend on the River Shannon are especially noteworthy. Here are found areas of wet meadow dominated by rushes and sedges and supporting a diverse and species-rich vegetation, including such uncommon species as Blue-eyed Grass (Sisyrinchium bermudiana) and Pale Sedge (Carex pallescens).

Floating river vegetation characterised by species of Water-crowfoot (Ranunculus spp.), Pondweeds (Potamogeton spp.) and the moss Fontinalius antipyretica are present throughout the major river systems within the site. The rivers contain an interesting bryoflora with Schistidium alpicola var. alpicola recorded from in-stream boulders on the Bilboa, new to county Limerick.

Alluvial woodland occurs on the banks of the Shannon and on islands in the vicinity of the University of Limerick. The woodland is up to 50m wide on the banks and somewhat wider on the largest island. The most prominent woodland type is gallery woodland where White Willow (Salix alba) dominates the tree layer with occasional Alder (Alnus glutinosa). The shrub layer consists of various willow species with sally (Salix cinerea ssp. oleifolia) and what appear to be hybrids of S. alba x S. viminalis. The herbaceous layer consists of tall perennial herbs. A fringe of Bulrush (Typha sp.) occurs on the riverside of the woodland. On slightly higher ground above the wet woodland and on the raised embankment remnants of mixed oak-ash-alder woodland occur. These are poorly developed and contain numerous exotic species but locally there are signs that it is invading open grassland. Alder is the principal tree species with occasional Oak (Quercus robur), Elm (Ulmus glabra, U. procera), Hazel (Corylus avellana), Hawthorn (Crataegus monogyna) and the shrubs Guelder-rose (Viburnum opulus) and willows. The ground flora is species-rich.

Woodland is infrequent within the site, however Cahiracon Wood contains a strip of old Oak woodland. Sessile Oak (Quercus petraea) forms the canopy, with an understorey of Hazel and Holly (Ilex aquifolium). Great Wood-rush (Luzula For inspection purposes only. sylvatica) dominates the groundConsent flora. of copyright Less owner common required for any species other use. present include Great Horsetail (Equisetum telmeteia) and Pendulous Sedge (Carex pendula).

In the low hills to the south of the Slievefelim mountains, the Cahernahallia River cuts a valley through the Upper Silurian rocks. For approximately 2km south of Cappagh Bridge at Knockanavar, the valley sides are wooded. The woodland consists of Birch (Betula spp.), Hazel, Oak, Rowan (Sorbus aucuparia), some Ash (Fraxinus excelsior) and Willow (Salix spp.). Most of the valley is not grazed by stock, and as a result the trees are regenerating well. The ground flora feature prominent Greater wood-rush and Bilberry (Vaccinium myrtillus) with a typical range of woodland herbs. Where there is more light available, Bracken (Pteridium aquilinum) features.

The valley sides of the Bilboa and Gortnageragh Rivers, on higher ground north east of Cappamore, support patches of semi-natural broadleaf woodland dominated by Ash, Hazel, Oak and Birch. There is a good scrub layer with Hawthorn, Willow, Holly and Blackthorn (Prunus spinosa) common. The herb layer in these woodlands is often open with a typically rich mixture of woodland herbs and ferns. Moss species diversity is high. The woodlands are ungrazed. The hazel is actively coppiced in places.

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 There is a small area of actively regenerating cut away raised bog at Ballyrorheen. It is situated approx. 5km north west of Cappamore Co. Limerick. The bog contains some wet areas with good moss (Sphagnum) cover. Species of particular interest include the Cranberry (Vaccinium oxycoccos) and the White Sedge (Carex curta) along with two other regionally rare mosses including S. fimbriatum. The site is being invaded by Birch (Betula pubescens) scrub woodland. Both commercial forestry and the spread of rhododendron has greatly reduced the overall value of the site.

A number of plant species that are Irish Red Data Book species occur within the site - several are protected under the Flora (Protection) Order, 1999:

• Triangular Club-rush (Scirpus triquetrus) - in Ireland this protected species is only found in the Shannon Estuary, where it borders creeks in the inner estuary. • Opposite-leaved Pondweed (Groenlandia densa) - this protected pondweed is found in the Shannon where it passes through Limerick City. • Meadow Barley (Hordeum secalinum) - this protected species is abundant in saltmarshes at Ringmoylan and Mantlehill. • Hairy Violet (Viola hirta) - this protected violet occurs in the Askeaton/Foynes area. • Golden Dock (Rumex maritimus) - noted as occurring in the River Fergus Estuary. • Bearded Stonewort (Chara canescens) - a brackish water specialist found in Shannon Airport lagoon. • Convergent Stonewort (Chara connivens) - presence in Shannon Airport Lagoon to be confirmed.

Overall, the Shannon and Fergus Estuaries support the largest numbers of wintering waterfowl in Ireland. The highest count in 1995-96 was 51,423 while in 1994-95 it For inspection purposes only. was 62,701. Species listed onConsent Annex of copyright I of owner the required E.U. for Birds any other Directive use. which contributed to these totals include: Great Northern Diver (3; 1994/95), Whooper Swan (201; 1995/96), Pale-bellied Brent Goose (246; 1995/96), Golden Plover (11,067; 1994/95) and Bar-tailed Godwit ( 476; 1995/96). In the past, three separate flocks of Greenland White-fronted Goose were regularly found but none were seen in 1993/94.

Other wintering waders and wildfowl present include Greylag Goose (216; 1995/96), Shelduck (1,060; 1995/96), Wigeon (5,976; 1995/96); Teal (2,319; 1995-96); Mallard (528; 1995/96), Pintail (45; 1995/96), Shoveler (84; 1995/96), Tufted Duck (272; 1995/96), Scaup (121; 1995/96), Ringed Plover (240; 1995/96), Grey Plover (750; 1995/96), Lapwing (24,581; 1995/96), Knot (800; 1995/96), Dunlin (20,100; 1995/96), Snipe (719, 1995/96), Black-tailed Godwit (1062; 1995/96), Curlew (1504; 1995/96), Redshank (3228; 1995/96), Greenshank (36; 1995/96) and Turnstone (107; 1995/96). A number of wintering gulls are also present, including Black-headed Gull (2,216; 1995/96), Common Gull (366; 1995/96) and Lesser Black-backed Gull (100; 1994/95). This is the most important coastal site in Ireland for a number of the waders including Lapwing, Dunlin, Snipe and Redshank. It also provides an important staging ground for species such as Black-tailed Godwit and Greenshank.

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 A number of species listed on Annex I of the E.U. Birds Directive breed within the site. These include Peregine Falcon (2-3 pairs), Sandwich Tern (34 pairs on Rat Island, 1995), Common Tern (15 pairs: 2 on Sturamus Island and 13 on Rat Island, 1995), Chough (14-41 pairs, 1992) and Kingfisher. Other breeding birds of note include Kittiwake (690 pairs at Loop Head, 1987) and Guillemot (4010 individuals at Loop Head, 1987)

There is a resident population of Bottle-nosed Dolphin in the Shannon Estuary consisting of at least 56-68 animals (1996). This is the only known resident population of this E.U. Habitats Directive Annex II species in Ireland. Otter, a species also listed on Annex II of this directive, is commonly found on the site.

Five species of fish listed on Annex II of the E.U. Habitats Directive are found within the site. These are Sea Lamprey (Petromyzon marinus), Brook Lamprey (Lampetra planeri), River Lamprey (Lampetra fluviatilis), Twaite Shad (Allosa fallax fallax) and Salmon (Salmo salar). The three lampreys and Salmon have all been observed spawning in the lower Shannon or its tributaries. The Fergus is important in its lower reaches for spring salmon while the Mulkear catchment excels as a grilse fishery though spring fish are caught on the actual Mulkear River. The Feale is important for both types. Twaite Shad is not thought to spawn within the site. There are few other river systems in Ireland which contain all three species of Lamprey.

Two additional fish of note, listed in the Irish Red Data Book, also occur, namely Smelt (Osmerus eperlanus) and Pollan (Coregonus autumnalis pollan). Only the former has been observed spawning in the Shannon.

Freshwater Pearl-mussel (Margaritifera margaritifera), a species listed on Annex II of the E.U. Habitats Directive, occurs abundantly in parts of the Cloon River.

There is a wide range of landuses within the site. The most common use of the For inspection purposes only. terrestrial parts is grazing byConsent cattle of copyrightand some owner requiredareas for have any other been use. damaged through overgrazing and poaching. Much of the land adjacent to the rivers and estuaries has been improved or reclaimed and is protected by embankments (especially along the Fergus Estuary). Further, reclamation continues to pose a threat as do flood relief works (e.g. dredging of rivers). Gravel extraction poses a major threat on the Feale.

In the past, Cord-grass (Spartina sp.) was planted to assist in land reclamation. This has spread widely, and may oust less vigorous colonisers of mud and may also reduce the area of mudflat available to feeding birds.

Domestic and industrial wastes are discharged into the Shannon, but water quality is generally satisfactory - except in the upper estuary, reflecting the sewage load from Limerick City. Analyses for trace metals suggest a relatively clean estuary with no influences by industrial discharges apparent. Further industrial development along the Shannon and water polluting operations are potential threats.

Fishing is a main tourist attraction on the Shannon and there are a large number of Angler Associations, some with a number of beats. Fishing stands and styles have been erected in places. The River Feale is a designated Salmonid Water under the

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 E.U. Freshwater Fish Directive. Other uses of the site include commercial angling, oyster farming, boating (including dolphin-watching trips) and shooting. Some of these may pose threats to the birds and dolphins through disturbance. Specific threats to the dolphins include underwater acoustic disturbance, entanglement in fishing gear and collisions with fast moving craft.

This site is of great ecological interest as it contains a high number of habitats and species listed on Annexes I and II of the E.U. Habitats Directive, including the priority habitat lagoon, the only known resident population of Bottle-nosed Dolphin in Ireland and all three Irish lamprey species. A good number of Red Data Book species are also present, perhaps most notably the thriving populations of Triangular Club-rush. A number of species listed on Annex I of the E.U. Birds Directive are also present, either wintering or breeding. Indeed, the Shannon and Fergus Estuaries form the largest estuarine complex in Ireland and support more wintering wildfowl and waders than any other site in the country. Most of the estuarine part of the site has been designated a Special Protection Area (SPA), under the E.U. Birds Directive, primarily to protect the large numbers of migratory birds present in winter.

6.10.2006

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 SITE SYNOPSIS

SITE NAME: RIVER BARROW AND RIVER NORE

SITE CODE: 002162

This site consists of the freshwater stretches of the Barrow/Nore River catchments as far upstream as the Slieve Bloom Mountains and it also includes the tidal elements and estuary as far downstream as Creadun Head in Waterford. The site passes through eight counties – Offaly, Kildare, Laois, Carlow, Kilkenny, Tipperary, Wexford and Waterford. Major towns along the edge of the site include Mountmellick, Portarlington, Monasterevin, Stradbally, Athy, Carlow, Leighlinbridge, Graiguenamanagh, New Ross, Inistioge, Thomastown, Callan, Bennettsbridge, Kilkenny and Durrow. The larger of the many tributaries include the Lerr, Fushoge, Mountain, Aughavaud, Owenass, Boherbaun and Stradbally Rivers of the Barrow and the Delour, Dinin, Erkina, Owveg, Munster, Arrigle and King’s Rivers on the Nore. Both rivers rise in the Old Red Sandstone of the Slieve Bloom Mountains before passing through a band of Carboniferous shales and sandstones. The Nore, for a large part of its course, traverses limestone plains and then Old Red Sandstone for a short stretch below Thomastown. Before joining the Barrow it runs over intrusive rocks poor in silica. The upper reaches of the Barrow also runs through limestone. The middle reaches and many of the eastern tributaries, sourced in the Blackstairs Mountains, run through Leinster Granite. The southern end, like the Nore runs over intrusive rocks poor in silica. Waterford Harbour is a deep valley excavated by glacial floodwaters when the sea level was lower than today. The coast shelves quite rapidly along much of the shore.

The site is a candidate SAC selected for alluvial wet woodlands and petrifying springs, priority habitats on Annex I of the E.U. Habitats Directive. The site is also selected as a For inspection purposes only. candidate SAC for old oak woodlands,Consent of copyright floating owner required river for vegetation,any other use. estuary, tidal mudflats, Salicornia mudflats, Atlantic salt meadows, Mediterranean salt meadows, dry heath and eutrophic tall herbs, all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive - Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Nore Freshwater Pearl Mussel, Crayfish, Twaite Shad, Atlantic Salmon, Otter, Desmoulin’s Whorl Snail Vertigo moulinsiana and the Killarney Fern.

Good examples of Alluvial Forest are seen at Rathsnagadan, Murphy’s of the River, in Abbeyleix estate and along other shorter stretches of both the tidal and freshwater elements of the site. Typical species seen include Almond Willow (Salix triandra), White Willow (S. alba), Grey Willow (S. cinerea), Crack Willow (S. fragilis), Osier (S. viminalis), with Iris (Iris pseudacorus), Hemlock Water-dropwort (Oenanthe crocata), Angelica (Angelica sylvestris), Thin-spiked Wood-sedge (Carex strigosa), Pendulous Sedge (C. pendula), Meadowsweet (Filipendula ulmaria), Valerian (Valeriana officinalis) and the Red Data Book species Nettle-leaved Bellflower (Campanula trachelium). Three rare invertebrates have been recorded in this habitat at Murphy’s of the River. These are: Neoascia obliqua (Diptera: Syrphidae), Tetanocera freyi (Diptera: Sciomyzidae) and Dictya umbrarum (Diptera: Sciomyzidae).

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 A good example of petrifying springs with tufa formations occurs at Dysart Wood along the Nore. This is a rare habitat in Ireland and one listed with priority status on Annex I of the EU Habitats Directive. These hard water springs are characterised by lime encrustations, often associated with small waterfalls. A rich bryophyte flora is typical of the habitat and two diagnostic species, Cratoneuron commutatum var. commutatum and Eucladium verticillatum, have been recorded.

The best examples of old Oak woodlands are seen in the ancient Park Hill woodland in the estate at Abbeyleix; at Kyleadohir, on the Delour, Forest Wood House, Kylecorragh and Brownstown Woods on the Nore; and at Cloghristic Wood, Drummond Wood and Borris Demesne on the Barrow, though other patches occur throughout the site. Abbeyleix Woods is a large tract of mixed deciduous woodland which is one of the only remaining true ancient woodlands in Ireland. Historical records show that Park Hill has been continuously wooded since the sixteenth century and has the most complete written record of any woodland in the country. It supports a variety of woodland habitats and an exceptional diversity of species including 22 native trees, 44 bryophytes and 92 lichens. It also contains eight indicator species of ancient woodlands. Park Hill is also the site of two rare plants, Nettle-leaved Bellflower and the moss Leucodon sciuroides. It has a typical bird fauna including Jay, Long-eared Owl and Raven. A rare invertebrate, Mitostoma chrysomelas, occurs in Abbeyleix and only two other sites in the country. Two flies Chrysogaster virescens and Hybomitra muhlfeldi also occur. The rare Myxomycete fungus, Licea minima has been recorded from woodland at Abbeyleix.

Oak woodland covers parts of the valley side south of Woodstock and is well developed at Brownsford where the Nore takes several sharp bends. The steep valley side is covered by Oak (Quercus spp.), Holly (Ilex aquifolium), Hazel (Corylus avellana) and Birch (Betula pubescens) with some Beech (Fagus sylvatica) and Ash (Fraxinus excelsior). All the trees are regenerating through a cover of Bramble (Rubus fruticosus agg.), Foxglove (Digitalis purpurea) Wood Rush (Luzula sylvatica) and Broad Buckler-fern (Dryopteris For inspection purposes only. dilatata). Consent of copyright owner required for any other use.

On the steeply sloping banks of the River Nore about 5 km west of New Ross, in County Kilkenny, Kylecorragh Woods form a prominent feature in the landscape. This is an excellent example of a relatively undisturbed, relict Oak woodland with a very good tree canopy. The wood is quite damp and there is a rich and varied ground flora. At Brownstown a small, mature Oak-dominant woodland occurs on a steep slope. There is younger woodland to the north and east of it. Regeneration throughout is evident. The understorey is similar to the woods at Brownsford. The ground flora of this woodland is developed on acidic, brown earth type soil and comprises a thick carpet of Bilberry (Vaccinium myrtillus), Heather (Calluna vulgaris), Hard Fern (Blechnum spicant), Cow- wheat (Melampyrum spp.) and Bracken (Pteridium aquilinum).

Borris Demesne contains a very good example of a semi-natural broad-leaved woodland in very good condition. There is quite a high degree of natural re-generation of Oak and Ash through the woodland. At the northern end of the estate Oak species predominate. Drummond Wood, also on the Barrow, consists of three blocks of deciduous woods situated on steep slopes above the river. The deciduous trees are mostly Oak species. The woods have a well established understorey of Holly (Ilex aquifolium), and the herb

EPA Export 26-07-2012:23:56:2726-05-2014:23:41:29 layer is varied, with Brambles abundant. Whitebeam (Sorbus devoniensis) has also been recorded.

Eutrophic tall herb vegetation occurs in association with the various areas of alluvial forest and elsewhere where the flood-plain of the river is intact. Characteristic species of the habitat include Meadowsweet (Filipendula ulmaria), Purple Loosestrife (Lythrum salicaria), Marsh Ragwort (Senecio aquaticus), Ground Ivy (Glechoma hederacea) and Hedge Bindweed (Calystegia sepium). Indian Balsam (Impatiens glandulifera), an introduced and invasive species, is abundant in places.

Floating River Vegetation is well represented in the Barrow and in the many tributaries of the site. In the Barrow the species found include Water Starworts (Callitriche spp.), Canadian Pondweed (Elodea canadensis), Bulbous Rush (Juncus bulbosus), Milfoil (Myriophyllum spp.), Potamogeton x nitens, Broad-leaved Pondweed (P. natans), Fennel Pondweed (P. pectinatus), Perfoliated Pondweed (P. perfoliatus) and Crowfoots (Ranunculus spp.). The water quality of the Barrow has improved since the vegetation survey was carried out (EPA, 1996).

Dry Heath at the site occurs in pockets along the steep valley sides of the rivers especially in the Barrow Valley and along the Barrow tributaries where they occur in the foothills of the Blackstairs Mountains. The dry heath vegetation along the slopes of the river bank consists of Bracken (Pteridium aquilinum) and Gorse (Ulex europaeus) species with patches of acidic grassland vegetation. Additional typical species include Heath Bedstraw (Galium saxatile), Foxglove (Digitalis purpurea), Common Sorrel (Rumex acetosa) and Bent Grass (Agrostis stolonifera). On the steep slopes above New Ross the Red Data Book species Greater Broomrape (Orobanche rapum-genistae) has been recorded. Where rocky outcrops are shown on the maps Bilberry (Vaccinium myrtillus) and Wood Rush (Luzula sylvatica) are present. At Ballyhack a small area of dry heath is interspersed with patches of lowland dry grassland. These support a number of Clover species including the legally protected Clustered Clover (Trifolium glomeratum) - a For inspection purposes only. species known from only oneConsent other of sitecopyright in ownerIreland. required forThis any other grassland use. community is especially well developed on the west side of the mud-capped walls by the road. On the east of the cliffs a group of rock-dwelling species occur, i.e. English Stonecrop (Sedum anglicum), Sheep's-bit (Jasione montana) and Wild Madder (Rubia peregrina). These rocks also support good lichen and moss assemblages with Ramalina subfarinacea and Hedwigia ciliata.

Dry Heath at the site generally grades into wet woodland or wet swamp vegetation lower down the slopes on the river bank. Close to the Blackstairs Mountains, in the foothills associated with the Aughnabrisky, Aughavaud and Mountain Rivers there are small patches of wet heath dominated by Purple Moor-grass (Molinia caerulea) with Heather (Calluna vulgaris), Tormentil (Potentilla erecta), Carnation Sedge (Carex panicea) and Bell Heather (Erica cinerea).

Saltmeadows occur at the southern section of the site in old meadows where the embankment has been breached, along the tidal stretches of in-flowing rivers below Stokestown House, in a narrow band on the channel side of Common Reed (Phragmites) beds and in narrow fragmented strips along the open shoreline. In the larger areas of salt meadow, notably at Carrickcloney, Ballinlaw Ferry and Rochestown on the west bank; Fisherstown, Alderton and Great Island to Dunbrody on the east bank, the Atlantic and

EPA Export 26-07-2012:23:56:2826-05-2014:23:41:29 Mediterranean sub types are generally intermixed. At the upper edge of the salt meadow in the narrow ecotonal areas bordering the grasslands where there is significant percolation of salt water, the legally protected species Borrer’s Saltmarsh-grass (Puccinellia fasciculata) and Meadow Barley (Hordeum secalinum) (Flora Protection Order, 1987) are found. The very rare Divided Sedge (Carex divisa) is also found. Sea Rush (Juncus maritimus) is also present. Other plants recorded and associated with salt meadows include Sea Aster (Aster tripolium), Sea Thrift (Armeria maritima), Sea Couch (Elymus pycnanthus), Spear-leaved Orache (Atriplex prostrata), Lesser Sea-spurrey (Spergularia marina), Sea Arrowgrass (Triglochin maritima) and Sea Plantain (Plantago maritima).

Salicornia and other annuals colonising mud and sand are found in the creeks of the saltmarshes and at the seaward edges of them. The habitat also occurs in small amounts on some stretches of the shore free of stones.

The estuary and the other Habitats Directive Annex I habitats within it form a large component of the site. Extensive areas of intertidal flats, comprised of substrates ranging from fine, silty mud to coarse sand with pebbles/stones are present. Good quality intertidal sand and mudflats have developed on a linear shelf on the western side of Waterford Harbour, extending for over 6 km from north to south between Passage East and Creadaun Head, and in places are over 1 km wide. The sediments are mostly firm sands, though grade into muddy sands towards the upper shore. They have a typical macro-invertebrate fauna, characterised by polychaetes and bivalves. Common species include Arenicola marina, Nephtys hombergii, Scoloplos armiger, Lanice conchilega and Cerastoderma edule.

The western shore of the harbour is generally stony and backed by low cliffs of glacial drift. At Woodstown there is a sandy beach, now much influenced by recreation pressure and erosion. Behind it a lagoonal marsh has been impounded which runs westwards from Gaultiere Lodge along the course of a slow stream. An extensive reedbed occurs here. For inspection purposes only. At the edges is a tall fen dominatedConsent of copyrightby sedges owner required(Carex for any spp.), other use. Meadowsweet, Willowherb (Epilobium spp.) and rushes (Juncus spp.). Wet woodland also occurs. This area supports populations of typical waterbirds including Mallard, Snipe, Sedge Warbler and Water Rail.

The dunes which fringe the strand at Duncannon are dominated by Marram grass (Ammophila arenaria) towards the sea. Other species present include Wild Sage (Salvia verbenaca), a rare Red Data Book species. The rocks around Duncannon ford have a rich flora of seaweeds typical of a moderately exposed shore and the cliffs themselves support a number of coastal species on ledges, including Thrift (Armeria maritima), Rock Samphire (Crithmum maritimum) and Buck's-horn Plantain (Plantago coronopus).

Other habitats which occur throughout the site include wet grassland, marsh, reed swamp, improved grassland, arable land, quarries, coniferous plantations, deciduous woodland, scrub and ponds.

Seventeen Red Data Book plant species have been recorded within the site, most in the recent past. These are Killarney Fern (Trichomanes speciosum), Divided Sedge (Carex divisa), Clustered Clover (Trifolium glomeratum), Basil Thyme (Acinos arvensis), Hemp nettle (Galeopsis angustifolia), Borrer’s Saltmarsh Grass (Puccinellia fasiculata),

EPA Export 26-07-2012:23:56:2826-05-2014:23:41:29 Meadow Barley (Hordeum secalinum), Opposite-leaved Pondweed (Groenlandia densa), Autumn Crocus (Colchicum autumnale), Wild Sage (Salvia verbenaca), Nettle-leaved Bellflower (Campanula trachelium), Saw-wort (Serratula tinctoria), Bird Cherry (Prunus padus), Blue Fleabane (Erigeron acer), Fly Orchid (Ophrys insectifera), Broomrape (Orobanche hederae) and Greater Broomrape (Orobanche rapum-genistae). Of these the first nine are protected under the Flora Protection Order 1999. Divided Sedge (Carex divisa) was thought to be extinct but has been found in a few locations in the site since 1990. In addition plants which do not have a very wide distribution in the country are found in the site including Thin-spiked Wood-sedge (Carex strigosa), Field Garlic (Allium oleraceum) and Summer Snowflake (Leucojum aestivum). Six rare lichens, indicators of ancient woodland, are found including Lobaria laetevirens and L. pulmonaria. The rare moss Leucodon sciuroides also occurs.

The site is very important for the presence of a number of EU Habitats Directive Annex II animal species including Freshwater Pearl Mussel (Margaritifera margaritifera and M. m. durrovensis), Freshwater Crayfish (Austropotamobius pallipes), Salmon (Salmo salar), Twaite Shad (Alosa fallax fallax), three Lamprey species - Sea (Petromyzon marinus), Brook (Lampetra planeri) and River (Lampetra fluviatilis), the marsh snail Vertigo moulinsiana and Otter (Lutra lutra). This is the only site in the world for the hard water form of the Pearl Mussel M. m. durrovensis and one of only a handful of spawning grounds in the country for Twaite Shad. The freshwater stretches of the River Nore main channel is a designated salmonid river. The Barrow/Nore is mainly a grilse fishery though spring salmon fishing is good in the vicinity of Thomastown and Inistioge on the Nore. The upper stretches of the Barrow and Nore, particularly the Owenass River, are very important for spawning.

The site supports many other important animal species. Those which are listed in the Irish Red Data Book include Daubenton’s Bat (Myotis daubentoni), Badger (Meles meles), Irish Hare (Lepus timidus hibernicus) and Frog (Rana temporaria). The rare Red Data Book fish species Smelt (Osmerus eperlanus) occurs in estuarine stretches of the For inspection purposes only. site. In addition to the FreshwaterConsent ofPearl copyright Mussel, owner required the for site any other also use. supports two other freshwater Mussel species, Anodonta anatina and A. cygnea.

The site is of ornithological importance for a number of E.U. Birds Directive Annex I species including Greenland White-fronted Goose, Whooper Swan, Bewick’s Swan, Bar- tailed Godwit, Peregrine and Kingfisher. Nationally important numbers of Golden Plover and Bar-tailed Godwit are found during the winter. Wintering flocks of migratory birds are seen in Shanahoe Marsh and the Curragh and Goul Marsh, both in Co. Laois and also along the Barrow Estuary in Waterford Harbour. There is also an extensive autumnal roosting site in the reedbeds of the Barrow Estuary used by Swallows before they leave the country.

Landuse at the site consists mainly of agricultural activities – many intensive, principally grazing and silage production. Slurry is spread over much of this area. Arable crops are also grown. The spreading of slurry and fertiliser poses a threat to the water quality of the salmonid river and to the populations of Habitats Directive Annex II animal species within the site. Many of the woodlands along the rivers belong to old estates and support many non-native species. Little active woodland management occurs. Fishing is a main tourist attraction along stretches of the main rivers and their tributaries and there are a number of Angler Associations, some with a number of beats. Fishing stands and styles

EPA Export 26-07-2012:23:56:2826-05-2014:23:41:29 have been erected in places. Both commercial and leisure fishing takes place on the rivers. There is net fishing in the estuary and a mussel bed also. Other recreational activities such as boating, golfing and walking, particularly along the Barrow towpath are also popular. There is a golf course on the banks of the Nore at Mount Juliet and GAA pitches on the banks at Inistioge and Thomastown. There are active and disused sand and gravel pits throughout the site. Several industrial developments, which discharge into the river, border the site. New Ross is an important shipping port. Shipping to and from Waterford and Belview ports also passes through the estuary.

The main threats to the site and current damaging activities include high inputs of nutrients into the river system from agricultural run-off and several sewage plants, overgrazing within the woodland areas, and invasion by non-native species, for example Cherry Laurel and Rhododendron (Rhododendron ponticum). The water quality of the site remains vulnerable. Good quality water is necessary to maintain the populations of the Annex II animal species listed above. Good quality is dependent on controlling fertilisation of the grasslands, particularly along the Nore. It also requires that sewage be properly treated before discharge. Drainage activities in the catchment can lead to flash floods which can damage the many Annex II species present. Capital and maintenance dredging within the lower reaches of the system pose a threat to migrating fish species such as lamprey and shad. Land reclamation also poses a threat to the salt meadows and the populations of legally protected species therein.

Overall, the site is of considerable conservation significance for the occurrence of good examples of habitats and of populations of plant and animal species that are listed on Annexes I and II of the E.U. Habitats Directive respectively. Furthermore it is of high conservation value for the populations of bird species that use it. The occurrence of several Red Data Book plant species including three rare plants in the salt meadows and the population of the hard water form of the Pearl Mussel which is limited to a 10 km stretch of the Nore, add further interest to this site.

For inspection purposes only. 6.10.2006 Consent of copyright owner required for any other use.

EPA Export 26-07-2012:23:56:2826-05-2014:23:41:29 SITE SYNOPSIS

SITE NAME: BUNARUDDEE BOG

SITE CODE: 001352

Bunaruddee Bog NHA is situated approximately 4 km west of Moyvane in the townlands of Bunaruddee, Leitrim West and Lamore, Co. Kerry. The site comprises a raised bog that includes both areas of high bog and cutover bog. The site is surrounded by streams to the east and west and a river to the south.

The site consists of a Western Raised Bog, which has developed on a floodplain of the Galey River. It supports a range of characteristic species of bogs including western indicator species and lichens. The southern section of the bog is the most intact. There was a small central quaking area, with hummock/hollow complexes but no pools, which has been more actively cut and drained since the last survey. The bog had a good compliment of Sphagnum species.

Much of the high bog has vegetation typical of a Western Raised Bog. The high bog is dominated by Ling Heather ( Calluna vulgaris ), Cottongrass ( Eriophorum angustifolium and Eriophorum vaginatum ) with abundant Bog Mrytle ( Myrica gale ). There is a good layer of bog moss growing underneath the Ling Heather. Bunnaruddee Bog also supports a good cover of Lichen ( Cladonia spp.) as it has not been burnt in a while. Western indicators present on the bog include Carnation Sedge (Carex panicea ), Lousewort ( Pedicularis sylvatica ), the moss Racomitrium lanuginosum and the liverwort Pleurozia purpurea . The wet central area with quaking bog and hummock/hollow complexes prior to being developed for peat cutting supported Sphagnum cuspidatum in the hollows with frequent Sphagnum For inspection purposes only. imbricatum hummocks. OtherConsent species of copyright of owner interest required recorded for any other use. on the high bog include Great Sundew ( Drosera anglica ), Cranberry (Vaccinium oxycoccos ) and seven species of Sphagnum including Sphagnum subnitens and S. tenellum.

The cutover supports a range of habitats including humid grasslands, improved grassland, forestry, old peat-cutting and active peat-cutting. There are extensive areas of humid grassland with Purple Moor-grass ( Molinia caerulea ) to the north, west and north-east. In places, cutover supports Ling Heather.

Current landuse on the site comprise active peat-cutting on all margins. Areas of cutover have been reclaimed for agricultural purposes to the south, east, west and north of the site. There is a small conifer plantation on the eastern margin of the high bog. Damaging activities associated with these landuses include drainage and burning of the high bog. These are all activities that have resulted in loss of habitat and damage to the hydrological status of the site, and pose a continuing threat to its viability.

Bunaruddee Bog NHA is a site of considerable conservation significance comprising as it does a raised bog, a rare habitat in the E.U. and one that is becoming increasingly scarce and under threat in Ireland. This site supports a diversity of raised bog microhabitats, including hummock/hollow complexes, as well as a number of scarce

EPA Export 26-07-2012:23:56:2826-05-2014:23:41:29 plant species. The bog is located in Kerry in the south-west extreme of the geographical range of raised bog habitat in Ireland. Ireland has a high proportion of the total E.U. resource of this habitat type (over 50%) and so has a special responsibility for its conservation at an international level.

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15.11.2002

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Appendix 1 Site Synopsis

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Appendix 2- Figures

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EPA Export 26-07-2012:23:56:2826-05-2014:23:41:29 Legend

Site Location N

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Date Issue no. Date By Checked Approved Note Ref Scanned

environmental health and safety engineering project management Montgomery EHS, 2 Beechwood Gardens, Newcastle west, Co. Limerick Tel: 353 (0)6966796 Email: [email protected]

Client Brandon Products Title Figure 1 - Location

Project No. Scale. 1:50,000 P011 016 Figure No. Rev. A EPAP012 Export-009A 26-07-2012:23:56:2826-05-2014:23:41:29 Legend

Site Location N

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Date Issue no. Date By Checked Approved Note Ref Scanned

environmental health and safety engineering project management Montgomery EHS, 2 Beechwood Gardens, Newcastle west, Co. Limerick Tel: 353 (0)6966796 Email: [email protected]

Client Brandon Products Title Figure 2 - Location

Project No. Scale. 1:25,000 P011 016 Figure No. Rev. A EPAP012 Export-009B 26-07-2012:23:56:2826-05-2014:23:41:29 Legend

Site Location N

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Date Issue no. Date By Checked Approved Note Ref Scanned

environmental health and safety engineering project management Montgomery EHS, 2 Beechwood Gardens, Newcastle west, Co. Limerick Tel: 353 (0)6966796 Email: [email protected]

Client Brandon Products Title Figure 3 – Aerial Photography

Project No. Scale. 1:5000 P011 016 Figure No. Rev. A EPAP012 Export-009C 26-07-2012:23:56:2826-05-2014:23:41:29 Legend

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Date Issue no. Date By Checked Approved Note Ref Scanned

environmental health and safety engineering project management Montgomery EHS, 2 Beechwood Gardens, Newcastle west, Co. Limerick Tel: 353 (0)6966796 Email: [email protected]

Client Brandon Products Title Figure 4 – SPA Overview

Project No. Scale. 1:50000 P011 016 Figure No. Rev. A EPAP012 Export-009D 26-07-2012:23:56:2826-05-2014:23:41:29 Legend

Site Location N

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Date Issue no. Date By Checked Approved Note Ref Scanned

environmental health and safety engineering project management Montgomery EHS, 2 Beechwood Gardens, Newcastle west, Co. Limerick Tel: 353 (0)6966796 Email: [email protected]

Client Brandon Products Title Figure 5 – Designations Maps

Project No. Scale. 1:5000 P010 016 Figure No. Rev. A EPAP012 Export-09E 26-07-2012:23:56:2826-05-2014:23:41:29 Legend

Site Location N

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Date Issue no. Date By Checked Approved Note Ref Scanned

environmental health and safety engineering project management Montgomery EHS, 2 Beechwood Gardens, Newcastle west, Co. Limerick Tel: 353 (0)6966796 Email: [email protected]

Client Brandon Products Title Figure 6 – Designations Maps

Project No. Scale. 1:25,000 P010 016 Figure No. Rev. A EPAP012 Export-09F 26-07-2012:23:56:2826-05-2014:23:41:29

Attachment 2 Best Available Technologies (BAT) Assessment

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Brandon Products Ltd

BAT Assessment

May 2012 For inspection purposes only. Consent of copyright owner required for any other use.

Montgomery EHS 2 Beechwood Gardens Newcastle West. Co. Limerick

Tel: 069 66796 Mob 087 239 0421 Email: [email protected]

EPA Export 26-07-2012:23:56:2826-05-2014:23:41:29 Brandon Products Ltd, Kilcolman, Asdee, Co. Kerry

BAT Assessment

Disclaimer

Montgomery EHS & Brandon Products Ireland Ltd accepts no liability or responsibility whatsoever in respect of any use of or reliance upon all or part of this Document by any third party.

For inspection purposes only. Document No. P012-012-02 Consent of copyright owner required for any other use.

Rev MEHS Description Origin Review Changes/Amendments Date Approval

1 Draft report TM MM TM 28/04/12 Review document 2 Draft 2 TM MM TM 01/05/12 Review document 3 Re-Issue TM MM TM 25/05/12 Final Document 4 Final TM MM TM 13/06/12

Montgomery EHS, Registered 2 Beechwood Gardens, Newcastle West, Co Limerick Tel: 069 66796 Email: [email protected]

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Brandon Products Ltd, Kilcolman, Asdee, Co. Kerry

BAT Assessment

May 2012

Contents

1.0 INTRODUCTION ...... 4

1.1 Overview of BAT ...... 4 1.2 BAT Guidance Note ...... 6 1.3 Scope of Work ...... 6

2.0 BAT ASSESSMENT TABLES ...... 8

3.0 SPECIFIC POINTS OF BAT DISCUSSION ...... 24 3.1. Environmental Management ...... 24

4.0 CONCLUSIONS ...... 24

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1.0 INTRODUCTION

Brandon Products Ltd has applied for an Integrated Pollution Prevention and Control License (IPPC) from the Environmental Protection Agency (EPA, the Agency) for the “The production of phosphorus-based, nitrogen-based or potassium-based fertilisers (simple or compound fertilizers)” on the 24th of January 2012, (Reg. No. P0957-01).

The application is required following the enactment of the Protection of the Environment Act 2003 (No. 27 of 2003) providing for Implementation of Directive 96/61/EC concerning Integrated Pollution Prevention and Control (IPPC). As a result, Brandon Products compiled an IPPC License application. The application register number with the EPA for this license application is P0957-01. As part the new IPPC License application form, Environmental Considerations and Best Available Techniques (BAT) is required under Section I.8. This report is designed to reflect the BAT assessment requirements of Section I.8 and the agency request.

The Agency requested the following:

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1.1 Overview of BAT

BAT was introduced as a key principle in the IPPC Directive, 96/61/EC. This Directive has been incorporated into Irish law by the Protection of the Environment Act 2003. To meet the requirements of this Directive, relevant Sections of the Environmental Protection Agency Act 1992 and the Waste Management Act 1996 have been amended to replace BATNEEC (Best Available Technology not Entailing Excessive Costs) with BAT.

BAT is defined in Section 7 of the Protection of the Environment Acts 2003 and Section 5(2) of the Waste Management Acts 1996 to 2005 as the “most effective and advanced stage in the development of an activity and its methods of operation, which indicate the practical suitability of particular techniques for providing, in principle, the basis for emission limit values designed to

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prevent or eliminate or, where that is not practicable, generally to reduce an emission and its impact on the environment as a whole”, where: B ‘best’ in relation to techniques, means the most effective in achieving a high general level of protection of the environment as a whole A ‘available techniques’ means those techniques developed on a scale which allows implementation in the relevant class of activity under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced within the state, as long as they are reasonably accessible to the person carrying on the activity. T ‘techniques’ includes both the technolog used and the wa in which the installation is designed, built, managed, maintained, operated and decommissioned At the facility/installation level, the most appropriate techniques will depend on local factors. A local assessment of the costs and benefits of the available options may be needed to establish the best option.

BAT to be employed:  The technical characteristics of the facility;  Its geographical location;  Local environmental considerations;  The economic and technical viability of upgrading existing installations.

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The overall objective of ensuring a high level of protection for the environment as a whole will often involve making a judgement between different types of environmental impact, and these judgements will often be influenced by local considerations. On the other hand, the obligation to ensure a high level of environmental protection including the minimisation of long-distance or transboundary pollution implies that the most appropriate techniques cannot be set on the basis of purely local considerations. The guidance issued in this note in respect of the use of any technology, technique or standard does not preclude the use of any other similar technology, techniques or standard that may achieve the required emission standards and is demonstrated to the Agency to satisfy the requirement of BAT.

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1.2 BAT Guidance Note

The EPA is currently in the process of drafting BAT guidance notes designed to provide guidance to those applying for licenses. The objective of these BAT notes is to identify the types of techniques that will be used by the EPA to define BAT for an activity. There is no BAT guidance note on Best Available Techniques for the production of phosphorus-based, nitrogen-based or potassium-based fertilizers (simple or compound fertilizers). The EU Best Available Techniques Reference Document (BREF) on Large Volume Inorganic Chemicals - Ammonia, Acids & Fertilizers (12.06) is the only document with is close to the license sector.

1.3 Scope of Work

For the BAT Assessment work was undertaken as a series of tasks as follows: Task 1: Review of existing BAT Reference documents that are relevant to the Brandon Products including the existing IPPC application licence (Reg. No. P0957-01). Task 2: Prepare BAT Assessment Report.

The above tasks may be further detailed as follows. Task 1: Review of Relevant BAT Information Montgomery EHS reviewed published BAT Reference Documents that are relevant to the Brandon Products such as; For inspection purposes only. Consent of copyright owner required for any other use. • BAT Guidance Note for the General Inorganic & Alumina Sector • BAT Guidance Note for the Organic Chemical Sector • BAT Guidance Note Pesticides, Pharmaceuticals & Speciality Organic Chemicals Sector

The pan-European BAT Reference (BREF) documents including; o BREF on Large Volume Inorganic Chemicals - Ammonia, Acids & Fertilisers (12.06) o The common Waste Water and Waste Gas Treatment / Management Systems in the Chemical Sector, • IPPC licence application information, • Other information that Montgomery EHS has gained from Brandon Products project work to date.

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Task 2: Prepare BAT Assessment Report. Montgomery EHS have prepared this draft BAT assessment report, identifying compliance with BAT based on the information obtained in Tasks 1. The assessment is presented in Sections 4 and 5 of this report. Montgomery EHS utilised, a tabular style approach, designed to facilitate easy comparison and to reduce the report wordage as follows: • The bulk of the detailed assessment work is presented in tables in Section 4 of this report; • Some discussion is presented in Section 5 of this report on specific points where elaboration is required and where that discussion point encompasses several subject areas re: BAT. This section also covers other areas for BAT consideration not readily formatted in the BAT tables, namely: o Environmental Management Systems. • Montgomery EHS have included detailed activity descriptions only where necessary in the context of identifying and assessing BAT. Montgomery EHS has excluded any detailed impact assessments and monitoring or analysis in the event of describing BAT deviation or where techniques identified are not considered BAT. Montgomery EHS have instead relied on information and data readily available from Brandon Products records.

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2.0 BAT ASSESSMENT TABLES

The BAT Assessment tables as set out below are divided into a number of different categories, specifically; • Process • Emissions to Water • Emissions to Air • Materials Handling & Storage • Energy

The BAT Assessment tables are structured as follows: • Each categor has a number of specific ‘topics’ (e g , Process topics include ‘plant design’ and ‘process control’) • Column 1 (Questions) a mix of closed and open questions on each topic are presented in order to obtain the information necessary to assess the level of BAT on site for each topic. • Column 2: (Techniques Observed). For each question, this is effectively an answer and with answers as closely as practicable linked to the BAT guidance (Column 3). • Column 3 (BAT Guidance): This is the BAT guidance as set out in guidance indicated in Section 2 above and, relating to emission limit values, BATNEEC, for the fertiliser industry (as no BAT has been developed). It should be noted that not all BAT For inspection purposes only. guidance is applicable,Consent depending of copyright owner on required the forprocess any other use.techniques and plant technology

employed. However, Montgomery EHS has excluded that non-applicable BAT guidance where possible. • Column 4 (BAT, yes or no): Here, the technique observed in Column 2 is considered BAT if it meets, exceeds or is an alternative to the BAT guidance presented in Column 3. If what has been observed is an alternative meeting the designed objective of the BAT guidance, then comments or justification for deviation from the exact BAT guidance is presented in Column 5. This latter column also may contain notes to further explain aspects of BAT.

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Table 2.1 BAT Assessment of Process

QUESTIONS - TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ PROCESS (Y/N) COMMENTS Topic – Plant Design Do you have a Brandon Products Management programmes targets the Maximise process efficiency Y procedure for the reduction in water, energy and use of raw materials and Minimise use of chemicals introduction of new progress is tracked with these projects and updates will be Avoid the use of auxiliary processes and is it given as part of the AER each year. substances utilised? What does it cover? New processes are brought through the project evaluation Minimise energy requirements system. This system is aligned with the Project evaluation Use renewable feedstock rather for control of capital projects on site. than depleting, wherever technically and economically practicable (seaweed) The liquid and gaseous streams from the site Choose substances so as to project/modification are assessed for suitability with the minimise the potential for Brandon Products waste treatment facilities (scrubbers, accidents, releases and fires waste water treatment). Options to reduce waste or raw materials Brandon Products examine options to eliminate and/or For inspection purposes only. reduce the need to use chemicalConsent of and copyright redu ownerce required raw for m anyate otherrial use. requirements.

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QUESTIONS - TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATIO PROCESS (Y/N) N/ COMMENTS Cooling Brandon Products uses cooling water for production Use cooling techniques where Y system cooling. The cooling towers are closed cooling systems possible and closed loop. design? for the extraction vessels, evaporation and other cooling requirements.

Brandon Products has an ambient cooling circuit using a closed loop cooling tower water re-circulation and fresh water top-up to compensate for cooling tower purges and evaporation.

Has there been Brandon Products has maximised, where possible and Minimise pumping and Y consideration to especially with production buildings, the gravity maximise gravity flow maximise gravity transfer of process materials within the process. flow?

Topic – Process Safety and Process Control

What sorts of Process Brandon Products utilises manual Forand inspection Prog purposesramm only.able Logic Use a modern process Y Consent of copyright owner required for any other use. Control Systems are Control (PLC) where appropriate. control system to enable a employed? high degree of automation and ensure a stable and efficient operation, i.e. boiler

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QUESTIONS - TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ PROCESS (Y/N) COMMENTS

Process Safety The identification of hazards (hazardous processes, tasks or BAT is to carry out a Y Programme and equipment) and the minimisation of risk (determination of structured safety assessment Procedures? the level of control required) is central to the safe operation for normal operation and to Designed into of the site. take into account the effects Process Design of potential deviations in the criteria? An important part of this procedure is a Process Hazard chemical process and Study, covering (depending on the process change): operation of the plant and to carry out required training. • Initial Chemical Assessment (Containment Strategy) • Chemical Reaction Hazard Assessment. BAT is to apply one or a • Preliminary Hazard Analysis combination of the • Risk Assessment following techniques to • Safety Walk downs ensure the process is • Compilation of a Basis of Environmental Health and adequately controlled: Safety Report. Organisational measures Any changes identified as a result of any of the above • Engineering controls studies are incorporated where appropriate, for example at • Reaction stoppers preliminary design stage or detailed design stage and when (e.g. quenching)

the process change has been appro Forve inspectiond (e.g. purposes, issu inonly.g revised • Emergency cooling Material Safety Data Sheets Consentand u ofp copyrightdating owner Batc requiredh R foreco anyr dother use. • Pressure resistant Books). construction • Pressure relief. Actual process safety engineering measures also result from the above assessment and may include, where appropriate:

• Emergency cooling; • Pressure relief; • Overpressure design in vessels (pressure resistant construction); • Process shut-down.

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QUESTIONS - BAT TECHNIQUE OBSERVED BAT GUIDANCE JUSTIFICATION/ PROCESS (Y/N) COMMENTS

Topic – Process Maintenance

What maintenance Brandon Products utilises a Preventative BAT is to put in place a Y procedures or system Maintenance Programme which is simple in monitoring and are in place? design but effective. The system ensures that the maintenance programme required maintenance is carried out as scheduled. that: • Is structured and Maintenance and calibration frequencies for allows for failure equipment are based on plant and criticality. modes of equipment; • Can allow diagnostic testing where appropriate; • Facilitates adequate record Topic – Trainingk eeping; • Is properly planned.

Is training provided Production personnel are trained in every facet of Provide sufficient training Y on processes to the operating plant and a r e s pe c Forifi inspectioncally tpurposesraine donly. on Consent of copyright owner required for any other use. production teams? specific products.

Record Books are used to guide the operator through the manufacturing of a process and will contain information on safety or environmental critical steps.

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Table 2.2 BAT Assessment of Emissions to Sewer and/or Water

QUESTIONS – EMISSIONS TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ TWOA TER (Y/N) COMMENTS Topic – Collection Systems

Are Separate Collection systems There are separate collection systems Process water is segregated Y available for process emissions as follows: from uncontaminated and storm water emissions? 1. Process (aqueous waste) rainwater and other wastewater; uncontaminated water 2. Domestic wastewater; releases. 3. Surface water process effluent drainage system for The rear yard surface water is potentially contaminated recovered as feed water for areas; use in the process as the site 4. Surface water drainage system is a net consumer of water. for non-contaminated areas.

This minimises the amount of water requiring treatment and the hydraulic load sent to the treatment facilities. The site For inspection purposes only. Consent of copyright owner required for any otherhas use. no discharge of surface water from the rear yard. The site has a package sewage treatment plant for the treatment of domestic effluent.

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Table 2.3 BAT Assessment of Emissions to Air

QUESTIONS – TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ EMISSIONS TO AIR (Y/N) COMMENTS Topic –Minimisation of Exhaust Gas Volume and Flow Rate

Properly sealed Process trains are sealed to eliminate the egress of BAT is to close any Y All extraction vessels, process vessels odours from the connected vent header systems. unnecessary openings in process tanks connected to and other vessels order to prevent air being the cooking process are to minimise Reactors and other vessels are pressure rated for sucked to the gas collection sealed with cooling ingress of air? both overpressure and under-pressure (vacuum). system via the process provided in some cases to Regular leak testing is carried out on vessels as per equipment. reduce the volume of gases the preventative maintenance schedule. and vapours. The cooling BAT is to ensure the air also condenses moisture tightness of process from the air stream thereby equipment, especially of reducing the loading on the vessels. bio-scrubber. The moisture is returned to the process.

Pressure checks and leak For inspection purposes only. Consent of copyright owner required for any other use. checks are conducted in order to minimise risk of odours.

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Topic – Treatment of Process Wastewater What type of on-site There is a biological (activated sludge) BAT is to treat effluents Treated domestic treatment is wastewater treatment plant on the Brandon containing a relevant organic Y wastewater from the available for process Site for domestic effluent. load, such as aqueous wastewater treatment wastewaters during residues from production plant discharges for production? The 2 spent water tanks are used to contain all processes, in a biological additional treatment to process wastewater from the process. This spent treatment plant. percolation area water is re-used in the process. avoiding any odours.

The condensate from the evaporation process is used All vapours from the as boiler feed water as the temperature of the spent water tanks are o condensate is > 70 C. extracted and treated by the Bio-Scrubber

All process wastewater and condensate is recycled. The process is a net consumer of water there by reducing boiler fuel and reducing For inspection purposes only. Consent of copyright owner required for any other use. volume of air emitted.

Condenser A range of condenser designs are employed and BAT is to minimise the Y The site has four cooling system design? are industry standard units (such as Shell & Tube). exhaust gas volume flows tower systems for from extraction vessels extraction vessels, product and the evaporator by cooling, evaporation, etc. condensing as much of the The cooling systems are vapours as possible. capable of dealing with a large range of process duties.

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QUESTIONS – BAT JUSTIFICATION/ EMISSIONS TO TECHNIQUE OBSERVED BAT GUIDANCE AIR (Y/N) COMMENTS Topic – Gaseous emissions abatement

For inspection purposes only. Consent of copyright owner required for any other use.

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What abatement Centralised gaseous emissions treatment is carried BAT is the application of Y The provision of significant system is used? out on the Brandon Products site. Detail on the various recovery or abatement cooling to the process abatement systems employed has been provided in techniques singly or in reduces the temperature that Attachment E.1 of the Licence Application form combination to achieve the the product is processed at, (IPPC Application Register number P0957-01). required emission limit this reduces the loading on values. the bio-scrubber. In summary, individual emissions are gathered in central duct from where they are directed to the Bio- The Bio-scrubber has a scrubbers. retention time of 8 seconds and this is

accepted to be sufficient Brandon Products utilises primary and secondary to remove acidic odorous condensation, often in series, as required by the gases present in the process and the cooling towers. process air stream from the plant.

The normal requirement would be 2 seconds.

An additional aeration tank has been added in For inspection purposes only. Consent of copyright owner required for any other use. order to reduce COD, Ammonia, TKN, etc.

Smoke testing has been employed on the site in order to improve the integrity of the site buildings.

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Table 2.4 BAT Assessment of Materials Handling & Storage

QUESTIONS – MATERIALS TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ HANDLING AND STORAGE (Y/N) COMMENTS Topic – Designated Areas Is loading and unloading carried Drums: Loading and unloading is carried Carry out loading and out only in designated areas? out in designated storage areas. unloading only in designated areas protected against Y Are the designated areas for Loading and unloading is carried out on leakage and run-off. loading and unloading concrete surfaces. protected against leakage run- off? The designated loading areas are protected with sumps and/or gullies that can be diverted to the process effluent drainage systems.

Designate specific areas for

Are materials awaiting disposal As above For inspection purposes only. storage and collection of Y Consent of copyright owner required for any other use. stored and collected in designated materials awaiting disposal. areas? Are the areas designated for Review the implications of storage and collection of materials leakage run-off from areas awaiting disposal protected against designated for storage and leakage run-off? collection of materials awaiting disposal, upgrade hard- standing, bunding and run-off drainage/containment as appropriate.

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QUESTIONS – BAT JUSTIFICATION/ MATERIALS TECHNIQUE OBSERVED BAT GUIDANCE HANDLING AND (Y/N) COMMENTS STORAGE

Topic – Testing and Inspection of Bunds / Tanks and Pipelines

Are there established There is a requirement from the IPPC Licence to Establish programmes for N A programme will be procedures for testing test all underground lines every 3 years. Brandon testing and inspection of tanks established to test all drums and inspection of Products will maintain a three year rolling drain and pipelines where tanks and as part of the IPPC license tanks and pipelines testing programme as required by the IPPC pipes are not situated in requirements situated outside licence. bunded areas. bunded areas?

Are inspections There is licence requirement to visually inspect Inspect leaks on flanges Y carried out and pipelines that carry materials other than water for and valves on pipes used logged for leaks on leaks where those pipelines are not provided with to transport materials flanges and valves on leak collection. inspection or testing with pipes used to water and maintain a log transport materials of such inspections other than water? For inspection purposes only. Consent of copyright owner required for any other use.

Are supply Spill kits materials are available at designated Provide supply containment Y containment booms areas around the site. booms and suitable and suitable absorbent material. absorbent material provided?

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QUESTIONS – BAT JUSTIFICATION/ MATERIALS TECHNIQUE OBSERVED BAT GUIDANCE HANDLING AND (Y/N) COMMENTS STORAGE

Are bunded There is a requirement to test all bunds on a three The site will conduct an Y It is anticipated that the structures tested? year cycle. integrity test of all bunded IPPC licence will require

structures every 3 years. that all bunds are integrity There is also a Brandon Products requirement to Documenting the procedure tested on a periodic basis. ensure that the bunds are fit for use. for establishing and maintaining a test log, training appropriate personnel in its use and allocating staff time and responsibilities for carrying out the testing is currently in development.

For inspection purposes only. Consent of copyright owner required for any other use.

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Table 2.5 BAT Assessment of Energy Consumption

QUESTIONS – ENERGY BAT JUSTIFICATION/ TECHNIQUE OBSERVED BAT GUIDANCE CONSUMPTION (Y/N) COMMENTS Topic – Energy Management and Monitoring

Does the company have an There is a written and signed As a whole improving Y energy management policy? Environment Policy that includes an energy efficiency includes energy conservation guideline. This many different types of Has an energy policy been guideline requires assessment of energy measures, which are to be written and published? users and an improvement process to carried out in the right order achieve energy reductions. to get best results and avoid sub optimisation. First, the focus is to be on the

Do the energy policy and The Environmental Policy is signed by the products and their energy Y efficiency initiatives have senior MD, with sufficient resources allocated to demand and after that how management endorsement and ensure the policy is implemented. to produce them in the most demonstrable support? energy efficient way. To avoid sub-optimisation, For inspection purposes only. Consent of copyright owner required for any otherbes use.t practice is to: Are energy management These will be incorporated into the 1 - implement energy saving Y techniques incorporated within environmental management system measures in the following the requirements of an overall and progress in targets tracked order: environmental management through the Environmental (a) implement process related system (EMS)? Management Programme (EMP). measures that decrease energy demand (b) manage utilities (c) re-use of energy

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QUESTIONS – ENERGY TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ C CONSUMPTION (Y/N) COMMENTS O In line with the IPPC NDoes the EMS include Energy Management comes under the 2 - carry out a Y license requirements a EMS Sclear accountability for Operations Director and his team comprehensive energy will be established Uenergy management? audit using top-down and bottom up approaches M combining: The EMS to be established PAre systems in place for Energy monitored as part of monthly Y (a) First identify will include energy Tcontinuous monitoring and costs. opportunities of energy monitoring. Iassessment of energy use within saving in units/processes, e.g. Othe installation? N energy Improvement targets and tracking Y Does the system enable the completion on these targets is carried out The EMS to be established through the EMP collection, analysis and reporting will include energy targets, of data relating to energy water usage, waste performance as well as the generation and evaluation setting, review and revision of of equipment faults. For inspection purposes only. energy performance targets? Consent of copyright owner required for any other use.

Does the system identify areas of energy wastage?

Does the system highlight exceptions to normal performance?

Does the system evaluate the impact of energy saving actions or of faults in equipment?

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JUSTIFICATION/ QUESTIONS – ENERGY TECHNIQUE OBSERVED BAT GUIDANCE BAT COMMENTS

Is staff training in their energy Training is carried out for relevant Y The EMS to be established management responsibilities personnel on energy conservation. will include training of all maintained? personnel.

Does the system include setting The EMS to be established realistic targets for improvement? will include targets on energy, water, waste, extraction rates, etc, and equipment availability Monthly meetings are held Are energy-saving ideas from Energy awareness will be organised on Y and will include Safety, staff actively encouraged? the site on a regular basis. environment, quality, etc Can staff implement changes Energy saving ideas will be encouraged The use of the monthly themselves where appropriate? through poster campaigns and quizzes. meetings will examine

(Once health and safety and options for business Changes to equipment operation or business risks have been improvement. design are led through the operations assessed) director. For inspection purposes only. Consent of copyright owner required for any other use.

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QUESTIONS – ENERGY TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ CONSUMPTION (Y/N) COMMENTS

Has the total and specific energy Through the monthly costs the energy Y Energy audit will be produced been assessed, costs can be seen easily and targeted for conducted on the Brandon including a breakdown by reduction. Products production facility energy source? Brandon Products will carry out an energy audit using qualified external consultants. This audit will look at mainly technical aspects of energy usage and monitoring and also energy management. The audit will provide recommendations for improvement, mainly specific technical improvements. These recommendations will be considered in the setting of targets and projects at Brandon Projects.

For inspection purposes only. Consent of copyright owner required for any other use.

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QUESTIONS – ENERGY TECHNIQUE OBSERVED BAT GUIDANCE BAT JUSTIFICATION/ CONSUMPTION (Y/N) COMMENTS Topic – Heat Recovery Is the facility utilising any Condensate from the evaporation process Best Practice with regard Energy audit will be specific heat recovery is used as feed water for the boilers. to heat recovery is to: Y conducted on the Brandon operations at the site? 1. Identify all possibilities Products production facility within the company and What is company policy in co-operate with other relation to heat recovery? companies, 2. Carry out a comprehensive energy audit. 3. Optimise the utilisation of different energy flows by recovering energy.

For inspection purposes only. Consent of copyright owner required for any other use.

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3.0 SPECIFIC POINTS OF BAT DISCUSSION

3.1. Environmental Management

In accordance with the proposed IPPC Licence that Brandon Products will be issued with, it will established and continue to maintain an Environmental Management System. This meets the requirements of BAT.

A notable aspect of the proposed Brandon Products environmental management is the implementation of policies and guidelines. Topics covered include:

• Management of Change; • Resource conservation; • Release Reduction; • Waste minimisation; • Water conservation; • Energy Conservation.

4.0 CONCLUSIONS

Montgomery EHS was commissioned to undertake a BAT assessment of the Brandon Products production facilities located on Kilcoman, Asdee, Co. Kerry. The BAT assessment was undertaken with a view towards the implementation of a proposed IPPC license covering the production operation For inspection at purposesBrandon only. Products. Consent of copyright owner required for any other use.

In general, there is a high degree of BAT implemented at Brandon Products in the context of an existing installation (as against a new installation). Particular aspects of the implementation of BAT at Brandon Products:

1. The very good degree of process control at Brandon Products;

2. The implementation of an Environmental Management Systems, which includes an Environmental Policy and Environmental Management Programme.

3. The requirement to adhere to a number of standards on a range of BAT related subjects (e.g., waste minimisation). All system of internal audits will be implemented extensively against these standards;

4. The adoption of centralised bio-scrubber abatement.

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5. Brandon Products will incorporate a detailed change control procedure that requires an environmental review and which identifies opportunities for raw materials usage efficiency;

6. Brandon Products has in place waste management requirements that allows only approved waste management companies manage waste on behalf of Brandon Products;

7. Drainage systems are segregated such that the volumes of domestic wastewater being sent for on-site wastewater treatment are very low and Brandon Products continues to seek opportunities to reduce this wastewater loading. The site is a significant net consumer of water and all the rain water, drain down, etc. in the rear yard is returned to the process via the spent water tanks.

8. Extensive chemical composition and odour sampling have been conducted on the Bio-Scrubber (by Catalyst Environmental and Odour Net Ireland) and these results show that the levels of odorous compounds exiting the bio-scrubber are below the discharge limits for rendering or animal slaughtering odour abatement equipment such as bio-filters or bio-scrubbers. The odour modelling conducted shows that the levels of odours at the residential dwellings are low, < 1.5 Ou/m3. The Bio-scrubber is a wet scrubber that removes gaseous and particulate pollutants; the absorption is dependent on the solubility of the gas in the liquid. This solubility relationship has been determined by the amount of scrubbing liquid utilized. Once this is set, the keys to obtaining good removal efficiency are: For inspection purposes only. • Provide a largeConsent contact of copyright area ownerbetween required forthe any gas other anduse. liquid • Provide good mixing • Allow adequate residence or contact time between gas and liquid • Keeping the concentration of indicator parameters as low as possible.

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Attachment 3 Updated Non-Technical Summary

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 26-07-2012:23:56:2926-05-2014:23:41:29 Non-Technical Summary of IPC Licence Application

The company commenced operations in 1998 following several years’ research at the Institute of Technology, Tralee. Brandon Products Ltd has been operating at its current site in Kilcoman, Asdee, Co. Kerry since 2008.

Brandon Products Ltd makes a liquid seaweed extract for use in horticulture and amenity grass care markets. The products are sold in a variety of pack sizes through gardens centres and other distributors to the relevant markets. Brandon Products is located on the south side of the Shannon estuary between the village of Asdee and Ballybunnion. Brandon Products site is approximately 0.9 acres. The plant operates a number of different products all centred around seaweed as the primary raw material.

The main energy usage is involved in steam production is in the form of gas oil and electrical energy.

Emissions arising from the site include the waste water arising from toilets, etc. and are treated in a wastewater treatment plant.

Waste materials are collected in dedicated area's and are disposed of by permitted contractors such as cardboard and paper and plastic are segregated after collection and recycled subject to contamination by ingredients.

Air emissions arise from the on-site boiler stack and the bio-scrubber air treatment system. The Bio-scubber has been examined for odour dispersion and the possible installed of a discharge stack.

The design and layout of the facility enables process to operate efficiently with minimal environmental impact. Emphasis has been placed on resource usage efficiency and waste minimisation and improved recycling. An Environmental Management Programme is being prepared in line with general requirements For inspection of IPPC purposes licenses. only. Consent of copyright owner required for any other use.

All personnel have received adequate training and guidance to undertake their work practices in an environmentally acceptable manner. On-going awareness programmes aim to keep personnel aware of environmental issues and waste reduction initiatives

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Attachment 4 Updated Air Dispersion Model

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 26-07-2012:23:56:2926-05-2014:23:41:29 ODOUR & Environmental Engineering Consultants

Unit 32 De Granville Court, Dublin Rd, Trim, Co. Meath

Tel: +353 46 9437922 Fax: +353 46 9483696 Mobile: +353 86 8550401 Mobile: +353 87 6829011 E-mail: [email protected] E-mail: [email protected] www.odourireland.com

ODOUR IMPACT ASSESSMENT OF BRANDON PRODUCTS LTD LOCATED IN KILCOLMAN, ASDEE, CO. KERRY.

PERFORMED BY ODOUR MONITORING IRELAND ON BEHALF OF MONTGOMERY EHS LTD

For inspection purposes only. Consent of copyright owner required for any other use.

PREPARED BY: Dr. Brian Sheridan th DATE: 30 April 2012 REPORT NUMBER: 201250(3) DOCUMENT VERSION: Document Ver. 003 REVIEWERS: Mr. Trevor Montgomery

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TABLE OF CONTENTS

1. Executive Summary...... iii 2. Introduction...... 1

3. Materials and Methods ...... 2 3.1. Odour sampling and analysis...... 2 3.1.1. Odour sampling techniques ...... 2 3.1.2. Olfactometry...... 2 3.1.3. Odour measurement in accordance with the EN13725:2003...... 2 3.1.4. What is an odour unit?...... 2 3.2. Volumetric airflow rate calculation...... 3 3.3. Odour emission rate calculation...... 3 3.4. Dispersion modelling...... 3 3.4.1. Atmospheric dispersion modelling of odours: What is dispersion modelling?...... 3 3.4.2. AERMOD Prime...... 4 3.4.3. Model assumptions...... 4 3.4.4. Odour impact criterion for Brandon Products Ltd bio-scrubbing operations...... 5 3.5. Meteorological data...... 5 3.6. Terrain data...... 6 3.7. Building wake effects ...... 6

4. Results...... 7 4.1. Volumetric airflow rate calculations for Scenario 1 ...... 7 4.2. Odour emission data for Scenarios 1...... 8 4.3. Odour emission rates from Brandon Products Ltd bio-scrubbing operations for atmospheric dispersion modelling Scenario 1...... 8 4.4. Results of odour dispersion modelling for the bio-scrubbing operations located in Brandon Products Ltd facility ...... 9

5. Discussion of results...... 11 5.1. Odour impact from existing facility operations – ref Scenario 1...... 11 For inspection purposes only. 5.2. Odour impact from proposedConsent offacilit copyrighty operations owner required for– reanyf otherScenari use. o 2...... 11 5.3. Odour impact from proposed facility operations – ref Scenario 3...... 11 5.4. Odour impact from proposed facility operations – ref Scenario 4...... 11

6. Conclusions ...... 13

7. Recommendations...... 13

8. Appendix I - Odour dispersion modelling contour results...... 14 8.1. Site layout ...... 14

9. Appendix II – Odour Management plan overview...... 19 9.1. Odour management plan - – Standard practice...... 19

10. References...... 20

11. Appendix III - Meteorological data examined and used in the dispersion modelling exercise...... 21 12. Total ...... 21 www.odourireland.com i

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Document Amendment Record

Client: Montgomery EHS Ltd.

Title: Odour impact assessment of Brandon Products Ltd located in Kilcolman, Asdee, Co. Kerry.

For inspection purposes only. Consent of copyright owner required for any other use.

Document Reference: Odour impact Project Number: 201250(3) assessment of Brandon Products Ltd located in Kilcolman, Asdee, Co. Kerry. 201250(1) Document for review BAS JWC BAS 18/01/2012 201250(2) Minor amendments BAS JWC BAS 18/01/2012 Updated with stack 201250(3) BAS JWC BAS 30/04/2012 calculations

Revision Purpose/Description Originated Checked Authorised Date

www.odourireland.com ii

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1. Executive Summary

Odour Monitoring Ireland was commissioned by Montgomery EHS to perform an odour impact assessment of the bio-scrubbing odour control system located in Brandon Products Ltd, Kilcolman, Asdee, Co. Kerry. The bio scrubber treats odours from the seaweed manufacturing process.

Volume flow and odour sampling and analysis were performed on the exhaust of the bio scrubbing process and were used to construct the basis of the modelling assessment. The measured odour emission rate was used in conjunction with odour dispersion modelling to assess the potential odour impact of the bio scrubbing system in line with established odour dose response impact criteria.

One data set for odour emission rates was calculated to determine the potential odour impact of Brandon Products Ltd bio scrubbing operations. This included:

Ref Scenario 1: Predicted overall odour emission rate from existing Brandon Products Ltd bio scrubber operations (see Table 4.3).

Aermod Prime (12060) was used to determine the overall odour impact of the scenario as set out in odour impact criteria presented in Section 3.4.4. The output data was analysed to calculate:

Ref Scenario 1: • Predicted odour emission contribution of overall existing Brandon Products Ltd bio- scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th 3 percentile for an odour concentration of less than or equal to 1.50 OuE/m (see Figure 8.2) for 7 years of screened hourly sequential meteorological data (Shannon 1999 considered worst case year) – ref Scenario 1 - Existing. Ref Scenario 2: • Predicted odour emission contribution of overall proposed Brandon Products Ltd bio- scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th 3 percentile for an odour concentration of less than or equal to 1.50 OuE/m (see Figure 8.3) for 7 years of screened hourly sequential meteorological data (Shannon 1999 For inspection purposes only. considered worst case year)Consent – of ref copyright Scenario owner required 2 – Proposed for any other use.stack height 7m. Ref Scenario 3: • Predicted odour emission contribution of overall proposed Brandon Products Ltd bio- scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th 3 percentile for an odour concentration of less than or equal to 1.50 OuE/m (see Figure 8.4) for 7 years of screened hourly sequential meteorological data (Shannon 1999 considered worst case year) – ref Scenario 3 – Proposed stack height 10m. Ref Scenario 4: • Predicted odour emission contribution of overall existing Brandon Products Ltd bio- scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th 3 percentile for an odour concentration of less than or equal to 1.50 OuE/m (see Figure 8.5) for 7 years of screened hourly sequential meteorological data (Shannon 1999 considered worst case year) – ref Scenario 4 - Proposed stack height 15m.

These computations give the odour concentration at each Cartesian grid receptor location that is predicted to be exceeded for 2% (175 hours) of seven years of screened hourly meteorological data providing approximately 61,320 hourly computations with the worst case year selected for data presentation.

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It was concluded that:

1. The odour bio-scrubbing system is achieving a treatment volume flow of 5,069 m3/hr and a treatment removal efficiency of 62% on the day of monitoring. The mass odour emission rate from the exhaust of the bio-scrubbing odour control system was 1,003 OuE/s. 2. With regard to Scenario 1, in accordance with odour impact criterion in Table 2.2, and in keeping with current recommended odour impact criterion in this country, all residential receptors in the vicinity of the operating facility will perceive and odour concentration less 3 th than 1.50 OuE/m for the 98 percentile of hourly averages for worst case meteorological year Shannon 1999. 3. With regard to Scenario 2, 3 and 4, in accordance with odour impact criterion in Table 2.2, and in keeping with current recommended odour impact criterion in this country, all residential receptors in the vicinity of the operating facility will perceive and odour 3 th concentration less than 1.50 OuE/m for the 98 percentile of hourly averages for worst case meteorological year Shannon 1999. 4. With regards to stack implementation, it would be good practice to install a stack with a total height of approximately 3 m above the roof ridge height of the highest building on site.

For inspection purposes only. Consent of copyright owner required for any other use.

www.odourireland.com iv

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2. Introduction

Odour Monitoring Ireland was commissioned by Montgomery EHS to perform an odour sampling and odour dispersion modelling assessment of the existing bio-scrubbing operations located in Brandon Products Ltd, Kilcolman, Asdee, Co. Kerry.

The existing facility processes sea weed in useable products. The bio-scrubbing odour treatment process abates odours from this process.

This document will present the collected odour threshold concentration and volume flow data from the bio scrubbing process and the dispersion modelling scenarios generated for the existing and proposed site operations. Materials and methods, assumptions, results and discussion and conclusions are presented within this document.

For inspection purposes only. Consent of copyright owner required for any other use.

www.odourireland.com 1

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3. Materials and Methods

This section will describe the materials and methods used throughout the study period.

3.1. Odour sampling and analysis

3.1.1. Odour sampling techniques

In order to obtain air samples for odour assessment, a static sampling method was used where air samples were collected in 40 to 60 litre pre-conditioned NalophanNA bags using a vacuum sampling device over a 5 to 10 minute period. The sampler operates on the 'lung principle', whereby the air is removed from a rigid container around the bag by a battery powered SKC vacuum pump at a rate of 5 to 9 l min-1. This caused the bag to fill through a stainless steel and PTFE tube whose inlet is placed in ambient air, with the volume of sample equal to the volume of air evacuated from the rigid container. Samples were taken on the inlet and exhaust of the bio- scrubbing system.

3.1.2. Olfactometry

Olfactometry using the human sense of smell is the most valid means of measuring odour (Dravniek et al, 1986) and at present is the most commonly used method to measure the concentration of odour in air (Hobbs et al, 1996). Olfactometry is carried out using an instrument called an olfactometer. Three different types of dynamic dilution olfactometers exist: • Yes/No Olfactometer • Forced Choice Olfactometer • Triangular Forced Choice Olfactometer.

In the dynamic dilution olfactometer, the odour is first diluted and is then presented to a panel of screened panellists of no less than four (CEN, 2003) Panellists are previously screened to ensure that they have a normal sense of smell (Casey et al., 2003). According to the CEN standard this n screening must be performed using a certified For inspection reference purposes only. gas -butanol. This screening is applied to eliminate anosmia (low sensitivity)Consent andof copyright super- ownernoses required (high for any othersensitivity). use. The odour analysis has to be undertaken in a low odour environment such as an air-conditioned odour free laboratory. Analysis should be performed preferably within 8 to 12 hours of sampling.

3.1.3. Odour measurement in accordance with the EN13725:2003

An ECOMA TO8 dynamic yes/no olfactometer was used throughout the measurement period to determine the odour threshold concentration of the sample air. The odour threshold concentration is defined as the dilution factor at which 50% of the panel can just detect the odour. Only those panel members who pass screening tests with n-butanol (certified reference gas, CAS 72-36-3) and who adhered to the code of behaviour were selected as panellists for olfactometry measurements (CEN, 2003). Odour measurement was carried out in an odour free laboratory in accordance with EN13725:2003. The analyses were carried out in the laboratory of Odour Monitoring Ireland in Trim Co. Meath.

3.1.4. What is an odour unit?

The odour concentration of a gaseous sample of odourant is determined by presenting a panel of selected screened human panellists with a sample of odourous air and varying the concentration

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The European odour unit is that amount of odourant(s) that, when evaporated into one cubic metre of neutral gas (nitrogen), at standard conditions elicits a physiological response from a panel (detection threshold) equivalent to that elicited by one European Reference Odour Mass (EROM) evaporated in one cubic meter of neutral gas at standard conditions. One EROM is that mass of a substance (n-butanol) that will elicit the Z50 physiological response assessed by an odour panel in accordance with this standard. n-Butanol is one such reference standard and is equivalent to 123µg of n-butanol evaporated in one cubic meter of neutral gas at standard conditions (CEN, 2003).

3.2. Volumetric airflow rate calculation.

Volume flow rate was measured in accordance with EN13284-1 where possible. Measurement for air flow rate was performed in a 600 mm by 600mm square section of duct work.

The overall volumetric airflow rate from the identified source is presented in Table 4.1 for scenario 1.

In terms of the proposed stack scenarios, it was assumed that stack heights of 7, 10 and 15m were examined. The stack tip diameter utilised was 0.98m.

3.3. Odour emission rate calculation.

The measurement of the strength of a sample of odourous air is, however, only part of the problem of quantifying odour. Just as pollution from a stack is best quantified by a mass emission rate, the rate of production of an odour is best quantified by the odour emission rate. For a -3 chimney or ventilation stack, this is equal to the odour threshold concentration (OuE m ) of the discharge air multiplied by its flow-rate (m3 s-1). It is equal to the volume of air contaminated every -1 second to the threshold odour limit (OuE s ). The odour emission rate can be used in conjunction with dispersion modelling in order to estimate the approximate radius of impact or complaint (Hobson et al, 1995). For inspection purposes only. Consent of copyright owner required for any other use.

3.4. Dispersion modelling

3.4.1. Atmospheric dispersion modelling of odours: What is dispersion modelling?

Any material discharged into the atmosphere is carried along by the wind and diluted by wind turbulence, which is always present in the atmosphere. This process has the effect of producing a plume of air that is roughly cone shaped with the apex towards the source and can be mathematically described by the Gaussian equation. Atmospheric dispersion modelling has been applied to the assessment and control of odours for many years, originally using Gaussian form ISCST 3 and more recently utilising advanced boundary-layer physics models such as ADMS and -1 AERMOD (Keddie et al. 1992). Once the odour emission rate from the source is known, (OuE s ), the impact on the vicinity can be estimated. These models can effectively be used in three different ways: firstly, to assess the dispersion of odours and to correlate with complaints; secondly, in a “reverse” mode, to estimate the maximum odour emissions which can be permitted from a site in order to prevent odour complaints occurring; and thirdly, to determine which process is contributing greatest to the odour impact and estimate the amount of required abatement to reduce this impact within acceptable levels (McIntyre et al. 2000). In this latter

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3.4.2. AERMOD Prime

The AERMOD model was developed through a formal collaboration between the American Meteorological Society (AMS) and U.S. Environmental Protection Agency (U.S. EPA). AERMOD is a Gaussian plume model and replaced the ISC3 model in demonstrating compliance with the National Ambient Air Quality Standards (Porter et al., 2003) AERMIC (USEPA and AMS working group) is emphasizing development of a platform that includes air turbulence structure, scaling, and concepts; treatment of both surface and elevated sources; and simple and complex terrain. The modelling platform system has three main components: AERMOD, which is the air dispersion model; AERMET, a meteorological data pre-processor; and AERMAP, a terrain data pre- processor (Cora and Hung, 2003).

AERMOD is a Gaussian steady-state model which was developed with the main intention of superseding ISCST3 (NZME, 2002). The AERMOD modeling system is a significant departure from ISCST3 in that it is based on a theoretical understanding of the atmosphere rather than depend on empirical derived values. The dispersion environment is characterized by turbulence theory that defines convective (daytime) and stable (nocturnal) boundary layers instead of the stability categories in ISCST3. Dispersion coefficients derived from turbulence theories are not based on sampling data or a specific averaging period. AERMOD was especially designed to support the U.S. EPA’s regulatory modeling programs (Porter at al., 2003). Special features of AERMOD include its ability to treat the vertical in-homogeneity of the planetary boundary layer, special treatment of surface releases, irregularly-shaped area sources, a three plume model for the convective boundary layer, limitation of vertical mixing in the stable boundary layer, and fixing the reflecting surface at the stack base (Curran et al., 2006). A treatment of dispersion in the presence of intermediate and complex terrain is used that improves on that currently in use in ISCST3 and other models, yet without the complexity of the Complex Terrain Dispersion Model- Plus (CTDMPLUS) (Diosey et al., 2002).

3.4.3. Model assumptions For inspection purposes only. Consent of copyright owner required for any other use. The approach adopted in this assessment is considered a standard investigation in respect of emissions to the atmosphere from the bio-scrubbing operations. These assumptions are summarised and include:

The approach adopted in this assessment is considered a worst-case investigation in respect of emissions to the atmosphere from the existing bio-scrubbing operations. These predictions are therefore most likely to over estimate the GLC that may actually occur for each modelled scenario. These assumptions are summarised and include:

• Emissions to the atmosphere from the existing bio-scrubbing operations were assumed to occur 24 hours each day / 7 days per week over a standard year at 100% output. • Seven years of hourly sequential meteorological data from Shannon 1998 to 2002 and 2004 to 2005 inclusive was used in the modelling screen which will provide statistical significant results in terms of the short and long term assessment. The worst case year 1999 was used for data analysis. This is in keeping with guidance. In addition, AERMOD incorporates a meteorological pre-processor AERMET PRO. The AERMET PRO meteorological preprocessor requires the input of surface characteristics, including surface roughness (z0), Bowen Ratio and Albedo by sector and season, as well as hourly observations of wind speed, wind direction, cloud cover, and temperature. The values of Albedo, Bowen Ratio and surface roughness depend on land-use type (e.g., urban, cultivated land etc) and vary with seasons and wind direction. The assessment of

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appropriate land-use type was carried out to a distance of 10km from the meteorological station for Bowen Ratio and Albedo and to a distance of 1km for surface roughness in line with USEPA recommendations. • AERMOD Prime (12060) dispersion modelling was utilised throughout the assessment in order to provide the most conservative dispersion estimates. • All building wake affects were assessed within the dispersion model.

3.4.4. Odour impact criterion for Brandon Products Ltd bio-scrubbing operations

An odour impact criterion defines the odour threshold concentration limit value above baseline in ambient air, which will result in an odour stimulus capable of causing an odour complaint. There are a number of interlinked factor, which causes a nearby receptor (i.e. resident) to complain. These include: • Odour threshold concentration, odour intensity and hedonic tone-defined measurable parameters at odour source, • Frequency of odour-how frequently the odour is present at the receptor location, • Duration of odour-how long the odour persists at the receptor location, • Physiological-previous experiences encountered by receptor, etc.

By assessing these combined interlinked factors, the ability for a facility to cause odour complaint can be determined. As odour is not measurable in ambient air due to issues in sampling techniques, limit of detections for olfactometers and the inability to monitor continuously, therefore dispersion models become useful tools in odour impact assessments and odour risk analysis. Dispersion modelling also allows for the assessment of proposed changes in processes within the facility without actually having to wait for the processes to be changed (i.e. predictive analysis).

Impacts from the facility operations are assessed in accordance with the following requirements. These include:

1. EPA guidance documents “Odour impacts and odour emission control measures for intensive agriculture, EPA, 2001,

2. AG4 - Air Dispersion Modelling from Industrial Installations Guidance Note (AG4) and For inspection purposes only. Consent of copyright owner required for any other use. 3. H Horizontal Guidance notes (2010), UK Environment Agency

3 th Based on these publications, a value of less than 1.50 OuE/m at the 98 percentile of hourly averages for 7 years of screened hourly sequential meteorological data was examined as this was considered the most appropriate odour impact criterion as this facility.

3.5. Meteorological data.

Seven years of hourly sequential meteorological data was chosen for the modelling exercise (i.e. Shannon 1998 to 2002 and 2004 and 2005 inclusive). A schematic wind rose and tabular cumulative wind speed and directions of all seven years are presented in Section 11. All seven years of met data was screened to provide more statistical significant result output from the dispersion model. The worst case year 1999 was used for data presentation. This is in keeping with national and international recommendations on quality assurance in operating dispersion models and will provide a worst case assessment of predicted ground level concentrations based on the input emission rate data. Surface roughness, Albedo and Bowen ratio were assessed and characterised around Aldergrove met station for AERMET Pro processing.

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3.6. Terrain data.

Topography effects were not accounted for within the dispersion modelling assessment as terrain was considered simple in the immediate area around the site. All receptor heights were assumed to be at the same height as the emission point as confirmed by Montgomery EHS.

3.7. Building wake effects

Building wake effects are accounted for in modelling scenarios through the use of the Prime algorithm (i.e. all building features located within the facility) as this can have a significant effect on the compound plume dispersion at short distances from the source and can significantly increase GLC’s in close proximity to the facility. All building structures and stack height and orientations were inputted into the dispersion model in order to allow for wake effects to be taken in to account in the calculations. The latest BPIP version (04274) was utilised in the analysis. The emission point was considered a horizontal emission point within the assessment.

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4. Results

This section will present the results obtained from the study.

4.1. Volumetric airflow rate calculations for Scenario 1

Table 4.1 presents the results for the volumetric airflow rate performed at the operational bio-scrubbing operations.

Table 4.1. Measured volumetric airflow rate values for dispersion modelling examination for the operational bio-scrubbing facility.

Emission point Area of airflow Average airflow Volume flow Volume flow rate Temperature of identity measurement point (m2) velocity (m/s) rate (m3/s) (m3/hr) exhaust (K) Exhaust of bio- 0.32 4.40 1.408 5068.8 289.25 scrubber

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4.2. Odour emission data for Scenarios 1

One data set for odour emission rate was calculated to determine the potential odour impact of the existing operational bio-scrubber utilising site specific and source odour emission data. This scenario included:

Ref Scenario 1: Predicted overall odour emission rate from existing Brandon Products Ltd bio-scrubbing facility operations (see Table 4.3).

4.3. Odour emission rates from Brandon Products Ltd bio-scrubbing operations for atmospheric dispersion modelling Scenario 1.

Table 4.2 presents the results collected from the odour threshold concentration measurement study. As can be observed the overall average exhaust odour threshold concentration is 712 3 OuE/m . The bio-scrubbing system was achieving an odour removal efficiency of at least 62%.

Table 4.2. Odour threshold concentration data for the measurement survey on the operational bio-scrubbing system located in Brandon Products Ltd.

Average odour Sample Odour threshold Odour removal Sample identity 3 threshold conc number conc (OuE/m ) 3 eff. (%) (OuE/m ) Outlet of bio- S1281011 670 - - scrubber Outlet of bio- S2281011 845 - - scrubber Outlet of bio- S3281011 621 712 62.15 scrubber Inlet to bio-scrubber S4281011 1,689 - - Inlet to bio-scrubber S5281011 1,824 - - Inlet to bio-scrubber S6281011 For inspection 2,128 purposes only. 1,881 - Consent of copyright owner required for any other use.

Tables 4.3 illustrates the overall odour emission rate from the existing operational bio-scrubber in Brandon Products Ltd.

As can be observed in Table 4.3, the overall odour emission rate from the bio-scrubbing operations is approximately 1,003 OuE/s.

Table 4.3. Predicted overall odour emission rate from existing Brandon Products Ltd bio- scrubbing facility operations (ref Scenario 1).

Average exhaust odour Volume flow rate Odour emission Sample identity 3 3 threshold conc (OuE/m ) (m /hr) rate (OuE/s) Exhaust odour 712 5,069 1,003 threshold conc.

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Table 4.4 illustrated the source characteristics of the emission point and formed the basis of the dispersion model input file.

Table 4.4. Source characteristics for the dispersion model.

Emission Emission Emission Emission point – point – point – point – Exhaust bio- Exhaust bio Exhaust bio Exhaust bio Parameter scrubber = scrubber – scrubber – scrubber – Ref Scenario Ref Scenario Ref Scenario Ref Scenario 1 2 3 4 X coordinate 492871.4 492871.4 492871.4 492871.4 Y coordinate 646250.1 646250.1 646250.1 646250.1 Elevation (A.O.D) (m) 65.30 65.30 65.30 65.30 Stack height (m) 1.04 7 10 15 Orientation Horizontal Vertical Vertical Vertical Temperature (K) 289.25 289.25 289.25 289.25 Efflux velocity (m/s) 1.866 Max volume flow 3 5,069 5,069 5,069 5,069 (Am /hr) Stack tip diameter (m) 0.98 0.98 0.98 0.98 Max building height (m) 11.40 11.40 11.40 11.40 Max building ground 65.30 65.30 65.30 65.30 level (m)

4.4. Results of odour dispersion modelling for the bio-scrubbing operations located in Brandon Products Ltd facility

Aermod Prime (12060) was used to determine the overall odour impact of the bio-scrubbing operations in Brandon Products Ltd as set out in odour impact criteria contained in Section 3.4.4. The output data was analysed to calculate:

For inspection purposes only. Ref Scenario 1: Consent of copyright owner required for any other use. • Predicted odour emission contribution of overall existing Brandon Products Ltd bio-scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th percentile for an odour 3 concentration of less than or equal to 1.50 OuE/m (see Figure 8.2) for 7 years of screened hourly sequential meteorological data (Shannon 1999 considered worst case year) – ref Scenario 1 - Existing. Ref Scenario 2: • Predicted odour emission contribution of overall proposed Brandon Products Ltd bio- scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th percentile 3 for an odour concentration of less than or equal to 1.50 OuE/m (see Figure 8.3) for 7 years of screened hourly sequential meteorological data (Shannon 1999 considered worst case year) – ref Scenario 2 – Proposed stack height 7m. Ref Scenario 3: • Predicted odour emission contribution of overall proposed Brandon Products Ltd bio- scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th percentile 3 for an odour concentration of less than or equal to 1.50 OuE/m (see Figure 8.4) for 7 years of screened hourly sequential meteorological data (Shannon 1999 considered worst case year) – ref Scenario 3 – Proposed stack height 10m. Ref Scenario 4: • Predicted odour emission contribution of overall existing Brandon Products Ltd bio-scrubbing system operation (see Table 4.3), to odour plume dispersal at the 98th percentile for an odour

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3 concentration of less than or equal to 1.50 OuE/m (see Figure 8.5) for 7 years of screened hourly sequential meteorological data (Shannon 1999 considered worst case year) – ref Scenario 4 - Proposed stack height 15m.

These computations give the odour concentration at each Cartesian grid receptor location that is predicted to be exceeded for 2% (175 hours) of seven years of screened hourly meteorological data providing approximately 61,320 hourly computations. The worst case meteorological year was utilised for data presentation as per AG4 guidance.

This will allow for the predictive analysis of any potential impact on the neighbouring sensitive locations while the facility is in operation. It will also allow the operators of the facility site to assess the effectiveness of their mitigation strategies. The intensity of the odour from two or more sources of the facility operation will depend on the strength of the initial odour threshold concentration from the sources and the distance downwind at which the prediction and/or measurement is being made. Where the odour emission plumes from a number of sources combine downwind, then the predicted odour concentrations may be higher than that resulting from an individual emission source. It is important to note that various odour sources have different odour characters. This is important when assessing those odour sources to minimise and/or abate. Although an odour source may have a high odour emission rate, the corresponding odour intensity (strength) may be low and therefore it is easily diluted. Those sources that express the same odour character, as an odour impact should be investigated first for abatement/minimisation before other sources are examined as these sources are the driving force behind the character of the perceived odour.

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5. Discussion of results

This section will discuss the results obtained during the study.

5.1. Odour impact from existing facility operations – ref Scenario 1

As can be observed in Figure 8.2, the predicted odour plume from the facility operations has a radial impact area of approximately 25m from the boundary of the site in a north and north west direction 3 th for an odour concentration of less than or equal to 1.50 OuE/m at the 98 percentile of hourly averages for worst case meteorological year Shannon 1999. In accordance with the odour impact criterion presented in Section 3.4.4, there will be no odour impact from the operational bio-scrubbing system based on the data collected on the day of monitoring. In addition, odour concentration levels were predicted at eleven nearby sensitive receptors in the vicinity of the operational facility. As can be observed in Table 5.1, all residential receptors will perceive an odour concentration less than 1.50 3 th OuE/m for the 98 percentile of screened hourly averages over 7 years.

5.2. Odour impact from proposed facility operations – ref Scenario 2

As can be observed in Figure 8.3, the predicted odour plume from the facility operations has a radial impact area of approximately 25 to 35m from the boundary of the site in a north and north west 3 th direction for an odour concentration of less than or equal to 1.0 OuE/m at the 98 percentile of hourly averages for worst case meteorological year Shannon 1999. In accordance with the odour impact criterion presented in Section 3.4.4, there will be no odour impact from the operational bio-scrubbing system based on the data collected on the day of monitoring. In addition, odour concentration levels were predicted at eleven nearby sensitive receptors in the vicinity of the operational facility. As can be observed in Table 5.1, all residential receptors will perceive an odour concentration less than 1.50 3 th OuE/m for the 98 percentile of screened hourly averages over 7 years.

5.3. Odour impact from proposed facility operations – ref Scenario 3

As can be observed in Figure 8.4, the predicted odour plume from the facility operations has a radial impact area of approximately 100m from the boundary of the site in a north and north west direction 3 th for an odour concentration of less than or equal to 0.50 OuE/m at the 98 percentile of hourly For inspection purposes only. averages for worst case meteorolConsentogical of copyright year ownerShannon required for1999. any other In use. accordance with the odour impact criterion presented in Section 3.4.4, there will be no odour impact from the operational bio-scrubbing system based on the data collected on the day of monitoring. In addition, odour concentration levels were predicted at eleven nearby sensitive receptors in the vicinity of the operational facility. As can be observed in Table 5.1, all residential receptors will perceive an odour concentration less than 1.50 3 th OuE/m for the 98 percentile of screened hourly averages over 7 years.

5.4. Odour impact from proposed facility operations – ref Scenario 4

As can be observed in Figure 8.5, the predicted odour plume from the facility operations has a radial impact area of approximately 200m from the boundary of the site in a north and north west direction 3 th for an odour concentration of less than or equal to 0.20 OuE/m at the 98 percentile of hourly averages for worst case meteorological year Shannon 1999. In accordance with the odour impact criterion presented in Section 3.4.4, there will be no odour impact from the operational bio-scrubbing system based on the data collected on the day of monitoring. In addition, odour concentration levels were predicted at eleven nearby sensitive receptors in the vicinity of the operational facility. As can be observed in Table 5.1, all residential receptors will perceive an odour concentration less than 1.50 3 th OuE/m for the 98 percentile of screened hourly averages over 7 years.

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Table 5.1. Predicted odour concentrations at eleven sensitive receptor locations in the vicinity of Brandon Products Ltd facility for Scenarios 1, 2, 3 and 4.

Receptor identity (see Scenario 1 Scenario 2 Scenario 3 Scenario 4 X coordinate (m) Y coordinate (m) 3 3 3 3 Figure 8.1) (OuE/m ) (OuE/m ) (OuE/m ) (OuE/m ) R1 492820.8 646200.7 0.86 0.47 0.30 0.13 R2 492796.1 646268.1 0.60 0.36 0.30 0.16 R3 492718.4 646353.2 0.32 0.19 0.16 0.11 R4 492959.6 646062.7 0.19 0.11 0.10 0.07 R5 493006.9 646095.9 0.22 0.13 0.11 0.08 R6 493040.7 646098 0.16 0.10 0.08 0.05 R7 493141 646028.8 0.08 0.05 0.04 0.03 R8 493045.7 646139.6 0.29 0.17 0.14 0.09 R9 492975.1 646386.8 0.16 0.15 0.21 0.14 R10 493013.9 646456.7 0.12 0.10 0.14 0.11 R11 493018.9 646511.7 0.13 0.11 0.13 0.10

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6. Conclusions

A worst-case odour emission scenario was modelled using the atmospheric dispersion model Aermod Prime 12060. The measured odour emission data and source characteristics were inputted into the dispersion model in order to assess the potential area of impact for the operating bio- scrubbing system. It was concluded that:

7. Recommendations

The following recommendations were developed during the study:

1. An odour management plan and auditing procedure should be operated and maintained throughout facility operations in line with standard practice.

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8. Appendix I - Odour dispersion modelling contour results

8.1. Site layout

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Figure 8.1. Aerial diagram of Brandon Products Ltd facility and residential locations.

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8.2 Predicted odour emission contribution of existing Brandon Products Ltd bio-scrubbing system operation to odour plume th 3 dispersal at the 98 percentile for an odour concentration of ≤ 1.50 OuE/m (ref Scenario 1)

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Figure 8.2. Predicted odour emission contribution of existing Brandon Products Ltd bio-scrubbing system operations to odour plume dispersal for th 3 Scenario 1 at the 98 percentile for odour concentrations ≤ 1.50 OuE/m ( ).

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8.3 Predicted odour emission contribution of proposed Brandon Products Ltd bio-scrubbing system operation to odour plume th 3 dispersal at the 98 percentile for an odour concentration of ≤ 1.0 OuE/m (ref Scenario 2)

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Figure 8.3. Predicted odour emission contribution of proposed Brandon Products Ltd bio-scrubbing system operation to odour plume dispersal for th 3 Scenario 2 at the 98 percentile for odour concentrations ≤ 1.0 OuE/m ( ).

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8.4 Predicted odour emission contribution of proposed Brandon Products Ltd bio-scrubbing system operation to odour plume th 3 dispersal at the 98 percentile for an odour concentration of ≤ 0.50 OuE/m (ref Scenario 3)

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Figure 8.4. Predicted odour emission contribution of proposed Brandon Products Ltd bio-scrubbing system operation to odour plume dispersal for th 3 Scenario 3 at the 98 percentile for odour concentrations ≤ 0.50 OuE/m ( ).

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8.5 Predicted odour emission contribution of proposed Brandon Products Ltd bio-scrubbing system operation to odour plume th 3 dispersal at the 98 percentile for an odour concentration of ≤ 0.20 OuE/m (ref Scenario 4)

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Figure 8.5. Predicted odour emission contribution of proposed Brandon Products Ltd bio-scrubbing system operation to odour plume dispersal for th 3 Scenario 4 at the 98 percentile for odour concentrations ≤ 0.20 OuE/m ( ).

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9. Appendix II – Odour Management plan overview.

9.1. Odour management plan - – Standard practice

The Odour Management Plan (OMP) is a core document that is intended to detail operational and control measures appropriate to management and control of odour at the site. The format of the OMP should provide sufficient detail to allow operators and maintenance staff to clearly understand the operational procedures for both normal and abnormal conditions.

An Odour Management Plan (OMP) should be prepared for all processes. The OMP should also include sufficient feedback data to allow site management (and local authority inspectors) to audit site operations. An example of some of the issues to be considered is summarised as follows. More detailed guidance is provided with this document.

• A summary of the site and any waste, odour sources and the location of receptors, • Details of the site management responsibilities and procedures for reporting faults, Identifying maintenance needs, replenishing consumables, complaints procedure, • Odour critical plant operation and management procedures (e.g. correct use of plant, process, materials; checks on equipment performance, maintenance and inspection, • Operative training, • Housekeeping, • Maintenance and inspection of plant (both routine and emergency response), • Spillage and house keeping management procedures, • Record keeping – format, responsibility for completion and location of records, • Emergency breakdown and incident response planning including responsibilities and mechanisms for liaison with the local authority. • Public relations.

The Odour Management Plan is a living document and should be regularly reviewed and upgraded. It should form the basis of a document Environmental and Odour Management system for the operating site. The Odour Management System documentation should define the roles of the Plant Operator and staff and sets out templates in relation to the operating of the facility and reporting procedures to be employed. Requirements for the Odour management plan should be implemented For inspection purposes only. thought out the site with a Consentbranched of copyright management owner required for systemany other use. implemented in order to share responsibility around the site. The head manager should ensure all works are performed in accordance with the OMP. The OMP should be integrated in the overall Environmental Management System/Performance management system.

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10. References

1. Callan, B.T., (1993). Noses Knows Best. In malodour measurement and control. Proceedings of the International Tydnall School, September. 134-145. 2. CEN, (2003). EN13725-Air-quality-Determination of odour concentration by dynamic olfactometry. Brussels, Belgium. 3. DOE, (1993). Report by the Inspector on a Public Inquiry into the Appeal by Northumbrian Water Limited for Additional Sewage treatment facilities on land adjacent to Spitial Burns, Newbriggin-by-the-Sea, Northumberland in March 1993. DoE ref APP/F2930/A/92/206240. 4. Dravniek, A., (1986). Atlas of odor character profiles. ASTM Committee on sensory evaluation of materials and products, ASTM data series. Baltimore, MD, USA. 5. EPA, (2001). Odour impacts and odour emission control measures for intensive agriculture. Commissioned by the Environmental Protection Agency (Ireland). OdourNet UK Ltd. 6. Longhurst, P., (1998). Odour impact assessment of an extension to the Brogborough landfill site. IREC, Cranfield University, England. 7. McIntyre, A., (2000). Application of dispersion modelling to odour assessment; a practical tool or a complex trap. Water Science and Technology, 41 (6). 81-88. 8. Sheridan, B.A. (2002). In house odour intensity and hedonic tone profile data of different odourous sources. Unpublished. 9. Sheridan, B.A., (2001). Controlling atmospheric emissions-BAT Note Development, UCD Environmental Engineering Group, Department of Agricultural and Food Engineering, UCD, Dublin 2. 10. Sheridan, B.A., Hayes, E.T., Curran, T.P., Dodd, V.A., (2003). A dispersion modelling approach to determining the odour impact of intensive pig production units in Ireland. Bioresource Technology. Published.

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11. Appendix III - Meteorological data examined and used in the dispersion modelling exercise

Table 11.1. Tabular illustration of Shannon meteorological files for Years 1998 to 2002 and 2004 to 2005 inclusive (7 years). 7 year Meteorological file for Shannon airport 1998 to 2002 and 2004 to 2005 inclusive <= 1.54 <= 3.09 <= 5.14 <= 8.23 <= 10.80 > 10.80 Dir \ Speed 12. Total m/s m/s m/s m/s m/s m/s 0.0 0.75 0.83 1.81 0.52 0.09 0.01 4.02 22.5 0.72 0.61 1.32 0.38 0.07 0.01 3.11 45.0 0.64 0.64 1.23 0.43 0.06 0.01 3.02 67.5 0.56 0.44 0.70 0.35 0.08 0.01 2.12 90.0 0.43 0.40 1.48 0.57 0.07 0.00 2.96 112.5 0.59 0.96 3.57 1.03 0.17 0.05 6.36 135.0 0.64 1.13 3.85 1.55 0.45 0.12 7.74 157.5 0.55 0.87 3.52 2.49 0.67 0.17 8.26 180.0 0.42 0.59 2.51 1.44 0.52 0.12 5.59 202.5 0.43 0.62 2.87 1.43 0.38 0.07 5.80 225.0 0.42 0.71 2.90 1.86 0.68 0.24 6.81 247.5 0.64 1.05 4.68 3.30 1.46 0.55 11.67 270.0 0.56 0.99 4.23 2.64 1.07 0.37 9.85 292.5 0.64 1.06 3.66 2.36 0.83 0.18 8.73 315.0 0.56 0.92 2.86 1.18 0.25 0.05 5.84 337.5 0.90 1.06 2.66 0.72 0.19 0.02 5.56 Total 9.44 12.85 43.85 22.26 7.04 1.99 97.42 Calms ------2.24 Missing ------0.34 Total ------100.00

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Figure 11.1. Windrose illustration of meteorological files for years Shannon 1998 to 2002 and 2004 to 2005 inclusive (7 years).

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