PPC Farm Permit Decision Document Template for new applications (general)
Q57/19 Version 1
Decision Document for Permit Number P0476/15A (Neill Patterson – Seaforde)
CONDITION(S)
1.1The permitted activities
JUSTIFICATION: Decision document
The Permit covers the rearing of poultry for the production of poultry meat and waste storage - including carcasses
prior to transfer off site for rendering in an authorised facility or on-site incineration. Bird numbers quoted in the
application are 74,000 broilers. The birds will be housed in 2 new steel houses with roof mounted fans.
A proportion of the litter produced on the farm will be exported for spreading to land in the Republic of Ireland.
Some manure may also be exported for mushroom composting, anaerobic digestion, or combustion in authorised
facilities.
The operator may also wish to export litter from the site for spreading in Northern Ireland on operator controlled
land or third party land at some time in the future. A land bank in Northern Ireland has not yet been identified but
permit conditions (2.3.5.1, 2.3.5.5 and IMP6) require the operator to submit a full Nutrient Management Plan prior to
first exporting litter from the site for land-spreading in Northern Ireland.
The houses will be heated by means of hot water heaters and biomass boilers (and LPG heaters as backup).
Planning permission (R/2014/0685/F) for the proposed poultry houses was granted on 18th March 2015.
1.2.1 The site
1.3 Overall Management
The site boundary is as shown in bold on the site plan. The site encompasses the poultry sheds, surrounding hard
standing areas, waste water tanks, gas tanks, feed tanks, carcass skip, generators, biomass heating system, associated
fuel tanks, litter storage silo and the swale.
These are standard conditions.
PPC Farm Permit Decision Document Template for new applications (general)
Q57/19 Version 1
1.5 Off site conditions
1.6 Minor operational changes
Condition 1.4.1 requires the operator to inform the Chief Inspector 14 days prior to the 40,000 bird capacity being
exceeded and therefore the permit becoming effective. Pre-Operation Condition 1.4.2 requires a suitable wash water
tank to be constructed prior to the installation being stocked above 40,000 birds. Pre-Operation Condition 1.4.3 has
been added to ensure that a separate drainage system is provided to collect wash water from the houses and litter
storage silo and drain it directly to the waste water tanks without relying on a diverter. Pre-Operation Condition 1.4.4
has been added to ensure that the yard areas associated with the poultry houses and litter storage silo are suitably
designed and contained with all heavily contaminated yard drainage directed to waste water tank(s) and all lightly
contaminated site drainage directed to swale. Condition 1.4.5 requires the operator to provide collision protection
for LPG storage tanks. Condition 1.4.6 ensures that suitable bunding is provided for the generator and associated fuel
storage. Condition 1.4.7 ensures that a suitable store is provided for pesticides and veterinary medicines and
condition 1.4.8 ensures that there is sufficient metering of all water used on the site. Condition 1.4.9 requires the
operator to construct a swale to treat the lightly contaminated drainage from the site.
There are no off-site conditions.
These are standard conditions.
2.1 Farm Management
Techniques
These are standard conditions. IMP4 has been added to ensure appropriate IPPC training is completed within 12
months of permit issue or as soon as a course becomes available.
2.2.1 – 2.2.3 Raw Materials and
Water
These are standard conditions. Pre-Operation Condition 1.4.8 requires water meters to be installed to enable water
usage of specific activities to be monitored prior to the site exceeding 40,000 birds. Improvement Condition IMP1
has been added to ensure that an audit of water use is undertaken within 3 years of the effective date of the permit.
2.3.1 Feed delivery, milling and
preparation
2.3.2 Storage of agricultural fuel
oils and other materials
These are standard conditions. Feed will be blown into fully covered and sealed bins.
1.4 Pre-operation conditions
These are standard conditions. Pre-Operation condition 1.4.5 has been added to ensure that suitable collision
protection is provided for any gas tanks on site. Pre-Operation condition 1.4.6 has been added to ensure that the
generator installation and any fuel tanks associated with the generator are suitably bunded to contain any potential
leaks or spills of fuel, coolant or lubricant. Pre-Operation condition 1.4.7 has been added to ensure that all chemicals
are correctly stored.
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PPC Farm Permit Decision Document Template for new applications (general)
2.3.3 Minimising emissions from
housing
2.3.4 Litter storage
2.3.5 Litter spreading
Q57/19 Version 1
Pre-Operation Condition 1.4.9 requires a swale to be constructed for the treatment of lightly contaminated site runoff. Pre-Operation Condition 1.4.2 requires an underground tank to be installed to collect poultry house wash water
and heavily contaminated site run-off associated with the new poultry houses. Pre-Operation Condition 1.4.3 has
been added to ensure that a separate drainage system is provided to collect wash water from all the houses and litter
storage silo and drain it directly to the waste water tanks without relying on a diverter. Pre-Operation Condition 1.4.4
has been added to ensure that the yard areas associated with the poultry houses and litter storage silo are contained
with all heavily contaminated yard drainage directed to waste water tank(s) and all lightly contaminated site drainage
directed to swale.
The installation and operation of a biomass heating system should help improve the quality of the litter and reduce
emissions from the houses (ammonia, odour). The biomass heating system is an indirect heating system (hot water)
which will reduce production of CO2 and water vapour within the houses (see section 2.3.7 for further details).
Litter shall not be stored on site other than when held in poultry houses prior to clean out or in planned storage as set
out in the application. Pre-operation conditions 1.4.2 - 1.4.4 require suitable run-off collection facilities to be put in
place for litter storage.
Litter will be loaded directly from the poultry sheds onto covered trailers and removed from site for export to the
Republic of Ireland for land-spreading; mushroom composting, anaerobic digestion, for combustion in an authorised
facility or land-spreading in Northern Ireland in accordance with a nutrient management plan.
Litter will be exported from the site for use in mushroom composting, combustion, anaerobic digestion in authorised
facilities or land-spreading in the Republic of Ireland. The relevant regulatory authority (Department of Agriculture,
Food and Marine, DAFM) in the ROI has been notified in writing of the proposed export of litter from the poultry
farm. Relevant legislation (Animal Veterinary Health Certificates, TRACES etc) and record requirements will be
complied with. The operator may also wish to land-spread litter in Northern Ireland at some time in the future. A
land bank in Northern Ireland has not yet been identified but permit conditions (2.3.5.1, 2.3.5.5 and IMP6) require
the operator to submit a full Nutrient Management Plan prior to first exporting litter for spreading in Northern
Ireland on operator controlled or third party land. An anaerobic digestion outlet has not yet been identified but
permit conditions (2.3.5.1 and IMP9) require the operator to submit details prior to first exporting litter to this outlet.
The operator estimates the litter produced on the site to be approximately 577T per year.
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PPC Farm Permit Decision Document Template for new applications (general)
2.3.6 Odour
2.3.7 Operation of biomass
heating system
Q57/19 Version 1
These are standard conditions.
The closest third party receptor is a garden centre approximately 120m southwest of the poultry site. Third party
dwellings are located approximately 180m to the south-southeast, 180m south-southwest, 190m southwest and there
are multiple dwellings 300-350m to the west of the installation.
Check odour modelling carried out by NIEA-IPRI indicates that the odour guideline value of 3 OU/m3 (as set out in
the Environment Agency H4 Odour Management Guidance, March 2011) is unlikely to be exceeded at either the
garden centre or any of the third party dwellings in the area.
Measures described in the odour management plan provided with the application shall be implemented. A
satisfactory complaints procedure was submitted with the odour management plan.
The installation and operation of biomass boilers should help improve the quality of the litter and reduce emissions
from the houses (ammonia, odour). The biomass heating system is an indirect heating system (hot water) which will
reduce production of CO2 and water vapour within the houses (see section 2.3.7 for further details).
It is considered that people should not be unduly affected by odour emissions from the poultry unit provided the
conditions set out in the permit are strictly adhered to.
The poultry houses will be heated by means of hot water heaters. The hot water will be provided for the poultry
houses by means of biomass boilers with LPG burners as a back-up. Permit conditions (2.3.7.1 to 2.3.7.5) have been
added requiring the operator to ensure correct installation, maintenance and operation of the boilers and that
appropriate biomass fuel is used.
Technical details of the biomass boilers and hot water heating system have been submitted with the application. Only
non waste wood material, e.g. wood pellets, wood chip or willow, will be used as fuel (condition 2.3.7.3). The
biomass heating system meets the technical criteria to be eligible for the Renewable Heat Incentive (RHI). A detailed
air dispersion modelling report has also been submitted which provides a demonstration that potential air emissions
(NO2, CO and particulate matter) from the heating system are not likely to be significant, i.e. relevant air quality
standards are unlikely to be exceeded. Check modelling carried out by NIEA gave similar results. This concludes
that air emissions from small biomass boilers burning virgin timber are not likely to pose a significant risk to the
environment or human health, provided the relevant criteria are met (see EA Position Statement “Intensive Farming
– Biomass boilers on EPR intensive farms”, May 2013).
The installation and operation of a biomass heating system should help improve the quality of the litter and reduce
emissions from the houses (ammonia, odour). The biomass heating system is an indirect heating system (hot water)
which will reduce production of CO2 and water vapour within the houses.
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PPC Farm Permit Decision Document Template for new applications (general)
Q57/19 Version 1
2.4 Discharges to Groundwater
No emissions from the permitted installation shall give rise to the introduction into groundwater of any hazardous
substance or non hazardous pollutants.
2.5 Waste minimisation
These are standard conditions. IMP2 has been added to ensure a waste minimisation audit is undertaken within 3
years of the effective date of the permit.
2.5.2 Disposal of carcasses
These are standard conditions. Carcasses will be disposed of to a DARD approved rendering plant, or on-site
incineration in a DARD approved incinerator. IMP8 has been included requiring the operator to submit evidence that
the incinerator complies with the Animal By-Product requirements.
These are standard conditions. A number of features have been incorporated into the design of the poultry houses to
reduce the energy consumption e.g. high levels of insulation in the walls and roof. The operator does not participate
in a Climate Change Levy Agreement. Therefore, IMP3 has been added to ensure an Energy Audit is carried out
within 3 years of the effective date of the permit.
2.6 Energy Use
2.7 Accident Prevention and
Management
2.8 Noise and vibration
These are standard conditions. The plan provided with the application was considered satisfactory.
2.9.1 Recording
These are standard conditions. A satisfactory noise management plan including complaints procedure was provided
with the application. The closest third party receptor is a garden centre approximately 120m southwest of the poultry
site. Third party dwellings are located approximately 180m to the south-southeast, 180m south-southwest, 190m
southwest and there are multiple dwellings 300-350m to the west of the installation.
Significant noise impacts are not considered likely from this installation at these distances provided permit
conditions are adhered to. Permit condition 2.8.2 requires deliveries of feed, apart from emergencies, to be restricted
to between the hours of 0700 and 2200 Monday to Saturday, or as otherwise agreed in writing with the Chief
Inspector.
These are standard conditions stating the requirements for recording and monitoring
2.9.2 Emissions and Monitoring
No specific controls are required on either emissions to air or water.
2.10 Decommissioning
These are standard conditions. A satisfactory site closure plan was submitted with the application.
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PPC Farm Permit Decision Document Template for new applications (general)
Q57/19 Version 1
IMPROVEMENT
PROGRAMME
IMP1 has been added to reinforce the need for a water audit to be undertaken within 3 years of the effective date of
the permit. IMP2 requires a waste minimisation audit to be undertaken within 3 years of the effective date of the
permit. IMP3 ensures that the operator will either become part of a CCLA or submit an energy audit within 3 years.
IMP4 will ensure that the operator, or another responsible person working on the installation, will complete training
in Pollution Prevention and Control. IMP5 requires the operator to carry out and submit a review of the site drainage
plan after the site is constructed. IMP6 requires the operator to submit a Nutrient Management Plan for landspreading on any land in Northern Ireland at least 1 month prior to export for land-spreading. IMP7 requires the
inspection and maintenance schedule to be updated to include the operation of the biomass boilers which may be
installed at some time in the future. IMP8 requires the operator to submit evidence that the incinerator complies with
the Animal By-Product requirements. IMP9 requires the operator to submit details of the proposals to export litter
for anaerobic digestion.
CONSULTEE COMMENTS
Public Health Agency (PHA)
Comments and measures in permit where applicable
No concerns were raised by The Public Health Agency. They state that “the principal potential public health
concerns in relation to such facilities would be emissions to air, water and land (odour, gases, effluent, etc.) and
possibly noise. If the applicant carries out all the mitigation measures during the construction and operational phases
as outlined in the application then the Public Health effects would be minimal and the PHA would have no
immediate concerns regarding adverse health effects of the facility related to IPPC issues”.
The closest third party receptor (a garden centre) is at approximately 120m with the closest dwellings approximately
180m from the poultry site. At these distances, significant impacts from odour and dust emissions from a poultry site
of this size are not expected. Check odour modelling carried out by NIEA-IPRI indicates that the odour guideline
value of 3 OU/m3 (as set out in the Environment Agency H4 Odour Management Guidance, March 2011) is unlikely
to be exceeded at either the garden centre or any of the third party dwellings in the area.
No concerns were raised by Newry, Mourne & Down District Council. No further conditions are considered
necessary.
The FSA states that a well managed poultry production facility should present a very low risk of compromising the
safety of the food chain and concludes that provided the operator complies with relevant technical guidance it is
unlikely there will be any unacceptable effects on the human food chain as a result of the operations at the facility.
No further conditions are considered necessary.
District Council
Food Standards Agency (FSA)
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PPC Farm Permit Decision Document Template for new applications (general)
NIEA Conservation,
Designations and Protection
(NIEA-CDP)
Q57/19 Version 1
In their response NIEA-CDP stated they had previously carried out an assessment of this proposal, for planning
application R/2014/0685/F and requested that bird numbers be limited to 74,000 birds. The assessment below is
based on this number.
Use of the AQMAU (EA Air Quality Monitoring Assessment Unit) Ammonia Screening Tool (v4.4) predicts an
ammonia contribution of 0.021µg/m3 (0.7% of the critical level) from the proposed farm on the Murlough
SAC/ASSI which is 2.3 km away. The predicted ammonia contribution is 0.011µg/m3 (1.1% of the critical level) on
the Ballykilbeg SAC/ASSI at 3.5 km and 0.008µg/m3 (0.8% of the critical level) on the Lecale Fens SAC/ASSI at
4.5 km.
CDP carried out a Habitats Regulation Assessment (HRA) when assessing the planning application and concluded
that there will be no likely significant effects on designated sites in the area of the farm (see below for further
details).
IMPACTS ON THE
ENVIRONMENT
European sites
The closest European sites are Murlough SAC/ASSI at a distance of 2.3 km, Ballykilbeg SAC/ASSI at 3.5 km,
Lecale Fens SAC/ASSI at 4.5 km and Hollymount SAC/ASSI at 5.3 km from the proposed poultry houses.
Use of the AQMAU (EA Air Quality Monitoring Assessment Unit) Ammonia Screening Tool (v4.4) predicts an
ammonia contribution of 0.021µg/m3 (0.7% of the critical level) from the proposed farm on the Murlough SAC. The
predicted ammonia contribution is 0.011µg/m3 (1.1% of the critical level) on the Ballykilbeg SAC at 3.5 km,
0.008µg/m3 (0.8% of the critical level) on the Lecale Fens SAC at 4.5 km and 0.006µg/m3 (0.2% of the critical level)
on the Hollymount SAC at 5.3 km.
The predicted ammonia impact at Ballykilbeg SAC is 1.1% of the critical level, i.e. just above the threshold (1%)
above which it is not automatically considered insignificant and an in-combination assessment would be required
with other PPC installations in the area (reference Environment Agency guidance document “Assessing the impact
of ammonia releases from new and expanding intensive farms on nature conservation sites” – August 2013). There
are no other pig/poultry installations within 7.5km of Ballykilbeg SAC that are likely to have a significant impact.
Given that the ammonia contribution from the applicant’s proposed farm is less than 20% of the critical level at
Ballykilbeg SAC, there are unlikely to be any adverse impacts from this development.
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PPC Farm Permit Decision Document Template for new applications (general)
ASSIs
Q57/19 Version 1
Habitats Regulations Assessment
In accordance with Regulation 43(1) of the Conservation (Natural Habitats, etc.) (Northern Ireland) Regulations
1995 (as amended), the Chief Inspector (i.e. Competent Authority) has considered whether the application
(reference: P0476/15A) either alone or in combination (neither being directly connected with, nor necessary to the
management of the site) is likely to have a significant effect on the Natura 2000 site. As part of that consideration,
the Chief Inspector has:(a) Taken into account the mitigation measures contained in the application, along with all legally enforceable
obligations designed to avoid environmental effects;
(b) Applied the precautionary approach set out in the European Commission Guidance “Managing Natura 2000
sites” and as required by the European Court of Justice in C-127/02 (Waddenzee); and
(c) Consulted the Natural Environment Division of NIEA and have regard to any representations made by it
within such reasonable time as the Chief Inspector may specify for the purposes of the assessment or
determining whether an assessment is required for a plan or project.
From the HRA ‘screening’ assessment of the project carried out by NIEA-NED, the Chief Inspector has concluded
that the project would not be likely to have a significant effect on any European site, either alone or in combination
with any other plans or projects.
The closest ASSIs are Murlough ASSI at a distance of 2.3 km, Ballykilbeg ASSI at 3.5 km, Corbally (Lecale Fens)
ASSI at 4.5 km and Hollymount ASSI at 5.3 km from the proposed poultry houses. These sites are also SACs and
predicted impacts are discussed above.
Black Lough ASSI lies 5.6km from the poultry farm. Use of the AQMAU (EA Air Quality Monitoring Assessment
Unit) Ammonia Screening Tool (v4.4) predicts an ammonia contribution of 0.006µg/m3 (0.6% of the critical level)
from the proposed farm on this ASSI.
The predicted impacts are below the threshold (1%) above which it is not automatically considered insignificant and
an in-combination assessment would be required with other pig and poultry installations in the area (reference:
Environment Agency guidance document “Assessing the impact of ammonia releases from new and expanding
intensive farms on nature conservation sites” – August 2013).
Woodgrange ASSI lies 3.9km from the poultry farm but is unlikely to be adversely affected as it is designated for its
Pleistocene geological features.
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Other environmental receptors
Pre Operation Conditions have been included to ensure that all heavily contaminated yard drainage is diverted to
waste water tanks to be disposed of in accordance with DARD CoGAP and that a swale is constructed to treat all
lightly contaminated site drainage to minimise potential for pollution of ground and surface waters (pre-operation
condition 1.4.9). Pre-Operation Conditions also require gas tanks to be protected from collision (1.4.5); fuel to be
adequately contained to minimise potential for surface or ground water pollution (1.4.6) and chemicals to be
adequately contained within a suitable store (1.4.7). All litter is removed from the installation in covered trailers for
combustion, mushroom composting at authorised facilities or land-spreading. All carcasses are removed from the
site for rendering at an approved rendering facility or may be incinerated on site in a DARD-approved incinerator.
People
Odour, Dust or Noise impacts are not expected to be significant at any existing dwellings provided permit conditions
are adhered to. Satisfactory Noise and Odour Management Plans, including complaints procedures, were provided
with the application. Noise, dust or odour concerns were not raised in any of the consultation responses received.
The closest 3rd party receptor is a garden centre approximately 120m to the southwest of the poultry houses and the
closest third party dwellings are approximately 180m south southeast and south southwest of the poultry site.
Check odour modelling carried out by NIEA-IPRI indicates that the odour guideline value of 3 OU/m3 (as set out in
the Environment Agency H4 Odour Management Guidance, March 2011) is unlikely to be exceeded at any of the
third party dwellings in the area or at the garden centre.
Measures described in the odour management plan provided with the application shall be implemented. A
satisfactory complaints procedure was submitted with the odour management plan.
The installation and operation of biomass boilers should help improve the quality of the litter and reduce emissions
from the houses (ammonia, odour). The biomass heating system is an indirect heating system (hot water) which will
reduce production of CO2 and water vapour within the houses (see section 2.3.7 for further details).
It is considered that people should not be unduly affected by emissions (odour, dust, noise) from the poultry unit
provided the conditions set out in the permit are strictly adhered to.
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PPC Farm Permit Decision Document Template for new applications (general)
Overall BAT demonstration.
Q57/19 Version 1
The application and additional information submitted indicates that appropriate measures have been taken to control
the risk of pollution of waterways and that procedures are in place for the control of the handling/storage of waste
materials on the site. The site is designed with a high level of containment. The releases to air from the poultry farm
are predicted to be low. The installation is not a major energy user and is not likely to give reasonable cause for
annoyance due to noise. The combination of measures proposed in the application and required by the permit is
considered to represent the Best Available Techniques for an installation of this nature.
The determination of this application (P0476/15A) is that a permit should be granted.
Completed by:
NIEA – Industrial Pollution & Radiochemical Inspectorate
Date:
September 2015
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