Decision Document for Permit P0385/11A
Determination of a Permit Application for a PPC Landfill Permit under
the Pollution Prevention and Control (Industrial Emissions)
Regulations (NI) 2013 (SR 2013 No. 160) and the Landfill Regulations
(Northern Ireland) 2003 (SR 2003 No. 496)
Decision Document recording the decision-making process
Note: all references to the “PPC Regulations” are to the Pollution Prevention and Control
(Industrial Emissions) Regulations (Northern Ireland) 2013 (SR 2013 No.160) and all references
to the “Landfill Regulations” are to the Landfill Regulations (Northern Ireland) 2003 (SR 2003
No. 496).
Administrative details
Application date
NIEA/Chief Inspector
Application”)
22nd December 2011
reference
(“the
Permit WPPC 12/05
Permit number (the “Permit”)
P0385/11A
Applicant (the “Applicant”)
Eamon Jordan
Address/location of Installation(the “Installation”)
Moira Inert Landfill
Lurgan Road
Moira
Co Armagh
BT67 0LX
Name of Account Officer
Claire Gracey
Signature of Account Officer:
Name of Authorising Officer
Eugene Kelly
Signature of Authorising Officer:
All relevant documents have been sent to the IPPC Public Registers
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Decision Document for Permit P0385/11A
Purpose of this document
The Decision Document ("DD") explains how the Applicant’s Application has been determined
and why the specific conditions in the Permit have been imposed. It is a record of the decisionmaking process to show how all relevant factors have been taken into account.
This DD provides an explanation for the use of the conditions within the Permit.
Summary of the decision
We have decided to grant a Permit that allows the Applicant to operate the Installation, subject
to the conditions set out in this Permit. The conditions have been considered to be appropriate
for the Installation, in particular in taking account of the principle that all appropriate measures
will be taken against pollution and that no significant pollution will be caused. We consider that
in our decision to issue the Permit and in the conditions included therein, we have taken into
account all relevant considerations and legal requirements.
Description of the Permitted Installation
A non-technical summary of the activities covered by the Permit is contained within the
Application. There is also a description of the Installation included in the Introductory Note to
the Permit.
Definitions are the same as described in schedule 7 of the Permit.
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Decision Document for Permit P0385/11A
Part A – Introduction
A1 Administration
This section includes administrative information relating to the Application and
information about the Applicant and the Installation.
"Duly made" check on Application received
The Application was determined to be duly made on 5th January 2012
Consultation on the Permit Application
The Application was advertised by the Applicant on 20th January 2012 in The Ulster Star and
on 20th January 2012 in The Belfast Gazette.
We sent copies of the Application to the following statutory consultees in accordance with Part 2
of Schedule 4 to the PPC Regulations:

Food Standards Agency Northern Ireland

The Planning Service

Public Health Agency

Craigavon Borough Council

NIEA Conservation Designations and Protection

DCal Inland Fisheries

NIEA Water Management Unit

Health & Safety Executive Northern Ireland
Consideration of consultation responses
Responses were received from the following:

Food Standards Agency Northern Ireland

The Planning Service

Public Health Agency

Craigavon Borough Council

NIEA Conservation Designations and Protection

DCal Inland Fisheries

NIEA Water Management Unit

Health & Safety Executive Northern Ireland
We have considered all responses in determining the Permit Application. The ways in which
material responses have been taken into account are summarised in Appendix I to this
document.
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Decision Document for Permit P0385/11A
Schedule 4 Notice
A Schedule 4 Notice for additional Information was issued on 26th March 2012 requesting the following:

Electronic version of site layout

Method statement to assess unspent explosives risk

Geological barrier material specification and testing

Additional groundwater monitoring

Sump water monitoring

Additional HRA

Suspended solid management information

Smooth newt Triturus vulgaris survey

In-waste landfill gas well proposals

Historical waste investigations and report

Details on fencing and gate security
The applicant responded on 24th July 2012 and provided the following:

Electronic version of site layout

Health and safety filling method statement to mitigate explosives risk and confirmation risk was
removed.

Brief detail on the geological barrier selection.

Additional groundwater and sump water monitoring data

Additional HRA

Newt survey report

In-waste landfill gas well proposals

Brief detail on historical deposited waste

Detail that gates will be locked and the site is surrounded by agricultural fencing
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Decision Document for Permit P0385/11A
A2
The Applicant
Fit and Proper Person
The Applicant has been able to demonstrate that it is a Fit and Proper Person to carry out the
Specified Waste Management Activities that are part of the permitted activities at the
Installation.
The considerations taken into account were:
Technical Competence –The Operator has provided evidence that the management of Moira
Inert Landfill will hold the appropriate WAMITAB certificates for the operations carried out at
Moira Inert Landfill Site.
A3
The Installation
Activities
We have determined that the Installation comprises of the following activities listed in Part 1 of
Schedule 1 to the PPC Regulations and the following directly associated activities:
Section 5.2 Part A (a) The disposal of waste in a landfill.
The Site
The Applicant provided a plan (Figure 4 Site Layout Plan – Revision A Dated June 2012) which
we consider is satisfactory for showing the site of the Installation and its extent . This plan is
included in the Permit as Schedule 2. The Operator is required to carry out the Permitted
activities within the site boundary.
The Permit Conditions
1. Management
1.1 General Management
Based upon the information submitted in the Application, we are satisfied that appropriate
management systems and management structures are in place for this Installation and that
sufficient financial, technical and manpower resource is available to the Operator to ensure
compliance with all the Permit conditions.
The condition requires the Operator to submit a site-specific Management Plan that will detail
the procedures to be used to undertake the Activities at the site. We consider that this is
necessary to ensure that we can effectively regulate the Installation. The Operator is required to
undertake the Activities in accordance with the Management Plan, however in order to ensure
that the Operator is able to amend their management of the site, the Management Plan can be
changed, subject to notification to and consent by the Chief Inspector.
Pre-operational Condition (Reference 2. in Table S1.2 of the Permit) requires the operator to
provide the Site Specific Management Plan.
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Decision Document for Permit P0385/11A
1.2 Breach of permit conditions
Condition 1.2 requires the Operator to suspend operations if a permit breach threatens to cause
immediate significant adverse effect on the environment. Any breach of permit condition must
be reported to the Chief Inspector immediately and take measures to ensure that compliance is
restored in the shortest possible time.
1.3 Accidents that may cause pollution
The Application contained a section on accident management. This permit condition requires
that the Operator prepare and operate an appropriate accident management plan in order that
accidents that may cause pollution are minimised.
1.4 Finance
Based upon the information submitted in the Application, we are satisfied that the Operator
intends to, and is able to, make suitable Financial Provision obligations. This condition requires
that the Financial Provision must maintain adequate financial provision throughout the
subsistence of this Permit.
1.5 Energy Efficiency
Condition 1.5 requires the Operator to review energy efficiency every 4 years and implement
any appropriate measures identified by the review.
1.6 Avoidance, recovery and disposal of wastes produced by the activities
Condition 1.6 requires the Operator to ensure that the waste hierarchy referred to in Article 4 of
the Waste Framework Directive is applied to the generation of waste by the activities and any
waste generated by the activities is treated in a accordance with the hierarchy and where
disposal is necessary, this is undertaken in a manner which minimises its impact in the
environment.
1.7 Site security
Condition 1.71 requires the Operator to provide site security that will prevent unauthorised
access to the site.
1.8 Multiple operator Installations
This is not a multi-operator installation.
2. Operations
2.1 Permitted activities
Permitted activities are specified in Schedule 1.
2.2 The Site
The PPC boundary is outlined in red on Figure 4 Site Layout Plan – Revision A Dated June
2012.
2.3 Off-site conditions
No off site conditions apply.
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Decision Document for Permit P0385/11A
2.4 Commencement
The Operator shall not commence disposal in any new phase until the Chief Inspector gives his
agreement in writing.
2.5 Pre-Operational Conditions
Pre-operational conditions are listed in Schedule 1 Table S1.2.
2.6 Improvement programme
Improvement programme requirements are listed in Schedule 1 Table S1.3.
2.7 Engineering.
This condition sets the requirements that the Operator must comply with regarding the
engineering works proposed within the Application. The Operator must submit construction
proposals and CQA documentation prior to any construction taking place and must also submit
CQA validation reports following construction.
2.8 Waste acceptance
Condition 2.8.6 limits the maximum quantity of waste which can be deposited annually to 75,000
tonnes.
2.9 Leachate Management
No condition applies.
2.10 Closure, aftercare and decommissioning
This condition requires the Operator to operate the facility so as to prevent or where that is not
practicable to minimise any pollution risk. The Operator is required to maintain a site closure
plan and review the closure plan every 4 years.
2.11 System for the protection of soil and groundwater
This condition requires the Operator to review the justification that the monitoring is not required
every 5 years. We have decided that the monitoring conditions within the permit fulfil the
requirements of this condition.
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Decision Document for Permit P0385/11A
3. Site infrastructure
3.1 Site access
This condition is included to ensure that the Operator provides and maintains adequate roads
within the Installation and provides wheel cleaning facilities, in order to prevent the tracking of
mud onto the public highway.
3.2 Noticeboards
This condition requires the Operator to provide an appropriate noticeboard for the Installation.
3.3 Liquid storage
This condition sets the requirements for the storage of liquids whose emission to water or land
could cause pollution.
4. Emissions and monitoring
4.1 Emissions to water air or land
On the basis of the details provided in the Application we are satisfied that the only emissions
from the Installation will be from the point sources identified within the Application.
4.2 Emissions to groundwater
On the basis of the Hydrogeological Risk Assessment (HRA) provided with the Application, we
are satisfied that the Operator’s proposals will not result in pollution of groundwater. This
condition requires the Hydrogeological Risk Assessment to be reviewed over the lifetime of the
Installation.
In Table S4.1, control levels have been set for chloride, ammoniacal nitrogen, nickel and
sulphate as suitable substances for assessment of an inert landfill site.
In Table S4.2, trigger levels have been set for chloride, ammoniacal nitrogen, nickel and
sulphate. The trigger levels set for these substances are at the appropriate EALs for these
substances based on the information provided in the Application.
Condition 4.2.4 sets out the actions that the Operator must take upon the exceedance of any
trigger levels. These actions are in accordance with Schedule 3, paragraph 4(1) to the Landfill
Regulations.
4.3 Fugitive emissions of substances
On the basis of the details provided in the Application, we are satisfied that fugitive emissions
that may cause pollution are unlikely to occur. This condition requires the Operator to take
appropriate measures to prevent any such fugitive emissions from causing pollution.
4.4 Odour
This condition requires the Operator to take appropriate measures to prevent any odours at
levels likely to cause annoyance outside the Site.
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Decision Document for Permit P0385/11A
4.5 Noise and vibration
This condition requires the Operator to take appropriate measures to prevent any noise and/or
vibration at levels likely to cause annoyance outside the Site.
4.6 Birds, Vermin and insects
This condition requires the operator to prevent or minimise the nuisance and hazards arising
from birds, vermin and insects.
4.7 Monitoring
On the basis of the details provided in the Application and the conditions within the Permit, we
are satisfied that sufficient monitoring will be undertaken to satisfy the requirements of the
Landfill Regulations and ensure that the impact of the Installation upon the environment is
suitably measured. Monitoring schedules have been amended as stated below:
a) Tables S4.4 and S4.5 provide the emission limits and monitoring requirements for the
discharge points into surface waters.
b) Groundwater. Table S4.1 provides control levels for emissions to groundwater. Table S4.2
provides trigger levels for emissions to groundwater.
c) Table S4.3 sets the monitoring requirements for the groundwater monitoring points.
d) Landfill gas. Table S4.6 sets the monitoring requirements for in waste landfill gas monitoring
boreholes.
e) Particulate Matter. Table S4.7 sets the monitoring requirements for the particulate
monitoring points.
5. Information
5.1 Records
Based upon the information submitted in the Application, we are satisfied that appropriate
procedures are in place to ensure that records are kept. This condition sets the standards for
making and retaining records.
5.2 Reporting
This condition sets the requirements and standards for reporting to the Chief Inspector on the
performance of the Activities.
5.3 Notifications
This condition sets the requirements and standards for notifying the Chief Inspector of specific
events detailed within the condition.
5.4 Interpretation
This condition establishes that the expressions contained within Schedule 7 and used within the
Permit will have the meaning given in that Schedule.
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Decision Document for Permit P0385/11A
Schedule 1 – Operations
Table S1.1 Activities
Based upon the information submitted in the Application, we are satisfied that the listed and
directly associated activities detailed in this Table are those relevant to the Installation.
Table S1.2 Pre-operational Requirements
Based upon the information submitted in the Application, we are satisfied that the requirements
within this Table are necessary to prevent and/or minimise pollution and that they can be carried
out by the due date.
Table 1.2 Pre-operational Measures S1.2 Pre-operational Measures
Reference
Pre-operational Measures
1
The operator shall provide, for the written agreement of the Chief Inspector, additional proposals to those
detailed in the application which will prevent/minimise the impact of suspended solids on discharge waters.
2
The operator shall provide, for his agreement in writing, a Site Specific Management Plan (“the Management
Plan”). The Site Management Plan must include but not be limited to those requirements set out in Condition
1.1.1 of this Permit. The plan must also include detailed methodology and management of historical infill at
the site and groundwater management plan.
The operator shall provide a Construction Quality Assurance Plan for the construction of the groundwater
drainage layer and geological barrier. The CQA must be approved by the Agency prior to the commencement
of construction works. Accordance must be to Environment Agency Guidance Note: Environmental Permitting
Regulations: Inert Waste Guidance: Standards and Measures for the Deposit of Inert Waste on Land. Method
statement for the management of groundwater during drainage layer and geological barrier installation must
also be provided.
3
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Decision Document for Permit P0385/11A
Table S1.3 Improvement Programme Requirements
Based upon the information submitted in the Application, we are satisfied that the requirements
within this Table are necessary to prevent and/or minimise pollution and that they can be carried
out by the due date.
Table 1.3 Improvement Programme Requirements S1.3 Improvement programme requirements
Reference
Requirement
Date
1
The Operator shall produce a report reviewing 12 months monitoring
of groundwater and surface water quality at the site which is under
the permit. The report shall propose revised groundwater trigger
levels (if required) based on the monitored groundwater quality. The
report may suggest a reduced groundwater and surface water
monitoring schedules, justified against the monitored water quality.
The Chief Inspector will provide written confirmation of any changes
to the groundwater trigger levels or monitoring schedules as a result
of this submission.
The Operator shall provide the Chief Inspector, for his agreement in
writing, with proposals for carrying out monitoring and assessment of
particulate emissions, in accordance with the Environment Agency
Technical Guidance Document M17, Monitoring of Particulate Matter
in Ambient Air Around Waste Facilities for the parameters required by
Table S4.7. The proposals shall include, but not be limited to,
identification and justification of monitoring points, operating
procedures for the implementation of monitoring measures,
schedules, techniques, compliance action plans, data management
and reporting procedures, as required in Table S5.1.
The proposals shall be submitted in the form of a revision to the
relevant section of the management plan required by condition 1.1.1
of this permit.
The operator shall provide, for the written approval of the Chief
Inspector, a CQA plan for proposed in-waste landfill gas monitoring
boreholes with timescales for borehole installation.
To be proposed by
the Operator and
agreed in writing by
the Chief Inspector
2
3
To be proposed by
the Operator and
agreed in writing by
the Chief Inspector
To be proposed by
the Operator and
agreed in writing by
the Chief Inspector
Table S1.4 Annual Waste Limits
This table contains the limits on the quantities of waste which can be deposited in the site.
Schedule 2 – Site plan
The site plan (Figure 4 Site Layout Plan – Revision A Dated June 2012) included here clearly
shows the Installation boundary, outlined in red. The Activities permitted by the Permit may only
take place within this boundary.
Schedule 3 - List of Permitted wastes
Table S3.1 details the sources from which wastes which may be accepted at the Installation. All
wastes accepted at the installation must also be in accordance with the requirements of
condition 2.8 of the Permit (Waste Acceptance).
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Decision Document for Permit P0385/11A
Schedule 4 – Emissions and monitoring
The Tables in this section list the limits and monitoring requirements detailed in the discussion
to condition 4.7.
The monitoring requirements have been set in response to the risk assessments provided and
those proposed for the Permit.
Schedule 5 – Reporting
Table S5.1 Reporting of monitoring data
This Table details the reporting requirements for the monitoring that the Operator shall make
under the conditions of the Permit.
Table S5.2 Performance Parameters
This Table details the reporting requirements for the use at the Installation of water (potable and
non potable) and energy.
Table S5.3 Reporting waste
This Table details the reporting requirements for the summary waste return.
Schedule 6 –Notification
This Schedule details the information that the operator must provide regarding any abnormal
operations that have caused, are causing or may cause significant pollution; for any breaches of
a limit or detection of any significant adverse environmental effect.
Schedule 7 – Interpretation
This Schedule provides interpretations of words or phrases used within the Permit.
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Decision Document for Permit P0385/11A
APPENDIX I – Consultee responses
A summary of consultation responses received and the way in which they have been taken in to
account in the determination process:
Response received Brief summary of issues raised
from
Summary of actions taken
or show how this has been
covered
Food Standards Agency
Northern Ireland
No specific action
A well managed inert landfill facility should
present a very low risk of compromising the
safety of the food chain.
Due to the inert nature of the waste to be
disposed of it is unlikely that leachate
containing persistent contaminants and
landfill gas will be generated by the landfill,
provided it is properly managed and that
adequate procedures are in place to
ensure only inert waste enters the site.
The Planning Service
Full Planning Permission for infilling of
existing disused quarry and erection of
commercial business units and office
accommodation with proposed right hand
turning lane at the above address was
granted on 17th August 2010, ref
N/2008/0418/F.
No specific action
The site layout plan shown included with
the PPC Permit Application appears to be
in general conformity with the plans
granted consent with N/2008/0418/F.
Public Health Agency
The Public Health Agency comments that
the principal public health concerns in
relation to such facilities would be
emissions to air and ground (particulate
matter) and the possibility of
noise/vibration.
Conditions within the Permit will
ensure that appropriate measures
are in place to mitigate the impacts of
emissions to air/groundwater and to
reduce noise.
Provided that Eamon Jordan fully
implements mitigation measures proposed
within the application, the PHA would have
no specific IPPC issues.
Craigavon Borough
Council
The Council have no previous role in
respect to the site and are not aware of any
complaints. Sensitive Receptors include:Factory units on Lurgan Road opposite
Quarry and 4 dwellings at No.s 68, 57, 81
& 56 Lurgan Road.
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Conditions within the Permit will
ensure that appropriate measures
are in place to mitigate the effect of
the site on sensitive receptors.
Decision Document for Permit P0385/11A
NIEA Conservation
Designation &
Protection(CDP)
CDP has assessed the potential impacts
from the proposal and is satisfied that
significant impacts to any designated site
are unlikely. However, if future condition
assessment monitoring on any designated
site near the landfill site indicates that the
operations are impacting upon these areas,
CDP may require the licence to be
amended accordingly.
CDP commented that the pond area on site
was a suitable habitat for Smooth Newts.
DCAL
Salmonid habitat identified in receiving
waters.
The processes, emissions and
environmental protection measures to be
incorporated in the operation of this site are
noted. The provision for interception,
suspended solids removal and flow
attenuation of storm water are welcomed.
Appropriate measures will be a
requirement of the Permit.
A Smooth Newt survey was carried
out by Corvus Consulting on 24/7/12.
No newts were found and the site is
not a possible breeding ground.
Pre-operational Condition (Reference
1) within the Permit will ensure that
appropriate measures are in place to
mitigate the effect of suspended
solids on receiving waters.
NIEA Water Management
Unit (WMU)
WMU do not routinely monitor the site.
They have one discharge consent for the
site (No. 233/07). WMU have no issues to
report in relation to the discharge as it is
not monitored. WMU are not aware of any
prosecution action against this site.
No specific action
Health & Safety Executive
The operator would need to take into
account the potential for explosive
substances on the floor of the quarry and
will need specialist assistance in identifying
and remediating this. The developer would
also need to indicate how they intend to
implement the recommendations of the
geotechnical assessment.
The developer submitted a method
statement to address the risk posed
from the potential presence of
misfired explosives in the base of the
quarry and agreed to ensure its
implementation.
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HSENI (Dr Bryan Monson) is content
that the risks have been addressed.
Decision Document for Permit P0385/11A
APPENDIX II –The Risk Assessments
The following paragraphs detail the findings of our technical reviews of the Risk Assessments
that accompanied the Application.
1. Stability Risk Assessment
The Stability Risk Assessment (SRA) was considered to adequately demonstrate the stability of
the installation.
2. Landfill Gas Risk Assessment
The scope of the Landfill Gas Risk Assessment (LFGRA) is considered appropriate to the likely
risks posed by the installation. A condition has been included within the permit to deal with
proposed perimeter landfill gas monitoring boreholes.
3. Hydrogeological Risk Assessment
The Hydrogeological Risk Assessment (HRA) was considered to adequately describe the
relationship between the installation and the local groundwater environment and shows that the
risk to groundwater quality is acceptably low (i.e. compliance with the Groundwater Regulations
will be achieved) in the short, medium and long-term.
4. Habitats Regulations Assessment
The Habitats Regulations Assessment was conducted In accordance with Regulation 43(1) of
the Conservation (Natural Habitats, etc) (Northern Ireland) 1995 (as amended), to consider
whether the application either alone or in combination (neither being directly connected with or
necessary to the management of the site) was likely to have a significant effect on surrounding
habitats.
Moira Inert landfill is situated approximately 7km from Lough Neagh and Lough Beg SPA and
approximately 25 km from Belfast Lough SPA/Belfast Lough Open Water SPA.
No significant effect on the designated sites was determined.
End of Decision Document
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