Decision Document for Permit Number P0474/15A (James Anderson) CONDITION(S) 1.1The permitted activities 1.2.1 The site 1.3 Overall Management JUSTIFICATION 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 71,000 broilers. The site may also produce turkeys for certain crops of the year. If turkeys are produced a maximum stocking capacity of 30,000 turkeys could be reared to 6 weeks of age and then 50% removed off site, with the remaining 15,000 turkeys to be finished on the site. The birds will be housed in 3 existing houses of timber construction – two houses are naturally ventilated and the third has high speed 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 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 IMP7) require the operator to submit a full Nutrient Management Plan prior to first exporting litter from the site for spreading on third party land in Northern Ireland. The houses will be heated by means of biomass boilers and permit conditions have been included to control emissions from this activity - LPG boilers will provide backup. 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 and associated fuel tanks and part of the swale. These are standard conditions. PPC Farm Permit Decision Document Template for new applications (general) 1.4 Pre-operation conditions 1.5 Off site conditions 1.6 Minor operational changes 2.1 Farm Management Techniques Q57/19 Version 1 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 section 2 in 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 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 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. These are standard conditions. IMP4 has been added to ensure appropriate IPPC training is completed within 12 months of the effective date of section 2 of the permit 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. 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. Page 2 of 9 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 2.3.6 Odour 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 house. A SSAFO approved tank is already in operation for the existing poultry house. Pre-Operation Condition 1.4.3 has been added to ensure that a separate drainage system is provided to collect wash water from the two poultry houses 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 two poultry houses 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. 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, 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 export litter from his poultry farm for spreading on land 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 IMP7) require the operator to submit a full Nutrient Management Plan prior to first exporting litter for spreading in Northern Ireland on third party land. An anaerobic digestion outlet has not yet been identified but permit conditions (2.3.5.1 and IMP6) 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 up to 554T per year. These are standard conditions. Page 3 of 9 PPC Farm Permit Decision Document Template for new applications (general) 2.3.7 Operation of biomass heating system 2.4 Discharges to Groundwater Q57/19 Version 1 The closest third party dwelling is approximately 400m South West of the poultry site. Odour screening carried out by NIEA predicts 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. 3 existing poultry houses - two houses are naturally ventilated and the third has high speed roof mounted fans. 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 – for further details see section 2.3.7. 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 existing poultry houses by means of biomass boilers with LPG burners as a back-up. New 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 variation 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. No emissions from the permitted installation shall give rise to the introduction into groundwater of any hazardous substance or non hazardous pollutants. Page 4 of 9 PPC Farm Permit Decision Document Template for new applications (general) 2.5 Waste minimisation 2.5.2 Disposal of carcasses 2.6 Energy Use 2.7 Accident Prevention and Management 2.8 Noise and vibration Q57/19 Version 1 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. These are standard conditions. Carcasses will be disposed of to a DARD approved rendering plant, or on-site incineration in a DARD approved incinerator. IMP10 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. These are standard conditions. The plan provided with the application was considered satisfactory. 2.9.2 Emissions and Monitoring These are standard conditions. A satisfactory noise management plan including complaints procedure was provided with the application. The closest third party dwelling is approximately 400m South West of the poultry site. Significant noise impacts are not considered likely from this installation at this distance 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. Condition 2.9.1.8 requires records of biomass deliveries to be maintained. 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. 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 details of the proposals to export litter for 2.9.1 Recording Page 5 of 9 PPC Farm Permit Decision Document Template for new applications (general) CONSULTEE COMMENTS Public Health Agency (PHA) District Council Food Standards Agency (FSA) NIEA Conservation, Designations and Protection (NIEA-CDP) Q57/19 Version 1 anaerobic digestion. IMP7 requires the operator to submit a Nutrient Management Plan for land-spreading on any third party land in Northern Ireland at least 1 month prior to export for land-spreading. IMP8 requires the inspection and maintenance schedule to be updated to include the operation of the biomass heating system. IMP9 requires the operator to submit evidence that the incinerator complies with the Animal By-Product requirements. 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 (ammonia, dust, odours, 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 dwelling is approximately 400m South West of the poultry site. At these distances, significant impacts from odour and dust emissions from a poultry site of this size are not expected. The results of NIEA in-house screening indicate that odour impacts from the site will be acceptable at all existing 3rd party dwellings and that dust impacts will be acceptable at all existing dwellings. Causeway Coast and Glens Borough Council response confirms that they have no record of any previous complaints about emissions from the site and note that there are potentially sensitive receptors at 473 metres from the site. No further conditions are considered necessary. The FSA response states that a well managed poultry production facility with appropriately trained staff 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 additional conditions are considered necessary. In their response NIEA-CDP stated that “using SCAIL to project the likely output of ammonia to nearby designated sites including White Rocks ASSI, Portballintrae ASSI, Craigahulliar ASSI, Runkerry ASSI, Ramore Head and the Skerries ASSI, Portrush West Strand ASSI, Giant’s Causeway and Dunseverick ASSI, North Antrim Coast SAC and Garry Bog SAC/ASSI a stocking capacity of 71,000 birds would result in a process contribution of less than 10% of the critical level of each site. In-house check modelling carried out by NIEA-IPRI using the EA AQMAU (Air Quality Monitoring Assessment Unit) Ammonia Screening Tool (v4.4) predicts that impacts will not be significant ie. <0.03 at all local habitats (<1% of habitat critical levels). The predicted impacts are below the threshold (1%) above which it is not considered insignificant and an in-combination assessment would be required with other PPC Page 6 of 9 PPC Farm Permit Decision Document Template for new applications (general) Q57/19 Version 1 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). IMPACTS ON THE ENVIRONMENT European sites The closest European sites are Skerries & Causeway SAC at approx. 4.1km and Garry Bog SAC at approx. 7.1km from the poultry site. In-house check modelling carried out by NIEA-IPRI using the EA AQMAU (Air Quality Monitoring Assessment Unit) Ammonia Screening Tool (v4.4) predicts that impacts will not be significant ie. <0.008ug/m3 ammonia at all local habitats (<1% of habitat critical levels) ie. 0.008ug/m3 at Skerries & Causeway SAC (0.26% of critical level), and 0.003 at Garry Bog SAC (0.3% of critical level). Therefore, as the impacts are predicted to be less than 1% of the critical levels for these habitats they are not considered significant. Habitats Regulations Assessment (HRA) 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: P0474/15A) 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 European 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; and (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). ASSIs From the HRA ‘screening’ assessment of the project carried out, 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 ASSI’s are: Craigahullier ASSI @4.3km (rock features); Prolusk ASSI @8.6km. Causeway Coast ANOB is also located approx. 1.8km. In-house check modelling carried out by NIEA-IPRI using the EA AQMAU (Air Quality Monitoring Assessment Unit) Ammonia Screening Tool (v4.4) predicts that impacts will not be significant ie. <0.03 at all local habitats (<1% of habitat critical levels) ie. 0.008ug/m3 at Craigahullier ASSI (0.26% Page 7 of 9 PPC Farm Permit Decision Document Template for new applications (general) Other environmental receptors People Q57/19 Version 1 of critical level), and 0.004 at Prolusk ASSI (0.13% of critical level). Therefore, as the impacts are predicted to be less than 1% of the critical levels for these habitats they are not considered significant. 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 1.4.9). Pre-Operation Conditions also require gas tanks and feed bins 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, anaerobic digestion at authorised facilities or land-spreading. All carcasses are incinerated on-site or removed from the site for rendering at an approved rendering facility. 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. The closest third party dwelling is approximately 400m South West of the poultry site. Check odour screening carried out by NIEA predicts 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. 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. Overall BAT demonstration. 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. 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 Page 8 of 9 PPC Farm Permit Decision Document Template for new applications (general) Q57/19 Version 1 considered to represent the Best Available Techniques for an installation of this nature. The determination of this application (P0474/15A) is that a permit should be granted. Completed by: NIEA – Industrial Pollution & Radiochemical Inspectorate Date: August 2015 Page 9 of 9