CLOSURE AUDIT R - Environmental Protection Agencyfacility from the rearing of broiler birds to pullet layers for the purposes of producing eggs for market. The pullet layers are sourced

Panther Environmental Solutions Ltd, Unit 4, Innovation Centre,

Institute of Technology, Green Road, Carlow, Ireland.

Mobile: 087-8519284

Telephone /Fax: 059-9134222

Email: [email protected] Website: www.pantherwms.com

CLOSURE AUDIT REPORT

MR PATRICK J CULLINANE DROMONA, CAPPOQUIN,

CO. WATERFORD IPPC LICENCE NO: P0892-01

Report number: RP10128

Date: 28th March 2014

Auditor: Martin O’Looney, BSc. Checked: Mike Fraher, BSc.

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Closure Audit Report Mr Patrick J Cullinane, Dromona, Cappoquin, Co. Waterford

REPORT CONTENTS SECTION SUBJECT PAGE 1.1 Facility Description & History 1

1.2 Methodology & Scoping 3

1.3 Closure Audit Report Executive Summary 4

1.4 Closure Considerations 4

1.4.1 General Comments & Assumptions 4

1.5 Criteria for Successful Closure 5

1.6 Closure Plan Implementation 6

1.7 Summary of Closure Audit 7 2.0 Main Process Area 8

2.1 Broiler Houses No. 1 - 3 8

2.2 Septic Tank, Wash-water Sumps & Litter Storage 8

2.3 Water Tank & Feedstuff Silo Bins 10

2.4 Liquid Chemical & Fuel Storage 11 3.0 General Yard Area 12

3.1 Yard Area 12

3.2 Drainage 12

3.2.1 Storm-water 12

3.2.2 Walls & Groundwater 12

3.2.3 Surface-water 12 4.0 Waste 13 5.0 On-going Utilities & Services 14 6.0 Health & Safety Issues 14 7.0 Aftercare 15

7.1 Monitoring Programme 15

7.2 Closure Plan Validation 17

7.3 Surrender of Licence 17

7.4 Closure Plan Update & Review 17 APPENDICES Appendix A Site Map 18

Appendix B Agency Guidance Checklist 20

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Closure Audit Report Mr. Patrick J Cullinane, Dromona, Cappoquin, Co. Waterford

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1.1 Facility Description & History Mr. Patrick J Cullinane owns and operates a poultry farm at Dromona, Cappoquin, Co. Waterford. The site is licensed by the Environmental Protection Agency (EPA) to carry out the following activity; - The rearing of poultry in installations, whether within the same complex or within 100

metres of the same complex, where the capacity exceeds 40,000 places

On 10th December 2009, Mr. Patrick J Cullinane was granted an Integrated Pollution, Prevention and Control Licence (IPPC), Register Number: P0892-01. This was undertaken in order to meet the requirements of the IPPC Directive (96/61/EC) which was transposed into Irish Law in 2003 with the enactment of the Protection of the Environment Act (PoE) 2003. This was an intensive broiler farm where day old chicks were reared to market weight. The facility is located in a rural area. The farm consists of three broiler houses, litter storage pad, and ancillary facilities/equipment necessary for the operation and management of the farm. The structures and equipment on the site were designed and installed for the purpose of rearing poultry for sale off the site. The farm had the capacity for c 60,000 broiler birds, and is managed by Mr. Patrick J Cullinane. Poultry farming activities have been carried out on this farm since 1982. This site is a well managed modern site, well constructed and in an excellent state of repair throughout. No significant pollution has been caused by operations on the farm in the past. In March 2013, the site was destocked of broilers in order to facilitate closure and a change of enterprise. In March 2014, Mr Patrick J Cullinane changed the enterprise conducted at the facility from the rearing of broiler birds to pullet layers for the purposes of producing eggs for market. The pullet layers are sourced from Shannonvale Foods Ltd., Shannon Vale, Gullane, Clonakilty, Co. Cork at 18 weeks of age and housed in shed three of the farm. The pullet layers are then kept for the purposes of producing eggs for market through Shannonvale Foods Ltd. for a period of 60 to 61 weeks, after which the brood is restocked. The principal legislation regarding the welfare and husbandry of laying hens is “EC (Welfare of Farmed Animals) Regulations, 2010” (S.I. 311 of 2010).

Regulation8(9)(d) states that “A person shall not keep a laying hen in a barn or free- range system, if the laying hens have access to open runs, unless the stocking density does not exceed 9 laying hens per square metre usable area.”

The maximum legal capacity of the facility is 26,604 birds (barn system pullet layers), as per EC (Welfare of Farmed Animals) Regulations, 2010. Mr. Patrick J Cullinane follows industry standard guidance for the management and husbandry of his facility from the “Ross PS Management Handbook, 2013”. The stocking density of the facility has been based on the guidance value of 5.5 birds/m2, as per Table 10, Section 2 – Management into Lay.

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Shannonvale Foods Ltd. is a member of the Bord Bia Quality Assurance Scheme and requires its egg producers to meet standards as set out in “Egg Quality Assurance Standard: Producer/Rearer” Bord Bia, Rev3, June 2009. Mr Cullinane follows advice and guidance from Shannonvale Foods Ltd. in the management of his farm to Bord Bia quality standards. As a result of the reduced stock numbers on-site which now fall below 40,000 birds, Panther Environmental Solutions Ltd was commissioned by Mr. Patrick J. Cullinane to carry out this Closure Audit as part of the surrender of IPPC licence procedure. This report is being prepared as a requirement under the IPPC licence, as follows: Condition 10; Decommissioning & Residuals Management 10.1 Following termination, or planned cessation for a period greater than six months, of

use or involvement of all or part of the site in the licensed activity, the licensee shall, to the satisfaction of the Agency, decommission, render safe or remove for disposal/recovery, any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter contained therein or thereon, that may result in environmental pollution.

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1.2 Methodology & Scoping The EPA guidance documents entitled ‘Guidance to Licensees on Surrender, Cessation and Closure of Licensed Sites’ (EPA 2012), and ‘Guidance on Assessing and Costing Environmental Liabilities’ (EPA 2014) have been used as the basis for the methodology in preparing this report. Section 8.1 of the EPA Guidance 2012 document states that the surrender application process requires the licensee to verify to the Agency: “…that the condition of the relevant installation is not causing or likely to cause environmental pollution and the site of the activity is in a satisfactory state”. This guidance states that main focus of the licence surrender application is the Independent Closure Audit (ICA), carried out by/on behalf of the licensee. The objective of the ICA is essentially to verify the implementation of the Closure, Restoration and Aftercare Management Plan (CRAMP). The initial CRAMP step involved is to scope the requirements of the closure and aftercare management. This report will focus on the Known Liabilities of the site i.e. the planned and or anticipated liabilities associated with facility closure, decommissioning and aftercare management such as monitoring and or reporting required for these. Following an assessment of the facility, materials and activities carried out therein, PES Ltd. has determined that this facility presents a decreased level of risk to the environment as, due to the change of enterprise at the facility, environmental liabilities have been reduced. It is proposed that Mr Patrick J Cullinane’s facility will follow a non-clean closure approach since a smaller scale operation will continue to be conducted at the facility post surrender of licence.

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1.3 Closure Audit Report Executive Summary A site evaluation was carried out on the 27th March 2014 and the main closure considerations were found to relate to the feed silos, water tank, broiler sheds, wash-water sumps, litter storage, and wastes onsite. The closure is considered to be a non-clean closure type, in that upon granting of the surrender of licence based on a change of enterprise, there will be a reduced level of ongoing environmental liabilities at the facility. There is determined to be no necessity for aftercare as there have been no incidences of significant environmental pollution during the facilities operation, and there is determined to be a low risk of significant environmental pollution due to the change of enterprise. It is the determination of Panther Environmental Solutions Ltd. that the condition of the site is not causing or likely to cause significant environmental pollution, and the site of the activity is in a satisfactory state and all environmental liabilities have been addressed. 1.4 Closure Considerations 1.4.1 General Comments & Assumptions In order to meet the requirements of conditions 10.1 of the IPPC licence (Decommissioning & Residuals Management Plan), a series of considerations have been made when preparing this report. The strict environmental policies implemented on site ensure that the change of enterprise of the facility has been a well managed and resourced process. The change of enterprise has therefore been a well planned event for over a period of time, as detailed in Table 5.1 below. Production schedules and raw materials purchasing and storage have been planned with the change of enterprise already factored in.

This closure plan assumes that the facility has been decontaminated and decommissioned so as to be fit for future agricultural use, i.e. the costs for dismantling of buildings etc is not considered under this plan. In the event of the licence not being surrendered, it is assumed that this Closure Plan will be subject to annual reviews as per the IPPC Licence, particularly focusing on the cost and suitable financial provisions and to take into account the changes in the activities carried out at the facility.

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1.5 Criteria for Successful Closure Successful non-clean closure will be expected to be achieved when it can be demonstrated that there is a reduced level of environmental risk at the site. This will require that the following criteria have been met:

1. There will be a reduced risk of environmental pollution after the closure plan is implemented.

2. Operation with due regard to the environment is maintained and actively followed.

3. All broiler sheds are cleaned and completely washed down and disinfected.

4. The stocking density applied conforms with EC (Welfare of Farmed Animals) Regulations, 2010, stocking density limit of 9 hens/m2.

5. Shed one and two silo bins are emptied and completely cleaned.

6. The onsite gas tank and generator are structurally sound and safe.

7. All drains, wash-water sumps, septic tank, and litter storage are structurally sound.

8. Wash-water sumps for sheds one and two are sealed to prevent access of rainwater.

9. All wastes are disposed or recovered in a manner which complies with regulatory requirements.

10. All liquid chemicals are stored in a manner which complies with regulatory requirements.

11. All relevant records relating to waste and materials movement, including all chemicals, and transfer or disposal are managed and retained.

12. Access to monitoring locations will be maintained at all times during the surrender process.

13. Groundwater monitoring records will show no evidence of contamination to a level that poses a risk to human health or neighbouring properties.

14. Site security will be maintained at all times while the site is in ownership of Mr. Patrick J Cullinane.

15. Consultation with the EPA and other interested parties will be maintained.

16. All Health & Safety issues are addressed.

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1.6 Closure Plan Implementation According to the EPA Guidance Note (2014), a project programme with a logical sequence of tasks and timeframes has been developed and included in the Closure Report. This project programme is shown in Table 5.1 below. Test Programme Panther Environmental Solutions Ltd has compiled this final validation report, including a certificate of completion, for the residuals management plan, prior to the EPA being asked to carry out an external closure audit. It is assumed that the findings of this closure audit will demonstrate that the criteria detailed in Table 5.1 have been achieved and this, along with the other information collected as part of the audit, will be sufficient to demonstrate the completion of the site closure in accordance with the CRAMP. The findings of any ongoing storm-water visual inspections will be recorded by the site in accordance with the current conditions of the IPPC Licence and will be submitted to the EPA in accordance with the provisions of the IPPC Licence basis.

It is therefore assumed that the documentation and communications that are to be undertaken by the site before, during and after site closure will be sufficient to demonstrate successful implementation of the CRAMP. Table 5.1 Project Programme for Closure of the Site

Action Mar 13

Apr 13

June 13

July 13

Aug 13

Sept 13

Oct 13

Nov 13

Dec 13

Jan 13

Feb 13

Mar 14

Apr 14

May 14

Notify EPA of intent to surrender licence

Cease Production.

Prepare Closure, Restoration and Aftercare Management Plan.

Empty and clean all broiler sheds, silo’s, pipelines, tanks and sumps.

Arrange for all waste to be taken off-site and recycled/disposed in an appropriate manner.

Arrange for sale/disposal of any product or raw materials located at the site at the time of closure.

Internal Closure Validation Audit carried out by or on behalf of Mr. Patrick J Cullinane.

External closure audit by the EPA – TBC by Agency

TBC

Closure Validation Certification issued by the EPA to indicate formal acceptance of the closure of the site. – TBC by Agency

TBC

Agree the surrender of the IPPC Licence to the EPA. – TBC by Agency

TBC

Continue visual monitoring of storm water.

Re-stocking of Shed 3 with pullet layers.

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1.7 Summary of Closure Plan Implementation Outlined below is a summary of actions carried out to successfully implement the closure plan of the farm, ensuring there will be a reduced level of environmental liabilities remaining on site once the closure plan is completed.

Section Area Timeframe Status 2.0 Main Process Areas 2.1 Broiler Sheds No. 1 - 3

1 Remove all carcasses from last batch to carcass skip for offsite rendering.

March 2013 Completed

2 Remove all litter from the broiler shed floors to the litter storage pad. March 2013 Completed

3 Thoroughly wash down and disinfect broiler sheds 1 – 3, by external contractor.


4 Verify integrity of floors in sheds one and two by visual inspection. March 2014 Completed 2.2 Septic Tank, Wash-water Sumps & Litter Storage Pad

1 Empty and thoroughly clean wash-water sumps, and spread on adjacent land bank.


2 Bung drains leading to shed one and two wash water sumps and cover to prevent entry of rainwater.

April 2014 Completed

3 Remove litter by a registered contractor for land spreading. March 2013 Completed 4 Thoroughly clean litter storage pad. March 2013 Completed

5 Verify integrity of wash-water sumps and litter storage pad in accordance with BS8007:1987 “Design of Concrete Structures for retaining Aqueous Liquids”.


2.3 Water Tank & Feedstuff Silo Bins 1 Empty shed one and two feedstuff silo bins. March 2013 Completed 2 Return remaining feedstuff to suppliers. March 2013 Completed 3 Clean shed one and two feedstuff silo bins. March 2013 Completed 4 Visual Inspection of feedstuff silo bins and water tank. March 2014 Completed

2.4 Liquid Chemical & Fuel Storage 1 Cleaning chemicals properly bunded. March 2014 Completed 2 Gas tank barrier in place. April 2014 Completed 3 Generator structurally sound (visual inspection). March 2014 Completed

3.0 General Yard Area 3.1 Yard Area 1 Remove all refuse and thoroughly clean yard. March 2013 Completed 2 Empty carcass skips from last broiler batch by registered contractor. March 2013 Completed 3 Dispose of general municipal waste. January 2014 Completed

4.0 Waste 1 Maintain records of waste removal onsite. On-going On-going

6.0 Health and Safety Issues

1 Sheds one, two and cleaning chemical store room locked and secured.


2 MSDS sheets for cleaning chemical kept in farm office. On-going On-going

3 Emergency Response Procedure, List of Emergency Contact Numbers, and Incident Record kept in farm office.

On-going On-going

4 Access to top of feed silo bins for sheds one and two restricted. March 2013 Completed 7.1 Monitoring Programme

7.1.2(b) Storm Water Monitoring 1 Maintain record of visual inspections of storm water On-going On-going

7.1.2(c) Ground Water Monitoring

1 Biological results of groundwater monitoring show no contamination posing a risk to human health.

February 2014 Completed

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2.0 Main Process Areas: 2.1 Broiler Sheds No. 1 - 3: The broiler sheds are 925, 925 and 1,106 M3 in area respectively. The roofs of broiler sheds one and two, approx 2,000 square meters, has asbestos cladding, which is in good structural condition. As the site will be used for further agricultural activities, the buildings will remain intact. Therefore, no further action would be required on this asbestos.

Issues and Proposed Actions 1. Remove all carcasses from previous batch to carcass skip for offsite rendering. 2. Remove all litter from the broiler shed floors to the litter storage pad. 3. Thoroughly wash down and disinfect broiler sheds 1 – 3, by external contractor.

Proposed Action Timescale Status

1. Remove carcasses. March 2013 Completed 2. Remove litter. March 2013 Completed 3. Wash and disinfect sheds. March 2013 Completed 4. Verify integrity of floors in sheds one and

two by visual inspection. March 2014 Completed

Sheds one and two are currently being used for the storage of agricultural materials. The floor of the sheds one and two were visually assessed in accordance with the condition 6.5 of the sites IPPC licence, and show no evidence of cracking or spalling, and appear to be in good condition. 2.2 Septic Tank, Wash-water Sumps & Litter Storage Pad The septic tank was built in 2008, and is located behind the chemical store room/farm office. It is a 1.4 M3 tank which is fed from a toilet in the office, however it has not been used since its construction. This tank therefore does not contain any waste so there are no implications in terms of this closure plan. There are three wash-water sumps, fed from the three sheds. Wash water has been spread on the farm owners land bank throughout the operation of the facility. This practice will be continued with wash-water from shed three prior to annual restocking of pullet layers. Litter from the sheds was collected at the litter storage area at the end of every batch. Mr. Patrick J Cullinane has an agreement with a number of farm operators for the use of this litter as an organic fertilizer. Transport of the litter was carried out by a registered contractor and appropriate records have been kept. As a condition of Shannonvale Food Ltd.’s compliance conditions with the Bord Bia Quality Assurance Scheme, poultry litter cannot be stored onsite on farms producing eggs. Litter will be removed from shed three and collected prior to annual restocking of pullet layers. Transport of the litter will be carried out by a registered contractor and appropriate records will be kept.

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Issues and Proposed Actions 1. Empty and thoroughly clean wash-water sumps, and spread on adjacent land bank. 2. Bung drains leading to shed one and two wash-water sumps and cover to prevent entry

of rainwater. 3. Remove litter by a registered contractor for land spreading. 4. Thoroughly clean litter storage pad. 5. Verify integrity of wash-water sumps and litter storage pad in accordance with

BS8007:1987 “Design of Concrete Structures for retaining Aqueous Liquids”.

Proposed Action Timeframe Status 1. Empty and Clean Wash-water Sumps. March 2013 Completed 2. Seal off shed one and two wash-water sumps. April 2014 Completed 3. Removal of litter for land spreading. March 2013 Completed 4. Clean Litter Storage Pad. March 2013 Completed 5. Verify integrity of wash-water sumps and

litter pad. March 2014 Completed

The litter storage pad is currently being used for the storage of agricultural equipment and machinery, and the carcass waste skip. The litter pad was visually assessed in accordance with condition 6.5 of the sites IPPC licence, and shows no evidence of cracking or spalling and appears to be in good condition. A full scale hydrostatic test was conducted on the three wash-water sumps on the 26th and 27th March 2014. Testing was conducted by Martin O’Looney of Panther Environmental Services Ltd. in accordance with condition 6.4 of the sites IPPC licence, and:

British standard BS 8007:1987a – Design of concrete structures for retaining aqueous liquids.

At 09.00am on Wednesday 26th March, the wash-water sumps were flooded with water to pre-determined levels. The water level in the bund was allowed to stabilise for a period of approximately 24 hours. A shallow plastic bund structure was also filled with water and placed adjacent to the rest area for the purpose of recording any evaporation which may occur during the test period. A measuring device was placed within the bund structure and at 09.00am on Thursday 27th March, a start water level was recorded. 6 hours later at 15.00pm, a second water level was recorded. The results of this test are as follows;

Wash-water Sump

Capacity (litres)

Start level (mm)

End level (mm)

Reference Start level

(mm)

Reference End level

(mm) (from ceiling of sump)

Sump 1 4,500 19 19 30 30 Sump 2 4,500 18 18 30 30 Sump 3 6,000 24 24 30 30

There was no drop in water levels and so it was concluded that the sumps are structurally sound.

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2.3 Water Tank & Feedstuff Silo Bins: Wash-water is sourced from the onsite bulk water tank of 10,000 litres capacity. The water tank is fed from an offsite group water scheme reservoir. In the past, this tank was also fitted with a backup feed from an offsite groundwater well, however this has been disconnected. This tank will continue to supply shed three with wash-water, therefore it will remain filled. There are three silo bins onsite, with a capacity of 10 tonne for sheds one and two, and 13 tonne for shed three, which are used for the storage of feedstuffs. The 13 tonne feedstuff silo will continue to be used for shed three pullet layers. The water tank was visually inspected and no evidence of leakage was found. Shed one and two feedstuff silo bins were clean and clear which allowed for a good visual inspection, and were found to be structurally sound.

Issues and Proposed Actions

1. Empty shed one and two feedstuff silo bins by suppliers. 2. Return remaining feedstuff to suppliers. 3. Thoroughly clean shed one and two feedstuff silo bins. 4. Visual inspection of silo bins for structural integrity.

Proposed Action Timeframe Status 1. Empty shed one and two feedstuff silo bins. March 2013 Completed 2. Return remaining feedstuff to suppliers. March 2013 Completed 3. Clean shed one and two feedstuff silo bins. March 2013 Completed 4. Visual inspection of shed one and two feedstuff silo bins and water tank.


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2.4 Liquid Chemical & Fuel Storage:

Stored Liquid Storage Area Storage Type Average Quantity in

Storage (Litre)

Cleaning Chemicals – Disinfectant

Site Yard 1 x Drum 10

1 x Gas Tank Site Yard 1 x 5,000 litre tank 5,000

A circular plastic bund is located in the chemical store room/farm office and is used for the storage of 10 litre drum of Aqua Clean (Hydrogen Peroxide 50%w) cleaning chemical. The bund has a capacity of 41.3 litres, which provides in excess of 25% of total chemicals stored and 110% of the largest container. The bund was visually inspected and was found to be in good condition with no evidence of seepage, cracking or major corrosion. In the front yard of the site there is a 5,000 litre gas tank used for the heating of the pullet layer shed (shed three). A barrier wall has been erected surrounding this gas tank in order to prevent accidental collision by agricultural machinery and delivery vehicles, and mitigate the risk of explosion and accidental release to the environment. A 20 kVA generator also exists’ onsite, which, if needed, is powered by connection to a tractor power-take-off (PTO). It is in place as a backup generator for the facility, and dairy processes which are located adjacent to the licensed site. Therefore, this will be maintained in order to ensure safe operation.


1. Cleaning chemicals stored in a structurally sound bund with sufficient capacity to prevent accidental release to the environment.

2. Gas tank surrounded by a barrier to prevent accidental release to the environment. 3. Generator is structurally sound to prevent accidental release to the environment.

Proposed Action Timeframe Status

1. Cleaning chemicals properly bunded. March 2014 Completed 2. Gas tank barrier in place. April 2014 Completed 3. Generator structurally sound (visual) March 2014 Completed

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3.0 General Yard Area 3.1 Yard Area: Waste carcasses are stored in a covered leak-proof skip which is located in the litter storage area. The carcass skips were emptied at the end of the last broiler batch in March 2013 by Molloy Waste Services Ltd. and sent for rendering at ABP Protein, Ferrybank, County Waterford (see section 4.0). The services of Molloy Waste will be retained for future waste carcass collection. Facility general (black bag) waste is collected along with domestic general waste and disposed of to Youghal Landfill, County Cork by the facility owner.


1. Remove all refuse and thoroughly clean yard. 2. Carcass skips emptied by contractor. 3. General waste removed to landfill.

Proposed Action Timeframe Status

1. Clean yard March 2013 Completed 2. Empty carcass skips by registered contractor March 2013 Completed 3. Dispose of general waste by contractor January 2014 Completed 3.2 Drainage:

3.2.1 Storm-water Rainwater from roofs is collected via a network of storm water pipes and drains and is discharged to collection points at the side of shed two. Monitoring of storm water emissions is carried out as per Schedule C.2.3. of the sites IPPC licence. No emission limit values (ELV’s) are in place in the sites IPPC licence. The licence requires that the monitoring of storm water emissions be carried out for COD/BOD as required by the EPA, and visual inspection be carried out on a weekly basis.

3.2.2 Wells & Groundwater: The well is a group water scheme offsite. Water is fed to a nearby reservoir, with water then pumped to the onsite 10,000 litre wash-water tank. The reservoir also services the adjacent dairy operations and therefore, will be maintained in order to ensure safe operation.

3.2.3 Surface-water There are no discharges to surface water onsite.

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4.0 Waste: Table below details all wastes on-site, including disposal methods and timeframe. Records of disposal have been received for all wastes removed off-site from all contractors. All relevant Permits and licences below are on file.

Waste Type EWC Code

Disposal Method

Waste Collection Contractor

Waste Collection Permit No.

Disposal/Recycling Facility Waste

Permit No.

Est. Amounts Removed

Timeframe Status

Litter / Manure

02 01 06 Land-

spreading Johnny Cotter

Johnny Cotter

Johnny Cotter – Own Lands Kilcannon and

Knocknaskagh, County Wexford

N/A 450 tonnes March 2013

Completed

Wash-water 02 01 99 Land-

spreading Internal N/A

Adjacent Land-bank

N/A 15 M3 March 2013

Completed

Mixed Municipal

Waste 20 03 01 Landfill Internal N/A

Youghal Landfill, Cork County Council

W0068-03 < 1 tonne annually

January 2014

Completed

Waste Carcasses

02 01 02 Rendering Molloy Waste Services

Ltd, Lawlesstown, Clonmel, Co Tipperary

WCP-CK-10-768-01

ABP Protein, Ferrybank, County Waterford

P0205-02 13.6

tonnes March 2013

Completed

Given the change in enterprise at the facility, it is estimated that the following levels of waste will be produced annually;

75 tonnes of litter 6 M3 wash-water, <1 tonne of mixed municipal waste, and <1 tonne of waste carcasses

Mr Patrick J Cullinane will continue to manage waste disposal arrangements as they were prior to the change in enterprise.

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5.0 Ongoing Utilities & Services As the facility will continue to operate after the change of enterprise, on-going utilities and services will be maintained by Mr Patrick J Cullinane.

1. Security Security will be maintained by Mr Patrick J Cullinane. 2. Pest Control The services of Arrest-A Pest Ltd., Clonmel will be retained by Mr

Patrick J Cullinane. 3. Power Reduced requirement as only shed three will be stocked. 4. Water Reduced requirement as only shed three will be stocked. 5. Fuel Reduced requirement as only shed three will be heated. 6. Insurance Buildings and public liability policy will be maintained by Mr Patrick J

Cullinane. 6.0 Health & Safety Issues Onsite

1. Lock and secure chemical store/site office, and broiler sheds one and two. 2. MSDS sheets for cleaning chemicals kept in farm office. 3. Emergency Response Procedure, List of Emergency Contact Numbers, and Incident

Record kept in farm office. 4. Shed one and two feed silo bins – restrict access to top of silos.

Proposed Action Timescale Status

1. Lock and secure Chemical Store, and sheds one and two.


2. MSDS sheets for cleaning chemicals kept in farm office.

On-going On-going

3. Emergency Response Procedure, List of Emergency Contact Numbers, and Incident Record kept in farm office.

On-going On-going

4. Restrict access to top of shed one and two feed silos.


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7.0 Aftercare 7.1 Monitoring Programme (to be agreed with EPA)

7.1.1 Emissions to Atmosphere – Monitoring Future emissions to atmosphere will not be significant due to the smaller scale of the activities conducted at the site, therefore no monitoring is required.

7.1.2 Emissions to Water – Monitoring

Proposed Action Timescale Status 1. Storm water monitoring On-going On-going 2. Groundwater monitoring 28/02/14 Completed

7.1.2(a) Surface Water

There are no emissions to surface water onsite.

7.1.2(b) Storm Water Storm water is to be monitored by visual assessment weekly in accordance with the current IPPC Licence, schedule 6.8 Storm Water, until the licence has been surrendered. Weekly visual inspection of storm-water has been maintained, and no visible evidence of contamination has been observed.

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7.1.2(c) Groundwater The group water scheme supply was analysed on 28/02/2014 to establish whether the soil/groundwater is contaminated from onsite activities. The results of these tests are as follows; St. Davids Poultry Team Ltd., Lab Reference No; 280 22014RM1 Nutwell Estate, Lympstone, Sample Date: 26/02/2014 Exmouth, Devon EX8 5AN, Report Date: 28/02/2014 United Kingdom Client: Shannonvale Ireland

Flock Code: David Cullinane Results:

Parameter Unit Result Total Viable Count @ 37°C CFU/ml 12

Coliform CFU/ml 0 The results of the testing show that the group water scheme water supply is bacteriologically clean, and not effected by facility activities.

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7.3 Closure Plan Validation Upon completion of implementation of the Closure Plan, PES Limited conducted a validation audit on the 27th March 2014 to demonstrate to the EPA that the closure plan has been implemented. This validation closure audit report was completed on the basis of that audit. 7.4 Surrender of the Licence The validation process and certification resulting from it, relate solely to the physical closure of the facility and the formal acceptance of closure. As a result of the reduced stock numbers on-site which now fall below 40,000 birds, the farmer is applying to the Agency to surrender the site IPPC licence. The surrender of this licence must be formally agreed with the EPA. 7.5 Closure Plan Update and Review In accordance with the IPPC Licence ‘the plan shall be reviewed annually and proposed amendments thereto notified to the Agency for agreement as part of the AER’. It is proposed therefore that, in the event of the surrender of licence application being turned down, the closure plan will be subject to review as required by the licence and will reflect any process changes on the site.

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APPENDIX A - SITE MAP ˗

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APPENDIX B

- AGENCY GUIDANCE CHECKLIST ˗ (ATTACHMENT 2 OF THE SURRENDER

APPLICATION FORM)

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Attachment 2: Checklist for Scope for Independent Closure Audit A key requirement of the surrender/closure process is for the Licensee to arrange for a Closure Audit to be undertaken by an

independent expert1. The scope of the Independent Closure Audit must have prior written approval by the Agency before being conducted. See below for what the Independent Closure Audit should address, and what should be reported upon in the Independent Closure Audit Report.

1. Identify and document the decommissioning, rendering safe or removal for disposal/recovery, of any soil, sub-soils, buildings, plant, equipment, or waste materials or substances or any other matter contained therein or thereon, that may result in environmental pollution. This should include:

Waste Inventory/Register listing all wastes arising onsite [description, EWC Codes, tonnages, permit details of hauliers, permit/licence details of final destinations, all relevant documents {C1s, TFS’s etc}. Should confirm whether any hazardous wastes present such as Asbestos [see below], PCBs2, laboratory chemicals, fuel oil, refrigerant gases, ammonia/glycol from chiller units, timber preservatives etc.

Asbestos3: where there is potential for asbestos to be present, require full identification, management and safe removal, if required, by appropriately certified contractor.

Identification of all underground structures including tanks, pipelines and sumps [containing or previously containing fuel, chemicals, slurry, other], with maps, their integrity testing history & records for same. Where there is poor information on this, integrity testing by a Chartered Engineer may need to be conducted during the ICA process to ascertain the current integrity of tanks to inform on risk of previous leakage/contamination.

Documented verification that all plant, equipment, tanks, bunds, sumps will be fully emptied, cleaned and verified as such and contents removed appropriately.

See section 4.0 - Waste of this report.

Sheds 1-2 will not be demolished, as stated in section 2.1 of this report.

See Appendix A – Site Map, and sections 2.1 to 2.4 of this report.

Emptying and cleaning of all items not

applicable due to further agricultural use. See relevant sections of report for works undertaken.

2. Assessment of the potential for soil/groundwater contamination: Has a hydro-geological assessment previously been conducted as part of the licence or due to known contamination

onsite. If so, submit same.

Some level of investigation will be required to be carried out by an appropriately qualified and experienced hydro-geologist professional to establish whether the soil/groundwater is contaminated; the extent of the investigation will vary on a site by site basis and will depend on previous site activities, the condition of the site etc, but should include a Source Audit/Preliminary Risk Assessment/Preliminary Site Assessment [Source-Pathway-Receptor], together with a Conceptual Site Model [CSM]. Development and revision of a good CSM is the overarching framework within which everything else must be based. All potential exposure pathways should be considered. Refer to Model Procedures for the Management of Land Contamination - Contaminated Land Report 11 [EA, 2004], http://www.contaminatedland.co.uk/ [CLEA Website] and any future guidance issued by the

No hydro-geological historically

conducted.

See section 7.1.2 (c) of this report.

1 e.g. a competent, adequately qualified and experienced hydro-geological expert or similar.

2 e.g. from oil in electrical transformers, 3 E.g. in roofing, floor tiles, rope insulation, gaskets

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Agency regarding Contaminated Land and Groundwater. The basic information that should also be provided includes an assessment of recent and available groundwater monitoring results, whether the site overlies a groundwater protection zone and the Aquifer Status and Vulnerability [See: http://www.gsi.ie/Programmes/Groundwater/Aquifer+Classification.htm]. Consideration of the need for further detailed investigation and/or the need for further risk assessment [GQRA, DQRA4] and/or remediation should be considered.

3.

Timescale for completion and submission of the Independent Closure Audit Report. It should include a Declaration as to whether or not the condition of the site is not causing or likely to cause environmental pollution5 and the site of the activity is in a satisfactory state6 and that all environmental liabilities have been addressed.

Included in this report, see;

Timescale – Section 1.6 Declaration – Section 1.3

4.

Identify how environmental liabilities will be dealt with post-closure, and whether any remediation measures are necessary. Submit the following documents where available: Residual Management Plan/Decommissioning Management Plan/Closure Restoration Aftercare Management Plan Financial provision[s]

See section 7.0 of this report for

aftercare considerations. Financial provision for site closure has

been provided by Mr PJ Cullinane’s personal finances.

5.

Proposals for revised sampling, analysis and reporting arrangements on foot of the changes on site, for agreement with the Agency.

See section 7.0 of this report.

6.

Consideration of health & safety issues during decommissioning7 and site security

See sections 5.0 and 6.0 of this report.

7.

The Independent Closure Audit and its Report should be in accordance with all relevant Agency guidance and submitted to the Agency in triplicate.

The EPA guidance documents entitled

‘Guidance to Licensees on Surrender, Cessation and Closure of Licensed Sites’ (EPA 2012), and ‘Guidance on Assessing and Costing Environmental Liabilities’ (EPA 2014) have been used as the basis for the methodology in preparing this report.

4 General Quantitative Risk Assessment, Detailed Quantitative Risk Assessment 5 under S.95[7] of the EPA Act 1992 as amended /S.48[7] of the WMA 1996, as amended 6 under S.95[7] of the EPA Act 1992 as amended 7 e.g. Safety, Health and Welfare at Work (Construction) Regulations 2006 (S.I. No. 504 of 2006)

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Documents

CLOSURE AUDIT R - Environmental Protection Agencyfacility from the rearing of broiler birds to pullet layers for the purposes of producing eggs for market. The pullet layers are sourced