Decommissioning Management Plan · 10.4 A final validation report to include a certificate of completion for the Decommissioning Management Plan, for all or part of the site as necessary,

Decommissioning Management Plan

For ABP Clones

Final

12th April 2017

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Document Control

Status Draft Final Draft Final Final

Date 24/03/17 07/04/17 10/04/17 12/04/17

Version # 1 2 3 4

Written

Approved

This report has been prepared by Environet Consulting Ireland Ltd, with all appropriate care and diligence within

the terms of the Contract with the client. This Contract incorporates our Terms and Conditions and takes account

of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of works.

This report is confidential to the client and we accept no responsibility to third parties to whom this report, or any

part thereof, is made known. Such parties rely on the report at their own risk.

Dungarvan Business Centre

Fairlane

Shandon

Dungarvan

Co. Clones

Ireland

Tel: 058-51155

Fax: 058-51231

Email: [email protected]

www.environet.ie

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http://www.environet.ie/

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TABLE OF CONTENTS:

1 EXECUTIVE SUMMARY ........................................................................... 1

1.1 Activity Detail ...................................................................................... 1

1.2 Report Preparation .............................................................................. 1

1.3 Comparison with Previous Plans ...................................................... 1

1.4 Overview of the Plan ........................................................................... 2

1.5 Scoping ................................................................................................ 2

1.6 Cost Summary ..................................................................................... 2

1.7 Financial Provision ............................................................................. 3

1.8 Review .................................................................................................. 3

2 INTRODUCTION ....................................................................................... 4

2.1 Site Description ................................................................................... 4

2.2 Site History .......................................................................................... 4

2.3 Classes of Activity Licensed .............................................................. 4

2.4 Licence Requirements ........................................................................ 5

3 SITE EVALUATION .................................................................................. 7

3.1 Operator Performance ........................................................................ 7

3.2 Company Structure ............................................................................. 7

3.3 Environmental Pathways and Sensitivity .......................................... 8

3.4 Processes ............................................................................................ 8

3.5 Inventory of Main Buildings ............................................................. 10

3.6 Inventory of Plant and Equipment ................................................... 11

3.7 Inventory of Raw Materials, Products and Wastes ........................ 12

4 CLOSURE TASKS AND PROGRAMMES .............................................. 15

5 CRITERIA FOR SUCCESSFUL CLOSURE ........................................... 16

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6 CLOSURE PLAN VALIDATION ............................................................. 16

7 CLOSURE PLAN COSTING ................................................................... 17

8 CLOSURE PLAN UPDATE AND REVIEW ............................................. 22

9 RESTORATION/AFTERCARE MANAGEMENT PLAN .......................... 22

10 FINANCIAL PROVISION ........................................................................ 22

Appendix A – Site Location Map

Appendix B – Site Layout Plan

Appendix C – Groundwater Monitoring Reports

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1 Executive Summary

1.1 Activity Detail

Name: Anglo Beef Processors Ireland t/a ABP Clones

Address: Teehill, Clones, Co. Monaghan

IE Licence Number: P0190-02

Activities Licensed: 7.4.1 The operation of slaughterhouses with a carcass

production capacity greater than 50 tonnes per day.

7.8 (a)i The treatment and processing, other than

exclusively packaging, of the following raw materials,

whether previously processed or unprocessed, intended

for the production of food or feed from only animal raw

materials (other than exclusively milk) with a finished

product production capacity greater than 75 tonnes per

day.

RBME Category: B3

1.2 Report Preparation

This report was prepared on behalf of the operator by Environet Solutions.

Environet Solutions

Dungarvan Business Centre

Dungarvan

Co. Clones

1.3 Comparison with Previous Plans

This will be the third Decommissioning Management Plan (DMP) for the site.

Details of previous costs associated with the DMP are given in Table 1.

Year

Cost Financial Instrument Expiry of Financial

Instrument

2013 € 101,368 Parent Company Guarantee No time limit


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Year

Cost Financial Instrument Expiry of Financial

Instrument


Table 1: Decommissioning Management Plan History

1.4 Overview of the Plan

Mr. Alan Setter of Environet visited the site on 16th February 2017. A site tour was

undertaken in the company of Mr John Durkan, Sustainability and Environmental

Manager.

This DMP has been prepared in accordance with the following guidance

documents issued by the EPA:

‘Guidance on Assessing & Costing Environmental Liabilities’, (2014);

‘Guidance on Unit Cost Rates for Verification’, (2014);

‘Guidance on Financial Provision for Environmental Liabilities’, (2015);

1.5 Scoping

Based on all available documentation it has been determined that the site has no

potential long term environmental liabilities as there has been no history of

spillages resulting in soil or groundwater contamination. Therefore, a clean closure

is envisioned for the site and neither restoration nor aftercare management are

expected to be required post closure.

1.6 Cost Summary

The total cost associated with the closure, restoration and aftercare management

of the facility has been estimated to be €330,000.

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1.7 Financial Provision

ABP Clones is part of ABP Beef which is wholly owned by ABP Food Group. ABP

Beef processes c.1m cattle each year and is the largest processor of beef in

Ireland and the UK, and one of the top three processors in Europe.

ABP Food Group has made the necessary provisions to cover the closure

liabilities identified in this report by way of a Parent Company Guarantee pending

approval from the Agency.

Table 2 below details the proposed financial instrument to be put in place.

Type Description Source/ Method

of Quantification

Amount of

Provision

Financial

Instrument

Known liabilities

associated with the

closure of the site

As detailed in

this DMP

As detailed in

Table 8 of this

report

€330,000 Parent Company

Guarantee

Table 2: Financial Instrument

1.8 Review

This closure and restoration/aftercare plan will be reviewed annually and any

updates will be notified to the EPA as part of the sites Annual Environmental

Report (AER).

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2 Introduction

2.1 Site Description

The site is situated approximately 1 km south of the centre of Clones, Co.

Monaghan, a town with a population of approximately 3,000. The site has an area

of approximately 11 hectares.

The facility employs approximately 300 full time staff and the main processes

operate from 7am to 5pm from Monday to Friday with occasional Saturday

operations at busy times of the year.

A Site Location Map is included in Appendix A and a Site Layout Map is included

in Appendix B.

2.2 Site History

The original building on the site was a Workhouse built in the 1840s and closed in

the early 1900s. The workhouse was used as an army barracks in the 1920s and

was then used as a technical college until the 1970s. There was a meat canning

factory on site in the 1950s. Slaughtering began in the 1960s and it became

Clones Meat Packers around 1968. It then became Tunney Meat Packers and

Tunney Meats until 1991 when the site was acquired by Kerry Group who named

the factory Meadow Meats. The factory was then acquired by ABP Food Group in

1995.The Boning hall structure was built in 1975. The lower cold store was built in

1975 and the upper cold store was built in 1985. The current kill floor was

refurbished in 2006 and the new boning hall opened in August 2007.

2.3 Classes of Activity Licensed

ABP Clones has an IPC licence (P0190-02) issued by the EPA on 20th December

2013 for the following activity:

The operation of slaughterhouses with a carcass production capacity

greater than 50 tonnes per day.

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This licence was technically amended to an Industrial Emissions licence on the

23rd December 2013 for the following activities:

7.4.1 The operation of slaughterhouses with a carcass production

capacity greater than 50 tonnes per day.

7.8 (a)i The treatment and processing, other than exclusively packaging,

of the following raw materials, whether previously processed or

unprocessed, intended for the production of food or feed from only

animal raw materials (other than exclusively milk) with a finished product

production capacity greater than 75 tonnes per day.

2.4 Licence Requirements

The preparation of the Decommissioning Management Plan (DMP) is a

requirement under the IE licence;

Condition 10 of the IE Licence requires the following:

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.

10.2 Decommissioning Management Plan:

10.2.1 The licensee shall prepare, to the satisfaction of the Agency, a fully

detailed and costed plan for the decommissioning or closure of the site or

part thereof. This plan shall be submitted to the Agency for agreement

within six months of the date of grant of this licence.

10.2.2 The plan shall be reviewed annually and proposed amendments

thereto notified to the Agency for agreement as part of the AER. No

amendments may be implemented without the written agreement of the

Agency.

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10.2.3 The licensee shall have regard to the Environmental Protection

Agency Guidance on Environmental Liability Risk Assessment,

Decommissioning Management Plans and Financial Provision when

implementing Condition 10.2.1 above.

10.3 The Decommissioning Management Plan shall include as a minimum, the

following:

(i) A scope statement for the plan.

(ii) The criteria which define the successful decommissioning of the activity

or part thereof, which ensures minimum impact to the environment

(iii) A programme to achieve the stated criteria.

(iv) where relevant, a test programme to demonstrate the successful

implementation of the decommissioning plan; and

(v) details of the costings for the plan and the financial provisions to

underwrite those costs.

10.4 A final validation report to include a certificate of completion for the

Decommissioning Management Plan, for all or part of the site as necessary,

shall be submitted to the Agency within three months of execution of the

plan. The licensee shall carry out such tests, investigations or submit

certification, as requested by the Agency, to confirm that there is no

continuing risk to the environment.’

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3 Site Evaluation

3.1 Operator Performance

Environet has reviewed the site’s compliance with its IE licence in 2015 by

reviewing the 2015 Annual Environmental Report (AER).

The most recent audit carried out by the EPA was on 9th September 2015 resulting

in one observation but no non-compliances. There were no environmental

complaints received from the general public during 2015 or 2016. Process effluent

emissions from the site are, for the most part, in compliance with existing licence

limits. Exceedances of the Chloride limit have occurred in recent years as Chloride

in the influent (generated by the water treatment system) pass through waste

water treatment plant unaffected. ABP is currently addressing this issue in

consultation with the Agency.

In general, Environet Solutions found the site to be very well managed and highly

compliant with the requirements of its IE licence. The site has a relatively small

environmental footprint with little potential for significant impact.

3.2 Company Structure

The company’s director(s) and general manager will have specific responsibility for

ensuring financial provisions are in place to cover unknown liabilities and with

regards the implementation of the risk management programme. The financial

manager will have the responsibility to ensure implementation and review of

financial provisions associated with unknown liabilities, whilst the implementation

of risk management programme will be the responsibility of the group

Environmental Manager in coordination with each site Environmental Officer.

The Environmental Management System implemented at the ABP Clones facility

is certified to the revised ISO14001:2015 since 18th Nov. 2016. A key benefit of

operating an EMS is to encourage a review of all processes on-site and their

impact on the environment, and the assessment of how these impacts can be

reduced. ABP maintains a system of continuing improvement and strives to ensure

it meets all environmental commitments and licence conditions.

ABP has in place a dedicated environmental division, namely Group

Environmental ABP Ireland. Environmental management for all ABP facilities is

effected through Group Environmental ABP Ireland, with commitment, support and

participation from top management and all levels of the organisation. The

Environmental Division, headed by the Group Environmental Manager, co-

ordinates and oversees environmental matters on all ABP sites.

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3.3 Environmental Pathways and Sensitivity

The bedrock geology in the area consists of Argillaceous dark grey bioclastic

limestones, with subsidiary shale. Groundwater vulnerability is classified as

Moderate and the aquifer is Regionally Important with fissured bedrock.

The site discharges both treated process effluent and surface waters to a tributary

of the River Finn.

The nearest area of ecological importance is the Kilroosky Lough Cluster

approximately 2km to the north of the facility. This is classified as a Special Area

of Conservation (SAC) and a proposed Natural Heritage Area (pNHA). 4km to the

south of the facility is Lisabuck Lough which is a pNHA. Neither of these sites is

expected to be impacted by the activities of the facility.

3.4 Processes

The activities at ABP Clones comprise the taking in of cattle to the lairage where

the cattle are inspected by Dept. of Agriculture, Food and the Marine personnel.

The cattle are then moved to the knocking area of the slaughter hall and

slaughtered. The carcass of the animal is convoyed through the slaughter hall

where the hide is detached and the feet and head are removed. The installation

has the capacity to slaughter 700 cattle/day.

Evisceration is subsequently undertaken, removing the red and green offal. Green

offal and paunch are conveyed to separate trailers and sent off-site for recovery.

Red offal is trimmed, chilled and packaged and this product is either sent to the

Cold Stores, Vac-Pack store or removed off-site. Fat from the carcasses is

processed in the adjoining fat plant and pumped for temporary on-site storage in

tallow storage tanks which is removed off-site at regular intervals. Hides from the

carcasses are conveyed to the adjoining hide store where they are subsequently

weighed, classified and salted, after which they are placed on pallets and removed

off-site for further processing in a tannery.

After the carcass is split in the slaughtering hall, it is conveyed to the chills where it

is rapidly chilled. After chilling the carcasses are conveyed to the marshalling area

for quartering. Quarters are then either dispatched off-site in refrigerated trucks or

sent to the adjoining boning hall for deboning. The bones from the boning hall are

conveyed directly to trailers. These trailers are covered and sealed prior to

transportation off-site to a further processing facility. Further processing also takes

place on-site in which processed product is placed in consumer packs for dispatch

off-site within 7 days.

Following on-site deboning, the meat product is packed into lined boxes and

dispatched to chills where the product is chilled. Vacuum packed meat from the

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boning hall is sent to the Vac-Pack store where it is stored for up to four weeks

prior to dispatch to the customer.

Process and sanitary effluent are treated by the on-site waste water treatment

plant (WWTP). The waste water treatment plant comprises of preliminary

(screening, dissolved air flotation (DAF), and balancing), secondary (aeration

basin) treatment and tertiary treatment (sand filters). Nitrogen is removed via

denitrification through the WWTP and phosphorus is removed by chemical

precipitation.

Process effluent arises primarily from:

Washing of livestock trucks and the lairage;

Wash water arising from the cleaning of the slaughter hall and process areas;

Sanitary effluent from toilets;

Hand washes and showers taken by staff working in production;

Canteen waste water.

There are no emissions to ground from the ABP Clones site. However, ABP

Clones monitors site groundwater quality on an annual basis as a condition of the

current Industrial Emissions (IE) licence. Results of groundwater monitoring

indicate groundwater of good quality and no indication of contamination.

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3.5 Inventory of Main Buildings

The table below lists the main buildings located at the facility. During the site audit

there was no evidence of asbestos containing materials being present in roofing

materials or pipe lagging. Site management confirmed that to their knowledge

asbestos containing materials are not present at the site.

Table 3 below contains an inventory of the main site buildings and infrastructure.

# Building Construction Activity Area (m2)

1 Lairage Steel frame, external steel cladding, internal

block walls, steel roof, concrete flooring

Cattle staging

area 2,096

2 Slaughter Hall Steel frame, external steel cladding, internal


Production 451

3 Boning Hall Steel frame, external steel cladding, internal


Production 1,041

4 Hide Salting Steel frame, external steel cladding, internal


Production 865

5 Cold Stores Steel frame, external steel cladding, internal


Storage 5,051

6 Vac-Pack Store Steel frame, external steel cladding, internal


Storage 768

7 Administration

Building

Cavity walls and timber trussed roof Offices and

Administration 580

8 Wastewater

Treatment Building

Steel frame, external steel cladding, internal


Wastewater

Treatment 141

9 Boiler House Steel frame, external steel cladding, internal


Utilities 147

10 Car & Trailer Parks Reinforced Concrete or Asphalt Infrastructure 3,827

11 Roadways & Paved

Areas

Reinforced Concrete or Asphalt Infrastructure 14,318

12 External Bulk

Chemical Storage

All mild steel external storage units Storage 35

Table 3: Inventory of Site Buildings & Infrastructure

The costs associated with the removal of all above structures (buildings) in order

to return the site to green field status have not been included in this report. The

facility is located within a largely industrial area. Should closure occur, all buildings

will be emptied and cleaned and drainage services will be cleaned, but these

structures will be sold/leased as part of the site, however will not pose an

environmental risk once the closure plan has been implemented. The units on-site

represent a significant asset to the site and potential future industrial use.

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3.6 Inventory of Plant and Equipment

Buildings Content

Machinery and equipment within the buildings will most likely be redistributed to

other ABP Ireland facilities or sold on to similar type facilities. Where this is not

possible and disposal is the remaining option, all machinery/equipment will be

recovered and/or disposed of in accordance the Waste Management Act, 1996 as

amended. The contents represent a significant financial asset to the ABP group.

Table 4 below lists the main plant and equipment on-site.

Plant/Equipment Location

Refrigeration Equipment Cold Stores

WWTP Equipment WWTP

Air Compressors Boiler House

Boilers Boiler House

Water Softening Plant Water Treatment Room

Reverse Osmosis Unit Water Treatment Room

Fat Melting Plant Fat Plant

Abattoir Line Abattoir

Boning Hall Line Boning Hall

Table 4: Inventory of Plant & Equipment

ABP Clones keeps an inventory of all containment structures, tanks and bunds on-

site. All laboratory chemicals are stored within designated self-contained flame

proof cabinets within the laboratories and as such are not included in the

containment structure inventory in Table 5 below.

# Tank Capacity (litres) Construction Activity

1 Processed Blood 22,500 Stainless Steel Production

2 Tallow Storage 22,000 Mild Steel Production



5 Heavy Fuel Oil 35,000 Mild Steel Production

6 Heavy Fuel Oil 35,000 Mild Steel Production

7 Diesel 2,500 Mild Steel Production

8 Diesel 10,000 Mild Steel Utilities

9 Balancing Tank 2.5 M Glass Coated Mild Steel Wastewater Treatment

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# Tank Capacity (litres) Construction Activity

10 Anoxic Tank 1.8 M Precast Concrete Wastewater Treatment

11 Aeration Tank 1.8 M Precast Concrete Wastewater Treatment

12 Settling Tank 200,000 Glass Coated Mild Steel Wastewater Treatment

13 Sludge Storage Tank 200,000 Glass Coated Mild Steel Wastewater Treatment

14 Water Storage Tank 500,000 Glass Coated Mild Steel Water Storage

15 Office Heating Oil

Tank 1,150

Medium Density

Polyethylene

Utilities

16 Waste Oil Tank 2,500

Medium Density

Polyethylene

Maintenance

17 Cold Stores Oil Tank 2,500

Medium Density

Polyethylene

Utilities

Table 5: Inventory of Tanks

Site management confirmed that all bunds are tested in accordance with the

conditions of the company’s IE licence and are certified by external contractors to

the current EPA recommendations.

3.7 Inventory of Raw Materials & Products

Table 6 below is an estimate of the quantity of raw materials and products stored

on-site at any one time. In order to arrive at an estimated cost for waste removal, it

has been conservatively assumed that 100% of the hazardous portion of this

inventory will need to be removed as part of the DMP process.

In the event of a sudden closure, it is expected than finished product will be sold

on to suppliers. However, if for whatever reason this is not suitable, the product

will be rendered as CAT 3 material. Animal by-product such as CAT 1 and CAT 3

material are of commercial value and it is anticipated that these can be sold. A

maximum of 24 tonnes of such material is stored on-site and this material will be

removed off-site within 48-hours of production ceasing on-site in keeping with

current practices. Following cessation of processing, no further animal by-products

will be generated on-site. Paunch will be removed off-site within one to two weeks

of process cessation and in keeping with current practices; no more than 20

tonnes will be on-site requiring removal off-site. Blood will be removed off-site

within two to three days of process cessation and hides (approx. 24 tonnes) will be

removed off-site within two weeks of process cessation. All animal by-products will

be removed off-site within the timeframes specified in the IE licence conditions.

As hides and meat in cold storage are considered to be easily sold on and as such

no costs have been associated with their removal from site.

It is proposed to return all raw materials to suppliers and/or to redistribute to sister

ABP Ireland facilities or similar processing facilities where possible. There is a

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relatively small volume of chemicals stored on-site and these comprise mainly

cleaning agents. All such chemicals are currently stored in enclosed bunded

containers on-site. Upon closure all chemicals will be removed off-site, either to

other ABP Ireland facilities or returned to suppliers. The final or worse-case

scenario is disposal via an appropriately authorised waste contractor however as

the chemicals are of commercial value to ABP Ireland, it is envisaged that they will

be used at other ABP Ireland facilities.

Type Hazardous

(Y/N)?

Storage

Area Storage Type

Maximum

Storage

Capacity

(tonnes)

Disposal/

Recovery

Option

Salt for hide salting N Salt Store Stockpiled 30 Returned to

supplier

Boiler Chemicals N Boiler Room Bunded IBCs

& Stockpiled 2

Returned to

supplier

Water Treatment

Chemicals (incl. salt) N

Dry Goods

Store Bunded IBCs 30 Sent to Customer

Wastewater

Treatment Plant

Chemicals

Y Dry Goods

Store Bunded IBCs 3

Sent to Alternate

Plant

Production Cleaning

Chemicals Y

Dry Goods

Store Various 2

Sent to Alternate

Plant

Diesel Y Bunded

Tanks

Bunded

Tanks 12

Sent to Alternate

Plant

Sodium Hypochlorite Y

Water

Treatment

Plant

Bunded IBCs 2 Sent to Alternate

Plant

Cat 1 & 3 N Stores Trailered 24 Sent to Alternate

Plant

Paunch N Paunch

Trailer Trailered 20

Sent to Alternate

Plant

Blood N Processing

Area

Bunded

Tanks 22

Sent to Alternate

Plant

Hides N Hide Store Stockpiled 24 Sent to Alternate

Plant

Tallow N Fat Plant Bunded

Tanks 75

Sent to Alternate

Plant

Meats (Finished

Product) (ABP

Owned)

N

VAC-Pac

Store, Cold

Stores

Various

3,500

pallet

space

Sent to Alternate

Plant

Meats (Finished

Product) (Stored for

clients)

N

VAC-Pac

Store, Cold

Stores

Various

3,500

pallet

space

Sent to Customer

Table 6: Inventory of Raw Materials and Products

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3.8 Inventory of Wastes

Tables 7 & 8 below list of all waste materials generated at the site in 2016. For the

purposes of the DMP we assume that 50% of this material will require disposal in

a closure scenario.

Waste description EWC

Code

Source of

Waste

Annual

Quantity

Generated

(tonnes)

Method of

Recovery or

Disposal

Fluorescent tubes and other mercury-

containing waste

20 01 21* Maintenance 0.103 R5 Inorganic

substance recycling/

reclamation

Synthetic engine, gear and lubricating

oils

13 02 06* Maintenance 4.200 R9 Oil re-refining or

other reuses of oil

Absorbents, filter materials (including oil

filters not otherwise specified), wiping

cloths, protective clothing contaminated

by dangerous substances

15 02 02* Maintenance 0.240 R9 Oil re-refining or

other reuses of oil

Gases in pressure containers (including

halons) containing dangerous

substances

16 05 04* Maintenance 0.240 R4 Metal recycling/

reclamation

Total 4.783

Table 7: Annual Hazardous Waste, 2016

Waste description EWC

Code

Source of

Waste

Annual

Quantity

Generated

(tonnes)

Method of

Recovery or

Disposal

Paper & cardboard packaging 15 01 01 Production 30.58 R3 Organic


reclamation

Wood other than that mentioned in 20

01 37

20 01 38 Production 57.74 R3 Organic


reclamation

Metals 20 01 40 Maintenance 7.20 R4 Metal recycling/

reclamation

Mixed municipal waste 20 03 01 Production 130.20 R1 Use as fuel

Total 225.72

Table 8: Annual Non-Hazardous Waste, 2016

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4 Closure Tasks and Programmes

This section focuses on the closure aspects for the activity. The closure plan

includes the decommissioning and decontamination of all of the structures and the

management and safe removal of any residuals arising as a result of

decommissioning and decontamination.

The purpose of the closure process is to ensure that the site no longer poses a

risk of environment pollution and is considered to be environmentally inert.

It is not envisaged that any of the plant and/or equipment will have to be

demolished. These elements, once decommissioned and decontaminated, will be

tested to ensure there is no risk of environmental pollution remaining. The

following steps will be carried out in sequential order to achieve closure of the

production area of the site:

Decontamination and decommissioning of production buildings shall follow

standard site cleaning procedures. All wash waters discharged to WWTP

for treatment. All residual waste and materials removed to waste storage

areas. Due to the nature of the activity as a food processor this

decontamination process takes place each day as an integral part of

production and is not considered to be an additional cost associated with

this DMP.

Emptying of warehouses and decontamination of warehouse buildings.

Material returned to supplier or forwarded to customers, where possible, or

labelled and dispatched to waste storage areas.

Emptying, decontamination and decommissioning of tanks. No residuals to

remain in tanks or pipelines. Residuals to be treated on-site or

recovered/disposed of off-site at appropriate facilities. Shutdown,

decontaminate and decommission boilers. Residual fuels to be removed

from tanks and pipelines.

Removal of all residual waste to waste storage areas.

Clear and clean all office and administration areas. WEEE to be removed

by suitably permitted operator. All other wastes to be dispatched to waste

storage areas.

It is expected that the above operations will take approximately 8-weeks.

Tasks and timings are detailed in Section 7 of this report.

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5 Criteria for Successful Closure

The following criteria have been established to set the benchmark for the

successful closure of the site:

All plant will be safely decontaminated using standard site procedures and

suitably trained personnel;

All waste will be handled, packaged, temporarily stored, recovered and/or

disposed of in a manner which complies with regulatory requirements and

best practice;

All relevant records relating to movement, transfer or disposal of waste will

be managed and retained throughout the closure process and will be

available for review by the EPA;

No soil within the site boundary will be contaminated to a level that poses a

risk to human health or neighbouring properties;

Access to monitoring locations will be maintained at all times during the

closure process;

The site will remain in compliance with its IE licence during the closure

process and until the date of licence surrender;

That any remaining issues are closed out in a timely manner following the

EPA site closure audit;

That the site is left in an environmentally inert state;

That sufficient funds are available to cover the full cost of closure.

6 Closure Plan Validation

Once the closure plan has been implemented the licensee will arrange for an

Independent Closure Audit (ICA) to be carried out by an independent third party

consultant. The qualification and experience of the independent auditor will be

provided and agreed with the EPA prior to the ICA commencing. The scope of the

audit will be agreed in advance with the EPA and, following approval, the chosen

independent auditor will complete the validation audit. The completed Validation

Audit report will be submitted to the EPA for approval.

The EPA may then elect to carry out a final closure audit to verify compliance.

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7 Closure Plan Costing

Closure plan costing is presented in Table 9 below:

Task Description Quantity Unit Unit Rate

(€)

Cost

(€)

Source

Plant & Equipment

Decontamination

Blood Tanks 1 tank 3800 3800 ABP

Tallow Storage Tanks 3 tank 3800 11400 ABP

Diesel & Heavy Fuel Oil Tanks 4 tank 2600 10400 ABP

Associated Pipework 5 day 1 800 4000 ABP

Bunded Areas 3 day 1 800 2400 ABP

Decontamination of Utilities (chillers, boilers, cooling towers,

generators, transformers, etc.) 2 day 1 800 1600 ABP

Wastewater Treatment Plant Tanks 5 day 1 800 4000 ABP

Drain jetting 100–300 mm. Cleaning and surveying of surface

water drainage and foul drainage 2 day 1 800 1600 ABP

Decontamination of

Buildings/Areas

Lairage Building 1 day 1 800 800 ABP

Knocking Area 1 day 1 800 800 ABP

Slaughter Hall 1 day 1 800 800 ABP

Boning Hall 1 day 1 800 800 ABP

Hide Store 1 day 1 800 800 ABP

Vac Pack Stores 0.5 day 1 800 400 ABP

Administration Building 1 day 1 800 800 ABP

Wastewater Treatment Building 2 day 1 800 1600 ABP

Boiler House 0.5 day 1 800 400 ABP

Trailers 0.5 day 1 800 400 ABP

1 Assumes 1 Supervisor and 3 Operatives at current ABP employee staffing rates

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(€)

Cost

(€)

Source

Chemstore 0.5 day 1 800 400 ABP

Fat Plant 1 day 1 800 800 ABP

Plant & Equipment

Decommissioning

Lairage Building 2 day 2 1800 3600 ABP

Knocking Area 0.5 day 2 1800 900 ABP

Slaughter Hall 1 day 2 1800 1800 ABP

Boning Hall 1 day 2 1800 1800 ABP

Hide Salting/Store 0.5 day 2 1800 900 ABP

Vac Pack Stores 0.5 day 2 1800 900 ABP

Administration Building 1 day 2 1800 1800 ABP

Wastewater Treatment Building 2 day 2 1800 3600 ABP

Boiler House 1 day 2 1800 1800 ABP

Trailers 0 day 2 1800 0 ABP

Chemstore 0 day 2 1800 0 ABP

Fat Plant 1 day 2 1800 1800 ABP

Decommissioning of Utilities (chillers, boilers, generators,

transformers, etc.) 3 day 2 1800 5400 ABP

Plant & Equipment

Transport and Disposal WEEE Removal 10 tonne 80 800 Haulier

Plant & Equipment Transport 100 tonne 80 8000 Haulier

Recovery Cost (note nil cost) 110 tonne 0 0 -

Waste Removal 3

Fluorescent tubes and other mercury-containing waste 0.052 tonne 240 12 Waste Contractor

Synthetic engine, gear and lubricating oils 2.100 tonne 290 609 Waste Contractor

2 Assumes 1 Supervisor and 7 Operatives at current ABP employee staffing rates. 3 Assuming 50% of waste arisings for the year will require removal

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(€)

Cost

(€)

Source

Absorbents, filter materials (including oil filters not otherwise

specified), wiping cloths, protective clothing contaminated by

dangerous substances

0.120 tonne 290 35 Waste Contractor

Gases in pressure containers (including halons) containing

dangerous substances 0.120 tonne 7500 900 Waste Contractor

Paper & cardboard packaging 15.290 tonne 80 1223 Waste Contractor

Wood other than that mentioned in 20 01 37 28.870 tonne 50 1444 Waste Contractor

Metals 3.600 tonne 100 360 Waste Contractor

Mixed municipal waste 65.100 tonne 120 7812 Waste Contractor

Decontamination &

Decommissioning Waste

Removal and Disposal

Residual waste from decontamination phase 20 tonne 290 5800 Waste Contractor

Sludge from Wastewater Treatment Plant 4 240 tonne 15 3600 ABP

Materials Removal Oils, Chemicals & Lubricants Transport 12 tonne 80 960 Haulier

Off-Site Transport of Residual Fuels (Diesel & HFO) 83 tonne 80 6640 Haulier

By-Product Transportation 165 tonne 50 8250 Haulier

Packaging Material Transportation 10 tonne 50 500 Haulier

Operation of the Waste

Water Treatment Plant

(WWTP)

Labour & Maintenance 2 month 2200 4400 ABP

WWTP Chemicals 5 tonne 600 3000 ABP

Environmental Monitoring Wastewater Monitoring 60 sample 60 3600 Exova

Surface Water Monitoring 8 sample 60 2640 Exova

Post-Closure Groundwater Sampling 2 sample 2400 4800 Exova

Decontamination Interrogation & Assessment 20 sample 230 4600 Exova

Consultant 3 day 800 2400 Environet

Validation Audit Environmental Closure Audit & Report 1 item 7000 7000 Environet

4 6000 m3 of activated sludge at MLSS of 8,000 mg/l = 48 t dry solids to remove. Assuming sludge is at 20% dry solids then sludge to be removed = 48 x 5 = 240 t

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(€)

Cost

(€)

Source

Management Costs Utilities (assuming production has ceased) 2 month 14000 28000 ABP

Security 2 month 11000 22000 ABP

Management 2 month 10000 20000 ABP

Administration (2 days per week) 2 month 3600 7200 ABP

Insurance 2 month 16750 33500 ABP

IE licence Licence Surrender Fee 1 item 8888 8888 EPA

SUB-TOTAL 271,273

Plus 20% Contingency 54,255

TOTAL € 325,527

Table 9: Closure Plan Costing

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21

The schedule for site closure and remediation works is summarised below:

Table 10: Gantt Chart

Action Wk. 1 Wk. 2 Wk. 3 Wk. 4 Wk. 5 Wk. 6 Wk. 7 Wk. 8

Cease production

Notify EPA and Monaghan County Council of sudden closure

Arrange for sale/disposal of any product or raw materials & products located at

the site at the time of closure

Post-closure environmental monitoring; wastewater, waste, surface water &

groundwater sampling

Decontaminate any plant/equipment

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

appropriate manner

Arrange for sale/recycling of plant/ equipment

Internal Closure Validation audit carried out by or on behalf of ABP Clones

External closure audit by the EPA

Closure Validation Certification issued by the EPA to indicate formal

acceptance of the closure of the site.

Surrender the IE Licence to the EPA

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8 Closure Plan Update and Review

As per the IE licence:

‘10.2.2 The plan shall be reviewed annually and proposed amendments thereto

notified to the Agency for agreement as part of the AER. No amendments may

be implemented without the agreement of the Agency.’

ABP Clones confirms its intention to review the DMP annually and to inform the

EPA of any changes to same via the sites Annual Environmental Report (AER).

9 Restoration/Aftercare Management Plan

As the most recent Groundwater Monitoring report by Exova has indicated that

there are no significant groundwater contamination issues at the site, it has

been decided that the site will opt for a ‘Clean Closure’. Therefore, other than

the requirement to continue to monitor wastewater and surface water emissions

until the licence is surrendered and the management costs associated with the

site, there are not expected to be any other significant aftercare costs.

10 Financial Provision

ABP Clones has agreed to cover the closure liabilities identified in previous

versions of this report by way of a Parent Company Guarantee. ABP Clones is

awaiting approval from the Agency prior to issuing same.

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Appendix A – Site Location Map

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Project Environmental Liabilities Risk Assessment

Client ABP Clones

Drawing Name Site Location ‘Discovery Series’ Map

Version 1

Date 24-03-2017

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Appendix B – Site Layout Plan

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Environet

ABP Clones

Client ABP Clones

Figure 1

Title Site Layout Plan

Date 24/03/2017

Version 1.0

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Appendix C – Groundwater Monitoring Reports

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WATER - POTABLE

Client: Eamon HennebryABP ClonesTeehillClonesCo. MonaghanIreland

Date Sampled:Sample Type:

Category:Date Testing Initiated:Sample Condition:Order No.:Date Received:

219170216H073671N/623751 of 110/08/201623/08/2016

Certificate No.:Job Ref:Sample Ref No.: LSNPage No.:Date Received:Date Reported:

CERTIFICATE OF ANALYSISWell Water Sample 1 (Road) - ABP Clones - 09/08/16

ENVIRO 10/08/2016Satisfactory N/A 10/08/2016

xTest Result Unit Method

Ammonia Nitrogen (as N) mg/l x0.52 ET 038 MEWAM 1981

Conductivity @ 25degC uS/cm# x2180 ET 056/APHA 2012:2510:B

Chemical Oxygen Demand (COD) mg/l# x6 ET 068/APHA 2012:5220D

pH Value pH unit x7.0 ET 124/APHA 2012:4500:H:B

Sulphate by IC mg/l# x1103 ET C98/APHA 2012: 4110 B

Ammonium (NH4) mg/l x0.67 ET 038 MEWAM 1981

T:+353 (0) 21 482 2288E:[email protected]:www.eurofins.ie

Eurofins Cork Limited, Glanmire Industrial Estate,Glanmire, Co Cork, Ireland.

Comments, opinions, grades and interpretations expressed herein are outside this current scope of INAB accreditation. The Laboratory has tested the material/items supplied by the customer as sampled in accordance with the customers own requirements.

All tests are carried out according to our INAB schedule of accreditation unless marked. Tests marked # indicate a non-accredited test result as the value falls outside our current accredited range of measurement and/or scope of accreditation for this test.

16H07367/LSN1N/62375/1/1/1

Dan HealyB.Sc (Hons)

Technical Manager

.

Registered Office: Eurofins Cork Limited, IDA Industrial Estate, Clogherane, Dungarvan, Co Waterford, Ireland. Registered No.570719

Signed for and on behalf of Eurofins Cork Limited.

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WATER - POTABLE

Client: Eamon HennebryABP ClonesTeehillClonesCo. MonaghanIreland

Date Sampled:Sample Type:

Category:Date Testing Initiated:Sample Condition:Order No.:Date Received:

219170216H073671N/623761 of 110/08/201623/08/2016

Certificate No.:Job Ref:Sample Ref No.: LSNPage No.:Date Received:Date Reported:

CERTIFICATE OF ANALYSISWell Water Sample 2 (Rain Tank) - ABP Clones - 09/08/16

ENVIRO 10/08/2016Satisfactory N/A 10/08/2016

xTest Result Unit Method

Ammonia Nitrogen (as N) mg/l x0.35 ET 038 MEWAM 1981

Conductivity @ 25degC uS/cm# x2650 ET 056/APHA 2012:2510:B

Chemical Oxygen Demand (COD) mg/l# x6 ET 068/APHA 2012:5220D

pH Value pH unit x7.0 ET 124/APHA 2012:4500:H:B

Sulphate by IC mg/l# x1503 ET C98/APHA 2012: 4110 B

Ammonium (NH4) mg/l x0.45 ET 038 MEWAM 1981

T:+353 (0) 21 482 2288E:[email protected]:www.eurofins.ie

Eurofins Cork Limited, Glanmire Industrial Estate,Glanmire, Co Cork, Ireland.

Comments, opinions, grades and interpretations expressed herein are outside this current scope of INAB accreditation. The Laboratory has tested the material/items supplied by the customer as sampled in accordance with the customers own requirements.

All tests are carried out according to our INAB schedule of accreditation unless marked. Tests marked # indicate a non-accredited test result as the value falls outside our current accredited range of measurement and/or scope of accreditation for this test.

16H07367/LSN1N/62376/1/1/1

Dan HealyB.Sc (Hons)

Technical Manager

.

Registered Office: Eurofins Cork Limited, IDA Industrial Estate, Clogherane, Dungarvan, Co Waterford, Ireland. Registered No.570719

Signed for and on behalf of Eurofins Cork Limited.

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Documents

Decommissioning Management Plan · 10.4 A final validation report to include a certificate of completion for the Decommissioning Management Plan, for all or part of the site as necessary,