AIE
OES AIE 2023 01
Under the AIE Regs to request a list of intensive agricultural sites that have been notified to the EPA by Local Authorities, which are below the stocking threshold for EPA licencing, to include the date first notified to EPA, and the general reasons for notification
For the purposes of this AIE please consider the years 2021, 2022 and 2023 YTD
https://goo.gl/maps/wWZYKJqHFMFWsFKx9?coh=178572&entry=tt
Licensee
Name of Installation Future Pigs Limited
Licensee Future Pigs Limited
Licence Register No. P0420-03
CRO Number 118651
Site Address Gorteen Lower, Nurney, Kildare
Site Visit Reference No. SV27496
Report Detail
Issue Date 28/02/2023
Prepared By Lisa Maher
Site Visit Detail
Date Of Inspection 07/02/2023
The licensee was found to be in breach of nine conditions of the licence. This level of non-compliance is of serious concern to the Agency.
Two compliance investigations have been opened in relation to digestate management and surface water management.
Enforcement action will continue to ensure compliance is restored in the shortest timeframe possible.
The Licensee is required to submit a response to the non-compliances raised in this site visit report within 30 days
The following site areas were inspected:
• AD Plant and associated digestate lagoons
• Piggery operations
• Storm water drainage system and attenuation tank
• Storm water monitoring points SW3 and SW4
The following documents were inspected during the site visit:
• Monthly available storage capacity for digestate lagoons 1, 2 & 3
Digestate Management
Digestate had overtopped and spilled from storage Lagoon 1 at two locations
Digestate was observed on the surface of the external yard and was flowing from the yard to unprotected ground at the rear of storage containers located at the boundary fence between the AD Plant and Piggery
Digestate was visible on the side slope of Lagoon 1 at the digestate offtake area which had arisen due to a spillage from a damaged pipe
This is non-compliant with condition 6.13.3 whereby there was no containment of digestate which had spilled/overflowed from the digestate storage lagoon resulting in the release of digestate to unprotected ground.
Digestate had spilled and accumulated in the offtake area. The drainage system serving this area which is designed to direct any spillages to an underground sump/tank was blocked and not functioning
The size of this pipework did not facilitate inspection by CCTV during the site visit therefore the integrity of these leak detection systems could not be confirmed. The source of the three pipes at each inspection chamber could not be explained by the licensee’s representatives.
Storm Water Management
Storm water gullies serving the yard area between the Intake Building and Pasteuriser Building at the AD Plant were visually inspected. One gully was blocked, with brown water accumulating on the yard surface. A site operative was observed trying to unblock this gully
Further storm water gullies serving this drainage line were visually inspected and observed to contain dark coloured liquid and solids
The storm water attenuation tank was visually inspected at two locations: the point labelled ADSW1 (approximate location – middle of the attenuation tank) and the immediate down-gradient (d/g) manhole. At this d/g manhole, the contents appeared brown and sludge-like
At the Piggery, a sump covered with a meal bar grid located at the edge of the concrete yard, opposite the Feed Mixing Building was observed to contain black liquid and solids
The Site Plan for the installation indicates that this gully is part of the storm water drainage system, with an outfall to a land-drain at the licensed emission point ref. SW 3. This land-drain flows to the Kildoon River which is a tributary of the Tully River. The Tully River flows into the Barrow River. The Barrow River is an Special Area of Conservation (SAC).
This is non-compliant with conditions 5.3, 6.15.2 & 6.15.4 whereby polluting matter was discharged to the surface water drainage system; the storm water drainage system was not properly maintained; and the surface water system did not contain uncontaminated surface water from impervious areas of the site.
A pool of black liquid was observed on the external concrete yard adjacent to the Brewery Tank which is used to store black grain. It was not clear if there was a gully located underneath this pool of liquid. The Site Plan for the installation indicates the presence of a gully at this location which is part of the storm water drainage system, with an outfall to a land-drain at the licensed emission point ref. SW 3. This land-drain flows to the Kildoon River.
A gully serving the external yard located adjacent to Leak Detection (LD) Point 6, associated with Digestate Storage Lagoon 1, was also observe to be full and contained brown liquid. This gully does not appear on the Site Plan for the installation and therefore it is not known if this gully is part of the storm water drainage system.
A further gully at the Piggery, located outside the roller door serving the Feed Mixing Building was observed to be nearly full and contained black liquid. This gully does not appear on the Site Plan for the installation. Therefore it is not known if this gully is part of the storm water drainage system.
The shut-off valve serving the storm water system at the AD Plant appears to be located within the d/g manhole associated with the storm water attenuation tank.
Storm water emission points SW3 and SW4 were visually inspected. The liquid at SW4 appeared cloudy and grey with evidence of a film on the surface. The was no flow from SW4 during the site visit to facilitate the taking of a sample for analysis. Sewage fungus was observed on the surface of the pipework at SW3. A sample was taken at this discharge point during the site visit.
Upstream of surface water emission points SW4 and ADSW1a, a pipe was observed arising from the bank and overhanging the land drain. The pipe was traced to the rear of mobile homes located adjacent to the Weaner House at the Piggery.
Waste stored on unprotected ground
Rubber chippings which had arisen from the Hydrogen Sulphide scrubber at the AD Plant, were observed stored in flexible Intermediate Bulk Container (IBC) bags on unprotected ground to the rear of Digestate Storage Lagoon 2/side of Digestate Storage Lagoon 3. This waste was not labelled. Staining was observed around the base of these bags. One bag was burst and the contents had spilled on to unprotected ground.
Two dolav bins which contained brown liquid/scum were observed stored on unprotected ground to the rear of Digestate Storage Lagoon 3
Dolavs containing numerous 20/25L drums of various chemicals were observed stored on unprotected ground to the rear of the Weaner House at the Piggery.
Metal waste had been removed from the metal waste skip and was stored on the concrete yard. Liquid was observed arising from this waste stockpile and flowing onto unprotected ground. The base of the metal skip was heavily worn and 3 holes were visible in the base of the skip. Due to the condition of the metal skip it is not appropriate for the storage of waste.
This is non-compliant with condition 8.5 whereby waste was not labelled or stored in designated areas, protected against leachate run-off.
Bunding of liquids
IBCs containing a dark liquid were observed stored un-bunded in the external yard adjacent to the Belly Grass Intake Area of the Intake Building at the AD Plant
Liquid with an iridescent sheen was observed on the external yard adjacent to the Pasteuriser Building. This liquid was traced to the base of the cladding of the Pasteuriser Building and a nearby pedestrian door. Upon visual inspection, black liquid and solids was observed to have accumulated in a bund directly inside this door
This is non-compliant with condition 3.5.2 and 3.5.3 whereby IBCs were stored un-bunded and liquid from the bund in the Pasteuriser building was not diverted for collection and safe disposal.
A mobile bund labelled “3” and located adjacent to LD point 6 at the AD Plant was observed to be nearly full with liquid. The mobile bund for the coolant was observed to contain liquid with a green tint.
Materials Handling
• Digestate was observed on unprotected ground adjacent to the digesters.
• A spillage of green liquid was observed on unprotected ground at the engines associated with the CHP Plant.
• Staining was observed on unprotected ground to the rear of the Weaner House. Staining at the base of the wall of the Weaner House was observed close-by.
• Black liquid was observed pooling on unprotected ground adjacent to the Brewery Tank.
This is non-compliant with condition 8.4 whereby the loading and unloading of materials was not carried out in designated areas protected against spillage and leachate run-off.
• A spillage of white liquid was observed on the yard underneath a trailer parked at the Offloading Area of the Intake Building. The control measure of placing drip trays underneath parked vehicles to capture food and food residues associated with unloading activities was not in place.
• Black grain was observed accumulating on the yard next to the Brewery Tank.
• Bins for storage of pig carcasses were observed on unprotected ground.
Corrective Action Required:
Comply with condition 8.4.
In accordance with condition 6.10, demonstrate the integrity and water tightness of the slurry storage tanks associated with the weaner house. A report in this regard shall be submitted in response to this site visit report.
Staff shall be trained on the actions to be implemented on finding a spillage at the site including the reporting of such spillages to the Environmental Manager. Records of this training shall be maintained onsite.
Bins for storage of pig carcasses shall be held on an impervious surface
Odour
An odour assessment was undertaken by the Agency on 07/02/2023, in accordance with EPA Air Guidance document AG5 (Odour Impact Assessment Guidance for EPA Licensed Sites). Persistent, moderate odours originating from the site were detected at a sensitive receptor beyond, and downwind of, the installation boundary. During the subsequent site visit, odours consistent with those detected off-site were experienced on-site at the piggery.
This is non-compliant with Condition 5.2.
Condensate was observed leaking from overhead pipework associated with the digesters. This leak was identified by an Agency inspector due to the odour arising from the leaking condensate.
Roller door 2 serving the Intake Building was open during the site visit. The licensee’s representative stated that the door had malfunctioned and required repair. This presents a potential pathway for the release of odour to atmosphere.
Residues from operations occurring within the Intake Building where observed on the yard outside roller door 2. Residues are being transferred to the outdoor yard via the tires of vehicles accessing this building.
This represents a potential odour source during warmer weather.
The findings of the report on Negative-Pressure Testing of the Intake Building were discussed. Discussions focused on the report recommendations that: roller door 2 and the roller door to be installed at the opening to the Attritor area should be interlocked; and installation of fasting acting roller doors throughout this building.
Corrective Action Required:
Comply with condition 5.2 & 5.5.2.
Repair the leak in the condensate line without delay.
Implement the recommendations from the report on Negative-Pressure Testing of the Intake Building
Impervious areas of the site
The following observations require action by the licensee to prevent the release of emissions from the installation to ground (soil/groundwater):
At the AD Plant –
• The yard outside roller door 3 of the Intake Building was eroded and damaged.
• The internal floor in the Attritor Area of the Intake Building was eroded and channeling was observed
At the Piggery –
• The yard adjacent to the Feed Mixing Building was cracked/broken.
• Open joints were observed in the internal floor in the Feed Mixing Building. Milk was observed in these joints.
Action Required:
Ensure an impervious surface is maintained at the areas listed above. Submit evidence of same in response to this site visit report
Data Recording/Management System
While a SCADA monitoring system is in place at the installation, there is no associated data recording/management system.
This is non-compliant with Condition 11.7 (iv).
Corrective Action Required:
Install a data recording /management system for the SCADA system without delay.
Inputs to the AD Plant
During the site visit, licensee representatives indicated that various waste/material arising from onsite operations are directed to the intake tanks for the AD process including contents of bunds, the contents of the storm water drainage system and associated tanks etc.
Action Required:
Provide details of all waste/material arising from onsite operations which are input to the AD process.
Include the List of Waste code, where relevant. This information shall be provided in response to this site visit report.
AIE/23/085 Appealed to OCEI
Register of cattle herds with over 500 cattle per head, to include the herd number and location of each cattle farm
AAIE/23/050 Appealed to OCEI
Herd number and location of derogation farms in the Electoral District of Dripsey, Cork in 2021
AIE 23075 Internal Review
Register of poultry flocks with over 10000 / 40000 birds
AAIE/23/074 Internal Review
Pig farms with over 1000 pigs
Reactive nitrogen pollution, particularly ammonia (NH3), when above critical limits adversely impacts biodiversity through eutrophication, acidification or direct toxic effect. Though total nitrogen deposition is a primary driver for species community changes and impacts, the concentration of ammonia should also be considered. Both total nitrogen deposition and ambient ammonia concentrations are above levels that can result in harm to biodiversity at many Natura 2000 sites across Europe and in Ireland. Reactive nitrogen is principally composed of both chemically reduced ammonia and ammonium (NH4+), alongside oxides of nitrogen (NOx). While traffic is the primary source of oxides of nitrogen, agriculture accounts for virtually all ammonia emissions in Ireland.
Although there is substantial evidence that reactive nitrogen causes negative impacts on biodiversity, the relationship between exposure to reactive nitrogen (dose) and negative ecological indicators (effect) is not always straightforward. The complexity of understanding dose-effect relationships increases if multiple factors with negative effects occur concurrently (e.g. adverse effects of air quality occurring at the same time as adverse effects of climate change). Additionally, adverse impacts of reactive nitrogen are likely to occur over long periods of time and may not be immediately visible during a site survey. It is recommended that, although indicators of negative effects may be observed during field visits, these indicators should be used alongside other evidence (such as monitored or modelled concentration or deposition, local sources, local knowledge) to build evidence of adverse impacts on a site. Essentially, ecological indicators alone should not be used as evidence of adverse impacts but rather considered as part of a suite of indicators. Survey indicators could include algal proliferation, presence of nitrogen tolerant species, absence of nitrogen sensitive species, presence of pink or decaying Reindeer Lichen (Cladonia portentosa) or of decaying Sphagnum spp.
A guidance document describing a framework for the assessment of impacts of ammonia emissions from intensive agricultural installations has recently been published in the Republic of Ireland by the Environmental Protection Agency (EPA). Similar guidance has also been published in Northern Ireland, England, Scotland and Wales as well as other European Member States on how reactive nitrogen should be assessed in the context of Environmental Impact Assessment (EIA), Appropriate Assessment (AA) and AA screening. Recent court rulings in the Netherlands support the need to implement science-based and defensible approaches to the assessment and management of agricultural emissions of nitrogen to the atmosphere. There have been two broad approaches applied within Europe to the assessment of potential reactive nitrogen and ammonia impacts on Natura 2000 sites, namely the Critical Criteria Approach and the Integrated Approach.
The Critical Criteria Approach prevents the development of new sources that have a significant potential to adversely affect Natura 2000 Sites but allows the development of sources that do not have significant adverse effects. The Critical Criteria Approach is currently adopted by the majority of Member States who have a policy of dealing with such emissions. The Integrated Approach provides a framework for reducing emissions from existing sources to create room for new activities such as infrastructure, housing or intensive agricultural installations. The Integrated Approach was adopted by the Netherlands in 2015. However, because it allowed credits for reductions to be gained prior to the gains being realised, it was deemed illegal by the Dutch Council of State in 2019. As a consequence, modifications to the integrated approach are currently being investigated in the Netherlands. However, the European Commission commended the integrated approach highlighting it as the most appropriate method to deal with the issue of adverse impacts of reactive nitrogen from agriculture.
The assessment of emissions of ammonia from agricultural developments, required for planning or licence consent, is predominantly undertaken using air dispersion modelling techniques. A range of dispersion modelling approaches are available for the assessment of impacts from agricultural development. These dispersion modelling approaches vary in complexity and accuracy with simple approaches generally overestimating impacts to provide a highly conservative indication of potential
impacts and more advanced modelling approaches generally providing a more representative, yet conservative indication of potential impacts. This Irish Wildlife Manual aims to summarise:
– The effects of emissions of ammonia from intensive agricultural sources and its deposition on biodiversity.
– The regulatory requirements for the assessment of these effects and the indicators of adverse effects including physical observations and theoretical limits used in modelling assessment.
– The approach recommended by the Irish EPA and approaches used in various European Countries that are currently used to assess and report on the potential effects of emissions of ammonia from agricultural development.
– A framework for high-level review of dispersion modelling assessment intended for non-expert users of dispersion models that details a non-technical basis to consider whether the critical components of a dispersion modelling study meet the requirements of dispersion modelling guidance issued by the Irish EPA.
There is no single publicly available database in Ireland that quantifies and locates ammonia emitting activities
Emissions from individual projects that are determined to be insignificant in isolation can be approved using a critical criteria approach. The use of the same approach for multiple projects, either concurrently or consecutively can result in baseline creep, where over time the combined impacts of individually insignificant projects result in a significant adverse impact, that may not be identified using a critical criteria approach.
The predominant source of ammonia in Ireland is cattle farming, which is well dispersed throughout the country. Intensive farming of pigs and poultry contributes a far lower proportion of total emissions of ammonia, but these activities are concentrated in a small number of high production areas, where the effects on biodiversity can be significant.
The border counties of Cavan and Monaghan have the highest concentrations of IED licensed and sub-threshold intensive agricultural facilities. Both Cavan and Monaghan also have high densities of cattle (cattle/km²) compared to the average cattle density in Ireland.
NTIG to establish a working group to address the gaps in processes governing the protection of waters from the movement of animal manures (Source: NTIG Minutes, March 2021)
Extract from minutes:
Recent intensive pig and poultry license applications have seen many farms doubling in size.
The HSE (who gave presentation on issue at NTIG meeting) is concerned about possible impacts of slurry and other animal manures on drinking water quality.
Tracking and following up on the movement of manures between farms is very challenging.
The EPA licensing process for intensive pig and poultry farms does not regulate the management of slurry that is moved offsite
Potential health implications
• Microbial contamination of ground and surface water
• Nutrient enrichment
• There are 380k private well supplies in Ireland; 180k of these are not registered or tested.
• As part of environmental health regulations, 1418 small private supplies are tested. These are generally associated with small food businesses so are subject to inspections by LAs.
Annually, approximately 6% of these inspections show that the private supply is contaminated.
• WHO documents are available on the implications of nitrate pollution of groundwater, which can be carcinogenic.
Suggested control measures
• Risk rating of any potential measures would be key to ensuring effective outcomes.
LAWPRO: Role and experience of LAs, the EPA and others in the control system for manure, animal by products and digestates
• LAWPRO provided an overview of the LA experience, which has shown that there are potential gaps in control measures.
Discussion
• Tracking and transparency are key issues.
• DAFM has moved to an online tracking system may assist with this.
• Geographic concentration of intensive agriculture can lead to increased potential risk in those areas.
• ACTION: NTIG to establish a working group to look at this issue.
Update:
Farms now submit via DAFM (Record 3 form) and that data is submitted to IPPC licencing
System went online at the end of 2021
Screenshot
The PRTR Intensive livestock production and aquaculture sector includes the following activities:
(a) Installations for the intensive rearing of poultry or pigs
(i) With 40 000 places for poultry;
(ii) With 2 000 places for production pigs (over 30 kg);
(iii) With 750 places for sows.
(b) Intensive aquaculture with a production capacity of 1 000 tonnes of fish or shellfish per year.
https://data.gov.ie/dataset/prtr-intensive-livestock-production-and-aquaculture?package_type=dataset
