Mr Pat Waters Manager Cooksgrove Limited trading as Euro Farm Foods Cooksgrove Duleek County Meath

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1 I Environmental Protection Agency An Ghniomhorreocht om Chaomhnu Comhrhaorl Mr Pat Waters Manager Cooksgrove Limited trading as Euro Farm Foods Cooksgrove Duleek County Meath Regional Inspectorate McCumiskey House, Richview, Clonskeagh Road, Dublin 14, Ireland Cigireacht Rbigiunach, Teach Mhic Chumascaigh Dea-Radharc. B6thar Cluain Sceach 8aile Atha Cliath 14, tire T F: E. info@epa.ie W: LoCall: May 2007 Reg. No: PO Dear Mr Waters, I refer to your application for an Integrated Pollution Prevention and Control licence, which was received on 17 April I am to advise in accordance with Article 11(2)(b)(ii) of the EPA (Licensing) Regulations 1994 to 2004, that the following information is required in support of the application under Article 10 of the Regulations: Provide a full development and operational history of the site including slaughter capacity/throughput from date of commencement of the activity. Identify on an appropriately scaled site map the clean yard areas which drain to surface water, and the yards areas from where the storm water is collected and sent to the on-site wastewater treatment plant (WWTP). Identify the location, on a suitable scaled map, and the class of each oil interceptor. Provide details of the quantity of effluent generated in the lairage area (slurry and wash water). Provide details of the storage capacity within the lairage storage tank. Provide details of the proposed new replacement boiler (emission point Al-1) Identify that this is in accordance with BAT for the Slaughtering Sector. Complete Tables E. 1 (i), E.l (ii), E. l(iii) as appropriate. Provide an assessment of the impact of the emissions to atmosphere from the proposed boiler. Complete Table F(2)(i) in relation to SW1 and SW2. Complete Table G. l(i) and G. l(ii) for all process related raw materials, intermediates, products, etc. used or generated on site. Provide details of the refrigeration system and the refrigerant gases used on site. Also include this information in Table G.l(i) and G.l(ii) as appropriate. Complete Tables H.l(i) and H.l(ii), as appropriate, for all wastes generated by the activity. Provide an assessment of the alternatives to the on-site treatment of sewage sludge, from the proprietary septic tank, in the WWTP with subsequent landspreading. All written communications and replies should be directed to Ms Ann Kehoe,>EA, PO Box

2 11. Indicate whether any of the substances specified in the schedule of the EPA (Licensing)(Amendment) 2004, S.I. 394 of 2004, are discharged by the activity to the relevant medium. 12. Describe in outline the main alternatives, if any, to the proposals contain in the application which were studied by the applicant. Waste Water Treatment Plant WWTP) 13. Describe the on-site wastewater treatment process, including hydraulic capacity of each element and treatment capacity in terms of BOD loading. Provide a flow diagram of the WWTP plant processes; details of the process controls associated with each process treatment stage, and operating parameters. Complete Table F. 1.(i) for the WWTP Provide a copy of all monitoring data for the WWTP over the past twelve months period. Provide details of the quantity of wastewater treated (daily, weekly and monthly maximum) and provide details of the quantity of wastewater generated by the truck wash. In the case of the proposal to discharge the emuent from the WWTP to an Integrated Constructed Wetland, provide details of the WWTP upgrade proposals to ensure that the quality of the final effluent is appropriate for final polishing (i.e. emission levels are at least in accordance with BAT for the Slaughtering Sector). Waste Manapement 16. In relation to the current and proposed practice of landspreading of organic waste (wastewater, lorry wash water, lairage waste, alimentary tract contents, and sludge) from the installation: (i) (ii) (iii) (iv) (iv) (v) Provide the concentration of nutrients in the organic wastes sent for landspreading and provide a summary table outlining the maximum quantity of each organic waste generated per annum; Provide a Nutrient Management Plan (NMP) which demonstrates that there are adequate lands for landspreading the total quantity of organic wastes generated by the activity. The NMP shall include suitably scaled maps (1:10560) and include soil sample results where available. Complete Tables E.4(i), E.4(ii), I.4(ii) and 1.4(iii); Provide a suitably scaled map (1:50,000) to identify the all lands used; Provide details of the management of all applications to land including timing of applications, hydraulic loading, land and weather suitability assessments etc.; Provide a description of the organic waste storage facilities, their location, and give details of the available capacity. Identify the storage period, in weeks, provided by the storage facilities; and Provide details of measures to be taken to comply with the requirements of S.I. 378 of 2006, European Communities (Good Agricultural Practice for Protection of Waters) Regulations 2006 (Nitrates Regulations).

3 1 Environmental Protection Agency *" bh"lornb,~m Urn ChWrnh"" iomh,t,mi, Inteprated Constructed Wetland 17. The Agency considers that the proposed Integrated Constructed Wetland (ICW) has a technical connection to the Cooksgrove installation and therefore considers that it should be included in the licence application unless otherwise demonstrated by the applicant to the satisfaction of the Agency. The Agency advises that the ICW shall - not be used for the disposavrecovery of any organic waste including waste water from the activity prior to receipt of all approvals. If the ICW is proposed to be included within the scope of the IPPC licence application please provide the following information: i. ii. iii. iv. v. vi. vii.... viii. ix. Provide details of the planning status of the ICW; Provide a map of the ICW with the boundary of the area highlighted in colour and identified as part of the installation; Provide details of the calculations used to size the ICW; Provide details of the site assessment undertaken prior to construction of the ICW; Provide details of the proposed arrangements for the transportation and discharge of treated wastewater from the on-site WWTP to the ICW. Provide details of all discharges (surface water, groundwater, etc) from the proposed ICW including emission rates, and concentration of parameters in the discharges; Provide details on the receiving water body including water quality, classification (Q rating, water framework directive etc) and flow rates (95%ile and dry weather flow). Provide details of the predicted impact of the discharge from the ICW on the receiving water body by means of assimilative capacity calculations; Assess the impact of the emissions from the ICW to ground, groundwater and the atmosphere; Provide details of the measurements taken during the construction to confirm the quality of the construction works completed, provide copies of any signoffs completed by a suitable qualified engineer during the construction of the ICW. Also provide details of all measures taken to demonstrate the permeability beneath the ICW ponds; x. Provide details of the proposed daily discharge to the ICW from the installation. Provide a mass balance for effluent movements in the ICW, the mass balance shall take account of, but shall not be limited to, the inputs and outputs of effluent, and any losses to groundwater and the atmosphere; xi. Provide details of any service and maintenance contract which you have in relation to the ICW; xii. Complete Table E.2 (ii) of the application form with the predicted effluent discharge concentrations; xiii. Provide details and calculations of the treatment provided as the effluent passes through the ICW; and

4 18. xiv. Provide details of all proposed operating controls, proposals for monitoring of emissions from the ICW (surface water, groundwater etc) and ambient environment. The following information shall be prepared by an independent, professionally qualified and indemnified hydrologist: i. Provide a hydrogeological description of the site (i.e. conceptual model including plan and section drawings) and immediate surrounds of the ICW (c. 500 metres), the description shall include depth to groundwater, flow direction and identification of springs, wells, deep drains or standing water. All identified features shall be identified on a suitable scale map; iii. iv. Provide a comprehensive risk assessment report and an analysis of the risk posed to each receptor by means of the Source-Pathway-Receptor model; Based on the risk assessment identify measures, as necessary, that shall be taken to minimise risk to the environment; Characterise the subsoil types underlying the ICW, the thickness of the various layers, including lateral and vertical variations; v. Provide the classification of the bedrock geology, and the classification of the subsoil; vi. Provide an assessment and proposals to ensure a permeability rating of 1 x 1 O-* d s beneath all ICW ponds. The installation of a liner system shall be investigated as part of the assessment; and vii. Identify appropriate groundwater monitoring points around the ICW based on the flow direction of the groundwater beneath the ICW site. Fit and Proper Person 19 Demonstrate that the applicant is in a position to meet any financial commitments or liabilities incurred by the carrying on of the activities relating to this application. These commitments include compliance with the Integrated Pollution Prevention and Control (IPPC) licence (if issued) and its conditions and also the environmental liabilities concerned with the ceasing of activities pertaining to the application and the return of the site to a satisfactory state. In addition to the above please also provide an updated non-technical summary to reflect the information provided in your reply. The requested information should be submitted to the Agency within eight weeks of the date of this notice, in order to allow the Agency to process and determine your application. In the circumstances, you should make immediate arrangements to have the required document(s) (1 signed original and 2 copies in hardcopy format, and 2 copies of all files in electronic searchable PDF format on CD-ROM) submitted to the Agency without delay. Your response to this request should be directed to Ann Kehoe, Administration Officer, Office of Licensing & Guidance.

5 It should be noted that the eight-week period within which the Agency is to decide the proposed determination will commence on the day on which this notice has been complied with. If you have any further queries please contact Mr Stuart Huskisson at the number above. Yours sincerely,j$s- Stuart Huskisson Inspector Office of Licensing & Guidance