GES Limited Ground and water environment consultants

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1 GES Limited Ground and water environment consultants Geotechnical & Environmental Services Ltd., Campus Innovation Centre Green Road, Carlow Ph: Fax: Landspread Assessment (additional lands) Job No: Report No: Date: 28/07/08 Site: Spreadlands in Ballon, Co. Carlow Client: Ballon Meats Ltd Raheenkillane, Ballon, Co. Carlow EPA Export :01:17:09

2 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Contents 1. Introduction 1.1 General 1.2 Sources of Information 2. Generalised Description of the Existing Environment 2.1 Topography, Surface Water Features and Climate 2.2 Geology Bedrock Geology Soil and Subsoil Geology 2.3 Hydrogeology 3. Risk Assessment 3.1 Introduction 3.2 Hazard 3.3 Pathways 3.4 Targets 3.5 Risk Mitigation 4. Assessment of Landspread Areas 4.1 Introduction 4.2 Discussion Appendices 1. Summary Spreadsheet detailing aquifers and vulnerability 2. Regional Location Maps 3. Excluded Areas (provided by GES). 4. GSI Response Matrix for Landspreading Report prepared by: Report checked by: Eoin Fitzpatrick Jer Keohane EPA Export :01:17:09

3 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July INTRODUCTION 1.1 General Geotechnical and Environmental Services Limited were requested by Ballon Meats, Ballon, Co. Carlow to undertake an independent assessment of hectares for the Ballon Meats onsite landbank where it is intended to dispose of organic waste generated at the Ballon Meats facility at Raheenkillane, Ballon, Co. Carlow through controlled landspreading procedures. This study comprises the assessment of soil conditions, surface water and groundwater and their inter-relationship in the areas in which it is proposed to spread organic waste together with an assessment of the potential impact of landspreading. The proposed landbank is wholly owned by Ballon Meats and this assessment is required as part of the proposed IPPC (Integrated Pollution Prevention and Control) Licence for the Ballon Meats facility. This study was undertaken between June and July The overall study comprised the following phased approach. A desk study of available information on the Geology, Aquifer and Groundwater Vulnerability Classifications for the additional proposed landspreading areas. Elimination of areas deemed unsuitable for landspreading based on the information gathered, including information from the walk-over survey undertaken by GES Ltd. Preparation of the report. This report provides information on the following items: Description of Existing Environment Physical Features Location and size of proposed landspread areas Natural and artificial surface water features Existing land-use Topography, slopes and surface water run-off susceptibility 1 EPA Export :01:17:09

4 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Geology and Hydrogeology Geological description of bedrock and subsoils Permeability of subsoils Depth to bedrock Aquifer classification Groundwater Vulnerability Local hydrogeology Borehole locations Localised groundwater flow Assessment of the likely Impacts of Landspreading The proposed landspread areas are grouped into larger sections, which are independently assessed based on Risk Management Principles, taking into account: The existing environment and the available guidelines on good farm practice. Assessment guidelines for landspreading areas Guidelines on aquifer vulnerability and protection 1.2 Sources of Information The findings of the assessment (desk study) are presented in spreadsheet format and refer to the farm plots as detailed on the map sets prepared by GES Ltd. The sources of information used in this study are as follows: The 1:100,000 scale Bedrock Geology map of Carlow - Wexford, (Sheet 19) (Geological Survey of Ireland, 1995) The South-eastern River Basin District Interim Vulnerability Map and the National Aquifer Map available at the Geological Survey of Ireland website. The O.S. 6 - inch maps provided by GES Ltd outlining the location of the farm. 2 EPA Export :01:17:09

5 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 The O.S Discovery Series Map No. 61. Archive maps (at a scale of 6 inches to 1 mile) held at the GSI, indicating the location of mapped outcropping bedrock. Information from the walk-over surveys undertaken by GES Ltd. on the lands detailing relevant information on soil depths on the farm, from drainage ditches, stream channels, presence of outcrop, evidence of previous excavations or buried drains. The Agroclimatic Atlas of Ireland (Collins and Cummins, 1996). Landspreading of Organic Waste Guidance on Groundwater Vulnerability Assessment of Land (EPA, 2004). EPA/GSI Groundwater Response Matrix for Landspreading. The matrix suggests that a consistent minimum thickness of 2m of soil/subsoil should be demonstrated overlying Regionally Important Aquifers (where Vulnerability is classified as Extreme) while 1m of soil/subsoil should be demonstrated overlying Locally Important or Poor Aquifers (where Vulnerability is classified as Extreme) before landspreading is considered to be acceptable. Information collected as part of the license application on behalf of the client. A spreadsheet was then prepared detailing the following for the farm. Farmcode Number, field numbers in the plot, farmers name and farm plot location Usable area Geological Unit Aquifer Classification Presence of outcrops on farm plot Groundwater Vulnerability Classification Presence of Source Protection Area Observations on drain depths etc. taken from the Walkover Surveys Auger Numbers on the plot Minimum Depth Achieved 3 EPA Export :01:17:09

6 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Soil Types Encountered Notes / Comments 2 GENERALISED DESCRIPTION OF THE EXISTING ENVIRONMENT 2.1 Topography, Surface Water Features and Climate The proposed landspread area comprises 1 No. farm and approximately hectares in total usable area. The proposed spreadlands are situated in County Carlow and are located in the townland of Raheenkillane, Ballon, Co. Carlow. The topography of the area, determined from the O.S. Discovery Series (1:50,000 scale) maps for the area, is generally low lying (less than 100m OD) and gently sloping. The spreadlands located on this landbank are located within catchment of the Burren River and the Douglas River. The Burren River is a tributary of the River Barrow and flows into the River Barrow at Graiguecullen Bridge, Carlow town. The Douglas River flows into the Slaney River at Gallows Hill, 3.5 km northeast of Ballon, Co. Carlow. A number of unnamed streams, ditches and artificial drainage channels border the proposed landbank. Any streams and / or artificial drainage channels may locally alter the natural shallow groundwater flow. It is thought that the landbank has low a run-off susceptibility. The proposed spreadland is mainly set to grassland and corn. Annual precipitation is recorded as between 1000mm/yr, with the wettest period expected from September to January. Groundwater recharge takes place almost exclusively in the winter months due to low vegetation moisture demand and high moisture content. Some summer recharge is possible during prolonged heavy showers, when precipitation exceeds the vegetation moisture demand. 2.2 Geology Bedrock Geology Reference to the 1:100,000 scale Bedrock Geology map of Carlow - Wexford, (Sheet 19) (Geological Survey of Ireland, 1995) indicates that the proposed landspread area is underlain by Igneous rocks of the Tullow Pluton. 4 EPA Export :01:17:09

7 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Tullow Pluton The Microline Porphyritic Granite comprises granite with microcline phenocrysts Soil and Subsoil Geology Reference to the Soil Map of Ireland (1980) indicates that the soils covering the majority of the proposed landspread areas are Podzols - Leptic. Podzols are equivalent to a leached soil with strongly developed horizons. The EPA Soil Map of Ireland also maps the area as been covered by surface and groundwater gleys to the north and centre of the landbank. The development of the subsoils within the proposed spreadlands, is associated with the movement of ice sheets that extended across the area from both the Irish Sea basin and from the west and north Midlands, during the Munsterian and Midlandian (most recent) Glaciations (Quaternary Period). The Quaternary period is characterised by alternating cold (glacial) stages and warm (interglacial) stages, during which the advancing or retreating ice sheets deposited overburden material of varying type and thickness. The deposits from the ice sheets infilled, or partially filled, hollows and valleys in the preglacial topography. The fine-grained materials (CLAYS, SILTS and fine SANDS) are associated with advancing ice sheets and are a result of the grinding down of rock fragments. The coarse grained deposits (SANDS and GRAVELS) are associated with retreating ice sheets, where the outwash from the glaciers caused deposition of coarse, unsorted materials. Along the main river floodplains, there is generally up to 2m of alluvium. Alluvium deposits constitute modern day sedimentation. Sediment is eroded and carried downstream by the carrying capacity of turbulent water flow. Reference to the Teagasc Subsoil map of Ireland available at the GSI website shows that subsoils covering the majority of the landspread area consist of tills derived chiefly from Granite. Bedrock outcrops are recorded by the GSI and are outlined in the summary spreadsheet. No evidence of areas of rock close to the surface can be found close to the landbank area. No auger holes were excavated within the landbank (see summary spreadsheet in Appendices). The EPA manual on the Landspreading of Organic Waste Guidance on Groundwater Vulnerability Assessment of land (EPA, 2004) states that no augering is required on spreadlands where the groundwater vulnerability of those lands is Low, Moderate, or High. 5 EPA Export :01:17:09

8 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July Hydrogeology and Hydrology Reference was made to the National Aquifer Map available from the GSI. Information is available on the bedrock unit (described above in Section 2.2.1) which is classified as an Aquifer unit. The Microline Porphyritic Granite is classified (by the Geological Survey of Ireland) as a Poor Aquifer, which are generally unproductive. (Pl). The Quaternary deposits have a major effect on the hydrogeology of the underlying consolidated aquifers. The nature and thickness of the subsoils influence the hydraulic conditions and the amount of precipitation recharging the ground water, are pathways for discharge and provide additional storage for the underlying strata. These deposits are also a very important source of baseflow to the river network. Furthermore the movement of contaminants from the surface may be restricted or prevented and/or the concentration sharply reduced by physical, chemical and biological processes active in the subsoils. In general, the water table is a subdued reflection of the topography, which is considered to be less than 10m from the surface within the proposed spreadlands. The permeability of the sub-terrain material will normally be highest in the top 30m (including Quaternary deposits and weathered bedrock) where the effect of weathering and dissolution are most significant. Potential aquifer recharge is estimated to be between 450mm/yr. In addition to direct recharge some aquifers also receive indirect recharge (returns from septic tanks, water mains leakage, etc). During the winter recharge months the groundwater storage will become fully restored. Thereafter the vast majority of the additional recharge is rejected. Evidence of this rejected recharge can be seen on the ground springs and seeps, large discharge rates of some springs and streams and ground flooding. A sensitive balance exists between the surface and groundwater systems in the study area, where the surface water may recharge the groundwater and similarly the groundwater systems provide baseflow to the river systems. Therefore the risk assessments of the proposed landspreading on surface and groundwater are intimately linked. 6

9 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July RISK ASSESSMENT 3.1 Introduction The concepts of Risk, Risk Assessment and Risk Management have become important tools in the area of environmental protection. The philosophical basis and language of risk is useful in that it provides a logical framework for considering the impact of landspreading. The framework enables a more rigorous, systematic approach to decision making. In addition, it is an aid in conceptualising the landspreading procedure and its potential impact at a site. The conventional hazard-pathway-target model for environmental management can be applied to groundwater and surface water risk management. A hazard presents a risk when it is likely to affect something of value (the target), which in this case is groundwater, surface water and ultimately humans and other animals. An impact can only occur if a link (pathway) exists between the hazard and target. 3.2 Hazard In the context of this landspreading assessment the source (hazard) is the organic waste generated at the Ballon Meats Ltd facility in Raheenkillane, Ballon, Co. Carlow. The nutrients of most concern released from organic waste from an environmental point of view are Nitrogen, Phosphorus and Potassium. The objective of the waste management strategy is to recycle the nutrients to land so that crop uptake is optimised. This strategy generally requires the transport of the organic waste to lands with nutrient deficits. Where these nutrients are not taken up by plant growth, they can be dissolved and pass into waters (the targets) by surface run-off or leaching, resulting in contamination of aquifers and/or surface water features. Other pollutants include faecal bacteria, viruses and cryptospiridium, which pose a threat to groundwater and human health. The organic waste is potentially a source of contamination if discharged directly to groundwater or surface waters. Whether or not land application of the organic waste creates a risk to the aquatic environment is largely dependent on a number of natural physical characteristics. These include factors such as geology, soils, climate, hydrology and hydrogeology, and on more anthropogenic factors such as operational procedures and the proximity of other potentially polluting features such as farmyards, silage pits, slurry pits and septic tanks. 7

10 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 The assessment of the likely impacts from landspreading needs to consider all of the above factors in a holistic way. 3.3 Pathways The pathway is represented by the overland movement of surface run-off to streams and rivers and by water percolating into the ground and reaching the watertable. These pathways are dependent on the nature of the topographical, geological and hydrogeological features of the proposed spreadlands. Groundwater Vulnerability is a term used to represent the intrinsic geological and hydrogeological characteristics that determine the ease with which groundwater may be contaminated by human activities. The travel time, attenuation capacity of the soils and the nature of the contaminants are important elements in determining the vulnerability of groundwater. The Geological Survey of Ireland has prepared guidelines to help in categorising vulnerability. By applying these guidelines and using the properties of the subsoils determined in this study, vulnerability ratings have been determined for the proposed landspread region considered in this study, which are further discussed in Section 4. Where the subsoil thickness is <3m, the vulnerability is rated as Extreme. Where the subsoil thickness is >3m, the vulnerability is rated as High, Moderate, or Low (depending on the nature and thickness of the subsoil). Groundwater Vulnerability information is available from the South-eastern River Basin District Interim Vulnerability map. These vulnerability maps classify the vulnerability of the landspread area into either four or two categories, Extreme, High, Moderate, and Low or Extreme and High to Low. These two separate methods of categorising vulnerability take into account previous subsoil depth information available from the completion of a county groundwater protection scheme. The landspread area in Co. Carlow is divided into two categories Extreme and High to Low. All of the landspread area is classified as High to Low vulnerability. The classifications given to the various parts of the farm are outlined in the summary spreadsheet included in the appendices of this report. When the aquifer classification is considered in addition to the vulnerability, an assessment can be made to determine the potential risk from a potentially polluting activity. For instance a Poor Aquifer considered to have a High to Low Vulnerability rating is designated Pl/H-L. 8

11 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 The control of potentially polluting activities in each groundwater protection zone can be determined using a response matrix. A response matrix for landspreading has been prepared in a guideline EPA/GSI Groundwater Protection Response Matrix (Appendices). The matrix suggests that a consistent minimum thickness of 2m of soil/subsoil should be demonstrated overlying Regionally Important Aquifers (where the Vulnerability is classified as Extreme) and a consistent thickness of 1m of soil/subsoil over Locally Important and Poor Aquifers (where the Vulnerability is classified as Extreme) before landspreading is considered to be acceptable. Surface Water Where subsoils are of low permeability there is an increased risk to surface water, resulting from reduced infiltration to the ground and increased risk of surface run-off. With surface water protection in mind, it is important that good farm practices are adhered to. Of particular importance are areas sloping towards watercourses that may be prone to surface run-off. If any of the slopes in areas within the proposed landbank are considered excessive for landspreading, then these areas will have been removed from landspreading. However, it is thought that over the majority of the proposed landbank the slopes are not excessive, and provided the proposed mitigation measures are adhered to, the risk to surface water and/or groundwater targets is expected to be low. 3.4 Targets The target is represented by items of value: the aquifer (i.e. aquifer resource), groundwater abstraction, surface water features, humans or animals that use or come into contact with the water and, in the wider sense, the environment in general. The aquifer categories are determined by consulting the available information at the Geological Survey of Ireland. Aquifer Classification The bedrock geology is old and indurated; hence most of the original depositional features, such as primary permeability and porosity, are no longer present. In these types of strata secondary permeability is dominant. The principal geological processes that develop secondary permeability (fissures/fractures/joints) in rock are structural movement, solution (karstification), dolomitisation and general weathering. These are all somewhat irregular processes, as is the permeability created in the rocks. The permeability developed by these processes will be greatest in the clean, competent, coarser grained and uniform strata, such as Limestones and Sandstones. What this means is that there is little attenuation of pollutants available once they are allowed to enter the aquifer. 9

12 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 The thick geological succession with numerous different lithologies, complex structure and wide variation in permeability leads to a complicated hydrogeological regime and closely spaced groundwater boundaries. The Geological Survey of Ireland aquifer classification is as follows: Rk: Rf: Rg: Regionally Important Aquifer, where flow is predominantly through karst conduits (fractures enlarged by solution). Regionally Important Aquifer, where flow is predominantly through fractures and fissures. Regionally Important Gravel Aquifer (Throughput of groundwater through Regionally Important Aquifers is expected to be large. This means that the travel time of contaminants is rapid). Lm: Ll: Lg: Pl: Pu: Locally Important Aquifer, generally moderately productive. Locally Important Aquifer, moderately productive only in local zones. Locally Important Gravel Aquifer Poor Aquifer, generally unproductive except for local zones. Poor Aquifer, generally unproductive. Based on the available hydrogeological information approximately 100% of the landspread area is underlain by Poor Aquifers. 3.5 Risk Mitigation The purpose of Risk Assessment is to identify targets and assess pathways. The aim of the Risk Assessment is to develop a means by which the risk can be minimised. This is achieved by combining a number of approaches; protection of vulnerable targets (achieved by the establishment of cordon sanitaires) eliminating pathways (achieved by excluding unsuitable lands) managing the hazard (good farm practice). 10

13 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Relevant Guidelines Over the past few years a number of working parties have produced guidelines on the environmental management of landspreading activities. The objective of these working parties was to produce workable guidelines that would result in less environmental impact from landspreading operations. These include: The Geological Survey of Ireland guidelines for the assessment of the vulnerability of groundwater to various potentially polluting activities and proposed approaches to the risk assessment of groundwater pollution (Daly, 1994). Landspreading of Organic Waste Guidance on Groundwater Vulnerability Assessment of land (EPA, 2004) The BATNEEC guidance notes for the Pig Production Sector, published by the EPA (1996). Guidelines for good farm practice detailed in the Rural Environment Protection Scheme documentation (1992). Guidance notes relating to the Integrated Pollution Control Licensing Application procedures (EPA, 1997). Code of practice for the protection of groundwater from the landspreading of organic wastes, published by LG/DoE/EPA/GSI Working Group (1999). Good Agricultural Practice for protection of waters Regulations 2006 (SI 378 of 2006) Reference was made to all these sets of guidelines in the preparation of this report. 11

14 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 The wastes will be transported and applied to agricultural land by approved contractors in accordance with an up to date NMP. The intention is to adhere to the guidelines for land application of wastes (1993) which suggest that, in general organic waste should not be applied: On wet or waterlogged lands. On steep slopes (>6%), particularly sloping towards watercourses. On frozen or snow covered lands. On exposed bedrock. On fields that have been pipe or mole drained and the soil is cracked down to the drains or backfill. On fields that have been pipe or mole drained in the previous 12 months. On fields that have been subsoiled over a pipe or mole drainage system in the previous 12 months. Within 30m of exposed karstified limestone or karst features such as swallow holes, springs and collapse features. Where the watertable is within 1m of the surface in free draining areas. Selecting the optimum times for spreading is also discussed. Although precise calendar dates are not listed, the advice suggests that the application of nutrients should coincide with periods of plant growth, so that the nutrients within the sludge will be utilised by the growing crop. Application of natural fertilisers (sludge and slurries) should be avoided when the soil conditions prevent infiltration, such as wet or waterlogged soil, frozen or snow covered soils and on land sloping steeply towards watercourses. Unsuitable climatic conditions include when heavy rain is forecast within 48 hours. Spreading should not be undertaken within 10m of any watercourse and the cordon sanitaire is increased in some instances where the slope towards the watercourse was deemed excessive (>18%). A 20m exclusion zone is normally applied to larger rivers. Spreading should not be undertaken within 10m of public roadways. Spreading should not be undertaken within 100m of dwelling houses and within 200m of sensitive buildings, such as schools and churches. 12

15 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Spreading should not be undertaken within 50m of a domestic supply well and between 50m and 300m of a public supply well, depending on the topographic gradient, groundwater flow direction and the vulnerability of the area. Spreading should not be undertaken on lands delineated by Source Protection Areas where areas of extreme vulnerability classification are determined within the Outer Source Protection Area. Areas of high, moderate, or low vulnerability within the Outer Source Protection Area are subject to organic loading rates as specified in the GSI Response Matrix for Landspreading of Organic Waste. Spreading of organic waste is not acceptable on lands within the area delineated by the Inner Source Protection Area as stated in the GSI Response Matrix for Landspreading of Organic Waste. Spreading should be done in a safe and secure manner in strict accordance with the best available weather forecasts. The proposed spreading rates should be maintained within the guideline rates. This also helps mitigate against any potential impacts. The application of the organic waste through landspreading in a controlled manner can have a number of advantages Its application to soil results in a significant soil organic matter improvement. Its application to the land, as a replacement to inorganic fertilisers, recycles the waste. 13

16 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July ASSESSMENT OF LANDSPREAD AREAS BY PLOT. 4.1 Introduction The proposed landspread area comprises 1 No. farm and approximately hectares in total usable area and this hydrogeological assessment was undertaken between June and July Landspread Assessment by plot The farm on this landbank in County Carlow has been assessed as part of the desk study and the spreadsheet summarises the data compiled during the desk study. The summary spreadsheet, outlining the geological formation, aquifer classification, presence of outcropping bedrock, groundwater vulnerability classification, observations on drain and subsoil depths etc taken from questionnaire and the walkover survey, source protection area information, and whether there is sufficient depth to allow spreading to proceed, is included in the appendices of this report. Any notes / comments are also included. The farm has been listed with the field numbers within the plot, indicated on the spreadsheet. The farmer s name and the location of the plot is also listed, along with the county the farm is located in, the usable area of the plot and the map it is marked on. Other headings on the spreadsheet and an explanation of the information contained in these columns are noted below. Geological Unit The geological formations summarised on the spreadsheet are described in Section Aquifer Classification Each of these aquifers is given an Aquifer Classification following the Geological Survey of Ireland s classification scheme. These are explained above in Sections 2.3 and 3.4. The information was obtained from the GSI s National Aquifer Map. Outcrops present on plot? The 6 inch sheets held at the GSI which show outcropping bedrock were also consulted for the farm. The spreadsheet indicates whether or not outcrops are present on the plot and outlines their general location. 14

17 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Groundwater Vulnerability The farm was also assessed in terms of its Groundwater Vulnerability. The Geological Survey of Ireland has prepared guidelines to help in categorising vulnerability. By applying these guidelines and using the properties of the subsoils determined in this study, vulnerability ratings have been determined (by the Geological Survey of Ireland) for the spreadlands. This information has been used to classify the farm in the proposed landbank. The South-eastern River Basin District Interim Vulnerability map states that where the subsoil thickness is <3m, the vulnerability is rated as Extreme. Where the subsoil thickness is >3m, the vulnerability is rated as High to Low. Presence of Source Protection Area? The presence of a source protection area and the delineated area around that groundwater source has been noted in this column. The source protection areas mentioned in this column refer to the areas defined by the Geological Survey of Ireland Source Protection Area map at the GSI website. These areas are divided into Inner and Outer Source Protection Areas. The Inner Protection Area is designed to protect the groundwater source from microbial contamination and is defined by the 100-day time of travel from any point below the water table to the groundwater source. The Outer Protection Area details the remainder of the zone of contribution of the groundwater source. Using the groundwater protection response matrix for landspreading, areas may or may not be excluded from landspreading. Observations on soil and drain depths etc. taken from Walk Over Survey This column outlines observations made during completion of the walkover survey (collated by GES Ltd.) on the soil and subsoil depths on the farm plot. This information is generally from observations made on the depth of drains, streams and river channels and information on previous excavations (for percolation areas, fence posts, sheds etc.) and borehole depths. Number of Augers on the plot This column on the spreadsheet indicates the number of augers undertaken on the plot (if required). Minimum Depth Achieved This column indicates if a sufficient consistent minimum thickness of soil/subsoil was encountered on the farm during augering. Soil thicknesses on the farm are sufficient (i.e. to at least 1m over Locally Important and Poor Aquifers of Extreme Vulnerability and to 2m over 15

18 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July 2008 Regionally Important Aquifers of Extreme Vulnerability). Areas where soil thickness is not sufficient have been excluded in the farm maps (included in the appendices to this report). Notes / Comments This column outlines if and where spreading is excluded on the farm, and the reasons for it (e.g. close to outcrops, rivers or insufficient depth of soil). 16

19 Report No. 08/18/01 Landspread Assessment Ballon Meats, Ballon, Co. Carlow EF/GES July Discussion Landspreading guidelines recommend that landspreading should not be undertaken within 10m of public roads, 100m of household dwellings, 200m of sensitive buildings (i.e. schools, churches), 50m of groundwater wells. The guidelines also recommend that a cordon of 10m should be maintained adjacent to surface water features. This cordon is a minimum distance to reduce the risk of surface run-off affecting the aquatic environment and should be increased if the slope towards the watercourse channel is deemed excessive (>18%). The exact location of all wells should be located prior to spreading to ensure that the correct 50m radial cordon is established. A 100m radial cordon should be maintained around all houses, industrial buildings and commercial buildings adjacent of near the landbank. A cordon sanitaire of 10m should be maintained adjacent to any drainage ditches. Any fields or parts of fields that are wet or waterlogged should be allowed to dry out before landspreading can be carried out. Certain areas of the farm have been eliminated from the proposed spreadlands as a result of data collected during the assessment. Areas where insufficient depth has been proven (noted in the Notes / Comments and Sufficient Depth Achieved columns of the spreadsheet) will have been excluded. Areas close to outcrops will have been eliminated due to insufficient depth of subsoil over the bedrock. Over the remainder of the area, auger investigations have demonstrated a minimum of 1.0m of subsoil which is required over Locally Important Aquifers and Poor Aquifers and up to 2.0m of subsoil was noted over Regionally Important Aquifers where the Groundwater Vulnerability is classified as Extreme. Landspreading is deemed acceptable on the remainder of the landbank based on the criteria set down in the Response Matrix for Landspreading (DoE-LG/EPA/GSI, 1999) and the new EPA guidelines on sampling requirements (from landspreading of Organic Waste Guidance on Groundwater Vulnerability Assessment of Land, EPA, 2004). Provided good farm practice is adhered to the environmental impact posed by the landspreading activity will be low. 17

20 Appendices

21 Appendix 1 Summary Spreadsheet Detailing Aquifers and Vulnerability

22 Job.: Summary Spreadsheet for the Ballon Meats Landspread Area located in Ballon, County Carlow Land Parcel Information on Drain / Field Location Aquifer Outcrops present South-Eastern RBD Presence of Source Depths etc from Minimum Depth Farmcode Numbers Area (ha) Farmer (Townland) 6 inch No. OS Geological Unit Classification on plot? Interim Vulnerability Protection Area Walkover Survey Auger Recommendations Auger Numbers Required Notes and Comments Exclude spreading along the road, and around the Stream located to the houses. Exclude speading east border of the plot. alond the steep slopes to the Most drains 0.5m drain in field 1. Exclude depth and 1.5m width. spreading around the wells Drain located in field 1 No Augers Required - and the waterlogged areas. BM 1-16, 18- Raheenkillane, Carlow Microcline Porphyritic to 0.4m depth and Provided the Walkover Exclude spreading around BM Ballon Meats Ballon 17/1 61 Granite Pl None High to Low None 2.0m width. Survey is completed in Full. - - the septic tank in field 1.

23 Appendix 2 Regional Location Map

24 to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ns en Co se ru he ot.

25 Appendix 3 Excluded Areas

26

27 Appendix 4 GSI Response Matrix for Landspreading

28 RI Acceptable, subject to normal good practice. R2' Acceptable subject to a maximum organic nitrogen load (including that deposited by grazing animals) not exceeding 170 kg/heetarelyr. R3' Not generally acceptable, unless a consistent minimum thickness of 1 m of soil and subsoil can be demonstrated. R3-' R3-' R4 Not generally acceptable, unless a consistent minimum thickness of 2 m of soil and subsoil can be demonstrated. Not generally acceptable, unless no alternative areas are available and detailed evidence is provided to show that contamination will not take place. Not acceptable, 0 If contamination by nitrate (or other contaminants) is a problem in any particular area, then more restrictive responses may be necessary. Monitoring carried out under any Local Authority or Agency authorisation will assist in determining whether or not a variation in any of these responses is required. 0 The total nitrogen (organic and inorganic) load applied should not exceed Teagase's nutrient recommendations for growing crops. 0 No spreading should be allowed within 50 m of groundwater sources 0 In karst limestone areas, features such as swallow holes, caves and streams connected to karst systems, must be taken into account. Landspreading should not occur within 30 m of karst features. 0 Landspreading should coincide with the growing season so that the nutrients applied will be utilised by the growing crop. 0 Landspreading should be avoided when soil conditions prevent infiltration or when heavy rain is forecast within 48 hours. It is generally unacceptable to carry out landspreading during the period November to February inclusive. Operators who are considering landspreading during this period should consult the relevant authority. ~ Site investigations (e.g. trial pits, auger holes, boreholes) should reach sufficient depths to show that the minimum required subsoil thickness is present. In extreme vulnerability areas or within source protection areas there should be at least one investigation point per hectare. In all other cases the sampling points should be at a minimum frequency of one per 5 hectares.

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30 Panther Environmental Solutions Ltd, Unit 4, Innovation Centre, Institute of Technology, Green Road, Carlow, Ireland. Mobile: Telephone /Fax: Website: Nutrient Management Plan Report Ballon Meats Ltd Date of Report: 28/7/08 Report No: NMP0813 Compiled By: Michael Fraher, Panther Environmental Solutions Ltd

31 Nutrient Management Plan For Ballon Meats Ltd CONTENTS PAGE Contents Page No. Cover Page 1 Contents Page Introduction Background Information Nutrient Management Plant Summary Methodology Lanspreading of Organic Manures Landspreading of Paunch Landspreading of Lairage Slurry Landspreading of Truck-Wash Solids Landspreading of Stand-Off Solids 6 Sign-Off on Lands 8 2

32 1.0 Introduction Nutrient Management Plan For Ballon Meats Ltd Panther Environmental Solutions Ltd has been requested by Ballon Meats Ltd to submit a Nutrient Management Plan for the purpose of land spreading of paunch, lairage slurry, truck-wash and stand-off area waste at their landbank adjacent to their factory grounds at Ballon, Co Carlow. This NMP is required in order to determine the receiving capacity of this landbank and is prepared in conjunction with the landbank assessment carried out by GES ltd, as per attachment E.4 (a). The following two tables outline the waste types and their corresponding details at Ballon Meats Ltd. Table 1 Waste Type Phosphorus Value (mg P/Kg ) Phosphorus Value (Kg/Tonne) Tonnage per annum Total Phosphorus (Kg per year) Paunch 1, Lairage Slurry 2, Truck wash solids Stand-off area waste , Table 2 Waste Type TOTAL 1,940 1,040 = Kg phosphorus per tonne on average Nitrogen Value (mg N/Kg ) Nitrogen Value (Kg/Tonne) Tonnage per annum Total Nitrogen (Kg per year) Paunch 2, ,000 Lairage Slurry 1, Truck wash solids Stand-off area waste , TOTAL 1,940 1,408 = Kg nitrogen per tonne on average Nitrogen availability is determined at 40% for 2008 as per Article 15, Table 9 of SI 378 of This equates to 0.3 kg of available Nitrogen/m 3 applied. 3

33 2.0 Background Information Nutrient Management Plan For Ballon Meats Ltd Part 3 (Nutrient Management Section) of SI 378 European Communities (Good Agricultural Practice for Protection of Waters) Regulations of 2006 (Nitrates Directive) came into effect on the 1 st August The implementation of the Nitrates Directive will have significant implications for the future management of the landbank. This NMP forms part of the overall landbank for the organic materials as per tables 1 & 2 coming from the premises at Ballon Meats and has a spreadable area of hectares of land located beside the facility. The landbank was soil sampled in June of Samples were analysed by IAS Ltd., Kilcarrig Street, Bagenalstown, Co. Carlow. The NMP is prepared to comply with the Nitrates Directive and to allow for strategic management of the landbank. 3.0 Nutrient Management Plan 3.1 Summary An N.M.P. was prepared to promote the efficient use of nutrients being applied to the soil without causing any adverse environmental impact and also to promote an optimum soil mineral balance in order to optimize crop production efficiency in terms of yield and output. The N.M.P. was prepared in compliance with the Teagasc 2004 recommendations: Nutrient and Trace Element Advice for Grassland and Tillage Crops, Teagasc 2004 and SI 3778 European Communities (Good Agricultural Practice for Protection of Waters) Regulations of 2006 (Nitrates Directive). It is intended to concentrate the landspreading in early spring and also during the September/October period and incorporate the organic product at application. This will mitigate against potential impacts such as odour and runoff. Soil incorporation may not be practicable in all circumstances, however in all situations, the criteria as specified with the BAT Guidance Note for the Pig Production Sector and the Nitrates Directive will be adhered to. 4

34 4.0 Methodology Nutrient Management Plan For Ballon Meats Ltd The following information was compiled and collated: a) Ordnance Survey maps of the areas intended for the receipt of organic product. b) The cropping program for the coming year (ie. Harvest of 2008) and previous land use. c) Each potential landspread area was assigned a reference number. d) By reference to the farm map, the current land use and the areas to which the product is to be applied were identified. e) A baseline soil fertility survey of the farms was carried out on commencement of the landbank. The mapping of the soil sample areas was carried out in conjunction with the farmer and was based on soil type, previous fertilization and cropping history. The soil sample areas did not exceed 12 hectares and included a minimum of 20 cores per sample. Soil sample areas from land areas with a Morgan s P reading in excess of 10 p.p.m. will not be used. f) The calculation of the application rate for sludge was based upon the following: Soil Phosphorous (P) reading, Crop Nitrogen and Phosphorous requirement and on the Nitrogen and Phosphorous content of the waste organic materials. The Phosphorous limits as specified in Teagasc 2004 recommendations: Nutrient and Trace Element Advice for Grassland and Tillage Crops, Teagasc 2004 and SI 378 European Communities (Good Agricultural Practice for Protection of Waters) Regulations of 2006 (Nitrates Directive) were adhered to. g) In all cases, a stocking rate for grazing animals at 1 to 1.5 livestock units per hectare was taken. No deduction was taken off the phosphorus recommendations to account for slurries returned to land from animals housed during the winter period as this will be taken into account by the stand-off area waste. h) A maximum of 170 Kgs of inorganic No potential was placed on each section of land. i) Buffer zones were marked as per the conditions specified in the SI 378 European Communities (Good Agricultural Practice for Protection of Waters) Regulations of 2006 (Nitrates Directive) and in accordance with guidelines for the Landspreading of Organic Waste issued by the Environmental Protection Agency (EPA), and the spreadable area calculated. 5 EPA Export :01:17:11

35 Nutrient Management Plan For Ballon Meats Ltd 5.0 Landspreading of Organic Materials Nutrients should be applied at times that coincide with the growth pattern of different crops to promote efficient use of nutrients in fertilizers and slurries and to minimize the risk of surface run off and leaching to groundwater. The landspreading practices and precautions as detailed in the Code of Good Farming Practice will form part of the spreading methodology by Ballon Meats. No imported organic wastes can be spread on any lands between October 31 st and February 28 th. 5.1 Landspreading of Paunch An approximate annual total of 400 tonnes of Paunch is taken as having a P & N nutrient content as detailed in Tables 1 & 2. The total volume of Paunch will be land spread over fields 6, 7, 11, 16 & 21. This represents a total utilizable area of ha of maize land. Paunch is spread only on maize land during March and October of each year. 5.2 Landspreading of Lairage Slurry An approximate annual total of 240 tonnes of lairage slurry is taken as having a P & N nutrient content as detailed in Tables 1 & 2. The total volume of slurry will be land spread over fields 2, 3, 4, 5, 8, 9, 10, 12 & 14. This represents a total utilizable area of ha of grass land. Slurry is spread only on grassland during March and October of each year. 5.3 Landspreading of Truck-Wash Solids An approximate annual total of 100 tonnes of truck-wash solids is taken as having a P & N nutrient content as detailed in Tables 1 & 2. These solids are land spread over fields 13 & 15. This represents a total utilizable area of ha of grass land. This is spread only on grassland between March and October of each year. During winter months, this is pumped to the effluent plant, at a rate of 8,000 litres per month. 5.4 Landspreading of Stand-off Solids An approximate annual total of 1,200 tonnes of stand-off solids is taken as having a P & N nutrient content as detailed in Tables 1 & 2. Due to the current under-stocking of this stand-off area, Ballon Meats Ltd has decided not to spread this material during 2008 and therefore reuse the stand-off material for another year. This will be spread on maize land during October EPA Export :01:17:11

36 Nutrient Management Plan For Ballon Meats Ltd Table 3 - Nutrient Management Plan for Ballon Meats Ltd Field ID No. Total Area (ha) (c) Total usable area (ha) Soil P Level (mgp/l) Date of soil test P Index Crop Type Total P Required (kg/ha.) Volume of onfarm Slurry Returned (m 3 /ha.) Estimated P value of on-farm slurry Returned (kgp/ha.) Volume of organic product to be applied (m 3 /ha.) P applied in organic product (kgp/ha.) Total Org N (on farm & imported) (kgn/ha.) Total volume of organic product per plot (m 3 ) Slurry /6/08 2 Grass /6/08 2 Grass /6/08 2 Grass /6/08 3 Grass /6/08 2 Grass /6/08 3 Grass /6/08 2 Grass /6/08 3 Grass /6/08 3 Grass Total Paunch /6/08 3 Maize /6/08 3 Maize /6/08 3 Maize /6/08 2 Maize /6/08 3 Maize Total Lorrywash /6/08 3 Grass /6/08 3 Grass Total Not spreadable /6/08 4 Grass /6/08 4 Cereals Willows 4/6/08 3 Willows /6/08 4 Maize Total 0 7 EPA Export :01:17:11

37 Nutrient Management Plan For Ballon Meats Ltd Sign-off on Lands I have completed a Fertiliser Plan (Nutrient Management Plan) for lands referenced above to receive organic product from Ballon Meats Ltd during This Fertiliser Plan complies with the requirements of the European Communities (Good Agricultural Practice for Protection of Waters) Regulations, 2006 (SI No. 378 of 2006). In my professional opinion, the organic product form the Ballon Meats Ltd may be used to fertilise any of those farmlands in a quantity identified in the Fertiliser Plan and in a manner that complies with the requirements of the Code of Practice and European Communities (Good Agricultural Practice for Protection of Waters) Regulations, 2006 (SI No. 378 of 2006), which will not cause, and is not likely to cause, significant environmental pollution. Signed Dated: 28/7/08 8 EPA Export :01:17:11