To whom it may concern,

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1 Panther Environmental Solutions Ltd., Unit 4, nnovation Centre, nstitute of Technology, ' Green Road, Carlow, reland. Mobile: ENVRONMENTAL Telephone / Fax: SOLUTONS LTD. info@pantherwms.com We bsi te : www. pantherwms. com 1 2fh February Office of Licencing and Guidance Environmental Protection Agency PO Box 3000 Johnstown Castle Estate CO Wexford Subject: PPC Draft Licence Objections, Register numbe.: PO Facility: Ballon Meats Limited, Raheen, Ballon, CO CarlGw To whom it may concern, n accordance with section 87(5) of the Environmental Protection agency Acts 1992 and 2003, Ballon Meats Limited wishes to make objections to the proposed determination, dated 27'h January 20 10, as detailed below. Please find enclosed a cheque in the amount of 253 in respect of the objection fee. Yours Sincerely,, -* A.-. *.,., ' '. / ental solutions Ltd COMPANY REGSTRATON NUMBER

2 1. Condition states the following: The licensee shall, within one month of the date of grant of this licence, provide an nstallation Notice board on the installation.... The licensee shall, within four months of the date of grant of this licence, provide an nstallation Notice board on the installation.... Ballon Meats Ltd requests this time change for the following reasons: A. This four month time period is in line with other PPC licences of similar type industry. B. This time period would allow realistic time to have the installation notice board manufactured a;nd installed. ;

3 2. Condition 3.9 states the following: The licensee shall, within six months of the date of grant of this licence, install and maintain at the installation (i) (ii) silt traps to ensure that all storm water discharges, other than from roofs, from the installation pass through a silt trap in advance of discharge to the Black Stream; an oil separator on the storm water discharge from all uncontaminated yard ar,eas. The separator shall be a Class 1 full retention separator. The silt traps and separator shall be in accordance with 1.S EN 858-2:2003 (separator systems for light liquids). Ballon Meats Ltd requests that this condition be removed from the final licence for the following reasons: 1, ~ Point 3.9 Ci) - Surface water drainage discharge to the Black Stream shall be generated from the hardcore cark-park area and the hard-standing area to the front of the main factory building. This drainage system currently incorporates several gullies which have been designed and constructed in accordance with S $N Drain & Sewer Systems Outside Buildings. These gullies are effectively trap systems and if properly maintained and monitored will intercept and trap silt and solids runoff from the hardcore cark-park area and the hard-standing area to the front of the main factory building. t is therefore the opinion of Ballon Meats Ltd that additional silt traps are not required. Point 3.9 (ii) - t is the opinion of Ballon Meats Ltd that an oil interceptor system is not required in advance of discharge to the Black Stream. As listed above, surface water drainage discharge to the Black Stream shall be generated from the hardcore cark-park area and the hard-standing area to the front of the main factory building. Run-off from the hard-standing area to the rear of the main factory building, where livestock loading, unloading and wash-down are undertaken, is currently diverted to the constructed wetland system. No high risk actives are undertaken within the hard-core car-park area / r 19 the hard-standing $&-ea to the front of the main factory building. Similarly, 1 no oils;/del or chemlicals are stored within khese areas, therefore ndoff &om nsideredt as low risk. r drainage system will also be visually inspected on a daily basis as per condition of proposed licence.

4 3. Condition and are identical conditions in the proposed licence. Ballon Meats Ltd requests that condition is deleted. 4. Condition 3.19 states the following: The licensee shall, within six months of the date of grant of this licence, provide appropriate storage facilities on-site for containment of run-off from the out-wintering pad and the paunch storage area. Run-off from these areas will be landspread in accordance with condition 8.12 of this licence. The licensee shall, within six months of the date of grant of this licence, provide appropriate covering for the paunch storage area in order to prevent rainwater leachate run-off. 5_ Ballon Meats Ltd requests this change for the following reasons: / Paunch storage area - Leachate coming from the paunch storage is mainly caused by rainwater run-off, as paunch is generally a dry type of waste. f the paunch storage area is adequately covered to prevent rainwater getting in contact with the paunch, then this would address the run-off issue at this storage area. Out-wintering pad - Prior to construction of the out-wintering pad, Ballon Meats Ltd contacted Teagasc to obtain advice on the construction and implementation of the out-wintering pad. A representative from Teagasc visited the site to provide technical advice on construction of the out-wintering pad. The out wintering pad was constructed in 2005, prior to the introduction of the Department of Agriculture guidelines which were released in February artment of Agriculture guideli gement arid stodge in Sectio ea1 with.the requirements Section of the guidelines quote Statutory nstrument S flo i378, 2006 in relation to the storage facilities for the holding or treatment!of livestock manure and effluents. Section 6(3) of S No 375 states that storage facilities includes out-wintering pads, earthen-lined stores, wetlands and any other system used for the holding o manure or other organic fertilisers. At present all effluent generated from the out wintering pad and discharged directly to Pond 2 ofi the constructed wetland sydtem. No effluent generated from the out wintering pad area is hischarged directly to groundwaters or surface waters. Ballon Meats Ltd arellof the oiinion that it! P

5 would be extremely expensive to provide a new storage facility for this effluent and that this is unnecessary as storage and treatment is already being provided by the constructed wetland system in accordance with Department of Agriculture guidelines. Discharge of effluent from the out-wintering pad to the constructed wetland system is generally in accordance with the above Statutory nstruments and Department of Agriculture guidelines and therefore a separate storage facility for this effluent is not required. t should also be noted that ammonia loading to the constructed wetland system will be vastly reduced due to the installation of a secondary wastewater treatment system, therefore considering the aerial size of the constructed wetland system, this shall be more than adequate to deal with the volumes of effluent generated from the out-wintering pad. Future effluent monitoring of the constructed wetland system will also provide a means of assessing how the system is managing the discharge of effluent from the out-wintering pad _ 5. Condition states the following: "The licensee shall not apply wastewaters, manures or slurries other than those mentioned in condition to the willow plantation, without prior agreement from the agency" "The licensee shall apply wastewaters, manures or slurries to the willow plantation, with prior agreement from the agency" Ballon Meats Ltd requests this change for the following reasons: A. The site may wish to spread slurries on this willow plantation and also sludge as a result of lagoon remediation works. These materials would be of benefit to the willows and would be spread in accordance with a prepared Nutrient Management Plan for the specified plantation area.!

6 6. Schedule B.2 Emissions to water Schedule B.2 of the proposed license states that the maximum volume to be emitted in any one day is 70 M3.that the maximum volume to be emitted in any one day is 100 M3 Ballon Meats Ltd requests this increase in daily discharge volume for the following reasons: A. The site may wish to increase production in the future and in order to do this, the site would require additional production related water usage and subsequent increased discharge volumes.,