Environmental Health 'Service Consultation Report. (As a Statutory Consultee (Planning and Development' Acts 2000, & Regs made thereunder)

Transcription

1 Fedhmeannacht na Serbhse Slnte Health Servce Executve R HSE South,.Communty Care Centre, Western Road, Clonmel, Co. Tpperary, ' reland. : : :.... :.! , HSE SUBMSSON REPORT. Envronmental Health 'Servce Consultaton Report. (As a Statutory Consultee (Plannng and Development' Acts 2, & Regs made thereunder) Report to: Mr. Patrck Doyle Programme Offcer Envronmental Lcensng Programme Offce of Envronmental Sustanablty Envronmental Protecton Agency, Headquarters, PO Box 3 Johnstown Castle Estate Co. Wexford. Type of Consultaton: ntegrated Polluton Preventon and Control Lcence Applcaton Reference No. P Plannng Authorty. Tpperary County Councl. Reference number: P Our Reference Humber: D59. Applcant: Mle Tree Farm's Ltd. Clashnska Lower, C Dnmel, Co. Tpperary. c :.,. w Proposed Development: Applcaton to The Envronmental Protecton Agency for an ntegrated Polluton Preventon and Control Lcence for the rearng of pgs n an nstallaton where the capacty exceeds, (a) 75 places for sows, or (b) 2 places for the producton of pgs where each s over 3kg. The applcaton relates to the exstng farm complex at Clashnska Lower, Clonmel, Co. Tpperary.

2 R 1) General ntroducton. Ths report only comments on Envronmental Health (EH) mpacts of the proposed development as outlned n ths Envronmental Report (ER) and the adequacy of the ER from an EH perspectve. We have made observatons on the followng specfc EH areas. A) NoseNbraton. B) Ar Qualty. C) Water Qualty. D) Pest Control. E) Legonella Control. 1 2 Assessment of Prncple & Descrpton of the Proect. The farm complex s stuated n a rural locaton approxmately 2.8 km north of Clonmel or( the R688. The exstng pggery faclty has been establshed for n excess of 2 years and s located approxmately 35 metres off the man Clonmel /Cashel road. The ste of the exstng pggery s approxmately 1.2 hectares and s surrounded by agrcultural land much of whch s owned by Mr. Wllam Carroll the owner/operator of the pggery. The landscape around the pggery s low lyng and comprses of manly mproved grassland and some land used for arable purposes. There are a scatterng of resdental developments along the man road. The exstng farm compler conssts of Dry Sow Houses, Farrowng Houses, Weaner Houses, Fattenng Houses and an assortment of servce buldngs, feed storage slos and underground slurry storage tanks. The applcant Mr. Carroll has spent a number of years modernsng the exstng faclty nto a fnancally vable pg rearng and fattenng unt and currently operates an ntegrated pg unt comprsng of 6 sows and 3 fattenng pgs at the faclty. There are currently three fulltme stock men employed at the ste. The faclty also provdes employment n the form of mantenance contracts for repars, slurry applcaton to land, and professonal servces such as veternarans, accountant and agrcultural consultant on an ongong bass., Plannng permsson to extend the ste was granted to the applcant by Tpperary Co. Councl back n 1991 and The structures, for whch these permssons were sought, ncorporate modern desgn concepts n areas of anmal welfare, nsulaton, ventlaton And envronmental protecton n the day to day operaton of the faclty. The proposed applcaton conssts of modfcatons to exstng housng and facltes to accommodate a 7 sow herd. t can therefore be consdered that the proposed applcaton wll comply wth strct anmal welfare legslaton and ncorporate best avalable technques n order to mnmse emssons to the envronment. The process at the faclty nvolves sows beng mpregnated, and once sows have farrowed the $glet s progress through a two stage weaner phase whch takes approxmately 5 days. At ths stage the weaners should acheve a target weght of 32 kg. Fnally, the weaners are transferred to fattenng unts n order to acheve a slaughter weght of approxmately 9-1 OOkg. The fattened pgs are then sold to a meat processng plant located n Roscrea.

3 R The pg farm has been nspected and accredted for the Bord Ba Code of Practce and the daly operaton of the faclty follows the Bord Ba Code of Practce for pg rearng we fare. 3) Assessment of the Envronmental mpact Statement. have sncc: had an opportunty to look at the Envronmental mpact Statement n detal whch was submtted as part of the lcence applcaton. vsted the faclty c Thursday the 29'h of September 216 and spoke to the applcant Mr. Wllam Carroll and was escorted around the ste. He outlned the pg producton process and hs proposals to ncrease the herd at the faclty and comply wth current legslatve requrements for anmal welfare. Mr Carroll nformed me that the pggery was frst establshed on the ste back n the early 195's and over tme has gradually expanded. The current faclty s very compact and appeared to be well managed and mantaned n a tdy manner at the tme of vst. Documentaton s n place and ncludes the followng: A) Lst of farmers suppled wth slurry from the faclty, ncludng dates and volumes of slurry removed. B) Waste removal, ncludng muncpal waste and dead carcass. C) Pest Control. D) Water samplng programme of prvate water supply. E) Health and Safety Statement. F) Record of calbraton on ventlaton montorng sensors located n ndvdual pg housng unts etc. The Envronmental mpact Statement n my vew was not very detaled, and dd not provde suffcent nformaton to demonstrate that concerns from an Envronmental Health perspectve wll be adequately addressed. should therefore lke to make the followng comments and recommendatons n order to mnmse the rsk of potental nusance to nearby resdents. JA) Nose (Operatonal Phase). Once the pg herd has ncreased ths wll no doubt lead to an ncrease n pg numbers n all categores of pgs at the faclty ncludng sows, weaners and fatteners. Fonsequently ths may lead to an ncrease n nose levels from pgs at feedng tmes and ncreased demand from plant and equpment. t s therefore strongly recommended that a nose survey he undertaken. The survey should be undertaken by a competent qualfed acoustcs consultant to establsh the predcted nose levels from fxed plant and equpment such as ventlaton fans, motors, pumps etc. The nose survey should be undertaken n accordance wth B.S 4142 Nose from ndustral sources affectng resdental premses. Where nose levels are lkely to exceed background levels all fxed nose generatng plant and equpment assocated wth the operaton of the pggery should be ncorporated nto sutable acoustc enclosures where practcable, or alternatvely be adequately nsulated and ftted wth sutable nose attenuaton /antvbraton devces n order to mnmse the rsk of nose nusance to nearby resdental premses..

4 R Feedng The peak nose on pg farms s generally at feedng tmes when pgs compete for space and food at the feedng trough. A dry feedng regme pertans throughout the pg farm, augers transfer feed to the varous pg buldngs from the bulk slos located at the faclty. The sucklng sows, frst /second stage weaners and the fatteners are fed pellet feed n dry feed hoppers ad lb. Pellets are eaten off the shelf and water s suppled va a npple po t n each pen. The peak nose levels are therefore avoded as the pgs are more content and do not have to compete for food and can feed throughout the day. Dry sows, glts and boars, are fed twce daly va augers. -- Delveres t s strongly recommended that delveres such as pgs and feedstuffs, and exports such as pgs and pg manure should not take place any earler than 7. a.m and no later than 2. hours Monday to Saturday. Ths wll help mnmse the rsk on nose nusance from traffc movements.. /B) Ar Qualty (Operatonal Phase). Odour Durng the operatonal phase of the pggery there are two aspects whch relate to ar qualty.e. odour from on ste actvtes and odour off ste from land spreadng of pg manure. The odour from the pggery arses from the day to day operatons such as slurry agtaton, washng down passageways and unts wthn the pggery etc. The exstng farm already uses current best avalable technques. All unts housng pgs are on slatted floors and are washed, dsnfected and rested on a regular bass between batches of pgs. Temperature control systems mantan the ventlaton of the houses wthn the pggery at optmum ar movements whch assst n mtgatng aganst any odour potental. Removal of pg manure from the faclty s by vacuum leak proof tanker and agtaton of slurry s kept to an absolute mnmum n order to mnmse odour release. Underground slurry storage tanks have equvalent to 4 months manure storage capacty. All dead carcasses are stored n a contaner at the pggery and removed for renderng on a monthly bass and more frequently f necessary by a lcensed waste contractor. \ The pg farm s located n a rural agrcultural area where farm odours are part and parcel of the 2haracter of the localty. There are a number of odour senstve locatons wthn 15-3 metres of the farm faclty. On the day of my vst to the pggery on the 29 h of September 21 6 there was a slght detectable pg slurry odour at the man entrance to the faclty.

5 .. R Pg Slurry apclcaton to land The pg slurry produced on the farm s used as a fertlzer by customer farms wthn the Clonmel/ Clerhan area of South Tpperary. A regster of all pg slurry exported s mantaned on ste wth date, volume exported, farmers name and address recorded. The pg slurry s appled to agrcultural land n accordance wth the Ntrate Drectve Regulatons (S.1 No. 6 1 of 2 1) and Teagasc Code of Good Practce for applcaton of slurry to land. n order to mtgate aganst any potental odour nusance durng applcaton of pg slurry to land t s strongly recommended that the followng measures be adopted. All pg slurry should be njected drectly nto the sol, or alternatvely tankers should be ftted wth low trajectory splash plates or band spreader to mnmse aerosol formaton. Pg slurry should not be appled any closer than 1 metres to resdental dwellngs to elmnate rsk of odour complants and Contamnaton of prvate water supply. No applcatons of pg slurry to land durng wndy condtons to prevent carry over of odour/ aerosol to any nearby resdental dwellngs or man roads. Pg slu&y should only be appled to land between the perods of 1 5'h of January to the 1 5'h of October n accordance wth the drectve. C) Water Qualty Operatonal Phase). The man potental threat to the contamnaton of ground water s the large volume of pg manure stored on ste. n order to mtgate aganst any potental groundwater contamnaton t s recommended that the followng measures be ncorporated nto the proposals. The slurry storage capacty should be calculated based upon the BATNEEC Gudance Note for Pg Producton Sector (Revson 1 -February 1998). lt's strongly recommended that a leak detecton system s nstalled to help elmnate the rsk of ground water contamnaton. The leak detecton systems should be nspected on a regular bass and any samples obtaned at leak detecton stes should be analysed by an ndependent accredted laboratory to determne the nature of any contamnaton. All pg manure appled to agrcultural land should be n accordance wth the Ntrate Drectve Regulatons prevously mentoned. t r strongly recommended that water samples are obtaned on a regular bass (at least on a quarterly bass) from any dranage dtches used for surface water runoff. The samples should be analysed by an ndependent accredted laboratory to ensure no contamnaton from the pggery enters the dranage dtch. The farm has ts own prvate water supply by means of a prvate bored well. Ths water supply s currently used for the pggery alone, and samples are

6 R Y ' (D) Pest Control obtaned from the well twce annually and submtted to an ndependent laboratory for analyss to ensure that the drnkng water supply comples wth the E.C. (Drnkng Water) Regulatons 27. As mans dranage s not accessble on ste, a septc tank s provded to accommodate staff W/C facltes and staff canteen. The Septc Tank should be nspected on a regular bass, servced and de-sludged n accordance wth th; manufactures re-commendatons. The outfall should be sampled at least annually and sent to an ndependent laboratory for analyss to ensure t comples wth the loadng rates for commercal premses as outlned n the Waste Water Treatment Manual produced by the Envronmental Protecton Agency. The very nature of the farm envronment tends to attract rodents such as rats and mce and nsects such as fles.e. blue bottles and cluster fles etc. They have a food and water supply, warmth and shelter readly avalable. t s vrtually mpossble to completely pest proof farm buldngs as lvestock requre adequate ventlaton therefore gvng pests a p3thway to enter buldngs. Durng my vst to the pggery dd not see any evdence of rodent nfestatons, however there was evdence of fly actvty n several of the housng unts. Currently all pest control s undertaken by staff employed at the faclty. There s the potental for pest problems at the faclty due to the avalablty of food and shelter. therefore strongly recommended that the servces of a reputable, competent Pest Control Contractor be apponted to control rats, mce and flyng nsects. nspectons should be carred out at least quarterly and more frequently f necessary. A fnap of all bat ponts throughout the farm should be provded and a record of all nspectons/comments should be avalable for nspecton at all tmes. (E) Levonella Control. Day to day actvtes at pg farms nvolve the use of large volumes of hot and cold <water for washng down and dsnfecton of pg houses. t s therefore mperatve that all plant used for the dstrbuton of heatng/coolng of water supples (e.g. water tanks, ppe work, coolng towers, pumps, valves etc) should be properly mantaned and servced to elmnate the rsk and spread of Legonella. A1 new equpment should be desgned as far as possble to elmnate the producton of aerosols. The temperature and qualty of the water used should be such that t wll not support the growth of Legonella. The plant and equpment should be cleaned, flushed and dsnfected on a regular bass and preferably have resdual dsnfecton at all tmes. Regular temperature survellance montorng of the water system should be undertaken and mcrobologcal samples obtaned for analyss to detect the presence of Legonella. t s recommended that all staff are traned and educated n the preventon and spread of Legonella. /

7 '1, / :,, 1 Concluson, The applcant Mr. Wllam Carroll currently operates Mle Tree Farms Ltd. Clashnska Lower, Clonmel, Co. Tpperary. The applcant has consderable experence n pg producton and has operated on the current ste for n excess of 2 years. The applcant nformed me that he has never receved any complants from resdents whch lve n close proxmty, to the pggery. The current faclty s compact and well managed and no addtonal constructon works are requred to accommodate the ncrease n pg numbers, where necessary, exstng buldngs wll be modfed to accommodate the ncrease n pg numbers. The current faclty comples wth strct anmal welfare condtons and ncorporates best avalable technques to mnmse emssons from the facty, the current slurry storage capacty exceeds 4 months. The farm s accredted for the Bord BA Code of Practce and s nspected on a regular bass to ensure t follows < the Code of Practce for pg rearng welfare. The proposed development comprses of an actvty to whch an ntegrated Polluton Preventon and Control Lcence (PPCL) under Part V of the Envronmental Protecton Agency 1992 as amended s requred. '. : have snce had an opportunty to look at the Envronmental mpact Statement wth regards to the proposed ncrease n the pg herd at the faclty. As outlned prevously, the mtgatod measures (for controllng emssons to ar and emssons to ground and surface water) as set out n the Envronmental mpact Statement were not very detaled. therefore strongly recommend that those mtgaton measures outlned under tems A to E above are also mplemented as part of the lcence applcaton condtons. therefore have no addtonal or adverse comments to make n respect of the proposed applcaton. Sgned: # Date: 3th September R All correspondence or any queres wth regard to ths report ncludng acknowledgement of ths report should be forwarded to Mr. Ray Parle (Prncpal Envronmental Health Offcer) Envronmental Health Department, Communty Care Buldngs, Western Rd. Clonmel, CO, Tpperary. H.S.E. -FUTH Q '/&-Am 4 OCT 216 fdh ENVRONMENTAL HEAL1 h WPARTMENT SOUTH TPPERARY OFFCE