Decommissioning Management Plan

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For ABP Clones
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Final
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12th April 2017

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 Dungarvan Business Centre
Fairlane
Shandon
Dungarvan
Co. Clones
Ireland
Tel: 058-51155
Fax: 058-51231
Email: info@environet.ie

www.environet.ie

Document Control

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Status Draft Final Draft Final
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Final
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Date 24/03/17 07/04/17 10/04/17 12/04/17

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Version # 1 2 3 4
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Written
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Approved

This report has been prepared by Environet Consulting Ireland Ltd, with all appropriate care and diligence within
the terms of the Contract with the client. This Contract incorporates our Terms and Conditions and takes account
of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of works.

This report is confidential to the client and we accept no responsibility to third parties to whom this report, or any
part thereof, is made known. Such parties rely on the report at their own risk.

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TABLE OF CONTENTS:

1 EXECUTIVE SUMMARY ........................................................................... 1

1.1 Activity Detail ...................................................................................... 1

1.2 Report Preparation .............................................................................. 1

1.3 Comparison with Previous Plans ...................................................... 1

1.4 Overview of the Plan ........................................................................... 2

1.5 Scoping ................................................................................................ 2

1.6 Cost Summary ..................................................................................... 2

1.7 Financial Provision ............................................................................. 3

1.8 Review .................................................................................................. 3

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2 INTRODUCTION ....................................................................................... 4
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2.1 Site Description ................................................................................... 4

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2.2 Site History .......................................................................................... 4

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2.3 Classes of Activity Licensed .............................................................. 4

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2.4 Licence Requirements ........................................................................ 5

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3 SITE EVALUATION .................................................................................. 7

3.1 Operator Performance ........................................................................ 7

3.2 Company Structure ............................................................................. 7

3.3 Environmental Pathways and Sensitivity .......................................... 8

3.4 Processes ............................................................................................ 8

3.5 Inventory of Main Buildings ............................................................. 10

3.6 Inventory of Plant and Equipment ................................................... 11

3.7 Inventory of Raw Materials, Products and Wastes ........................ 12

4 CLOSURE TASKS AND PROGRAMMES .............................................. 15

5 CRITERIA FOR SUCCESSFUL CLOSURE ........................................... 16

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6 CLOSURE PLAN VALIDATION ............................................................. 16

7 CLOSURE PLAN COSTING ................................................................... 17

8 CLOSURE PLAN UPDATE AND REVIEW ............................................. 22

9 RESTORATION/AFTERCARE MANAGEMENT PLAN .......................... 22

10 FINANCIAL PROVISION ........................................................................ 22

Appendix A – Site Location Map

Appendix B – Site Layout Plan
Appendix C – Groundwater Monitoring Reports

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 ABP Clones

1 Executive Summary
1.1 Activity Detail

Name: Anglo Beef Processors Ireland t/a ABP Clones

Address: Teehill, Clones, Co. Monaghan
IE Licence Number: P0190-02
Activities Licensed: 7.4.1 The operation of slaughterhouses with a carcass
production capacity greater than 50 tonnes per day.

7.8 (a)i The treatment and processing, other than

exclusively packaging, of the following raw materials,
whether previously processed or unprocessed, intended
for the production of food or feed from only animal raw
materials (other than exclusively milk) with a finished
product production capacity greater than 75 tonnes per

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RBME Category: B3
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1.2 Report Preparation

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This report was prepared on behalf of the operator by Environet Solutions.

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Environet Solutions
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Dungarvan Business Centre

Dungarvan
Co. Clones

1.3 Comparison with Previous Plans

This will be the third Decommissioning Management Plan (DMP) for the site.
Details of previous costs associated with the DMP are given in Table 1.

Cost Financial Instrument Expiry of Financial

Instrument
Year

2013 € 101,368 Parent Company Guarantee No time limit

2014 € 226,000 Parent Company Guarantee No time limit

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 ABP Clones

Cost Financial Instrument Expiry of Financial

Instrument
Year

2017 € 330,000 Parent Company Guarantee No time limit

Table 1: Decommissioning Management Plan History

1.4 Overview of the Plan

Mr. Alan Setter of Environet visited the site on 16th February 2017. A site tour was
undertaken in the company of Mr John Durkan, Sustainability and Environmental
Manager.

This DMP has been prepared in accordance with the following guidance
documents issued by the EPA:
‘Guidance on Assessing & Costing Environmental Liabilities’, (2014);
‘Guidance on Unit Cost Rates for Verification’, (2014);

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‘Guidance on Financial Provision for Environmental Liabilities’, (2015);
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1.5 Scoping
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Based on all available documentation it has been determined that the site has no
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potential long term environmental liabilities as there has been no history of

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spillages resulting in soil or groundwater contamination. Therefore, a clean closure

is envisioned for the site and neither restoration nor aftercare management are
expected to be required post closure.

1.6 Cost Summary

The total cost associated with the closure, restoration and aftercare management
of the facility has been estimated to be €330,000.

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1.7 Financial Provision

ABP Clones is part of ABP Beef which is wholly owned by ABP Food Group. ABP
Beef processes c.1m cattle each year and is the largest processor of beef in
Ireland and the UK, and one of the top three processors in Europe.

ABP Food Group has made the necessary provisions to cover the closure
liabilities identified in this report by way of a Parent Company Guarantee pending
approval from the Agency.
Table 2 below details the proposed financial instrument to be put in place.

Type Description Source/ Method Amount of Financial

of Quantification Provision Instrument

Known liabilities As detailed in As detailed in €330,000 Parent Company

associated with the this DMP Table 8 of this Guarantee
closure of the site report

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1.8 Review
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This closure and restoration/aftercare plan will be reviewed annually and any
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updates will be notified to the EPA as part of the sites Annual Environmental
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Report (AER).
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2 Introduction
2.1 Site Description

The site is situated approximately 1 km south of the centre of Clones, Co.

Monaghan, a town with a population of approximately 3,000. The site has an area
of approximately 11 hectares.

The facility employs approximately 300 full time staff and the main processes
operate from 7am to 5pm from Monday to Friday with occasional Saturday
operations at busy times of the year.

A Site Location Map is included in Appendix A and a Site Layout Map is included
in Appendix B.

2.2 Site History

The original building on the site was a Workhouse built in the 1840s and closed in
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the early 1900s. The workhouse was used as an army barracks in the 1920s and
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was then used as a technical college until the 1970s. There was a meat canning
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factory on site in the 1950s. Slaughtering began in the 1960s and it became
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Clones Meat Packers around 1968. It then became Tunney Meat Packers and
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Tunney Meats until 1991 when the site was acquired by Kerry Group who named
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the factory Meadow Meats. The factory was then acquired by ABP Food Group in
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1995.The Boning hall structure was built in 1975. The lower cold store was built in
1975 and the upper cold store was built in 1985. The current kill floor was
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refurbished in 2006 and the new boning hall opened in August 2007.
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2.3 Classes of Activity Licensed

ABP Clones has an IPC licence (P0190-02) issued by the EPA on 20th December
2013 for the following activity:
The operation of slaughterhouses with a carcass production capacity
greater than 50 tonnes per day.

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 ABP Clones

This licence was technically amended to an Industrial Emissions licence on the

23rd December 2013 for the following activities:
7.4.1 The operation of slaughterhouses with a carcass production
capacity greater than 50 tonnes per day.

7.8 (a)i The treatment and processing, other than exclusively packaging,
of the following raw materials, whether previously processed or
unprocessed, intended for the production of food or feed from only
animal raw materials (other than exclusively milk) with a finished product
production capacity greater than 75 tonnes per day.

2.4 Licence Requirements

The preparation of the Decommissioning Management Plan (DMP) is a

requirement under the IE licence;

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Condition 10 of the IE Licence requires the following:
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10.1 Following termination, or planned cessation for a period greater than six
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months, of use or involvement of all or part of the site in the licensed activity,
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the licensee shall, to the satisfaction of the Agency, decommission, render

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safe or remove for disposal/recovery, any soil, subsoils, buildings, plant or

equipment, or any waste, materials or substances or other matter contained
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therein or thereon, that may result in environmental pollution.

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10.2 Decommissioning Management Plan:

10.2.1 The licensee shall prepare, to the satisfaction of the Agency, a fully
detailed and costed plan for the decommissioning or closure of the site or
part thereof. This plan shall be submitted to the Agency for agreement
within six months of the date of grant of this licence.

10.2.2 The plan shall be reviewed annually and proposed amendments

thereto notified to the Agency for agreement as part of the AER. No
amendments may be implemented without the written agreement of the
Agency.

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 ABP Clones

10.2.3 The licensee shall have regard to the Environmental Protection

Agency Guidance on Environmental Liability Risk Assessment,
Decommissioning Management Plans and Financial Provision when
implementing Condition 10.2.1 above.

10.3 The Decommissioning Management Plan shall include as a minimum, the

following:
(i) A scope statement for the plan.

(ii) The criteria which define the successful decommissioning of the activity
or part thereof, which ensures minimum impact to the environment
(iii) A programme to achieve the stated criteria.

(iv) where relevant, a test programme to demonstrate the successful

implementation of the decommissioning plan; and

(v) details of the costings for the plan and the financial provisions to

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10.4 A final validation report to include a certificate of completion for the

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Decommissioning Management Plan, for all or part of the site as necessary,

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shall be submitted to the Agency within three months of execution of the

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plan. The licensee shall carry out such tests, investigations or submit
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certification, as requested by the Agency, to confirm that there is no

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continuing risk to the environment.’

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3 Site Evaluation
3.1 Operator Performance

Environet has reviewed the site’s compliance with its IE licence in 2015 by
reviewing the 2015 Annual Environmental Report (AER).

The most recent audit carried out by the EPA was on 9th September 2015 resulting
in one observation but no non-compliances. There were no environmental
complaints received from the general public during 2015 or 2016. Process effluent
emissions from the site are, for the most part, in compliance with existing licence
limits. Exceedances of the Chloride limit have occurred in recent years as Chloride
in the influent (generated by the water treatment system) pass through waste
water treatment plant unaffected. ABP is currently addressing this issue in
consultation with the Agency.

In general, Environet Solutions found the site to be very well managed and highly
compliant with the requirements of its IE licence. The site has a relatively small
environmental footprint with little potential for significant impact.

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3.2 Company Structure

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The company’s director(s) and general manager will have specific responsibility for
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ensuring financial provisions are in place to cover unknown liabilities and with
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regards the implementation of the risk management programme. The financial

manager will have the responsibility to ensure implementation and review of
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financial provisions associated with unknown liabilities, whilst the implementation

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of risk management programme will be the responsibility of the group

Environmental Manager in coordination with each site Environmental Officer.

The Environmental Management System implemented at the ABP Clones facility

is certified to the revised ISO14001:2015 since 18th Nov. 2016. A key benefit of
operating an EMS is to encourage a review of all processes on-site and their
impact on the environment, and the assessment of how these impacts can be
reduced. ABP maintains a system of continuing improvement and strives to ensure
it meets all environmental commitments and licence conditions.

ABP has in place a dedicated environmental division, namely Group

Environmental ABP Ireland. Environmental management for all ABP facilities is
effected through Group Environmental ABP Ireland, with commitment, support and
participation from top management and all levels of the organisation. The
Environmental Division, headed by the Group Environmental Manager, co-
ordinates and oversees environmental matters on all ABP sites.

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3.3 Environmental Pathways and Sensitivity

The bedrock geology in the area consists of Argillaceous dark grey bioclastic
limestones, with subsidiary shale. Groundwater vulnerability is classified as
Moderate and the aquifer is Regionally Important with fissured bedrock.

The site discharges both treated process effluent and surface waters to a tributary
of the River Finn.

The nearest area of ecological importance is the Kilroosky Lough Cluster

approximately 2km to the north of the facility. This is classified as a Special Area
of Conservation (SAC) and a proposed Natural Heritage Area (pNHA). 4km to the
south of the facility is Lisabuck Lough which is a pNHA. Neither of these sites is
expected to be impacted by the activities of the facility.

3.4 Processes

The activities at ABP Clones comprise the taking in of cattle to the lairage where
the cattle are inspected by Dept. of Agriculture, Food and the Marine personnel.

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slaughtered. The carcass of the animal is convoyed through the slaughter hall
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where the hide is detached and the feet and head are removed. The installation
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has the capacity to slaughter 700 cattle/day.

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Evisceration is subsequently undertaken, removing the red and green offal. Green
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offal and paunch are conveyed to separate trailers and sent off-site for recovery.
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Red offal is trimmed, chilled and packaged and this product is either sent to the
Cold Stores, Vac-Pack store or removed off-site. Fat from the carcasses is
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processed in the adjoining fat plant and pumped for temporary on-site storage in
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tallow storage tanks which is removed off-site at regular intervals. Hides from the
carcasses are conveyed to the adjoining hide store where they are subsequently
weighed, classified and salted, after which they are placed on pallets and removed
off-site for further processing in a tannery.

After the carcass is split in the slaughtering hall, it is conveyed to the chills where it
is rapidly chilled. After chilling the carcasses are conveyed to the marshalling area
for quartering. Quarters are then either dispatched off-site in refrigerated trucks or
sent to the adjoining boning hall for deboning. The bones from the boning hall are
conveyed directly to trailers. These trailers are covered and sealed prior to
transportation off-site to a further processing facility. Further processing also takes
place on-site in which processed product is placed in consumer packs for dispatch
off-site within 7 days.

Following on-site deboning, the meat product is packed into lined boxes and
dispatched to chills where the product is chilled. Vacuum packed meat from the

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boning hall is sent to the Vac-Pack store where it is stored for up to four weeks
prior to dispatch to the customer.

Process and sanitary effluent are treated by the on-site waste water treatment
plant (WWTP). The waste water treatment plant comprises of preliminary
(screening, dissolved air flotation (DAF), and balancing), secondary (aeration
basin) treatment and tertiary treatment (sand filters). Nitrogen is removed via
denitrification through the WWTP and phosphorus is removed by chemical
precipitation.
Process effluent arises primarily from:

 Washing of livestock trucks and the lairage;

 Wash water arising from the cleaning of the slaughter hall and process areas;

 Sanitary effluent from toilets;

 Hand washes and showers taken by staff working in production;

 Canteen waste water.

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There are no emissions to ground from the ABP Clones site. However, ABP
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Clones monitors site groundwater quality on an annual basis as a condition of the

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current Industrial Emissions (IE) licence. Results of groundwater monitoring

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indicate groundwater of good quality and no indication of contamination.

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3.5 Inventory of Main Buildings

The table below lists the main buildings located at the facility. During the site audit
there was no evidence of asbestos containing materials being present in roofing
materials or pipe lagging. Site management confirmed that to their knowledge
asbestos containing materials are not present at the site.
Table 3 below contains an inventory of the main site buildings and infrastructure.
# Building Construction Activity Area (m2)
1 Lairage Steel frame, external steel cladding, internal Cattle staging
2,096
block walls, steel roof, concrete flooring area
2 Slaughter Hall Steel frame, external steel cladding, internal Production
451
block walls, steel roof, concrete flooring
3 Boning Hall Steel frame, external steel cladding, internal Production
1,041
block walls, steel roof, concrete flooring
4 Hide Salting Steel frame, external steel cladding, internal Production
865
block walls, steel roof, concrete flooring
5 Cold Stores Steel frame, external steel cladding, internal Storage
5,051
block walls, steel roof, concrete flooring

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6 Vac-Pack Store Steel frame, external steel cladding, internal Storage
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7 Administration Cavity walls and timber trussed roof Offices and

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580
Building Administration
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8 Wastewater Steel frame, external steel cladding, internal Wastewater

141
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Treatment Building block walls, steel roof, concrete flooring Treatment

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9 Boiler House Steel frame, external steel cladding, internal Utilities

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block walls, steel roof, concrete flooring
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10 Car & Trailer Parks Reinforced Concrete or Asphalt Infrastructure 3,827

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11 Roadways & Paved Reinforced Concrete or Asphalt Infrastructure

14,318
Areas
12 External Bulk All mild steel external storage units Storage
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Chemical Storage

Table 3: Inventory of Site Buildings & Infrastructure

The costs associated with the removal of all above structures (buildings) in order
to return the site to green field status have not been included in this report. The
facility is located within a largely industrial area. Should closure occur, all buildings
will be emptied and cleaned and drainage services will be cleaned, but these
structures will be sold/leased as part of the site, however will not pose an
environmental risk once the closure plan has been implemented. The units on-site
represent a significant asset to the site and potential future industrial use.

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3.6 Inventory of Plant and Equipment

Buildings Content

Machinery and equipment within the buildings will most likely be redistributed to
other ABP Ireland facilities or sold on to similar type facilities. Where this is not
possible and disposal is the remaining option, all machinery/equipment will be
recovered and/or disposed of in accordance the Waste Management Act, 1996 as
amended. The contents represent a significant financial asset to the ABP group.
Table 4 below lists the main plant and equipment on-site.

Plant/Equipment Location

Refrigeration Equipment Cold Stores

WWTP Equipment WWTP

Air Compressors Boiler House

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Boilers Boiler House
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Water Softening Plant Water Treatment Room
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Reverse Osmosis Unit Water Treatment Room

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Fat Melting Plant Fat Plant

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Abattoir Line Abattoir

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Boning Hall Line Boning Hall

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Table 4: Inventory of Plant & Equipment

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ABP Clones keeps an inventory of all containment structures, tanks and bunds on-
site. All laboratory chemicals are stored within designated self-contained flame
proof cabinets within the laboratories and as such are not included in the
containment structure inventory in Table 5 below.
# Tank Capacity (litres) Construction Activity
1 Processed Blood 22,500 Stainless Steel Production
2 Tallow Storage 22,000 Mild Steel Production
3 Tallow Storage 22,000 Mild Steel Production
4 Tallow Storage 22,000 Mild Steel Production
5 Heavy Fuel Oil 35,000 Mild Steel Production
6 Heavy Fuel Oil 35,000 Mild Steel Production
7 Diesel 2,500 Mild Steel Production
8 Diesel 10,000 Mild Steel Utilities
9 Balancing Tank 2.5 M Glass Coated Mild Steel Wastewater Treatment

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# Tank Capacity (litres) Construction Activity

10 Anoxic Tank 1.8 M Precast Concrete Wastewater Treatment
11 Aeration Tank 1.8 M Precast Concrete Wastewater Treatment
12 Settling Tank 200,000 Glass Coated Mild Steel Wastewater Treatment
13 Sludge Storage Tank 200,000 Glass Coated Mild Steel Wastewater Treatment
14 Water Storage Tank 500,000 Glass Coated Mild Steel Water Storage
15 Office Heating Oil Medium Density Utilities
1,150
Tank Polyethylene
16 Waste Oil Tank Medium Density Maintenance
2,500
Polyethylene
17 Cold Stores Oil Tank Medium Density Utilities
2,500
Polyethylene

Table 5: Inventory of Tanks

Site management confirmed that all bunds are tested in accordance with the
conditions of the company’s IE licence and are certified by external contractors to
the current EPA recommendations.

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3.7 Inventory of Raw Materials & Products

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Table 6 below is an estimate of the quantity of raw materials and products stored
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on-site at any one time. In order to arrive at an estimated cost for waste removal, it
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has been conservatively assumed that 100% of the hazardous portion of this
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inventory will need to be removed as part of the DMP process.

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In the event of a sudden closure, it is expected than finished product will be sold
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on to suppliers. However, if for whatever reason this is not suitable, the product
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will be rendered as CAT 3 material. Animal by-product such as CAT 1 and CAT 3
material are of commercial value and it is anticipated that these can be sold. A
maximum of 24 tonnes of such material is stored on-site and this material will be
removed off-site within 48-hours of production ceasing on-site in keeping with
current practices. Following cessation of processing, no further animal by-products
will be generated on-site. Paunch will be removed off-site within one to two weeks
of process cessation and in keeping with current practices; no more than 20
tonnes will be on-site requiring removal off-site. Blood will be removed off-site
within two to three days of process cessation and hides (approx. 24 tonnes) will be
removed off-site within two weeks of process cessation. All animal by-products will
be removed off-site within the timeframes specified in the IE licence conditions.

As hides and meat in cold storage are considered to be easily sold on and as such
no costs have been associated with their removal from site.

It is proposed to return all raw materials to suppliers and/or to redistribute to sister

ABP Ireland facilities or similar processing facilities where possible. There is a

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relatively small volume of chemicals stored on-site and these comprise mainly
cleaning agents. All such chemicals are currently stored in enclosed bunded
containers on-site. Upon closure all chemicals will be removed off-site, either to
other ABP Ireland facilities or returned to suppliers. The final or worse-case
scenario is disposal via an appropriately authorised waste contractor however as
the chemicals are of commercial value to ABP Ireland, it is envisaged that they will
be used at other ABP Ireland facilities.
Maximum
Disposal/
Hazardous Storage Storage
Type Storage Type Recovery
(Y/N)? Area Capacity
Option
(tonnes)
Returned to
Salt for hide salting N Salt Store Stockpiled 30
supplier
Bunded IBCs Returned to
Boiler Chemicals N Boiler Room 2
& Stockpiled supplier
Water Treatment Dry Goods
N Bunded IBCs 30 Sent to Customer
Chemicals (incl. salt) Store
Wastewater
Dry Goods Sent to Alternate
Treatment Plant Y Bunded IBCs 3
Store Plant
Chemicals

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Chemicals Store Plant
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Bunded Bunded Sent to Alternate

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Diesel Y 12
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Tanks Tanks Plant

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Water
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Sent to Alternate
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Sodium Hypochlorite Y Treatment Bunded IBCs 2

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Plant
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Sent to Alternate
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Cat 1 & 3 N Stores Trailered 24

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Plant
Paunch Sent to Alternate
Paunch N Trailered 20
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Trailer Plant
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Processing Bunded Sent to Alternate

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Blood N 22
Area Tanks Plant
Sent to Alternate
Hides N Hide Store Stockpiled 24
Plant
Bunded Sent to Alternate
Tallow N Fat Plant 75
Tanks Plant
Meats (Finished VAC-Pac 3,500
Sent to Alternate
Product) (ABP N Store, Cold Various pallet
Plant
Owned) Stores space
Meats (Finished VAC-Pac 3,500
Product) (Stored for N Store, Cold Various pallet Sent to Customer
clients) Stores space

Table 6: Inventory of Raw Materials and Products

13

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 ABP Clones

3.8 Inventory of Wastes

Tables 7 & 8 below list of all waste materials generated at the site in 2016. For the
purposes of the DMP we assume that 50% of this material will require disposal in
a closure scenario.
Annual
Method of
EWC Source of Quantity
Waste description Recovery or
Code Waste Generated
Disposal
(tonnes)
Fluorescent tubes and other mercury- 20 01 21* Maintenance 0.103 R5 Inorganic
containing waste substance recycling/
reclamation
Synthetic engine, gear and lubricating 13 02 06* Maintenance 4.200 R9 Oil re-refining or
oils other reuses of oil
Absorbents, filter materials (including oil 15 02 02* Maintenance 0.240 R9 Oil re-refining or
filters not otherwise specified), wiping other reuses of oil
cloths, protective clothing contaminated
by dangerous substances
Gases in pressure containers (including 16 05 04* Maintenance 0.240 R4 Metal recycling/

.
se
halons) containing dangerous reclamation
substances ru
he
ot
ny
fo y.

Total 4.783
d nl
ra
re o
ui es
eq os

Table 7: Annual Hazardous Waste, 2016

r r rp
ne pu
ow ion
ht ct
ig pe
yr ns
op r i
f c Fo

Annual
Method of
EWC Source of Quantity
Waste description Recovery or
o

Code Waste Generated

nt

Disposal
se

(tonnes)
n
Co

Paper & cardboard packaging 15 01 01 Production 30.58 R3 Organic

substance recycling/
reclamation
Wood other than that mentioned in 20 20 01 38 Production 57.74 R3 Organic
01 37 substance recycling/
reclamation
Metals 20 01 40 Maintenance 7.20 R4 Metal recycling/
reclamation
Mixed municipal waste 20 03 01 Production 130.20 R1 Use as fuel
Total 225.72

Table 8: Annual Non-Hazardous Waste, 2016

14

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 ABP Clones

4 Closure Tasks and Programmes

This section focuses on the closure aspects for the activity. The closure plan
includes the decommissioning and decontamination of all of the structures and the
management and safe removal of any residuals arising as a result of
decommissioning and decontamination.

The purpose of the closure process is to ensure that the site no longer poses a
risk of environment pollution and is considered to be environmentally inert.

It is not envisaged that any of the plant and/or equipment will have to be
demolished. These elements, once decommissioned and decontaminated, will be
tested to ensure there is no risk of environmental pollution remaining. The
following steps will be carried out in sequential order to achieve closure of the
production area of the site:

 Decontamination and decommissioning of production buildings shall follow

standard site cleaning procedures. All wash waters discharged to WWTP
.
se
ru
for treatment. All residual waste and materials removed to waste storage
he
ot
ny
fo y.

areas. Due to the nature of the activity as a food processor this

d nl
ra
re o
ui es

decontamination process takes place each day as an integral part of

eq os
r r rp

production and is not considered to be an additional cost associated with

ne pu
ow ion

this DMP.
ht ct
ig pe
yr ns


op r i

Emptying of warehouses and decontamination of warehouse buildings.

f c Fo

Material returned to supplier or forwarded to customers, where possible, or

o
nt

labelled and dispatched to waste storage areas.

se
n
Co

 Emptying, decontamination and decommissioning of tanks. No residuals to

remain in tanks or pipelines. Residuals to be treated on-site or
recovered/disposed of off-site at appropriate facilities. Shutdown,
decontaminate and decommission boilers. Residual fuels to be removed
from tanks and pipelines.

 Removal of all residual waste to waste storage areas.

 Clear and clean all office and administration areas. WEEE to be removed
by suitably permitted operator. All other wastes to be dispatched to waste
storage areas.

 It is expected that the above operations will take approximately 8-weeks.

Tasks and timings are detailed in Section 7 of this report.

15

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 ABP Clones

5 Criteria for Successful Closure

The following criteria have been established to set the benchmark for the
successful closure of the site:

 All plant will be safely decontaminated using standard site procedures and
suitably trained personnel;

 All waste will be handled, packaged, temporarily stored, recovered and/or

disposed of in a manner which complies with regulatory requirements and
best practice;

 All relevant records relating to movement, transfer or disposal of waste will

be managed and retained throughout the closure process and will be
available for review by the EPA;

 No soil within the site boundary will be contaminated to a level that poses a
risk to human health or neighbouring properties;

.
se
ru

he
Access to monitoring locations will be maintained at all times during the
ot
ny
fo y.

closure process;
d nl
ra
re o
ui es
eq os

 The site will remain in compliance with its IE licence during the closure
r r rp
ne pu
ow ion

process and until the date of licence surrender;

ht ct
ig pe
yr ns

 That any remaining issues are closed out in a timely manner following the
op r i
f c Fo

EPA site closure audit;

o
nt


se

That the site is left in an environmentally inert state;

n
Co

 That sufficient funds are available to cover the full cost of closure.

6 Closure Plan Validation

Once the closure plan has been implemented the licensee will arrange for an
Independent Closure Audit (ICA) to be carried out by an independent third party
consultant. The qualification and experience of the independent auditor will be
provided and agreed with the EPA prior to the ICA commencing. The scope of the
audit will be agreed in advance with the EPA and, following approval, the chosen
independent auditor will complete the validation audit. The completed Validation
Audit report will be submitted to the EPA for approval.
The EPA may then elect to carry out a final closure audit to verify compliance.

16

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 ABP Clones

7 Closure Plan Costing

Closure plan costing is presented in Table 9 below:
Task Description Quantity Unit Unit Rate Cost Source
(€) (€)
Plant & Equipment Blood Tanks 1 tank 3800 3800 ABP
Decontamination
Tallow Storage Tanks 3 tank 3800 11400 ABP
Diesel & Heavy Fuel Oil Tanks 4 tank 2600 10400 ABP
Associated Pipework 5 day 1 800 4000 ABP

.
se
1
Bunded Areas 3 day 800 2400 ABP

ru
he
Decontamination of Utilities (chillers, boilers, cooling towers,

ot
2 day 1 800 1600 ABP

ny
fo y.
generators, transformers, etc.)

d nl
ra
re o
ui es
Wastewater Treatment Plant Tanks 5 day 1 800 4000 ABP

eq os
r r rp
Drain jetting 100–300 mm. Cleaning and surveying of surface

ne pu
2 day 1 800 1600 ABP

ow ion
water drainage and foul drainage

ht ct
ig pe
Decontamination of Lairage Building 1 day 1 800 800 ABP

yr ns
Buildings/Areas

op r i
f c Fo
1
Knocking Area 1 day 800 800 ABP
Slaughter Hall 1 day 1 800 800 ABP
o
nt
se
1
Boning Hall 1 day 800 800 ABP
n
Co

Hide Store 1 day 1 800 800 ABP

Vac Pack Stores 0.5 day 1 800 400 ABP
1
Administration Building 1 day 800 800 ABP
Wastewater Treatment Building 2 day 1 800 1600 ABP
Boiler House 0.5 day 1 800 400 ABP
1
Trailers 0.5 day 800 400 ABP

1 Assumes 1 Supervisor and 3 Operatives at current ABP employee staffing rates

17

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 ABP Clones

Task Description Quantity Unit Unit Rate Cost Source

(€) (€)
Chemstore 0.5 day 1 800 400 ABP
Fat Plant 1 day 1 800 800 ABP
Plant & Equipment Lairage Building 2 day 2 1800 3600 ABP
Decommissioning
2
Knocking Area 0.5 day 1800 900 ABP
Slaughter Hall 1 day 2 1800 1800 ABP
2
Boning Hall 1 day 1800 1800 ABP
Hide Salting/Store 0.5 day 2 1800 900 ABP

.
day 2

se
Vac Pack Stores 0.5 1800 900 ABP

ru
he
2
Administration Building 1 day 1800 1800 ABP

ot
ny
fo y.
d nl
day 2

ra
Wastewater Treatment Building 2 1800 3600 ABP

re o
ui es
eq os
Boiler House 1 day 2 1800 1800 ABP

r r rp
ne pu
2
Trailers 0 day 1800 0 ABP

ow ion
ht ct
ig pe
Chemstore 0 day 2 1800 0 ABP

yr ns
op r i
f c Fo
2
Fat Plant 1 day 1800 1800 ABP
Decommissioning of Utilities (chillers, boilers, generators,
day 2
o
3 1800 5400 ABP
transformers, etc.) nt
se
n

Plant & Equipment

Co

WEEE Removal 10 tonne 80 800 Haulier

Transport and Disposal
Plant & Equipment Transport 100 tonne 80 8000 Haulier
Recovery Cost (note nil cost) 110 tonne 0 0 -
3
Waste Removal Fluorescent tubes and other mercury-containing waste 0.052 tonne 240 12 Waste Contractor
Synthetic engine, gear and lubricating oils 2.100 tonne 290 609 Waste Contractor

2 Assumes 1 Supervisor and 7 Operatives at current ABP employee staffing rates.

3 Assuming 50% of waste arisings for the year will require removal

18

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 ABP Clones

Task Description Quantity Unit Unit Rate Cost Source

(€) (€)
Absorbents, filter materials (including oil filters not otherwise
specified), wiping cloths, protective clothing contaminated by 0.120 tonne 290 35 Waste Contractor
dangerous substances
Gases in pressure containers (including halons) containing
0.120 tonne 7500 900 Waste Contractor
dangerous substances
Paper & cardboard packaging 15.290 tonne 80 1223 Waste Contractor
Wood other than that mentioned in 20 01 37 28.870 tonne 50 1444 Waste Contractor
Metals 3.600 tonne 100 360 Waste Contractor
Mixed municipal waste 65.100 tonne 120 7812 Waste Contractor

.
se
Decontamination &

ru
Residual waste from decontamination phase 20 tonne 290 5800 Waste Contractor

he
Decommissioning Waste

ot
Sludge from Wastewater Treatment Plant 4 240 tonne 15 3600 ABP

ny
fo y.
Removal and Disposal

d nl
ra
re o
Materials Removal

ui es
Oils, Chemicals & Lubricants Transport 12 tonne 80 960 Haulier

eq os
r r rp
Off-Site Transport of Residual Fuels (Diesel & HFO) 83 tonne 80 6640 Haulier

ne pu
ow ion
By-Product Transportation 165 tonne 50 8250 Haulier

ht ct
ig pe
yr ns
Packaging Material Transportation 10 tonne 50 500 Haulier

op r i
f c Fo
Operation of the Waste Labour & Maintenance 2 month 2200 4400 ABP
Water Treatment Plant
o
(WWTP) WWTP Chemicals nt 5 tonne 600 3000 ABP
se
n
Co

Environmental Monitoring Wastewater Monitoring 60 sample 60 3600 Exova

Surface Water Monitoring 8 sample 60 2640 Exova
Post-Closure Groundwater Sampling 2 sample 2400 4800 Exova
Decontamination Interrogation & Assessment 20 sample 230 4600 Exova
Consultant 3 day 800 2400 Environet
Validation Audit Environmental Closure Audit & Report 1 item 7000 7000 Environet

4 6000 m3 of activated sludge at MLSS of 8,000 mg/l = 48 t dry solids to remove. Assuming sludge is at 20% dry solids then sludge to be removed = 48 x 5 = 240 t

19

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 ABP Clones

Task Description Quantity Unit Unit Rate Cost Source

(€) (€)
Management Costs Utilities (assuming production has ceased) 2 month 14000 28000 ABP
Security 2 month 11000 22000 ABP
Management 2 month 10000 20000 ABP
Administration (2 days per week) 2 month 3600 7200 ABP
Insurance 2 month 16750 33500 ABP
IE licence Licence Surrender Fee 1 item 8888 8888 EPA
SUB-TOTAL 271,273

.
Plus 20% Contingency 54,255

se
ru
he
TOTAL € 325,527

ot
ny
fo y.
d nl
ra
re o
Table 9: Closure Plan Costing

ui es
eq os
r r rp
ne pu
ow ion
ht ct
ig pe
yr ns
op r i
f c Fo
o
nt
se
n
Co

20

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 ABP Clones

The schedule for site closure and remediation works is summarised below:

Action Wk. 1 Wk. 2 Wk. 3 Wk. 4 Wk. 5 Wk. 6 Wk. 7 Wk. 8

Cease production

Notify EPA and Monaghan County Council of sudden closure

Arrange for sale/disposal of any product or raw materials & products located at
the site at the time of closure

.
se
Post-closure environmental monitoring; wastewater, waste, surface water &

ru
groundwater sampling

he
ot
ny
fo y.
d nl
ra
re o
Decontaminate any plant/equipment

ui es
eq os
r r rp
ne pu
Arrange for all waste to be taken off-site and recycled/disposed in an

ow ion
appropriate manner

ht ct
ig pe
yr ns
op r i
Arrange for sale/recycling of plant/ equipment

f c Fo
o
nt
Internal Closure Validation audit carried out by or on behalf of ABP Clones
se
n
Co

External closure audit by the EPA

Closure Validation Certification issued by the EPA to indicate formal

acceptance of the closure of the site.

Surrender the IE Licence to the EPA

Table 10: Gantt Chart

21

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 ABP Clones

8 Closure Plan Update and Review

As per the IE licence:
‘10.2.2 The plan shall be reviewed annually and proposed amendments thereto
notified to the Agency for agreement as part of the AER. No amendments may
be implemented without the agreement of the Agency.’

ABP Clones confirms its intention to review the DMP annually and to inform the
EPA of any changes to same via the sites Annual Environmental Report (AER).

9 Restoration/Aftercare Management Plan

As the most recent Groundwater Monitoring report by Exova has indicated that
there are no significant groundwater contamination issues at the site, it has
been decided that the site will opt for a ‘Clean Closure’. Therefore, other than

.
se
the requirement to continue to monitor wastewater and surface water emissions
ru
he
ot

until the licence is surrendered and the management costs associated with the
ny
fo y.
d nl
ra

site, there are not expected to be any other significant aftercare costs.
re o
ui es
eq os
r r rp
ne pu
ow ion
ht ct

10 Financial Provision
ig pe
yr ns
op r i
f c Fo

ABP Clones has agreed to cover the closure liabilities identified in previous
o
nt

versions of this report by way of a Parent Company Guarantee. ABP Clones is

se
n
Co

awaiting approval from the Agency prior to issuing same.

22

EPA Export 03-05-2017:03:09:23

 Co
nse
nt
of 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
ot
he
ru

Appendix A – Site Location Map

se
.
ABP Clones

EPA Export 03-05-2017:03:09:23

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

Project Environmental Liabilities Risk

Assessment
Client ABP Clones
Drawing Name Site Location ‘Discovery Series’ Map
Version 1
Date 24-03-2017

EPA Export 03-05-2017:03:09:23

 Co
nse
nt
of 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
Appendix B – Site Layout Plan
ny
ot
he
ru
se
.
ABP Clones

EPA Export 03-05-2017:03:09:23

 Environet

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

Client ABP Clones

Figure 1
Title Site Layout Plan
Date 24/03/2017
Version 1.0

ABP Clones

EPA Export 03-05-2017:03:09:23

 Co
nse
nt
of 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
ot
he
ru
se
.

Appendix C – Groundwater Monitoring Reports

ABP Clones

EPA Export 03-05-2017:03:09:23

 Eurofins Cork Limited, T:+353 (0) 21 482 2288
Glanmire Industrial Estate, E:infocork@eurofins.ie
Glanmire, Co Cork, W:www.eurofins.ie
Ireland.

Client: Eamon Hennebry Certificate No.: 2191702

ABP Clones Job Ref: 16H07367
Teehill Sample Ref No.: LSN 1N/62375
Clones Page No.: 1 of 1
Co. Monaghan Date Received: 10/08/2016
Ireland Date Reported: 23/08/2016

CERTIFICATE OF ANALYSIS
Well Water Sample 1 (Road) - ABP Clones - 09/08/16
Date Sampled: Category: ENVIRO
Sample Type: WATER - POTABLE Date Testing Initiated: 10/08/2016
Sample Condition: Satisfactory
Order No.: N/A
Date Received: 10/08/2016

.
se
Test
x Result Unit Method
ru
he
ot
ny
fo y.

Ammonia Nitrogen (as N) 0.52 mg/l ET 038 MEWAM 1981 x

d nl
ra
re o

# Conductivity @ 25degC 2180 uS/cm ET 056/APHA 2012:2510:B x

ui es
eq os

# Chemical Oxygen Demand (COD) 6 mg/l ET 068/APHA 2012:5220D x

r r rp
ne pu

pH Value 7.0 pH unit ET 124/APHA 2012:4500:H:B x

ow ion

# Sulphate by IC
ht ct

1103 mg/l ET C98/APHA 2012: 4110 B x

ig pe
yr ns

Ammonium (NH4) 0.67 mg/l ET 038 MEWAM 1981 x

op r i
f c Fo
to
en
ns
Co

All tests are carried out according to our INAB schedule of accreditation unless marked. Tests marked # indicate a non-accredited test result as the
value falls outside our current accredited range of measurement and/or scope of accreditation for this test.

Comments, opinions, grades and interpretations expressed herein are outside this current scope of INAB accreditation. The Laboratory has tested
the material/items supplied by the customer as sampled in accordance with the customers own requirements.
Signed for and on behalf of Eurofins Cork Limited.

Dan Healy
B.Sc (Hons)
Technical Manager

.
Registered Office: Eurofins Cork Limited, IDA Industrial Estate, Clogherane, Dungarvan, Co Waterford, Ireland. Registered No.570719
16H07367/LSN1N/62375/1/1/1
EPA Export 03-05-2017:03:09:23
 Eurofins Cork Limited, T:+353 (0) 21 482 2288
Glanmire Industrial Estate, E:infocork@eurofins.ie
Glanmire, Co Cork, W:www.eurofins.ie
Ireland.

Client: Eamon Hennebry Certificate No.: 2191702

ABP Clones Job Ref: 16H07367
Teehill Sample Ref No.: LSN 1N/62376
Clones Page No.: 1 of 1
Co. Monaghan Date Received: 10/08/2016
Ireland Date Reported: 23/08/2016

CERTIFICATE OF ANALYSIS
Well Water Sample 2 (Rain Tank) - ABP Clones - 09/08/16
Date Sampled: Category: ENVIRO
Sample Type: WATER - POTABLE Date Testing Initiated: 10/08/2016
Sample Condition: Satisfactory
Order No.: N/A
Date Received: 10/08/2016

.
se
Test
x Result Unit Method
ru
he
ot
ny
fo y.

Ammonia Nitrogen (as N) 0.35 mg/l ET 038 MEWAM 1981 x

d nl
ra
re o

# Conductivity @ 25degC 2650 uS/cm ET 056/APHA 2012:2510:B x

ui es
eq os

# Chemical Oxygen Demand (COD) 6 mg/l ET 068/APHA 2012:5220D x

r r rp
ne pu

pH Value 7.0 pH unit ET 124/APHA 2012:4500:H:B x

ow ion

# Sulphate by IC
ht ct

1503 mg/l ET C98/APHA 2012: 4110 B x

ig pe
yr ns

Ammonium (NH4) 0.45 mg/l ET 038 MEWAM 1981 x

op r i
f c Fo
to
en
ns
Co

All tests are carried out according to our INAB schedule of accreditation unless marked. Tests marked # indicate a non-accredited test result as the
value falls outside our current accredited range of measurement and/or scope of accreditation for this test.

Comments, opinions, grades and interpretations expressed herein are outside this current scope of INAB accreditation. The Laboratory has tested
the material/items supplied by the customer as sampled in accordance with the customers own requirements.
Signed for and on behalf of Eurofins Cork Limited.

Dan Healy
B.Sc (Hons)
Technical Manager

.
Registered Office: Eurofins Cork Limited, IDA Industrial Estate, Clogherane, Dungarvan, Co Waterford, Ireland. Registered No.570719
16H07367/LSN1N/62376/1/1/1
EPA Export 03-05-2017:03:09:23