Permit ( Application) Number: PPC/ A/ 1158010

Applicant: Aviagen Limited

Aviagen Limited

Madderty Poultry Farm

Permit Application

PPC/ A/1158010

CONTENTS

1 NON TECHNICAL SUMMARY OF DETERMINATION................................................................ 2

2 EXTERNAL CONSULTATION AND SEPA' S RESPONSE.......................................................... 33 ADMINISTRATIVE DETERMINATIONS...................................................................................... 54 INTRODUCTION AND BACKGROUND....................................................................................... 54. 1 Historical Background to the activity and application............................................................. 5

4. 2 Description of activity................................................................................................................ 64. 3 Guidance/ directions issued to SEPA by the Scottish Ministers under Reg. 60 or 61 ............. 64. 4 Identification of important and sensitive receptors.................................................................65 KEY ENVIRONMENTAL ISSUES................................................................................................ 7

5. 1 Summary of significant environmental and human health impacts....................................... 7

5. 2 Point Sources to Air................................................................................................................... 7

5. 3 Implications of the Variation on - Point Source Emissions to Surface Water and Sewer ..... 95. 4 Point Source Emissions to Groundwater................................................................................. 95. 5 Fugitive Emissions to Air...........................................................................................................95. 6 Fugitive Emissions to Water.................................................................................................... 105. 7 Odour........................................................................................................................................ 10

5. 8 Management............................................................................................................................. 10

5. 9 Raw Materials............................................................................................................................ 115. 10 Raw Materials Selection........................................................................................................... 115.11 Waste Minimisation Requirements..........................................................................................11

5. 12 Water Use.................................................................................................................................. 12

5. 13 Waste Handling, Waste Recovery or Disposal....................................................................... 12

5. 14 Energy....................................................................................................................................... 12

5.15 Accidents and their Consequences........................................................................................13

5. 16 Noise......................................................................................................................................... 13

5. 17 Monitoring................................................................................................................................. 13

5. 18 Closure...................................................................................................................................... 14

5. 19 Site Condition Report ( and where relevant the baseline report)........................................... 14

5. 20 Consideration of BAT............................................................................................................... 15

6 OTHER LEGISLATION CONSIDERED...................................................................................... 157 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH...................................................... 168 DETAILS OF PERMIT................................................................................................................ 169 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES ..... 1610 PEER REVIEW.................................................................................. Error! Bookmark not defined. 11 FINAL DETERMINATION.......................................................................................................... 1712 REFERENCES AND GUIDANCE............................................................................................... 17

1 NON TECHNICAL SUMMARY OF DETERMINATION

PPC requires that where the draft determination of an application or a SEPA initiated variation isto be subject to public consultation ( this is usually referred to as PPD consultation) the decisiondocument will contain a non technical summary of the determination. There is no need to havea non technical summary if the application is no subject to PPD

Will the draft determination be subject to public consultation? Yes

Aviagen is a company that supplies broiler breeder grandparent and parent chicks to customersworldwide. This application is to rear broilers at the existing Madderty Poultry Farm, located to the westof Perth. The permit application by Aviagen is made under Schedule 1 Section 6. 9 Part A paragraph ( a) of the Pollution Prevention and Control ( Scotland) Regulations 2012 covering the rearing of poultry.

As a Permitted installation, Madderty Poultry Farmwill be covered by The Standard Farming InstallationRules ( SFIR) issued by SEPA; this document is based on the Best Available Techniques ( commonlyknown as BAT) Reference Document ( abbreviated to BREF) for Intensive Livestock Installations. Please see Section 5 for more information on BAT at this site.

There has been a poultry farm on site since the late 1990s. This application is to expand the existing 3sheds to accommodate a further 12, 420 birds bringing the total places for broilers to 48, 420 thereforeexceeding the PPC threshold of 40, 000. As such the operator has made this application to SEPA for arelevant PPC permit.

Birds will be fed a range of diets via an automated system according to their stage of development toensure optimal use of nutrients to prevent excessive excretions and water will be provided to minimisespills to control manure and litter moisture levels. Delivery and removal of birds from the site will bestaggered so there are only 4. 5 crops per annum with 21 days between crops for cleaning anddisinfection.

The housing is well insulated and the ventilation arrangement — mechanically operated side inlets andfans which expel air through high velocity chimney vents located on the roof - is controlled by computerand designed to provide optimal temperature and humidity control which can be adjusted according tothe requirements of the flock. Housing will be heated using LPG fuelled heaters.

This unit is a high bio -security site and to minimise movements on and off site the fallen stock will bedisposed of on site in a Defra approved incinerator. At the end of each cycle the sheds will be thoroughlycleaned and soiled litter and washwater will be spread to land outwith the installation boundary asfertiliser in accordance with the farm Waste Management Plan and GBR18.

The closest residential receptor is the on- site farmhouse 40 metres from the sheds. The applicant hasprovided detailed odour and noise management plans and the potential impacts on nearby designatedsites have been assessed and it has been concluded that there will be no likely significant impact fromthe proposals.

Under the Habitats Regulations ( Conservation ( Natural Habitats, & c.) Regulations 1994) and the NatureConservation ( Scotland) Act 2004 there are duties placed on for SEPA for the protection of designatedsites. With it is SEPA's procedure to undertake the Simple Calculation of Ammonia Limits ( or SCAILcalculation) to calculate the impact of ammonia emissions for the site on SNH Designations. Madderty

Poultry Farm is within 10km of 10 designated sites ( please see Section 4. 5 of this Main DecisionDocument). The model provides an estimate of the amount of nitrogen deposited, in form of NH3, on ahabitat from the farm. The Simple Calculation of Ammonia Limits ( or SCAIL assessment) wasundertaken and showed that no exceedences of the Critical Load Ammonia and Nitrogen capacities ofthe sites would be made as a consequence of the proposed Permit for Madderty Poultry Farm.

Finally in order to ensure consistency across the Scottish Agricultural Sector SEPA has consulted bothwith both its internal agricultural permitting group and the Company to ensure the permit is consistentwith other intensive agriculture permits issued in Scotland.

Glossary of terms

PPC Pollution Prevention and Control ( Scotland) Regulations 2012BAT Best Available Techniques

CO Coordinating OfficerELV Emission Limit ValueSCAIL - Simple Calculation of Ammonia LimitsBREF - Best Available Techniques Reference DocumentSSSI - Site of Special Scientific InterestSAC - Special Area of ConservationSPA - Special Protected AreaEAL - Environmental Assessment LevelPPD — Public Participation DirectivePEPFAA Code - Prevention of Environmental Pollution from Agricultural ActivityAPHA - Animal and Plant Health AgencyGBR18 — General Binding Rule 18 of the Water Environment ( Controlled Activities) ( Scotland) Regulations 2011

2 EXTERNAL CONSULTATION AND SEPA' S RESPONSE

Is Public Consultation Required - Yes

Advertisements Check: Date Compliance with advertising requirements

Edinburgh Gazette 12/ 06/ 2017 Yes

Strathearn Herald 16/ 06/ 2017 Yes

Officer checking advert: CO

No. of responses received: None

Summary of responses and how they were taken into account during the determination: N/ A

Is PPC Statutory Consultation Required — Yes

The routine consultation was sent with this caveat:

The baseline report and modelling of particulate matter accompanying this application require furtherinformation from the applicant in order to fulfil the relevant criteria. If you wish to receive this informationprior to making a formal response to this consultation please contact me on the number below.

Food Standards Scotland: Response received 19/06/2017 —No objection.

Tayside NHS Health Board: Response received:

21/ 06/ 2017 — Comments returned included: Emission standards are set at a level which ensures thatthe most vulnerable are not harmed. Potential health issues for individuals and local populations areaddressed within this requirement. It is not possible to identify the health at an individual level but whereemissions occur vulnerable people in the area will be affected when emissions contribute to airpollution

levels in excess of guideline levels. Although emission levels are set at levels which should not preventharm to vulnerable populations it is noted that less than 500 yards away is a primary school with 64pupils — Madderty Primary School. There may be vulnerable children amongst this group who may besensitive to dust and odour from the poultry farm. It would be prudent to ensure that the school is awareof who to contact on the farm and at SEPA if there is an increase in odour or dust in the area. CO sendsresponse to Senior Specialist Scientist ( Human Health) for advice.

22/ 06/2017: Following advice from the Specialist the CO returned via email the following to the NHSrepresentative: Schools are not deemed anymore sensitive than residential locations for PM,o exposure. The PM,o assessment criterion is derived to protect all vulnerable receptors including children, elderlyand people with existing health conditions such as asthma. The site have undertaken a modellingexercise which is being assessed by SEPA Specialists to ensure that such dust is within statutory limitsfor both 24 hour and annual average.

Odour is not deemed to be a significant negative effect from this site; the site is existing ( the applicationfor a permit is due to an increase in bird places bringing the site in PPC regulation) and management ofBest Available Techniques should ensure that odour is minimal. An advert in the local paper ( theapplication is available for people to comment upon) and the statutory consultation of the permit on theSEPA website under the Public Participation Directive fulfils the requirements of consultation and

enhanced consultation is not deemed necessary in these circumstances. 1 hope this addresses yourcomments... but if not please feel free to contact me... and we can discuss it further.

22/ 06/ 2017: NHS retains advice to make the school aware of the application.

29/06/2017: NHS confirms that there is no objection to the application.

18/ 07/ 2017: Following advice from the consultee for the NHS the CO sent a letter to the head ofMadderty Primary School to make them aware of the extension at the farm and that SEPA has noconcerns regarding emissions at this time. This was not a consultation but a letter for awareness only.

Perth & Kinross Council Local Auth: No response.

Health and Safety Executive: No response.

Scottish Natural Heritage ( PPC Regs consultation): Response received 23/ 06/ 2017 — Noobjection.

Discretionary Consultation - No

Enhanced SEPA public consultation - No

Off-site' Consultation - No

Transboundary Consultation - No

Public Participation Consultation - Yes

STATEMENT ON THE PUBLIC PARTICIPATION PROCESSThe Pollution Prevention and Control (Scotland) Regulations 2012 (schedule 4, para 22) requiresthat SEPA' s draft determination of this application be placed on SEPA' s website and publicregister and be subject to 28 days' public consultation. The dates between which thisconsultation took place, the number of representations received and SEPA' s response to theseare outlined below.

Date SEPA notified applicant of draft determination 11/ 12/ 2017

Date draft determination placed on SEPA' s Website TBC

Details of any other 'appropriate means' used to advertisethe draft.

TBC

Date public consultation on draft permit opened TBC

Date public consultation on draft permit consultation

closed

TBC

Number of representations received to the consultation TBC

Date final determination placed on the SEPA's Website TBC

3 ADMINISTRATIVE DETERMINATIONS

Determination of the Schedule 1 activity

As detailed in the application and its amendments.

Determination of the stationary technical unit to be permitted.

As detailed in the application and its amendments.

Determination of directly associated activities:

As detailed in the application and its amendments.

Determination of `site boundary'

As detailed in the application and its amendments.

4 INTRODUCTION AND BACKGROUND

4. 1 Historical Background to the activity and application

There has been a poultry farm on site since the late 1990s; prior to this the site was openundeveloped land and then a pig farm. This application is to expand the current 3 sheds toaccommodate a further 12, 420 birds bringing the total places for broilers to 48, 420 thereforeexceeding the PPC threshold of 40, 000. As such the operator has made this application to SEPAfor a relevant PPC permit.

Some parts of the application and its supporting documentation have been amended several times; this decision document shows the determination of the application in its final revision.

The application was determined after the publication of the BRef and the BAT conclusions

published in February 2017, the applicant was required to demonstrate that the new shed wasdesigned having regard to the following principles outlined in the BREF as Best AvailableTechnique:

reducing the ammonia -emitting surface; removing the manure frequently to an external store ( e. g. with belt removal systems); quickly drying the manure; using surfaces which are smooth and easy to clean;

4. 2

4. 3

lowering the indoor temperature and ventilation as much as animal welfare and/ orproduction allow.

All proposals for new housing should include a comprehensive appraisal of different design optionsand demonstration of how the chosen design addresses the above principles.

Description of activity

Rearing poultry intensively in an installation with more than 40, 000 places is described in Part A ofSection 6.9 ( a) of Schedule 1 of the Regulations. Aviagen Limited proposes to have 48,420 places

and expand the facility accordingly.

Other Directly Associated Activities include:

Feed preparation and storage,

Fuel storage;

Water storage:

Chemical storage;

Manure handling and storage; Dirty water storage; Storage of fallen stock for disposal;

Incinerators for disposal of fallen stock

Management of lightly contaminated surface water.

Guidance/ directions issued to SEPA by the Scottish Ministers under Reg. 60 or 61. None.

4. 4 Identification of important and sensitive receptors

Madderty Farm is within 10km of 10 Scottish Natural Heritage designated sites ( please see Section4. 5 of this Main Decision Document). Livestock such as poultry emit ammonia (which contains thenutrient nitrogen) into the atmosphere which may impact on certain species of flora and fauna. TheSimple Calculation of Atmospheric Limits ( SCAIL) screening tool provides an estimate of theamount of nitrogen deposited, in form of NH3, on a habitat from the livestock unit, storage area or

spreading technique. The impact of ammonia and nitrogen from the poultry housing at Maddertyhas been screened using SCAIL to show that there will be no negative effects ( please see Sections5. 1 and 5.2 below). Madderty Farm is within a Nitrate Vulnerable Zone as well as a Drinking WaterProtection Area ( Groundwater) but neither Designation will be unduly impacted by the installationas permitted. The site is located in a rural area with outspread residences with the nearest within40 metres.

Several human health sensitive receptors were identified as part of the required modelling of PM, oemissions from this site. These are listed in Table 7 of the modelling report submitted with theapplication ( please see Associated Document 1). The results and SEPA's assessment of the

modelling findings are discussed in Sections 5. 1 and 5. 2 below.

Consultation with the Tayside NHS Health Board highlighted the request to inform the local primary

school of the extension at Madderty Farm and who to contact if dust and/ or odour was an issue. This is discussed in Section 2 of this report and no undue risk to human health has been identified.

5 KEY ENVIRONMENTAL ISSUES

5. 1 Summary of significant environmental and human health impacts

SEPA have identified a number of environmental impacts ( not necessarily significant) these areidentified as follows:

Emissions to Air Ammonia, dust ( PM, o) and odourEmissions to Land Waste, faecal material and nutrient inputs to a Nitrate Vulnerable ZoneEmissions to Water Surface Water Discharge to Groundwater; Other Emissions Noise

Associated risks Containment of fuel

SEPA aims to control these through the conditions contained in the permit and by the requirementon the operator to comply with BAT as indicated in the SFIR.

As there are properties within 250 metres of the sheds the applicant was required to carry outmodelling for PM, o on nearby sensitive receptors.

The initial interpretation and presentation of the findings in the report were queried by SEPA' s AirModelling and Air Chemistry Specialists ( all correspondence is documented in the SCAIL and PM, ofolder). By early August all but one of SEPA' s queries were addressed and relevant clarificationwas supplied by the applicant.

Both the SCAIL screening, the results from the applicant' s PM, o modelling exercise and SEPA' ssubsequent assessments demonstrate that there shall be no significant or unacceptable

environmental and human health impacts.

5.2 Point Sources to Air

SEPA has identified that the major environmental impacts from the farm will be dust and ammonia

Ammonia

Ammonia can be carried on the air and deposited in lakes and ponds causing eutrophication. It isassessed that the main point source of ammonia at Madderty Farm will come from the ventilationpoints along the roofs of the chicken sheds. The housing and ventilation conform to the BATConclusion ( Technique a) in the 2017 BREF BAT Conclusions published on 21 February 2017.

In order to assess the potential impact of ammonia from Intensive Agricultural Installations the

applicant is required to supply calculations to indicate the amount ammonia released from theinstallation chicken unit. Using the Scottish Government approved figure for Broilers ( ammoniaproduced by an average sized bird) given in the application form the company supplied calculationsindicating that the ammonia released from the installation at Madderty would be on average 1646kg/ yr ( based on a population of 48, 420 birds).

There are 10 Designated Sites under the above legislation within 10km of the Permitted site

threshold dictated by SEPA Nature Conservation Procedure NCP -P- 01). After carrying out theSCAIL screening for agriculture it was assessed that there would be no likely significant impact onthe Designated Sites by ammonia. This evaluation was carried out in accordance with the " Theassessment of potential impacts on designated sites of atmospheric emissions of ammonia from

PPC intensive agriculture installations: Guidance on the implementation of SEPA' s statutory dutiesfor the protection of Special Areas of Conservation, Special Protection Areas, Ramsar Sites and

Sites of Special Scientific Interest" ( NCP -P- 02). This guidance dictates that the installation aloneshould not contribute more than 4% of ' Critical Load for Ammonia' for any Designated Site.

As the background ammonia levels and loads used in the SCAIL screening tool were last updatedin 2014 any new permitted sites or permit variations to increase bird numbers from 2015 onwardsfor sites within 10km of Madderty must also be included in assessing impacts. Mains of DuncrubPoultry Unit increased bird places by 39, 500 in 2016 and SCAIL screened for the combinedammonia, nitrogen and acid impacts from Madderty and Mains of Duncrub. The above guidancestates that combined Intensive Agriculture sites should not contribute more than 20% of ' CriticalLoad for Ammonia' for any Designated Site. The results of this SCAIL screening showed that thetwo farms would not contribute more than 3% of any critical load or level for ammonia, nitrogen oracid. As such it can be concluded that there will be no likely significant impact on the DesignatedSites.

Dust ( PM, o1)

PM10 dust particles are subject to statutory air quality standards. These standards have beenspecified to reduce health effects and environmental risks to an acceptable level. Air quality limitvalues and averaging periods are set out in the Air Quality Standards ( Scotland) Regulations 2010. In addition to the air quality standards, Scotland has air quality objectives which are set out in theAir Quality ( Scotland) Regulations 2000 ( as amended).

Where sensitive receptors are located within 250m of a poultry unit, SEPA requests that theApplicant models the emission of particulate matter to establish whether the emission will cause

any air quality standards to be breached. Two sensitive receptors were identified within 250m ofMadderty Poultry Unit.

Not all relevant considerations were demonstrated in the modelling report so several revisions hadto be submitted ( please see Associated Document 2). After full assessment by SEPA the modelledconcentrations of particulate matter at the receptors have been found as below the applicableScottish objectives.

Please also see Section 2 above with reference to the correspondence and advice from TaysideNHS Health Board.

Diesel Generator

As it is a requirement of the animal welfare regulations that the birds have adequate heating andventilation at all times; the company have advised that a diesel generator is used as a back- uppower unit at Madderty to provide power in the event of a mains outage. SEPA are aware thatdiesel generators can give rise to dense fume especially at start up or if the generator is poorlymaintained and would expect the operator to use BAT particularly with regard to servicing andmaintenance to minimise visible emissions and particulates from the exhaust.

Incinerator

Carcases are incinerated on site in an APHA- approved incinerator as shown on the site layoutplan. The incinerator stack, is included as an emission point in Table 3.2. No emission limit hasbeen set for this discharge to air, although visible monitoring ( i. e. Ringlemann 1 at start up and novisible smoke during operation) is required.

Bioaerosols

SEPA does not have any specific policies in relation to bioaerosols from IA processes, there arecurrently no health criteria values available for interpreting the results of bioaerosol monitoring. Routine monitoring will be required at receptors within 250m should appropriate criteria forassessment be identified.

Particulate matter 10 micrometres of less in diameter

5. 3 Implications of the Variation on - Point Source Emissions to Surface Water and Sewer

There are no public sewers within the vicinity of Madderty and therefore there will be no dischargesto the sewer.

A previous septic tank has been upgraded to a biodisc package treatment plant used to collect all

domestic waste water from the Amenity block and discharges to a soakaway south of the poultrysheds. The septic tank is currently authorised under The Water Environment ( Controlled Activities) Scotland) Regulations 2011 ( CAR/ R/ 1148939). The septic tank is not considered part of the

Permitted installation and will be a very small discharge from the amenity area.

Updates to SEPA received during the application process now confirm that surface water run- offfrom the poultry sheds and low -contamination yards are directed to swales or a detention basin orboth ( please see Associated Document 1). The lightly contaminated water is directed to SuDS forwhich the relevant capacity calculations have demonstrated adequate storage for this purpose. The areas draining to the SuDs feature can also be diverted to underground tanks in the event thatthere is risk of contamination such as vehicle movements and cleaning. The proposed drainagesystems adhere to the Rural Sustainable Drainage Systems — A practical design and build guidefor Scotland's farmers and landowners (2016) which is considered BAT.

All swales and the detention basin are directed to the adjacent tributary of the Pow Water to theeast of the farm although they are unlikely to flow except in adverse weather. A small section ofthis burn was realigned in order to make room for the extension to the farm. The activity waslicensed under The Water Environment ( Controlled Activities) ( Scotland) Regulations 2011CAR/ S/ 1147817).

5. 4 Point Source Emissions to Groundwater

There shall be no point source emissions to groundwater as a consequence of this application.

SEPA has assessed as satisfactory the Baseline Report that was revised and resubmitted duringthe application process. This report evaluates past potential contamination and future pollutionrisks to both soil and groundwater. See section 5. 19.

5. 5 Fugitive Emissions to Air

There are a number of potential fugitive emissions to air. These include the release of ammonia

during cleaning or opening of the poultry sheds for fallen stock removal and also from the birdsthemselves. Whilst SEPA accepts that some fugitive releases are unavoidable e.g. odour fromunplanned releases due to an unforeseen incident, others such as poor cleaning out practices canbe controlled through the relevant management techniques. SEPA views fugitive releases to air

from these activities as an indication of process or maintenance issues and would require anydefects to be reported and rectified as soon as possible.

Although not specifically covered by conditions within the permit maintenance issues are coveredby the PPC Regulations under Regulation 22 which requires the use of "Best Available Techniques" see definition of " techniques" within the explanatory notes attached to the draft permit). SEPA

seeks to reduce these occurrences by requiring operators to record maintenance issues anddemonstrate a high degree of environmental management over the activities they undertake. SEPAfor its part has a number of regulatory instruments it can use to gain compliance should the operatorfail to comply.

SEPA has assessed that there is a slight possibility of emissions from feed or dust from cleaninghowever providing good housekeeping techniques are employed these should pose no risk to theenvironment.

The litter is kept dry and ' friable ( 60% moisture content) by well insulated buildings with closelycontrolled temperature and humidity (50-70%) and by preventing leaks from the drinking system.

5.6 Fugitive Emissions to Water

There are a number of potential sources which could lead to fugitive emissions to water, these

include: poorly maintained drainage systems, bird delivery and collection contaminating surfacewaters, lack of care during cleaning of the chicken sheds and diesel tank filling and associatedbund emptying.

SEPA views fugitive releases as avoidable and can usually link these incidents to either operationalerror or negligence. SEPA seeks to reduce these occurrences in the permit by requiring thecompany to provide training to relevant staff in environmental issues and exercising a high degreeof environmental management over the activities they undertake.

Aviagen have carried out an inspection of the drainage network and found it to be in good conditionwith no cracks or damage

5. 7 Odour

SEPA acknowledges that Odour from intensive agriculture installations can give rise to complaintsand to this end requires operators to undertake odour assessments and to formulate and implementOdour Management Plans to reduce the impact on the local environment.

SEPA has identified that the potential odour issues from this intensive poultry farm are ammoniaand general poultry smells, with secondary odours from the use of any chlorinated cleaningmaterials or disinfectants to clean the sheds. Conditions within the permit will require the companyto produce an Odour Management Plan detailing how odour issues will be resolved and thePartnership is advised by SEPA to have regard to the BAT contained within Section 2. 8 of SEPA' sStandard Farming Installation Rules which deals with odour management.

The manure and soiled litter from the site will be transported in covered trailers to be utilised as asoil conditioner on farmland. This material will be spread in accordance with the requirements of

the Farm Waste Management Plan and GBR18 but this activity is outwith the PPC Regulationsand therefore the permit.

The site meets BAT for its housing system as stated in the recently published BAT Conclusions forthe Intensive Rearing of Poultry or Pigs ( Forced ventilation and a non -leaking drinking system ( incase of solid floor with deep litter)). Such systems are BAT in order to reduce ammonia emissionsthereby reducing the impact of odour on nearby receptors.

5.8 Management

Permit condition 2. 1. 5 requires that the permitted activity is operated in accordance with anenvironmental management system ( EMS). The BREF requires that in order to improve the

overall environmental performance, the EMS should incorporates the following key features:

Management commitment

Environmental policyFinancial planning and investmentRelevant procedures ( training, record keeping, maintenance, emergencyprocedures)

Checking performance ( monitoring, preventative action, auditing) Review

Continual improvement

Benchmarking

Noise Management Plan

Odour management Plan

5. 9 Raw Materials

Chemicals:

Chemicals used in poultry rearing include cleaning and disinfection chemicals, pesticides, rodenticides, herbicides, insecticides and fungicides. All of these chemicals are required to be

DEFRA approved. Chemicals will be delivered to Madderty Poultry Farm and stored in lockedchemical stores. Once on site chemicals will be kept within bunded containers within the storage

area of the poultry unit. Visual inspection by the Applicant of the chemical store did not identify anyobvious leaks or spillages and observed the integrity of the concrete floor and bund to be in goodcondition i. e. no obvious cracks of signs of degradation.

Red Diesel:

Red diesel will be stored within a roofed above -ground 2,200 litre -capacity tank that is appropriatelybunded near the amenity area to fuel the back- up generator, tractor and power washer. The fuelstorage is compliant with The Water Environment ( Oil Storage) (Scotland) Regulations 2006.

Liquid Propane Gas ( LPG)

Existing LPG tanks are being retained but moved to the north of the poultry sheds with a maximumstorage capacity of 32, 000 litres. The sheds are heated during the early part of the production cycleusing LPG -fuelled space heaters.

Water:

Water is sourced from the mains and use is discussed below in 5. 12.

Feed:

Feed will be supplied to site, pre mixed, into to 6 fully enclosed silos. Feed will then be transportedinto the feed chain systems within the units by augers. Any feed spillages will be cleared upimmediately to prevent any potential contamination of ground water or watercourses. Rations willbe formulated by poultry nutritionists and the company veterinary surgeon. Feed specifications willbe created to minimise the amount of nitrogen and phosphorous excreted by the hens over thelaying cycle by optimising crude protein output and feed utilisation. A nutrition plan will be availableon request. SEPA is satisfied that this meets the requirements of SFIR and BAT.

Litter

Up to 8 tonnes of wood shavings can be stored in the general storage shed prior to use in thesheds during use as bedding litter.

5. 10 Raw Materials Selection

Records are kept to comply with Farm Assurance Schemes with regard to feed type and quantity. The standard permit condition requiring the formal assessment of resource utilisation on site willallow the operator to identify where any efficiencies can be made.

5. 11 Waste Minimisation Requirements

As a commercial operation, SEPA believes it is in the interest of both the company and theenvironment to minimise waste on the site, as a result SEPA encourages all companies applyingfor PPC Part A permits to examine their Raw Materials usage and seek ways to reduce their impact

on the environment. To this end, SEPA has included permit conditions requiring the operator tominimise waste and where possible develop and implement recycling strategies.

Records will be kept on site of all waste

taken. This data will be reviewed after 12

efficiency report required in the permit.

5. 12 Water Use

streams and the source, quantity and disposal routesmonths and thereafter every 4 years in the resource

Water use within the food production sector is primarily a BAT issue as the operator of theinstallation is required under other legislation to provide an adequate supply of clean water for boththe welfare of the birds and to undertake adequate cleaning of vehicles. It is up to the operator todemonstrate the use of BAT to minimise water usage but SEPA does directly regulate water use

through permit conditions requiring the operator to minimise water consumption and exploreoptions for minimisation.

The greatest volume of water consumed is drinking water for the birds. Fresh water will bedelivered to poultry via nipple line drinkers and drip collection cups to prevent spillages ( as outlinedin the SFIR and BAT standards). The drinking equipment will be inspected daily to minimise waterleakages. Water consumption will be monitored and recorded daily. Water pressure on the feedsystem is set to minimise the spill risk and the water is taken from the mains supply.

5. 13 Waste Handling, Waste Recovery or DisposalUnderground waste water storage tanks will be used to collect contaminated water from the shed

cleaning and vehicle was processes.

Foot washes are located at various locations around the site and a wheel wash is located at themain entrance to the site. Spent disinfectant is emptied into the underground waste water tank at

the end of the shed and be taken off site. Where a disinfectant or effluent from cleaning may containlist I or II substances, it must be exported from site and disposed of at a suitably licenced facility. When a disinfectant does not contain list I or II substances it can be spread to land in accordancewith the Farm Waste Management Plan and GBR18.

The applications supporting information states that the washwater tanks will contain biocides suchas Virkon LSP, Viroshield and Vanadox. The Baseline Report (Figure 4) does state that washwater

will be disposed of by licenced carrier.

Empty containers ( e. g. disinfectant, cleaning products etc.) will where possible be returned to thesupplier. If that is not possible they will be thoroughly rinsed and flattened prior to collection anddisposal by a licensed contractor. As above where the wash water contains List I or II substancesit must be disposed of at a suitably licenced facility.

Fallen stock are to be disposed of in an incinerator located within a separate shed in the south

western area of the main compound, with the resulting ash removed to an offsite landfill facility. The concrete base/floors of the incinerator and the poultry sheds are to be annually inspected bya government body, the Animal and Plant Health Agency (APHA). The ash is to be placed in heavyduty plastic bags and stored in a steel bin with a lid in the building prior to uplift.

The volume of other wastes stored on the site is minimal and all will be considered in the relevantsection of the resource efficiency assessment required under the standard permit condition. Theonus of Duty of Care shall apply to all waste management at the installation.

Soiled litter will be removed from the houses at the end of each cycle into trailers loaded as close

as possible to the shed doors. The areas outside of the sheds are swept clean after loading andthe trailers are covered and taken to a location outside of the installation boundary where it isstored prior to being spread onto land.

5. 14 Energy

The poultry sheds at the farm have a computer - controlled heating system in order to maintaintemperature within the housing. This is directly linked to the ventilation system to prevent over- heating and lack of free ventilation. SEPA recognises that energy usage is dependent on anumber of factors outwith the control of the operator who has to maintain the welfare of the birdsin extremes of weather.

A permit condition requiring the formal systematic assessment of Energy Consumption on site willrequire the operator to identify where efficiencies can be made.

The site is subject to a Climate Change Agreement which is recognised by SEPA as BAT for energyconsideration and management. Climate change agreements are voluntary agreements made byUK industry and the Environment Agency to reduce energy use and carbon dioxide ( CO2) emissions. In return, operators receive a discount on the Climate Change Levy ( CCL), a tax addedto electricity and fuel bills. The Environment Agency administers the CCA scheme on behalf of thewhole of the UK.

5. 15 Accidents and their Consequences

The Pollution Prevention and Control ( Scotland) Regulations 2012 specifically preclude SEPA fromadding conditions to a Permit regarding the Health and Safety of Staff or workers on- site; howevershould an accident or incident occur that is likely to pose a risk to the environment or harm tohuman health in the wider community then SEPA would require, under the conditions of the permit, that not only must the Operators take action to limit the immediate environmental impact but where

necessary implement changes to try to ensure that the event doesn' t happen again.

In general all accidents or incidents likely to cause pollution and all complaints to the site regardingnuisance emissions are required by the Permit to be recorded and dependent on the severitynotified to SEPA.

Incident Reporting is covered by Condition 2. 12 of the Permit which requires the operator toproduce an Incident Prevention and Mitigation Plan as per SFIR and BAT.

5. 16 Noise

The predominant source of noise from poultry units is generated from the ventilation systems. Other sources of noise related to this type of activity can include vehicle movements in and aroundthe site and the placement and removal of the birds. The latter two are considered as being unlikelyto cause issues as the activities will take place for such short durations as well as being infrequent. Regular maintenance of fans will also prevent noise and the noise management plan will address

any issues that should arise and will be updated as stipulated in the permit.

The Permit and SFIR recognise that noise can give rise to complaints; SEPA takes noise

complaints from PPC Part A installations seriously and to this end requires the operator toundertake noise assessments and produce a Noise Management Plan to lessen the impact on the

local environment.

Noise at the permitted installation is covered by Section 2. 9 of the SFIR which is considered bySEPA to be BAT which the operator is required to have regard to when operating an intensiveagriculture site under the PPC Regulations.

5. 17 Monitoring

SEPA places a lot of emphasis on self- monitoring and record keeping as keys to the successfulrunning of a PPC installation. As a result the operator is required within the permit to undertakeodour and noise assessments. General monitoring of the site is also covered in the Permit as aspecific requirement, SEPA expects the company to use monitoring to correct deficiencies withinthe activity and to alleviate any nuisance.

Monitoring is required to assess operational conditions and environmental performance. Variouspermit conditions require the operator to monitor the level of inputs and the volume of outputs, to

consider how changes made benefit the environment. The new BREF introduces the followingadditional monitoring requirements

The total nitrogen and total phosphorus excreted in manure

Ammonia emission to air

Dust emissions

Process parameters

The European Commission during deliberations around the revised BREF, accepted the proposalfrom the UK technical Working Group to estimate emissions by using DEFRA approved emissionfactors.

Process parameters include water consumption, energy consumption, fuel consumption, thenumber of incoming and outgoing animals, feed consumption and manure generation. This isalready well documented and will be formally required via the resource utilisation permit condition.

Monitoring requirements held within the permit also include those relating to the generator andincinerator exhausts. It is stated that the standard Ringelmann 1 will be used at start up and duringoperation.

5. 18 Closure

Standard conditions, shown as Condition 2. 14 of the permit, will be appropriate for this installation

including the production of a Decommissioning Plan for the installation. The operator has agreedto meet the SFIR for Decommissioning.

In order to ensure that the site can be returned to its pre -PPC Permit state SEPA have required

the company detail any pre -application problems prior to permitting so that a site surrender reportcan be compared with the Site Condition and Baseline Reports. Conditions are contained in the

permit to cover this. Surrender of the permit is by an application to SEPA who have to be satisfiedthat the requirements of Regulation 19 of the PPC Scotland Regulations 2012 ( as amended) arecomplied with.

As per the PPC Regulations the Applicant shall need to remediate the site where required to thelevels cited in the baseline report (please see Section 5. 19 below for more information).

5. 19 Site Condition Report ( and where relevant the baseline report)

As per Regulation 48 of the PPC Regulations a baseline report was submitted with the Site

Condition Report. This required revisions following SEPA assessment which found that not all riskshad been fully considered and current condition explained.

The final baseline report was submitted in September 2017 and was found to be satisfactory bySEPA for the purposes of this application. The limitations of the ground investigation mean that the

findings cannot be assumed to be reliably representative of the actual site condition but the finalreport acknowledges the limitations in the baseline investigation. There is a residual risk that

existing contamination may be encountered during future soil or water monitoring.

Particular risks have been identified as:

the historic pig burial pit, uncertainty in relation to the potential for hydrocarbon contamination in the vicinity of thefuel tank'

a hotspot of metal contamination in groundwater has been identified in BH04. The originand spatial extent of the hotspot is unproven and

ground gas (elevated CO2) encountered in BH01 and BH02.

The operator has been made aware that, since the baseline contamination has not been fullycharacterised, there is a risk that additional existing contamination may be identified during futuresoil and groundwater monitoring. This would then require to be addressed prior to PPC permitsurrender.

5. 20 Consideration of BAT

It has been demonstrated by the operator and stipulated above that BAT ( as per the BREFDocument 2017) has been considered for the following:

Surface Water

Soil & groundwater

Ammonia;

Dust;

Odour;

Noise;

Raw Materials;

Water Use;

Waste;

Energy; Incident Management;

Site Management.

6 OTHER LEGISLATION CONSIDERED

Nature Conservation ( Scotland) Act 2004 & Conservation ( Natural Habitats & c.) Regulations

1994

Is there any possibility that the proposal will have any impact on site designated under theabove legislation? Yes but no likely significant impact.

Justification: There are 10 Designated Sites under the above legislation within 10km of the Permitted

site ( threshold dictated by SEPA Nature Conservation Procedure NCP -P- 01). After carrying out theSimple Calculation of Atmospheric Impact Limits ( SCAIL) for agriculture it was found that there would

be no likely significant impact on the Designated Sites.

Screening distance( s) used — 10km.

Are there any SSSIs within the area screened? Yes

Has SNH been consulted under section 75( 5) of the 2004 Act? No - After carrying out the SimpleCalculation of Atmospheric Impact Limits ( SCAIL) for agriculture it was found that there would be no

likely significant impact on the Designated Sites. This is in accordance with SEPA Nature ConservationProcedure guidance NCP -P- 01.

Has SEPA reached agreement with SNH on protection of the SSSI? - Yes

Are there any SPA or SAC designated areas within the area screened? Yes — please see boxabove for consultation justification.

Other legislation?

The Water Environment ( Controlled Activities) ( Scotland) Regulations 2011 and Groundwater Directive

CAR) — There are no conflicts with ongoing CAR regulation of this process.

Nitrates Directive — This primarily applies to land -spreading activities outwith the process boundary. However the swale system to treat surface water drainage may enrich the ground locally and thisenrichment must be considered with respect to the Nitrates Directive when designing.

Carcasses are dealt with under The Animal By -Products Regulations and as a Directly AssociatedActivity in the permit.

Officer: CO

ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH

How has any relevant information obtained or conclusion arrived at pursuant to Articles 5, 6 and7 of Council Directive 85/ 337/ EEC on the assessment of the effects certain public and private

projects on the environment been taken into account? N/ A

How has any information contained within a safety report within the meaning of Regulation 7safety report) of the Control of Major Accident Hazards Regulations 1999 been taken into

account? N/ A

8 DETAILS OF PERMIT

Do you propose placing any non- standard conditions in the Permit: No

9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES

Are you are dealing with either a permit application, or a permit variation which would involve areview of existing ELVs or equivalent technical parameters? Yes - BAT Associated Emission LimitsAELs') for ammonia and total nitrogen and total phosphorus excreted have been inserted at Table 3. 4

of the permit. As part of the BREF review and 2017 publication of the BREF it was accepted by theCommission that operators could use emission factors to demonstrate compliance with the BAT Annual

Emission Limits for ammonia The AEL range for broilers with a final weight of up to 2. 5kg is 0. 01- 0.08kgNH3/ animal place/ year. The emission factor used for broiler, house in fan ventilated, fully litteredfloors with non - leaking drinkers is 0. 034 kgNH3/ animal place/ year, which is comfortably within therequired range. The operator will be required to confirm on an annual basis that the DEFRA emissionfactor still applies and that no changes have been made.

The AEL range for total nitrogen excreted from broilers is 0. 2- 0. 6 and total phosphorus is 0. 05- 0. 45.

There are presently no approved emission factors but it is expected that data indicating compliance willbe submitted by industry representatives on behalf of the sector as a whole and this is being encouragedby the UK technical working group.

Emission limit values Air

Substance: Incinerators exhaust ( smoke)

Relevant emission benchmarks: Industry standard for visual monitoring of stacks

ELV: Ringelmann Shade 1 during start up. No visible smoke during operation.

Emission points: Incinerator Stacks

Rationale: Included to prevent conflict with Condition 2. 5. 1 of the permit and to capture sufficientregulation of this emission.

Substance: Generator exhaust ( smoke)

Relevant emission benchmarks: Industry standard for visual monitoring of stacks

ELV: Ringelmann Shade 1 during start up. No visible smoke during operation.

Emission point: Generator Stack

Rationale: Included to prevent conflict with Condition 2. 5. 1 of the permit. The Diesel Generator is onlyused in reserve situations when Mains Power is unavailable to ensure the health and safety of thelivestock, operators and receptors and the regulatory compliance of the installation.

10 FINAL DETERMINATION

Issue the permit PPC/A/1158010 — Based on the information available at the time of the determinationSEPA is satisfied that:

The applicant will be the person who will have control over the operation of the installation,

The applicant will ensure that the installation is operated so as to comply with the conditions of thePermit,

That the operator is in a position to use all appropriate preventative measures against pollution, inparticular through the application of best available techniques.

That no significant pollution should be caused.

11 REFERENCES AND GUIDANCE

Standard Farming Installation Rules ( SEPA' s general sector Guidance) Nature Conservation Procedure NCP -P- 01

The assessment of potential impacts on designated sites of atmospheric emissions of ammonia from PPCintensive agriculture installations NCP -P- 02

Sniffer ER26: Final Report on the update of the Simple Calculation of Atmospheric Impact Limits ( SCAIL) 2014)

BAT Conclusions for the Intensive Rearing of Poultry or Pigs ( 2017) Rural Sustainable Drainage Systems — A practical design and build guide for Scotland' s farmers andlandowners ( 2016).

Associated Supporting Documents

Document 1: Application for Permit PPC/ A/ 1158010 ( including supporting and revised documents) Document 2: Applicant PM10 Modelling Report ( Final) Document 3: Baseline Report

Document 4: Schedule 4 Information Notice