HomeMy WebLinkAbout2560416 - F.I. Received Doc. - Submission response25/574TE
16th September 2026
Planning Section
Monaghan County Council
Planning Offices
1 Dublin Street
Monaghan
H18 X982
Re: Planning Ref. 25/60416
Mullanarry Environmental trading as JC Environmental
Mullanarry, Carrickmacross, Co. Monaghan
Response to Third Party Submission
Dear Sir/Madam,
1.0 Introduction
The applicant has reviewed the third-party submissions received in respect of the proposed development and
acknowledges the concerns raised, particularly in relation to odour, residential amenity, waste handling, noise, pest
control and traffic.
The applicant considers it important to clarify the nature and scale of the proposed operation, as a number of the
concerns appear to arise from an understanding that the site is proposed to operate as a general waste-treatment
or waste-transfer facility receiving material from third parties.
This is not the proposed operation.
The Mullanarry facility will be used solely in connection with JC Environmental's own drainage, gully -cleaning and
sewer-cleaning activities. No third-party waste will be accepted at the facility.
The maximum annual quantity of material to be brought to the site will be limited to 2,000 tonnes per annum.
JC Environmental operates specialist recycler/vacuum tanker vehicles. During off-site gully and drain-cleaning
operations, these vehicles undertake the majority of the liquid/solid separation and recycle recovered water for
continued use during the cleaning operation.
Consequently, the material returned to Mullanarry is primarily a concentrated residual fraction comprising grit, silt,
sediment, screenings and other debris, together with a comparatively small residual liquid fraction.
The proposal is therefore substantially different from the receipt of bulk untreated wastewater for processing.
The operation at Mullanarry will consist of the controlled reception of JC Environmental's own residual material,
secondary/final physical screening where required, short-term contained storage and onward transfer to
appropriately authorised facilities.
There will be no composting, biological treatment, thermal treatment, chemical treatment or disposal of waste at the
site.
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2.0 Waste Type, Quantity and Storage
The concerns raised regarding the absence of sufficiently detailed information on waste types and quantities are
acknowledged.
The proposed waste streams are:
EWC 19 08 01 – Screenings
EWC 20 03 03 – Street-cleaning residues
EWC 20 03 06 – Waste from sewage cleaning
The maximum annual intake will be restricted to 2,000 tonnes per annum.
All routine unloading and secondary/final screening will occur within the enclosed Debris Reception Building, which
has an approximate floor area of 192 m².
The majority of separation takes place within the recycler vehicle prior to arrival at the site. On return to Mullanarry,
the residual material will be discharged in a controlled manner inside the Debris Reception Building.
Solid material will be transferred directly into covered soiled-debris trailers, while the comparatively small residual liquid
fraction will be transferred to the covered/underground storage system.
There will be no uncovered external stockpiling of waste.
The current storage schedule provides for:
Underground/covered liquid storage: maximum physical capacity of 20,000 gallons, with a maximum operational
quantity of 18,000 gallons.
Covered soiled-debris trailer No. 1: capacity 10 m³.
Waste will be removed regularly and will not be permitted to accumulate beyond the specified operational limits.
Incoming material will only be accepted where sufficient available storage capacity exists.
3.0 Odour and Existing Complaints
The applicant acknowledges the concerns raised by residents regarding odour and does not seek to dismiss the
reported experiences.
The occurrence of an odour within the surrounding area should, however, be distinguished from confirmed attribution
of that odour to a particular source. The revised odour assessment recognises that the receiving environment contains
a number of potential odour sources, including three existing operational piggeries with an approximate combined
population of 2,000 pigs. The assessment does not attribute existing complaints to those facilities or to JC Environmental
without supporting source-characterisation evidence.
Any future complaint will therefore be investigated having regard to the character and intensity of the odour, wind
direction and meteorological conditions, operating conditions at JC Environmental at the relevant time, persistence
and duration and other identifiable local sources.
The proposed development incorporates a substantially enhanced odour-control arrangement specifically intended
to prevent uncontrolled release of potentially odorous air.
All potentially odorous waste unloading, secondary screening and handling will take place within the enclosed Debris
Reception Building.
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The building will be maintained under negative pressure during potentially odorous operations so that air movement
is predominantly into the building rather than from the building to the external environment.
The roller-shutter doors will remain closed during unloading and processing except for the minimum period necessary
for vehicle access.
Potentially odorous building air will be mechanically extracted and treated through the proposed odour -control
unit/biofilter prior to controlled discharge to atmosphere.
The adopted design basis is:
Extraction airflow: 4,000 m³/hr
Maximum normal-operating treated outlet concentration: 400 OUE/m³
Controlled discharge stack height: 7.45 m
Emission point: A1
The OCU will be selected, commissioned, operated and maintained to achieve a treated outlet concentration of 400
OUE/m³ or lower during normal operation.
The revised conservative dispersion assessment predicts that the 400 OUE/m³ design case remains below the adopted
1.5 OUE/m³ odour screening benchmark at all identified residential receptors.
The nearest assessed residential receptors are approximately 64–90 m from the controlled discharge and are
predicted at approximately 1.30–1.36 OUE/m³ under the normal-operating design case.
The proposed control system will be commissioned prior to routine operation to verify extraction airflow, system
balance, negative-pressure performance and treated-air performance.
Waste unloading and processing will cease where the extraction or odour-control system is unavailable and effective
odour containment cannot be maintained.
4.0 Weekend Operations
The concern expressed regarding odour being experienced at weekends is specifically noted.
The proposed hours during which waste may be received, unloaded, screened or otherwise processed will be:
Monday to Friday: 08:00–19:00
Saturday: 08:00–16:00
Sunday and Public Holidays: No routine waste reception or processing
Accordingly, there will be no routine recycler unloading, screening, debris handling, tanker transfer or waste-
processing activity on Sundays or Public Holidays.
Activities outside the stated hours will be limited to security, emergency response and essential maintenance and will
not involve routine waste reception or processing.
The odour-control equipment may continue to operate where necessary to maintain appropriate environmental
control; operation of the OCU itself should not be interpreted as waste-processing activity.
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5.0 Odour Monitoring and Complaint Management
A revised Odour Management Plan has been prepared for the proposed operation.
Routine boundary odour assessments will be undertaken and an odour complaint register maintained.
Where an odour complaint is received, the circumstances of the complaint will be investigated. The investigation will
consider meteorological conditions, wind direction, odour character, intensity and persistence, site operating status
and other credible sources within the receiving environment.
Where a site-related odour is identified, appropriate corrective action will be implemented and increased monitoring
undertaken where necessary to demonstrate that effective control has been restored.
This approach is intended both to protect residential amenity and to ensure that complaints are investigated
objectively rather than either automatically attributed to, or automatically dismissed by, the applicant.
6.0 Noise
The concerns regarding potential construction and operational noise have been addressed through the revised Noise
Impact Assessment.
Baseline noise monitoring was undertaken over a seven-day period, including daytime, night-time and weekend
conditions.
The operational noise model has been updated to reflect the actual proposed development, including:
JC Environmental recycler/vacuum tanker movements; controlled unloading within the enclosed Debris Reception
Building; secondary/final screening within the building; process and transfer pumps; the OCU extraction fan;
vehicle/equipment washing; and associated ancillary activities.
The revised modelling predicts operational noise levels at the four representative residential receptors of
approximately 31.0–41.7 dB Lden and 24.8–38.2 dB Lnight.
The indicative predicted daytime change in the existing acoustic environment is approximately +0.2 to +1.7 dB. The
conservative night-time model, which principally represents operation of the OCU fan rather than routine waste
processing, indicates an increase of approximately +0.2 to +3.1 dB, with the highest predicted change occurring at
the eastern receptor.
Operational mitigation will include enclosed waste screening, closed-door management during noise-generating
activities, selection and maintenance of low-noise mechanical equipment, acoustic attenuation of the OCU fan and
pumps where required, minimisation of vehicle reversing and idling, and control of loading and unloading activities
to avoid unnecessary impact noise and clattering.
Routine waste processing will not occur during the night-time period.
7.0 Rodent and Pest Control
The concern regarding rodent control is acknowledged.
A formal pest-control and housekeeping programme will form part of the operational management of the facility.
The potential for pests will be minimised through contained storage of all waste, covered debris trailers,
covered/underground liquid storage, minimisation of waste-retention periods, regular removal of residual material,
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routine cleaning of the Debris Reception Building and processing equipment, prompt clean-up of spillages and
maintenance of drainage infrastructure.
No loose or uncovered waste will be stockpiled externally.
A competent pest-control contractor will inspect the facility at appropriate intervals and maintain baiting/monitoring
stations where required. Inspection and treatment records will be retained on site, and evidence of pest activity will
trigger prompt corrective action.
8.0 Traffic and Vehicle Movements
The concerns regarding traffic and additional machinery are acknowledged.
The operational scope has now been significantly clarified.
The facility will not accept third-party waste vehicles. Material will be returned solely in vehicles associated with JC
Environmental's own gully, drain and sewer-cleaning activities.
The maximum annual intake is restricted to 2,000 tonnes per annum, and the recycler technology allows recovered
water to be reused during the off-site cleaning process. Consequently, the proposal does not involve routine third-
party bulk wastewater deliveries to the site.
Operational waste-related vehicle movements will be confined to the approved operating hours.
Vehicles will be managed within the application site so as to avoid obstruction or queuing on the public road. Engines
will not be left idling unnecessarily, reversing movements will be minimised where practicable and vehicle movements
within the site will be undertaken at low speed.
Construction traffic will be temporary in nature and will be managed to minimise disturbance to surrounding residential
properties.
9.0 Residential Amenity
The concerns raised regarding the ability of residents to enjoy their homes and gardens are acknowledged.
The purpose of the revised design and the additional technical assessments submitted with the Further Information
response is to ensure that the proposed development operates in a manner compatible with the surrounding mixed
residential, commercial and agricultural environment.
In particular, the revised proposal includes enclosure of waste handling, a reduced and clearly defined annual
throughput, no third-party waste acceptance, restricted operating hours, negative-pressure extraction, a high-
performance OCU, an elevated treated-air discharge, contained waste storage, noise mitigation, pest-management
measures and ongoing environmental monitoring.
The concern raised regarding property values is noted. The applicant does not propose to speculate on individual
property valuations. The relevant planning consideration is the protection of residential amenity, which has been
specifically addressed through the revised design and the accompanying odour, noise, lighting and operational-
control assessments.
10.0 Conclusion
The applicant acknowledges the concerns raised in the third-party submissions and has used the Further Information
process to provide substantially greater detail regarding the nature, scale and control of the proposed activity.
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In particular, it is now confirmed that:
the facility is for JC Environmental's own operations only and will not accept third-party waste; the annual intake is
limited to 2,000 tonnes; most liquid/solid separation occurs in the recycler vehicle before returning to the site; routine
unloading and secondary screening will occur inside the enclosed Debris Reception Building; only a limited residual
liquid fraction will normally return to the site; waste will be stored in covered/contained infrastructure for short periods
only; potentially odorous air will be extracted under negative pressure and treated through the OCU; the OCU will be
designed to achieve 400 OUE/m³ or lower during normal operation; treated air will discharge through a 7.45 m stack;
routine waste processing will not occur on Sundays or Public Holidays; and noise, pest, traffic, housekeeping and
complaint-management controls will be implemented.
On the basis of the revised design, restricted operational scope and environmental-control measures proposed, the
applicant considers that the development can be operated without giving rise to a significant adverse effect on the
residential amenity of surrounding properties.
Yours faithfully,
Nevin Traynor
Traynor Environmental Ltd.
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