HomeMy WebLinkAbout2560416 - F.I. Received Doc. - Application - Cover Letter25/574TE
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
Dear Sir/Madam,
We refer to the Further Information Request issued by Monaghan County Council in respect of Planning Application
Ref. 25/60416.
Item 1(a) – Noise Impact Assessment
A revised Noise Impact Assessment prepared by Traynor Environmental Ltd. is submitted with this Further Information
response.
The assessment has been specifically updated to take account of the existing background noise environment and
the potential increase in noise associated with the proposed development.
Baseline noise monitoring has been undertaken at representative locations surrounding the application site, including
short-term monitoring at representative noise-sensitive receptor locations and long-term monitoring at the application
site. The assessment considers the nearest residential noise-sensitive receptors and assesses both construction and
operational noise impacts.
The operational assessment has also been revised to reflect the clarified nature and scale of the proposed
development, namely:
• the facility will be used solely in connection with JC Environmental's own operations;
• no third-party waste will be accepted;
• the annual waste intake will not exceed 2,000 tonnes per annum;
• the majority of liquid/solid separation takes place within the specialist recycler vehicle before material
returns to Mullanarry;
• residual-material unloading and secondary/final screening will take place within the enclosed Debris
Reception Building;
• the Debris Reception Building has an approximate floor area of 192 m²;
• the odour-control/biofilter extraction system has a nominal design airflow of 4,000 m³/hour;
• routine waste reception and processing will be limited to the proposed operating hours set out under Item
2(c); and
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• there will be no routine waste processing on Sundays or Public Holidays.
The operational assessment considers the recycler/vacuum tanker, controlled unloading, secondary/final screening,
pumps, the biofilter/odour-control fan, vehicle movements and equipment washing under conservative operating
conditions.
Operational noise mitigation will include:
• all routine waste unloading and screening being undertaken within the enclosed Debris Reception
Building;
• external doors remaining closed during unloading and screening except for vehicle entry and exit;
• fixed plant being selected and/or acoustically attenuated to achieve the design sound levels adopted in
the Noise Impact Assessment;
• acoustic attenuation being provided to the biofilter/odour-control fan where required;
• pumps and continuously operating plant being acoustically enclosed or attenuated where necessary;
• prevention of unnecessary vehicle idling;
• minimisation of reversing movements;
• controlled handling of material to avoid unnecessary impact, dropping or clattering;
• routine plant maintenance; and
• investigation and corrective action in response to any substantiated noise complaint.
These operational controls are incorporated into the Noise Impact Assessment.
The assessment concludes that, subject to implementation of the specified mitigation and operational controls, the
development can operate without giving rise to unacceptable noise effects at surrounding residential receptors.
Accordingly, the submitted Noise Impact Assessment addresses Item 1(a) of the Further Information Request.
Item 1(b) – Odour Assessment
An updated Odour Impact Assessment and Air Dispersion Assessment and revised Odour Management Plan prepared
by Traynor Environmental Ltd. are submitted with this Further Information response.
The assessment has been prepared having regard to EPA Air Guidance Note AG5 and specifically addresses the
matters identified by the Planning Authority.
The previous description of the receiving environment as being simply “predominantly agricultural” has been
corrected.
The application site is situated within a mixed receiving environment, comprising residential properties and estates,
commercial premises, agricultural lands and the urban edge of Carrickmacross. Residential properties have therefore
been treated as high-sensitivity receptors for the purposes of the odour assessment.
The assessment also explicitly identifies three operational piggeries within the surrounding area, with approximate
populations of:
• 1,500 pigs;
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• 250 pigs; and
• 250 pigs.
Odour Containment
The revised development has been designed so that routine potentially odorous activities, including:
• waste reception and unloading;
• waste/debris handling;
• screening and separation;
• decanting;
• liquid/solid separation;
• transfer operations; and
• temporary waste storage,
will take place within the enclosed Debris Reception Building.
The building has an approximate floor area of 192 m² and an estimated enclosed volume of approximately 950 m³.
Potentially odorous process air will be mechanically extracted from the enclosed building and conveyed to the
proposed odour-control system for treatment.
The Debris Reception Building will be maintained under negative pressure during potentially odorous operations, with
roller-shutter doors remaining closed except for the minimum period necessary for vehicle entry and exit.
Odour-Control System
The proposed odour-control arrangement is based on an Anua Clean Air Dual-Pass Monashell OCU, or technically
equivalent dual-stage odour-control system.
A nominal whole-building extraction airflow of:
4,000 m³/hour has been adopted.
This represents approximately 4.2 air changes per hour based upon an indicative enclosed building volume of
approximately 950 m³.
Following treatment within the OCU, treated air will discharge vertically through controlled Emission Point A1, located
at ITM E 683929, N 803346.
The proposed controlled discharge comprises a 7.45 m high vertical stack, terminating approximately 2.5 m above
the highest roof ridge, with a terminal outlet diameter of approximately 0.240 m. At the adopted extraction airflow of
4,000 m³/hour, the calculated vertical discharge velocity is approximately 24.6 m/s.
The OCU will be designed, commissioned and operated to achieve a maximum normal-operating treated outlet
odour concentration of 400 OUE/m³, corresponding to an odour emission rate of approximately 444 OUE/s.
The following operational controls will also apply:
• waste-retention periods will be minimised;
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• screened debris and residual liquids will be removed regularly;
• the Debris Reception Building and processing equipment will be routinely cleaned;
• spills will be contained and cleaned promptly;
• covered tanks and closed or vapour-tight transfer connections will be maintained;
• the extraction and odour-control system will operate throughout potentially odorous activities;
• duty/standby extraction arrangements will be provided;
• roller-shutter doors will remain closed except for essential access;
• odour complaints will be recorded and investigated;
• routine and complaint-response boundary odour assessments will be undertaken having regard to EPA
AG5; and
• waste unloading and processing will cease where failure of the extraction or odour-control system prevents
effective odour containment.
The combination of process enclosure, negative-pressure extraction, treatment through the OCU, elevated vertical
discharge, limited waste-retention periods and operational controls substantially reduces the potential for
uncontrolled odour emissions from the proposed development.
Accordingly, the submitted Odour Impact Assessment and revised Odour Management Plan address Item 1(b).
Item 1(c) – Air Dispersion Assessment
An air-dispersion assessment has been undertaken for the proposed controlled OCU discharge to assess potential
ground-level odour concentrations at surrounding sensitive receptors.
The assessment has been prepared taking account of the relevant principles of EPA Air Dispersion Modelling
Guidance Note AG4, including consideration of:
• source location and characteristics;
• odour emission rate;
• discharge height and outlet characteristics;
• representative meteorological conditions;
• nearby sensitive receptors;
• the surrounding receiving environment;
• background odour sources; and
• appropriate odour assessment criteria.
The principal controlled emission source is designated A1, located at ITM E 683929, N 803346.
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The assessment is based upon:
• 4,000 m³/hour extraction airflow;
• 7.45 m vertical stack height;
• 0.240 m terminal outlet diameter;
• approximately 24.6 m/s vertical discharge velocity; and
• a maximum normal-operating treated outlet concentration of 400 OUE/m³.
At the adopted airflow, 400 OUE/m³ corresponds to an odour emission rate of approximately: 444 OUE/s
A conservative Gaussian screening methodology has been applied across a range of atmospheric stability classes
and wind speeds. The highest calculated ground-level concentration at each assessed distance has been used as
the screening result.
An odour assessment benchmark of: 1.5 OUE/m³ has been adopted having regard to the indicative criterion set out
in EPA AG4 Appendix H for relatively offensive odour sources.
The closest identified residential receptors are located approximately 64 m, 67 m, 84 m and 90 m from A1.
Under the 400 OUE/m³ design case, the predicted screening concentrations at these receptors are approximately:
Receptor Distance from A1 Predicted Concentration Screening Benchmark
R4 64 m 1.36 OUE/m³ 1.50 OUE/m³
R2 67 m 1.36 OUE/m³ 1.50 OUE/m³
R1 84 m 1.30 OUE/m³ 1.50 OUE/m³
R3 90 m 1.32 OUE/m³ 1.50 OUE/m³
Accordingly, the 400 OUE/m³ normal-operating design case remains below the adopted 1.5 OUE/m³ screening
benchmark at each of the identified residential receptors.
The assessment also considers higher treated outlet concentrations as sensitivity scenarios. These demonstrate that
deterioration in OCU performance would result in increased predicted ground-level concentrations and therefore
reinforce the requirement for the system to be designed, commissioned, maintained and operated to achieve 400
OUE/m³ or lower during normal operation.
Five complete years of meteorological information for the period 2021–2025 from Met Éireann Ballyhaise Station
have also been reviewed. The data indicate a predominantly south-westerly wind regime over the assessment
period.
The submitted air-dispersion assessment therefore demonstrates that, subject to the specified OCU performance
and operational controls, the proposed controlled discharge satisfies the adopted screening benchmark at the
identified sensitive residential receptors.
Accordingly, the submitted air-dispersion assessment responds to Item 1(c).
Item 1(d) – Background Odour and Sensitive Receptors
Background odour conditions and nearby sensitive receptors have been specifically considered within the revised
assessment.
The Planning Authority's concern regarding the characterisation of the surrounding receiving environment is
acknowledged.
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The locality is no longer described as simply agricultural. The assessment recognises:
• the mixed residential, commercial and agricultural receiving environment;
• the urban edge of Carrickmacross;
• nearby residential dwellings and gardens;
• the Crann Nua residential area; and
• three existing operational piggeries within the surrounding area.
The closest identified residential properties have been treated as high-sensitivity receptors, with receptor distances of
approximately 64–90 m from the proposed controlled discharge A1.
The three nearby piggeries are treated as separate pre-existing livestock/manure odour sources and have been
specifically considered when characterising the existing background odour environment.
Arbitrary numerical odour-emission rates have not been assigned to the piggeries, as reliable numerical modelling
would require verified source-specific information including pig-house geometry, ventilation arrangements, manure-
management practices and representative odour-emission data.
Background odour will therefore be considered through:
• identification of credible existing odour sources;
• routine and complaint-response field observations;
• prevailing wind direction and meteorological conditions;
• odour character;
• odour intensity;
• persistence and duration;
• the operational status of the JC Environmental facility; and
• the location of the receptor relative to each credible potential odour source.
• Routine and complaint-response odour assessments will be undertaken having regard to EPA AG5.
Item 2(a) – Waste Screening Process and Biofilter Technology
Nature and Scope of the Proposed Operation
JC Environmental operates a specialist drainage, gully-cleaning, sewer-cleaning and environmental-services
business.
The proposed Mullanarry facility will be used solely in connection with material generated through JC Environmental's
own drainage, sewer and gully-cleaning operations.
No third-party waste will be accepted at the facility.
The development will therefore not operate as a general commercial waste-transfer station and will not accept
waste from other waste collectors, contractors, businesses or members of the public.
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The waste streams proposed to be managed at the facility comprise:
• EWC 19 08 01 – Screenings;
• EWC 20 03 03 – Street-cleaning residues; and
• EWC 20 03 06 – Waste from sewage cleaning.
The total quantity of waste managed at the facility will not exceed 2,000 tonnes per annum.
Recycler Vehicles and Preliminary Separation
JC Environmental operates specialist recycler/vacuum tanker vehicles as part of its gully-cleaning, drain-cleaning and
sewer-cleaning activities.
Material removed from gullies, drains and sewers typically comprises water together with grit, sediment, silt, screenings,
stones, organic material and other debris.
The recycler vehicles undertake a substantial degree of liquid/solid separation and water recovery while the cleaning
operation is being carried out off site. A substantial proportion of the recovered water is reused by the vehicle during
the cleaning operation.
Consequently, the majority of the liquid/solid separation and water-recovery process has already taken place
before the vehicle returns to Mullanarry.
The material returned to the facility principally comprises the concentrated residual fraction remaining following this
process, including:
• grit;
• sediment and silt;
• screenings;
• stones and other coarse debris;
• organic material removed from the drainage system; and
• a comparatively small residual liquid fraction.
The facility is therefore not intended to receive bulk untreated wastewater for primary separation.
Waste Reception
All routine waste reception, unloading, screening, separation and associated waste-handling activities will take place
inside the enclosed Debris Reception Building.
The revised Debris Reception Building has a floor area of approximately 192 m² and accommodates the recycler
vehicle, secondary screening/handling operations, the underground liquid-storage arrangement and the covered
soiled-debris trailers. No routine waste unloading, screening, processing or uncovered storage of waste will take place
externally. On returning to Mullanarry, the recycler vehicle will enter or position within the enclosed Debris Reception
Building. The mechanical extraction and odour-control system will be operational before unloading commences and
the roller-shutter doors will be closed during unloading and processing activities.
The residual material contained within the recycler vehicle will subsequently be discharged in a controlled manner
within the building.
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Secondary / Final Screening
The screening undertaken at the Mullanarry facility constitutes a secondary/final physical screening operation.
The principal water-recovery and liquid/solid separation process has already taken place within the recycler vehicle
before it returns to the site.
The purpose of the secondary screening operation is to:
• remove remaining coarse solid material;
• separate the limited residual liquid fraction;
• facilitate controlled handling and storage of the resulting fractions; and
• prepare the separated material for onward transfer to appropriately authorised receiving facilities.
The process is a physical separation process only.
There will be:
• no composting;
• no biological treatment of waste;
• no chemical treatment;
• no thermal treatment;
• no land treatment; and
• no disposal of waste at the Mullanarry site.
Following secondary screening, the solid fraction comprising grit, sediment, silt, screenings and other debris will be
transferred directly into the dedicated covered soiled-debris trailers located within the Debris Reception Building.
The comparatively small residual liquid fraction will be directed to the dedicated covered/underground wastewater -
storage system.
The proposed operation therefore comprises waste reception, secondary/final physical screening where required,
short-term contained storage and onward transfer to appropriately authorised facilities.
Process Sequence
The proposed operational sequence can be summarised as follows:
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JC Environmental undertakes gully, drain and sewer cleaning off site
↓
Material is recovered using JC Environmental's specialist recycler vehicle
↓
Liquid/solid separation and water recycling take place within the recycler vehicle
↓
Recovered water is reused during the cleaning operation
↓
Concentrated residual grit, sediment, screenings and limited residual liquid are returned to Mullanarry
↓
Recycler vehicle enters or positions within the enclosed Debris Reception Building
↓
Mechanical extraction and odour-control system operates and doors are closed
↓
Controlled unloading of residual material
↓
Secondary/final physical screening where required
↓
Solid fraction transferred to covered debris trailers
↓
Limited residual liquid transferred to covered/underground storage
↓
Short-term contained storage
↓
Removal to appropriately authorised receiving facilities
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Onward Transfer
Separated solid material will be removed regularly from the Mullanarry facility and transferred to a waste facility
appropriately authorised to accept the relevant waste stream. The residual liquid fraction will be removed using an
enclosed tanker and transferred to an appropriately authorised wastewater-treatment facility. Waste will only be
stored for the minimum period necessary to facilitate efficient onward transfer. No long-term storage or stockpiling of
waste is proposed.
Odour Containment and Building Extraction
Although the quantity of free liquid returned to the facility is relatively limited due to the operation of the recycler
vehicles, the applicant recognises that the residual material has the potential to generate odour. All unloading,
secondary screening and associated waste-handling activities will therefore take place within the enclosed Debris
Reception Building. The building will operate under controlled mechanical extraction during all waste unloading,
screening and handling operations. The extraction system will be designed and operated to maintain the Debris
Reception Building under negative pressure, ensuring that the predominant movement of air is into the building rather
than allowing untreated, potentially odorous air to escape to the external environment. The roller-shutter doors will
remain closed during unloading and processing activities except for the minimum period necessary to facilitate
vehicle entry and exit. The extraction and odour-control system will be operational before unloading commences and
throughout all waste unloading, screening and handling activities.
Proposed Biofilter / Odour-Control System
Extracted air from the Debris Reception Building will be conveyed through dedicated ductwork to the proposed Anua
Clean Air Dual-Pass Monashell biofiltration system, or a technically equivalent system providing an equivalent or
greater level of odour treatment.
The current design extraction rate is: 4,000 m³/hour. This airflow provides approximately four whole-building air changes
per hour and provides the design basis for maintaining the Debris Reception Building under negative pressure during
potentially odorous operations.
The proposed air-treatment sequence will comprise:
Potentially odorous air within the Debris Reception Building
↓
Mechanical extraction
↓
Ducted conveyance to the odour-control unit
↓
Contact with conditioned biologically active filter media
↓
Transfer of odorous compounds into the moisture/biofilm associated with the media
↓
Biological degradation by microorganisms
↓
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Controlled discharge of treated air through emission point A1
Biofiltration is a biological air-treatment process whereby potentially odorous air passes through a moist biologically
active filter medium. Odorous biodegradable compounds contained within the extracted air are transferred into the
moisture and biofilm associated with the filter media, where naturally occurring microorganisms metabolise and
degrade those compounds.
Effective operation of the biofilter will be maintained through appropriate control of:
• media moisture content;
• airflow distribution;
• filter-media condition;
• water supply; and
• drainage.
The proposed biofilter installation includes two 1.5 m³ drainage sumps, associated pumps, drainage pipework and a
potable-water connection. These sumps are associated specifically with the operation and drainage of the biofilter
and do not constitute waste-storage tanks. Following treatment within the odour-control system, treated air will be
discharged through the dedicated A1 controlled emission point.
Operational Odour Controls
The following operational controls will apply:
• the facility will be used solely for material arising from JC Environmental's own operations;
• no third-party waste will be accepted;
• incoming material will arise principally from JC Environmental's own gully, drain and sewer-cleaning
activities;
• recycler vehicles will recover and reuse water during the off-site cleaning process;
• the majority of liquid/solid separation will therefore occur within the recycler vehicle prior to returning to the
site;
• only a comparatively small residual liquid fraction will normally return to the facility;
• all routine unloading and secondary screening will take place within the enclosed Debris Reception
Building;
• the mechanical extraction and odour-control system will operate during all waste unloading, screening
and handling activities;
• the building will be maintained under negative pressure during such activities;
• roller-shutter doors will remain closed except for essential vehicle access;
• waste-retention periods will be minimised;
• screened debris and residual liquid will be removed regularly to appropriately authorised facilities;
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• processing equipment and the building floor will be routinely cleaned;
• any spillages will be contained and cleaned promptly;
• drainage infrastructure will be routinely inspected and maintained; and
• waste unloading and processing will cease in the event of failure of the extraction or odour-control system
where effective odour containment cannot be maintained.
The combination of on-board recycler separation, enclosed waste reception, secondary screening, contained
storage, negative-pressure extraction, biofiltration and operational management measures will substantially minimise
the potential for uncontrolled odour emissions from the proposed activity.
Item 2(b) – Exact Volume of Waste to be Stored on Site
The proposed annual quantity of waste managed at the facility will not exceed 2,000 tonnes per annum.
This annual throughput should be distinguished from the maximum quantity of waste which may be stored at the site
at any one time.
Waste storage will be restricted to:
1. the covered/underground tank system used for the limited residual liquid fraction; and
2. the two covered soiled-debris trailers used for grit, sediment, screenings and other solid debris.
There will be no external stockpiling or uncovered storage of waste.
The maximum physical capacities and proposed operational limits are as follows:
Storage Facility Material Maximum Physical
Capacity
Maximum Operational
Quantity
Covered/underground tank
system
Residual liquid fraction 20,000 gallons 18,000 gallons
Covered soiled-debris trailer
No. 1
Grit, screenings, sediment
and debris
10 m³ 8 m³
The covered/underground liquid-storage system will therefore be operated below its maximum physical capacity,
with an operational limit of 18,000 gallons.
The two 1.5 m³ biofilter drainage sumps are associated solely with operation of the biofilter and are not included
within the waste-storage capacity of the facility.
The facility will be managed such that the stated operational storage limits are not exceeded.
Incoming material will only be unloaded where sufficient available storage capacity exists.
Waste will be removed regularly and will not be permitted to accumulate beyond the stated operational limits.
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Item 2(c) – Proposed Hours of Operation
The proposed hours during which waste may be received, unloaded, screened or otherwise processed at the facility
will be:
Monday to Friday: 08:00 to 19:00
Saturday: 08:00 to 16:00
Sunday and Public Holidays: No routine waste reception or processing.
No routine:
• waste reception;
• recycler unloading;
• waste screening;
• debris handling;
• tanker transfer; or
• other waste-processing operations
will take place outside the above operating hours.
Activities outside the stated operating hours will be restricted to security, emergency response and essential
maintenance where required.
Such activities will not involve routine waste reception or processing.
The mechanical extraction and odour-control system will remain operational throughout all periods during which
potentially odorous waste unloading, screening or handling activities are occurring.
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ITEM 7 – EXTERNAL AND SECURITY LIGHTING
The Planning Authority requested details of existing and proposed floodlighting and security lighting, having regard
to Section 8.39 and Policies LP1, LP2 and LP3 of the Monaghan County Development Plan 2025-2031.
A detailed External Lighting Assessment and Lighting Management Plan prepared by Traynor Environmental Ltd. is
submitted with this response.
The proposed development will not include high-mast floodlighting.
External lighting will comprise low-output, warm-white, fully shielded LED luminaires mounted principally on site-
facing building elevations and directed inward towards those areas requiring lighting for safe operation, including:
• the site entrance;
• office/access areas;
• operational yard;
• Debris Reception Building entrance and loading apron; and
• defined servicing areas.
The waste-processing activity itself will occur within the enclosed Debris Reception Building and will therefore not
require broad-area external floodlighting.
It is considered that the proposed lighting strategy accords with Section 8.39 and Policies LP1, LP2 and LP3 of the
Monaghan County Development Plan 2025-2031 and adequately addresses Item 7 of the Further Information
Request.
Item 8 – Clarification of Waste Processing Building
The Planning Authority notes that the development description submitted with the original planning application
referred to the change of use of one bay of the existing machinery shed to a proposed waste-processing building,
whereas the previously submitted plans appeared to indicate that a greater portion of the existing building was to
be used for waste-processing activities.
The applicant wishes to clarify that, following review and revision of the proposed development, the existing
machinery shed/bays will no longer be used for waste reception, unloading, screening, separation or other waste-
processing activities.
The proposal has been revised so that the waste-processing operations will instead be undertaken within the
proposed enclosed Debris Reception Building shown on the revised Further Information drawings.
The revised Debris Reception Building has a floor area of approximately 192 m² and has been specifically arranged
to accommodate the recycler vehicle, controlled residual-material unloading, secondary/final screening,
associated handling activities and the covered waste-storage infrastructure. The revised drawing identifies this as a
dedicated Debris Reception Building.
Accordingly, under the revised proposal:
• the existing machinery shed will not be used for waste-processing operations;
• no bay of the existing machinery shed is proposed to undergo a change of use to waste processing;
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• all routine waste reception and recycler unloading will take place within the proposed enclosed Debris
Reception Building;
• all secondary/final screening and associated waste handling will take place within the proposed Debris
Reception Building;
• solid debris will be transferred to the covered debris trailers associated with that building;
• the limited residual liquid fraction will be directed to the covered/underground storage system; and
• potentially odorous air arising from these operations will be mechanically extracted from the Debris
Reception Building to the proposed biofilter/odour-control system.
This revised arrangement also ensures that the waste-processing operation is physically contained within a
dedicated enclosed building and is consistent with the noise and odour mitigation measures submitted as part of
the Further Information response.
Item 9 – Submissions from Third Party Residents
A separate detailed response to the matters raised in the third-party submissions is enclosed with this Further
Information submission and should be read in conjunction with the technical assessments and clarification provided
herein.
Conclusion
The information submitted with this Further Information response provides detailed clarification and supporting
technical assessment in respect of Items 1, 2, 7 and 8 and 9 of Monaghan County Council's Further Information Request
for Planning Ref. 25/60416.
Having regard to the revised development arrangement, the accompanying technical assessments, the proposed
operational controls, the revised planning drawings and the separate response to third-party submissions, it is
considered that Further Information Items 1, 2, 7, 8 and 9 have been comprehensively addressed.
The Planning Authority is respectfully requested to have regard to the Further Information submitted and to continue
its assessment of Planning Application Ref. 25/60416 on the basis of the revised proposal.
Yours faithfully,
Nevin Traynor
Traynor Environmental Ltd.
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