PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and...

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PM GROUP Takeda Ireland Ltd (Grange Castle) Ninlaro Project IE0311985-22-RP-0001, Issue A 31/01/2017 IE0311985-22-RP-0001_A_01.DOCX Page 161 of 198 Formal Issue 11 Land and Soils 11.1 Introduction This chapter assesses and evaluates the potential impacts of the proposed development on land and soils, i.e. the soil, geological and hydrogeological aspects of the site and surrounding area during both the construction and operational phases. This assessment is based on a desktop study of the site including publically available information from the Geological Survey of Ireland (GSI), and a recent geotechnical site investigation at the proposed site. Mitigation measures are provided where necessary. 11.2 Methodology The assessment of the potential impact of the proposed development on land and soils was carried out according to the methodologies specified in EPA (see Section 1.7.1) and Institute of Geologists of Ireland (IGI) 64 guidance documents. The rating of potential environmental impacts on the soils, geological and hydrogeological environment is based on the EPA matrix presented in Table 1.3 which takes account of the quality, significance, duration and type of impact characteristic identified. The collection of baseline data was derived from the following sources: - GSI on-line mapping – groundwater vulnerability, geo-hazard database, geological heritage sites, minerals and karst database 65 . - EPA ENVision Maps – bedrock geology, soils, subsoils, aquifers 66 . - Gavin & Doherty Geosolutions Ltd. Site investigation Report. December 2016 (Reference 16128-02). - Exova Jones Environmental. Environmental Testing Results. November/December 2016 (Test Report Reference Numbers 16/17582 and 16/18050) (Attachment 6). 11.3 Existing Environment The site is owned by Takeda but is not currently being used. Part of the site was previously used as a compound for the construction of the existing Takeda facility. It has an area of approximately 4 hectares. The site is generally flat with local undulations in level (covered with grass) with ground levels at approximately 63.6mOD in the north rising to 64.5mOD in the south. The River Griffeen which was originally running through the site has been diverted along the business park and its original route may have been infilled with imported material. As part of the investigative woks carried out by Gavin & Doherty Geosolutions Ltd., a total of 6 no. trial pits (TPs) and 5 no. boreholes (BHs) were excavated. The locations of these TPs and BHs are illustrated in Figure 11.1. 64 IGI, (2013), Guidelines for the Preparation of Soils, Geology and Hydrogeology Chapters of Environmental Impact Statements 65 GSI, Online Mapping, http://www.gsi.ie/Mapping.htm 66 EPA ENVision database. Groundwater Quality, Soils and Subsoils Database - http://gis.epa.ie/ For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 18-07-2017:03:18:27

Transcript of PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and...

Page 1: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

PM GROUP

Takeda Ireland Ltd (Grange Castle) Ninlaro Project

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11 Land and Soils

11.1 Introduction

This chapter assesses and evaluates the potential impacts of the proposed development on land and soils, i.e. the soil, geological and hydrogeological aspects of the site and surrounding area during both the construction and operational phases. This assessment is based on a desktop study of the site including publically available information from the Geological Survey of Ireland (GSI), and a recent geotechnical site investigation at the proposed site. Mitigation measures are provided where necessary.

11.2 Methodology

The assessment of the potential impact of the proposed development on land and soils was carried out according to the methodologies specified in EPA (see Section 1.7.1) and Institute of Geologists of Ireland (IGI)64 guidance documents.

The rating of potential environmental impacts on the soils, geological and hydrogeological environment is based on the EPA matrix presented in Table 1.3 which takes account of the quality, significance, duration and type of impact characteristic identified.

The collection of baseline data was derived from the following sources:

- GSI on-line mapping – groundwater vulnerability, geo-hazard database, geological heritage sites, minerals and karst database65.

- EPA ENVision Maps – bedrock geology, soils, subsoils, aquifers66.

- Gavin & Doherty Geosolutions Ltd. Site investigation Report. December 2016 (Reference 16128-02).

- Exova Jones Environmental. Environmental Testing Results. November/December 2016 (Test Report Reference Numbers 16/17582 and 16/18050) (Attachment 6).

11.3 Existing Environment

The site is owned by Takeda but is not currently being used. Part of the site was previously used as a compound for the construction of the existing Takeda facility. It has an area of approximately 4 hectares. The site is generally flat with local undulations in level (covered with grass) with ground levels at approximately 63.6mOD in the north rising to 64.5mOD in the south. The River Griffeen which was originally running through the site has been diverted along the business park and its original route may have been infilled with imported material.

As part of the investigative woks carried out by Gavin & Doherty Geosolutions Ltd., a total of 6 no. trial pits (TPs) and 5 no. boreholes (BHs) were excavated. The locations of these TPs and BHs are illustrated in Figure 11.1.

64

IGI, (2013), Guidelines for the Preparation of Soils, Geology and Hydrogeology Chapters of Environmental Impact Statements 65

GSI, Online Mapping, http://www.gsi.ie/Mapping.htm

66 EPA ENVision database. Groundwater Quality, Soils and Subsoils Database - http://gis.epa.ie/

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Page 2: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

Trial: Fi • TP'OX

C::i ble p rcusston / Rorary

Core Ho ~hole

Extent f proposed grou11d

i11ve-:.tii,:atim1 area

• snox/ RCOX

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Figure 11.1: Trial Pit and Borehole Locations

11.3.1 Soils

The GSI soil mapping indicates that the soils underlying the proposed development site comprise primarily of Surface water Gleys / Ground water Gleys Basic (BminPD). A Gley is a wetland soil that, unless drained, is saturated with groundwater for long enough periods to develop a characteristic gleyic colour pattern. This pattern is essentially made up of reddish, brownish or yellowish colours at surfaces of soil particles in the topsoil mixed with a grey or blue coloured soil. Figure 11.2 shows the soil types at the proposed development site and the surrounding area. A description for this soil type is as follows:

BminPD - Surface water Gleys / Ground water Gleys Basic

These are soils in which the effects of drainage impedance dominate and which have developed under the influence of permanent or intermittent water logging. The impedance may be due to a high water table, to a 'perched' water table caused by the impervious nature of the soil itself, or to seepage of runoff from slopes.

This data is likely to be outdated as the actual site is not a wetland. Remediation works to the site by the SDCC, involved redirecting the river Griffeen which once passed through the site around the site via a new channel. Ground investigations by Gavin & Doherty also confirm that the soil is not waterlogged or considered to hold surface water.

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Page 3: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

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• BmlnDW·De~11sndr.i1nS'dm,n@ral( alnlybac!lcf

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!!mlnSRFT • Sh;il!Ow tocl!y. lltlii ~-llililt'jmlni<il cornul11 es l ,1.1111~ b.$lC

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Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group)

11.3.2 Subsoils (Drift Geology)

Figure 11.3 has been captured from the GSI webviewer for Subsoil classification. The subsoil underlaying the Takeda site and also the surrounding area is classed as TLs, a till derived from limestone carboniferous material. The topsoil is of class BminPD which represents a mineral poorly drained soil derived mainly from calcareous parent materials.

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Page 4: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

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BmllSPF'T • SflaljDW peaty pOQf1y dratnml llllfleral (Mamly basitJ

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10SRPT· Slllllk>,,, nKio/ peacyJnon11eaiym r\Bllil oo~exe.s (Matnfy acid o)

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Figure 11.3: Subsoil for the Site and Surrounding Area (Extract from GSI, Annotated by PM Group)

As part of the ground investigation by Gavin & Doherty Geosolutions Ltd. for the proposed site, a soil sampling programme was undertaken in order to verify the condition of the soils at the site. A copy of the laboratory results is included in Attachment 6.

The results are outlined in Table 11.1. Results have been compared to standards outlined in the EPA publication Towards Setting Environmental Quality Objectives for Soil, Developing a Soil Protection Strategy for Ireland, A Discussion Document, EPA 2002. In the absence of standards in this document, soil guideline values (SGV) developed by the UK Environment Agency (UK EA) for use in assessing the chronic risk to human health from long-term exposure to chemicals in soil, have been used. For some parameters, there is no standard available in either of the aforementioned documents, and in such instances Dutch Target and Intervention Values from the Ministry of Housing, Spatial Planning and Environment, Directorate-General for Environmental Protection, 2000, were used as a guideline only.

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Page 5: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

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Takeda Ireland Ltd (Grange Castle) Ninlaro Project

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Table 11.1: Soil Environmental Testing Results (Refer to Figure 11.1 for locations of TPs)

Parameter Units Result from TP02

Result from TP03

Result from TP05

Environmental Guideline

Value

Environmental Guideline

Source

pH pH units 8.15 8.04 - N/A N/A

Moisture Content

% 24.6 - 8.9 N/A N/A

Total Organic Carbon

% - 2.28 0.37 N/A N/A

Organic Matter % 3.8 - - N/A N/A

Sulphate as SO4

g/l 0.017 - - N/A N/A

Total Cyanide mg/kg <0.5 - - 20 Dutch Intervention

Value

Mineral Oils (C10-C40)

mg/kg - - <30 5,000 Dutch Intervention

Value

Poly Aromatic Hydrocarbons

(PAHs) 16 Total

mg/kg <0.6 - - 40 Dutch Intervention

Value(1)

PAH 17 Total mg/kg - - <0.64 40 Dutch Intervention

Value(1)

Extractable Petroleum

Hydrocarbons (EPH) (C8-

C40)

mg/kg 122 - - N/A N/A

Methyl-tert-butyl ether

(MTBE) µg/kg - - <5 100,000

Dutch Indicative Level for Serious Contamination

Benzene µg/kg - - <5 95,000(2) UK EA SGV

Toluene µg/kg - - <5 4,400,000(2) UK EA SGV

Ethylbenzene µg/kg - - <5 2,800,000(2) UK EA SGV

m/p-Xylene µg/kg - - <5 3,200,000(2,3) UK EA SGV

o-Xylene µg/kg - - <5 2,600,000(2) UK EA SGV

Polychlorinated Biphenyls

(PCBs) – Total 7(4)

µg/kg - - <35 240(2,5) UK EA SGV

Arsenic mg/kg 35.2 - - 1 – 50 EPA Guideline

Value

Water Soluble Boron

mg/kg 1.1 - - 20 – 1,000 EPA Guideline

Value

Cadmium mg/kg 1.8 - -

0.1 – 1 EPA Guideline

Value

230(2) UK EA SGV

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Page 6: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

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Parameter Units Result from TP02

Result from TP03

Result from TP05

Environmental Guideline

Value

Environmental Guideline

Source

Chromium mg/kg 53.8 - - 2 – 250 EPA Guideline

Value

Copper mg/kg 30 - - 2 – 100 EPA Guideline

Value

Lead mg/kg 35 - - 2 – 80 EPA Guideline

Value

Mercury mg/kg <0.1 - - 0.03 – 0.8 EPA Guideline

Value

Nickel mg/kg 47.7 - - 0.5 – 100 EPA Guideline

Value

Zinc mg/kg 163 - - 10 – 200 EPA Guideline

Value

Notes: (1): Dutch Intervention Value for PAH (sum 10) (2): SGV for Commercial Land Use (3): SGV for p-Xylene used as a conservative approach (4): Total 7 PCBs is the sum of PCB28, PCB52, PCB101, PCB118, PCB138, PCB153 and PCB180 (5): SGV for the sum of PCDDs, PCDFs and dioxin-like PCBs

The laboratory results on the soil samples that were analysed indicates that no parameter identified at a level that exceeded the appropriate standard with the exception of Cadmium, where the results of 1.8mg/kg from TP02 exceeds the EPA Guideline Value 0.1-1mg/kg; however it is well below the UK EA SGV for Cadmium of 230mg/kg.

The above results were input into the HazWaste online tool67 to determine if any of the samples can be classified as hazardous. The tool concluded that none of the samples are classified as hazardous based on the results in Table 11.1.

Of the three samples tested, two of these also had the full WAC (Waste Acceptance Criteria) testing suite performed (TP03 and TP05). The results of the samples tested for the full WAC suite were compared against landfill WAC limits and all test results indicated the samples to be inert WAC.

11.3.3 Bedrock Geology

According to the Geological Survey of Ireland (GSI) Bedrock map for Dublin, the site is largely underlain by the Dublin Calp Limestone (CP) (see Figure 11.4). The Calp consists of grey to dark grey / black predominantly argillaceous, occasionally calcisiltite limestones (bedded) with subordinate blackish grey mudstone or shale.

Rotary drilling methods were used to recover soil and bedrock samples from the proposed locations. The samples were recovered using open hole drilling methods in line with Section 3.2 of IS EN 1997-2:2007 and IS EN ISO 22475-1. Rotary core drilling was conducted by Ground Investigations Ireland (GII) on behalf of Gavin & Doherty Geosolutions Ltd. using a track mounted T44 Beretta rig.

During the site investigation, bedrock was encountered at approximately 1.5 to 2m bgl. The bedrock at the site is described as shale. The shallow shale is distinctly weathered over the initial 0.5m. Beneath the distinctly weathered rock it is described as partially weathered becoming unweathered at approximately 5mbgl in RC01. The shale is described as medium strong and black in colour. The shale contains occasional clay bands and occasional pyrite with fractures at close to medium spacing.

67 Available at: https://www.hazwasteonline.com/

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Page 7: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

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Figure 11.4: Bedrock Geology of the Site and Surrounding Area (Extract from GSI)

Geological Heritage

The Geological Survey of Ireland (GSI) Irish Geological Heritage (IGH) Programme database was reviewed via their Public Viewer www.gsi.ie/mapping. There are no recorded sites on the site of the proposed development and surrounding area.

Karst Features

According to GSI online mapping database, there is no record of any karst features at the subject site or the surrounding area.

Economic Geology

According to GSI online mapping database, the nearest quarry is Belgard Quarry, which is located approximately 3.5km to the southeast of the proposed development site.

Geo-hazards

According to GSI online mapping database, there are presently no records of geo-hazards such as landslides, within a radius of 5km of the site.

Radon

According to the EPA radon mapping68, the site is in an area classed where 5 to 10% of homes are above reference levels. A High Radon Area is any area where it is predicted that 10 per cent or more of homes will exceed the Reference Level of 200 bequerel per cubic metre (Bq/m3). The area for the proposed development is therefore not considered a High Radon Area.

11.3.4 Hydrogeology

As part of the site investigation, groundwater was encountered in the bedrock; however, monitoring data for the groundwater level was not recorded. Historical ground investigation results at the site indicate groundwater seepage in trial pits at the depth of 1.3 and 1.7m, while the rotary core

68 EPA Radon Map, http://www.epa.ie/radiation/radonmap/

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Page 8: PM - Environmental Protection Agency · Formal Issue Figure 11.2: Topsoil for the Site and Surrounding Area - (Extract from GSI, Annotated by PM Group) 11.3.2 Subsoils (Drift Geology)

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samples show the seepage at 2.8 and 4.9m deep. However, since no pipe has been installed in the boreholes during these tests, it is probable that the actual water level is higher than measured.

Aquifer Classification

An aquifer is an underground body of water-bearing rock or unconsolidated material (gravel or sand) from which groundwater can be extracted and used. The GSI have divided aquifers into three main groups based on their resource potential and subdivided these groups depending on the type of openings trough which groundwater flows. The area of bedrock aquifer that the site is situated on is referred to as a Locally Important Aquifer (LI). This type of bedrock aquifer is classed as moderately productive at storing water in local zones. Figure 11.5 has been taken form the GSI website and illustrates the different types of bedrock aquifers in the area.

Figure 11.5 has two main layers overlaid as shown; the bedrock aquifer fault lines (black lines) and the bedrock aquifer classification. The known bedrock fault lines do not cross under the site, so they do not pose any hazard to the proposed development. The underlying bedrock is not known to show any evidence of karst and is classed as a locally important aquifer.

Figure 11.5: Bedrock Aquifer Classification (Extract from GSI, Annotated by PM Group)

Groundwater Flow Direction

Given that the Griffeen River would have been the low point through middle of the site, it is probable that groundwater flow continues to flow in an east to west direction.

Groundwater Vulnerability

Vulnerability is defined by the GSI as the intrinsic geological and hydrogeological characteristics that determine the ease with which groundwater may be contaminated by human activities. The GSI uses four groundwater vulnerability categories - Extreme, High, Moderate and Low, in the assessment of risk to groundwater. According to the data portrayed in Figure 11.6, the proposed development is situated within an area of Extreme vulnerability.

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0

II

D W-Water

L- Low

Layer \llsibiiily

•- ~ Grnunawater VulnembHity

GroundwarerVuTneraJ;ility

• X-R!&C'k.atornea;surf:aee i,rl<'ars

E-Extreme

-High

M-Mooetate

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Figure 11.6: Groundwater Susceptibility for the Site and Surrounding Area (Extract from GSI, Annotated by PM Group)

Source Protection Areas

There are no Source Protection Areas on, or in the immediate vicinity of, the site, according to the GSI national database. A Source Protection Area is a land area that contributes groundwater to a borehole or spring.

Groundwater Wells and Springs

According to the GSI national database, the closest ground water wells/springs to the site are approximately 3km to the east and 3km to the north west.

Groundwater Quality

As part of the ground investigation carried out by Gavin & Doherty Geosolutions Ltd. groundwater samples were taken from the boreholes and analysed by Exova Jones Environmental, a UKAS accredited laboratory.

Groundwater was sampled at two boreholes - BH01 and BH02 (see Figure 11.1). The results are outlined in Table 11.2. Results have been compared to standards outlined in the European Communities Environmental Objectives (Groundwater) Regulations, 2010 (S.I. No. 9 of 2010), and where standards were not available in the aforementioned regulations standards were referenced from Towards Setting Guideline Values for the Protection of Groundwater in Ireland Interim Report, EPA 2003 (EPA IGV). A copy of the groundwater laboratory results is included in Attachment 6.

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Table 11.2: Borehole Sampling Results

Parameter Units BH01 BH02 Environmental Guideline Value

Environmental Guideline Source

Dissolved Oxygen mg/l 9 1 No Abnormal

Change EPA IGV

Conductivity µS/cm

@ 25°C 481 917 800 – 1875 S.I. 9 of 2010

Temperature °C 7.1 6.0 25 EPA IGV

Total Alkalinity (as CaCO3)

mg/l 59500 50740 No Abnormal

Change EPA IGV

BOD mg/l <2 2 N/A N/A

COD mg/l <10 64 N/A N/A

Faecal Coliforms CFU/100

ml 50 50 0 EPA IGV

Total Organic Carbon mg/l <2 4 No Abnormal

Change EPA IGV

Fluoride mg/l 0.6 0.3 1 EPA IGV

Sulphate mg/l 44.0 55.3 187.5 S.I. 9 of 2010

Nitrate (as N) mg/l 0.38 0.13 37.5 S.I. 9 of 2010(1)

Nitrite (as N) mg/l 0.046 0.053 0.375 S.I. 9 of 2010(2)

Orthophosphate (as P) mg/l <0.03 <0.03 0.03 EPA IGV

Total Oxidised Nitrogen (as N)

mg/l 0.4 <0.2 No Abnormal

Change EPA IGV

Total Ammonia (as N) mg/l 0.69 0.47 0.065 – 0.175 S.I. 9 of 2010

Total Aliphatics (C5-C35)

µg/l <10 <10 N/A N/A

Total Aromatics (C5-C35)

µg/l <10 <10 N/A N/A

Methyl-tert-butyl ether (MTBE)

µg/l <500 <500 30 EPA IGV

Benzene µg/l <500 <500 0.75 S.I. 9 of 2010

Toluene µg/l <500 <500 10 EPA IGV

Ethylbenzene µg/l <500 <500 10 EPA IGV

m/p-Xylene µg/l <500 <500 10 EPA IGV

o-Xylene µg/l <500 <500 10 EPA IGV

Total PAH 16 µg/l <0.195 0.207 0.1 EPA IGV

Phenol mg/l <0.01 <0.01 0.0005 EPA IGV

Dissolved Aluminium µg/l <20 <20 150 S.I. 9 of 2010

Dissolved Arsenic µg/l <2.5 <2.5 7.5 S.I. 9 of 2010

Dissolved Barium µg/l 12 23 100 EPA IGV

Dissolved Boron µg/l 66 64 750 S.I. 9 of 2010

Dissolved Cadmium µg/l <0.5 <0.5 3.75 S.I. 9 of 2010

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Parameter Units BH01 BH02 Environmental Guideline Value

Environmental Guideline Source

Dissolved Calcium mg/l 60.7 173.1 200 EPA IGV

Dissolved Chromium µg/l <1.5 <1.5 37.5 S.I. 9 of 2010

Dissolved Copper µg/l <7 <7 1500 S.I. 9 of 2010

Dissolved Iron µg/l <20 <20 200 EPA IGV

Dissolved Lead µg/l <5 <5 18.75 S.I. 9 of 2010

Dissolved Magnesium mg/l 12.9 15.1 50 EPA IGV

Dissolved Manganese µg/l 40 134 50 EPA IGV

Dissolved Mercury µg/l <1 <1 0.75 S.I. 9 of 2010

Dissolved Nickel µg/l 3 8 15 S.I. 9 of 2010

Dissolved Phosphorus µg/l <5 <5 35 S.I. 9 of 2010(3)

Dissolved Potassium mg/l 4.8 5.2 5 EPA IGV

Dissolved Selenium µg/l 14 <3 N/A N/A

Dissolved Silver µg/l <5 <5 N/A N/A

Dissolved Sodium mg/l 11.2 11.6 150 S.I. 9 of 2010

Dissolved Zinc µg/l <3 <3 100 EPA IGV

Total Cyanide mg/l <0.01 <0.01 0.0375 S.I. 9 of 2010

Notes: (1): Limit is for Nitrate as NO3 (2): Limit is for Nitrite as NO2 (3): Limit is for Molybdate Reactive Phosphorus (as P)

The groundwater at the site was found to be in good quality with the majority of groundwater quality parameter value below or within acceptable ranges of the relevant quality standards. There are some results which are higher than applicable standards. Faecal coliforms show values above the standards for both borehole locations. This may be due to the fact that there has been possible bloodstock grazing on these lands in the past. Other exceedences such as Ammonia and PAHs are only slightly exceeded and do not represent poor groundwater quality. Manganese values found at the site were higher than the relevant standard in one borehole, which can be a common occurrence. Elevated manganese levels do not pose a health risk however.

The WaterMaps online mapping system69 was consulted in order to determine the status of the groundwater body in the vicinity of the proposed development site. The proposed development site presides over the Griffeen Lower water body (IE_EA_09_242). This groundwater body is of Bad status with and overall objective to Restore by 2027.

11.4 Potential Impacts

11.4.1 Construction Phase

As discussed in Section 2.9 of this EIS, during the construction phase of the project, soil will be excavated from the site as part of the enabling earthworks and in order to facilitate the levelling of the site and the laying down of foundations for the new structures. These soil excavations will result in unavoidable soil removal from below the site in localised areas. This soil will be reused elsewhere on site as part of the landscaping plan.

69 www.wfdireland.ie

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Concrete (specifically, the cement component) is highly alkaline and any spillage which migrates though subsoils would be harmful to groundwater quality.

Runoff containing large amounts of silt could migrate vertically and impact on the groundwater quality underlying the site. Silt water can arise from exposed ground and soil stockpiles (prior to reinstatement).

Any dewatering carried out on site may result in the localised lowering of the water table in the immediate vicinity.

The earthworks aspects of the development will include the following;

- Topsoil clearance.

- The area of the proposed works will be filled in order to achieve the desired finished floor level for the proposed building of 65.45mOD.

- This will involve the excavation of an estimated 7,000m3 of topsoil. This material will be reused onsite as part of the site landscaping plan and/or removed from site for appropriate disposal, in agreement with SDCC. The building footprint and associated plant areas will be raised using imported granular material. Any imported soil required will be specified as outlined in Section 11.5.1 of this EIS.

In relation to the construction phase, the potential impact on land and soils is Long term – Moderate-Negative.

11.4.2 Operational Phase

The operational phase is unlikely to have any significant adverse impacts on land and soils due to the environmental design considerations that will be considered during the detailed design (see Section 11.5.2).

The construction hard standing and roofed areas over the presently un-surfaced ground across the site will result in an increase in the proportion of rainfall that forms surface water runoff. This will result in a reduction in the amount of rainfall recharge to groundwater below the site.

Any accidental emissions from storage or delivery of chemicals or fuels could cause contamination if the emissions enter the soil and groundwater environment.

In relation to the operational phase, the potential impact on the soils, geology and hydrogeology is Long term – Moderate-Negative.

11.5 Mitigation Measures

11.5.1 Construction Phase

General

In order to reduce the potential impacts it is necessary to devise mitigation measures to be adopted as part of the construction works on site in order to address the main areas of potential impact which are as follows:

- Control of soil excavation and fill placement works

- Fuel and chemical handling, transport and storage

- Sources of fill and aggregates for the project

Control of Soil Excavation and Fill Placement

As soil is excavated from the clearance of the site it will be necessary to designate areas within the site where stockpiles will be established in order to facilitate the efficient transfer of material around the site to be used in landscaping berms. In order to minimise the potential environmental impact of stockpiles it will be necessary to adopt the following mitigation measures:

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- Excavated topsoil will be stored for reuse in piles less no higher than a pre-determined height to prevent damage to the soil structure. Other excavated materials of lower engineering quality can be stored in higher piles;

- Different grades of soil will be segregated, where they arise;

- Spoil and temporary stockpiles will be positioned in locations which are distant from residences, watercourses and drainage systems;

- Minimise movements of materials within the stockpiles in order to reduce the degradation of the soil structure;

- The generation of silty surface water run-off from the stockpiles will be prevented through the use of covers, if feasible, cut-off ditches and through directing clean run off to local drainage for discharge;

- Long term stockpiles will be vegetated to prevent dust in dry weather conditions and reduce erosion of the stockpile to form silty runoff. Ensure adequate weed control;

- Wheel wash facilities will be provided on-site in order to prevent any egress of soil or dirt to local roads;

- Mist hoses will be provided if necessary in order to reduce dust emission from stockpiles.

- The transportation of clean aggregates to the site will be done in a manner which ensures minimal loss of material during transport and loads should be covered and lightly hosed in order to prevent dust nuisance.

Fuel and Chemical Handling, Transport and Storage

Due to the extreme vulnerability of the underlying local aquifer it will be necessary to adopt the following mitigation measures at the construction site in order to prevent any spillages to ground of fuels and to prevent any consequent groundwater quality impacts;

- A bunded refuelling area at the contractor’s compounds will be provided;

- Spill kit facilities will be provided at the fuelling area in order to provide for any accidental releases or spillages in and around the area;

- Any used spill kit materials will be disposed of using a hazardous waste contractor; and

- Where mobile fuel bowsers are used on the site the following measures will be noted:

- Any flexible pipe, tap or valve will be fitted with a lock where it leaves the container and locked shut when not in use;

- Flexible delivery pipes will be fitted with manually operated or a valve at the delivery end that closes automatically when not in use;

- The pump or valve will have a lock and will be locked shut when not in use;

- Each bowser will carry a spill kit and each bowser operator must have spill response training;

- Portable generators will be placed on suitable drip trays and any spillages will be cleaned up using spill kit materials.

In the case of drummed fuels or other chemicals which may be used during construction the following measures will be adopted:

- All containers that contain potential pollutants will be securely stored e.g. fuel oils and chemicals in a dedicated internally bunded chemical storage cabinet unit or inside a concrete bunded area;

- All containers will be clearly labelled so that appropriate remedial action can be taken in the event of a spillage;

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- Storing drums tightly against each other will be avoided. Drums will be stored in a manner which allows them to be easily check for leaks;

- All drums will be checked before moving to ensure that the bung is secure;

- Only drums which are UN approved and in good condition will be allowed on to the site or reused within the site;

- When moving drums from the bunded storage area to locations within the site plot a suitably sized spill pallet will be used for containing any spillages during transit; and

- Drums will be unloaded and loaded only by competent trained personnel using forklifts with drum grab attachments.

Should concrete be mixed onsite, it will be done so a t a designated area. The pouring of concrete will take place within a designated area to prevent concrete runoff into the soil/groundwater media. Wash down and washout of concrete transporting vehicles will take place within a designated area of the site.

Sources of Aggregates and Clean Fill for the Project

Subsoils excavated during the initial site development works will not be suitable for use in the construction of the internal roads, or capping under the buildings. Therefore, aggregates and clean fill material will be imported for these purposes and will consist of suitable material as specified in the TII’s “Specification for Roadworks”70 for roads and pavements and as specified in EN13242 SR21:2016.

This material will be sourced by the contractor. The project contract and procurement procedures will be developed to ensure that all aggregates are sourced from reputable sources. The most likely sources of this material is the nearest quarries to the proposed site. All potential suppliers will be vetted for the following criteria:

- Environmental management status; and

- Regulatory and legal compliance status of the company.

Only suppliers who are in compliance with the planning requirements should be considered for inclusion in the project.

Likewise, clean fill material will only be sourced from suppliers who comply with the above requirements. An environmental due diligence will be carried out of the proposed source area and that a waste permit is obtained from SDCC or the source legal authority in accordance with the Waste Management (Facility Permit and Registration) Regulations, 2007 (as amended). The hauliers who move the fill will have a waste collection permit in accordance with the Waste Management (Collection Permit) Regulation, 2007 (as amended).

11.5.2 Operational Phase

The proposed development will be designed and operated in accordance with the requirements of the EPA Guidance Note ‘Storage and Transfer of Materials for Scheduled Activities, 2004’, which defines criteria for the design and operation of infrastructure on industrial sites for the storage and movement of potentially polluting materials.

The site-wide mitigation measures and spill control programme that is proposed in accordance with EPA requirements for licensed activities will apply during the operational phase. This will include on-going bund integrity and drain testing programme, environmental monitoring and management procedures for potentially polluting materials.

70 National Roads Authority (NRA), 2000, ‘Specification for Roadworks’, Manual of contract Documents for Roadworks, Volume 1

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Spill kits will be located at strategic points around the site or adjacent to bulk and drummed chemical stores in order to ensure a quick response to any spillages which occur. Any used spill kits will be disposed of using a hazardous waste disposal contractor.

The dataset from the Gavin & Doherty Geosolutions Ltd site investigation already undertaken and pre-construction investigation planned for the proposed development will allow for the detailed design phase to identify any further potential mitigation measures required during the operational phase in order to minimise any potential land and soils impacts.

11.6 Residual Impacts

With the employment of the mitigation measures above, it is considered that there will be no negative impacts on land and soils.

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12 Water

12.1 Introduction

This chapter of the EIS assesses the impacts to the water environment from the proposed development. This section should be read in conjunction with the related sections dealing with land and soils (Chapter 11) and biodiversity (Chapter 10) which pay particular attention to the groundwater environment and aquatic ecology respectively. The following key aspects of the water environment are covered in detail within this section:

- Wastewaters from the proposed development

- Storm waters from the proposed development

- Water Supply for the proposed development

- Natural water bodies adjacent to the site of the proposed development

- Flood Risk

12.2 Methodology

This chapter of the EIS was prepared in accordance with the relevant EPA Guidelines. The following sources of information were used in the compilation of this assessment:

- Surface water sampling and analysis report prepared by Complete Laboratory Solutions (CLS) (Attachment 7)

- Office of Public Works’ (OPW) national flood hazard mapping (www.floodmaps.ie)

- OPW’s Catchment Flood Risk Assessment and Management (CFRAM) Study (http://www.cfram.ie/) – Eastern CFRAM Study

12.3 Existing Environment

12.3.1 Sanitary/Wastewater Services

The existing site is part of the wider serviced Grange Castle Business Park, which is catered for by its own pumping station. The wastewater sewage is connected to the off-site SDCC sewer. The SDCC mains sewage is connected to the Ringsend WWTP which currently has a capacity to treat a population equivalent of 1.64 million, with the intention to increase this capacity to 2.38 million PE71. The local network/infrastructure was designed by SDCC to allow for the development of such facilities similar to the one being proposed within the Business Park.

12.3.2 Surface Water Drainage

At the existing Takeda site, surface water drainage is directed into a dedicated surface water drainage network and into an underground attenuation tank located in the north-western corner of the site. Surface water is currently discharged at a controlled rate from the tank to a tributary of the Griffeen River. The outlet from the attenuation tank is monitored for the pH and Total Organic Carbon (TOC) and incorporates control valves for automatic shut-off in the event of limits being exceeded.

71 Irish Water intends to submit a planning application to An Bord Pleanála towards the end of 2016 for the upgrading of Ringsend WWTP. According to www.water.ie (Accessed 04/08/2016). No further update had been received as of January 2017.

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12.3.3 Water Supply

The existing water supply in the local area is provided by SDCC through their local mains supply. The area around the site is currently serviced by a combination of 200mm, 300mm and 450mm diameter water mains.

12.3.4 Natural Surface Water Bodies

Figure 1.2 illustrates the main surface water bodies in the vicinity of the proposed development as described below.

The main surface water body in the vicinity of the site is the Griffeen River. The headwaters of the Griffeen rise in the hills south of Rathcoole (Saggart Hill) and in the high ground around Athgoe and generally flow in a northward direction. The main river channel commences at the confluence of the tributaries at Greenoge west of Baldonnel Aerodrome and flows northwards for approximately 4km, to the outskirts of the urban area of Griffeen Valley Park. From this point the river runs for approximately 2km through parkland and by some detached residential properties in the Lucan Village area to the confluence with the River Liffey.

The Griffeen River catchment comprises of 3,900 hectares and forms a sub-catchment of the River Liffey into which it flows in the vicinity of Lucan Village. The land-use within the catchment south of Lucan village is largely agricultural with pockets of developed areas at Rathcoole, Newcastle and Baldonnel. It floods in Lucan upstream of its confluence with the River Liffey.

A section of the Griffeen River which previously ran through the proposed site was realigned during the construction of the Business Park and runs along the eastern boundary of the proposed development site on the far side of the road. Significant work has been carried out on the bed and banks of the river, and the surrounding area has been re-landscaped. Furthermore ponds and other attenuation measures have been put in place as part of the development of the Business Park.

The Kilmahuddrick Stream is a tributary of the Griffeen River that runs parallel to, and south of, the Grand Canal. It is culverted under the Grand Canal and enters into the Griffeen River. The Grand Canal is located approximately 1km north of the site and runs from west to east. There is no hydraulic connectivity between the two water courses. Furthermore, no drainage from the Grange Castle Business Park enters the Grand Canal.

Griffeen River Monitoring Results

Surface water sampling and analysis was carried out by Complete Laboratory Solutions (CLS) on 7th November 2016. Sampling was carried out at 2 locations in the Griffeen River. One location was upstream of the Takeda site and the other sampling location was located downstream of the Takeda site. The results of this analysis are provided in Tables 12.1 (upstream) and 12.2 (downstream). The full report is provided in Attachment 7.

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Table 12.1: Griffeen River Sampling Results Upstream of TIL Site

Parameter Units Result Environmental Guideline Value

Environmental Guideline Source

Fats, Oils and Greases mg/l <5 N/A N/A

Biological Oxygen Demand (BOD)

mg/l <1 1.5 (Good Status) S.I. 272 of 2009

Suspended Solids mg/l 11 50 S.I. 294 of 1989

Chemical Oxygen Demand (COD)

mg/l <10 40 S.I. 294 of 1989

Turbidity N.T.U. 1.0 1.0 S.I. 278 of 2007

pH pH

units 8.1 6.0 – 9.0 S.I. 272 of 2009

Conductivity @ 20°C µS/cm 568 2,500 S.I. 278 of 2007

Alkalinity, total mg/l

CaCO3 265 N/A N/A

Total Phosphorus as P mg/l 0.05 0.3572

(Good Status) S.I. 272 of 2009

Nitrate as NO3 mg/l 21.9 50 S.I. 278 of 2007

Nitrite as NO2 mg/l <0.017 0.5 S.I. 278 of 2007

Phosphate as PO4 mg/l <0.03 0.3573

(Good Status) S.I. 272 of 2009

Temperature °C 8.4 50 S.I. 278 of 2007

Dissolved Oxygen (%) %Sat 101 >80 and <120 S.I. 272 of 2009

Total Hardness (Kone) mg/l

CaCO3 316 N/A N/A

Sulphate mg/l 43.1 250 S.I. 278 of 2007

PRO74 GRO Water 5 day TAT

µg/l <10 N/A N/A

Total Organic Carbon (TOC)

mg/l 2.48 No Abnormal Change S.I. 278 of 2007

Detergent, anionic mg/l <0.21 N/A N/A

Extractable Hydrocarbons EPH Water 5 day TAT

µg/l <10 N/A N/A

Ammonium mg/l 0.025 0.3 S.I. 278 of 2007

72 Value for Molybdate Reactive Phosphorus (mgP/l)

73 Value for Molybdate Reactive Phosphorus (mgP/l)

74 Petrol Range Organics

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Table 12.2: Griffeen River Sampling Results Downstream of TIL Site

Parameter Units Result Environmental Guideline Value

Environmental Guideline Source

Fats, Oils and Greases mg/l <5 N/A N/A

Biological Oxygen Demand (BOD)

mg/l <1 1.5 (Good Status) S.I. 272 of 2009

Suspended Solids mg/l 12 50 S.I. 294 of 1989

Chemical Oxygen Demand (COD)

mg/l <10 40 S.I. 294 of 1989

Turbidity N.T.U. 0.9 1.0 S.I. 278 of 2007

pH pH

units 8.0 6.0 – 9.0 S.I. 272 of 2009

Conductivity @ 20°C µS/cm 560 2,500 S.I. 278 of 2007

Alkalinity, total mg/l

CaCO3 264 N/A N/A

Total Phosphorus as P mg/l 0.05 0.3575

(Good Status) S.I. 272 of 2009

Nitrate as NO3 mg/l 20.6 50 S.I. 278 of 2007

Nitrite as NO2 mg/l <0.017 0.5 S.I. 278 of 2007

Phosphate as PO4 mg/l <0.03 0.3576

(Good Status) S.I. 272 of 2009

Temperature °C 7.9 50 S.I. 278 of 2007

Dissolved Oxygen (%) %Sat 100 >80 and <120 S.I. 272 of 2009

Total Hardness (Kone) mg/l

CaCO3 307 N/A N/A

Sulphate mg/l 42.4 250 S.I. 278 of 2007

PRO GRO Water 5 day TAT

µg/l <10 N/A N/A

Total Organic Carbon (TOC)

mg/l 2.75 No Abnormal Change S.I. 278 of 2007

Detergent, anionic mg/l <0.21 N/A N/A

Extractable Hydrocarbons EPH Water 5 day TAT

µg/l <10 N/A N/A

Ammonium mg/l <0.01 0.3 S.I. 278 of 2007

Tables 12.1 and 12.2 show very little difference in the upstream and downstream results, thus demonstrating that the results are appropriate in terms of setting of a baseline. Some of the parameters analysed for were below laboratory limits of detection, e.g. Oils, Fats and Grease, BOD, Suspended Solids, and COD. pH and BOD levels were within the standards outlined in the European Communities Environmental Objectives (Surface Water) Regulations 2009, as amended.

Where standards were not outlined in the aforementioned regulations, standards were used from the European Communities (Quality of Surface Water Intended for the Abstraction of Drinking Water) Regulations, 1989; the European Communities (Drinking Water) (No. 2) Regulations 2007;

75 Value for Molybdate Reactive Phosphorus (mgP/l)

76 Value for Molybdate Reactive Phosphorus (mgP/l)

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and the EPA’s Parameters of Water Quality – Interpretation and Standards, 2001. The concentration of each parameter measured is below its relevant standard’s limit.

Griffeen River Flow Characteristics

A Catchment Management Study was prepared in 1999/2000. This involved the hydraulic assessment of the entire river and preliminary flood alleviation and planning recommendations. The catchment is predominately rural in the upper reaches and becomes more urban further downstream. Significant development is planned for this catchment. Recent flood events for the Griffeen River include 1986, 1993 & 2000. The national flood hazard mapping website77 hosted by the OPW maintains all historic records for flooding in Ireland.

Flow data for the Griffeen River derived by the EPA was reviewed as part of the EIS baseline investigation. The data was obtained from a location downstream of the proposed site at Lucan (station number 09002). Data from the EPA HydroNet online database for the year up to June 2016 indicates an average daily mean flow of 0.64m3/s.

According to the OPW national flood hazard mapping (www.floodmaps.ie), there have not been any historical flood events that have affected the proposed development site.

According to the OPW’s Catchment Flood Risk Assessment and Management (CFRAM) Study, it is predicted that a 1 in 100 or a 1% AEP (Annual Exceedance Probability) year storm event will not affect the proposed site. A 1 in 1000 or 0.1% AEP year storm event has the potential to affect the new development site. Measures have been put in place to try mitigate this risk, such as a raising the building floor level and providing a berm along the eastern boundary of the site. Figures 12.1 and 12.2 illustrate the levels of these future predictive flood events.

SDCC consultant CSEA (Clifton Scannell Emerson and Associates) have advised that the potential flood level of the Griffeen River during a 1 in 100 year storm event is 64.85m OD. Ground levels on the site are currently below this level. The proposed finish floor level of the building is 65.45m OD which is above the potential flood level outlined in the Microsoft planning application and above the 0.1% AEP flood level.

77 www.floodmaps.ie

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Figure 12.1: Predicted Flood Depth Map for a 1% AEP

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Figure 12.2: Predicted Flood Depths for a 0.1% AEP

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12.4 Potential Impacts

The potential impacts to the water environment from the proposed development are considered in this section. Reference should also be made to the land and soils section (Chapter 11) where considerations concerning any potential impacts to groundwater and the water table are outlined.

12.4.1 Construction Phase

During the construction phase of this proposed development there may be potential impacts to the water environment which, however short lived, must be assessed in light of the overall potential impacts of the development.

Water supply requirements during the construction phase will be planned for in order to prevent any potential impacts on the local water supplies, including potential loss of pressure, for the overall area and the regional water storage reservoirs.

During the construction phase there will also be a number of construction personnel based on site requiring canteen and toilet facilities and there may be potential impacts to the water environment if sewage is not disposed of in a planned and regulated manner.

There will be a number of materials brought on to the site as part of concrete mixes and other activities during construction which could potentially have an environmental impact if released to surface waters. Fuels, oils and other chemicals may be used during construction for various purposes and these hazardous materials may have an impact on the environmental if there is an uncontrolled release to the environment.

There may be a potential impact due to any potential localised flooding impacts or sediment discharges from earthworks to storm waters. Natural surface waters within the vicinity of the development will be potentially sensitive environmental receptors to any storm water run-off or other emissions from construction activities. In particular, any earthworks activities where the soil cover may be temporarily removed resulting in the exposure of soil to storm waters could potentially give rise to silty run off which may affect the quality and aquatic ecology of receiving surface waters

12.4.2 Operational Phase

In the absence of adequate management and mitigation measures the operational phase of the development could have an adverse impact on the water environment in the event of:

- Excessive demand on the Ringsend WWTP and/or the sewer delivery system to Ringsend

- An uncontained spillage or discharge of domestic/foul or utilities waste water

- An uncontained spillage of polluting materials stored and used on site. The facility will use and store small quantities of potentially polluting materials on site during operation including laboratory chemicals, cleaning chemicals, diesel for the emergency generator and firewater pump, chemicals for the operation/maintenance of utilities equipment, chemicals used in the process, etc.

- The discharge of excessive storm water / surface water runoff from paved and roofed areas of the site resulting in flooding of local watercourses

- Risks to the quality of the surface water leaving the site relate to the potential for polluting materials (i.e. chemical or fuel) to enter the surface water drainage system and be conveyed to the receiving waters of the Griffeen River further downstream. Fuel/oil leaks from vehicles in the car park or other areas on site

- Excessive demand on the local authority water main in loss of pressure, reduced supply etc. in the local area.

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12.5 Mitigation Measures

12.5.1 Construction Phase

General

In order to effectively manage all of the environmental aspects and impacts of the project works during the construction phase a Construction Environmental Management Plan (CEMP) will be prepared in advance of construction activities.

The purpose of the CEMP is to set out the responsibilities and environmental standards for the duration of the construction phase of the project. This plan will outline the following;

- Project management and reporting structure

- Environmental communications programme

- Schedule of environmental objectives and targets

- Environmental awareness and training programmes

- Environmental best practice for pollution control

- Waste management procedures

- Environmental emergency response procedure

- Inspection, auditing and corrective action process

The CEMP will document the Contractor’s objectives, policy and commitment to environmental management. It will also establish a project specific system of hierarchical procedures, work practices and controls to ensure that the interfaces with the project, individual roles and responsibilities and environmental protection requirements are clearly defined. The CEMP will be distributed to all personnel and will be available to them in their place of work to direct, guide and assist in their activities.

All personnel working on the construction phase of the project will be made responsible for the environmental control of their own work and will perform their duties in accordance with the requirements of the CEMP and in compliance with the procedures referenced therein. No deviations should be permitted without the written authority of the Contractor’s Construction Manager.

The Contractor’s site Environmental Officer will have overall authority for ensuring that the contents of the CEMP are satisfactorily implemented during the construction phase of the project which is expected to last for approximately 12-13 months. The CEMP will be subject to on-going review and any necessary updates and revisions made as required.

Foul Sewage

During the construction phase, sewage will arise from construction workers and other personnel based at the site. It is expected that there will be a main contractor’s compound within the confines of the site. It is expected that portable toilet facilities will be provided at the facility or alternatively, toilet facilities with an underground holding tank will be provided. This underground holding tank or these portable facilities will then be periodically emptied by an authorised drain cleaning or sewage disposal contractor. It must be ensured that an authorised contractor who has the necessary waste collection permit and waste disposal authorisations from SDCC is selected.

Alternatively, the contractor may seek temporary connection to the Grange Castle Business Park sanitary sewer which traverses the site.

Storm Water

During the construction phase the soil cover is likely to be removed to varying degrees at various stages and this will provide for less water absorptive capacity on the site, particularly at the site of the main buildings and car park.

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In order to mitigate against water that has ponded on the site being released to the Griffeen River, the following measures will be taken:

- Where necessary, and as deemed required in the detailed design phase of the project, temporary attenuation ponds will be excavated as part of such construction works in order to contain any silt waters and allow for some settlement and treatment of any silty waters prior to release to local surface waters.

- Construction works will be planned in a manner which prevents extensive tracts of exposed soil from being exposed at any one time and which ensures a more progressive clearance of Greenfield lands. In particular it will be ensured that a filter strip is left in order to protect any nearby surface waters.

- All drainage systems will have inspection chambers and be set up in such a manner as to facilitate isolation from the discharge point, and have an alternative containment system, as may be required in the event that the discharge becomes contaminated or the receiving water becomes unsuitable to receive the discharge effluent.

- When undertaking excavations, measures will be taken in order to prevent water from entering the excavation pits. If necessary a vacuum tanker will be made available on a standby basis for pumping away any waters which may enter the excavation.

- In order to prevent any potential contamination of surface waters leaving the site due to construction run-off the following measures will be taken in relation to fuel and chemical storage:

- Any diesel oil tank or other chemical bulk storage on site will be located away from drains and watercourses and held in double skinned tanks or in an integrity tested bunded area with the a capacity of 110% of the largest container or 25% of the total tank storage capacity. There will also preferably be a drip tray, which drains to the bund around any delivery points or filling hoses.

- All generators used on site will be placed on suitably sized drip traps which can retain any potential leaks. Any leaks on the drip tray will be drummed for reuse if clean or held in UN approved labelled tight-head drum for off-site disposal using an authorised hazardous waste disposal contractor through agreement with SDCC.

- Any chemical containers or materials other than water will be stored in a dedicated area within a leak-proof storage or “Chemstore” type unit and handled carefully when used in order to avoid any contamination arising from spillages.

Water Supply

Water supply during the construction phase is not expected to be a significant issue in light of the overall proposed development as there are unlikely to be any activities carried out on site which involve a high water demand.

Natural Surface Waters

The proposed site is located adjacent to the Griffeen River, therefore all construction activities will be carried out in a manner which ensures that no discharges of potentially polluting materials to natural surface waters occur.

The mitigation measures recommended under the preceding sections covering foul sewage, storm waters and water supply will contribute significantly to ensuring the protection of natural surface water bodies during construction. As part of the overall CEMP weekly visual checks of all surface water adjacent to on-going construction works will be carried out as part of the site Environmental, Health and Safety (EHS) auditing and inspection process.

The initial pre-construction works water quality sampling of the river has been undertaken by CLS as per Section 12.3.4 of this EIS at representative locations in the water body upstream and downstream of the proposed site.

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As part of the overall CEMP further surveys will be carried out at least on a biannual basis during the construction phase in order to monitor water quality and ensure that construction works are not having any impact on the surface waters. Samples will be analysed by an accredited laboratory for the following parameters as a minimum;

- Electrical conductivity

- Temperature

- Turbidity

- pH

- BOD

- Total Suspended Solids

- Turbidity

Any results which show unusual trends will be investigated and satisfactorily closed out under the CEMP corrective action process.

The CEMP environmental communications process will allow for regular consultations with the Inland Fisheries Ireland (IFI) and other regulatory authorities over the course of the construction if required.

Water arising from any dewatering operations on site will be analysed and treated appropriately. Suspended solids are the most common water pollutant on a construction site, if required. A suitably sized settlement pond will be maintained on site to remove suspended solids prior to discharge.

The following typical control measures will be implemented where necessary:

- Grit traps will be installed as part of all drainage facilities to enhance removal of any sediment contained in site run-off.

- The clearing and repair of existing and new drainage will be carried out in a controlled manner so as to prevent pollution.

- The Environmental Officer will inspect all equipment, pumps, drainage pipes, and concrete washout facility as part of the weekly site environmental inspection.

As part of the site emergency response procedure and surface water protection procedure spill response kits will be available at the contractor compounds across the construction site. Spill response training will be provided to key personnel at each contractor compound and all incidents reported in accordance with the CEMP incident investigation and corrective actions procedures.

There will be on-going environmental supervision of construction works in order to ensure compliance with method statements and in order to deal effectively with any water related issues which may arise on site.

Any concrete delivery trucks coming to the site to deliver concrete will only wash out their trucks and chutes at a dedicated concrete washout facility at their home depot. If wash out of concrete trucks is required, a single designated bunded and contained area will be provided.

12.5.2 Operational Phase

The site has an IEL which contains site-wide mitigation measures which will be implemented in full at the proposed development.

Foul Sewage

The following mitigation measures will be adopted in order to ensure that the provision of wastewater does not adversely affect the water environment;

- Process wastewater will go to a proposed balancing tank (for pH balancing) before being further neutralised in the on-site tank farm. From here it will be taken off-site in a tanker,

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following testing to confirm the water quality is within acceptable limits, and disposed of at an appropriately licensed facility.

- All foul sewers will be pressure tested and surveyed prior to connection to the existing mains foul sewer.

Storm Water and Natural Surface Waters

The increases in volumes of storm waters due to rainfall runoff have been identified as a potential impact and therefore the project storm water drainage design proposals need to mitigate sufficiently for these impacts in order to reduce any potential severity. In particular, the detailed design of the project will incorporate the following:

- All surface water run-off from paved areas will firstly pass through a Class 1 bypass oil interceptor. Interceptors will be positioned downstream of the car park surface water drains and full retention at the generator. A maintenance contract will be put in place to ensure on going optimum performance and records will be retained for oily waste removed.

- The external surface water drainage system will be designed in accordance with Sustainable Urban Drainage Systems (SUDS), the Greater Dublin Strategic Drainage Study, and EN standards. See Section 2.7.

- Storm water drainage on site will be maintained as required by a suitably qualified contractor and in particular storm water drain flushing may be carried out.

- A storm water retention tank currently exists on the existing Takeda site. The new storm water network will fall to this existing underground retention tank. The existing tank has sufficient capacity to cater for the additional surface water of the proposed development. The attenuation system will comprise of an underground water retention tank with a volume of 2,472m3. A hydro brake on the outfall will ensure that discharge flows are controlled. The hydrobrake will limit the storm water outflow form the site to 4l/s/ha for the 2 year return period and 8.4l/s/ha for the 30 year return period.

Water Supply

The requirements for water usage on site will be associated with potable water for drinking and domestic purposes; sprinkler water and building services requirements. Local authority mains water will be utilised for all water requirements at the facility and the aforementioned demand has been confirmed as available by SDCC.

Sprinkler water will be stored on the existing site in an existing tank approximately 500m3 in volume as per insurance requirements.

12.6 Residual Impacts

Taking into account the mitigation measures outlined in Section 12.5 there are no predicted residual impacts due to the construction and operational phases of the proposed development.

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13 Waste Management

13.1 Introduction

This chapter describes the anticipated types of wastes that will be generated at the proposed development during both the construction and operational phases and also outlines the site specific waste management policies, practices and programmes to be employed at the proposed development.

13.2 Methodology

The assessment of the impacts of the proposed development arising from the generation of waste materials was carried out taking account of the methodology specified in the EPA guidance notes relating to the preparation of EISs (see Section 1.7.1).

A review of the construction and operational waste types generated by the proposed development was undertaken. A document review was completed to assist in identifying current and future requirements for waste management and included:

- National Policies and Strategies such as:

- A Resource Opportunity - Waste Management Policy in Ireland, the then Department of the Environment, Community and Local Government (DoECLG), 2012

- National Strategy on Biodegradable Waste, DoEHLG, 2006.

- National Hazardous Waste Management Plan 2014-2020, EPA, 2014

- Towards a Resource Efficient Ireland – A National Strategy to 2020, EPA 2014

- Directives and Statutory Instruments such as:

- Waste Management Act 1996 (as amended) and regulations

- Local Government Act 1994 (as amended) and regulations

- Directive 2002/96/EC of the European Parliament and of the Council of 27 January 2003 on waste electrical and electronic equipment (WEEE)

- Protection of the Environment Act 2003 (as amended) (SI No. 27 of 2003)

- Litter Pollution Act 1997 (No. 13 of 1997) (as amended)

- EPA National Waste Database Reports

- Codes of Practice and Guidelines such as:

- Best Practice Guidelines on the Preparation of Waste Management Plans for Construction and Demolition Projects, the then DoECLG, 2006

- Local Authority Plans such as:

- Eastern and Midlands Region Waste Management Plan 2015-2021

- SDCC Development Plan 2016 - 2022

13.3 Existing Environment

The proposed development is located in the Eastern and Midlands Waste Region (EMWR). The EMWR was established following on from the publication of Government Policy document “A Resource Opportunity- Waste Management Policy in Ireland” issued in July 2012 which reduced the Waste Management Regions from 10 to 3.

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The EMWR is made up of 12 Local Authorities (Dublin City, Fingal, Dun Laoghaire, South Dublin, Longford, Westmeath, Kildare, Offaly, Louth, Laois, Meath and Wicklow). The Waste Management Plan78 was published in May 2015.

Takeda’s waste management policy, for both the construction and operational phases will be in full accordance of the requirements of the EMWR Waste Management Plan.

13.4 Potential Impacts

13.4.1 Construction Phase

The construction phase will involve initial site development to include cut and fill works. This will be followed by the construction of the plant itself. It is anticipated that the construction phase of the proposed development will extend over a period of approximately 12-13 months.

13.4.2 Construction Wastes Generated

The development will involve the excavation of approximately 9,600m3 of soils (topsoil and subsoil), which will be reused on-site as part of the landscaping plan. Therefore it is anticipated that no soils will be removed from the proposed development site for disposal.

It is expected that the construction phase will typically result in the generation of a range of other waste materials including rubble, steel, timber, plastics, cardboard packaging, office waste, canteen waste, and small quantities of hazardous waste (e.g. mastic, adhesives and paint containers).

In the event that the above waste types are not handled correctly or disposed of in an incorrect manner, there is the potential for an impact at the site and in the vicinity of the site in relation to waste management. Table 13.1 lists the activities which will be undertaken as part of the construction phase, the potential impacts of these activities in the absence of mitigation measures and the magnitude, significance and duration in accordance with the relevant guidelines.

Table 13.1: Potential Impacts during the Construction Phase

Activity Potential Impacts Quality Significance Duration

Waste Management

Targets outlined in the Waste Management Plan for Eastern and Midlands Region will not

be achieved.

Negative Slight Short-term

The use of unlicensed or non-permitted waste contractors could give rise to inappropriate

management of waste and result in environmental impacts/pollution.

If waste is not managed and stored correctly, this may lead to litter or pollution issues on the

site or adjacent sites.

Typically recyclable/reusable waste material would include:

- Timber;

- Cut cable and cable tray;

- Steel offcuts;

- Cut aluminium sections;

- Glass; and

- Piping offcuts.

78 SDCC (2015), Eastern-Midlands Draft Regional Waste Management Plan

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Material for disposal to licensed landfill is likely to include:

- Waste cladding;

- Waste insulation (e.g. rockwool, fibreglass, etc.);

- Gypboard offcuts;

- Cut ceiling tiles; and

- Miscellaneous construction and domestic wastes.

13.4.3 Operational Phase

The operation of the facility will result in the generation of a number of wastes, both hazardous and non-hazardous. The main wastes resulting from the operation of the proposed development as well as their disposal route can be described as follows:

Non-Hazardous Waste

- Cardboard

- Plastic (polypropylene)

In total, it is anticipated that there will be approximately 5 tonnes of non-hazardous waste generated at the proposed development per annum. This will be removed along with non-hazardous waste generated at the existing facility by licensed waste contractors to approved waste recycling facilities in accordance with the relevant national and EU waste legislation.

Hazardous Waste

- Waste chemicals

- Fluorescent tubes

- Waste batteries

- Waste oils

- Waste chemical/oil drums

Table 13.2 includes the different types of hazardous waste generated during the process itself, as well as an approximate volume to be generated per batch and its disposal method. It is noted that there will be 6-10 batches produced per annum.

Table 13.2: Hazardous Waste to be generated during Process

Description Disposal Volume/batch

High Solvent content Fuel blending or incineration <0.25 tonnes

High Solvent- Acidic Incineration 0.25-0.5 tonnes

High Solvent- Basic Incineration 0.25-0.5 tonnes

High Solvent content containing active Incineration 0.25-0.5 tonnes

Chlorinated solvent waste Packed off into drums or IBC <0.25 tonnes

Process Effluent and area washings Treated at onsite WWTP and tankered offsite 10 tonnes

In the event that the above waste types are not handled correctly or disposed of in an incorrect manner, there is the potential for an impact at the site and in the vicinity of the site in relation to waste management. Table 13.3 lists the potential impacts of these activities and the magnitude, significance and duration in accordance with the relevant guidelines. It is noted these impacts are the same as the construction phase.

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Table 13.3: Potential Impacts during the Operational Phase

Activity Potential Impacts Quality Significance Duration

Waste Management

Targets outlined in the Waste Management Plan for Eastern and Midlands Region will not

be achieved.

Negative Slight Short-term

The use of unlicensed or non-permitted waste contractors could give rise to inappropriate

management of waste and result in environmental impacts/pollution.

If waste is not managed and stored correctly, this may lead to litter or pollution issues on the

site or adjacent sites.

13.5 Mitigation Measures

13.5.1 Construction Phase

General

Waste will be managed as part of the overall Construction Environmental Management Plan (CEMP), which will be put in place by the management contractor for the entirety of the construction activities. The plan will include specific detail on waste segregation and disposal, as described below.

A Construction Waste Management Plan (CWMP) has been developed and will be implemented site-wide for the duration of the work. The full CWMP is included in Attachment 8 of this EIS.

Excavated Material

Any excavated material generated during site clearance works will be reused onsite as part of the site landscaping plan. It is possible that a minimal quantity of excavated material will be removed from site for appropriate disposal by licensed waste contractors, in agreement with SDCC.

Other Construction Waste

Where possible any generated construction waste will be re-used or recycled while the remaining wastes shall be disposed of by licensed waste contractors to an approved landfill site in accordance with the relevant national and EU waste legislation.

Construction Waste Segregation

A system for waste segregation will be implemented on site with separate skips for different types of waste e.g.:

- Timber;

- Metal;

- Plastic;

- Rubble;

- Paper/cardboard;

- Paint/chemical containers; and

- Oils and greases.

Subcontractors will be advised of this requirement at tender stage and it will be re-iterated at pre-appointment meetings. Subcontractors will be obliged to comply with the site CWMP.

Waste segregation will be “policed” primarily by the site agent and safety officers but generally by all members of the Construction Management Team (CMT).

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The earthworks contractor will be required to produce the waste licence of their proposed landfill and their own waste collection permits prior to appointment. Disposal will be monitored for the duration.

Contractors will be required to supply separate labelled skips for their own plastic and cardboard packaging waste, as well as other waste materials particular to their trade (e.g. electrical cable cuttings).

If any potentially contaminated soil is encountered during the construction works, it will be segregated from all other soils, tested to confirm the classification of the soil for disposal purposes and will be collected and disposed of by a permitted waste contractor to a suitably licenced landfill.

All waste leaving the site will be taken by suitably permitted contractors and transported to suitably licensed or permitted facilities in full compliance with the relevant Sections of the Waste Management Acts of 1996 (as amended).

Quantities of waste leaving the site will be recorded and copies of relevant documentation maintained onsite.

13.5.2 Operational Phase

Takeda have previously been granted by the EPA an IEL, Reg No. P0693-01. Condition 7 Waste Management of the granted IEL License outlines all of the site requirements.

A Waste Management Programme will be implemented during the operation of the proposed development to ensure the proper management of waste on site in accordance with the site IEL. The programme forms part of an Environmental Management System (EMS) at the facility. All waste generated on site, both hazardous and non-hazardous, is handled, stored, transported off-site and treated/disposed of in accordance with statutory requirements and in a manner that minimises any risk to persons and/or the environment. Copies of licenses for all approved disposal locations used by the waste contractor will be on file. Similar waste management procedures to the existing will be followed.

Mitigation measures associated with material assets assessed in other chapters are described in the respective chapters, e.g. Land and Soils, Human Environment, Landscape and Visual, and Archaeology, Architecture and Cultural Heritage.

13.6 Residual Impacts

The mitigation measures detailed in Section 13.5 will ensure the waste arising from the development is dealt with in compliance with the provisions of the Waste Management Act 1996 (as amended), and associated Regulations, the Litter Act of 1997 and the Waste Management Plan for Eastern and Midlands Region as well as Takeda’s IEL requirements and achieve optimum levels of waste reduction, re-use and recycling. The predicted impact will be imperceptible and long term.

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14 Material Assets

14.1 Introduction

Material assets comprise the physical resources in the environment, which may be of human or of natural origin. The objective of the assessment is to ensure that these assets are used in a sustainable manner with respect to the proposed development.

The material assets, which have been identified as being within and adjacent to the proposed site and which may be directly affected by the proposed development, are addressed below in terms of the requirements by the development, the provision of these requirements, impacts and mitigation measures. Other material assets have been considered in various chapters of this EIS, e.g. Land and Soils, Population and Human Health, Landscape and Visual, and Archaeology, Architecture and Cultural Heritage.

14.2 Methodology

The assessment was carried out according to the methodologies specified in EPA guidance documents (see Section 1.7.1). A desk study was carried out on the existing material assets associated with the site of the proposed development.

Material assets are defined in EPA guidance documents as:

‘Resources that are valued and intrinsic to specific places are called ‘Material Assets’. They may be either human or natural origin’.

Material assets which are considered in this chapter are:

- Public Utilities and Natural Resources

14.3 Public Utilities and Natural Resources

14.3.1 Introduction

Material assets of natural origin which have been considered elsewhere in the EIS include:

- Land and Soils (Refer to chapter 11)

- Water (Refer to chapter 12)

- Landscape and Visual (Refer to chapter 5)

Material assets of human origin which have been considered elsewhere in the EIS include:

- Traffic and Transportation ( Refer to chapter 6)

- Waste Management (Refer to chapter 13)

- Archaeology and Cultural Heritage (Refer to chapter 7)

Material assets which are considered in this chapter are public utilities such as:

- Electrical Supply

- Gas Supply

- Telecommunications

- Water

See Sections 2.6 and 2.7 for specific details.

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14.4 Potential Impacts

14.4.1 Public Utilities

Overall, the impact on public utilities is considered to be neutral.

There will be minimal use of natural resources during the construction phase. Resources consumed will include the use of aggregates and clean fill and the use of fuels for construction related machinery. There will be a minimal use of water resources during the construction phase.

14.4.2 Use of Natural Resources

During the operational phase there will be resource requirements for the proposed facility, in particular electricity and potable water. There is no requirement for natural gas in the proposed site.

There is a potential impact on natural resources i.e. water, soils, air and the built environment if mitigation measures associated with the proposed development are not implemented.

Earthworks will involve stripping the topsoil and laying down a granular platform prior to the buildings foundations being poured. Any extra soil after excavation will be used to construct an earthen bank on the boundary of the site for landscaping. Additional till will be required to raise the level of the site to accommodate the raised finished floor level of 65.45m.

In relation to the operational phase the potential impact of the proposed development on Material Assets is considered to be Long term – Slight-Negative.

14.5 Mitigation Measures

There are sufficient supplies of electricity and natural gas currently available to the proposed development, although a gas supply will not be required. The same applies to telecommunications services. The water and sewage services in the area of the proposed development will also be adequate to serve the requirements of the facility.

There will be an interface established with ESB, Gas Networks Ireland (GNI), SDCC, Irish Water, Eir and other relevant service providers within the locality during the construction planning phase of the project. This interface will be managed in order to ensure a smooth construction schedule without disruption to the local and business community.

The following requirements are likely to arise from the interface;

- Attention will need to be paid to the safety and other requirements outlined in the GNI and ESB Safety Document: Guidelines for Builders.

- The exact locations of known local underground services will be confirmed and the detail of overhead line relocations will be agreed.

Energy efficiency measures will be incorporated into the detailed design of the facility. This is a positive environmental aspect of the project.

In accordance with the requirements of Section 11.7.6 of the South Dublin County Development Plan 2016 – 2022, the potential for waste heat recovery and distribution was considered. It has concluded that the proposed facility will not generate sufficient waste heat to warrant provision of heat recovery measures. Condensate will be recovered to generate hot water used for HVAC (Heating, Ventilation and Air Conditioning) heating.

Mitigation measures associated with material assets assessed in other chapters are described in the respective chapters, e.g. Land and Soils, Human Environment, Landscape and Visual, and Archaeology, Architecture and Cultural Heritage.

14.6 Residual Impacts

The proposed development will not have any significant impact on material assets.

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15 Interactions and Cumulative Impacts

15.1 Introduction

An important aspect of assessing the environmental impacts associated with any large industrial development is to consider how impacts identified under each of the subject headings might interact to cause a cumulative effect. Similarly, consideration must also be given to the cumulative effects arising from the interaction of the project with impacts arising from current and known future developments in the area.

This chapter considers the impacts of the development which occur as a result of cumulative or indirect impacts or through the interaction of impacts.

The examination of these impacts is important as an impact which directly affects one environmental medium may also have an indirect impact on other media (sometimes referred to as cross media impacts). This indirect effect can sometimes be more significant that the direct effect.

- Impact inter-relationships or interactions are the reactions between impacts within a project and the inter-relationship between impacts identified under one environmental topic with impacts identified under another environmental topic.

- Cumulative impacts are impacts which occur as a result of incremental changes caused by other past, present or reasonably foreseeable actions together with this project.

15.2 Methodology

This assessment has been carried out in accordance with the methodologies specified in Environmental Protection Agency (EPA) guidance documents outlined in Section 1.7.1.

15.3 Potential Impacts

15.3.1 Interaction of Impacts

The interaction of impacts between the various environmental media examined during the EIA has been assessed (Table 15.1). It is concluded that there will be no significant interactive impacts identified for any of the environmental media. This conclusion is based on the nature of the proposed facility and the successful implementation of all mitigation measures detailed under each environmental medium. It is considered that all potential impacts from an interaction with another environmental media have been addressed sufficiently under the respective headings of the EIS.

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Table 15.1: Matrix of Environmental Disciplines & Interactions

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Population and Human Health ü ü ü ü ü ü ü

Landscape and Visual ü ü ü ü

Traffic and Transportation

ü ü ü ü

Archaeology and Cultural Heritage

ü ü

Noise and Vibration ü ü ü

Air Quality and Climate ü ü ü ü

Biodiversity ü ü ü ü ü ü

Land and Soils ü ü ü

Water ü ü ü ü ü

Waste Management ü ü

Material Assets ü ü

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15.3.2 Cumulative Impacts

The potential cumulative impacts between the various environmental media examined during the EIA and the different stages of both the construction and the operational phases were examined.

The proposed development at Grange Castle Business Park from a socio economic point of view will lead to a significant number of temporary jobs during construction. There will also be significant employment at the facility when it is operational. This will have a positive cumulative impact with the employment currently provided by other businesses in the Park.

The operation of the proposed facility, including the use of utilities, and the generation of waste and wastewater, will result in cumulative impacts with the existing demands on these utilities and services by other facilities in the locality. However as discussed in the relevant chapters of this EIS, anticipated demands on these services are not excessive. The relevant service providers have been / will be consulted as appropriate in relation to provision of these services for the proposed development.

The operation of the proposed facility will result in a cumulative impact on air quality in the vicinity of the proposed site. However, as detailed in Chapter 9, air emissions from the site are not significant and when added to the pollutants in the ambient air, the resultant is well within the relevant AQS for all pollutants being considered.

Both the construction phase and operational phase of the proposed development will have a cumulative impact on the noise environment in the vicinity of the site. However, the construction phase will be temporary and will only last 12-13 months. All construction activities likely to generate significant noise levels will be scheduled at the most appropriate working times practicable. In relation to the operational phase, noise modelling has been carried out which included the cumulative effect that the proposed development will have on the nearest noise sensitive locations. This modelling concluded that the proposed development will have no impact at these NSLs. Furthermore noise levels from other facility currently under construction or in planning were also considered and the proposed development will not add to the cumulative impacts predicted from the other developments.

15.4 Mitigation Measures

Chapters 4 to 14 have identified mitigation measures relevant to the various assessment topics. The majority of potential impacts due to the proposed development and other known projects, both on and off-site, relate to the construction phase. Key to the successful management of all environmental mitigation measures identified is an overall plan, namely a CEMP to ensure all measures are implemented in a co-ordinated manner and no one measure is unduly priorities over another.

Prior to the commencement of construction activities a CEMP will be prepared to incorporate all mitigation measures identified within this EIS and any subsequent planning requirements. A suitably qualified senior member of the Construction Management Team will be assigned responsibility for its execution, maintenance and on-going review. The appointed Main Contractor and all sub-contractors will have important roles to ensure compliance with the CEMP.

The CEMP will include plans for dust, waste, water, traffic and noise management and set out the necessary measures to ensure protection of the environment during the construction phase. The CEMP will form part of the overall Construction Management Plan for the proposed development. This will include detailed arrangements and plans for traffic and site logistics.

Communications will be maintained with SDCC throughout the construction phase of the development to ensure any new development proposals brought forward can be considered for potential cumulative impacts.

15.5 Residual Impacts

Based on the implementation of the CEMP and all mitigation measures outlined in the EIS, there are no significant residual impacts foreseen.

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The potential for cumulative impacts as a result of emissions during the operational phase of the proposed development and other development proposals has been assessed. No significant impacts are considered likely to occur.

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