9 Noise and Vibration

Alexion Proposed Manufacturing Facility IE0311488-22-RP-0002, Issue A

08/05/2015

IE0311488-22-RP-0002_A_01.DOC Page 151 of 242 Formal Issue

9 Noise and Vibration

9.1 Introduction

This chapter details the current noise levels at the proposed development site in the College Business & Technology Park, Blanchardstown Road North, Blanchardstown, Dublin 15. It also outlines the predicted noise levels that would be generated due to the operation of the proposed development, along with the Phase 1 Alexion development which is currently under construction. A baseline noise survey of the site and noise modelling of the proposed on-site activity have been carried out to determine the impact from the proposed development on noise levels in the local area. Based on this information the necessary noise mitigation measures are incorporated into the development design, thereby avoiding any adverse effects.

9.1.1 Effects of Noise

Noise pollution can be a significant issue at industrial sites. As outlined in the EPA’s ‘Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4)’ the effects from the generation of excessive noise in the community are:

- It can cause annoyance and disturbance to people at work or during leisure activities;

- It can cause sleep disturbance;

- It can have a deleterious effect on general physical and mental well-being.

Since the potential effects of noise pollution are so considerable a thorough investigation and analysis of local noise levels has been carried out as detailed in the following sections.

Vibration is a related issue that can also adversely affect people and structures in the vicinity of the vibration source. Ground improvement and foundations works will be required, however no rock blasting or piling will be undertaken as part of the proposed development. No aspect of the operation of the proposed facility will cause vibration to the surrounding areas.

9.2 Assessment Methodology

In order to comprehensively assess the potential impact of noise from the proposed development on the surrounding area noise levels in the vicinity are assessed for the following development stages:

- Pre-development stage – current noise levels at noise sensitive locations close to the proposed development site are measured to provide baseline data to which predicted and future noise measurements for the area can be compared. Baseline noise measurements are carried out both during the day, evening and at night-time using a calibrated sound level meter.

- Construction stage – potential noise impacts arising from construction equipment are considered in order to develop sufficient noise mitigation measures for the construction phase

- Operational Stage – noise emissions from the site when operational are modelled using noise modelling software in order to predict their impact on the noise sensitive locations26 (NSLs) in the vicinity. This will include external noise sources associated with the proposed development. The model results are then added to the baseline results in order to predict the cumulative effect of the proposed development at NSLs, and to implement mitigation measures if necessary.

9.3 Characteristics of the Proposed Development

When considering a development of this nature, the potential noise and vibration impact on the surroundings must be considered for each of two distinct stages:

26 Noise Sensitive Location – any dwelling house, hotel or hostel, health building, educational establishment, place of worship or entertainment, or any other facility or other area of high amenity which for its proper enjoyment requires the absence of noise at nuisance levels. (EPA NG4, 2012)

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- Temporary construction phase, and;

- Long term operational phase.

The construction phase entails the excavation and the construction of new buildings over a phased construction period.

Operational noise sources will consist, mainly of, utilities and manufacturing processes, car park activity and additional traffic on public roads.

9.4 Receiving Environment

The baseline noise measurement studies were carried out by PM Group on the 22 January 2014 and 09 April 2015. Daytime and evening time readings were taken at all five noise sensitive locations (NSLs) around the proposed site while night time readings were taken at only one NSL , i.e. NSL1 (see Table 9.1 and Figure 9.1). This is due to the fact that this is the only dwelling and NSL2 to NSL5 would not be normally used at night-time. The baseline noise surveys were carried out in accordance with NG4 and supporting FAQ document27.

Note: The daytime results from the January 2014 survey are used in this assessment as they are considered more indicative of normal background levels as Phase 1 of the Alexion development is currently under construction. It is also noted that there are no new significant developments currently in the area. Evening and night-time levels were updated in the April 2015 survey as construction does not occur at these times.

Table 9.1: Description of Baseline Noise Sensitive Locations

Noise Sensitive Location

(NSL)

Monitoring Period

Description National Grid Coordinates

NSL1 Day/Evening/Night Outside nearest residential dwelling along Dromheath Drive ~330m south west of the

proposed facility boundary

307341E, 240724N

NSL2 Day/Evening East corner of Lady’s Well park ~50m south west

of the proposed facility boundary 307447E, 240971N

NSL3 Day/Evening ~300m west of the proposed facility boundary at

the rear of Mulhuddart Cemetery 307375E, 241293N

NSL4 Day/Evening Outside the Bright Horizons early childhood care

and education centre ~200m east of the proposed facility boundary

308283E, 240926N

NSL5 Day/Evening Outside of the Institute of Technology

Blanchardstown (ITB) Learning and Innovation Centre ~15m south of the proposed site boundary

307790E, 240835N

The five NSLs were chosen given their vicinity and their vulnerability to potential noise disturbance from the proposed development. Due to potential sensitivity to noise disturbance only occurring during day and evening time periods at NSLs 2 - 5, night-time monitoring was not conducted at these locations.

NSL 1 is the closest residential dwellings to the proposed development site and therefore was monitored for the daytime, evening time and night-time noise levels.

27 http://www.epa.ie/pubs/advice/noise/Questions_NG4.pdf

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Figure 9.1: Locations of Baseline Noise Monitoring Points (Site Boundary in red)

9.4.1 Noise Measurement Parameters

Noise is measured in terms of decibels (dB). The various measurement parameters and noise terminology are defined below.

- Decibel (dB)

Decibel (dB) is the standard unit for expressing the noise level (sound pressure level). It is calculated as a logarithm of the intensity of sound. It is derived from the logarithm of the ratio between the value of a quantity and a reference quantity. For sound pressure level the reference quantity is 20µPa which is the threshold of normal hearing and equates to 0dB. At the upper end of the scale 140dB is the threshold of pain.

- A-weighted Decibel (dBA)

Decibels measured on a sound level meter incorporating a frequency weighting (A weighting) which differentiates between sound of different frequency (pitch) in a similar way to the human ear. This takes account of the fact that the human ear has different sensitivities to sound at different frequencies.

- Leq

The equivalent continuous sound level – the sound pressure level of a steady sound having the same energy as a fluctuating sound over a specified measuring period. It can be considered similar to an average level. The LAeq value is the A-weighted Leq.

- LA90 and LA10 Values

The LA90 and LA10 values represent the A-weighted sound pressure levels exceeded for a percentage of the instrument measuring time. The LA90 represents the sound pressure level exceeded for 90% of the monitoring period and is a good indicator of the background noise

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level excluding peak noise events. LA10 indicates the sound pressure level exceeded for 10% of the monitoring period and is a good parameter for expressing event noise such as passing traffic.

- LAMax (dBA)

The maximum instantaneous value recorded over the monitoring period including A-weighting.

- LAr T (dBA)

The equivalent continuous A-weighted sound pressure level during a specified time interval, T, plus specified adjustments for tonal character and impulsiveness of the sound.

- Tonal Noise

Sounds which cover a range of only a few Hz which contains a clearly audible tone, i.e. distinguishable, discrete or continuous noise (whine, hiss, screech, or hum etc.) are referred to as being ‘tonal’.

- Impulsive Noise

A noise that is of short duration (typically less than one second), the sound pressure level of which is significantly higher than the background. e.g. hammer blow to metal sheet.

9.4.2 Noise Monitoring Equipment

The noise surveying was carried out using the following equipment:

- Noise Meter 1: Bruel and Kjaer 2260 Sound Level Meter28 c/w Bruel and Kjaer type 4189 Microphone and windshield (meter set to fast response time)

- Noise Meter 2: Bruel and Kjaer 2250 Sound Level Meter1 c/w Bruel and Kjaer type 4189 Microphone and windshield (meter set to fast response time)

- Brüel and Kjaer type 4231 Calibrator – used to calibrate the meters before and after surveying for each measurement session

- 2 No. Tripods

The sound level meters were field calibrated prior to and immediately following each measurement session.

The Bruel and Kjaer 2260 Sound Level Meter and Brüel and Kjaer type 4231 Calibrator were last calibrated by the manufacturers Brüel & Kjaer UK Ltd, on 01/09/2014 in accordance with procedure documented in BS7580:Part 1:1997 and IEC60942:2003 Annex B Class 1.

The Bruel and Kjaer 2250 Sound Level Meter and Brüel and Kjaer type 4231 Calibrator were last calibrated by the manufacturers Brüel & Kjaer UK Ltd, on 29/05/2012 and 05/11/2013, respectively in accordance with procedure documented in BS7580:Part 1:1997 and IEC60942:2003 Annex B Class 1 (Note: these are the calibration dates valid for the January 2014 daytime monitoring results).

9.4.3 Weather Conditions

January 2014: Weather conditions were cool and dry with wet ground conditions. There was a gentle breeze blowing during all measurement sessions, with all wind speeds below 5m/s.

April 2015: Weather conditions were warm and dry. There was a gentle breeze blowing during all measurement sessions, with all wind speeds below 5m/s.

9.4.4 Baseline Noise Monitoring Results

The baseline noise monitoring was carried out at each NSL in accordance with the EPA’s ‘Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to

28 The Bruel and Kjaer 2260 & 2250 Sound Level Meters are Type 1 meters

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Scheduled Activities (NG4)’. Noise levels at each NSL were measured over three 15 minute periods during the day (07:00-19:00 hours); and one 15 minute period in the evening time (19:00-23:00 hours). NSL 1 noise levels were also measured over two 15 minute periods during the night-time measurement (23:00-07:00 hours).

The LAeq, LAMax, LA10 and LA90 results for all measurement periods are presented in Tables 9.2, 9.3 and 9.4.

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Table 9.2: Baseline Noise Monitoring Results – Daytime Monitoring (22/1/2014; 07:00 – 19:00 hours)

Noise Monitoring

Point Time Period

Noise Meter used (see Section 9.3.2)

LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)

Audible Sounds During Measurement Period

NSL1 Start time: 10:09

Duration: 15 minutes Noise Meter 1 54 76 56 50

• Traffic travelling along the M3 was audible and constant throughout the measurement period - dominant noise source

• Birdsong throughout measurement

• Vehicles passing near meter

• Intermittent air traffic over head – commercial airlines taking off

• Intermittent sound of children playing in distance

• Car alarm in distance

• Impact noise from banging of gate in nearby house





• Construction activities from estate entrance on Chapel Road was audible in the distance

• Vehicle passing near meter

• Air traffic over head – commercial airline taking off

• Intermittent sound of car alarm in distance

• Impact noise from banging of gate in nearby house

• Impact noise from car driving over loose manhole on roadway








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Noise Monitoring

Point Time Period


LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)





• Traffic along Chapel Road was audible - intermittent





• Rustling of leaves from nearby trees and hedgerows














• Intermittent sound of car alarm in distance



• Dog barking near meter


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Noise Monitoring

Point Time Period


LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)




• Traffic travelling along the M3/M50 was audible and constant throughout the measurement period - dominant noise source

• Intermittent sound of banging in distance




• Alarm sounding in distance

• Faint crackling noise from ESB power line



















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Noise Monitoring

Point Time Period


LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)




• Traffic travelling along the M3/M50 and R121 was audible and constant throughout the measurement period - dominant noise source




• Intermittent sound of children playing in day care centre






• Intermittent air traffic over head – commercial airline taking off









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Noise Monitoring

Point Time Period


LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)


NSL5

Start time: 11:03

Duration: 15 minutes

Noise Meter 2 53 70 55 50

• Construction activities from ITB grounds located ~ 200m from meter- dominant noise source

• Traffic travelling along the M3 was audible and constant throughout the measurement period

• Constant sound of people training on ITB pitches – people shouting and whistles blown intermittently

• Faint sound of birdsong throughout measurement


















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Table 9.3: Baseline Noise Monitoring Results – Evening time Monitoring (09/04/2015; 19:00 – 23:00 hours)

Noise Monitoring

Point Time Period


LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)

Audible sounds during measurement period




• Birdsong audible throughout reading

• Vehicles passing near meter (4 No.)

• Sound of angle grinder is distance

• Car idling close to meter for approx. 5 mins

• Intermittent air traffic over head – commercial airlines taking off (4 No.)

• Motorbikes accelerating fast intermittently throughout reading




• Birdsong audible

• Intermittent sound of people training on ITB pitches – people shouting and whistles being blown




• Traffic travelling along the M3 and Church Road was audible and constant throughout the measurement period - dominant noise source



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Noise Monitoring

Point Time Period


LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)




• Traffic travelling along the surrounding road network was audible and constant throughout the measurement period - dominant noise source (M3/M50 and R121)



• Vehicles entering and exiting Digiweb office block ~100m from meter (2 No.)




• Vehicles passing near meter (15 No. entering and exiting ITB)

• Intermittent sound of people training on ITB pitches – people shouting and whistles blown intermittently


• Intermittent air traffic over head – commercial airline taking off (5 No.)

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Table 9.4: Baseline Noise Monitoring Results – Night-time Monitoring (09/04/2015; 23:00 – 07:00 hours)

Noise Monitoring

Point Time Period


LAeq dB(A)

LAMax dB(A)

LA10 dB(A)

LA90 dB(A)





• 2 No. cars passed by meter

• Intermittent barking of dog in distance

• Car alarm in distance




• 3 No. cars passed by meter

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9.4.5 Tonal Analysis

Tonal analysis was carried out on the results of the noise survey for all monitoring periods. This involved the analysis of the spectrum of noise levels recorded at each monitoring location with respect to the frequencies (Hz) at which they occurred. Tonal analysis was carried out in accordance with the requirements of NG4.

One-third octave band tonal analysis was employed and involves the calculation of an averaged noise level to represent the frequencies within each third of an octave. These noise levels are then compared with the noise levels calculated for the adjacent one-third octave bands. If a noise level meets the below criteria with regard to the noise levels representing the adjacent bands then it is considered tonal, since it is significantly louder than noise levels at similar frequencies.

- 15dB in low frequency one third octave bands (25Hz to 125Hz);

- 8dB in middle frequency bands (160Hz to 400Hz), and;

- 5dB in high frequency bands (500Hz to 10,000Hz).

Tonal analysis results are given in Tables 9.5 and 9.6 for NSL1 to NSL5 for the daytime and evening time monitoring, while results for NSL1 for the night-time monitoring are given in Table 9.7.

Table 9.5: Tonal Noise Results – Daytime Monitoring

Noise Monitoring Point Tonal Noise Level, LLeq (dB) Frequency at which it

occurred (Hz)

NSL 1 No Tonal Component detected





Table 9.6: Tonal Noise Results – Evening time Monitoring


occurred (Hz)






Table 9.7: Tonal Noise Results – Night-time Monitoring


occurred (Hz)


9.4.6 Discussion of Baseline Noise Monitoring Results

The results detailed in Tables 9.2 to 9.4 shows that the proposed site is situated in an area where noise levels are relatively consistent through the day, evening and night time periods. Following screening in according to the EPA NG4 guidance note, the existing environment cannot be

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classified as a ‘Quiet Area’ or an ‘Area of Low Background Noise’. Currently noise levels in the area are dominated by traffic from the M3 motorway and air traffic taking off from Dublin Airport.

The EPA NG4 Guidance Note recommends that noise level contributions at sensitive locations should be kept at least below a LAr,T of 55dB(A) at daytime, 50dB(A) at evening time and 45dB(A) at night-time for IEL and Waste licenced facilities.

From the results for the noise surveys it can be seen that the baseline noise levels in the vicinity of the proposed site are generally just below the recommended limit for daytime hours. The recorded baseline noise levels for evening time and night-time are generally above the recommended noise limits. These exceedances are due to existing noise sources in the area, i.e. air traffic and very busy road traffic.

The tonal analysis results in Tables 9.5 to 9.7 indicate that there was no tonal noise detected during the daytime, evening time, or night-time noise measurement periods.

9.5 Potential Impacts

9.5.1 Construction Phase

Guidance

There is no published statutory guidance relating to the maximum permissible noise level that may be generated during the construction phase of a project. Local authorities normally control construction activities by imposing limits on the hours of operation.

In the absence of specific noise limits, guidance can be found on criteria relating to permissible construction noise levels for a development of this scale in the National Roads Authority (NRA) publication ‘Guidelines for the Treatment of Noise and Vibration in National Road Schemes, 2004’ which has no legally binding status but is instructive. Table 9.8 indicates the maximum permissible noise levels at the facade of nearest dwellings during the construction period as recommended by the NRA.

Table 9.8: Maximum Permissible Noise Levels at the Facade of Dwellings during Construction

Days and Times Noise Levels (dBA)

LAeq(1hr) LAMax

Monday to Friday 07:00 to 19:00 hrs 70 80

Monday to Friday 19:00 to 22:00 hrs 60 65

Saturday 08:00 to 16:30 hrs 65 75

Sundays and Bank Holidays 08:00 to 16:30 hrs

60 65

Proposed Construction Hours

Construction noise will occur for a period of 24 months. Normal construction working hours will be Monday to Friday 7:00am to 7:00pm, with extended periods under stricter noise limits to 9pm when required and approved, and 8:00am to 6:00pm on Saturdays, with limited or no works outside of this period.

Construction Noise – Potential Impacts

The primary sources of noise during the construction phase will be temporary and include:

- Ground preparation phase – excavators, dump trucks and rollers for ground, filling and levelling

- Structural phase – installation of foundations and erection of new buildings involving the use of equipment such as compressors, generators, pneumatic tools, hand-held power tools, and mobile/fixed cranes

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- Construction related traffic

During the construction phase of the proposed development, a variety of items of plant will be in use, such as excavators, lifting equipment, dumper trucks, compressors and generators.

Due to the nature of the activities undertaken on a large construction site, there is potential for temporary or sporadic generation of significant levels of noise. Table 9.9 contains noise emissions levels for typical construction equipment as detailed in BS 5228: Part 1: 2009 Code of practice for noise and vibration control on construction and open sites.

Table 9.9: Typical Noise Levels Generated by Construction Phase Equipment

Phase Item of Plant (BS 5228:2009

Reference) LAeq @ 10m (dBA)

Site clearance Tracked excavator (C.2/14) 79

Wheeled loader (C.2/27) 80

Filling Operations

Dump truck (tipping fill) (C.2/30) 79

Dump truck (empty) (C.2/31) 87

Roller (rolling fill) (C.2/37) 79

Steel erection Articulated truck (C.4/2) 78

Tower crane (C.4/49) 77

Concreting (surfacing) Road Roller (C.5/19) 80

In summary, construction noise will be generated for a limited period during the construction phase of the proposed development. The level of construction noise during the daytime will be minimised as much as practicable to limit the impact on ambient noise levels and noise sensitive receptors (e.g. residential dwellings) in the vicinity. It is not anticipated that any night working will be required, but if it is necessary it will be kept to a minimum, and managed to ensure that noise levels do not significantly impact on nearby noise sensitive receptors. Any such activity will be approved by FCC prior to commencement.

There is no requirement for either blasting or driven piles during the construction of the proposed facility. Therefore vibration is not envisioned as issue with respect to the proposed development.

9.5.2 Operational Phase

In order to assess the potential noise impact due to the proposed development a noise model has been carried out. Full details of this noise modelling are outlined in the Noise Modelling Report (PM Group Document No. IE0311488-22-RP-0004) included in Appendix E of this EIS.

There will be a number of noise generating equipment items and activities associated with the operation of the proposed facility. The majority of the noisy equipment associated with the proposed development will be housed internally within the proposed development buildings, therefore mitigating that potential source. Also included in the model are the noise sources associated with the Phase 1 development, which is currently under construction. Any noise from production and utilities equipment located inside/within the site buildings will be mitigated by both equipment design and/or the building structure to prevent any external noise impact.

The externally located utility equipment items which could potentially impact on ambient noise levels, are as follows:

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Proposed Development (Phase 2)

- 4 No. Cooling Towers located on the roof of the central utilities building

- 1 No. main fresh air intake louver located on southern elevation of main process building

- 1 No. main exhaust air louver located on eastern elevation of main process building

- 2 No. warehouse air intake louvers on northern elevation of warehouse building

- 5 No. pumps associated with waste water treatment area

Development under Construction (Phase 1)

- 4 No. cooling towers in utilities yard

- 12 No. cold room compressors (4 No. located on roof of warehouse building; 8 No. located on external wall in utilities yard)

- 14 No. AHUs associated with the administration, canteen, warehouse and laboratory buildings (overall 22 No. separate fan noise sources located at various points at external intake and exhaust louvers)

For the purposes of the impact assessment, only the main noise sources were included in the noise model. Noise from site emergency equipment, i.e. fire water pump, emergency generators etc., is not considered normal operational noise for the purposes of this assessment. See Section 4.4.1 of NG4 for further justification details.

Model Software and Input Data

The Brüel & Kjaer Predictor Type 7810, Version 7.10 software package was used to model the noise levels being emitted to the surrounding environment from the proposed facility. Predictor Type 7810 is a proprietary noise calculation package for computing noise levels in the vicinity of industrial sites. Calculations are based on the International Standard ISO 9613-2: 1996 “Acoustics – Attenuation of Sound Outdoors – Part 2: General Method of Calculation.” This method has the scope to take into account a range of factors affecting the attenuation of sound including:

- The magnitude of the noise source in terms of sound power

- The distance between the source and the receiver

- The presence of obstacles such as screens or barriers in the propagation path

- The presence of reflecting surfaces

- The hardness of the ground between the source and receiver

- Attenuation due to atmospheric adsorption

- Meteorological effects such as wind gradient, temperature gradient and humidity

- Calculations are performed in octave bands from 63 Hz to 8 kHz as well as in overall A-weighted decibels (dBA).

- The input data for each noise source in the noise model included:

- The source position

- The source elevation (metres)

- Directivity

Noise Emission – The octave band analysis sound power levels determined for each source were A-weighted and input to the model. The model then calculates an overall sound power level (dBA) for each source. (In accordance with ISO 9613-2, the sound power levels at 31 Hz were not input to the model).

Working Hours – The model allows the user to define daytime, evening, and night-time periods, so that noise levels can be predicted for each period. For the purposes of this assessment, in order to

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predict the maximum possible noise levels, all of the noise sources were assumed to run continuously throughout a 24-hour period.

The principal buildings on the site were also input to the model, i.e. proposed development and development under construction (Phase 1 and Phase 2).

Predicted noise levels are calculated for a set of receiver points, which are chosen by the model user. For the purposes of this assessment, the receiver points are the noise sensitive locations outlined in Section 9.4.

The ground conditions between the noise sources and the receptor points were also included in the model.

Noise Modelling Results

The noise modelling results from the facility noise sources at the selected receiver points are summarised in Table 9.10. The table includes the cumulative effect of ambient noise and predicted noise due to facility operations which have been calculated by adding the model predicted noise contribution to existing ambient noise levels at the receiver points.

Table 9.10: Predicted Noise Contribution from Facility and Cumulative Noise Level at Noise Sensitive Locations

Receiver Point Predicted Noise

Contribution from Facility (dBA)

Existing Ambient29

Noise Level LAeq (dBA)

Cumulative Noise Level

LAeq (dBA)

NSL1 28 54 (day)

55 (evening) 48 (night)

54 (day) 55 (evening)

48 (night)

NSL2 29 55 (day)

55 (evening) N/A (night)

55 (day) 55 (evening) N/A (night)

NSL3 30 53 (day)



NSL4 33 54 (day)



NSL5 41 54 (day)



The modelling shows that the predicted noise level contribution from the proposed facility are below the applicable noise criteria LAr,T of 55dB(A) at daytime, 50dB(A) at evening time and 45dB(A) at night-time.

The perceived impact rating and the subjective response to changes in noise levels with regards to perceived changes in loudness has been outlined in Table 9.11 below.

Table 9.11: Perceived Impact Rating and Subjective Responses

Change in Noise Level

Impact Rating EPA Glossary of Impacts

Subjective Reaction

Subjective Change

0 No Change N/A N/A N/A

29 The existing ambient values in Table 9.10 are arithmetic averages of the values recorded during the noise monitoring surveys

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Change in Noise Level

Impact Rating EPA Glossary of Impacts

Subjective Reaction

Subjective Change

< 3 dBA Not Significant Neutral, Imperceptible or Slight Impact

Barely Perceptible Negligible

3 – 5 dBA Minor Significant Impact: Positive or Negative only

Perceptible Noticeable

6 – 10 dBA Moderate Up to a doubling of loudness

Clearly Noticeable

11 – 15 dBA Major Over a doubling of loudness

Substantial

> 15 dBA Severe Profound Significant Impact: Negative only

-- Very Substantial

Note: Based on Extract from Morris, Peter and Therivel, Riki, Methods of Environmental Impact Assessment 2

nd Edition, 2001, UCL Press.

Table 9.11 is provided for information in order to assess the significance of a change in noise level, to aid the assessment of the impact of the noise sources. As can be seen from the modelling results that the operational phase of the proposed development results in a change in the Cumulative Noise level for only one receptor, during one time period (NSL5 – evening time). The predicted increase in noise level at NSL5 (evening time) is only 1 dBA, which falls within the category ‘below 3 dBA’, and with reference to Table 9.11 is assessed as not significant, with a negligible subjective change. It is noted that some of the background levels are currently above the relevant noise criteria, however the predicted results show that the predicted increase is nil or negligible.

Additional Vehicular Traffic

A traffic assessment has been prepared by Malachy Walsh & Partners, see Chapter 6 (Traffic and Transportation). This has been used to determine the predicted change in noise levels on the road routes in the vicinity of the proposed development for the future years 2018, 2023 and 2033.

For the purposes of assessing potential noise impact, it is appropriate to consider the relative increase in noise level associated with traffic movements with and without the development using the provided AADT flow figures. The results are presented in Tables 9.12.

Table 9.12 shows the predicted increase in traffic flows associated with the proposed development. This will result in increases of the order of max +0.03dB, +0.07dB and +0.06dB in the vicinity of the development in the years 2018, 2023 and 2033 respectively. Increases of this order would have a negligible subjective change and would not be a significant impact.

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IE0311488-22-RP-0002_A_01.DOC Page 170 of 242

Formal Issue

Table 9.12: Predicted Changes in Traffic Noise Levels

2018 2023 2033

Existing Proposed

dB Difference

Existing Proposed dB

Difference Existing Proposed

dB Difference

R121 (North) 15781 15843 0.02 16137 16279 0.04 16776 16918 0.04

R121 Blanchardstown Road North (south)

15010 15114 0.03 15350

15588 0.07 15918 16156

0.06

R121 Interchange Bridge 21268 21312 0.01 21761 21862 0.02 22649 22750 0.02

N3 (south) 65351 65468 0.01 66974 67241 0.02 69778 70045 0.02

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9.5.3 ‘Do Nothing’ Scenario

In the absence of the proposed development the existing noise environment will remain the same in the short to medium term.

From the results of the baseline noise surveys carried out it was shown that the baseline noise levels in the vicinity of the proposed site are generally just below the recommended limit for daytime hours. The recorded baseline noise levels for evening time and night-time are generally above the recommended noise limits. These exceedances are due to existing noise sources in the area, i.e. air traffic and very busy road traffic.

9.5.4 Cumulative Impacts

Both the construction phase and operational phase will have a cumulative impact on the noise environment in the vicinity of the site. 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, the noise modelling carried predicts the effect that the proposed development will have on the nearest NSLs. This modelling concluded that the proposed development will not have a significant impact at these NSLs. In the context of the cumulative operation impact with the proposed developments of BMS and Montjeu the following is noted:

- The worst case predicted noise levels from the proposed BMS development are in the order of 32 dBLAeq, T at the nearest sensitive locations to BMS. The proposed BMS development is located to the northeast of the proposed development site, on the opposite side of the Cruiserath Road.

- The worst case predicted noise levels from the proposed Montjeu development are in the order of 38 dBLAeq,T at the nearest sensitive locations to the proposed Montjeu development. The proposed Montjeu development is located adjacent to the proposed development site, to the northwest of the Alexion site boundary.

- The worst case limit is 45 dBLAeq,T (night-time), therefore it is considered that the potential for cumulative noise impacts from the proposed development in combination with Montjeu and BMS proposed developments is not significant.

In terms of traffic noise, both the proposed BMS and Montjeu developments predicted negligible impacts due to increased traffic. Given that the proposed development operational traffic will not impact the noise environment significantly, it is predicted that there will be no significant cumulative impacts due to increased traffic.

9.6 Mitigation Measures


As outlined in Section 9.5.1, the construction phase of the development will have the potential to cause a significant increase in noise levels in the immediate vicinity of the development site. However, as part of the construction contract and CEMP, the development contractor will be obliged to reduce as far as possible the potential noise impact of the construction activity. The main mitigation measures to be taken are as follows:

- Control of Working Hours

Construction noise will occur for a period of 24 months. Normal construction working hours will be Monday to Friday 7:00am to 7:00pm, with extended periods under stricter noise limits to 9pm when required and approved, and 8:00am to 6:00pm on Saturdays,

- All construction equipment will be correctly operated and maintained to ensure optimal performance and minimise out of balance effects that may result in ground-borne vibration or

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excessive noise. Noisy equipment will be located as far as practicable from noise sensitive receptors

- All construction equipment used will be required to comply with the relevant regulations on plant and equipment noise, namely the European Communities (Construction Plant and Equipment) (Permissible Noise Levels) Regulation, 1988 (SI No. 320 of 1988) & Amendment Regulation, 1996 (SI No. 359 of 1996) and the European communities (Noise Emission by Equipment of Use Outdoors) Regulations, 2001 (SI No. 632 of 2001) & Amendment Regulations, 2006 (SI No. 241 of 2006)

In summary, the construction phase of the development has the potential to cause a negative impact on noise levels in the vicinity of the site. However all available construction industry good practice methods will be used to ensure that noise impacts are kept to a minimum. In addition it must be noted that the noise impact of the construction phase is a temporary one only (it is estimated that the construction phase of the development will take approximately 24 months to complete). As a result the construction of the development will have no long-term effect on the noise levels in the surrounding area.


The majority of the noisy equipment associated with the proposed development will be housed internally within the proposed development buildings, therefore mitigating that potential source.

Site equipment will be subjected to maintenance regime which will ensure correct optimal performance is maintained and noise emissions are minimised.

Testing and maintenance of the emergency generator will be restricted to day time hours only.

The proposed facility will require an IEL from the EPA to operate. As part of this licence the facility will be required to adhere to all conditions set out in the licence in relation to noise, including noise limit values at noise sensitive locations. EPA NG4 Guidance Note states that the noise attributable solely to on-site activities, expressed as a free field value at any NSL, should not generally exceed the values given below.

Daytime (07:00 to 19:00hrs): 55dB LAr,T

Evening time (19:00 to 23:00hrs): 50dB LAr,T

Night time (23:00 to 07:00hrs): 45dB LAeq,T

As can be seen from the noise modelling carried out (Table 9.10), the external equipment items proposed are not predicted to lead to significant increases at the nearest noise sensitive locations.

No additional mitigation measures are deemed necessary for the operational phase of the proposed development as the predicted noise emissions will not have a significant impact on existing ambient noise levels at the site.

9.7 Residual Impacts

With the employment of the mitigation measures as detailed above for operational phase, and given the temporary nature and mitigation measures detailed for the construction phase, it is not expected that the proposed development will have any significant adverse residual impact on the local environment during the construction or operational phases.

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10 Water and Effluent

10.1 Introduction

This chapter assesses and evaluates the potential impacts of the proposed development on the surrounding water environment. This chapter should be read in conjunction with the Description of the Proposed Development (Chapter 2), Soils, Geology & Hydrogeology (Chapter 7) and Flora & Fauna (Chapter 8) of this EIS.

The following key aspects of the water environment are covered in detail within this section:

- Existing surface water environment including natural water bodies

- Waste water (foul and process waste water) from the proposed development

- Storm water (rainfall runoff) from the proposed development and potential flood risk

- Water supply to the proposed development

The site of the proposed development is located at College Park, Blanchardstown, Dublin 15. The Phase 1 development is currently under construction and the design, planning and construction of it has been used to inform the consideration of potential impacts on the water environment arising from the Phase 2 development.


The assessment of the potential impact of the proposed College Park Phase 2 development on the water environment was carried out according to the methodology specified in the following guidance documents:

- Guidelines on the Information to be Contained in Environmental Impact Statements (Environmental Protection Agency (EPA))

- Advice Notes on Current Practice (in the Preparation of Environmental Impact Statements) (EPA)

- Eastern River Basin District (ERBD) Management Plan

- ERBD Management Plan Water Management Units

- Stage 1 Flood Risk Assessment (College Park Phase 1), PM Group, 2014

- EPA EnVision Online Mapping


The characteristics of the proposed development with regard to water and effluent are outlined in the following sections.

10.3.1 Storm Water

Storm Water Run-Off

The storm water drainage system will collect rain water runoff from roofs, roads and paved areas.

Prior to discharge to the external storm water sewer system, the runoff will be collected in an on-site attenuation pond (currently under construction as part of the Phase 1 development).

The attenuation pond will be extended from 1,850m3 to 3,600m3 as part of the Phase 2 development. In accordance with the Greater Dublin Strategic Drainage Study, no flood waters will be allowed to leave the site up to and including a 1:100 year storm event. The pond will be lined with a 2.5mm thick impermeable HDPE liner to ensure a complete water tight structure.

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Further to consultation with Fingal County Council, the quantity of surface water discharged from the site shall not exceed 3.4 litres/second/hectare.

Storm Water Quality

Drainage of the main car park is proposed to be provided using a system of bio retention swales/basins. As well as enhancing the aesthetic nature of the development, the swales also provide a sustainable system of drainage (SuDS) to the proposed development.

The runoff from all car park areas will pass through a hydrocarbon interceptor prior to discharge to the pond. The Class 1 bypass interceptor, complying with EN 858, will retain any hydrocarbons in the runoff. The quality of runoff from the proposed development will be further improved by the fact that the storm water attenuation pond will also act as a settlement pond.

The surface water piped drainage network will discharge to an existing 1050mm Council drain at the south east of the site. This drain connects to an 1800mm pipeline that continues to the ornamental pond at the Business Park entrance, which in turn discharges to the River Tolka.

Fire Water Run Off

A risk assessment has been carried out for the Alexion site to establish the technical requirement or otherwise for on-site emergency firewater retention i.e., for the prevention of potentially contaminated firewater run-off (or storm water run-off) from reaching the environment. The risk assessment methodology is based on the inventory of potentially polluting materials within the site and the risk of that material being released to the environment in an emergency event such as a fire. Because the manufacturing process at Alexion is an aqueous based activity, the inventory of chemical material potentially stored on site is small and does not exceed any of the guideline thresholds for firewater retention. Furthermore, storage of all potentially polluting materials on the site will be bunded. Consequently, the risk assessment concluded that on-site emergency retention is not required.

Notwithstanding this conclusion, it is proposed to install an emergency shut off valve at the end of the site surface water drainage system to allow automatic shut-off of the surface water sewer, upstream of its point of connection to the external public surface water sewer and downstream of the on-site attenuation pond. This valve will be linked to the building fire alarm system and to the Building Management System (BMS), and will be closed in the event of an emergency such as a fire or an accidental spillage. Any firewater that were to be discharged to the attenuation pond in such a scenario would be analysed prior to a decision being made with respect to viable disposal options.

10.3.2 Waste Water

Effluent from the proposed Phase 2 development will arise from a number of sources, namely the new process/manufacturing operations, utilities and sanitary sources.

The Phase 1 development (currently under construction) produces waste water from laboratory and sanitary sources only.

Figure 10.1 provides a schematic diagram of the waste water management strategy for the site covering both the Phase 1 and Phase 2 developments.

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Figure 10.1 Site Waste Water Management Strategy

It is planned that effluent arising from the Phase 2 development will undergo preliminary treatment on site, before discharge to the municipal sewer. The on-site waste water treatment facilities will include the following operations;

1. Heat inactivation of aqueous waste streams potentially containing Genetically Modified Micro-organisms (GMM) cells from the process (located within the manufacturing building)

2. Balancing and neutralisation of all process waste waters from Phase 2

3. Cooling, odour management and monitoring

Steps 2 and 3 above will be located in a new external Waste Water Treatment area in the northern part of the site (Figure 2.2).

The biotechnology processes to be used at the Phase 2 facility will generate a range of aqueous waste streams containing biodegradable organic components and nutrients. The utility equipment that will be provided at the facility to support the production process will also generate aqueous waste streams containing low levels of biodegradable organics. Sanitary waste water (sewage) will also arise.

The majority of waste water arising from the facility will be generated in the manufacturing building, and in particular from the waters associated with vessel cleaning therein. The basic characteristics of the various aqueous waste streams from the facility are as follows:

- Production Areas

o Inactivated pre-culture, cell culture and harvest waste streams

o Waste streams from recovery, purification and formulation

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o Clean in Place (CIP) wash waters (medium strength BOD/COD, high nitrogen, high phosphorus, low solids)

- Centralised Utilities

o Reverse Osmosis (RO) reject

o Water softener brine

o Boiler / cooling tower blowdown (low BOD/COD, low solids)

- Sanitary waste water (normal sewage form toilets, lockers, showers and canteen)

A full characterisation of the waste water streams from the development is described in Table 10.1 below.

Table 10.1 Anticipated Waste Water Loads

Parameter Average Loading to Sewer

(including Phase 11)

Maximum Loading to Sewer

(including Phase 11)

Daily Volume (m3/day) 1060 1600

Hourly volume (m3/hr) 44.2 66.7

Instantaneous volume (l/s) 12.3 81.92

BOD kg/day 320 720

Suspended Solids (kg/day) 250 500

Total Phosphorus (kg/day) 80 160

Total Nitrogen (kg/day) 80 160

Total Sulphates (mg/l) 400 600

Oil, fats and grease (mg/l) 25 50

Temperature (oC) <40 <40 1. Phase 1 loading constitutes <5% of the total combined Phase 1 and Phase 2 loadings under both average and maximum conditions

2. Maximum discharge rate permissible by Irish Water for release of waste water retained on site during specified storm events. Otherwise maximum

discharge rate will be 25.8l/s

Site Waste Water Management Strategy

The location of the proposed development in College Park to a large extent defines the manner in which waste water from the facility will be handled. The site is currently connected to an existing public sewer system serving College Park that eventually connects to the 1200mm 9C interceptor trunk sewer from Blanchardstown. The 9C trunk sewer in turn discharges to the sewerage system transporting sewage across Dublin City to the Ringsend Waste water Treatment Plant. Waste water treated at Ringsend is discharged to Dublin Bay in accordance with their EPA licence.

As such, the only viable disposal route for waste water arising at the proposed development site is via public sewer to Ringsend. There are no watercourses in proximity to the site with capacity to assimilate treated waste water from the proposed development. Accordingly, in considering the most appropriate strategy for management of waste water generated at the site, the following options were evaluated;

1. Direct disposal of all waste water to the public sewer for subsequent downstream treatment at Ringsend WWTP

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2. Pre-treatment only on the Alexion site, with balanced and neutralised waste water going to public sewer for subsequent downstream treatment in Ringsend

3. Primary treatment with chemically enhanced sedimentation on the Alexion site, with partially treated waste water going to Ringsend

4. Secondary biological treatment on the Alexion site, with treated waste water going to Ringsend

Note: For all the above options, heat inactivation treatment (and subsequent cooling) of the cell-contented waste streams will be carried out on the Alexion site, prior to combining with the other effluent streams before discharging to the local public sewer.

In evaluating the options, the following key issues were considered;

Options 3 and 4 above would require development on the Alexion site of significant waste water treatment infrastructure comprising large tankage, typically involving aeration and activated sludge processes, chemical addition as well as sludge processing and associated storage and handling.

The scale of plant and tankage likely to be required to accommodate primary sedimentation and/or secondary treatment on the Alexion site would be significant and unlikely to be accommodated within the subject property without compromising the ability of the site to maintain the manufacturing operations proposed.

In addition, potential environmental issues associated with the installation of such plant in College Park would be potentially significant and require the implementation of mitigation measures for the management of odour, bio-aerosols release, sludge handling and associated traffic.

In consultation with Irish Water, it has been confirmed that Ringsend WWTP (including current and planned expansions, ref section 10.4.4), has the capacity to treat the projected waste water volumes when they arise from the development in 2018.

In addition, Irish Water have confirmed that the sewer network external to the College Park site has the capacity to cater for the projected waste water volumes, subject to the site complying with the following condition;

During storm events no discharge will be permitted to the network for periods of up to 7 hours. It will be the Customers responsibility to provide onsite storage to cater for this. Once storm conditions have abated a maximum discharge rate of 81.9l/s from the site would be permitted to facilitate emptying of the on-site storage.

Accordingly, Option 2 (including allowance to address the above condition) is deemed to be the most environmentally sustainable approach to management of waste water from the site. This option is shown schematically in Figure 10.4.

Proposed On-Site Waste Water Management System

The proposed on-site waste water management system will provide pre-treatment to the process effluent only and will consist of the following component treatment steps:

- Screening

- Waste Water Balancing

- Cooling

- Neutralisation

- Monitoring

(Note: Sanitary effluent from the Phase 2 facility (from lockers and toilets) will combine with the sanitary and laboratory effluent form the Phase 1 development prior to separately entering the foul sewer in College Park, as shown in Figure 10.4.)

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Effluent Screening: Upstream coarse screening to remove production vials; hair nets etc. which may have a detrimental impact on downstream mechanical equipment will be employed.

Waste Water Balancing: The main purpose of the balance tank system is to provide buffering capacity to smooth out variations in the flow and pollution loads. This will allow a uniform discharge to the public sewer, and provide natural buffering to pH fluctuations allowing the effluent feed to the downstream neutralisation stage to remain steady.

An additional buffer tank will also be provided to cater for periods of peak load or abnormal concentration requiring retention. Peak loads can be diverted to the buffer tank away from the balance tank and bled back into the system over time allowing for a more uniform treatment and discharge profile. The buffer tank will also cater for storing waste water during specific storm events (to be notified via telemetry by Irish Water) where no discharge will be permitted to the external sewer network for periods of up to 7 hours. Once storm conditions have abated a maximum discharge rate of 81.9l/s from the site would be permitted to facilitate emptying of the on-site storage.

Overall up to 5 tanks are envisaged, each of approximately 400m3 working capacity.

Cooling: Process effluent from the production facility will be at elevated temperatures due to the thermal deactivation of production wastes and the potential use of high temperature utilities such as Water for Injection (WFI). IEL conditions are likely to restrict effluent temperature to a maximum of 40oC, therefore it may be necessary to reduce effluent temperature. Cooling will naturally occur during effluent transfer and equalisation.

Neutralisation: The pH control will be achieved utilising inline dosing, with a PLC controlled chemical dosing system (acid and caustic). There will be upstream and downstream pH sensors installed allowing for effective pH adjustment. The recirculation loop will be provided downstream of the monitoring point to reverse waste water back to the balancing tanks if the quality of discharge waste water does not comply with licence requirements.

Odour Control: Under normal circumstances it is not expected that odours will arise from the waste water management system. However, given the biological nature of the process effluent, any risk of odour would be monitored on an on-going basis to determine the requirement of either corrective actions or abatement.

Monitoring: Flows and loads will require monitoring to ensure compliance with IEL requirements. As a minimum, flow, temperature and pH will require continuous monitoring. A 24 hour proportional flow composite sampler, with refrigeration, will also be installed.

10.3.3 Water Supply

Public water supply to service the Phase 2 College Park development will be utilised to produce water for operations (WFO). The Phase 2 development will require approximately 1,000m3 per day of potable water supply to the site and will be supplied from a separate Irish Water water main, with its own flow meter, from the existing 300mm diameter supply main running outside the eastern boundary of the site. On-site water storage, capable of meeting 24 hours site process demand, will be provided in the form of a single glass lined steel tank in the utility area in the northern part of the site.

Irish Water has confirmed that sufficient public water supply is available via the Ballycoolin reservoirs to meet the demands of the development, subject to the following condition;

A section of 660m of existing 200mm ductile iron main along Cruiserath Road requires upsizing to a 500mm main. This proposed upsize would supply the development in line with the ultimate design and water tower WSA plan. Also required is the commissioning of a section of existing, but still uncommissioned, 300mm main to the east of the site.

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Alexion will continue to liaise with Irish Water to ensure that this infrastructure is provided in order to meet the requirements of the project.

It is proposed to extend the rainwater harvesting system installed as part of Phase 1 to cover supply to all WC cisterns and Urinal cisterns within the Phase 2 development. This will reduce the requirement for mains potable water on an intermittent basis (as affected by actual rainfall frequency).


10.4.1 General

The site is located within the Eastern River Basin District (ERBD) as defined under the S.I. 722 of 2003, European Communities (Water Policy) Regulations, 2003, the enabling legislation of the European Communities Water Framework Directive (WFD) - Directive 2000/60/EC - establishing a framework for Community action in the field of water policy.

The WFD updates all existing water legislation in the EU by setting common objectives for water. The legislation provides for the protection of the status of all waters (surface and groundwater), the establishment of River Basin Districts (RBDs), co-ordination of actions by all relevant public authorities for water quality management in a RBD including cross-border RBDs, characterisation of each RBD, establishment of environmental objectives and the development of programmes of measures and River Basin Management Plans (RBMP).

The proposed development site is located within the Eastern River Basin District (ERBD) in Hydrometric Area No. 09 of the Irish River Network. The Eastern River Basin Management Plan (2009 - 2015), published in July 2010 includes the objective to maintain water status for High and Good status waters and to restore to at least “Good Status” all waters by 2015.

The ERBD is further delineated into a number of Water Management Units (WMU), which are defined as ‘a geographical sub-unit of a river basin district consisting of a number of water bodies relevant to a particular catchment’. The proposed development is within the Tolka catchment. The water bodies which comprise the water management unit consist of groundwater aquifers, rivers, lakes, transitional and coastal water bodies. In accordance with the requirements of the WFD, each water body has been ‘characterised’ describing the water status of the water body and the pressures (anthropogenic and others) on each water body. As part of the Plan each river catchment within the RBD was assessed and a WMU Action Plan detailing the programme of measures was put in place for each.

The strategies and objectives of the WFD in Ireland have influenced a range of national legislation and regulations, since its inception in the year 2000. In terms of surface water, the applicable legislation is SI No. 272 of 2009 European Communities Environmental Objectives (Surface Waters) Regulations 2009 as amended (S.I. No. 327/2012). These regulations implement the requirements of the WFD and establish Environmental Quality Standards for the purpose of assessing the status of surface waters. These Surface Waters Regulations apply to all surface waters - including lakes, rivers, canals, transitional waters, and coastal waters and supersede all previous water quality regulations

10.4.2 Surface Water Quality

There are no rivers, streams or other natural surface water bodies located on or directly adjacent to the site.

The Alexion site naturally drains in a south-easterly direction, and there are a number of currently dry drainage ditches on the site. These include a drainage ditch which runs in a south-easterly direction across the centre of the site and a ditch running in a southerly direction located inside the eastern boundary of the site. There is no visible outflow point from the drainage ditches in the south-east corner of the site as they currently terminate at a land-berm. Therefore it is likely that

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any water accumulating in the ditches could infiltrate to ground and/or ultimately feed into an unnamed tributary of the Tolka River.

The closest surface water bodies to the development site are:

- the Tolka River which at its closest point flows approximately 1km south-west of the proposed development site

- the Pinkeen River which is a tributary of the Tolka River and is located approximately 1.5km west of the proposed development site

The surrounding surface water environment is shown in Figure 10.1.

Figure 10.1 Surrounding Hydrological Environment

The River Tolka river rises near Dunshaughlin in Co. Meath and flows in a south-easterly direction for approximately 33 kilometres before entering the sea near East Wall/Clontarf on the north side of Dublin City. The river has a total catchment area of approximately 14,150 hectares.

For the purpose of the baseline assessment of the proposed development, the River Tolka was assessed under the auspices of the ERBD. Based on historical biotic data compiled by the EPA and local authorities, the overall recorded status of the River Tolka is ‘Poor’. The WFD recognises that, in some cases, it may not be possible to achieve all core objectives by 2015. For the Tolka WMU, the main pressure preventing achievement of ‘Good’ Status is diffuse agricultural pollution. Full implementation of the measures is expected to correct this; however it is estimated that the River Tolka will not achieve ‘Good’ Status until 2021.

The catchment of the River Tolka is a significant salmonid system. The river supports Atlantic salmon, Lamprey and Brown trout populations in addition to eel, stone loach, minnow and three spined stickleback and provides a particularly important nursery function for salmonid species throughout. According to Inland Fisheries Ireland (IFI), the Tolka holds some wild trout and is also stocked by the local angling club. IFI undertook sampling and monitoring of the Tolka River at Violet Hill Drive, Glasnevin in 2011. The sampling recorded a total of six fish species with minnow being the most abundant species followed by three-spined stickleback, lamprey, eels, stone loach

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and salmon. The ecological status of the Tolka was classified as Poor based on the monitoring carried out.

10.4.3 Storm Water Drainage

There are no watercourses or surface water bodies located on or directly adjacent to the existing site. Storm water from the existing and proposed developments on the Alexion campus arise from rain water run-off from buildings, car-parks, road-ways, service yards and other developed areas of the site which discharge to the main College Park storm water system. The storm water discharge from the College Park exits and flows via storm water culvert to an existing 1050mm diameter surface water drain located to the south east of the site and ultimately discharges to the River Tolka which at its closest point is approximately 1km south-west of the proposed development site.

Flooding

In accordance with the guidelines produced by the Department of the Environment, Heritage and Local Government (DoEHLG) - The Planning System and Flood Risk Management (FRM) Guidelines for Planning Authorities, November 2009, a Stage 1 assessment was carried out for the Alexion site as part of the EIS and planning application for the Phase 1 development.30

The Stage 1 Assessment deals with ‘Flood Risk Identification’. The purpose of the assessment is to identify whether there may be any flooding or surface water management issues related to the proposed development site that may warrant further investigation.

The conclusions of the report were that there is low to zero potential for the site to be flooded in either a 1 in 100 year storm event or other extreme storm event. It is not expected that there will be any risk of flooding associated with overland flow, artificial drainage systems, groundwater flooding or from the proposed development itself. Therefore, it is considered that the Stage 1 Flood Risk Identification is sufficient and that it is not necessary to carry out Stages 2 or 3 of the FRA process.

10.4.4 Waste Water

College Park, where the proposed development is located, is serviced by a 450mm diameter foul sewer, located to the south of the site and a 525mm diameter foul sewer flowing southwards along the eastern boundary of the site. Waste water from the Dublin 15 area, including College Park, is currently directed to the Ringsend Waste Water Treatment Plant (WWTP) for treatment prior to discharge to Dublin Bay. Under a Connection Agreement from Irish Water, Phase 1 of the Alexion development at College Park connects to the 450mm diameter sewer to the south of the site. the flow path from the site to Ringsend WWTP is shown in Figure 10.3.

30 PM Group, (2014), Flood Risk Assessment, Alexion College Park Phase 1, Report No. IE0311193-30-RP-0003, Issue A

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Figure 10.3 Waste water Flow to Dublin Bay (Schematic only)

Irish Water has advised that the existing treatment works at Ringsend has a capacity of 1.65 million population equivalent (PE) but is currently receiving and treating a daily load of approximately 1.75 million PE. To accommodate current loads and to allow for future growth of the Dublin region, it is necessary to increase the capacity to at least 2.1 million PE. In addition to an increase in capacity, the treatment works must also be upgraded to treat effluent to a higher standard than the original design.

Planning permission (An Bord Pleanala Ref. PL29C.YA0010) has been granted to upgrade the plant to 2.1 million PE capacity and Irish Water is committed to developing the plant as an urgent national priority.

The upgrade and expansion of the treatment works will be implemented in 3 phases. Phase 1 – immediate upgrades – has already commenced and comprises advanced works to improve certain aspects of the existing works, including additional odour treatment and improved sludge handling capacity. Phase 2- 400,000 PE Extension – the construction is programmed to commence in the second half of 2016 with the new extension available for waste water treatment in 2018. Phase 3 – existing works nutrient removal upgrade – is planned to commence when Phase 2 is available, in 2018 and is expected to take 2 years to complete, with an anticipated completion timescale of the end of 2020, subject to obtaining relevant permits for the project.

The Greater Dublin Drainage Project, currently being prepared to go for planning approval, is a regional waste water project to serve the Greater Dublin Area, with a planned treatment plant at Clonsaugh, Fingal. The project includes an orbital sewer and two pumping stations which will divert drainage from the north of Dublin City to the new treatment plant. Subject to being granted planning approval, it is anticipated that this project will be operational in 2022. Waste water from the entire Dublin 15 area, including College Park, will ultimately be diverted from the Ringsend WWTP to the new plant at Clonshaugh.

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10.4.5 Water Supply

Public water supply to the College Park site is currently fed from Irish Water’s high and low level reservoirs at Ballycoolin. Alexion’s Phase 1 development is being fed from a 300mm diameter water main to the south of the site which is supplied from the low level reservoir.

There is a 1000mm trunk main and 200mm supply main from Ballycoolin running along Cruiserath Road serving lands to the west (Tyrellstown, Hollystown and Powerstown). There is also a 300mm diameter water main running outside the eastern boundary of the site.

The water supply network serving the Ballycoolin reservoirs is from two Irish Water treatment plants, located at Lexilip and Bog of the Ring, and produce up to 4 million litres of drinking water every day, as well as 168 million litres of treated water for general use. The Leixlip Water Treatment Plant is currently being expanded and when completed will provide for an extra 80Ml/day to the region.


The potential impacts of the proposed development on the water environment are considered in this section. Reference should also be made to Chapter 7 (Soils, Geology and Hydrogeology) of the EIS which assesses the potential impacts to groundwater.


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

- The discharge of high levels of suspended solids as a result of silt / mud being washed off the site

- The discharge of raw or uncured concrete

- The discharge of wash-down water from construction vehicles

- An uncontained spillage of pollutants, such as fuel, oil or hazardous chemicals used during construction

- An uncontained spillage of domestic/foul effluent generated during construction

As described in Section 10.3.3, there are no rivers, streams or other natural surface water bodies located on or directly adjacent to the existing greenfield site which would limit any potential impact on the water environment. However, there are some dry drainage ditches on the site which could infiltrate to ground and/or ultimately feed into an unnamed tributary of the Tolka River.

The construction phase of the development could also have an adverse impact if water demands during construction exceeded local water supply capacity resulting in loss of pressure, reduced supply etc. in the local area.


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

- Discharge of excessive quantities of cooking oil/grease to sewer from the on-site canteen

- 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

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pump, chemicals for the operation/maintenance of utilities equipment chemicals such as boiler water treatment chemicals and lubricating oils/greases 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 River Tolka 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.


Under a ‘Do Nothing’ scenario where there would be no change in land use and the impacts to the water environment would be minor as Phase 1 of the Alexion development is currently under construction.


Cumulative impacts include the potential for increased run-off at the site due to the addition of hard standing area on site as well as additional run-off from adjacent sites. However, this cumulative impact will be mitigated for the Alexion site and the adjacent sites (BMS and Montjeu) due to the SUDS approach taken at each site. Furthermore, the Alexion site and adjacent sites are located on lands zoned for industrial development with a public storm water discharge network.

There is an increase in potential for contamination of watercourses during both construction and operational phases. however, the proposed Phase 2 development and the proposed BMS and Montjeu applications will have CEMPs to reduce the potential for contamination during construction and operation. In addition, as these facilities are all likely to be licensed under the EPA during operation, mitigation measures and monitoring programmes will reduce the likelihood of any contamination being discharged to ground during operation.

Cumulative impact of waste water on the sewerage infrastructure is considered by the service provider, Irish Water, who have confirmed provision to accept the proposed effluent.



In order to effectively manage all potential environmental impacts during the construction phase, a Construction Environmental Management Plan (CEMP) will be implemented. The CEMP will set out the responsibilities, environmental standards and requirements for the duration of the construction phase of the project. This will include the necessary environmental controls and mitigation measure to prevent/mitigate any potential impact on the water environment.

The following mitigation measures will, at a minimum, be implemented during the construction phase;

- To minimise any impact on off-site surface waters arising from material spillages, all oils, solvents and paints used during construction will be stored within temporary bunded areas. Oil and fuel storage tanks will be stored in designated areas, and these areas will be bunded to a volume of 110% of the capacity of the largest tank/container within the bunded area(s) (plus an allowance of 30 mm for rainwater). Drainage from the bunded area(s) will be diverted for collection and safe disposal.

- Refuelling of construction vehicles and the addition of hydraulic oils or lubricants to vehicles, will take place in a designated area (where possible) of the site, which will be away from

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surface water gulleys or drains. In the event of a machine requiring refuelling outside of this area, fuel will be transported in a mobile double skinned tank. An adequate supply of spill kits and hydrocarbon adsorbent packs will be stored in this area. All relevant personnel will be fully trained in the use of this equipment. Relevant guidelines will be adhered to.

- Concrete will be mixed off–site and imported to the site. The pouring of concrete will take place within a designated area to prevent concrete runoff into the site surface water drainage network. Wash down and washout of concrete transporting vehicles will take place at an appropriate facility offsite.

- Silt traps will be installed on the surface water drainage system for the duration of the construction works for the purpose of removing any excess silt that runs-off to the surface water sewer system.


As discussed in Section 1.5, the proposed development will be applying for an Industrial Emissions Licence (IEL). Part II (9) of S.I. No. 137/2013 - Environmental Protection Agency (Industrial Emissions) (Licensing) Regulations 2013 sets out the statutory requirements for information to accompany a licence application. These requirements include the need for Treatment, Abatement and Control Systems for all emissions in accordance with the relevant BAT (see Section 1.5.3).

The site-wide mitigation measures and spill control programme that is proposed in accordance with IED 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.

The following mitigation measures will be implemented during the operational phase of the development to prevent/mitigate any adverse impacts on the water environment occurring.

Waste Water

As set out in Table 10.1, it is conservatively estimated that the average hydraulic load will be in the order of 1,060m3/day with occasional peak loading estimated up to 1,600m3/day. Similarly, the average BOD5 loading of the waste water is conservatively estimated to be in the order of 320kg/day with occasional peaks of up to 720kg/day.

Irish Water have confirmed that that the Ringsend WWTP (including current and planned extension and upgrade) has sufficient capacity to cater for the hydraulic and organic loading associated with the project.

Irish Water have also confirmed that sufficient hydraulic capacity is available in the sewerage system, from the point of discharge from the Alexion site via College Park and the sewer network, to Ringsend WWTP (subject to a requirement to provide 7 hours on-site storage during specified storm events) without compromising overall capacity.

The Fourth Schedule of the 1994 Urban Waste Water Treatment Regulations (as amended) specifies particular requirements for industrial waste water entering public collection systems and Urban Waste Water Treatment Plants. These requirements are outlined below in the context of Alexion’s proposed mitigation measures to ensure that all requirements are met:

Protect the health of staff working in collecting systems and treatment plants

- At no time will the treated effluent from the Alexion facility contain a substance or material in a quantity that could impact the health of local authority staff

Ensure that collecting systems, waste water treatment plants and associated equipment are not damaged

- The preliminary treated effluent from the Alexion facility will not contain any gross solids or other aggressive constituents that could damage the local authority sewer or treatment

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equipment. In particular, parameters such as pH, temperature, and sulphate will be controlled below levels that could impair the integrity of concrete sewers.

Ensure that the operation of a waste water treatment plant and the treatment of sludge are not impeded

- The treated effluent from the Alexion site will not contain materials or constituents that could impede the operation of the Ringsend WWTP including the treatment of sludge.

Ensure that discharges from treatment plants do not adversely affect the environment or prevent receiving waters from complying with other Community Directives

- The treated effluent from the Alexion site will not contain materials or constituents that cannot be readily treated in conventional municipal waste water treatment facilities to the standards required under all current Community Standards relevant to the receiving waters.

Ensure that sludge can be disposed of safely and in an environmentally acceptable manner

- The nature of the waste water discharged from the Alexion site will not impact on the ability to dispose of sludge from the Ringsend WWTP in a safe and environmentally friendly manner. In particular, the Alexion waste water will not affect the classification of the WWTP sludge in the context of the Waste Management (Use of Sewage Sludge in Agriculture) Regulations (SI No. 148 of 1998) as amended.

Storm Water / Surface Water (Rainfall) Runoff Management

There will be a single storm water discharge point from the facility for surface water runoff from paved / hard standing areas and building roofs on-site. Discharge of all surface water run-off will be to the existing 1050mm diameter surface drain at the south east of the site.

Surface water discharge from the site will be attenuated as per the requirements of Fingal County Council. The allowable discharge from the site has been calculated at a rate of 3.4 litres per second per hectare. This is the basis of design to be submitted for planning permission.

To restrict the outflow in accordance with this calculated site discharge, it is proposed to use a hydro-brake flow control device. Any flow greater than 3.4 l/s will be retained in the facility’s storm water attenuation pond.

On-site attenuation will minimise hydraulic loading and flooding of downstream water courses and lands. As stipulated in the Greater Dublin Strategic Drainage Study, no flood waters will be allowed to leave the site up to, and including, a 1 in 100 year storm event.

The proposed pipe network has been designed to accommodate a 1 in 2 year return period storm event, and has been checked for surcharging in the 1 in 5 year event, while flooding is checked for the 1 in 30 year and the 1 in 100 year storm event.

A Class 1 bypass oil separator will be installed on the surface water drainage line prior to the attenuation pond.

An emergency shut off valve will be installed at the end of the site surface water drainage system to allow automatic shut-off of the surface water sewer, upstream of its point of connection to the external public surface water sewer and downstream of the on-site attenuation pond.

These measures will ensure that only uncontaminated surface water at a controlled rate is discharged from the facility to the local authority surface water drain which ultimately discharges to the Tolka River.

Storage and Use of Polluting Materials

The facility will use and store quantities of potentially polluting materials on site during operation including:

- Cleaning chemicals which will be stored in contained areas/spill pallets

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- Diesel for the emergency generator and firewater pump which will be stored in individually bunded tanks

- Chemicals for the operation/maintenance of utilities equipment such as boiler water treatment chemicals and lubricating oils/greases etc. will be stored in individually bunded areas and/or spill pallets.

- Waste water storage tanks (5 no. 400m3) and neutralisation system vessels will all be contained in a reinforced concrete bund structure.

- The loading and unloading of chemical and fuel materials will be carried out in designated areas protected against spillage and leachate run-off.

- The drum storage building will be internally bunded to 25% of its storage capacity

The following measures will also be implemented in accordance with the anticipated requirements of the site IEL requirements:

- A documented Emergency Response Procedure will be put in place before commencement of activity that addresses any emergency situation which may originate on-site.

- All tank, container and drum storage areas shall be rendered impervious to the materials stored therein. Bunds shall be designed having regard to Agency guidelines 'Storage and Transfer of Materials for Scheduled Activities' (2004). All tank and drum storage areas shall, as a minimum, be bunded, either locally or remotely, to a volume not less than the greater of the following:

o 110% of the capacity of the largest tank or drum within the bunded area; or

o 25% of the total volume of substance that could be stored within the bunded area.

- All drainage from bunded areas shall be treated as contaminated unless it can be demonstrated to be otherwise. All drainage from bunded areas shall be diverted for collection and safe disposal, unless it can be deemed uncontaminated and does not exceed the established trigger levels set for storm water emissions.

- All inlets, outlets, vent pipes, valves and gauges will be within the bunded area.

- All tanks, containers and drums will be labelled to clearly indicate their contents.

Therefore any potential leaks/spillage from these and any other potentially polluting materials will be fully contained locally to prevent discharge to the surface water drainage system.

Waste chemicals will not be discharged to drain; they will be collected and treated/disposed off-site by a licensed waste contractor in accordance with regulatory requirements.

Procedures will be in place in relation to the management of deliveries and transfer. Spill kits will be maintained on site at designated locations and a spill response procedure will be implemented during the operation of the facility to contain and clean up any leakages/spills of chemicals or other polluting materials.

Fuel/oil leaks from vehicles in the car park or other areas on site

A Class 1 bypass oil separator will be installed on the surface water drainage line prior to the attenuation pond which will retain any fuel/oil leaks in the surface water runoff. The separator will be inspected and maintained as part of the site preventive maintenance system.


Taking into account the mitigation measures described in Section 10.6, the predicted residual impact is long term imperceptible on the water environment. The mitigation measures described for the construction and operational phases will ensure the proper management of waste water, storm water/surface-water, potentially polluting materials and water-usage on site, to prevent any significant adverse impact on the water environment.

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11 Air Quality and Climate

11.1 Introduction

This chapter has been prepared for the purpose of assessing the likely air quality impacts associated with the construction and operational phases of the proposed development.


11.2.1 Desktop Assessment

A desktop assessment was carried out in order to describe the national and EU legislation in relation to air quality, and to describe the existing environment in the general area of the proposed development. The Irish Statue Book, EurLex and EPA website and relevant EPA publications and guidance were referenced in order to complete this assessment.

Prediction of the potential impacts on air quality due to the operation of the proposed facility has been carried out using computer based air dispersion modelling techniques.

The impact assessment is based on predicting the maximum resulting ground level concentrations of the relevant pollutant parameters, and with due regard to the existing air quality, ensuring that the essential Air Quality Standards for the protection of human health and the environment are maintained. The Air Quality Standards defined by Irish and European legislation are outlined in section 11.2.2 below.

A full technical assessment of potential impacts due to the construction activities has also been carried out. Mitigation measures to address both the construction and operational impacts have been established.

11.2.2 Ambient Air Quality Standards

Air Quality Standards (AQSs) for the protection of human health and the environment have been developed at European level and implemented into Irish legislation for a number of atmospheric pollutants. AQSs set limit values for Ground Level Concentrations (GLCs) of certain pollutants for both the short term (hourly, daily) and long term (annual averages) averaging periods. Limit values are often expressed as percentiles e.g. 98 percentile of mean hourly values which means that only 2% of the results obtained during the monitoring period can exceed the stated limit value.

The following ambient air quality legislation is currently implemented in Ireland:

- Arsenic, Cadmium, Mercury, Nickel and Polycyclic Aromatic Hydrocarbons In Ambient Air Regulations 2009 (S.I. No. 58/2009) which implement EU Directive 2004/107/EC. These regulations set target values in ambient air to be attained, from 31 December 2012, for concentrations of arsenic, cadmium, nickel and benzo(a)pyrene (a measurable indicator of the level of polycyclic aromatic hydrocarbons) and also specify monitoring requirements for mercury and other polycyclic aromatic hydrocarbons.

- Air Quality Standards Regulations 2011 (S.I. No. 180/2011) which implement EU Directive 2008/50/EC on ambient air quality and cleaner air for Europe. This Directive merges most of the existing directives (Directives 96/62/EC, 1999/30/EC, 2000/69/EC and 2002/3/EC) into a single directive. The regulations set ambient air quality limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, benzene, lead and particulate matter (PM10/ PM2.5).

Emissions to the atmosphere from the proposed facility will potentially include some of the pollutants addressed in the above air quality legislation. Therefore the relevant air quality standards for this air quality assessment are detailed in Table 11.1.

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Table 11.1: Air Quality Standard (AQS) Limit Values

Pollutant AQS (µg/m3)*

Oxides of Nitrogen (NO2 / NOx)

NO2 99.8 Percentile hourly 200

NO2 Annual (Human Health Protection) 40

NOx Annual (Vegetation Protection) 3031

Sulphur Dioxide (SO2)

SO2 99.7 Percentile Hourly 350

SO2 99.2 Percentile Daily 125

SO2 Annual 20

Particulate Matter less than 10 µm (PM10)

PM10 Annual 40

Carbon Monoxide (CO)

CO 8-hour 10,000

Benzene (C6H6)

C6H6 Annual 5

Lead (Pb)

Pb Annual 0.5

*As specified in EU Directive 2008/50/EC / S.I. 180 of 2011


The characteristics of the proposed development in terms of air quality is described in Section 11.5.2


The existing environment has been described with reference to EPA air monitoring data for Ireland. The EPA publication Air Quality in Ireland 2013 Key Indicators of Ambient Air Quality was referenced in order to describe the existing air quality in the general area of the proposed development site.

31 The Regulations and Directive state that a sampling point targeted at the protection of vegetation and natural ecosystems shall be sited more than 20km from agglomerations or more than 5km away from other built-up areas, industrial installations or motorways or major roads with traffic counts of more than 50,000 vehicles per day, which means that a sampling point must be sited in such a way that air sampled is representative of air quality in a surrounding area of at least 1000 km2. Therefore the annual NOx limit for the protection of vegetation would not directly apply to the area in which the proposed development is located.

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11.4.1 Air Quality Zones

The EPA manages the national ambient air quality network.

The Air Framework Directive deals with each EU member state in terms of "Zones". The Air Quality Standards Regulations 2011 state “The Agency shall establish zones and agglomerations throughout the territory of the State for the purpose of air quality assessment and air quality management”. The zones and agglomerations are defined as follows:

- Zone A: Dublin Conurbation

- Zone B: Cork Conurbation

- Zone C: Other large cities and towns comprising Galway, Limerick, Waterford, Clonmel, Kilkenny, Sligo, Drogheda, Wexford, Athlone, Ennis, Bray, Naas, Carlow, Tralee, Dundalk, Navan, Letterkenny, Celbridge, Newbridge, Mullingar, Balbriggan, Portlaoise, Leixlip and Greystones.

- Zone D: Rural Ireland, i.e. the remainder of the State excluding Zones A, B and C

11.4.2 Ambient Air Quality

The EPA monitors ambient air quality at a number of locations throughout Dublin (Agglomeration A). Average annual mean ambient air quality data for 2013 for all the monitoring stations in Dublin is summarised in Table 11.2 below.

Table 11.2: Annual Mean Ambient Air Quality Data (2013)

Pollutant Parameter

Annual Mean Concentration (µg/m3)

Dublin (Zone A)

Nitrogen Dioxide (NO2) Hourly 19

Oxides of Nitrogen (NOx) Hourly 33

Sulphur Dioxide (SO2) Hourly 2.4

Carbon Monoxide (CO) 8-Hour 333

Particulate Matter (PM10) Daily 17

Particulate Matter (PM2.5) Daily 10

Ozone (O3) 8-Hour 51

Benzene Daily 0.94

Toluene 1.9

Ethylbenzene 0.31

M- and P-Xylene 1.48

O-Xylene 0.35

Lead (Pb) Monthly 3.4

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Pollutant Parameter

Annual Mean Concentration (µg/m3)

Dublin (Zone A)

Arsenic (As) Monthly 0.3

Cadmium (Cd) Monthly 0.2

Nickel (Ni) Monthly 2.3

Poly Aromatic Hydrocarbons (PAHs) Monthly

0.00047*

* Highest value reported for the individual PAHs (Naphthalene)

The EPA report Air Quality in Ireland 2013 Key Indicators of Ambient Air Quality states that overall, relative to other EU states, Ireland continues to enjoy good air quality which is largely due to the clean westerly air flow from the Atlantic, a small number of large cities and an industrial sector which is relatively clean and well regulated.

The ambient air quality monitoring results for Dublin in Table 11.2 are below the relevant air quality standard limit values (Table 11.1) for the majority of parameters listed, indicating reasonably good air quality. The monitoring results for NOx appear to exceed the annual limit value. The EPA report attributes high NOx levels to transport/vehicle emissions in urban centres.



The duration of the construction phase will be approximately 24 months and up to 1200 construction workers will be employed at peak.

Various construction activities on site could result in the generation of dust which could adversely impact ambient air quality including:

- Excavation and earthmoving activities

- Temporary stockpiling of excavated and imported materials (topsoil, overburden) on site

- Transportation of loose materials that are not properly contained

- Transfer of mud/soil from the wheels of construction traffic onto surrounding roads

It is probable that the majority of dust generated will be deposited within or close to the site boundary. A number of factors will affect the extent of dust generation and potential impacts on air quality including wind speed and direction, the dryness of the soil, and the proximity of sensitive receptors to the site.

The operation of construction equipment, mobile plant and the movement of vehicular traffic associated with site construction staff will result in exhaust emissions which could potentially impact on ambient air quality. These emissions, typical of all motorised vehicles and equipment, will include NO2, CO, PM10, Volatile Organic Compounds (VOC) and Benzene, along with limited quantities of SO2 from the use of diesel fuel.

Therefore, in the absence of adequate management and mitigation measures, the construction phase of the development could have a short-term adverse impact on ambient air quality as result of dust generation and vehicle emissions.

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Potential emissions to atmosphere from the operating facility are considered under the following headings:

- Boiler and emergency generator emissions

- Volatile organic compounds (VOC) emissions

- Miscellaneous emissions (HVAC extracts, firewater pump and WWTP)

It is to be noted that there is no potential for the release of mammalian cells to the environment via the atmosphere. Venting of the vessels will be filtered at source as well as secondary filters on the single vent to atmosphere using 0.2 micron filters.

Boilers

Heating is required for the proposed development for the HVAC (Heating, Ventilation and Air Conditioning) system, domestic hot water, and radiator heaters. This heating will be provided using gas-fired boilers. 3 No. 5.6MW high efficiency gas-fired steam boilers (2 duty and 1 stand-by) will be installed as part of the proposed development. 4 No. 1.2MW LPHW (low pressure hot water) boilers (3 duty and 1 stand-by) will be installed for hot water distribution.

It is proposed to install the boiler plant within the CUB. The boiler flues shall be externally located on the outside of the building, supported in a purpose built steel cradle. The boilers will emit combustion exhaust gases containing NO2 and CO to atmosphere.

Emergency Generators

4 No. 2,500kVA standby generators will be installed to provide emergency power in the event of a failure of the electricity mains supply. They will be used for emergency cover only and not for peak shaving. Under normal circumstance, they will be run for short periods, estimated at one to two hours per week, for test purposes. Low sulphur diesel (maximum 0.1% sulphur by mass) will be used as a fuel for the emergency generator. When operational, the emergency generator will emit combustion exhaust gases containing NOx/NO2, CO, SO2 and particulates to atmosphere.

Volatile Organic Compound (VOC) Emissions

Organic solvents will only be used in relatively small quantities at the proposed development in media and buffer solutions. The process is aqueous based so no large volume solvents are used. The only solvent used in the purification process is an 18% solution of ethanol which will give rise to low level fugitive emissions only. These emissions will vent to a single release point on the building. There may also be some fugitive emissions from the use of IBCs containing ethanol. These ethanol emissions are expected to be minor.

Extract Air Vents from HVAC system

There will be extract air vents located throughout the facility which will emit spent fresh air which has been utilised in the building(s) HVAC system.

Firewater Pump

A fire hydrant ring main will be provided around the perimeter of the buildings. The ring main will be fed from a new firewater storage tank and associated pump house located at the east of the proposed development. The firewater pump will not be run during normal operation other than for testing purposes (ca. 30 minutes per week). Low sulphur diesel (maximum 0.1% sulphur by mass) will be used as a fuel for the firewater pump. When operational, the firewater pump will emit combustion exhaust gases containing NOx/NO2, CO, SO2 and particulates to atmosphere.

Waste Water Treatment Area

Waste water treatment for the proposed development will only involve primary treatment prior to being sent to the local authority sewer system. Primary treatment will include effluent collection,

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and flow balancing, and pH neutralisation. Therefore it is not anticipated that malodourous emission will occur.

Air Dispersion Modelling

For the purposes of assessing the emission from the facility the only major emission to atmosphere will be from the steam boilers on-site. Therefore air dispersion modelling has been undertaken on all boiler on-site, including those that will be installed in the Phase 1 development, which is currently under construction. In total 7 No. gas fired boilers are included in the model. An Air Dispersion Modelling Report (PM Group Document No. IE0311488-22-RP-0003) is included in Appendix F, which details in full the assessment of air emissions from the site boilers.

In the Air Dispersion Modelling Report the maximum predicted ground level concentrations (GLCs) have been compared against the relevant AQS limit values to assess the impact of atmospheric emissions from the proposed facility on ambient air quality, human health and the environment. Table 11.3 summarises these results with the predicted pollutant emissions (including background values) expressed as a percentage of the AQS.

Table 11.3: Summary of Air Dispersion Modelling Results

Pollutant Description

Predicted Concentration

(Facility Contribution)

(µg/m3)

Total Conc.: Background + Predicted

(µg/m3)

Air Quality Standards (AQS)

(µg/m3)

Predicted Total Conc. as

Percentage of AQS

Nitrogen Oxides

1 hr NO2 (99.8%ile)

26.8 64.8 200 32%

Annual NO2

(Human Health

Protection)

2 21 40 53%

Carbon Monoxide

8 hr CO 12 345 10,000 3.5%

As can been seen from Table 11.3 the maximum predicted ground level concentrations (GLCs) of NO2 and CO arising from boiler emissions from the proposed facility are well below the relevant Air Quality Standards (AQSs).

Therefore it is predicted that the impact to ambient air quality from the proposed facility will be negative, long-term but imperceptible.


Should this development not proceed it is considered most likely that a development of some similar nature would establish in the short to medium term on these lands. Any such broadly similar development would be likely to have a generally similar impact on the surrounding environment.


There are two planning applications which have been recently submitted for new facilities in the general area of the proposed development. These are the proposed BMS biopharmaceutical manufacturing plant (Planning Ref. FW15A/0043), and the proposed Montjeu Ltd. biopharma facility (Planning Ref. FW15A/0038). For the purposes of this EIS these facilities will be considered for cumulative impacts with the proposed development in relation to NO2 and CO emissions.

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A methodology has been developed by the USEPA, which can be adapted for use in Ireland, in order to determine whether a nearby source needs to be included in an air dispersion modelling assessment. The approach is outlined in the EPA Guidance document AG4, and is known as the Prevention of Significant Deterioration (PSD) and it is based on allowing a specific incremental release from each installation. It can be viewed as the maximum relative increase in concentration which is allowed to occur for each pollutant from each installation in the region where emissions overlap significantly. The USEPA does not require a full cumulative assessment for a particular pollutant when emissions of that pollutant from a proposed source do not increase ambient levels by more than the significant ambient impact level. The guidance states that an increment of 25% of the Air Quality Standard (AQS) should be used for assessing impacts at all locations in Ireland, this can be seen in Table 11.4.

Table 11.4: PSD Increments as applied to Air Quality Standards

Pollutant Averaging Period PSD Increment (as a % of Air Quality

Standards)

PSD Increment as applied to EU

Standards (µg/m3)

NO2 Annual 25% 10

1-Hr 25% 50

CO 8-Hour 25% 2,500

Table 11.5 outlines in summary the worst case predicted concentrations of NO2 and CO for both facilities mentioned above and also for the proposed development.

Table 11.5: Summary of Emissions from Proposed Facilities

Facility and Pollutant

Averaging Period Predicted Concentration

(µg/m3)

Predicted Concentration as %

of Air Quality Standards

Montjeu – NO2 Annual 6.7 17%

1-Hr 48.1 24%

BMS – NO2 Annual 4.3 11%

1-Hr 36.1 18%

BMS – CO 8-Hour 48.7 0.5%

Proposed Development – NO2

Annual 2 5%

1-Hr 26.8 13%

Proposed Development – CO

8-Hour 12 0.1%

The incremental increase as a percentage of the respective Air Quality Standard for each modelled pollutant and respective averaging period is below 25%. Therefore, a cumulative impact assessment does not need to be undertaken as the cumulative impacts from the aforementioned installations will not be significant. This is in accordance with the methodology outlined in Appendix F of AG4.

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In order to effectively manage all potential environmental impacts during the construction phase, a CEMP will be implemented. The CEMP will set out the responsibilities and environmental standards & requirements for the duration of the construction phase of the project. This will include the necessary environmental controls and mitigation measure to prevent/mitigate any potential impact on ambient air quality.

As part of the CEMP, the following specific mitigation measures will be put in place to minimise any dust generation and thus prevent any significant impact on air quality:

- Good housekeeping and site management including the proper storage of spoil / loose materials on site

- Hard surfaced roads will be swept to remove mud and aggregate materials from their surface. Any unsurfaced roads will be restricted to essential site traffic only, apart from the contractor’s car park which will be hard-core only

- Vehicles using site roads will have their speed restricted, and this speed restriction will be enforced rigidly

- Damping of site roads as necessary

- Wheel washing facilities will be provided for heavy vehicles exiting the site in order to ensure that mud and other wastes are not tracked onto public roads.

- Public roads outside the site will be regularly inspected and cleaned as necessary

- Proper containment of loose materials that are transported on or off site

- All vehicles and combustion equipment (e.g. generators, pumps etc.) will undergo appropriate inspection and maintenance to ensure proper functioning

- No outdoor burning will occur on-site


Given the results of this assessment and the fact that it is predicted that there will be no significant impact to the air environment due to the proposed development, it is not required to employ specific mitigation measures in order to minimise or eliminate potential impact.

The proposed development will be designed to the highest specification in line with BAT thus ensuring that atmospheric emissions from the facility will not result in an impact to human health or the environment. The boilers have been specified so that as a minimum the pollutant emissions for each boiler, as specified in the Air Dispersion Modelling Report (Appendix F), will not be exceeded.

The proposed development will be governed by an Industrial Emissions Licence (IEL) from the EPA. Part II (9) of S.I. No. 137/2013 - Environmental Protection Agency (Industrial Emissions) (Licensing) Regulations 2013 sets out the statutory requirements for information to accompany a licence application. These requirements include the need for Treatment, Abatement and Control Systems for all emissions. The site-wide mitigation measures that are proposed in accordance with the IED (Industrial Emissions Directive 2010/75/EU, transposed into Irish law by S.I. 566 of 2012) will apply during the operation phase.


As construction phase impacts will be temporary in nature there will be no residual impact resulting from the construction phase post mitigation.

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Furthermore, given the fact that there are no significant impacts predicted for the operational phase of the proposed development, there are no predicted significant residual impacts as a result.

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12 Waste Management

12.1 Introduction

This chapter describes the anticipated types and quantities of wastes that will be generated from the Phase 2 development and also outlines the waste management policies, practices and programmes that will be employed at the proposed development. This chapter should be read in conjunction with Chapter 2 (Description of the Proposed Development), Chapter 7 (Soils, Geology & Hydrogeology) and Chapter 10 (Water & Effluent) of this EIS.

The site of the proposed Phase 2 development is located at College Park, Blanchardstown, Dublin 15. Information regarding waste generation and management derived from the planning, design and construction of the Phase 1 development at the same site has been used to inform the consideration of potential impacts arising from the Phase 2 development.


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 following guidance documents:

- Environmental Protection Agency (EPA) Guidelines on the Information to be Contained in Environmental Impact Statements

- EPA Advice Notes on Current Practice (in the Preparation of EIS)

A review of the operational wastes types generated by Alexion was undertaken. This data was used to estimate waste types that will be generated from the construction and operational phases of the proposed development. An extensive document review was completed to assist in identifying current and future requirements for waste management and included:

- National Policies and Strategies such as:

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

o National Strategy on Biodegradable Waste, Do EHLG, 2006.

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

o Directives and Statutory Instruments such as:

o Waste Management Act 1996 (as amended)

o Local Government Act 1994 (as amended) and regulations

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

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

o Litter Pollution Act 1997 (No. 13 of 1997)

o Directive 2010/75/EU of the European Parliament and of the council of 24 November 2010 on industrial emissions (integrated pollution prevention and control)

o Environmental Protection Agency National Waste Database Reports

- Codes of Practice and Guidelines such as:

o Best Practice Guidelines on the Preparation of Waste Management Plans for Construction and Demolition Projects, DoEHLG, 2006

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o Construction and Demolition Waste Management – a handbook for Contractors and Site Managers, 2002

- Local Authority Plans such as:

o Waste Management Plan for Eastern and Midlands Region 2015-2021 (currently in draft)


The characteristics of the proposed Phase 2 development with regard to the waste management are outlined as follows:

12.3.1 Construction Activities

The construction phase will involve initial site clearance and preparatory works for the construction of the manufacturing building, CUB, warehouse, waste water treatment area and external utilities. The development will include initial cut and fill works, followed by the construction of the buildings.

Cut and fill works will result in the generation of approximately 82,500m3 of excavated material. The design intention is that material excavated during the site clearance and preparatory works will be reused on site where practicable. If not, excess spoil material will be transported off-site by a licensed waste contractor to a suitably permitted facility.

The construction phase will typically result in the generation of a range of waste materials including excavated material, rubble, steel, metal decking, cladding, insulation materials, timber, plastics, cardboard packaging, office waste, canteen waste, and small quantities of hazardous waste (e.g., resins, adhesives and paint containers).

A site specific C&D Waste Management Plan will be implemented for the proposed development in accordance with the C&D Waste Management Guidelines. The C&D Waste Management Plan will be part of the overall Construction Environmental Management Plan, which will be put in place by the Construction Management Team for the entirety of the construction activities. The plan will include specific detail on waste segregation and disposal. This document will be a live document and will be subject to revision throughout the course of the construction phase. The plan will include specific details on the projected waste types and subsequent management, as described in Table 12.1.

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Table 12.1 Projected Construction Waste Types and Description

Waste Name EWC Code Description

Non Hazardous

Timber 17 02 01 It is expected there will be timber waste generated from material off-cuts, used cable drums, damaged pieces and wooden pallets and crates used for deliveries to site. Timber that is uncontaminated, i.e. free from paints, preservatives, glues etc.,

will be segregated at source and stored in dedicated skips for recycling.

Glass 17 02 02 A designated skip will be provided for any broken or other waste glass, which can then be recycled. The nominated Waste

Manager will liaise with the appointed waste contractor(s) to establish any specific segregation requirements for waste glass (e.g. by colour or type).

Plastic 17 02 03 Plastic generated will be primarily from packaging and material off-cuts. All recyclable plastic will be segregated at source

and stored in dedicated recycling skip.

Cardboard 20 01 01 Excess cardboard will be generated from shipping containers, boxes, packing material etc. Cardboard will be flattened and

placed in designated covered recycling skip on site to prevent it getting wet.

Metals (including their alloys)

17 04

Metals will be segregated into mixed ferrous, cladding, aluminium, high grade stainless steel, low grade stainless steel etc. Metals will be segregated at source and stored in dedicated skips. Steel panels are comprised of composite metal and non-

metal materials bonded together and are therefore more difficult to recycle; these will be taken off-site for specialist shredding, metal recovery and conversion of the residual to fuel used for energy generation at suitably licensed facilities.

Insulation materials, e.g. piping and ducting,

insulation panels, etc. 17 06 04 Insulation materials will be separated and placed in designated covered recycling skip on site to prevent it getting wet.

Concrete 17 01 Any concrete generated is expected to be clean, inert material and it is proposed to reuse it for construction purposes where

possible.

Waste Electrical and Electronic Equipment

(WEEE)

20 01 35

08 03 17

This will consist of electrical equipment out of date or damaged. The WEEE Directive 2012/19/EU and associated Waste Management (WEEE) Regulations 2014 have been enacted to ensure a high level of recycling of electronic and electrical equipment. It is the manufacturers’ responsibility to take back the WEEE, regardless of whether a replacement product is purchased or not. Any electrical or electronic equipment will be taken back by the suppliers. A receptacle will be available

for WEEE

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Waste Name EWC Code Description

Soil and stones other than those mentioned in 17 05

03 17 05 04

If there is any excess inert soils and subsoils excavated that is not required for use as fill on site it will be re-used offsite. The soil will be removed and disposed of by a licensed waste contractor.

Hazardous

Hydraulic oils 13 01*

Liquid waste will be stored in drums in a designated bunded area of the construction compound. When the level of the tank reaches a predetermined level, the waste contractor will be notified, prepare the necessary paperwork and obtain the

required approvals before transporting the waste liquid off site.

Engine, gear and lubricating oils

13 02*

Liquid Fuels 13 07*

Oil wastes not otherwise specified

13 08*

Insulation materials, e.g. piping and ducting,

insulation panels, etc. 17 06 03*

These will be transferred to a specialised container in the waste storage area and taken off site by a licenced waste contractor.

Paints, inks, adhesives, resins

20 01 27-28* These will be transferred to a specialised container in the waste storage area and taken off site by a licenced waste

contractor.

Absorbents, filter materials, wiping cloths and protective

clothing 15 02*

All disposable PPE or any material will segregated from non-hazardous waste and disposed of in designated waste receptacles. All wipes and cloths used in the event of spills on site will be treated as hazardous waste and will be managed

accordingly.

Soil and stones containing dangerous substances

17 05 03*

As the site is greenfield it is unlikely, however if any soil encountered is deemed to be contaminated (i.e. non-hazardous or hazardous), it will be stored separately to the inert material, sampled and tested, in order to appropriately classify the

material as non-hazardous or hazardous in accordance with Council Decision 2003/33/EC before being transported to an appropriately licensed facility by permitted contractors.

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12.3.2 Operational Activities

The operation of the facility will result in the generation of a range of wastes. These will include both hazardous and non-hazardous wastes. Wastes produced on site will be segregated at source. Table 12.2 is a summary of anticipated hazardous and non-hazardous wastes arising at the Alexion Facility.

As discussed in Section 1.5, the proposed development will be applying for an Industrial Emissions Licence (IEL). Part II (9) of S.I. No. 137/2013 - Environmental Protection Agency (Industrial Emissions) (Licensing) Regulations 2013 sets out the statutory requirements for information to accompany a licence application. These requirements include the need for detailed measures in relation to the management of waste on site in accordance with the relevant BAT (see Section 1.5.3).

The site-wide mitigation measures and spill control programme that is proposed in accordance with the site IEL 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.

It is estimated that 50-60 tonnes/annum of general non-hazardous waste will be produced during the operational phase. It is the intention of Alexion that at least 85% of non-hazardous waste will be recycled/recovered.

Disposable waste materials such as production bags, tubings and spent filters that potentially have been in contact with the manufacturing process cell culture material will be treated on-site in autoclaves to render them inactive and classified as non-hazardous waste. These materials will be stored for collection and transported off-site by a licensed waste contractor for offsite disposal as non-hazardous waste.

One of the advantages of using biotechnology processes for the production of human medicine products is the relatively small quantity of hazardous waste produced when compared to facilities using synthetic chemical processes. The latter can produce many thousands of tonnes per annum (principally solvents) whereas it is expected that the proposed facility will produce hazardous waste in the order of 10-15 tonnes per annum.

Some of the empty material drums and containers used to store process raw materials may be classified as hazardous waste. The majority of drums and containers of this nature will be returned to the original suppliers for cleaning, recovery and reuse. Some containers may be sent to specialist waste contractors for appropriate cleaning and recovery under waste licence.

Laboratory waste chemicals will be segregated where possible and stored in a designated chemical store in suitable labelled containers. These wastes will then be collected by a licensed waste contractor for recovery or disposal at an appropriate EPA and Alexion approved licensed hazardous waste management facility. Quantities of raw materials found to be out of date or off-specification arise from time to time. This material will be returned to the supplier, where possible.

As with any industrial facility, standard hazardous wastes such as fluorescent tubes, batteries, oils, etc. will arise from time to time. These wastes will be stored and managed as hazardous waste. Under licensed waste management contract, these wastes will be sent for recovery or recycling.

The anticipated management of operational waste is summarised in Table 12.2.

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Table 12.2 Projected Operational Waste Types and Description

Waste Name EWC Code

Description

Non Hazardous

Timber 20 01 38 Pallets, packing crates etc. Disposed of in designated timber collection containers. Timber that is uncontaminated,

i.e. free from paints, preservatives, glues etc., will all be recycled.

Paper and Cardboard 20 01 01 Confidential paper disposed of in secure “Shred-It” containers located throughout the facility. Collected by

contractors and shredded onsite. Shredded paper transported off site for recycling. Cardboard shipping containers, boxes, packing material etc. disposed of in designated cardboard compactors on site.

Plastics 20 01 39 Plastic will be generated from site construction projects and Industrial activities, general dry waste and contractor

waste. Drums from raw materials associated with media and buffer make up. All recyclable plastic will be segregated at source and stored in dedicated skips

Metals 20 01 40 Metals will be segregated into mixed ferrous, cladding, aluminium, high grade stainless steel, low grade stainless

steel etc. Metals will be segregated at source and stored in dedicated skips.

Waste Cooking Oil 20 01 25 Storage drum provided for used cooking oil which will be contained within a designated bund or on a spill pallet.

Glass 20 01 02 Glass generated from staff members in the staff canteen and laboratories e.g. Winchesters. To maximise recycling

efficiency, glass will be separated by colour (green, clear and brown).

Waste Electrical and Electronic Equipment (WEEE)

20 01 35

08 03 17

This will consist of electrical equipment out of date or damaged. The WEEE Directive 2012/19/EU and associated Waste Management (WEEE) Regulations 2014 have been enacted to ensure a high level of recycling of electronic

and electrical equipment. It is the manufacturers’ responsibility to take back the WEEE, regardless of whether a replacement product is purchased or not. Any electrical or electronic equipment will be taken back by the suppliers.

A receptacle for WEEE awaiting collection is located in the waste storage area.

Mixed Packaging 15 01 06 Packaging materials segregated if possible into different waste types e.g. cardboard and plastic. If not then

disposed of in residual waste containers as dry mixed recyclables

Compost 20 01 08 Organic waste from the canteen will be segregated for separate collection. Segregation at source and separate

collection of organic waste is required in accordance with the Waste Management (Food Waste) Regulations 2009. Waste printer and toner

cartridges 18 01 00 Receptacles to be provided in the admin areas for disposal of printer and toner cartridges.

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Waste Name EWC Code

Description

Mixed Municipal Waste 20 03 01 Mixed waste including canteen waste and general refuse

Wastes whose collection and disposal is not subject to

special requirements in order to prevent infection

18 01 04 Disposable clothing and PPE.

Inactivated Bio hazardous Waste 07 05 14 Waste from the manufacturing process and laboratory activities that was in contact with biological agents but has

been inactivated using a verified inactivation method e.g. autoclaving. Waste will be sent for a total destruction method off site.

Water treatment waste – exchange resins 19 09 05 Waste resin from clean water systems e.g. water softeners and anion exchange resins

Hazardous

Waste Liquids and waste oils

11 01 06*

06 01 06*

13 07*

Waste liquids will be stored in the relevant containers e.g. steel, Polyethylene or steel with Polyethylene liner. The appointed contractor will be notified, prepare the necessary paperwork and obtain the required approvals before

transporting the drums off site.

Empty packaging containing residues of or contamination by

dangerous substances 15 01 10*

Rejected, returned, unused raw materials will be stored in the original container or appropriate secondary container. This will be stored in secure collection area and segregated according hazard classification

Wastes whose collection and disposal is subject to special

requirements in order to prevent infection

18 01 03* These include Sharps containers, used agar plates or any potentially infectious material, equipment or PPE. Packaged in UN approved boxes, appropriately labelled and stored in a secure area awaiting collection by a

licensed waste contractor.

Product contaminated waste 18 01 06*

The volume of product contaminated waste will be small. This will include all API, placebo, inactivated production bags, tubing, filters, disposable PPE or any material, except sharps and used agar plates, generated and having had direct or the potential for product contact. Waste will be segregated and packed into dedicated bins or UN

approved drums or fibreboard boxes. Any waste collected in bins will be subsequently re-packaged into UN approved drums/boxes. The drums/boxes will then be taken to the dedicated hazardous waste storage area prior to

loading onto a shipping container for transportation offsite.

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Waste Name EWC Code

Description

Fluorescent tubes and other mercury containing waste

20 01 21* Any waste fluorescent tubes generated will be collected for hazardous disposal by a suitably licenced waste

contractor.

Paints, inks, adhesives, resins 20 01 27- Transferred to a specialised container in the waste storage area and taken off site by a licenced waste contractor.

Detergents 20 01 29- Transferred to a specialised container in the waste storage area and taken off site by a licenced waste contractor.

Batteries 20 01 33-

34* Prior to disposal, battery terminals/contacts will be taped to prevent contact. All batteries will be double bagged and

transferred to dedicated battery boxes for storage pending collection and transfer offsite.

Interceptors Sludges 13 05 03* Oily water and sludge from oil interceptor

Passivation Waste (Corrosive Waste)

16 10 01* Waste corrosive and detergent solutions from commissioning activities

Empty and partial empty paint containers

15 01 10* Paint Tins

Laboratory waste

(organic halogenated solvents)

(other organic solvents)

07 05 03*

07 05 04*

06 01 06*

Assay waste from laboratory activities Waste liquids will be stored in the relevant containers e.g. steel, Polyethylene or steel with Polyethylene liner. The appointed contractor will be notified, prepare the necessary

paperwork and obtain the required approvals before transporting the drums off site.

Miscellaneous process items (Solid Waste contaminated with

Active Pharmaceutical Ingredients (API)), IPA or

dangerous substances

07 05 13* Contaminated with API and/or dangerous substances Waste material will be stored in the relevant containers e.g. steel, Polyethylene or steel with Polyethylene liner. The appointed contractor will be notified, prepare the necessary

paperwork and obtain the required approvals before transporting the drums off site

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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.

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) and launched its Draft Waste Management Plan 2015/2021 in November 2014. The final waste management plan will be published by the end of March 2015.

Alexion’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.


The potential impacts to waste management from the proposed development are considered in this section.


Table 12.3 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 12.3 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.


Table 12.4 lists the activities which will be undertaken during the operational phase, 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 12.4 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 Long-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.


In the absence of the proposed development the existing environment will remain the same in the short to medium term. Waste will be generated as part of the Phase 1 construction phase and operational phase.


The cumulative impact of all known developments in the vicinity of the Phase 2 development has been considered. These facilities would be likely to have similar impacts arising from the generation of waste materials (i.e. neutral and imperceptible) provided appropriate mitigation measures are implemented.


Proposed mitigation measures for both the construction phase and the operational phase are highlighted in the following sections.


In order to minimise the potential impacts identified in Table 12.3, the mitigation measures highlighted in Table 12.5 will be implemented.

Table 12.5 Mitigation Measures during the Construction Phase

Potential Impacts Mitigation Measures

Targets outlined in the Waste Management Plan for Eastern and Midlands

Region will not be achieved.

A site specific C&D Waste Management Plan for the construction phase of the proposed development will be prepared to ensure effective waste management and recycling of waste generated at the site. Mitigation measures that will be implemented during the construction phase are summarised as follows and will be described in more detail in the C&D Waste Management Plan: The use of unlicensed or

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non-permitted waste contractors could give rise

to inappropriate management of waste and

result in environmental impacts/pollution.

• A Waste Manager will be appointed by the construction contractor to oversee and take ownership of the waste programme to ensure compliance with the C&D WMP.

• On-site segregation of all non-hazardous and hazardous waste materials into appropriate categories

• All non-hazardous waste materials will be transferred to skips or other suitable receptacles in designated waste storage areas.

• All hazardous waste will be packaged in appropriate UN approved receptacles and stored in dedicated hazardous waste storage areas pending transportation off site.

• All waste storage areas will be audited regularly to ensure the wastes are being segregated and stored in accordance with the C&D WMP.

• 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 site will be recycled, recovered or reused where possible, with the exception of those waste streams where appropriate facilities are currently not available.

• All waste leaving the site will be taken by suitable 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.

If waste is not managed and stored correctly, this

may lead to litter or pollution issues on the site

or adjacent sites.


Alexion will be applying to the EPA for an Industrial Emissions Licence (IEL). Part II (9) of S.I. No. 137/2013 - Environmental Protection Agency (Industrial Emissions) (Licensing) Regulations 2013 sets out the statutory requirements for information to accompany a licence application. These requirements include the need for Treatment, Abatement and Control Systems for all emissions in accordance with the relevant BAT (see Section 1.5.3). The site-wide mitigation measures and spill control programme that is proposed in accordance with IED will apply during the operational phase.

In order to minimise the potential impacts identified in Table 12.4, the mitigation measures highlighted in Table 12.6 will be implemented.

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Table 12.6 Mitigation Measures during the Operational Phase


Targets outlined in the Waste Management Plan for Eastern and Midlands

Region will not be achieved

The EHS manager will serve as the Waste Manager and will be the point of contact for all matters relating to the characterisation and management of waste. The primary responsibilities of the waste manager include:

• All wastes will be managed in accordance with IEL conditions e.g. Environmental Management Systems (EMS), Hazardous Waste Programme Manual and Waste Management Procedures. These would be subject to audits (both corporate and regulatory) thereafter.

• Ensure that personnel involved in the management of waste are qualified and trained to perform job specific duties

• Liaise with personnel, contractors and regulators on all waste /certification matters

• Ensure that waste is properly packaged and labelled according to the type of waste.

• Ensure that waste is properly segregated and the waste being shipped meets the appropriate waste acceptance criteria.

• Ensure that waste is disposed of in a manner compliant with all regulations and standards of practice.

• Ensure that copies of licenses for all approved disposal locations used by the waste contractor are on file.

• Further, the waste contractor shall be subject to audits by Alexion personnel to verify compliance with regulations and standards.

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.

12.7 Residual Impact

The mitigation measures detailed in Section 12.6 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 Alexion’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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13 Material Assets

13.1 Introduction

Material assets comprise the physical resources in the environment, which may be of human or 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 Alexion site and which may be directly affected by the proposed development, are addressed below in terms of existing environment, impacts and mitigation measures. Any material assets addressed elsewhere in this EIS are listed below for cross referencing purposes.

Information already gathered from the planning, design and construction of the current Phase 1 development have been incorporated and updated to inform the consideration of potential impacts on material assets from the proposed Phase 2 development.

Material assets of natural origin which have been considered include:

- Geological Resource – Refer to Chapter 7 (Soils, Geology and Hydrogeology) and Chapter 12 (Waste Management)

- Undeveloped Land Resource – Refer to Chapter 4 (Human Environment)

- Natural Amenities – Refer to Chapter 4 (Human Environment)

- Designated Areas – Refer to Chapter 5 (Landscape and Visual) and Chapter 8 (Flora and Fauna)

- Scenic routes – Refer to Chapter 5 (Landscape and Visual)

Material assets of human origin which have been considered include:

- Public Utilities – Refer to Chapter 2 Description of the Proposed Development) and Chapter 10 (Water and Effluent)

- Transport Infrastructure – Refer to Chapter 6 (Traffic and Transportation)

- Land Use, Property, Recreational Facilities and Amenities – Refer to Chapter 4 (Human Environment)

- Cultural Heritage – Refer to Chapter 14 (Archaeology, Architecture and Cultural Heritage)


The assessment was carried out according to the methodologies specified in EPA guidance documents. A desk study was carried out on the existing material assets associated with the site of the proposed development; this is a continuation of the desk study carried out as part of the Phase 1 assessment. The extent of services has been determined by records obtained largely from service/utility providers, FCC data, IDA Ireland data and existing mapping data.


13.3.1 Public Utilities and Natural Resources

Electricity

A number of overhead 10/20kV electricity lines that were previously on site have now been rerouted as part of the Phase 1 development.

The current ESB Networks supply terminates at an ESB Switch room at the southern end of the site. The adjacent MV Switch room supplies 2 no. Unit Substations (Admin & CUB) via MV ring

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main arrangement. The additional electrical infrastructure envisaged for Phase 2 will be accommodated in the new CUB and adjacent yard north of the Manufacturing Building. This will cater for the following:-

- Increased incoming 10kV supply from ESB Networks as outlined above.

- 10/20kV Main MV Switchboard (adjacent to ESB Networks Switch room).

- 10/20kV Non-Essential MV Switchboard, supplying Non-Essential A+B Unit Substations throughout the site as necessary.

- 10/20kV Essential MV Switchboard, supplying Essential A+B Unit Substations throughout the site as necessary.

- 10/20kV Critical MV Switchboard, supplying Critical A+B Unit Substations throughout the site as necessary.

Natural Gas

An existing 125mm, 4 bar Bord Gais pipeline is located at the south of the site. The facility’s internal gas main will be serviced from the proposed above ground installation (AGI), which will be designed and constructed by Bord Gais Networks. An area at the south east of the site has been dedicated for this purpose.

Two options are currently being investigated with Bord Gáis:

- Upgrade the existing Phase 1 AGI model G650 with a larger model.

- Retain the existing AGI G650 model and provide a new gas connection and AGI at the north of the site to serve Phase 2.

Water

Details in relation to water resources available at the proposed site are provided in Chapter 10, (Water and Effluent) of this EIS.

Telecommunications

The proposed site is currently well serviced with respect to telecommunications lines for telephone and broadband services. A number of buried Eircom ducts pass the site at the northern end of the site (Cruiserath road). In addition a number of Eircom ducts are installed along the southern end of the site (IDA road, adjacent to the Institute of Technology Blanchardstown).


In consultation with all the relevant utility providers it has been confirmed that there are sufficient supplies of electricity, natural gas, telecommunications, water, and sewerage services available to serve the requirements of the proposed development.


There will be minimal use of natural resources during the construction phase. There will be no requirement to import any soil. 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.


During the operational phase there will be resource requirements for the production process in particular natural gas, electricity and potable water. Energy efficiency and water conservation measures will be incorporated into the detailed design of the facility. This is a continuation of what was proposed as part of Phase 1 and is a very positive environmental aspect of the project.

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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. An operational risk assessment and associated mitigation measures is included in Section 13.5.

In relation to both the construction phase and the operational phase the potential impact of the proposed Phase 2 development on Material Assets is considered to be Long term –Slight-Negative.


Mitigation measures associated with material assets assessed in other chapters are described in the respective chapters.

There will need to be consultation with the ESB, Bord Gais Éireann (BGE), Fingal County Council, Eircom, Irish Water and other relevant service providers within the locality during the construction planning phase of the project to ensure construction proceeds without disruption to the local and business community.

The following requirements are likely to arise from the consultations:

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

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

In relation to the use of natural resources there will be comparatively low use of fuel, electricity, natural gas and potable water during the construction phase. Resources consumed will mainly include use of fuels for construction related machinery, electricity to light the site and power construction tools and gas to heat the buildings. On-site segregation of all waste materials will take place; see Chapter 12 (Waste Management). It will be a priority to source materials from locations close to the site, where possible, in order to reduce transport distances. Site lighting will be on a timer / photovoltaic / sensor system and on low lux for after hours.

During the operational phase there will be resource requirements for manufacturing, principally electricity, natural gas and potable water. In this regard the facility is being designed to incorporate the following resource efficiency and sustainable measures:

- The site proposes to use clean natural gas fuel only for steam generation.

- The site proposes to use best available technologies for steam generation with direct digital combustion control, oxygen trim and heat recovery through economisers and flash steam recovery. A high level of condensation recovery will also be implemented.

- Harvesting of rainwater from building roofs for domestic type reuse will be implemented where feasible to reduce water usage.

- Recirculated air for Heating Ventilation and Air Conditioning (HVAC) will be utilised, where possible

- Attention will be given to the required room volumes as this generally drives airflow and AHU sizing.

- Optimise air changes to achieve required Cleanroom Grade with the manufacturing building.

- Use of 30% to 60% cleanroom relative humidity range (to reduce operating costs).

- Capability for night setback of cleanroom HVAC.

- Use of pressure independent 2-port control valves for HVAC chilled and heating systems with pump VSDs.

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- Energy efficient Air Handling Units (AHUs) and the use of primary/secondary AHU configuration.

- Capability to reduce fan motor speeds via Variable Speed Drive (VSDs).

- Premium efficiency (IE3) motors.

- Attention to pressure drop through in-line fittings e.g. coils, filters, CAVs / VAVs etc.

- Accurate (diversified) load profiling critical to avoid oversizing.

- Water cooled compressors and chillers (more efficient than air cooled).

- Heat recovery from air compressors, glycol chillers, WFI, pure steam generator, process waste, condensate vent recovery etc. to generate reduced temperature heating distribution for HVAC e.g. 45 oC / 35 oC (compared to conventional 80 oC / 60 oC) + condensing boilers. Also within the Steam boiler package all boilers have flue gas economisers to preheat the boiler feed water along with VSD burners. Majority of steam condensate (>90%) is also recovered.

- Increased chilled water temperature for HVAC e.g. 8oC / 15 oC (compared to conventional 6 oC / 12 oC)

- Heated compressed air absorption dryers (not heatless).

- VSD technology for HVAC chillers and air compressors

- Consideration of part load efficiency in utility plant selection.

Through on-going consultation with the relevant utility providers for the supply of water, natural gas and electricity to the proposed facility, it has been confirmed that there is sufficient local capacity available to accommodate the proposed development in College Park, without compromising the ability to maintain existing and planned future supplies in the area either locally or regionally.

Operational Risk Assessment

As the site will have an IEL a risk assessment was carried out to assess the potential environmental hazards that could impact on natural resources during the operational phase. Table 13.1 shows the potential impacts and the mitigation measures proposed.

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Table 13.1 Operational risk assessment and associated mitigation measures

Scenario Potential Impact Mitigation Measures to be Taken

Leak or spill when loading and unloading of materials on site

Leak or spill during loading/unloading of drums, IBCs or other containers containing hazardous

and/or polluting materials. Potential to discharge to surface water and/or ground.

1. Loading/unloading areas bunded and/or designed to contain accidental releases

2. Routine inspection of all drums and containers delivered to site

3. Best practice operational procedures for loading/unloading of materials. 4. Site spill response procedure

Storage and handling of hazardous and/potentially polluting materials on site

(e.g. drum store raw materials, diesel, engineering materials - hydraulic oil,

lubricants etc.)

Leak or spill to surface water, ground or groundwater from storage and handling of hazardous and polluting materials on site

1. Any hazardous materials stored in appropriately designed sealed containers.

2. Emergency generator will be bunded. 3. Routine inspection/maintenance of bunded

areas, tanks, containers, equipment & pipework 4. Best practice operational procedures for

handling of materials 5. Site spill response procedure

Spill/leak from bulk liquid storage tanks Failure of tank resulting in spill of contents to surface water, ground water and/or ground.

Adherence to the conditions assigned in the IEL. Regular inspection and monitoring undertaken in

accordance with IEL

Failure from bunded areas Loss of bund integrity. Direct discharge of

contents to ground//surface water


accordance with IEL

Spill from vehicles onsite Leaks of fuel, oil etc. from vehicles to surface

water, ground or groundwater

1. Paved roads and car parks on site which drain to site surface water runoff drainage system

2. Oil/petrol interceptor on surface water drainage system

3. Periodic inspection/cleaning of interceptor 4. Routine inspection/maintenance of operational

vehicles e.g. forklifts

Production Process Spillages during the production process.

Contained within production area.


accordance with IEL

Movement of process (trade) effluent onsite to waste water treatment area

Loss of pipeline integrity. Leaks from drains and discharges/spills of process effluent to surface

water, ground or groundwater

1. Process effluent collected in process drainage system and sent to waste water treatment area for pre-treatment prior to discharge to local authority

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sewer and then Ringsend WWTP 2. Continuous monitoring of process effluent prior

to discharge to local authority sewer 3. Periodic inspection/maintenance

Movement of foul and sanitary effluent on-site to waste water treatment area

Loss of integrity. Leaks from drains and discharges/spills of foul and sanitary effluent to

surface water, ground or groundwater

1. Foul and sanitary effluent discharged to local authority foul sewer which drains to Ringsend

WWTP 2. Periodic inspection/maintenance of pipework and

on site pumping station

Discharge of rainfall/storm water runoff from roofs and paved-areas on site

Discharge of excessive volumes of storm water containing excessive suspended solids and/or

hazardous materials

1. Trigger levels to be established and monitored as part of IEL.

2. Site attenuation pond has shut off valve for containment on-site.

Operation of Boilers and associated air abatement systems

Failure of abatement, release of unabated emissions to atmosphere in excess of Emission

Limit Values (ELVs).

1. Modern efficient plant and equipment designed in accordance with BAT and air dispersion

modelling has shown no significant adverse impact on air quality

2. Annual monitoring at emission point (s) 3. Routine inspection/maintenance of equipment as

part of site maintenance management system

General operational activities including plant operation, use of process and mechanical equipment and traffic

movement on site

Excessive noise generated on site and at noise sensitive locations off site

1. Noise criteria specified for all plant and equipment as part of design and procurement

process 2. Plant will be designed not to exceed limits at

noise sensitive locations specified in IEL. 3. Noise modelling has indicated facility will not

have any significant adverse impact at noise sensitive locations

4. Plant and equipment will be suitably serviced and maintained

5. Periodic ambient noise monitoring will be carried out.

Gas Tank Yard Leak or pipe rupture leading to fire or explosion

1. Above ground installation designed, installed and maintained by utilities company / Gas Networks

Ireland 2. Gas pipework is designed, installed and

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inspected to appropriate standard

Fire at the facility Emissions to air, firewater discharge to ground,

surface water and/or groundwater

1. Fire detection will be installed throughout facility. 2. Sprinkler system

3. Buildings designed into separate fire compartments.

4. Site emergency response procedure

Unauthorised disposal of hazardous/non-hazardous waste

Improper classification of waste for purpose of disposal/recovery. Discharges/spills of waste

materials to surface water, ground or groundwater. Incorrect handling procedures by

contractor.

Adherence to the conditions assigned in the IEL. Regular inspection and monitoring undertaken in accordance with IEL and proposed Environmental

Management System

Failure of waste water treatment area Failure of treatment resulting in untreated effluent

discharge to sewer in excess of Emission Limit Values (ELVs). Impact on Ringsend WWTP.


Management System

Monitoring and control systems Failure of on-site monitoring control systems.

Release of hazardous emissions to air, surface water and/or waste water.


Management System

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The site has been designed for, and the infrastructure provided for, a development of this nature and scale. The mitigation measures outlined in Table 13.1 will be implemented as part of the site IEL.

The overall predicted impact of the proposed Phase 2 development, taking Phase 1 into consideration, can be classed as long term but neutral with respect to material assets.

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14 Archaeology, Architecture and Cultural Heritage

14.1 Introduction

This chapter assesses and evaluates the potential impacts of the proposed development on the archaeology, architectural heritage and cultural heritage of the site and surrounding area. This chapter should be read in conjunction with the Chapter 2 (Description of the Proposed Development) and Chapter 5 (Landscape and Visual) of this EIS.

The proposed development will be constructed on the existing College Park site, where Phase 1 is currently under construction.

The Phase 1 development at the same site is currently under construction. Information derived from the planning, design and construction of the Phase 1 development has been used to inform the consideration of potential impacts on archaeology, architecture and cultural heritage arising from the proposed Phase 2 development.


14.2.1 General

The assessment of the potential impact of the proposed development on Archaeology, Architectural Heritage and Cultural Heritage was carried out according to the methodologies specified in Environmental Protection Agency (EPA) guidance documents32,33.

The NRA criteria34 for rating the magnitude and significance of impacts at EIA stage on cultural heritage sites are also relevant in determining impact assessment and are presented in Table 14.1. This table provides the baseline criteria used to describe the impacts that potential developments can have on cultural heritage sites.

Table 14.1 Criteria Used to Determine Impacts on Cultural Heritage Sites

Magnitude of Impact Direct Indirect

Severe

Cultural Heritage site is within a proposed development area.

Construction work will entail the removal or part of the entire

cultural heritage.

Cultural Heritage site is within a proposed development area.

Construction works will entail the destruction of the visual context of

the site or isolate it from associated groups or features.

Potentially Severe

Cultural Heritage site is adjacent to a proposed development area.

There is potential for related remains being affected by

development works.

Cultural Heritage site is adjacent to a proposed development area.

Construction works will greatly injure the visual context of the site

or isolate it from associated groups or features.

Moderate

Existing access to a cultural heritage site will be severed.

Development works will affect the context of a cultural heritage site.

N/A

No Predicted The proposed development will

have no predicted impact. N/A

32 EPA (2002), Guidelines on the Information to be Contained in EISs 33 EPA (2003), Advice Notes on Current Practice (in the Preparation of EISs)

34 NRA (2003), Guidelines for the Assessment of Archaeological Heritage Impacts of National Road Schemes

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In order to set the study area within its wider archaeological, architectural and cultural heritage landscape, a comprehensive desk top study of all available written and cartographic sources was undertaken. Using this information, the likely impact of the proposed development on the archaeological, architectural and cultural heritage has been evaluated.

14.2.2 Desktop Study

This is a document and cartographic survey utilising a number of sources in order to identify all known archaeological sites and other monuments of historical interest within the study area. The principal sources used for identifying archaeological monuments are described below.

Record of Monuments and Places

The Record of Monuments and Places (RMP) is a list of archaeological sites known to the National Monuments Service of the Department of Arts, Heritage and the Gaeltacht (DoAHG) with accompanying RMP maps, based on the first and second editions of the OS 6” Sheets, which indicate the location of each recorded site. The list is based on the Sites and Monuments Record (SMR) files which are kept in the National Monuments Service and are updated on a regular basis. The Sites and Monuments Records (SMR) are lists with accompanying maps and files of all known archaeological sites and monuments mainly dating to before 1700. These lists were initially compiled from cartographic, documentary and aerial photographic sources.

National Museum of Ireland Topographical Files

The find spots of artefacts can provide valuable information on the archaeological potential of an area. The National Museum of Ireland Topographical Files is the national archive of all known antiquities recorded by the museum and consists of a catalogue of objects reported to that institution since 1928. These files mostly contain information on finds but there are also references to monuments and sites of archaeological significance. A record of all previous archaeological excavations undertaken in Ireland is also available from the National Museum. The National Museum of Ireland Topographical records contain no records of any archaeological artefacts in the curatorship of the state from the Buzzardstown townland.

County Development Plans

County and City Development Plans are made in accordance with the requirements of the Local Government and are an important source for identifying protected structures. The plans set out each council’s policy for the conservation and enhancement of a county’s natural and built environment and lists items of special environmental or archaeological interest. Fingal County Development Plan (2011-2017) and Fingal Heritage Plan (2011-2017) were both consulted. The County Development Plan includes a Record of Protected Structures (RPS), which is a list of buildings which may not be altered or demolished without grant of permission under the Planning and Development Act 2000, as amended.

Cartographic Sources and Aerial Photography

The 1st and 2nd editions (6”and 25”) of the Ordnance Survey maps for the area were consulted as well as the OSI aerial photography which can be accessed online at www.osi.ie. A review of the historic mapping for the study area did not highlight any other sites of archaeological or cultural heritage significance within the study area.

Excavations Bulletins

Excavations Bulletins are annual bulletins which contain summaries of all licensed excavations undertaken in Ireland from 1985 to 2015. The database is available on at www.excavations.ie.

14.2.3 Field Survey

As part of the Phase 1 development, which is currently under construction, an EIS was submitted with the planning application. The EIS included a full archaeology, architecture and cultural heritage impact assessment. The scope of the survey, carried out by Margaret McCarthy MA MIAI Consultant Archaeologist in December 2013, included the full site, i.e. the lands on which the

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proposed Phase 2 development will be sited. Therefore a further survey of the site is not required for the proposed Phase 2 development.


A description of the development is included in Chapter 2 (Description of the Proposed Development) and includes details of the construction works, and the various individual buildings, car parking, roads, landscaping and services.


The lands are located within the parish of Mulhuddart in Buzzardstown townland whose name is derived from the former Anglo-Norman occupants of the area. The east boundary to the proposed development forms the townland boundary between Buzzardstown and Ballycoolen. The site comprises three substantial tillage fields which had been harvested at the time of the field inspection. The fields are gently undulating and slope gradually to the east. The lands are bound to the north by Cruiserath Road, to the south by the IDA College Business and Technology Park and to the east and west by agricultural land. The site of the proposed development is currently a construction site for the development of Phase 1 of the proposed campus. Large scale business and enterprise developments are prevalent in the area as well as residential housing.

14.4.1 Previous Field and Desktop Study

Extensive assessments were carried out a part of the planning application for College Park Phase 1. The following extracts are taken from the 2014 EIS for Phase 1 in order to detail the impacts, mitigation measures and residual impacts identified at that time.

14.4 Impact Assessment

Impact on recorded archaeological monuments and architectural heritage

There are no recorded archaeological monuments or architectural heritage within the study area therefore no impacts are predicted on the existing archaeological or architectural heritage. The nearest recorded archaeological monuments to the site are a mound (DU013-023), a holy well (DU013-009) and a church and graveyard (DU013:001-2). These are located a considerable distance from the study area and there will be no direct or indirect impact on the monuments.

Impact on previously unknown archaeological features

It is anticipated that the greatest potential impacts on archaeological heritage will arise during large scale removal of topsoil at the initial construction phase.

In order to prevent accidental damage to any archaeological resource, including any potential sub-surface archaeological finds or features, the following mitigation measures are proposed.

Targeted archaeological testing will be carried out in this section of the study area focusing in particular on the locations of the proposed buildings. Testing will not be required in any other sections of the study area as it is not proposed to develop these lands as part of this planning application. The test excavation will be carried out under licence prior to the commencement of any development works at the site and the results will be submitted to the National Monuments Service, DoAHG and the National Museum of Ireland for review.

14.5.2 Phase 1: Construction Phase Mitigation

The greatest potential impact of the proposed development on the archaeological heritage of the surrounding landscape will be during the removal of topsoil. Topsoil stripping, soil storage, movement of heavy machinery and excavation of foundation and service trenches can all have a permanent, damaging effect on the archaeological resource. Throughout the development site it is possible that buried archaeological features may exist below ground level and therefore all topsoil removal operations will be fully monitored by a qualified archaeologist. The archaeologist will require an excavation licence for this work to be issued by The National Monuments Service, Department of Arts, Heritage and The Gaeltacht (DAHG) and approved by the National Museum of Ireland (NMI). The time-scale for the construction phase will be made available to the archaeologist at an early stage with information on where and when topsoil stripping will take place.

The monitoring archaeologist will be empowered to halt the development if buried archaeological features or finds are uncovered. If archaeological remains are encountered, these sites become an archaeological site

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and are protected by the National Monuments legislation. Further work on the site would then require consultation with the archaeological staff of The National Monuments Service, Department of Arts, Heritage and the Gaeltacht.

Provision, including finances and time, will be made to facilitate any excavation or recording of archaeological material that may be uncovered during the developmental works. The excavations will be undertaken in compliance with any measures that the DAHG and the National Museum of Ireland deem appropriate.

As part of the pre-construction activities intensive test trenching of the full site was carried out. This was done so that the requirement for a monitoring archaeologist during the earthwork would not be required, in agreement with National Monument Section of the DoAHG.

14.4.2 Archaeological Test Trenching

Pre-construction archaeological test trenching was carried out by Irish Archaeological Consultancy (IAC) Ltd, on behalf of PM Group for Alexion in April 2014. Figure 14.1 shows the locations of the test trenching. The full details of the test trenching are included in the IAC report in Appendix G. A programme of intensive trenching was used in order to ascertain the potential impact of the proposed Phase 1 development on the archaeological resource that may exist within the development area. Test trenching commenced at the site on 28th April and lasted for three days. This was carried out using two mechanical excavators equipped with flat, toothless buckets, under strict archaeological supervision. A total of 39 trenches, measuring 7,419 linear metres, were mechanically investigated across the test area, which measured c. 16.8 hectares.

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Figure 14.1 Test Trenching Locations35

Two areas of archaeological significance were identified during the program of testing; a group of pits including a possible charcoal-production kiln (Area 1) and a single, possible cremation pit (Area

35

IAC (2014), Archaeological Assessment at College Business & Technology Park, Snugborough Road, Blanchardstown, Dublin 15

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2). With the exception of those two areas nothing of archaeological significance was uncovered. The mitigation measures recommended by IAC were as follows (extract from IAC report):

“We recommend the following actions in mitigation of the impacts above.

- It is recommended that archaeological Areas 1 and 2 be subject to preservation by record in advance of any development works. Excavation areas measuring 25m by 15m (Area 1) and 10m by 10m (Area 2) should facilitate the preservation by record of all features identified in the test trenches. Excavation should be undertaken by a licence eligible archaeological in consultation with the National Monuments Service of the DAHG.

- As the proposed development area was subject to intensive test trenching with limited archaeological findings it is recommended that monitoring of the ground works through the construction phase is not necessary.”

The necessary excavations and recording of the identified archaeological areas was carried out by IAC on 14th and 15th May 2014 under licence. A report of the excavations was issued in November 2014 to the National Monuments Service of the DoAHG.

14.4.3 Archaeological Excavation Report

IAC carried out archaeological excavations as required under the mitigation measures outlined in the test trenching report. The work was carried out by IAC for PM Group on behalf of Alexion under licence 14E141 in May 2014. Full details of the excavations are outlined in the IAC report included in Appendix G.

Two areas were excavated within the south-west corner of the development area. The three spreads recorded in Area 1 were identified as non-archaeological in origin.

A single pit was recorded in Area 2 which contained a small quantity of charcoal, seed and burnt bone. It was not possible to determine if the bone remains represented animal or human bone due to the condition and size of the fragments. Analysis of the seed and charcoal indicated cereal-drying activity was on-going in the vicinity however no in situ burning was recorded during the current excavation. The pit, which appeared to contain domestic refuse, has been dated to the early medieval period.



There are no further potential impacts to the site area that has been intensively tested, as this area has now been fully resolved in terms of archaeology.

There is a small area of land to the north of the site above test trench no. TT34 (see IAC test trenching report in Appendix G) which was not tested and is now proposed for development. There is the potential that unknown areas of archaeology may be present in that location and may be uncovered during the earthworks phase of construction. In respect of direct impacts therefore, construction works proposed for Phase 2 could have a negative impact on any potential sub-surface archaeological features and artefacts that may survive within that small area on-site, without appropriate controls measures.


There is no predicted impact to archaeology or architectural heritage during the operational phase of the development.


In the ‘Do Nothing’ scenario, there would be no impact on the archaeological heritage as there would be no opportunity to establish the nature and extent of potential sub-surface archaeological features.

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No cumulative impacts are noted


In order to prevent accidental damage to the archaeological landscape, including any potential sub-surface archaeological finds or features, the following mitigation measures are proposed:


In terms of mitigating the potential impact in the northern part of the site that was not previously tested, it is proposed that during earthworks in that area all topsoil removal operations will be fully monitored by a qualified archaeologist. The archaeologist will require an excavation licence for this work to be issued by The National Monuments Service, DoAHG and approved by the National Museum of Ireland (NMI). The time-scale for the construction phase will be made available to the archaeologist at an early stage with information on where and when topsoil stripping will take place.

The monitoring archaeologist will be empowered to halt the development if buried archaeological features or finds are uncovered. If archaeological remains are encountered, these sites become an archaeological site and are protected by the National Monuments legislation. Further work on the site would then require consultation with the archaeological staff of The National Monuments Service of the DoAHG.

Provision, including finances and time, will be made to facilitate any excavation or recording of archaeological material that may be uncovered during the developmental works. The excavations will be undertaken in compliance with any measures that the DoAHG and the NMI deem appropriate.


No mitigation measures are proposed for the operational phase.


The greatest potential impact of the proposed works on the archaeological heritage of the area is to hitherto unknown archaeological features. The works proposed for Phase 2 could have a negative archaeological impact on undisturbed areas of ground in the northern part of the site which has not been tested previously. Construction phase archaeological monitoring of topsoil removal in that area will ensure the full recognition and recording of any buried finds or features. There will be no residual impact on the archaeological and cultural heritage resources after the proposed mitigation measures have been implemented.

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15 Interactions and Cumulative Impacts

15.1 Introduction

An important aspect of assessing the environmental impacts associated with any 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 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.

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.

Indirect impacts are impacts on the environment which are not a direct result of the project, produced some distance from the project or as a result of a complex pathway.

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.


This section of the EIS has been prepared in accordance with the EPA ‘Guidelines on the information to be contained in Environmental Impact Statements’, 2002 and with the EPA ‘Advice Notes on Current Practice (in the Preparation of Environmental Impact Statements)’, 2003.


Phase 1 of the College Park development i.e. the construction of a 5 storey office building and roof top plant room, QC laboratories, packaging / warehouse, utility building and spine corridor and a Data Centre was granted planning permission by Fingal County Council (FCC) in May 2014 (See Planning Ref. FW14A/0020 for application documents and accompanying Environmental Impact Statement (EIS)), with a further grant of planning permission for certain changes to Phase 1 granted in January 2015 (Planning Ref. FW14A/0138).

The scope of this construction project will be complete before commencement of Phase 2.

The remaining Greenfield lands within College Park are zoned for high technology/high technology manufacturing type employment in a high quality built and landscaped environment and their development is consistent with the economic development and spatial planning policies of Fingal County Development Plan.

Figure 15.1 shows the relevant planning permissions in the environs of the Alexion site, this highlights that the vast bulk of development lands and relevant proposals are located to the north of the site. Planning permissions in other areas surrounding the site are generally of smaller scale, reflective of the built up nature of these areas.

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Figure 15.1 Relevant planning permissions in the environs of the Alexion site

From Figure 15. It can be seen that there are 2 no. significant proposed developments identified in the surrounding area:

- Montjeu: Proposed Biopharmaceutical Manufacturing Facility, College Business & Technology Park, Cruiserath Road, Blanchardstown, Dublin 15 (Planning Reference: FW15A/0038). The Montjeu application site boundary adjoins the Alexion site to the North West.

- Bristol Myers Squibb (BMS): Proposed Biopharmaceutical Manufacturing Facility, Cruiserath Road, Blanchardstown, Dublin 15 (Planning Reference: FW15A/0043). The BMS application is located on the Cruiserath Road, north-north east of the Alexion site. The proposed application will have a new dedicated site entrance on the east side (N2 link) of the existing BMS site.

In addition other applications in the vicinity of the proposed Alexion Phase 2 development include proposed residential developments (Planning References: FW15A/0009 and FW15A0108) and a proposed Data Centre (Planning Reference: FW14A/0152). In terms of cumulative impact these are considered less significant due to the nature and scale of the developments.

At the date of issue of this EIS, there are no other known projects in the vicinity of the Alexion site, although it is not entirely possible to ascertain the timing or scale of all future development as this is largely dependent on private sector initiatives. Accordingly, it is considered that the assessment of impacts associated with the proposed Phase 2 development has taken full account of the prevailing environmental effects associated with all other existing, planned and reasonably foreseeable activities in the area. Similarly, the proposed measures for the mitigation of impacts and the quantification of residual impacts take due regard of all other impacts arising from local sources.

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If the proposed Phase 2 works are not carried out there can be no impact from construction and operation of the proposed Phase 2 development however the following works will be carried out in the area:

The proposed permitted Alexion Phase 1 biopharmaceutical facility is currently being constructed and includes a proposed 2015 operational opening year and a total of 290 operational staff. Details of the proposed permitted Alexion Phase 1 biopharmaceutical facility operational traffic have been established on the basis of the EIS submitted to FCC.

The proposed BMS Biotech facility includes a proposed 2017 operational opening year, a total of 500 staff, 450 staff maximum on-site at any one time and a new dedicated staff access on the east (N2 link) side of the existing BMS site.

The proposed adjacent Montjeu biopharmaceutical development includes a 2016 operational opening year, 87 operational staff and access on Cruiserath Road.


This section considers the cumulative impacts that the proposed Phase 2 development could cause through interaction with current developments in the area, as well as the construction and operation of future developments in the area. The assessment considers other projects planned at the Alexion site and known developments in proximity off-site having potential to cause 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 operation of the proposed Alexion facility, including the use of utilities, and the generation of waste and waste water, 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 (Irish Water, ESB, Bord Gais, FCC etc.) have been/will be consulted as appropriate in relation to provision of these services for the proposed development.

Chapters 4-14 of the EIS contain specific sections on the cumulative impacts associated with each topic.

15.4.3 Indirect Impacts

The proposed Phase 2 development will lead to a number of indirect spin-off employment opportunities through local contractors, service providers and suppliers.

Off-site treatment and disposal of the wastes and waste waters generated could have a potential indirect impact on air, soil, surface water, and groundwater quality at the off-site treatment/disposal sites. However as discussed in the relevant chapters of the EIS these activities will be carried out by licensed operators and contractors in accordance with regulatory requirements and therefore will have an imperceptible negative impact only.

15.4.4 Interaction of Impacts

This section addresses potential interactions between the various impacts identified in the individual chapters of the EIS. Table 15.1 shows a matrix of the environmental disciplines and where potential interactions can occur. The introduction section of each chapter in the ES highlights the interactions with the other chapters.

These potential interactions have been examined and a number of areas have been identified where further consideration is required in addition to the potential impacts dealt with in the individual chapters. These are addressed in the following sections.

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Landscape and Visual & Human Beings

The visual impact of the proposed development has the potential to impact on human beings resident in the locality. However this potential impact is mitigated by the following factors:

- As much as possible of the existing hedgerow and trees on the site will be retained to provide screening and additional landscaping will be employed to enhance the appearance of the development.

Traffic & Landscape and Visual Impact

As stated in Chapter 6 (Traffic and Transportation), there will be on average approx. 545 construction personnel on-site on a given day rising to a peak of approximately 1263 during the busiest periods of construction including the mechanical and electrical building fit-out. This will result in additional cars and construction vehicles passing along the local road network which may cause minor visual disruption to pedestrians and local residents living and working in the vicinity.

However as the site is within an area zoned for industrial and commercial activity, HGV and large vehicle movements are common in the area. The surrounding environment is not considered to be visually sensitive to the sight of construction components, plant or vehicles. Mitigation measures have been designed for the safe and orderly flow of traffic through the surrounding road network, including a proposed construction route plan. The mitigation measures advised in Chapter 6 (Traffic and Transportation) will ensure there is no driver delay or queues resulting in adverse visual impact of construction vehicles parking or idling outside the site boundary.

Traffic & Air / Water / Noise

The additional traffic generated in the locality as a result of the proposed Phase 2 development will have an imperceptible negative impact on local air quality and surface water runoff quality due to vehicle emissions. The additional traffic will also have a slight negative impact on the noise environment at the designated NSLs during both the construction and operational phases. The effects of traffic and construction noise will be a temporary impact which will decrease in magnitude as the building work is completed and construction activities move indoors.

Soils, Geology, Hydrogeology & Water and Effluent

Chapter 7 (Soils, Geology & Hydrogeology) of the EIS has considered the potential effects of the proposed development on below ground features of the environment including soils, subsoils and hydrogeology. Chapter 10 (Water and Effluent) of the EIS has considered emissions to water and demands on the local water resources. Construction activities including excavation, material storage, surface water runoff management have the potential to cause impacts common to both. For example an accidental spillage at the excavation site may result in contamination of surface water and groundwater.

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Table 15.1 Matrix of Environmental Disciplines & Interactions

Interaction Human

Environment Landscape

& Visual Traffic &

Transportation

Soils, Geology &

Hydrogeology

Flora & Fauna

Noise & Vibration

Water & Effluent

Air Quality & Climate

Waste Managem

ent

Material Assets

Archaeology

Human Environment

ü ü ü ü ü ü

Landscape & Visual

ü ü ü ü

Traffic & Transportation

ü ü ü

Soils, Geology & Hydrogeology

ü ü ü

Flora & Fauna ü ü ü

Noise & Vibration

ü ü

Water & Effluent

Air Quality & Climate

ü ü ü

Waste Management

ü ü

Material Assets ü ü ü

Archaeology ü ü

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Chapters 4 to 14 have identified mitigation measures relevant to the various assessment topics. The majority of potential impacts arising from the proposed Phase 2 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 Construction Environmental Management Plan (CEMP) to ensure all measures are implemented in a co-ordinated manner and no one measure is unduly priorities over another. An outline CEMP is prepared as part of this planning application.

Prior to the commencement of construction activities the final CEMP will be prepared for the proposed Phase 2 development 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 Principal 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 Phase 2 development. This will include detailed arrangements and plans for traffic and site logistics.

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

As part of the design and planning for this project, consultation has been held with all parties responsible for the provision of utility services to support the proposed Phase 2 development.


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

The potential for cumulative impacts as a result of emissions during the operational phase of the proposed Phase 2 development and other development proposals has been assessed. No significant impacts are considered likely to occur.

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Documents

9 Noise and Vibration