ABCO Marine - epa.ie · ABCO No: C20196 -MP 002 CEMP Page : 1 of 51 DAFM Killybegs Smooth Point Pier Extension Issue: REV 002 Date: 27/09/2019 ABCO MARINE Marine Civil Engineering

Construction Environmental Management Plan (CEMP)

ABCO No: C20196-MP-002- CEMP

Page : 1 of 51

DAFM Killybegs Smooth Point Pier Extension Issue: REV 002

Date: 27/09/2019

ABCO MARINE Marine Civil Engineering Specialist

ABCO Marine

ABCO Marine Ltd

282 Moira Road

Lisburn

Co Antrim

BT28 2TU

E [email protected]

T 028 9262 2731

www.abcomarine.co.uk

Document Number: C20196-MP-002-CEMP

Killybegs Smooth Point Pier Extension Construction Environmental Management Plan (CEMP)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:27

http://www.abcodivers.co.uk/



Page : 2 of 51


Date: 27/09/2019

CONTENTS

Document Control .......................................................................................................................................... 5

1.0 Environmental Management Plan...................................................................................................... 6

1.1 Project Introduction ....................................................................................................................... 6

1.2 Purpose of the CEMP ..................................................................................................................... 6

1.3 Environmental Control ................................................................................................................... 8

2.0 Pre-Construction Information ............................................................................................................ 9

3.0 Project Team ....................................................................................................................................10

3.1 Identification of Roles ..................................................................................................................10

3.1.1 Contact details .............................................................................................................................12

3.2 Induction, Training and Briefing Procedures for Staff ..................................................................13

3.2.1 Environmental Site Induction ......................................................................................................13

3.2.2 Toolbox Talks and Daily Briefings.................................................................................................13

3.2.3 Environmental Actions and Commitments Register ....................................................................14

3.3 Key Environmental Legislation .....................................................................................................14

3.4 Understanding of EPA Dumping at Sea Requirements ................................................................15

3.5 Understanding of Planning Condition 17/51385 .........................................................................17

3.6 Protection of Sensitive Areas .......................................................................................................18

4. Ecology ......................................................................................................................................................19

4.1 Large Megafauna .........................................................................................................................19

4.2 Otters ...........................................................................................................................................20

4.3 Fisheries .......................................................................................................................................20

5. Monitoring of Construction Activities .......................................................................................................21

6. Control of Environmental RIsk ..................................................................................................................22

6.1 Dredging Unsuitable Material ......................................................................................................22

6.1.1 Spillage of Dredged Material into water ......................................................................................23

6.1.2 Spill and the Dredging Operation.................................................................................................23

6.2 Disposal at Sea .............................................................................................................................24

6.3 Offloading from Barge ..................................................................................................................25

6.4 Ecological Clerk of Works .............................................................................................................25

6.5 Marine Mammals .........................................................................................................................25

6.5.1 Operational Mitigation ................................................................................................................26

6.5.2 Marine Mammal Observer ...........................................................................................................26

6.5.3 Pre-Start Monitoring ....................................................................................................................26

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:27



Page : 3 of 51


Date: 27/09/2019

6.5.4 Mitigation Zone ............................................................................................................................26

6.5.5 Soft Start ......................................................................................................................................27

6.5.6 Breaks in Operations ....................................................................................................................27

6.5.7 Reporting .....................................................................................................................................27

6.6 Archaeology & Cultural Heritage .................................................................................................27

6.6.1 Excavation Strategy – Marine Dredge..........................................................................................28

6.6.2 Excavation Strategy - Shore .........................................................................................................28

6.7 Air Quality ....................................................................................................................................29

6.7.1 Dusts, Fibres and Particulates ......................................................................................................29

6.7.2 Emissions (CO²) ............................................................................................................................30

6.7.3 Gases, Vapours and Aerosols (including pathogens) ...................................................................30

6.7.4 Fires on Site ..................................................................................................................................31

6.8 Waste Management and Materials .............................................................................................31

6.9 Ground Conditions .......................................................................................................................31

6.10 Water ...........................................................................................................................................32

6.11 Visual Impacts ..............................................................................................................................33

7 Population and Human Health ..................................................................................................................34

7.1 Economic Activity .........................................................................................................................34

7.2 Social Considerations ...................................................................................................................34

7.3 Health and Safety .........................................................................................................................34

8. Environmental Monitoring Requirements ................................................................................................35

8.1 Marine Monitoring Sites ..............................................................................................................35

8.2 Phytoplankton & Zooplankton Monitoring ..................................................................................36

8.3 Benthic Monitoring ......................................................................................................................36

8.3.1 Benthic Sediment Survey .............................................................................................................37

8.3.2 Benthic Fauna ..............................................................................................................................37

8.3.3 Sediment Profile Imagery ............................................................................................................38

8.4 Water Quality Monitoring ............................................................................................................38

8.4.1 In-Situ Monitoring ........................................................................................................................38

8.4.1.1 Turbidity ....................................................................................................................................38

8.4.1.2 Dissolved Oxygen ......................................................................................................................38

8.4.2 Mobile Monitoring .......................................................................................................................39

8.4.3 Mitigation Measures ....................................................................................................................39

8.5 Noise & Vibration .........................................................................................................................39

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:27



Page : 4 of 51


Date: 27/09/2019

8.5.1 Noise ............................................................................................................................................39

8.5.2 Vibration ......................................................................................................................................41

8.6 General Prevention of Spillage .....................................................................................................42

8.6.1 Environmental Control within Laydown Areas ............................................................................43

9. Incident Prevention and Emergency Response ........................................................................................44

9.1 Summary of Procedures to be followed in the Event of an Environmental Emergency ..............44

9.2 Environmental Complaints, Spills & Incidents .............................................................................45

Appendix 1 – Accident Prevention Procedure ..............................................................................................46

Appendix 2 – Register of Environmental Actions & COmmitments (REAC) ..................................................47

Appendix 3 – Dredge Layout Plan .................................................................................................................48

Appendix 4 - Complaint/ Spills/ Incident Report ..........................................................................................49

Appendix 5 – Complaint/ Spills/ Incident Log ...............................................................................................50

Appendix 6 - Marine Mammal Recording Form ...........................................................................................51

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:27



Page : 5 of 51


Date: 27/09/2019

DOCUMENT CONTROL

PREPARED BY ABCO MARINE LIMITED IN THE ROLE OF PRINCIPAL CONTRACTOR

Issue / Date Status Prepared by Reviewed by Approved by

Rev001

24/09/2019 First Issue

Name:

Fionnuala Kerr Name: Ryan McDermott Name: John McGill

Signature:

Fionnuala Kerr

Signature:

Signature:

Rev002

27/09/2019 Revised after Client Review

Name:

Fionnuala Kerr Name: Ryan McDermott Name: John McGill

Signature:

Fionnuala Kerr

Signature:

Signature:

Issue details: Rev 002

Distribution:

Controlled copies: Rev 002 Uncontrolled copies: Rev001

Contract File: Site / Server Contractor: ABCO Marine

Originated by: Fionnuala Kerr Reviewed by: Ryan McDermott

Authorised for issue by:

This document will be routinely reviewed by the ABCO Project Manager and QHSE Director, with the report re-

issued after any revision or refinement as the project progresses.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:27



Page : 6 of 51


Date: 27/09/2019

1.0 ENVIRONMENTAL MANAGEMENT PLAN

1.1 Project Introduction

Killybegs Harbour is regarded as one of the largest fishing ports in Ireland, with approximately 45% of Ireland’s

total fish landings taking place at Killybegs Harbour Fisheries Centre. The Department of Agriculture Food and

the Marine (DAFM) seek to provide improved berthing facilities at Smooth Point to meet the demands of the

fishing industry in Ireland and allow the port to take on new opportunities in the oil and gas industry.

Due to the success of the harbour development in 2004, marine traffic associated with both commercial and

the fishing industry have increased significantly and consequently the demand for berthing now exceeds

available quay space at peak periods. The objective of the contract is to create an additional 120m of deep-

water quay to -9m CD allowing for sheltered, deep water, stern on berthage for fishing vessels in the location

of Smooth Point. Smooth Point is a naturally occurring gravel spit located to the western end of the north quay

at Killybegs FHC.

The works will involve:

▪ Capital Dredging of approximately 108,00m³ of silts gravels and rock to create the required berthing pocket

▪ Disposal of approximately 92,000m³ of dredged silts and gravels at sea under EPA Dumping at Sea Permit

▪ Stockpiling of approximately 18,000m³ of dredged rock on a site within the FHC

▪ Construction of new Combi Type Quay Wall and return wall

▪ Construction of piled relieving platform slab behind the quay wall

▪ Excavation of existing hinterland to achieve the payline stipulated on the drawings. This material will be stockpiled within the FHC and processed for re-use as site won 6A and 6N material in the permanent work

▪ Provisions for future retro fit of Ship to Shore Power including a future Isolating Transformer Building

▪ Installation of piles to support future construction of Isolating Transformer Building

The proposal to upgrade the existing Killybegs Harbour and associated Vessel Berths provides opportunities to

maximise the use of the existing infrastructure at the Harbour. It is considered that the proposed development

is consistent with objectives set out in the national and regional documents for sustainable developments.

1.2 Purpose of the CEMP

This document defines the Environmental procedures, work practices and management responsibilities

relating the marine operation during the delivery of the Killybegs Smooth Point Pier Extension project. This

plan fulfils the requirements of ABCO Marine’s (ABCO) environmental policy statement and has been

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:27



Page : 7 of 51


Date: 27/09/2019

prepared to include any environmental considerations brought to our attention by the Client. It should be

read in association with business unit policies and procedures, and Pre-construction Information where

applicable.

The development of a project specific environmental plan will flow from the ABCO Pre-Start Meeting Agenda

with sections amended, deleted or added as required.

The Project Manager is responsible for reviewing the proposed work processes and monitoring site activities.

The environmental implications of the project’s activities will be considered during design reviews, planning

meetings, method statement reviews and on site as part of the health, safety and environment inspections.

ABCO’s QHSE Director and Environmental Manager will provide environmental management guidance to the

project. Where necessary further advice may be sought from specialist external consultants.

The Objectives of the CEMP are to:

▪ Identify the key staff structures and responsibilities, and the environmental control and communication and training requirements

▪ Provide all the necessary guides in achieving the Project’s stated environmental objectives and targets;

▪ Ensure legal and contractual compliance by outlining procedures set for the management of all environmental issues envisaged with negative impacts at the project delivery phase

▪ Demonstrate how all operations required during the project delivery phase will be properly integrated to the requirements of environmental legislation, policy, good practice, and those of the environmental regulatory authorities and third parties;

▪ Record the objectives, commitments and mitigation measures to be implemented together with programme and date of achievement

▪ Provide a review, monitoring and audit mechanism to determine effectiveness of, and compliance with, environmental control measures and how any necessary corrective action will take place.

The CEMP is a live document for managing potential environmental risks and opportunities and provides the

framework for identifying environmental aspects and impacts associated with the Project and, therefore, will

be regularly reviewed and updated to take account of new information, changing external factors and

feedback from the review. ABCO are committed to constructing the Smooth Point Pier Extension without

compromising or depletion of natural resources, which is evident throughout the project. The CEMP has

been developed taken into account the importance of Killybegs Harbour to the local community, fishing

industry and economy.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:27



Page : 8 of 51


Date: 27/09/2019

1.3 Environmental Control

ABCO operate an integrated management system incorporating ISO:14001 Environmental, ISO:9001 Quality

and OHSAS:18001 Health and Safety management systems, that we use in conjunction with any additional

Client requirement / marine license and planning permit, for effective environmental management of the

project.

The performance of the site will be regularly checked via site inspections carried out by the QHSE Director

and senior personnel. All sites will:

▪ Comply with all relevant environmental legislation avoiding prosecutions for the contravention of environmental law and regulations

▪ Raise environmental awareness throughout the site management team and subcontractors by means of regular environmental tool box talks and awareness sessions

▪ Implement suitable and robust controls to achieve zero pollution incidents (emergency spills, noise /nuisance, water contamination, waste management issues, fire prevention) whilst maintaining an operational work site

▪ Implement the waste hierarchy: prevent waste where we can; reuse materials until we can’t use them again; recycle waste where reasonably practicable; recover waste (e.g. energy recovery); and only dispose of waste if no other options within the hierarchy are possible

▪ Identify and recognise all designated sites, preventing damage to existing buildings, fences, gates, walls, roads, paved areas and other site features, which are to remain in position during execution of the works. The site will instigate appropriate mitigation measures to ensure adequate protection and that minimum disturbance is caused.

BS EN ISO 14001:2015 Registration

ABCO Marine hold registration to BS EN ISO 14001:2015. The certificates can be made available on request.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 9 of 51


Date: 27/09/2019

2.0 PRE-CONSTRUCTION INFORMATION

The following information was provided to ABCO Marine help inform the development of the CEMP:

▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Natura Impact Statement: Screening Report (NIS)

▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Volume 1

▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Volume 2 Drawings and Figures

▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Volume 3 Technical Appendices

▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Non-Technical Statement

▪ Department for Agriculture, Food and the Marine - Dumping at Sea Permit – Permit Reg No. S0028-01

▪ Monitoring Plan for Dredging & Disposal Operations for Killybeg Harbour – Aquafact International Services Ltd - September 2016

▪ Planning Conditions 17/51385

▪ Article 11 Declaration No.2167

▪ Specification Requirements

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 10 of 51


Date: 27/09/2019

3.0 PROJECT TEAM

3.1 Identification of Roles

The environmental manager that has been appointed for this project is:

Name: Fionnuala Kerr

Email: [email protected]

The environmental manager may delegate duties to appropriate members of the site team however all project

staff have a responsibility to work in accordance with the CEMP, from the senior management down to all

operatives. Sustainability and environmental protection are core values; therefore, all staff will lead by

example, setting the highest standards for environmental management practice and performance.

All personnel will be inducted prior to the commencement of every operation, in which they are to act

immediately to correct any non-conforming practice or behaviours and promote environmental awareness,

good environmental behaviours and continuous improvement at every opportunity. Works supervisors and

frontline workers will confirm during their induction that they understand these requirements. The roles of

individual team members are highlighted below:

Project Director – John McGill:

The Project Director will provide leadership sufficient to inspire and influence all project staff to achieve the

predetermined environmental project objectives. For this project, he is the principal source of functional and

technical expertise available to the entire Project team and must ensure sufficient resources are available to

achieve the Project’s set objectives and targets and that those resources have sufficient skills to conduct the

roles competently.

▪ Responsible for ensuring all significant environmental issues are reflected in all related environmental aspects identified for the Project.

▪ The Project Director is responsible for ensuring that resources are available to implement site management procedures and plans.

▪ Environmental plans, procedures and work instructions as applicable are prepared, reviewed and approved prior to the commencement of works.

Project Manager – Emmet Scanlan:

For this project, he is the principal source of functional and technical expertise available to the entire Project

team and must ensure sufficient resources are available to achieve the Project’s set objectives and targets and

that those resources have sufficient skills to conduct the roles competently.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

mailto:[email protected]



Page : 11 of 51


Date: 27/09/2019

▪ Ensure that all relevant environmental permits are obtained for the Project and finally strategies

monitoring programmes, which assess the performance of this CEMP thereby relating it to other project delivery plans, as scheduled to be implemented.

▪ Arranges for full details of all arising, movement and treatment of waste to be recorded during the project.

▪ Ensuring that site personnel, contractors, subcontractors and visitors are aware of environmental procedures relevant to their activities on-site.

▪ Ensuring that site environmental procedures are implemented and adhered to.

Environmental Manager – Fionnuala Kerr:

Assist Project Director and Project Manager in delivering highest environmental standards.

▪ Implementation of this CEMP and monitoring progress internally.

▪ Responsible for ensuring that relevant environmental legislation and obligations are communicated to the site team.

▪ Responsible for implementing monitoring, inspection and auditing regimes.

▪ Dealing and recording all Environmental Complaints.

▪ Cross examination of relevant environmental documents and ensuring all significant environmental issues are reflected in the environmental aspects identified.

▪ Provide ongoing support to work supervisors and site personnel in implementing this CEMP.

Marine Operations Manager – Martin Patten:

Marine Operations Manager ensures that dredge operations are planned in line with license and monitoring

requirements, and all environmental aspects are reviewed during daily activities.

▪ Implementation of this CEMP for the marine operations.

▪ Liaise daily with the Harbour Master to ensure the Works are progressing as planned and concerns such as dust, spillage within the Harbour are adequately addressed.

Shore Works Supervisor – John Keaney:

Shore Works Supervisor ensures that materials are ordered so that the quantity delivered, the timing of the

delivery and the storage is not conductive to the creation of unnecessary waste.

▪ Implementation of this CEMP for the shore based operations.

▪ Liaise daily with the Harbour Master to ensure the Works are progressing as planned and concerns such as dust, spillage within the Harbour are adequately addressed.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 12 of 51


Date: 27/09/2019

Environmental Clerk of Works – Michael Deery:

An Ecological Clerk of Works shall be engaged on site during the works to ensure implementation of all

environmental mitigation and protection measures in accordance with Planning Register 17/51385.

Archaeologist – Mizen Archaeology:

As the works area is located within an area of high archaeological importance, an Archaeologist will be

employed to monitor the loading activity at Smooth Point.

▪ Compliance with Archaeological License and constraints.

Marine Mammal Observer – Mizen Archaeology:

Employed to provide mitigation measures for marine mammals and meet the monitoring and reporting

requirements of the National Parks and Wildlife Service.

▪ Compliance with Marine License and Dumping at Sea (DaS) Permit.

Site Operatives:

Site Operatives have a responsibility to adhere to site environmental management procedures to ensure that

their activities do not have a detrimental effect on the environment.

Subcontractors:

It is the responsibility of all subcontractors to adhere to the environmental procedures whilst on site.

3.1.1 Contact details

All queries relating to the CEMP should be directed to Fionnuala Kerr. These contact details will be made

available to the all site staff. The site environmental team contact details are:

Responsibility Name Contact Details

Project Manager Emmett Scanlan +44 (0) 7764 958509

Environmental Advisor Fionnuala Kerr +44 (0) 7713 973133

Marine Operations Manager Martin Patten +44 (0) 7738 758665

H&S Manager Gareth McKee +44 (0) 7719 478307

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 13 of 51


Date: 27/09/2019

3.2 Induction, Training and Briefing Procedures for Staff

3.2.1 Environmental Site Induction

The Environment team will prepare and deliver an environmental site induction. All staff, regardless of their

position or level of responsibility, will receive the induction which will cover the following:

▪ The statutory consents associated with the Planning Conditions and Dumping at Sea Permit Conditions

▪ The environmental sensitivities at the project site and constraints associated with Killybegs Fishery Harbour Centre and outlying area towards the dump site location; This is to ensure from the outset that all the environmentally sensitive areas and the appropriate management techniques are communicated to all staff during the initial site induction

▪ The environmental requirements and restrictions as set out in this CEMP including Method Statements for environmental mitigation

▪ The procedure for stopping works if activities on site do not comply with legal environmental requirements

▪ Monitoring and reporting environmental risks

▪ Actions to take in the event of an environmental incident, including emergency contact details.

The environmental site induction will be delivered to staff prior to commencing works on site. Inductions will

be held regularly as new staff join the project or as environmental requirements are refined.

3.2.2 Toolbox Talks and Daily Briefings

To reinforce and supplement the information provided as part of the induction process, Toolbox Talks will be

delivered to ensure that all staff are briefed on the environmental risks associated with each phase of work,

and their responsibilities for environmental protection. At all other times, all staff will attend a daily briefing,

which will include details relating to environmental issues and control measures.

The details of proposed Toolbox Talks will include;

▪ Spill Response Plan

▪ Killybegs Harbour Specific Requirements

▪ Oil and Diesel Spill Prevention and Remediation

▪ Dump at Sea Permit Compliance

▪ Dredge to Barge Transfer – Material Transfer

▪ Archaeology

▪ Noise & Marine Mammals

▪ Environmental Policies, permits and licensing

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 14 of 51


Date: 27/09/2019

These will be displayed in works areas/ works vessels along with a copy of the dumping at sea permit, as a

constant visual reminder to all personnel and site visitors of the conditions necessary to ensure compliance.

Environmental Pocket Books will also be provided to personnel on site to raise potential environmental issues

and provide the appropriate mitigation in case of an incident.

3.2.3 Environmental Actions and Commitments Register

The identification of Environmental Actions and population of a Register of Environmental Actions and

Commitments (REAC) is an important aspect of the environmental performance of a project. The draft of the

REAC is provided in Appendix 2.

The register is developed to allow compliance with the measures outlined therein, by considering the option

of impact avoidance, minimisation and application of all reasonable and practicable measures to prevent or

minimise impacts associated with the dredging operation and disposal process to wholly comply with

applicable environmental legislation.

3.3 Key Environmental Legislation

The proposed development is subject to European and National legislation. Principal legislation as follows:

▪ European Directive 2011/92/EU

▪ The Planning Development Act, 2000 (As Amended)

▪ The Planning and Development (Amendment) Act 2010

Further subsidiary legislation is as follows:

▪ The Water Framework Directive (Council Directive 2000/60/EC)

▪ The Groundwater Directive 2006/118/EC

▪ European Communities (Water Policy) Regulations (2003)

▪ The Wildlife Act, 1976 aa amended by the Wildlife Act 1976 Regulations, 1980, 2000 and 2010

▪ European Communities (Conservation of Wild Birds) Regulations 1985

▪ European Communities (Natural Habitats) Regulations

▪ European Communities (Conservation of Birds & Natural Habitats) Regulations 2011

▪ The Flora (Protection) Order, 1999

▪ The Planning & Development Acts, 2000-2010

▪ National Biodiversity Plan, 2002

▪ Biodiversity Species List for County Donegal, 2009

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 15 of 51


Date: 27/09/2019

▪ Threat Response Plan: Otter 2009-2011 (DEHLG, 2009)

▪ Environmental Noise Regulations 2006 (SI 140/2006)

All works shall be undertaken in strict accordance with the EPA Dumping at Sea Permit and Planning Permission

17/51385.

3.4 Understanding of EPA Dumping at Sea Requirements

The Dumping at Sea Permit S0028-01 for loading in Killybegs and Dumping in Donegal Bay refers to a series of

Conditions in Part III. A copy of this permit will be issued to all relevant personnel whose duties relate to any

condition of this permit and information, instruction and supervision necessary to ensure compliance will be

provided.

A summary of the conditions is provided below to demonstrate ABCO’s understanding of these conditions:

Condition

Number Details Summary of Key Elements for DAFM and AFJV relating to loading and unloading

Condition 1 Scope ▪ The dredging works in Smoothpoint will be carried out using GPS Dredging

system and relate specifically to the defined dredge area. The exclusion zone

will be applied to ensure potentially contaminated material is not brought to

sea (see section 7.1);

▪ The maximum dredged material per day is limited to 6,075 tonnes. Our

proposed dredge volume is less than this. (see section 7.2)

Condition 2 Management

of loading and

dumping at

sea activities

▪ Notification of the Agency (EPA) at least fourteen calendar days prior to

commencement of loading and dumping;

▪ Experience, qualifications of personnel during works (see section 3.1);

▪ Toolbox Talks on the DaS Permit for compliance of the associated conditions

(see section 3.2.2);

▪ Corrective Action: Procedures for non-conformity. ABCO will have in place an

escalation process in the event of a breach to the conditions with an

associated improvement plan (see section 6);

▪ Public Awareness and Communication programme. ABCO will assist or lead

as required:

- Reduction in manmade materials dumped at sea;

- No significant noise emissions;

▪ Dissolved oxygen at Swynes Bay, Donegal Bay (Dump Site) and Harbour

limited to between 5 percentiles > 80% (Lower) to 95 percentiles < 120%

(Upper) (see section 8.4.1.2).

Condition 3 Loading and

dumping at

sea activities

▪ Programme constraints. Dredge is planned first in the programme to de-risk

from winter dredge;

▪ Turbidity monitoring carried out with responsive plan such as silt curtain if

thresholds were exceeded (see section 8.4.1.1);

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 16 of 51


Date: 27/09/2019

▪ Overflow of material on transit to the dump site or during loading. Barges

have agreed limit to fill to avoid overflow (see section 8.4.3);

▪ Recording of the dumping voyage which we propose to use IDS Datalink and

SPOT GEN3 GPS Tracker;

▪ Location co-ordinates off set inwards of DaS site to de-risk material being

dumped outside of the DaS location (see section 8.3.2);

▪ Marine Survey Office approval of the proposed vessels involved in the

dredging (see section 7.1);

▪ Access by others. We will permit access as required for

inspection/enforcement compliance.

Condition 4 Control and

Monitoring ▪ C1.2 Bathymetry surveys of the harbour and of the DaS location;

▪ Archaeology C1.5 at loading locations with individuals with relevant

qualifications and a license from Department of Culture, Heritage and the

Gaeltacht (see section 7.5.1);

▪ Turbidity/suspended solids including an alarmed sensor (see section 8.4);

▪ Suspended solids, dissolved oxygen, Phytoplankton and Zooplankton testing

(see section 8.2 & 8.4);

▪ Marine Mammal Observers (MMO) C1.4 at loading location (see section 7.4);

▪ Vessel speed limited to 5 Knots (see section 7.4.1);

▪ Vessels fitted with guarded propellers (see section 7.4.1);

▪ Dissolved oxygen limits (see section 8.4.1.2);

▪ Limiting dredging of area within the exclusion zone locations as identified in

C1.1.1 (see section 7.1);

▪ Benthic monitoring surveys as C1.1 including grab samples for fauna and

sediments (see section 8.3);

▪ Water quality monitoring C1.3 (see section 8.4);

▪ Sediment monitoring C2.3 (see section 8.3).

Condition 5 Incident

Prevention

and

Emergency

Response

▪ Development of emergency response procedures;

▪ Agreed recording of incidents and notification according to the permit

requirements.

(see section 10)

Condition 6 Notification,

Records and

Reports

▪ Notification of incidents to the agency and their bodies as listed;

▪ Record of incident;

▪ Complaint Register;

▪ Availability of documentation;

▪ Environmental Report including;

- Register of loading and dumping activities

- Incidents, complaints, monitoring, MMO reporting, Accident prevention,

emergency response procedure, investigation of alternative re-use

summary.

(see section 10)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 17 of 51


Date: 27/09/2019

Condition 7 Financial

Charges ▪ As required by the license

3.5 Understanding of Planning Condition 17/51385

Planning Condition 17/51385 details a number of conditions on which planning permission has been granted.

A summary of the conditions is provided below to demonstrate ABCO’s understanding of these conditions:

Condition Number

Details Summary of Key Elements

Condition 1 Logged Plans In order to define the permission, the development will be carried out in strict accordance with the logged plans detailed within the planning register.

Condition 2 CEMP In the interest of orderly development, the Construction Environmental Management Plan (CEMP) will be submitted to the Planning Authority detailing the intended construction practice; traffic management, waste management, material storage, hours of construction and dust/dirt control. See:

- C20196-MP-005-TMP – Traffic Management Plan

- C20196-MP-006-MTMP – Marine Traffic Management Plan

- C20196-MP-010-SWMP – Site Waste Management Plan

Condition 3 AIRE Mitigation To protect the integrity of the environment and ecology of the area and that of Natura 2000 sites, development will be carried out in strict accordance with the mitigation measures set out in the AIRE.

A) Sediment and water control

B) Marine Mammal Observer

Condition 4 Archaeological Monitoring

To protect the archaeological heritage of the area, archaeological monitoring will be carried out during all ground works.

If archaeological monitoring reveals deposits of archaeological potential then , excavation and construction works will cease until permission is obtained from the Planning Authority for recommencement of the works.

Condition 5 Ecological Clerk of Works

To define the terms of the permission and ensure the integrity and perseveration of Natura2000 sites and their qualifying interests, and ECoW will be engaged on site for the duration of the works.

ECoW will supervise, monitor and ensure strict implementation of all mitigation, observation and monitoring works set out in the AIRE dated November 2016.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 18 of 51


Date: 27/09/2019

3.6 Protection of Sensitive Areas

A screening for Appropriate Assessment was undertaken to assess whether the planned works pose an adverse

effect on the integrity of any of these European sites. The works location is not located within a Natura 2000

site, however there are four Special Area of Conservation (SACs) and further four Special Protection Areas

(SPAs) within 15km of the proposed development:

Figure 1 - SPAs and SACs within 15km of Killybegs Harbour. Source: Natura Impact Statement: Screening Report

▪ St John’s Point SAC (1)

▪ Inishduff SPA (2)

▪ West Donegal Coast SPA (3)

▪ Slieve League SAC (4)

▪ Donegal Bay (5)

▪ Slieve Tooey/ Tormore Isalnd/ Loughros Beg Bay SAC (6)

▪ Lough Nillan Bog (Carrickatlieve) SAC (7)

▪ Lough Nillan Bog SPA (7)

The AIRE report demonstrates that the proposed works are unlikely to cause any significant effects on the

protected sites. Modelled outputs of the dredging and disposal plumes show that no impact is expected on

reef habitats within the SACs due to the distance and the insignificant levels of suspended sediments. In

addition, any impact on bird populations due to dredging and disposal operations was considered negligible.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 19 of 51


Date: 27/09/2019

4. ECOLOGY

The main ecological sensitivities and relevant mitigation approaches to be implemented during the project

delivery, guided by the AIRE, are detailed below.

In the event of disturbance to and/or the unforeseen discovery of protected species, further measures will be

implemented which will be agreed with the relevant statutory agencies including the National Parks and

Wildlife Service (NPWS) and Donegal County Council as and when required.

4.1 Large Megafauna

Baleen whales (minke whale, fin whale), toothed whales (killer whale, sperm whale, cuvier’s beaked whale,

harbour porpoise, common dolphin, bottle nose dolphin, risso’s dolphin, striped dolphin, white sided dolphin,

white beaked dolphin), seals (common seal, grey seal), basking sharks and turtles (leatherback) have all been

recorded in inshore Irish waters.

Potential impacts on the megafauna of Donegal bay are likely to be from an increase in underwater noise levels

generated through dredging and underwater construction, dredging and disposal operations and an increase

in collision risk with vessels.

In order to reduce the risk to large megafauna within Donegal Bay, the following mitigation shall be

implemented:

▪ A suitably qualified MMO shall be employed for the full duration of dredge and disposal activities, operating in accordance with DAHG document ‘Guidance to manage risk to marine mammals from man-made sound sources in Irish waters January 2014’ (see section 6.5).

▪ Vessels carrying out loading and dumping activities from 1st April – 31st August inclusive, shall be limited to a speed no greater than 5 knots so as to reduce the likelihood of collision with megafauna.

▪ Vessels with unguarded duct propellers will be prohibited to prevent any large megafauna from being pulled through the duct.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 20 of 51


Date: 27/09/2019

4.2 Otters

The Eurasian Otter, the only native UK species of Otter, is fully protected as a European protected species and

also under sections 9 & 11 of the Wildlife Act 1976 and EU Directive 92/43 and the Bern Convention (1979) for

international standard. Phase 1 Habitat & Otter Survey conducted as part of the AIRE found suitable resting

places however anecdotal evidence of otter presence in the works area.

In order to reduce disturbance to otter populations potentially present in the works area, the following

mitigation is recommended:

▪ Site works shall be avoided between sunset and sunrise to minimise disturbance to otters which are primarily nocturnal or crepuscular.

▪ In the event that an otter is discovered on site, work in that area must stop immediately and a suitably qualified ecologist consulted.

4.3 Fisheries

Donegal Bay is home to a number of important fishing grounds including McSwynes Shellfish farm, Richie’s Bay

finfish farm and there is a known salmon/trout migratory-run directly through Killybegs Harbour.

McSwynes Bay is a designated shellfish area under the EC Quality of Shellfish Waters Regulations 2006, located

5km southeast of Killybegs Harbour. There a further 16 finfish farms within 5km of these shellfish waters and

an Atlantic Salmon and Sea Trout migratory pass through the bay into the Bungosteen River, used for migration

upstream between September and August.

Killybegs is an operational fisheries harbour whereby the bed is continually disturbed through propeller wash

as vessels access/ egress the berthing facilities. Through this activity, the harbour already demonstrates

insignificant levels of ecological impact and so no specific mitigation for the protection of fisheries is required.

The relevant mitigation is already built into the project design and will also be covered by following standard

best practice guidance during the construction period.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 21 of 51


Date: 27/09/2019

5. MONITORING OF CONSTRUCTION ACTIVITIES

The following activities shall be completed by the environmental team on an ongoing basis to ensure strict

monitoring and compliance with the CEMP.

1. Completion of Site Weekly HSE Inspection Sheet

2. Fortnightly review of site waste management plan (see document C2016-MP-010-SWMP – Site Waste

Management Plan)

3. Monthly audits carried out by Senior Management, QHSE Director and ABCO Environmental Manager.

4. Ongoing noise, dust & vibration monitoring (see document C2016-MP-009 NVMP – Noise & Vibration

Monitoring Plan)

5. Ongoing water quality monitoring – turbidity/ suspended solids, dissolved oxygen content,

phytoplankton & zooplankton

6. Ongoing observation for marine mammals

7. Ongoing archaeological monitoring

In the event of non-compliance, a Non-Conformance Report (NCR) will be immediately reported to the

Employer, the Employer’s Representative and Employer’s Site Representative. ABCO site management team

will raise the NCR documentation and the team will review the procedure to establish the cause of the failing.

The NCR will be raised to the Environmental Manager, Project Director and Project Manager.

▪ If staff behaviour is found to be the cause, the member(s) of staff involved will receive additional environmental awareness training, which will focus on ensuring that the staff understand the importance of conforming with the environmental policy, procedures and to the requirements of this CEMP.

▪ If a failure of equipment is found to be the cause, the equipment will be serviced and if necessary, replaced.

▪ If a failure of procedure is found to be the cause, the CEMP will be reviewed and revised as necessary.

The Environmental Manager will report the findings to the management team and the course of action to close

the NCR and to avoid reoccurrence.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 22 of 51


Date: 27/09/2019

6. CONTROL OF ENVIRONMENTAL RISK

This section details the environmental risks associated with all project activities and, describes the mitigation

measures that are set in place to eliminate or reduce the risks. As the project proceeds, changes in the

environmental risks will be monitored and evaluated.

6.1 Dredging Unsuitable Material

One of the key environmental risks of the project is the accidental dredging of material deemed to be

unsuitable for dumping at sea due to the presence of elevated levels of chemical contaminants. There is

potential for contaminants to be present in the surface silts and gravels in the area of Smooth Point adjacent

to the previous dredging campaign.

The risk of dredging material in this area will be mitigated by the use of a 3D Machine Guidance System

displaying Exclusion Zones.

▪ The top 1.1m of sediments from the area outlined in green of drawing “E2538-AML-00-XX-DR-X-1001 – Phase A Layout Plan” was previously dredged and disposed through a previous project.

Figure 2 - E2538-AML-00-XX-DR-X-1001- Phase A Layout Plan

▪ The excavator will be fitted with several positional sensors on the bucket, stick and boom together with GPS receivers for positional correction, giving a live feed of the barge, excavator and bucket positions at all times.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 23 of 51


Date: 27/09/2019

▪ An RTK base station was set up at a fixed position on the shore providing positional correction to the

excavator GPS via a radio communication link

▪ The pre- works bathymetry survey, design dredge level, tolerances and the exclusion zone will be uploaded to the software enabling the operator to view in real time proximity to the exclusion zone.

▪ Should the bucket encroach on the exclusion zone an alarm will be raised within the cab and in the wheelhouse of the dredge barge, which is monitored by the Vessel Master.

▪ A quayside benchmark will be established with a known position and elevation to enable regular bucket checks to be carried out to confirm the accuracy of the bucket positioning. Checks will be carried out regularly, at least on a weekly basis and where there was a change to the sensors or excavator set up.

▪ A line of buoys will be deployed along the edge of the area to provide a constant visual reminder, as identified by Black Hatched Line in Fig. 2 – Drawing: E2538-AML-00-XX-DR-X-1001- Phase A Layout Plan.

▪ All vessels involved with dredge activities will receive approval from the Marine Survey Office prior to the commencement of works.

In addition, all reasonable efforts shall be made to remove any solid/floating waste during the loading and

dumping activities:

▪ Dredged material will be passed through ≤ 30cm grid screen to minimise the amount of man-made materials dumped at sea.

6.1.1 Spillage of Dredged Material into water

Another key environmental risk for this project is the dispersion of dredged material during the dredging

operation and transportation. The release of dredge material can result in significant adverse effects on marine

species. A site-specific Spill Response plan has been developed to counteract, minimise and eliminate those

risks.

6.1.2 Spill and the Dredging Operation

Marine Dredge operations will be undertaken with a specially adapted sealed ‘environmental bucket’. The

environmental bucket is designed to minimise loss or spillage of dredged sediment. The dredger is controlled

using Global Positioning System (GPS) technology which ensures a high degree of accuracy.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 24 of 51


Date: 27/09/2019

Figure 3 - Environmental Bucket

Dredged material will be deposited directly into hopper barge. The bucket will not be lifted from the bed before

the bucket has been properly sealed shut. The bucket will then be lifted to the surface and slewed over the

hopper barge, with the material deposited into the Hopper Barge.

6.2 Disposal at Sea

In order to accurately control and record the nature of each disposal event, a bespoke automatic vessel logging

system will be installed onto all vessels used for sea disposal activities. This system has been developed in

conjunction with IDS Monitoring (IDS), a marine technology specialist, and the Environmental Protection

Agency (EPA) for use on split hopper barges and is programmed to record the following information for each

voyage:

▪ Name of Vessel;

▪ Source of Material;

▪ Date, time, location and position at which loading began and ended;

▪ Date, time, location and position at which dumping voyage for purposes of dumping began;

▪ Date, time, location and position at which dumping began;

▪ Date, time, location and position at which dumping ended;

▪ Quantity of material dumped (m3);

▪ Date, time, location and position at which the vessel completed the voyage for the purpose of dumping, and;

▪ Logged vessel track record data.

In addition, the release of suspended solids into the water column during loading and on voyages to and from the dumpsite will be minimised.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 25 of 51


Date: 27/09/2019

The maximum daily rate of disposal will be limited to 6,075 tonnes per day. Disposal will be limited to a total

maximum quantity of 170,000 tones (wet weight) dredge material and be completed by 30th April 2019.

6.3 Offloading from Barge

The hopper barge will be moored alongside the quay. Dredged material not to be dumped at sea will be

offloaded into articulated dumpers for transportation to the temporary storage area. An environmental bucket

will be used, which will be sealed shut. The bucket will remain above the barge until all water has ceased

draining from it.

Articulated Dumpers will be loaded not exceeding their capacity to reduce the risk of spillage during

transportation. The jetty, hardstanding and haul road will be cleaned immediately if dredged material is spilt

onto surfaces.

For effective monitoring, site personnel will be assigned to ensure all haulage vehicles upon leaving the

contractor’s working area. All vehicles will be inspected for wheel and undercarriage cleanliness prior to leaving

the working area. All road gullies will be screened using geotextile to prevent contaminated water from being

washed into the storm sewer network.

A general note for the works supervisors prior to the commencement of all operation/dredging activities, they

should ask and ensure that spill kits are readily accessible and there is sufficient material to clean up a range

of spills

6.4 Ecological Clerk of Works

An Ecological Clerk of Works shall be engaged on site during the works to ensure implementation of all

mitigation and protection measures. Their role will include observation and monitoring of the works in

accordance with Planning Register 17/51385.

6.5 Marine Mammals

To date 25 species of cetaceans have been recorded in Irish waters and two regularly occurring seal species,

the Grey Seal and Harbour/Common Seal. This high number reflects the diversity of habitats which are used

for foraging, transit between terrestrial resting places and other behaviours linked to their annual life cycles

(e.g., social behaviour, territoriality).

In Ireland, cetaceans (whale, dolphins and porpoises), pinnipeds and the Eurasian otter (Lutra lutra) are

protected under a suite of national and international legislation. European and national legislative frameworks

include the EC Habitats Directive and conventions such as the Convention on Biological Diversity and OSPAR

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 26 of 51


Date: 27/09/2019

Convention. All cetaceans, as well as grey (Halichoerus grypus) and harbour seals (Phoca vitulina) and otters

are also protected under the Wildlife Act (1976) whereby it is an offence to hunt, injure or willfully interfere

with, disturb or destroy the resting or breeding place of a protected species. In order to maintain legislative

compliance and prevent harm or disturbance to any marine mammals encountered during the works, the

following mitigation measures shall be implemented.

6.5.1 Operational Mitigation

Vessels employed for dredging and dumping at sea between April and August will be instructed to limit speed

of passage to <5knots to minimise risk of collision. In addition, unguarded ducted propellers will be prohibited.

6.5.2 Marine Mammal Observer

ABCO will provide a suitably qualified Marine Mammal Observer (MMO) with awareness of Irish Regulatory

Procedures. The dedicated MMO will supervise the works in accordance with National Parks and Wildlife

Service “Guidance to manage risk to marine mammals from man-made sound sources in Irish Waters, January

2014” and be responsible for advising ABCO personnel if a delay in the commencement of operations is

required.

The MMO will be JNCC qualified and will operate to the Joint Nature Conservation Committee’s (JNCC)

‘Statutory nature conservation agency protocol for minimising the risks of injury to marine Mammals from

piling noise’ (August 2010) will be followed.

6.5.3 Pre-Start Monitoring

Prior to the commencement of any noise producing activities, MMO will be positioned onboard the source

vessel to conduct a pre-start search of the mitigation zone. In waters up to 200m deep, pre-start monitoring

will be completed at least 30 minutes before noise producing activities are due to commence. Activities shall

not commence until 30 minutes have elapsed with no marine mammals detected within the Mitigation Zone

(see section 6.5.4). Construction activities shall only commence in daylight hours where effective visual

monitoring has been achieved. Where effective visual monitoring is not possible, activities shall be postponed

until effective visual monitoring is possible.

6.5.4 Mitigation Zone

A mitigation zone will be established around the source of the noise producing activity. The MMO will keep

watch within this area and delay the start of activity should any marine mammal be detected.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 27 of 51


Date: 27/09/2019

▪ During dredging operations, the mitigation zone is a 500m radial distance from the dredging

sound source.

▪ During piling operations this zone is extended to 1000m radial distance from the pile driving sound source.

▪ For all multibeam, single beam, side-scan sonar and sub-bottom surveys conducted within bays, inlets and estuaries, or 1,500m from the entrance of enclosed bays/inlets/estuaries, the mitigation zone will be 1,000m radial distance from the sound source.

6.5.5 Soft Start

Soft-start procedure shall be adopted for marine operations on the project. During this ramp up period if a

mammal is observed within the mitigation zone, the ramp up should either be stopped or maintained at the

same noise level until the mitigation zone is observed as clear for 30 minutes after the last visual detection.

The MMO will track any marine Mammals detected and ensure they are satisfied the animals have left the

mitigation zone before they advise the crew to commence dredging activities.

6.5.6 Breaks in Operations

Once normal dredging operations commence, there is no requirement to halt or discontinue the activity at

night-time, if weather or visibility conditions deteriorate nor if marine mammals are observed within the

mitigation zone. If there is a break in dredging sound output for a period greater than 30 minutes (e.g., due to

equipment failure, shut down or location change) then all pre-start monitoring must be undertaken in

accordance with the above conditions prior to the recommencement of dredging activity.

6.5.7 Reporting

MMO will log all marine mammal detections and relevant sound-producing events using the standardised

reporting form included in Appendix 5.

6.6 Archaeology & Cultural Heritage

Smooth Point is in located an area of high archaeological significance, where there is a potential for the

development works to impact previously unrecorded archaeological material.

ABCO will engage a specialist and suitably qualified archaeologist to monitor the works in compliance with the

requirements of the EPA Dumping at Sea Permit, Planning Permission 17/51385 and the Underwater

Archaeology Unit of Department of Culture Heritage and the Gaeltacht.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 28 of 51


Date: 27/09/2019

3 weeks prior to the commencement of loading and dumping activities, ABCO will notify the Underwater

Archaeology Unit of the Department of Culture Heritage and the Gaeltacht to obtain an Archaeological

Excavation License.

Archaeological monitoring will be carried out during all onshore and marine works. If deposits of archaeological

potential are uncovered during excavations, excavation and construction works will cease until permission is

obtained from the Planning Authority for recommencement of the works.

6.6.1 Excavation Strategy – Marine Dredge

The site archaeologist will be notified when works are due to commence and be positioned in a safe

observation area to review and confirm dredge materials do not contain items of interest in accordance with

the archaeological license.

Constant visual inspection of the excavator bucket shall be maintained as it emerges from the water and as

material is deposited into the hopper barges. Should any material of archaeological interest arise from the

dredging operation, the Underwater Archaeology Unit will be notified immediately, and dredging works will

cease whist the material is inspected and logged by the Archaeologist.

The steps to be taken in the event of a discovery are listed below:

1. STOP work immediately.

2. IMMEDIATELY PROTECT the find by marking/blocking off.

3. NOTIFY the discovery to the project team including Client’s Representative who should notify

the Underwater Archaeology Unit of the Department of Culture, Heritage and the Gaeltacht

and other relevant Stakeholders.

4. Access to the area by vessels, machinery and personnel is to be prevented.

5. Time is to be allowed for the archaeologist to undertake the appropriate level of recording.

6. Archaeological objects and treasure discovered must be reported to the regulator.

Note: A suitable water tank will be available on site so that findings may be stored appropriately to

prevent degradation.

6.6.2 Excavation Strategy - Shore

The site archaeologist will be notified when works are due to commence and be positioned in a safe

observation area to review and confirm shore excavations do not contain items of interest in accordance

with the archaeological license.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 29 of 51


Date: 27/09/2019

Constant visual inspection of the excavated area shall be maintained. Should any material of archaeological

interest arise from the operation, the Department of Arts, Heritage and the Gaeltacht will be notified

immediately, and works in the area will cease whist the material is inspected and logged by the Archaeologist.

The steps to be taken in the event of a discovery are listed below:

1. STOP work immediately.

2. IMMEDIATELY PROTECT the find by fencing/blocking off.

3. NOTIFY the discovery to the project team including Client’s Representative who should notify the

Department of Culture, Heritage and the Gaeltacht and other relevant Stakeholders.

4. Access to the area by machinery and personnel is to be prevented.

5. Time is to be allowed for the archaeologist to undertake the appropriate level of recording.

6. Archaeological objects and treasure discovered must be reported to the regulator.

Note: A suitable water tank will be available on site so that findings may be stored appropriately to

prevent degradation.

6.7 Air Quality

The key environmental risks associated with air quality are the generation of dust, particulates, gases, vapours

and aerosols, which can affect human health. The following measures will be implemented to reduce these

risks.

6.7.1 Dusts, Fibres and Particulates

The main source of dust will be from excavations, vehicle movements, windblown dusts from the site and the

dredged material from the rock brought to shore. Dust will only be created in dry conditions; during such times

dust monitoring, will be carried out to ensure that the works do not cause a nuisance. If the entrance/exit to

the contractor’s working area generates dust from vehicle movements, a road sweeper will be used. Haulers

will take all appropriate measures including covering their loads if necessary. If necessary, water bowsers will

be used to dampen windblown dusts on-site.

The trigger level for implementing dust control measures will initially be by visual evidence of dust whip,

followed by monitoring of suspended dust (PM10) to ensure compliance with emission limits (50 micrograms

per cubic - 24 hr. average).

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 30 of 51


Date: 27/09/2019

6.7.2 Emissions (CO²)

The main source of emissions will be from running construction plant and delivery to and from the site. The

following mitigation measures shall be adopted to minimise emissions during the construction operations:

▪ Site Office facility shall be energy efficient, incorporating sensors and push water taps to minimise energy use. Energy and water usage will be monitored and recorded for the duration of the project.

▪ All plant shall be regularly serviced to have engines working efficiently, to minimise fumes/ smoke from engine exhaust.

▪ Construction vehicle movements will be minimised, and all plant engines shall be turned off when not in use.

▪ Enhancing employee and subcontractor understanding, with a site specific environmental induction for all personnel.

▪ Source environmentally sustainable materials, reducing our consumption of energy and raw materials and maximising the opportunities to re-use and recycle, where feasible.

▪ Encourage shared transport to and from site for all personnel, including subcontractors.

▪ Audio and visual conference facilities provided to support site meetings and communications, mitigating against prolonged travel to site.

▪ Local supply chain shall be engaged were suitable to support site operations, supply materials or supporting personnel.

▪ Energy efficient lighting shall be used to support winter working.

▪ No burning of waste will be permitted on site.

6.7.3 Gases, Vapours and Aerosols (including pathogens)

Monitoring for vapours will be carried out daily to determine if odours are deemed to be a nuisance. Olfactory

assessment will be carried out within agreed designated areas on the site. If necessary, a photoionization (PID)

meter will be used to measure volatile organic compounds (VOCs) at the boundary and if a detection reading

of above 10ppm for VOCs is measured then all materials will be covered during operations with polythene to

reduce the vapours. To minimise odour emission during excavation, excavated material placed in stockpile that

is emitting odours will be covered with an impermeable membrane until levels are acceptable. If odours do

become a problem even after being covered then a secondary system can be implemented, i.e. an odour

masking/misting system; however, this is not likely to be required.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 31 of 51


Date: 27/09/2019

6.7.4 Fires on Site

To limit the risk of any flash point fires, smoking is not permitted on-site. All works will be carried out in open

aired conditions, which will reduce the risk of vapour build up, and flash point fires. In the event of a fire, the

Fire Brigade will be called. All plant will be equipped with fire extinguishers in the event of any fires.

Killybegs Fire Brigade, Shore Road, Killybegs. Tel: 999/112

Tel: 074 97 31272

In the event of fire outbreak, the following procedures will be followed

▪ Activate the nearest fire alarm to warn others - this may be a horn on construction sites.

▪ Notify the local fire service and other relevant emergency services

▪ Disconnect utilities and equipment unless doing so jeopardises safety

▪ Remove fuel (mobile fuel bowser) if it is safe to do so

▪ Assemble in the designated ‘Fire Assembly Point’ which will be clearly marked using relevant signage

6.8 Waste Management and Materials

Refer to C20196-MP-010-SWMP Site Waste Management Plan. As an overview, the following mitigation

measures will be implemented:

▪ Waste skips will be on site to segregate timber, plastic and rubber for transport off site for suitable recycling;

▪ Waste Skips will be provided for site offices and removed by a licenced waste contractor;

▪ Waste Transfer documentation for all material removed from site will be submitted to the Engineer on a weekly basis;

▪ Disposal or recovery of solid waste shall only take place in accordance with the conditions of permit S0028-01 and in accordance with the appropriate National and European legislation and protocols;

▪ Solid waste sent for disposal or recovery shall be transported only by an authorised waste contractor. The solid waste shall be transported from the site of the activity to the site of the recovery/disposal only in a manner that will not adversely affect the environment and in accordance with the appropriate National and European legislation and protocols.

6.9 Ground Conditions

The following mitigation measures will be implemented:

▪ Ensure that all areas where liquids (including fuel) are stored or cleaning is carried out are in a designated area

▪ Careful consideration will be given to the location of any fuel storage facilities. These will be designed in accordance with guidelines produced by CIRIA, and will be fully bunded

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 32 of 51


Date: 27/09/2019

▪ All works will be carried out in accordance with the following Pollution Prevention Guidelines (PPGs)

relating to water quality. Special consideration given to

• PPG1 General Guide to the Prevention of Pollution

• PPG2 Above Ground Oil Storage Tanks [new GPP issued January 2017]

• PPG5 Works in, Near or Liable to Affect Watercourses [new GPP issued January 2017]

• PPG6 Working at Construction and Demolition Sites

• PPG21 Pollution Incident Response Planning [new GPP issued July 2017] ▪ Damaged, leaking or empty drums will be removed from site immediately and disposed of by

registered a waste disposal contractor

▪ Mobile plant will be refuelled in a designated area, away from drains or watercourses

▪ All vehicles and plant will be regularly inspected for fuel, oil and hydraulic fluid leaks. Suitable equipment to deal with spills will be maintained on site

▪ Soils requiring off site removal will be undertaken in accordance with the specific waste acceptance criteria of the receiving facilities and in accordance with relevant waste legislation

▪ Minimise the use of cleaning chemicals

▪ A spill kit with sand, earth or commercial products that are approved for the stored materials will be kept close to the storage area. Staff will be trained on how to use spill kits correctly

▪ Dredged (Rock) material will be placed in dump trucks at the designated quay for transport to storage areas

▪ Stockpiles will be compacted, sealed and battered with the back of the excavator bucket to prevent any storm water infiltration

▪ All road gullies will be screened using geotextile to prevent surface run-off construction water from being washed into the storm sewer network

6.10 Water

The following mitigation measures will be implemented:

▪ Ensure that all areas where liquids (including fuel) are stored or cleaning is carried out are in a designated impermeable area that is isolated from the surrounding area and within a secondary containment system, e.g. by a roll-over bund, raised kerb, ramps or stepped access

▪ Careful consideration will be given to the location of any fuel storage facilities. These will be designed in accordance with guidelines produced by CIRIA, and will be fully bunded

▪ Damaged, leaking or empty drums will be removed from site immediately and disposed of by registered a waste disposal contractor

▪ Mobile plant will be refuelled in a designated area, on an impermeable base away from drains or watercourses

▪ All vehicles and plant will be regularly inspected for fuel, oil and hydraulic fluid leaks. Suitable equipment to deal with spills will be maintained on site

▪ Ensure that all staff are trained and follow vehicle cleaning procedures. Post details of the procedures in the work area for easy reference

▪ Soils requiring off site removal will be undertaken in accordance with the specific waste acceptance criteria of the receiving facilities and in accordance with relevant waste legislation

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 33 of 51


Date: 27/09/2019

▪ Minimise the use of cleaning chemicals

▪ Dredged material will be placed in sealed dump trucks at the quay side via a sealed environmental bucket

▪ Stockpiles will be compacted, sealed and battered with the back of the excavator bucket to prevent any storm water infiltration

▪ All road gullies will be screened using geotextile to prevent contaminated water from being washed into the storm sewer network

6.11 Visual Impacts

Visual impact was scoped out of the Assessment of Impact on the Receiving Environment (AIRE) (November

2016). As the site is located within the Killybegs Harbour estate, the project is not expected to be sensitive in

terms of visual impact as works will be at the level of the existing quay. The risk of adverse effects on the

landscape are minimal and no specific mitigation measures are proposed.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 34 of 51


Date: 27/09/2019

7 POPULATION AND HUMAN HEALTH

As the works are to be carried out within the existing harbour area, the risks of disturbance to people and

communities are low. All roads will be kept free of mud and debris and any other material which might cause

a nuisance. Vehicle movements will be kept to a minimum and restricted to defined haul routes within the site.

If for any reason the site traffic leaving the site causes a fouling of the roadway, then the debris will be cleared

using hand shovels or a mobile road sweeper. All such incidents will be fully recorded in a daily log.

A commercial Scarab type road sweeper will be on site at all times during the dredging, treatment and disposal

operations. All dust will be controlled in accordance with the material COSHH sheet and the recommendations

of the manufacturer of the material.

ABCO will implement and maintain a Public Awareness and Communications Program to ensure members of

the public can obtain information at reasonable times concerning the environmental performance of the

works. ABCO will provide an environmental storyboard and a copy of the monthly progress report, available

within the harbor office, for inspection by the public during office hours.

7.1 Economic Activity

With the appropriate mitigation measures outlined in this CEMP in place, the construction and operational

process will have an imperceptible impact on adjacent businesses, and it is considered that there will no further

mitigation measures required.

7.2 Social Considerations

The mitigation measures included in this CEMP will reduce or eliminate any negative impacts on local amenity

and social facilities. No further measures are required.

7.3 Health and Safety

Mitigation measures will be proposed to minimise any health and safety risk to the public and residents, as

well as ensuring the site layout and surrounding roads have the capacity to deal with the additional traffic.

▪ In accordance with current legislation and in order to prevent and minimise construction activities accidents, a QSHE manager has been appointed to coordinate the design and to address and minimise construction risks during the design period

▪ A Health and Safety Plan will be implemented and reviewed by the project team

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 35 of 51


Date: 27/09/2019

▪ During construction all areas will be delineated and will be under the control of the QSHE

manager who will coordinate and supervise all safety aspects of the project

▪ A Safety File will be compiled and maintained on site for the duration of the project and the implementation of the Plan will be subject to regular audits

▪ Strict security procedures will be implemented on site. These procedures will require all vehicles and personnel visiting the site to be logged in and out.

8. ENVIRONMENTAL MONITORING REQUIREMENTS

The key monitoring requirements for this project relate to water quality and construction noise output. There

is potential for changes in water quality and benthic structure resulting from dredging and offshore disposal

activities as well as an increase in noise and vibration within the harbour area from construction activities.

▪ All analysis and measurements will be undertaken by competent staff and in accordance with the

relevant documented operating procedure;

▪ Operating procedures will be assessed for suitability for the test matrix and performance characteristic

determined;

▪ All procedures will be subject to Analytical Quality Control using control standard with evaluation of

test response;

▪ Analysis for compliance purposes including sub-contracted analysis, shall be done by a competent

laboratory.

8.1 Marine Monitoring Sites

Marine monitoring sites have been selected based on environmental sensitivities within the area.

The sensitive areas that require monitoring are the aquaculture sites at Inver Bay and McSwynes Bay as well

as the SAC at St Johns Point. In addition to these, it is best practice to monitor the area surrounding the

dredging operation and to monitor an offshore control for the disposal site outside the influence of the disposal

operation.

On the basis of this, 4 static monitoring locations have been selected in addition to the dump site itself:

Monitoring Location Longitude Latitude

Static Monitoring Locations

1 Killybegs Harbour -8°26.40’ 54°37.03’

2 McSwynes Bay -8°25.19’ 54°34.75’

3 Inver Bay -8°23.84’ 54°36.41’

4 Offshore Control Site -8°32.40’ 54°33.65’

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 36 of 51


Date: 27/09/2019

Disposal Monitoring Locations

5 Offshore Disposal Site

(i) -8°37.85 54°33.62

(ii) -8°37.29 54°33.63

(iii) -8°37.84 54°33.30

(iv) -8°37.28 54°33.30

(v) -8°37.57’ 54°33.46’

8.2 Phytoplankton & Zooplankton Monitoring

As fundamental components of the water food web, plankton are among the first to react to water quality

changes and by this initiate a chain reaction which is successively reflected within other groups of organisms

such as benthic fauna, fish and birds etc.

As plankton communities are sensitive to changes in their environment and respond rapidly, levels of

Phytoplankton and Zooplankton will be periodically monitored as measure of water quality. Monthly samples

shall be collected at the 4No static monitoring locations, beginning a minimum of 1 month prior to loading and

dumping activities and will continue monthly for the duration of the works until all loading and dumping

activities are complete.

Survey Method Storage Solution

Phytoplankton 10-minute surface tow Lugol’s Iodine

Zooplankton U-tow (from the surface down to the seabed and back up to the surface)

5% Buffered Formalin

8.3 Benthic Monitoring

Benthic surveys within Donegal Bay shall be completed at the 5 monitoring locations identified in section 8.1,

to assess the condition of fauna and sediment. Grab sampling techniques will be used to establish the

distribution patterns of benthic animals as well as their relationship with the biochemical properties of the

sediment.

The benthic monitoring program has been designed to statistically measure the direction and severity of any

change in the benthic environment. The frequency and extent of each monitoring survey to be completed is

detailed below:

Monitoring Frequency

10 Days Post Disposal 6 Months Post Disposal 12 Months Post Disposal

Monitoring Survey Requirements

4No Static Monitoring Locations

Grab samples for benthic fauna and sediment






For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 37 of 51


Date: 27/09/2019

Disposal Monitoring Location

SPI Survey SPI Survey SPI Survey

Grab samples will be processed for sediment and fauna in accordance with the analytical and quality

requirements set out in ‘M. Cronin et al, 2006. Guidelines for the Assessment of Dredge Material for Disposal

in Irish Waters. Marine Environment & Health Series, No24. Marine Institute’ and ‘’Marine Sediment and

Benthic Studies for Killybegs Harbour Dredging and Disposal Operations’’ provided as part of the AIRE.

8.3.1 Benthic Sediment Survey

The proposed works could potentially lead to chemical contamination of the environment as a result of

suspension and dispersal of poor-quality sediments during dredging and disposal activities. The potential for

introduction of tributyl tin (TBT), formally used as ship anti-fouling paint, through the release of dredge

sediments is the main concern. The TBT compound is by far the most toxic to marine life, responsible for the

disruption of the endocrine system of marine shellfish, impairing immune system and causing malformations

after exposure to even extremely low concentrations.

In order to prevent the disposal of poor-quality sediments, the following mitigation shall be employed:

▪ The risk of dredging contaminated material will be mitigated by the use of a 3D GPS Machine Guidance System, displaying exclusion zones to ensure no material is dumped at sea which is classified as unsuitable. (See section 7.1 Dredging Unsuitable Material for further mitigation).

▪ Identified contaminated sediment found unsuitable for disposal at sea will be removed by an excavator fitted with an environmental bucket for processing and disposal on land.

▪ No material will be dumped at sea that has been classed as unsuitable.

8.3.2 Benthic Fauna

Dumping sediments on the seabed may smother and crush organisms living on the seafloor and may cause

changes in benthic habitats and biological communities. In order to mitigate against any potential changes to

the benthic environment, the following mitigation shall be employed:

▪ Dumping will be via release of material through hull of the vessel while the vessel is in motion to aid the dispersion of sediments over the full dump site area and lessen the effects of smothering.

▪ Dumping activities will be conducted to ensure a uniform spread of material thoughout the dumping site.

▪ Dumpsite location coordinates will be offset inwards of the permitted DaS site in order to de-risk the potential for material being dumped outside the permitted area.

▪ Dredge material will be passed thought a ≤ 30 cm grid to minimise the amount of large sediments and rock disposed offshore.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 38 of 51


Date: 27/09/2019

8.3.3 Sediment Profile Imagery

A Sediment Profile Imagery (SPI) survey will be conducted at the dumpsite pre works in order to set a baseline

for measuring change, and a further 10 days, 6 months and 12 months post disposal.

SPI is an underwater technique for photographing the sediment-water interface at the seafloor and can be

used to measure the biological, chemical and physical processes occurring at the benthic boundary layer. SPI

takes images of the upper 25cm of the sea floor and records physical parameters such as sediment grain size

and dredge material thickens.

With the growing requirements for environmental impact assessment and monitoring, SPI a very rapid means

of assessing the status of underwater sediment habitats.

8.4 Water Quality Monitoring

8.4.1 In-Situ Monitoring

Water quality will be continuously monitored at the 4 static monitoring stations detailed in section 8.1

throughout the works using an in-situ sensor providing real time data on turbidity, suspended solids and

dissolved oxygen. A moored buoy will be deployed at each of 4No locations 1 month prior to dredging

commencing and will remain in place for the duration of dredge operation.

8.4.1.1 Turbidity

During the pre-dredging phase, water samples for suspended sediments will be collected to calibrate against

turbidity and obtain a background range. These will be collected every hour for 12 hours for 1 week during the

baseline data collection phase and continue weekly thereafter.

At the sensitive aquaculture sites of St Johns Point/ Inver Bay and McSwynes Bay, a turbidity trigger level of

50mg/l above background has been agreed. If turbidity levels exceed this agreed limit, a silt curtain shall be

utilised.

8.4.1.2 Dissolved Oxygen

The limits for dissolved oxygen are set in accordance with permit condition 4.8 and are detailed below:

Dissolved Oxygen Lower Limit Dissolved Oxygen Upper Limit

5 percentile >80% 95 percentile <120%

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 39 of 51


Date: 27/09/2019

8.4.2 Mobile Monitoring

In addition to in-situ monitoring, a mobile monitoring campaign will be carried out within Killbegs Harbour

during active dredging.

Mobile monitoring will be carried out downstream from the dredger on the ebb and upstream on the flood

tide during the dredging activity i.e. twice a day. Sampling will involve 5No point samples at the following

distances from the dredger: +20m, +50m, +100, +250m, +500m.

A further transect through the dredge plume every 50-100m will be monitored hourly during dredging

operations. Once compliance with the trigger levels is demonstrated, the time between dredge plume sampling

sessions may be extended to 12 hourly intervals. Mobile monitoring will commence 2 days prior to dredging,

continue every day during of active dredging and cease 24 hours after dredging ceases.

8.4.3 Mitigation Measures

ABCO will employ tried and tested techniques to mitigate against a reduction in water quality due to the

elevation of suspended solids:

▪ The direction of dredging works will be orientated with the current, instead of across the current to minimise the potential for negative effects on water quality.

▪ A sealed environmental bucket will be fitted to all excavators employed for the removal of soft sediments to minimise suspension of bed material through washout. Once the bucket is full, a shutter is closed and only then is the bucket hauled out of the water and sediments discharged into the barge. Sealing the bucket prior to raising from the seabed limits the potential for dispersion of material and generation of suspended solids.

▪ Fill levels on the Hopper Barges employed the transfer of dredge material to sea will be closely monitored and recorded to prevent overloading or overflow of the barge, limiting the release of suspended solids into the water during loading and on voyage to the dump site.

▪ Overflow of dredge material from hopper barge during loading activities and on voyage to/from the disposal site is prohibited.

8.5 Noise & Vibration

8.5.1 Noise

There is potential for the noise environment of residents located in close proximity to Killybegs Harbour to be

impacted by construction activities. The most sensitive receptors considered to have a view of the harbour

development site are as follows:

▪ Residential properties on Fintra Road

▪ Killybegs Community Hospital

▪ Binroe Hamlet (North)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 40 of 51


Date: 27/09/2019

▪ Binroe Hamlet (South)

The closest sensitive-receptor is a residential property on St Catherine’s Road, approximately 300m distance

from the harbour development. With reference to the AIRE, the noise limits at this property should not exceed

the following levels:

Day Time Period Noise Target (LAeq)

Monday to Friday

7am – 8am 70 dBA

8am – 6pm 75 dBA

6pm – 7pm 70 dBA

7pm – 10pm 65 dBA

10pm – 7am Not audible

Saturday 8am – 1pm 75 dBA

1pm – 2pm Not audible

Sunday N/A Not audible Note: A maximum noise limit of 75dB applies to all construction works on site and within the harbour.

Mitigation Measures

The only construction activity predicted to have any noise impact is piling in the evening period. This will be a

short-term activity and site operates will control this through restricted working hours.

▪ Good neighbour/tenant relations are recognised as an important factor in reducing nuisance.

▪ Selection of optimum technology for piling activities.

▪ ABCO will establish a project email address and phone line for engagement with local community during the project.

The works will be carried out in accordance with the general recommendations set out in BS 5228:1 2009 Code

of Practice for Noise Control on Construction and Demolition Sites.

Some of the best practice activities that will be adopted to minimise noise include:

▪ Ensuring where possible, that static items such as generators, are sited away from sensitive receptors and where necessary noise control means such as barrier, enclosures or silencers are utilised to further reduce noise;

▪ Limiting the hours of operation for specific pieces of equipment or operations, especially mobile sources operating through community areas;

▪ Reducing project traffic routing through community areas wherever possible;

▪ During the works, noise levels will be monitored when a new work item is stared;

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 41 of 51


Date: 27/09/2019

▪ All restrictions on noise imposed by Donegal County Council will be strictly complied with.

The main ongoing noise source will be the plant in operation. The following measures will be implemented to

reduce the effects of noise on site:

▪ Drop heights of materials will be minimised. In accordance with Best Practicable Means, plant and activities to be employed on site will be reviewed to ensure that they are the quietest available for the required use.

▪ Plant and equipment will be regularly maintained by trained personnel.

Electricity supply via ESB is available on site. It is unlikely that compressors will be required. In the unlikely

event compressors are required, the following will be implemented:

▪ Compressors will be silenced either by using fully silenced models fitted with effective exhaust silencers and properly lined and sealed acoustic covers or using effective acoustic screens to enclose the noise source.

▪ Compressors, silencers or other equipment will be maintained in good and efficient working order and will not be altered in such a way that the noise caused in operation is made greater by the alterations.

▪ Ancillary pneumatic percussive tools used on the site will be fitted with silencers of a type recommended by the manufacturers of the tools.

NOTE: ABCO will comply with any project specific restrictions. All noise levels relating to new works

activities will be recorded and reported to the Employers Representative on a weekly basis, or as required.

8.5.2 Vibration

A key risk of the works, particularly the rock breaking and piling activities, is the risk imposed on existing

structures within the vicinity of work such as the existing quay wall and Syncrolift located adjacent to the north

east corner of the site. Further, piling activities at the eastern section of site have been identified as having

potential to disrupt residential properties as well as buildings on site and within the immediate vicinity of the

harbour. Cosmetic damage may be possible to structures located 20m from piling activities, however at greater

distances damage is less likely to occur.

To mitigate against any potential damage caused by vibration, vibration monitors will be positioned on the end

of the Syncrolift and on the existing quay wall adjacent to the works, for the full duration of the piling and rock

breaking activities.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 42 of 51


Date: 27/09/2019

Figure 4 – Vibration Monitoring Locations

Monitors will provide real time data and have alerts set for the agreed limits of 5mm/s (intermittent) and

1.5mm/s (continuous), in accordance to BS5228. If these vibration limits are exceeded, activities will be ceased

immediately or altered so as to prevent damage to adjacent structures.

8.6 General Prevention of Spillage

As part of additional control measures, the dredging operation is planned to ensure that all reasonable care

will be taken that no materials or equipment will fall into the water. In the event that something unavoidably

falls into water, it will be recovered as soon as it is safe to do so.

Any leaks from mobile plant and equipment that comprise oil products will be cleaned away using absorbents.

An appropriate stock of absorbents should be maintained on-site and, in a location, accessible to all personnel.

However, after the use of the absorbent it will be stored in a temporary container until disposal to a licensed

landfill site.

All fuel storage tanks on-site will comply with Control of Pollution Oil Storage Regulations 2010. All fuel will be

stored in double bunded locked tanks, sited at least 25m from water.

All fuel transfer and plant refuelling operations shall be supervised, with Spill Kits, Drip Trays, Plant Nappies

and Secondary containment kit utilised were applicable. Onshore a designated refuelling area will be

established within the treatment works, in a controlled environment with spillage kits as required to prevent

entering the water body.

Vibration Monitoring

Control Point 1

Vibration Monitoring

Control Point 2

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 43 of 51


Date: 27/09/2019

Routine maintenance and checks for all plant and machinery which form part of our Quality Management

Procedures will be carried out prior to deployment. All mobile plant will also be inspected daily by the plant

operator, with all records maintained within the site files.

All works will be carried out in accordance with the following Pollution Prevention Guidelines (PPGs) relating

to water quality. A review plan for the PPGs is currently underway, which will result in a replacement guidance

series, Guidance for Pollution Prevention (GPPs). The CEMP will be regularly reviewed and updated with any

changes in legislation and guidance. Referenced should be made to the following;

▪ PPG1 General Guide to the Prevention of Pollution

▪ PPG2 Above Ground Oil Storage Tanks [new GPP issued January 2017]

▪ PPG3 Use & design of oil separators in surface water drainage systems

▪ PPG5 Works in, Near or Liable to Affect Watercourses [new GPP issued January 2017]

▪ PPG6 Working at Construction and Demolition Sites

▪ PPG18 Managing Firewater and Major Spillage

▪ PPG21 Pollution Incident Response Planning [new GPP issued July 2017]

▪ PPG26 Storage and Handling of Drums and Intermediate Bulk Containers

8.6.1 Environmental Control within Laydown Areas

At all times, contractor’s laydown areas should be tidy up and clean, free from all hazardous substances which

has the potential of causing environmental. Storm water run-off containing fuel and lubricants will be

minimised, by following best practice and ensuring robust mitigation measures are in place, including a Spill

Response Plan and ensuring sufficient bunded areas for storage of hazardous substances are in place. This is

particularly important in the vicinity of the contractor’s laydown area; specifically the storage facilities, plant

and equipment parking area etc.

The laydown areas should be secured, fenced off to prevent unauthorised access. Additionally, storage areas

for hazardous substances shall be clearly marked. Work supervisors should always ensure and inquire that all

hazardous substances within the laydown and storage areas for fuel and other hazardous substances are

bunded correctly.

In addition, the vehicle refuelling location shall be strategically located, taking into consideration the

topographical nature of the area, preventing Storm water from returning spills to the water course

No leaks or spill will be considered as minor, due to the environmental sensitivity of the project site, therefore,

works supervisors should ensure full implementation of our spill response plan.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 44 of 51


Date: 27/09/2019

9. INCIDENT PREVENTION AND EMERGENCY RESPONSE

In the event of an environmental incident resulting in harm/ potential harm to an any of the environmental

sensititives identified within this CEMP, ABCO will:

1. Identify the date, time and place of the incident;

2. As soon as practicable, notify the EPA and all other relevant bodies;

3. Carry out an investigation to identify the nature, course and cause of the incident and any impact

arising therefrom;

4. Isolate the source of any such impact;

5. Evaluate the pollution, if any, cause by the incident;

6. Identify and execute measures to minimise the effects thereof.

Please refer to Appendix 1 for the Accident Prevention Procedure.

9.1 Summary of Procedures to be followed in the Event of an Environmental Emergency

The methodology and mitigation measures set out in this CEMP will minimise the risk of an environmental

emergency or incident. If an environmental emergency occurs, the member(s) of staff involved in must

maintained active communication by contacting their supervisor immediately.

In the event of an incident the permit holder shall immediately: -

1. Identify the date, time and place of the incident

2. As soon as practicable notify the Agency, in a format prescribed, and other relevant authorities;

3. Carry out an investigation to identify the nature, source and cause of the incident and any impact arising therefrom;

4. Isolate the source of any such impact;

5. Evaluate the pollution, if any, caused by the incident; and

6. Identify and execute measures to minimise the effect thereof.

Prior to works commencement, an Emergency Plan will be prepared which will set out the procedures to be

followed in the event of an environmental emergency. Possible emergencies will be identified, taking into

consideration the causes, risks, locations or point sources related to the type of emergency referred to in the

Plan.

The following aspects will be considered:

▪ The activities to be performed and the construction methods used

▪ Raw materials, including their characteristics, storage conditions, and the quantities stored

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 45 of 51


Date: 27/09/2019

▪ Equipment and facilities, including consideration of the risk of leaks and spills, systems for the

transfer and handling of products, and the potential for the malfunction of detection systems

▪ Waste generated

The Emergency Plan will be circulated to all staff and will form part of the environmental site induction. As a

minimum, all personnel are required to satisfactorily complete the Project Induction.

All staff will be encouraged to report any incidents of non-compliance with the CEMP to their supervisor. The

Environment Team will investigate the incident and report on the findings, including any changes required to

working practices and/or staff training.

9.2 Environmental Complaints, Spills & Incidents

▪ Complaints received by the public or other interested parties as a result of the works must be

recorded on the Environmental Complaints/Spills/Incident Report. Refer to Appendix 3.

▪ Every effort should be made to establish the cause of the issue leading to a complaint/spill/incident.

Assuming the issue arose from the failure of a control system, the issue shall be put right at the

earliest opportunity. This should be logged within the project Environmental Complaints Log

(Appendix 4).

▪ The response action shall be recorded on the Environmental Complaints/Spills/Incident Report by

the Project Manager / H&S Manager / Environmental Manager.

▪ A log of all complaints/spills/incidents and follow-up actions should be kept and made available for

inspection.

▪ Environmental Complaints/Spills/Incident forms should be forwarded to the Project Manager,

Environmental Manager & QHSE Director who are responsible for investigating environmental

complaints.

▪ The Project Manager shall retain all records with relation to an environmental complaint/spill or

incident.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 46 of 51


Date: 27/09/2019

APPENDIX 1 – ACCIDENT PREVENTION PROCEDURE

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

Title: ACCIDENT PREVENTION PROCEDURE

___________________________________________________________________________________

Section Ref: AB-QHSE-08 Date: 30/01/19 Revision: 1.0 Page: 1 Approved by: ABCO QHSE

___________________________________________________________________________________

1.0 PURPOSE

This procedure details the operational & organisational measures employed by ABCO so as to control and prevent accidents.

2.0 APPLICATION

This Procedure will be operated by ABCO Marine Ltd / ABCO Divers Ltd / ABCO Marine Ireland Ltd marine personnel and specialist subcontractors.

3.0 REFERENCES

ABCO Marine – H&S Policy AB-IMS08 Pre Contract Planning AB-IMS10 Mobilisation AB-IMS14 Inspection and Practical Completion AB-IMS16 Training, Awareness and Competence AB-IMS18 Identification of Health and Safety Risks and Environmental Aspects & Risks AB-IMS21 Legal and Other Requirements AB-IMS22 Incident Investigation AB-IMS23 Monitoring and Measuring AB-IMS24 Emergency Plans AB-IMS25 Waste Management P1-Quality Policy P2-HSW Policy P3-Environmnental Policy P4-First Aid Policy P5-PPE Policy AB-IMS12 Procurement of Subcontractor or Designers AB-QHSE-02 Risk Assessment Guidance AB-QHSE-04 Incident Investigation Procedure Environmental, Quality and Health and Safety Management System, ISO 14001, ISO 9001 and OHSAS 18001

4.0 CONTROL OF DOCUMENTS

All procedures and risk assessments are controlled in line with ISO:9001, ISO:14001 and OHSAS 18001.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28


___________________________________________________________________________________


___________________________________________________________________________________

5.0 SCOPE

This procedure applies to all employees, suppliers, contractors and visitors. It outlines ABCO’s overall aims and

principles of action with respect to the control and prevention of accidents on all metal recovery sites and any

environmental impact of accidents.

6.0 DEFINITIONS

Accident:

An unplanned event which results in death, ill health, personal injury or damage to health.

Incident:

An unplanned event which does not result in personal injury but does result in damage to equipment, environment,

plant or product.

An unplanned event which results in an impact or potential impact to the environment.

7.0 PROCEDURE

Accident:

An unplanned event which results in death, ill health, personal injury or damage to health.

7.1 ABCO operates an Integrated Management System (IMS) (ISO 9001, ISO 14001 & OHSAS 18001) in order to

manage quality, environmental and health & safety issues. The H&S policy statement and risk assessments form

an integral part of both the Integrated Management System and the Accident Prevention Procedure.

7.2 Control measures are implemented for all potential hazards identified via risk assessments and development of

safe systems of work. Procedures to support planning and management include, AB-IMS08 Pre Contract

Planning, AB-IMS10 Mobilisation and AB-QHSE-02 Risk Assessment Guidance.

7.3 All ABCO employees are appropriately trained in accordance with AB-IMS16 Training, Awareness and

Competence. AB-IMS16 stipulates that employee training will be reviewed and evaluated on an on-going basis

Training records are maintained electronically on the IMS database.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28


___________________________________________________________________________________


___________________________________________________________________________________

7.4 AB-IMS24 Emergency Plans and AB-IMS18 Identification of Health and Safety Risks and Environmental Aspects &

Risks Procedure sets out the actions to be taken in situations where there is an immediate risk to employee

health & safety or the environment.

7.5 In accordance with AB-IMS21 Legal and Other Requirements and P5-PPE Policy. PPE is supplied by ABCO to

employees at no cost to the employee. Minimum PPE to be worn on all ABCO sites includes Hard Hat, Hi-

Visibility Vest/Jacket, Gloves. Light Eye Protection and Safety Footwear. Additional items of PPE are required for

specific tasks. Failure to comply with company PPE requirements may lead to disciplinary action.

7.6 All accidents, incidents and near misses are reported to the QHSE Department and where necessary to external

bodies such as the HSE/HAS, MIAB or Local Authority. Reporting of incidents & accidents is detailed in AB-IMS22

Incident Investigation and AB-QHSE-04 Incident Investigation Procedure.

7.7 All accidents, incidents and near misses that occur within the ABCO group are recorded, each incident / accident

/ near miss is investigated, and appropriate control measures are implemented to prevent reoccurrence.

7.8 ABCO Safety Committee Meetings are conducted on a quarterly basis so that IMS issues can be identified and

discussed.

8.0 AMENDMENT HISTORY

Date Amendment

Number Page

Number New Issue

Comment Approved

By

30.01.19 1 ALL 1.0 Draft and Issue RMD

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 47 of 51


Date: 27/09/2019

APPENDIX 2 – REGISTER OF ENVIRONMENTAL ACTIONS & COMMITMENTS (REAC)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

F8.10 Register of Environmental Actions Commitments (REAC)

Sub No. ReferenceDescription of Environmental Commitment/

Mitigation Action

Achievement Creiteria / Reporting

Requirement

Reference Document

(for futher information)Responsibility Status

Date

Completed Action By

1 EC 001 Provide CEMP, SWMPProduction of key environmental documentation to ensure ongoing environmetmal

protection in strict accordance with EPA DaS Permit and Planning Regsiter Document issue to Client (DAFM)

C20196-MP-002-CEMP

C20196-MP-010-SWMPABCO Ongoing

2 EC 002 Environmental SIte Induction

Environmental induction communicated to all personnel on site:

- The statutory consents associated with the Planning Conditions and Dumping at Sea

Permit & environmental sensitivities at the project site;

- Procedure for stopping works if activities do not comply with environmental legisaltion;

- Monitoring and reporting.

F3.11 Site Safety Induction signed and

stored within site filing system. Site register

updated daily following all project

inductions.

Site Register ABCO Ongoing

3 EC 003 Environmental Toolbox TalksDelivered on a regualr basis to reinforce and supplement information provided during

induction. Site Regsiter updated with all TBT's Site Register ABCO Not Started

4 EC 004 Compliance Document Review Fortnightly Review of SWMP

Monthly Environmental Audit C2016-MP-010-SWMP

ABCO/ Third Party

Environmental AuditerNot Started

5 EC 005

Ecological Management

Marine Mammals - Prevent risk to marine mammals as a

result of underwater noise/ construction activities

Marine Mammal Obserer employed for the project duration, to meet the monitoring and

reporting requirements of the National Parks and Wildlife Service;

Vessels not to travel greater than 5 knots;

All ducted propellers will be guarded.

Daily monitoring. Daily reporting forms

recorded.

Full reporting on MMO operations and

mitigation undertaken to be made to EPA

and [email protected] within 1 month of

campaign completion.

C20196-MP-002-CEMP

Permit Number S0028-01 (4.7)Marine Mammal Observer Not Started

6 EC 006

Ecological Management

Ecological Clerk of Works - To enusure integrity and

preservation of Natura 2000 sites and their qualifiying

interests

ECoW employed for the duration of the works to implament mitigation identified in CEMP. Daily inspection on site C20196-MP-002-CEMP ECoW Not Started

7 EC 007Archaeology & Cultural Heritage- Protect the

archaeological heritage of the area

Appoint a suitably qualified Archaeologist to monitor all works in compliance with the

requirements of the EPA Dumping at Sea Permit, Planning Permission 17/51385 and the

Underwater Archaeology Unit of Department of Culture Heritage and the Gaeltacht.

Daily inspection on site C20196-MP-002-CEMP

Permit Number S0028-01 Archaeologist Not Started

8 EC 008Air Quality - Reduce impacts from dust and emissions of

heavy construction machinery

Road sweeper to be utilised during dry conditions;

Hauliers to take approproate care and cover loads if necessary;

If dust whip is observed, suspended dust monitoring will be undertaken.

Emission limits of 50 micrograms per cubic -

24h average C20196-MP-002-CEMP ABCO Not Started

9 EC 009Landscape - Reduce visual impacts from construction

compound

Screening to be provided around the works compound to reduce impacts on surrounding

residents;

Construction lighting will be directed away from residental and busniess properties to

reduce the effect of light pollution;

Night time working will be minimisued to minimise light pollution from the works.

Daily inspection on site C20196-MP-002-CEMP ABCO Not Started

10 EC 010 Loading Activites

All efforts made to remove soild waste collected during loading. Soild waste brought

ashore.

Material passed though a 30x30cm grid to removed solid waste.

Archaeologist to monitor each bucket as it is lifted from the water and discharged into

Hopper Bage.

Daily dredge log C20196-MP-002-CEMP ABCO Not Started

11 EC 011Dumping at Sea - ensure compliance with dump at sea

permit S0028-01

No material will be dumped at sea that is considered unsuitable for disposal..

Automatic logging of each diposal activity,

Daily disposal log.

Logged vessel track record data collected

for each disposal event using IDS vessel

monitoring equipment

C20196-MP-002-CEMP

Permit Number S0028-01 ABCO Not Started

12 EC 012

Water Quality - Reduce the negative impact of dreding

activites on turbidity, suspended solids, dissolved oxygen

and plankton communities

Environemntal bucket used for all soft-sediment dredging.

Overflow during loading activites is prohibited.

Tubidity levels shall not exceed the prediected SS values detailed in the document

'Mathematical modelling of proposed dredge and spoil disposal operations for Killybegs

harbour development works '.

Monitoing results made available on site.

Monitroing report to be made available to

the Agency as part of ARE

C20196-MP-002-CEMP

Permit Number S0028-01 ABCO/ Client Not Started

Client

Project Name

Project Number

Register of Environmental Actions & Commitments (REAC)

Department of Agriculture, Food and the Marine (DAFM)

C20196

DAFM Killybegs Smoothpoint Pier Extension

Document: F8.10

Rev: 1.0

Date: 30/08/2019

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 48 of 51


Date: 27/09/2019

APPENDIX 3 – DREDGE LAYOUT PLAN

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

0

20

30

40

25

35

45

50

55

60

65

984 T

RA

CK

S

SE

RV

IC

E

HA

TC

H

SE

RV

IC

E

HA

TC

H

SE

RV

IC

E

HA

TC

H

SE

RV

IC

E

HA

TC

H

SE

RV

.

HA

TC

H

SE

RV

.

HA

TC

H

510

15

FU

NN

EL

D

U

ME

SS

GA

LLE

Y

CH

AN

GE

CABLES

WM

/T

D

U

RE

FR

.

WA

SH

DIS

H

MIC

RO

FRYER

HA

LL/S

TA

IR

S

WC

MA

CH

.

VE

NT

.

EM

ER

.

ES

C.

A

1

B C D E F G H I J K L M N O P Q R S T U V X X2

34

56

78

910

1112

1314

1516

1718

A B C D E F G H I J K L M N O P Q R S T U V X X

Dredge Pocketto -9m CD

Dredge Pocketto -7m CD

Exclusion zone

MLWS Contour = +0.60mCD

Line of buoys toshow exclusion zone

Alarm to be raised in wheel house of dredgershould bucket cross into exclusion zone

Indicative location of rock abovedesign level. Rock location to beconfirmed on site

Capall Mara excavating soft material into850m3 split hopper barge

850m3 split hopper barge

850m3 split hopper bargebeing towed to dump site

Ocean bank tug

Possible risk mitigation measurematerial to be dredged and broughtashore for testing and remediation

-2.20mCD contour.Dredging can only take place

at high water in this area toallow for draught of vessels

150.751m 63.593m

Rock armour to be removedby land marine

A A

Foyle barge for dredging

Syncrolift

Benchmark for daily bucketchecks to confirm accuracy ofGPS machine guidance system

Quay

Exte

nsion

Exist

ing Q

uay W

all to

be R

etaine

dLiv

e Ber

th to

be M

aintai

ned

Drawing Status

Scale at A1

Drawing No Issue

Drawing Title

Job Title

A1

1

2

3

4

5

6

7

8

9

10

11

A B C D E F G H I J K L M N

Do not scale

T1

1:500

Preliminary

E2538-AML-00-XX-DR-X-1001

Phase 2A Layout Plan

Contractor

Issue Date By Chkd Appd

/ /T1 15 05 19 PM JMcG JMcG

Tender Issue

ABCO Marine Ltd

ABCO House, 282 Moira Road, Lisburn, BT28 2TU

t +44 (0) 2892 622731

www.abcomarine.co.uk

Principal Contractor

Client

Killybegs Smooth Point Pier

Extension

Key:

Extent of soft material to be dredged to -9mCD

Extent of dredge pocket to be dredged to -7mCD

Extent of Dredge pocket to be graded to existingsurface level at a minimum 1:5 slope

Extent of dredge envelope to be graded to a level of-7mCD at a minimum 1:5 slope

Extent of Dredge pocket to be graded to existingsurface level at a minimum 1:4 slope

Extent of rock material in dredge envelope to begraded to existing rock surface level at 1:1 slope

Extent of dredge pocket to be removed and takenashore for testing

Extent of rock to be removed (data taken from March 2000 boreholes)

Barge Exclusion zone

MLWS Area at low tide access by land

-2.2mCD This area is subject to reduced accessdue to shallow draft

Proposed Line of buoys

Material to be removed to licensed facility

Tide Levels

MHWS = +4.10m CD MHWS = +1.76m ODMHWN = +3.00m CD MHWS = +0.66m ODMLWN = +1.50m CD MLWN = -0.84m ODMLWS = +0.060m CD MLWS = -1.74m OD

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

AutoCAD SHX Text

b

AutoCAD SHX Text

e

AutoCAD SHX Text

d

AutoCAD SHX Text

c(f)

AutoCAD SHX Text

b

AutoCAD SHX Text

e

AutoCAD SHX Text

d

AutoCAD SHX Text

c(f)

AutoCAD SHX Text

b

AutoCAD SHX Text

e

AutoCAD SHX Text

d

AutoCAD SHX Text

c(f)

AutoCAD SHX Text

-2

AutoCAD SHX Text

-1

AutoCAD SHX Text

0

AutoCAD SHX Text

1

AutoCAD SHX Text

2

AutoCAD SHX Text

3

AutoCAD SHX Text

4

AutoCAD SHX Text

5

AutoCAD SHX Text

6

AutoCAD SHX Text

7

AutoCAD SHX Text

8

AutoCAD SHX Text

9

AutoCAD SHX Text

10

AutoCAD SHX Text

11

AutoCAD SHX Text

13

AutoCAD SHX Text

14

AutoCAD SHX Text

16

AutoCAD SHX Text

17

AutoCAD SHX Text

18

AutoCAD SHX Text

19

AutoCAD SHX Text

20

AutoCAD SHX Text

21

AutoCAD SHX Text

15

AutoCAD SHX Text

12

AutoCAD SHX Text

22

AutoCAD SHX Text

23

AutoCAD SHX Text

24

AutoCAD SHX Text

25

AutoCAD SHX Text

26

AutoCAD SHX Text

27

AutoCAD SHX Text

28

AutoCAD SHX Text

29

AutoCAD SHX Text

31

AutoCAD SHX Text

30

AutoCAD SHX Text

32

AutoCAD SHX Text

33

AutoCAD SHX Text

34

AutoCAD SHX Text

35

AutoCAD SHX Text

36

AutoCAD SHX Text

37

AutoCAD SHX Text

38

AutoCAD SHX Text

39

AutoCAD SHX Text

40

AutoCAD SHX Text

41

AutoCAD SHX Text

42

AutoCAD SHX Text

43

AutoCAD SHX Text

44

AutoCAD SHX Text

45

AutoCAD SHX Text

46

AutoCAD SHX Text

47

AutoCAD SHX Text

48

AutoCAD SHX Text

49

AutoCAD SHX Text

50

AutoCAD SHX Text

51

AutoCAD SHX Text

52

AutoCAD SHX Text

53



Page : 49 of 51


Date: 27/09/2019

APPENDIX 4 - COMPLAINT/ SPILLS/ INCIDENT REPORT

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

F8.7 Environmental Complaints / Spills / Incident Report

Document: F8.7 UNCONTROLLED WHEN PRINTED Page 1 of 1

Rev: 1.0

Date: 30/01/18

Project

(Title/Number)

Date/Time of Incident

What happened, nature of incident?

Did others witness the incident? If so who?

What caused it?

What measures have been taken to ensure it does not happen again?

Was there any significant pollution or environmental damage to land, water or protected areas – for example: dust,

odour or noise pollution outside the site or spillage of polluting liquids onto the ground, or into a drain or a watercourse?

If so what?

Is there a continuing threat? YES / NO

Circulate this form to ABCO Management & QHSE

Manager

Date Form was circulated?

Date Form was returned?

Please PRINT your

name & sign:

ABCO QHSE Review:-

Does the incident need to be the authorities? YES / NO

How (if required) was the incident reported?

Please PRINT your

name & sign:

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 50 of 51


Date: 27/09/2019

APPENDIX 5 – COMPLAINT/ SPILLS/ INCIDENT LOG

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

F8.8 Environmental Complaints / Spills / Incident Log


Rev: 1.0

Date: 30/01/18

Reference Date Details of Incident

Named ABCO

person dealing

with issue

Action Taken Was the incident

reportable?

Follow up actions

if any?

Date issue

was closed

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Page : 51 of 51


Date: 27/09/2019

APPENDIX 6 - MARINE MAMMAL RECORDING FORM

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

F7.31 MMO Recording Form


Rev: 1.0

Date: 30/01/18

MARINE MAMMAL RECORDING FORM - COVER PAGE Regulatory reference number (e.g. DECC no., BOEM permit no., OCS lease no., etc.)

Country Location Ship/ platform name Contract No:

Client

Contractor Survey type site VSP 2D WAZ 3D piling 4D explosives OBC other 4C

Start date End date

Number of source vessels Type of source (e.g. airguns)

Number of airguns (only if airguns used)

Source volume (cu. in.)

Source depth (metres)

Frequency (range in which peak

energy is emitted, in Hz)

Intensity (primary peak-to-peak

amplitude in dB re. 1µPa or bar metres)

Shot point interval (metres)

Method of soft start

increase number increase frequency increase pressure increase number increase number other of guns (where permitted) (where permitted) and frequency and pressure

Visual monitoring equipment used (e.g. binoculars, big eyes, etc.)

Magnification of optical equipment (e.g. binoculars)

Height of eye above water surface (metres)

How was distance of animals estimated?

by eye

with laser rangefinder

with rangefinder stick/ callipers

with reticle binoculars

by relating to object at known distance

other

Number of dedicated MMOs

Training of MMOs

JNCC approved MMO training course for UK waters

PSO training course for the Gulf of Mexico

MMO training course for Irish waters

MMO training course for New Zealand waters

other

none

Was PAM used?

yes no

Number of PAM operators

Description of PAM equipment

Range of PAM hydrophones from airguns (metres)

Bearing of PAM hydrophones from airguns (relative to direction of travel)

Depth of PAM hydrophones (metres)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Rev: 1.0

Date: 30/01/18

MARINE MAMMAL RECORDING FORM – OPERATIONS

Regulatory Reference Number ...............………………………………... Ship / Project Name ........................................................................... (e.g. DECC no., BOEM permit no., OCS lease no., etc.) Complete this form every time the airguns are used, including overnight, whether for shooting a line or for testing or for any purpose. Times should be in UTC, using the 24 hour clock.

Date

Reason for firing l = line t = test x = test

followed immediately by

line

Time soft start /

ramp-up began

Time of full power

Time of start of line

Time of end of line

Time of reduced

output (if relevant)

Time airguns/ source

stopped

Time pre-shooting

search began

Time search ended

Time PAM began

Time PAM ended

Dept range (during pre-

shoohting search)

s = <200m d = >200m b = both

Was it day or night in

period prior to firing?

d = day n = night w = dawn k = dusk

Was any mitigating

action required?

(yes/ no)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28



Rev: 1.0

Date: 30/01/18

MARINE MAMMAL RECORDING FORM - EFFORT

Regulatory reference number ................………………………………... Ship/ platform name ........................................................................... (e.g. DECC no., BOEM permit no., OCS lease no., etc.)

Record the following for all watches, even if no marine mammals are seen. START A NEW LINE IF SOURCE ACTIVITY OR WEATHER CHANGES. ENTER DATA AT LEAST EVERY HOUR.

Date

Visual watch

or PAM (v/ p)

Observer's Name / Operator's Name

Time of start of section

of watch (UTC, 24hr

clock)

Time of end of section

of watch (UTC, 24hr

clock)

Source activity

(f/ s/ r/ n/ v)

Start position (latitude and longitude)

Depth at start (m)

End position (latitude and longitude)

Depth at end

(m)

Speed of

vessel (knots)

Wind dir’n

Wind force (B’fort scale)

Sea state

(g/s/c/r)

Swell (o/m/l)

Vis. (visual watch only)

(p/m/g)

Sun glare (visual watch only)

(n/wf/sf/vf/wb/sb/

vb)

Precip. (n/l/m/h/

s)

Visual watch or PAM: v = visual watch; p = PAM Source activity: f = full power; s = soft start; r = reduced power (not soft start); n = not active; v = variable (e.g. tests) Sea state: g = glassy (like mirror); s = slight (no/ few white caps); c = choppy (many white caps); r = rough (big waves, foam, spray) Swell: o = low (< 2 m); m = medium (2-4 m); l = large (> 4 m) Visibility: p = poor (< 1 km); m = moderate (1-5 km); g = good (> 5 km) Sun glare: n = none; wf = weak forward; sf = strong forward; vf = variable forward; wb = weak behind; sb = strong behind; vb = variable behind Precipitation: n = none; l = light rain; m = moderate rain; h = heavy rain; s = snow

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

F7.31 MMO Recording form


Rev: 1.0

Date: 30/01/18

MARINE MAMMAL RECORDING FORM – SIGHTINGS Regulatory reference number (e.g. DECC no., BOEM permit no., OCS lease no., etc.)

Ship/ Project Name Sighting number (start at 1 for first sighting of survey)

Acoustic detection number (start at 500 for first detection of survey)

Date

Time at start of encounter (24hr clock)

Time at end of encounter (24hr clock)

Were animals detected visually and/ or acoustically?

visual acoustic both

How were the animals first detected?

visually detected by observer keeping a continuous watch visually spotted incidentally by observer or someone else acoustically detected by PAM both visually and acoustically before operators/ observers informed each

other

Observer's/ operator's name

Position (latitude and longitude) Water depth (metres)

Species/ species group

Description (include features such as overall size; shape of head; colour and pattern; size, shape and position of dorsal fin; height, direction and shape of blow; characteristics of whistles/ clicks)

Bearing to animal (when first

seen or heard) (bearing from true north)

Range to animal (when first seen or heard) (metres)

Total number

Number of adults (visual sightings only)

Number of juveniles (visual sightings only)

Number of calves (visual sightings only)

Photograph taken yes no

Behaviour (visual sightings only)

Direction of travel (relative to ship)

towards ship variable away from ship milling parallel to ship in same direction as ship stationary parallel to opposite direction to ship other crossing perpendicular ahead of ship unknown

Direction of travel (compass points)

N W NE NW E variable SE stationary S unknown SW

Airgun (or other source) activity when animals first detected

full power not firing soft start reduced power

(other than soft start)

Airgun (or other source) activity when animals last detected

full power not firing soft start reduced power

(other than soft start)

Time animals entered mitigation/ exclusion zone (UTC, 24hr clock)

Time animals left mitigation/ exclusion zone (UTC, 24hr clock)

Closest distance of animals from airguns (or other source) (metres)

Time of closest approach (UTC, 24hr clock)

If seen during soft start give: First distance Closest distance Last distance during soft start (metres)

What action was taken?(according to requirements of guidelines/ regulations in country concerned) none required delay start of firing shut-down of active source power-down of active source power-down then shut-down

of active source

Length of power-down and/ or shut-down (if relevant) (length of time until subsequent soft start, in minutes)

Estimated loss of production (if relevant) due to mitigating actions (km)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-05-2020:04:08:28

Documents

ABCO Marine - epa.ie · ABCO No: C20196 -MP 002 CEMP Page : 1 of 51 DAFM Killybegs Smooth Point Pier Extension Issue: REV 002 Date: 27/09/2019 ABCO MARINE Marine Civil Engineering