AIR POLLUTION AND ENVIRONMENTAL CONSULTANCY

Transcription

1 ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON AIR QUALITY IMPACT OF PROPOSED DRYER EXPANSION PROGRAMME AT MALLOW PLANT, CO. CORK DAIRYGOLD CO-OPERATIVE SOCIETY LTD. CO. CORK ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON AIR POLLUTION AND ENVIRONMENTAL CONSULTANCY ENVIROCON ENVIROCON ENVIROCON ENVIROCON ENVIROCON LTD. ENVIROCON OLD ROAD ENVIROCON KILCARN BRIDGE ENVIROCON NAVAN, CO. MEATH ENVIROCON Tel: (046) ENVIROCON Fax: (046) ENVIROCON ENVIROCON Date: 19 TH JULY 2012 Report By: Michael L. Bailey EPA Export :23:03:54

2 1.0 INTRODUCTION Dairygold Cooperative Society Ltd. is planning to redevelop its production facility at Mallow to provide additional processing of milk after 2015 following the abolition of the Milk Quota system. The milk processing plant is currently operating under an IPPC Licence (P ) issued by the Environmental Protection Agency in April Schedule A of the Licence specifies air emission limit values for the boilers, thermoheater and the Niro Dryer. Two new Niro Dryers plants are planned that will result in an increase from the current maximum powder production rate of 5.5 tonnes/h to 20.5 tonnes/h, with the installation of two 7.5 tonnes/h dryers and associated evaporator plant, pasteurization, packing and storage buildings and silos. The new dryer building will be located within the same area of the site as the existing dryer building and this will require the demolition of some of the adjacent structures to allow construction of the new buildings to house the new evaporators, dryers and packing lines. There is sufficient boiler capacity on-site to meet future process steam demand and so no additional boiler plant is required as part of the proposed expansion in milk powder production. However, two new thermoheaters will be installed to provide process heat to the new dryers. There are 4 boilers used to generate steam and these consist of a 13.6MW CHP (Combined Heat and Power) boiler, a 19 MW boiler and two 11.5 MW boilers that burn natural gas. In the event of an interruption in the supply of natural gas to the facility, the 19MW and 11.5MW boilers can be run on gasoil. At present sufficient steam generating capacity for existing milk processing requirements by operating the CHP and 19MW boiler, with the other two used as backup boilers, with one boiler running on hot-standby. As part of the environmental impact assessment, Envirocon Ltd. was requested to undertake an air quality impact evaluation exercise of the proposed expansion development on local air quality. The detailed study described in this report examined the No Development and With Development operational scenarios using air quality dispersion modelling software. The ADMS4 model was used to predict ground level concentrations within the area around the Dairygold facility. This is an advanced air quality model that is suitable for modelling complex industrial sources with buildings and numerous emission sources and is approved for use by the Environmental Protection Agency in Ireland. The No Development scenario examined the impact of emissions from the existing boiler stacks and particulate emissions from the Niro Dryer on local air quality. Particulate emissions from the dryer exhaust stack were modelled as PM 10 (particulate material with a mean aerodynamic diameter of less than 10 µm). The With Development scenario examined the air quality impact of atmospheric emissions from the two new dryers and thermoheaters. The predicted ground level concentrations for nitrogen dioxide ( NO 2 ), sulphur dioxide (SO 2 ) and particulates (PM 10 ) were compared with the National Air Quality Standards (NAQS) specified in the Air Quality Standards Regulations 2011 (SI: No 180 of 2011). ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 1 EPA Export :23:03:54

3 2.0 EMISSION SOURCES 2.1 Boilers Existing Boiler Plant No Development The boiler plant is housed in the boiler building that is located within the SE part of the Dairygold facility and comprises 4 boilers that normally burn natural gas. The primary boiler that operates close to full load for much of the time is a Combined Heat (CHP) unit fired on natural gas with a steam generating capacity of 18 tonne/h. The generating capacity of this boiler is supplemented with Boiler No 1 that has a capacity of 29.5 tonne/h and normally runs on natural gas. The other two boilers, Boiler No 2 and 3 each have a steam generating capacity of 18 tonne/h and are only used in the event of the CHP boiler or Boiler No 1 being taken off-load and so operate in Hot-Standby mode for much of the year. In the event of an interruption of the gas supply to the plant, Boilers No 1, 2 and 3 can burn gasoil as an alternative fuel. There is also a small boiler, referred to as a Thermoheater, with a capacity of 1,850 kw, which burns natural gas and is installed to heat air for the Niro Dryer plant. This small boiler is located in the dryer building with the exhaust stack discharging from the northern side of the building. The small heater capacity of this boiler will result in very low exhaust emissions compared to the main boilers. Fuel consumption and emission data for the boiler exhaust stacks were supplied by the company. This information is based on the exhaust stack measurements obtained from manual sampling programmes and boiler manufacturer performance data when the units are fired on natural gas and, in the case of Boilers No1, 2 and 3, also burning gasoil. Table 1 Emission characteristics of boilers and existing thermoheater exhaust stack Stack ( IPPC Licence Designation) Stack Ht (m) Diameter (m) Ref Exhaust Volume (Nm 3 /h) (i) Actual Exhaust Volume (Nm 3 /h) (ii) Exit T. ( o C) Exit Vel (m/s) Boiler No 1 (A1-1) ,000 26, Boiler No 2 (A1-2) ,600 16, Boiler No 3 (A1-3) ,600 16, CHP Boiler (A1-4) ,200 45, Dryer Thermoheater (A1-5) ,700 2, Note: (i) Exhaust flows at EPA IPPC Licence Reference Conditions of Dry/ 3% O 2. (ii) Actual exhaust volume flows for Boilers No 1, 2 and 3 and the thermoheater are based on O 2 /moisture conditions in the flue gas of 3.2% O 2 and 16% moisture and 15% O 2 and 10% moisture for the CHP boiler. Column 4 of Table 1 gives the exhaust airflow from each boiler and the thermoheater at the EPA IPPC Licence Reference Conditions of Dry gas and 3% Oxygen (O 2 ) with the hourly flow rate as discharged expressed in Nm 3 /h (Normalised cubic meters per hour referenced at a temperature of 0 o C and pressure of 1 atmosphere) in column 5. For boilers No1, 2 and 3 and the thermoheater, the actual exhaust flow is based on a moisture content in the flue gas of 16% and an oxygen content of 3.2%. For the CHP boiler information supplied by the ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 2 EPA Export :23:03:54

4 manufacturer gives an oxygen content of approximately 15% and 10% moisture. The exhaust flow at the Reference Condition of 15% O 2 was estimated to be a maximum flow of 39,150 Nm 3 /h, based on the design exhaust flow for this unit burning natural gas. Table 2 SO 2 and NO x emission estimates from the boilers based on the maximum hourly load Stack ( IPPC Licence Designation) SO 2 Hourly Average (g/s) NO x Hourly Average (g/s) Natural Gasoil Natural Gasoil gas gas Boiler No 1 (A1-1) Neg Boiler No 2 (A1-2) Neg Boiler No 3 (A1-3) Neg CHP Boiler (A1-4) Neg Dryer Thermoheater (A1-5) Neg Maximum hourly SO 2 emission rates from the boiler exhaust stacks are given in Table 2. These emission rates, expressed as g/s, were calculated by applying a sulphur content of 0.1% by weight to the maximum hourly gasoil consumption rate for the 3 boilers that are designed to burn oil. The maximum permitted sulphur content for gas oil was reduced to 0.1% by weight in 2008 with the implementation of the EU Directive 1999/32/EC and so SO 2 emissions are very low when this grade of oil is used. The CHP boiler and Dryer thermoheater only burn natural gas. Emissions of SO 2 from burning natural gas are negligible and so an emission value of zero may be assumed for the purpose of air dispersion modelling. This approach to deriving SO 2 emissions from boilers provides a more accurate rate than multiplying the exhaust flow rates for each stack by a uniform emission concentration for SO 2 of 200 mg/nm 3 as this value is an upper emission limit value. The rate of NO x emissions from the boiler and thermoheater stack within the facility depends on the type of fuel being burnt and combustion conditions within the burner zone of the boiler. Formation of NO x in the flue gas is a complex process as it is related not only to the amount of combustion air available and chemistry of the fuel being burnt but also to the temperature within the flame area of the boiler. Over 95% of the total nitrogen oxides (NO x ) in the exhaust gas from industrial boilers is typically emitted as nitric oxide (NO) with the remainder (< 5%) emitted as nitrogen dioxide (NO 2 ). For natural gas firing, all NO x generated is thermal NO x as the amount of nitrogen in the fuel is negligible. The NO x forms in the zone downstream of the burner where the combustion air is mixed. The maximum NO x emission rate for each of the boilers (Table 2) was calculated from the hourly exhaust flow with the boilers running at full load and applying the maximum permitted emission concentrations in the exhaust gas of 200 mg/nm 3 specified in the IPPC Licence for Boilers No 1, 2 and 3 and the thermoheater. The same maximum NO x emission concentration was used to calculate emissions from the thermoheater exhaust stack. A value of 300 mg/nm 3 given in the IPPC Licence for the CHP exhaust stack was used to calculate the emission rate from this boiler plant. ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 3 EPA Export :23:03:54

5 2.1.2 Proposed Boiler Plant With Development There is sufficient boiler capacity on-site to meet future process steam demand and so no additional boiler plant is required as part of the proposed expansion in milk powder production. However, two new thermoheaters will be installed to provide process heat to the new dryers. In the event of an interruption in the supply of natural gas to the facility, Boilers No 1 and No 2 or 3 boilers can be run on gasoil. At present sufficient steam generating capacity for existing milk processing requirements are achieved by operating the CHP and 19MW boiler, with the other two used operating as back-up boilers, with one on hot-standby. Boilers No 2 and 3 have a combined steam generating capacity of 36 tonnes and these will only be used in the event of the CHP boiler or Boiler No 1 being taken off-line for planned maintenance or emergency shut-down. Projected future steam demand for the operation of all 3 dryers will be a maximum of about 35 tonne/h. The existing combination of the CHP boiler and the 19MW Boiler No 1 can generate up to 47 tonne/h with both operating at 100% load. The CHP boiler will continue to operate as the main boiler with additional demand being met by Boiler No 1. Boilers No 2 and 3 will only be used as back-up. The emission characteristics of the 4 boilers and thermoheater given in Tables 1 and 2 can be used for assessing the future emissions of NO 2 and SO 2 as they represent maximum emission rates for each boiler. The only change in the boiler operating scenario with the additional dryers will be an increase in the number of weeks during the year when the production is occurring. At present, it is approximately from March to August when milk processing is taking place and this is projected to increase to 40 weeks from February to November. The two thermoheaters associated with the two new dryers will operate during the February to November milk production period, along with the existing thermoheater. These small boilers will operate on natural gas only. The emission characteristics of the two new thermoheaters are given in Table 3. Emissions of NO x are 0.45 g/s, based on a maximum emission concentration of 200 mg/nm 3 in the flue gas of each of these thermoheaters. Table 3 Emission characteristics proposed thermoheater exhaust stacks Stack Stack Ht (m) Diameter (m) Ref Exhaust Volume (Nm 3 /h) (i) Actual Exhaust Volume (Nm 3 /h) (ii) Exit T. ( o C) Exit Vel (m/s) Dryer 2 Thermoheater ,500 10, Dryer 3Thermoheater ,500 10, Note: (i) Exhaust flows at EPA IPPC Licence Reference Conditions of Dry/ 3% O Process Plant Existing Dryer Emissions No Development There is currently one dryer in operation and emissions from this production plant are emitted from a stack located on the roof of the Dryer building, which is the highest building and ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 4 EPA Export :23:03:54

6 located in the western part of the site. This exhaust stack (A2-1) extends 2m above the building roof. Particulate and exhaust flow measurements undertaken in recent years give a calculated maximum exhaust volume flow of approximately 223,200 Nm 3 /h. The emission parameters for the existing dryer stack is given in Table 4, with the total particulate material (PM) emission rate based on the current permitted emission limit value in the IPPC Licence of 50 mg/nm 3. However, measurements carried out demonstrate maximum PM concentrations consistently below 10 mg/nm 3. Table 4 Emission characteristics and emissions rates of total particulates (PM) from the Niro Dryer exhaust stack Emission Stack Stack Ht (m) Diameter (m) Exhaust vol (Nm 3 /h) Exhaust vol (Nm 3 /s) Exit T. (C) Exit Vel (m/s) Dryer No , Emission vent Ref Particulate Conc (mg/nm 3 ) Particulate Emission (g/s) Dryer No 1: A Particulate emissions from the 3 boilers and thermoheater are insignificant compared to those from the process exhaust stack. Burning natural gas in industrial boilers produces negligible particulate matter in the flue gas compared to burning fuel oil or coal Proposed Dryer Emissions With Development Table 5 Total particulate (PM) emission characteristics of proposed process exhaust stacks Emission Stack (IPPC Ref) Stack Ht (m) Diameter (m) Exhaust vol (Nm 3 /h) Exhaust vol (Nm 3 /s) Exit T. (C) Exit Vel (m/s) Dryer No 1: (A2-1) , Dryer No , Dryer No , Emission Stack (IPPC Ref) Particulate Conc (mg/nm 3 ) Particulate Emission (g/s) Dryer No 1: (A2-1) Dryer No Dryer No ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 5 EPA Export :23:03:54

7 The emission characteristics of the dryers operating in the proposed expansion of the facility are given in Table 5. The exhaust stacks of the two new dryers will be located on top of the new drier building that will be constructed adjacent to the south side of the existing dryer building. This building has a planned roof height of 39.6m. Each exhaust stack will have a minimum height above the roof of 2m and an exit diameter of 2m. The design exhaust air flow from each dryer is calculated to be 137,600 Nm 3 /h and this will resulting in an exit velocity from the stacks of 15.3 m/s. Exhaust air from the new dryer plant will pass through a baghouse containing high efficiency bag filters, resulting in low particulate emissions of 10 mg/nm 3 or lower. Therefore, the maximum particulate emissions concentration from the new exhaust stacks are expected to be well below 20 mg/nm 3, resulting in mass emission rates for PM of <0.8 g/s at maximum dryer output. The emission rates for the two new dryers given in Table 5 are based on maximum exhaust flow with a PM concentration in the exhaust air of 20 mg/nm MODEL REQUIREMENTS 3.1 Introduction The ADMS4 (Atmospheric Dispersion Modelling System Version 4.2, February 2010) air quality dispersion model was used to predict ground level concentrations within 0.75km of the facility boundary. The ADMS4 model has been developed by CERC (Cambridge Environmental Research Consultants) and is a third generation prediction model. It has been used for air pollution studies worldwide and the modelling software has been approved by the Environmental Protection Agency for IPPC applications. The ADMS4 model takes account of the substantially improved understanding of the plume dispersion within the atmospheric boundary layer by the use of more complex parameterisation, than used in previous generation models. It uses boundary layer theory based on the Monin-Obukhov length and boundary layer height instead of the categories of atmospheric stability 3.2 Model Input Parameters Emission Source Characteristics Data relating to the stack height and exit diameter, exit velocity and temperature with the NO x and SO 2 emissions for each of the boilers and PM emissions from the dryer stacks as described in Section 2 above were input into the model. The emission rates for these pollutant parameters are based on continuous maximum emissions for each exhaust stack. No daily or seasonal variation in the operational conditions for the boilers was applied and so the emission rates represent a worst-case air dispersion modelling scenario for predicting ground level concentrations of NO x and SO 2 for both the No Development and With Development plant scenarios. Maximum continuous daily operation of the dryer plant was also assumed in calculating the daily average PM emission rates from the dryer stacks. However, for each of the dryers there ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 6 EPA Export :23:03:54

8 will be occasions during the year when one or more are not in production and so particulate emissions will be zero. The daily variation in the number of hours of production was also not included and so the PM (expressed as PM 10 in the model) was based on maximum output as given in Tables 4 and 5 above Building Wake Effects The effect of buildings on the dispersion of emission plumes from nearby stacks can have a significant effect on predicted downwind ground level concentrations, under certain weather conditions. The presence of a building creates turbulence around the structure, which may result in the emission plume being caught in this area of turbulence. This zone consists of a recirculating flow region or cavity near the building with a diminishing turbulent wake further downwind. The emission plume entrained in the cavity region will be brought down to ground level near the building and so this will result in a significant increase in predicted ground level concentrations. Buildings that are more than 30% of the stack heights being modelled should be included in the ADMS4 model as these can contribute to building wake effects on plume dispersal from an exhaust stack. An assessment of the existing buildings layout and proposed redevelopment of the dryer building area to house the new dryer plant was undertaken based on digital site plans and elevations of the various buildings. There are a number of building structures within the site, which are used for production and storage, along with tanks and other miscellaneous smaller buildings such as the boiler building. The 4 boilers are housed within a building, which has a roof height of 5.5m and the 4 exhaust stacks are located on the roof of this building. In the case of the Boiler No 1, 2 and 3 stacks which are over 33m high the roof of the boiler building is well below 30% of these stacks and so will not contribute to significant wake effects on the plume dispersion. However, the CHP stack is much lower at 18.8m and the boiler building may have a marginal effect on plume dispersion and so was included in the dispersion model. The dominant building affecting the emission plume from the existing dryer exhaust stack and thermoheater stack is the dryer building and evaporator building structure with an overall maximum height of 32m. With the proposed redevelopment of this part of the site to construct the buildings for the new dryers the maximum height will increase to 39-40m. Dimensions of the main building structures are as follows with each structure aligned with the side identified as Length orientated approximately along a N-S axis. Existing Dryer Building Height 31.7m, Length 19m, Width 38m New Dryer Building Height 39.6m, Length 38m, Width 45m New Evaporator Building Height 29m, Length 17m, Width 40m Packaging/Storage Building Height 16m, Length 19m, Width 25m Storage Building Height 16m, Length 130m, Width 45m Climatological Data Sequential hourly climatological data from the meteorological station at Cork Airport (35km to SE) were used in predicting the ground level concentrations of the various pollutants in the ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 7 EPA Export :23:03:54

9 locality of the Dairygold facility. A two-year period of hourly climatological data (2005 and 2006) from this station was used. In addition, climatological data for 2006 from Shannon Airport (60km to N) were also included in the 3-year data-set as Mallow is further inland and at a lower altitude of 50m OD than Cork Airport (154m OD) and so will also tend to reflect overall wind conditions across the North Cork area. Therefore, it was considered that a combination of these two sets of climatological data would be indicative of the wind field pattern throughout the year for the Mallow area. This would provide a data-set for evaluating the direction and rate of dilution of the boiler and process stack emission plumes from the Dairygold facility using the ADMS4 model. The year-to-year variations in wind speed and direction were taken into account in the modelling by using the three data-sets; instead of relying on predicted concentration results based on a single year. The wind roses for the three separate years at Cork Airport and Shannon Airport are given in Figure 1. Input parameters for wind speed, direction, cloud cover and air temperature provided values to enable the degree of atmospheric turbulence, or stability within the lower air layers to be calculated. Atmospheric instability occurs due to heating of the ground by solar radiation and this is related to the amount of cloud cover, coupled with the solar inclination, which is a function of the time of year. These parameters are computed by the ADMS4 dispersion model Surface Roughness The vertical wind profile above the ground is an important parameter in determining the structure of the atmospheric boundary layer near the ground. The Monin-Obukhov length provides a measure of the relative importance of buoyancy generated by heating of the ground and mechanical mixing generated by the frictional effect of the earth s surface. This frictional effect is related both to the surface roughness length and wind speed. The former parameter is supplied as input to the ADMS4 dispersion model and it can vary from 0.001m over open sea to 1.5m in urban areas. It is used in calculating the boundary layer structure, which determines the rate of dispersion of an emission plume both in the horizontal and vertical plane as the plume travels downwind from the stack. A surface roughness length value of 0.5m, which approximates to surfaces within suburban/parkland areas, was used in the ADMS4 model to represent conditions in Mallow Receptor Grid A receptor grid with regular spacing of 2,500 receptor points (50x50 grid) was used to predict ground level concentrations within the locality. The grid covered an area of 1.2 x 0.9 km around the site with a grid reference of E, N for the SW corner and extending to E, N at the NE corner of the grid. This area is where the maximum ground level impact of emissions from the Dairygold manufacturing plant is likely to occur, due to the effects of building wake turbulence as the plume disperses downwind of the site Terrain The surrounding terrain is flat or gently undulating in the locality, with a low slope gradient and so a flat terrain was assumed for the modelling runs. The terrain module in the ADMS4 is generally for assessing the impact of dispersion of the emission plume along slopes of greater ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 8 EPA Export :23:03:54

10 than 1:10 and so the local terrain profile did not require this additional refinement in the model NO x and NO 2 modelling As the emission plumes from the boiler stacks disperse downwind, the nitric oxide (NO) component emitted is partially converted to NO 2. The rate at which this conversion takes place varies with the degree of solar insolation present and the atmospheric instability conditions and so changes throughout the day and over the year. The conversion rate of NO to NO 2 is generally limited by the level of ozone present. This is normally at a maximum value during the summer, with strong sunshine forming convective cells near the ground resulting in unstable flow conditions. The ADMS4 model incorporates the reactions between ozone, NO and NO 2 using the simple reaction, which is based on the chemical reactions between ozone, NO and NO 2. This scheme takes account of the photo-chemical reactions, in the conversion process of NO to NO 2 within the emission plume, based on solar radiation and travel time of the pollutant between the emission source and receptor locations. Background concentrations of ozone and NO x are used to initialise the chemistry scheme in the ADMS4 model. An annual average level for NO x of 30 μg/m 3 and 14 μg/m 3 for NO 2 was used as background concentrations appropriate for Mallow. An annual average ozone concentration of 44 µg/m 3 was used in the model, based on results from an EPA monitoring site at Glashaboy Co. Cork, will be typical of background levels in the North Co. Cork area Background Concentrations Table 6 Air Quality in Zone D (non-urban) Regions of Ireland in 2010 (μg/m 3 ) Pollutant Annual average concentration Nitrogen Dioxide (NO 2 ) 3-10 Sulphur Dioxide (SO 2 ) <5 PM Source: Air Quality in Ireland 2010, EPA 2011 EU Legislation on Air Quality requires Member States to divide their country into 4 zones (A-D), for the purpose of air quality monitoring, reporting, assessment and management. Outside of the Dublin and Conurbation and towns with populations greater than 15,000 the remainder of the country is within Zone D. Mallow is within the Zone D (small town/rural) air quality zone classification. Representative air quality data for Zone D locations in Ireland for 2010 published by the EPA (Air Quality in Ireland 2011) are given in Table 6. In the absence of any ambient monitoring data for Mallow, concentrations for NO 2, SO 2 and PM 10 given in Table 6 were used as background values. This allows an estimate to be calculated of the total or combined impact on local air quality of predicted contribution from the facility with existing pollutant levels. This combined impact can then be compared with the NAQS values. The total impact is calculated by adding twice the background SO 2 concentration to the predicted hourly 99.7 percentile or daily 99.2 percentile value. ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 9 EPA Export :23:03:54

11 In relation to combined NO 2 impacts, a background annual average value is already included in the ADMS4 model for NO x and NO 2 calculations as outlined in Section above and so no additional background value is required. There is no ambient particulate monitoring data for Mallow and so an annual average concentration of 18 μg/m 3 was used as indicative of maximum PM 10 concentrations for the town. This value is based on the median observed concentration of the 7 Zone C and D towns reported by the EPA for 2010 (Air Quality in Ireland 2011). These 7 urban areas include Galway and smaller towns such as Ennis, Longford and Castlebar. This annual background PM 10 concentration allows an estimate to be calculated of the maximum total or combined impact on local air quality of the predicted PM 10 contribution from the facility with existing background levels. The annual average background PM 10 level is added to the predicted daily 90.4 percentile daily concentrations from the dryer emissions to give a total concentration that can then be compared with the NAQS value. Similarly, the annual background concentration is added to the predicted annual level due to the Dryer emissions, to give the total annual PM 10 concentration to assess compliance with the annual NAQS. 4.0 RESULTS OF MODELLING STUDY 4.1 Introduction Table 7 National Air Quality Standards (NAQS) Pollutant Criteria (µg/m 3 ) Compliance Date SO 2 Hourly 99.7% (not to be Jan 2005 exceeded more than 24 times per year) Daily 99.2% (not to be Jan 2005 exceeded more than 3 times per year) NO 2 Hourly 99.8% ( not to be Jan 2010 exceeded more than 18 times per year) Annual average 40 1 Jan 2010 Particulates (as PM 10 ) Daily 90.4% (not to be 50 1 Jan 2005 exceeded more than 35 times per year) Annual Average 40 1 Jan 2005 Source: Air Quality Standards Regulations 2011 (SI No 180 of 2011) Predicted ground level SO 2, NO 2 and PM concentrations were compared with the hourly and daily National Air Quality Standards (NAQS) values specified in the Air Quality Standards Regulations 2011 (SI: No 180 of 2011) (Table 7). The results of the modelling study are presented as ground level concentration contour plots, based on boiler and drier emission scenarios, described in Section 2 above. The predicted values shown in the contour plots are ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 10 EPA Export :23:03:54

12 the maximum percentile statistic obtained at each of the receptor points within the modelled area over the three separate climatological data-sets used in the modelling study. The PM emissions from the Dryer exhaust stacks were modelled as total particulates and so it is assumed that all particulates present in the dryer exhaust air are within the particle size fraction of PM 10 so that comparison with the daily and annual NAQS can be made. 4.2 Predicted impact No Development Nitrogen Dioxide (NO 2 ) Hourly The predicted 99.8 percentile of hourly NO 2 ground level concentrations due to the combined emissions of NO x from the CHP and Boiler No 1 burning natural gas and a background annual level of 14 µg/m 3 is given in Figure 2. The highest 99.8 percentile of hourly NO 2 concentrations beyond the boundary is 42 μg/m 3 and this maximum level occurs within 400m of the boundary of the Dairygold facility. This maximum 99.8 percentile value is 21% of the hourly NAQS. For the scenario where Boilers No 2 and 3 are required to operate at full load the corresponding predicted 99.8 percentile of hourly NO 2 concentrations is 30 μg/m 3 or 15% of the hourly NAQS Annual The predicted annual average NO 2 ground level concentration pattern indicates maximum annual average levels of about 21 μg/m 3 beyond the facility boundary. These predicted ground level concentrations include an annual background level used in the air dispersion model of 14 μg/m 3. The predicted annual concentrations are 52% of the annual NAQS of 40 μg/m Sulphur Dioxide (SO 2 ) Hourly SO 2 The pattern of the predicted 99.7 percentile of hourly SO 2 concentrations in the locality of the Dairygold facility based on Boilers No 1and 2 on full load operating on gasoil is shown in Figure 3. The CHP boiler is only installed to burn natural gas. The maximum predicted hourly 99.7 percentile concentration is significantly below the NAQS hourly standard of 350 μg/m 3. The highest predicted level is 15 μg/m 3, or 4% of the hourly NAQS and this is predicted near the Western boundary. For the scenario where Boiler No 1 is off-line and both Boiler No 2 and 3 are required to run on gasoil, due to unavailability of natural gas, then the maximum predicted 99.7 percentile of hourly levels is 13 μg/m 3, which again is below 5% of the hourly NAQS Daily SO 2 The maximum predicted 99.2 percentile of daily SO 2 concentration beyond the facility boundary is well below the daily NAQS for both the Boiler No 1 and No 2 operational scenario and the standby Boiler No 2 and No 3 scenario. The peak predicted concentration is 7 μg/m 3 in the case of Boiler No 1 as shown in Figure 4 with a predicted daily level of 6 μg/m 3 for Boilers No 2 and 3 beyond the facility boundary. These predicted concentrations ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 11 EPA Export :23:03:54

13 for each boiler scenario are below 6% of the daily NAQS. The results represent a worstcase daily scenario where the boilers are both operating continuously at full load and burning gasoil due to non-availability of natural gas at the Dairygold facility Particulates (as PM 10 ) Daily The predicted daily particulate concentrations due to maximum emissions from the existing Niro Dryer exhaust stack (A2-1) are shown in Figure 5, expressed as the 90.4 percentile over an annual period. The predicted levels are calculated on the assumption that all of the PM is emitted as PM 10 size material and emissions from the stack are at the IPPC licence emission limit value of 50 mg/nm 3. The results indicate that the maximum predicted concentration is 16 μg/m 3 and this occurs close to the northern boundary. When a background level of 18 μg/m 3 is included the maximum concentration is 34 μg/m 3 or 68% of the daily NAQS value of 50 μg/m 3 ; even where this conservative modelling approach has been applied Annual PM 10 The predicted maximum annual average PM 10 concentration due to the emissions from the dryer exhaust stack is 4 μg/m 3 beyond the facility boundary as shown in Figure 6. Total predicted annual PM 10 concentrations, including a background level of 18 μg/m 3, beyond the boundary is calculated to be 22 μg/m 3, or 44% of the annual NAQS value of 40 μg/m With Development Nitrogen Dioxide (NO 2 ) Hourly The predicted 99.8 percentile of hourly NO 2 ground level concentrations due to the combined emissions of NO x from the CHP and Boiler No 1 burning natural gas and all 3 thermoheaters on full load, including the background NO 2 level of 14 μg/m 3 is given in Figure 7. The maximum 99.8 percentile hourly concentration beyond the facility boundary is predicted to be 48 μg/m 3 and this maximum level occurs within 200m of the western boundary of the Dairygold facility. This maximum 99.8 percentile value is less than 25% of the hourly NAQS. The predicted percentage increase in the maximum predicted hourly level is 14% compared to the highest concentrations based on the existing boiler operating scenario Annual The maximum annual average concentration due to maximum emissions from the CHP and Boiler No 1 and the 3 thermoheaters at full load on natural gas, including a background NO 2 concentration of 14 μg/m 3 is 22 μg/m 3. This predicted maximum annual level is 55% of the annual NAQS of 40 μg/ Sulphur Dioxide (SO 2 ) Hourly SO 2 There is no change in predicted maximum hourly SO 2 concentrations beyond the facility boundary with gasoil being burnt in the boilers instead of natural gas compared to the No Development scenario. ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 12 EPA Export :23:03:54

14 Daily SO 2 There is no change in predicted maximum daily SO 2 concentrations beyond the facility boundary with gasoil being burnt in the boilers instead of natural gas compared to the No Development scenario Particulates (as PM 10 ) Daily The predicted daily particulate concentrations due to maximum emissions from the existing Niro Dryer exhaust stack (A2-1) and the proposed 2 new dryer exhaust stacks are shown in Figure 8, expressed as the 90.4 percentile over an annual period. Predicted levels are calculated on the assumption that all of the PM is emitted as PM 10 size material. These results are also based on a worst-case scenario where emissions from all three stacks are continuous at the maximum rate for A2-1 stack of 50 mg/nm 3 with particulate emissions from the two new stacks at 20 mg/nm 3. The results indicate that the maximum predicted concentration is 23 μg/m 3 and this occurs close to the northern boundary. When a background level of 18 μg/m 3 is included the maximum concentration is 41 μg/m 3, or 82% of the daily NAQS value of 50 μg/m 3 ; even where this conservative modelling approach has been applied Annual PM 10 The predicted maximum annual average PM 10 concentration due to the emissions from the existing and planned dryer exhaust stacks is 7 μg/m 3 beyond the facility boundary as shown in Figure 9. Total predicted annual PM 10 concentrations, including a background level of 18 μg/m 3, beyond the boundary is calculated to be 25 μg/m 3, or 63% of the NAQS value of 40 μg/m 3. The maximum percentage increase in the total annual concentration compared to the existing scenario is 14%. 5.0 CONCLUSION AND DISCUSSION A detailed air quality dispersion modelling study was undertaken using the ADMS4 model to evaluate the impact of air emissions from the proposed Dryer expansion programme at the Dairygold manufacturing facility in Mallow on the local air quality. The study examined the expansion programme at the facility, referred to as the With Development scenario, compared to the existing production scenario, referred to as the No Development for both boiler plant emissions and the particulate emissions from the planned three Niro Dryer exhaust stacks. The predicted impacts due to emissions of Nitrogen Oxides (as NO 2 ) and Sulphur Dioxide (SO 2 ) from the exhaust stacks of the boilers and Particulates (as PM 10 ) emissions from the Dryer exhaust stacks were examined in relation to compliance with the relevant National Air Quality Standards (NAQS). Table 8 gives the maximum ground level concentrations of NO 2, SO 2 predicted beyond the Dairygold facility boundary for the No Development and With Development boiler plant operational scenarios. The CHP and Boiler No 1 have sufficient steam generating capacity for both the current and future demands and the other two boilers, Boiler No 2 and 3, are fired as stand-by in the event of emergency shut-down of the main boilers. All the boilers burn natural gas as the primary fuel, with gasoil only used as an alternative fuel, in the unlikely ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 13 EPA Export :23:03:54

15 event of an interruption in the supply of gas to the facility. The predicted hourly and annual NO 2 ground level concentrations are calculated for the total (facility emissions + background) air quality impact. This is based on the contribution from the boiler emissions and an existing annual background NO 2 level of 14 μg/m 3 in the locality. The highest hourly 99.8% concentration beyond the site boundary increases by 14% from 21% of the NAQS for the No Development to 24% of the NAQS based on the With Development maximum emission scenarios. The change in the predicted annual average concentration is very small and in the order of 5% increase, with the With Development annual level 55% of the NAQS, including a background concentration. The increase arises due to the emissions of the 2 new thermoheaters that will be installed with an increase in ground level concentrations close to the facility boundary. The predicted maximum 99.8 percentile of hourly concentrations is 24% of the hourly NAQS based on boiler and thermoheater emissions for the proposed Dryer expansion development with a small increase in ambient levels near the boundary. Similarly, there is a small increase in the annual concentrations near the boundary. However, this predicted increase in hourly and annual NO 2 concentrations is insignificant compared to the NAQS limit values. Table 8 Maximum predicted NO 2, SO 2 concentrations beyond boundary and compliance with NAQS (μg/m 3 ) Pollutant NAQS No Development With Development Limit Value (μg/m 3 ) Max Predicted Conc. beyond Boundary (μg/m 3 ) % of NAQS Max Predicted Conc. beyond Boundary (μg/m 3 ) % of NAQS Nitrogen dioxide 99.8% Hourly (42) 14(21) 34(48) 17(24) Annual 40 7(21) 17(52) 8(22) 20(55) Sulphur Dioxide 99.7% Hourly (26) 4(7) 16(26) 4(7) 99.2% Daily 125 7(17) 6(14) 7(17) 6(14) Note: (i) Air Quality Standards Regulations 2011 (SI No 180 of 2011). Values in () Total (facility emissions + background) The predicted SO 2 hourly and daily concentrations based on maximum emissions arising from the boiler operational scenario where gasoil is being burnt due to unavailability of natural gas are very low and less than 5% of the hourly and daily NAQS. This grade of oil has a sulphur content of 0.1% by weight of fuel burnt so even with two boilers running to meet production steam demand; the resulting SO 2 emissions will have a negligible impact on local air quality. When the predicted levels due to emissions from the facility are added to a derived background concentration of twice the annual average of 5 µg/m 3, the total impact is 7% of the hourly and 14% of the daily NAQS. Table 9 gives the maximum predicted daily and annual concentrations due to emissions from the dryer stacks and the total (facility emissions + background concentration), along with the percentage compliance with the NAQS values. The predicted 90.4% of daily concentrations are 32% and 46% of the daily NAQS value for the No Development and ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 14 EPA Export :23:03:54

16 With Development emission scenarios respectively. The total air quality impact of the proposed development, with the inclusion of the annual background concentration of 18 μg/m 3, results in a daily concentration of 82% of the NAQS and an annual average 63% of the NAQS. The predicted change in air quality impact due to the addition of 2 dryers to the existing Niro Dryer and PM emissions from the exhaust stacks will be small with a 20% increase in the predicted total daily 90.4 percentile and 14% in the annual average. Table 9 Maximum predicted PM 10 concentrations beyond boundary and comparison with NAQS values (μg/m 3 ) Pollutant NAQS No Development With Development Limit Value (μg/m 3 ) % of NAQS % of NAQS Max Predicted Conc. beyond Boundary (μg/m 3 ) Max Predicted Conc. beyond Boundary (μg/m 3 ) PM % Daily (34) 32(68) 23(41) 46(82) Annual Average 40 4 (22) 10(55) 7(25) 18(63) Note: (i) Air Quality Standards Regulations 2011 (SI No 180 of 2011). Values in () Total (facility emissions + background) These modelled results are based on a conservative approach, where all the PM is emitted as PM 10 size material, at a concentration in the flue gas of 50 mg/nm 3 from the existing Dryer stack and at 20 mg/nm 3 from the planned two Dryers. Actual emissions are likely to be substantially lower. Each of the Dryers is also assumed to be operating at maximum output on a continuous basis throughout the year, whereas no production currently takes place during the winter months. The results demonstrate that for both the No Development and With Development scenarios that the daily 90.4 percentile and annual average are below the NAQS limit values. Overall, the results of the modelling study demonstrate that there will be no significant impact on the health of the local community or surrounding environment due to the projected change in the boiler and Dryer stack emissions occurring as a result of the Dryer expansion programme at the Dairygold Mallow facility. ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 15 EPA Export :23:03:54

17 FIGURES 1-9 WIND ROSES AIR QUALITY DISPERSION MODELLING RESULTS ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 16 EPA Export :23:03:54

18 (knots) Wind speed (m/s) FIGURE 1a WIND ROSE FOR 2005 CORK AIRPORT (knots) Wind speed (m/s) FIGURE 1b WIND ROSE FOR 2006 CORK AIRPORT ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 17 EPA Export :23:03:54

19 (knots) Wind speed (m/s) FIGURE 1c WIND ROSE FOR 2006 SHANNON AIRPORT ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 18 EPA Export :23:03:54

20 FIG 2: PREDICTED 99.8 PERCENTILE OF HOURLY NO 2 CONCENTRATIONS DUE TO EMISSIONS FROM CHP AND BOILER NO 1 (STACKS A1-4 AND A1-1 ) WITH EXISTING THERMOHEATER, ALL ON NATURAL GAS COMBINED WITH BACKGROUND CONCENTRATION (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 19 EPA Export :23:03:54

21 FIG 3: PREDICTED 99.7 PERCENTILE OF HOURLY SO 2 CONCENTRATIONS DUE TO EMISSIONS FROM BOILERS NO 2 AND 3 (STACKS A1-2 AND A1-3) ON GASOIL (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 20 EPA Export :23:03:54

22 FIG 4: PREDICTED 99.2 PERCENTILE OF DAILY SO 2 CONCENTRATIONS DUE TO EMISSIONS FROM BOILERS NO 2 AND 3 (STACKS A1-2 AND A1-3) ON GASOIL (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 21 EPA Export :23:03:54

23 FIG 5: PREDICTED 90.4 PERCENTILE OF DAILY PM 10 CONCENTRATIONS DUE TO EMISSIONS FROM EXISTING DRYER (STACK A2-1) (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 22 EPA Export :23:03:54

24 FIG 6: PREDICTED ANNUAL AVERAGE PM 10 CONCENTRATIONS DUE TO EMISSIONS FROM EXISTING DRYER (STACK A2-1) (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 23 EPA Export :23:03:54

25 FIG 7: PREDICTED 99.8 PERCENTILE OF HOURLY NO 2 CONCENTRATIONS DUE TO EMISSIONS FROM CHP AND BOILER NO 1 (STACKS A1-4 AND A1-1) WITH EXISTING AND PLANNED THERMOHEATERS, ALL ON NATURAL GAS COMBINED WITH BACKGROUND CONCENTRATION (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 24 EPA Export :23:03:54

26 FIG 8: PREDICTED 90.4 PERCENTILE OF DAILY PM 10 CONCENTRATIONS DUE TO EMISSIONS FROM EXISTING DRYER (STACK A2-1) AND NEW DRYERS (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 25 EPA Export :23:03:54

27 FIG 9: PREDICTED ANNUAL AVERAGE PM 10 CONCENTRATIONS DUE TO EMISSIONS FROM EXISTING DRYER (STACK A2-1) AND NEW DRYERS (μg/m 3 ) ENVIROCON LTD., DAIRYGOLD CO-OP, MALLOW EIS REPORT 19/07/12 26 EPA Export :23:03:54

28 Appendix 9.1 Calibration certificates for the noise level meter and acoustic calibrator EPA Export :23:03:54

29 EPA Export :23:03:54

30 EPA Export :23:03:54

31 Appendix 9.2 Glossary of noise related terms EPA Export :23:03:54

32 GLOSSARY Ambient Noise Totally encompassing sound in a given situation at a given time usually composed of a sound from many sources near and far. Background noise level The A-weighted sound pressure level of the residual noise at the assessment position that is exceeded for 90% of a given time interval, T measured using time weighting F, and quoted to the nearest whole number of decibels. EPA Day: Night: 0800 hrs to 2200 hrs 2200 hrs to 0800 hrs Decibel (db) The unit of sound pressure level, calculated as a logarithm of the intensity of sound. 0 db is the threshold of hearing, 140 db is the threshold of pain. A change of 1 db is detectable only under laboratory conditions. A change of 10 db corresponds approximately to halving or doubling the loudness of sound. db(a) Decibels measured on a sound level meter incorporating a frequency weighting (A weighting) which differentiates between sound of different frequency (pitch) in a similar way to the human ear. Measurements in db(a) broadly agree with peoples assessment of loudness. Hertz (Hz) Unit of frequency (pitch) of a sound. Impulsive Noise A noise which is of short duration (typically less than one second), the sound pressure level of which is significantly higher than the background. 1/3 Octave band analysis Frequency analysis of sound such that the frequency spectrum is sub divided into bands of one third of an octave each. An octave is taken to be the frequency interval, the upper limit of which is twice the lower limit (in Hertz). LAeq Equivalent Continuous A-weighted Sound Level. The continuous steady noise level, which would have the same total A-weighted acoustic energy as the real fluctuating noise measured over the same period of time. EPA Export :23:03:54

33 L(A) 10 The noise level that is equaled or exceeded for 10% of the measurement period. L(A) 90 The noise level that is equaled or exceeded for 90% of the measurement period. Noise Unwanted sound. Any sound which has the potential to cause disturbance, discomfort or psychological stress to a subject exposed to it, or any sound which has the potential to cause actual physiological harm to a subject exposed to it or physical damage to any structure exposed to it, is known as noise. Noise Sensitive Receptor A noise sensitive receptor is regarded as any dwelling house, hotel or hostel, health building, educational establishment, places of worship or entertainment, or any other facility or area of high amenity which for its proper enjoyment requires the absence of noise at nuisance levels. Rating level L ArTr The specific noise level plus any adjustment for the characteristic features of the noise. Residual Noise The ambient noise remaining at a given position in a given situation when the specific noise source is suppressed to a degree such that it does not contribute to the ambient noise. Sound Power The energy output from a source. It is measured in Watts (W). Specific Noise Source The noise source under investigation for assessing the likelihood of complaints. Tone A noise with a narrow frequency composition. EPA Export :23:03:54

34 Appendix 9.3 Model Input Data EPA Export :23:03:54

35 Reference Item Sound Power Level db(a) Operating Times Source Proposed New External Noise Sources T/h Dryer No 1 Air Intake Louvre 80dB(A) 100% - 24hrs Dairygold T/h Dryer No 2 Air Intake Louvre 80dB(A) 100% - 24hrs Dairygold T/h Dryer No 1 Pressure Relief Vent Panels 80dB(A) 100% - 24hrs Dairygold T/h Dryer No 2 Pressure Relief Vent Panels 80dB(A) 100% - 24hrs Dairygold 5 7.5T/h Dryer No 1 Exhaust (including silencer) 90dB(A) 100% - 24hrs Dairygold 6 7.5T/h Dryer No 2 Exhaust (including silencer) 90dB(A) 100% - 24hrs Dairygold 7 Refrigeration Condenser No 1 96dB(A) 100% - 24hrs Dairygold 8 Refrigeration Condenser No 2 96dB(A) 100% - 24hrs Dairygold 9 Refrigeration Condenser No 3 96dB(A) 100% - 24hrs Dairygold 10 Cooling Tower Cell No 1 85dB(A) 100% - 24hrs Dairygold 11 Cooling Tower Cell No 2 85dB(A) 100% - 24hrs Dairygold 12 Cooling Tower Cell No 3 85dB(A) 100% - 24hrs Dairygold 13 Delivery Lorry 102dB(A) 14 Delivery Lorry Revving at weigh bridge 106dB(A) 15 Emitting Roof/ Facade (noise from dryer building walls/ roof) 216 HGVs Day 44 HGV Evening 64 HGV Night 14% Day 8% Evening 7% Night (30 seconds at high rpm for each lorry) Dairygold (Vehicle Numbers) Source db Noise Levels Source db Noise Levels 66dB(A) 100% - 24hrs GEA Existing Noise Sources to Remain 16 Air Intake for Niro 2 dryer % - 24hrs 17 Air Ducting for Niro 2 dryer % - 24hrs 18 Davenport Cooling Tower % - 24hrs 19 Chimney Exhaust Niro dryer % - 24hrs 20 Milk Intake (West Entrance) % - 24hrs 21 Milk Intake (East Entrance) % - 24hrs 22 Combined heat and power (Door Open) % -- 24hrs Summary of Noise Emissions, Dairygold IPC licence application Validation Model EPA Export :23:03:54

36 Natura Impact Statement Proposed Redevelopment at Dairygold Cooperative Society Ltd. at Mallow, County Cork July 2012 Job number Revision Prepared by Checked by Status Date Rev A PR, MR, JK CF Final July 2012 EPA Export :23:03:55

37 Rev A Natura Impact Statement June 2012 Table of contents 1 INTRODUCTION Background Legislative Context Stages of AA Screening Steps Natura Impact Assessment Steps Assessment Methodologies STAGE 1 SCREENING Management of Natura 2000 Site Description of Project Identification of Natura 2000 sites Identification of Potential Impacts Assessment of Significance of Potential Impacts Conclusion of Screening Stage NATURA IMPACT STATEMENT Introduction Description of the Project Characteristics of the Blackwater River (Cork/Waterford) SAC (002170) Features of Interest Assessment of Potential Significant Impacts Mitigation Cumulative Impacts CONCLUSION References EPA Export :23:03:55

38 Rev A Natura Impact Statement July 2012 Table of Tables Table 1. Significance of impact (EPA,2002)... 8 Table 2. Types and Quantities of Inputs Table 3. Existing Machinery/Equipment Table 4. Existing Buildings Table 5. Future Machinery/Equipment Table 6. Future Tanks Table 7. Future Buildings Table 8. Generated Waste and Disposal Outlets Table 9. Future Types and Quantities of Inputs Table 10. Designated conservation sites within a 15km radius of proposal site Table 11. Designated sites with features of interest Table 12. Features of Interest of the Blackwater River SAC Table 13. Overall conservations status of aquatic species (NPWS, 2008) Table 14. Summary of unmitigated construction phase impacts to conservation status of selected qualifying interests of the Blackwater River SAC Table 15. Summary of construction phase residual / mitigated impacts of the proposal on the Blackwater River SAC Table of Figures Figure 1. Location of proposal site at Annabella, Mallow, County Cork. [Adapted from 10 Figure 2. Existing site layout Figure 3. Existing Buildings (see Table 4 for building numbers) Figure 4. Proposed redevelopment layout of Dairygold Facility (see Table 7. Future Buildings, for corresponding Building Reference No.) Figure 5. Designated Natura 2000 sites within 15km of Dairygold site EPA Export :23:03:55

39 Rev A Natura Impact Statement July 2012 List of Appendices Appendix 1 Appendix 2 Site Summaries Conservation Objectives EPA Export :23:03:55

40 Rev A Natura Impact Statement July Introduction 1.1 Background Member States are required to designate Special Areas of Conservation (SACs) and Special Protected Areas (SPAs) under the EU Habitats and Birds Directives, respectively. SACs and SPAs are collectively known as Natura 2000 sites. An Appropriate Assessment (AA) is a required assessment to determine the likelihood of significant impacts, based on best scientific knowledge, of any plans or projects on Natura 2000 sites. A Screening for AA determines whether a plan or project, either alone or in combination with other plans and projects, is likely to have significant effects on a Natura 2000 site in view of its conservation objectives. This Screening for AA has been undertaken to determine the potential for significant impacts of a proposal to redevelop the milk powder processing facility at the Dairygold Co-operative Society facility in Mallow, County Cork, on nearby Sites with European conservation designations (i.e. Natura 2000 Sites). The purpose of this assessment is to determine, the appropriateness, or otherwise, of the proposed project in the context of the conservation objectives of such sites. This Screening for AA has been undertaken by Malachy Walsh and Partners ecologists, Monica Reidy (BSc MSc), Jon Kearney (BSc MSc) and Pat Ryan (BSc). Assessment of potential impacts on other species of national and community interest does not fall within the scope of this report. An Environmental Impact Assessment entitled, Dairygold, Malllow, Dryer Facility Expansion EIA has been carried out. This document forms Appendix 10 of the Environmental Impact Statement. 1.2 Legislative Context The Habitats Directive (92/43/EEC) seeks to conserve natural habitats and of wild fauna and flora by the designation of SACs and the Birds Directive (79/409/EEC) seeks to protect birds of special importance by the designation of SPAs. It is the responsibility of each member state to designate SPAs and csacs, both of which will form part of Natura 2000, a network of protected sites throughout the European Community. An Appropriate Assessment is required under Article 6 of the Habitats Directive where a project or plan may give rise to significant effects upon a Natura 2000 Site, and paragraphs 3 and 4 state that: 6(3) Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public. 4 EPA Export :23:03:55

41 Rev A Natura Impact Statement July (4) If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest. The current assessment was conducted within this legislative framework and also the recent DoEHLG (2009) guidelines. As outlined in these, it is the responsibility of the proponent of the project, in this case the applicant, to provide a comprehensive and objective Natura Impact Statement, which can then be used by the competent authority in order to conduct the Appropriate Assessment (DoEHLG, 2009). 1.3 Stages of AA A Screening for Appropriate Assessment (AA) has been prepared by Malachy Walsh and Partners, to determine the likelihood of significant impacts, if any, of the proposal to redevelop the milk powder processing facility at the Dairygold Co-operative Society facility in Mallow, County Cork, on nearby sites with European conservation designations (i.e. Natura 2000 sites). A Natura Impact Statement (NIS) has also been undertaken and is presented in this report after the Screening stage. The AA process is a four-stage process to complete the AA, with issues and tests at each stage. An important aspect of the process is that the outcome at each successive stage determines whether a further stage in the process is required. This proposal has proceeded as far as Stage 2 only. The first stage of the AA process and that undertaken to determine the likelihood of significant impacts of this proposal is: Stage 1: Screening. The second stage of the AA process, presented in this report after the Screening stage, assesses the impact of the proposal (either alone or in combination with other projects or plans) on the integrity of the Natura 2000 site with respect to the conservation objectives of the site and its ecological structure and function. A Natura Impact Statement containing a professional scientific examination of the proposal is required and includes any mitigation measure to avoid, reduce or offset negative impacts: Stage 2: Natura Impact Statement (NIS). If the outcome of Stage 2 is negative i.e. adverse impacts to the sites cannot be scientifically ruled out, despite mitigation, the plan or project should proceed to Stage 3 or be abandoned. This stage examines alternative solutions to the proposal: Stage 3: Assessment of alternative solutions. 5 EPA Export :23:03:55

42 Rev A Natura Impact Statement July 2012 The final stage is the main derogation process examining whether there are imperative reasons of overriding public interest (IROPI) for allowing a plan or project to adversely affect a Natura 2000 site where no less damaging solution exists: Stage 4: Assessment where no alternative solutions exist and where adverse impacts remain. In summary, the purpose of the Screening stage is to determine the necessity or otherwise for a NIS. Screening for AA examines the likely effects of a project or plan, alone and in combination with other projects or plans, upon a Natura 2000 site and considers whether it can be objectively concluded that these effects will not be significant. If it is determined during Screening that the proposal may have a significant effect on a Natura 2000 site then a NIS will need to be prepared. A Screening exercise has been undertaken and concluded that a NIS was required. The Screening is outlined in section 2 below as it now forms part of the overall NIS. The NIS is presented in Section 3 below. 1.4 Screening Steps This Screening for AA, or Stage 1 of AA, has been undertaken in accordance with the European Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the Habitats Directive 92/43/EEC (EC, 2001) and the European Commission Guidance Managing Natura 2000 sites (EC, 2000). Screening for AA involves the following: Establish whether the plan is necessary for the management of a Natura 2000 site; Description of the Plan; Identification of Natura 2000 sites potentially affected; Identification and description of individual and cumulative impacts likely to result from the plan; Assessment of the significance of the impacts identified above on site integrity; and Exclusion of sites where it can be objectively concluded that there will be no significant effects. Stage 1, Screening, examines whether or not likely effects upon a Natura 2000 site will be significant and determines whether the AA process for the proposed redevelopment of the milk powder processing facility needs to proceed to Stage Natura Impact Assessment Steps Similarly, the Natura Impact Assessment has been undertaken in accordance with the same guidance used for Screening in the previous section. 6 EPA Export :23:03:55

43 Rev A Natura Impact Statement July 2012 A Natura Impact Assessment (NIA) involves the following: Ensure adequate information is available to complete the NIA, which may require further ecological surveys to adequately determine the aspects of the proposed project which may affect conservation objectives of Natura 2000 sites; Identify possible and potential magnitude and duration of direct, indirect and cumulative impacts; and Predict the significance of the identified impacts upon the conservation objectives adopting the precautionary principle as necessary. 1.6 Assessment Methodologies Desk Study A desk study was carried out to collate available information on the site s natural environment. This comprised a review of the following publications, datasets and on-line resources: OSI Aerial photography and 1:50000 mapping; National Parks and Wildlife Service (NPWS); BirdWatch Ireland; BirdLife International; Teagasc soil area maps (NBDC website); Geological Survey Ireland (GSI) area maps; Environmental Protection Agency (EPA) water quality data; South Western River Basin District (SWRBD) datasets (Water Framework Directive); National Biodiversity Centre (on-line map-viewer); Water & Wastewater Assessment for New Drier Facility at Dairygold Mallow, Co. Cork (Appendix 6 of EIS) Integrated Pollution Prevention Control (IPPC) Licence Reg. No. P River Blackwater WWTP Discharges Discharge Licences. Natura Impact Statement (Ryan Hanley, 2011) Freshwater Pearl Mussel Munster Blackwater Sub-basin Management Plan second draft (NS 2, 2010) Consultation As part of the EIS consultation was undertaken with the NPWS and IFI and Sharon Casey of CCC Ecological Site Survey Habitat and initial ecological field surveys were conducted by ecologists on the 12 th of June, 2012 to establish the ecological features and resources of the site which include important species and habitats. The area surveyed included the proposed development site and the land bounding the site. The site was walked to determine the habitats present on site and habitats were categorised according to the Heritage Council s A Guide to Habitats in Ireland (Fossitt, 2000) to level 3. Aerial photography was used together with GPS to accurately enable field navigation. Notes were made on all habitats encountered, including notes on dominant and indicative vegetation. A 7 EPA Export :23:03:55

44 Rev A Natura Impact Statement July 2012 qualitative assessment was made of plant species diversity, vegetation structure, topography and drainage, disturbance and management. Other ecological features and resources were recorded on field sheets. Scientific and common names for plants follow Webb et al. (1996) and Blamey et al. (2003), respectively. In addition to habitat identification, each habitat was assessed for its ecological significance, based on the National Roads Authority (NRA) ecological impact assessment guidelines (NRA, 2009) and the Institute of Ecology and Environmental Management (IEEM) guidelines (IEEM, 2006). Habitat boundaries and associated attribute data were mapped using desk-based GIS software, namely ArcView 9.2, which was also used to calculate habitat areas and lengths Impact Assessment Once the potential impacts that may arise from the proposal are identified the significance of these is assessed through the use of key indicators: Habitat loss; Habitat alteration; Habitat or species fragmentation; Disturbance and/or displacement of species; and Water quality and resource. In line with the EPA Guidelines (EPA, 2002), the following terms are defined when quantifying duration: Temporary: up to 1 year; Short-term: from 1-7 years; Medium-term: 7-15 years; Long-term: years; and Permanent: over 60 years. The impact significance criteria follow EPA guidance (EPA, 2002). Table 1. Significance of impact (EPA,2002) Significance of Impacts Imperceptible Impact Slight Impact Moderate Impact Significant Impact Profound Impact Definition An impact capable of measurement but without noticeable consequences. An impact which causes noticeable changes in the character of the environment without affecting its sensitivities. An impact that alters the character of the environment in a manner that is consistent with existing and emerging trends. An impact which, by its character, magnitude, duration or intensity alters a sensitive aspect of the environment. An impact which obliterates sensitive characteristics. 8 EPA Export :23:03:55

45 Rev A Natura Impact Statement July Stage 1 Screening 2.1 Management of Natura 2000 Site The proposal is not connected with or necessary to the conservation management of a Natura 2000 site. 2.2 Description of Project Brief Project Description Dairygold Co-Operative Society Ltd. wishes to redevelop its milk powder processing facility at Mallow in order to increase the processing capabilities of the site. The projected increase in milk intake is from 123 million litres (27 million gallons) to approximately 885 million litres (195 million gallons) of milk each year. The facility being proposed will have the capacity to process 3.2 million litres of milk per 24 hours, producing approximately 450 tonnes of milk powder and 10 tonnes of cream per day to allow the facility to increase the overall production rates of milk powders in line with the projected increase in milk deliveries. There will be no changes to the range of activities currently being undertaken at the facility. All redevelopment works will be within the existing site boundary and will comprise of a phased program of demolition, construction and site development works Purpose of the Project Proposal The need to develop the site s processing potential is to cater for the anticipated increased volumes of milk to be delivered to the facility post 2015 with the abolition of the Milk Quota system Site Location The site is situated beside the Mallow by-pass (part of the N20 Cork Limerick National Primary road) on the western side of Mallow Town Centre. The entire site occupies an area of approximately 9.14ha. The Dairygold site is bounded to the west by the N20 dual carriageway and to the east by Shortcastle Street. Lower Beecher Street forms the northern boundary of the site and West End Road forms the southern boundary of the site. 9 EPA Export :23:03:55

46 Rev A Natura Impact Statement July 2012 Figure 1. Location of proposal site at Annabella, Mallow, County Cork. [Adapted from Description of the Site and Existing Layout As was mentioned previously the proposal site is situated within the urban fabric of Mallow town. The Bedrock at the site is Dinantian Pure Bedded Limestones and soil type is described as Made. The Corine Landcover category for the proposal site and for the area which extends away from the site boundary is Urban 1. A small stream, Linehans Stream, drains southward through the site to the Blackwater River at a point approximately 0.55km to the south of the site boundary. This stream is culverted along part of its course through the proposal site. Previous exploratory works undertaken in 2007 determined elevated levels of arsenic and nickel at depth of 2 8m in some of the site soil samples. It was concluded from further investigations that these levels were of natural origin, associated with the geological strata, in particular, the Namurian Shale and sandstone till. These soils were retained on the site in suitable areas onto low permeability sub-soils and capped them with inert soils. Further detail on these aspects is presented in detail in Section of Chapter 7 of Volume 2 of the EIS. Evidence from the laboratory analysis suggested heavy metals were not leaching; Arup Engineering (see Appendix 7.2 of Volume 3 of the EIS) established the elevated metal levels were of natural origin and there were no elevated levels of the metals in the groundwater. 1 [accessed 6/06/2012] 10 EPA Export :23:03:55

47 Rev A Natura Impact Statement July 2012 Dairy Processing has been conducted on this site since the 1880 s, initially producing Condensed milk. The existing site layout is illustrated in Figure 1. The site is bisected by a stream, known as either Linehans steam or the Hospital stream, which partly runs underground through a culvert. The area east of this stream has completely been cleared of past processing facilities with only a water tank and diesel storage tank remaining. These are still in use as part of current site activities. The area west of the stream contains all current site activities and the remnants of several former facilities. The southern section of this area of the site has largely now been cleared of processing facilities since the old Nestle facility was demolished. The boiler house is the only structure left in this area, with the exception of some walls of former buildings which have been left standing. The existing processing plant is located in the northwest section of the site and comprises milk intake, pasteurisation / separation facilities, evaporation and drying, packing (with some storage), Cleaning In Place (CIP), water treatment and refrigeration all in one block of conjoined buildings. Separate to this and located on the other side of the access way to/from the milk intake is the main powder store which is located in the old Borden Building. South of the processing area is a mixed use building, comprising maintenance workshop, canteen and offices. A Milk Laboratory building, weigh bridge and Security office, visitor carparking are located in the south-western section of the site. An ESB incoming sub-station is located in the northwest corner of the site. A gas compound is located to the west of the processing plant. There are currently two access points to the site, one located along the southern boundary and one at the north-western boundary of the site. The existing main site entrance is located along the southern site boundary with access gained directly from West End Road close to the roundabout on the N20. Currently all traffic accessing the site use this entrance. 11 EPA Export :23:03:55

48 Rev A Natura Impact Statement July 2012 Milk Intake + Processing Powder Store Building Maintenance/Stores Canteen/Offices Boiler House + Energy generation Laboratory Planning Application Boundary Site Boundary Figure 2. Existing site layout Overview of Existing Facility The Dairygold facility at Mallow is a milk processing installation for milk powder production. Today the facility processes in excess of 123 million litres of raw milk per annum (750,000 litres of raw milk per day). Products manufactured comprise milk powders, (including whole milk powders, skim milk powders and blended milk powders). The process also produces surplus cream, a saleable byproduct. 12 EPA Export :23:03:55

49 Rev A Natura Impact Statement July 2012 The activity is supported by associated ancillary services, i.e. laboratories, maintenance workshop, engineering facilities, utilities and wastewater treatment plant. The Dairygold facility at Mallow is regulated by the EPA and was granted an Integrated Pollution Control (IPC) Licence Reg. No. 403 on the 28 of July In 2006 the EPA requested a review of the Licence to bring site operations into compliance with the requirements of the IPPC Directive 96/61/EC. Dairygold Mallow was subsequently granted an Integrated Pollution Prevention Control (IPPC) Licence Reg. No. P on 6 th June Under Section 83(1) of the Environmental Protection Agency Acts 1992 and 2003, Dairygold Co-Operative Society Limited, is licenced by the EPA to carry on the following activities at Annabella, Mallow, Co. Cork the manufacture of dairy products where the processing capacity exceeds 50 million gallons of milk equivalent per year The Licence was again reviewed in 2011 in accordance with Section 87 (2) of the Environmental Protection Agency Acts 1992 and A revised Licence was granted in April 2012 (Licence Reg. No. P ) by the EPA to carry on the following activity: The treatment and processing of milk, the quantity of milk received being greater than 200 tonnes per day (averaged value on a yearly basis) Standard health and safety operating procedures in terms of accident prevention, emergency response and materials handling are in place under environmental management and health and safety systems Existing Site Activities The main activities currently undertaken on-site are i) raw milk intake, ii) raw milk processing (namely its clarification and separation, pasteurisation and standardisation), iii) processing of the milk into powder and iv) distribution of end products. Further detail on these aspects is presented in detail in Section 2.3 of Chapter 2 of Volume 2 of the EIS. Products currently manufactured at Dairygold Mallow comprise milk powders, including whole milk powders (instant, 26%, 28%), skim milk powders, and blended milk powders. The process also produces surplus cream, a saleable by-product. Further detail on these aspects is presented in detail in Section 2.3 of Chapter 2 of Volume 2 of the EIS. The main types of raw goods inputs and ancillary materials and the annual raw material requirement of the plant are as indicated in Table EPA Export :23:03:55

50 Rev A Natura Impact Statement July 2012 Table 2. Types and Quantities of Inputs Material Inputs Food Grade Materials Volumes per annum Raw milk 123million litres Water 182,000m 3 Ingredients 1,850 tonnes CIP Materials Caustic (30%) 241 Tonnes Nitric acid (55%) Blended caustic detergent 48 Tonnes 130 tonnes Fuel Diesel Oil Back up as required Water and Wastewater treatment Gas Bulk Propane Gas Chloros, Quick lime, water treatment salts, Aluminium Sulphate (8%) Piped 23,611litres 160 tonnes Storage arrangements for food grade material inputs, fuels and cleaning chemicals principally comprises stainless steel silos which are located throughout the main production areas in tank farms. Palletised storage is provided for packaged milk powders which are stored in the powder storage building (Bordens building). The manufacturing plant currently operates on a seasonal basis, typically 40 weeks per year (maximum), from March to November. Operating hours at the plant are 24 hour per day, 7 days per week. During the winter months, December to February, the facility maintains its function as a milk powder distribution centre with product storage and dispatch activities continuing during this period Existing Infrastructure and Major Equipment The principal infrastructure, machinery and equipment currently on-site are set out in Table 3 and 14 EPA Export :23:03:55

51 Rev A Natura Impact Statement July 2012 Table 4. Table 3. Existing Machinery/Equipment EXISTING Machinery/Equipment Quantity / Number Milk Intake bays 4 Separators / Clarifiers 2 Milk Pasteurisers 3 Cream Pasteurisers 1 Evaporators 1 Spray dryers 1 No. 5.25/h Tonne Boilers 3 CHP 1 Packing lines 2 15 EPA Export :23:03:55

52 Rev A Natura Impact Statement July 2012 Table 4. Existing Buildings Building Ref No. (Figure 3) EXISTING BUILDINGS Height (m) Area (m2) 1 Milk Intake unit Pasteurisation + Separation Unit Evaporator Building ,008 4 Spray dryer building Engineering workshop 12 3,564 6 Blue + White Tower over the engineering workshop and stores Laboratory CHP Building ,142 9 Utility Building Former Office building Powder Storage Building Store Tower to No Packaging store , Security office- weigh bridge control Store building Total 21, EPA Export :23:03:55

53 Rev A Natura Impact Statement July 2012 Figure 3. Existing Buildings (see Table 4 for building numbers) The sites process water requirement is supplied by 3 No. deep bore wells. These are located to the south of the site. Potable water for the non processing activities is sourced from municipal supply. The energy demand on the site is currently met by a combination of natural gas (permanent connection to gas grid) and electricity from an on-site Combined Heat and Power (CHP) plant. The site provides most of its own electricity sources but it is also connected to the national electricity grid. 17 EPA Export :23:03:55

54 Rev A Natura Impact Statement July Wastes, Emissions and Residues The principal solid wastes of volume significance generated by the installation are biological sludges associated with the effluent treatment process. Today approximately 210 tonnes per annum of sludge is generated from the on-site wastewater treatment plant (WWTP) and this is recovered by landspreading under an approved nutrient management plan (NMP) and in accordance with condition 8.10 of the facility s IPPC Licence. All landspreading is carried out by a permitted contractor. The remaining waste streams typically comprise packaging wastes (cardboard and plastics), waste oils, laboratory wastes, and general domestic type waste (canteen and office). There is a number of dedicated solid waste storage areas located throughout the facility for holding waste materials prior to their collection for disposal/recovery. All solid waste handling contractors and waste disposal facilities used by Dairygold are fully permitted (by the Local Authorities) and/or licensed (by the EPA). There are several different wastewater streams generated by the facility, of which the most significant is process wastewater. The other wastewater streams include cooling water from utilities, stormwater, and sanitary sewage. Process wastewater is mainly generated during cleaning operations (tank, truck and storage tank washing, pipe line washing and sanitizing) and condensate discharges during the manufacturing process. It contains milk solids, detergents, sanitizers and milk wastes. All process wastewaters are directed to the facility s WWTP prior to discharging the River Blackwater via the licenced discharge point SW1. These discharges are sampled, monitored and analysed in accordance with the facility IPPC Licence (see Schedule 2.1 Emissions to Water). The facility s WWTP is regulated under the facilitys IPPC License. This license permits the facility to discharge 4,500m 3 of treated effluent per day to the River Blackwater. Domestic wastewater is generated on site from the installations canteen, laboratory and toilet facilities. This wastewater stream is collected by a series of foul water sewer lines on-site and connected to the Mallow town public sewerage system. Surface water arising on the site (from roofs and yard areas) is discharged to the internal stream, known as Linehans stream via two (2) outfalls. These outfalls are licensed emissions points under the facility s IPPC licence and have emission point references as SWD2 and SWD3. These discharges are sampled, monitored and analysed as per Licence Schedule C.2.3 Monitoring of Storm Water Emissions. The principal sources of air emissions on site relate to exhaust gas emissions from the site boilers and CHP plant, and exhaust discharges from the spray drying equipment. Air pollutants of concern contained in the exhaust gas emissions from the on-site boilers are nitrogen oxides [NOX]. Particulates of fine milk powder residues are the key pollutants of concern in the exhaust air from the spray drying systems. The existing dryer is fitted with a wet scrubber system to enhance the quality of air released from the drying process. 18 EPA Export :23:03:55

55 Rev A Natura Impact Statement July Characteristics of the Project This project is fundamentally about upgrading the existing facility in Mallow, installing improved technology and re-organising the facility on site in order to future proof the facility for post 2015 marketplace. In order to increase processing capabilities and maintain the operating efficiency of the plant, the proposal necessitates a revision of the existing layout. All redevelopment works will be within the existing site boundary. The proposed revisions to the existing site layout range from minor alterations to a complete dismantling of some existing structures and installation of new equipment. To achieve the desired improvements in processing capabilities, the following site redevelopment and infrastructural works are being proposed: Upgrading the existing northern entrance to the site for milk deliveries and for the export of finished product Construction of a new internal roadway to provide access from the upgraded northern site entrance to the milk intake area. Decommissioning of existing milk intake area and construction of a new expanded milk intake facility on the southern section of the site. Decommissioning of the existing pasteurisation building and construction of a new building to house separation, pasteurisation and standardisation unit plus cream pasteurisation facility Decommissioning of the existing utilities building and construction of a new utilities building within the site Construction of a new drying and evaporator building to house additional drying and evaporation equipment Demolition of a section of an existing packing store building (bag filling and palletising building) to allow construction of the new building to house the new evaporators, dryers and packing lines Construction of a new bag filling and palletising building Demolition of the existing bulk powder storage building and construction of a new powder storage building in the same location Modifications of the existing maintenance and engineering store Installation of additional silo storage tankage for raw milk, milk products, water, ingredients, chemicals, fuel. Creation of a new car park for staff and visitors Re organisation of existing services on site including foul and storm water services, electrical and common network systems Landscaping of green areas, boundaries and zone adjacent to Linehans stream. Landscaping will include permanent berms at the north of the site. Further detail on these aspects is presented in detail in Section 2.4 and 2.5 of Chapter 2 of Volume 2 of the EIS. The proposal is further in the following sections. 19 EPA Export :23:03:55

56 Rev A Natura Impact Statement July 2012 Figure 4. Proposed redevelopment layout of Dairygold Facility (see Table 7. Future Buildings, for corresponding Building Reference No.) 20 EPA Export :23:03:55

57 Rev A Natura Impact Statement July Size, scale, area, land-take The proposal will not extend beyond the existing site boundary. The following presents the relevant area measurements: The area within the proposal site boundary comprises 9.14ha Total area existing buildings: 22,580m 2 Total area to be demolished: 13,469m 2 Total area to be retained: 9,111m 2 Total area of proposed new buildings: 22,059m 2 Detail on extent of new hardstand area (comprises upgrade of existing and expansion of area to include access route for traffic): 13,729m 2 (chapter 2, slab) Details of physical changes that will take place during the various stages of implementing the proposal Details of physical changes have been described above. The principal changes in terms of the sites layout arrangement comprise: A new internal road network The relocation of the milk intake/reception area and raw milk storage tanks The relocation of the separation and pasteurisation unit The relocation of the utility building The construction of a new dryer building All other changes essentially relate to upgrading or demolition of existing buildings and the introduction of new additional silo storage tanks. The principal infrastructure, machinery and equipment proposed for the future activity are set out in the following tables. Table 5. Future Machinery/Equipment Machinery/Equipment Existing Quantity / Number Retained Proposed New Milk Intake bays Separators / Clarifiers Milk Pasteurisers Cream Pasteurisers Evaporators Spray dryers 1 No. 5.25Tonne/hr 1 No. 5.25Tonne/hr 2 No.7.5 Tonne/hr Boilers CHP Packing lines Total Future Quantity / Number 2 No.7.5Tonne 1 No. 5.25Tonne 21 EPA Export :23:03:55

58 Rev A Natura Impact Statement July 2012 Table 6. Future Tanks TANKS Quantity Height Volume Bunding Tank Ref No (2.12) Retained New (m) (m 3 ) Yes/No Food Grade Materials CIP Materials Raw Milk storage Yes 25 Cream storage Yes 26 Pasteurised Milk storage Yes 2,3,5,6,7 1* Yes 1 1* Yes Yes 27 Vegetable Oil Storage Yes 28 Milk Ingredient storage Yes 29 Raw Milk CIP tanks Yes 30 Pasteuriser Milk CIP tanks Yes 31 Pasteurised CIP tanks Yes 32 Bulk Chemical storage Yes 33 Other Treated Spring Water No 19 Super Spring Water No 20 Condensed chlorinated Water No 21 Treated condensate Water No 22 Boiler Feed Water No No 24 Condensate water tanks No 34 Process Water tank ,005 No 35 Firewater storage ,005 No 36 Diesel storage (boiler backup fuel) Yes 37 *Existing raw milk storage tanks to be retained and converted to Pasteurised milk Storage tank 22 EPA Export :23:03:55

59 Rev A Natura Impact Statement July 2012 Table 7. Future Buildings Building Ref No. (Figure 2-11) RETAINED AND NEW BUILDINGS Height (m) Area (m 2 ) 3 Existing Evaporator Building ,008 4 Existing Spray dryer building ,527 5 Existing Maintenance workshop Existing Laboratory Existing Boiler House 5.4 1, Refurbished Powder storage building 16 4, General store New Milk Intake unit 6 1, New Pasteurisation + Separation Unit New Evaporator Building 29 2, New Spray dryer Building 40 8, New Bulk Chemical In-take New Admin and Staff facilities 13 1, New Utility Building Polisher building New Packaging store 16 1, Weighbridge control building New visitor security office Transformer Building In addition, the proposed development will result in a net decrease in the amount of rainwater runoff due to the introduction of additional bunds and rainwater harvesting from building roofs Description of Resource Requirements for the Construction Phase The resource requirements for the construction phase are summarised here: Water supply - an existing supply is available on site. Electricity supply - supplies are available on site. Construction materials ready-mix and pre-cast concrete, imported stone, cladding, reinforcement steel, cladding, structural steel, drainage pipes, watermains, electrical cabling and equipment, mechanical and electrical goods, tarmacadam and materials for industrial buildings (e.g. insulation) will be required. Plant and machinery requirements for excavators, cranes, dumpers, Volvo dump trucks, trailers, telescopic site handlers, road sweeping equipment, welding gear, elevation platforms, concrete saw cutters, rollers, rock breakers, crushing equipment along with forklifts and small power tools (grinders, saws, drills, kango hammers, powerfloats, temporary lights, water pumps, concrete vibrators etc). Site compound this will be located east of Linehans Stream and this compound will have dedicated bunded areas for hazardous substances such as fuels, oils and any chemicals. Dedicated waste storage area and appropriate bins are also included in this area. 23 EPA Export :23:03:55

60 Rev A Natura Impact Statement July 2012 Welfare faculties - including canteen and toilets will be provided temporarily as part of the main contractors site set up. There is adequate water supply and there is an existing connection to the public sewer Storage area for materials and hazardous substances - dedicated areas on site within contractors compound will be bunded and use appropriate containers etc Persons - the construction phase is 18 months and will be in three stages, employment could vary between 20 and 60 people during the works with peaks in phase 2. Working hours are typically from 8.30 to during the week with some instances where work may also take place on a Saturday from 8.30 to Car parking construction staff and delivery vehicle parking will be provided on the east of the site Site Preparation and Pre-construction Activities Site preparation and pre-construction activities include the following: Erection of signage and information boards for the general public, employees and trucks delivering raw materials to site and exporting finished product. A traffic management plan A Construction Environmental Management Plan (CEMP) will be prepared and agreed between Dairygold, the contractor and relevant stakeholders such as IFI, Mallow Town Council and Cork County Council. The EPA may also need to be consulted as part of that pre construction process. One of the perceived risks during the construction phase is the risk of run-off from the site particularly during demolition, excavation and general construction works. Part of the preconstruction activities will be the construction of a berm along the edge of the onsite stream with associated settlement ponds to act as a protection measure against run-off. A demolition plan will be included in the overall construction management plan and adequate mitigation measures to minimise dust, noise and potential run-off will be incorporated into the CEMP Surface Water Management during Construction The site is already a sealed surface site and so existing surface water is managed through the present surface water system. This project in effect will see the site re-organised and rebuilt with new buildings, yard areas and areas with different functions than previously. Importantly, the existing surface water management system will have to be dismantled in stages and a new system constructed to reflect the new site layout. During the construction phase there is a risk of run-off from the site reaching the stream passing through the site, directly over the surface or via existing drains. At the outset the CEMP will set out how surface water management will be undertaken during the works. A temporary protective watercourse soil berm with associated settlement ponds can be constructed so as to protect Linehans stream. The CEMP will include measures for the control of run-off and general surface 24 EPA Export :23:03:55

61 Rev A Natura Impact Statement July 2012 water management. The sequencing of works, particularly removal of the existing network and construction of new network will be carefully managed to reduce risk. Once the demolitions, excavations, new slabs and building substructures are well advanced there will be less exposed surface area for the potential for run-off. A key aspect on site will be the management of plant and equipment, fuel, oils, solvents, construction related chemicals/additives etc all of which will be on site during the works. The management of these aspects will also form part of the CEMP for the project. The stream running through the site is a tributary of the River Blackwater, approximately 0.5km from the site. The stream passing through the site is a conduit through which sediment, run-off or any fuel spill could eventually reach the Blackwater and so surface water management will be an important aspect to be controlled and monitored throughout the works Description of Construction Activities and Phasing The main elements of construction activity include the following: Site set up and separation of the construction site from the active production site - this will change in each phase Demolitions of buildings, removal of substructures, grubbing up of decommissioned services, removal of redundant yard slabs Construction of the substructures of all new buildings Construction of the superstructure of all buildings Delivery and placement of all tanks, bunds and ancillary equipment Delivery, installation and commissioning of all process plant Installation new underground services, including foul, surface and rainwater systems - this would include new upgraded foul sewer to the treatment plant Mechanical, electrical and process fit out - commissioning of all plant Construction of new access roads internally - work externally from the site on roundabouts and northern access road Construction of all new yard areas - construction of new employee/visitor car park to the south of the site. Switchover of various elements of the plant at key dates in order to allow for a transition to the layout and operating facility Final snagging, handover and site cleanup The project will have to be constructed in phase s in order to allow for sequenced demolitions and the commissioning of new plant without affecting the operation of the facility. The construction and commission is expected to take 18 months and is expected to commence from September The construction work will be phased as follows: 25 EPA Export :23:03:55

62 Rev A Natura Impact Statement July 2012 Phase 1 This initial phase will entail upgrading the access from the north and bringing the new road through the site on the eastern section going past the rear of the existing Burdens store. This phase will include the off-site improvements to both the Annabella and northern roundabout N20 roundabouts and a portion of approach road to the site between the roundabout and site entrance, on Lower Beecher Street, which are required as part of the overall project. This work needs to be done first to facilitate the switch of traffic to the northern entrance in Phase 2. This phase will see the site separated into two broad areas, the western portion being the Dairygold production area of the site and the eastern section being the construction site. It is envisaged that during this phase that the northern entrance will be used for traffic and the eastern part of the site across Linehans Stream will become the main contractor s compound and construction staff parking area. The existing southern entrance to the site will continue to be used for production/process related traffic and for employee access for Dairygold. This phase will also see the demolition of the existing Vocational Educational Committee (VEC) office, part of the Burdens store and the clearance of the remnants of buildings adjacent to the CHP boiler house where the new milk intake area will be built. This phase will also see grubbing up of redundant slabs and the preparation of ground for new concrete slabs to accommodate the revised site layout. This work will include the re-organisation of the underground services (foul, surface water, watermains and service ducts (e.g. electrical wires, steam ducts)) to link in with the new site layout. The new weighbridges and access control buildings will be put in place in conjunction with the new road network. Once the new access road is in place then the noise screens and temporary watercourse protection berm will be put in place and any landscaping will be undertaken at the north of the site in advance of the heavy works commencing in Phase 2 and so provides mitigation against construction phase noise and traffic. A portion of the new access road will traverse the area where previously excavated soils that had naturally occurring elevations of Arsenic and Nickel are stored (see Section above). There will be no excavation on this area of ground. It is envisaged that this ground will firstly be compacted and then covered with a geotextile followed by a further capping layer of stone and then finally the stone layer supporting the concrete road slab. The material will not be excavated, but will be left in situ and will not be disturbed. The outline of this phase can be seen in Figure 2.6 in Chapter 2 of Volume 3 of the EIS. Phase 2 This phase effectively sees the construction site footprint expanding westwards and further demolitions taking place. The construction of the new milk intake and associated buildings will be completed, and the site area for the new drier building, packing area and the remainder of the new powder store will also be completed. In this phase the delivery of milk and the export of product will now switch to the new upgraded northern entrance and the access to the existing milk intake will be temporarily modified to facilitate ongoing deliveries. At that point the construction entrance will 26 EPA Export :23:03:55

63 Rev A Natura Impact Statement July 2012 change to the southern side so as to facilitate the substantial completion of the main buildings and importantly to keep the ongoing process traffic separate from the construction phase traffic. Access and parking generated by staff will have to be separated out temporarily. Some limited access will be maintained through the site past the laboratory and offices to facilitate day to day operations. This access route would be primarily pedestrian and would exclude heavy vehicles. Towards the end of Phase 2 the construction of the following buildings will be complete: Milk intake area including Pasteurisation/Separation building Drier building Evaporation building Administration building Powder store Packaging and Palletising store All associated and necessary tanks to facilitate process This approach will allow for the switchover of traffic to the northern entrance and the change of location of production on site from the north of the site to the south. An important element of this phase will be the substantial completion of the foul and surface water network on site and the new discharge points, be they surface water to the Linehans Stream or the foul to the treatment plants. All services will have to be fully completed at the end of this phase to facilitate the operation of the plant. The service bridges between the Boiler building and the other new structures will be completed in this stage to facilitate the tie in of all services, energy, power, steam etc. The commissioning of the various elements of plant will be done in stages, but this will not have external impacts as the work will mostly be contained within the new buildings. The outline of this phase can be seen in Figure 2.7 of Volume 3 of the EIS. Phase 3 This final phase is primarily about completing the northwest portion of the site, getting all final tankage in place, completing the tie in of services. It will also include the tie in of the new administration building to the existing engineering workshops and stores at a high level. This phase will see completion of the remaining new yard slabs, the completion of the new visitor and employee car park at the southern entrance and finally the removal and clean up of the contractor s compound on the eastern portion of the site. In this final phase the level of construction traffic and noise will have reduced, as the main construction work for new buildings will have been completed. This final phase will also include ancillary elements being completed such as signage, line markings, any landscaping required Waste Disposal during Construction Phase This project will generate waste from the construction process, but also from the existence of employees on site. Demolition waste generated by the demolition renovation and construction 27 EPA Export :23:03:55

64 Rev A Natura Impact Statement July 2012 activities associated with the proposal including rubble, glass, general and electrical fixtures and fittings. Surplus excavation will be taken off-site to approved waste facilities. The waste from site will be generated as part of the normal residues that occur during construction where you can have fragments of steel, cladding, cement bags, insulation, materials packaging etc arising during the works. Table 8. Generated Waste and Disposal Outlets Activity Waste Generated Disposal/Treatment Recommendations* Delivery of materials Materials wrapping To be removed from the Cladding to buildings Off cuts of metal and insulation site by Approved Waste Contactor and disposed / Reinforced concrete elements walls, floors, foundations Reinforcement steel, shutters, DPM, insulation recovered at an Approved registered or licenced waste facility Walls of buildings Operation of machinery Canteen facilities Ready mixed concrete Electrical fit out Mechanical fit out Process plant Operational Phase Concrete blocks, insulation and wrapping Oils, filters and cleaning materials Food waste, packaging materials, dry recyclables Wash out from trucks Metal, wire Pipe off cuts, wrapping, insulation, weld rods Pipe off cuts, wrapping, insulation, weld rods There will be no changes to the range activities currently being undertaken at the facility. Principal activities will continue to comprise i) raw milk intake, ii) raw milk processing, (namely its clarification and separation, pasteurisation and standardisation), iii) processing of the milk into powder and iv) distribution of end products. Surplus cream will also continue to be produced on site and will be dispatched as a saleable by-product. The proposed extension at the site will allow the facility to increase the overall production rates. The raw material required for the process is available in the Munster region through a network of society farmers. Adequate milk supply will be available going forward due to the lifting of Quota limits on milk production. With the exception of vegetation oil which is required for in the production of fat filled powder milk, there will be no changes in the types of raw materials to be used on site. The following estimates have been made regarding the future volumes of material inputs. 28 EPA Export :23:03:55

65 Rev A Natura Impact Statement July 2012 Table 9. Future Types and Quantities of Inputs Material Inputs Food Grade Materials Volumes per annum Raw milk 885 million litres Water 490,000m 3 Ingredients 9,150tonnes CIP Materials Caustic (30%) 1000 Tonnes Nitric acid (55%) Blended caustic detergent 200 Tonnes 500 tonnes Fuel Diesel Oil Back up as required Gas Piped Water and Wastewater treatment Bulk Propane Gas 95,000 Chloros, Quick lime, water treatment salts, Aluminium Sulphate (8%) 650tonnes The current process water requirement is approximately 650m 3 /day. It is calculated that the future process water requirement for the new facility will be in the order of 1961m 3 per day. Thus an additional 1,311m 3 of process water will be required. It is proposed that approximately 600m 3 of this water requirement will be supplied by the existing groundwater wells thus increasing the daily abstraction from the site wells from 650m 3 /day to approximately 1250m 3 /day. The remaining 711m 3 water requirement will be met by recycling condensate for cleaning in place (CIP) activities. The facility currently uses natural gas and electricity as energy inputs. There will be no change to these types of energy inputs. The additional electricity requirement will be meet by the CHP plant in parallel with the ESB national grid. No new waste types will be generated on site, nor will there be any requirement for changes to the existing waste disposal/recovery routes as a result of the proposed redevelopment. It is anticipated that sludge generated by the facility wastewater treatment plant will be significantly increased from 210 tonnes of sludge per annum to approximately 1,930 tonnes of sludge per annum. It is proposed that the landspreading of sludge generated by the on-site wastewater treatment plant will continue to be carried out by permitted contractor in accordance with an approved Nutrient Management Plan. There is also an option to dispose of sludge in a Dairygold digester at its Mitchelstown plan should it be required. Process effluent and cooling water from the site is currently directed to the facility WWTP. This is located south of the dairy processing centre and approximately 100 m from the River Blackwater. There will be no change to the wastewater treatment activities. It is projected that the volume of 29 EPA Export :23:03:55

66 Rev A Natura Impact Statement July 2012 process wastewater to be generated by future site activities will be increased from 993m 3 per day to approximately 3,729m 3 per day. An assessment of the carrying capacity of the existing WWTP has been undertaken by Malachy Walsh and Partners (see Appendix 6 of EIS). It determined that the existing WWTP will be able to accommodate the future additional wastewater load. Should a malfunction of the WWTP occur the facility will have the capability to undertake a diversion and containment preventing untreated effluent discharge entering the Blackwater River. It is proposed that sanitary/domestic wastewater generated by the future facility will continue to be discharged to the town sewerage scheme. It is anticipated that the volume of domestic wastewater to be generated by future site activities will be increased from 5m 3 per day to approximately 7m 3 per day. Surface water arising on the site (from roofs and yard areas) will continue to discharged to the internal stream, known as Linehans stream or the Linehans Stream, via the two (2) existing licenced outfalls. (IPPC licence emission point references SWD2 and SWD3). These discharges will continue to be monitored as per Licence Schedule C.2.3 Monitoring of Storm Water Emissions. No new types of air emissions will be generated on site as a result of the proposed redevelopment. The new dryers and associated gas burners will however be new emission sources. It is proposed that the new dryers will be fitted with bag house filters to enhance the quality of air released from the drying process. Full details of the future operational air emissions from the facility including a detailed air impact assessment are provided in Chapter 8 of Volume 2 of the EIS. The manufacturing plant will continue to operate on a seasonal basis, typically 40 weeks per year (maximum), from March to November. Operating hours at the plant will be 24 hour per day, 7 days per week. The operational phase of the new upgraded facility will employ up to an additional 40 persons. 30 EPA Export :23:03:55

67 Rev A Natura Impact Statement July Identification of other projects or plans The development site is situated on the western side of Mallow Town Centre. Urban run-off is a potential source of non point pollution and diffuse pollution run-off to the Blackwater Mallow Waste Water Treatment Plant (WWTP) The wastewater in Mallow is collected in a partially combined foul and separated foul sewage drainage network located approximately 2 km downstream of the Dairygold site. The wastewater drains from the town on both sides of the Blackwater River. The wastewater drains to a pumping station at Mallow Bridge, which is then pumped to the WWTP. The Mallow WWTP is designed for a Population Equivalent (PE) of 18,000PE and BOD loading of 1,080 Kg/day. The maximum hydraulic capacity of the Mallow WWTP is 556m 3 /h which is 2.5 Dry Weather Flow (2.5DWF). The treatment plant treats all flows that arrive at the works to secondary standards in accordance with the Urban Waste Water Directive Other IPPC Licenced Sites Two other IPPC licensed facilities are situated in the Mallow municipal area. These are the Micam and Road Binders installations located approximately 1km upstream and opposite the Dairygold plant respectively. Micam (Mica & Micanite (Ireland) Ltd.) manufacture Industrial Laminates, Plastic Machined Components and Printed Circuit Boards (PCBs) at their site in Sean Moylan Park, Mallow. The plant features an integral WWTP which treats wastewater on-site before discharging to the sewer network for further treatment at Mallow WWTP. There is no process effluent being discharged to the sewer network, only municipal sewage. The Roadbinders plant manufactures a range of cationic emulsions for use in the road construction and maintenance industry. Waste water is discharged to the public sewer. The closed Irish Sugar Factory, a former IPPC and contaminated site, is located approximately 3km upstream and contains a number of settlement lagoons Agriculture The upland parts of the Blackwater catchment are open country or afforested. In the lowland areas the dominant Corine Landcover category is Pasture 2. Agriculture is the key source of total phosphorous inputs; mostly diffuse (69%) 3, to the Blackwater catchment, for example, 80% to the Awbeg (SWRBD, 2010a) and 79% to the Bride (SWRBD, 2010b). However, there has been very considerable change in agricultural practices since the introduction of the Nitrates Action Plans (1 and 2) that has led to a significant reduction in the level of chemical fertiliser usage, in particular phosphorus. In addition, restrictions on applications at vulnerable times of year have reduced losses to surface water. In recent years much of the agricultural point source problem has been addressed 2 [accessed 12/07/2102] 3 Blackwater Water Management Unit Action Plan (SWRBD) available at 31 EPA Export :23:03:55

68 Rev A Natura Impact Statement July 2012 through the implementation of the Farm Waste Management Scheme which assists farmers in meeting requirements under the European Communities (Good Agricultural Practice for Protection of Waters) Regulations 2005 (S.I. No. 788 of 2005). The Scheme has brought about changes in onfarm storage and management of animal excreta, soiled water and other farmyard manures together with new equipment for the application of same to farmland Forestry The practices associated with the management of commercial forestry such as initial site preparation, construction of the required infrastructure and subsequent thinning, felling and replanting can be a significant source of silt and nutrients to watercourses. Forestry accounts for 7% of diffuse phosphorous pollution in the Blackwater catchment. Site preparation, can cause erosion and release of silt into rivers or lakes, as can clearfelling, when large areas can become exposed to surface water run-off of silt and the residues adhering to soil particles. The use of herbicides and the application of fertiliser, particularly aerial fertilization, can lead to pollution concerns when close to watercourses or when drainage networks discharge to watercourses without adequate buffering (Kilfeather, 2000). Acidification of waters is also associated with afforestation. The Corine Landcover (2006) layer indicates that, while there are some areas of forestry both upstream and downstream of Mallow these are not dominant within the catchment. The upstream distribution is concentrated in the upper reaches of the Blackwater around Mount Eagle, to the north of Ballydesmond. The majority of the afforestation downstream within the catchment is concentrated in the upland areas of the Nagles Mountains. 4 [accessed 12/07/2012] 32 EPA Export :23:03:55

69 Rev A Natura Impact Statement July Identification of Natura 2000 sites Zone of impact influence The Screening stage of AA involves compiling a long list of European sites within a zone of potential impact influence for later analysis which may or may ultimately not be impacted upon by the proposal. All Natura 2000 sites within 15km of the proposal location will be characterised in the context of the rationale for designation and qualifying features, in accordance with NPWS guidance. Following this, the potential impacts associated with the proposal will be identified before an assessment is made of the likely significance of these impacts. Finally, in the conclusion of the screening stage, the Natura 2000 sites within 15km whose integrity will not be adversely impacted will be ruled out. If screening indicates sites will be affected it will be necessary to proceed to Stage 2, Appropriate Assessment for a more detailed assessment Identification of Natura 2000 and Ramsar sites Adopting the precautionary principle in identifying potentially affected European sites, it has been decided to include all csacs and SPAs/Ramsar sites, within a 15km radius of the proposal site. The Convention on Wetlands of International Importance especially as Waterfowl Habitat, more commonly known as the Ramsar Convention, was ratified by Ireland in Although not specifically required, it would be considered best practice to include Ramsar sites (classified under the Ramsar Convention 1971) in the appropriate assessment process 5. No Ramsar sites occur within 15km. Figure 5 and Table 10 below detail the Natura 200 sites within 15km of the Dairygold facility. 5 EPA, A Note on Waste Water Discharging Licence Appropriate Assessments 33 EPA Export :23:03:55

70 Rev A Natura Impact Statement July 2012 Figure 5. Designated Natura 2000 sites within 15km of Dairygold site 34 EPA Export :23:03:55

71 Rev A Natura Impact Statement Table 10. Designated conservation sites within a 15km radius of proposal site No. Designated Site Site Code Proximity of site to designated site 1 Blackwater River Cork/Waterford SAC km 2 Kilcolman Bog SPA km Summaries of the sites outlined in Table 10 above are included in Appendix Characteristics of Natura 2000 and Ramsar sites The following table lists the csacs and SPA and Ramsar sites selected for Appropriate Assessment with their qualifying features and other conservation interests (information pertaining to designated sites is from site synopses, conservation objectives and other information available on and on Table 11. Designated sites with features of interest Designated Site Blackwater River (Cork/Waterford) SAC Site Code Kilcolman Bog SPA Features of Interest Species Freshwater pearl mussel (Margaritifera margaritifera) [1029] White-clawed crayfish (Austropotamobius pallipes) [1092] Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Allis shad (Alosa alosa) [1102] Twaite shad (Alosa fallax fallax) [1103] Salmon (Salmo salar) [1106] Otter (Lutra lutra) [1355] Killarney fern (Trichomanes speciosum) [1421] Habitats Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Perennial vegetation of stony banks [1220] Salicornia and other annuals colonizing mud and sand [1310] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Mediterranean salt meadows (Juncetalia maritimi) [1410] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno- Padion, Alnion incanae, Salicion albae) [91E0] Taxus baccata woods of the British Isles [91J0] Whooper Swan (Cygnus cygnus) [A038] Teal (Anas crecca) [A052] Shoveler (Anas clypeata) [A056] Wetlands & Waterbirds [A999] 35 EPA Export :23:03:55

72 Rev A Natura Impact Statement Conservation Objectives According to the Habitat s Directive, the conservation status of a natural habitat will be taken as favourable when: its natural range and areas it covers within that range are stable or increasing, and the specific structure and functions which are necessary for its long-term maintenance exist and are likely to continue to exist for the foreseeable future, and the conservation status of its typical species is favourable as defined below. According to the Habitat s Directive, the conservation status of a species means the sum of the influences acting on the species concerned that may affect the long-term distribution and abundance of its populations. The conservation status will be taken as favourable when: population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats, and the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis. These conservation objectives are of a wide-ranging nature and most of the conservation objectives developed by NPWS for Natura 2000 sites area are adapted from these and published on-line as Generic Conservation Objective documents. However, more site specific conservation objectives have been developed for some sites and these are published on-line, by the NPWS, as comprehensive Conservation Statements. Copies of the Generic Conservation Objective documents for the Natura 2000 sites are included in Appendix 2 and are also available on 36 EPA Export :23:03:55

73 Rev A Natura Impact Statement 2.4 Identification of Potential Impacts Construction Phase Potential construction phase impacts are identified in this section. Only those features of the development that have the potential to impact on qualifying features, conservation interests and conservation objectives of the identified Natura 2000 sites are considered. Description of elements of the project likely to give rise to impacts on Natura 2000 sites. 1. Demolition of existing structures and surfaces 2. Excavations to accommodate new structures and surfaces 3. Construction of new structures, surfaces, ancillary services and storage tanks. 4. Use of hazardous substances such as fuels/oils, concrete and chemicals 5. Use of construction equipment, vehicles and plant Describe any likely direct, indirect or secondary impacts of the project (either alone or in combination with other plans or projects) on Natura 2000 sites by virtue of: Size and scale; Land-take; Distance from Natura 2000 Site or key features of the Site; Resource requirements; Emissions; Excavation requirements; Transportation requirements; Duration of construction, operation etc.; and Other. Describe any likely changes to the site arising as a result of: 1. Disturbance and risk of pollution run-off during construction phase 2. Proximity of some construction elements to Linehans stream which enters Blackwater River SAC increasing pollution risk 3. Potential risk of run-off of silt, fuels/oils, cementitious material, chemicals to local watercourses during construction phase 4. Potential risk of water quality environmental quality standard exceedances at existing discharge points to Linehans stream during construction phase 5. Risk of accidental spillage event of pollutants such as fuels/oils, cementitious material, chemicals during construction phase Reduction of habitat area; Disturbance of key species; Habitat or species fragmentation; Reduction in species density; Changes in key indicators of conservation value; and Climate change. Describe any likely impacts on the Natura 2000 site as a whole in terms of: Interference with the Key relationships that define the structure of the site; and Interference with key relationships that define the function of the site. Water quality impacts arising during the construction phase to Blackwater SAC could adversely affect designated aquatic qualifying species and their habitats, or qualifying habitats A reduction in water quality, a significance indicator of conservation status that underpins the structure and function of the Natura 2000 site, could interfere with key relationships. 37 EPA Export :23:03:55

74 Rev A Natura Impact Statement Operational Phase Potential operational phase impacts are identified in this section. Only those features of the development that have the potential to impact on qualifying features, conservation interests and conservation objectives of the identified Natura 2000 sites are considered. There will be no changes to the range activities currently being undertaken at the facility. All redevelopment works of the proposed scheme will be within the existing site boundary. The proposed redevelopment of the Mallow facility will incorporate best environmental practice, enhancing the environmental protections already in place. The Dairygold facility at Mallow is regulated by the EPA under an Integrated Pollution Prevention Control (IPPC) Licence Reg. No. P The Licence was reviewed in 2011 in accordance with Section 87 (2) of the Environmental Protection Agency Acts 1992 and The licence sets out in detail the conditions under which Dairygold Co-operative Society Limited will operate and manage this installation. The proposal will operate under the IPPC licence and therefore the site will be under the control and regulation of the EPA and the site will be required to adhere to existing, and any new future, licence requirements. The EPA is satisfied, on the basis of the information available, that subject to compliance with the conditions of the licence, any emissions from existing activities will comply with and will not contravene any of the requirements of Section 83(5) of the Environmental Protection Agency Acts 1992 to As part of the licence agreement an Environmental Management System (EMS) is in place and updated annually. The EMS includes for: environmental objectives and targets; Environmental Management Programme (EMP); corrective action should the specified requirements of the licence not be fulfilled; awareness and training for all personnel whose work can have a significant effect on the environment; communication programme; maintenance programme; and efficient process control to ensure there is adequate control of processes under all modes of operation. Under the licence, ph, flow, Biological COD, suspended solids and sludge dewatering are monitored on a daily basis. The current limits are set based on the latest surface water regulations (S.I. No. 272 of 2009) and monitoring and reporting requirements are set out in IPCC licence. Site inspections from the EPA may be arranged and on-the-spot. Every licensee has to submit its Annual Environmental Report each year in the month of March detailing the environmental performance of the facility. Following the redevelopment of the facility, it is proposed that the landspreading of sludge generated by the on-site wastewater treatment plant will continue to be carried out by permitted contractor in accordance with an approved Nutrient Management Plan (NMP). Landspreading is subject to conditions and prior agreement with the Agency. The landbank is checked and approved annually as part of the NMP. There is also an option to dispose of sludge in a Dairygold digester at its Mitchelstown plant should it be required in the future under any new licence agreement. This is subject to agreement and approval with the relevant authorities. There will be no change to the wastewater treatment activities; however there will be an intensification of volume. The existing WWTP will be able to accommodate the future additional wastewater load (see Appendix 6 of Volume 3 of the EIS for assessment on the WWTP). It determined that the existing WWTP will be able to accommodate the future additional wastewater 38 EPA Export :23:03:55

75 Rev A Natura Impact Statement load. Should a malfunction of the WWTP occur the facility will have the capability to undertake diversion and containment measures in accordance with normal execution of operations preventing any discharge of untreated effluent to the Blackwater River. In the normal execution of operations, it is therefore not expected that the proposed redevelopment will have a significant impact on the Blackwater River SAC. Possible scenarios for potential emergency situations to arise at the Dairygold site have been identified as follows: A spill of material (food grade, CIP, other) during a delivery from a delivery vehicle or during transfer to storage tanks Leakage of material from tanks, containers and drum storage areas Leakage of materials during transport/pumping from storage to destined location The risk areas for potential spills and leaks include: Milk intake Area Access road from entrance to milk intake area Main dispatch area / pasteurised milk storage area at north of site o Here the chemical in-take building is where all the various chemicals are fed into the storage tank system Existing boiler house o New diesel fuel storage tank to service the existing boiler house Standard health and safety operating procedures in terms of accident prevention, emergency response and materials handling are in place under environmental management and health and safety systems. Under the existing operating licence requirements: all emission points must have adequate sampling equipment in place as required by the Agency; all tanks, containers and drum storage areas are required to be adequately impervious and bunded; have adequate supply of containment booms and/or suitable absorbent material to contain or absorb any spillage; and have silt traps and oil separators on all storm water discharges. All pumps sumps, storage tanks, lagoons or other treatment plant chambers from which spillage of environmentally significant materials might occur in such quantities as are likely to breach local or remote containment or separators, shall be fitted with high liquid level alarms (or oil detectors as appropriate). A catchment system must be in place to collect any leaks from flanges and valves. With redevelopment of the site there will be a requirement on the EPA to review and update the IPPC licence. A key element of the redevelopment of the site will be upgrading of the safety and environmental procedures on site as a result of bringing in new equipment, buildings, foul and surface water systems. The redevelopment of the site is an opportunity to extend the safety and environmental operational aspects of the facility such as installation of new bunded tanks with 110% capacity and dedicated underground surface water and foul sewer services, increased efficiencies in machinery, water recycling. For example the installation of new underground services forms part of 39 EPA Export :23:03:55

76 Rev A Natura Impact Statement the redevelopment. As part of the review and upgrade of the IPPC licence there will be a requirement to put new and adequate safety and environmental procedures in place. Roof water will be diverted to a rainwater harvesting system thus reducing the volume of rainfall falling on open hard surfaces and entering the surface water drainage system. All relevant areas of the site are designed with crossfalls to direct any accidental spillages to the surface water or process wastewater drainage systems as appropriate. The milk intake area has a covered roofed area. Any spillage or leaks in this area is contained by a dedicated sump and drain system and in the even of an accidental spillage it is directed along a crossfall (downward slope) to the new process wastewater drainage system and onto the Dairygold WWTP. All storage tank bunds associated with the redevelopment are designed to 110% capacity factor e.g. chemicals, fuels, water tanks. No surface water drains exist beneath the new chemical intake area. In the event of accidental spills or leaks on any of the roads, yards or hardstand areas an isolating valve and a conductivity controlled valve will be installed prior to the discharge point, which enables the site manager to control and isolate any spill risk. Alternatively, for a localised spill on a section of surface water drainage line, a stopper can be manually inserted to locally contain the spill and allow for clean up and avoidance of any risk to the stream. Good site procedures in this regard will be part of the IPCC licence requirements for any review and update of licence. It is important that Linehans stream, the main conduit from the site to the Blackwater River SAC, is adequately protected. If an accidental spill on the hardstand or road area were to occur the first point of protection is the proposed raised continuous concrete kerb (~0.2m high). A road gulley also forms part of the surface water drainage system on site and as mentioned an accidental spill can be isolated from the stream and controlled. For added protection the crossfall directs any accidental spills away from the kerb towards the road gulley. Spills inside buildings will be self contained and will not enter the surface water drainage system. All underground services are laid in trenches with concrete surround and protection. Additionally, all services are protected by a new reinforced concrete slab, the hardstand, which is overlain at ground level through the site. Prior to the completion of construction these service lines are tested by air or water pressure prior to hand over. All surfaces will be sealed over the entire site area so any accidental spillage travels to either the surface water system or foul sewer system as appropriate. Oil interceptors with adequate capacity will be installed on surface water drains beside the diesel storage tank. Under an updated IPPC licence all conditions including those dealing with accident prevention and emergency response will be upgraded should planning be granted. In summary, for these reasons outlined above, it is not expected that the elements of the operational phase of the proposal for the redevelopment Dairygold site will result in significant direct or indirect impacts to Natura 2000 sites, namely the Blackwater River SAC. 40 EPA Export :23:03:55

77 Rev A Natura Impact Statement 2.5 Assessment of Significance of Potential Impacts This section considers the list of sites identified in Section 2.3 above. The magnitude/extent, probability and duration of potentially significant impacts, identified in the previous section, affecting these sites are examined in the following sections. A distance in excess of 11km separates the location of the proposal considered in this document from the Kilcolman Bog SPA (004095) site. The SPA is within a separate sub-catchment of the Blackwater River catchment. Therefore, any potential impacts from the proposal on the avian species for which the Natura 2000 site is designated, or on the habitats that they require would be attenuated by the intervening distance and separation of sub-catchment. It is considered that the conditions required to initiate a potential source-pathway-target vector connecting the proposal site to this designated site will not be created. Therefore, it is not expected that the proposal will significantly adversely affect the conservation objectives for Kilcolman Bog SPA. Therefore, the assessment of significance of potential impacts that follows focuses on the remaining designated sites as follows: Blackwater River (Cork/Waterford) SAC (002170). The potential for significant impacts arising from the proposal was determined based on a number of indicators including: Habitat loss; Habitat alteration; Habitat or species fragmentation; Disturbance and/or displacement of species; Water quality and resource Habitat Loss or Alteration It is noted that the footprint of the proposed project to redevelop the milk powder processing facility at Mallow, County Cork is outside any designated site, albeit immediately adjacent to a stream that drains to the Blackwater River SAC. Therefore, no land take within any Natura 2000 site boundary is required and no direct terrestrial or riparian habitat loss or alteration is expected to result from the proposal within the Blackwater River SAC. However, the construction phase of the proposal does require extensive construction work in an area adjoining a stream that drains to the Blackwater River. As a consequence, indirect habitat loss or alteration impacts caused either by the ingress of suspended solids or by water pollution impacts or by a combination of these impacts, could occur as a result of the unmitigated project within the Blackwater River SAC. Therefore, it cannot be objectively concluded that significant indirect impacts on the habitats and species, for which this site is designated, will not ensue from the current unmitigated construction phase Habitat or species fragmentation Habitat fragmentation has been defined as reduction and isolation of patches of natural environment (Hall et al., 1997 cited in Franklin et al., 2002) usually due to an external disturbance such that an alteration of the spatial composition of a habitat occurs that alters the habitat and create[s] isolated or tenuously connected patches of the original habitat (Wiens, 1989 cited in 41 EPA Export :23:03:55

78 Rev A Natura Impact Statement Franklin et al., 2002). This results in spatial separation of habitat units which had previously been in a state of greater continuity. Adverse effects of habitat fragmentation on species or populations can include increased isolation of populations or species which can detrimentally impact on the resilience or robustness of the populations reducing overall species diversity and altering species abundance. As there will be no direct habitat loss it is not considered that significant habitat fragmentation will arise from the proposal. However, if habitats or species distribution (e.g. spawning habitats) significantly altered as a result of habitat alteration impacts arising from the proposed construction phase, then fragmentation could occur. This is addressed under habitat loss and alteration and water qualify impacts Disturbance and/or displacement of species Aquatic fauna It is noted that the Blackwater River SAC is designated for the aquatic species listed below. While it is acknowledged that a number of these species have a strong association with estuarine and marine habitats it is presumed on the basis of the precautionary principle, and for the purposes of this document, that all species are within the zone of impact influence of the proposal. The species are: White-clawed crayfish (A. pallipes) [1092] Sea lamprey (P. marinus) [1095] Allis shad (A. alosa) [1102] Twaite shad (A. fallax fallax) [1103] Freshwater pearl mussel (M. margaritifera) [1029] Brook lamprey (L. planeri) [1096] River lamprey (L. fluviatilis) [1099] Salmon (S. salar) [1106] It is noted that the construction phase of the proposal requires demolition of existing structures and extensive excavation over a substantial footprint in an area adjacent to a stream that drains to the Blackwater River. As a consequence, indirect disturbance or displacement impacts caused either by the ingress of suspended solids into the aquatic environment or by water pollution impacts or by a combination of these impacts, could occur as a result of the unmitigated project. In the event that such impacts were to ensue from the construction phase of the proposal, significant disturbance or displacement impacts on these species could be initiated Otter (Lutra lutra) The biological water quality of Linehans stream was Q2 (bad status) and Q3 (poor status) (see Section 5.2 of Volume 2 of the EIS). The stretch of Linehans stream that bounds the Dairygold site supports a limited vegetation cover with an absence of a riparian corridor while much of the stream is culverted. The stream is also culverted where it intersects with national roads. Therefore, it is highly unlikely that otter use Linehans stream in the vicinity of the facility it due to its poor water quality and low suitability. However, otter are likely to use the main Blackwater River channel. Should the water quality of the river be adversely affected by the construction phase run-off significant effects cannot be precluded. 42 EPA Export :23:03:55

79 Rev A Natura Impact Statement Killarney Fern (Trichomanes speciosum) It is noted that the Blackwater River SAC is designated for Killarney Fern. A search of the NPWS on line mapviewer indicates that the record for this species is located within the 10km grid squares S00 6 (near Lismore, County Waterford) and not 10km grid square W59 where the proposal site is located. A similar search of the National Biodiversity Data Centre 7 confirms the presence/absence locations data outlined above. It is considered that the habitats found within the proposal site are not suitable habitat for the species as defined in the All Ireland Species Action Plan 8 as follows: In Ireland the sporophyte occurs in dripping caves, cliff faces, crevices by waterfalls and cascades, rock crevices in woodlands and very occasionally on the floor of damp woodlands. The gametophyte grows in similar habitats, albeit drier and darker, as it does not appear to require direct contact with water The species is frost-sensitive. On the basis of the habitat requirements of this species it is objectively concluded that this species is unlikely to be within the zone of impact influence of the proposal considered in this document. It is not expected that significant disturbance or displacement impacts on this species are reasonably foreseeable as a result of the proposal considered in this document Water quality and resource The water quality in the River Blackwater is essential for supporting the biological elements associated with the river habitat. Adverse impacts to its water quality could have indirect impacts on other the qualifying interests of Blackwater River SAC. Uncontrolled silt run-off could impact negatively on freshwater pearl mussel populations. A reduction in water quality arising from the construction phase could affect the distribution and density of salmonids, which could potentially affect the availability of prey for otter, or the availability of salmonid hosts required by the parasitic larval stage of the freshwater pearl mussel. Due to the risk of water pollution from the proposed construction phase entering the adjacent stream which is directly connected to the Blackwater River (Cork/Waterford) SAC the potential for occurrence of significant impacts cannot be ruled out. 6 Available at: [accessed 7/06/2012] 7 Available at: [accessed 7/06/2012] 8 Available at: [accessed 7/06/2012] 43 EPA Export :23:03:55

80 Rev A Natura Impact Statement 2.6 Conclusion of Screening Stage In conclusion, to determine the potential impacts, if any, of the proposal to redevelop the Dairygold milk powder processing facility at Mallow, County Cork on nearby Natura 2000 sites, a Screening for AA was undertaken. The proposed development is within 15km of 2 Natura 2000 sites. It has been objectively concluded during the screening process that one of these sites is not likely to be significantly impacted by the proposal considered in this document and this Natura 2000 site is: Kilcolman Bog SPA (004095) It has been concluded that one site may be significantly impacted by the proposal considered in this document. Potential impacts may occur within the following sites: Blackwater River Cork/Waterford SAC (002170) Hence, the recommendation of the screening process is to proceed to Stage 2: Natura Impact Statement, with regard to the construction phase of the proposal, for the following Natura 2000 sites: The Blackwater River (Cork/Waterford) SAC (002170) 44 EPA Export :23:03:55

81 Rev A Natura Impact Statement 3 Natura Impact Statement 3.1 Introduction The main objective of Stage 2 of the Appropriate Assessment process, Natura Impact Assessment, is to consider the impacts of the proposal on the integrity of the Natura sites, either alone or in combination with other projects, with respect to the conservation objectives of the sites and then to identify and assess mitigation measures against any adverse effects that the phases of the project are likely to cause. In this regard, the Blackwater River SAC site, which could potentially be impacted by the proposed development, is described below. The potential impacts resulting from the unmitigated construction phase of the proposal are then discussed in relation to the conservation objectives. Mitigation measures where appropriate are presented in below in Section Description of the Project A detailed description of the characteristics is outlined at section 2.2 above and further detail is presented in Chapter 2 of the Volume 2 of the EIS. 3.3 Characteristics of the Blackwater River (Cork/Waterford) SAC (002170) The River Blackwater is one of the largest rivers in Ireland, draining a major part of Co. Cork and five ranges of mountains. The site consists of the freshwater stretches of the River Blackwater as far upstream as Ballydesmond, the tidal stretches as far as Youghal Harbour and many tributaries, the larger of which includes the Licky, Bride, Flesk, Finisk, Araglin, Awbeg (Buttevant), Clyda, Glen, Allow, Dalua, Brogeen, Rathcool, Finnow, Owentaraglin and Awnaskirtaun. The extent of the Blackwater, and its tributaries in this Natura 2000 site, flows through the counties of Kerry, Cork, Limerick, Tipperary and Waterford. The site is a candidate SAC selected for alluvial wet woodlands and Yew wood, both priority habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected as a candidate SAC for floating river vegetation, estuaries, tidal mudflats, Salicornia mudflats, Atlantic salt meadows, Mediterranean salt meadows, perennial vegetation of stony banks and old Oak woodlands, all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive - Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, White-clawed Crayfish, Twaite shad, Allis shad, Atlantic salmon, Otter and the Killarney Fern. The Blackwater River is notable for being one of the best salmon fishing rivers in the country. Sea Trout ascend the lower reaches and one of its tributaries, the Bride. The Blackwater is noted for its enormous run of salmon over the years. The river is characterised by mighty pools, glides and generally, a good push of water coming through except in very low water. Spring salmon fishing can be carried out as far upstream as Fermoy and is very highly regarded especially at Careysville. The site supports many of the mammal species occurring in Ireland. Those which are listed in the Irish Red Data Book include Pine Marten, Badger and Irish Hare. The bat species Natterer s Bat, 45 EPA Export :23:03:55

82 Rev A Natura Impact Statement Daubenton s Bat, Whiskered Bat, Brown Long-eared Bat and Pipistrelle, are to be seen feeding along the river, roosting under the old bridges and in old buildings. Overall, the River Blackwater is of considerable conservation significance for the occurrence of good examples of habitats and of populations of plant and animal species that are listed on Annexes I and II of the E.U. Habitats Directive. 3.4 Features of Interest Table 12 below includes the full list of qualifying features of interest in the Blackwater River SAC. Potential impacts on the features or interest, or qualifying features, will be assessed in the context of the proposed redevelopment of the Dairygold facility. The ecological characteristics and conservation status of these species and habitats are presented in the following sub-sections. Table 12. Features of Interest of the Blackwater River SAC Designated Site Site Code Features of Interest Blackwater River (Cork/Waterford) Species Freshwater pearl mussel (Margaritifera margaritifera) [1029] White-clawed crayfish (Austropotamobius pallipes) [1092] Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Allis shad (Alosa alosa) [1102] Twaite shad (Alosa fallax fallax) [1103] Salmon (Salmo salar) [1106] Otter (Lutra lutra) [1355] Killarney fern (Trichomanes speciosum) [1421] Habitats Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Perennial vegetation of stony banks [1220] Salicornia and other annuals colonizing mud and sand [1310] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Mediterranean salt meadows (Juncetalia maritimi) [1410] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] Taxus baccata woods of the British Isles [91J0] Species Aquatic Species It is noted that the Blackwater River (Cork/Waterford) SAC (002170) is designated for the aquatic species listed below. Table 13 below indicates the overall conservation status of the species. 46 EPA Export :23:03:55

83 Rev A Natura Impact Statement Table 13. Overall conservations status of aquatic species (NPWS, 2008) Qualifying interest White-clawed crayfish (A. pallipes) Sea lamprey (P. marinus) Allis shad (A. alosa) Twaite shad (A. fallax fallax) Freshwater pearl mussel (M. margaritifera) Brook lamprey (L. planeri) River lamprey (L. fluviatilis) Salmon (S. salar) Overall conservation status Poor Poor Unknown Bad Bad Good Good Bad The following provides further information on these aquatic species. White-clawed crayfish (A. pallipes): In Ireland, the white-clawed crayfish most commonly occurs in small and medium-sized lakes, large rivers, streams and drains, wherever there is sufficient lime (Reynolds, 2007). The species prefers relatively cool temperatures and adequate dissolved oxygen and lime, although it is capable of tolerating significant fluctuations. Juveniles live among submerged tree-roots, gravel or aquatic plants, while larger crayfish need stones to hide under, or earthen banks in which to burrow. Crayfish show little activity during the winter period (December to March), spending most of their time torpid in refuges. They become more active when the water temperature increases. Females carry their eggs over winter attached in a dense cluster under their tails (Peay, 2003) and they require undisturbed shelter over a prolonged winter-spring period. White-clawed crayfish eat a wide range of food including fallen leaves, aquatic vegetation, dead fish, aquatic invertebrates such as snails and caddis-fly larvae, and other dead or live crayfish. They have a wide range of predators; juveniles are eaten by fish, birds and invertebrate predators, adults are taken by large predators; heron, otter and mink. The crayfish try to avoid predation by hiding in refuges by day and coming out at night, when most birds and fish are resting. The overall conservation status of the white-clawed crayfish in Ireland is poor, due to the reduction of range and the continuing pressures that it faces (NPWS, 2008). The published favourable reference range for this species does not include the 10km square which incorporates the proposal considered in this document. However records retained at the NBDC include a 2009 record for white clawed crayfish at a location downstream of the proposal site. This record is for 100m grid square W which is a linear distance of approximately 16km from the proposal site. It is presumed in light of the aforementioned direct evidence and on the basis of the precautionary principle, that this species is potentially present within the zone of impact influence of the proposal. 9 [accessed 7/06/2012] 47 EPA Export :23:03:55

84 Rev A Natura Impact Statement Sea lamprey (P. marinus): Sea lampreys spend their adult life in marine and estuarine waters, living as external parasites on other fish species. They migrate up rivers to spawn in areas of clean gravels and after they have spawned, they die. After hatching, the young larvae settle in areas of fine sediment in still water, where they burrow. They live as filter feeders and may remain in fine sediments for several years before transforming into adult fish. Sea lampreys, which can grow up to 1m in length, are widely distributed around the coast. However they tend to occur in low densities. Overall, the conservation status of the sea lamprey in Ireland is considered to be poor (NPWS, 2008). Although the published favourable reference range for this species does not include the 10km square of the proposal considered in this document, juveniles have been recorded as having a wide distribution within the Blackwater system, ranging from the headwaters to the lower reaches of the system (King, et al., 2004) with spawning activity recorded in the headwaters of the system at Ballydesmond which is situated upstream of the proposal site (Kurz and Costello, 1999 cited in King, et al., 2004). Allis shad (A. alosa): Allis shad spend their adult life at sea or in the lower reaches of estuaries, ascending to freshwater to spawn in early summer. The spawning females shed their eggs into the water where they either drop into the gravel bed or begin to drift downstream. Those eggs that fall into gravels hatch after several days and then drift downstream. The young fish may remain in estuarine waters during their second year before finally going to sea where they mature. While European populations have a recorded capacity for significant migration upstream, this capacity seems more constrained in Irish populations (King et al., 2004). Weirs and dams are known to be obstacles to the migration of Allis shad upstream. In the case of the Blackwater it has been noted that a weir located at Careysville 10 is likely to constitute a barrier to their movement upstream beyond that point (King, et al., 2004). The current conservation status of the species is Unknown (NPWS, 2008). The favourable reference range of this species does not include the 10km square where the proposal considered in this document occurs; because of this, and bearing in mind the barrier to migration referred to above, it is considered probable that this species does not occur within 15km of the proposed development and is not considered further in this assessment. Twaite shad (A. fallax fallax): Twaite shad spend their adult life at sea or in the lower reaches of estuaries and normally spawn near the tidal limits (NPWS, 2008). Weirs and dams are known to be obstacles to the migration of Twaite shad upstream. In the case of the Blackwater it has been noted that a weir located at Careysville is likely to constitute a barrier to their movement upstream beyond that point (King, et al., 2004). The current conservation status of the species is bad (NPWS, 2008). The favourable reference range of this species does not include the 10km square where the proposal considered in this document occurs; because of this and bearing in mind the aforementioned barrier to migration, 10 Situated downstream of Fermoy, County Cork. It is proposed to remove this weir to allow for the free and uninterrupted passage of migratory fish, as required by national and European legislation. [accessed 7/06/2012] 48 EPA Export :23:03:55

85 Rev A Natura Impact Statement it is considered probable that this species does not occur within 15km of the proposed development and is therefore not considered further in this assessment. Freshwater pearl mussel (M. margaritifera): Ireland is said to support up to 46% of the known populations of the freshwater pearl mussel (M. margaritifera) within the European Union (Anon, 2010). The freshwater pearl mussel is listed under Annex II of the EU Habitats Directive and is one of the species for which the Blackwater River SAC has been designated. Freshwater pearl mussels have a complex life cycle. They mature between seven and 15 years of age and can have a prolonged fertile period lasting into old age. The larvae (glochidia) initially attach to the gills of salmonid fish hosts which provide nourishment, before they become large enough for independent development in the river bed. After excysting from host fish juvenile mussels survive in the interstices of the substrate, comprised of a stable combination of sand, gravels and cobbles, where good oxygen exchange occurs. A covering of fine silt may prevent this and cause heavy mortalities. In summary, the freshwater pearl mussel requires very high quality rivers with clean river beds and waters with very low levels of nutrients without artificially elevated levels of siltation. The survival of the freshwater pearl mussel is under threat and many of the populations are not reproducing and will ultimately disappear if rehabilitative action is not taken. The Blackwater River has a water quality status of moderate and has been downgraded because of the pearl mussel, which requires high quality water. With regard to the measures required to rehabilitate the population in the Blackwater River SAC, it is noted in the Munster Blackwater Sub Basin Management Plan that the timescale required to rehabilitate the species is longer than the timescale of survival of the remaining mussels in the wild (Anon, 2010, p.45). Of the remaining populations in Ireland it is estimated that at least 90% will probably never breed successfully again (Moorkens, 2006, cited in Byrne et al., 2009). The principal threat to this species is poor substrate quality due to increased growth of algal and macrophyte vegetation as a result of severe nutrient enrichment, as well as physical siltation. The river quality of the Blackwater has been reduced due to nutrient enrichment and siltation from agriculture, forestry, sewage and industry and very heavy in-stream sediment loads are common along its length (Anon, 2010). Freshwater pearl mussel is listed as critically endangered in the Republic of Ireland in the most recent review of local IUCN threat status of Irish molluscs. Its overall conservation status in Ireland is Unfavourable (NPWS, 2008) The published current distribution for this species 11 includes the 10km square which incorporates the location of the proposal considered in this document. Much of the following information above is derived from the Freshwater Pearl Mussel Munster Blackwater Sub-basin Management Plan (NS 2, 2010). It is likely that a scattered population at least exists over the wide area from upstream of Mallow to Fermoy (and indeed from as far upstream as Knocknagree to as far downstream as Lismore). A significant concentrated population of freshwater pearl mussel in the Blackwater River 11 Species distribution mapping published in NPWS, EPA Export :23:03:55

86 Rev A Natura Impact Statement occurs along approximately 10km stretch between the Finnow and Fiddane River tributaries, either side of Mallow. The main ecological pressures within the Blackwater catchment are from diffuse (forestry, on-site WWTS) and point (WWTPs, quarries, contaminated lands) pollution sources. A summary of relevant freshwater pearl mussel studies carried out in the between 2005 and 2010 can be summarised as follows: A survey by Moorkens in 2004 in the Clyda area, 2 km upstream of Mallow yielded two living mussels and 300 dead shells from 500m of river. Siltation of the mussels caused by instream works was believed to be the cause of the mussel kill. A Stage 1 (presence/absence) non-continuous survey of the pearl mussel was carried out in the River Blackwater in September 2008 by Ecoserve, from approximately 6 km upstream to 6 km downstream of Mallow, Co. Cork. Mussels were found at 19 of the 38 examined locations. The mussel was found at every site examined upstream of Mallow town, in some places in relatively high density. Downstream of Mallow town, 42 Margaritifera was recorded from only one station. At a location along the north bank of the river adjacent of the Sugar Factory, an estimated density of up to individuals per m 2 was found beneath overhanging trees. The information from the surveys outlined above suggests that whilst pearl mussels still may be relatively widespread in the Blackwater, and there are still small localised areas with moderately high densities, the numbers have declined, and the population is composed entirely of aged adults with no evidence of recruitment for at least 20 years. From the information available to date and from the habitat conditions in the river, there is good evidence that the pearl mussel population has not reproduced sustainably since perhaps the 1950 s and is still extant only through the longevity of individuals that were born in the first half of the last century. The population is in decline due to depressed river quality from nutrient enrichment and siltation from agriculture, forestry, sewage and industry. It is very difficult to estimate numbers of mussels remaining in the river. While it is likely to be considerably less than 10,000, it may even be reduced to the 100 s. The prognosis for the population is very poor. Any measures towards the rehabilitation of juvenile mussel conditions are likely to be slow to achieve, there is a large body of sediment already within the river bed that could take decades to be removed. The timescale of measures are therefore longer than the timescale of survival of the remaining mussels in the wild. Brook lamprey (L. planeri) and River lamprey (L. fluviatilis): The river lamprey grows to 30cm and has a similar life history to the sea lamprey. The brook lamprey is the smallest of the three lampreys native to Ireland at 15 to 20cm. It is also the only one of the three which is non-parasitic and spends all its life in freshwater. Despite the difference in ecology, brook and river lamprey are very similar genetically and extremely difficult to distinguish from each other. Juvenile river and brook lampreys cannot be discriminated and metamorphosed individuals can only be distinguished on the basis of dentition (King et al., 2004). As a result, for the purposes of 50 EPA Export :23:03:55

87 Rev A Natura Impact Statement this assessment, the brook and river lampreys have been treated together. Both are species of qualifying interest for the Blackwater River (Cork/Waterford) SAC and the current known distribution for these species includes the 10km square within which the proposal considered in this document occurs. The current conservation status of these species in Ireland is considered to be good (NPWS, 2008). Salmon (S. salar): Atlantic salmon is a species of qualifying interest for the Blackwater River SAC. It is an anadromous species, living in freshwater for at least the first 2 or 3 years of life before migrating to sea. Relatively large cool rivers with extensive gravelly bottom headwaters are essential during their early life. Smolts migrate to sea where they may live for 1 or 2 years before returning to freshwater. A decline in Salmon stocks is well recognised in Ireland and throughout the range of the North Atlantic Salmon and is attributed to several factors including the salmon disease Ulcerative Dermal Necrosis (UDN), poor marine survival and some overfishing. The NPWS suggest that agricultural enrichment, forestry related pressures and poor water quality resulting from inadequate sewage treatment are the major pressures affecting Irish salmon rivers (NPWS 2007). The main channel of the River Blackwater is an important salmon fishery and it is a designated Salmonid Water under the EU Freshwater Fish Directive (78/659/EEC). In this respect, there is a legal obligation for the water quality of the river to meet the standards as set out in the EC Quality of Salmonid Regulations 1988 (SI 293/1988) Otter (Lutra lutra) The otter is a species of qualifying interest for the Blackwater River SAC and its overall conservation status is poor (NPWS, 2008). The SAC is considered one of the most important sites for otter in the country. The otter is widespread throughout the country, in freshwater and coastal habitats, and Ireland has long been considered to hold one of the most important otter populations in Western Europe (Whilde, 1993). Due to a decline in the population in Europe, including Ireland, the otter has been listed in Annex II of the EU Habitats Directive and Appendix II of the Berne Convention. It is also protected under the Wildlife Acts 1976 and It is listed in the Red Data Book (Whilde, 1993) as vulnerable. Otters can, potentially, exploit all stretches of a river system where they are present. A search of the NBDC online resource indicates that the most recent, adjacent, record retained for this species is a 2007 Road Kill Survey 12 record for a location on the N72 less than 1km west of the proposal site. This record confirms that otters are potentially present within the vicinity of the proposal. The two major threats facing otters in Europe are habitat destruction and water pollution (from NPWS, 2009) and the current conservation status for the species is considered Unfavourable- Inadequate (NPWS, 2008). In an Irish context the main four threats have been assessed to be direct and indirect habitat destruction, pollution (particularly organic pollution resulting in fish kills), 12 Available at: [accessed 7/06/2012] 51 EPA Export :23:03:55

88 Rev A Natura Impact Statement disturbance from increasing recreational activities and accidental death and persecution (Foster- Turley, et al., 1990). It is highly unlikely that otter use Linehans stream in the vicinity of the facility it due to its poor water quality and low suitability (see Section above) Killarney Fern (Trichomanes speciosum) On the basis of the habitat requirements of this species (see Section above) it is objectively concluded that this species is unlikely to be within the zone of impact influence of the proposal considered in this document. It is not expected that significant disturbance or displacement impacts on this species are reasonably foreseeable as a result of the proposal considered in this document, therefore it is not considered further in this assessment Habitats The Blackwater River SAC site has been designated for 10 Habitats Directive Annex I habitats, which are listed below, two of which are priority habitats, namely, alluvial wet woodlands and Yew wood numbers 9 and 10 below. 1. Estuaries [1130] 2. Mudflats and sandflats not covered by seawater at low tide [1140] 3. Perennial vegetation of stony banks [1220] 4. Salicornia and other annuals colonizing mud and sand [1310] 5. Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] 6. Mediterranean salt meadows (Juncetalia maritimi) [1410] 7. Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation [3260] 8. Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] 9. Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] 10. Taxus baccata woods of the British Isles [91J0] Coastal Habitats Habitat types 1 to 6, above, are categorised as Coastal and Halophytic (EDG, 2007) and are located a linear map distance of in excess of 50km from the location of the proposal site. Therefore, due to the attenuating distance these habitats are not considered further in this assessment Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation [3260 Habitat type 7, above, Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260], is a freshwater habitat found in sections of water courses with natural or semi-natural dynamics (minor, average and major beds) where the water quality shows no significant deterioration (EDG, 2007). Because floating river vegetation communities are found along much of the freshwater stretches within the site (see Site synopsis , Appendix 1) 52 EPA Export :23:03:55

89 Rev A Natura Impact Statement it is likely that this habitat is within the zone of impact influence of the proposal. The primary pressures on this habitat are considered to be eutrophication, overgrazing, excessive fertilisation, afforestation and the introduction of invasive alien species. The current conservation status of this habitat type is bad (NPWS, 2008) Forest Habitats Habitats 8, 9 and 10 are categorised as Forests (EDG, 2007) and their locations are described in the site synopsis (see Site Synopsis , Appendix 1). Old sessile oak woods with Ilex and Blechnum in British Isles [91A0]: Sessile oak (Quercus petraea) woodlands occur on acid soils mostly in upland areas through the country but especially in Wicklow and west Cork/south Kerry. This habitat is considered to be of bad overall conservation status (NPWS, 2008). The habitat type is found in several locations in the site, with the majority found in the area north of Youghal. Other locations include Lismore valley and the Owenshad and Glenmore river valleys all approximately 50km from the location of the proposal. 13 It is noted that the Owenshad and Glenmore rivers are tributary rivers of the Blackwater and therefore any habitats located in their river valleys are upstream of the main Blackwater River watercourse. It is considered near certain that this habitat does not occur within the zone of impact influence of the proposal and is therefore not considered further in this assessment. Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0]: Alluvial forests are typically woodland of alder (Alnus glutinosa) and ash (Fraxinus excelsior), of ten with willows (Salix sp.) and sometimes oak (Quercus robur). The habitats are subject to flooding along rivers and on lake shores. This habitat is considered to be of bad overall conservation status (NPWS, 2008). The habitat type is described as being concentrated, primarily, along the River Bride and in the Cappaquin/Youghal area. The towns of Cappoquin and Youghal are situated, respectively, approximately 53km and 60km from the location of the proposal and the River Bride is a tributary river which enters the Blackwater at a point 12km north of Youghal. Additional areas of this habitat type are found in the lower reaches of the Awbeg River another, separate, downstream, tributary which enters the Blackwater east of the village of Killavullen at a point approximately 16km downstream from the location of the proposal. As these locations are all situated upstream of the main Blackwater channel it is considered unlikely that this habitat does occur within the zone of impact influence of the proposal and is therefore not considered further in this assessment. 13 All linear distances referred to in Section 3.5 were measured using the Measurement Tools available at and the Draw and Measure tool available at [accessed 04/01/2012] 53 EPA Export :23:03:56

90 Rev A Natura Impact Statement Taxus baccata woods of the British Isles [91J0] Yew woodlands occur largely on outcrops of limestone and are dominated by yew (Taxus baccata) with occaisionla ash and a poorly developed shurb layer. The overall conservation assessment is considered bad (NPWS, 2008). A single location for this habitat is described at Villierstown, County Waterford approximately 53km from the location of the proposal. As this locations is at a significant remove from the proposal site it is considered unlikely that this habitat does occur within the zone of impact influence of the proposal and is therefore not considered further in this assessment. 3.5 Assessment of Potential Significant Impacts This section considers the ecological features selected for Natura Impact Assessment identified within the zone of impact influence in Section 3.4 above. The significance of the impacts affecting these sites identified in the previous section is assessed in terms of magnitude/extent, probability and duration in the following sections. The potential for significant impacts arising from the construction phase of the proposal was determined based on a number of indicators including: Habitat loss or alteration Disturbance or displacement of species Potential impairment of water quality and the consequent impacts on aquatic habitats and species Loss or Alteration of Habitat The Blackwater River SAC site has been designated for 10 Habitats Directive Annex I habitats, which are listed below, two of which are priority habitats, namely, alluvial wet woodlands and Yew wood. One habitat has been selected for assessment: Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation There will be no direct loss of designated habitats within the Blackwater River SAC. However, the construction phase of the proposal does require extensive construction work in an area adjoining a stream that drains to the Blackwater River. As a consequence, indirect habitat loss or alteration impacts caused either by the ingress of suspended solids or by water pollution impacts or by a combination of these impacts, could occur as a result of the unmitigated project within the Blackwater River SAC. Therefore, it cannot be objectively concluded that significant indirect impacts on the Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation habitat will not ensue from the current unmitigated construction phase. 54 EPA Export :23:03:56

91 Rev A Natura Impact Statement Disturbance of Displacement of Species Aquatic Fauna Freshwater pearl mussel (Margaritifera margaritifera) A significant concentration of freshwater pearl mussel occurs along the stretch of River Blackwater immediately south of the proposal site and therefore there is a significant risk to these species from the unmitigated proposal. There is also a risk of negative impact to this species because of its complex life cycle which includes a larval stage when they are dependent on salmonid fish hosts. It is possible that these salmonids could be in the impact zone of the development when they migrate further upstream. The main potential risk to the mussel posed by the proposed development is the threat of sedimentation and pollution of waterways during the construction phase of the proposal. Therefore, it cannot be objectively concluded that significant indirect impacts on the freshwater pearl mussel will not ensue from the current unmitigated construction phase. White-clawed crayfish (Austropotamobius pallipes) There is a risk that the water quality of the boundary stream adjacent to the location of the proposal, and of the Blackwater River SAC to which it drains, could be impaired during the construction stage of the proposal. It is possible that this could impact negatively on the whiteclawed crayfish. The main potential risk posed by the proposed development is the threat of sedimentation and pollution of waterways during the construction phase of the proposal. Therefore, it cannot be objectively concluded that significant indirect impacts on the white-clawed crayfish will not ensue from the current unmitigated construction phase. Sea lamprey (Petromyzon marinus) The main potential risk posed by the proposed development is the threat of sedimentation and pollution of waterways during the construction phase of the proposal. Therefore, it cannot be objectively concluded that significant indirect impacts on the sea lamprey will not ensue from the current unmitigated construction phase. Brook lamprey (Lampetra planeri) [1096] and River lamprey (Lampetra fluviatilis] There is a potential risk of a negative impact on these species from the construction. The main potential risk posed by the proposed development is the threat of sedimentation and pollution of waterways during the construction phase of the proposal. Therefore, it cannot be objectively concluded that significant indirect impacts on lamprey will not ensue from the current unmitigated construction phase. Salmon (Salmo salar) The main potential risk posed by the proposed development is the threat of sedimentation and pollution of waterways and consequent potential loss of spawning habitat during the construction phase. Therefore, it cannot be objectively concluded that significant indirect impacts on the salmon will not ensue from the current unmitigated construction phase. 55 EPA Export :23:03:56

92 Rev A Natura Impact Statement Otter (L. lutra) It is considered that the proposal considered in this document could potentially pose a risk of habitat degradation through sedimentation and/or pollution. This could impact the otter directly or indirectly through the reduced availability of prey. Therefore, it cannot be objectively concluded that significant indirect impacts on the otter will not ensue from the current unmitigated construction phase Water Quality As was noted previously, the footprint of the proposal is connected via the stream draining through the proposal site to the Blackwater River SAC. There is a possible risk of entry of pollutants to the adjacent stream during construction activities which could be transported to the Blackwater River SAC. In the event that ingress of pollutants should occur this could, potentially, cause loss of habitat due to sedimentation/siltation of spawning grounds. All aquatic qualifying interest species are vulnerable to any ingress of suspended solids or deleterious material with salmon and freshwater pearl mussel considered particularly vulnerable. In the absence of adequate control measures, contamination of the water course with suspended solids and or other pollutants may have the potential to impact on water quality or potential spawning and nursery areas for these and other species and this is the potentially significant impact of the proposal. Pollution of the local watercourse could result in a significant negative impact on Blackwater River SAC and could result from: 1. Pollution of watercourses with suspended solids due to run-off from excavations during construction. 2. Pollution of watercourses with nutrients adsorbed or chemically bound to eroded suspended solids released during excavation or demolition. 3. Pollution of watercourses with cementitious material from construction areas. 4. Pollution of watercourses with oils or fuels due to run-off from operating machinery or refuelling operations. In the absence of adequate mitigation measures, pollution of water courses from any of the above possible sources has the potential to impact on qualifying interests, aquatic species, otter and freshwater habitat within the Blackwater River SAC. This is the most significant potential impact of the proposed development. The impact, if it resulted in a severe pollution event, would be classified as a significant negative impact on the adjacent stream and on the Blackwater River SAC. A number of species of qualifying interest could be affected, particularly if spawning success of these species was negatively impacted. Additional impacts would occur, particularly to otter, should availability of prey be reduced. 56 EPA Export :23:03:56

93 Rev A Natura Impact Statement Summary of unmitigated impacts The potential significant impacts of the construction phase of the proposed development on aquatic ecology (without mitigation) are listed below. Table 14 below, summarises the potential significance of the unmitigated construction phase impacts of the proposal. Table 14. Summary of unmitigated construction phase impacts to conservation status of selected qualifying interests of the Blackwater River SAC Ecological Feature Potential impacts Potential significance of the unmitigated impact Possible decrease in habitat quality from sedimentation or pollution. Possible death of glochidia larvae. Freshwater pearl mussel (Margaritifera margaritifera) White-clawed crayfish (Austropotamobius pallipes) Sea lamprey (Petromyzon marinus) Brook lamprey (L. Planeri) and River lamprey (Lampetra fluviatilis) Atlantic salmon (Salmo salar) Otter (L. lutra) Possible decrease in abundance of parasitic salmonid hosts due to sedimentation or pollution of habitat. Possible decrease in habitat quality from sedimentation or pollution. Possible decrease in habitat quality from sedimentation or pollution. Possible decrease in habitat quality from sedimentation or pollution and reduction in spawning area. Possible decrease in habitat quality from sedimentation or pollution and reduction in spawning area. Possible decrease in habitat quality and/or prey availability from sedimentation or pollution. Significant Significant Significant Significant Significant Significant Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation / Impairment of water quality Possible decrease in water quality as a result of run-off of pollution. Significant In summary, the possible occurrence of potentially significant unmitigated impacts to the Blackwater River SAC cannot be ruled out during the construction phase of the redevelopment of the Dairygold facility. 57 EPA Export :23:03:56

94 Rev A Natura Impact Statement 3.6 Mitigation A number of mitigation measures have been incorporated into the project design in order to reduce the likely significance of the impacts on the Natura 2000 sites as outlined above. The main concern is the potential impacts on the water quality of watercourses within the Blackwater River SAC during the construction phase, and the subsequent impacts on the aquatic species of qualifying interest. In order to avoid or reduce the risks associated with these potential impacts, the following mitigation measures will be incorporated into the CEMP Water Quality Measures during the Construction Phase The main risk to the water quality of Linehans stream draining through the site (which in turn drains into the Blackwater River SAC) results from the potential of sedimentation of streams, run-off of pollutants from construction discharging into watercourses and accidental fuel spillages. These risks arise from both demolition and construction activities. It is noted that no in-stream works are proposed. A number of mitigation measures should be implemented in order to reduce the significance of the potential adverse impacts associated with the construction phase Protection of Watercourses (General Measures) It is recommended that the following measures should be incorporated into the development so as to ensure no significant negative impact on water course and the features of conservation interest: Raw or uncured waste concrete/ cementitious material should be disposed of by removal from the site. The amount of in-situ concreting required should be minimised and ready-mix suppliers should be used in preference to on-site batching. Fuelling and lubrication of equipment should be carried out in bunded areas. Any spillage of fuels, lubricants or hydraulic oils should be immediately contained and the contaminated soil removed from the site and properly disposed of. Oil booms and oil soakage pads should be kept on site to deal with any accidental spillage. Waste oils and hydraulic fluids should be collected in leak-proof containers and removed from the site for disposal or re-cycling. Prior to any work it should be ensured that all construction equipment is mechanically sound to avoid leaks of oil, fuel, hydraulic fluids and grease. Overnight parking of vehicles away from watercourses Run-off and Sediment Control Plan and Measures A Sediment and Erosion Control Plan should be designed to safeguard the water environment and incorporated into the CEMP and other surface water management measures employed during the construction phase of the proposal (see Section above). The main aspects of the plan are outlined hereunder: Reduce changes in run-off regimes Control surface water run-off within and its effects outside the site 58 EPA Export :23:03:56

95 Rev A Natura Impact Statement Protect aquatic environments Separate clean water from construction activity effected water Appropriately design and specify the provision of sediment series ponds and silt traps Prevent all sediment associated pollution entering watercourses and groundwater Erosion control where run-off is prevented from flowing across exposed ground and sediment control where run-off is slowed to allow suspended sediment to settle are important elements in run-off and sediment control. This plan should be implemented during construction to control increased run-off and associated suspended solid loads in discharging waters from the construction area. All site compound drainage should be passed through a settlement facility with the capacity to retain any accidental spillage or leakage of polluting substances. The main elements of this plan include: Prior to excavation, drains should be established to effectively drain grounds prior to earthworks. Such drains should be positioned at an oblique angle to slope contours to ensure ground stability. All site excavations and construction should be supervised by a suitably qualified engineer. The contractor s methodology statement should be reviewed and approved by a suitably qualified engineer prior to site operations. The existing stream will be considered during the development of the sediment and erosion plan and will be integrated into the plan. Run-off from foundation concrete / cementitious material pours shall not be permitted to enter the watercourse and shall be contained within the foundation excavations and designated areas that are suitably sited and designed. The area of exposed ground will be kept to a minimum by maintaining, where possible, existing vegetation. Temporary deposition areas will be designated and designed to hold temporary stockpiles of spoil. These will be located away from the stream and will have additional protection by silt trapping apparatus such as a geotextile silt fence to prevent contaminated run-off. Silt fences or other appropriate silt retention measure will be installed where there is a risk of erosion run-off to the stream from construction related activity, particularly during prolonged wet weather periods or an intense rainfall event. Check dams will be placed at regular intervals based on slope gradient along all drains to slow down run-off to encourage settlement and to reduce scour and ditch erosion. Drains carrying construction site run-off will be diverted into silt traps. Wheel washes will be provided in a bunded area at a remove from the stream. Pumped or tremied concrete / cementitious material will be monitored carefully to ensure no accidental discharge into the stream. A programme of inspection and maintenance of drainage and sediment control measures during construction will be designed and dedicated construction personnel assigned to manage this programme. 59 EPA Export :23:03:56

96 Rev A Natura Impact Statement Silt traps will be regularly inspected, any blockages cleared and they will be maintained and cleaned during dry weather. A continuous silt fence will be installed down slope from the works area but outside the leave strip/buffer area. This will act as a physical impediment to any material or run-off reaching the stream and will be installed prior to the commencement of site excavations as follows. Effective and adequate temporary silt fences should be erected on the river side buffer strip to trap sediment particles when work is taking place during a prolonged wet weather period or intense rainfall event. The silt fences will be inspected regularly to ensure that the integrity of the structure remains intact and fit for purpose throughout the construction phase of the proposal Fuel and Oil Management Plan An adequate fuel and oil management plan should be agreed with the civil contractor prior to commencement of construction and incorporated into the CEMP. This will outline measures to prevent fuel and oil from entering local watercourses and emergency procedures to deal with any accidental spillages. Refuelling of vehicles should take place in a designated area well away from aquatic zones and fuel oils must not, under any circumstances, discharge into an aquatic zone. The management of fuel on site will have regard to the following elements: No servicing or repair of plant, machinery or vehicles should be undertaken on site. Prior to any work it will be ensured that all construction equipment is mechanically sound to avoid leaks of oil, fuel, hydraulic fluids and grease. Mobile bowsers, tanks and drums will be stored in secure, impermeable storage area, away from drains and open water. Bunds will be designed with a capacity of 110% of the storage tanks it protects. Fuel containers must be stored within a secondary containment system e.g. bund for static tanks or a drip tray for mobile stores. Ancillary equipment such as hoses, pipes must be contained within the bund. Taps, nozzles or valves must be fitted with a lock system. Fuel and oil stores including tanks and drums will be regularly inspected for leaks and signs of damage. All plant and machinery e.g. excavators, dumpers to be refuelled a minimum of 50m from watercourses. Only designated trained operators will be authorised to refuel plant on site and emergency spill kits will be present at equipment for all refuelling events. Procedures and contingency plans will be set up to deal with an emergency accidents or spills. An emergency spill kit with oil boom, absorbers etc. will be kept on site in the event of an accidental spill. 60 EPA Export :23:03:56

97 Rev A Natura Impact Statement Truck Wash and Concrete / Cementitious Material Residue It is important to prevent concrete and other cementitious material from entering the stream situated in close proximity to the site. It is recommended that a designated bunded and impermeable truck wash area be provided. Resultant waste water is to be diverted to siltation pond for settling out of solids, prior to release. It is important that a pumping / dewatering system is well planned. Pumped water will need to be treated in the adequate settlement pond and silt trap before it can enter the stream. Among other things, concrete and other cementitious material will be used for the construction and the following measures should be implemented: Designate a concrete / cementitious material washout area away from drains and watercourses at a designated, contained impermeable area or washout trucks off-site. A designated trained operator experienced in working with concrete and other cementitious material will be employed during the pouring phase. Large volumes of concrete and other cementitious material water to be pumped into a skip to settle out. Wash down water from exposed aggregate surfaces, cast-in-place concrete and from concrete trucks should be trapped on-site to allow sediment to settle out and reach neutral ph before clarified water is released to any stream or drain system or allowed to percolate into the ground. Settled solids will need to be appropriately disposed off site Waste Control The main contractor should engage a waste company to deal with all its wastes during construction, so all waste streams are identified at the outset and a selection of skips and bins are delivered to the contractor s compound at the outset and the waste is then managed throughout the construction phase. The contractor should prepare a Waste Management Plan. Sufficient waste storage should be supplied near to all working areas Storage The storage of materials, containers, stockpiles and waste, however temporary, should follow best practice at all times and be stored at designated areas. Storage should be located as follows: Away from drains and any watercourses or drains Fuel oils etc. should be stored on a sheltered dry elevated site well removed from aquatic zones On an impermeable base Under cover to prevent damage from the elements In secure areas Well away from moving plant, machinery and vehicles On land not required until later in the development 61 EPA Export :23:03:56

98 Rev A Natura Impact Statement All containers should be stored upright and clearly labelled. Sufficient storage should be supplied near to all working areas Summary of Residual Mitigated Impacts Table 15 below includes an assessment of the likely residual impacts of the proposal provided that all management mitigation measures outlined above are adequately implemented. Table 15. Summary of construction phase residual / mitigated impacts of the proposal on the Blackwater River SAC Ecological Feature(s) / Impact Freshwater pearl mussel (Margaritifera margaritifera) / Impairment of water quality White-clawed crayfish (Austropotamobius pallipes) / Impairment of water quality Sea lamprey (Petromyzon marinus) / Impairment of water quality River lamprey (Lampetra fluviatilis) and brook lamprey (L. Planeri) / Impairment of water quality Atlantic salmon (Salmo salar) Impairment of water quality Otter (Lutra lutra) / Impairment of water quality Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation / Impairment of water quality Potential significance of the unmitigated impact Significant Significant Significant Significant Significant Significant Summary of Mitigation Measures Protection of water quality (general) Run-off and Sediment Control Plan and Measures Fuel and Oil Management Plan Truck Wash and Concrete / Cementitious Material Residue Waste Control Storage Significant Potential significance of the mitigated Not significant Not significant Not significant Not significant Not significant Not significant Not significant 3.7 Cumulative Impacts The residual impact of the proposed redevelopment of the Dairygold facility is not expected to have a significant impact on the conservation objectives of the Blackwater River SAC. Potential exists for cumulative impacts from the following: Mallow WWTP Other IPPC Licensed Sites Agriculture Forestry 62 EPA Export :23:03:56

99 Rev A Natura Impact Statement During the determination of the Dairygold IPPC licence, the EPA undertook an assimilative capacity of the discharges to the Blackwater River from the facility and considered the in-combination effects of other point and diffuse pollution source. In the most recent review of the IPPC licence, the EPA undertook a mass balance calculation assessment of the background concentrations (upstream water quality) and the discharges from the facility and determined the assimilative capacity of the river. They concluded that suspended solids, BOD and Ortho-P loading from the facility, at current emission values, was not significant but a reduction in Total Ammonia was required in order to comply with the Surface Water Regulations (S.I. No. 272 of 2009) and a stricter limit was applied from January Based on the EPAs assimilative capacity assessment, and the new stricter limits on Total Ammonia, of the River Blackwater, it is considered that the proposal will not have a significant impact on the qualifying interests of the Blackwater SAC. 4 Conclusion In conclusion, it is not expected that significant impacts to the Blackwater River SAC will occur as a result of the redevelopment of the Dairygold facility at Mallow. 63 EPA Export :23:03:56

100 Rev A Natura Impact Statement 4.1 References Anon, (2010). Freshwater Pearl Mussel Second Draft Munster Blackwater Sub-Basin Management Plan. (Produced by NS 2; Funded by Department of the Environment, Heritage and Local Government (DoEHLG) BirdLife International (2012a) Species factsheet: Cygnus cygnus. Downloaded from on 12/06/2012. BirdLife International (2012b) Species factsheet: Pluvialis squatarola. Downloaded from on 13/06/2012. Blamey, M., Fitter, R. & Fitter, A. (2003). Wild Flowers of Britain and Ireland. London: A & C BlackPublishers Ltd Byrne, A., Moorkens, E.A., Anderson, R., Killeen, I.J. & Regan, E.C. (2009) Ireland Red List No. 2 Non- Marine Molluscs. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland. Department of the Environment, Heritage and Local Government (DoEHLG) (2009). Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of Environment, Heritage and Local Government. EC (2000). Managing Natura 2000 Sites: The provision of Article 6 of the Habitats Directive 92/43/EEC. Luxembourg: Office for Official Publications of the European Communities, 2000 EC (2001). Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. Luxembourg: Office for Official Publications of the European Communities. Environment Directorate General (EDG) (2007). Interpretation Manual of European Union Habitats, European Commission, Brussels. EPA, Guidelines on information to be contained in Environmental Impact Statements. Published by the Environmental Protection Agency, Ireland. Fossitt, J. A. (2000) A Guide to Habitats in Ireland. Kilkenny: The Heritage Council. Foster-Turley, P., Macdonald, S.M. & Mason, C.F. (1990). Otters: an action plan for their conservation. Gland, Switzerland: International Union for the Conservation of Nature and Nature Resources/Species Survival Commission/Otter Specialist Group. Franklin, Alan B., Noon, Barry R. & Luke George T., (2002), What is Habitat Fragmentation?, Studies in Avian Biology No. 25: IEEM (2006). Guidelines for Ecological Impact Assessment in the United Kingdom. Institute for Ecology and Environmental Management. Kilfeather, P. (2000) Fisheries and the aquatic environment. In: Forests and water. Eds: E Hendrick 64 EPA Export :23:03:56

101 Rev A Natura Impact Statement & L. MacLennan. Proceeding of a Coford Seminar, 15 November King J. J. and Linnane S. M. (2004) The status and distribution of lamprey and shad in the Slaney and Munster Blackwater SACs. Irish Wildlife Manuals, No. 14. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland. NPWS (2007) Atlantic salmon (Salmo salar L.) (1106) Conservation Status Assessment Report. National Parks & Wildlife Service. National Parks and Wildlife Service (NPWS), (2008). The Status of EU Protected Habitats and Species in Ireland. Conservation Status in Ireland of Habitats and Species listed in the European Council Directive on the Conservation of Habitats, Flora and Fauna 92/43/EEC, Department of the Environment, Heritage and Local Government. National Parks and Wildlife Service (NPWS) (2011) Dundalk Bay Special Protection Area (Site Code 4026) Conservation Objectives Supporting Document VERSION 1 (Available at: ent_v1-1.pdf [accessed: 11/07/2012]) NRA (2009). Guidelines for Assessment of Ecological Impacts of National Road Schemes. National Roads Authority. Peay, S. (2003). Guidance on habitats for white-clawed crayfish. R&D Technical report WI-067/TR, Bristol: Environment Agency. In: Reynolds, J. D. (2007). Conservation Assessment of the White- Clawed Crayfish Austropotamobius Pallipes (Lereboullet, 1858) in Ireland. Report to National Parks and Wildlife Service. Reynolds, J. D. (2007). Conservation Assessment of the White-Clawed Crayfish, Austropotamobius Pallipes, (Lereboullet, 1858) in Ireland. Report to National Parks and Wildlife Service. Webb, D.A., Parnell,J. & Doogue, D., (1996), An Irish Flora, Dundalgan Press (W.Tempest) Ltd., Dundalk. Whilde, A., (1993) Threatened Mammals, Birds, Amphibians and Fish in Ireland Irish Red Data Book 2: Vertebrates. HMSO, Belfast. 65 EPA Export :23:03:56

102 Rev A Natura Impact Statement Appendix 1 Site Summaries EPA Export :23:03:56

103 SITE SYNOPSIS SITE NAME: BLACKWATER RIVER (CORK/WATERFORD) SITE CODE: The River Blackwater is one of the largest rivers in Ireland, draining a major part of Co. Cork and five ranges of mountains. In times of heavy rainfall the levels can fluctuate widely by more than 12 feet on the gauge at Careysville. The peaty nature of the terrain in the upper reaches and of some of the tributaries gives the water a pronounced dark colour. The site consists of the freshwater stretches of the River Blackwater as far upstream as Ballydesmond, the tidal stretches as far as Youghal Harbour and many tributaries, the larger of which includes the Licky, Bride, Flesk, Chimneyfield, Finisk, Araglin, Awbeg (Buttevant), Clyda, Glen, Allow, Dalua, Brogeen, Rathcool, Finnow, Owentaraglin and Awnaskirtaun. The extent of the Blackwater and its tributaries in this site, flows through the counties of Kerry, Cork, Limerick, Tipperary and Waterford. Towns along, but not in the site, include Rathmore, Millstreet, Kanturk, Banteer, Mallow, Buttevant, Doneraile, Castletownroche, Fermoy, Ballyduff, Rathcormac, Tallow, Lismore, Cappoquin and Youghal. The Blackwater rises in boggy land of east Kerry, where Namurian grits and shales build the low heather-covered plateaux. Near Kanturk the plateaux enclose a basin of productive Coal Measures. On leaving the Namurian rocks the Blackwater turns eastwards along the northern slopes of the Boggeraghs before entering the narrow limestone strike vale at Mallow. The valley deepens as first the Nagles Mountains and then the Knockmealdowns impinge upon it. Interesting geological features along this stretch of the Blackwater Valley include limestone cliffs and caves near the villages and small towns of Killavullen and Ballyhooly; the Killavullen caves contain fossil material from the end of the glacial period. The associated basic soils in this area support the growth of plant communities which are rare in Cork because in general the county s rocks are acidic. At Cappoquin the river suddenly turns south and cuts through high ridges of Old Red Sandstone. The Araglin valley is predominantly underlain by sandstone, with limestone occurring in the lower reaches near Fermoy. The site is a candidate SAC selected for alluvial wet woodlands and Yew wood, both priority habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected as a candidate SAC for floating river vegetation, estuaries, tidal mudflats, Salicornia mudflats, Atlantic salt meadows, Mediterranean salt meadows, perennial vegetation of stony banks and old Oak woodlands, all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive - Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Crayfish, Twaite Shad, Atlantic Salmon, Otter and the Killarney Fern. EPA Export :23:03:56

104 Wet woodlands are found where river embankments, particularly on the River Bride, have broken down and where the channel edges in the steep-sided valley between Cappoquin and Youghal are subject to daily inundation. The river side of the embankments was often used for willow growing in the past (most recently at Cappoquin) so that the channel is lined by narrow woods of White and Almondleaved Willow (Salix alba and S. triandra) with isolated Crack Willow (S. fragilis) and Osier (S. viminalis). Grey Willow (S. cinerea) spreads naturally into the sites and occasionally, as at Villierstown on the Blackwater and Sapperton on the Bride, forms woods with a distinctive mix of woodland and marsh plants, including Gypsywort (Lycopus europaeus), Guelder Rose (Viburnum opulus), Bittersweet (Solanum dulcamara) and various mosses and algae. These wet woodlands form one of the most extensive tracts of the wet woodland habitat in the country. A small stand of Yew (Taxus baccata) woodland, a rare habitat in Ireland and the EU, occurs within the site. This is on a limestone ridge at Dromana, near Villierstown. While there are some patches of the wood with a canopy of Yew and some very old trees, the quality is generally poor due to the dominance of non-native and invasive species such as Sycamore, Beech and Douglas Fir (Pseudotsuga menzsisii). However, the future prospect for this Yew wood is good as the site is proposed for restoration under a Coillte EU Life Programme. Owing to its rarity, Yew woodland is listed with priority status on Annex I of the EU Habitats Directive. Marshes and reedbeds cover most of the flat areas beside the rivers and often occur in mosaic with the wet woodland. Common Reed (Phragmites australis) is ubiquitous and is harvested for thatching. There is also much Marsh Marigold (Caltha palustris) and, at the edges of the reeds, the Greater and Lesser Pond-sedge (Carex riparia and C. acutiformis). Hemlock Water-dropwort (Oenanthe crocata), Wild Angelica (Angelica sylvestris), Reed Canary-grass (Phalaris arundinacea), Meadowsweet (Filipendula ulmaria), Nettle (Urtica dioica), Purple Loosestrife (Lythrum salicaria), Marsh Valerian (Valeriana officinalis), Water Mint (Mentha aquatica) and Water Forget-me-not (Myosotis scorpioides). At Banteer there are a number of hollows in the sediments of the floodplain where subsidence and subterranean drainage have created isolated wetlands, sunk below the level of the surrounding fields. The water rises and falls in these holes depending on the watertable and several different communities have developed on the acidic or neutral sediments. Many of the ponds are ringed about with Grey Willows, rooted in the mineral soils but sometimes collapsed into the water. Beneath the densest stands are woodland herbs like Yellow Pimpernel (Lysimachia nemorum) with locally abundant Starwort (Callitriche stagnalis) and Marsh Ragwort (Senecio palustris). One of the depressions has Silver Birch (Betula pendula), Ash (Fraxinus excelsior), Crab Apple (Malus sylvestris) and a little Oak (Quercus robur) in addition to the willows. Floating river vegetation is found along much of the freshwater stretches within the site. The species list is quite extensive and includes Pond Water-crowfoot (Ranunculus peltatus), Water-crowfoot (Ranunculus spp.), Canadian Pondweed (Elodea canadensis), Broad-leaved Pondweed (Potamogeton natans), Pondweed (Potamogeton spp.), Water Milfoil (Myriophyllum spp.), Common Club-rush (Scirpus EPA Export :23:03:56

105 lacustris), Water-starwort (Callitriche spp.), Lesser Water-parsnip (Berula erecta) particularly on the Awbeg, Water-cress (Nasturtium officinale), Hemlock Waterdropwort, Fine-leaved Water-dropwort (O. aquatica), Common Duckweed (Lemna minor), Yellow Water-lily (Nuphar lutea), Unbranched Bur-reed (Sparganium emersum) and the moss Fontinalis antipyretica. The grassland adjacent to the rivers of the site is generally heavily improved, although liable to flooding in many places. However, fields of more species-rich wet grassland with species such as Yellow-flag (Iris pseudacorus), Meadow-sweet, Meadow Buttercup (Ranunculus acris) and rushes (Juncus spp.) occur occasionally. Extensive fields of wet grassland also occur at Annagh Bog on the Awbeg. These fields are dominated by Tufted Hair-grass (Deschampsia cespitosa) and rushes. The Blackwater Valley has a number of dry woodlands; these have mostly been managed by the estates in which they occur, frequently with the introduction of Beech (Fagus sylvatica) and a few conifers, and sometimes of Rhododendron (Rhododendron ponticum) and Laurel. Oak woodland is well developed on sandstone about Ballinatray, with the acid Oak woodland community of Holly (Ilex aquifolium), Bilberry (Vaccinium myrtillus), Greater Woodrush (Luzula sylvatica) and Buckler Ferns (Dryopteris affinis, D. aemula) occurring in one place. Irish Spurge (Euphorbia hyberna) continues eastwards on acid rocks from its headquarters to the west but there are many plants of richer soils, for example Wood Violet (Viola reichenbachiana), Goldilocks (Ranunculus auricomus), Broad-leaved Helleborine (Epipactis helleborine) and Red Campion (Silene dioica). Oak woodland is also found in Rincrew, Carrigane, Glendine, Newport and Dromana. The spread of Rhododendron is locally a problem, as is over-grazing. A few limestone rocks stand over the river in places showing traces of a less acidic woodland type with Ash, False Brome (Brachypodium sylvaticum) and Early-purple Orchid (Orchis mascula). In the vicinity of Lismore, two deep valleys cut in Old Red Sandstone join to form the Owenashad River before flowing into the Blackwater at Lismore. These valleys retain something close to their original cover of Oak with Downy Birch (Betula pubescens), Holly and Hazel (Corylus avellana) also occurring. There has been much planting of Beech (as well as some of coniferous species) among the Oak on the shallower slopes and here both Rhododendron and Cherry Laurel (Prunus laurocerasus) have invaded the woodland. The Oak wood community in the Lismore and Glenmore valleys is of the classical upland type, in which some Rowan (Sorbus aucuparia) and Downy Birch occur. Honeysuckle (Lonicera periclymenum) and Ivy (Hedera helix) cover many of the trees while Greater Woodrush, Bluebell (Hyacinthoides non-scripta), Wood Sorrel (Oxalis acetosella) and, locally, Bilberry dominate the ground flora. Ferns present on the site include Hard Fern (Blechnum spicant), Male Fern (Dryopteris filix-mas), Buckler Ferns (D. dilatata, D. aemula) and Lady Fern (Athyrium felix-femina). There are many mosses present and large species such as Rhytidiadelphus spp., Polytrichum formosum, Mnium hornum and Dicranum spp. are noticeable. The lichen flora is important and includes 'old forest' species which imply a continuity of woodland here since ancient times. Tree Lungwort (Lobaria spp.) is the most conspicuous and is widespread. EPA Export :23:03:56

106 The Araglin valley consists predominantly of broadleaved woodland. Oak and Beech are joined by Hazel, Wild Cherry (Prunus avium) and Goat Willow (Salix caprea). The ground flora is relatively rich with Pignut (Conopodium majus), Wild Garlic (Allium ursinum), Garlic Mustard (Alliaria petiolata) and Wild Strawberry (Fragaria vesca). The presence of Ivy Broomrape (Orobanche hederae), a local species within Ireland, suggests that the woodland, along with its attendant Ivy is long established. Along the lower reaches of the Awbeg River, the valley sides are generally cloaked with mixed deciduous woodland of estate origin. The dominant species is Beech, although a range of other species are also present, e.g. Sycamore (Acer pseudoplatanus), Ash and Horse-chestnut (Aesculus hippocastanum). In places the alien invasive species, Cherry Laurel, dominates the understorey. Parts of the woodlands are more semi-natural in composition, being dominated by Ash with Hawthorn (Crataegus monogyna) and Spindle (Euonymus europaea) also present. However, the most natural areas of woodland appear to be the wet areas dominated by Alder and willows (Salix spp.). The ground flora of the dry woodland areas features species such as Pignut, Wood Avens (Geum urbanum), Ivy and Soft Shield-fern (Polystichum setiferum), while the ground flora of the wet woodland areas contains characteristic species such as Remote Sedge (Carex remota) and Opposite-leaved Golden-saxifrage (Chrysosplenium oppositifolium). In places along the upper Bride, scrubby, semi-natural deciduous woodland of Willow, Oak and Rowan occurs with abundant Great Woodrush in the ground flora. The Bunaglanna River passes down a very steep valley, flowing in a north-south direction to meet the Bride River. It flows through blanket bog to heath and then scattered woodland. The higher levels of moisture here enable a vigorous moss and fern community to flourish, along with a well-developed epiphyte community on the tree trunks and branches. At Banteer a type of wetland occurs near the railway line which offers a complete contrast to the others. Old turf banks are colonised by Royal Fern (Osmunda regalis) and Eared Willow (Salix aurita) and between them there is a sheet of Bottle Sedge (Carex rostrata), Marsh Cinquefoil (Potentilla palustris), Bogbean (Menyanthes trifoliata), Marsh St. John's-wort (Hypericum elodes) and the mosses Sphagnum auriculatum and Aulacomnium palustre. The cover is a scraw with characteristic species like Marsh Willowherb (Epilobium palustre) and Marsh Orchid (Dactylorhiza incarnata). The soil high up the Lismore valleys and in rocky places is poor in nutrients but it becomes richer where streams enter and also along the valley bottoms. In such sites Wood Speedwell (Veronica montana), Wood Anemone (Anemone nemorosa), Enchanter's Nightshade (Circaea lutetiana), Barren Strawberry (Potentilla sterilis) and Shield Fern occur. There is some Wild Garlic, Three-nerved Sandwort (Moehringia trinervia) and Early-purple Orchid (Orchis mascula) locally, with Opposite-leaved Golden-saxifrage, Meadowsweet and Bugle in wet places. A Hazel stand at the base of the Glenakeeffe valley shows this community well. EPA Export :23:03:56

107 The area has been subject to much tree felling in the recent past and re-sprouting stumps have given rise to areas of bushy Hazel, Holly, Rusty Willow (Salix cinerea subsp. oleifoila) and Downy Birch. The ground in the clearings is heathy with Heather (Calluna vulgaris), Slender St John's-wort (Hypericum pulchrum) and the occasional Broom (Cytisus scoparius) occurring. The estuary and the other Habitats Directive Annex I habitats within it form a large component of the site. Very extensive areas of intertidal flats, comprised of substrates ranging from fine, silty mud to coarse sand with pebbles/stones are present. The main expanses occur at the southern end of the site with the best examples at Kinsalebeg in Co. Waterford and between Youghal and the main bridge north of it across the river in Co. Cork. Other areas occur along the tributaries of the Licky in east Co. Waterford and Glendine, Newport, Bride and Killahaly Rivers in Waterford west of the Blackwater and large tracts along the Tourig River in Co. Cork. There are narrow bands of intertidal flats along the main river as far north as Camphire Island. Patches of green algae (filamentous, Ulva species and Enteromorpha sp.) occur in places, while fucoid algae are common on the more stony flats even as high upstream as Glenassy or Coneen. The area of saltmarsh within the site is small. The best examples occur at the mouths of the tributaries and in the townlands of Foxhole and Blackbog. Those found are generally characteristic of Atlantic salt meadows. The species list at Foxhole consists of Common Saltmarsh-grass (Puccinellia maritima), small amounts of Greater Seaspurrey (Spergularia media), Glasswort (Salicornia sp.), Sea Arrowgrass (Triglochin maritima), Annual Sea-blite (Suaeda maritima) and Sea Purslane (Halimione portulacoides) - the latter a very recent coloniser - at the edges. Some Sea Aster (Aster tripolium) occurs, generally with Creeping Bent (Agrostis stolonifera). Sea Couch-grass (Elymus pycnanthus) and small isolated clumps of Sea Club-rush (Scirpus maritimus) are also seen. On the Tourig River additional saltmarsh species found include Lavender (Limoniun spp.), Sea Thrift (Armeria maritima), Red Fescue (Festuca rubra), Common Scurvy-grass (Cochlearia officinalis) and Sea Plantain (Plantago maritima). Oraches (Atriplex spp.) are found on channel edges. The shingle spit at Ferrypoint supports a good example of perennial vegetation of stony banks. The spit is composed of small stones and cobbles and has a well developed and diverse flora. At the lowest part, Sea Beet (Beta vulgaris), Curled Dock (Rumex crispus) and Yellow-horned Poppy (Glaucium flavum) occur with at a slightly higher level Sea Mayweed (Tripleurospermum maritimum), Cleavers (Galium aparine), Rock Samphire (Crithmum maritimum), Sandwort (Honkenya peploides), Spear-leaved Orache (Atriplex prostrata) and Babington s Orache (A. glabriuscula). Other species present include Sea Rocket (Cakile maritima), Herb Robert (Geranium robertianum), Red Fescue (Festuca rubra) and Kidney Vetch (Anthyllis vulneraria). The top of the spit is more vegetated and includes lichens and bryophytes (including Tortula ruraliformis and Rhytidiadelphus squarrosus). The site supports several Red Data Book plant species, i.e. Starved Wood Sedge (Carex depauperata), Killarney Fern (Trichomanes speciosum), Pennyroyal (Mentha pulegium), Bird s-nest Orchid (Neottia nidus-avis, Golden Dock (Rumex maritimus) and Bird Cherry (Prunus padus). The first three of these are also protected under the EPA Export :23:03:56

108 Flora (Protection) Order The following plants, relatively rare nationally, are also found within the site: Toothwort (Lathraea squamaria) associated with woodlands on the Awbeg and Blackwater; Summer Snowflake (Leucojum aestivum) and Flowering Rush (Butomus umbellatus) on the Blackwater; Common Calamint (Calamintha ascendens), Red Campion (Silene dioica), Sand Leek (Allium scorodoprasum) and Wood Club-rush (Scirpus sylvaticus) on the Awbeg. The site is also important for the presence of several Habitats Directive Annex II animal species, including Sea Lamprey (Petromyzon marinus), Brook Lamprey (Lampetra planeri), River Lamprey (L. fluviatilis), Twaite Shad (Alosa fallax fallax), Freshwater Pearl-mussel (Margaritifera margaritifera), Otter (Lutra lutra) and Salmon (Salmo salar). The Awbeg supports a population of White-clawed Crayfish (Austropotamobius pallipes). This threatened species has been recorded from a number of locations and its remains are also frequently found in Otter spraints, particularly in the lower reaches of the river. The freshwater stretches of the Blackwater and Bride Rivers are designated salmonid rivers. The Blackwater is noted for its enormous run of salmon over the years. The river is characterised by mighty pools, lovely streams, glides and generally, a good push of water coming through except in very low water. Spring salmon fishing can be carried out as far upstream as Fermoy and is very highly regarded especially at Careysville. The Bride, main Blackwater upstream of Fermoy and some of the tributaries are more associated with grilse fishing. The site supports many of the mammal species occurring in Ireland. Those which are listed in the Irish Red Data Book include Pine Marten, Badger and Irish Hare. The bat species Natterer s Bat, Daubenton s Bat, Whiskered Bat, Brown Long-eared Bat and Pipistrelle, are to be seen feeding along the river, roosting under the old bridges and in old buildings. Common Frog, a Red Data Book species that is also legally protected (Wildlife Act, 1976), occurs throughout the site. The rare bush cricket, Metrioptera roselii (Orthoptera: Tettigoniidae), has been recorded in the reed/willow vegetation of the river embankment on the Lower Blackwater River. The Swan Mussel (Anodonta cygnea), a scarce species nationally, occurs at a few sites along the freshwater stretches of the Blackwater. Several bird species listed on Annex I of the E.U. Birds Directive are found on the site. Some use it as a staging area, others are vagrants, while others use it more regularly. Internationally important numbers of Whooper Swan (average peak 174, 1994/95-95/96) and nationally important numbers Bewick's Swan (average peak 5, 1996/ /01) use the Blackwater Callows. Golden Plover occur in regionally important numbers on the Blackwater Estuary (average peak 885, 1984/85-86/87) and on the River Bride (absolute max. 2141, 1994/95). Staging Terns visit the site annually (Sandwich Tern (>300) and Arctic/Common Tern (>200), average peak ). The site also supports populations of the following: Red Throated Diver, Great Northern Diver, Barnacle Goose, Ruff, Wood Sandpiper and Greenland Whitefronted Goose. Three breeding territories for Peregrine Falcon are known along the Blackwater Valley. This, the Awbeg and the Bride River are also thought to support EPA Export :23:03:56

109 at least 30 pairs of Kingfisher. Little Egret now breed at the site (12 pairs in 1997, 19 pairs in 1998) and this represents about 90% of the breeding population in Ireland. The site holds important numbers of wintering waterfowl. Both the Blackwater Callows and the Blackwater Estuary Special Protection Areas (SPAs) hold internationally important numbers of Black-tailed Godwit (average peak 847, 1994/95-95/96 on the callows, average peak 845, 1974/75-93/94 in the estuary). The Blackwater Callows also hold Wigeon (average peak 2752), Teal (average peak 1316), Mallard (average peak 427), Shoveler (average peak 28), Lapwing (average peak 880), Curlew (average peak 416) and Black-headed Gull (average peak 396) (counts from 1994/95-95/96). Numbers of birds using the Blackwater Estuary, given as the mean of the highest monthly maxima over 20 years ( ), are Shelduck ( breeding pairs), Wigeon (780), Teal (280), Mallard ( breeding pairs), Goldeneye (11-97), Oystercatcher (340), Ringed Plover ( breeding pairs), Grey Plover (36), Lapwing (1680), Knot (150), Dunlin (2293), Snipe (272), Black-tailed Godwit (845), Bar-tailed Godwit (130), Curlew (920), Redshank (340), Turnstone (130), Black-headed Gull (4000) and Lesser Black-backed Gull (172). The greatest numbers (75%) of the wintering waterfowl of the estuary are located in the Kinsalebeg area on the east of the estuary in Co. Waterford. The remainder are concentrated along the Tourig Estuary on the Co. Cork side. The river and river margins also support many Heron, non-breeding Cormorant and Mute Swan (average peak 53, 1994/95-95/96 in the Blackwater Callows). Heron occurs all along the Bride and Blackwater Rivers - 2 or 3 pairs at Dromana Rock; c. 25 pairs in the woodland opposite; 8 pairs at Ardsallagh Wood and c. 20 pairs at Rincrew Wood have been recorded. Some of these are quite large and significant heronries. Significant numbers of Cormorant are found north of the bridge at Youghal and there are some important roosts present at Ardsallagh Wood, downstream of Strancally Castle and at the mouth of the Newport River. Of note are the high numbers of wintering Pochard (e.g. 275 individuals in 1997) found at Ballyhay quarry on the Awbeg, the best site for Pochard in County Cork. Other important species found within the site include Long-eared Owl, which occurs all along the Blackwater River, and Barn Owl, a Red Data Book species, which is found in some old buildings and in Castlehyde west of Fermoy. Reed Warbler, a scarce breeding species in Ireland, was found for the first time in the site in 1998 at two locations. It is not known whether or not this species breeds on the site, although it is known to nearby to the south of Youghal. Dipper occurs on the rivers. Landuse at the site is mainly centred on agricultural activities. The banks of much of the site and the callows, which extend almost from Fermoy to Cappoquin, are dominated by improved grasslands which are drained and heavily fertilised. These areas are grazed and used for silage production. Slurry is spread over much of this area. Arable crops are grown. The spreading of slurry and fertiliser poses a threat to the water quality of this salmonid river and to the populations of Habitats Directive Annex II animal species within it. Many of the woodlands along the rivers belong to old estates and support many non-native species. Little active woodland management occurs. Fishing is a main tourist attraction along stretches of the Blackwater and its tributaries and there are a number of Angler Associations, some with a number of EPA Export :23:03:56

110 beats. Fishing stands and styles have been erected in places. Both commercial and leisure fishing takes place on the rivers. Other recreational activities such as boating, golfing and walking are also popular. Water skiing is carried out at Villierstown. Parts of Doneraile Park and Anne s Grove are included in the site: both areas are primarily managed for amenity purposes. There is some hunting of game birds and Mink within the site. Ballyhay quarry is still actively quarried for sand and gravel. Several industrial developments, which discharge into the river, border the site. The main threats to the site and current damaging activities include high inputs of nutrients into the river system from agricultural run-off and several sewage plants, dredging of the upper reaches of the Awbeg, overgrazing within the woodland areas, and invasion by non-native species, for example Cherry Laurel. Overall, the River Blackwater is of considerable conservation significance for the occurrence of good examples of habitats and of populations of plant and animal species that are listed on Annexes I and II of the E.U. Habitats Directive respectively; furthermore it is of high conservation value for the populations of bird species that use it. Two Special Protection Areas, designated under the E.U. Birds Directive, are also located within the site - Blackwater Callows and Blackwater Estuary. Additionally, the importance of the site is enhanced by the presence of a suite of uncommon plant species EPA Export :23:03:56

111 SITE SYNOPSIS SITE NAME: KILCOLMAN BOG SPA SITE CODE: Kilcolman Bog is situated on the southern foothills of the Ballyhoura Mountains in Co. Cork. It occupies a glacially eroded hollow in Carboniferous limestone. The site comprises a quaking fen fed by calcareous groundwater, with areas of reed swamp, freshwater marsh and wet grassland. The reed swamp is made up of Bottle Sedge (Carex rostrata) and Water Horsetail (Equisetum fluviatile) with some Bulrush (Typha latifolia). This grades into stands of Bogbean (Menyanthes trifoliata) and Marsh Cinquefoil (Potentilla palustris) with many associated species including Ragged-Robin (Lychnis flos-cuculi), Marsh Willowherb (Epilobium palustre) and Greater Spearwort (Ranunculus lingua). There is a small permanent lake but in winter a large flooded area is usual. The surrounding landuse is mostly intensive agriculture. Kilcolman Bog is an important site for wintering waterfowl, with nationally important populations of Whooper Swan (136), Teal (1,060) and Shoveler (201) - figures are average peaks for 5 year period 1995/ /00. The Shoveler population is of particular note as it comprises over 6% of the national total. Other species with important populations include Wigeon (850), Pochard (52), Tufted Duck (38), Coot (146), Lapwing (1,000) and Golden Plover (194), while Mallard (256), Little Grebe (19) and Pintail (7) also occur. The site formerly supported a small Greenland Whitefronted Goose population but this has since died out. Gulls are also winter visitors, mainly Black-headed Gull (220) and Lesser Black-backed Gull (131). Breeding birds include Little Grebe, Mute Swan, Coot and, on occasions, Shoveler. A feral Greylag Goose population uses the site. The fluctuating water levels provide an unusual habitat which favours two notable plant species, the locally-occurring Red Goosefoot (Chenopodium rubrum) and the rare Red Data Book species Golden Dock (Rumex maritimus). Kilcolman Bog is a privately-owned Nature Reserve that has been managed for conservation since the 1970s. Management includes control of the water levels and supplementary feeding of the waterfowl during hard weather. The bird populations have been intensively monitored since the 1970s. Activities such as drainage or forestry on surrounding lands could affect the viability of the site. The site is of ornithological interest because it supports nationally important numbers of three species. Of particular note is the population of Whooper Swan, a species that is listed on Annex I of the E.U. Birds Directive. The site is notable as being one of the few sites in the country where almost daily observations have been made over a long period EPA Export :23:03:56

112 Rev A Natura Impact Statement Appendix 2 Conservation Objectives EPA Export :23:03:56

113 18 July 2011 Generic Conservation Objective Conservation Objectives for Blackwater River (Cork/Waterford) SAC [002170] Start The overall aim of the Habitats Directive is to maintain or restore the favourable conservation status of habitats and species of community interest. These habitats and species are listed in the Habitats and Birds Directives and Special Areas of Conservation and Special Protection Areas are designated to afford protection to the most vulnerable of them. These two designations are collectively known as the Natura 2000 network. European and national legislation places a collective obligation on Ireland and its citizens to maintain habitats and species in the Natura 2000 network at favourable conservation condition. The Government and its agencies are responsible for the implementation and enforcement of regulations that will ensure the ecological integrity of these sites. The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level. Favourable conservation status of a habitat is achieved when: its natural range, and area it covers within that range, are stable or increasing, and the specific structure and functions which are necessary for its long term maintenance exist and are likely to continue to exist for the foreseeable future, and the conservation status of its typical species is favourable. The favourable conservation status of a species is achieved when: population dynamics data on the species concerned indicate that it is maintaining itself on a long term basis as a viable component of its natural habitats, and the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long term basis. Objective: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected: [1029] Margaritifera margaritifera [1092] Austropotamobius pallipes [1095] Petromyzon marinus [1096] Lampetra planeri [1099] Lampetra fluviatilis [1103] Alosa fallax [1106] Salmo salar (only in fresh water) [1130] Estuaries [1140] Mudflats and sandflats not covered by seawater at low tide [1220] Perennial vegetation of stony banks [1310] Salicornia and other annuals colonizing mud and sand [1330] Atlantic salt meadows (Glauco Puccinellietalia maritimae) [1355] Lutra lutra [1410] Mediterranean salt meadows (Juncetalia maritimi) Citation: NPWS (2011) Conservation objectives for Blackwater River (Cork/Waterford) SAC [002170]. Generic Version 3.0. Department of Arts, Heritage & the Gaeltacht. For more information please go to: EPA Export :23:03:56

114 18 July 2011 Generic Conservation Objective [1421] Trichomanes speciosum [3260] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho Batrachion vegetation [91A0] Old sessile oak woods with Ilex and Blechnum in the British Isles [91E0] * Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno Padion, Alnion incanae, Salicion albae) [91J0] * Taxus baccata woods of the British Isles Citation: NPWS (2011) Conservation objectives for Blackwater River (Cork/Waterford) SAC [002170]. Generic Version 3.0. Department of Arts, Heritage & the Gaeltacht. For more information please go to: EPA Export :23:03:56

115 16 April 2012 Generic Conservation Objective Start Conservation Objectives for Kilcolman Bog SPA [004095] The overall aim of the Habitats Directive is to maintain or restore the favourable conservation status of habitats and species of community interest. These habitats and species are listed in the Habitats and Birds Directives and Special Areas of Conservation and Special Protection Areas are designated to afford protection to the most vulnerable of them. These two designations are collectively known as the Natura 2000 network. European and national legislation places a collective obligation on Ireland and its citizens to maintain habitats and species in the Natura 2000 network at favourable conservation condition. The Government and its agencies are responsible for the implementation and enforcement of regulations that will ensure the ecological integrity of these sites. The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level. Favourable conservation status of a habitat is achieved when: its natural range, and area it covers within that range, are stable or increasing, and the specific structure and functions which are necessary for its long term maintenance exist and are likely to continue to exist for the foreseeable future, and the conservation status of its typical species is favourable. The favourable conservation status of a species is achieved when: population dynamics data on the species concerned indicate that it is maintaining itself on a long term basis as a viable component of its natural habitats, and the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long term basis. Objective: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA: Cygnus cygnus [wintering] Anas crecca [wintering] Anas clypeata [wintering] Wetlands [] Citation: NPWS (2011) Conservation objectives for Kilcolman Bog SPA [004095]. Generic Version 4.0. Department of Arts, Heritage & the Gaeltacht. For more information please go to: EPA Export :23:03:56

116 Dairygold Co-Operative Society Ltd. Dryer Facility Expansion Project Schedule of Drawings All Drawings are Prefixed 13871: Site Location Plan (1:10560) 5002 Site Location Plan (1:2500) 5003 Existing Site Layout Levels 5004 Existing Layout of Roundabout at N20 North of Site Levels 5005 Site Layout Plan Proposed 5006 Existing Site Layout showing Demolition Works 5007 Site Layout Plan Existing Facilities 5008 Site Layout Plan Proposed Facilities 5009 Proposed Swept Path Analysis Articulated Milk Tanker (Length 15.3m) 5010 Proposed Swept Path Analysis Fire Appliance, Rigid Delivery Van and Tankers to Chemical Intake and Vegetable Oil Tanks 5011 Proposed Swept Path Analysis Articulated Lorry (Length 16.5m) 5012 Site Layout Plan Proposed Surfaces and Levels 5013 Site Layout Plan Proposed Temporary Works 5014 Site Layout Plan Future Tank Designation 5015 Site Layout Plan Buildings 5016 Proposed Site Contiguous Sectional Elevations 5050 Proposed Landscape Masterplan 5051 Landscape Proposals to North Entrance 5052 Landscape Proposals to South Entrance Schedule of Drawings - Dairygold Mallow Dryer Facility Expansion Project EPA Export :23:03:56