LITTLE ISLAND. Attachment I EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY B I O E N E R G Y. Attachment I

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1 LITTLE ISLAND B I O E N E R G Y Attachment I Attachment I EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY EPA Export :23:31:50

2 ATTACHMENT N O I EXISTING ENVIRONMENT CONTENTS ATTACHMENT I.1 - ASSESSMENT OF ATMOSPHERIC EMISSIONS... I-1 Existing Environment... I-1 Statement Regarding Principle Polluting Substances... I-2 Dispersion Model... I-2 Impacts... I-6 Mitigation... I-7 ATTACHMENT I.2 - ASSESSMENT OF IMPACT ON RECEIVING SURFACE WATER... I-9 Existing Environment... I-9 Statement Regarding Main Polluting Substances... I-12 Compliance with EC Environmental Objectives... I-13 Impacts... I-13 ATTACHMENT I.3 - ASSESSMENT OF IMPACT OF SEWAGE DISCHARGE... I-16 Impacts... I-16 Compliance with Article 15 of IED Directive... I-17 ATTACHMENT I.4 - ASSESSMENT OF IMPACT OF GROUND/GROUNDWATER EMISSIONS... I-19 Baseline Report... I-19 Existing Groundwater Quality... I-20 Ground and Groundwater Impacts and Mitigation... I-20 ATTACHMENT I.5 GROUND AND/OR GROUNDWATER CONTAMINATION... I-22 Site Investigations I-22 Site Investigations I-25 Statement Regarding EC Environmental Objectives... I-26 ATTACHMENT I.6 ON-SITE WASTE RECOVERY AND/OR DISPOSAL... I-27 Recovery and Disposal Arrangements... I-27 Impacts... I-27 ATTACHMENT I.7 NOISE IMPACT... I-29 ATTACHMENT I.8 - ENVIRONMENTAL CONSIDERATIONS, MAIN ALTERNATIVES & BAT... I-32 I.8a Main Alternatives... I-32 I.8f Environmental Considerations... I-33 I.8g Proposed Measures... I-35 I.8i Best Available Techniques (BAT)... I-39 TABLES Table 1 Arsenic Concentration I-23 Table I.8(i-a) Conclusions on BAT Waste Treatment Industries (2006)... I-40 Table I.8(i-b) Conclusions on BAT Energy Efficiency (2009)... I-58 Table I.8(i-c) Conclusions on BAT Emissions from Storage (2006)... I-77 Table I.8(i-d) Conclusions on BAT Large Combustion Plants (2006)... I-103 Table I.8(i-e) Conclusions on BAT Slaughterhouses and Animal By-Product Industries (2005)... I-117 EPA Export :23:31:50

3 ATTACHMENT N O I EXISTING ENVIRONMENT ATTACHMENT I.1 - ASSESSMENT OF ATMOSPHERIC EMISSIONS An Air Quality and Climate Assessment undertaken by Odour Monitoring Ireland forms Chapter 8 of the Environmental Impact Statement (EIS) (Volume II) that accompanies this application. Full details of the monitoring undertaken, dispersion modelling, impacts of proposed emissions and measures for mitigating impacts are presented within this chapter. Existing Environment The EU Air Framework Directive deals with each EU Member State in terms of Zones and Agglomerations for air quality. For Ireland, four zones, A, B, C and D have been defined: Zone A Dublin conurbation Zone B Cork conurbation Zone C 21 towns in Ireland with population > 15,000 Zone D remaining area of Ireland Inchera and its environs are classified for the purposes of this assessment as falling within Zone B. While there is some availability of recent and historic data for air quality in major cities, there is no data available from the national air quality monitoring database for air quality specific to Inchera. As such, available data from the EPA Monitoring Site located in a Zone B area has been referenced for Carbon Monoxide, Nitrogen Oxides, Sulphur Dioxide and PM 10 and PM 2.5 levels and is considered representative of background air quality in the study area. In addition and for completeness, a baseline air quality survey was performed between December 2014 and January 2015 at five locations in the vicinity of the application area (see Figure 8-2 of Chapter 8). This survey was undertaken in order to assess the baseline air quality concentrations of specific key pollutants including Nitrogen dioxide, Sulphur dioxide, Benzene, Total particulate matter and Odours. This monitoring also allowed for the assessment of cumulative baseline emissions in the vicinity of the proposed plant. The baseline values recorded for each parameter are presented in Table 8-7 of Chapter 8. Each of the key pollutants was determined to be within the limit values for both the protection of human health and eco systems. The results of the survey conclude that air quality in the vicinity of the application area is expected to be average/good with typical levels of pollutants for a suburban area. All pollutant levels are within the relevant Irish and EU limits (for similar sized population centres) for ambient air quality standards. Proposed Renewable BioEnergy Plant I-1 Little Island BioEnergy Ltd. EPA Export :23:31:50

4 ATTACHMENT N O I EXISTING ENVIRONMENT An odour sniff survey was performed in the vicinity of the application area at eleven locations over two individual events during Dec 2014 and Jan This survey was performed in line with the EPA s Air Guidance Note 5 (AG5) and allowed for the establishment of baseline odour levels in the vicinity of the application area. The results of the survey are presented on Table 8-8. No distinct odours were detected, therefore baseline odours were considered to be ambient, not distinct and neutral. Consequently it is considered that there are no significant contributory sources to odour in the immediate vicinity of the application area at present. Statement Regarding Principle Polluting Substances The proposed scheduled emission points will include emissions of carbon monoxide, oxides of nitrogen, sulphur dioxide, particulate matter and total non-methane volatile organic compounds. Each of these substances is listed as principal polluting substances in S.I. No. 137 of The dispersion model undertaken as part of the Air Quality and Climate Assessment demonstrates that in addition to the existing baseline and when all processes are operational at the proposed plant the maximum predicted ground level concentrations (GLCs) for each of the parameters listed above are well within EU and Irish air quality limit values. Therefore, the operation of the proposed plant s scheduled emission points is not likely to impair the environment. Dispersion Model The predicted impacts as a result of operation of scheduled emission points at the proposed plant for air quality and odours was examined utilising air quality and odour emission rate data in accordance with procedures and methods contained in the following publications: EN13275: Air quality - Determination of odour concentration by dynamic olfactometry, (CEN), H4 Odour Management, Guidance Parts 1 and 2, Environment agency, UK, Air Dispersion Modelling from Industrial Installations Guidance Note (AG4), EPA This data was inputted into a dispersion model in order to predict the impacts of named pollutant emissions from scheduled emissions points to be located within the proposed plant s Proposed Renewable BioEnergy Plant I-2 Little Island BioEnergy Ltd. EPA Export :23:31:50

5 ATTACHMENT N O I EXISTING ENVIRONMENT boundary. AERMOD Prime (12345) and 5 years of hourly sequential meteorological data (Cork Airport 2008 to 2012) representative of the study area were utilised within the dispersion model with the worst case year Cork 2008 used for data presentation. Model Assumptions The approach adopted in this assessment is considered a worst-case investigation in respect of emissions to the atmosphere from the proposed scheduled emission points to be located within the operational plant. These predictions are therefore most likely to overestimate the GLC s that may actually occur for each modelled scenario. The assumptions are summarised and include: All emissions were assumed to occur at maximum potential emission concentration and mass emission rates for each scenario and were assumed to occur for 100% of an operating year, simultaneously (when the proposed plant is in operation); Five years of hourly sequential meteorological data from Cork Airport 2008 to 2012 inclusive was used in the modelling screen which will provide statistical significant results in terms of the short and long term assessment. The worst case year 2008 was used for data analysis, this is in keeping with guidance presented in AG4. In addition, AERMOD incorporates a meteorological pre-processor AERMET PRO. The AERMET PRO meteorological pre-processor requires the input of surface characteristics, including surface roughness (z0), Bowen Ratio and Albedo by sector and season, as well as hourly observations of wind speed, wind direction, cloud cover, and temperature. The values of Albedo, Bowen Ratio and surface roughness depend on land-use type (e.g., urban, cultivated land etc) and vary with seasons and wind direction. The assessment of appropriate land-use type was carried out to a distance of 10km from the meteorological station for Bowen Ratio and Albedo and to a distance of 1km for surface roughness in line with USEPA recommendations; AERMOD Prime (12345) dispersion modelling was utilised throughout the assessment in order to provide the most conservative dispersion estimates; All building wake affects were assessed within the dispersion model; Topographical data was inputted into the model in order to take account of any rolling terrain in the vicinity of the site (which is the case in this instance); and Baseline data was used in conjunction with the predicted process emissions. In addition traffic contribution values gathered from a review of available literature for EPA Proposed Renewable BioEnergy Plant I-3 Little Island BioEnergy Ltd. EPA Export :23:31:50

6 ATTACHMENT N O I EXISTING ENVIRONMENT monitoring sites contained in Air Quality in Ireland 2013 and also through the monitoring of baseline air quality at five locations in the vicinity of the proposed plant was used to assess proposed impacts. Odour Impact Criterion Potential odours from the proposed plant are associated with the operational phase and may arise from the release of odorous gases from: The handling and processing of feedstock material within the process; Fugitive odour emissions from building leakage; Pumping of liquids between tanks; Digestate thickening (dewatering); Storage of digestate on site; and Process effluent treatment. Impacts from the proposed plant s operations are assessed in accordance with the following requirements. These include: Odour Impacts and Odour Emission Control Measures for Intensive Agriculture, EPA, 2001; Air Dispersion Modelling from Industrial Installations Guidance Note (AG4), EPA, 2010, and H4 Odour Management, Guidance Parts 1 and 2, Environment agency, UK, Based on these publications, a value of less than 1.50 Ou E/m 3 at the 98 th percentile of hourly averages for 5 years of screened hourly sequential meteorological data was examined as this was considered the most appropriate odour impact criterion given the nature of the proposed activity. Input Data i. Source Characteristics The input source characteristics of each of the four scheduled emission points are specified in Table This data was utilised in conjunction with the emission rate data for both odour and classical air pollutants in order to predict the worst case GLC over the total fine grid area Proposed Renewable BioEnergy Plant I-4 Little Island BioEnergy Ltd. EPA Export :23:31:50

7 ATTACHMENT N O I EXISTING ENVIRONMENT of 16 km sq. and the course grid area of 306 km sq. giving a total receptor grid number of 2,223 receptor points in the assessment area. ii. Odour Input odour emission data for the proposed plant processes is presented in Table The overall odour emission rate from identified processes will be 36,111 Ou E/s. Table 8.17 presents the overall negative ventilation strategy for the various processes located throughout the proposed plant. It is assumed that the building envelope will be constructed to achieve a building integrity sealing of near 100%. iii. Air Quality The overall air quality emission data for Carbon monoxide, Oxides of nitrogen, Sulphur dioxide, Total particulates (as PM 10 and PM 2.5), Total non-methane Volatile organic compounds expressed as Benzene, Hydrogen sulphide and Ammonia from the identified processes is presented in Table This data was inputted into the dispersion model to allow for the examination of predicted classical air pollutant levels for maximum predicted regime at each of the identified sensitive receptors presented in Tables 8.3 to 8.5. For modelling classical air pollutants and in order to obtain the predicted environmental concentration (PEC), baseline data was added to the predicted process emission at ground level. In relation to the predicted annual averages, the ambient background concentration was added directly to the predicted process concentration. However, in relation to the predicted short-term peak 1 hr concentrations, twice the background concentration level was added to the predicted environmental concentration (PEC) (UK Environment Agency). As a baseline survey was performed in the vicinity of the proposed plant for selected priority pollutants, the existing contribution of pollutants from other sources in close proximity to the proposed plant have been taken into account within this data set (e.g. other EPA licenced facilities in the vicinity of the site). The worst case baseline figure gathered during the survey of the application area and from a review of EPA air quality data was utilised in calculations to remain conservative. With regards to ammonia and hydrogen sulphide, it was assumed that emissions of ammonia and hydrogen sulphide will occur from the gas utilisation engines and odour control system. The centrifuge room will be placed under negative pressure and all gases collected will be Proposed Renewable BioEnergy Plant I-5 Little Island BioEnergy Ltd. EPA Export :23:31:50

8 ATTACHMENT N O I EXISTING ENVIRONMENT passed through the odour control system for treatment. This is considered worst case assessment for critical exposure impact on sensitive habitats. In addition, since no defined baseline levels of ammonia were measured, it is assumed that an impact criterion of 20% of the critical exposure levels is utilised so as to take account of any incident of ammonia emissions being greater than the critical level. This is also considered significantly conservative for ammonia impact assessment. For Hydrogen sulphide, 1/40 th and 1/100 th of the 8 hr and 15 min Time Weighted Average limit value contained in EH40 Workplace Exposure Limits notes (SI 691 of 2011) was utilised for assessment. Impacts Output Odour Data Of all the receptors evaluated, C15, a commercial receptor, is identified as the worst case receptor with a maximum predicted GLC of odour less than or equal to 0.15 Ou E/m 3 at the 98 th percentile of hourly averages for the worst case meteorological year Cork Airport This is less than 10% of the odour impact criterion of 1.5 Ou E/m 3 stated in Irish EPA Guidance AG4 (page 70). In addition, the maximum predicted odour concentration anywhere in the vicinity of the proposed plant (including inside and outside the boundary of the facility and within the fine grid area of 16 km sq. and a course grid area of 306 km sq.) will be less than or equal to 0.20 Ou E/m 3 for the 98 th percentile of hourly averages for the worst case meteorological year Cork Airport This is 13% of the worst case odour impact criterion of 1.5 Ou E/m 3 stated in Irish EPA Guidance AG4 (page 70). As the GLC value is assessed as being below 1.0 Ou E/m 3 at each of the residential, commercial and designated site receptors in the vicinity of the proposed plant when fully operational, odour from the proposed plant will not result in any significant impact in the vicinity of the facility. Output Air Quality Data Table 8.23 presents the maximum predicted classical air pollutant values in the vicinity of the proposed plant when all processes are operating. The maximum predicted GLCs of Carbon monoxide, Oxides of nitrogen, Sulphur dioxide, Particulate matter as PM 10 and PM 2.5, Total Proposed Renewable BioEnergy Plant I-6 Little Island BioEnergy Ltd. EPA Export :23:31:50

9 ATTACHMENT N O I EXISTING ENVIRONMENT non-methane volatile organic compounds, Hydrogen sulphide and Ammonia with baseline values and predicted traffic related emissions is well within EU and Irish air quality limit values. The cumulative predicted GLC of each pollutant is well within their respective GLC limit (range of less than 0.10 to 74.70% of impact criterion when the proposed plant is at 100% operation capacity (see Tables 8.24 to 8.27). Mitigation In view of the potential for adverse environmental effects, the design and operation of the proposed plant is intended to ensure that there will be no significant impacts to air quality as a result of the operation of the proposed plant. A number of measures have been incorporated into the design of the proposed plant and include: The main building is totally enclosed with access into or out of the building only possible through automatic rapid open/shut doors. Pedestrian doors will for remain closed and only open when access is required. This will ensure the risk of egress of odour through building apertures is minimised; Extraction systems in the reception area of the main building will maintain negative pressure inside all areas where waste is handled and processed. This will encourage air to flow into the building, thus further preventing uncontrolled egress of odour; The air extracted from the waste processing building will be treated in an odour control system prior to being exhausted through a 25m stack which is considered to have sufficient height to ensure an adequate level of dispersion; There will be no emissions to atmosphere from the digestion tanks or other process vessels containing odorous materials as waste will be contained within fully sealed tanks; and The combustion of biogas by the CHP units or gas flare will destroy any potentially odorous compounds contained in the biogas. The proposed design of a 28m high stack is considered to represent a good level of environmental performance, to ensure adequate dispersion; In terms of the likelihood of fugitive emissions of odours, these will be negligible as all buildings and processes containing odorous activities will be of high containment integrity (near 100% integrity) and all areas where odorous activities occur will be placed under negative extraction; and Proposed Renewable BioEnergy Plant I-7 Little Island BioEnergy Ltd. EPA Export :23:31:50

10 ATTACHMENT N O I EXISTING ENVIRONMENT All aspects of the odour management system including the containment, extraction and treatment system as described in Attachment F.1 will be continuously monitored by the SCADA system and a network of sensors to ensure it is functioning adequately. The Air Quality and Climate assessment demonstrates that emission levels as a result of the operation of the proposed plant will not result in any air quality impact in line with Irish and European assessment criteria limits. Proposed Renewable BioEnergy Plant I-8 Little Island BioEnergy Ltd. EPA Export :23:31:50

11 ATTACHMENT N O I EXISTING ENVIRONMENT ATTACHMENT I.2 - ASSESSMENT OF IMPACT ON RECEIVING SURFACE WATER A Hydrological Assessment undertaken by Environmental Risk Solutions (ERS) Ltd. forms Chapter 13 of the EIS (Volume II). A comprehensive description of the proposed surface water management system is provided in Chapter 2 (see Section ) of the EIS (Volume II) and Section 6 of Appendix 2-1 (Volume III). These should be read in conjunction with this Attachment for full details of the impact of the proposed plant on the receiving surface water. The proposed storm water drainage layout is presented on Drawing Existing Environment Regional Drainage Surface water in the study area includes Lough Mahon, which together with the outer River Lee Estuary, forms the upper section of Cork Harbour. Surface water flow into Lough Mahon includes freshwater flow from the River Lee into the tidal estuary which is mixed with tidal sea water from the lower Cork Harbour. The River Lee flows into Lough Mahon in the upper harbour. The River Lee is one of the largest rivers in southwest Ireland and is the largest discharging into Cork Harbour, with a total catchment area covering approximately 2,000 sq. km. Local Drainage There are two drainage features to the east of the site, none of which are classed as Water Framework Directive (WFD) water bodies. Drainage Channel 1 is approximately 85m east of the site. This drainage channel is clearly visible on historical aerial photography and OS mapping. Current aerial photography shows a new road north east of the development which has somewhat altered the alignment. There is high ground between the site and this drainage feature providing protection. Drainage Channel 2 commences at the north east corner of the proposed site, see Figure 13-1 of Chapter 13. These drainage channels run south to north discharging to a drainage basin adjacent to the N25. This basin drains under the N25 to the east of the N8, N25 interchange and ultimately south west under the N25 into Lough Mahon. Drainage Channels 1 and 2 along the eastern boundary of the site are affected by backwatering from the sea. Assessing the surrounding Proposed Renewable BioEnergy Plant I-9 Little Island BioEnergy Ltd. EPA Export :23:31:50

12 ATTACHMENT N O I EXISTING ENVIRONMENT drainage of the area, the drainage channels east of the site would be affected by tidal conditions and backwatering affect when the level in Lough Mahon is high. Therefore, flood risk may be exacerbated if high surface water flows coincide with a period of high sea levels. Low pressure and strong easterly winds cause surges in Cork Harbour. High tides also impact on the level of flooding ( and a detailed Flood Risk Assessment has been prepared by Tobin Consulting Engineers and is included as Appendix I.2 of this Attachment. Existing Stormwater Drainage The site was formerly occupied by a pharmaceutical manufacturing facility operated by Pfizer Cork Ltd. Historic drainage from the site was drained from the site via a pipe that runs from the northern site entrance to the drainage basin that lies to the south of the N25 and which ultimately discharged to Lough Mahon via the drainage basin that is located on the northern side of the N25. This drainage system remains intact following the decommissioning and demolition of surface structures on the site. This discharge was monitored historically under the former IPPC Licence for the site for ph and TOC and monitoring was discontinued when the site ceased manufacturing operations in Water Framework Directive Water quality in the River Lee at Leemount Bridge has been classified by the EPA as being of Good Status (Q4). Surface water quality in Lough Mahon has been classified by the EPA as being Intermediate. Lough Mahon and Upper Cork Harbour are designated Nutrient Sensitive Transitional Waters (EPA). Lough Mahon is a Transitional Waterbody (reference code IE_SW_060_0750) mapped under the Southwestern River Basin District completed under the Water Framework Directive (refer to Figure 13-1). Lough Mahon has been classified as having an overall status of Moderate and being At Risk (1a) of not achieving Good Status by The objective is to restore the waterbody to good status by Dissolved Inorganic Nitrogen status (DINV) and Dissolved oxygen as per cent saturation status (DO) are classified as being Moderate and drive the overall Moderate Status for the waterbody. The Waterbody Status report is provided in Appendix Proposed Renewable BioEnergy Plant I-10 Little Island BioEnergy Ltd. EPA Export :23:31:50

13 ATTACHMENT N O I EXISTING ENVIRONMENT European Designated Areas There are three Natura 2000 sites within a 15km radius of the development site. The closest site (Cork Harbour SPA) is located approximately 100m to the southwest of the development site. The screening assessment presented in the Natura Impact Statement (NIS) (see Attachment B.6 of this application) identifies the Cork Harbour SPA as the only site with a potential source pathway- receptor link to the operational phase of the proposed plant. The screening assessment presented in the NIS determines that based on the proposed treatment of process water at the onsite process effluent treatment plant prior to discharge to the existing municipal sewer and further treatment at the Carrigrennan wastewater treatment plant (WwTP) no significant changes in water quality are predicted to occur in the receiving waters of Cork Harbour. The screening assessment concludes that there will be no significant effects resulting from the discharge of treated process water on the integrity of any designated site. The proposed development is not likely to result in a measurable impact on any qualifying feature in light of the conservation objectives for the Natura 2000 sites and is therefore screened out from further assessment. Flood Risk In accordance with the guidelines produced by the Department of Environment Heritage and Local Government (DEHLG) The Planning System and Flood Risk Management: Guidelines for Planning Authorities (2009), a Stage 1 Preliminary Flood Risk Assessment (PFRA) has been prepared by Tobin Consulting Engineers and is included as Appendix I.2. A search on the Office of Public Works (OPW) National Flood Hazard Mapping website found no record of past flooding within the proposed development area. The OPW and its partners, Cork City Council and Cork County Council, have undertaken a catchment-based flood risk assessment and management study of the Lee Catchment the Lee Catchment Flood Risk Assessment and Management (CFRAM) Study. The main outputs from this study are flood maps and a Catchment Flood Risk Management Plan (CFRMP) which identifies a programme of prioritised studies, actions and works to manage the flood risk in the Lee catchment, both now and into the future. Proposed Renewable BioEnergy Plant I-11 Little Island BioEnergy Ltd. EPA Export :23:31:50

14 ATTACHMENT N O I EXISTING ENVIRONMENT The Lee CFRAM Study provides flood extent, hazard, depth and velocity mapping for the catchment area. Current and future scenario tidal mapping is provided for the Little Island Area. The future scenario is known as the Mid-Range Future Scenario (MRFS) which includes an allowance for climate change (0.55m). The mapping indicates that the site is outside the extent of all storm events, see Figure 4.3 of Appendix I.2. However, based on topographical levels of the site, the north eastern corner of the site would be inundated under all events. The Irish Coastal Protection Strategy Study (ICPSS) was completed in 2013 and is in line with the Lee CFRAM study. It provides coastal flood hazard maps for the coastline of Ireland, including the coastline in the proximity of the proposed site. It is estimated from the Irish Coastal Protection Strategy Study (ICPSS) mapping, the ICPSS flood levels and site topography, that only the north-eastern corner of the site is located within the estimated 1,000- year flood zone for the MRFS, approximately 0.2ha of the site is inundated during the 0.1% annual exceedance probability (AEP) event. Based on the 0.1% AEP (1000-year) flood level provided in the Lee CFRAMS and the ICPSS, the estimated MRFS tidal flood level is 3.54mOD. It is proposed to raise the site to a level of 7.8mOD by raising site levels. This will include raising approximately 0.09ha of land currently located within the 1,000-year floodplain, as estimated from the Lee CFRAMS and ICPSS. The floodplain for the drainage basin, south of the N25 is roughly estimated to be 35ha (based on the flooding extent from the ICPSS). The percentage of the floodplain removed due to development is 0.3%. It is estimated, due to the minimal encroachment into the flood plain (i.e. <0.5%), that there proposed development will have an imperceptible impact on flood levels. In accordance with guidelines and recommendations it has been determined that the developed site will be in Flood Zone C and is assumed to be appropriate from a flood risk perspective. The development will be discharging into the existing surface water sewer at greenfield rates and will not increase surface water runoff into Lough Mahon. Statement Regarding Main Polluting Substances The proposed plant would require the discharge of clean treated surface water runoff to the existing municipal storm water sewer. A Sustainable Drainage System (SuDS) has been incorporated into the overall design of the plant to manage and control surface water runoff. A full description of the proposed SuDS is presented in Attachment F.1. Clean treated surface water will be discharged at an average of 32m 3 per day. The rate of discharge will be limited Proposed Renewable BioEnergy Plant I-12 Little Island BioEnergy Ltd. EPA Export :23:31:50

15 ATTACHMENT N O I EXISTING ENVIRONMENT to the greenfield discharge rate (6.1 l/s/ha) by means of a flow control device. Prior to any discharge the runoff will pass through a hydrocarbon interceptor and grit trap to remove any suspended solids. There will be no emissions of any of the main polluting substances (as defined in the Schedule of EPA (Licensing) (Amendment) Regulations 2004, S.I. No. 394 of 2004) to the existing storm water drainage network based on the source of the discharge (surface water run-off) and its treatment prior to discharge. Thus there will be no impairment of the environment as a result of this emission. Compliance with EC Environmental Objectives The activity is in compliance with the requirements of the EC Environmental Objectives (Surface water) Regulations 2009 as no emissions of any of the main polluting substances, as defined in the Schedule of EPA (Licensing) (Amendment) Regulations 2004, S.I. No. 394 of 2004 will be discharged to the existing municipal storm water network. The surface water discharge point from the proposed site drains into the municipal storm sewer network which in turn discharges to Lough Mahon which is considered of moderate quality and is not a water body identified under the First Schedule of the EC EO (Freshwater Pearl Mussel) Regulations Impacts The methodology involved in the assessment of the hydrology at the site can be summarised as follows: A desk study, in which relevant published data sources for the area were examined. A site walkover survey. Analysis of the information gathered and assessment of the potential impacts of the development. The main potential direct impacts during the operational phase of the proposed plant on the local surface water courses could be the accidental spillage of hazardous materials that runoff the site impacting surface water quality and changes to flooding characteristics from the development of the site affecting runoff characteristics. Measures have been incorporated into the design of the plant to mitigate against such occurrences and include: Proposed Renewable BioEnergy Plant I-13 Little Island BioEnergy Ltd. EPA Export :23:31:50

16 ATTACHMENT N O I EXISTING ENVIRONMENT All chemicals will either be stored under cover in a bunded area or will be stored outside in sealed tanks which will be bunded; All fuels will be stored in bunded tanks with the provision of a storage/retention capacity of 110% of tank storage volume and will be stored in a designated area; All unloading of waste material and all processing at the site will be undertaken indoors under cover to ensure that no contamination of surface water runoff occurs from this stage in the process. Wash-down from the process area of the main building will be recycled to the AD process. Storage or treatment of process liquid and effluent will be in sealed tanks in areas bunded to 110% of the largest tank capacity; All process liquid will be diverted to and treated in an on-site process effluent treatment plant. All vehicles exiting the plant will pass through a wheelwash located near the exit gate to ensure that there is no soiling of public roads in the vicinity of the subject site. Wastewater from onsite welfare facilities and runoff from the wheelwash will be discharged directly to the public sewer. The surface water management system for the site has been designed based on a 1 in 100 year storm event with an additional allowance of 20% for climate change. Storm water runoff attenuation will be provided at the site and it will be designed to ensure that the surface water is discharged in a controlled manner at the greenfield runoff rate (6.1 l/s/ha), and will not pose an increased flood risk downstream of the site to land and property. The risk of serious pollution incident impacting Lough Mahon is further mitigated by the proposed stormwater attenuation tank, which will allow interception and remediation of a pollution incident before discharge occurs to Lough Mahon. In the event of a major accident at the facility, a remotely controlled shut-off valve will be utilised at the discharge point from the site to ensure that all runoff will be retained on site for appropriate assessment, and if necessary treatment and disposal. In summary, the potential impacts to hydrology during the operational phase before considering additional mitigation factors are concluded to be imperceptible (i.e. an impact Proposed Renewable BioEnergy Plant I-14 Little Island BioEnergy Ltd. EPA Export :23:31:50

17 ATTACHMENT N O I EXISTING ENVIRONMENT capable of measurement but without noticeable consequences). Due to their nature, imperceptible impacts are not considered necessary for mitigation. It is concluded that there will be no residual impacts to hydrology and surface water as a result of the operational phase of the proposed plant. Proposed Renewable BioEnergy Plant I-15 Little Island BioEnergy Ltd. EPA Export :23:31:50

18 LITTLE ISLAND B I O E N E R G Y ATTACHMENT I.2 - ASSESSMENT OF IMPACT ON RECEIVING SURFACE WATERS Appendix I.2 Preliminary Flood Risk Assessment EPA Export :23:31:50

19 Stream Bio Energy Ltd Proposed Renewable Bioenergy Plant at Preliminary Flood Risk Assessment February, 2015 TOBIN CONSULTING ENGINEERS EPA Export :23:31:50

20 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment PROJECT: Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment CLIENT: Stream BioEnergy Unit 1 Avondale Business Park, Carysfort Avenue,, Blackrock, Co. Dublin, Ireland. COMPANY: TOBIN Consulting Engineers Block 10-4 Blanchardstown Corporate Park Dublin 15 Template rep 003 EPA Export :23:31:50

21 P3 Design Control Form DCO 0032 Form 3.2 Rev c Effective Date 14/02/07 DOCUMENT AMENDMENT RECORD Client: Project: Title: Stream BioEnergy Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment PROJECT NUMBER: 7722 DOCUMENT REF: PFRA B Incorporating comments JF 2402/15 PF 24/02/15 DC 25/02/15 A First Issue JF 18/02/15 PF 18/02/15 DC 18/02/15 Revision Description & Rationale Originated Date Reviewed Date Authorised Date TOBIN Consulting Engineers EPA Export :23:31:50

22 Proposed Renewable BioEnergy Plant, Preliminary Flood Risk Assessment TABLE OF CONTENTS 1.0 INTRODUCTION METHODOLOGY SITE DESCRIPTION HYDROLOGY OF THE REGION HISTORICAL FLOODING LEE CATCHMENT FLOOD RISK ASSESMENT AND MANAGEMENT (CFRAM) STUDY IRISH COASTAL PROTECTION STRATEGY STUDY (ICPSS) PLANNING AND FLOOD RISK MANAGEMENT GUIDELINES Cork County Development plan (2014) Planning & Flood Risk Management Guidelines Sequential Approach and Justification Test IMPACT OF DEVELOPMENT ON FLOODING Local Surface Water Runoff Encroachment into the floodplain Conclusion SUMMARY AND CONCLUSIONS APPENDICES Appendix A OPW Flood Hazard Information Appendix B Lee CFRAM Study Flood Extent Maps Appendix C ICPSS Flood Extent Maps Page (i) EPA Export :23:31:50

23 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment 1.0 INTRODUCTION TOBIN Consulting Engineers have been appointed by Stream BioEnergy Ltd to prepare a site specific Flood Risk Assessment for their planning application for a proposed Renewable Bioenergy Plant at. The development will consist of a processing building, tank farm, service yard, office accommodation, laboratory, car parking area and all ancillary works, as well as the demolition of an existing wastewater treatment plant and substation building. The layout of the proposed works is shown on drawing of the main planning submission. 2.0 METHODOLOGY This Flood Risk Assessment is being carried out due to the proximity of the site to the River Lee at Lough Mahon and the presence of two drainage features to the east of the site. It has therefore been considered necessary to carry out a Flood Risk Assessment, to be submitted in conjunction with the planning application, so that Cork County Council may make an informed decision in relation to any flood risk which may exist in the vicinity of the site. The report takes due consideration of the Planning System and Flood Risk Management Guidelines, the primary guidance document when considering flood risk in relation to planning decisions. The study includes: Review of available information, including: o o o OPW Flood Hazard Mapping Irish Coastal Protection Strategy Study Lee Catchment Flood Risk Assessment and Management (CFRAM) Study Review of the proposed development with regard to the Planning System and Flood Risk Management (PSFRM) Guidelines. 3.0 SITE DESCRIPTION The site subject to this initial Flood Risk Assessment is approximately 2.0 hectares in area and varies in height across the site from 7.5mOD Malin along the western boundary of the site, to 9.5mOD Malin at the centre of the site. The site drops steeply to approximately 2.0mOD Malin along the eastern boundary (see existing layout and topography drawing of the main planning submission). The site formally housed a Pfizer Plant, which has since been demolished. A treatment plant remains along the eastern boundary of the site. The proposed development proposes to regrade the western and central portion of the site to approximately 7.8mOD and raise a portion of the eastern end to the same level. No development is proposed to be undertaken below this level (see proposed site layout drawing of the main planning submission). EPA Export :23:31:50

24 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment The site is bounded by a BASF Plant to the south, undeveloped area to the east, and the Hoffmann Business Park to the North and West. The site is approximately 150m west of Lough Mahon in Cork Harbour. Outlet to Lough Mahon Drainage Basin North Cork to Youghal Road (N25) Proposed Site Drainage Channel 2 Drainage Basin South New Road River Lee (Lough Mahon) Drainage Channel 1 Figure 3.3: Aerial Photo of Proposed Site (Extracted from OSI MapViewer) Cork Harbour is one of the largest sea inlets in Ireland and is the deepest, natural harbour in Ireland. Cork Harbour is essentially divided into two main sections; the upper harbour, consisting of the outer Lee Estuary and Lough Mahon; and the lower harbour, or Cork Harbour. The River Lee flows into Lough Mahon in the upper harbour. The River Lee is one of the largest rivers in southwest Ireland and is the largest discharging into Cork Harbour, with a total catchment area covering approximately 2,000 sq km. Low pressure and strong easterly winds cause surges in Cork Harbour. High tides also impact on the level of flooding ( EPA Export :23:31:50

25 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment River Lee Figure 3.1: Looking West from the South West corner of the site There are two drainage features to the east of the site. Drainage Channel 1 is approximately 85m east of the site. This drainage channel is clearly visible on historical aerial photography and OS mapping. Current aerial photography shows a new road north east of the development which has somewhat altered the alignment. There is high ground between the site and this drainage feature providing protection. Drainage Channel 2 commences at the north east corner of the proposed site. Refer Figure 3.2 and 3.3 for details. Drainage Channel 2 Drainage Channel 1 Figure 3.2: Looking East / North east over the Existing Treatment Plant These drainage channels run south to north discharging to a drainage basin adjacent to the N25. This basin drains under the N25 to the east of N8, N25 interchange and ultimately south west under the N25 into Lough Mahon. Refer Figure 3.3 for details. Assessing the surrounding drainage of the area, the drainage channels east of the site would be affected by tidal conditions and backwatering affect when the level in Lough Mahon is high. Therefore, flood risk may be exacerbated if high surface water flows coincide with a period of high sea levels. EPA Export :23:31:50

26 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment 4.0 HYDROLOGY OF THE REGION 4.1 HISTORICAL FLOODING Anecdotal evidence from the client indicated that the eastern boundary of the site, where the levels are approximately 2.0mOD Malin was previously subjected to flooding. From visual inspection and analysis of the topographical survey, surface water ponding is likely to occur in this area as the levels are not conducive to natural drainage. Runoff from the entrance road and from the high ground to the east would congregate in this area. Refer Figure 4.1. Figure 4.1: Looking North and East at topography beside the Existing Treatment Plant A search on the OPW National Flood Hazard Mapping website found no record of past flooding within the proposed development area. The OPW flood maps have indicated areas denoted as Land Commission adjacent to the proposed development area. The glossary for the website offers the following definition for areas denoted under Land Commission Land Commission Maps indicating areas of land defended to some degree against flooding that were formerly the responsibility of the Land Commission. This definition indicates that flooding has previously been a concern at lands adjacent and that flood defence works may have been carried out or considered at these locations in the past. The website is an internet based search for flooding in the area and can be found at: (see Figure 4.2). EPA Export :23:31:51

27 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment Location of Site Figure 4.2: OPW Flood Hazard Mapping (Extracted from OPW floodmaps website) 4.2 LEE CATCHMENT FLOOD RISK ASSESMENT AND MANAGEMENT (CFRAM) STUDY The Office of Public Works and its partners, Cork City Council and Cork County Council, have undertaken a catchment-based flood risk assessment and management study of the Lee Catchment the Lee Catchment Flood Risk Assessment and Management (CFRAM) Study. The main outputs from this study are flood maps and a Catchment Flood Risk Management Plan (CFRMP) which identifies a programme of prioritised studies, actions and works to manage the flood risk in the Lee catchment, both now and into the future. A hydraulic assessment was undertaken with the objective of determining the flood risk for the Lee, its tributaries and the harbour for specific design events and future scenarios. The majority of the hydraulic modelling and flood mapping reported was undertaken between 2007 and 2009, prior to the November 2009 flood event in the catchment. Only the locations that were badly affected by the November 2009 flood event and had a noticeable difference between the observed and modelled flood extents (Crookstown, Kilumney and Cork City) were remodelled. The Cork Harbour model where our site is located was not included in this recalibration exercise. Calibration for the Harbour model was undertaken taking into account flood events prior to 2009 and data from gauging stations. The Lee CFRAM Study provides flood extent, hazard, depth and velocity mapping for the catchment area. Current and future scenario tidal mapping is provided for the Little Island Area. The future EPA Export :23:31:51

28 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment scenario is known as the Mid-Range Future Scenario (MRFS) which includes an allowance for climate change (0.55m). The mapping provides tidally dominated flood water levels for the following node / positions: Node less than 1km west of the proposed site location, located centrally in the River Lee Node located approximately 2km downstream of the proposed site. Node Label Future Scenario Mid Range Future Scenario Mid Range Future Scenario 10-year (10% AEP) Water Level (mod Malin) per AEP 200-year (0.5% AEP) 1,000-year (0.1% AEP) Table 4-1 Lee CFRAMS Estimated Flood Water Levels (extract from Hydraulics Report/Flood maps) The mapping produced for the 10-year, 200-year and 1,000 year coastal flood events, for the current and MRFS scenarios, are provided in Appendix B. Figure 4.3 indicates the MRFS flood extent mapping. The mapping indicates that the site is outside the extent of all storm events, however based on topographical levels of the site, the north eastern corner of the site would be inundated under all events. As part of the Lee CFRAM Study, a research and development project was undertaken to provide guidance for the development of uncertainty estimates associated with hydrological and hydraulic modelling and hence with the production of flood extents maps. This report is entitled Development Of Flood Mapping Formats for the Lee Catchment Flood Risk Assessment & Management Study (2008) A rapid method for estimating and showing the uncertainty on the flood maps was developed and tested as part of the Lee CFRAM Study. The uncertainty in water levels for each return period is estimated, using a simple scoring method. This is then transformed into a measure that represents how the uncertainty in water level will affect the location of the flood outline. This gives a horizontal uncertainty for each point on the flood outline, which is then communicated to the user by using different linestyles, thicknesses or colours. The uncertainty is generally thresholded into 3 classes (low, medium, high) to allow it to be displayed clearly. Refer Figure 4.3 for details of these classes. Flooding in the vicinity of the proposed site is given a low confidence indicating that the flood extent could be more than 40m wider than that indicated. EPA Export :23:31:51

29 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment Proposed Site ` Figure 4.3: MRFS Flood Extent Mapping (Extracted from Lee CFRAMS) The low lying areas to the north of the N25 have been identified as areas of potential significant risk and as a result management options as part of the CFRMP have been proposed including construction of a new sluice gate on the culvert under the N25 to the east of N8, N25 interchange. This culvert currently allows for the natural propagation of tidal water into low lying lands to the north of the N25. This new sluice gate would prevent the propagation of tidal floodwaters northwards. 4.3 IRISH COASTAL PROTECTION STRATEGY STUDY (ICPSS) The Irish Coastal Protection Strategy Study (ICPSS) was completed in 2013 and is in line with the Lee CFRAM study. It provides coastal flood hazard maps for the coastline of Ireland, including the coastline in the proximity of the proposed site. Work Package 9A of the ICPSS provides mapping for future scenarios, including an allowance for climate change for two climate scenarios: MRFS Mid-Range Future Scenario HEFS High-End Future Scenario The mapping provides the following coastal flood water levels for a node/position located approximately 2km downstream near Node 008 from the Lee CFRAMS. Water Level (mod Malin) per AEP Node Label Future Scenario 10-year (10% AEP) 200-year (0.5% AEP) 1,000-year (0.1% AEP) C_3 High End Future Scenario EPA Export :23:31:51

30 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment C_3 Mid Range Future Scenario Table 4-2 ICPSS Estimated Flood Water Level for Node C_3 (extract from Irish Coastal Protection Strategy Study) It is estimated from the ICPSS mapping (see Appendix C), the ICPSS flood levels (see Table 4-2) and site topography, that only the north-eastern corner of the site is located within the estimated 1,000-year flood zone for the MRFS, approximately 0.2ha of the site is inundated during the 0.1% AEP event. It should be noted that the ICPSS mapping comes with the following user note: Note : More detailed maps showing combined tidal and fluvial flood Hazard for this area have been prepared under the Lee CFRAM study. The Lee CFRAM Study and mapping has been considered in Section 4.2 of this report. Proposed Site Figure 4.4: MRFS Flood Extent Mapping (Extracted from ICPSS Package 9A Flood Maps) 4.4 PLANNING AND FLOOD RISK MANAGEMENT GUIDELINES Cork County Development plan (2014) The Cork County Development Plan ( ) provides general guidance in relation to the consideration of flood risk in planning decisions. It states that vulnerable land uses should be located away from flood prone areas and developments should not exacerbate flooding through their affects on the flood plains, rivers and drainage. There are a number of objectives relating to flood risk outlined in Section 11 of the Development Plan including: Objective WS 5-1: Surface Water and SuDS Ensure that all new developments incorporate sustainable drainage systems (SuDS). EPA Export :23:31:51

31 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment Objective WS 5-2: River Channel Protection Ensure that where practical, development is kept at 10m or other appropriate distance from stream and river banks and adequate protection measures put in place. Objective WS 5-3: Surface Water Management Manage surface water catchments and the use and development of lands adjoining streams, watercourses and rivers in such a way as to minimise damage to property by instances of flooding and with regard to any conservation objectives of European sites within the relevant catchments and floodplains. Objective WS 6-1: Flood Risks Overall Approach Take the following approach in order to reduce the risk of new development being affected by possible future flooding: Avoid development in areas at risk of flooding; and Where development in floodplains cannot be avoided, to take a sequential approach to flood risk management based on avoidance, reduction and mitigation of risk. In areas where there is a high probability of flooding Zone A - it is an objective of this plan to avoid development other than water compatible development as described in Section 3 of The Planning System and Flood Risk Management Guidelines for Planning Authorities issued in November 2009 by DoEHLG. In areas where there is a moderate probability of flooding Zone B it is an objective of this plan to avoid highly vulnerable development described in section 3 of The Planning System and Flood Risk Management Guidelines for Planning Authorities issued in November 2009 by DoEHLG. Implement the recommendations of the South Western CFRAM study. The preference, as outlined in Section 11 of the development plan, should always be to avoid flood risk and the Sequential Approach, as outlined in The Planning System and Flood Risk Management Guidelines, should be implemented when considering developments in flood risk areas. The development plan aims to ensure that structures and earthworks are not, if possible, located or designed to interfere with natural river courses and floodplains; and to reduce insofar as possible the rate and quantity of surface water run-off. EPA Export :23:31:51

32 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment Where development in flood risk areas cannot be avoided, or substituted with a land use which is less vulnerable to flooding, then the development plan proposes that the Justification Test should be implemented and appropriate mitigation measures be put in place Planning & Flood Risk Management Guidelines The County Development Plan requires that regard be given to The Planning System and Flood Risk Management. For the purpose of this report the guidelines have been abbreviated to PSFRM Guidelines. The Department of Environment, Heritage and Local Government and the Office of Public Works (OPW) issued The Planning System and Flood Risk Management Guidelines for Planning Authorities and Technical Appendices in November These guidelines outline a three staged approach to be adopted in carrying out flood risk appraisals. The stages of appraisal and assessment are: Stage 1 Flood risk identification Stage 2 Initial flood risk assessment Stage 3 Detailed flood risk assessment Due to the proximity of the site to the River Lee and some minor drainage features, the site would benefit from further assessment. Therefore, in accordance with the guidelines, this flood risk assessment has been carried out as a Stage 2 Assessment Initial flood risk assessment Sequential Approach and Justification Test The guidelines are based on the Sequential Approach to the management of flood risk in relation to planning decisions. The Planning System and Flood Risk Management Guidelines recommend that the Sequential Approach is applied as follows: Avoid development in flood risk areas where possible. Substitute the type of development by a type which is not especially vulnerable to flooding Justify that the development is being considered for strategic reasons Mitigate to ensure flood risk is reduced to acceptable levels Proceed only when Justification Test is passed. Ensure emergency planning measures are in place. The three Flood Zones, as outlined by the Planning System and Flood Risk Management Guidelines for the purpose of implementing the Sequential Approach and Justification Test, are summarised in Table 4.3. Flood Zone Probability of Flooding (Return Periods) Recommendation based on Vulnerability of Development Highly Vulnerable Less Vulnerable Water Compatible EPA Export :23:31:51

33 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment Highest Probability A Fluvial: more frequent than 1 in 100-yr Coastal: more frequent than 1 in 200-yr Justification Test Justification Test Appropriate B Moderate Probability Fluvial: 1 in 100-yr to 1 in 1000-yr Coastal: 1 in 200-yr to 1 in 1000-yr Justification Test Appropriate Appropriate Low Probability C Fluvial: less frequent than 1 in 1000-yr Coastal: less frequent than 1 in 1000-yr Appropriate Appropriate Appropriate Note: The PSFRM Guidelines provide probabilities for fluvial and tidal flooding. For clarity only river flooding probabilities have been included in this table Table 4.3 Matrix of vulnerability versus flood zone to illustrate appropriate development and that are required to meet the Justification Test (Extract from the PSFRM Guidelines) 4.5 IMPACT OF DEVELOPMENT ON FLOODING The PSFRM Guidelines Table 3.1 states that developments with potential significant sources of pollution are Highly Vulnerable. Although any sources of pollution will be contained within bunded areas, for the purposes of this report this site is classified as highly vulnerable Local Surface Water Runoff The flood level of 3.54mOD is a tidal level and may be exacerbated if high surface water flows coincide with a period of high sea levels. If this is the case, local runoff to the drainage basins north and south of the N25, east of the M8/N25 interchange may increase the flood level locally beyond 3.54mOD. Normal drainage from the area will be from the basin south of the N25 to the basin north of the N25 to the sea. When the tide level is high at 3.54mOD, the outlet to the sea is restricted. Surface water draining from the north basin catchment will affect levels in both the north basin and south basin due to backflow, with the levels in the south basin further increased by runoff from its own catchment. It is therefore necessary to estimate the effect of this surface water flow will have on the flood level locally. Drainage Basin to the North of the N25 The drainage basin catchment area north of the N25 has been estimated as 253ha (Based on contours from Discovery Mapping). We have calculated the surface water runoff from a 2% AEP (50-year) 6 hour storm (The Lee CFRAM 0.1% AEP tidal design event was based on the joint probability of a 2% AEP EPA Export :23:31:51

34 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment fluvial coinciding). It is estimated, that this rainfall event would result in a flow of 5.8m 3 /s to the north and south basin (as a result of backflow). The area of the combined drainage basins is approximately 5.2ha from aerial photography, but the top surface area increases to approximately 37ha as the level increases to 3.54mOD (estimated from ICPSS flood maps for the 0.1% tidal AEP). Based on the latter area, the increase in flood level from a flow of 5.8m 3 /s over 6 hours would be in the order of 0.3m across the north and south basin. Drainage Basin to the South of the N25 The south basin would also be impacted from local surface water flows from its own catchment. The drainage basin catchment area south of the N25 has been estimated as 95ha (Based on contours from Discovery Mapping). We have calculated the surface water runoff from a 2% AEP (50-year) 6 hour storm as per the above. A flow of 1.4m 3 /s to the drainage basin would result. The area of the south basin is approximately 1.7ha from aerial photography, but the top surface area increases to approximately 13.9ha as the level increases to 3.54mOD (area estimated from ICPSS flood maps for the 0.1% tidal AEP). Based on the latter area, the increase in flood level from a flow of 1.4m 3 /s over 6 hours would be in the order of 0.3m. Therefore the overall rise in flood level across the flood plain south of the N25 is 0.6m which would equate to a level of 4.14mOD Malin. When combined with the estimated level for the 0.1% tidal AEP, the site would be 3.66m above this flood level and at low risk of flooding Encroachment into the floodplain Based on the 0.1% AEP (1000-year) flood level provided in the Lee CFRAMS and the ICPSS, the estimated MRFS tidal flood level is 3.54mOD. It is proposed to raise the site to a level of 7.8mOD by raising site levels. This will include raising approximately 0.09ha of land currently located within the 1,000-year floodplain, as estimated from the Lee CFRAMS and ICPSS. The floodplain for the drainage basin, south of the N25 is roughly estimated to be 35ha (based on the flooding extent from the ICPSS). The percentage of the floodplain removed due to development is 0.3%. It is estimated, due to the minimal encroachment into the flood plain (i.e. <0.5%), that there proposed development will have an imperceptible impact on flood levels Conclusion In accordance with guidelines and recommendations it has been determined that the developed site will be in Flood Zone C. A planning application for a highly vulnerable development in a Flood Zone C category is considered appropriate. Objective WS 5-2 of the Cork County Development Plan requires where practical that development be kept at 10m or other appropriate distance from stream and river banks and adequate protection measures put in place. The site embankment is 10m from Drainage Channel 2 but will be within its floodplain and as such will be constructed to withstand erosion from such flood events. EPA Export :23:31:51

35 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment Grading of the lower level area maybe required such that it is easily drained into Drainage Channel 2 following surface water events to avoid standing water at the base of the embankment. The development will be discharging into the existing surface water sewer at greenfield rates and will not increase surface water runoff. SUDs methods and rainwater harvesting will be provided where practicable. Following completion of the preliminary flood risk assessment 5.0 SUMMARY AND CONCLUSIONS TOBIN Consulting Engineers have undertaken a site specific Flood Risk Assessment on behalf of Stream BioEnergy for their proposed development at Inchera, Litttle Island, Cork. The Flood Risk Assessment undertook a review of: 1) The Planning System and Flood Risk Management Guidelines 2) Cork County Development Plan ( ) 3) OPW Flood Hazard Mapping 4) Irish Coastal Protection Strategy Study 5) The Lee Catchment Flood Risk Assessment and Management (CFRAM) Study It was found that: Two open channel drains are present close to the eastern boundary of the site The site is located approximately 150m from the River Lee at Lough Mahon Drainage Channels 1 and 2 along the eastern boundary of the site are affected by backwatering from the sea. The levels along the eastern boundary of the site are also a trap for surface water runoff and could aid standing water. The Irish Coastal Protection Strategy Study (ICPSS) and the Lee CFRAMS provides flood extent mapping as follows: o o Mid-Range Future Scenario (ICPSS & CFRAMS) High End Future Scenario (ICPSS) The mapping shows that the north east corner of the site is located within the 200-year and 1,000-year flood extents for both of these future scenarios. MRFS flood levels are approx 3.54mOD. Existing Levels at the site are predominately above this flood level except for the north east corner of the site (2.0mOD). Approximately 0.2ha of the site would be inundated. The proposed site is proposed to extend 0.09ha into the floodplain at a level of 7.8mOD Malin The floodplain for the drainage basin, south of the N25 is roughly estimated to be 35ha. The percentage of the floodplain removed due to development is 0.3% and as such will not significantly increase the risk of flooding at the proposed site or elsewhere. EPA Export :23:31:51

36 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment Surface water runoff from the local catchment to the drainage basins adjacent to the N25 has been estimated for the 2% AEP 6 hour event and will increase the 0.1% tidal flood level in the vicinity of the site by 0.6m to 4.14m. The level of the site is at 7.8mOD and as such is at low risk of flooding The type of development is defined as Highly Vulnerable Development by the Planning System and Flood Risk Management (PSFRM) Guidelines due to having sources of potential pollution The developed site will be located in Flood Zone C and the development is assumed to be appropriate. The development will be discharging into the existing surface water sewer at greenfield rates and will not increase surface water runoff into Lough Mahon. EPA Export :23:31:51

37 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment APPENDIX A OPW Flood Hazard Information EPA Export :23:31:51

38 Summary Local Area Report This Flood Report summarises all flood events within 2.5 kilometres of the map centre. The map centre is in: County: Cork NGR: W This Flood Report has been downloaded from the Web site The users should take account of the restrictions and limitations relating to the content and use of this Web site that are explained in the Disclaimer box when entering the site. It is a condition of use of the Web site that you accept the User Declaration and the Disclaimer. Map Legend Flood Points Multiple / Recurring Flood Points Areas Flooded Hydrometric Stations Rivers 1 Result Map Scale 1:62,129 Lakes River Catchment Areas Land Commission * Drainage Districts * Benefiting Lands * * Important: These maps do not indicate flood hazard or flood extent. Thier purpose and scope is explained in the Glossary. 1. Glounthaune Oct 2004 Start Date: 27/Oct/2004 County: Cork Flood Quality Code: 4 Additional Information: Reports (1) More Mapped Information Report Produced: 16-Feb :39 EPA Export :23:31:51

39 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment APPENDIX B Lee CFRAM Study Flood Extent Maps EPA Export :23:31:51

40 Government of Ireland OSi permit number EN Water Level (mod) per AEP Node Label WL 10% WL 0.5% WL 0.1% Location Plan : 4GLA_ ± 4GLA_0! EXTENT MAP Legend: 10 % AEP Flood Extent (1 in 10 chance in any given year) 0.5 % AEP Flood Extent (1 in 200 chance in any given year) 0.1 % AEP Flood Extent (1 in 1000 chance in any given year) Defended area High Confidence (<20m) (10% AEP) Medium Confidence (<40m) (10% AEP) Low Confidence (> 40m) (10% and 0.1% AEP)! High Confidence (<20m) (0.5% AEP) Medium Confidence (<40m) (0.5% AEP) Low Confidence (>40m) (0.5% AEP) River Centreline Node Point Node Label (refer to table) USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Halcrow Group Ireland 3A Eastgate Road Eastgate Little Island Cork Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland Project : LEE CATCHMENT FLOOD RISK ASSESSMENT AND MANAGEMENT STUDY Map : CORK CITY Map Type : Source : Map area : Scenario : FLOOD EXTENT TIDAL FLOODING URBAN AREA CURRENT Figure By : Valeria Medina Checked By : Paul Dunne Approved By : Clare Dewar Date : 21 June 2012 Date : 21 June 2012 Date : 21 June Kilometres Figure No. : M9/UA/EXT/CURS/007 Drawing Scale : 1:5,000 Revision 1 Plot Scale : A3 EPA Export :23:31:51

41 Government of Ireland OSi permit number EN Location Plan : ± EXTENT MAP Legend: 10 % AEP Flood Extent (1 in 10 chance in any given year) 0.5 % AEP Flood Extent (1 in 200 chance in any given year) 0.1 % AEP Flood Extent (1 in 1000 chance in any given year) Defended area High Confidence (<20m) (10% AEP) Medium Confidence (<40m) (10% AEP) 001 Low Confidence (> 40m) (10% and 0.1% AEP) High Confidence (<20m) (0.5% AEP) Medium Confidence (<40m) (0.5% AEP) Low Confidence (>40m) (0.5% AEP) River Centreline Node Point Node Label (refer to table) USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Halcrow Group Ireland 3A Eastgate Road Eastgate Little Island Cork Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland Kilometres Project : LEE CATCHMENT FLOOD RISK ASSESSMENT AND MANAGEMENT STUDY Map : LITTLE ISLAND Map Type : FLOOD EXTENT Source : TIDAL FLOODING Map area : URBAN AREA Scenario : CURRENT Figure By : Checked By : Approved By : Figure No. : Valeria Medina Paul Dunne Clare Dewar Date : 21 June 2012 Date : 21 June 2012 Date : 21 June 2012 Revision M9/UA/EXT/CURS/008 Drawing Scale : 1:5,000 1 Plot Scale : A3 EPA Export :23:31:51

42 Government of Ireland OSi permit number EN ± Water Level (mod) per AEP Node Label WL 10% WL 0.5% WL 0.1% Location Plan : EXTENT MAP Legend: 10 % AEP Flood Extent (1 in 10 chance in any given year) 0.5 % AEP Flood Extent (1 in 200 chance in any given year) 0.1 % AEP Flood Extent (1 in 1000 chance in any given year) Defended area High Confidence (<20m) (10% AEP) Medium Confidence (<40m) (10% AEP) 001 Low Confidence (> 40m) (10% and 0.1% AEP) High Confidence (<20m) (0.5% AEP) Medium Confidence (<40m) (0.5% AEP) Low Confidence (>40m) (0.5% AEP) River Centreline Node Point Node Label (refer to table) USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Halcrow Group Ireland 3A Eastgate Road Eastgate Little Island Cork Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland ! 008 Kilometres Project : LEE CATCHMENT FLOOD RISK ASSESSMENT AND MANAGEMENT STUDY Map : LITTLE ISLAND Map Type : FLOOD EXTENT Source : TIDAL FLOODING Map area : URBAN AREA Scenario : CURRENT Figure By : Checked By : Approved By : Figure No. : Valeria Medina Paul Dunne Clare Dewar Date : 21 June 2012 Date : 21 June 2012 Date : 21 June 2012 Revision M9/UA/EXT/CURS/009 Drawing Scale : 1:5,000 1 Plot Scale : A3 EPA Export :23:31:51

43 Government of Ireland OSi permit number EN Water Level (mod) per AEP Node Label WL 10% WL 0.5% WL 0.1% Location Plan : 4GLA_ ± 4GLA_0! EXTENT MAP Legend: 10 % AEP Flood Extent (1 in 10 chance in any given year) 0.5 % AEP Flood Extent (1 in 200 chance in any given year) 0.1 % AEP Flood Extent (1 in 1000 chance in any given year) High Confidence (<20m) (10% AEP) Medium Confidence (<40m) (10% AEP) Low Confidence (> 40m) (10% and 0.1% AEP) High Confidence (<20m) (0.5% AEP)! Medium Confidence (<40m) (0.5% AEP) Low Confidence (>40m) (0.5% AEP) River Centreline Node Point Node Label (refer to table) USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Halcrow Group Ireland 3A Eastgate Road Eastgate Little Island Cork Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland Project : LEE CATCHMENT FLOOD RISK ASSESSMENT AND MANAGEMENT STUDY Map : CORK CITY Map Type : FLOOD EXTENT Source : TIDAL FLOODING Map area : URBAN AREA Scenario : MID RANGE FUTURE SCENARIO Figure By : Valeria Medina Date : 25 June 2012 Checked By : Paul Dunne Approved By : Clare Dewar Date : 25 June 2012 Date : 25 June Kilometres Figure No. : M9/UA/EXT/MRFS/007 Drawing Scale : 1:5,000 Revision 1 Plot Scale : A3 EPA Export :23:31:51

44 Government of Ireland OSi permit number EN Location Plan : ± EXTENT MAP Legend: 10 % AEP Flood Extent (1 in 10 chance in any given year) 0.5 % AEP Flood Extent (1 in 200 chance in any given year) 0.1 % AEP Flood Extent (1 in 1000 chance in any given year) High Confidence (<20m) (10% AEP) Medium Confidence (<40m) (10% AEP) Low Confidence (> 40m) (10% and 0.1% AEP) 001 High Confidence (<20m) (0.5% AEP) Medium Confidence (<40m) (0.5% AEP) Low Confidence (>40m) (0.5% AEP) River Centreline Node Point Node Label (refer to table) USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Halcrow Group Ireland 3A Eastgate Road Eastgate Little Island Cork Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland Project : LEE CATCHMENT FLOOD RISK ASSESSMENT AND MANAGEMENT STUDY Map : LITTLE ISLAND Map Type : FLOOD EXTENT Source : TIDAL FLOODING Map area : URBAN AREA Scenario : MID RANGE FUTURE SCENARIO Figure By : Valeria Medina Date : 25 June 2012 Checked By : Paul Dunne Approved By : Clare Dewar Date : 25 June 2012 Date : 25 June Kilometres Figure No. : M9/UA/EXT/MRFS/008 Drawing Scale : 1:5,000 Revision 1 Plot Scale : A3 EPA Export :23:31:51

45 Government of Ireland OSi permit number EN ± Water Level (mod) per AEP Node Label WL 10% WL 0.5% WL 0.1% Location Plan : EXTENT MAP Legend: 10 % AEP Flood Extent (1 in 10 chance in any given year) 0.5 % AEP Flood Extent (1 in 200 chance in any given year) 0.1 % AEP Flood Extent (1 in 1000 chance in any given year) High Confidence (<20m) (10% AEP) Medium Confidence (<40m) (10% AEP) Low Confidence (> 40m) (10% and 0.1% AEP) 001 High Confidence (<20m) (0.5% AEP) Medium Confidence (<40m) (0.5% AEP) Low Confidence (>40m) (0.5% AEP) River Centreline Node Point Node Label (refer to table) USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Halcrow Group Ireland 3A Eastgate Road Eastgate Little Island Cork Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland! 008 Project : LEE CATCHMENT FLOOD RISK ASSESSMENT AND MANAGEMENT STUDY Map : LITTLE ISLAND Map Type : FLOOD EXTENT Source : TIDAL FLOODING Map area : URBAN AREA Scenario : MID RANGE FUTURE SCENARIO Figure By : Valeria Medina Date : 25 June 2012 Checked By : Paul Dunne Approved By : Clare Dewar Date : 25 June 2012 Date : 25 June Kilometres Figure No. : M9/UA/EXT/MRFS/009 Drawing Scale : 1:5,000 Revision 1 Plot Scale : A3 EPA Export :23:31:51

46 Proposed Renewable Bioenergy Plant, Preliminary Flood Risk Assessment APPENDIX C ICPSS Flood Extent Maps EPA Export :23:31:51

47 Location Plan : Government of Ireland Osi permit number EN ± NOTE : MORE DETAILED MAPS SHOWING COMBINED TIDAL AND FLUVIAL FLOOD HAZARD FOR THIS AREA HAVE BEEN PREPARED UNDER THE LEE CFRAM STUDY. PLEASE REFER TO FOR MORE INFORMATION EXTENT MAP Legend: 0.5% AEP FLOOD EXTENT (1 in 200 chance in any given year) 0.1% AEP FLOOD EXTENT (1 in 1000 chance in any given year) High Water Mark (HWM) Node Point S 34 Node Label (refer to table)! C_3 USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Elmwood House 74 Boucher Road Belfast BT 12 6RZ Northern Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland Water Level (mod Malin) per AEP Node Label WL 10% WL 0.5% WL 0.1% C_ Project : IRISH COASTAL PROTECTION STRATEGY STUDY - PHASE III Map : SOUTH COAST FLOOD EXTENT MAP Map Type : FLOOD EXTENT Source : TIDAL FLOODING Map area : RURAL AREA Scenario : MID RANGE FUTURE SCENARIO Figure By : PJW Date : Dec 2011 Checked By : JMC & JR Date : Dec 2011 Figure No. : S / RA / EXT / MRFS / 33 Revision 1 Drawing Scale : 1:25,000 Plot Scale : A Kilometers EPA Export :23:31:51

48 Location Plan : Government of Ireland Osi permit number EN ± NOTE : MORE DETAILED MAPS SHOWING COMBINED TIDAL AND FLUVIAL FLOOD HAZARD FOR THIS AREA HAVE BEEN PREPARED UNDER THE LEE CFRAM STUDY. PLEASE REFER TO FOR MORE INFORMATION EXTENT MAP Legend: 0.5% AEP FLOOD EXTENT (1 in 200 chance in any given year) 0.1% AEP FLOOD EXTENT (1 in 1000 chance in any given year) High Water Mark (HWM) Node Point S 34 Node Label (refer to table)! C_3 USER NOTE : USERS OF THESE MAPS SHOULD REFER TO THE DETAILED DESCRIPTION OF THEIR DERIVATION, LIMITATIONS IN ACCURACY AND GUIDANCE AND CONDITIONS OF USE PROVIDED AT THE FRONT OF THIS BOUND VOLUME. IF THIS MAP DOES NOT FORM PART OF A BOUND VOLUME, IT SHOULD NOT BE USED FOR ANY PURPOSE. Elmwood House 74 Boucher Road Belfast BT 12 6RZ Northern Ireland Office of Public Works Lower Hatch Street Dublin 2 Ireland Water Level (mod Malin) per AEP Node Label WL 10% WL 0.5% WL 0.1% C_ Project : IRISH COASTAL PROTECTION STRATEGY STUDY - PHASE III Map : SOUTH COAST FLOOD EXTENT MAP Map Type : FLOOD EXTENT Source : TIDAL FLOODING Map area : RURAL AREA Scenario : HIGH END FUTURE SCENARIO Figure By : PJW Date : Sept 2012 Checked By : JMC & JR Date : Sept 2012 Figure No. : S / RA / EXT / HEFS / 33 Revision 0 Drawing Scale : 1:25,000 Plot Scale : A Kilometers EPA Export :23:31:51

49 ATTACHMENT N O I EXISTING ENVIRONMENT ATTACHMENT I.3 - ASSESSMENT OF IMPACT OF SEWAGE DISCHARGE A comprehensive description of the foul drainage system is provided in Attachment F.1 of this application, in Chapter 2 (section ) of the EIS (Volume II) and in Section 7 of the Engineering Services Report presented in Appendix 2-1 of the EIS (Volume III). The proposed foul water drainage layout is presented on Drawing In summary, all process liquid will be diverted to and treated in an on-site process effluent treatment plant with the likely treatment process being reverse osmosis (RO). This is a physical purification technique that uses a membrane as a physical barrier which acts as a molecular sieve retaining the high solute concentrate (permeate) and allowing water to infiltrate. The permeate is recycled into the main process and is used to dilute the incoming feedstock. Excess treated process effluent that is not required for the process will be discharged via gravity to the existing municipal sewer at the south western boundary of the application site. It is estimated that up to 200m 3 /day of treated process effluent will be discharged to the sewer from emission point SE1. This effluent will have a significantly reduced organic loading following the treatment in the on-site process effluent treatment plant, with a maximum population equivalent of approximately 750 (based on 1 PE = 54g of BOD per day). The characteristics of the emission are presented in Table E.3 (ii) of this application. Wastewater effluent from welfare facilities and washwater discharged from the wheel wash will be discharged directly to the municipal foul sewer network. It is estimated that a total volume of 11m 3 per day will be discharged. It should be noted that washwater from the washing of the main building floor will be captured and recycled directly to the AD process. Impacts Waste water treatment works can affect the environment through unmanaged releases of waste water and sludge. These may cause land contamination, pollution of surface water and/or groundwater, and public nuisance due to odour. Proposed Renewable BioEnergy Plant I-16 Little Island BioEnergy Ltd. EPA Export :23:31:51

50 ATTACHMENT N O I EXISTING ENVIRONMENT During normal operating conditions it is not proposed to discharge process liquid or effluent/wastewater to the surface water drainage network therefore there will be no impact on the mass balance and assimilative capacity in the receiving surface water bodies. The elements that make up the proposed process effluent treatment plant will be contained within the main building. Should there be any breach in the plant, the released material would be contained within building and redirected back into the AD process. All tanks associated with the treatment of process effluent will be covered and will be vented to the odour control system thus preventing the escape of fugitive odours. Flow rates from each of the tanks are included in the ventilation strategy for the plant and were inputted into the dispersion model. The maximum predicted odour concentration anywhere in the vicinity of the proposed plant (including inside and outside the boundary of the facility and within the fine grid area of 16 km sq. and a course grid area of 306 km sq.) will be less than or equal to 0.20 Ou E/m 3 for the 98 th percentile of hourly averages for the worst case meteorological year Cork Airport This is 13% of the worst case odour impact criterion of 1.5 Ou E/m 3 stated in Irish EPA Guidance AG4 (page 70). The following BAT measures will be implemented on site during the operational phase in order to minimise the accidental uncontrolled discharge of process effluent which could have an effect on the local watercourse quality or groundwater: Daily checks on the effluent management system and maintenance of a log of all checks; The plant s SCADA system will continuously monitor the process effluent treatment plant and will detect any system faults; effluent discharge; Procedures for avoiding effluent by-passing the treatment plant systems, and Reusing treated waste waters in the process. Compliance with Article 15 of IED Directive The environment as a whole is provided an equivalent level of protection and will not lead to higher levels of pollution as a dedicated process effluent treatment plant will be utilised on site Proposed Renewable BioEnergy Plant I-17 Little Island BioEnergy Ltd. EPA Export :23:31:51

51 ATTACHMENT N O I EXISTING ENVIRONMENT to treat process effluent. Any effluent not recycled back into the process would be discharged to the existing municipal foul water network at one point (SE1) only from the site. The process effluent treatment plant utilises RO technology which reduces ammonia, BOD and solids from the liquid stream such that the treated liquid is of suitable quality to be recycled to the incoming feedstock in the twin shaft shredders, in order to reduce the dry solids concentration of the incoming material or to be discharged to the municipal foul water network for further treatment at the municipal WwTP at Carrigrennan. Proposed Renewable BioEnergy Plant I-18 Little Island BioEnergy Ltd. EPA Export :23:31:51

52 ATTACHMENT N O I EXISTING ENVIRONMENT ATTACHMENT I.4 - ASSESSMENT OF IMPACT OF GROUND/GROUNDWATER EMISSIONS An assessment of soils and geology was prepared by O Callaghan, Moran and Associates and is presented in Chapter 12 of the EIS (Volume II). A hydrogeological assessment was undertaken by Environmental Risk Solutions (ERS) Ltd. and is presented in Chapter 13 of the EIS (Volume II). Both chapters should be read in conjunction with this application. Baseline Report The Industrial Emissions Directive (2010/75/EU) or IED entered into force within the European Union on 6 January For industrial activities regulated by the IED, such as the proposed development, Article 22(2) of Chapter II of the IED states that: Where the activity involves the use, production or release of relevant hazardous substances and having regard to the possibility of soil and groundwater contamination at the site of the installation, the operator shall prepare and submit to the competent authority a baseline report before starting operation of an installation or before a permit for an installation is updated for the first time after 7 January The baseline report shall contain the information necessary to determine the state of soil and groundwater contamination so as to make a quantified comparison with the state upon definitive cessation of activities provided for under paragraph 3. Article 22(2) was transposed into Irish national law on 23 April 2013 by the European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013) and resulting amendments to the Environmental Protection Agency Act A Baseline Report has been prepared in accordance with section 86B of the EPA Act and the European Commission s Guidance concerning baseline reports under Article 22(2) of Directive 2010/75/EU on industrial emissions (2014) and is presented at the end of this section. Proposed Renewable BioEnergy Plant I-19 Little Island BioEnergy Ltd. EPA Export :23:31:51

53 Existing Groundwater Quality ATTACHMENT N O I EXISTING ENVIRONMENT Table 1.4 (i) describes the existing groundwater quality at the application site and is presented in the main application form. Ground and Groundwater Impacts and Mitigation A Soils and Geology Assessment and Hydrology and Hydrogeology Assessment are presented in Chapters 12 and 13 of the EIS (Volume II) that accompanies this application. There are no direct or planned discharges to ground or groundwater included as part of the proposed development. The avoidance of impacts is integral to the design and operation of the proposed Plant. However, during the operational phase potential impacts may arise due to the accidental or uncontrolled discharge of hydrocarbons, chemicals, process water or effluent to ground and which may impact on the groundwater quality in the underlying aquifer. To minimise any contamination risk arising from the proposed development the following mitigation measures will be implemented: All process areas of the site will be located either within buildings with paved floors or on paved ground and there will be no direct access to the subsoils for any rain-water or other surface water run-off in the process areas. Impermeable surfacing will extend across the entire site. All chemicals at the site will be stored under cover in a bunded area or in double skinned storage tanks; All fuels will be stored in bunded tanks with the provision of a storage/retention capacity of 110% of tank storage volume and will be stored in a designated area; All process liquor/effluent will be circulated in enclosed pipes and stored in covered tanks. The tanks will be located in areas which are bunded to 110% of the largest tank capacity; All storage tanks will be located in appropriately sized and constructed bunds, whose design complies with the Agency s Guidance Note on the Storage and Transfer of Materials (EPA 2004); All onsite vehicles will be regularly maintained and checked to ensure any damages or leakages are repaired; Proposed Renewable BioEnergy Plant I-20 Little Island BioEnergy Ltd. EPA Export :23:31:51

54 ATTACHMENT N O I EXISTING ENVIRONMENT All process effluent will be treated on site and recycled or discharged under consent from the EPA to the local foul sewer network; Process water from the wheelwash will be discharged off site to the foul sewer network; Wash-down water from the building floor will be captured and directed back into the digestion process; Rainfall runoff from roofs, the bunded tank farm, roads and hardstand areas will be harvested and reused on-site. Any excess runoff will be discharged to the local stormwater sewer network following attenuation and treatment in a hydrocarbon interceptor. There will be no discharge of stormwater runoff to ground; The Plant is designed so that in the event of a major accident at the facility, all contaminated runoff will be retained on site for appropriate treatment and disposal; and All unloading of waste material and all processing at the site will be undertaken indoors under cover on a contained concrete surface to ensure that no contamination escapes to ground. Any soil contaminated from an accidental spillage will be contained and treated appropriately and in accordance with the Waste Management Act These mitigation measures will reduce the risk of contamination to the underlying soil and bedrock environments and groundwater as a result of the operation of the proposed Plant. The mitigation measures incorporated into the design and operation of the facility will ensure that any residual impact on the soils and geology and groundwater of the area will be imperceptible and neutral. Proposed Renewable BioEnergy Plant I-21 Little Island BioEnergy Ltd. EPA Export :23:31:51

55 LITTLE ISLAND B I O E N E R G Y BASELINE REPORT BASELINE REPORT EPA Export :23:31:51

56 Little Island BioEnergy Limited Proposed Renewable Bioenergy Plant at. Baseline Report July 2015 EPA Export :23:31:51

57 BASELINE REPORT CONTENTS 1. INTRODUCTION... 1 Background... 1 Requirement for Baseline Report... 2 Objectives and Scope of the Report HAZARDOUS SUBSTANCES SITE HISTORY... 6 Development History... 6 Relevant Hazardous Substances... 6 Historical Site Investigations ENVIRONMENTAL SETTING & SITE INVESTIGATION Topography Made Ground, Subsoils & Depth to Bedrock Surface Water Groundwater SITE SPECIFIC POLLUTION POSSIBILITY CONCLUSIONS FIGURES APPENDIX TABLES Table 1 Hazardous Substances to be used at the Proposed Facility... 5 Table 3 Environmental Sample Analysis PLATES Plate 1 Trends in Chloroform Concentration in BH Plate 2 Trend in MBTE Concentration in Well Plate 3 Schematic of Surface Water Drainage System Flow EPA Export :23:31:51

58 BASELINE REPORT FIGURES Figure 1 Regional Site Location Map Figure 2 Proposed Site Layout Plan and Emission Points Figure 3a Proposed Stormwater Drainage Layout Figure 3b Proposed Foul Sewer Drainage Layout Figure 4 Former Location of RHSs, Trial Pits and Wells at Pfizer Plant Figure 5 Existing Site Layout Plan, Topo & Structures Proposed for Demolition Figure 6 Teagasc Subsoils Figure 7 GSI Quaternary Sub-Soils Figure 8 Bedrock Geology Map Figure 9 Trial Pit, Borehole & CBR Locations (IGSL Ground Investigations, 2015) Figure 10 Aquifer Classification & GSI Borehole Records Figure 11 Groundwater Vulnerability Figure 12 Conceptual Site Model APPENDIX Appendix 1 Engineering Services Report Appendix 2 Laboratory Report Appendix 3 Tapella IPPC Licence (PO103-03) Surrender Report EPA Export :23:31:52

59 BASELINE REPORT 1. INTRODUCTION Background Little Island BioEnergy Ltd. (LIBE) proposes to construct and operate a Renewable Bioenergy Plant that will generate up to 4MW of renewable electricity from 90,000 tonnes per annum (tpa) of non-hazardous biodegradable waste, utilising anaerobic digestion (AD) technology. The plant will be located at see Figure 1. In summary, the proposed 90,000 tonne per annum plant will comprise the following: The Main Building will be divided up internally to contain the feedstock reception and pre-treatment areas, quarantine area, digestate dewatering and storage areas and effluent treatment area. An odour control system and stack will be located immediately adjacent to this building. The building will be approximately 14m tall in order to accommodate delivery/removal vehicles and to contain equipment used to treat the waste, and ventilation ductwork. The Tank Farm will be bunded and shall contain the pre-treatment, digestion, pasteurisation, process water, concentrate and chemical storage tanks. The tallest tanks will be approximately 24m to the highest point. The Biogas Treatment Area will incorporate the combined heat and power (CHP) units consisting of 2 x 2MW engines and associated stack, a biogas holder, a standby gas flare, a boiler and associated stack and gas treatment facilities including a gas booster and gas dryer. An Administration Building incorporating a reception area welfare facilities, canteens, offices, meeting and training rooms, a laboratory, storage and first aid rooms, communications and control rooms. A number of ancillary structures will be located outside these areas and will include a bunded diesel refuelling area, a workshop, a boiler, a motor control centre (MCC) kiosk, an electrical substation, transformers, weighbridges and kiosk, wheelwash, pipe bridge, access stairways, walkways and gantries, car parking, lighting, fencing and security gates. The proposed development will be built on a re-profiled site with ground levels varying from 7.1mO.D to 8.15mO.D. This requires some areas of the site in the west and centre to be lowered by up to 1.5m and the eastern end of the site to be raised by up to 6m. Proposed Renewable Bioenergy Plant 1 Little Island BioEnergy Ltd. EPA Export :23:31:52

60 BASELINE REPORT A site plan and drainage layout drawings (illustrating the proposed location of emission to stormwater and sewer points) for the proposed facility are included as Figure 2 and Figures 3a and 3b. A planning application was submitted to Cork County Council (reg. ref ) on the 6 th May 2015 and is currently under consideration. The relevant activities in the First Schedule of the EPA Act 1992, as amended, to which the activity relates are as follows: 11.4 b) Recovery, or a mix of recovery and disposal, of non-hazardous waste with a capacity exceeding 75 tonnes per day involving one or more of the following activities, (other than activities to which the Urban Waste Water Treatment Regulations 2001 (S.I. No.254 of 2001) apply): (i) biological treatment c) Notwithstanding clause (b), when the only waste treatment activity carried out is anaerobic digestion, the capacity threshold for that activity shall be 100 tonnes per day. Requirement for Baseline Report The Industrial Emissions Directive (2010/75/EU) or IED entered into force within the European Union on 6 January For industrial activities regulated by the IED, such as the proposed development, Article 22(2) of Chapter II of the IED states that: Where the activity involves the use, production or release of relevant hazardous substances and having regard to the possibility of soil and groundwater contamination at the site of the installation, the operator shall prepare and submit to the competent authority a baseline report before starting operation of an installation or before a permit for an installation is updated for the first time after 7 January The baseline report shall contain the information necessary to determine the state of soil and groundwater contamination so as to make a quantified comparison with the state upon definitive cessation of activities provided for under paragraph 3. Article 22(2) was transposed into Irish national law on 23 April 2013 by the European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013) and resulting amendments to the Environmental Protection Agency Act Proposed Renewable Bioenergy Plant 2 Little Island BioEnergy Ltd. EPA Export :23:31:52

61 BASELINE REPORT Objectives and Scope of the Report The purpose of the Baseline Report is to summarise all of the evaluated information collected relating to soil and groundwater at the application site to produce a report which identifies the state of soil and groundwater contamination by relevant hazardous substances. This report has compiled the information available as of June 2015 related to soil and groundwater at the application site, which is required under Section 86(B) of the Environmental Protection Agency Act 1992, as amended. In producing this report Stages 1 to 8 as set out in the European Commission s Guidance concerning baseline reports under Article 22(2) of Directive 2010/75/EU on industrial emissions (2014) has been followed. First the report identifies the hazardous substances to be used, produced or released at the installation (Section 2). Those substances considered to be relevant hazardous substances (RHSs) and thus capable of having an adverse impact on soil or groundwater are set out within the report. The past use of the site is described in Section 3. RHSs previously stored at the site which correspond to those proposed to be used in the Renewable Bioenergy Plant are outlined and available information on historical soil and groundwater measurements is included. An outline of the environmental setting including surrounding land uses and information regarding the geological, hydrogeological and hydrological baseline that exists at the site is provided in Section 4. As is permitted by the Guidelines existing site investigation and water quality analysis is presented within this section of the report. An assessment of potential pollution risks at the site is presented in Section 5 taking account of the location of each substance on site and the method of storage and handling on site. Finally, the report concludes that sufficient control measures combined with the natural ground conditions at the site means that the operational phase of the proposed plant will not result in any deterioration in the existing soil or groundwater quality at the site. Proposed Renewable Bioenergy Plant 3 Little Island BioEnergy Ltd. EPA Export :23:31:52

62 BASELINE REPORT 2. HAZARDOUS SUBSTANCES Hazardous substances to be used at the proposed facility and which may cause contamination of soil and groundwater if not controlled are presented in Table 1 below. The relevant hazard statement associated with each substance as defined in Annex III of Regulation (EC) No 1272/2008 is also presented. The proposed location for the storage of each of these substances is presented on Figure 2. The proposed plant will not produce or release any hazardous substances which may contaminate soil or groundwater. Waste as defined in Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste is not a substance, mixture or article within the meaning of Article 2 of Regulation 1272/2008. Relevant Hazardous Substances (RHS) are those substances or mixtures which as a result of their hazardousness, mobility, persistence and biodegradability are capable of contaminating soil and groundwater. The substances presented in Table 1 are all considered as RHSs as they may pose a threat to both the soil and groundwater environment if there was for example an accidental release due to a rupture in a containment vessel. However, the design of the proposed plant incorporates extensive mitigation measures that will ensure that the risk to the environment (soil and groundwater) is negligible. Further details are provided under the Site Specific Pollution Possibility section of this report. Proposed Renewable Bioenergy Plant 4 Little Island BioEnergy Ltd. EPA Export :23:31:52

63 BASELINE REPORT Table 1 Hazardous Substances to be used at the Proposed Facility Material Amount Stored Annual Usage Nature of Use Location on Site (See Figure 2) Diesel Oil 2,500 L 30,000 L Refuelling onsite vehicles 4 Caustic Soda (Sodium Hydroxide) 48m 3 65 T Chemical used to control ph in organic slurry post pasteurisation Polyelectrolyte 2 T 15 T Required for dewatering process 9 Ferric Sulphate 48m T Sulphuric Acid 48m T Hydrogen Peroxide 48m T Chemical used to reduce the formation of hydrogen sulphide in grit removal tanks and digesters Chemical used at the pasteurisation stage to acidify the slurry to prevent emissions of ammonia. Chemical used at the pasteurisation stage to assist with slurry stabilisation Storage Conditions Dedicated selfbunded fuel storage tank Double walled tank Intermediate Bulk Container (IBC) under cover Double walled tank Double walled tank Double walled tank Hazard Statement (H-) 226,304,315,322, , ,312, , 315, 318, 335 Proposed Renewable Bioenergy Plant 5 Little Island BioEnergy Ltd. EPA Export :23:31:52

64 BASELINE REPORT 3. SITE HISTORY Development History The application area of circa 2 hectares was originally developed in 1973 and was acquired from Pharmacia by Pfizer in Pfizer Cork Ltd (PCL) operated a pharmaceutical plant at the subject site. Pfizer was granted an Integrated Pollution Control (IPC) Licence (Reg. No. P ) by the Environmental Protection Agency (EPA) on 28th November 1996 for the manufacture of pesticides, pharmaceutical or veterinary products and their intermediates. In February 2007, the IPC licence was reviewed and replaced by an Integrated Pollution Prevention Control (IPPC) Licence (Reg. No. P ) issued on 21st January The installation produced bulk pharmaceutical intermediate active products. PCL ceased manufacturing operations in March In January 2012 PCL announced the sale of the site to Tapella Limited. A licence transfer application was subsequently made to the EPA by PCL and Tapella in May A planning application for the demolition of redundant industrial buildings, structures, plant and equipment was made to Cork County Council (CCC) (Reg Ref. 12/0690) by Tapella Ltd. in 2012 and was subsequently granted in April The works associated with this permission are now complete and the application site is largely vacant and is dominated by a range of artificial surfaces. A decommissioned waste water treatment plant (WwTP) and utilities building associated with the former Pfizer plant are present at the eastern extent of the site. It is proposed as part of the planning application made to CCC in May 2015 by Stream BioEnergy Ltd. that these features will be demolished to allow for redevelopment of the site. A surrender application for licence number P has been submitted to the EPA by Tapella Ltd. and is under consideration. Relevant Hazardous Substances The application documents submitted by PCL in May 2007 for licence P have been reviewed to identify if any of the RHSs identified in Table 1 may have been used during the operation of the site as a pharmaceutical plant. Those materials common to both processes include: Diesel Oil; Proposed Renewable Bioenergy Plant 6 Little Island BioEnergy Ltd. EPA Export :23:31:52

65 BASELINE REPORT Caustic Soda (Sodium Hydroxide); and, Sulphuric Acid. The location of the storage or use of each of these substances at the application site was identified from Drawing No. FSK-2027 included with the Pfizer application and which is presented in Figure 4 of this report. Best Available Techniques (BAT) for materials handling and storage were implemented on site during the operational phase of the Pfizer plant and included: Loading and unloading carried out in designated areas protected with sumps and/or gullies diverted to the process effluent drainage system; Corrosive materials, such as acids, unloaded in areas provided with protective surfaces on the concrete; Overfill protection on storage tanks containing potentially polluting substances (e.g., pump/level interlocks); Spill kits maintained at designated areas; and, Pfizer maintained a three year rolling bund integrity testing, tanks and pipe testing programme as required by the licence. Historical Site Investigations Pfizer Cork Ltd. Manufacturing activities at the site were discontinued by Pfizer in Following the cessation of production activities and decommissioning of the site by PCL, site investigations (SI) were undertaken by URS Ireland Ltd. (URS) in 2010 to quantify the underlying soil and groundwater conditions. A report detailing the site investigation works was submitted to the EPA as a post closure report (URS Report Ref: /2248/CKRP0001) dated 18 th February 2011, with an updated version of this report subsequently submitted to the Agency dated 14 th March A summary of the findings of the site investigations undertaken within the subject development application area is presented below. The site investigation points that were installed within the subject application area are presented in Figure 4. Proposed Renewable Bioenergy Plant 7 Little Island BioEnergy Ltd. EPA Export :23:31:52

66 BASELINE REPORT The investigations detected some evidence of localised oil and groundwater contamination consistent with the historical industrial use of the site, but it was concluded by URS that this posed negligible risk to the surrounding environment. Groundwater A chloroform concentration of 305 µg/l was detected in the groundwater sample purged from BH2 in November 2010 which was consistent with historical trends for that borehole which is located at the southern boundary of the application area. This concentration was above the Groundwater Threshold Value (GTV) and Interim Guideline Value (IGV) but below the Dutch Intervention Value (DIV) of 400 µg/l (the level above which further assessment or remediation may be required). Historically, the chloroform concentration in groundwater from well BH2 was much higher, over 20,000 µg/l, but has been consistently below 350 µg/l since 2009 and is following a long-term declining trend. Methyl Tertiary Butyl Ether (MTBE) of 5,685 µg/l was detected in groundwater from well (November 2010) close to the Southern Tank Farm (see Figure 4). This well was resampled in January 2011 and the MTBE concentration had reduced to 5,019 µg/l. MTBE was not detected above the DIV of 9,200 µg/l. There has been no MTBE usage or storage on site since February The reported Total Petroleum Hydrocarbon (TPH) concentrations were below reporting limits. Trace detections of TPHs were recorded in well Arsenic was detected in November 2010 above one or more relevant criteria in three groundwater monitoring wells installed within the proposed application area. The reported concentration in well was above the GTV, IGV and DIV values. While arsenic in groundwater from wells and was above the GTV and draft IGV only. Historically, arsenic has been detected in varying concentrations from all three wells as presented below. Monitoring Well Table 2 Arsenic Concentration Arsenic Concentration (µg/l) October 2003 August 2006 July 2007 November n/s n/s n/s not sampled Proposed Renewable Bioenergy Plant 8 Little Island BioEnergy Ltd. EPA Export :23:31:52

67 BASELINE REPORT All three wells exhibited reducing (anaerobic) groundwater conditions which it is believed was responsible for localised dissolution of naturally-occurring arsenic from aquifer materials. Soils Localised low detections of chloroform were reported in soil collected form 3 bores drilled at the western end of the Southern Tank Farm (see Figure 4), with a maximum soil concentration of 52 µg/kg. All detections were above the soil Dutch Target Level (DSV) of 20 µg/kg but below the soil Dutch Intervention Level (DIV) of 10,000 µg/kg. The DSVs generally represent background concentrations in soil from unpolluted areas. The DIVs represent concentrations above which there may be a risk to human receptors and further assessment or remediation may be required. MBTE was detected in eight soils samples collected from beneath the Southern Tank Farm area. The reported MTBE concentrations ranged from 12 µg/kg to 2,322 µg/kg. PAH compounds were also detected in isolated shallow soil samples from beneath the Southern Tank Farm, the former Process Areas and Wastewater Treatment Plant (WwTP) (see Figure 4). In the Southern Tank Farm and WwTP areas detections were low, below 300 µg/kg. PAH concentrations in the Process Areas, which corresponds to the location of the proposed Main Building of the Renewable Bioenergy Plant, were more elevated at 15,647 µg/kg which exceeds the DSV level (1,000 µg/kg) but is considerably below the DIV level (40,000 µg/kg). PAHs were not detected in groundwater indicating that the impact in the soil is localised and not mobile. Other compounds, including BTEX and alcohols were detected at low concentrations in the soils beneath the Southern Tank Farm and the former Process Areas. Methanol was detected at concentrations above the corresponding DIV level at the Process Area, but methanol was not detected in the groundwater near this area, despite the long operational history of methanol use at this part of the site. Heavy metals were detected above reporting limits in soil cores from across all process areas, but concentrations were within the typical range for unpolluted agricultural soils in Ireland. Proposed Renewable Bioenergy Plant 9 Little Island BioEnergy Ltd. EPA Export :23:31:52

68 BASELINE REPORT It should be noted that none of the substances detected at elevated concentrations in soils or groundwater as reported above l correspond to the proposed RHSs to be used at the proposed Renewable Bioenergy Plant. Quantitative Risk Assessment A Detailed Quantitative Risk Assessment (DQRA) (URS Report Ref /DURP0001) was submitted to the EPA by PCL in December The report concluded that the risk of environmental pollution arising from pollutant concentrations detected in monitoring at the Pfizer Inchera site is not significant. The peak concentrations of contaminants identified in groundwater underlying the site were not considered significant in terms of potential risk to surface water quality in the key surface water receptors adjacent to the site including Bury s Basin and Lough Mahon. The DQRA found that any residual contamination on site would continue to reduce through natural attenuation over time. The Agency confirmed that it was in agreement with the DQRAs conclusion that the environmental risk posed by the presence of contaminants in the groundwater underlying the Pfizer site is not significant (EPA Ref. P /ap01mor.docx). The Agency required that quarterly groundwater monitoring be continued at the facility in order to confirm that the risk continues to be mitigated by the natural attenuation strategy that is in place. Proposed Renewable Bioenergy Plant 10 Little Island BioEnergy Ltd. EPA Export :23:31:52

69 4. ENVIRONMENTAL SETTING & SITE INVESTIGATION Topography BASELINE REPORT The subject site is a largely vacant, roughly rectangular shaped plot and varies in height from 7.1m above ordnance datum (AOD) along the western boundary of the site, to 9.5m AOD at the centre of the site. The site drops steeply to approximately 2.0m AOD along the eastern boundary, see Figure 5. Made Ground, Subsoils & Depth to Bedrock The natural topsoil at the subject site has been largely removed and made ground now extends across the site, as confirmed by Teagasc mapping (see Figure 6). A site investigation conducted in February 2015 as part of the planning application process for the proposed Renewable Bioenergy Plant confirmed the presence of made ground, which was encountered to depths varying between 0.3m and 3.3m below ground level, see Appendix 1. The made ground typically comprises re-enforced concrete foundations or bitumen paving above brown gravelly clay or brown clayey gravel fill. Occasional pieces of steel, plastic, PVC piping and concrete were also encountered. Beneath the made ground lies naturally occurring brown subsoils comprising either very clayey sandy gravels or sandy very gravelly clays across the majority of the site (see Figure 7). The GSI has mapped the underlying bedrock as Dinantian Pure Unbedded Limestones from the Waulsortian Limestones Formation, see Figure 8. There are no mapped structural fault lines running through the site. The depth to bedrock has been found to vary from approximately 8 m depth to over 18 m depth from previous investigations. The thickness of subsoils across the site also has been found to vary in response to the variation in the depth to bedrock surface. Environmental Screening As described in the preceding section of this report a site investigation undertaken on behalf of Pfizer Cork Ltd. in 2010 identified the presence of a range of substances/compounds in the subsoils at levels that were above background concentrations, but not of environmental significance. In 2015, on behalf of Stream BioEnergy Ltd. twelve trial pits were excavated across the site and samples from the made ground and subsoils were collected. The trial pit locations were determined by the layout of the proposed development in order to facilitate the collection of Proposed Renewable Bioenergy Plant 11 Little Island BioEnergy Ltd. EPA Export :23:31:52

70 BASELINE REPORT samples for both geotechnical and environmental purposes from targeted locations (see Figure 9). TP-1 is adjacent to the proposed DERV diesel tank. TP-9, TP-10 and TP-11 are within or adjacent to the footprint of the chemical storage tanks which will contain the Sodium Hydroxide, Sulphuric Acid, Hydrogen Peroxide and Ferric Sulphate. TP-4, TP-6, TP-7 and TP- 8 are within the footprint of the main building where the Polyelectrolyte and Antifoaming Agent will be stored. O Callaghan Moran and Associates (OCM) collected sufficient samples of the made ground and subsoils from the trial pits to ensure representative coverage of both unconsolidated formations across the site. The samples chosen for analysis were from the naturally occurring subsoils that underlie the made ground and the made ground itself where this will remain in situ either at its current location, or be used to raise ground levels in the eastern part of the site. One sample from each trial pit was selected for analysis. The samples submitted to the laboratory were analysed for ph, chloride and Extractable Petroleum Hydrocarbons (C- 8-C 40). These parameters were chosen to represent the baseline condition of the soils beneath the site based on the RHSs that will be used at the site during the operational stage. The full laboratory report is presented in Appendix 2 and the results of the analysis are presented in the Table below. Trial Pit No. Sample depth TP TP Table 3 Environmental Sample Analysis Soil Description MADE GROUND - Brown gravelly CLAY MADE GROUND - Dark brown sandy gravelly CLAY ph (Units) Chloride (mg/kg) EPH (C8 C40) (mg/kg) < <30 TP Brown clayey sandy GRAVEL <30 TP TP MADE GROUND Sandy GRAVEL MADE GROUND Sandy GRAVEL TP Gravelly CLAY <30 TP TP MADE GROUND Brown sandy CLAY Brown sandy gravelly CLAY / SILT <30 TP Brown clayey sandy GRAVEL <30 Proposed Renewable Bioenergy Plant 12 Little Island BioEnergy Ltd. EPA Export :23:31:52

71 Trial Pit No. Sample depth Soil Description BASELINE REPORT ph (Units) Chloride (mg/kg) EPH (C8 C40) (mg/kg) TP Brown clayey sandy GRAVEL <30 TP Brown clayey sandy GRAVEL <30 TP TP MADE GROUND Sandy GRAVEL MADE GROUND Dark brown clayey sandy GRAVEL < TP Brown clayey sandy GRAVEL <30 TP TP TP Notes: MADE GROUND Clayey sandy GRAVEL Slightly sandy gravelly SILT/CLAY MADE GROUND Clayey GRAVEL - Indicates that the sample was taken but not scheduled for analysis < There was no visual / olfactory evidence of contamination noted during the excavations, with the exception of one trial pit (TP-6) where a slight chemical odour was noted. An elevated chloride concentration was detected in the sample collected from TP-6, relative to the results reported for samples analysed from the other trial pits. However, EPH was not detected in the TP-6 sample, which was the trial pit in which a slight chemical odour was noted during sampling. There was a low level detection of EPH in one of the trial pits (TP-12). The sample collected from TP-9 had elevated ph and chloride values in comparison to the other samples. None of the reported concentrations are considered to be of environmental significance. Surface Water Surface water in the area includes Lough Mahon, which together with the outer River Lee Estuary, forms the upper section of Cork Harbour. The River Lee flows into Lough Mahon in the upper harbour. Water quality in the River Lee at Leemount Bridge has been classified by the EPA as being Good Status (Q4). Surface water quality in Lough Mahon has been classified by the EPA as being Intermediate. Lough Mahon and Upper Cork Harbour are designated Nutrient Sensitive Transitional Waters (EPA). Lough Mahon is a Transitional Waterbody (reference code IE_SW_060_0750) mapped under the Southwestern River Basin District completed under the Water Framework Directive. Lough Mahon has been classified as having an overall status of Moderate and being At Risk Proposed Renewable Bioenergy Plant 13 Little Island BioEnergy Ltd. EPA Export :23:31:52

72 BASELINE REPORT (1a) of not achieving Good Status by The objective is to restore the waterbody to good status by Dissolved Inorganic Nitrogen status (DINV) and Dissolved oxygen as per cent saturation status (DO) are classified as being Moderate and drive the overall Moderate Status for the waterbody. There are two existing drainage features to the east of the site (Drainage Channel 1 and Drainage Channel 2), neither of which are classed as Water Framework Directive (WFD) water bodies. Drainage Channel 1 is approximately 85 m east of the site. There is high ground between the site and this drainage feature, minimising the potential for the site to impact on the channel. Drainage Channel 2 commences at the north east corner of the site. These drainage channels run south to north discharging to a drainage basin adjacent to the N25. This basin drains under the N25 to the east of the N8, N25 interchange and ultimately south west under the N25 into Lough Mahon. Drainage Channels 1 and 2 along the eastern boundary of the site are affected by backwatering from the sea. Assessing the surrounding drainage of the area, the drainage channels east of the site would be affected by tidal conditions and backwatering affect when the level in Lough Mahon is high. Therefore, flood risk may be exacerbated if high surface water flows coincide with a period of high sea levels. Low pressure and strong easterly winds cause surges in Cork Harbour. High tides also impact on the level of flooding ( and a detailed Flood Risk Assessment has been prepared. A search on the OPW National Flood Hazard Mapping website found no record of past flooding within the proposed development area. A Preliminary Flood Risk Assessment prepared by Tobin Consulting Engineers is included as Appendix I.2 to this application. Based on the 0.1% AEP (1000-year) flood level provided in the Lee Catchment Flood Risk Assessment and Management Study (CFRAMS) and the Irish Coastal Protection Strategy Study (ICPPS), the estimated Mid-Range Future Scenario (MRFS) tidal flood is 3.54mOD. It is proposed to raise the site to a level of 7.8mOD by raising site levels. This will include raising approximately 0.09ha of land at the east of the application area currently located within the 1,000 year floodplain. The percentage of floodplain removed due to development is 0.3%. It is considered due to the minimal encroachment into the flood plain that the proposed development will have an imperceptible impact on flood levels. The Flood Risk Assessment concludes that the developed site will be located in Flood Zone C and is assumed to be appropriate from a flood risk perspective. Proposed Renewable Bioenergy Plant 14 Little Island BioEnergy Ltd. EPA Export :23:31:52

73 BASELINE REPORT The proposed development will discharge clean treated surface water into the existing surface water sewer at a greenfield rate of 6.1 l/s/ha. Based on the source of the discharge (surface water run off), its treatment prior to discharge and its estimated quantity (32m 3 /day), no significant change in water quality is predicted on Lough Mahon/Cork Harbour. Groundwater Groundwater Body The site is located above the Little Island Groundwater Body (Waterbody Code IE_SW_G_051), which has been designated and mapped as part of the Southwestern River Basin District in accordance with the Water Framework Directive (2000/60/EC). Groundwater Body has been classified as being of Poor chemical and overall status due to pressures from contaminated land. The Groundwater Body is considered to be At Risk (1a) of not achieving risk good chemical status/potential at least by 2015 according to the Groundwater Body Report for Little Island (WFD Dissemination Agency). Aquifer Status The limestone bedrock is classified by the Geological Survey of Ireland (GSI) as a Regionally Important Aquifer karstified (diffuse) (Rkd), see Figure 10. According to the GSI the site is underlain by undifferentiated sands and gravels, but these have not been classified as an aquifer. Nevertheless it is expected that these fluvio-glacial deposits are in hydraulic continuity with the bedrock aquifer providing additional storage capacity and a component of intergranular flow above the secondary permeability (fissure / conduit flow) within the karst limestone bedrock system. Vulnerability Groundwater vulnerability has been mapped as High according to the GSI and an area of thin subsoil and an area of bedrock near to the surface has been mapped approximately 100m to the north of the site (see Figure 11). The design and operation of the plant will reduce the potential impact of the site on the underlying ground and groundwater. The Groundwater recharge has been mapped as 137mm/yr based on average effective rainfall of 683mm/yr over a made ground land cover with an estimated 20% recharge coefficient (Geological Survey of Ireland). The extent of recharge will be dependent on the nature of Proposed Renewable Bioenergy Plant 15 Little Island BioEnergy Ltd. EPA Export :23:31:52

74 BASELINE REPORT surface cover and may be lower than that mapped by the GSI due to presence of impermeable surfaces across a high proportion of the site. Groundwater Users There are no reported users of groundwater down gradient of the site to the adjacent surface water bodies, which are expected to form the natural discharge areas for groundwater. The GSI s well database indicates the presence of three monitoring wells m to the northeast of the site installed by Warner Lambert (Pfizer), and a well 400m to the southeast also considered to be a monitoring well. The GSI s database indicates an industrial use intermediate spring approximately 1km to the east of the site, which is located up hydraulic gradient of the site. Groundwater Depth and Flow Groundwater ingress was not encountered in any of the boreholes or trial pits installed during the ground investigations undertaken by IGSL during February 2015, see Figure 9. However, it is possible that perched groundwater may occur within more permeable lenses of the subsoil underlying the site. Such groundwater could be perched above lower permeability horizons in the subsoil and would not be spatially extensive. Groundwater beneath the site was measured at depths ranging from 2.25 m to 8.7 m below ground level in February 2015 on behalf of Tapella Ltd, equating to 0.85 m above Ordnance Datum (maod) to maod. Groundwater is expected to flow within both the sand and gravel deposits and the limestone bedrock to discharge to the adjacent marine waters in Lough Mahon. Previous groundwater flow mapping completed by Pfizer (URS, 2011) using a dense network of groundwater monitoring wells across the more extensive former Pfizer site indicated general groundwater flow to the northwest at gradients ranging from to It is expected that gradients and flow directions will vary locally across the site reflecting topography (see Figure 5) and variations in the underlying geology. It is not envisaged that any spilled substances at adjacent industries would migrate onto the application site. Although previous groundwater level monitoring to the west of the proposed development site indicated a tidal influence on groundwater levels (at monitoring wells and see Figure 4), there was no observed tidal effect in groundwater monitoring wells beneath the Proposed Renewable Bioenergy Plant 16 Little Island BioEnergy Ltd. EPA Export :23:31:52

75 BASELINE REPORT proposed development footprint, which is to be expected as tidal influences decrease with distance from the foreshore. Groundwater Quality Baseline quality data indicates that the groundwater is reducing (lacking oxygen) beneath the site as well as brackish conditions in deeper groundwater. This reduces the resource potential of the groundwater beneath the site as a potable supply. Groundwater quality has been impacted by historic anthropogenic activities and significant decreasing concentration trends with time have been observed for chloroform and MTBE as described earlier in this report. Both compounds have very high aqueous solubility, which explains the initial high concentrations observed and the significant reductions which have occurred over time as the compounds have dissolved and migrated within groundwater. Recent (2014 and 2015) groundwater monitoring (see Appendix 3) undertaken by EnviroManagement Services on behalf of Tapella Ltd. as part of the licence surrender application to the EPA demonstrates that chloroform levels continue to decline with a 8 fold reduction in measured levels observed between 2010 and February Chloroform concentrations decreased from of 0.4mg/l (February 2011) to 0.035mg/l in monitoring well BH2 in February The most recently reported concentration of chloroform in well BH2 is below the GTV (75 µg/l) and DIV (400 µg/l) for chloroform. Plate 1 Trends in Chloroform Concentration in BH2 Source: EnviroManagement Services (2015) Proposed Renewable Bioenergy Plant 17 Little Island BioEnergy Ltd. EPA Export :23:31:52

76 BASELINE REPORT MTBE concentration is reducing in well 06-08, with significant reductions (18 fold) evident compared to the period November Concentrations in monitoring well have decreased from a mean of 4mg/l in 2011 to 0.31mg/l in February 2015, see Plate 2 below. Plate 2 Trend in MBTE Concentration in Well Source: EnviroManagement Services (2015) A Groundwater Monitoring Status report is included in Appendix 3, and demonstrates a continuous trend of improvement in groundwater quality on site during the period 2014 to February The report indicates that there are no significant residual sources of contamination present beneath the site. Conceptual Site Model Based on the available information, a Conceptual Site Model (CSM) for the proposed development is illustrated in Figure 12 and described below. Effective rainfall (i.e. rainfall less evapotranspiration) falling outside the site footprint can infiltrate the soil and subsoil to percolate to underlying groundwater in the sand and gravel and limestone bedrock. Groundwater flows to Lough Mahon within the sand and gravel and limestone bedrock where it discharges to surface water. There are no reported users of groundwater down gradient of the site to the natural discharge areas. Proposed Renewable Bioenergy Plant 18 Little Island BioEnergy Ltd. EPA Export :23:31:52

77 BASELINE REPORT Rainfall over the proposed site will be collected, attenuated and discharged at Greenfield runoff rates to the storm sewer. Due to the impermeable surface cover over the site, there will be no infiltration to groundwater beneath the site. Therefore, there will be no migration pathways from potential surface sources on the site to underlying made ground, subsoils or groundwater. Proposed Renewable Bioenergy Plant 19 Little Island BioEnergy Ltd. EPA Export :23:31:52

78 BASELINE REPORT 5. SITE SPECIFIC POLLUTION POSSIBILITY Relevant Hazardous Substances associated with the operational phase of the proposed facility are presented in Table 1. It is considered that the potential for soil and groundwater contamination is low / negligible for the following reasons: The facility has been designed to ensure the protection of soil and groundwater. All materials handling will be undertaken indoors and external areas of hardstanding are designed to eliminate a direct pathway for any hazardous substances to pollute the underlying ground. The facility will be operated under an Environmental Management System which will ensure adequate procedures and work practices are in place to prevent pollution of the environment. The proposed development will not use particularly hazardous materials in the process, e.g. substances with Risk Phrases R50 (very toxic to aquatic organisms) or R58 (may cause long-term adverse effects in the environment). It is concluded the potential for contamination of surface water features, soil and groundwater by RHSs is limited to the following potential sources which are reviewed in further detail below. Contamination of surface water runoff (e.g. by spill etc.) leading to subsequent contamination of soil/groundwater; Loss of containment from above ground chemical storage tanks; and, Chemical spills and leaks on areas of hardstanding draining to ground. Surface Water Management It is proposed to construct an engineered surface water drainage system which will serve the entire site (see Figure 3) that will be covered in impermeable surfacing. Runoff from roofs, roads and paved areas will be collected in the system. The surface water drainage system will carry the storm water to an underground attenuation tank located at the western end of the site. Should the stormwater comply with the discharge conditions of the Industrial Emissions Licence, it will be released to the existing municipal storm sewer. All road and paving gullies will be trapped. No flood waters will be allowed to leave the site up to and including a 1:100 year event in accordance with the Greater Dublin Strategic Drainage Study. A hydrobrake flow control device will limit the flow of stormwater to the existing storm sewer. Furthermore a Proposed Renewable Bioenergy Plant 20 Little Island BioEnergy Ltd. EPA Export :23:31:52

79 BASELINE REPORT class 1 bypass petrol interceptor will be installed on the surface water drainage system. In the event that discharge from the stormwater attenuation tank is outside of the licensed parameters for discharge, a shut-off valve will be provided on the outlet of the surface water attenuation tank in order for it to be isolated. The non-compliant stormwater may be sent to the nearby Carrigrennan WwTP for treatment or held in the attenuation tank for interim storage pending a decision on its fate. An outline of the surface water drainage system as described above is presented below. Plate 1 Schematic of Surface Water Drainage System Flow Above Ground Tanks and Pipework Tanks and associated pipework are designed to be fit for purpose and will be inspected visually on a regular basis to ensure their continued integrity and to identify the requirement for any remedial action. Liquid levels within all storage tanks will be continuously monitored by pressure sensors which will alert the operator to high levels and operate interlocks. Float switches will also be in place that will activate alarms when preset levels have been reached. Diesel will be stored in a certified self bunded fuel tank mounted on an impermeable surface. Self bunded tanks are designed to prevent leaks, and if there is a breach in the inner wall, the Proposed Renewable Bioenergy Plant 21 Little Island BioEnergy Ltd. EPA Export :23:31:52

80 BASELINE REPORT outer wall of the tank will prevent liquid from escaping and contaminating the area. In addition the tank will be fitted with an over fill protection unit supplied with mechanical shut off and audible alarm. The maximum volume to be stored on site is 2500L. Refuelling of vehicles will take place on the bunded hardstanding area adjacent to the diesel tank. Sodium Hydroxide, Sulphuric Acid, Hydrogen Peroxide and Ferric Sulphate will be stored on site within fit for purpose double walled tanks. Such tanks comprise an inner tank and a secondary outer tank that has a 110% capacity of the inner tank and serves for containment purposes in the event of a spillage. In addition, the dome of the inner tank overlaps the sidewalls of the outer tank and so prevents rainwater entering the containment area. These tanks will be further contained within the tank farm bund. Polyelectrolyte and Antifoaming Agent will be stored in IBCs which will be located under cover in a dedicated chemical storage area within the main building. Operational areas of the site will benefit from impermeable surfacing and engineered drainage systems. Chemical Spills Detailed procedures and training will be established for the use, handling and storage of all chemicals on-site to ensure that the risk of spills is minimised. Chemicals will be stored in designated, labelled areas and bunding will be provided where required. Bunding will be designed in accordance with EPA requirements. Preventative maintenance and routine monitoring of tanks and equipment will minimise the likelihood of leaks/spills occurring and ensure that any leaks are quickly detected and controlled. Should a spill be identified, procedures outlined in the facility s Quality, Environmental, Health and Safety Policy (QESH) will be immediately implemented using appropriate spill clean-up materials which will be maintained on site. As outlined above an engineered drainage system will serve the entire site and will capture any spill and prevent it from entering the underlying soil or groundwater. Proposed Renewable Bioenergy Plant 22 Little Island BioEnergy Ltd. EPA Export :23:31:52

81 BASELINE REPORT 7. CONCLUSIONS This report presents the potential RHS s (source), the underlying ground conditions (pathway) and the soils, groundwater and surface water environment (receptors) of the application area. As described under the section entitled Site Specific Pollution Possibility above sufficient control measures combined with the natural ground conditions underlying the site means that the operational phase of the proposed plant will not impact on the existing soil or groundwater quality at the plant. An Environmental Liabilities Risk Assessment (ELRA) was commissioned by Pfizer as part of a Closure Plan submitted to the EPA in The report states that elevated concentrations of certain organic chemicals were noted in past soils and groundwater monitoring reports. The locations are specific and associated with past site activities. The IPPC groundwater monitoring programme has demonstrated a continuous downward trend in contaminant concentration. The substantial reductions over time and the high solubility of the compounds indicates that there are no significant residual sources of contamination present beneath the site. The current contaminant levels are not regarded as environmentally significant. Localised low detections of chloroform were reported in soil collected form 3 bores drilled at the western end of the Southern Tank Farm with a maximum soil concentration of 52 µg/kg. All detections were above the soil Dutch Target Level (DSV). The contaminants identified in the groundwater monitoring programme do not correspond to the relevant hazardous substances presented in Table 1 to be used during the operational phase of the proposed Renewable Bioenergy Plant. Environmental screening undertaken as part of the Environmental Impact Statement submitted with this IEL revealed no evidence of contamination in the made ground or subsoils at the application site. There was no visual / olfactory evidence of contamination noted during the excavations, with the exception of one trial pit (TP-6) where a slight chemical odour was noted. The facility has been designed to ensure the protection of soil and groundwater. All materials handling will be undertaken indoors and external areas of hardstanding and bunding are designed to eliminate a direct pathway for any relevant hazardous substances to pollute the underlying ground. Proposed Renewable Bioenergy Plant 23 Little Island BioEnergy Ltd. EPA Export :23:31:52

82 BASELINE REPORT Robust environmental management practices will ensure that the risk of unplanned events will be minimised. The facility will be operated under an Environmental Management System (EMS) which will ensure adequate procedures and work practices are in place to prevent pollution of the environment. The entire site process will be constantly monitored on a SCADA system to continuously assess the performance of the plant and identify any adjustments necessary to prevent technical issues arising thus limiting the potential for environmental incidents. The plant will be operated in accordance with stringent regulatory controls and limits. The EPA licence will impose an extensive range of conditions in accordance with international and national threshold limits. The plant will also be subject to environmental performance reporting requirements and regular inspections by as part of the licence. In the event of cessation of site activities, the site will be closed in accordance with the Closure Plan which has been submitted as part of this application. Furthermore an Environmental Liability Risk Assessment (ELRA) has been carried out and included in the IEA application. This ELRA will be updated as required throughout the operational lifetime of the proposed development. This will ensure that any potentially polluting substances are removed from the site in a controlled manner and that there will be no significant residual pollution of soil or groundwater. Proposed Renewable Bioenergy Plant 24 Little Island BioEnergy Ltd. EPA Export :23:31:52

83 BASELINE REPORT FIGURES Figure 1 Regional Site Location Map Figure 2 Proposed Site Layout Plan and Emission Points Figure 3a Proposed Stormwater Drainage Layout Figure 3b Proposed Foul Sewer Drainage Layout Figure 4 Former Location of RHSs, Trial Pits and Wells at Pfizer Plant Figure 5 Existing Site Layout Plan, Topo & Structures Proposed for Demolition Figure 6 Teagasc Subsoils Figure 7 GSI Quaternary Sub-Soils Figure 8 Bedrock Geology Map Figure 9 Trial Pit, Borehole & CBR Locations (IGSL Ground Investigations, 2015) Figure 10 Aquifer Classification & GSI Borehole Records Figure 11 Groundwater Vulnerability Figure 12 Conceptual Site Model Proposed Renewable Bioenergy Plant 25 Little Island BioEnergy Ltd. EPA Export :23:31:52

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97 BASELINE REPORT APPENDIX Appendix 1 Engineering Services Report Appendix 2 Laboratory Report Appendix 3 Tapella IPPC Licence (PO103-03) Surrender Report Proposed Renewable Bioenergy Plant 26 Little Island BioEnergy Ltd. EPA Export :23:31:53

98 LITTLE ISLAND B I O E N E R G Y BASELINE REPORT Appendix 1 Engineering Services Report EPA Export :23:31:53

99 Stream BioEnergy Ltd Proposed Renewable Bioenergy Plant At Engineering Services Report Date: April 2015 Revision: D TOBIN CONSULTING ENGINEERS EPA Export :23:31:53

100 ENGINEERING SERVICES REPORT PROJECT: Proposed Renewable Bioenergy Plant, CLIENT: COMPANY: Stream BioEnergy Unit 1 Avondale Business Park, Carysfort Avenue, Blackrock, Co. Dublin, Ireland. TOBIN Consulting Engineers Unit 10-4 Blanchardstown Corporate Park Blanchardstown Dublin 15 EPA Export :23:31:53

101 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork DOCUMENT AMENDMENT RECORD Client: Project: Title: Stream BioEnergy Proposed Renewable Bioenergy Plant, Engineering Services Report PROJECT NUMBER: 6301 DOCUMENT REF: 6301_04_01 D C B A Engineering Services Report Engineering Services Report Engineering Services Report Engineering Services Report JF DC DC JF DC DC JF DC DC JF DC DC Revision Description & Rationale Originated Date Checked Date Authorised Date TOBIN Consulting Engineers EPA Export :23:31:53

102 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork TABLE OF CONTENTS 1 INTRODUCTION SITE LOCATION TOPOGRAPHY DETAIL OF THE PROPOSED DEVELOPMENT PROPOSED SITE INFRASTRUCTURE EXISTING SERVICES BUILDINGS Structural Form Building Heights ACCOMPANYING INFORMATION ACCESS AND INTERNAL ROADS GENERAL PARKING AREAS, SERVICE YARD AND ANCILLARY INFRASTRUTURE AREA EARTH WORKS GENERAL WATER SUPPLY POTABLE WATER SUPPLY Domestic Supply Fire Water Supply Water Requirements for Ancillary Process Requirements WASHWATER REQUIREMENTS SURFACE WATER GENERAL SURFACE WATER DESIGN SUSTANABLE URBAN DRAINAGE FOUL WATER EPA Export :23:31:53

103 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 7.1 GENERAL SANITARY WASTEWATER WASHWATER WASTEWATER TANK BUND WASTEWATER PROCESS EFFLUENT SUSTAINABILITY SUSTAINABLE URBAN DRAINAGE (SUDS) ENERGY EFFICIENCY MEASURES Energy Efficiency in the AD Process CONSTRUCTION QUALITY ASSURANCE ANCILLARY SERVICES GENERAL HEALTH & SAFETY GENERAL APPENDICES APPENDIX 1... Water Requirements... APPENDIX 2... Water Supply Design... APPENDIX 3... Surface Water Design... APPENDIX 4... Foul Water Design... EPA Export :23:31:53

104 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 1 INTRODUCTION Stream BioEnergy (SBE) proposes to develop a Renewable Bioenergy Plant (herein after referred to as the Plant) at. The proposed plant will primarily accept and process 90,000 tonnes per annum of non hazardous biodegradable waste to generate up to 4 MW of renewable electricity, utilising anaerobic digestion (AD) technology. The development will consist of a processing building, tank farm, service yard, office accommodation, laboratory, car parking area and all ancillary works, as well as the demolition of an existing wastewater treatment plant and utilities building This Report together with its Appendices addresses the proposed infrastructural requirements of the development and will support the Planning Application for the development of the proposed Plant. 1.1 SITE LOCATION The site is located in a heavily industrialised area within the townland of Inchera at the western end of Little Island and comprises an area of circa 2 hectares (ha) (c. 5 acres), see Drawing No The application area is located approximately 0.5km southeast of the Dunkettle Interchange which forms the junction between the N25 Cork-Waterford (east) National Primary Route the M8 Cork- Dublin (north) Motorway and the N40 South Ring Road, see Drawing No Hoffmann Business Park occupies the lands to the north and west, while BASF Ireland, a chemical manufacturing plant, occupies the area to the south. Immediately east of the application site there is an area of undeveloped ground and beyond this is a Pfizer pharmaceutical plant. 1.2 TOPOGRAPHY A detailed topographical survey was carried out at the site.the final output of this survey for the proposed site is presented on Drawing No The site varies in height across the site from 7.1mOD along the western boundary of the site, to 9.5mOD Malin at the centre of the site. The site drops steeply to approximately 2.0mOD Malin along the eastern boundary. 6 EPA Export :23:31:53

105 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 2 DETAIL OF THE PROPOSED DEVELOPMENT The development will consist of a processing building, tank farm, service yard, office accommodation, laboratory, car parking area and all ancillary works, as well as the demolition of an existing wastewater treatment plant and utilities building. The facility if permitted will process up to 90,000 tonnes per annum of non-hazardous biodegradable waste using anaerobic digestion (AD) as its core technology. AD is a sustainable form of renewable energy production through a naturally occurring process in which microorganisms break down biodegradable material, in the absence of oxygen in an enclosed system. The process produces a biogas, which is largely made up of methane (60%) and carbon dioxide (40%), and a soil improving material, known as digestate. The digestate is nutrient rich, and free from odour, contaminants and pathogens and can be used as an organic biofertiliser which replaces the use of artificial fertilisers. The biogas can be converted into renewable heat and electricity for use in homes and businesses. The plant will generate a consistent supply of up to 4MW of renewable electricity, which is enough energy to power 7,500 local homes annually and heat generated will be reused in the process. 2.1 PROPOSED SITE INFRASTRUCTURE This section details the site infrastructure that is proposed for the Plant. The proposed site layout is outlined on Drawing No of the Planning Drawings and the detail of the development is further described elsewhere in this Report. The following is a schedule of the main infrastructure elements which shall form the proposed Plant: Access roads, parking areas, and hardstanding areas Administration Building Workshop Main Building Tank bunded area containing: o Grit Removal Tank x 4 o Post Digestion Buffer Tank x 2 o Pasteurisation Tank x 2 o Pasteurisation and Sludge Storage Tank x 2 o Process Water Tank x 1 o Concentrate Tank x 1 o Digestion Tank x 4 o Chemical Tank x 4 Odour Control System and Stack Weighbridge and Weighbridge control building Wheelwash Vehicle refuelling area Biogas Treatment Area containing: o Combined Heat and Power (CHP) Plant 1 o Combined Heat and Power (CHP) Plant 2 o CHP Stack o Biogas Flare o Gas holder o Gas Booster o Gas Dryer o Boiler o Motor Control Centre (MCC) Kiosk 7 EPA Export :23:31:53

106 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork o Electrical Power Supply Infrastructure Surface Water Infrastructure Foul Water Infrastructure Potable Water Supply Landscaping Features Site Access Access to the Plant will be via the existing Hoffman Business Park access road, located on the R623 regional road. Access into the site for feedstock delivery vehicles will be via an internal road in the Hoffmann Business Park and through the gate to the north of the site. The weighbridge for feedstock vehicles entering the site is located on the road along the southern boundary of the site. This weighbridge is visible to the weighbridge kiosk located at the south west gate. Feedstock vehicles will exit via the gate to the south west of the site. The weighbridge for exiting feedstock vehicles is at the south west gate adjacent to the weighbridge kiosk. Access to and from the administration area will be via the gate to the south west of the site. Appropriate signage will direct employees and visitors to the administration area and designated car parking areas and direct waste vehicles to the incoming weighbridge. Site Security Site security arrangements to prevent unauthorised access at the Plant include the following: The site entrances will have a 2.4m high mesh panel gate that is closed outside normal operating times. This gate is located as shown on Drawing No , with details presented on Drawing No Fencing around the entire boundary of the plant footprint, with the exception of the site entrances, will comprise of 2.4m high mesh panel fencing. The fencing layout is shown on Drawing No , with fencing details presented on Drawing No A CCTV system will also monitor the entrance to the plant. Anti-intruder alarms will be located in all lockable plant buildings. Weighbridge and Weighbridge Kiosk Two weighbridges, each capable of weighing up to 60 tonnes, will be provided at the feedstock delivery vehicle entrance at the locations outlined on Drawing No Two weighbridges will be constructed, one to weigh incoming feedstock vehicles and the second to weigh outgoing end product collection vehicles. The two weighbridges are considered necessary to allow for the free-flow of vehicular traffic and to ensure efficient turnaround times at the plant. Entry control barriers will be provided at each of these weighbridges. A weighbridge kiosk as shown on Drawing No will be constructed adjacent to the weighbridges and will include toilet facilities. Details of the weighbridge kiosk are presented on Drawing No Administration Building A 2 storey Administration Building is proposed for the development. The building will provide all necessary welfare facilities, office spaces, training areas, laboratory facilities, monitoring and control equipment required for the operation and maintenance of the Plant. It is envisaged that this will be a steel portal framed building, incorporating precast concrete floors and an insulated cladding system including a high quality insulated window system. Details of the structure and dimensions are included in Drawing No to of the Planning Drawings. It is envisaged that the Administration Building will comprise of a ground floor 8 EPA Export :23:31:53

107 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork and a first floor and will include the following areas as shown in Drawing No of the Planning Drawings. Reception Area Canteen (Operational and maintenance personnel) Canteen (Supervisory and office personnel) Toilets and showers (Women) Toilets and showers (Men) 1 No. Wash Room 1 No. Disabled Toilet 1 No. Meeting Room Plant Manager s office 2 No. offices Training Room Control Room SCADA Room Laboratory 2 No. Store Rooms First Aid Room The design of the Administration Building includes all necessary provisions required for the operation and maintenance of the Plant in accordance with safety, health and welfare at work legislation and other legal requirements. Air conditioning will be provided in all areas of this building. Fire and intruder alarm systems will also be installed in this building. The building will comply with the latest version of the Building Regulations (including access for disabled people). Main Building The Main Building will be constructed as a steel portal framed structure with a proprietary cladding. Details of the structure and dimensions of the Main Building are included in Drawing No to of the Planning Drawings. The building will be supplied with 3-phase power and will include both security and fire alarm systems. The building will be divided internally to contain the feedstock reception, storage and pre-treatment areas, effluent treatment, digestate treatment and storage areas, quarantine areas, skip bays and standby generator room. The building will be kept under negative air pressure and all the extracted air from this area will be treated by the odour control system prior to discharge. The maintenance of a negative pressure environment within the building will prevent the emission of untreated air thereby minimising potentially nuisance causing odour emissions. The provision of air changes within the building will also provide appropriate working conditions for plant operators. Workshop The Workshop will be constructed as a steel portal framed structure with a proprietary cladding. Details of the structure and dimensions of the workshop are included in Drawing No of the Planning Drawings. The building will be supplied with 3-phase power and will include both security and fire alarm systems. Odour Control System The Odour Control system comprises a bio-trickling filter consisting of 2No. filter bed containers, a plasma injection and carbon filtration system which will treat the extracted air from the main building and process equipment. Treated air emissions, from each biofilter section, will be vented to atmosphere by a 25m high stack. Details of the structure are included in Drawing No of the Planning Drawings. 9 EPA Export :23:31:53

108 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork Digestion Tank Farm The Digestion Tank Farm will be bunded and will contain the following tanks Grit Removal Tanks (up to 22.3m in height and 629m 3 in volume x 4), Digestion Tanks where the primary anaerobic digestion process occurs (up to 22.1m in height and 4956m 3 in volume x 4) Post Digestion Buffer Tank to act as a buffer between the digestion and pasteurisation stages (up to 22.3m in height and 629m 3 in volume x 2) Pasteurisation Tank (up to 16.9m in height and 217m 3 in volume x 2) Post Pasteurisation and Sludge Storage Tanks (up to 22.3m in height and 629m 3 in volume x 2) Process Water Tank to hold process effluent to be recycled back to the AD process or discharged to foul sewer (up to 22.3m in height and 1278m 3 in volume x 1) Concentrate Tank (up to 8.3m in height and 234m 3 in volume x 1) Chemical Storage Tanks (up to 5m in height and 35m 3 in volume x 4) Details of the structure and dimensions of the tanks are included in Drawing No to of the Planning Drawings. Combined Heat and Power Units The Combined Heat and Power (CHP) unit consists of 2 x 2MW engines. Both electricity and heat will be generated by the CHP system which is operated on biogas generated by the AD process. Electricity is generated from combustion of biogas while air and heat is recovered from the cooling jacket, oil lubrication system and flue gas. This plant will produce a supply of up to 4MW of thermal energy and this will be reused in the AD process for heating the pasteurisation units and digestion tanks, as well as other ancillary purposes. The CHP engines will discharge residual levels of pollutants to the atmosphere by a single multi-flue stack at a height of 28m above ground level. A gas booster will be provided to increase the gas pressure to the required level for supply to the engines and a dehumidifier to remove moisture from the biogas. A standby boiler will be located adjacent to the CHP units to provide hot water for pasteurisation and digester heating requirements in the event the CHP units go out of service. The details for the CHP units, gas booster and boiler equipment is shown on Drawing No and of the Planning Drawings Gas Holder and Flare The details for the gas holder and flaring equipment is shown on Drawing No of the Planning Drawings. The biogas holder will be a hemisphere dome and have a capacity of 1800m 3 and will stand at a height of 13.7m. The gas flare will be equipped with regulator valves, monitoring valves, ventilator, flame arrestor, and ignition equipment. This is a standby gas flare which will be used in the event that the CHP Plants are unavailable and that there is insufficient volume in the biogas holder. Wheelwash A wheel wash will be provided on the site at the location shown on Drawing No and to the details shown on Drawing No The wheel wash water supply will be from the rainwater harvesting/attenuation system. Runoff from the wheelwash will discharge to the foul sewer. Fuel Storage Bunded fuel storage will be provided for the diesel fuel that will be required for the onsite plant and equipment. This bunded fuel storage area will be located to the west of the site at the location shown on Drawing No This bunded fuel store area will comprise of a proprietary 2,500 litre diesel tank. Details of the tank are shown on Drawing No EPA Export :23:31:53

109 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork Electrical Substation and Transformers An electrical substation will be provided in the development to allow for the export and import of electricity to the national grid. Under normal operation the plant will be powered by the CHP s with supply from the grid provided as a backup. Transformers will transform outgoing electricity from low to high voltage and incoming electricity from high to low voltage. Site Roads, Parking and Hardstanding Concrete hardstand areas will be provided at the service yard, fuel storage area tank farm and biogas treatment area to the east of the site. Internal roads are proposed along the southern boundary of the site and to the east of the tank farm towards the entrance to the north of the site. Roads and parking areas will typically be designed as bituminous macadam pavements. The proposed locations of these areas at the site are shown on Drawing No and are detailed on Drawing No Landscaping There are opportunities for providing screen tree planting to the western and eastern boundaries of the site, which will assist in screening the lower levels of the development from the R623 road to the west of the site and the proposed future link access road from the N25 to Little Island to the east of the site. The proposed landscape planting will generally be established with forestry planting techniques, i.e. bare root transplants, whips and feathered trees which adapt readily to disturbed ground conditions. The existing trees and remnant stone wall to the northern boundary of the site will be retained and protected within the scheme. The proposed Landscape Plan is presented on Drawing No of the Planning Drawings. Water Supply Potable water supply for the site is proposed to be from the existing county council watermain system as indicated on Drawing No Water from the existing watermain is required for domestic purposes, fire fighting requirements, and for ancillary process requirements. Washwater supply will be from the storm water attenuation/rainwater harvesting system as indicated on Drawing No Refer to Section 5 for further details. Surface Water and Foul Water Infrastructure The layout of the surface water and foul drainage system proposed for the site is shown on Drawing No and respectively. As shown on Drawing No a proprietary oil interceptor will be installed through which all intercepted run-off from hard stand within the site will be diverted. The outfall from the oil interceptor will be discharged to the surface water attenuation/ rainwater harvesting system. This system is sized to provide adequate capacity for a 30-year storm event, limit discharge to the public sewer at greenfield rates and provide water to meet site washwater requirements. Refer to Section 6 and 7 for further details. 2.2 EXISTING SERVICES As the site was previously occupied by a Pfizer plant, there are connections to existing services. A live Cork County Council watermain crosses the north east corner of the site, while an offtake to this watermain crosses the north west corner. Power and gas are also available within the existing Business Park. It is intended to provide a power supply from an existing overhead mast to the proposed substation via an underground cable. Surface water from the site currently discharges via two outlets. It discharges to the existing public drainage system located at the entrance at the south west corner of the site and to a drainage pipeline located at the entrance to the north of the site. This drainage pipeline discharges to a drainage basin 11 EPA Export :23:31:53

110 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork north of the site adjacent to the N25 motorway. Foul water previously discharged to the existing public foul system at the access gate at the south west corner of the site. Proposed connections to the existing public watermain and public surface water and foul sewers are shown on drawings of the Planning Drawings. 2.3 BUILDINGS Structural Form The locations of the buildings at the proposed plant are shown on Drawing Nos , with details shown on Drawing Nos , which form part of the Planning Application. Typically the buildings are designed as steel portal framed structures, with a proprietary cladding, constructed on reinforced concrete floor slabs. With the exception of the Administration Building which will incorporate precast concrete floors and an insulated cladding system including a high quality insulated window system. The buildings shall be constructed to the levels and details provided in the Planning Application Drawings. Intrusive site investigation works have been carried out in the locations of the proposed buildings. The report concluded that the made ground overlying the site can be used for non critical works such as car parks, landscaping etc. It can also be utilised under light foundations, assuming that it is carefully assessed on site and that all very coarse or unsuitable material is removed. Underlying this is a gravelly clay / clayey gravel material which is suitable for buildings to be founded upon. Predominately the buildings on site will be located on this underlying stratum with little excavation required following grading of the site, however, in the location of the Odour Control System, Administration Building and Digestion Tank No. 1, deeper excavations will be required with the possibility of shallow piles being required Building Heights The heights of the buildings shall be in compliance with the Planning Application. The heights of the various structures are shown on the relevant Planning Application Drawings. The maximum height of buildings on site is 13.9m, not including stack heights. 2.4 ACCOMPANYING INFORMATION This Report is accompanied by Appendices 1 to 4 and the Planning Drawings, which include the information detailed hereunder. Table 2.1 Appendices Appendix Name Appendix Contents Appendix 1 Water Requirements Appendix 2 Water Supply Design Appendix 3 Surface Water Design 12 EPA Export :23:31:53

111 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork Appendix 4 Foul Water Design Table 2.2 Planning Drawings Drawing Number Drawing Title Regional Site Location Map Application Area (Site Location Map) Existing Site Layout, Topography and Demolition Plan Proposed Site Layout and Track Analysis Proposed Site Layout on Aerial Photography Proposed Visualisation Proposed Site Concept Process Plan Proposed site Elevations Existing Site Sections Proposed Site Sections Main Building and Odour Control System Proposed Elevations Main Building and Odour Control System Proposed Ground Floor Plan and Section Main Building Proposed Internal Ground Floor Drainage Plan Main Building and Odour Control System Proposed Ground Roof Plan Administration Building Elevations Administration Building Layout Plan Proposed Workshop Details Tank Farm Plan Tank Farm Elevations Digestion Tank and Pasteurisation Tank Process Water Tank and Grit Removal Tank Post Digestion Buffer Tank, Concentrate Tank, Post Pasteurisation & Sludge Storage Tank 13 EPA Export :23:31:53

112 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork Proposed Tank Farm Stairwell, Access Stairs & Pipe Bridge Plan and Elevations Proposed Odour Control System Plan and Elevations Proposed Security/ Weighbridge Office and Wheelwash Plan and Details Proposed Flare Stack and Gas Holder Plan and Elevations Proposed CHP Engine Containers & CHP Stack Plan, Sections and Elevations Propose Electrical Transformers, Electrical Substation, Chemical Storage Tanks Plan, Section and Elevations Proposed Refuelling Tank, MCC Kiosk, Booster & Dryers and Boiler Plan Sections and Elevations Proposed Gates, Fencing Plan and Directional Signage Sections and Elevations Proposed Stormwater Drainage Layout Plan Proposed Watermain Layout Plan Proposed Foul Drainage Layout Plan Proposed Electrical and Comms Layout Plan Typical Manhole Details Proposed Underground Rainwater Harvesting/ Attenuation System Proposed Petrol Interceptor and Pump Chamber Details Typical Watermain Details Typical Road Construction Details Proposed Landscape Plan 14 EPA Export :23:31:53

113 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 3 ACCESS AND INTERNAL ROADS 3.1 GENERAL Access to the Plant is from the R623 Regional Road at the southwest of the Tapella landholding, via the existing Hoffmann Business Park access road. The adequacy of this access junction is considered by a Traffic and Transport Assessment, which is presented in Chapter 15 of the Environmental Impact Statement (Volume II) which accompanies the Planning Application. An AutoTrack analysis of the internal road layout, within the Plant site, has been undertaken by Trafficwise Ltd. Internal roads have been designed to cater for articulated truck movements. Refer to Drawing No for details of this analysis. Road layouts, with road marking details, are shown on Drawing No of the Planning Drawings. Roads are typically designed as bituminous macadam pavements, or where appropriate, concrete pavements, with cross falls and longitudinal falls to promote drainage of the surfaces. Drainage of access roads is by means of gullies which will collect surface water. Typical construction details are shown on Drawing No of the Planning Drawings. Detailed design of the pavements shall be undertaken prior to the construction stage of the proposed Plant. 3.2 PARKING AREAS, SERVICE YARD AND ANCILLARY INFRASTRUTURE AREA As part of the plant development it is proposed to provide a car parking area to service the development. This car parking area will be located adjacent to the Administration Building, as shown on Drawing No Surface water drainage from this parking area shall be directed to the piped network. Edge restraints shall be provided by an appropriate kerbing system. 33 No. parking spaces have been provided including one disabled parking space, two motorcycle spaces and two electric charging points. There would be a maximum of 7 number of staff on site per shift. To allow for all staff to be on site during shift change over periods, would require a maximum parking requirement of 13. Footpaths have been provided throughout the site and are upto 2m wide. Zebra crossings are proposed along the administration access road to link the administration and ancillary infrastructure area to the tank farm and main building. Each of the crossings is intended as a continuation of the line of footways. The Biogas Treatment and Service Yard areas are designed as concrete pavement, with cross falls and longitudinal falls to promote drainage of the surfaces. Surface water drainage from these areas shall be directed to the attenuation/ rainwater harvesting system via an appropriately sized petrol interceptor and grit trap. Outflow from the attenuation pond shall discharge, at Greenfield Runoff rates, to the existing public surface water infrastructure. The surface water drainage layout for the site is shown on Drawing No , and further information is provided in Section 6 of this Report. 15 EPA Export :23:31:53

114 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 4 EARTH WORKS 4.1 GENERAL The site varies in height across the site from 7.1mOD along the western boundary of the site, to 9.5mOD Malin at the centre of the site. The site drops steeply to approximately 2.0mOD Malin along the eastern boundary The site is proposed to be regraded to between 7.1mOD to 8.0mOD therefore material will be required to be cut from the central area of the site and moved to the east where the ground is required to be raised. It is intended to make the maximum use of the material on site and minimise the import and export from the site. A materials balance indicates that the volume of useable materials excavated will be 95% of that required to raise the eastern part of the site to the formation levels. The shortfall will be made up using quarry sourced granular fill. A site investigation programme, comprising of trial pits, boreholes and laboratory testing, was carried out across the site of the proposed Plant, to determine the most appropriate construction methodologies for the site. The site investigation works, concluded that the made ground overlying the site can be used for non critical works such as car parks, landscaping etc. It can also be utilised under light foundations, assuming that it is carefully assessed on site and that all very coarse or unsuitable material is removed. Underlying this is a gravelly clay / clayey gravel material which is suitable for buildings to be founded upon. Predominately the buildings on site will be located on this underlying stratum with little excavation required following grading of the site, however, in the location of the Odour Control System, Administration Building and Digestion Tank No. 1, deeper excavations will be required with the possibility of shallow piles being required. Proposed site levels are indicated on Drawing No of the Planning Drawings. 16 EPA Export :23:31:53

115 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 5 WATER SUPPLY The proposed development will require a water supply for: Potable water for domestic use Water for fire fighting/ancillary process requirements; Water for washwater requirements. A full water balance for the site is included in Appendix 1. The watermain layouts including location of valves, hydrants, etc. are shown on Drawing No of the Planning Drawings. It is proposed that water requirements for potable use, firefighting requirements and process requirements are provided from the public water supply, while water requirements for washwater requirements is provided from reused stored surface water run-off collected on site. Further detail is provided hereunder. 5.1 POTABLE WATER SUPPLY Potable water supply for the site is proposed to be from the Cork County Council watermain as indicated on Drawing No of the Planning Drawings. There are existing offtakes from the watermain into the site from when Pfizer occupied the area. This offtake pipeline will be discarded during regrading and a new pipeline of similar dimensions provided. A layout of the watermain is shown on Drawing No , with details shown on Drawing No of the Planning Drawings. It is proposed to have a combined watermain for domestic, fire fighting and ancillary process requirements. The distribution main shall be 250mm diameter pipes, with 100mm offtakes to the individual buildings (see potable water calculations in Appendix 2 for justification of this figure). The main shall be looped as per best practice Domestic Supply It is estimated that the domestic potable water demand for the development will be approximately 0.43 m 3 /d (see potable water calculations in Appendix 2 for justification of this figure) Fire Water Supply Fire water for the proposed development shall be supplied via the existing watermain. Hydrants shall be connected to the watermain at locations throughout the site as per the layout shown on Drawing Nos of the Planning Drawings. Hydrants locations have been designed in accordance with Building Regulations Technical Guidance Document B Fire Safety Clause Requirements of the Planning Authority in relation to fire safety and fire fighting requirements shall be fully complied with in the Fire Safety Certificate application for the site, which will be prepared during the detailed design of the Plant and in advance of construction Fire Water Retention Fire water retention shall be in compliance with the requirements of the EPA Guidance on Fire Water Retention. Fire water, should it arise, would be dealt with in a number of different ways. Fire water generated in the Main Building will be directed to drainage sumps along the centre of the building, which is effectively a bunded tank with a capacity of approximately 535m 3. Fire water generated in the tank farm will be contained within the bund walls which have a capacity of approximately 4186m 3. Fire water generated elsewhere in site will be directed to the surface water attenuation tanks via a petrol interceptor. 17 EPA Export :23:31:53

116 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork Any firewater would be analysed prior to a decision being made with respect to possible tankering offsite to an approved wastewater plant, or an approved alternative treatment Water Requirements for Ancillary Process Requirements Potable water will be required for ancillary process requirements. It is estimated that the process potable water demand for the development is approx. 4.9 m 3 /d. 5.2 WASHWATER REQUIREMENTS The proposed Plant will have a requirement for fresh water operational purposes such as wash down and wheel wash requirements. Fresh water requirements will be met by means of a surface water attenuation/rainwater harvesting system. Fresh water will be required for the following activities: Wheel wash water requirements Floor wash water requirements It is estimated that the total fresh water demand for the development is approx. 26m 3 /d. Floor washdown water will be collected in sumps and recycled to the AD process. Discharge from the wheelwash will be diverted to the foul water system. For the purposes of supplying the fresh water for wash water, surface water shall be taken from the surface water attenuation/ rainwater harvesting system and pumped directly to the area where required. 18 EPA Export :23:31:53

117 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 6 SURFACE WATER 6.1 GENERAL The proposed topography of the site varies from approximately 7.1mOD to 8.0mOD. The surface water collection system has been designed such that discharge from all areas will be collected and diverted to an attenuation/rain water harvesting system, prior to discharge from the site to the existing local authority surface water sewer at greenfield runoff rates. It is proposed to collect the surface water runoff from hardstanding areas, the tank farm and buildings via a network of pipes as indicated on Drawings No Surface water captured in bunded areas, such as the tank farm, will be tested for contaminants prior to discharge to the drainage system, by pumping from a sump in the bund, to ensure there is no inadvertent discharge to the surface water drainage system. All surface water to be discharged to the attenuation/rainwater harvesting system shall pass through a petrol interceptor, in order to improve the quality of the runoff from the proposed development. The attenuation/rain water harvesting system has a dual purpose of reducing the quantity of discharge from the site by attenuating the flow and providing permanent storage for reuse of collected rainwater in the operation of the proposed facility. It is proposed to re-use water in the surface water attenuation/rain water harvesting system for the following: Wheel wash water requirements Floor wash water requirements The proposed surface water network showing attenuation structures, discharge locations, manhole locations, and direction of flow, is shown on Drawing Nos of the Planning Drawings. Appendix 3 contains calculations providing pipe sizes, cover levels, invert levels and gradients for the network. A flow diagram has been provided in Appendix 1, to further facilitate an understanding of the movement of water throughout the proposed development. 6.2 SURFACE WATER DESIGN Surface water design has been carried out in accordance with requirements of BS 752; the GDSDS (Greater Dublin Strategic Drainage Study) and the Recommendations for Site Development Works for Housing Areas published by the then Department of the Environment (D.O.E.). Drainage of the site is achieved by a combination of piped and channel drainage systems. Calculations for the surface water network are included in Appendix SUSTANABLE URBAN DRAINAGE Implementing the design standards of the GDSDS, the surface water drainage system takes into account the recommendations of the GDSDS and utilises SuDs (sustainable urban drainage) devices where appropriate. The layout of the site has been designed to collect surface water runoff from hardstanding areas and roofs within the development and discharge to surface water attenuation within the boundary of the proposed development. From here the water will be subsequently reused for washdown or will discharge to the existing drainage system at the appropriate Greenfield run off rates. The principal behind SuDs is to reduce the quantity of discharge from developments to predevelopment flows and also to improve the quality of run-off from proposed developments. In this case it is proposed to decrease the quantity of run-off by providing surface water attenuation and utilising stored water for onsite operation requirements, including washdown water and the wheelwash. Calculations for attenuation requirements are provided in Appendix EPA Export :23:31:53

118 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork Applying the GDSDS, in conjunction with site specific rainfall data, an allowable outflow from the site of 6.1 l/s/ha was calculated. As discussed above, it is proposed to limit outflow from the site through attenuation. Due to the levels of the site, a gravity inflow and outflow to and from surface water attenuation/rain water harvesting system has been achieved. Bearing in mind the requirements of the GDSDS and in order to avoid flooding of the site, a 1 in a 30 yr storm event was deemed appropriate, for underground storage. This assessment is based on the Level of service (flooding) for the site as per Volume 2 of the GDSDS, whereby no flooding is allowed on site except where specifically planned for. Additionally the design has been checked in accordance with the other criteria of the GDSDS and the design is such that there is no internal property flooding for a 1 in 100 year storm event. During this scenario storage is provided in the tank bund, the underground attenuation/ rainwater harvesting tank and minor surface flooding in the car park and service yard. The design criteria of the GDSDS determined a storage requirement of 868m 3 including a climate change factor of 20%. The detailed calculations are contained in Appendix 3. It is also intended that storage is provided for site operational use which is approximately 26m 3 /day for washwater requirements. Considering historical rainfall statistics, it is deemed appropriate to allow 10 days for drought conditions on the site and thus an additional 260m 3 of storage is required for this purpose. Total storage in the surface water attenuation/rain water harvesting system will be 1128m 3, with 260m 3 being permanent storage and 868m 3 being attenuation storage. A design risk assessment has been carried out and a potential risk identified is that contaminated water from surface water collected in the tank farm could enter the surface water system. To guard against this it is proposed that no direct connection is provided from bunded areas to the surface warter drainage system. After a rain event, the water shall be tested and pumped to the drainage system on clearance. The quality of runoff from the proposed development is improved by the fact that the surface water attenuation tank will provide some additional settlement and furthermore, the runoff will pass through an oil interceptor prior to discharge to the attenuation/rain water harvesting system. The oil interceptors, will retain any hydrocarbons in the runoff and thereby improve the quality of the runoff. In relation to the capacity of the system the surface water discharge system has been designed as follows: o The surface water attenuation tank will cater for the 1:30yr storm event (and includes for washwater requirements) o The surface water attenuation/storage system caters for storm water attenuation and site operational reuse purposes. o Discharge from the site shall be restricted to Greenfield runoff rates 20 EPA Export :23:31:53

119 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 7 FOUL WATER 7.1 GENERAL Potential sources of foul water in the proposed development are: o Wastewater from sanitary facilities o Overflow water from the wheel wash o Run off from the tank farm bunded area (if contaminated) o Treated process effluent from the Process Water Tank The proposed foul water network is shown on Drawing No of the Planning Drawings. The foul collection network shall be a gravity system, due to the gradient of the site. A flow diagram has been provided in Appendix 1, to further facilitate an understanding of the movement of effluent throughout the proposed development. Appendix 4 contains calculations with respect to the foul discharge loading and network characteristics. 7.2 SANITARY WASTEWATER Sanitary wastewater i.e., wastewater from toilets, washing facilities, kitchens etc. will be collected in each building and directed to the existing public foul sewer, via a foul water collection network. It is estimated that up to 1m 3 /day of sanitary wastewater will be discharged to the sewer. 7.3 WASHWATER WASTEWATER Washwater runoff from the wheel wash will drain to the foul collection network and ultimately to the existing public foul sewer. It is estimated that up to 10m 3 /day of washwater will be discharged to the sewer. 7.4 TANK BUND WASTEWATER Precipitation captured in the tank farm will be tested for contaminants prior to discharge to the surface water drainage system. In the event that there is evidence of contamination discharge will be undertaken manually via over pumping to the foul sewer. 7.5 PROCESS EFFLUENT Process effluent will be produced in the process. The AD process has been designed in order to maximise the reuse of this effluent. The effluent arises from the separate liquid generated at the dewatering stage following digestion and pasteurisation. The effluent will be treated to reduce its organic content. The likely treatment process will be reverse osmosis (RO) that will utilise membrane technology to separate soluble organic components from the liquid. Reverse osmosis produces a low solute concentration permeate that filters through the semi-permeable membranes, and a high solute concentrate that contains the filtered components. Before entering the RO plant, the effluent passes through a suspended solids removal system in order to prevent the membranes in the RO plant becoming critically fouled. The permeate delivered from the RO plant will be recycled to the front end of the process where it will be added to the incoming feedstock in the twin shaft shredders, in order to reduce the dry solids concentration of the incoming material to c.18%. Excess treated process water that is not required for dilution of incoming feedstock will be discharged to the foul network as treated effluent. It is estimated that up to 200m 3 /day of treated process effluent will be discharged to the sewer. This effluent will have a significantly reduced organic loading following the RO treatment, with a maximum population equivalent of c EPA Export :23:31:53

120 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork A flow diagram has been provided in Appendix 1, to further facilitate an understanding of the movement of process effluent throughout the proposed development. 22 EPA Export :23:31:53

121 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 8 SUSTAINABILITY Sustainability has been to the fore in the design and planning of the proposed Plant. The following elements have been included in the design of the Plant. 8.1 SUSTAINABLE URBAN DRAINAGE (SUDS) The principals of Sustainable Urban Drainage (Suds), as set down by the Greater Dublin Strategic Drainage Study, have been implemented in the design of this Plant and specific reference should be made to Section 6 of this Report. The following specific measures have been incorporated into the design which will reduce the quantity of runoff produced and improve the quality of the runoff; Attenuation of storm water run-off (1:30yr event) and discharge at Greenfield runoff rates [controlled by a flow control device]; Capture of storm water run-off and reuse for operational requirements such wash water requirements and wheel wash requirements, thus reducing demand on treated water from the public supply. Surface water collection systems to pass through oil interceptors and grit traps. 8.2 ENERGY EFFICIENCY MEASURES A critical element of the design of the Plant has been to address the energy requirements of the Plant. While the detailed design of the Plant will address specific design issues, such as insulation, lighting fixtures, etc., a number of specific measures have been incorporated into the preliminary design of the Plant to reduce the amount of energy that the Plant will require over its operational lifespan. Some of these measures relate to the buildings while the majority relate to the energy uses of the process Energy Efficiency in the AD Process Both electricity and heat will be generated by the CHP system which is operated on biogas generated by the AD process. Electricity is generated from the combustion of biogas while air and heat is recovered from the cooling jacket, oil lubrication system and flue gas. This plant will produce a supply of 4 MW. The plant will be a net power producer with the excess renewable electricity from the CHP engines exported to the national grid via the substation incorporating transformers. Under normal operation the plant will be powered by the CHPs with supply from the grid provided as a backup. Heat produced from the CHP plant will be used within the process for heating the pasteurisation units and digestion tanks, as well as other ancillary purposes. The reuse of heat will avoid the consumption of natural gas from the grid and the associated carbon emissions extracting the fossil fuel. 23 EPA Export :23:31:53

122 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 9 CONSTRUCTION QUALITY ASSURANCE In order to provide assurance that the Plant is constructed in accordance with the intended design and technical specifications, a comprehensive Construction Quality Assurance (CQA) plan will be implemented during the construction stage. The CQA plan will include Construction Quality Control (CQC) procedures to ensure that materials and workmanship meet defined specifications. Construction quality control procedures will include the integrity testing of all surface water, foul water, process water pipe work and underground structures in accordance with industry accepted standards and procedures. All integrity testing will be inspected and witnessed by an appropriately qualified person acting on behalf of SBE. Integrity test certificates will be signed by both the contractor s engineer and the engineer representing SBE. Following the completion of construction and testing of the Plant and prior to the acceptance of waste, it is proposed that a Construction Quality Assurance (CQA) Report will be prepared by a third party in compliance with good industry practice. 24 EPA Export :23:31:53

123 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 10 ANCILLARY SERVICES 10.1 GENERAL Further engagement with electricity and telecoms service providers will take place following the grant of regulatory approvals for the proposed development. The proposed plant will require a three phase electricity supply connection with an envisaged MIC (Maximum Import Capacity) of approximately 800kVA. This connection will be via an existing electricity pole on site. It is envisaged that the distribution of electricity to the electrical rooms in the Administration, Laboratory and Control Building and the Main Building will be by means of a 10kV/20kV medium voltage network. Hermetically sealed oil cooled transformers will transform the electricity to 400V for distribution in a low voltage network to electrical panels for the powering of plant and equipment at the Plant. The transformers will also transform the electricity to high voltage for distribution to the national grid. The proposed development would export renewable energy onto the electricity network. 25 EPA Export :23:31:53

124 Engineering Services Report Proposed Renewable Bioenergy Plant, Inchera, Little Island, Cork 11 HEALTH & SAFETY 11.1 GENERAL TOBIN Consulting Engineers have complied with the obligations as set out in the Safety, Health, and Welfare at Work Construction Regulations Principles of Prevention have been considered and a design risk assessment for the site development elements of the works has been carried out. Hazards have been identified and where possible they have been engineered out. Where this has not been possible, mitigation measures have been included. A record shall be kept of any residual risks arising and these will be passed on to the contractor in the preliminary Health and Safety Plan, prior to the construction stage. EPA Export :23:31:53

125 Appendix 1 APPENDIX 1 Water Requirements Water Balance Sheet Water Flow Diagram EPA Export :23:31:53

126 1:30yr event with Greenfield runoff rates (6.1l/s/ha) 868m 3 required 10 days Storage for Washwater Requirements 260m 3 required Precipitation Runoff from paved areas diverted to attenuation ponds by surface water sewer network Oil Interceptor (SAAR = 1043 mm) Attenuation/ Rainwater Harvesting System Existing Public Surface Water Sewer Excess volumes to discharge to on site outfall Outfall limited to Greenfield Runoff Rates Outfall controlled by automatic valve, linked to monitoring system Potable Water Supply from Public Watermain 6.1L/s/ha 4.9m 3 /day [Ponds used for attenuation and Washwater Requirements] Floor Wash Process 16 m 3 /day 10 m 3 /day Wheelwash 10m 3 /day Site Foul Sewer Sanitary Waste: Up to 1m3/d Domestic Supply: Up to 1m3/d Firewater Supply: 7,171m3/d Process water Storage Tanks Existing Public Foul Water Sewer Site Watermain for fire/ Domestic Requirements Indicative Water Flow Diagram EPA Export :23:31:53

127 Water Balance - Renewable BioEnergy Plant, Cork Potable Water Requirement Recirculated Water Requirement Fresh Water Requirement Units - AD Process Polymer Make-up 4.9 Mixing and washing Line Cubic Metres/day Mixing and washing Line Cubic Metres/day Washing Cubic Metres/day Plant Operation Floor Washwater 16.0 Cubic Metres/day Wheel Wash Water Requirements 10.0 Cubic Metres/day Site Domestic Water Requirements 0.4 Cubic Metres/day TOTAL Cubic Metres/day Process Effluent available for recycle 464 Fresh water available from Attenuation/Rainwater System 26 Total Water Requirement (Note 1) Cubic Metres/day Excess Waste Water 117 Cubic Metres/day (See Note 1) Note 1: Peak flow is 200m 3 /day EPA Export :23:31:53

128 Appendix 2 APPENDIX 2 Water Supply Design Potable Water Calculations EPA Export :23:31:53

129 PROJECT: File Location: This Element: CALCULATION SHEET Ref No: 7722 Renewable Bioenergy Plant, Inchera, Cork Sheet No: 1 Designer: ELEMENT: Potable Water Demand Date: 20/04/2015 W:\Projects\ Stream BioEnergy Anaerobic Digestion Facility Little Island\04- Potable Water Demand JF Potable Supply for Domestic Use Design Population Site AD Plant Max. No. Visitors 2.0 persons Max. No. Employees (5) Total 14.0 persons 16.0 persons Staff Water Usage Rate Visitor Water Usage Rate 60.0 l/day/person (See Note 2) 10.0 l/day/person (See Note 2) Demand EPA Design Guidelines Avg. Daily Demand l/sec 314 m3/annum Peak Demand l/sec Potable Supply for Ancillary Use Demand Avg. Daily Demand Peak Demand Potable Supply for Firewater l/sec l/sec Demand Peak Demand l/sec (See Note 3) 149 m3/month Pipe Sizing Ø velocity m/s m/s m/s m/s Therefore, use 250 mm diameter watermains Notes: 1. Pipe sizing uses an average velocity of v = 1.2 m/s 2. The Flow rates are obtained from Table 3 Wastewater Treatment Manuals (pg.8). 3. Guidelines on flow requirements for developments served by Dublin Fire Brigade - Class II 4. Wavin Polyethylene Water Systems Technical Guide - max. velocity = 5.0 m/s 5. Max no. of employees per shift is 7 people. At shift changeover, the max. no. of employees is 14 people EPA Export :23:31:53

130 Appendix 3 APPENDIX 3 Surface Water Design Surface Water Network Calculations Rainwater Harvesting/ Attenuation System Calculations Greenfield Runoff Calculation EPA Export :23:31:53

131 PROJECT: Renewable Bioenergy Plant, Inchera, Cork ELEMENT: Greenfield Runoff Calculation CALCULATION SHEET Ref No: 7722 Sheet No: 1 Designer: JF Date: 25/02/2015 File location: This Element: Engineer: W:\Projects\ Stream BioEnergy Anaerobic Digestion Facility Little Island\04-Documents\01-Reports\Engineering Services Report\Appendix 3 Surface Water\[ Greenfield Runoff_dc.xls]Greenfield Runoff Greenfield Runoff Joanne Frehill Runoff Estimation Q bar = *(AREA) 0.89 *(SAAR) 1.17 *(SOIL) 2.17 SAAR = 1048 mm Institute of Hydrology report No Flood Estimation for Small Catchments Area = 50 ha = 0.5 km 2 SOIL = 0.3 (0.15S S S S S 5) Soil type S S S S S Q bar = m 3 /s = l/s Allowable Runoff = l/s/ha (Criterion 4.3, Table 6.3, GDSDS - Volume 2) 5 Site Area discharging to Sewer T Multiplier Flow/ha Flow to Sewer m Ha Flow to Sewer Flow EPA Export :23:31:54

132 CALCULATION SHEET Ref No: 7722 Sheet No: 1 PROJECT: Renewable Bioenergy Plant, Inchera, Cork Designer: JF ELEMENT: Attenuation Pond Calculation Date: 15/04/2015 SURFACE WATER STORAGE : PIPE/TANK Storage Required for Attenuation Storm Return Period Shortcut Key Ctrl + l Ctrl + j Ctrl + y Ctrl + h Ctrl + t Ctrl + e Ctrl + q Storm Return Period = 30 Years Total Site Area = Hectares (ha) Existing Open Space = ha Proposed Impermeable Area Roof Area = 0.39 ha.@ 100% Hard Standing /Road Area = 1.36 ha.@ 100% Permeable Area % Allowable Outflow = 6.1 Litres/sec/ha Rainfall Intensity as recorded at Cork Airport 1 hectare = 10,000m 2 Duration Rainfall Intensity Rainfall Proposed Total Allowable Storage Runoff Runoff Outflow Req'd (min) (mm) (mm/hr) (m 3 /ha) (m 3 ) (m 3 ) (m 3 ) (m 3 ) Minimum value of storage required = 868 m 3 Oversized Pipe Requirements Tank Requirements Pipe dia. Length X = 27 m Y = 1.2 m (mm) (m) Z = 27 m Y Storage Required for Operation Use X Z Wheel Wash Water Requirements 10 m3/day Washwater Requirement 16 m3/day 26 m3/day Having looked at the rainfall data for the last two years at cork airport and have noted the following: There was only 4 occurrences where the there was no rain for more than 11 consecutive days There was only 23 occurrences where there was no rain for more than 3 consecutive days We feel that 10 days of storage would be more than enough to provide sufficient storage 260 m3 Total Required 1128 m 3 EPA Export :23:31:54

133 CALCULATION SHEET Ref No: 7722 Sheet No: 2 PROJECT: Renewable Bioenergy Plant, Inchera, Cork Designer: JF ELEMENT: Attenuation Pond Calculation Date: 15/04/2015 EPA Export :23:31:54

134 CALCULATION SHEET PROJECT: Renewable Bioenergy Plant, Inchera, Cork ELEMENT: Surface Water Flow Calculation File location: W:\Projects\ Stream BioEnergy Anaerobic Digestion Facility Little Island\04- This ElementSurface Water Flow Calculation Ref No: Sheet No: Designer: Date: JF 08/04/2015 Note: "A" Refers to Impervious Area Only Rainfall Intensity (i) mm 50 Area Runoff Pipe Sewer Ref: A Cum. A Q Cum. Q Run Dia Gradient Velocity Capacity (Ha) (Ha) l/s l/s m mm 1 : x m/sec l/sec MH 1 G G2 G G3 MH MH 2 G G5 MH MH 3 G G7 G G8 G G9 MH MH 4 MH MH 5.5 MH MH 5 MH MH8 Tank Tank MH MH9 ExManhole MB1 MB MB2 MB MB3 MB MB4 MB MB5 MB MB6 MH MH6 MH di Workshop MH di MH7 MH EPA Export :23:31:54

135 CALCULATION SHEET Ref No: Sheet No: Designer: Date: JF 08/04/2015 PROJECT: ELEMENT: File location: This Element: Renewable Bioenergy Plant, Inchera, Cork Manhole Schedule W:\Projects\ Stream BioEnergy Anaerobic Digestion Facility Little Island\04- Manhole Schedule Min cover in Trafficked areas is Min cover in Other areas is 1.2 m 0.9 m MH No. MH No. Upstream Downstream Upstream Downstream Upstream Downstream Grad. Dia Distance C.L C.L I.L I.L Cover Cover 1 : x mm MH 1 G mod 7.84 mod 6.48 mod 6.38 mod 1.20 m 1.23 m G2 G mod 7.75 mod 6.38 mod 6.30 mod 1.23 m 1.23 m G3 MH mod 7.69 mod 6.30 mod 6.23 mod 1.23 m 1.23 m MH 2 G mod 7.63 mod 6.23 mod 6.17 mod 1.08 m 1.08 m G5 MH mod 7.75 mod 6.17 mod 6.07 mod 1.30 m 1.30 m MH 3 G mod 7.93 mod 6.07 mod 6.00 mod 1.55 m 1.55 m G7 G mod 7.83 mod 6.00 mod 5.91 mod 1.55 m 1.55 m G8 G mod 7.74 mod 5.91 mod 5.81 mod 1.48 m 1.48 m G9 MH mod 7.62 mod 5.81 mod 5.70 mod 1.48 m 1.48 m MH 4 MH mod 7.51 mod 5.97 mod 5.63 mod 1.20 m 1.43 m MH 5 MH mod 7.90 mod 5.63 mod 5.55 mod 1.43 m 1.90 m MH8 Tank 7.90 mod 7.90 mod 5.55 mod 5.45 mod 1.90 m 2.00 m Tank MH mod 7.12 mod 5.45 mod 5.35 mod 1.72 m 1.54 m MH9 ExManhole 7.12 mod 7.12 mod 5.35 mod 5.33 mod 1.54 m 1.56 m EPA Export :23:31:54

136 Appendix 4 APPENDIX 4 Foul Water Design Foul Discharge Loading EPA Export :23:31:54

137 PROJECT: ELEMENT: File location: This Element: CALCULATION SHEET Renewable Bioenergy Plant, Inchera, Cork Foul Water Discharge Ref No: Sheet No: Designer: Date: W:\Projects\ Stream BioEnergy Anaerobic Digestion Facility Little Island\04-Documents\01- Foul Water Discharge JF 20/04/2015 Sanitary Wastewater Applying BS EN 752: Design Population Site Bioenergy Renewable Plant, Cork Max. No. Visitors per day Max. No. Employees 2.0 persons 14.0 persons Average DWF Staff Foul Discharge 60.0 l/person/day Visitor Foul Discharge 10.0 l/person/day DWF l/sec or m³/d Peak Design Flow 6*DWF l/sec or m³/d Process Wastewater Flow Average Design Flow Q = l/sec or m³/d Peak Design Flow l/sec or m³/d Wheel Wash Flow AverageDesign Flow l/sec or m³/d Peak Design Flow Q = l/sec or m³/d Tank Bund Bund Area (ha) Peak Design Flow Q= l/sec 0.04 m3/event Colebrook-White Formula Q = l/sec Pipe Dia. Ø = mm ks = 1.50 mm Gradient = 1 in Kinematic viscosity 1.141x10^-6 m²/sec Q = l/sec OK Self Cleansing Vel m/sec v = m/sec OK Summary Use 275mmØ min. pipe size if using gravity sewers Use 1:300 min. gradient to ensure self-cleansing velocities are achieved with gravity sewers. EPA Export :23:31:54

138 INTERNATIONAL NETWORK Galway Fairgreen House, Fairgreen Road, Galway. Ph +353 (0) Fax +353 (0) Dublin Block 10-4, Blanchardstown Corporate Park, Dublin 15. Ph +353 (0) Fax +353 (0) Castlebar Market Square, Castlebar, Co. Mayo. Ph +353 (0) Fax +353 (0) visit Krakow (Poland) Ul. Cystersow 9, , Krakow, Poland. Ph Fax poland@tobin.ie Oxfordshire (UK) CAB International Nosworthy Way, Wallingford, Oxfordshire. Ph Fax uk@tobin.ie EPA Export :23:31:54

139 LITTLE ISLAND B I O E N E R G Y BASELINE REPORT Appendix 2 Laboratory Report EPA Export :23:31:54

140 Jones Environmental Laboratory Registered Address : Unit 3 Deeside Point, Zone 3, Deeside Industrial Park, Deeside, CH5 2UA. UK O'Callaghan Moran & Associates Unit 15 Melbourne Business Park Model Farm Cork Ireland Unit 3 Deeside Point Zone 3 Deeside Industrial Park Deeside CH5 2UA Tel: +44 (0) Fax: +44 (0) Attention : Date : Neil Sandes 16th February, 2015 Your reference : Our reference : Location : Date samples received : Status : Issue : Test Report 15/3446 Batch 1 Schedule A Inchera Little Island 10th February, 2015 Final report 1 Eighteen samples were received for analysis on 10th February, 2015 of which twelve were scheduled for analysis. Please find attached our Test Report which should be read with notes at the end of the report and should include all sections if reproduced. Interpretations and opinions are outside the scope of any accreditation, and all results relate only to samples supplied. All analysis is carried out on as received samples and reported on a dry weight basis unless stated otherwise. Results are not surrogate corrected. Compiled By: Bruce Leslie Project Co-ordinator Bob Millward BSc FRSC Principal Chemist QF-PM v16 Please include all sections of this report if it is reproduced All solid results are expressed on a dry weight basis unless stated otherwise. 1 of 7 EPA Export :23:31:54

141 Jones Environmental Laboratory Client Name: O'Callaghan Moran & Associates Report : Solid Reference: Location: Contact: JE Job No.: 15/3446 Inchera Little Island Neil Sandes Solids: V=60g VOC jar, J=250g glass jar, T=plastic tub J E Sample No Sample ID TP-1 TP-2 TP-3 TP-4 TP-5 TP-6 TP-7 TP-8 TP-9 TP-10 COC No / misc Depth Please see attached notes for all abbreviations and acronyms Containers V J V J V J V J V J V J V J V J V J V J Sample Date 05/02/ /02/ /02/ /02/ /02/ /02/ /02/ /02/ /02/ /02/2015 Sample Type Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Batch Number Date of Receipt 10/02/ /02/ /02/ /02/ /02/ /02/ /02/ /02/ /02/ /02/2015 LOD/LOR Units Method No. EPH (C8-C40) # <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 mg/kg TM5/PM8 Natural Moisture Content <0.1 % PM4/PM0 Chloride # <2 mg/kg TM38/PM20 ph # <0.01 ph units TM73/PM11 QF-PM v11 Please include all sections of this report if it is reproduced All solid results are expressed on a dry weight basis unless stated otherwise. 2 of 7 EPA Export :23:31:54

142 Jones Environmental Laboratory Client Name: O'Callaghan Moran & Associates Report : Solid Reference: Location: Inchera Little Island Solids: V=60g VOC jar, J=250g glass jar, T=plastic tub Contact: JE Job No.: Neil Sandes 15/3446 J E Sample No Sample ID TP-11 TP-12 COC No / misc Depth Please see attached notes for all abbreviations and acronyms Containers V J V J Sample Date 06/02/ /02/2015 Sample Type Soil Soil Batch Number 1 1 Date of Receipt 10/02/ /02/2015 LOD/LOR Units Method No. EPH (C8-C40) # <30 36 <30 mg/kg TM5/PM8 Natural Moisture Content <0.1 % PM4/PM0 Chloride # <2 mg/kg TM38/PM20 ph # <0.01 ph units TM73/PM11 QF-PM v11 Please include all sections of this report if it is reproduced All solid results are expressed on a dry weight basis unless stated otherwise. 3 of 7 EPA Export :23:31:54

143 Jones Environmental Laboratory Notification of Deviating Samples Client Name: Reference: Location: Contact: O'Callaghan Moran & Associates Inchera Little Island Neil Sandes J E Job No. Batch Sample ID Depth J E Sample No. Analysis Reason No deviating sample report results for job 15/3446 Please note that only samples that are deviating are mentioned in this report. If no samples are listed it is because none were deviating. Only analyses which are accredited are recorded as deviating if set criteria are not met. QF-PM v3 Please include all sections of this report if it is reproduced 4 of 7 EPA Export :23:31:54

144 NOTES TO ACCOMPANY ALL SCHEDULES AND REPORTS JE Job No.: SOILS Please note we are only MCERTS accredited for sand, loam and clay and any other matrix is outside our scope of accreditation. Where an MCERTS report has been requested, you will be notified within 48 hours of any samples that have been identified as being outside our MCERTS scope. As validation has been performed on clay, sand and loam, only samples that are predominantly these matrices, or combinations of them will be within our MCERTS scope. If samples are not one of a combination of the above matrices they will not be marked as MCERTS accredited. It is assumed that you have taken representative samples on site and require analysis on a representative subsample. Stones will generally be included unless we are requested to remove them. All samples will be discarded one month after the date of reporting, unless we are instructed to the contrary. If we are instructed to keep samples, a storage charge of 1 (1.5 Euros) per sample per month will be applied until we are asked to dispose of them. If you have not already done so, please send us a purchase order if this is required by your company. Where appropriate please make sure that our detection limits are suitable for your needs, if they are not, please notify us immediately. All analysis is reported on a dry weight basis unless stated otherwise. Results are not surrogate corrected. Samples are dried at 35 C ±5 C unless otherwise stated. Moisture content for CEN Leachate tests are dried at 105 C ±5 C. Where Mineral Oil or Fats, Oils and Grease is quoted, this refers to Total Aliphatics C10-C40. Where a CEN 10:1 ZERO Headspace VOC test has been carried out, a 10:1 ratio of water to wet (as received) soil has been used. % Asbestos in Asbestos Containing Materials (ACMs) is determined by reference to HSG 264 The Survey Guide - Appendix 2 : ACMs in buildings listed in order of ease of fibre release. WATERS 15/3446 Please note we are not a Drinking Water Inspectorate (DWI) Approved Laboratory. It is important that detection limits are carefully considered when requesting water analysis. UKAS accreditation applies to surface water and groundwater and one other matrix which is analysis specific, any other liquids are outside our scope of accreditation As surface waters require different sample preparation to groundwaters the laboratory must be informed of the water type when submitting samples. Where Mineral Oil or Fats, Oils and Grease is quoted, this refers to Total Aliphatics C10-C40. DEVIATING SAMPLES Samples must be received in a condition appropriate to the requested analyses. All samples should be submitted to the laboratory in suitable containers with sufficient ice packs to sustain an appropriate temperature for the requested analysis. If this is not the case you will be informed and any test results that may be compromised highlighted on your deviating samples report. SURROGATES Surrogate compounds are added during the preparation process to monitor recovery of analytes. However low recovery in soils is often due to peat, clay or other organic rich matrices. For waters this can be due to oxidants, surfactants, organic rich sediments or remediation fluids. Acceptable limits for most organic methods are % and for VOCs are %. When surrogate recoveries are outside the performance criteria but the associated AQC passes this is assumed to be due to matrix effect. Results are not surrogate corrected. DILUTIONS A dilution suffix indicates a dilution has been performed and the reported result takes this into account. No further calculation is required. NOTE Data is only reported if the laboratory is confident that the data is a true reflection of the samples analysed. Data is only reported as accredited when all the requirements of our Quality System have been met. In certain circumstances where all the requirements of the Quality System have not been met, for instance if the associated AQC has failed, the reason is fully investigated and documented. The sample data is then evaluated alongside the other quality control checks performed during analysis to determine its suitability. Following this evaluation, provided the sample results have not been effected, the data is reported but accreditation is removed. It is a UKAS requirement for data not reported as accredited to be considered indicative only, but this does not mean the data is not valid. Where possible, and if requested, samples will be re-extracted and a revised report issued with accredited results. Please do not hesitate to contact the laboratory if further details are required of the circumstances which have led to the removal of accreditation. QF-PM v30 Please include all sections of this report if it is reproduced All solid results are expressed on a dry weight basis unless stated otherwise. 5 of 7 EPA Export :23:31:54

145 JE Job No.: 15/3446 ABBREVIATIONS and ACRONYMS USED # B DR M NA NAD ND NDP SS SV W + ++ * AD CO LOD/LOR ME NFD OC UKAS accredited. Indicates analyte found in associated method blank. Dilution required. MCERTS accredited. Not applicable No Asbestos Detected. None Detected (usually refers to VOC and/svoc TICs). No Determination Possible Calibrated against a single substance Surrogate recovery outside performance criteria. This may be due to a matrix effect. Results expressed on as received basis. AQC failure, accreditation has been removed from this result, if appropriate, see 'Note' on previous page. Result outside calibration range, results should be considered as indicative only and are not accredited. Analysis subcontracted to a Jones Environmental approved laboratory. Samples are dried at 35 C ±5 C Suspected carry over Limit of Detection (Limit of Reporting) in line with ISO and MCERTS Matrix Effect No Fibres Detected Outside Calibration Range QF-PM v30 Please include all sections of this report if it is reproduced All solid results are expressed on a dry weight basis unless stated otherwise. 6 of 7 EPA Export :23:31:54

146 Jones Environmental Laboratory Method Code Appendix JE Job No: 15/3446 Test Method No. Description Prep Method No. (if appropriate) Description UKAS MCERTS (soils only) Analysis done on As Received (AR) or Dried (AD) Reported on dry weight basis PM4 Gravimetric measurement of Natural Moisture Content and % Moisture Content at either 35 C or 105 C. Calculation based on ISO and BS1377. PM0 No preparation is required. TM5 TM38 TM73 Modified USEPA 8015B method for the determination of solvent Extractable Petroleum Hydrocarbons (EPH) with carbon banding within the range C8-C40 GC-FID. Soluble Ion analysis using the Thermo Aquakem Photometric Automatic Analyser. Modified US EPA methods 325.2, 375.4, 365.2, 353.1, Modified US EPA methods and 9045D. Determination of ph by Metrohm automated probe analyser. PM8 PM20 End over end extraction of solid samples for organic analysis. The solvent mix varies depending on analysis required. Extraction of dried and ground samples with deionised water in a 2:1 water to solid ratio for anions. Extraction of as received samples with deionised water in a 2:1 water to solid ratio for ammoniacal nitrogen. Samples are extracted using an orbital shaker. Yes AR Yes Yes AD Yes PM11 Extraction of as received solid samples using one part solid to 2.5 parts deionised water. Yes AR No QF-PM v14 Please include all sections of this report if it is reproduced 7 of 7 EPA Export :23:31:54

147 LITTLE ISLAND B I O E N E R G Y BASELINE REPORT Appendix 3 Tapella IPPC (Reg No. PO103-02) Licence Surrender Report EPA Export :23:31:54

148 Tapella Ltd. IPPC Licence Reg. No. PO IPPC LICENCE SURRENDER Independent Closure Audit March 2015 Prepared by: Declan Waugh B.Sc. C.WEM. C.Env. MCIWEM. MIEMA. MCIWM. Report Number: 23/03/15/TPLS EPA Export :23:31:54

149 EnviroManagement Services 11 Riverview O Doherty s Rd Bandon Co. Cork Ireland Tel: declan@enviro.ie Website: Project Title: Report Title: Report No: Status: Issued by: Tapella Ltd IPPC Licence surrender IPPC Licence Surrender 23/03/15TPLS Final Document Approval Record: EnviroManagement Services Approved By Signature Date Position Declan Waugh 23 rd Mar 2015 Chartered Water and Environmental Manager Environmental Consultant EPA Export :23:31:54

150 Contents 1.0 INTRODUCTION General History Environmental Risk and Liabilities Residual Management Plan Post Closure Site Investigation Detailed Qualitative risk Assessment (DQRA) Environmental Liabilities Risk Assessment (ELRA) Regulatory oversight by the EPA Transfer of IPPC Licence Financial Provision for Environmental Liabilities Site Decommissioning Current Status of Site Stockpile of Inert recovered product Status of Site Buildings Current Status of Groundwater Environmental Status of Site Criteria for Successful Decommissioning and IPPC Surrender Application for Surrender of IPPC licence Appendix 1: Site Map Appendix 2: Analysis of Recovered C& D Waste Appendix 3: Groundwater Monitoring Report March 2015 Appendix 4. Waste Register for Demolition Works Appendix 5. Certificate of Completion of Demolition and Site Clearance Works. EPA Export :23:31:54

151 TAPELLA IPPC LICENCE SURRENDER-PO INTRODUCTION 1.1 General Tapella Ltd. Hoffmann Park is located at the former Pfizer site located on a 31 acre site (developed) at Inchera in the Little Island Industrial Estate. Production ceased on the site in 2010 and IPPC licence conditions ceased to have effect from March Planning permission was obtained for demolition and site clearance works of the former production facilities in March 2013 and works were completed in late October The decommissioning of plant, buildings and associated facilities related to previous licensable facilities has left the site is in a satisfactory state. The potential for environmental pollution in its current status is negligible. Having consideration for the environmental investigations carried out on site, the termination of IPPC licence conditions and successful decommissioning of the former production facilities Tapella Ltd. now seek for the IPPC licence to be surrendered. This documented provides supplementary information to the application form for IPPC Licence surrender. 1.2 History Tapella Ltd. Hoffmann Park is located at the former Pfizer site located on a 31 acre site (developed) at Inchera in the Little Island Industrial Estate. Pfizer Cork Ltd (PCL) was granted an Integrated Pollution Control (IPC) Licence (Reg. No. P ) by the EPA on 28th November 1996 for the manufacture of pesticides, pharmaceutical or veterinary products and their intermediates. In February 2007, PCL announced the decision to sell/close the Pfizer Cork Ltd. site. The IPC licence was reviewed and replaced by an Integrated Pollution Prevention Control (IPPC) Licence (Reg. No. P ) which was issued by the EPA on 21 st January 2008 for: the use of a chemical or biological process for the production of basic pharmaceutical products. and the removal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required. Production of pharmaceuticals on site ceased in February 2010 along with associated emissions. Following termination of licensable activities, in accordance with guidance recommendations PCL undertook a programme of decommissioning on site. The Wastewater Treatment Plant was shut down and ceased operation in June In accordance with EPA approval monitoring of the storm water was discontinued in September In Oct 2011, PCL initiated a project for the disinvestment of certain items of remaining plant and equipment. Prior to commencement of works Pfizer submitted a detailed Waste Management Plan to the EPA. 1 P a g e EPA Export :23:31:54

152 TAPELLA IPPC LICENCE SURRENDER-PO All wastes which arose from this work programme were detailed in the 2012 AER report submitted by Pfizer to the EPA. In accordance with best practice all production systems and buildings were decommissioned by PCL. The programme of works undertaken by PCL included the removal of process chemicals, liquid and solid materials stored on site and the cleaning of drains and ancillary pipework. PCL announced the sale of the site to Tapella Ltd on the 13th January The sale was subject to agreement on financial provision mechanisms to cover liabilities identified by PCL in relation to historical activities on site and acceptance by the Environmental Protection Agency (EPA) on licence transfer to Tapella Ltd. The EPA agreed the terms of financial provisions in May The existing IPPC licence was transferred to Tapella Ltd on the 4 th July Tapella were notifed by the EPA on the 4th February 2013, that the IPPC licence PO ceased to have effect from the 4th March Conditions pertaining to groundwater monitoring were to remain on the site until such time as the Agency agreed that no further monitoring or remediation is required facilitating the surrender of the IPPC licence in acordance with Section 95 of the EPA Acts 1992 and Environmental Risk and Liabilities Pfizer Cork Ltd (PCL) undertook detailed due diligence including site investigations and risk assessments pertaining to the presence or absence of environmental impacts associated with the legacy Inchera API facility in Cork, Ireland (hereafter referred to as the Site). 2.1 Residual Management Plan In 2008, Pfizer Cork Ltd (PCL) submitted a Residual Management Plan (RMP) report (Pfizer Cork Ltd., Inchera- Residual Management Plan, URS Report, dated 17 th June 2008). The RMP addressed site decommissioning, closure and remediation. The RMP recommended a post closure investigation of soil and groundwater to determine whether the site required soil or groundwater remediation programmes. 2.2 Post Closure Site Investigation. In February 2011, PCL submitted a site investigation report (URS Report ref: /2248/CKRP0001 Final, dated 18 th February 2011) on the comprehensive site investigation works that were carried out in 2010 to quantify site environmental conditions for soil and groundwater across the PCL site. The key steps of investigation involved: 1. Characterising potential source areas of chemical release (soils); 2. Soil sampling of potential source areas 3. Groundwater sampling for target compounds based on assessment of current and historical operations on the site; 4. Recommendation for remediation as appropriate. The investigations involved the excavation of 12 trial pits and the drilling of 42 soil bores and 6 additional groundwater wells. In total, 107 soil samples and 34 groundwater samples were analysed for a wide range of parameters. The investigation determined that soil and groundwater contamination was extremely localised with negligible risk to the surrounding environment. The EPA agreed to a groundwater management programme and the results of the ongoing sampling continue to show declining concentrations trends for all contaminants. 2 P a g e EPA Export :23:31:54

153 TAPELLA IPPC LICENCE SURRENDER-PO Detailed Qualitative risk Assessment (DQRA). In December 2011, PCL submitted the Detailed Quantitative Risk Assessment (DQRA) report ( Pfizer Cork Ltd., Inchera Detailed Quantitative Risk Assessment, URS Report /DURP0001Final Dated 20 th April 2011) for the Inchera site. In summary the DQRA concluded that the potential human health risks to current and future site workers associated with reported concentrations in soil and groundwater underlying the site were not considered significant. The peak concentrations of contaminants identified in groundwater underlying the site were not considered significant in terms of potential risk to surface water quality in the key surface water receptors adjacent to the site. The DQRA found that any residual contamination on site would continue to reduce through natural attenuation over time. It was recommended that groundwater monitoring be continued for a period as agreed with Agency. This position would be kept under review with the Agency in the event of future sustained adverse groundwater monitoring results. 2.4 Environmental Liabilities Risk Assessment (ELRA) In March 2012, PCL submitted the Environmental risk Liabilities Risk Assessment Report undertaken by URS (Ref: ELRA ) which addressed the historic environmental liabilities and financial provisions for the site from past and present activities. The risk identified in the site specific ELRA were regarded as negligible. The ELRA determined the costs of unknown liabilities to be 45,000 which included the costs of groundwater monitoring Regulatory oversight by the EPA In March 2014, the EPA confirmed to PLC (Ref: P /ap01mor.docx, Dated 16 th March 2012) that the information contained in the ELRA, Residual Management Plan and Detailed Quantitative Risk Assessment Reports were to the satisfaction of the Agency. In considering the DQRA submitted the EPA confirmed that is was in agreement with the DQRA conclusion that the environmental risk posed by the presence of contaminants in the groundwater underlying the site is not significant. The agency required that quarterly monitoring continue for a period in order to confirm that the risk continues to be mitigated. 4.0 Transfer of IPPC Licence Pfizer announced the sale of the site to Tapella Ltd on the 13th January The sale was subject to agreement on financial provision mechanisms to cover liabilities identified by Pfizer in relation to historical activities on site and acceptance by the Environmental Protection Agency (EPA) on licence transfer to Tapella Ltd. The EPA agreed the terms of financial provisions in May The existing IPPC licence was transferred to Tapella Ltd on the 4 th July P a g e EPA Export :23:31:54

154 TAPELLA IPPC LICENCE SURRENDER-PO Financial Provision for Environmental Liabilities In May 2014, the EPA (Ref: P /ap02mor.docx, Dated 14th May 2012) agreed the financial provisions submitted by Tapella to cover environmental liabilities pertaining to the site. 5.0 Site Decommissioning Tapella Ltd. received planning permission (Ref 12/06090) in March 2013 for the demolition of redundant industrial buildings, structure, plamt and equipment including a purified water building, production buildings, milling and drying buildins, operationa facilities buildings, technical services offices, synthesis plant, stores, workshops, utilities building, substation and ancillary pipe racks, plant and equipment. Demolition works commenced on the 21st June 2013 and were completed in on the 23rd October Subject to completion of demolition works and ongoing groundwater surveillance, the IPPC licence is to be surrendered in accordance with Section 95 of the EPA Acts 1992 and The scope of the demolition work involved the decommissioning and demolition of specific built infrastructure. All waste arising from the proposed works were recycled or disposed of in licensed waste facilities using authorised waste contractors in accordance with IPPC licence requirements. The main work packages comprised the following infrastructure: Syn1, Core, Tanks external to Syn1 Kilo Plant and tanks external to Kilo North side utilities building, North stores P1,P2,P3,P4,P6, Milling and Drying, Operational facilities, Technical services offices OP5 and external tanks Southside Tank Farm, pipe racks and pipes external to buildings Southside Utilities, Switch Room, Transformers, Generator room Old Engineering Stores Workshop Water Purification buildings and water storage tanks Tapella Ltd commissioned Keltbray, a leading specialist engineering, demolition, decommissioning and remediation company to oversee and manage the demolition works on site and all activities associated with waste management arising from demolition and site clean-up. Materials generated from the demolition of the structures at Inchera, Little island, Cork can be categorized into the recycled products, general waste, scrap metals and hazardous waste. A detailed demolition waste register was completed in accordance with best practice documenting the schedule of waste arising and certification of recovery and disposal. 4 P a g e EPA Export :23:31:54

155 TAPELLA IPPC LICENCE SURRENDER-PO In summary, the total quantity of waste generated from the demolition and site cleanup works are; Scrap Metals 3, tonnes General Waste 273 tonnes Hazardous Wastes Sodium Hydrochloride Washings 1 IBC Wipes contaminated with Sodium Hydrochloride and Vesta Litres Asbestos Waste 0.41tonnes As part of the site decommissing and demolition works Keltbray undertook crushing of inert construction and demolition waste arising from site demolishing works. Demolished blocks were crushed and screened on site for future use as recycled aggregate. Metal waste was removed mechanically with magnets and manual hand picking was undertaken to remove plastics and other wastes. Waste arising from screening of material were recycled or disposed of as general waste. External steel cladding building material was recycled and reused by Pfizer Inc. Demolition works were completed in accordance with planning conditions and site clean-up was completed without environmental incident. No environmental damage or contamination arose as a consequence of demolition works. 5 P a g e EPA Export :23:31:55

156 TAPELLA IPPC LICENCE SURRENDER-PO Current Status of Site The site clearance areas where demolition works were completed comprising the former production facilities and associated infrastructure remain vacant. The Figures 1-4 provide evidence of completion of site clearance works. A certification of completion of site clearance and demolition works by Keltbray Ltd is provided in Appendix Stockpile of Inert recovered product Approximately15,000 tonnes of recovered inert material was produced from the demolition works. The recycled product has been screened with steel, timber and plastic removed. The recovered material is stockpiled on a hard standing area that was previously used as a car park. The recycled aggretate product does not contain any tarmac or contaminated soil or subsoil. Four composite samples of material were sampled and analysed for a range of contaminants to determine the classification of waste material in accordance with specified standards. The results of analysis are provided in Appendix 2. All samples were found to comply with the criteria for inert material. It is intention of Tapella Ltd. to reuse this material for the Dunkettle interchange improvement scheme. The Dunkettle interchange improvement scheme requires development works on the northern portion of the existing Inchera site. It is anticipated that significant infilling will be required for the Dukettle interchange improvement scheme. Reuse of recovery inert material for the Dukettle interchange improvement scheme provides for the most cost effective and sustainable environmental management of inert material from site demolition works. Recycled aggregate can be used as general bulk fill, sub base material in road construction Status of Site Buildings The Dunkettle office building and canteen remains unoccupied. The remaining on-site buildings that were not associated with production and manufacturing and were not part of the demolition works programme were retrofitted for use as offices, maintenance warehouses and support facilities. These buildings are currently occupied by a number of tenants. There are no discharges to WWTP which remains decommissioned. All office effluent discharges are to foul network connected to Cork County Council foul sewer. 1 Hemalatha B.R. et al. Construction And Demolition Waste Recycling For Sustainable Growth And Development, Journal of Environmental Research And Development Vol. 2 No. 4, April-June P a g e EPA Export :23:31:55

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161 TAPELLA IPPC LICENCE SURRENDER-PO Current Status of Groundwater Post completion of demolition and site clearance works ground water monitoring was undertaken in March and June 2014, with further sampling undertaken in February Monitoring consisted of the sampling of wells BH2, BH5, 03-05, 03-07, 06-02, 06-05, and for volatile organic compunds (VOCs), Semi-Volatile Organic Compounds (SVOCs); Chemical Oxygen Demand (COD), Methyl tert butyl ether (MTBE), Arsenic and Mercury as agreed with the Agency. A report addressing the results of groundwater monitoring was submitted to the Agency on the 25th July The updated groundwater report is provided in Appendix 3. Monitoring results for are representative of post demolition conditions on site and demonstrate that remediation works did not result in any deterioration of groundwater quality. Monitoring results demonstrate a continuous trend of improvement in groundwater quality on site. The continued improvement in groundwater quality is graphically illustrated in Figures 5 and 6 representing current and historical chloroform and MBTE detected in groundwater. Both graphs illustrate a continuing downward trend for both parameters. Chloroform levels continue to decline with an 8 fold reduction in measured levels observed between 2010 and February The concentration of chloroform in well BH2 and BH5 are below the GTV (75 μg/l) and DIV (400 μg/l) for chloroform. The concentration of arsenic in monitoring wells shows a modest decline between March 2014 and February MTBE concentrations in wells and are significantly lower than recorded in previous years. The reduction in MBTE concentrations is more gradual in well However significant reductions (18 fold) are evident compared to the period November The mercury concentration measured in well is February 2015 are the lowest reported to date measuring 0.03ug/L. Overall, data from the monitoring programme clearly demonstrates that residual groundwater contamination on site is reducing with continued decreasing concentration trends over time. 8.0 Environmental Status of Site All activities associated with the former IPPC licence ceased on site in 2010 and there are no environmental emissions associated with prior activities. The former production areas are vacant. The decommissioning of plant, buildings and associated facilities related to previous licensable production facilities has left the site is in a satisfactory state suitable for re-use of redevelopment. The condition of the site based on its current activity is not likely to cause environmental pollution and the potential for environmental pollution in its current status is negligible. Having consideration for the entensive environmental investigations carried out on site, the termination of IPPC licence conditions and successful decommissioning of the former production facilities Tapella Ltd now seek for the IPPC licence to be surrendered. 11 P a g e EPA Export :23:31:55

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164 TAPELLA IPPC LICENCE SURRENDER-PO Criteria for Successful Decommissioning and IPPC Surrender The criteria for successful decommissoning to ensure minimim impact on the environment with respect to residuals managament require that all buildings, waste or any other materials that could result in environmental pollution are removed from the site and recycled, recovered or disposed in accordance with regulations. The programme of works to ensure successful decommissioning includes: Stage 1: Stage 2: Stage 3: Stage 4: Stage 5: Stage 6: Stage 7: Stage 8: Stage 9: The removal of excess raw material and final products from site; The removal of production related hazardous waste/non hazardous wastes from site; Documentation to ensure that all raw materials and finished product were dispatched from the site; The cleaning of tanks, bunds, sumps and interceptors; The decontamination of all process equipment in accordance with best practice; Documentation to ensure that cleaning and decontamination was completed to agreed standards; Decommossioning of production plant and services including removal for recovery or disposal of contaminated process equipment and ancillary infrastructure including pipes, tanks, metal, non hazardous waste and hazardous material; Demolition of buildings and removal of uncontaminated equipment in accordance with planning permission; Documentation on the disposal of hazardous waste including full certification required under law (Trans-fronteir shipment of Hazardous waste Regulations, 1988, Waste Managemernt Act, 1996 and any amendments to waste legislation, and the company IPPC licence); Documention on the disposal of non-hazardous wastes including certification of disposal under the Waste Management Act and IPPC licence; Documentation relating to the proper management and removal of asbestos material; Stage 10: Stage 11: Stage 12: Documentation and certification of completion of decommissioning works. An assessment of groundwater contamination verified by a program of groundwater monitoring to determine if demolition works resulted in deteoriation of groundwater quality or increase in contaminant concentrations in groundwater; Completion of residual management plan including determination of whether ongoing groudwater monitoring is required. 14 P a g e EPA Export :23:31:55

165 TAPELLA IPPC LICENCE SURRENDER-PO Stages 1 through 6 were completed by Pfizer Cork Ltd prior to the completion of sale and transfer of IPPC licence to Tapella Ltd. Details of all historical waste records have been provided in the Pollutant Release and Transfer Register (PRTR) returns for the site submitted in the 2010 Annual Environmental Report (AER) and in on-site waste records for Tapella Ltd commissioned Keltbray to complete stages This programme of works was completed in Oct Documentation to support completion of programme of works is provided in Appendix 4 & 5. Post completion of demolition works groundwater monitoring has been undertaken on site. Groundwater monitoring data continues to demonstrate that residual groundwater contamination on site is reducing with decreasing concentration trends over time. Details of current groundwater monitoring data are provided in Appendix Application for Surrender of IPPC licence. The licensee Tapella Ltd. in accordance with the companys requirements under their Integrated Pollution Prevention and Control Licence now seek to surrender the EPA IPPC licence at Inchera, Little Island. This report is provided as supplementarty information to the IPPC licence surrender application. On completion of surrender of IPPC licence and subject to agreement with the EPA all monitoring wells shall be decommossioned and sealed by grouting the entire lenght of the well. 15 P a g e EPA Export :23:31:55

166 TAPELLA IPPC LICENCE SURRENDER-PO Appendix 1. Site Map showing current status and groundwater monitoring wells 1 P a g e EPA Export :23:31:55

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168 : Appendix 2. Analysis of Recovered C&D Waste P a g e EPA Export :23:31:55

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171 : Appendix 3. Groundwater Report March 2015 P a g e EPA Export :23:31:55

172 : Tapella Ltd. IPPC Licence Reg. No. PO GROUNDWATER QUALITY STATUS REPORT March 2015 Prepared by: Declan Waugh B.Sc. C.WEM. C.Env. MCIWEM. MIEMA. MCIWM. Report Number: TP P a g e EPA Export :23:31:55

173 : EnviroManagement Services 11 Riverview O Doherty s Rd Bandon Co. Cork Ireland Tel: declan@enviro.ie Website: Project Title: Tapella Ltd Groundwater Monitoring Report Title: Report No: Status: Issued by: Groundwater Monitoring Status Report TP Final Document Approval Record: EnviroManagement Services Approved By Signature Date Position Declan Waugh 11 th March 2015 Chartered Water and Environmental Manager Environmental Consultant Distribution: Electronic copy - EPA EnviroManagement Services EPA Export :23:31:55

174 : Table of Contents 1. 0 INTRODUCTION SCOPE OF WORK Field Work Laboratory Analysis RESULTS Laboratory Results Volatile Organic Compounds (VOCs) Miscellaneous Results Chemical Oxygen Demand (COD) MTBE Arsenic Mercury Conclusion... 5 Figure 1 Observation monitoring wells Figure 2 Trends in Groundwater Chloroform Figure 3 Trends in Groundwater MBTE Table 1. Groundwater Sampling inventory Table 2. Summary laboratory Results Table 3. Semi Volatile Organic Compound Data Table 4. Chloroform Table 5. Historical trends in MBTE, Arsenic and Mercury EnviroManagement Services EPA Export :23:31:55

175 1. 0 INTRODUCTION EnviroManagement Services were commissioned to undertake groundwater monitoring for Tapella Ltd. at the former Pfizer Inchera site at Little Island, Co. Cork. Production of pharmaceuticals on site ceased in February 2010 along with associated emissions. The existing IPPC licence was transferred to Tapella Ltd on the 4th July Tapella were notified by the EPA on the 4th February 2013, that the IPPC licence PO ceased to have effect from the 4th March Conditions pertaining to groundwater monitoring remain on the site until such time as the Agency agree that no further monitoring or remediation is required facilitating the surrender of the IPPC licence in accordance with Section 95 of the EPA Acts 1992 and This report provides the results of biannual groundwater undertaken in 2014 and the current groundwater results for February SCOPE OF WORK 2.1 Field Work Groundwater sampling and field monitoring was undertaken by EnviroManagement Services on the 28 th March, 10 th June 2014 and the 11 th February 2015 respectively. The scope of the survey involved the collection and analysis of groundwater from eight monitoring wells (BH2, BH5, 03-05, 03-07, 06-02, 06-05, and ) for the parameters specified in Table 1. Depth to groundwater and total depth in each monitoring well were measured with an interface probe prior to sampling and to confirm water table level. Before sampling each well was purged by evacuating three times the well volume to ensure a groundwater sample representative of that in the aquifer was collected from the monitoring well. Groundwater sampling was carried out by EnviroManagement Services personnel is in accordance with in house sampling procedures based on relevant standards and guidelines. The samples were collected in laboratory prepared bottles and were stored in coolers prior to delivery to Environmental Laboratories Services (ELS). ELS is an approved accredited laboratory. A log of all monitoring is maintained and samples returned to the laboratory using chain of control procedures. Figure 1 presents a map of all the well locations, field survey results are summarised in Tables 2. Laboratory results are provided in Tables 2 to Tables 5 inclusive. EnviroManagement Services Page 2 EPA Export :23:31:55

176 2.2 Laboratory Analysis All groundwater samples were submitted to Environmental Laboratories Services (ELS). ELS are an approved accredited laboratory. Samples from the two IPPC licensed monitoring wells were analyzed for: Volatile Organic Compounds (VOCs); Semi-Volatile Organic Compounds (SVOCs); and Chemical Oxygen Demand (COD). Samples from the six additional monitoring wells were scheduled for the following analyses: Methyl tert butyl ether (MTBE) wells 06-2, and Arsenic wells 03-05, and Mercury well RESULTS 3.1 Laboratory Results The summary results are provided in Table 2. Data on volatile organic compounds is provided in Table 3, trends in chloroform over time are illustrated in Table 4. Time series data for MTBE, arsenic and mercury are presented in Table 5. Trends in detected Chloroform and MBTE are provided in Figures 2 and 3 respectively. Where available, laboratory results have been compared to Dutch Intervention Values (DIVs), EPA draft Interim Guideline Values (IGVs) and Groundwater Threshold Values from Statutory Instrument No. 9, 2010 (GTVs). The DIV criteria are often used in European contamination assessments as a benchmark. The draft IGVs used are for the protection of groundwater for selected natural and synthetic substances. These represent indicators of contamination, rather than clean-up criteria. The GTVs are published Irish statutory groundwater regulations, which were developed to give effect to the EU Groundwater Directive. Exceedance of a threshold value triggers further investigation to confirm whether the exceedance suggests Poor groundwater chemical status for the groundwater body as a whole Volatile Organic Compounds (VOCs) Full VOC scan results for wells BH2 and BH5 are presented in Table 3. Only one EnviroManagement Services Page 3 EPA Export :23:31:55

177 compound, chloroform was detectable. In March 2014, the concentration of Chloroform in groundwater in borehole 2 and 5 was 45.8 and 89.7ug/L respectively. In February 2015, the concentrations were 34.9 and 72.0ug/L respectively. Groundwater concentrations are below the established GTV (75 μg/l) and DIV (400 μg/l) for chloroform. The data demonstrates a continued gradual decline (Fig 2) in background concentrations. Current measured levels in monitoring wells BH2 and BH5 significantly below previously measured levels. A summary of historical chloroform results are presented in Table 4 and recent trends illustrated in Figure Miscellaneous Results Miscellaneous additional groundwater results, as agreed with the EPA in March 2011, are presented in Table 2. Historic trends for MTBE, arsenic and mercury presented in Table Chemical Oxygen Demand (COD) MTBE Groundwater from wells BH2 and BH5 was analyzed for COD. The measured COD were below 8 mg/l in both wells. Results for COD are presented in Table 2. Monitoring for MTBE is required for three wells 06-02, and MTBE has been detected at various concentrations in these wells since Recent trends in monitoring data are provided in Fig 3. In March 2014, the concentration of MTBE measured in monitoring wells 06-02, and was 70.9, 11.3 and 388.1ug/L respectively. The concentrations measured in February 2015 were 9.4, 5.3 and 314.2ug/L. Groundwater monitoring demonstrates continued reductions in the concentration of MBTE in all wells, with only trace concentrations now present in wells and Historically the highest concentrations have been found in well with a peak of 5685ug/L in November 2010 compared the current concentration of 314.2ug/L. Overall the groundwater data illustrates a significant decline in MBTE as a contaminant present in groundwater. Current and historical MBTE results are presented in Table Arsenic Three groundwater wells 03-05, and continue to be analyzed for arsenic. As previously documented in URS reports submitted by Pfizer, the elevated arsenic results are associated with wells exhibiting reducing groundwater conditions (hydrogen sulphide odours, no dissolved oxygen and low redox results) and are considered to represent leaching of naturally occurring arsenic from aquifer materials under these reducing conditions release of arsenic under reducing conditions. Arsenic is known to be associated with clay fractions, where sulphides are present natural occurring arsenic EnviroManagement Services Page 4 EPA Export :23:31:55

178 concentrations may be found in the range measured on site. 2 In March 2014, the concentrations of arsenic in groundwater wells 03-05, and were 90.3, 3.4 and 52.5ug/L respectively, compared to 85.5, 3.4 and 46.9ug/L measured in February Arsenic concentrations in groundwater from well remain below the draft IGV of 10 μg/l.table 6 provides the current and historical data for arsenic Mercury Historically, mercury had been detected in groundwater from well 06-05, with a peak concentration of 2.8 μg/l reported in November In March 2014, groundwater mercury concentrations in well were 1.07ug/L, declining to 0.33ug/L in June 2014 and 0.03ug/L in February Conclusion Monitoring results for the period 2014 to February 2015 demonstrate a continuous trend of improvement in groundwater quality on site. The continued improvement in groundwater quality is graphically illustrated in figures 2 and 3 representing current and historical chloroform and MBTE detected in groundwater. Both graphs illustrate a continuing downward trend for both parameters. Chloroform levels continue to decline with a 8 fold reduction in measured levels observed between 2010 and February The concentration of chloroform in well BH2 and BH5 are below the GTV (75 μg/l) and DIV (400 μg/l) for chloroform. The concentration of arsenic in monitoring wells shows a modest decline between March 2014 and February MTBE concentrations in wells and are significantly lower than recorded in previous years. The reduction in MBTE concentrations is more gradual in well However significant reductions (18 fold) are evident compared to the period November The mercury concentration measured in well is February 2015 are the lowest reported to date measuring 0.03ug/L. Overall, data from the monitoring programme clearly demonstrates that residual groundwater contamination on site is reducing with continued decreasing concentration trends over time. 2 U.S Agency for toxic substances and disease Registry, Toxicological profile of Arsenic EnviroManagement Services Page 5 EPA Export :23:31:55

179 Figures EnviroManagement Services Page 6 EPA Export :23:31:55

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183 Tables EnviroManagement Services Page 10 EPA Export :23:31:55

184 Table 1. Groundwater sample inventory Groundwater Sampling Inventory Well VOCs SVOCs COD MBTE Arsenic Mercury 1 X X X 2 X X X 3 X 4 X 5 X 6 X 7 X 8 X X X: indicates analyses scheduled. VOCs: Volatile organic compounds including MTBE and Chloroform SVOCs: Semi Volatile Organic Compounds COD: Chemical Oxygen Demand MBTE: Methyl tert butyl ether EnviroManagement Services Page 11 EPA Export :23:31:55

185 Table 2. Groundwater Sampling Summary Results 2015 Tapella Ltd (Formerly Pfizer Inchera) Groundwater Sampling General Results 2015 COD MBTE Arsenic Mercury mg/l ug/l ug/l ug/l Mar-14 BH2 < 8 BH5 < 8 03_ _ _ _ _ _ Jun-14 BH2 < 8 BH5 < 8 03_ _ _ _ _ _ Feb-15 BH2 < 8 BH5 < 8 03_ _ _ _ _ _ Dutch Intervention Value (DIV) NV Groundwater Threshold Value (GTV) NV NV EPA Draft Interim Guideline Value (IGV) NV COD: Chemical Oxygen Demand MBTE: Methyl tert butyl ether EnviroManagement Services Page 12 EPA Export :23:31:55

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