FLORA AND FAUNA AWN & Environet _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 12, Page 1 12.0 FLORA AND FAUNA 12.1 INTRODUCTION This chapter provides an assessment of the impacts of the proposed development in question on the ecological environment, i.e. flora and fauna. It has been compiled in compliance with the European Communities Legal requirements and follows Guidelines on the Information to be contained in Environmental Impact Statements (Environmental Protection Agency, 2015a) and Advice Notes on Current Practice in the preparation of EIS (2015b). This section was compiled by Ger O’Donohoe M.Sc. of Moore Group (Environmental Services). 12.2 METHODOLOGY This section of the EIS concentrates on ecological features within the development area of particular significance, primarily designated habitats and species. This includes habitats/species listed in Annex I, II and IV of the EU Habitats Directive, rare plants listed in the Flora Protection Order and other semi-natural habitats of conservation value. The European Habitats Directive 92/43/EEC (Article 6) indicates the need for plans and projects to be subject to Habitats Directive Assessment (also known as Appropriate Assessment) if the plan or project not directly connected with or necessary to the management of a Natura 2000 site (which includes SACs and SPAs) but which has the potential to have implications on a site’s conservation objectives. These implications can be significant effects either individually or in combination with other plans or projects. An Appropriate Assessment Screening Report was undertaken by Moore Group for the proposed development which is presented as Appendix 12.1 to this chapter. 12.2.1 POLICY & GUIDANCE 12.2.1.1 EU Habitats Directive The “Habitats Directive” (Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Flora and Fauna) is the main legislative instrument for the protection and conservation of biodiversity within the European Union and lists certain habitats and species that must be protected within wildlife conservation areas, considered to be important at a European as well as at a national level. A “Special Conservation Area” or SAC is a designation under the Habitats Directive. The Habitats Directive sets out the protocol for the protection and management of SACs. The Directive sets out key elements of the system of protection including the requirement for “Appropriate Assessment” of plans and projects. The requirements for an Appropriate Assessment are set out in the EU Habitats Directive. Articles 6(3) and 6(4) of the Directive 12.2.1.2 Birds Directive The “Birds Directive” (Council Directive 79/409/EEC as codified by Directive 2009/147/EC) provides for a network of sites in all member states to protect birds at their breeding, feeding, roosting and wintering areas. This directive identifies species that are rare, in danger of extinction or vulnerable to changes in habitat and which need protection (Annex I species). Appendix I indicates Annex I bird species as listed For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 14-11-2016:15:23:25
AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 12, Page 1
12.0 FLORA AND FAUNA 12.1 INTRODUCTION
This chapter provides an assessment of the impacts of the proposed development in question on the ecological environment, i.e. flora and fauna. It has been compiled in compliance with the European Communities Legal requirements and follows Guidelines on the Information to be contained in Environmental Impact Statements (Environmental Protection Agency, 2015a) and Advice Notes on Current Practice in the preparation of EIS (2015b). This section was compiled by Ger O’Donohoe M.Sc. of Moore Group (Environmental Services).
12.2 METHODOLOGY
This section of the EIS concentrates on ecological features within the development area of particular significance, primarily designated habitats and species. This includes habitats/species listed in Annex I, II and IV of the EU Habitats Directive, rare plants listed in the Flora Protection Order and other semi-natural habitats of conservation value. The European Habitats Directive 92/43/EEC (Article 6) indicates the need for plans and projects to be subject to Habitats Directive Assessment (also known as Appropriate Assessment) if the plan or project not directly connected with or necessary to the management of a Natura 2000 site (which includes SACs and SPAs) but which has the potential to have implications on a site’s conservation objectives. These implications can be significant effects either individually or in combination with other plans or projects. An Appropriate Assessment Screening Report was undertaken by Moore Group for the proposed development which is presented as Appendix 12.1 to this chapter.
12.2.1 POLICY & GUIDANCE 12.2.1.1 EU Habitats Directive The “Habitats Directive” (Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Flora and Fauna) is the main legislative instrument for the protection and conservation of biodiversity within the European Union and lists certain habitats and species that must be protected within wildlife conservation areas, considered to be important at a European as well as at a national level. A “Special Conservation Area” or SAC is a designation under the Habitats Directive. The Habitats Directive sets out the protocol for the protection and management of SACs. The Directive sets out key elements of the system of protection including the requirement for “Appropriate Assessment” of plans and projects. The requirements for an Appropriate Assessment are set out in the EU Habitats Directive. Articles 6(3) and 6(4) of the Directive 12.2.1.2 Birds Directive The “Birds Directive” (Council Directive 79/409/EEC as codified by Directive 2009/147/EC) provides for a network of sites in all member states to protect birds at their breeding, feeding, roosting and wintering areas. This directive identifies species that are rare, in danger of extinction or vulnerable to changes in habitat and which need protection (Annex I species). Appendix I indicates Annex I bird species as listed
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on the Birds Directive. A “Special Protection Area” or SPA, is a designation under The Birds Directive. Special Areas of Conservation and Special Protection Areas form a pan-European network of protected sites known as Natura 2000 sites and any plan or project that has the potential to impact upon a Natura 2000 site requires appropriate assessment. 12.2.1.3 Wildlife Acts (1976 - 2012) The primary domestic legislation providing for the protection of wildlife in general, and the control of some activities adversely impacting upon wildlife is the Wildlife Act of 1976. The aims of the wildlife act according to the National Parks and Wildlife Service are “... to provide for the protection and conservation of wild fauna and flora, to conserve a representative sample of important ecosystems, to provide for the development and protection of game resources and to regulate their exploitation, and to provide the services necessary to accomplish such aims.” All bird species are protected under the act. The Wildlife (Amendment) Act of 2000 amended the original Act to improve the effectiveness of the Act to achieve its aims. The Wildlife (Amendment) Act of 2000 amended the original Act to improve the effectiveness of the Act in order to achieve its aims.
12.2.2 HABITAT ASSESSMENT The assessment was carried out in three stages, firstly through desktop assessment to determine existing records in relation to habitats and species present in the study area. This included research on the NPWS metadata website and a literature review of published information on flora and fauna occurring in the development area. The second phase of the assessment involved a site visit to establish the existing environment in the footprint of the proposed development. Areas which were highlighted during desktop assessment were investigated in closer detail according to the Heritage Council Best Practice Guidance for Habitat Survey and Mapping (Smith et al., 2011). Habitats in the proposed development areas were classified according to the Heritage Council publication “A Guide to Habitats in Ireland” (Fossitt, 2000). This publication sets out a standard scheme for identifying, describing and classifying wildlife habitats in Ireland. This form of classification uses codes to classify different habitats based on the plant species present. Species recorded in this report are given in both their Latin and English names. Latin names for plant species follow the nomenclature of “An Irish Flora” (Parnell & Curtis, 2012). Habitats were surveyed on the 12th April 2016 by conducting a site walkover covering the area under the footprint of the proposed development. The survey date is outside the optimal botanical survey period, however, given the modified habitats present, it is considered appropriate for the purposes of this assessment. Signs of mammals were searched while surveying the study area noting any sights, signs or any activity in the vicinity especially along adjacent boundaries. Evidence of bird nesting or potential for nesting was recorded. A photographic record was made of the main features of interest. The third stage of the assessment involves an evaluation of the development area and determination of the potential impacts on the flora and fauna of the area and is based on the following guidelines and publications:
Guidelines on the Information to be contained in Environmental Impact Statements (Environmental Protection Agency, 2015a);
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EPA Advice Notes on Current Practice (EPA, 2015b);
Assessment of plans and projects significantly affecting Natura 2000 sites (EC, 2002);
Managing Natura 2000 Sites (EC, 2000) Guidance document on Article 6(4) of the Habitats Directive 92/43/EEC (EC, 2007);
Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities (DEHLG, Rev. Feb. 2010).
The following resources assisted in the production of this section of the report:
Ordnance Survey Ireland maps;
OSI, Google and Bing Aerial photography;
National Parks and Wildlife Service (NPWS) Mapviewer: http://www.npws.ie/en/MapsData/;
Designated sites (SACs, SPAs, NHAs);
Records of protected species from 10km squares;
National Biodiversity Data Centre Records and Maps. Other environmental information for the area was reviewed, e.g. in relation to soils, geology, hydrology and hydrogeology. Interactions in terms of the chapters on these topics presented in this EIS were important in the determination of source vector pathways and links with potentially hydrogeologically connected areas outside the proposed development site.
12.2.3 CONSULTATIONS
The Development Applications Unit of the Department of the Arts, Heritage & Gaeltacht was contacted in a non-statutory context in relation to the natural heritage aspects of the development. A response from the NPWS will be attached to the planning file when received.
12.3 EXISTING ENVIRONMENT
The following is a description of the flora and fauna of the existing environment in the study area.
12.3.1 DESIGNATED CONSERVATION AREAS
Departmental guidance suggests an assessment of Natura 2000 sites within a zone of influence of 15 km which can be revised down depending on the proposed development and location of Natura 2000 sites. There is no direct hydrological connectivity with the Tibbotstown stream which is located c. 200m to the east of the site, is partly culverted under the Main Road into Carrigtwohill and the main Cork Road (N25) before discharging into Cork Harbour at Slatty Bridge. There are two Natura 2000 sites in Cork Harbour that can be considered within the zone of influence of the project: Great Island Channel SAC (Site Code 001058) and Cork Harbour SPA (Site Code 004030).
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Figure 12.1 Site Location at Abbvie Carrigtwohill in relation to the Cork Harbour European sites.
12.3.2 NON-DESIGNATED AREAS
The footprint of the proposed development is comprised predominantly of Buildings and artificial surfaces (BL3), see Figure 12.2. At the time of the site assessment, the greenfield area to the north of the development area is comprised of Gorse and Willow Scrub (WS1). The ground is wet and recolonising with Rush (Juncus spp.), Willowherb (Eplilobium hirsutum), Cuckoo flower (Cardamine pratensis) and Ragwort (Senecio jacobaea). This area has now been extensively cleared as part of the recently permitted warehouse development (other than the perimeter screening).
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Figure 12.2 Showing footprint habitats in the development area with the overall site boundary outlined in red (adapted from Bing).
12.3.3 MAMMALS 12.3.3.1 Otters The nearest record for otter in the study area from the National Biodiversity Data Centre is from 2012 from Slatty Bridge c. 1.5 km downstream from the development site. 12.3.3.2 Badgers There are no badger setts along field boundaries which would be disturbed and no signs of badgers in the study area. 12.3.3.3 Bats There is limited potential for bats and bat habitats in the footprint of the proposed development.
12.3.4 BIRDS There is limited potential for bird habitats in the footprint of the proposed development. Small passerines such as Great tit (Parus major) and Wren (Troglodytes troglodytes) were observed along with Wood pigeon (Palumba columbus).
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12.3.5 HABITAT EVALUATION The ecological value of the sites was assessed following the guidelines set out in the Institute of Ecology and Environmental Management’s Guidelines for Ecological Impact Assessment (2006) according to the Natura Scheme for evaluating ecological sites (after Nairn & Fossitt, 2004). Judgements on the evaluation were made using geographic frames of reference, e.g. European, National, Regional or Local. There are no rare or protected habitats recorded in the study area inside the site boundary. The habitats under the footprint of the proposed development are of low ecological value.
12.4 CHARACTERISTICS OF THE PROPOSED DEVELOPMENT
The proposed project will involve:
A building accommodating the new Creon DR production line;
Redevelopment of former warehousing area to accommodate new Creon DR production related activities;
Installation of a solvent bulk storage tank farm;
Installation of a Thermal Oxidiser (TO);
Installation of various ancillary facilities, including a new Nitrogen Skid;
Commissioning of new plant and equipment. The development will also include modifications to the existing pharmaceutical building and minor remedial site works and landscaping. It is estimated that the project will take 18 months to complete including commissioning.
12.5 POTENTIAL IMPACTS OF THE PROPOSED DEVELOPMENT 12.5.1 IMPACTS ON HABITATS
There would be no significant impacts as a result of the proposed development on the Cork Harbour Natura 2000 sites considered in the Report for Appropriate Assessment Screening. There would be no significant impacts as a result of the proposed development on the local ecology.
12.5.2 IMPACTS ON FAUNA
There are no significant impacts as a result of the proposed development on fauna. A worst case scenario could be considered whereby the project could result in a significant detrimental change in water quality in the area either alone or in combination with other projects or plans as a result of indirect pollution of surface or groundwater. The effect would have to be considered in terms of changes in water quality which would affect the habitats and species for which the SAC and SPA are designated. Aquatic species such as Otters require high quality water quality with relatively high oxygen levels and low suspended solids content. However, the potential for such an event to occur is unlikely as there is limited surface hydrological connectivity between the project site and the nearby SAC and SPA areas.
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12.6 REMEDIAL AND MITIGATION MEASURES
There are no predicted impacts on ecology and therefore no proposed mitigation measures.
12.7 PREDICTED IMPACTS OF THE PROPOSED DEVELOPMENT
The development is located in an area of low ecological value and as such will not have significant impacts on the local ecology. The proposed development will not have significant effects on designated sites within 15 km of the development site.
12.8 RESIDUAL IMPACT AND PROPOSED MONITORING
The development is located in an area of low ecological value and as such will not have significant impacts on the local ecology. There will be no requirement for monitoring.
12.9 CUMULATIVE IMPACTS
Cumulative impacts or effects are changes in the environment that result from numerous human-induced, small-scale alterations. Cumulative impacts can be thought of as occurring through two main pathways: first, through persistent additions or losses of the same materials or resource, and second, through the compounding effects as a result of the coming together of two or more effects. As part of the Screening for an Appropriate Assessment, in addition to the proposed works, other relevant projects and plans in the region must also be considered at this stage. This step aims to identify at this early stage any possible significant in-combination or cumulative effects / impacts of the proposed development with other such plans and projects on the Natura 2000 sites. A search of the Cork County Council Planning webpage revealed that there have been 8 other planning applications in the past three years for the entry IDA Industrial Estate Carrigtwohill. Any application within the Industrial Estate will be linked to the municipal and existing storm sewers. Thus in-combination impacts will be avoided. Abbvie Carrigtwohill have recently been granted permission to construct a warehouse to the north of the exist hardstand areas onsite. A report for AA Screening was carried out and a finding of no significant impacts was determined for this proposed development. The Cork County Development Plan in complying with the requirements of the Habitats Directive requires that all Projects and Plans that could affect the Natura 2000 sites in Cork Harbour would be initially screened for Appropriate Assessment and if requiring Stage 2 AA, that appropriate employable mitigation measures would be put in place to avoid, reduce or ameliorate negative impacts. In this way any in-combination impacts with Plans or Projects for development in the area of Carrigtwohill would be avoided. Any new applications for the project areas will be assessed on a case by case basis by Cork County Council which will determine the requirement for AA as per the requirements of Article 6(3) of the Habitats Directive.
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12.10 REFERENCES Department of the Environment, Heritage and Local Government (2010) Guidance on Appropriate Assessment of Plans and Projects in Ireland (as amended February 2010). EC (2000) Managing Natura 2000 sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. EC (2001) Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43EEC. European Commission, Brussels. EC (2007) Guidance document on Article 6(4) of the 'Habitats Directive '92/43/EEC: Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interests, compensatory measures, overall coherence and opinion of the Commission. European Commission, Brussels. EPA (2015a) Revised Guidelines on the Information to be contained in Environmental Impact Statements Draft September 2015. EPA (2015b) Advice Notes on for Preparing Environmental Impact Statements Draft September 2015. Fossitt, J. (2000) A Guide to Habitats in Ireland. The Heritage Council. Fossitt, J. (2000) A Guide to Habitats in Ireland. The Heritage Council. IEEM (2006) Guidelines for Ecological Impact Assessment. Institute of Ecology and Environmental Management. Nairn, R. and J. Fossitt (2004) The Ecological Impacts of Roads, and an Approach to their Assessment for National Road Schemes. In: J. Davenport and J.L Davenport (eds) The Effects of Human Transport on Ecosystems: Cars and Planes, Boats and Trains, 98-114. Dublin. Royal Irish Academy. Parnell, J. and T. Curtis (2012) Webb’s An Irish Flora. Cork University Press. Smith, G.F., O’Donoghue, P., O’Hora, K. and E. Delaney (2011) Best Practice Guidance for Habitat Survey and Mapping. The Heritage Council.
Project Number 16043 Document Reference 16043 Abbvie Carrigtwohill AAS1 Rev3.doc Revision Description Author Date Rev0 Issued for Client Review G. O’Donohoe 15th April 2016
Rev1 Updated post Client Review G. O’Donohoe 28th April 2016
Rev2 Updates subject to Air Dispersal Modelling
G. O’Donohoe 9th August 2016
Rev3 Final Draft G. O’Donohoe 10th August 2016 Moore Archaeological and Environmental Services Limited
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Moore Group – Archaeological, Architectural, Ecological Consultants 3
TABLE OF CONTENTS PAGE
1. INTRODUCTION 4 1.1. GENERAL INTRODUCTION 4 1.2. LEGISLATIVE BACKGROUND - THE HABITATS AND BIRDS DIRECTIVES 5 2. METHODOLOGY 6 2.1. GUIDANCE 7 2.2. DATA SOURCES 7 3. DESCRIPTION OF THE PROJECT 7 4. IDENTIFICATION OF NATURA 2000 SITES 9 4.1. DESCRIPTION OF NATURA SITES POTENTIALLY AFFECTED 9 4.2. CONSERVATION OBJECTIVES OF THE NATURA 2000 SITES 11 4.3. ASSESSMENT CRITERIA 14 4.3.1. EXAMPLES OF DIRECT, INDIRECT OR SECONDARY IMPACTS 14 4.3.2. ECOLOGICAL NETWORK SUPPORTING NATURA 2000 SITES 15 5. IDENTIFICATION OF POTENTIAL IMPACTS & ASSESSMENT OF SIGNIFICANCE 16 5.1. POTENTIAL IMPACTS 16 5.2. ASSESSMENT OF POTENTIAL CUMULATIVE EFFECTS 17 6. SCREENING STATEMENT 19 7. REFERENCES 20 Appendix A – Finding of No Significant Effects Report
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1. Introduction 1.1. General Introduction The Habitats Directive (Council Directive 92/43/EEC) requires that certain plans and projects requiring planning permission must be screened for potential impact and the likelihood of significant effects on Natura 2000 sites including Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). This process aims to establish whether a full Appropriate Assessment as required by Article 6 of the Directive is required in any particular case. This report contains information required for the competent authority, in this case Cork County Council, to complete an Appropriate Assessment (AA) process on the effects of the construction of an Extension to the Abbvie Pharmaceutical Plant, at the IDA Industrial Estate at Carrigtwohill, Co. Cork. The proposed development site has limited hydrological connectivity to Cork Harbour. The potential impacts on the Great Island Channel SAC (Site Code 001058) and Cork Harbour SPA (Site Code 004030) are considered in this screening assessment. Both sites form part of the Natura 2000 network of sites of highest biodiversity importance for rare and threatened habitats and species across the EU. The report has been prepared by Moore Group - Environmental Services for Abbvie Pharmaceutical and Cork County Council in accordance with Articles 6(3) and 6(4) of the Habitats Directive. The report was compiled by Ger O’Donohoe (B.Sc. Applied Aquatic Sciences (GMIT, 1993) & M.Sc. Environmental Sciences (TCD, 1999)) who has over 20 years’ experience in environmental impact assessment and has completed numerous Appropriate Assessment Screening Reports and Natura Impact Statements in terrestrial and aquatic habitats. The report assesses the potential for the proposed development to impact on sites of European-scale ecological importance. It is necessary that the Project has regard to Article 6 of the Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora (as amended) (referred to as the Habitats Directive). This is transposed into Irish Law most recently by the European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. 477) (referred to as the Habitats Regulations).
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1.2. Legislative Background - The Habitats and Birds Directives The Habitats Directive (Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora) is the main legislative instrument for the protection and conservation of biodiversity in the EU. Under the Directive Member States are obliged to designate Special Areas of Conservation (SACs) which contain habitats or species considered important for protection and conservation in a European Union context. The Birds Directive (Council Directive 79/409/EEC as amended by Directive 2009/147/EC) on the conservation of wild birds), is concerned with the long-term protection and management of all wild bird species and their habitats in the EU. Among other things, the Directive requires that Special Protection Areas (SPAs) be established to protect migratory species and species which are rare, vulnerable, in danger of extinction, or otherwise require special attention. Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas, designated under the Birds Directive, form a pan-European network of protected sites known as Natura 2000. The Habitats Directive sets out a unified system for the protection and management of SACs and SPAs. Articles 6(3) and 6(4) of the Habitats Directive set out the requirement for an assessment of proposed plans and projects likely to affect Natura 2000 sites. Article 6(3) establishes the requirement to screen all plans and projects and to carry out a further assessment if required (Appropriate Assessment (AA)): Article 6(3): “Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subjected to an appropriate assessment of its implications for the site in view of the site’s conservation objectives. In light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.” Article 6(4): “If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, Member States shall take all compensatory
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measures necessary to ensure that the overall coherence of the Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. Where the site concerned hosts a priority natural habitat type and/or a priority species the only considerations which may be raised are those relating to human health or public safety, to the beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest.” This Screening Report is a documentary record of the Appropriate Assessment process on the construction of an Extension to the Abbvie Pharmaceutical Plant, at the IDA Industrial Estate at Carrigtwohill, Co. Cork. 2. Methodology The Commission’s methodological guidance (EC, 2002) promotes a four-stage process to complete the AA, and outlines the issues and tests at each stage. An important aspect of the process is that the outcome at each successive stage determines whether a further stage in the process is required. Stage 1 Screening: This stage examines the likely effects of a project either alone or in combination with other projects upon a Natura 2000 site and considers whether it can be objectively concluded that these effects will not be significant. Stage 2 Appropriate Assessment: In this stage, there is a consideration of the impact of the project with a view to ascertain whether there will be any adverse effect on the integrity of the Natura 2000 site with respect to the conservation objectives of the site. Stage 3 Assessment of Alternative Solutions: This stage examines alternative ways of implementing the project that, where possible, avoid any adverse impacts on the integrity of the Natura 2000 site. Stage 4 Assessment where no alternative solutions exist and where adverse impacts remain: Where imperative reasons of overriding public interest (IROPI) exist, an assessment to consider whether compensatory measures will or will not effectively offset the damage to the sites will be necessary. In order to ensure that the Project complies fully with the requirements of Article 6 of the Habitats Directive and all relevant Irish transposing legislation, Moore Group carried out the screening stage of the Project.
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2.1. Guidance This AA Screening Report has been compiled in accordance with guidance contained in the following documents:
Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities. (Department of Environment, Heritage and Local Government, 2010 rev.).
Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Circular NPWS 1/10 & PSSP 2/10.
Assessment of Plans and Projects Significantly Affecting Natura 2000 sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC (European Commission Environment Directorate-General, 2001); hereafter referred to as the EC Article Guidance Document.
Managing Natura 2000 Sites: The Provisions of Article 6 of the Habitat’s Directive 92/43/EEC (EC Environment Directorate-General, 2000); hereafter referred to as MN2000.
2.2. Data Sources Sources of information that were used to collect data on the Natura 2000 network of sites are listed below:
Ordnance Survey of Ireland mapping and aerial photography available from www.osi.ie, Google Earth and Bing aerial photography.
Online data available on Natura 2000 sites as held by the National Parks and Wildlife Service (NPWS) from www.npws.ie including; the Natura 2000 network Data Form; Site Synopsis; Generic Conservation Objective data
o Online database of rare, threatened and protected species o Publicly accessible biodiversity datasets.
Status of EU Protected Habitats in Ireland. (National Parks & Wildlife Service, 2013) Relevant Development Plans and Local Area Plans in neighbouring areas.
3. Description of the Project The project consists of the development of an Extension to the Abbvie Pharmaceutical Plant, at the IDA Industrial Estate at Carrigtwohill, Co. Cork. The project will be connected to the public wastewater treatment system which has the capacity to assimilate the wastewater. The site location is presented in Figures 1 & 2.
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The facility specialises in Active Pharmaceutical Ingredient (API) particle size reduction through a nano-milling process resulting in lower dosage formulations. The facility currently manufactures six solid oral dose products for human use at commercial scale. An extension to the facility is required to facilitate production of a product known as Creon DR. The Creon DR manufacturing process involves the use of an organic solvent, namely; Acetone. Creon DR production will entail the use of moderate quantities of solvent (acetone - not currently in use at the site) and therefore an Industrial Emissions Licence will also need to be obtained from the Environmental Protection Agency. As a requirement of the Industrial Emissions Directive and related legislation, operators must ensure that emissions from their activities comply with the relevant emissions limit values set by the Directive. The emission limit values are achieved by use of suitable abatement in this case, given the primary emission of concern is a solvent a Thermal Oxidiser Unit (TOU) is proposed. The TOU will be situated directly adjacent to the tank farm which will be used to abate solvent vapours from the Creon DR production process. The proposed TOU will be 26m in height.
4. Identification of Natura 2000 Sites 4.1. Description of Natura Sites Potentially Affected The proposed development site is located at Carrigtwohill, Co. Cork. There is limited hydrological connectivity with the Tibbotstown stream which is located c. 200m to the east of the site, is partly culverted under the Main Road into Carrigtwohill and the main Cork Road (N25) before discharging into Cork Harbour at Slatty Bridge. There are two Natura 2000 sites in Cork Harbour that can be considered within the zone of influence of the project: Great Island Channel SAC (Site Code 001058) and Cork Harbour SPA (Site Code 004030). The location of the proposed development is presented in relation to the relevant Natura 2000 sites in Figure 3 below.
Site Boundary
Dev Area on site
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Figure 3. Showing the site location in relation to the Cork Harbour Natura 2000 sites.
Details of the qualifying Interests of the Great Island Channel SAC are listed in Table 1 and Cork Harbour SPA in Table 2 below and Site Synopses for all sites are available on the NPWS metadata site. Spatial boundary data on the Natura 2000 network was extracted from the NPWS website on 14th April 2016. Table 1. Special Areas of Conservation located within 5km of the Project (*indicates priority habitat).
Site Code
Site Name Qualifying Habitats Qualifying Species
001058 Great Island Channel SAC
Mudflats and sandflats not covered by seawater at low tide [1140] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330]
Site Location
Cork Harbour SPA Great Island Channel SAC
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4.2. Conservation Objectives of the Natura 2000 Sites The following Conservation Objectives, available from the NPWS, are set out for the SAC: Great Island Channel SAC [001058]. Version 1. 6th June 2014; 1140 Mudflats and sandflats not covered by seawater at low tide To maintain the favourable conservation condition of Mudflats and sandflats not covered by seawater at low tide in Great Island Channel SAC, which is defined by the following list of attributes and targets: Habitat area: Hectares;
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The permanent habitat area is stable or increasing, subject to natural processes. Community distribution: Hectares; Conserve the following community type in a natural condition: Mixed sediment to sandy mud with polychaetes and oligochaetes community complex. 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) To restore the favourable conservation condition of Atlantic salt meadows (Glauco- Puccinellietalia maritimae) in Great Island Channel SAC, which is defined by the following list of attributes and targets: Habitat area: Hectares; Area stable or increasing, subject to natural processes, including erosion and succession. For sub-sites mapped: Bawnard - 0.29ha; Carrigatohil - 1.01ha. Habitat distribution: Occurrence; No decline or change in habitat distribution, subject to natural processes. Physical structure: sediment supply: Presence/ absence of physical barriers; Maintain/restore natural circulation of sediments and organic matter, without any physical obstructions. Physical structure: creeks and pans: Occurrence; Maintain/restore creek and pan structure, subject to natural processes, including erosion and succession. Physical structure: flooding regime: Hectares flooded; frequency Maintain natural tidal regime. Vegetation structure: zonation: Occurrence; Maintain range of coastal habitats including transitional zones, subject to natural processes including erosion and succession. Vegetation structure: vegetation height: Centimetres; Maintain structural variation within sward. Vegetation structure: vegetation cover: Percentage cover at a representative number of monitoring stops; Maintain more than 90% area outside creeks vegetated.
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Vegetation composition: typical species and sub-communities: Percentage cover at a representative number of monitoring stops; Maintain range of sub-communities with typical species listed in SMP (McCorry and Ryle, 2009). Vegetation structure: negative indicator species – Spartina anglica: Hectares No significant expansion of common cordgrass (Spartina anglica), with an annual spread of less than 1% where it is known to occur. The following Conservation Objectives, available from the NPWS, are set out for the SPA: Cork Harbour SPA [004030]. Version 1. 16th December 2014; To maintain the favourable conservation condition of [the qualifying bird species listed] in Cork Harbour SPA, which is defined by the following list of attributes and targets: Population trend: Percentage change; Long term population trend stable or increasing. Distribution: Range, timing and intensity of use of areas; No significant decrease in the range, timing or intensity of use of areas by [the qualifying bird species listed], other than that occurring from natural patterns of variation. Specific Conservation Objectives are set out for the following species and habitats: A193 Common Tern Sterna hirundo Breeding population abundance: Apparently occupied nests (AONs): Number No significant decline. Productivity rate: fledged young per breeding pair: Mean number; No significant decline Distribution: breeding colonies: Number; location; area (hectares); No significant decline.
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Prey biomass available: Kilogrammes; No significant decline. Barriers to connectivity: Number; location; shape; area (hectares); No significant increase. Disturbance at the breeding site: Level of impact; Human activities should occur at levels that do not adversely affect the breeding common tern population. A999 Wetlands Habitat area: Hectares; The permanent area occupied by the wetland habitat should be stable and not significantly less than the area of 2,587 hectares, other than that occurring from natural patterns of variation. 4.3. Assessment Criteria 4.3.1. Examples of Direct, Indirect or Secondary Impacts In order to identify those sites that could be potentially affected, it is necessary to describe the Natura 2000 site in the context of why it has been designated i.e. in terms of its Qualifying Interests and the environmental and ecological conditions that maintain the condition of these features. The underpinning conditions that are required to maintain the ‘health’ of these features are listed in Table 3 below.
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Table 3. Qualifying Interests and Key environmental conditions supporting site integrity. Qualifying Interests Key environmental conditions supporting
site integrity Current Threats to Qualifying Interests
Atlantic salt meadows (Glauco-Puccinellietalia maritimae)
Marine and groundwater dependent. Medium sensitivity to hydrological change. Changes in salinity and tidal regime. Overgrazing, erosion and accretion.
Overgrazing; erosion; invasive species, particularly common cordgrass (Spartina anglica); infilling and reclamation.
Mudflats and sandflats not covered by seawater at low tide
Surface and marine water dependent. Low sensitivity to hydrological changes. Aquaculture, fishing and pollution.
Aquaculture, fishing, dumping of wastes and water pollution.
Wetlands & Waterbirds Highly sensitive to hydrological changes and loss of wetland habitat. Sensitive to disturbance.
A number of pressures have been identified by Crowe (2005). These pressures include: the modification of wetland sites, particularly for industry or housing and increased levels of disturbance, largely related to recreational activity. Eutrophication at a number of wetland sites as a result of nutrient inputs from a range of polluting activities were also identified as a potential pressure. However, this latter pressure is now being alleviated through stricter control of activities associated with water discharge/runoff etc. Climate change was also noted as a significant factor underlying changes in trends of wintering waterbirds in Ireland.
4.3.2. Ecological Network Supporting Natura 2000 Sites An analysis of the proposed Natural Heritage Areas and designated Natural Heritage Areas in terms of their role in supporting the species using Natura 2000 sites was undertaken. It was assumed that these supporting roles mainly related to mobile fauna such as mammals and birds which may use pNHAs and NHAs as “stepping stones” between Natura 2000 sites. Article 10 of the Habitats Directive and the Habitats Regulations 2011 place a high degree of importance on such non-Natura 2000 areas as features that connect the Natura 2000 network. Features such as ponds, woodlands and important hedgerows were taken into account during the rest of the AA process.
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The Great Island SAC is also a proposed Natural Heritage Area and so is considered under the Natura 2000 designation. There are no other areas of conservation concern with connectivity to the project site. 5. Identification of Potential Impacts & Assessment of Significance The project is not directly connected with or necessary to the management of the sites considered in the assessment and therefore potential impacts must be identified and considered. 5.1. Potential Impacts This section uses the information collected on the sensitivity of each Natura 2000 site and describes any likely significant effects of implementation of the Project. The likely significant effects of the Project are presented in Table 4 below, both in isolation and potentially in combination with other plans and projects. There will be no direct impact on the downstream Natura 2000 sites. Having established no direct impacts or habitat fragmentation, the assessment concentrates on potential indirect impacts. A worst case scenario would occur whereby the project would result in a significant detrimental change in water quality in Cork Harbour either alone or in combination with other projects or plans as a result of indirect pollution through surface water discharge. The effect would have to be considered significant in terms of changes in water quality which would affect the habitats or food sources for which the SAC and SPA species are designated. The possibility of significant impacts would be unlikely during the construction phase given the existing site has been developed. Additionally, the subject development will not result in additional foul water discharge. Surface water runoff from the site is collected via the on-site surface water drainage system, which discharges via petrol interceptor to the existing IDA Industrial Estate Stormwater sewer. This flows to a retention pond to the northwest of the site before ultimately discharging to the Slatty River southwest of the site.
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The interception of foul and storm water will ensure the water quality of Cork Harbour is not affected. An Air Dispersion Model undertaken by AWN Consultants (presented as part of the planning application) presents the following information:
For normal operational modelling scenarios, it has been assumed that all emission points are running continuously for the full year as a worst-case. The results indicate that the ambient ground level concentrations are below the relevant air quality guidelines for acetone even when it is assumed that each emission point is emitting solely acetone at the IED emission limit for the full year. Under worst case continuous operations, emissions from A2-1 and A2-6 onsite lead to ambient individual VOC concentrations which are at most 0.3% of the maximum 1-hour limit value at the worst-case receptor and less than 0.02% of the annual mean limit value at the worst-case off-site location. In relation to odour, all ambient concentrations are below the odour nuisance thresholds for each individual VOC under normal operating conditions. With regard to PM10 / PM2.5, emissions from the facility will lead to ambient PM10 / PM2.5 levels (including background) which are in compliance with the relevant limit values, with levels reaching at most 51% of the relevant limit values at the worst-case location. In summary, all emissions from the facility under worst case operations of the facility will be in compliance with the ambient air quality standards and will not lead to a substantive risk of non-compliance or odour nuisance. Any impacts with respect to climate and dust emissions are predicted to be negligible.
Based on this determination, in terms of predicted impacts on air quality, it can be stated with confidence that there would be no impact on habitats or species of conservation concern in the Cork Harbour European Sites. 5.2. Assessment of Potential Cumulative Effects Cumulative impacts or effects are changes in the environment that result from numerous human-induced, small-scale alterations. Cumulative impacts can be thought of as occurring through two main pathways: first, through persistent additions or losses of the same materials or resource, and second, through the compounding effects as a result of the coming together of two or more effects.
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As part of the Screening for an Appropriate Assessment, in addition to the proposed works, other relevant projects and plans in the region must also be considered at this stage. This step aims to identify at this early stage any possible significant in-combination or cumulative effects / impacts of the proposed development with other such plans and projects on the Natura 2000 sites. A search of the Cork County Council Planning webpage revealed that there have been 8 other planning applications in the past three years for the entry IDA Industrial Estate Carrigtwohill. Any application within the estate will be linked to the municipal and existing storm sewers. Thus in-combination impacts will be avoided. Abbvie Carrigtwohill intend to apply for permission to construct a warehouse to the north of the exist hardstand areas o site. A report for AA Screening was carried out and a finding of no significant impacts was determined for this proposed development. The Cork County Development Plan in complying with the requirements of the Habitats Directive requires that all Projects and Plans that could affect the Natura 2000 sites in Cork Harbour would be initially screened for Appropriate Assessment and if requiring Stage 2 AA, that appropriate employable mitigation measures would be put in place to avoid, reduce or ameliorate negative impacts. In this way any in-combination impacts with Plans or Projects for development in the area of Carrigtwohill would be avoided. Any new applications for the project area will be assessed on a case by case basis by Cork County Council which will determine the requirement for AA as per the requirements of Article 6(3) of the Habitats Directive.
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Table 4. Outlining the potential impacts in the absence of mitigation of the Project.
6. Screening Statement The construction of the project will not have a direct impact on the Cork Harbour Natura 2000 sites. The project has been designed to include appropriate treatment of foul and storm water which will avoid impacts on the water quality of Cork Harbour. There will be no impacts from the development on air quality. It has been objectively concluded by Moore Group Environmental Services that: 1. The project is not directly connected with, or necessary to the conservation management of the
Great Island SAC or Cork Harbour SPA and any other European sites. 2. The implementation of the project will not have a direct impact on the Great Island SAC or Cork
Harbour SPA. 3. The project has been designed to include avoidance measures which will avoid impacts on surface
and groundwater during the operational phase and therefore avoids indirect impacts on the Great Island SAC or Cork Harbour SPA.
4. The project, alone or in combination with other projects or plans, is not likely to have a significant effect on the Great Island SAC or Cork Harbour SPA or any other European sites in view of their conservation objectives.
Site Distance from Project
Potential Direct Impacts e.g. Habitat Loss
Potential Indirect Impacts e.g. alteration to hydrological regime
Surface or Groundwater Contamination
Disturbance to Protected Species (Habitats Directive Annex II & IV)
Stage 2 AA Required
001058 Great Island Channel SAC
c. 1 km No None None. None No
004030 Cork Harbour SPA
c. 1 km No None None. None No
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It is the view of Moore Group Environmental Services that it is not necessary to undertake any further stage of the Appropriate Assessment process. A finding of no significant effects report is presented in Appendix B in accordance with the EU Commission’s methodological guidance (European Commission, 2001). 7. References Crowe, O. (2005) Ireland’s Wetlands and their Waterbirds; Status and Distribution. BirdWatch Ireland. Department of the Environment, Heritage and Local Government (2010) Guidance on Appropriate Assessment of Plans and Projects in Ireland (as amended February 2010). European Commission (2000) Managing Natura 2000 sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. European Commission Environment DG (2001) Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43EEC. European Commission, Brussels. European Commission (2007) Guidance document on Article 6(4) of the 'Habitats Directive '92/43/EEC: Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interests, compensatory measures, overall coherence and opinion of the Commission. European Commission, Brussels. NPWS (2013) The Status of EU Protected Habitats and Species in Ireland. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin. NPWS (2008) Site synopsis of the Cork Harbour SPA 004030. Version date: 26.02.2008. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin. NPWS (2013) Site synopsis of the Great Island Channel SAC 001058. Version date: 24.09.2013 001058_Rev13.Doc. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin.
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NPWS (2014) Conservation Objectives: Great Island Channel SAC 001058. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. NPWS (2014) Conservation Objectives: Cork Harbour SPA 004030. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
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Appendix A FINDING OF NO SIGNIFICANT EFFECTS REPORT Finding no significant effects report matrix Name of project or plan Extension to the Abbvie Pharmaceutical Plant, at the IDA Industrial Estate at Carrigtwohill, Co. Cork. Name and location of the Natura 2000 site(s) The proposed development site is located at Carrigtwohill, Co. Cork. There is limited hydrological connectivity with the Tibbotstown stream which is located c. 200m to the east of the site, is partly culverted under the Main Road into Carrigtwohill and the main Cork Road (N25) before discharging into Cork Harbour at Slatty Bridge. There are two Natura 2000 sites in Cork Harbour that can be considered within the zone of influence of the project: Great Island Channel SAC (Site Code 001058) and Cork Harbour SPA (Site Code 004030). Description of the project or plan The project consists of the development of an Extension to the Abbvie Pharmaceutical Plant, at the IDA Industrial Estate at Carrigtwohill, Co. Cork. The project will be connected to the public wastewater treatment system which has the capacity to assimilate the wastewater. The facility specialises in Active Pharmaceutical Ingredient (API) particle size reduction through a nano-milling process resulting in lower dosage formulations. The facility currently manufactures six solid oral dose products for human use at commercial scale. An extension to the facility is required to facilitate production of a product known as Creon DR. The Creon DR manufacturing process involves the use of an organic solvent, namely; Acetone. Creon DR production will entail the use of moderate quantities of solvent (acetone - not currently in use at the site) and therefore an Industrial Emissions Licence will also need to be obtained from the Environmental Protection Agency. As a requirement of the Industrial Emissions Directive and related legislation, operators must ensure that emissions from their activities comply with the relevant emissions limit values set by the Directive. The emission limit values are achieved by use of suitable abatement in this case, given the primary emission of concern is a solvent a Thermal Oxidiser Unit (TOU) is proposed. The TOU will be situated directly adjacent to the tank farm which will be used to abate solvent vapours from the Creon DR production process. The proposed TOU will be 26m in height. Is the project or plan directly connected with or necessary to the management of the site(s) No Are there other projects or plans that together with the projects or plan being assessed could affect the site A search of the Cork County Council Planning webpage revealed that there have been 8 other planning applications in the past three years for the entry IDA Industrial Estate Carrigtwohill. Any application within the estate will be linked to the municipal and existing storm sewers. Thus in-combination impacts will be avoided.
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Abbvie Carrigtwohill intend to apply for permission to construct a warehouse to the north of the exist hardstand areas o site. A report for AA Screening was carried out and a finding of no significant impacts was determined for this proposed development. The Cork County Development Plan in complying with the requirements of the Habitats Directive requires that all Projects and Plans that could affect the Natura 2000 sites in Cork Harbour would be initially screened for Appropriate Assessment and if requiring Stage 2 AA, that appropriate employable mitigation measures would be put in place to avoid, reduce or ameliorate negative impacts. In this way any in-combination impacts with Plans or Projects for development in the area of Carrigtwohill would be avoided. Any new applications for the project areas will be assessed on a case by case basis by Cork County Council which will determine the requirement for AA as per the requirements of Article 6(3) of the Habitats Directive. The assessment of significance of effects Describe how the project or plan (alone or in combination) is likely to affect the Natura 2000 site. There will be no direct impact on the downstream Natura 2000 sites. Having established no direct impacts or habitat fragmentation, the assessment concentrates on potential indirect impacts. A worst case scenario would occur whereby the project would result in a significant detrimental change in water quality in Cork Harbour either alone or in combination with other projects or plans as a result of indirect pollution through surface water discharge. The effect would have to be considered significant in terms of changes in water quality which would affect the habitats or food sources for which the SAC and SPA species are designated. An Air Dispersion Model undertaken by AWN Consultants (presented as part of the planning application) presents the following information: For normal operational modelling scenarios, it has been assumed that all emission points are running continuously for the full year as a worst-case. The results indicate that the ambient ground level concentrations are below the relevant air quality guidelines for acetone even when it is assumed that each emission point is emitting solely acetone at the IED emission limit for the full year. Under worst case continuous operations, emissions from A2-1 and A2-6 onsite lead to ambient individual VOC concentrations which are at most 0.3% of the maximum 1-hour limit value at the worst-case receptor and less than 0.02% of the annual mean limit value at the worst-case off-site location. In relation to odour, all ambient concentrations are below the odour nuisance thresholds for each individual VOC under normal operating conditions. With regard to PM10 / PM2.5, emissions from the facility will lead to ambient PM10 / PM2.5 levels (including background) which are in compliance with the relevant limit values, with levels reaching at most 51% of the relevant limit values at the worst-case location. In summary, all emissions from the facility under worst case operations of the facility will be in compliance with the ambient air quality standards and will not lead to a substantive risk of non-compliance or odour nuisance. Any impacts with respect to climate and dust emissions are predicted to be negligible. Based on this determination, in terms of predicted impacts on air quality, it can be stated with confidence that there would be no impact on habitats or species of conservation concern in the Cork Harbour European Sites.
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Explain why these effects are not considered significant. The possibility of significant impacts would be unlikely during the construction phase given the existing site has been developed. Additionally, the subject development will not result in additional foul water discharge. Surface water runoff from the site is collected via the on-site surface water drainage system, which discharges via petrol interceptor to the existing IDA Industrial Estate Stormwater sewer. This flows to a retention pond to the northwest of the site before ultimately discharging to the Slatty River southwest of the site. The interception of foul and storm water will ensure the water quality of Cork Harbour is not affected. Based on the determination of the air dispersal modelling, in terms of predicted impacts on air quality, it can be stated with confidence that there would be no impact on habitats or species of conservation concern in the Cork Harbour European Sites. List of agencies consulted: provide contact name and telephone or e-mail address Cork County Council Response to consultation The need for Appropriate Assessment Screening was identified in pre-planning consultation with Cork County Council. Data collected to carry out the assessment Who carried out the assessment Moore Group Environmental Services. Sources of data NPWS database of designated sites at www.npws.ie National Biodiversity Data Centre database http://maps.biodiversityireland.ie Level of assessment completed Desktop Assessment Where can the full results of the assessment be accessed and viewed Cork County Council Planning Section
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Overall Conclusions The construction of the project will not have a direct impact on the Cork Harbour Natura 2000 sites. The project has been designed to include appropriate treatment of foul and storm water which will avoid impacts on the water quality of Cork Harbour. There will be no impacts from the development on air quality. It has been objectively concluded by Moore Group Environmental Services that: 1. The project is not directly connected with, or necessary to the conservation management of the Great Island SAC or Cork Harbour SPA and any other European sites. 2. The implementation of the project will not have a direct impact on the Great Island SAC or Cork Harbour SPA. 3. The project has been designed to include avoidance measures which will avoid impacts on surface and groundwater during the operational phase and therefore avoids indirect impacts on the Great Island SAC or Cork Harbour SPA. 4. The project, alone or in combination with other projects or plans, is not likely to have a significant effect on the Great Island SAC or Cork Harbour SPA or any other European sites in view of their conservation objectives. It is the view of Moore Group Environmental Services that it is not necessary to undertake any further stage of the Appropriate Assessment process.
The proposed Creon DR extension and related infrastructure is to be located on the north-western side of the existing facility at AbbVie Ireland’s site in the IDA Industrial Estate in Carrigtwohill, Co. Cork. This chapter assesses and evaluates the potential impacts on the soil, geological and hydrogeological aspects of the site and surrounding area.
In assessing likely potential and predicted impacts, account is taken of both the importance of the attributes and the predicted scale and duration of the likely impacts.
13.2 METHODOLOGY 13.2.1 General
The methodology for rating impacts for the EIS is completed in accordance with the EPA ‘Guidelines on the Information to be contained in Environmental Impact Statements’ (EPA, 2002). The EPA document entitled ‘Advice Notes on Current Practice in the Preparation of Environmental Impact Statements’ (EPA, 2003) is also followed in this geological assessment and classification of environmental impacts.
Due consideration is also given to the guidelines provided by the Institute of Geologists of Ireland (IGI) in the document entitled ‘Guidelines for the Preparation of Soils, Geology and Hydrogeology Chapters of Environmental Impact Statements’ (IGI 2013). In addition, the document entitled ‘Guidelines on Procedures for Assessment and Treatment of Geology, Hydrology and Hydrogeology for National Road Schemes’ by the National Roads Authority (NRA, 2009) is referenced where the methodology for assessment of impact is appropriate.
13.2.2 Criteria for Rating Impacts The rating of potential environmental impacts on the soils, geology and hydrogeological environment is based on the matrix presented in Table 13.1 below which takes account of the quality, significance, duration and type of impact characteristic identified.
In the EIS assessment, consideration is given to both the importance of an attribute and the magnitude of the potential environmental impacts of the proposed activities on that cited attribute. The impact ratings presented in Table13.1 below are in accordance with impact assessment criteria provided in the EPA (2002) publication.
AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 13, Page 2
Impact
Characteristic Term Description
Quality
Positive A change which improves the quality of the environment
Neutral A change which does not affect the quality of the
environment
Negative A change which reduces the quality of the environment
Significance
Imperceptible An impact capable of measurement but without noticeable
consequences
Slight
An impact which causes noticeable changes in the
character of the environment without affecting its
sensitivities
Moderate An impact that alters the character of the environment in a
manner consistent with existing and emerging trends
Significant An impact, which by its character, magnitude, duration or
intensity alters a sensitive aspect of the environment
Profound An impact which obliterates sensitive characteristics
Duration
Short-term Impact lasting one to seven years
Medium-term Impact lasting seven to fifteen years
Long-term Impact lasting fifteen to sixty years
Permanent Impact lasting over sixty years
Temporary Impact lasting for one year or less
Type
Cumulative The addition of many small impacts to create one larger,
more significant impact
‘Do Nothing’ The environment as it would be in the future should no
development of any kind be carried out
Indeterminable When the full consequences of a change in the
environment cannot be described
Irreversible
When the character, distinctiveness, diversity, or
reproductive capacity of an environment is not
permanently lost
Residual Degree of environmental change that will occur after the
proposed mitigation measures have taken effect
Synergistic Where the resultant impact is of greater significance than
the sum of its constituents
‘Worst Case’ The impacts arising from a development in the case where
the mitigation measures may substantially fail
Table 13.1 Glossary of Impacts following EPA Guidance Documents
The duration of each impact is considered to be either temporary, short-term, medium term, long-term, or a permanent impact. Temporary impacts are considered to be those which are construction related and last less than one year. Short term impacts were seen as impacts lasting one to seven years; medium-term impacts lasting seven to fifteen years; long-term impacts lasting fifteen to sixty years; and permanent impacts lasting over sixty years.
The NRA criteria for rating the magnitude and significance of impacts at EIA stage on the geological related attributes are also relevant in determining impact assessment and are presented in Table 13.2 below.
AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 13, Page 4
Importance Criteria Typical Examples
Extremely High
Attribute has a high quality
or value on an international
scale
Groundwater supports river, wetland or
surface water body ecosystem protected
by EU legislation e.g. SAC or SPA status
Very High
Attribute has a high quality
or value on a regional or
national scale
Regionally Important Aquifer with multiple
well fields
Groundwater supports river, wetland or
surface water body ecosystem protected
by national legislation – NHA status
Regionally important potable water source
supplying >2500 homes
Inner source protection area for regionally
important water source
High Attribute has a high quality
or value on a local scale
Regionally Important Aquifer
Groundwater provides large proportion of
baseflow to local rivers
Locally important potable water source
supplying >1000 homes
Outer source protection area for regionally
important water source
Inner source protection area for locally
important water source
Medium
Attribute has a medium
quality or value on a local
scale
Locally Important Aquifer
Potable water source supplying >50
homes
Outer source protection area for locally
important water source
Low Attribute has a low quality or
value on a local scale
Poor Bedrock Aquifer
Potable water source supplying <50
homes
Table 13.3 Estimation of Importance of Hydrogeology Attributes (NRA)
The principal attributes (and impacts) to be assessed include the following:
Geological heritage sites in the vicinity of the perimeter of the subject site;
Landfills, industrial sites in the vicinity of the site and the potential risk of encountering contaminated ground;
The quality, drainage characteristics and range of agricultural uses of soil around the subject site;
Quarries or mines in the vicinity, the potential implications (if any) for existing activities and extractable reserves;
The extent of topsoil and subsoil cover and the potential use of this material on site as well or requirement to remove it off-site as waste for disposal or recovery;
High yielding water supply springs/wells in the vicinity of the site to within a 2km radius and the potential for increased risk presented by the proposed development;
Classification (regionally important, locally important) and extent of aquifers underlying the site perimeter area and increased risks presented to them by the proposed development associated with aspects such as for example removal of
AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 13, Page 5
subsoil cover, removal of aquifer (in whole or part), drawdown in water levels, alteration in established flow regimes, change in groundwater quality;
Natural hydrogeological/karst features in the area and potential for increased risk presented by the activities at the site; and
Groundwater-fed ecosystems and the increased risk presented by operations both spatially and temporally.
13.2.3 Sources of Information
Desk-based geological information on the substrata (both Quaternary deposits and bedrock geology) underlying the extent of the site was obtained through accessing publically available databases and other archives where available. Data was sourced from the following:
Geological Survey of Ireland (GSI) – www.gsi.ie on-line mapping, Geo-hazard Database, Geological Heritage Sites & Sites of Special Scientific Interest, Bedrock Memoirs and 1:100,000 mapping.
Teagasc soil and subsoil database;
Ordnance Survey Ireland - aerial photographs and historical mapping;
National Parks and Wildlife Services (NPWS) – www.npws.ie on-line database; Protected Site Register; and
Relevant documentation consulted as part of this assessment included the following:
Groundwater Quality Monitoring Report 2015 at Fournier Laboratories Ireland Limited (AbbVie.) (AECOM Infrastructure and Environmental Ireland Ltd.).
Fournier Laboratories Ireland Ltd. – Phase I & Phase II Environmental Due Diligence Assessment Northern Site Extension (URS Ireland Ltd., April 2005)
Fournier Laboratories Ireland Ltd. – Phase II IDA Site Investigation (URS Ireland Limited August 2004).
Soil and Groundwater Baseline Report for AbbVie (Fournier Laboratories Ireland Ltd). (Draft) - Bluerock Environmental, April 2016.
The methodology for the assessment and mitigation measures proposed has regard to the following guideline documents:
CIRIA, (2011). Environmental good practice on site; Construction Industry Research and Information Association publication C692 (3rd Edition - an update of C650 (2005); (I. Audus, P. Charles and S. Evans), 2011; and
CIRIA, (2012). Environmental good practice on site –pocket book; Construction Industry Research and Information Association publication C715 (P. Charles, and G. Wadams), 2012.
13.2.4 Consultation
Consultation was undertaken with Cork County Council regarding their illegal landfill register. All other information required was available from the desk study and site walkover.
AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 13, Page 6
13.3 EXISTING ENVIRONMENT
13.3.1 Site Area Description
The footprint of the proposed extension is approximately 1808 square metres over four storeys (within the boundary of the existing site). Figure 13.1 shows the site location. The AbbVie site is located in the centre of the southern (original) portion of the IDA Industrial Estate in Carrigtwohill, County Cork. The site lies near the village of Carrigtwohill, approximately 2.2 km north of Cork Harbour. The immediate surrounding area of the AbbVie facility is industrial with agricultural land uses to the north. The closest residential housing is the Castle Lake residential estate which lies approximately 200m to the east of the site. Carrigtwohill town is the most densely populated settlement in the environs of the site, located c.1 km to the east.
13.3.2 Topography
The topography of the site is generally flat for the most part with an average ground level varying from 6.5m OD along the front southern boundary increasing to 7.5m OD around the Main Production Building. (Recent excavations have been completed as part of the recently permitted warehouse development).
13.3.3 Drainage
The existing drainage is discussed in more detail in Section 14.0 Water Hydrology & Aqueous Emissions. The proposed development is located within the South Western River Basin District (SWRBD). The most significant drainage system in the vicinity is Cork Harbour, which are located approximately 1 km south of the site. There are no streams or drainage ditches on the site itself.
13.3.4 Land Use
The immediate surrounding area of the AbbVie facility is industrial with agricultural land uses to the north. The closest residential housing is the Castle Lake residential estate which lies approximately 200m to the east of the site. Carrigtwohill town is the most densely populated settlement in the environs of the site, located c.1 km to the east.
According to data provided via the EPA website, there are a number of licensed IPPC facilities in the locality (Merck Millipore Ltd. and Georgia Holdings Ltd.). There are no licensed waste sites in the vicinity (1km) of the subject site. Consultation with Cork County Council confirmed that there are no known illegal/ historic landfills within 1 km of the site. The Cork County Council closed landfill in Carrigtwohill located in the Rossmore townland to the south of the village and it is approximately 3km from the subject site.
13.3.5 Soil & Subsoil
Figure 13.2 presents the Soil type predominantly at and surrounding the AbbVie site (Source: GSI/Teagasc soil mapping). The site including the proposed extension consist of deep well drained mineral soil (mainly acidic) (AminDW) derived chiefly from Devonian Sandstone.
Figure 13.3 illustrates the subsoil types found at and surrounding the AbbVie site. The subsoil type located at the proposed development is predominantly classified as TDSs – Till type subsoil comprising Sandstone till (Devionian).
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13.3.6 Bedrock Geology
The published geological maps show the area to be underlain by basinal limestone, mudstone and sandstone, which is predominately dark laminated, calcareous shale and is locally sandy. The bedrock has been classed as (Rk) indicating a regionally important aquifer with karstic flows, however this unit is not typically used for water supply in the area as well yields can be variable. Most drinking water comes from council mains supplied by the Lee Reservoir.
The overburden is comprised of sand and gravel, which comprises a locally important aquifer which is exploited for industrial water supply at the former Youghal Carpet site and within the original IDA Industrial Estate The depth to bedrock is variable in the area but prior investigations at the Fournier site indicate that depth to bedrock is likely to be greater than 25 metres at the subject site.
Information from the Geological Survey of Ireland suggests that the site lies close to the contact between ‘Waulsortian’ silty limestones and Upper Devonian sandstones, on the northern limb of a major syncline. Subsoils in the area typically consist of clays, silts, sands and gravels.
Inspection of the available GSI records (Data Sheet 25) show that the bedrock geology underlying the site and surrounding area is dominated by rocks of Carboniferous Age. The regional geology is presented in Figure 13.4. The AbbVie site is underlain predominately by Dinantian Pure Unbedded Limestones, while the surrounding areas are dominated by Dinantian Lower Impure Limestones and Dinantian Mudtones and Sandstone (Cork Group). Previous site investigations (URS, 2005) indicated that the depth to bedrock is generally >20 mbgl with the area of shallowest bedrock located in the east of the site.
The GSI (2015) database presently lists no karst features in the immediate vicinity of the AbbVie site.
13.3.7 Site Investigation History
Site specific information from the previous site investigations are detailed below: An Environmental Impact Statement (EIS) for the original IDA industrial estate at Carrigtwohill, was undertaken in 1977 by Malachy Walsh & Partners. Considerable variation in subsoil thickness was found between boreholes, with the dominant soil types being brown sandy clay with gravel, gravels with layers of sandy clay and loose to dense silty sands. The loose sand stratum was noted to have a low bearing capacity. Groundwater was recorded at less than 2 metres below ground and dewatering measures during excavation were considered likely to be required. A desk study site appraisal was carried out on the original IDA industrial estate at Carrigtwohill by Ove Arup & Partners Ireland in 1991 for IDA as well as an Environmental Impact Statement (EIS) for the northern extension of the industrial estate at Carrigtwohill, in 1997. Dames & Moore carried out a Phase II site investigation at the site of the current Fournier facility (then called Island Pharmaceuticals) in early 1997. Shallow soil sampling (3 to 5 metres depth) was carried out across the site and three monitoring
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wells were drilled to a maximum depth of 11 metres below ground to allow assessment of groundwater flow direction and chemical status. No bedrock was encountered in any well and clayey gravelly soils were encountered. Groundwater flow within the gravel units was interpreted to be southerly towards Cork Harbour (Slatty Water tidal channel). No evidence of soil or groundwater contamination by volatile organic compounds, semi-volatile organic compounds, petroleum hydrocarbons, pesticides, polychlorinated biphenyls or inorganic compounds was detected.
The 1997 wells on the Island Pharmaceutical site were sampled and analysed by Project Management in 2001, during Fournier Laboratories’ acquisition of the site. Elevated clostridium results indicated possible historical faecal pollution, possibly due to nearby agricultural activity (livestock grazing), as Island Pharmaceuticals did not have a septic tank system. Elevated iron and aluminium results and trace level detection of petroleum hydrocarbons were attributed to insufficient purging of the wells and the presence of suspended sediments in the samples prior to sampling. In 2003 Fournier Laboratories had two additional monitoring wells drilled by Geotech Specialists Limited due to destruction of two of the 1997 monitoring wells during construction on the Fournier site.URS Ireland Ltd (URS) was engaged by Fournier Laboratories Ireland Ltd., to undertake a Phase I and Phase II Environmental Due Diligence Assessment of lands adjacent to the existing Fournier site. A geotechnical and foundation study was undertaken in February/March 2005. Five boreholes were drilled to depth of up to 20 metres, including one specifically targeted on the major geophysical anomaly in the east of the site. No anomalous ground conditions were detected in any of the five boreholes. The borehole data suggest that the geophysical anomaly is not related to any geological feature. The cause of the anomaly remains uncertain. The water table in the soils is relatively deep.
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13.3.8 Geological Heritage
The GSI Public Viewer on-mapping (www.gsi.ie/mapping) was reviewed to identify sites of geological heritage for the site and surrounding area. There is no evidence of any site which could be considered suitable for protection under this programme or recorded in the Cork County Development Plan for 2015-2021. The nearest recorded site i.e. Rock Farm Quarry, Little Island is located approximately 5 km southwest of the site.
13.3.9 Economic Geology
The Extractive Industry Register (www.epa.ie) and the GSI mineral database were consulted to determine whether there were/ are any mineral sites close to the subject site. The closest active quarry is located approximately 1.5km from the site. The EPA ENVision website confirmed that there are no mines on/ near the subject site.
13.3.10 Geo-Hazards
According to the GSI on-line database, there are presently no records of geo-hazards such as landslides, within a radius of 10Km of the site.
13.3.11 Rating of Importance of Geological Attribute
Based on the NRA methodology (2009) - Criteria for rating site importance of geological features - the importance of the bedrock and soil features at this site is rated as Medium/High Importance based on the assessment that the attribute has a local/regionally important significance or value on a local scale. There are no extractable mineral localities or areas of geological heritage, and the soils are suitable for agricultural use but are typical of surrounding agricultural land.
Groundwater can be defined as water that is stored in, or moves through, pores and cracks in sub-soils. The potential of rock to store and transport water is governed by permeability of which there are two types, inter-granular and fissure permeability. Inter-granular permeability is found in sediments, sands, gravels and clays as are also present at the subject site, and fissure permeability which is found in bedrock, where water moves through (and is stored in) cracks, fissures, fracture planes and solution openings for example.
Aquifers are generally classified as rocks or other matrices that contain sufficient void spaces and which are permeable enough to allow water to flow through them in significant quantities.
13.3.12.1 Aquifer Classification
The GSI has classified the bedrock aquifer underlying the majority of the site as a Locally Important Bedrock Aquifer (Ll) which is moderately productive in Local Zones. The south of the site is underlain by a Regionally Important karstified bedrock aquifer (Rk) dominated by diffuse flow (refer Figure 13.5).
Reviewing the EPA on-line database, the site is located in the Midleton Groundwater Body (GWB) and its current status (i.e. based on quality data for the period 2007-2012) is ‘Good’’ and the Water Framework Directive risk score for this GWB is currently rated as ‘1a’ i.e. ‘at risk of not achieving good status’ by 2015.
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13.3.12.2 Aquifer Vulnerability Aquifer vulnerability is a term used to represent the intrinsic geological and hydrogeological characteristics that determine the ease with which groundwater may be contaminated generally by human activities. Due to the nature of the flow of groundwater through bedrock in Ireland, which is almost completely through fissures, the main feature that protects groundwater from contamination, and therefore the most important feature in protection of groundwater, is the subsoil (which can consist solely/ or of mixtures of peat, sand, gravel, glacial till, clays or silts).
The GSI presently classifies the aquifer in the region of the subject site as High (H) which indicates an overburden depth of 3m-5 m of low permeability soil is present (refer to Figure 13.6). The conceptual site model, initially developed by Dames & Moore (1997) and refined by URS in 2006, concluded that AbbVie (Fournier) site is underlain by moderate to low permeability clayey gravels, gravelly clays and sandy silts over 20m thick. Limestone bedrock is expected to be more than 25m below ground level. Based on the conceptual site model the aquifer of the subject site is classified as Low vulnerability
13.3.13 Groundwater Flow & Quality
The conceptual site model, initially developed by Dames & Moore (1997) and refined by URS in 2006, reported that groundwater within the sand and gravel horizons is perched and unconfined, with flows decreasing as silt and clay content increases. The principal aquifers in the area are expected to be the unconfined gravels and the deeper Waulsortian limestone bedrock. Based on the conceptual site model groundwater is considered to flow southwards, within the gravels, ultimately discharging to Cork Harbour in the vicinity of Slatty Water;
13.3.13.1 Groundwater Quality
Annual groundwater monitoring was undertaken at the AbbVie facility in December 2015 in line with previous monitoring activities. The scope of the work included sampling groundwater from the three on-site groundwater monitoring wells, analysis for a suite of parameters and comparison of results to published guidelines and historic results.
As in previous years, VOCs, SVOCS, Alcohols or acetates were not detected above Minimum Reporting Levels (MRLs) in groundwater from any of the three monitoring wells sampled.
Zinc was the only dissolved heavy metal detected above MRLs and reported concentrations were below relevant guidelines values.
Total Organic Carbon (TOC) and Chemical Oxygen Demand (COD) were not detected above their respective MRLs in any of the three wells.
Phosphorus was detected above the MRL but at concentrations below relevant guidelines values.
Total suspended solid concentrations were recorded at elevated levels, but within previously observed ranged and are attributed to turbid groundwater, related to the silty aquifer material.
13.3.14 Water Supplies
The GSI Well Card Index is a record of wells drilled in Ireland. It is noted that this record is not comprehensive as licensing of wells is not currently a requirement in the Republic of Ireland. Groundwater in the area is used for industrial supply. There are 37 groundwater wells recorded within 2 km of the site in the GSI well records. Of these 15 are known to abstract from the gravel units and 7 abstract from the sandstone bedrock. The aquifer unit is not known in the remainder of the wells.
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Most of the wells are for industrial or small scale domestic/agricultural use. No group water schemes or public supply wells are recorded. Five ‘Excellent’ (well yield > 400 m3/day) or ‘Good’ (well yield 100-400 m3/day) wells serving industrial users are noted within 1 km of the site (see Table 13.5). Four are to the east of the site and one is 250 m south of the site.
GSI Name Location Use Total
Depth (m) Depth to
Bedrock (m) Yield m3/d
Yield Class
1707SWW058 Killahora Unknown 30.8 4.6 32.7 Poor
1707SWW171 Anngrove Agri &
Domestic 46
1707SWW181 Foto Island
Estate Other 20
1707SWW057 Springhill Unknown 4.6 4.6 21.8 Poor
1707SWW133 Barryscourt Agri &
Domestic 81.7 4.5
1707SWW132 Carrigtwohill Domestic use
only 36.6 3 32.7 Poor
1707SWW131 Springhill Domestic use
only 30.5 1.8 54.5 Moderate
1707SWW135 Foaty Agri &
Domestic 25.3 9.1
1707SWW048 Killacloyne Industrial Use 31.1 381.8 Good
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1707SWW159 8 8 Table 13.4 GSI Well Index table from well search (source: www.gsi.ie)
Figure 13.8 presents the GSI well search for the area surrounding the site, and Table 13.4 and 13.5 summarises the details of some of the wells within this search area. The area in the vicinity of the site is generally serviced by public mains. There are no public water supplies sourced from groundwater in the area and there are no groundwater Source Protection Zones in the vicinity of the site according to the EPA & GSI (2015) online database.
13.3.15 Areas of Conservation
The nearest site designated for nature conservation is the proposed Natural Heritage Area (pNHA) and Special Area of Conservation (SAC) The Great Island Channel (001058), and the Special Protected Area (SPA) Cork Harbour (004030) located approximately 1 km south of the site. Refer to Chapter 12 Flora and Fauna.
13.3.16 Overall evaluation of Hydrogeological Features
Based on the NRA methodology (refer Table 13.3 above), the criteria for rating site importance of hydrogeological features, the importance of the hydrogeological features at this site is rated as Medium to High Importance. This is based on the assessment that the attribute has a medium - high quality significance or value on a local scale. The site is predominately underlain with a locally important bedrock aquifer and the south of the site is underlain by a Regionally Important karstified bedrock aquifer not used for public water supply or generally for potable use.
13.4 CHARACTERISTICS OF THE PROPOSED DEVELOPMENT
13.4.1 General
The characteristics of the proposed development with regard to the soil, geological and hydrogeological environment are outlined below. Due to the inter-relationship between soils, geology and hydrogeology, surface water (hydrology) and waste management the following impacts discussed will be considered applicable to both Chapter 14.0 and 15.0 of the EIS.
Creon DR will have its own dedicated production building located adjacent to the existing production building. The new dedicated production facility for Creon DR will primarily be required as there is insufficient production capacity within the existing manufacturing trains. In addition, the tabletting process for Creon DR differs slightly from existing processes, particularly in relation to the use of solvent. It is proposed to drain process effluent via a new connection to the existing process wastewater infrastructure, with the exception of certain high-phosphorus CIP streams which will be tankered off-site as aqueous waste for treatment and disposal. Surface water and foul water emissions associated with the new development will tie into the existing surface water and foul water systems respectively. The characteristics of the proposed development with regard to the soil, geological and hydrogeological environment, relate to both construction and operation activities. The proposed extension will be 1808 m2 in a further surrounding paved area.
13.4.2 Construction Stage
The proposed works will comprise construction on a portion of the site which has previously been undeveloped. The site is within an industrial park planned for industrial development and serviced by public water and sewer.
AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 13, Page 13
The key civil engineering works which will have potential impact on the soils, geology and hydrogeology environment during construction are summarised below:
During construction 160m³ of soil is estimated as requiring removal from site as part of the excavation for building foundations etc
Drainage Construction will involve the extension of existing surface water drainage system and foul drainage system to the building.
Other construction activities will include site storage of cement and concrete materials, temporary oils and fuels.
The potential impacts of construction in relation to the soil, geology and hydrogeological environment have been assessed based under the following headings:
13.4.2.1 Excavation and Infilling
Excavation of soil will be required for construction of building foundations. Site investigation and laboratory analysis has not identified any existing contamination does not indicate that any contaminated soil or water should be encountered. However, if contaminated soil/ water is encountered, it will be removed by a licensed waste contractor.
13.4.2.2 Accidental Spills and Leaks
During construction of the development, there is a risk of localised accidental pollution incidences from the following sources:
Spillage or leakage of temporary oils and fuels stored on site.
Spillage or leakage of oils and fuels from construction machinery or site vehicles.
Spillage of oil or fuel from refuelling machinery on site.
Run-off from concrete and cement during pad foundation construction.
Accidental spillages may result in localised contamination of soils and groundwater underlying the site, should contaminants migrate through the subsoils and impact underlying groundwater. Groundwater vulnerability at the site is currently considered low. Any soil stripping and foundation construction will also further reduce the thickness of subsoils and the natural protection they provide to the underlying aquifer. Concrete (specifically, the cement component) is highly alkaline and any spillage which migrates though subsoils would be detrimental to groundwater quality.
13.4.2.3 Surface Water Run-off
Surface water run-off during the construction phase may contain increased silt levels or become polluted from construction activities. Run-off containing large amounts of silt can cause damage to groundwater underlying the site. Silt-laden water can arise from exposed ground and soil stockpiles (prior to reinstatement).
Based on the points stated above in relation to the construction phase the potential impact on the soils, geology and hydrogeology during construction (following EPA, 2002) is considered to have a Short term, Imperceptible impact, i.e. an impact capable of measurement but without noticeable consequences.
13.4.3 Operational Stage
The key works which will have a potential impact on the soil, geology and hydrogeological environment during operation are summarised below:
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(i) Increased hard standing (on the green field) will reduce local recharge to ground and increase surface water run-off potential if not limited to the greenfield run-off rate from the site.
(ii) Bulk chemicals and solvents will be used and stores will be bunded. However, accidental releases could occur if not mitigated adequately.
(iii) Localised accidental discharge of hydrocarbons could occur in car parking areas and along roads.
(iv) Waste water discharge (process waste & foul) will be discharged to the foul sewer system and not to ground.
The potential impacts in relation to the soil, geology and hydrogeological environment which have been assessed are as follows:
There is no likely impact on the geological heritage, sensitive groundwater receptors or groundwater supplies in the vicinity of the proposed development site as none are present in the immediate vicinity of the site.
There will be a local reduction in recharge to the aquifer due to the increase in hardstanding on this and surrounding developed lands, however this is not likely to have any impact in terms of the regional groundwater regime.
There will be no direct discharges of contaminated water to groundwater or soil environments during the operational phase. Measures are in place to contain any accidental leaks.
The potential impact on soils, geology and hydrogeology during operation (following EPA, 2002) is considered to have a Long term, Imperceptible impact i.e. an impact capable of measurement but without noticeable consequences.
The design of the proposed development has taken account of the potential impacts on the soils, geology and hydrogeology environment local to the area where construction will take place and containment of contaminant sources during operation. Measures have been incorporated into the design to mitigate the potential effects on the surrounding soils, geology and hydrogeology. These are described in further detail below.
Due to the inter-relationship between soils, geology, hydrogeology, hydrology and waste management, the following mitigation measures discussed will be considered applicable to all.
13.5.2 Construction Stage
A project-specific Construction Management Plan (CMP) will be established and maintained by the contractors during the construction and operational phases of the proposed project. The plan will cover all potentially polluting activities and include an emergency response procedure. All personnel working on the site will be trained in the implementation of the procedures. At a minimum, the manual will be formulated in consideration of the standard best international practice including but not limited to:
CIRIA, (2001), Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors, (C532) Construction Industry Research and Information Association;
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CIRIA (2005), Environmental Good Practice on Site (C650); Construction Industry Research and Information Association;
BPGCS005, Oil Storage Guidelines;
CIRIA 697 (2007), The SUDS Manual; and
UK Pollution Prevention Guidelines, (PPG) UK Environment Agency, 2004. 13.5.2.1 Fuel and Chemical Handling
To minimise any impact from material spillages, all oils, solvents and paints used during construction will be stored within temporary bunded areas. Oil and fuel storage tanks shall be stored in designated areas, and these areas shall be bunded to a volume of 110% of the capacity of the largest tank/container within the bunded area(s) (plus an allowance of 30 mm for rainwater ingress). Drainage from the bunded area(s) shall be diverted for collection and safe disposal.
Re-fuelling of construction vehicles and the addition of hydraulic oils or lubricants to vehicles, will take place in a designated area (or where possible off the site) which will be away from surface water gulleys or drains. In the event of a machine requiring refuelling outside of this area, fuel will be transported in a mobile double skinned tank. An adequate supply of spill kits and hydrocarbon adsorbent packs will be stored in this area. All relevant personnel will be fully trained in the use of this equipment. Guidelines such as ‘Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors’ (CIRIA 532, 2001) will be complied with.
All ready-mixed concrete will be brought to site by truck. A suitable risk assessment for wet concreting will be completed prior to works being carried out which will include measures to prevent discharge of alkaline waste waters or contaminated storm water to the underlying subsoil. Wash down and washout of concrete transporting vehicles will take place at an appropriate facility offsite.
13.5.2.2 Accidental Releases
Emergency response procedures will be outlined in the site CMP. All personnel working on the site will be trained in the implementation of the procedures.
13.5.2.3 Soil Removal and Compaction
Construction works will require local removal of soil cover. As bedrock vulnerability is low (due to the thick cover of overburden on the site) any removal of soil cover will increase the vulnerability of the underlying bedrock however it is unlikely to result in any significant increase in risk. It is envisaged that where feasible much of the soil excavated will be retained on site and re-used as fill material or landscaping.
Temporary storage of soil will be carefully managed in such a way as to prevent any potential negative impact on the receiving environment and the material will be stored away from any open surface water drains. Movement of material will be minimised in order to reduce degradation of soil structure and generation of dust.
Although there is no evidence of historical contamination in the area, all excavated materials will be visually assessed for signs of possible contamination such as staining or strong odours. Should any unusual staining or odour be noticed, samples of this soil will be analysed for the presence of possible contaminants in order to ensure that historical pollution of the soil has not occurred. Should it be determined that any of the soil excavated is contaminated, this will be disposed of by a licensed waste disposal contractor.
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13.5.3 Operational Stage
AbbVie is currently finalising an application for an EPA Industrial Emissions Licence. As such, monitoring of containment measures to ensure environmental compliance will be undertaken as part of regular licensed operations. An environmental management plan (EMP) will be followed to ensure compliance with licencing requirements. This will include site-specific emergency response measures and all relevant personnel will be trained accordingly. Specific mitigation measures related to soil and water protection for the operational phase include the following:
13.5.3.1 Fuel and Chemical Handling
Chemical storage is limited to the bunded tank farm, drums stores and designated process areas. Handling and transfer of fuel and chemicals is carefully controlled. The volume of chemicals stored and the containment measures planned will minimise the risk of release of solid/liquid material spillages to the water environment.
All process materials, product and chemicals will be delivered to the site in tamper proof and/or lockable containers or tankers, which are approved for transport use. Storage of hazardous materials on site will be in bunded containers or compartments. All holding/ storage and chemical tanks within the tank farm will be bunded and will be located on a bunded concrete hard stand. The design of all bunds will conform to standard bunding specifications - BS8007:1987 and BS EN 1992-3:2006. Any chemicals required for site maintenance will be stored in suitable contained areas.
13.5.3.2 Fire Water System
In the development of the Creon project, AECOM have undertaken a Firewater Risk Assessment for the site and based on the amount and storage of flammable materials, the amount of materials with risk phase R52 and R53, the use of fire alarms and automatic sprinkler systems across the site, the use of automatic fire extinguishers and spoke detectors in the chemstore, and in consideration of the Environmental Protection Agency’s (EPA) “Guidance to Industry on the Establishment of Firewater Retention Facilities” (1995), they concluded that onsite firewater retention facilities will not be required (AECOM, 2016). AECOM have also provided the following recommendations to further reduce the environmental risks from firewater at the site:
Use of manual or automatic shut off valves on all discharge points where the stormwater drain exits the site;
Investigate feasibility of installing automatic fire extinguishers in the Wastestore (as per chemstore);
Paving of the unpaved gravel area immediately around and between the Wastestore and the Chemstore buildings.
Onsite stormwater drainage is discussed further below.
13.5.3.3 Site Drainage
All site drainage will be served by the existing foul and storm water drainage systems within the Industrial Park. The site storm water drainage system will pass through an interceptor) before passing to the main storm drainage system. This will protect the receiving waters from pollution by any oil, which may be present. As above, a shut off valve may be installed on the surface water discharge so that site discharges can be shut off in the event of a fire. Foul drainage will be collected from site (admin and canteen building etc.) and discharged to the local foul drainage network which ultimately
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AbbVie (Fournier Laboratories Ireland Ltd) EIS Chapter 13, Page 17
discharges to the local WWTP. Waste cooling water from the temperature control systems will also discharge to foul sewer. There are no planned discharges to ground.
13.5.3.4 Accidental Emissions
Operation of the plant will be according to BAT (Best Available Technology) principles and in compliance with the proposed IED licence for the site to ensure that inputs to, and subsequent contamination of soil and water environments does not occur during normal and/or emergency conditions (material spillage or fire event situations).
As the site will be paved any accidental emissions from fuel spills or contaminated run-off will be directed through the surface water drainage system through oil interceptors prior to discharge off site rather than infiltrate directly to ground.
Mitigation and emergency response measures are incorporated in the existing environmental management plans as part of the Licence requirement.
13.6 RESIDUAL IMPACTS & PROPOSED MONITORING
13.6.1 Residual Impacts
The residual impacts are those that would occur after the mitigation measures have taken effect.
The loss of land, in an area zoned for industrial development is considered negligible. There are no planned discharges to ground or likely changes to the natural groundwater regime. As such, for the proposed development the residual impact is considered to be Neutral in terms of quality and of Imperceptible significance as a result of this proposed development on the surrounding soils, geology and hydrogeological environment.
13.6.2 Monitoring
Groundwater monitoring will continue to be undertaken by AbbVie and will be part of any EPA licence requirements during the operational phase of the proposed development. (Soil monitoring may also be periodically required under the proposed IED licence).
13.7 PREDICTED IMPACT OF THE DEVELOPMENT
Following the NRA criteria for rating the magnitude and significance of impacts on the geological and hydrogeological related attributes, the magnitude of impact is considered Negligible.
13.7.1 Cumulative Impacts with Neighbouring Facilities
The site and surrounding lands within the Carrigtwohill industrial park are zoned for industrial development therefore further development is anticipated.
In terms of soils, geology and hydrogeology, the cumulative impacts considered are:
Increase in hard standing: This will result in localised reduced recharge to groundwater. However, in terms of the overall aquifer area, this is not likely to have any impact in terms of the regional groundwater regime.
There is an increase in potential for contamination of water courses during construction and operation. However, mitigation measures are required to manage
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sediment run-off during construction. The planned new Creon DR building and surrounding facilities will have construction management plans and be licensed under the EPA during operation. Mitigation measures and monitoring programmes required by the EPA will reduce the likelihood of any contamination being discharged to ground.
13.8 INTERACTION WITH OTHER CHAPTERS
Interaction with ecology and surface water has been considered.
13.9 CONCLUSIONS
In relation to the construction phase of the proposed development the potential impact on the soils, geology and hydrogeology during construction (following EPA, 2002) is considered to have a Short term, Imperceptible impact, i.e. an impact capable of measurement but without noticeable consequences. The potential impact on soils, geology and hydrogeology during operation (following EPA, 2002) is considered to have a Long term, Imperceptible impact i.e. an impact capable of measurement but without noticeable consequences. The residual impact once proposed mitigation measured are put in place is considered to be Neutral in terms of quality and of Imperceptible significance as a result of this proposed development on the surrounding soils, geology and hydrogeological environment.
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Copyright AWN CONSULTING LIMITEDAll rights reserved. No part of this workmay be modified or reproduced or copiedin any form or by means - graphic, electronicor mechanical, including photcopying,recording, taping or information retrieval system, or used for any purpose other thanits designated purpose, without the written permission of AWN Consulting Limited
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Copyright: Ordnance Survey Ireland/ Government of Ireland, DCENR, GSI. Ordnance Survey Ireland Licence No. EN 0047212. AWN licence no. EN 0007513Note: Drawing is for illustrative purposes only; Do not scale
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Environmental Impact Statement for a proposed expansion to the AbbVie facility in Carrigtwohill, Co. Cork.
PROJECT:D.McD.
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Copyright: Ordnance Survey Ireland/ Government of Ireland, DCENR, GSI. Ordnance Survey Ireland Licence No. EN 0047212. AWN licence no. EN 0007513Note: Drawing is for illustrative purposes only; Do not scale
0 1 20.5Km
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Copyright: Ordnance Survey Ireland/ Government of Ireland, DCENR, GSI. Ordnance Survey Ireland Licence No. EN 0047212. AWN licence no. EN 0007513Note: Drawing is for illustrative purposes only; Do not scale
0 1 20.5Km
LegendSite BoundaryDevonian Old Red SandstonesDinantian Lower Impure LimestonesDinantian Mudstones and Sandstones (Cork Group)Dinantian Pure Bedded LimestonesDinantian Pure Unbedded LimestonesDinantian Upper Impure LimestonesStructural faults (GSI 100k)
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Copyright: Ordnance Survey Ireland/ Government of Ireland, DCENR, GSI. Ordnance Survey Ireland Licence No. EN 0059208. AWN licence no. EN 0007513Note: Drawing is for illustrative purposes only; Do not scale
LegendSite BoundaryLlRkdUnclassified
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Ll - Bedrock which is Moderately Productive only in Local ZonesRkd - Regionally Important Aquifer - Karstified (diffuse)
GIS source: http://www.gsi.ie/Mapping
Aquifer Classification
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PROJECT:Environmental Impact Statement for proposedextension to theexisting AbbVie facilityCarrigtwohill, Co. Cork.
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LEGEND
Copyright: Ordnance Survey Ireland/ Government of Ireland, DCENR, GSI. Ordnance Survey Ireland Licence No. EN 0047212. AWN licence no. EN 0007513
0 1 20.5Km
±Site BoundaryX (Rock at/near surface or karst)E (Rock at/near surface or karst)H - HighHL - High-LowM - ModerateL - Low
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping,Aerogrid, IGN, IGP, swisstopo, and the GIS User Community GIS source: http://www.gsi.ie/Mapping
Aquifer Vulnerability
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National Vulnerability (GSI 2011)Vulnerability Class
X (Rock at/near surface or karst)E (Rock at/near surface or karst)H - HighHL - High-LowM - ModerateL - Low
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0 1 20.5Kilometers
Environmental Impact Statement for proposedextension to theexisting AbbVie facilityCarrigtwohill, Co. Cork.
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LEGEND
Copyright: Ordnance Survey Ireland/ Government of Ireland, DCENR, GSI. Ordnance Survey Ireland Licence No. EN 0047212. AWN licence no. EN 0007513Note: Drawing is for illustrative purposes only; Do not scale
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1707SWW1341707SWW130
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0 0.25 0.50.125Km
LegendSite Boundary
!A GSI - Monitoring wells (10-50m)GSI Wells (50-100m)GSI Wells (100-200m)GSI - Well Search (250-500m)GSI - Well Search (1Km)
±
GIS source: http://www.gsi.ie/Mapping
GSI Well Search
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