. 3.0 ENVIRONMENTAL IMPACTS AND REMEDIAL ...

Environm~ntallmpact Statement

. 3.0 ENVIRONMENTAL IMPACTS AND REMEDIAL MEASURES

OXigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2. Section 3

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. 3.1 Environmental Nuisances and Monitoring

3.1.1 Introduction

As with any waste facility it is possible that some environmental nuisances may occurwithin the site, and within the environs. However this impact will be minimal due largelyto the mitigation measures adopted on site to combat the effect of these environmentalnuisances. Strict adherence to the conditions of the waste license, good managementpractises, control over individual procedures, and maintenance of the negative airsystem are essential to ensure the site will not impact on receptors in the area. Theexisting site has an excellent environmental record which Oxigen will strive to maintain.

3.1.2 Baseline Description

The subject site is part of the overall Ballymount Industrial Estate, located in Clondalkinin Dublin's south west. The Ballymount Industrial Estate predominately consists ofcommercial and industrial uses. The development is well served by the existing roadnetwork and is located 0.5 km east of the M50 motorway and approximately 1kmsoutheast of the Red Cow Interchange. Oxigen currently operates a dry recyclables,general skip waste, and construction and demolition, recovery facility at the subject siteunder Waste Licence W0208-01.

Although there are environmental issues associated with any proposed wasteinfrastructure mitigation measures such as those listed below will be employed on site sothat the proposed facility operations will not present a risk to the local environment. Thefacility is designed and will continue to operate in a manner that will eliminate orminimize the risk of any environmental nuisance. Figure 3.1 below shows existingmonitoring locations on site. Specific measures are already in place on-site to combatthe effect of any potential environmental nuisance and these are listed below. Thesemeasures will be increased should they be required as a result of the proposeddevelopment. Environmental issues associated with the day to day operation of theexisting and proposed development are as follows;

• Noise• Vermin and Pest Control• Bird Control• Odour Control and Emissions to Air• Dust Emissions• Litter Control• Other

Oxigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2. Section 3

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Environme~tal Impact Statement

Figure 3.1. Ballymount Monitoring Locations

Q9 Noise Mon itoring Location

oDust Monitoring Location

SW

SE

Surface Water Monitoring Location

Sewer Water Monitoring Location

3.1.3 The Predicted Impacts

NoiseThe potential impact of the proposed development to noise levels is described in greaterdetail in Section 3.7 Noise. In summary noise monitoring is a requirement of the currentEPA waste licence (WO-208-01) for the site and control measures will be increased tocontrol and reduce noise emissions in compliance with the new EPA Licence for thefacility which will take account of the proposed new development. Baseline noisemeasurements are included in Section 3.7. These highlight that noise levels on site arebelow the emission limit values.

The main sources of noise at the facility will come from the following sources;

• Traffic Movement On-Site

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Environm~ntal Impact Statement

• Vehicle Tipping• Plant and Machinery• Construction Plant and Machinery• Processes in the Proposed Shed

Specific mitigation measures proposed include the following: All vehicles will be requiredto enter and leave the facility at the speed limit of 1Okm/hr as per the Waste AcceptanceProcedures. All treatment and handling operations will be conducted inside a buildingwhich is totally enclosed, thus the emission of noise from mobile and stationaryequipment is dramatically reduced. All plant, machinery, and fans etc. associated withthe process will be designed to produce minimum noise and will be maintained to a highstandard to ensure continued compliance with emission limit values of the EPA Licence.Noise levels may increase in the immediate vicinity during the construction period due toincreased traffic and construction work. Any noise effects are likely to be related mainlyto annoyance. The short-term construction period minimizes the risk of any healthaffects.

Vermin and Pest Control

Vermin and insects can potentially be a problem where putrecsible waste is not handledproperly. However, this usually arises where waste is either being disposed of such as tolandfill or where it is being stored for long periods of time. Control of rodents is amandatory prerequisite for any waste management facility and strict mitigation measureswill be put in place to control vermin and pests on the site. Eastern Pest control iscurrently employed on site and carries out 8 visits per year to monitor pest nuisance. Ifvermin are found then extra bait boxes are immediately laid and the number of visits byEastern Pest Control increased. Daily inspections are carried out by the ComplianceOfficer on site which highlights any nuisances. If any such nuisances are recorded onsite then appropriate measures are undertaken in accordance with the EMS procedures.

Current pest control measures on site consist of;

• Daily cleaning of the shed floors by a sweeper.• The laying of bait at various locations around the site to control vermin.• Bait shall be laid at various locations around the site to control vermin. The

Facility Manager shall decide where these are to be laid or may employ theservices of a Pest Control Company if considered necessary.

• On a daily basis the facility and surrounding areas are checked for verminnuisance by the Facility Manager/Assistant Facility Manager/ Compliance Officerand a daily inspection form is filled in. If a vermin nuisance is detected duringthis monitoring, then a more intensive baiting program is undertaken.

• If a yard operative notices any vermin during the course of his/her work thenhe/she informs the Facility Manager.

• Fly nuisance is minimised on site by the rapid removal of degradable waste offsite, the washing of the floor of each of the operations buildings with disinfectant,the covering of all compacted waste and ensuring all skips stored outside arekept empty and clean. In 2008 probes were installed in the sheds which canspray water or biodegradable insecticide as required.

Oxigen Environmental Ltd. Ballymount Pre-Treatment Facility Volume 2: Section 3

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. There will be no long term storage of MSW in the proposed shed as it will not be keptovernight. The treatment processes will be completely enclosed. The floor of the buildingwill be swept and washed down at regular intervals with disinfectant. Fly nuisance will beminimized in summer months by spraying on a monthly basis with biodegradableinsecticide. Current practice on site is to spray the building every fortnight in particularlyhot weather.

Bird Control

Birds will be attracted to waste management facilities where there is available food forthem to scavenge. Waste handling procedures on site will be such that waste is exposedonly within the pre-treatment shed and any stored waste within the shed will be in sealedcontainers and therefore not a source of food for scavenging birds. As a result birdcontrol measures are not deemed necessary.

Odour Control and Emissions to Air

The potential impact of the proposed development on odour levels within the area isdescribed in Section 3.3.2 Human Beings and Odour. In summary Odour is the mostsignificant potential environmental impact associated with the proposed developmentand has the greatest potential to create a local nuisance and deterioration of quality oflife. Therefore Oxigen have undertaken a number of mitigation measures to minimizeany impact. The primary mitigation measure is the proposed odour control system whichis based on carbon filtration and will be a simple and effective way of controlling theodour of the waste air coming from the building. This is dealt with in more detail inChapter 2.1.5. In order to ensure the full potential of the negative ventilation systemvarious containment principles will be implemented within the proposed building. Thesewill include;

• Making sure the building is constructed without any gaps in the building fabricusing combined flashing and expanding foam,

• Installation of rapid roller doors on the entrance and exit of the waste receptionhall,

• Installation of PVC plastic curtains inside the doors to reduce the available doorarea once the rapid door is opened,

• Zoned extraction within the building to remove odorous air from the most odoroussources within the building.

As all processes will take place in the fully enclosed building which will be kept undernegative air pressure at all times it will therefore avoid any odour nuisance. An odourdispersion model was carried out by RPS Consulting Engineers and is also detailed inChapter 3.3.2 and Volume 3: Appendix 3.1. The model predicts that the emissions fromthe proposed development will not give rise to reasonable cause for odour annoyanceonce the proposed mitigation measures are put in place.


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Environmental Impact Statement

Dust Emissions

Waste handling operations on the site ensure that all tipping of waste occurs within theproposed building and any dust emissions are therefore contained. Dust curtains will beinstalled on the entry/exit points to the proposed shed to minimize fugitive dustemissions. The proposed negative extraction odour control unit will result in the removalof 95% of dust particles from the air in the building before it is released through thestack. In dry weather the yard will be sprayed with water and as when required tominimize airborne dust nuisance. Oxigen Environmental will implement additional dustmonitoring and control procedures at the facility as per the monitoring requirements ofthe EPA licence.

Litter Control

Litter procedures are currently in place to prevent litter nuisance at the facility or in theimmediate area of the facility. These practices will be carried out for the proposeddevelopment also and are as follows;

• The road network is kept free from debris caused by vehicles entering or leavingthe facility, any debris is removed immediately.

• Waste will never be left uncovered or in the open air thereby minimizing thepotential for litter escape.

• Daily litter patrols of the overall site and the access roads are carried out.

In addition to the measures and controls outlined above, Oxigen Environmental willimplement strict and responsible operational procedures at the facility, to ensure safe,efficient, and environmentally safe activities. All areas of operation including wasteacceptance and waste transfer, equipment operation and maintenance and health andsafety and training will be carried out in such a way that is in compliance with the EPALicence and does not pose any significant risk to the environment. Emphasis will beplaced on energy reduction and emission control. All staff will follow a strict reportingstructure with clear and open channels of communication through line management.

3.1.4 Mitigation Measures

The table below presents the potential impacts from the proposed development, themitigation measures proposed by Oxigen Environmental and the resulting riskassessment.


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. Table 3.1.4 Potential Impacts from the Proposed & Mitigation Measures

SourceImpact

of IPotentialReceptor

IMitigation IRisk IFurther Comment

Use of Services Local Residents

Vermin Local Residents

Employment Local Population

Odour, PM 10 Local Residentsand aerosols

withSafety

Noise Survey includedin Section 3.6

ComplianceHealth &LegislationWell establishedexisting entrance withno queue delays. TIAincluded in Section3.7.Local Authority hasprovided adequateservices such as foul,sewerage and mainswaterCompliance with EPALicence will ensurethat controls aremaintained.Compliance withHealth and Safetylegislation

The proposed willrequire two additionalpersonal to operate.See Volume 3:Appendix 3.1 forOdour Model

Low

Low

Low

Low

Low

Certain

Remote

Indoorprocessing &bufferedmachineryPersonalProtectionEquipment (PPE)Adequate sitelines at entrance

Containment & LowExtraction

Specific controlmeasures,procedures andbaiting.OperationalProcedures andfirewaterretentionPositive Impact

Existing site withestablishedservices

Local Residents

Local Residents

Site WorkersNoise

Noise

Traffic

Fire Hazard Site Workers &Local Residents

In consideration of the factors detailed above and providing that the mitigation measuresare enforced by DEL and the regulatory agencies such as EPA, HAS and SOCC, theenvironmental nuisance posed by the development are low and are consideredacceptable.


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3.2 Water

TOBIN Consulting Engineers were appointed by Oxigen Environmental Ltd. to preparethe Water Section of an Environmental Impact Statement (EIS) to address the proposedextension to the Oxigen facility based at Ballymount, Dublin 22.

The site of the proposed development of a 4218 m2 processing building on 8960 m2

(0.89 hectares) of undeveloped land as shown on Drawing No 5993-2000. The site iscurrently used to store large skips.

The facility is part of the overall Ballymount Industrial Estate and is surrounded on allfour sides by commercial/industrial units. Three roads border the site, the TurnpikeRoad, the other two roads are unnamed internal estate roads. The main entrance to thesite is located to the northeast of the facility off one of the internal estate roads.

TOBIN Consulting Engineers have prepared this section of the EIS, which assesses theimpact of the proposed development on the water environment during the constructionand operational phases of the proposed facility expansion. Mitigation measures are alsodiscussed to prevent any possible sources of pollution from each phase.

3.2.1 Study MethodologyThis report has been prepared using the recommendations set out in the EnvironmentalProtection Agency (EPA) document 'Guidelines on Information to be contained inEnvironmental Impact Statements' (2002).

This section describes the hydrological and hydrogeological setting of the site and refersto the information available from a number of published sources.

The information contained in this section has been divided into sub-sections, so as todescribe the various aspects pertaining to the water environment. In the preparation ofthis section the following protocols were used in order to assess the hydrological andhydrogeological context and character of the site:

• The site was assessed using published information and regional hydrologicaldata;

• All available information was collected from the Environmental Protection Agencywith respect to historical water quality in this region;

• All available information from the Geological Survey of Ireland was assessed andcollated;

• Site specific information with respect to the existing services; and,• This Water Report (Surface Water, Groundwater, Water supply and Wastewater)

was prepared following the interrogation and collation of all available information.

The characterisation of the site is considered detailed and sufficient to adequatelycharacterise the hydrological and hydrogeological setting of the site.

All projects and developments that require an EIS are of a scale or nature that they havethe potential to have an impact on the environment. It is therefore crucial that the

OXigen Environmental Ltd. Ballymount Pre-Treatment Facility Volume 2: Section 3

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. significance of the potential impact is determined. In this section the potential impact onthe surface water environment resulting from the construction of the waste facilityextension at the proposed site is assessed and appropriate mitigation measures aresubmitted.

The site of the proposed development is located at Merrywell Industrial Estate, CoDublin. The Ballymount integrated waste facility and proposed extension is located in adesignated industrial area and is surrounded by industrial premises and infrastructure.

The total site area is 5.3 hectares and the proposed extension area makes up 0.89hectares of this area within the site boundary. The topographic elevation of the siteranges from approximately 58mOD in the east to approximately 62mOD in the southwestof the site. The site slope falls towards the northeast.

The site is located in the Lower Liffey Catchment [Hydrometric Area 09], within theEastern River Basin District (ERBD). The Robinhood stream (EPA Ref: 09-1252) isculverted through Merrywell Industrial Estate and flows in an easterly direction along thenorthern site boundary. This Robinhood stream (EPA Ref: 09-1252) is a tributary of theCamac River, which lies approximately 1.2km northeast of the facility. The Camac Riverflows in a general northeast direction before its confluence with the River Liffey atVictoria Key.

3.2.2 The Existing EnvironmentSurface Water QualitySurface water samples have been undertaken at the existing Ballymount Facility as partof Waste license W0208-01. A surface water monitoring schedule has been assigned tothe facility in Waste Licence W0208-01. A full data set for surface water monitoring asper Waste Licence W0208-01 is available in Volume 3: Appendix 3.2.1

Surface water samples were obtained from the surface water discharge point (EPA Ref:09-1252), along the eastern site boundary.

Concentrations for pH, Electrical Conductivity, Temperature and COD are all belowsuggested limit levels. Mineral Oil concentrations were below the laboratory detectionlimit «1 Omg/I) during all monitoring events in 2009.

Oxigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2. Section 3

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Figure 3,2,2,1 - River Id's and Locations

Suspended solid concentrations varied at the Ballymount facility during the 2008 and2009 monitoring events. During 2008 suspended solid concentrations varied at SW1,ranging from a low of 4.4mg/1 in 03 to a high of 214mg/1 in 04. Concentrations continuedto vary in 2009 with the concentrations ranging from a high of 119mg/1 in 01 to a low of11 mg/I in 03.

Biotic Indices (0 values)The EPA monitors the quality of Ireland's surface waters and assesses the quality ofwatercourses in terms of 4 no. quality categories; 'unpolluted', 'slightly polluted','moderately polluted', and 'seriously polluted'. These water quality categories and the

........ '··••11·••

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Oxigen Environmental Ltd. Ballymount Pre-Treatment Facility Volume 2 Section 3

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. water quality monitoring programme are described in the EPA publication 'Water Qualityin Ireland, 1998-2000'.

The water quality assessments are largely based on biological surveys. BiologicalQuality Ratings or Biotic Indices (Q values) ranging from Q1 to Q5 are defined as part ofthe biological river quality classification system. The relationship of these indices to thewater quality classes defined above, are set out in Table 3.2.1

d W t Q rt CIBO f I dOhO

b ta e ° 0 ° e a Ions IP e ween 10lC n Ices an a er ua Ity assesr.iO:l

1iE~..:l ~

Q5, 4-5, 4 Unpolluted Class AQ3-4 Slightly Polluted Class BQ3,2-3 Moderately Polluted Class CQ2, 1-2, 1 Seriously Polluted Class D

T bl 3221 R I f

The relevant water quality monitoring stations are located on the Camac River (at'Riversdale Estate Bridge' and 'Camac Close Emmet Road'. Biological Quality ratingsand other details are given in Table 3.2.2 No river water monitoring data was availablefor the Robinhood stream (EPA Ref: 09-1252) that transects the site.

The Riversdale Estate Bridge (Station Code: 09C020500) conferred a Q3 status on theCamac River upstream of the facility. The Camac Close - Emmet Road (Station Code:09C020500) downstream of the Ballymount and Robinhood industrial estates reported ariver water quality value of Q2-3.

° ht EPARO

d t f Ce ° 0 ° summary a a or amac Iver, copyng

j,

Riversdale09C020310 Q3 Q3

Estate Bridge -

Camac Close09C020500 Q2 Q2 Q2-Q3

Emmet Road

Tabl 3 2 2 2 EPA

The EPA Water Quality Database indicates that the biotic water quality in the CamacRiver upstream of the facility at 'Riversdale Estate Bridge' remained constant with avalue of Q3 - Moderately Polluted. The Biotic water quality downstream of the subjectsite at 'Comac Close Emmet Road' improved slightly between 2005 and 2008, to astatus of Q2-Q3 - moderately polluted.

Under the Water Framework Directive, the Camac River and tributaries are classed as'1a', i.e., at risk of failing to meet 'good status' by 2015 (See Volume 3: Appendix 3.2.2).The principle pressures on the Camac River are urban sources of point and diffusepollution and channelisation/modification of the Camac River and its tributaries.

Hydrometric DataRelatively recent flooding (2000) was reported and documented for the Camac River at'Camac Culvert' at the 'Old Naas Road' approximately 2km downstream of the proposedBallymount facility. This was due to problems associated with the structural integrity ofthe culvert (www.floodmaps.ie;).

OXigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2: Section 3

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Flooding was also recorded on the unnamed stream (EPA Ref: 09-1243), which isapproximately 1km from the Ballymount facility. This unnamed stream (EPA Ref: 091243) merges with the Robinhood stream (EPA Ref: 09-1252) to form the unnamedstream (EPA Ref: 09-1242). Surface water volumes in the unnamed stream (EPA Ref:09-1243) are independent of activities at the Ballymount facility. The confluence of theunnamed streams (EPA Ref: 09-1243 and 09-1252) is downstream of the recorded floodevent and approximately 1.2km from the Ballymount facility.

The subject site is located adjacent to the culverted Robinhood stream (EPA Ref: 091252) but is not located within a flood plain.

aUGENEilMIlI)/IIAENTlllTO

B.l.llYlolOONTt.lI.Tm_LSRtOOIEIff

F.CllITY

FlOOD W-P

Figure 3.2.2.2 - Flood Map


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GroundwaterRegional Details were identified from the following resources:

~ The EPA (http://maps.epa.ie/internetmapviewer/mapviewer.aspx)~ The Geological Survey of Ireland (http://www.gsi.ie).

The main points are as follows:

1. There are no proposed discharges to groundwater from the site2. The site is located in the in the Eastern River Basin District (ERBD).3. The aquifer is categorised as a Locally Important - Bedrock that is moderately

productive except in local zones (LI).4. The Groundwater Vulnerability within the site boundary is categorised as H

'High'.5. There are no source protection zones delineated by the GSI in the vicinity of the

subject site.6. The draft groundwater WFD status is considered as 1a - 'At risk of not achieving

good status' (www.wfdireland.ie).

Aquifer Classification and Flow TypeThe aquifer is categorised as a Locally Important Aquifer - Bedrock that is moderatelyproductive only in local zones (LI) (DoEHLG/EPAlGSI, 1999).

Groundwater VulnerabilityGroundwater Vulnerability guidelines are given in Table 3.2.3. Groundwater vulnerabilityis a term used to represent the intrinsic geological and hydrogeological characteristicsthat determine the ease with which groundwater may be contaminated by humanactivities. The vulnerability category is based on the relative ease with which infiltratingwater and potential contaminants may reach groundwater in a vertical or sub-verticaldirection. The permeability and thickness of the subsoil, which influence the attenuationcapacity of subsoil, are important aspects in determining the vulnerability ofgroundwater.

IlydrogeologkaJ Conditions-~~._.__._. I ·n.'ilturate

I ZoneT--------·-I---·---

Lu"", pcnn~~ahiljty i ~~·and:'g[<:l\'el

l L'.d!. Cla~"y .:iub~(lil. I ~ quif~ .day. pca' ~ i onl~)

r ill'sf

Feature.

«30mr~lL1iu~)

Table 3.2.2.3 Groundwater Vulnerability Guidelines (DoEHLG, EPA, GSI (1999))

According to the available sources, the groundwater vulnerability underlying theproposed extension is categorised as 'High'.


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There are no boreholes installed on the site for groundwater monitoring as there are noproposed or existing discharges to grounder at the site. There will be no discharge toground from the facility as all surface water runoff is directed to the surface waternetwork and all foul water is discharged to a South Dublin County Council seweradjacent to the site. Therefore there will be no impact from the proposed developmenton groundwater quality.

Resource Protection Zones

From the Groundwater Protection Schemes (DoEHLG, EPA and GSI, 1999), acombination of aquifer classification and vulnerability rating give rise to the resourceprotection zones (RPZ). The purpose of these zones is to place a control on the activitiespractised within a zone and thus provide protection to any underlying groundwaterresources. Therefore the RPZ for the subject site is PI/M (Poor aquifer with moderatevulnerability). There is no source protection zone delineated in the vicinity of the site.

Groundwater QualityThere is no requirement in Waste Licence W0208-01 for groundwater sampling as thereare no discharges to groundwater. As there are no proposed discharges to ground it isenvisaged that there will be no requirement for groundwater monitoring.

Groundwater Flow DirectionThe groundwater flow direction is based on an assessment of the drainage patterns, theaquifer flow type and the assumption that the water table is generally a subduedreflection of the topographic surface. There is no on site boreholes to assess the watertable height and slope. As groundwater flow paths are generally a subdued reflection ofthe surface water drainage pattern it is assumed that the general groundwater flow pathfollows the site slope and Robinhood stream (EPA Ref: 09-12.52) in a general northeastdirection towards the Camac River.

GSI Well and Karst DataA GSI well search was conducted within 1km radius of the site. 3 no. wells are locatedapproximately 0.9km north of the development. These GSI referenced wells are forindustrial use and have a yield value of moderate to good.

No known karst feature is recorded in the GSI karst databases within a 10 km radiussearch of the site.

Water Supply

The water usage at the site is considered low. The Ballymount facility is connected to thelocal water mains and uses this as a source of water for the facility. There is an existing4" uPVC watermain circulating the existing Oxigen building and a 110mm PVC-Awatermain circulating the adjacent processing plant owned by Dublin City Council.

This water is used for washing trailers, equipment and floors. No water is used in theprocess as the incoming material contains excess moisture.


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. Wastewater Treatment

Wastewater from the facilities operations is discharged to a South Dublin County CouncilSewer. An existing 150mm dia. foul sewer that serves the existing oxygen building.

Limits to sewer as per Waste Licence W0208-01 are set out in Table 3.2.2.3 below.

Table 3 2 2 3 EPA waste license Effluent Limits

DIscharge lImIts are set to 15m per day and 5m per hour.

...

1@e)rr' n~~[hrru

Temperature °C 42pH pH

6 -10Units

BOD mg/I 1000COD mg/I 3000Suspended Solids mg/I 1000Sulphates (as S04) mg/I 1000Oils, Fats & Greases mg/I 100Mineral Oils mg/I 10Detergents mg/I 100Zinc mg/I 5Copper mg/I 5

. . .3

3.2.3 Potential Impacts of the Development

Construction PhaseDevelopment of this section of the site will not significantly alter the setting of the site.There will be a slight increase in hardstanding area.

During the construction period, little potential exists for discharge of sediment-ladenwater from the site. Any sediment-laden water generated due to exposure of soilsurfaces will be contained within the site boundary, as there is an earth berm at the siteboundary. Alternatively, surface water runoff can discharge through the existing sitedrainage system where it will pass through a grit trap/oil interceptor prior to discharge.

Operational PhaseThe construction of the hardstanding will slightly alter the current hydrological setting ofthe site, whereby overland surface water runoff may potentially increase. This generationof increased runoff, as a result of the slight increase in hardstanding area, is a direct andlong-term impact of the development. Without mitigation measures the magnitude of thisancillary development is considered 'moderate'.

Appropriate mitigation measures are proposed to ensure that discharges from the siteare managed and regulated, to reduce/eliminate the potential impact of increase runoff.Mitigation measures in accordance with the recommendations of the Greater DublinStrategic Drainage Study (GDSDS). To this end the design of the surface waterdrainage system takes into account the recommendations of the GDSDS and utilisesSUDS devices where appropriate.


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Surface water runoff from hardstand areas has the potential to absorb potentialcontaminants from surfaces, i.e. spillages or leakages from vehicles, machinery, etc. Therunoff could also be heavily sediment laden. Discharge of such runoff to receivingwatercourses has the potential to adversely impact on water quality. This is a directpotential impact of the development, however the potential magnitude from thisproposed development is considered 'moderate'. Appropriate mitigation measures suchas attenuation tanks, grit traps and hydrocarbon interceptors are proposed to ensure thatsurface waters are protected against accidental discharges to the drainage network.

The generation of some additional runoff is a direct, long-term effect but if appropriatemitigation measures are incorporated, there is not considered to be a negative impact.

The waste to be handled within the facility will not come into contact with rainfall. Thefloor of the facility will be cleaned regularly. The facility is designed so that any runofffrom incoming material will be captured within the building.

Diesel tanks on site would have the potential to cause groundwater contamination due toaccidental leakages. The correct design of bunded areas for the storage of Diesel tankswill be used to prevent groundwater contamination as a result of accidental spillagesfrom the Waste Facility.

GroundwaterAccording to the GSI 3 No. wells are recorded within 1 km of the site. It is not envisagedthat the implementation of the proposed development will have any adverse impact onthese groundwater resources.

The proposed development would have a potential to cause groundwater contaminationfrom leakages from the wastewater collection and disposal systems and from vehicularfuel spillages or leakages on roads and car parking areas. The natural depth ofoverburden at the site affords a 'high' vulnerability to potential contamination sources.However, the existing surface water and wastewater disposal systems on site are built inaccordance with best practice and will prevent the occurrence of contaminated leakageor runoff from the site.

In summary the potential impact on the surface water and groundwater environment isassessed as 'low'.

3.2.4 Remedial or Mitigation Measures

Construction Phase

All site works will be conducted in an environmentally responsible manner so as tominimise any adverse impacts on the soils and water, which may occur as a result ofworks associated with the construction phase.

With regard to on site storage facilities and activities, any raw materials, fuels andchemicals, will be stored within structurally sound warehousing buildings and/or bunded


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. areas if appropriate to guard against potential accidental spills or leakages. Allequipment and machinery will have regular checking for leakages and quality ofperformance.

Appropriate measures are already in place prior to the construction phase to ensure that anypotential run off is diverted through the existing site settlement tanks and grit traps.

Operational PhaseThe design of the proposed development has taken into account the potential impactsassociated with the construction and operation of the development on the waterenvironment.

Surface waterSurafce water runoff and attenuation will comply with the recommendation of theGDSDS. In this instance it is proposed to reduce the quantity of run off from the site byincorporating an underground storage tank. The peak surface water discharge will belimited to the greenfield runoff rate, via the installation of a flow control device(hydrobrake or similar approved) and purpose built attenuation structure (Stormtech orsimilar approved), all located north of the proposed building.

The layout of the site has been designed for collection of surface water runoff from theroof and roadways, within the site for subsequent discharge to the existing 225mm~

storm sewer located to the east of the site.

The attenuation calculations required for 30yr and 100 yr return periods are shown inEngineers services report. The layout of the site drainage system has been designed forcollection of surface water from roadways, paths and roofs within the development.

In terms of surface water runoff, in order to prevent potential contamination of soil,surface water or groundwater media with water that may be contaminated with oil/solids,an appropriately sized hydrocarbon interceptor and grit trap is installed at the outfall fromthe surface water collection systems prior to discharge. A petrol interceptor will beprovided for interception of the first 5mm of rainfall from the surrounding yard asrecommended in the GDSDS. Secondly an isolator row surrounded with wovengeotextile, will enhance total suspended solids removal.

GroundwaterThe correct design, construction and maintenance of wastewater collection and disposalsystems will be used to prevent groundwater contamination.

Water SupplyWithin the proposed development, a water supply will be required for washing down ofthe facility. It is proposed to provide a 100mm dia. spur from the existing 110mmwatermain to service the proposed unit. The connection will be metered and the metershall be compatible with South Dublin County Council's AMR system

It is proposed to connect a 150mm 0 fire main to the 6" CI water main on the BallymountRoad Lower. This will be used comply with fire requirements and regulations only. This150mm 0 main will fully loop the proposed building and a non mechanical flow meter isto be provided at the connection in accordance with the requirements of the SDCCWater Division.

Oxigen Environmental Ltd. Ballymount Pre-Treatment Facility Volume 2' Section 3

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The watermain layout and specification to be in accordance with the BuildingRegulations TGD B & Specifications for the Laying of Water Mains and Drinking WaterSupply (Nov 2009). The water main layout including location of valves, hydrants, etc areshown on Drawing No's. 5993-2003.

WastewaterThere is an existing 150mm dia. foul sewer that serves the existing oxygen building. It isproposed to discharge wastewater from washing down of the facility to this foul sewerfurther downstream at an existing manhole within the development where there issufficient cover. A grease trap will be provided in accordance with the requirements forthe Greater Dublin Regional Code of Practice for Drainage Works.

The proposed foul water network; showing outfall, pipe sizes, gradients, manholelocations, and direction of flow are shown on drawing no's 5993-2001 with long sectionshown on Drawing No 5993-2002.

Residual Impacts

Construction PhaseDuring the construction period, significant potential does not exist for fugitive dischargeof sediment-laden water from the site. Any sediment-laden water generated due toexposure to soil surfaces will either be attenuated within the site boundaries earthenberm or within the existing surface water drainage system. During this attenuation periodsuspended materials will be allowed fall out of suspension prior to discharge to thesurface water network. With the incorporation of these remedial measures the predictedimpact of the construction phase on surface water quality is minimal.

Operational PhaseThe construction of the new facility and ancillary hardstanding will alter the naturalhydrological setting of the site, whereby overland surface run-off will be increased andnatural runoff flow paths disrupted. This generation of increased runoff from the facility isa direct and long-term impact. Without mitigation measures the magnitude of this impactis considered 'Low'.

If the remedial and reductive measures set out above failed, uncontrolled stormdischarges from the proposed increased hardstanding area of the site would result inshort pulses of high water volumes to the stormwater water network. However, bestpractice drainage design and the full implementation of proposed remedial and reductivemeasures will ensure that such a scenario will not arise.

Monitoring

During the works undertaken at the outset of the project, strict monitoring of all potentialpolluting materials used will be maintained. Current monitoring as per Waste LicenceW0208-01 will continue at the facility. The existing discharge point to surface water willremain in use and runoff from the proposed development will discharge at this locationalso. Any monitoring from this point will be representative of water quality from theexisting facility and proposed development. The attenuation tank, outflow control systemand oil interceptor will require periodic maintenance.


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. Reinstatement

Subject to the development of the site in line with the proposed plans, there is no scopefor reinstatement. The site will be permanently altered as a result of the development.

The proposed development will have no noticeable impact on the surrounding waterenvironment; therefore there will be no short to long-term impacts outside the siteboundary.


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EnVJronmentallmpact Statement

3.3 Human Beings

3.3.1 Introduction

Human beings are one of the most important elements of the 'environment' to beconsidered. One of the principle concerns in any proposed development is that the localpopulation experiences no reduction in the quality of life as a result of the developmenton either a permanent or temporary basis. All the effects of a development on theenvironment may impinge upon human beings. Any significant impact on the status ofhumans that may be potentially caused by a proposed development must, therefore, becomprehensively addressed. Air quality, water quality, noise and landscape impactdirectly while flora, fauna, and traffic impact indirectly.

3.3.2 The Existing Environment

The proposed development is located within the existing site facility in the MerrywellIndustrial Estate located in Ballymount to the south west of Dublin. The Industrial Estateconsists of several similar land uses to the subject site with Dublin City Council operatinga waste processing and recycling facility on the adjoining premises and Premier WasteLtd operating across the road.

The nearest dwelling house is located approximately 180 meters from the site onTurnpike Road; however it is not visible from the residences due to the numerous otherindustrial premises located between the residential dwellings and the proposeddevelopment site. The subject site also has a lower ground level then the adjoiningTurnpike Road and is screened by earth mounding and planting.


The proposed development will be operated under licence in accordance with the WasteManagement (Licensing) Regulations, 2004 (S.I No. 395/2004) as amended, whichderive from the Waste Management Act, 1996 which was amended by the Protection ofthe Environment Act, 2003. Section 32(1) of the Act states that 'A person shall not holdtransport, recover or dispose of waste in a manner which causes or is likely to causeenvironmental pollution'. Environmental pollution is defined to include 'nuisance throughnoise, odours or litter' and therefore has a bearing on emission to air.

Noise is an identified form of air pollution and uncontrolled it can cause nuisance ordeterioration of amenities. The potential impact of the proposed development on noiselevels in the area is described in Section 3.6. Noise. Baseline Noise measurements areincluded in that section.

Noise levels will increase in the immediate vicinity of the site during the constructionperiod. However the short-term construction period required for the proposeddevelopment minimizes the risk of any health effects. In summary due to existingbackground noise levels caused primarily by the surrounding road network, noise levels


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from on-site activities resulting from the proposed development will not significantlyincrease ambient noise levels. In particular noise levels at the nearest sensitivelocations (i.e. occupied residences) will not significantly deviate from the currentbackground daytime noise levels. Any noise sensitive location is more likely to beimpacted by closer and larger industrial activities to it than by the proposeddevelopment.

TOBIN Consulting Engineers Ltd carried out a traffic impact assessment in order toassess the potential impacts from additional traffic movements resulting from theproposed development and the impact the proposed development will have on theexisting road network. (Section 3.5 Traffic). To establish baseline data, traffic countswere carried out on Wednesday the 3rd of March 2010 at the following junctions:

• Ballymount Cross Roundabout• Priority Entrance to the Existing Facility• Priority Junction between Turnpike Road and an Internal Access Road

Full details of these traffic counts are available in Volume 3: Appendix 3.5. The trafficimpact assessment concluded that the proposed development will constitute less than5°,10 of traffic at the junctions affected, which is considered a negligible impact

Fire Safety

Prior to commencement of operations a fire safety audit of the site will be undertaken todetermine the fire extinguishing requirements of the site. The recommendations of thisreport shall be implemented within the site. In addition to these recommendations therewill be two fire extinguishers located at each door of the waste buildings, namely powderand foam. All staff on site are trained in fire prevention, fighting and evacuation. Fireprevention measures to be implemented shall include;

• The provision of appropriate fire extinguishers as recommended by a specialistsupplier to deal with types of fire sources that may be encountered on site.Regular inspections will be carried out and any missing, damaged, defective orout of date appliances replaced as a priority.

• Provision of sand bunkers at appropriate locations for use in dousing fires• Provision of 1500 gallon water bowser and pump for initial dousing/containment

of fires.• Fire suppression equipment on machines is to be checked daily by the driver

operator and any faults reported.• Training of employees in the correct selection and use of fire extinguishing media

for the range of types of fire incidents that may be encountered on site.• The enforcement of a strict no smoking policy on site except in the designated

smoking shelter.• The enforcement of no fires/burning on site.• A contract for maintenance of fire equipment with specialist suppliers.• A maintenance and defect reporting system for all portable and fixed plant and

for all electrical appliances.

Oxigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2- Section 3

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• Training of evacuation procedures and the identification of the location ofassembly points

It is also proposed to connect a 150mm 0 fire main to the 6" CI water main on theBallymount Road Lower. This will be used comply with fire requirements and regulationsonly. This 150mm 0 main will fully loop the proposed building and a non mechanicalflow meter is to be provided at the connection in accordance with the requirements of theSDCC Water Division.

The water main layout and specification to be in accordance with the BuildingRegulations TGD B & Specifications for the Laying of Water Mains and Drinking WaterSupply (Nov 2009). The water main layout including location of valves, hydrants, etc areshown on Drawing No's. 5993-2003.

Human health

A variety of air pollutants have known or suspected harmful effects on human healthand the environment. In many similar developments these pollutants are principally theproducts of combustion from power generations or from motor vehicle traffic. Theprimary potential air pollutants derived from the proposed developments are detailedfurther in section 3.6.

Primary pollutants derived from traffic includes the following; sulphur dioxide (S02),particulate matter, lead, oxides of nitrogen (NOx), carbon dioxide (C02) and volatileorganic compounds (VOC's).

The objective of air pollution control is to prevent adverse responses to all receptorcategories (human, animal, plant) exposed to the atmosphere. The adverse responseshave characteristics response times- short term (seconds or minutes), intermediate term(hours or days) and long term (months or years). Pollutants such as nitrogen dioxide(N02), sulphur dioxide (S02) and carbon monoxide (CO) can have potential healthimpacts. N02 is a respiratory irritant, which may exacerbate asthma and possiblyincrease susceptibility to infections. CO reduces the capacity of blood to carry oxygenaround the body at levels >9.9mg/m3 (8 hour average) and this may increase the risk ofproblems in those with angina and disease of the coronary arteries. At high levels, S02is a strong irritant to the eyes and mucous membranes, producing narrowing of theairways and stimulating coughing. While the effects are generally transient and easilyreversible in healthy people, the consequences can be more serious for people whosuffer from weakened cardio-respiratory systems.

The future contributions of sulphur dioxide and the oxides of nitrogen associated withthe increased traffic movements due to the proposed development will be within therecommended limit values at the nearest sensitive receptor and it is unlikely that theywill have adverse human impacts at that point. Predicted levels of VOC's, PM 1O, andcarbon monoxide are also within the recommended limit values (See Section 3.6: Air).Predicted concentration levels indicate that air pollutants will increase marginally due totraffic movements from the proposed development. However, any such increase is notconsidered significant and will be well within relevant ambient air quality standards.

Oxigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2' Section 3

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. Land Use

Any potential impacts from the proposed additional processing building for municipalwaste on the existing land uses of the area are not considered significant. The subjectsite has been operating as a waste management facility since 2004. Oxigen are notproposing any alterations to the existing land use on site but are simply proposing toextend their existing operations. Several other waste management facilities are locatedin the vicinity of the subject site and the predominately surrounding land use is one oflight industry and warehousing. The landscape of the area will not change as a result ofthe proposal and the existing topography will remain as low lying land in an urbanindustrialised setting.

The site itself is well screened due to having a lower ground level then the adjoiningTurnpike and Ballymount Road's. The proposed additional building will have a ridgeheight and eaves height to match the existing buildings on site so as to minimise thevisual impact.

Following cessation of the waste recycling and processing facility, site restoration willcommence in line with the aftercare management plan specific to the site and inaccordance with the waste license conditions. As a result of the above measures theimpact of the purposed development on the land use character of the area is consideredminimal.

Odour from the proposed development has the potential to cause the greatest impact toHuman Beings. Therefore a number of steps have been taken by Oxigen in the design ofthe proposed development to prevent any impact to Human Beings from Odour. It isproposed to extract odorous air from the new building using a negative air system and totreat the air through bag and carbon filtration. Other measures include roller doors andgood housekeeping to reduce the risk of fugitive emissions.

A desktop assessment of the potential odour impact from the proposed extension tooperations at the Oxigen facility in Ballymount was carried out by RPS using advanceddispersion model techniques (Volume 3: Appendix 3.1). The model predicts that theemissions from the proposed stack will not give rise to reasonable cause for odournuisance at the nearest sensitive receptors once it is operated to the design parameters.

Socio-Economic

It is considered that the proposed development will have a very limited direct social andeconomic effect. The proposed is unlikely to stimulate additional development in thearea and will not reduce the potential for the expansion of economic activities in thearea. Therefore the proposed will have a minimal impact on the existing populationstructure of the area. The proposed changes are also in keeping with existing andproposed land use patterns.

However it is perhaps the indirect impacts that will benefit the local and regionalcommunity the most. The additional services provided by the processing facility will notonly benefit the public but will increase the recovery potential of waste that wouldnormally be directed to landfill.


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The development of the building for pre-treating municipal waste will not impact on theeconomic activities currently taking place in the surrounding area and it is estimated thatonce operational the proposed will require only 2 additional staff members.


Waste facilities such as the proposed can impact on human health if uncontrolled. Thefollowing Table 3.3.3 presents the potential impact on human health from the proposeddevelopment, the mitigation measures proposed by the developer and the resulting riskassessment.

Table 3.3.4 Risk Assessment: Potential Impact on Human Health from ProposedDevelopment

Noise Local Residents Indoor Low Noise Survey includedprocessing & in Section 3.7bufferedmachinery

Noise Site Workers Personal Low Compliance withProtection Health & SafetyEquipment (PPE) Legislation

Traffic Local Residents Adequate site Low Well establishedlines at entrance existing entrance with

no queue delays. TIAincluded in Volume 3:Appendix 3.5

Air Pollutants Site Workers & Containment & Low Compliance with EPALocal Residents Extraction Licence will ensure

that controls aremaintained.

Fire Hazard Site Workers & Operational Low Compliance withLocal Residents Procedures and Health and Safety

firewater legislationretention

Employment Local Popu lation Positive Impact Certain The proposed willrequire two additionalpersonal to operate.

Odour Local Residents Containment & Low See Volume 3:Extraction Appendix 3.1 for

Odour Model

In consideration of the factors detailed above and providing that the mitigation measuresare enforced by DEL and the regulatory agencies such as EPA, HAS and SOCC, therisks to human health posed by the development are low and are considered acceptable.


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. 3.4 Air Quality

3.4.1 Introduction

This chapter examines the potential for the proposed development to impact upon airquality within the vicinity of the subject site. The chapter describes the current baselineconditions at the site using existing monitoring data carried out in compliance with theconditions of the Waste Licence. A further baseline air quality survey was carried out inJuly 2009 by BHP Laboratories to include parameters that are not regularly tested onsite (please see Volume 3: Appendix 3.4.1 for a copy of the report). This chapter alsodescribes the assessment methodology, the likely significant environmental effects, themitigation measures required to prevent, reduce or offset any significant adverse affectsafter these measures have been employed. It has been written with regard to currentadvice notes from the EPA for preparation of an Air Quality Chapter in an EIS.

In 1996, the Environment Council adopted the Framework Directive 96/62/EC onAmbient Air Quality Assessment and Management (AAQ&M). The Directive sets ageneral policy framework for dealing with air ambient quality. Instead of looking first atthe sources of the pollution, the Directive looks at the effects of the air pollution onhuman health and environments, and then shifts the focus to those sources thatcontribute the most to the effects. The main objectives of the Air Quality FrameworkDirective are:

• Sets out an EU-wide system for setting binding air quality objectives for specificpollutants to protect human health and environment;

• Requires Member States to put in place systems for assessing the quality of theambient air based upon common methods and criteria;

• Requires Member States to maintain ambient air quality where it is good andimprove it in other cases, by means of plans and programmes of action and

• Lays down provisions for a system of gathering, reporting and publicizinginformation. This includes both data to be reported to the European Commissionand information to be disseminated to the public.

The Directive was incorporated into the EPA Act, 1992 (AAQ & M) Regulations, 1999(S.1. No. 33 of 1999) and it covers the revision of previously existing legislation and theintroduction of new air quality standards for previously unregulated air pollutants, settingthe timetable for the development of daughter directives on a range of pollutants.

The Directive deals with each EU member state in terms of "Zones" and"Agglomerations". For Ireland, four zones are defined in the Air Quality Regulations(2002), amended by the Arsenic, Cadmium, Mercury, Nickel and Polycyclic AromaticHydrocarbons in Ambient Air Regulations (2009).

The main areas defined in each zone are:

• Zone A: Dublin Conurbation• Zone B: Cork Conurbation• Zone C: Other cities and large towns comprising Galway, Limerick, Waterford,

Clonmel, Kilkenny, Sligo, Drogheda, Wexford, Athlone, Ennis, Bray, Naas,


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Carlow, Tralee, Dundalk, Navan, Letterkenny, Celbridge, Newbridge, Mullingarand Balbriggan.

• Zone D: Rural Ireland, i.e. the remainder of the State excluding Zones A, BandC.

Air Quality for Zone A is currently classified as good. The index is calculated by theEPA at their numerous monitoring stations around the city and is based on the latestavailable measurements of ozone, nitrogen dioxide, PM10 and sulphur dioxide in ZoneA.

Daughter directives of the Act set limits for specific pollutants. The first two of thedirectives cover: Sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulatematter and lead, carbon monoxide and benzene. These two directives became Irish Lawas the Air Quality Standards Regulations 2002 (SI No. 271/2002). The regulations;

• Establish limit values and as appropriate, alert thresholds for concentrations ofcertain pollutants in ambient air intended to avoid, prevent or reduce harmfuleffects on human health and the environment as a whole;

• Provide for the assessment of concentrations of certain pollutants in ambient airon the basis of methods and criteria common to the Member states of the EU;

• Provide for the obtaining of adequate information on concentrations of certainpollutants in ambient air and ensure that it is made available to the public, interalia by means of alert thresholds and;

• Provide for the maintenance of ambient air quality where it is good and theimprovement of ambient air quality in other cases with respect to certainpollutants.

These daughter directives set down limit values for Sulphur Dioxide, Nitrogen Dioxide,Oxides of Nitrogen and Benzene as follows;

Table 3.4.1: Limit Values from Directive 19999/30/EC & Directive 2000/69/EC

Averaging peri""d Lin-u t Value

Hourly limit value fd the] How' ~OO. g/mJ NO.:! 3:;0 !J.g/mJ SO.:!pro te..:tio n f ll11ml~ 11 he al th

AnnuLll limit illue for lheCalcndtlJ year 40 g1mJ N02 5 j.lglmJ B~nze.neprotection "'\f lmmrUl health

Dajl~, limit.., alue for the24 hoW" - l25 . gim3 SO.:!prote..:tiol1 f human he aJth

An I'lU al limi t v'llue t or tl~ ('tllend .U· ye.U" 30 u~"nl NO, 20jJglm,) SO.:!protection of vegetation

Two more daughter directives deal with:

• Ozone (in Irish law as the Ozone in Ambient Air Regulations 2004)

Oxigen Environmental Ltd. Ballymount Pre-Treatment Facility Volume 2. Section 3

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• Polyaromatic hydrocarbons, arsenic, nickel, cadmium and mercury in ambient air(in Irish law as the Arsenic, Cadmium, Mercury, Nickel and Polycyclic AromaticHydrocarbons in Ambient Air Regulations 2009)

The Clean Air For Europe (CAFE) Directive was published in May 2008. When it entersinto force it will replace the Framework Directive and the first, second and third DaughterDirectives. The fourth Daughter Directive will be included in CAFE at a later stage.

The primary national legislation for the control of air pollution is the Air Pollution Act,1987 (Sl No. 6/1987). This act provides a comprehensive statutory framework for thecontrol of air quality by local authorities, specifically through 'orders' or 'plans' producedunder Part IV Special Control Areas and Part V of Air Quality Management Plans andStandards to which Local Authorities must have regard to in planning or Waste Licencedecisions. Part V of the Act also makes provision for transposing Air Quality Standardsinto law. The Act refers specifically to potential emissions of dust and or odours insection 24(2) which states 'The occupier of any premises shall not cause or permit anemission from such premises in such a quantity or in such a manner as to be anuisance'.

Traffic derived pollutants (Oxides of Sulphur and Nitrogen, Volatile Organic Compounds,PM1o), odour and the generation of dust are considered the main potential pollutants thatmay impact on the air quality during the construction and operational phases of theproposed development. Of particular importance in the instance of the subject proposalis the potential for the generation of odour and its impact on the air quality of thesurrounding area.


Dust & PM10

Dust is defined as particulate matter in the range 1-75I1m. The particles of dust between1 and 10 11m are known as particulate matter <10 11m or 'suspended particles'.Particulate matter varies widely in its physical and chemical composition, source andparticle size. Particulate matter arises from both man-made and natural sources. Naturalsources include wind blown dust, sea-salt and biological particles such as pollen. Manmade sources include large carbon particles from incomplete combustion, ash, dustparticles from quarrying and construction activities and dust generated from road traffic.In general large particles do not stay in the atmosphere for long and are deposited closeto their source, whereas small particles can be transported long distances. Particles,which are deposited to ground, give rise to problems such as soiling of buildings andother materials and also cause a general nuisance. In general the recommendedguideline value for dust emissions is 350 mg/m2/day.

In accordance with the Waste Licence W0208-01 dust monitoring is carried outbiannually and at least once during the period May to September (See Volume 3:Appendix 3.4.3 for BHP Dust Monitoring Reports, 2009). The limit laid out in the licencefor dust is 350mg/m2/day. BHP Laboratories conduct this sampling for OxigenEnvironmental. An analysis for environmental dust deposition on the site last year isgiven below in Table 3.4.2.1 The sampling was carried out in accordance with VDI 2110


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, Part 2 using Bergerhoff dust deposition gauges (German environmental standard for themonitoring of dust recognized by the EPA) at three locations shown on the Figure3.4.2.1 below. The method works by leaving out onsite dust jars for a period of 30 days.The samples were analysed at BHP's laboratory in accordance with Standard Methodsfor the examination of waste and wastewater, 20th Edition, 1998, published by theAmerican Health Association and as prescribed in the Waste Licence.

\ .....a:....;.'\.

Figure 3.4.2.1 BHP Monitoring Locations at Oxigen Ballymount Facility

B lIymount Facilityf h 0 .RMust onltormg esu ts ort e xigen amg/m2/day 01 02 03Results 1(March '09) 46.1 30.6 9.5Results 2(June' 09) 104.4 252.2 133.3

Table 3.4.2.1: 2009 D

As can be seen from the above table the level of deposition seen at all availablelocations is below the EPA guideline of 350mg/m2/day deposition. All results are withinthe emission limit values as outlined in Waste Licence W0208-01 which indicates thatcurrent dust mitigation measure are effective. In general dust from waste processingactivities on site is contained within the enclosed sheds. The main factors which affectthe potential for airborne dust to be created and dispersed to sensitive receptors beyondthe site boundary are road traffic and traffic on site. Although still within therecommended limits dust levels on site increase in the summer months due to truckmovements along the western portion of the site which is not covered in hard standing.


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Particulate matter with an aerodynamic diameter less than 10 microns is commonlyknown as PM 10.. PM10 arises from direct emissions of primary particulate such as blacksmoke and formation of secondary PM in the atmosphere by reactions of gases such assulphur dioxide and ammonia. The main sources of primary PM1Q are incomplete burningof fossil fuels such as coal, oil and peat and emissions from road traffic, in particulardiesel engines. Other sources of particulates include re-suspended dust from roads.Natural PM includes sea-salt and organic materials such as pollens.

Directive 1999/30/EC (CEC, 1999) established limit values for PM10 levels as follows; thePM 10 daily mean limit of 50 IJg/m3 should not be exceeded more than 35 times percalendar year. The annual mean PM10 limit value is 40 IJg/m3. The table below indicatesthat there has been one exceedance to date in 2010. This table has been included as itis the nearest EPA monitoring location to the subject site.

I Ballyferm ot PM10 0110112010· 3110112010

U9/cU"l• .PM10

100 ...i--------------------

80 ------------------------------------------------------

50 ------------------------------------------------------ceedances permitted before limit is deemed breac ed

40

2: ------.11 11111~~illl- --- ---------- -----03 17 24 31

Figure 3.4.2.2 EPA Results for PM1 0 Levels in Ballyfermot

PM10 was monitored on site as part of the baseline air quality survey carried out by BHPLaboratories. The current Waste License does not require PM 10 monitoring on site. BHPused a calibrated TSI Dust Trak Aerosol Monitor, Model 8530for the purpose. Monitoringoccurred at the three primary monitoring locations shown in Figure 3.41 above. Themonitors were set up to sample PM10 particles, i.e. inhalable dust, by attaching a 10IJrnparticle knock out. As can be seen from Table 3.4.3 below, the concentration levels ofPM 10 dust recorded at all 3 monitoring locations exceed the limit values set down in theAir Quality Directive. However the results are not entirely comparable as the averagingperiod for each of the measurements was typically 15 minutes and thereby different tothe averaging periods expressed in the Directive.


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. Odour

In general odours associated with waste are considered to be unpleasant and if detectedat sensitive receptor locations may potentially lead to loss of amenity. However odour isnot a significant concern at the existing facility as it currently processes 'dry wastes' suchas dry recyclables and Construction & Demolitions wastes which do not typically result ina significant odour nuisance. Subsequently it is not required to carry out specific odourmonitoring as part of the existing licence. An odour management programme, goodmanagement practises, and control over individual procedures, ensures that odour is notan issue on site. Previous BHP assessments of the baseline air quality on site (Volume3: Appendix 3.4.1) have not found any significant odour. The EPA also carries out theirown inspections (Volume 3: Appendix 3.4.2) of the existing facility and to date have notnoted any odour nuisance.

Sulphur Dioxide (S021

Power stations are the principal source of sulphur dioxide (S02) emissions, emitting 56per cent of the total in 2008 according to EPA figures. Reductions in S02 emissionsof 76 per cent from 1990 to 2008 have made significant progress towards achieving theS02 National Emissions Ceiling target. Ireland's national emission ceiling for S02 underthe NEC Directive is 42 kilotonnes (kt) to be achieved by 2010. This is equivalent to a 77per cent reduction from the 1990 baseline level of 182.5 kt S02. In general Ireland ismaking good progress towards achieving the S02 emissions ceiling, with 98 per cent ofthe required reduction from 1990 levels having been achieved by 2008. This reflectssignificant switching from the use of oil and solid fuels to natural gas and reducedsulphur content in coal and oil. The target is expected to be achieved by this year.

Sulphur Dioxide is a corrosive acid gas, which combines with water vapour in theatmosphere to produce acid rain. Sulphur Dioxide was monitored on site as part of thebaseline air quality survey carried out by BHP Laboratories using a Gastec ColourIndicator Tube. This tube has a detection range of 0.05-10ppm. The Limit of Detection is10ppb. Tube indicators change from yellow/green to yellow in the presence of sulphurdioxide. As can be seen from table 3.4.3 below the sulphur dioxide levels present arebelow the hourly, daily and annual limit values expressed in the Directives outlinedabove.

Nitrogen Oxides (NOd

The term oxide of nitrogen refers predominately to nitric oxide (NO) and nitrogen dioxide(N02). These Oxides are formed when nitrogen combines with oxygen at the hightemperatures generated by fossil fuel combustion. Nitric oxide has no colour, odour, ortaste and is non-toxic. In the atmosphere it is rapidly oxidized to nitrogen dioxide byreaction with ozone. Nitrogen dioxide is a reddish-brown gas that has an irritating odour.It absorbs light and contributes to the yellow-brown haze sometimes seen hanging overcities. It is one of the main components of smog. Nitrogen oxides occur both naturallyand from human activities. In nature, they are a result of bacterial processes, biologicalgrowth and decay, lighting, as well as forest and grassland fires. Traffic emissions arethe principal source of anthropogenic nitrogen oxides and is responsible forapproximately half the emissions in Europe ('Ireland's Environment -A MillenniumReport' EPA Apri/2000).

OXigen Environmental Ltd. Ballymount Pre-Treatment Facility Volume 2' Section 3

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. Oxides of nitrogen were monitored on site as part of the baseline air quality surveycarried out by BHP Laboratories using a Gastec Colour Indicator Tube (no. 11 L). Thishas a detection range of 0.04-0.08ppm. The Limit of Detection is 10ppb or 18.8Jlg.m3

.

The tube indicator changes from white to yellow/orange in the presence of oxides ofnitrogen. As can be seen from table 3.4.3 below the sulphur dioxide levels present arebelow the hourly, daily and annual limit values expressed in the Directives outlinedabove.

Volatile Organic Compounds (VOC's)

Volatile organic compounds (VOCs) are emitted as gases from the use of a wide array ofproducts including paints, paint strippers, glues, adhesives and cleaning agents. Severalconstituents of gasoline are important VOCs, which are emitted by combustion andevaporation. VOCs also arise as a product of incomplete combustion of other fuels,especially solid fuels, and as such are significant emissions from residential fuelcombustion. Individual VOCs may give rise to local air quality concerns but the principalenvironmental problem associated with VOC is their contribution to the formation ofground level ozone.

Ireland's national emission ceiling for VOC under the NEC Directive is 55 kilotonnes (kt),to be achieved by 2010. This represents a 32.9 per cent reduction from the 1990baseline level of 81.9 kt.

VOC's are released in vehicle exhaust gases either as unburned fuels or as combustionproducts and are also emitted by the evaporation of solvents and motor fuels. CertainVOC's are important because of the role they play in the photochemical formation ofozone in the atmosphere. The existing Waste Licence does not require specificmonitoring for VOC's largely because there is not an emissions point on site. Thebaseline survey carried out by BHP included VOC's as part of a general assessment ofair quality. They were sampled using coconut shell charcoal sorbent tubes attached to asampling pump at a flow rate of 200 mL/min. The sampling pump flow rate was set usinga film flow meter. 30 minute samples were collected at each sampling point. Sorbentmaterial in the CSC tubes were desorbed in Carbon Disulphide, whereby theconcentrations of organics were determined by GC FID- a non-selective flame ionizationdetector used in conjunction with a Benzene calibration curve. Except for a very feworganic compounds (e.g. carbon monoxide, etc.) the FID detects all carbon containingcompounds. The levels present on site did not show any peak results and thereforefurther sampling was not required.


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tIt f B IIT bl 3 4 2 2 A" M "t" Ra e ... Ir onlormg esu 5 or a Iymoun

Parameter 01 02 03

502 <16.2IlQ/m3 <16.2IlQ/m3 <16.2IlQ/m3

NOx <18.8Ilg/m3 <18.8Ilg/m3 <18.8Ilg/m3

VOCs <5Ilg/m3 <5Ilg/m3 <5IlQ/m3

PM10 721lg/m3 7Ollg/m3 821lQ/m3No significant odour Municipal waste No significant odour

Odour odour


Construction Phase

During this stage of the proposal the main potential impact to air quality will result fromthe generation of dust during the construction phase and the movement of additionaltraffic for construction purposes. However the short-term construction period required(less than 6 months for all significant works) to construct the proposed will minimize thepotential to impact on air quality.

Generation of DustThe impact of fugitive dust generated form the construction phase will to a certain extentdepend on wind direction, wind speed and rainfall. A limited amount of topsoil will be dugup during construction due to the existing ground levels and most of this overburden willbe reused on site. Any construction waste generated will be retained on site andprocessed during the operational phase of the development. Fugitive dust may arisefrom the movement of construction vehicles on the existing hard standing area. Howeverthe level of dust is likely to be of a relatively short duration with minimal impact on thereceiving environment.

Traffic PollutantsThe movement of construction vehicles at the site during the construction phase of thedevelopment will generate exhaust fumes and subsequently to potential emissions ofvolatile organic compounds, nitrogen oxides, sulphur dioxide and PM1o. While the levelsof these pollutants will increase temporarily during the construction phase strictadherence to 'good site/engineering practices' such as switching all vehicles off whennot in use will minimize the generation of any unnecessary air emissions. In any event itis considered that the level of contamination emitted will be minimal and of shortduration.


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Operational Phase

During the operational phase of the proposed development the anticipated increase intraffic entering and leaving the facility will increase by a predicted 36 vehicularmovements a day

Dust & PM10

BHP was commissioned by Oxigen Environmental Ltd. to carry out an impact study onair quality at the facility. Please see Volume 3: Appendix 3.4.3 for a full copy of thereport.

The results of the study show that the current band of environmental dust emissionsbased on previous dust monitoring reports supplied by BHP over a period of 2 yearsduring 2008-2009 is between 114.8 and 131.8 mg/m2/day with an average of 123.3mg/m2/day dust over the area which equates to 45.016 g/m2 per annum.

The predicted environmental dust emissions for the proposed development using currentbest practice will see dust levels rise to approximately 185 mg/m2/day or 67.5g/m2 perannum.

This projection is based on the current dust deposition level for the operation beingincreased by 50%.

From BHP's experience of monitoring such facilities with well-managed dust control andsuppression systems in place, dust levels will be consistently under the regulatory limit.

The proposed development will not involve any material washing or exposed gradingprocesses. All processes are being undertaken within a negative pressure environmentand all exhausts are being filtered.

The worst-case scenario would be an increase of 50% of the observed baseline dustdepositions due to the associated increase in traffic volumes.

The table illustrates the resulting level of deposition that this increase would result in atthe original monitoring stations. At no location is the level of PM10 generated from theproposed operation expected to exceed 40 ug/m3

.

RPS was commissioned by Oxigen Environmental Ltd to carry out an odour impactassessment and dispersion modelling assessment for the proposed additionalprocessing building. Please see Volume 3: Appendix 3.1 for a full copy of the report. Theodour dispersion model was undertaken to assess the odour abatement system on theproposed new processing building and to estimate the ground level odour concentrationsat sensitive receptors in the vicinity of the facility.

The results of the odour model are compared to the high-risk odour criteria presented inthe IPPC H4 guidance documentation, which requires compliance with a limit of 1.5Ou/m3 as a 98th percentile of 1 hour values. The model predicts that the emissionsfrom the proposed stack will not give rise to reasonable cause for odour annoyance at

Oxigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2 Section 3

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the nearest sensitive receptors once it is operated to the design parameters in Table 5.1.The highest off-site 1-hour odour concentration is S1.0 Ou/m3 as a 98th percentile and ispredicted to occur adjacent to the western perimeter of the site.


Oxigen Environmental is ensuring that all equipment installed in the proposed facility is

designed to the latest international best practice for extraction. Features of this

equipment are the control and management of dust.

The main potential sources of dust emissions from the proposed facility are the raising ofdust by vehicles entering and exiting the site.

Dust probes and a state of the art dust extraction system have been installed in theexisting sheds as a containment measure. These probes emit a fine water spray and areused more frequently in the summer when dust levels are higher. Yard spraying iscarried out in periods of dry weather to reduce dust emissions from vehicular movementson site.

Oxigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2: Section 3

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· 3.5 Traffic

3.5. 1 Introduction

TOBIN Consulting Engineers Ltd have been appointed to prepare a Traffic ImpactAssessment for a proposed processing and recycling facility at an existing facility locatedwithin the Merrywell Industrial Estate, Co. Dublin. This Traffic Impact Assessment formspart of the Environmental Impact Statement being submitted as part of the planningapplication for this project.

In preparing this report, TOBIN Consulting Engineers has made reference to:

• The NRA 'Traffic and Transport Assessment Guidelines'• The NRA 'Future Traffic Forecasts 2002 to 2040';• NRA DMRB TD 41-42/09;• NRA DMRB TD 9/07;• NRA DMRB TA 79/99;• DoT 'Traffic Management Guidelines'

The objective of this report is to assess the impact the proposed development will haveon the existing road network. This report will calculate the expected volume of traffic thatwill be generated by the proposed development and will assess the impact that thistraffic will have on the operational capacity of the road network in the vicinity of thedevelopment. In this case the junctions assessed are the existing entrance to the facility,the Ballymount Cross Roundabout and a priority junction between Turnpike Road and anAccess Road into the Industrial Estate. Road safety considerations are also includedwithin this report.

Methodology

Traffic surveys were carried out at each of the 3 junctions being assessed to determinethe baseline flows. These flows were then adjusted to take account of yearly trafficgrowth to determine the background traffic for each year analysed.

Estimates for the amount of traffic that would be generated were calculated from thequantity of materials that the proposed additional building will be catering for. Thegenerated traffic was then distributed onto the road network where it was combined withthe background traffic and subsequently analysed using a relevant software program.

The existing priority entrance to the facility and the priority junction on Turnpike Roadhave been analysed using the Transport Research Laboratory (TRL) computer programPICADY, which is widely used for the analysis of priority junctions. BallymountRoundabout was analysed using the Transport Research Laboratory (TRL) computerprogram ARCADY, which is widely used for the analysis of roundabouts.


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. 3.5.2 Existing Environment

Site Description

The facility is located within the Merrywell Industrial Estate, approximately 0.5 km east ofthe M50 motorway. The entrance to the facility is via an internal road within the estate, tothe northeast of the facility.

Existing Road Network

The entrance to the proposed development is located on an internal road within theMerrywell Industrial Estate. This road is a single carriageway road approximately 9m inwidth. Street lighting and footpaths are present along this road. This internal roadconnects to Ballymount Road Lower and an adjacent internal road of similar qualitywhich subsequently joins up with the Turnpike Road

Ballymount Road Lower is a single carriageway road approximately 7.5m in width. Streetlighting and footpaths are present along this road. This road connects to Turnpike Roadand an Access Road by means of a 4 arm roundabout.

Turnpike Road is a single carriageway road approximately 7.5m in width. Street lightingand footpaths are present along this road. This road connects to an internal access roadby means of a priority junction.

Existing Traffic Conditions

In order to determine the magnitude of the existing traffic flows, TOBIN used the resultsof Manual Classified Traffic Surveys that were carried out by Nationwide Data Collection.These surveys were carried out between the hours of 07.00 to 19.00 and distinguishedbetween cars and heavy good vehicles. These counts were carried out on Wednesdaythe 3rd of March 2010 at the following junctions:

• Ballymount Cross Roundabout• Priority Entrance to the Existing Facility• Priority Junction between Turnpike Road and an Internal Access Road

Full details of these traffic counts are available in Volume 3: Appendix 3.7.

In order to calculate peak traffic flows at these junctions, it was necessary first to convertthe raw traffic survey data, consisting of cars and heavy vehicles, into a common indexknown as passenger car units (PCU's). This was undertaken by applying a factor to allsurveyed traffic movements to take account of the composition of the different types ofvehicle. This factoring calculation assumes 1 car / light vehicle = 1 PCU, 1 heavy vehicle= 2.3 PCU's.

The peak hours experienced at the Ballymount Cross roundabout junction were 08:1509:15 in the AM and 13:00-14:00 in the PM. The peak hours experienced at the entranceto the development junction were 11 :00-12:00 in the AM and 15:45-16:45 in the PM. Thepeak hours experienced at the junction between Turnpike Road and the Access Roadwere 08:15-09:15 in the AM and 14:00-15:00 in the PM. The HGV percentage at eachjunction has also been calculated. The HGV percentage at the Ballymount Cross


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. roundabout is 12.3%), at the entrance to the facility its 31.2%) and the HGV percentage is13.9% at the Turnpike Road / Access Road junction.

Description of Proposed Development

Permission is being sought at an existing waste processing and recycling facility for theconstruction of an additional processing building for the pre-treatment of waste asrequired under the EU Landfill Directive (1999/31/EC). The proposed building will have afloor area of 4218m2

. Also included within the development is an associated air filtrationsystem, an ESB sub-station and all associated site works. The proposed additions to thefacility will accommodate an increase of 100,000 tonnes of waste to be delivered to thefacility per annum.

A planning search was carried out in the area and no significant committeddevelopments were identified in the surrounding area. The area is already welldeveloped and as such any increase in traffic is expected to be accounted for in thegrowth factors that have been applied to the background traffic.

Proposed Road Network Improvements

The Greenhills / Ballymount Reconfiguration Scheme has passed through the planningand compulsory purchase order phases. This scheme will see the construction of justunder 1km of new road and the widening of sections of Ballymount Avenue andCalmount Road. Also included in the project is the upgrading of several junctions.

3.5.3 Potential Impacts

Traffic Generation

As referred to in section 3.5.1, an estimate for the amount of traffic that will be generatedby the development has been calculated based on the additional quantity of material thatwill be delivered to site. Table 3.5.1 below details how the additional quantity of materialsthat will be arriving on site was calculated.

16 2

Table 3.5.3.1 Traffic Generation per Annum (one way)

* 52 weeks per year, 6 days per week assumed** 8 working hours per day assumed


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. For each truck delivering a load to the facility, a corresponding empty vehicle will leaveresulting in 32 additional HGV trips generated by the facility daily. In addition to tripsrelating to the delivery of materials, it is also expected that a certain amount of trips willbe generated by the need for additional staff as a result of the new facility. It is expectedthat 2 additional staff will be required and it is assumed that these staff will arrive in theAM peak and leave during the PM peak. The estimates for the total number of vehiclesthat will be arriving and departing from the facility during the AM and PM peaks aredetailed in Table 3.5.2 below.

AM Peak:

HGV Traffic 2 2

Staff Traffic 2 0

Total 4 2

PM Peak:

HGV Traffic 2 2

Staff Traffic 0 2

Total 2 2

Table 3.5.3.2 Peak Hour Traffic Generation

Trip Distribution

Generated traffic is assumed to distribute in a manner that mirrors existing flows at theentrance and then follow haul routes when using public roads. Figures 3.5.1 - 3.5.4indicate the expected distribution of traffic for the AM and PM peaks respectively.Figures relating to HGVs are indicated in brackets.


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PrivateAccess

r-----(100%)

Access Road

100%

BallymountRoad Lower

(1000/JDevelopment

100%-----l

___-----.JL- ------'T~u~rn~1D~iik~eLR~oa~d!!....._ _!_------ BallymountRoad Lower

'r.---(100%)

Access Road

Figure 3.5.3.1 Trip Distribution AM Peak Hour

PrivateAccess

Access Road

(500/._0,-)_------,


,...---(50%)

[0 (50%)Development [(50%)

___-----l ----!..T~ur~n!l>!oil~·k:S<.e..!...R~o~a~d-----_+------BallymountRoad Lower

(50%)-------''r.---(50%)

Access Road

Figure 3.5.3.2Trip Distribution PM Peak Hour


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PrivateAccess

Access Road

2(0)--------,

r-----O (2)


Development

___----'- T'-"U"-'-'rn:..:tlO"...,iik"-"e'--'R'-'-'o"-"a'-"'d'-- -+ BallymountRoad Lower

"----0 (2)

2(0)---'

Access Road

Figure 3.5.3.3 Generated Traffic AM Peak Hour

PrivateAccess

Access Road

0(1)--------,


r-----O (1)

Development1 (1)

l___----'- ---'T'-"u"-'rn=lO=iik=e'-'-R=o=a=d -+- Ballymount

Road Lower0(1) __-J "--------0(1)

Access Road

Figure 3.5.3.4 Generated Traffic PM Peak Hour


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. Seasonal Adjustment

In order to undertake an analysis of the junctions, it may be necessary to apply acorrection factor to convert the surveyed flow values into seasonally adjusted traffic flowsto take account of the seasonal variation that is experienced with traffic surveys. Theseseasonally adjusted conversion factors were calculated using data taken from a fixedautomatic traffic counter located on the M50 at Balrothery during 2008. Traffic flows inMarch were found to experience lower than average traffic flows. In order for a robustassessment, the surveyed traffic flows have been adjusted by a factor of 1.025. Figures3.5.5 to 3.5.6 below show the seasonally adjusted traffic flows for the AM and PM peaks(HGV percentages are shown in brackets).

PrivateAccess

13 0 11 BallymountAccess Road j [27301 )Road Lower(7.7 Yo) • 10

5(40.0%)~28 (25.0%)-----5(20.0%)-.

97

32~:t31:,'43(9.2j co.S%)Development

62 (9.7%~ ------.-.J125(16.8% •

34 (2.9% ----,Turnoike Road Ballymount

L-39 (23.1%) J [ '~~~1Ji~~l"Lower.. 780 (7.9%) 92 48

(9.8%) 58 (18.8%)

(8.6%)Access Road

JI[ L-22~9.1%)• 48 39.6%

15 5 .-13 92.3%(80.0% (60.0%)

o

24 (16.7%)-----.J206 (9.7%) •

Figure 3.5.3.5 Seasonally Adjusted 2010 Baseflow AM Peak


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6(16.7%)~49 (8.2%) --9(88.9%)-.

Access Road

PrivateAccess

o Ballymount

1~1c)1 I (! 17 Road Lower(6.3j L5..9%)

251

26~rj'6r( 135(9.3j L8.1%)Development

J1[12 ~50.0%)

----58 22.4%11 7 17 82.4%

(63.6% (57.1%)o

56 (30.4%) J[---- 562 (12.6%) 107 84

(10.3% 97 (4.8%)

(8.2%) Access Road

64 (9.4%~187 (10.7% ---

79 (8.9% -----".___..L-- ...!..CTu=rn~ID~iik~e~R~oa~d _+----- Ballymount

Road Lower

338J19.5%)----244 19.3%)

r----95 ( 1.1%)33 (24.2%)-----"289 (10.4%)----

Figure 3.5.3.6 Seasonally Adjusted 2010 Baseflow PM Peak

Traffic Growth

Background traffic on the road network is expected to grow in future years and theproposed development is expected to operate for the foreseeable future. Analysis hasbeen carried out on the expected year opening of 2011 and a design year of 2026. Thebackground traffic growth factors used in the analysis in this report are those provided bythe NRA (Published August 2003 for years 2002 - 2040).

The growth factors applied to the surveyed flows were the 'non-national primary roadsfactors' and are detailed in Table 3.5.3 below.

2010 - 2011 1.018 1.009

2010 - 2026 1.184 1.162

Table 3.5.3.3 Traffic Growth Factors

Figures 3.5.7 - 3.5.10 showing the baseline plus generated traffic flows for the AM andPM peaks in 2011 and 2026 are shown below (HGV percentages are shown inbrackets).


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PrivateAccess

Access Road 13j(7.7%)

5(40.0%)~28 (25.0%)---

7 (14.5%)-------.

o BallymountI (~ 11 Road LowerL7

.3

%)

98

33~t41:,'44(9.3J CO.6%)

93J [48(9.8%) (19.1%)

59

(8.6%) Access Road

Development

J1[22[9.3%)

-----49 39.5%7 5 15 94.7%

(831.6% (60.0%)

o

L----__ 39 (23.1 %)----- 787 (8.0%)

63 (9.7%}126 (17.0% ---41_

34(2.9% ----"___----'- ------=T-=u.:...:...rn=oii=ike"'-=-'R=oa=d=---- -+- Ballymount

Road Lower556J8.2%)

-----408 7.2%)r-----93 ( .8%)26 (15.4%}------'

208 (9.6%}----

Figure 3.5.3.72011 Baseflow + Generated Traffic AM Peak

PrivateAccess

o Ballymount

Access Road 17j ~ 16 Road Lower(6.0%) (6.4%)

6(17.0%)~49 (8.3%) ---10 (91.4%)-------.

136

27;,;n:, 255(9.4J C2•0%)

Development

56 (30.4%) J~----- 567 (12.7%) 108 85

(10.4% 98 (4.8%)

(8.3%) Access Road

65 (9.4%~189 (10.8% ---41_80(8.9% ------,

___---L- ------'-T=ur'-'-'n.t<!oii=k1eo<...:R'--"o""'a=d +- BallymountRoad Lower

342J19.9%)----247 19.4%)

r-----96 ( 1.2%)34 (26.5%)r--------'292 (10.6%)\-----

Figure 3.5.3.82011 Baseflow + Generated Traffic PM Peak


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PrivateAccess

Access Road

6(39.5%)~33 (25.1%) •8(14.8%)~

15j(7.9%)

o BallymountI (~ 13 Road LowerL7

•3

%1

113

38~t51':1161(9.3j CO.6%)Development

J1[26 f9 .1%)------56 40.2%

6 17 95.4%

(81~~% (59.2%)o

46 (23.9%) J[-----917 (8.2%) 107 56

(10.0% 68 (19.0%)

(8.7%) Access Road

72 (9.9%\146 (17.0% -----

40 (3.0% ------:It___--L... ...!....Tu~r~np~ii~kle"__CR'_"o""'a'_"'d _t_----- Ballymount

Road Lower

641 l8.3%~-----470 7.3%~--107 10.000)30 (16.7%)__--J

243 (9.9%)---

Figure 3.5.3.92026 Baseflow + Generated Traffic AM Peak

PrivateAccess

o Ballymount

Access Road 20j ~ 19 Road Lower(6.2%) (6.2%)

7(16.9%)~57 (8.3%) ----12 (87.3%-T---t

157

31~l3'T(1 294(9.5J L: 2

.0%)

14 ~50.8%<----68 22.6%

,----21 83.7%

Development

15] 1[10(61.9% (57.4%)

o

65 (30.8%) Jr----- 660 (12.9%) 125 I l./l 98

(10.4% 113 (4.8%)

(8.4%) Access Road

75 (9.5%)218 (10.9%) ----11_

92 (9.0%) ------,___---'---- ------'T-""u'-'-'rn~Dii=ke"'__'__'_Ro=a=d'_____ +_----- Ballymount

Road Lower395 ~20.0%)

----285 19.5%)~--111( 1.3%)3925.6%)__-J

340 (10.9%)------

Figure 3.5.3.10 2026 Baseflow + Generated Traffic PM Peak

Oxigen Environmental Ltd Ballymount Pre-Treatment Facility Volume 2: Section 3

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. Junction Analysis

Analysis has been carried out on the existing entrance to the facility and the priorityjunction between Turnpike Road and the Access Road using the Transport ResearchLaboratory (TRL) computer program PICADY, which is widely used for the analysis ofpriority junctions.

Analysis of the Ballymount Cross roundabout has been carried out using the TransportResearch Laboratory (TRL) computer program ARCADY, which is widely used for theanalysis of roundabouts.

The key parameters examined in the results of the analysis are the Ratio of Flow toCapacity Value (RFC value - desirable value should be no greater than 0.85 forARCADY and PICADY, values over 1.00 indicate the approach arm is over capacity), themaximum queue length on any approach to the junction and the average delay for eachvehicle passing through the junction during the modelled period.

PICADY and ARCADY require the following input data:• Basic modelling parameters (usually peak hour traffic counts synthesised over a 90

minute model period)• Geometric parameters (including lane numbers & widths, visibility, storage provision

etc.)• Traffic demand data (usually peak hour origin/destination table with composition of

heavy goods vehicles input).

Assessment Years

The years assessed within the analysis are the Opening Year (2011) and the DesignYear (2026).

Analysis Results

The analysis results for the Development Entrance are shown in Table 3.5.3.4 below.Full output results from PICADY are available in Volume 3: Appendix 3.5.


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2011Baseflow +GeneratedTraffic AM 0.043 0.04 0.046 0.05 0.014 0.02 0.051 0.05 0.062011Baseflow +GeneratedTraffic PM 0.033 0.03 0.032 0.003 0.034 0.04 0.064 0.07 0.052026Baseflow +GeneratedTraffic AM 0.051 0.05 0.054 0.06 0.016 0.02 0.060 0.06 0.062026Baseflow +GeneratedTraffic PM 0.038 0.04 0.037 0.04 0.041 0.05 0.077 0.08 0.05

Table 3.5.3.4 Development Entrance Junction Analysis

The above results indicate the entrance to the development will operate below capacityup to and including the design year.


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The analysis results for the Ballymount Cross Roundabout are shown in Table 3.5.3.5below. Full output results from ARCADY are available in Volume 3: Appendix 3.5.

2011Baseflow +GeneratedTraffic AM 0.229 0.32011Baseflow +GeneratedTraffic PM 0.315 0.52026Baseflow +GeneratedTraffic AM 0.272 0.42026Baseflow +GeneratedTraffic PM 0.384 0.6

0.448

0.560

0.527

0.666

0.8

1.3

1.1

2.0

0.924 9.9

0.682 2.1

1.110 76.6

0.824 4.4

0.337

0.345

0.430

0.448

0.5

0.5

0.7

0.8

0.17

0.09

0.76

0.13

Table 3.5.3.5 Ballymount Cross Roundabout Junction Analysis

The above results indicate the Ballymount Cross Roundabout will operate abovecapacity during the AM peak hour in the design year. This junction is alreadyapproaching capacity in the opening year and the application of the growth factorscaused capacity to be breached. The predicted increase in traffic at this junction relatingto the proposed development is less than 1% of traffic currently using the junction so theimpact caused by the development at this junction is considered negligible.

Oxigen EnVIronmental Ltd. Ballymount Pre-Treatment Facility Volume 2: Section 3

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The analysis results for the Turnpike Road/Access Road junction are shown in Table3.5.3.6 below. Full output results from PICADY are available in Volume 3: Appendix 3.5.

2011 Baseflow +Generated Traffic AM 0.130 0.20 0.128 0.63 0.032011 Baseflow +Generated Traffic PM 0.323 0.47 0.243 0.71 0.052026 Baseflow +Generated Traffic AM 0.210 0.26 0.279 1.09 0.042026 Baseflow +Generated Traffic PM 0.400 0.66 0.328 1.14 0.06

Table 3.5.3.6 Turnpike Road/Access Road Junction Analysis

The above results indicate the Turnpike Road/Access Road junction will operate belowcapacity up to and including the design year.

Link Capacity

A link capacity assessment for the Ballymount Road Lower and Turnpike Road wasundertaken using TAl 79/99. TA 79/99 gives a means of estimating the link capacity ofexisting urban roads and this document was used for calculating the capacities of theseroads.

For the purposes of classification of Road Type, the Ballymount Road Lower has beenclassified as UAP3 (variable standard road carrying mixed traffic with frontage access,side roads, bus stops and at grade pedestrian crossing). Existing carriageway widths areapproximately 7.5m which gives capacity estimate of 1300 PCU/hr in one direction. Themaximum one way flow expected occurs during the AM peak with a flow of 1346 PCUexpected. This suggests the road will operate slightly above capacity in the design year.It should be noted that the traffic generated by the proposed additional facility at thedevelopment accounts for less than 1% of the traffic using this road and as such theimpact is considered negligible.

For the purposes of classification of Road Type, the Turnpike Road has been classifiedas UAP3 (variable standard road carrying mixed traffic with frontage access, side roads,bus stops and at grade pedestrian crossing). Existing carriageway widths areapproximately 7.5m which gives capacity estimate of 1300 PCU/hr in one direction. Themaximum one way flow expected occurs during the AM peak with a flow of 1075 PCUexpected. This suggests the road will operate below capacity with approximately 17%spare capacity


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Other Considerations

Road Safety

Visibility at the entrance is considered adequate with 3 x 90m visibility splays available tothe left and right of the entrance. There is an additional entrance serving the officebuilding to ensure large vehicles are segregated from staff vehicles as much as possible.

Traffic flow within the site is managed by signage and road markings such that trafficflows clockwise around the main buildings. The speed limit within the boundaries of thesite is 10km/hr and is clearly indicated with signage. This traffic management system isstrictly enforced as a health and safety priority.

Parking

A total of 95 car parking spaces are provided within the site adjacent to the officebuilding. This is considered sufficient to accommodate both the current staff levels andthe additional staff required to operate the new facility.

Pedestrians

To accommodate staff travelling on foot within the development, safe walking routes areclearly marked on the roadway through the facility. External to the development there arefootpaths along the access roads within Merrywell Industrial Estate and also theBallymount Road Lower and Tunrpike Road.

Public Transport

The 56a runs from Tallaght to Dolphins Barn with approximately 19 buses per day ineach direction on weekdays. Its route takes it along the Ballymount Road Lower, pastthe Merrywell Industrial Estate. In addition, there are several bus routes that run alongthe N7 Naas Road which would be within walking distance of the development, as wouldthe Luas Red Line service.

Access for People with Disabilities

It is recommended that dish kerbing is installed at all crossings, positioned directlyacross all junctions, to assist wheelchair and push chair users. In addition, buff colouredtactile paving slabs should be installed at all uncontrolled dished crossings.

It is recommended that disabled parking spaces be provided in accordance with theNDA's Build for Everyone' it is recommended that these parking spaces be locatedclosest to the main buildings within the development.


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3.5.4 Conclusions and Recommendations

The conclusions of this report are as follows:• the development entrance will operate below capacity up to and including the design

year• the Ballymount Cross Roundabout will be operating above capacity by 2026 with or

without the inclusion of development related traffic• the Turnpike Road / Access Road junction will operate below capacity up to and

including the design year• The Turnpike Road will operate below capacity up to and including the design year• The Ballymount Road Lower will be operating above capacity by 2026• The traffic generated by this development will constitute less than 5% of traffic at the

junctions affected, which is considered a negligible impact

The recommendations of this report are as follows:• Disabled parking spaces to be provided in accordance with NDA's 'Building for

Everyone'.• The Greenhills / Ballymount Reconfiguration Scheme to be constructed to alleviate

some of the congestion on the Ballymount Road Lower• Dish kerbing and tactile paving is installed at all pedestrian crossings.


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3.6 Noise

3.6.1 Introduction

An assessment of noise has been carried out with reference to British Standards andother relevant policy guidance. Noise issues relating to the operation of the proposeddevelopment have been considered to the nearest noise-sensitive propertiessurrounding the site.

The subject site is currently operating as a waste processing and recycling facility. Theproposed development is essentially an extension of existing operations to allow for theconstruction of an additional shed to pre-treat MSW. The noise assessment in thischapter assessed the noise impacts from this proposal and examines the cumulativeimpacts against the stated criteria.

An assessment has been made of the baseline situation by BHP Laboratories in July of2009 (see Volume 3: Appendix 3.6 for a full copy of the report). Noise monitoring is notrequired as part of the current Waste Licence however existing planning conditions forthe site require the following:

• Noise due to the normal operations of the development expressed as LAeq over15 minutes in a noise sensitive location, shall not exceed the background levelfor the night time and

• Noise due to the normal operation of the development expressed as LAeq over 1hour at the fa9ade of a noise sensitive location, shall not exceed the daytimebackground level by more than 10dB(A)

Therefore the baseline assessment was carried out using the above parameters.


A Larson Davis System 824 Type 1 sound level meter was used to monitor noise levelson site. Two 60-minute daytime levels were measured at the noise sensitive location.The location was labelled NSL1 and is identified on the map included in the full BHPReport which can be seen in Volume 3: Appendix 3.6.

The usual limits for such operations are as follows:

Daytime LimitNightime Limit

LAeq < 55dBLAeq < 45dB

As can be seen in the results shown in section 4.1 of the BHP Report, daytime LAeq

levels at all noise sensitive locations are greater than the day time limit of 55dB. Themain noise source at this location is continuous traffic from the Turnpike Road. It canalso be seen that the noise due to normal operation of the development at the noisesensitive location does not exceed the daytime background level by more than 10dS.Night time L Aeq levels were less than the night time limit of 45dB.

Oxigen Environmental ltd. Ballymount Pre-Treatment Facility Volume 2: Section 3

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. It was concluded that the noise contribution made by the Oxigen operation does notexceed the daytime background limit by more than 10dB. The night time limit of 45dB isnot being breeched and there was no evidence of a tonal or impulsive component to thenoise attributable to the plant operation.


An assessment of predicted noise emissions during the course of operation of theproposed development has been made by BHP in their report of July 2009 (Volume 3:Appendix 3.6).

An examination of the impact of noise emissions on the surrounding environment of thetreatment facility when operational, especially on residential units in the immediatevicinity of the site, was carried out. The FHA Noise Model was used to model thepredictive noise to ensure that all responses made have due consideration to worst casescenario being predicted.

Environmental noise modelling describes the process of theoretically estimating noiselevels within a region of interest under a specific set of conditions. The results of noisemodelling of the predicted impacts of the proposed development can be seen inAppendix 3.6.

The proposed development when operational, will involve an increase in vehicular trafficentering and exiting the site. All other processes are enclosed with a negligible impacton the nearest noise sensitive locations.

The worst case scenario will involve activities close to the residential locations at N5 andN6. No increase in noise levels at the residential location close to N4 is envisaged due tothe shielding nature of the rock face already in place.


The following points are recommended with a view to reducing overall noise impacts onthe noise sensitive locations:

• The internal pavement of the facility should be maintained to reduce vehicularnoise, especially banging from empty trucks;

• A speed limit of 20km/hour should apply for all vehicles operating at the site (alimit of 15km/hour is already in place at the facility);

• Screening bunds close to the residences art the noise sensitive location shouldbe maintained and a planting programme introduced t further reduce potentialnoise impact;

• Periodic noise monitoring at the noise sensitive locations should be introduced toensure that all national guidelines in relation to noise ELV's are being compliedwith and

• A review of reversing sirens should take place with a view to examining theirpossible replacement with white sound technology


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3.7 Soil & Geology

3.7.1 Introduction

This section examines the type of soils and geology underlying the site. It alsoaddresses the impact of the proposed development on soils and geology. There were nointrusive ground investigations undertaken as part of this study as the proposeddevelopment is an extension to the existing operations on site.

Desk based information on the substrata underlying the subject site was obtainedthrough the Geological survey of Ireland (GSI) and from existing reports held on filewithin Oxigen Environmental.


The site is located within an industrial park and was used previously for steelmanufacturing and prior to this for agricultural purposes. It is predominately covered byimpervious hardstand with green area along some of the boundaries. The upper soilhorizons beneath the site were altered during the initial construction works on the sitewhen the original factory was built.

Historic geological maps of the area identify the natural Quaternary sedimentsunderlying the site as glacial tills which vary from loose aggregate to firm sandy gravelyclays and in size from cobbles to boulders, commonly referred to as Dublin Till. Wellcards from the Clondalkin region records a depth to bedrock of between 3 & 16 metersbelow ground level (bgl). Depth to bedrock is thought to lie at circa 4-6 meters beneaththe site.

Published Geological data of the study area identifies the bedrock geology as the CalpLimestones of Lower Carboniferous period. This formation is Chadian to Brigantine inage and was formed in the deep waters of the Dublin basin as turbidity deposits. Theformation consists of dark grey, fine grained, graded limestone with interbedded blackpoorly fossiliferous shales. The Clondalkin formation within the immediate vicinity of thesite, is karistified and dolomitised in certain areas. Structurally these rocks dip at 80towards the east/southeast with a north-south strike. There are no major faults reportedin the region.

The site and its immediate surrounds have historically been used for quarrying activities,which have been subsequently restored. The nature and extent of the quarryingactivities are unknown at this time and as such there is the potential for previouscontamination of the subsurface.


There are no geological features of significance present either at or beneath the site,therefore, the proposed development will have no impact on local geology. There arealso no groundwork's proposed which may impact on the geological composition of thesite. There will be no direct discharges to the subsoil as part of the proposal and


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. subsequently there will be no impacts to the underlying subsurface. Clean surfacewaters are directed into the surface water drainage system on site and discharged intothe nearby waterway. Foul waters are directed into the county council sewer system.


All wastes and fuels will be stored in fully bunded areas in accordance with relevantenvironmental guidelines and recognised standards. All bunds will be tested inaccordance with the waste license conditions. In addition oil absorbent materials will bekept on site in close proximity to any fuel storage tanks or bowsers during sitedevelopment works. The refuelling of plant will be undertaken in a designated area,which will be fully contained to prevent spillage into the surface water network.Furthermore in compliance with the conditions of the license all wastes being deliveredto or removed from the site will be loaded/unloaded within the fully bunded wasteprocessing building. Leachate drains are installed on site thereby minimizing thepotential for leaks of contaminated runoff to surface water drainage.


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Environme:ntallmpact Statement

3.8 Flora &Fauna

3.8.1 Introduction

This section assesses the potential impacts the proposal to erect a building to pre-treatmunicipal waste on site will have on any existing flora and fauna habitats. Themethodology of the assessment undertaken is in accordance with the EPA Guidelineson the Information to be contained in Environmental Impact Statements (2002).

Any habitats present are described in their current status and their conservation valueassessed. Consideration has been given to the vegetation and floral surveys that wereundertaken as part of the original EIS for the facility to establish if any sensitive orprotected species were present prior to the operation of a waste management facility onthe site.

In compiling this chapter, due regard was given to relevant legislation pertaining to floraand fauna assessment. These included;

• Wildlife Act 1976.• EC Council Directive on the Conservation of wild birds (Birds Directive, 1979).• European Communities (Conservation of Wild Birds) Regulations, 1985-1999).• EC Council Directive on the Conservation of Natural Habitats of Wild Fauna and

Flora (Habitats Directive, 1992).• European Communities (Natural Habitats) Regulations, 1997.• Wildlife (Amendment) Act, 2000.• Any relevant protection orders.


The subject site is located within an industrialised area, namely Ballymount IndustrialEstate, which is approximately 0.5 km off the M50, south east of the Red CowInterchange. There is an existing Waste Management and Recycling Facility on site towhich the current proposal relates. This Oxigen facility has been in operation on this sitesince 2004. Prior to this Corus Steel Ltd (formerly the Steel Company of Ireland)operated a steel manufacturing company from the site since 1945. Subsequent to thisthe site and much of the surrounding landscape was used for agricultural purposes.There is no existing landscaped or green belt area adjacent to the site which issurrounded by industrial/commercial units and as a result is habitat poor.

The site covers an area of approximately 13 acres, with the terrain for most part beingflat with earth mounding along the south west and part of the north east boundary. Thesite is mostly covered with hard standing. There is a grassed area surrounding the staffcar park at the office block which also has some mature trees dispersed through out.The site is accessed from the Ballymount Road lower and the Turnpike Road with twointernal estate roads leading to the two site entrances.

The soil beneath the site is disturbed and consists of light brown, glacial till withlimestone boulders. The bedrock geology is identified as Calp Limestones of LowerCarboniferous period.


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Surface water run-off from the site drains to the on site surface water drainage network,that discharges into the Ballymount Stream, which flows in South Dublin Countycouncil's underground surface water network adjacent to the site. The Ballymountstream discharges into the Camac River, a tributary of the River Liffey.

Existing Flora on site is limited due to the extent of the existing hardstanding area.However within the small areas of managed grassland there are several dominant grassspecies. These include cocksfoot (Dactylis glomerata), red fescue (Festuca rubra) andmeadow grass (Poa spp.). Broadleaf herb species present include buttercup(Ranunculus repens), dandelion (Taraxacum spp), daisy (Belis perennis), and red clover(Trifolium pratense,).

Due to the industrialised nature of the area the sites habitats are species-poor. Faunapresent on the site is limited for the most part to a few urban birds such as rook, (Corvusfrugilegus), blackbird (Turdus merula), robin (Erithecus rubecula), and woodpigeon(Columba palumus).

Designations in the vicinity

There are no designated NHA's, SAC's or SPA's in the vicinity of the subject site.However there are three proposed Natural Heritage Areas within 10km of the proposeddevelopment site which have not been formally designated but are in the process ofstatutory recognition. These sites are as follows;

• Liffey Valley (Site no. 00128)

• Grand Canal (Site no. 02104)

• Dodder Valley (Site no. 00991)

However the existing operations on site have no direct impact on these proposed NHA'sas there are no emissions to groundwater and all wastes and consumables on site arestored in bunded areas which discharge directly to the county Council foul sewer.


A baseline survey was carried out as part of the original EIS for the site. This surveyfound that there were no sensitive or protected species of flora or fauna on site. Themain habitat occurring on the site at that time was managed grassland. Since then thesite has been developed so that much of the once managed grassland has beenreplaced with hardstanding. In addition there are no significant groundworks proposedas part of the application therefore it is considered that there will be no resulting impactsto flora and fauna.


There will be no emissions to groundwater from the proposed development thereforethere is no potential to impact on the existing pNHA's. The flora and fauna present arelimited as the majority of the area is covered with concrete and there is no conservationvalue for the site. Consequently there are no planned mitigation measures.

Oxigen Environmental Ltd. Ballymount Pre-Treatment Facility Volume 2- Section 3

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Environme.ntal Impact Statement

· 3.9 Cultural Heritage


Archaeology

There are no recorded archaeological findings for the proposed development site.Furthermore previous groundwork's on site have not resulted in any findings of anarchaeological nature.

The closest recorded archaeological site is DU017-077 which is classified as anearthwork site and is located approximately O.5km to the northwest of the subject site inthe townland of the Red Cow. According to files held by Archaeological Survey ofIreland, it is likely that this site was destroyed during the construction of the Naas dualcarriageway. There is a flat cemetery (Ref DU022-022) located adjacent to theWalkinstown Cross at Greenhills Road approximately 2km east of the proposeddevelopment site.

History

There are no known traditions associated with the site or its immediate environs.

Architecture

The buildings on site have no architectural merit and there are no protected structureswithin the vicinity of the site.

3.9.2 Predicted Impacts

Archaeology

There are no groundwork's proposed as part of the subject development,notwithstanding this, there are also no sites of archaeological interest located in theenvirons of the site. Therefore there will be no impact to archaeology in the area. Itshould also be noted that none of the archaeological sites identified in Table 3.1 can beseen from anywhere within the development site and as such the proposed will not resultin any negative visual impact to these archaeological features.

History

It is envisaged that the proposed development will not impact on features or events ofhistorical interest.

ArchitectureThere are no structures of architectural interest located within the boundaries of thesubject site or indeed within the defined study area. Consequently as there are no sitesidentified there will not be any negative impact resulting from the proposed works.

OXigen Environmental Ltd. Baliymount Pre-Treatment Facility Volume 2: Section 3

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