ENVIRONMENTAL RISK ASSESSMENT Stockley Park Dcs LON5 to LON8

Virtus HoldCo Ltd ENVIRONMENTAL RISK ASSESSMENT Stockley Park DCs LON5 to LON8

70051165-ERA SP 001 FEBRUARY 2020 PUBLIC Virtus HoldCo Ltd

ENVIRONMENTAL RISK ASSESSMENT Stockley Park DCs LON5 to LON8

TYPE OF DOCUMENT (VERSION) PUBLIC

PROJECT NO. 70051165 OUR REF. NO. 70051165-ERA SP 001

DATE: FEBRUARY 2020

WSP 110 Queen Street Glasgow G1 3BX Phone: +44 141 429 3555 Fax: +44 141 429 3666 WSP.com

PUBLIC QUALITY CONTROL

Issue/revision First issue Revision 1 Revision 2 Revision 3

Remarks Draft for Rev1 to client Issue Comment

Date Nov 2019 Jan 2020 Feb 2020

Prepared by Stuart Clayton Charlotte Daniels C Daniels Charlotte Daniels Derek Schoehuys Consultant

Signature

Checked by Derek Derek Schoehuys D Schoehuys Schoehuys Associate

Signature

Authorised by Rachel Jones Stuart Clayton S Clayton Associate

Signature

Project 70051165 70051165 70051165 number

Report number /ERA SP 001 /ERA SP 001 /ERA SP 001

File reference \\uk.wspgroup.com\central data\Projects\700511xx\70051165 - Virtus - Generator Legislation Assessment

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd CONTENTS

1 INTRODUCTION 1

1.1 AUTHORISATION 1 1.2 BACKGROUND INFORMATION 1 1.3 OBJECTIVES OF THE ENVIRONMENTAL RISK ASSESSMENT (ERA) 1 1.4 EMERGENCY PREPAREDNESS AND RESPONSE 2 1.5 RECORD KEEPING 2 1.6 RESPONSIBILITY 2

2 SITE SETTING AND RECEPTORS 3

2.1 SURROUNDING LAND USES 3 2.2 RAW MATERIAL AND WASTE INVENTORY 4 2.3 INDUSTRIAL AND COMMERCIAL RECEPTORS 4 2.4 RESIDENTIAL RECEPTORS 4 2.5 GEOLOGY, HYDROLOGY AND HYDROGEOLOGY 4 2.6 ECOLOGICAL RECEPTORS 6 2.7 ANCIENT WOODLAND 7 2.8 CULTURAL HERITAGE 8

3 ENVIRONMENTAL RISK ASSESSMENT 9

3.1 SCOPE 9 3.2 METHODOLOGY 9 3.3 ODOUR RISK ASSESSMENT 10 3.4 NOISE AND VIBRATION RISK ASSESSMENT 12 3.5 UNCONTROLLED OR UNINTENDED FUGITIVE EMISSIONS 14 3.6 VISIBLE EMISSIONS 15

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd 3.7 DISCHARGES 16 3.8 ACCIDENTS 18

4 ACCIDENT MANAGEMENT PLAN KEY INFORMATION 21

TABLES Table 2-1 – Surrounding Land Uses 3 Table 2-2 - Groundwater/Water Abstractions within 2km of the Site 4 Table 2-3 - Surface Water Features within 2km of the Site 5 Table 2-4 - Tidal / Surface Water Abstractions within 2km of the Site 6 Table 3-1 – Odour Risk Assessment 10 Table 3-2 – Noise and Vibration Risk Assessment 12 Table 3-3 – Uncontrolled or Unintended Fugitive Emissions Risk Assessment 14 Table 3-4 – Visible Emission Risk Assessment 15 Table 3-5 – Discharges Risk Assessment 16 Table 3-6 – Accidents Risk Assessment 18

FIGURES Figure 2-1 - Ecological Receptors 7 Figure 2-2 - Ancient Woodland 8 Figure 2-3 - Cultural Heritage Sites 8

APPENDICES

ENVIRONMENT AGENCY HABITATS ASSESSMENT MAPS

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd 1 INTRODUCTION

1.1 AUTHORISATION On the instruction of Virtus Data Centres Limited (hereafter referred to as “Virtus”), an Environmental Risk Assessment (ERA) has been compiled for the Stockley Park Data Centre Campus located at Hillingdon, London (hereafter referred to as the “site”).

1.2 BACKGROUND INFORMATION Virtus are in the process of completing construction of a data centre at Stockley Park which, once fully operational, will house a total of up to 72 generators across 4 individual buildings. These will have an aggregated total thermal input of over 50 MW and, as such, will be required to be operated as a Part A1 combustion activity installation under an Environmental Permit as per the Environmental Permitting (England and Wales) Regulations 2016, as amended. This ERA has been undertaken for the installation at Stockley Park Campus as part of the Environmental Permit application process. The Environment Agency (EA) application reference details are: ¡ Stockley Park: EPR/AP3903PD/A001 This ERA comprises part of the Stockley Park Environmental Permit application which comprises the following sites and generators shown in Table 1.1 below.

Table 1.1 Stockley Park Generators Data Location Postcode Quantity Gen sets Net power Possible max Fuel Type Centre output thermal input ID Number Installed Designed kW Each Input total MW thermal LON5 Stockley UB11 18 21 2200 132 Diesel Park 1HB LON6 Stockley UB11 0 10 2000 91.43 Diesel Park 1HB 5 2400 LON7 Stockley UB11 0 21 2200 132 Diesel Park 1HB LON8 Stockley UB11 0 14 2200 88 Diesel Park 1HB

1.3 OBJECTIVES OF THE ENVIRONMENTAL RISK ASSESSMENT (ERA) The aim of the ERA is to identify any significant risks from the construction, operation and maintenance of the proposed date centre and to demonstrate how the risk of environmental pollution or harm will be minimised through appropriate measures.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 1 of 21 This ERA has been undertaken in accordance with GOV.UK web-based guidance Risk assessments for your environmental permit1 (updated January 2019). The ERA: § Identifies potential accidents and the measures in place to minimise them happening; § Identifies events or equipment failures that could damage the environment; § Considers the likely frequency of how often these events or failures are likely to occur; and § Details the consequences if they do occur. The guidance referred to above requires all receptors that are near the site and those that could reasonably be affected by the proposed activities to be identified and considered as part of the ERA. Therefore: ¡ A 2km radius has been adopted in reviewing potentially sensitive receptors of cultural and ecological importance; and ¡ A radius of 500m from the proposed permit boundary has been adopted for all other potentially sensitive receptors (for example, residential, commercial, industrial, agricultural and surface water receptors).

1.4 EMERGENCY PREPAREDNESS AND RESPONSE The installation has in place procedures for managing accidents, incidents and complaints. These dictate the actions to take in the event of these occurring and are part of the site Environmental Management System (EMS). Refer to Section 4.3 of the main permit application document.

1.5 RECORD KEEPING Records of all environmental accidents, incidents and complaints will be kept and be accessible to the management team. 1.6 RESPONSIBILITY The ERA is the responsibility of the Compliance Manager.

1 https://www.gov.uk/guidance/risk-assessments-for-your-environmental-permit#risk-assessments-for- bespoke-permits

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 2 of 21 2 SITE SETTING AND RECEPTORS

INSTALLATION ADDRESS The installation address is: Virtus Data Centres, Stockley Park campus Prologis Park West London, off Horton Road, London UB11 1HB Stockley Park is located on the outskirts of West London approximately 3km to the north of Heathrow Airport, in the London Borough of Hillingdon. The Stockley Park site is rectangular in shape and is accessed via Horton Road which forms the northern boundary. The site is approximately 12 hectares in area and is centred at National Grid Reference 507267, 180159. The four data centres which make up the total site take up the majority of this land, with the exception of a children’s play area and a central dividing road which separates London 5 and 6 from London 7 and 8.

2.1 SURROUNDING LAND USES The site is surrounded by a number of industrial, commercial and residential properties, as described in the table below.

Table 2-1 – Surrounding Land Uses

Boundary Land Use

North Primarily open land, Stockley Park Golf Club and course, Stockley Country Park, small fairground storage depot/caravans and Uxbridge football club. Residential areas start north of Stockley Road at approximately 770m from the boundary.

East Immediate boundary is taken up by a GSK site, beyond that the A408 separates the Stockley Park Estates which includes a number of large business facilities and offices such as Celgene biopharma, Marks and Spencer offices, video production studios, etc.

West The area to the west is characterised by dense spacing of units including small vehicle repair shops, larger vehicle repair shops and coachworks, autogas conversion, vehicle sales centres, vehicle dismantlers, engineering and fabrication workshops etc. Within this area there appears to be a short section of housing which may have been converted for business use. The suburban residential area of Yiewsley lies approximately 400m west of the site beyond the above industry. This area includes Rabbsfarm and St Mathews Primary schools, health centres, etc. West Drayton railway station lies 1km to the west of the boundary.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 3 of 21 South Immediately south over the canal lies a short section of industrial units mostly small vehicle servicing workshops, minibus hire, and a marble supplier, along Iron Bridge Rd South. Beyond that is the railway line, a narrow green buffer zone and an extensive residential area of Drayton Garden Village.

2.2 RAW MATERIAL AND WASTE INVENTORY Details on the use and storage of raw materials and handling and storage of waste are contained within the Environmental Permit Application main document Section 3.

2.3 INDUSTRIAL AND COMMERCIAL RECEPTORS The site is bounded by Horton Road and Stockley Park Golf Course to the north, Ironbridge Road North and the rest of Stockley Business Park (Phases 1 and 2) to the east, the Grand Union Canal and Mainline railway to the south, and the Horton Industrial Area to the west.

2.4 RESIDENTIAL RECEPTORS Residential areas start north of Stockley Road at approximately 770m from the boundary. The suburban residential area of Yiewsley lies approximately 400m west of the site. Beyond the railway line to the south is a narrow green buffer zone and an extensive residential area of Drayton Garden Village. 2.5 GEOLOGY, HYDROLOGY AND HYDROGEOLOGY GEOLOGY The Geology of Britain Viewer (displaying BGS data) indicates that the site is underlain by superficial deposits of River Terrace Deposits (undifferentiated) - Sand And Gravel. The underlying solid geology is comprised of the Thames Group - Clay, Silt, Sand And Gravel. Sedimentary Bedrock formed approximately 34 to 56 million years ago in the Palaeogene Period. The historical ground investigations undertaken on site confirm this; they indicate that the geology beneath the site consists of top soil, underlain by clay and sand. HYDROGEOLOGY The Envirocheck Report indicates that the bedrock underlying the site is classified as an unproductive aquifer with there being a potentially productive superficial aquifer overlaying the bedrock. The vulnerability of the aquifer is deemed to be medium or high across the site. The site is located within a nitrate vulnerable zone but not in a Source Protection Zone. There are 5 licensed groundwater abstractions within 1km of the site with a further 6 licensed groundwater abstractions present within 2km of the site.

Table 2-2 - Groundwater/Water Abstractions within 2km of the Site

Licensee Details Abstraction Point Approximate Direction Distance from from Site Site (m)

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 4 of 21 Prologis UK Business park make-up water Groundwater 15 NE

Stockley Park Golf courses: General washing Groundwater 199 NE Golf Club Limited

Stockley Park Golf courses: spray irrigation Groundwater 284 NE Golf Club direct Limited

Stockley Park Lake reservoir filling for spray Groundwater 851 E Management irrigation Ltd

Stockley Park Business parks: spray irrigation Groundwater 889 E Estates storage Company Ltd

R & R Barwick General agriculture: spray Groundwater 1,483 N irrigation direct

Hillingdon Hospitals: Drinking; Cooking; Groundwater 1,628 N Hospital NHS Sanitary; Washing; (Small trust Garden)

Hillingdon Hospitals: Drinking; Cooking; Groundwater 1,852 N Hospital NHS Sanitary; Washing; (Small trust Garden)

Hillingdon Hospitals: Drinking; Cooking; Groundwater 1,889 N Hospital NHS Sanitary; Washing; (Small trust Garden)

Harleyford Mineral products: mineral Groundwater 1,898 S Aggregates washing Ltd

Thorn EMI Manufacture (boiler) Groundwater 1,976 E Electronics

HYDROLOGY There are a number of surface water features in the vicinity of the site as identified by the Envirocheck report, details of which are outlined in Table 2-3 below.

Table 2-3 - Surface Water Features within 2km of the Site

Surface Water feature Approximate Direction Distance from from Site Site (m)

Inland River (not named) 10 E

Grand Union Canal 13 S

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 5 of 21 Grand Union Canal 245 SE

Lake 545 SE

Inland River (not named) 559 SE

Stockley Road Lake 563 SE

Inland River (not named) 564 SE

Inland River (not named) 568 E

Inland River (not named) 817 NE

Inland River (not named) 865 E

The Envirocheck Report indicates that there are two surface water abstractions within 1km of the site and a total of four within 2km. These are outlined below.

Table 2-4 - Tidal / Surface Water Abstractions within 2km of the Site

Licensee Details Abstraction Point Approximate Direction Distance from from Site Site (m)

British Other Industrial/Commercial: Surface water 366 SE Waterways Dust suppression Board

Canal and Mineral products: process water Surface Water 397 SE River Trust

British Cooling River/stream intake 1,508 NW Waterways

Canal and Other Surface water 1,836 E River Trust Industrial/Commercial/Public Services: Non-Evaporative Cooling

2.6 ECOLOGICAL RECEPTORS An online search using MAGIC maps was undertaken to identify ecological receptors alongside a screening during the Environment Agency pre-application process. Figure 2-1 shows the nearest ecological receptors to the site.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 6 of 21 Figure 2-1 - Ecological Receptors

There are the following ecologically designated sites within 10km of the installation:

¡ 0 Special Areas of Conservation (SAC); ¡ 1 Special Protection Area (SPA) which is South West London Waterbodies approximately 8km South West; and ¡ 1 Ramsar site which is South West London Waterbodies approximately 8km South West. There is no Site of Special Scientific Interest (SSSI) within 2km of the Installation.

There is no Local Nature Reserve within 2km of the site. The nearest is Yeading Meadows and Yeading Woods which are approximately 3km to the North East.

The Environment Agency has identified the potential for European Eel protected species migratory routes, and Local Wildlife Sites. The Agency Habitats screening maps are presented in Appendix A.

2.7 ANCIENT WOODLAND Figure 2-2 from MAGIC maps below shows that there are no ancient woodlands in the vicinity of the site. There is some deciduous woodland which is categorised as priority habitat inventory located adjacent to the site boundary to the north and north west.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 7 of 21 Figure 2-2 - Ancient Woodland

2.8 CULTURAL HERITAGE There are several listed buildings within a 2km buffer as shown in the Figure below. A map of nearest listed buildings is also presented below. There are no Scheduled Monuments or Registered Battlefields. The nearest listed buildings are 1km to the north, 1km to the west and 0.9km to the south west from the installation boundary.

Figure 2-3 - Cultural Heritage Sites

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 8 of 21 3 ENVIRONMENTAL RISK ASSESSMENT

3.1 SCOPE The environmental risk assessment in the following sections has been based on GOV.UK Guidance https://www.gov.uk/guidance/risk-assessments-for-your-environmental-permit. The environmental risks associated with the operation of the facility are considered for the following potential impacts: § Odour; § Noise and vibration; § Uncontrolled or unintended fugitive emissions (including dust, litter and pests); § Visible emissions, such as smoke or plumes; § Discharges, for example sewage or trade effluent to surface or groundwater and § Accidents. 3.2 METHODOLOGY The following steps outline the methodology that has been followed in the undertaking of the ERA for the site: Step One- Identification of Risks The key environmental risk areas have been detailed above in Section 3.1. Step Two- Identification of Receptors Section 2 of this document has described the site setting and the land uses in the vicinity of the site. This information has been used to identify the main receptors that could be potentially at risk from the activities of the site. Step Three- Identification of Pathways between Sources and Receptors For each of the identified hazards associated with the proposed site operations, the ERA has considered the pathways through which each hazard may impact on a sensitive receptor identified under Step Two. Where such pathways exist, the risks of potentially significant impacts have been assessed along with any controls and mitigation in place as detailed in Sections 3.2.4 and 3.2.5. Step Four- Assessment of Risks The risks from each potential impact is assessed according to the activity being undertaken. As this activity is a combustion activity using gas oil then the fundamental risks to be considered are emissions to air and releases of gas oil to land or groundwater. Step Five- Controls for risks The GOV.UK Guidance states: “You’ll need to show how you’re managing any risks appropriately by controlling and monitoring your emissions and through your management system.” The ERA is required to demonstrate how the risk of pollution or harm can be mitigated and the control measures that are in place as part of the environmental management system to reduce residual risks. Step Six- Presentation of the Results The findings of the ERA are presented in Tables 3-1 to 3-6 below.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 9 of 21 3.3 ODOUR RISK ASSESSMENT The risks associated with odour from the site are considered to be very low and would be associated with VOCs from the storage of oil and process emissions to air from a failure of equipment. The risk assessment with regards to odour is presented in Table 3-1 below.

Table 3-1 – Odour Risk Assessment

Hazard Receptor Pathway Risk Management Probability of Consequence What is the overall Exposure risk?

What has What is at How can What measures will you take to How likely is this What is the harm What is the risk that the risk? What the reduce the risk? If it occurs who is contact? that can be still remains? The potential to do I wish hazard responsible for what? caused? balance of cause to get to the probability and harm? protect? receptor consequence. ?

Odour from Nearest Air All of the diesel generators are newly Very Low- Low – Nuisance to Not significant provided process air residential commissioned, in the process of Mitigation amenity for housing equipment is operated in emissions properties commissioning or are yet to be installed measures in place within the locality. accordance with due to are located and are therefore in good working order. should ensure manufacturers failure of 160m to The generators will then be subject to that exposure is recommendations. equipment, the South periodic inspection in accordance with minimised. accident or at Rutters manufacturer’s maintenance other Close recommendations. abnormal The generators would only be operated operation during maintenance or grid failures as they are for emergency backup only. In the event of one failing during operation it would be immediately shut down. Any unusual odours to be investigated immediately in accordance with procedures within the EMS. Record and act on complaints in accordance with the EMS.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 10 of 21 Odour from Nearest Air Gases would only be vented during Very Low- Low – Nuisance to Not significant if storage of residential filling operations. Whilst filling tank is Mitigation amenity for housing management gas oil for properties back vented to tanker. There is pipework measures in place within the locality. techniques are use in are located between generators to allow for transfer should ensure adhered to. generators 160m to of oil from generator to generator but that exposure is the South this would only be done infrequently as minimised. at Rutters the generators are only operated during Close maintenance or grid failures as they are emergency backup. Any unusual odours to be investigated immediately in accordance with procedures within the EMS. Record and act on complaints in accordance with the EMS.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 11 of 21 3.4 NOISE AND VIBRATION RISK ASSESSMENT The risks associated with noise and vibration from the site are considered to be low and would be associated with the operation of the diesel generators which would only be infrequently during maintenance and testing, or during electrical grid failures, which are not expected to be extended in duration. The risk assessment with regards to noise and vibration is presented in Table 3-2 below.

Table 3-2 – Noise and Vibration Risk Assessment

Hazard Receptor Pathway Risk Management Probability of Consequence What is the overall Exposure risk?

What has What is How can What measures will you take to reduce How likely is this What is the harm What is the risk that the at risk? the hazard the risk? If it occurs who is responsible contact? that can be still remains? The potential What do I get to the for what? caused? balance of probability to cause wish to receptor? and consequence. harm? protect?

Noise from Nearest Air (noise Generator sets are located in steel Very Low- Low – Nuisance Not significant provided normal residential propagation) container units fitted with noise Mitigation to amenity for equipment is operated in operation properties attenuation. measures in place housing within the accordance with of diesel are should ensure locality. manufacturers All equipment will be maintained and generators located that exposure is recommendations. operated in accordance with the 160m to minimised. manufacturer’s guidance and maintained the South in good working order. at Rutters Close Any unusual noise or vibration to be investigated immediately in accordance with procedures within the EMS. Record and act on complaints in accordance with the EMS.

Noise and Nearest Air (noise All of the diesel generators are newly Very Low- Low – Nuisance Not significant provided vibration residential propagation) commissioned, in the process of Mitigation to amenity for equipment is operated in from diesel properties commissioning or are yet to be installed measures in place accordance with

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 12 of 21 generators are and are therefore in good working order. should ensure housing within the manufacturers due to located The generators will then be subject to that exposure is locality. recommendations. failure of 160m to periodic inspection in accordance with minimised. equipment, the South manufacturer’s maintenance accident or at Rutters recommendations. other Close The generators would only be operated abnormal during maintenance or grid failures as operation they are emergency backup. In the event of one failing during operation it would be immediately shut down. Any unusual noise or vibration to be investigated immediately in accordance with procedures within the EMS. Record and act on complaints in accordance with the EMS.

Noise from Nearest Air (noise All fuel deliveries will be made during Very Low- Low – Nuisance Not significant provided fuel residential propagation) normal working hours. Mitigation to amenity for equipment is operated in delivery properties measures in place housing within the accordance with The vehicles will not idle whilst off-loading vehicles are should ensure locality. manufacturers fuel. located that exposure is recommendations. 160m to Any unusual noise or vibration to be minimised. the South investigated immediately in accordance at Rutters with procedures within the EMS. Close Record and act on complaints in accordance with the EMS.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 13 of 21 3.5 UNCONTROLLED OR UNINTENDED FUGITIVE EMISSIONS The risks associated with uncontrolled or unintended fugitive emissions from the site are considered to be low and would be associated with the storage and use of oil. The risk assessment with regards to uncontrolled or unintended fugitive emissions is presented in Table 3-3 below.

Table 3-3 – Uncontrolled or Unintended Fugitive Emissions Risk Assessment

Hazard Receptor Pathway Risk Management Probability of Consequence What is the Exposure overall risk?

What has What is at How can the What measures will you take to reduce How likely is What is the harm What is the risk the potential risk? What hazard get the risk? If it occurs who is responsible this contact? that can be that still to cause do I wish to to the for what? caused? remains? The harm? protect? receptor? balance of probability and consequence.

Failure of Nearest Air All equipment is included in a preventative Very Low- Low – Nuisance Not significant engine residential maintenance programme to ensure they are Mitigation to amenity for provided equipment management properties maintained in optimal condition in measures in housing within the is operated in system are located accordance with manufacturer’s place should locality. accordance with 160m to the recommendations. ensure that manufacturers South at exposure is recommendations. Any failure in the engine management Rutters minimised. system will either send an alarm and the Close equipment would be manually shutdown via the control software or it would not be able to operate and would thus not start. Any unusual emissions to be investigated immediately in accordance with procedures within the EMS. Record and act on complaints in accordance with the EMS.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 14 of 21 3.6 VISIBLE EMISSIONS The risks associated with visible emissions are considered to be very low and would be associated with the operation of the diesel generators. The risk assessment with regards to visible emissions is presented in Table 3-4 below.

Table 3-4 – Visible Emission Risk Assessment

Hazard Receptor Pathway Risk Management Probability of Exposure Consequence What is the overall risk?

What has What is at How can What measures will you take How likely is this What is the What is the risk that still the risk? What the to reduce the risk? If it occurs contact? harm that can remains? The balance of potential do I wish to hazard who is responsible for what? be caused? probability and to cause protect? get to the consequence. harm? receptor?

Visible Neighbouring Air Generators are maintained Very Low- Mitigation Very Low – Not significant provided emissions commercial under a preventative measures in place should Nuisance to equipment is operated in from properties maintenance programme in ensure that exposure is amenity for accordance with diesel accordance with manufacturers minimised. housing within manufacturers Nearest generators recommendations. the locality. recommendations. residential Fuel is low in moisture properties Generators are for emergency and would not readily are located back-up generation and would generate a plume. 160m to the only operate in the event of a South at grid failure outside of Rutters performance testing. Close Any observed plumes would be investigated immediately in accordance with procedures within the EMS.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 15 of 21 3.7 DISCHARGES The risk assessment with regards to discharges into the receiving environment is presented in Table 3-5 below.

Table 3-5 – Discharges Risk Assessment

Hazard Receptor Pathway Risk Management Probability of Consequence What is the Exposure overall risk?

What has What is at How can the What measures will you take to reduce the How likely is this What is the What is the risk the risk? What hazard get risk? If it occurs who is responsible for contact? harm that can that still remains? potential do I wish to to the what? be caused? The balance of to cause protect? receptor? probability and harm? consequence.

Emissions Neighbouring Air Generators are maintained under a Very Low- Very Low – Not significant to Air commercial preventative maintenance programme in Mitigation Nuisance to provided equipment is properties accordance with manufacturers measures in place amenity for operated in recommendations. should ensure housing within accordance with Nearest that exposure is the locality. manufacturers residential Generators are for emergency back-up minimised. recommendations. properties generation and would only operate in the are located event of a grid failure outside of performance 160m to the testing. South at Emissions from each generator set will be Rutters periodically tested for emission performance Close in accordance with the requirements set with the sites environmental permit.

Low sulphur fuel is used to minimise SO2 emissions. Any observed emissions would be investigated immediately in accordance with procedures within the EMS.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 16 of 21 Emissions Watercourse Drainage All equipment is included in a preventative Very Low- Low – Not significant to Water System maintenance programme to ensure they are Mitigation Pollution of provided equipment is The nearest maintained in optimal condition in accordance measures in place watercourse. operated in surface with manufacturer’s recommendations. should ensure accordance with water that exposure is manufacturers features are All potentially contaminated surface site minimised. recommendations and an un-named drainage passes through an oil interceptor infrastructure river 10m prior to release to surface water. Roof maintained in east and the rainwater bypasses the interceptor. Penstock accordance with Grand Union valves are fitted to isolate the site in an preventative Canal 13m emergency. maintenance south. Periodic visual inspection of discharge after programme. the interceptor for signs of oil. Any observed oil would be investigated immediately in accordance with procedures within the EMS.

Emission Land Imperfections Generators are maintained under a Very Low- Low – Not significant to Land in preventative maintenance programme in Mitigation Pollution of provided equipment is Groundwater hardstanding accordance with manufacturers measures in place land or operated in recommendations. should ensure groundwater. accordance with Landscaped that exposure is manufacturers areas Infrastructure including bunding, kerbing and minimised. recommendations and hardstanding are maintained in accordance infrastructure with a preventative maintenance programme. maintained in All infrastructure will be subject to a periodic accordance with inspection. preventative maintenance Any observed imperfections and flaws in programme. hardstanding, bunding or kerbing will be repaired as soon as practicable. Any observed emissions to land would be investigated immediately in accordance with procedures within the EMS.

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 17 of 21 3.8 ACCIDENTS The risk assessment with regards to potential accidents which could occur at the installation is presented in Table 3-6 below.

Table 3-6 – Accidents Risk Assessment

Hazard Receptor Pathway Risk Management Probability of Consequence What is the Exposure overall risk?

What has What is at How can What measures will you take to reduce How likely is this What is the What is the risk the potential risk? What the hazard the risk? If it occurs who is responsible contact? harm that can that still remains? to cause do I wish get to the for what? be caused? The balance of harm? to receptor? probability and protect? consequence.

Leak from Land Drains All deliveries will be overseen by the driver Very Low- Low – Nuisance Not significant fuel deliveries Groundwat and member of staff to ensure that should a Mitigation to amenity for provided equipment is Imperfectio and vehicles er leak occur it would be identified and measures in place housing within operated in ns in rectified immediately. should ensure the locality. accordance with hardstandin that exposure is manufacturers g All vehicles are tested annually in minimised. recommendations. accordance with their MOT to ensure their road worthiness. Spill kits are maintained at site to clean up leaks and spills should they occur. All staff are trained in managing fuel deliveries and the use of spill kits. Any observed leaks would be investigated immediately in accordance with procedures within the EMS.

Leak from Land Drains All equipment is included in a preventative Very Low- Low – Nuisance Not significant lubricating oil Groundwat maintenance programme to ensure they are Mitigation to amenity for provided equipment is Imperfectio er maintained in optimal condition in measures in place housing within operated in ns in accordance with manufacturer’s should ensure the locality. accordance with hardstandin recommendations. Engines are fitted with g

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 18 of 21 warning / shutdown with LED indication of that exposure is manufacturers shutdowns for: low oil pressure, high or low minimised. recommendations. coolant temperature, overspeed, emergency stop, failure to start, or low coolant level. Spill kits are maintained at site to clean up leaks and spills should they occur. All staff are trained in the use of spill kits. Any observed leaks would be investigated immediately in accordance with procedures within the EMS.

Leak from Land Drains All equipment is included in a preventative Very Low- Low – Nuisance Not significant transfer of oil Groundwat maintenance programme to ensure they are Mitigation to amenity for provided equipment is Imperfectio between er maintained in optimal condition in measures in place housing within operated in ns in generator accordance with manufacturer’s should ensure the locality. accordance with hardstandin sump tanks recommendations. that exposure is manufacturers g minimised. recommendations. Spill kits are maintained at site to clean up leaks and spills should they occur. All staff responsible for fuel transfer are trained in managing fuel transfers and the use of spill kits. Any observed leaks would be investigated immediately in accordance with procedures within the EMS.

Leak of Land Drains All deliveries will be overseen by the driver Very Low- Low – Nuisance Not significant chemicals Groundwat and member of staff to ensure that should a Mitigation to amenity for provided equipment is Imperfectio used for er leak occur it would be identified and measures in place housing within operated in ns in engine water rectified immediately. should ensure the locality. accordance with hardstandin treatment/anti that exposure is manufacturers g All equipment is included in a preventative freeze minimised. recommendations. maintenance programme to ensure they are maintained in optimal condition in

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 19 of 21 accordance with manufacturer’s recommendations. Spill kits are maintained at site to clean up leaks and spills should they occur. All staff are trained in managing deliveries and the use of spill kits. Spill kits are maintained at site to clean up leaks and spills should they occur. Any observed leaks would be investigated immediately in accordance with procedures within the EMS.

Fire Land Direct Water mist fire extinguisher system Very Low- Low – Smoke Not significant contact implemented. Consists of a double knock Mitigation nuisance to provided equipment is Groundwat configured system complete with own measures in place amenity for operated in er Fire water detection and alarm system, sensing and should ensure housing within accordance with run-off Air discharge heads, distribution piping and all that exposure is the locality manufacturers entering water/gas bottles located in area at rear of minimised. recommendations. drainage container. Alarm system complete with VF system contacts to interface with site systems. Controls and viewing are accessible, visible and set at appropriate height. Water cylinders fitted within an insulated / ventilated enclosure and fitted with a thermostatically controlled heater wired back to a spur connection in the consumer unit. Virtus Fire Safety and Emergency Arrangements in place

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 20 of 21 4 ACCIDENT MANAGEMENT PLAN KEY INFORMATION

The key internal and external contacts for the installation are detailed in Table 4-1 below:

Table 4-1 Accident Risk Assessment and Management Plan

Contact Position Contact Details

Daniel Burgon Compliance Manager Mobile: 07388 857021 Direct Dial: 020 3814 3140

Environment Agency - Tel: 0800 80 70 60 Incident Hotline

Environment Agency TBC TBC Site Contact

Fire, Police and - 999 Ambulance Emergency Local Fire Service Contact Local Police Service Contact Local Ambulance Service Contact

London Borough of Environmental Health Officer 01895 556000 Hillingdon

Thames Water 0800 316 9800

ENVIRONMENTAL RISK ASSESSMENT PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd Page 21 of 21 ENVIRONMENT AGENCY HABITATS ASSESSMENT MAPS

Public

Nature and Heritage Conservation

Screening Report: Bespoke installations

Reference EPR/AP3903PD/A001

NGR TQ0728980157

Buffer (m) 208 (m)

Date report produced 31/01/2019

Number of maps enclosed 4

The nature conservation sites identified in the table below must be considered in your application.

Nature and heritage Screening Further information conservation sites distance (km) Special Protection Area (pSPA or SPA) 10 Joint Nature Conservation Committee South West London Waterbodies

Ramsar 10 Joint Nature Conservation Committee South West London Waterbodies

Local Wildlife Sites (LWS) 2 Appropriate Local Record Centre (LRC) London's Canals

Wall Garden Farm Sand Heaps

Little Britain

St George's meadows, Southlands Arts Centre

River Pinn and Manor Farm Pastures

The Grove

Stockley Park Country Park Stockley Rough Road

Iron Bridge Road Railsides (formerly the Piggeries)

Carp Ponds and Broads Dock

Stockley Business Park Lakes & Meadows

Bolingbroke Way Sunken Pasture

Lake Farm Country Park

Lower Colne

Protected Screening Further Information Species distance (m) European Eel up to 500m Environment Agency. Dial 03708 506 506 for your local Fisheries and Biodiversity team

Where protected species are present, a licence may be required from Natural England or the Welsh Government to handle the species or undertake the proposed works.

The relevant Local Records Centre must be contacted for information on the features within local wildlife sites. A small administration charge may also be incurred for this service.

Please note we have screened this application for protected and priority sites, habitats and species for which we have information. It is however your responsibility to comply with all environmental and planning legislation, this information does not imply that no other checks or permissions will be required.

Please note, the enclosed pre-application map(s) is valid for a period of 6 months. If you plan to submit your application more than 6 months after the map(s) was generated, you must request that the screen is re-run. This will ensure that you have used the most current information on heritage and nature conservation interests in your application.

Local Wildlife Sites

Legend

Local Wildlife Sites

0 750 1,500 2,250

Legend

Fish migratory routes screened for Environmental Permits

0 750 1,500 2,250

Legend

Ramsar (England) Ramsar (Wales) Marine Nature Reserves Marine Conservation Zones

0 750 1,500 2,250

Legend

SPA (England) SPA (Wales)

0 934 1,869 2,803

© Crown Copyright and database rights 2019 . Ordnance Survey 100024198. Metres ENVIRONMENTAL RISK ASSESSMENT WSP Project No.: 70051165 | Our Ref No.: 70051165-ERA SP 001 February 2020 Virtus HoldCo Ltd 110 Queen Street Glasgow G1 3BX wsp.com

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