ENVIRONMENTAL IMPACT ASSESSMENT REPORT for Proposed Extension of Bulk Biologics Facility at Regeneron Ireland U.C., Raheen Business Park, County Limerick
REGEN ERON prepared for For inspection purposes only. Consent of copyright owner required for any otherIRELAND use.
on behalf of by Environmental Impact Services 1st Floor 26 -24 Ormond Quay Upper Dublin 7
December 2017
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Document Control
Document Control Author/Reviewer Date
Prepared by Andrew Reynolds, Paul Fingleton, various dates to 04th December and other contributors listed in 2017 Table 1.1
Reviewed Paul Fingleton & Andrew Reynolds Various dates to 04th December by 2017
Status Final issue for submission
For inspection purposes only. Consent of copyright owner required for any other use.
by Environmental Impact Services i
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Table of Contents
Table of Contents 1 INTRODUCTION ...... 1
1.1 INTRODUCTION AND TERM OF REFERENCE ...... 1 1.2 EIAR FORMAT ...... 2 1.3 STUDY TEAM ...... 3 1.4 IMPACT PREDICTIONS ...... 5 1.5 DIFFICULTIES ENCOUNTERED ...... 6 1.6 LEVEL OF DETAIL IN PROJECT DESCRIPTION ...... 7 2 SCREENING & SCOPING ...... 8
2.1 LEGISLATION AND GUIDANCE ...... 8 2.2 SCREENING ...... 10 2.3 SCOPING ...... 10 3 ALTERNATIVES ...... 13
3.2 INTRODUCTION ...... 13 3.3 ALTERNATIVE OPTIONS CONSIDERED ...... 14 4 PROJECT DESCRIPTION...... 15
4.1 PERMANENT ELEMENTS...... 15 4.2 CONSTRUCTION PHASE ...... 18 5 POPULATION & HUMAN HEALTH ...... 20
5.1 INTRODUCTION ...... 20 5.2 THE PROPOSED DEVELOPMENT ...... 20 5.3 THE EXISTING ENVIRONMENT ...... 20 5.4 PREDICTED IMPACTS ...... 25 5.5 MITIGATION MEASURES ...... 26 5.6 RESIDUAL IMPACTS ...... 27 6 BIODIVERSITY ...... 28 For inspection purposes only. 6.1 INTRODUCTION ...... Consent ...... of copyright owner required ...... for any other use...... 28
6.2 CHARACTERISTICS OF THE PROPOSED DEVELOPMENT ...... 32 6.3 RECEIVING ENVIRONMENT ...... 32 6.4 POTENTIAL IMPACTS ...... 44 6.5 MITIGATION MEASURES ...... 45 6.6 CUMULATIVE IMPACTS ...... 46 6.7 RESIDUAL IMPACTS ...... 46 6.8 MONITORING ...... 46 7 LAND, SOILS, GEOLOGY & HYDROGEOLOGY ...... 47
7.1 INTRODUCTION/METHODOLOGY ...... 47 7.2 THE PROPOSED DEVELOPMENT ...... 48 7.3 THE RECEIVING ENVIRONMENT ...... 49 7.4 PREDICTED IMPACTS ...... 60 7.5 MITIGATION MEASURES ...... 61 7.6 RESIDUAL IMPACTS ...... 64 8 WATER & HYDROLOGY ...... 65
8.1 INTRODUCTION/METHODOLOGY ...... 65 8.2 METHODOLOGY ...... 65 8.3 THE PROPOSED DEVELOPMENT ...... 66 8.4 THE RECEIVING ENVIRONMENT ...... 68
by Environmental Impact Services ii
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Table of Contents
8.5 PREDICTED IMPACTS ...... 75 8.6 MITIGATION MEASURES ...... 77 8.7 RESIDUAL IMPACTS ...... 79 9 AIR QUALITY & CLIMATE ...... 80
9.1 INTRODUCTION & METHODOLOGY ...... 80 9.2 THE PROPOSED DEVELOPMENT ...... 82 9.3 THE RECEIVING ENVIRONMENT ...... 83 9.4 PREDICTED IMPACTS ...... 85 9.5 MITIGATION MEASURES ...... 89 9.6 RESIDUAL IMPACTS ...... 89 10 NOISE & VIBRATION ...... 90 10.1 INTRODUCTION ...... 90 10.2 THE PROPOSED DEVELOPMENT ...... 90 10.3 THE RECEIVING ENVIRONMENT ...... 91 10.4 PREDICTED IMPACTS ...... 94 10.5 MITIGATION MEASURES ...... 103 10.6 RESIDUAL IMPACTS ...... 104 11 LANDSCAPE & VISUAL IMPACT ...... 105
11.1 INTRODUCTION ...... 105 11.2 THE PROPOSED DEVELOPMENT ...... 105 11.3 RECEIVING ENVIRONMENT ...... 106 11.4 CHARACTER & APPEARANCE...... 107 11.5 PREDICTED IMPACTS ...... 111 11.6 MITIGATION MEASURES ...... 113 12 MATERIAL ASSETS ...... 114
12.1 INTRODUCTION ...... 114 12.2 ELECTRICAL SUPPLY ...... 114 12.3 GAS CONNECTION ...... 114 12.4 WATER ...... 115 12.5 TELECOMS ...... 115 For inspection purposes only. Consent of copyright owner required for any other use. 13 TRAFFIC & TRANSPORTATION ...... 116
13.1 INTRODUCTION/METHODOLOGY ...... 116 13.2 THE PROPOSED DEVELOPMENT ...... 117 13.3 THE RECEIVING ENVIRONMENT ...... 117 13.4 PREDICTED IMPACTS ...... 119 13.5 MITIGATION MEASURES ...... 122 13.6 RESIDUAL IMPACTS ...... 123 14 WASTE MANAGEMENT ...... 124
14.1 INTRODUCTION / METHODOLOGY ...... 124 14.2 THE PROPOSED DEVELOPMENT ...... 125 14.3 THE RECEIVING ENVIRONMENT ...... 128 14.4 PREDICTED IMPACTS ...... 129 14.5 MITIGATION MEASURES ...... 130 14.6 RESIDUAL IMPACTS ...... 131 15 ARCHAEOLOGY & ARCHITECTURAL HERITAGE ...... 133
15.1 INTRODUCTION ...... 133 15.2 METHODOLOGY ...... 134 15.3 THE PROPOSED DEVELOPMENT ...... 135
by Environmental Impact Services ii
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Table of Contents
15.4 THE RECEIVING ENVIRONMENT ...... 135 15.5 PREDICTED IMPACTS ...... 151 15.6 MITIGATION MEASURES ...... 151 15.7 RESIDUAL IMPACTS ...... 152 16 INTERACTIONS & CUMULATIVE EFFECTS ...... 153
16.1 INTRODUCTION ...... 153 16.2 MATRIX OF INTERACTIONS ...... 153 16.3 INTERACTIONS AND CUMULATIVE EFFECTS ...... 155
List of Figures Figure 1.1 Site Location ...... 1 Figure 4.1 Proposed Site Plan ...... 16 Figure 4.2 Proposed Elevations ...... 17 Figure 6.1 NHA’s and proposed pNHA’s within the zone of influence...... 34 Figure 6.2 SAC’s and SPA’s within the zone of influence ...... 34 Figure 6.3 Site location within the NBDC hectad (10 x 10 km Grid Square); R55...... 38 Figure 6.4 Habitats present on site ...... 40 Figure 6.5: Habitat map of significant habitats adjacent to the Regeneron Site ...... 41 Figure 6.6 Farm buildings and farmyard in site no. 47 ...... 42 Figure 7.1 Soil Maps ...... 50 Figure 7.2 Site Investigation Locations ...... 51 Figure 7.3 Site Geology ...... 52 Figure 7.4 Aquifer Classification ...... 53 Figure 7.5 Aquifer Vulnerability Map ...... 54 Figure 7.6 Aquifer Vulnerability Map ...... 55 Figure 7.7 GSI Well Search ...... 57 Figure 7.8 Site Conceptual Site Map ...... 58 Figure 7.9 Regional Cross Section ...... 59 Figure 8.1 Local Hydrology ...... 68 Figure 8.2 River Catchment Map and Quality For inspection ...... purposes only...... 71 Consent of copyright owner required for any other use. Figure 9.1 Shannon Airport Windrose 2011 – 2015...... 81 Figure 9.2 Maximum 1-Hour NO2 Concentrations (as a 99.8th%ile) (µg/m3) ...... 87 3 Figure 9.3 Annual Mean NO2 Concentrations (µg/m ) ...... 87 Figure 10.1 Site Context and Noise Sensitive Receivers ...... 91 Figure 11.1 External Context ...... 106 Figure 11.2 Internal Context ...... 106 Figure 11.3 The Site [red] in the Landscape Context ...... 107 Figure 11.4 Existing Views towards the site from surrounding roads ...... 108 Figure 11.5 Views or Prospects ...... 109 Figure 11.6 Landscape Character Areas ...... 110 Figure 15.1 Location of Recorded Monuments and Protected Structures (RPS)...... 143 Figure 15.2 Down Survey Map of the Barony of Pubblebrien, 1654-56 ...... 146 Figure 15.3 First Edition Ordnance Survey Map, 1844 ...... 146 Figure 15.4 Ordnance Survey Map, 1901 ...... 147 Figure 15.5 Third Edition Ordnance Survey Map, 1918-24 ...... 147 Figure 15.6 Aerial photography of the site ...... 148 Figure 15.7 Site of proposed extension looking north-west ...... 149 Figure 15.8 Site of proposed car park extension looking south-west ...... 149
by Environmental Impact Services iii
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Table of Contents
List of Tables
Table 1.1 Study Team for EIAR ...... 3 Table 1.2 Impact Predictions ...... 6 Table 2.1 Coverage of key changes arising from EIA Directive 2014/52/EU in this EIAR ...... 9 Table 5.1 Population Change at Sate, Secondary and Primary Hinterland Level ...... 22 Table 5.2 Age Profile at State, Secondary and Primary Hinterland Level, 2006 ...... 22 Table 5.3 Age Profile at State, Secondary and Primary Hinterland Level, 2011 ...... 23 Table 5.4 Age Profile at State, Secondary and Primary Hinterland Level, 2016 ...... 23 Table 5.5 Labour Force Participation Rate, 2011 ...... 24 Table 5.6 Population & Households at State, Secondary & Primary Hinterland Level ...... 24 Table 6.1 Criteria used in assessing the importance of ecological features...... 30 Table 6.2 The Designated Natura 2000 Sites within 15 km of site, or 20 km with a hydrological link 33 Table 6.3 Summary of the Ecological evaluation from the Flora and Fauna section of a previous EIS 44 Table 7.1 GSI Well Index Table from Well Search ...... 56 Table 7.2 Onsite Groundwater levels 24th April 2017 ...... 57 Table 8.1 Emission Limits to Shannon Development Pipeline SE-01 ...... 67 Table 8.2 EPA Biological Q ratings & key ...... 69 Table 8.3 EPA monitoring data for Barnakyle River ...... 70 Table 8.4 Emissions from SE-02 as per 2015 & 2016 Annual Environmental Reports ...... 72 Table 8.5 Bulk chemicals stored on site and bund capacity...... 76 Table 9.1 EU Air Quality Standards ...... 82 Table 9.2 Summary of Source Information...... 83 3 Table 9.3 Annual Mean NO2 Concentrations in Zone C Locations (µg/m ) ...... 84 Table 9.4 Dispersion Model Results at Worst Case Offsite Receptor – NO2 ...... 86 Table 9.5 Dispersion Model Results at Worst Case Offsite Receptor - CO ...... 88 Table 10.6 Summary of Measured Noise Levels at NSL 1 ...... 93 Table 10.7 Summary of Measured Noise Levels at NSL 2 ...... 94 Table 10.8 Example Threshold of Significant Effect at Dwellings ...... 95 Table 10.9 Rounded Baseline Noise Levels and Associated Categories ...... 95 Table 10.10 Allowable Vibration during Construction Phase ...... 96 Table 10.11 External Noise Limits from Licenced Sites ...... 96 Table 10.12 Proposed Operational Noise CriFor teriainspection ...... purposes only...... 98 Table 10.13 Likely Impacts AssociatedConsent with of copyright Change owner in required Traffic for anyNoise other use.Level ...... 98
Table 10.14 Predicted Noise Emission Levels at Nearest NSL during Construction Phase ...... 99 Table 10.15 Review of Predicted Changes in Existing Noise Levels ...... 103 Table 13.1: Annual Average Growth Rates for Mid-West region...... 118 Table 13.2: Baseline (2-way) AADT 2017 ...... 118 Table 13.3: Projected (2-way) AADT 2021 ...... 118 Table 13.4: Projected (2-way) AADT 2026 ...... 119 Table 13.5: Projected (2-way) AADT 2036 ...... 119 Table 13.6: Traffic Increase Associated with the Development Construction AADT (2-way) ...... 120 Table 13.7: Traffic Increase against 2021 Opening Year Baseline AADT (2-way) ...... 121 Table 13.8: Traffic Increase against 2021 Opening Year + 5 Baseline AADT (2-way) ...... 121 Table 13.9: Traffic Increase against 2021 Opening Year + 15 Baseline AADT (2-way) ...... 121 Table 15.1 Recorded monuments within 2 km of the development site boundary ...... 143 Table 15.2 Summary of Residual Impacts ...... 152 Table 16.1 Matrix of Interactions ...... 154
by Environmental Impact Services iv
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Table of Contents
List of Appendices The Appendices are contained in a separately bound volume.
Appendix to Section 2. Screening & Scoping Appendix 2.1 Draft Scoping Report
Appendix to Section 4. Project Description Appendix 4.1 Regeneron Detailed Description of Manufacturing Process
Appendix to Section 6. Biodiversity Appendix 6.1 Rare & Protected Species Recorded within the NBDC R55 Hectad
Appendix to Section 7. Soils, Geology & Hydrogeology Appendix 7.1 Impact Ratings & Assessment Criteria Appendix 7.2 Soil Results Appendix 7.3 Groundwater Results
Appendix to Section 8. Water & Hydrology Appendix 8.1 EPA Guidelines
Appendix to Section 9. Air Quality & Climate Appendix 9.1 Description of AERMOD Model
Appendix to Section 10. Noise & Vibration Appendix 10.1 Acoustic Terminology Appendix 10.2 Fundamentals of Acoustics Appendix 10.3 Baseline Noise Reports
Appendix to Section 14. Waste Management Appendix 14.1 Construction & Demolition Waste Management Plan
Compendium of Mitigation Measures 6. Biodiversity 7. Land, Soils, Geology & Hydrogeology For inspection purposes only. 8. Water & Hydrology Consent of copyright owner required for any other use. 9. Air Quality & Climate 10. Noise & Vibration 11. Landscape & Visual Impact 13. Traffic & Transport 14. Waste Management 15. Archaeology & Architectural Heritage
by Environmental Impact Services v
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Introduction
1 INTRODUCTION
1.1 INTRODUCTION AND TERM OF REFERENCE
1.1.1 GENERAL Environmental Impact Services has been commissioned by Jacobs to carry out an Environmental Impact Assessment (EIA) and prepare an Environmental Impact Statement Report (EIAR) for the proposed extension of Regeneron Ireland U.C.’s (hereafter referred to as Regeneron) bulk biologics facility.
The proposed project consists of a single storey extension to an existing biopharmaceutical manufacturing facility.
The proposed extension will be approx. 14.4 m high and have a total floor area of approx. 12,707 m2. This will accommodate 3 to 4 new biopharmaceutical manufacturing suites. The proposal includes a plant room, waste handling facility, plant and equipment mezzanines, a revised dock area and various other supporting elements including two new 20 m boiler stacks. A permanent new car park for 150 cars is also included in the proposal. A temporary contractors’ car park for 350 spaces is also proposed.
The existing facility includes a quality control laboratory building, external utilities and a 685 space car park. The total existing floor area is approximately 53,000 m2 and the existing site is approx. 12 ha in extent.
The description included in Section 4 of this EIAR describes the proposal in more detail and the further details are included in the planning application documents and drawings which accompany this EIAR in the application for planning permission to Limerick City & County Council.
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 1.1 Site Location
by Environmental Impact Services 1
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Introduction
1.1.2 OBJECTIVES OF THIS EIAR The core objectives of this EIAR are to predict any significant environmental impacts that are likely to occur due to the proposed development and, where applicable, propose measures to avoid, reduce or remedy them.
It reports on the findings of the EIA process to date and informs the Planning Authority (Limerick City & County Council), statutory consultees, other interested parties and the public in general about the likely effects of the project on the environment.
In doing this the EIAR has been prepared in compliance with the EU Directive on EIA. Section 2 provides details of the Directive as well as the Irish legislation that has been followed and the guidelines that have been taken into account. The relationship between this EIAR and other assessments prepared under separate legislation is also discussed in Section 2.
1.2 EIAR FORMAT
This EIAR follows a grouped format structure. Using this structure the EIAR examines each environmental topic in a separate section. These sections generally follow this format: -
. Introduction/methodology . the proposed development; . the receiving environment; . predicted (likely significant) impacts; . mitigation measures; and . residual impacts (where relevant).
Interactions between issues that arise in separate sections are assessed as they occur in each section. Cumulative effects are similarly assessed as appropriate in the relevant sections of the EIAR. The final section of the EIAR, Section 16 Interactions & Cumulative Effects, shows where interactions and cumulative effects have been identified and how they have been addressed.
Section 2 Screening & Scoping, gives more detail on the issues addressed under each heading.
Separate reports prepared in accordance Forwi inspectionth other purposes (non only. EIA) requirements cover other topics. A full Consent of copyright owner required for any other use. list of these is provided in the Planning Report. They include: . Appropriate Assessment (AA) Screening Report . Flood Risk Assessment (FRA) Screening Report . Traffic and Transportation Assessment (TTA) Report . Mobility Management Plan (MMP) . Civil Drainage Report and a . Planning Application Report
Some of these reports are also relevant in the consideration of the prescribed EIA topics so these are referred to in the EIAR, as and where appropriate. For example, the Water & Hydrology section refers to the FRA Screening and Civil Drainage Reports, the Traffic & Transportation section refers to the TTA Report and MMP and the Biodiversity section refers to the AA Screening Report.
The Mitigation Measures proposed in an EIAR constitute important and enforceable undertakings about the details of how a project is developed and managed. For ease of comprehension – especially during the Environmental Impact Assessment process by Consenting Authorities – it has proven useful to have an overview of all of the measures that are proposed within the EIAR to mitigate adverse effects. The Compendium of Mitigation measures included in the appendices provides a collection of all of the mitigation measures that are proposed.
by Environmental Impact Services 2
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Introduction
1.3 STUDY TEAM
Table 1.1 Study Team for EIAR Role Personnel Company Study Director Conor Skehan Environmental Impact Services Study Manager Paul Fingleton Environmental Impact Services Study Coordinator Andrew Reynolds Environmental Impact Services Specialist Topics (Section 2 Scoping sets out the basis for selection of these topics) Population & Human Health Tómas Glancy AOS Planning Biodiversity Andrew Torsney Environmental Impact Services Land, Soils, Geology & Teri Hayes & Paul Conaghan AWN Consulting Hydrogeology Water & Hydrology Teri Hayes & Paul Conaghan AWN Consulting Air Quality & Climate Dr. Edward Porter & Ciara AWN Consulting Nolan Noise and Vibration Dr. Stephen Smyth AWN Consulting Landscape Conor Skehan Environmental Impact Services Material Assets Paul Fingleton & Andrew Environmental Impact Services Reynolds Traffic & Transportation Joseph Campbell & Brian Jacobs Engineering Sloey Waste Management Robert Hunt AWN Consulting Archaeology & Cultural Heritage Donald Murphy Archaeological Consultancy Services Unit Interactions Paul Fingleton Environmental Impact Services For inspection purposes only. & Cumulative Effects Consent& Andrew of copyright Reynolds owner required for any other use.
Study Director - Conor Skehan (BSC), (MLArch) Master of Landscape Architecture, University of Pennsylvania, 1983. Conor has been chartered by a number of professional Institutes including the International Association for Impact Assessment; the Irish Landscape Institute; the Royal Institute of the Architects of Ireland; and the Irish Planning Institute. He co-founded and served as President of the Irish Landscape Institute from 1993 to 1994. Environmental Impact Services is a Registered Assessor member of the Institute of Environmental Assessment (UK). Conor is an Architect, Landscape Architect, Strategic Planner, Impact Analyst, academic and writer.
He has worked for over 30 years in many countries providing strategic and spatial planning and environmental consultancy to a wide range of government, public and private clients on assignments varying in scale from very large-scale infrastructural and industrial projects to large urban renewal and tourism projects. He has made significant contributions to a wide range of complex Environmental Impact Statements, planning applications and environmental reports for Industry (ICT, Bio-pharma) , Infrastructure (road, rail, airport, port, power, energy waste, drainage and water supply), Institutions (hospital, prison projects) as well as major urban renewal and extension projects
Study Manager, Paul Fingleton has an MSc in Rural and Regional Resources Planning (with specialization in EIA), University of Aberdeen, 1990. Paul is a member of the International Association for Impact Assessment as well as the Institute of Environmental Management and Assessment. Paul has over twenty years’ experience working in the area of Environmental Assessment. Paul has been
by Environmental Impact Services 3
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Introduction involved in a diverse range of projects including contributions to, and co-ordination of, a number of complex EIARs, NISs and / or IPPCL Applications for projects.
Study Coordinator - Andrew Reynolds has a BSc in Environmental Planning and Management, Dublin Institute of Technology, 2015. Andrew has contributed to a number of complex Environmental Impact Statements, planning applications and environmental reports. He has experience working as part of team projects and in the preparation of EIA documents on behalf of multi-nationals and infrastructural providers for a diverse range of projects.
Population & Human Health - Tomás Glancy has a BSc in Spatial Planning, Dublin Institute of Technology, 2015. Tomás is a member of the Irish Planning Institute (IPI). Tomás experience working as part of team projects and in the preparation of planning and EIA documents on behalf of multi-nationals and infrastructural providers. He also liaises with the various government agencies and local authorities in order to assimilate the environmental baseline information that is used in SEAs and EIAs and assists in the preparation of the various SEA and EIA related documentation.
Biodiversity - Andrew Torsney has an MRes in in Biodiversity and Conservation from the University of Leeds. Andrew is a full member of the Chartered Institute of Ecology and Environmental Management (MCIEEM). Andrew has over five years’ experience working as an Ecologist on both national and local scale projects. His experience ranges from academic research which has been implemented by practical management to extensive consultancy work. Andrew has designed and coordinated ecological elements of Environmental Impact Assessments (EIA) for multiple large scale projects.
Land, Soils, Geology & Hydrogeology and Water & Hydrology - Dr. Teri Hayes, BSc, MSc in Hydrogeology, 1990. Teri is a member of the International Association of Hydrogeologists (Irish Group) – former president and the Institute of Geologists of Ireland – Professional Member. Teri is a Director with AWN with 22 years of experience in water resource management and environmental assessment and remediation. She has contributed to numerous environmental impact assessments and design of appropriate mitigation measures, acted as an expert witness at public hearings, lectured in EIA and providing expert advice on EIA sections for planning authorities. Paul Conaghan – Environmental Consultant with AWN Consulting Ltd., with over 7 years’ experience working in environmental science and environmental engineering fields. Paul holds a Degree in Environmental Science from UL and a Masters in Environmental Engineering from Queens University Belfast and is a member of the International Association of Hydrogeologists. For inspection purposes only. Consent of copyright owner required for any other use. Air Quality & Climate - Dr. Edward Porter is Director of AWN Consulting with responsibility for Air Quality Assessment. He holds a BSc (Hons) from the University of Sussex (Chemistry), has completed a PhD in Environmental Chemistry (Air Quality) in UCD where he graduated in 1997 and is a Full Member of the Royal Society of Chemistry (MRSC CChem). He specialises in the fields of air quality, EIA and air dispersion modelling. Ciara Nolan – is an Environmental Consultant in the Air Quality section of AWN Consulting. She holds a BSc in Energy Systems Engineering from University College Dublin and has also completed an MSc in Applied Environmental Science at UCD. She is an Associate Member of the Institute of Air Quality Management. She specialises in the fields of ambient air monitoring, indoor air monitoring and EIA.
Noise and Vibration - Dr. Stephen Smyth is principal acoustic consultant holds for AWN Consulting. He holds a BAI and a PhD in Mechanical Engineering from TCD and is a member of Engineers Ireland and an Associate Member of the Institute of Acoustics. He has experience in both environmental and building acoustics, and has coordinated the data capture survey of Northern Ireland’s major road and rail networks and Belfast City in preparation of noise maps as required under the European Noise Directive.
Traffic & Transportation, Colin Wyllie has a BEng (Hons) in Civil and Transportation Engineering, Napier University, 1998 and has over eighteen years’ experience providing transport planning advice on a wide range of complex, large scale development and infrastructure projects. Colin is a member
by Environmental Impact Services 4
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Introduction of the Chartered Institution of Highways & Transportation and the Society of Road Safety Auditors. Colin has advised on numerous planning applications across the UK and Ireland in terms of traffic impact analysis relevant to TTAs and Environmental Impact Statements.
Waste Management, Robert Hunt is a Senior Consultant with AWN Consulting Ltd, with over 6 years’ experience in environmental consultancy and waste management. Robert Hunt has an BEng from UCD and a Masters in Environmental Engineering and has worked on many industrial pharmaceutical project developments over the last 6 years.
Archaeology & Architectural Heritage, Donald Murphy MSC from University College Dublin has over 20 years’ experience in professional archaeology having founded Archaeological Consultancy Services Unit. Having carried out some large-scale excavations between 1992 and 1997 for various clients including local authorities and state agencies, he then acted as archaeological advisor and consultant on some of the largest infrastructural projects between 1996 and 2009. Since 2009 he has focused on the publication of some of the major excavations and also acted as archaeological consultant on some Windfarm projects which were successfully seen through the process from inception to planning and construction. He continues to provide a full range of archaeological services through the firm originally founded in 1992 and which continues in operation today.
1.4 IMPACT PREDICTIONS
Rating of potential environmental impacts in the specialist sections is shown in Table 1.2 and is in accordance with the Glossary of Impacts contained in the EPA Guidelines1, except where otherwise stated. This takes account of the quality, significance, duration and type of impact characteristic identified.
In this EIAR, consideration is given to both the importance of an attribute and the magnitude of the potential environmental impacts of the proposed activities on that attribute.
The duration of each impact is considered to be either temporary, short-term, medium term, long- term, or a permanent impact. Temporary impacts are considered to be those which are construction related and last less than one year. Short term impacts are seen as impacts lasting one to seven years; medium-term impacts lasting seven to fifteen years; long-term impacts lasting fifteen to sixty years; and permanent impacts lasting over sixty years. For inspection purposes only. Consent of copyright owner required for any other use.
1 Guidelines on the information to be contained in Environmental Impact Statements, EPA, 2002 (Section 5)
by Environmental Impact Services 5
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Introduction
Table 1.2 Impact Predictions2 Impact Term Description Characteristic Positive A change which improves the quality of the environment A change which does not affect the quality of the Quality Neutral environment Negative A change which reduces the quality of the environment An impact capable of measurement but without noticeable Imperceptible consequences
An impact which causes noticeable changes in the character Slight of the environment without affecting its sensitivities Significance
An impact that alters the character of the environment in a Moderate manner consistent with existing and emerging trends
An impact, which by its character, magnitude, duration or Significant intensity alters a sensitive aspect of the environment
Profound An impact which obliterates sensitive characteristics Short-term Impact lasting one to seven years Duration Medium-term Impact lasting seven to fifteen years Long-term Impact lasting fifteen to sixty years Permanent Impact lasting over sixty years Temporary Impact lasting for one year or less The addition of many small impacts to create one larger, Cumulative more significant impact The environment as it would be in the future should no ‘Do Nothing’ development of any kind be carried out
When the full consequences of a change in the environment Indeterminable cannot For inspection be described purposes only. Consent of copyright owner required for any other use. Type When the character, distinctiveness, diversity, or reproductive Irreversible capacity of an environment is permanently lost Degree of environmental change that will occur after the Residual proposed mitigation measures have taken effect Where the resultant impact is of greater significance than the Synergistic sum of its constituents The impacts arising from a development in the case where ‘Worst Case’ the mitigation measures may substantially fail
1.5 DIFFICULTIES ENCOUNTERED
The EIA Regulations require that difficulties such as technical deficiencies, lack of information or knowledge encountered in compiling any specified information for the EIAR be described. In general, there were no significant difficulties encountered in the production of this EIAR. Any issues encountered during assessment of individual factors are as noted within the specialist sections.
2 Adapted from Glossary of Impacts contained in EPA, Guidelines on the information to be contained in Environmental impact Statements, 2002
by Environmental Impact Services 6
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Introduction
1.6 LEVEL OF DETAIL IN PROJECT DESCRIPTION
Some of the information provided in the description of the project (Section 4) will be subject to slight changes for these reasons:
All descriptions of proposed developments are approximations compared to the finished development. The nature of the construction process limits the amount of detail that is available at this planning consent stage to documentation that may be decried as ‘General Arrangement Illustrations’.
While a construction management plan is provided – some of the details of how the project is built will be a matter for the contractor who is awarded the project following a competitive tendering process. However it will need to be ensured that the environmental effects of any c summary and taken not selectively or out of context.
For inspection purposes only. Consent of copyright owner required for any other use.
by Environmental Impact Services 7
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Screening & Scoping
2 SCREENING & SCOPING
2.1 LEGISLATION AND GUIDANCE
EIAs are carried out in response to the requirements of the European Directives on the assessment of the effects of certain public and private projects on the environment, as codified in Directive 2011/92/EU. The enabling statutory instruments (S.I.s) which transpose these Directives into law in Ireland are the European Communities (Environmental Impact Assessment) Regulations, 1989, as updated by the Planning and Development Acts 2000 to 2006 (the EIA Regulations), with the main legislation being S.I. 600/01. These Regulations outline the classes of projects subject to Environmental Impact Assessment (EIA) and the statutory format and content for an EIAR.
This EIAR has been prepared in accordance with the above and has regard to other relevant regulations such as the Environmental Protection Agency (EPA) Guidelines on information to be contained in Environmental Impact Statements (EPA 2002), the EPA Advice Notes on Current Practice in preparation of Environmental Impact Statements (EPA 2003) and relevant European Commission guidance documents3.
A revised EIA Directive 2014/52/EU was adopted by the European Council on of 16 April 2014. This amends Directive 2011/92/EU. The deadline for Member States to bring into force the laws, regulations and administrative provisions necessary to comply with the amended Directive was 16 May 2017. As the amended Directive has come into force but regulations transposing it into national legislation have not been yet been enacted, the principle of direct effect applies.
The key changes affecting the information to be contained in an EIAR are set out in Table 2.1 below.
The EPA has made draft revised Guidelines on the information to be contained in Environmental Impact Assessment Reports (2017) available. While these are subject to further review by the EPA including changes to ensure alignment with the transposing legislation, they do indicate the changes that are likely to be introduced, particularly changes in the information that will be required to be contained in an EIAR to make it compliant with the new legislation. This EIAR has been prepared to comply with the current regulations and to anticipate and address the new requirements introduced by Directive 2014/52/EU. It follows the Forcur inspectionrent Guidelines purposes only. while also taking account of the changes Consent of copyright owner required for any other use. contained in the draft revised Guidelines.
An Appropriate Assessment (AA) Screening has also been carried out to assess the potential of the proposal to affect the integrity of the Natura 2000 network. Its findings are provided in an AA Screening Report which is included as a separately bound document within the planning application document set. The findings of the screening report are referred to in the Biodiversity section of this EIAR, without duplicating its contents.
The relationship between this EIAR and other assessments prepared under separate legislation is discussed in Section 2.3.2.
3 Including EIA-Guidance on Screening, EIA-Guidance on Scoping and EIA Review Checklist, all 2001, EC.
by Environmental Impact Services 8
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Screening & Scoping
Table 2.1 Coverage of key changes arising from EIA Directive 2014/52/EU in this EIAR
Change Notes on Coverage in this EIAR Section / Document Reference(s) Mandatory assessment of Covered Section 3 ‘reasonable alternatives’ Consideration of Alternatives Factor of Human Beings This change clarifies the meaning of Sections 5 to 14 and replaced by Population & Human Beings as Population & Human Section 16 Human Health Health. Population is covered by a socio-economic assessment of the proposal. Human Health is addressed under the various factors through which effects on human health could be caused, e.g. Air Quality, Noise, Traffic. Factor of Flora & Fauna This change in title aligns with current Section 6 Biodiversity replaced by Biodiversity terminology and does not affect the scope of this factor. Introduction of topic of Land This is largely intended to cover the effects Section 7 Land, Soils, of removal of land from other productive Geology & uses, primarily agricultural production. Hydrogeology Environmental effects of There are no risks to the site, e.g. due to The separate Flood climate change risks to the flooding of chemical storage areas which Risk Assessment development could affect surrounding flooded areas, Screening Report that would have significant potential to considers flood risk cause environmental effects. Requirement for competent The study team are all appropriately Section 1.3 Study experts to prepare the EIAR qualified, experienced and expert in their Team respective fields. Requirement for mitigation Mitigation and monitoring measures Sections 5 to 15 of and monitoring proposals to proposed in the EIAR are clearly set out so the EIAR and be included in consent that they can be readily referred to or Appendix 1.1 permission while avoiding included For in inspection planning purposes condition. only. Duplication Compendium of duplication of monitoring ofConsent monitoring of copyright required owner required under for any other other use. EU Mitigation Measures under other EU legislation legislation such as Waste or Industrial Emissions Licencing is avoided. Requirement to consider Covered. Ref. section 2.3.2 assessments carried out under other EU Directives, while avoiding duplication of assessment
by Environmental Impact Services 9
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Screening & Scoping
2.2 SCREENING
The legislation4 specifies classes of development and thresholds for determining which projects should be subject to EIA. Projects that fall into any of the specified project types or exceed the thresholds automatically require EIA. The legislation sets out criteria for deciding whether ‘sub-threshold’ projects should be subject to EIA.
This proposal falls into Class 6 in Schedule 5, Part 1 of the 2001 Regulations:
Integrated chemical installations, i.e. those installations for the manufacture on an industrial scale of substances using chemical conversion processes, in which several units are juxtaposed and are functionally linked to one another and which are-
(e) for the production of basic pharmaceutical products using a chemical or biological process
As it is an extension to an existing facility, the applicable size threshold is as set out under Class 13 of Part 2 of the 2001 Regulations:
Changes, extensions, development and testing (a) Any change or extension of development which would:- (i) result in the development being of a class listed in Part 1 or paragraphs 1 to 12 of Part 2 of this Schedule, and (ii) result in an increase in size greater than- - 25 per cent, or - an amount equal to 50 per cent of the appropriate threshold, whichever is the greater.
The existing facility is approximately 53,000 m2 in floor area. The total floor area of the proposed extension is approximately 12,707m2. This is an increase in size of approximately 20% which is 5% less than the 25% threshold. The project may thus be considered to be ‘sub-threshold’. In the context of the ‘wide scope and broad purpose’ of the Directive, sub-threshold projects are further screened by consideration against the criteria set out in Schedule 7 of the Regulations. Guidance on screening of sub-threshold projects is given in Environmental Impact Assessment (EIA) Guidance for Consent Authorities regarding Sub - threshold For inspection Development purposes only. (Department of the Environment, Heritage Consent of copyright owner required for any other use. and Local Government, 2003).
Considering the schedule 7 criteria, the Guidance, the ‘wide scope and broad purpose’ of the Directive and the nature and scale of the proposal it is considered prudent that it should be accompanied by an EIAR.
2.3 SCOPING
2.3.1 BASIS OF SCOPING FOR THIS EIAR Scoping is the process of identifying potential concerns that need to be examined in detail in an EIAR.
The determination of potential concerns to be addressed in this EIAR was largely based on: . the requirements of the EIA Regulations; . the requirements of the EIA Directive 2011/92/EU (as amended);
4 Particularly the Planning & Development Regulations, 2001 (S.I. 600/2001) and the EIA Directive 2011/92/EU (as amended).
by Environmental Impact Services 10
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Screening & Scoping
. the Environmental Protection Agency’s Guidelines on the information to be contained in Environmental Impact Statements (EPA, 2002) and Advice Notes on Current Practice (in the preparation of EISs) (EPA, 2003) ; . the Environmental Protection Agency’s draft Guidelines on the information to be contained in Environmental Impact Assessment Reports (EPA 2015); and . experience of the project team in preparing previous Environmental Impact Statements and EIARs.
The scoping process included circulation to and discussion of a draft scoping document with Limerick City & County Council. This is included as Appendix 2.1 to this EIAR. The sections which follow all follow the requirements of the agreed scope. The scope continued to be developed throughout the period of preparation of the EIAR.
As noted in the scoping document, the amendments to the EIA Directive include a requirement to consider the potential for the proposal to give rise to or be affected by accidents or disasters. The accompanying Flood Risk Assessment Screening report (ref section 2.3.2 below) finds that there are no significant flood risks associated with the proposal. The site is not a Seveso5 site as it does not exceed the prescribed hazard criteria. A review has found that the proposal does not change this status as the quantities and hazard rating of chemicals used at the site are low. The design of the extension and all details during fit-out and operation will be required to comply with strict design and safety standards. Compliance with these standards will ensure that risks are avoided or managed with safeguards put in place where appropriate. There is no significant environmental risk arising from elements of the proposal which could cause, or be affected by, accidents or disasters.
2.3.2 RELATIONSHIP BETWEEN THE EIAR AND ASSESSMENTS UNDER OTHER EU DIRECTIVES AND LEGISLATION This EIAR takes account of available results from other relevant assessments while avoiding duplication of those assessments, particularly the following:
The Industrial Emissions Directive (20120/75/EU) The development will be subject to an Industrial Emissions (IE) licence from the EPA. The licence will be applied for after the planning application stage and in the time for the licensing process to be completed prior to commencement of the proposed process operations in the extension. For inspection purposes only. Consent of copyright owner required for any other use. Sections 7 to 10 of this EIAR (Land, Soils, Geology & Hydrogeology, Water & Hydrology, Air Quality & Climate, Noise & Vibration and Waste Management) refer to aspects that will be covered in more detail in the IE licence application.
The Habitats and Birds Directives (92/43/EEC and 79/409/EEC) The proposal has been screened for requirement for a Natura Impact Statement (a.k.a. an Appropriate Assessment or AA). This screening has assessed the potential for the proposal to affect the integrity of the Natura 2000 network of protected sites and the findings are contained in a separate AA Screening report. Section 6, Biodiversity, takes account of the results of this screening report as relevant, without duplicating its contents.
The Waste Directive (2009/98/EC) Section 10, Waste Management, and the Construction & Demolition Waste Management Plan in Appendix 10.1 consider aspects which also fall under this Directive, as appropriate.
The Floods and Water Framework Directives (2007/60/EC and 2000/60/EC) A Flood Risk Assessment screening report and a Civil Drainage Planning Report are included as part of the planning permission application documents. The former follows the specific requirements of The Planning System and Flood Risk Management - Guidelines for Planning Authorities (OPW and the
5 Ref Seveso Directive 82/501/EEC (as amended)
by Environmental Impact Services 11
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Screening & Scoping
Department of the Environment and Local Government, 2009). Section 8 Water & Hydrology takes account of material presented in both of those reports as relevant. It also refers to requirements arising from the Water Framework Directive.
For inspection purposes only. Consent of copyright owner required for any other use.
by Environmental Impact Services 12
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Alternatives
3 ALTERNATIVES
3.1.1 LEGISLATION The Directive6 state that information to be contained in an EIAR shall include:
“(d) a description of the reasonable alternatives studied by the developer, which are relevant to the project and its specific characteristics, and an indication of the main reasons for the option chosen, taking into account the effects of the project on the environment;.”
While this wording is similar to the requirement contained in the Regulations7, the words reasonable, relevant and specific characteristics are significant changes.
3.2 INTRODUCTION
Before looking at the impacts of any development on the environment, the Planning and Development Regulations8 require the EIAR to include an outline of the main alternatives studied by the developer and an indication of the main reasons for the selected choice, taking into account the effects on the environment.
3.2.1 GUIDELINES The Environmental Protection Agency’s Guidelines on the Information to be contained in Environmental Impact Statements9 gives considerable coverage to alternatives because the consultation about the effectiveness of EIA practice found that “the acceptability and credibility of EIA findings can be significantly affected by the extent to which this issue is addressed.”
The Guidelines deal with the issue of alternatives under three key headings.
The consideration of alternative routes, sites, alignments, layouts, processes, designs or strategies, is the single most effective means of avoiding environmental impacts. The
acceptability and credibility of EIA Forfindings inspection can purposes be only. significantly affected by the extent to which this issue is addressed. Consent of copyright owner required for any other use.
However, it is important, from the outset, to acknowledge the existence of difficulties and limitations when considering alternatives. These include:
. Hierarchy . Non Environmental Factors . Site Specific Issues
6 Article 5, 1 (d) of Council Directive 2011/92/EC (as amended by Directive 2014/52/EU) 7 Schedule 6, 1 (d) of S.I. No. 600/2001 - the Planning and Development Regulations, 2001 8 2001 – 2006 (S.I 600/2001) Schedule 6 9 The 1992 Environmental Protection Agency Act (Section 72) provides for the preparation by the Environmental Protection Agency of guidelines on the information to be contained in an Environmental Impact Statement. The Act further provides that those preparing and evaluating Environmental Impact Statements shall have regard to such guidelines.
by Environmental Impact Services 13
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Alternatives
Hierarchy Many projects, especially in the area of public infrastructure, arise on account of plans, strategies and policies which have previously been decided upon. It is important to acknowledge that in some instances neither the applicant nor the competent authority can be realistically expected to examine options which have already been previously determined by a higher authority (such as a national plan or regional programme for infrastructure or a spatial plan).
Non-environmental Issues EIA is confined to the environmental effects which influence the consideration of alternatives. It is important to acknowledge that other non-environmental factors may have equal or overriding importance to the developer, e.g. project economics, land availability, engineering feasibility, planning considerations.
Site Specific Issues The consideration of alternatives also needs to be set within the parameters of the availability of land (it may be the only suitable land available to the developer) or the need for the project to accommodate demands or opportunities which are site specific. Such considerations should be on the basis of alternatives within a site e.g. design, layout.
For the purposes of the Regulations, alternatives may be described at three levels:
1. Alternative Locations 2. Alternative Designs 3. Alternative Processes
As this development is an extension to an existing facility there was minimal scope for consideration of (reasonable and relevant) separate locations or process alternatives. The examination of alternatives focussed on consideration of the preferred area for the development to be located in within the existing site and arrangement of the various required elements within the chosen area.
3.3 ALTERNATIVE OPTIONS CONSIDERED
3.3.1 SELECTION OF PREFERRED SITE AREA For inspection purposes only. The South West side of the site is Consentalready of copyrightused forowner parking required for and any otherlaboratories use. . There is no room to the
North West or South East sides. The area to the North East of the existing facility has been previously identified and reserved as an area for future expansion and it is suitable in terms of operations and logistics. It is previously disturbed ground with appropriate zoning for manufacturing activities. Locating the extension here forms a logical pattern of manufacturing islands within the enlarged facility.
3.3.2 SELECTION OF PREFERRED SITE ARRANGEMENT The preferred site arrangement maximises the available floor space on site. The utility building is placed to the south/east so that the manufacturing floor can be developed easily in phases. The new facility will utilise existing docks and laboratories.
by Environmental Impact Services 14
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Project Description
4 PROJECT DESCRIPTION
4.1 PERMANENT ELEMENTS
The proposed extension consists of a single storey manufacturing extension sized 12,707 square meters gross and 14.4 meters high. The manufacturing facility is located to the rear of the existing manufacturing building (to the south east) and consists of the following functions.:
A. A multipurpose manufacturing area sized 6,705 m2. The multi-purpose building is designed for the phased construction of manufacturing suites according to future needs. The facility is single storey using bridge trusses. The electrical and air handling needs of the manufacturing clean rooms below will be provided within these trusses. The manufacturing processes are described in Appendix 4.1.
B. A plant room area sized 1,680 m2. This facility will house boilers, chillers, compressors, purified water generation and water for injection as well as process cooling systems.
C. A waste handling facility sized 626 m2.
D. Miscellaneous mezzanines housing plant and equipment within the buildings sized 3,696 m2.
E. The proposed development includes a revised dock area, revisions to underground services, external items of plant and equipment, roof mounted plant and equipment, two 20 m high boiler stacks, external equipment and modular storage for industrial materials, pipe bridges and modifications to existing elevations. External items of equipment also include electricity transformers, modular bunded chemical storage units, waste compressors, skips, and waste balers.
F. A new permanent car park for 150 cars located to the south west of the existing car park, with landscaping, lighting and ancillary items.
For inspection purposes only. Consent of copyright owner required for any other use.
by Environmental Impact Services 15
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Project Description
0
ROCHES AVE.
EXTENT OF LANDS SUBJECT TO PLANNING APPLICATION EXTENT OF LANDS IN Af'PIJCANT'S t: O'NNERSHIP WAYLEAVE
*I
~
For inspection purposes only. Consent of copyright owner required for any other use.
REGENERON NEW PRODUCTION FACILITY SITE PLAN 31 Octobe r 2017 1 :500@ EXTENDED AO ~OBS Figure 4.1 Proposed Site Plan
by Environmental Impact Services 16
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Project Description
NORl'H EAST ELEVATIOH sc.oi.1:200 ·-· _ ... - ~ (oi) ... -' - (DJ. ,.. .$! .. - fol ;;, ... - i;;_lij (, "" n ,. i 11 ·R n 11·-li ;0 \B n. II n ,n, n 11 -11--nJ - - - - '" • - - "" n n - - .. - .. - "' l - ""I - ' /~x - l - ' --~-~ 7.: -- ___ ,.,..;;n/l ·rl I I I I I I I I I I I I I I I I I ! - IE>lllMlf..:.ll'fl _I ' ' ' ' ' ' ' ' ' ' ' : II -- -· ' ' ' ' ' ' r I I l I I I I I I I I I I I I I 11 I ]"':~ 801JTH WEIT ELEVATION -- Scal11;2DD
For inspection purposes only. Consent of copyright owner required for any other use.
REGENERON NEW PRODUCTION FACILITY PROPOSED ELEVATIONS AND SECTIONS 31 October 2017 1 :200@AO JACOBS Figure 4.2 Proposed Elevations
by Environmental Impact Services 17
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Project Description
The extension will increase employment at the facility by approximately 150 personnel and will operate on a shift basis similar to existing shift patterns.
4.2 CONSTRUCTION PHASE
It is envisaged that the basic construction of the facilities will take approximately 36 months, starting with the excavation on site and completing with the preliminary validation of the process systems, automation systems and clean rooms. The full validation process takes approximately 1 year after the completion of the buildings, after which the manufacture of medicines for patients can begin.
A contractors’ compound of approximately 1 ha is proposed to the North West of the site, adjacent to the existing site access. There will be a new entrance to this compound. A temporary 350 space contractors’ car park is also proposed. This will be adjacent to the proposed permanent car park.
Specific measures have been integrated in to the construction proposals to avoid or reduce environmental impacts, which might otherwise occur. These are set out in the accompanying outline Construction Environmental Management Plan (CEMP).
4.2.1 CONSTRUCTION STAGES AND SEQUENCING The anticipated sequence of construction activities on site are summarised below:
It is proposed to build this facility at an accelerated schedule.
The proposed general construction hours are as follows: Main day shift: 7.00am to 7.00pm normal daily works - Monday to Friday, Saturday 8.00am to 4.00pm.
The anticipated intensification work pattern will add a second construction shift of 5.00pm to midnight – one hour overlap between day shift and 2nd shift for safe handover of work scopes etc. Works taking place during the intensification period are principally internal works with low offsite impacts such as Piping / Electrical / HVAC / Fire Protection.
As part of a second shift, a small crew may work at night, cleaning the building site and insulating pipework, etc. For inspection purposes only. Consent of copyright owner required for any other use.
Under normal working conditions, it is anticipated that weekday evening activities will be significantly reduced and generally only involve internal activities. Concrete pouring or steel erection which will be required during certain phases of the development will require occasional works outside of the normal work-time patterns.
Considerable effort will be made to fabricate components and assemblies off-site to reduce the required manpower and in so doing will reduce demands on the infrastructure as well as the on-site parking and services.
As seen above, the following stages and sequence of the project are as follows:-
1. Temporary Works – Demolition and Clearing 2. Mass Excavation, Retaining Walls and Site Utilities 3. Concrete Foundations and Structures 4. Structural Steel Erection 5. Shell and Building Skin Construction 6. Mechanical, Electrical and Process Construction 7. Architectural Finishes 8. Cleanroom Construction 9. Start-up and Commissioning
by Environmental Impact Services 18
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Project Description
4.2.2 SITE ACCESS AND EGRESS AND TEMPORARY CONTRACTOR SITE LAYOUT The primary construction access will be through the new Northern Construction Entrance. This entrance will be dedicated to the construction traffic and heavy goods vehicles. A temporary car park for 350 car spaces will be constructed to the Southern part of the site. This temporary car park will be removed after the construction of the facility.
The construction site will be separated from the remainder of the site with temporary fencing and hoardings and a dedicated access route for construction personnel will be built on the periphery of the site.
Due to the site constraints most oversized deliveries such as steel deliveries will be planned for off- peak work and traffic hours. A second shift for deliveries may be employed for the 6 month period during shell construction - in the early part of the construction schedule.
For inspection purposes only. Consent of copyright owner required for any other use.
by Environmental Impact Services 19
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
5 POPULATION & HUMAN HEALTH
5.1 INTRODUCTION
This chapter considers the impact of the proposed development in the context of population and settlement, land use, employment and other impacts of a social and economic nature. In terms of human beings, the types of issues which developments such as this raise (both during construction and operation) include: impacts on amenities and services in the area; additional economic opportunities; increased traffic; and impacts on existing land uses. Whilst references are made to other environmental topics (such as traffic, noise and air) in this section, they are examined in detail in other sections of the EIAR.
5.2 THE PROPOSED DEVELOPMENT
The proposed extension is to the Regeneron facility located in Raheen Business Park, Co. Limerick. The facility is expected to employ approximately 150 persons once fully operational. During the construction phase of the project it is estimated that employment on site over the approximate 36- month construction period will peak at 500 persons and will fall gradually as the project nears completion.
5.3 THE EXISTING ENVIRONMENT
5.3.1 PLANNING AND DEVELOPMENT CONTEXT 5.3.1.1 General The existing Regeneron Facility is located within Raheen Business Park which is situated within a suburban area southwest of Limerick City, adjacent to the M20 motorway. In addition to Regeneron, the business park accommodates a number of international companies, such as Dell, Analog Devices, and Stryker Corp.
The Regeneron site is approximately 12 ha in area and is bounded to the south/ south-east by the business park road network and the Adhesive For inspection Research purposes only. Ireland and Dell Customer Solution Centre premises. The Limerick Training CentreConsent ofis copyright situated owner to required the fornorth any other of use. the site, while as the Freightshift
Nationwide and Aramark establishments are located towards the north-east of the site. The west of the site is adjoined by mature wooded area in addition to Roche Castle and associated out-buildings and grounds. Beyond the surrounding road network to the south and south-west of the Regeneron site is greenfield lands and further industrial/ enterprise units.
5.3.2 LAND USE STRUCTURE ADJACENT TO THE REGENERON SITE The subject site is an established manufacturing facility within a wider industrial area which facilitates a diverse range of economic sectors. A number of establishments including Dell Customer Centre, BD GenCell Biosystems, Stryker Orthopaedics and Analog Devices are located within close proximity of the subject site. Greenfield areas are located to the south, south-west and further west of the site, while as the closest residential area is situated ca. 400 metres to the east of the site along Ballycummin Road.
The Limerick City Centre is located approximately 5.2 km to the north west of the site. The University Hospital of Limerick is approximately 1.4 km to the north. Limerick Golf Club is located approximately 1.7 km west of the site.
In terms of infrastructure, the site is well positioned to the north-west of the M20 motorway approximately 1 km north of junction 3. The site is largely bordered by the business park road
by Environmental Impact Services 20
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
network which leads onto the R510 to the south-west, the R526 to the north-west and the Ballycummin Road to the east.
The subject lands lie within the functional area of Limerick City & County Council and within the Southern Environs area of Limerick City.
5.3.3 SOCIO-ECONOMIC FACTORS The following socio-economic analysis concentrates mainly on the immediate hinterland in terms of population and employment as this is the area where most impacts will arise.
The Regeneron site is located within Raheen Business Park which is situated in the Electoral Division (ED) of Ballycummin (to which the South Environs LAP is applicable to) and is in close proximity to Limerick City (Limerick City Centre is approximately 5.2 km north west of the site) and Roxborough ED (to the south-west of the site). These areas can be regarded as within the immediate hinterland in terms of the socio-economic impacts arising from the new development. The secondary hinterland can be regarded as the County Limerick and the Mid-West Region, as direct and indirect employment, purchasing, employee’s residences etc. are likely to be located throughout County Limerick the Mid- West Region. The Raheen Business Park (where Regeneron is located) is situated in the Southern Environs of Limerick City. The Southern Environs is recognised as a Gateway – Tier 1 in the settlement hierarchy within the Limerick County Development Plan. This socio-economic section includes an analysis of the immediate and secondary hinterlands in terms of population and employment.
5.3.4 POPULATION 5.3.4.1 Population Change In terms of the County, Region and State, population change is strongly influenced by migration and emigration rates, rather than birth and death rates. The 1990’s and early 2000’s saw a large movement of people into the Country due to the “economic boom” in Ireland. The Mid-West and surrounding areas experienced high levels of population growth as a result of strong economic growth in the region. The past 8 years have seen a decline in economic growth and a return to emigration of people from Ireland. Economic indicators show that this trend is again reversing and signals of demand for skilled workforce and economic growth are retuning. Throughout this period Ballycummin continued to experience population growth (7.1%) slightly below the national average (8.2%), while For inspection purposes only. as Limerick city had a population Consent growth of copyright of 8.7%. owner required This for was any otherwell use. above the trend at county level, which saw a 2.4% population growth in County Limerick in the 2006-2011 census period. In contrast, Roxborough witnessed a population decrease of 0.2%. Preliminary data indicates that County Limerick saw a population increase of 1.6% in the period from 2011-2016, lower than the 3.7% national average. Ballycummin and Limerick City both saw an increase of 5.1% and 2.1% respectively, while as Roxborough saw a further population decrease of -6.6% in the same census period.
Table 5.1 below shows the changes in population for the state, immediate (Ballycummin, Roxborough and Limerick City) and secondary (County Limerick and Mid-West Region) hinterlands of the proposed development.
by Environmental Impact Services 21
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
Table 5.1 Population Change at Sate, Secondary and Primary Hinterland Level10 % Change % Change 2006 2011 2016 2006-2011 2011-2016 State 4,239,848 4,588,252 4,757,976 +8.2% +3.7% M-W 361,028 379,327 385,172 +5.1% +1.5% Co. Limerick11 131,516 134,703 136,856 +2.4% +1.6% Limerick City 52,539 57,106 58,319 +8.7% +2.1% Ballycummin 16,335 17,490 18,388 +7.1% +5.1% Roxborough 1,605 1,601 1,495 - 0.2% - 6.6%
Table 5.1 above shows a variation in the population growth in the Mid-West Region, County Limerick, Limerick City, Ballycummin and Roxborough. The Census data in 2006, 2011 and 2016 shown above, indicate that moderate population growth has taken place in the Mid-West Region, Co. Limerick, Limerick City and Ballycummin, higher than national percentage growth which has taken place over the same period in some cases. However, population decreases have occurred in Roxborough. Despite the intermediate economic decline experienced in Ireland from 2008, population projections indicate that population growth in the South-East Region, County Limerick and Limerick City is expected to remain. In order to counteract the decline of the Roxborough ED and to maintain the moderate population growth in the Ballycummin ED, it is important that the areas role and functions are consolidated and sustained. The further development, such as that of the Regeneron Proposal, would contribute towards enabling the maintenance and growth of the population within ED’s such as a those of Ballycummin and Roxborough where the subject proposal is located within and in close proximity to.
Age Profile The age profile of the population is important in terms of the potential labour force, the demand for schools, amenities and other facilities and the future housing demand.
Table 5.2, Table 5.3 and Table 5.4Table 5.4 below show the age profiles for the state, immediate (Ballycummin, Roxborough and Limerick City) and secondary (County Limerick and the Mid-West Region) hinterlands of the proposed development for 2006, 2011 and 2016. This allows the changes in the population profile to be compared between census years.
12 Table 5.2 Age Profile at State, Secondary For inspection and purposes Primary only. Hinterland Level, 2006 Consent of copyright owner required for any other use. 0-14 15-24 25-44 45-64 65+ Total % % % % % Persons State 21 16 33 18 11 4,239,848 M-W 20.5 15.1 30.1 22.8 11.5 361,028 Co. Limerick 20.2 16.4 30.2 22.7 10.5 131,516 Limerick City 17.8 18.5 30.4 20.8 12.4 52,539 Ballycummin 20.1 15.2 41.9 16.6 6.2 16,335 Roxborough 22.7 14.8 22.9 30.8 8.7 1,605
10 Census of Population 2006, 2011 and 2016 11 Since the 2011 Census Limerick city & county have been amalgamated as part of the administrative counties. 12 Central Statistics Office Census of Population 2006
by Environmental Impact Services 22
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
Table 5.3 Age Profile at State, Secondary and Primary Hinterland Level, 201113 0-14 15-24 25-44 45-64 65+ Total Persons % % % % % State 21 13 32 23 12 4,588,252 M-W 21.3 12.9 29.6 23.8 12.5 379,327 Co. Limerick 21.4 13.4 30.2 23.6 11.7 134,703 Limerick City 17.9 15.9 30.5 22.6 13.2 57,106 Ballycummin 22.6 11.4 39.8 18.6 7.6 17,490 Roxborough 19.8 14.9 18.7 33.8 12.8 1,601
Table 5.4 Age Profile at State, Secondary and Primary Hinterland Level, 201614 0-14 15-24 25-44 45-64 65+ Total Persons % % % % % State 21.1 12.1 29.5 23.8 13.4 4,761,865 M-W 21 12.2 27.1 25 14.7 473,269 Limerick City & County15 20.3 13.3 28.4 24 14.1 194,899 Ballycummin 23.5 10.3 36.1 20.6 9.5 18,388 Roxborough 17.5 13.2 16.8 33.2 19.3 1,495
Table 5.2 shows that the age profile of the population of the Mid-West Region in 2006 revealed a slightly lower percentage within the 0-14 age group, at 20.5%, compared with the State average of 21%. County Limerick also recorded a slightly lower figure compared to the Mid-West Region and the State figures, at 20.2%. At the other end of the scale the national figure for persons aged 65+ in 2006 was 11% of population, with the Mid-West Region being higher at 11.5%, and County Limerick being lower at 10.5%. These figures are indicative of a youthful population in these areas, reflecting the arrival of a sizeable percentage of the resident population over the past decade.
In 2006 the percentage of the Mid-West population within the working age groups (14-64) amounted to 68%, compared to the State average of 67%. The comparable figure for County Limerick was 69.3%, while as for Limerick City, Ballycummin, Roxborough it was 69.7%, 73.7% and 68.5% respectfully. These figures are indicative of a youthful population of working age, providing a strong For inspection purposes only. pool of labour in the area. Consent of copyright owner required for any other use.
The figures in Table 5.3 indicate that since 2006, the overall trend in population for the State and the Mid-West Region, has been static or increasing in the proportion of the population in the 0-14 cohort. Between the years of 2006 and 2011 the proportion of 0-14 year olds in the State remained at 21%. Within the Mid-West Region during the same period the figure increased from 20.5% to 21.3%. County Limerick, Limerick City and Ballycummin also saw an increase in the 0-14 population cohort from 20.2% to 21.4%, 17.8% to 17.9% and 20.1% to 22.6% respectfully. Roxborough experienced a decline in the 0-14 population cohort from 22.7% to 19.8%.
Table 5.4Table 5.4 presents that the age profile of the population of the Mid-West Region in 2016 showed a marginally lower percentage within the 0-14 age group, at 21%, in comparison to the State average of 21.1%. Limerick City and County also recorded a slightly lower figure compared to the Mid-West Region and State figures, at 20.3%. With regard to persons aged 65+, the national average in 2016 was 13.4% of population, with the Mid-West Region and Limerick City and County, being higher at 14.7% and 14.2% respectfully, all of which are higher when compared to the 2011 figures. The 2016 figures show that the percentage of the Limerick City and County population within the working age groups (14-64) amounted to 65.7%, slightly higher than the Mid-West Region at 64.3%
13 Central Statistics Office Census of Population 2011 14 Central Statistics Office Census of Population 2016 15 Since the 2011 Census Limerick city & county have been amalgamated as part of the administrative counties.
by Environmental Impact Services 23
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
and the state average of 65.4%. The comparable figure for Ballycummin was 67%, which was higher than state, regional and county figures, and 63.2% for Roxborough. These figures indicate a youthful population of working age in area, thus providing a substantial supply of labour.
The volatility of migration makes it difficult to estimate very accurately future population changes, but indications are that population in most of the primary and secondary hinterlands will continue to rise.
Ballycummin, Limerick City and County Limerick have experienced a sustained population growth over the last ten years, despite the economic challenges that faced the country. The large percentage of the population living in the hinterland of the subject site and within the working age group, is indicative of the increasing job opportunities and the continuing expansion of the Region.
Labour Force Participation Labour Force Participation (LFP) measures the percentage of all people aged 15 years or over who are available for work, that is either at work or unemployed (labour force). The 2011 census indicates that County Limerick has a LFP rate of 60.2%, Limerick City with a LFP rate of 55.1% and Roxborough as having a LFP rate of 57.2%, which are lower than the state average at 61.9%. the 2011 figures also show that Ballycummin has a LFP rate of 67.6%, which is significantly higher than the state average. This level of information is not yet available from the 2016 census data.
Table 5.5 Labour Force Participation Rate, 201116 Labour Force Participation Rate State 61.9 % M-W 61.0% Co. Limerick 60.2% Limerick City 55.1% Ballycummin 67.6% Roxborough 57.2%
5.3.5 HOUSING DEMAND Table 5.6 Population & Households at State, Secondary & Primary Hinterland Level17 Population Households 2006 2011 % change 2006 2011 % change For inspection purposes only. State 4,239,848 4,588,252Consent of copyright owner required8.2 for any1,469,521 other use. 1,654,208 12.6
M-W 361,028 379,327 5.1 125,427 138,000 10.0 County 44,675 47,282 5.8 Limerick 131,516 134,703 2.4 Limerick 19,550 22,367 14.4 City 52,539 57,106 8.7 Ballycummin 16,335 17,490 7.1 5,721 6,240 9.1 Roxborough 1,605 1,601 - 0.2% 503 530 5.4
An analysis of the percentage of the population of County Limerick, Limerick City and Ballycummin who are available for work and the increase in both the population and number of households in the area, as illustrated in Table 5.4Table 5.4 and Table 5.5 above, indicates that both the population and number of households have increased significantly in recent years. Roxborough has seen decreases in population and minor growth in the number of households (as indicated on Table 5.5).
16 Central Statistics Office Census of Population 2011 17 Central Statistics Office Census of Population 2006 and 2011)
by Environmental Impact Services 24
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
5.4 PREDICTED IMPACTS
5.4.1 INTRODUCTION The proposed extension to the existing Regeneron facility will create a demand among employees for additional housing. The workforce will likely be drawn from the immediate hinterland and a wider geographical area. It is likely to have a small direct impact on the population of the hinterlands. It is also predicted that the proposed development will have significant effects on employment - both direct employment at the facility itself and indirect employment created by the multiplier effect. It is likely that these new employment opportunities will be availed of by both persons from the immediate hinterland of Ballycummin, Roxborough and Limerick City and the wider County Limerick area, in addition to a wider catchment area extending into the Mid-West Region. Because of the high degree of accessibility to the site, the beneficial impacts of the development are likely to be diffused over an extensive catchment area.
5.4.2 EMPLOYMENT The proposed development is consistent with the creation of new employment opportunities in the Southern Environs of the Limerick City and Environs Gateway (core economic growth area), and the wider area of the Mid-West region. Recent trends show that a significant proportion of new industrial/manufacturing/office employment is taking place outside of city centre locations and in locations where purpose built facilities or suitable greenfield sites are available.
During the construction phase of the project it is estimated that employment on-site will increase gradually to a peak of 500 persons and then fall gradually over the last few months as the project nears completion. It is estimated that this construction stage will last approximately 36 months.
It is anticipated that the proposed development will provide employment for approximately 150 personnel once fully operational.
It is anticipated that the staff profile (in educational terms) will consist of a significant proportion of third level graduates who have graduated from educational establishments throughout Ireland and abroad. Similar to the employment profile of other biopharmaceutical manufacturing facilities, it is expected that the workforce will be made up of members of the local community, national and international graduates and European expatriates who have relocated back to Ireland. For inspection purposes only. Consent of copyright owner required for any other use.
5.4.3 HOUSING It is not possible to accurately predict where employees of the new facility will reside but based on employment patterns in the area it is likely that employees will reside within a 30 km radius. According to the County Development Plan, the Southern Environs area is envisaged to accommodate growth in accordance with its designation as a Gateway within the Limerick County settlement hierarchy. The Local Area Plan adopted for the Southern Environs of Limerick City states that growth should be planned for a population of over 20,000 persons by 2022. There is a need to provide the appropriate social, economic and physical infrastructure to accommodate such growth.
The impact, on housing demand arising from the proposed new development is likely to be dispersed over a wide area. It is not therefore likely that the proposed development will create any adverse housing impacts. The growth in housing demand locally as a result of the proposal should lead to a greater investment and improvement in services and amenities in the hinterland in response to increased demand from residents.
5.4.4 CONSTRUCTION COSTS Total facility cost (fixed assets only) is estimated to be $25 million. It is envisaged that local contractors, services and materials will be utilised where possible.
by Environmental Impact Services 25
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
According to the CSO Labour Market statistics (Q1 2016) the total number of persons at work in the construction sector in Ireland was 131,300 persons. The provision of up to 500 building and construction jobs during the construction of this project can be expected to generate significant income in wages and salaries which will be of benefit to the local economy in terms of the purchase of goods and services and also to the national exchequer as taxation revenue.
5.4.5 MULTIPLIER EFFECTS Based upon research undertaken by the Economic and Social Research Institute the direct expenditure on wages and salaries would have a multiplier effect upon further indirect, or secondary service employment. According to the ESRI research, for every 100 jobs in direct manufacturing industry, there are 91 associated jobs in the supporting service industry. In this case, it can be expected that for the additional eventual workforce of 150 people, there would be a further approximately 137 associated jobs in the service industry.
5.4.6 IMPACTS FROM ADDITIONAL TRAFFIC This section considers traffic in general terms as it how could affect the population and human health. Section 13 Traffic and Transportation gives a comprehensive analysis of all traffic issues.
The existing road network is currently operating well. The Traffic and Transport Assessment undertaken indicates that the existing road network can successfully accommodate the additional traffic. The impact of the traffic generated by the proposed development will have only minor effects on the amenity of the area. The provision of a Construction Traffic Management Plan will mitigate and reduce the environmental impacts of the construction phase of the development. Furthermore, the introduction of a mobility management plan will highlight available travel options to staff, monitor travel patterns and minimise the impact of future travel levels.
5.4.7 HUMAN HEALTH In an EIAR the potential for effects on human health are dealt with under the more specific topics of the environmental medium by which it might be caused. The topics include air, water, noise and waste.
Some health and safety related topics are covered by separate and more specific legislation and so do not form part of an EIAR – examples in clude For inspection worker purposes health only. and safety and construction safety. Consent of copyright owner required for any other use.
5.4.8 IMPACTS ON AMENITY Local amenities in the area include the following; Limerick Golf Club and other minor recreational amenities (e.g. pitches to the north-east). These are located sufficiently far away from the proposed development site so as to no recognisable impact on their amenity.
5.5 MITIGATION MEASURES
5.5.1 GENERAL No specific mitigation measures are required to ameliorate the impacts on human beings as the impacts are largely positive. Section 13 on traffic and transport deals with specific mitigation measures proposed in relation to transport improvements, which will benefit residents of the general area. These are referred to in this section below. Mitigation measures in relation to the potential human health impacts of air and noise, particularly during construction are dealt with in detail in Section 9 and 10 of the EIAR.
by Environmental Impact Services 26
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Population & Human Health
5.5.2 DURING CONSTRUCTION Construction traffic including both construction plant and material deliveries will be programmed to avoid peak work and traffic hours. Further detail on mitigation measures will be included in the Construction Environmental Management Plan and the Traffic and Transport Assessment.
5.5.3 MOBILITY MANAGEMENT PLAN The proposed development will adopt and implement a Mobility Management Plan. The implementation of this plan will lower the potential traffic impacts. The plan will include a range of measures including the promotion of public transport, cycling and walking for travel to work.
5.6 RESIDUAL IMPACTS
The proposed development will have a positive long-term impact on the immediate and secondary hinterlands, Ballycummin, Roxborough, Limerick City and County, and the Mid-West region through continued expanded employment and the associated economic and social benefit.
For inspection purposes only. Consent of copyright owner required for any other use.
by Environmental Impact Services 27
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity
6 BIODIVERSITY
6.1 INTRODUCTION
6.1.1 OVERVIEW AND AIMS This section assesses potential impacts that may arise from the proposed development on biodiversity within the receiving environment; in accordance with the following guidance documents: Environmental Protection Agency (2000). Guidelines on Information to be contained in Environmental Impact Statements. Chartered Institute of Ecology and Environmental Management (CIEEM) (2016). Guidelines for Ecological Impact Assessment. Chartered Institute of Ecological and Environmental Management (CIEEM) (2012). Preliminary Ecological Appraisal. Fossitt JA (2000). A Guide to Habitats in Ireland. The Heritage Council (2011) Habitat Survey Guidelines: A Standard Methodology for Habitat Survey and Mapping in Ireland.
It aims to discuss the existing ecological environment, the potential impacts of the scheme and avoidance and mitigation measures in relation to habitats, flora and fauna in the zone of influence (ZOI) of the proposed development. The section was prepared by Andrew Torsney18. A separate stand-alone AA Screening Report is also included in the planning application documentation.
6.1.1.1 Legislative Context Specific focus is placed on protected species/habitat features as well as those of local or national importance. Ireland’s national biodiversity action plan Actions for Biodiversity 2011–201619, in accordance with the Convention on Biological Diversity, is a framework for the conservation and protection of Ireland’s biodiversity, with an overall objective to secure the conservation, including, where possible, the enhancement and sustainable use of biological diversity in Ireland and to contribute to collective efforts for conservation of biodiversity globally. The plan is implemented through legislation and statutory instruments concerned with nature conservation. The Planning and Development Acts, 2000–2015 and the European Communities (Environmental Impact Assessment) For inspection purposes only. Regulations, 1989 (as amended) areConsent particularly of copyright owner important required for any in other that use. regard and include a number of provisions directly concerned with the protection of natural heritage and biodiversity.
The Wildlife Acts, 1976–2012 are the principal mechanism for the legislative protection of wildlife in Ireland. They outline strict protection for species that have significant conservation value. In summary, the Wildlife Acts protect species from injury, disturbance and damage to breeding and resting sites. All species listed in the Wildlife Acts must, therefore, be a material consideration in the planning process. An important piece of national legislation for the protection wild flora, i.e. vascular plants, mosses, liverworts, lichens and stoneworts, is the Flora (Protection) Order, 2015, which makes it illegal to cut, uproot or damage a listed species in any way or to alter, damage or interfere in any way with their habitats. This protection applies wherever the species listed in the Schedules to the Order are found.
The European Communities (Birds and Natural Habitats) Regulations, 2011–2015 transpose into Irish law Directive 2009/147/EC (the Birds Directive) and the Habitats Directive, which list habitats and species of Community, i.e. European Union (EU), importance for conservation and that require protection. This protection is afforded in part through the designation of areas that represent significant populations of listed species within a European context, i.e. Natura 2000 sites. An area designated for bird species is classed as a Special Protection Area (SPA), and an area designated for
18 Senior Ecologist (M.Res, B.Sc, ACIEEM) of CAAS Ltd 19 This is due to be replaced by the Action Plan for Biodiversity 2017-2023; however, this is pending
by Environmental Impact Services 28
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity
other protected species and habitats is classed as a Special Area of Conservation (SAC). Birds listed in Annex I of the Birds Directive in SPAs and habitats and species listed in Annexes I and II, respectively, of the Habitats Directive in SACs in which they are designated features have full European protection. Species listed on Annex IV of the Habitats Directive are strictly protected wherever they occur, whether inside or outside European Sites. Annex I habitats outside of SACs are still considered to be of national and international importance and, under Article 27(4)(b) of the European Communities (Birds and Natural Habitats) Regulations, 2011, public authorities have a duty to strive to avoid the pollution or deterioration of Annex I habitats and habitats integral to the functioning of SPAs.
Sites of national importance for nature conservation are afforded protection under planning policy and the Wildlife Acts, 1976–2012. NHAs are sites that are designated under statute for the protection of flora, fauna, habitats and geological interest. Proposed NHAs (pNHAs) are published sites identified as of similar conservation interest but have not been statutorily proposed or designated.
The International Union for the Conservation of Nature and Natural Resources (IUCN) provides a global approach for evaluating the conservation status of species to inform and catalyse action for biodiversity conservation through the Red List of Threatened Species.
6.1.1.2 Approach to Ecological Evaluation and Impact Assessment Assessing impact significance is a combined function of the value of the affected feature (its ecological importance), the type of impact and the magnitude of the impact. It is necessary to identify the value of ecological features within the study area in order to evaluate the significance and magnitude of possible impacts.
The following parameters are described when characterising impacts (following CIEEM (2016), EPA (2002) and NRA (2009)): Direct and Indirect Impacts - An impact can be caused either as a direct or as an indirect consequence of a proposed development. Magnitude - Magnitude measures the size of an impact, which is described as high, medium, low, very low or negligible. Extent - The area over which the impact occurs – this should be predicted in a quantified manner. For inspection purposes only. Consent of copyright owner required for any other use. Duration - The time for which the effect is expected to last prior to recovery or replacement of the resource or feature. Temporary: Up to 1 Year; Short Term: The effects would take 1-7 years to be mitigated; Medium Term: The effects would take 7-15 years to be mitigated; Long Term: The effects would take 15-60 years to be mitigated; Permanent: The effects would take 60+ years to be mitigated. Likelihood – The probability of the effect occurring taking into account all available information. Certain/Near Certain: >95% chance of occurring as predicted; Probable: 50-95% chance as occurring as predicted; Unlikely: 5-50% chance as occurring as predicted; Extremely Unlikely: <5% chance as occurring as predicted. The CIEEM Guidelines define an ecologically significant impact as an impact (negative or positive) on the integrity of a defined site or ecosystem and/or the conservation status of habitats or species within a given geographic area. The integrity of a site is the coherence of its ecological structure and function, across its whole area, which enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified (CIEEM, 2016).
The results of the ecological survey were evaluated to determine the significance of identified features located in the study area on an importance scale ranging from international-national-county-
by Environmental Impact Services 29
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity
local. The local scale is approximately equivalent to one 10 km square but can be operationally defined to reflect the character of the area of interest. Because most sites will fall within the local scale, this is sub-divided into three categories: high local importance - local importance - local value. The criteria used for assessing the importance of ecological features are shown in Table 6.1. The criteria used for assessing impact type and impact magnitude are shown in Tables A1.1 and A1.2 which are contained in Appendix 6.1.
Table 6.1 Criteria used in assessing the importance of ecological features.
Importance Criteria International An internationally designated site or candidate site (SPA, pSPA, cSAC, pSAC, Ramsar Site, Biogenetic Reserve). Also, sites which qualify for designation as SACs or SPAs – this includes sites on the NGO shadow list of SAC’s. National A nationally designated site or candidate site (NHA, pNHA). Sites which hold Red Data Book (Curtis and McGough, 1988) plant species. County Sites which hold nationally scarce plant species (recorded from less than 65 of the national 10 km grid squares); unless they are locally abundant. Sites which hold semi-natural habitats likely to be of rare occurrence within the county. Sites which hold the best examples of a semi-natural habitat type within the county. High Local Sites which hold semi-natural habitats and/or species likely to be of rare Importance occurrence within the local area. Sites which hold the best examples of a high quality semi-natural habitat type within the local area. Local Sites which hold high quality semi-natural habitats. Importance Local Value Any semi-natural habitat.
6.1.1.3 Consultation For inspection purposes only. Consent of copyright owner required for any other use. Consultation was undertaken with Limerick City & County Council with regard to the scope of works within the Project. The consultation resulted in an expression of no concern in relation to Biodiversity related impacts due to the low ecological value of the receiving environment and the distance from protected sites.
6.1.2 METHODOLOGY
6.1.2.1 Desk Study A desktop review was carried out to identify features of ecological importance within the proposed development site and the wider environment. Ecological impact assessment is conducted following a standard source-pathway-receptor model, where, in order for an impact to be established all three elements of this mechanism must be in place. The absence or removal of one of the elements of the mechanism is sufficient to conclude that a potential effect is not of any relevance or significance. Source(s) – e.g. pollutant run-off from proposed works. Pathway(s) – e.g. groundwater connecting to nearby qualifying wetland habitats. Receptor(s) – qualifying aquatic habitats and species of European Sites.
Specific effort was put into the assessment of sensitive receptors of protected species/habitat features; as well as those of local or national importance. A source is any identifiable element of the
by Environmental Impact Services 30
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity
Project proposal which is known to have interactions with ecological processes. Pathways are any connections or links between the source and the receptor. This report determines if direct, indirect or cumulative adverse effects will arise from the proposed development.
6.1.2.2 Field Survey Work Site works undertaken on the 4th May 2017 by Biosphere Environmental Services comprised a walk- over survey (as feasible) of three land units around the existing developed site area. Additionally, data was collected by Scott Cawley on behalf of PM Group in November 2013 for the EIS of the conversion of the former Dell factory for use by Regeneron. This data covered the whole Regeneron site and between the updated surveys conducted on the 4th of May, the existing baseline data from Scott Cawley and an assessment of aerial photography produced sufficient data for assessment.
A habitat survey of the site was conducted following standard guidelines set out in ‘Best practice guidance for habitat surveys and mapping’ developed by the Heritage Council of Ireland20. Habitats were classified using habitat descriptions and codes published by the Heritage Council in ‘A Guide to Habitat Types in Ireland’21. Plant species nomenclature follows Rose’s ‘The Wild Flower Key: How to identify wild flowers, trees and shrubs in Britain and Ireland’22. A list of the dominant and notable plant species was taken for each habitat type. Particular emphasis was given to the possible occurrence of rare or legally protected plant species (as listed in Flora Protection Order 1999) or Red- listed plant species (Curtis & McGough 1985, Wyse Jackson et al. 2016).
Observations were made for fauna species present or likely to occur on site. Emphasis was placed on mammals and birds, and especially for species listed in the respective Red lists, namely Colhoun and Cummins (2013), and Marnell et al. (2009). For mammals, search was focused on signs of their presence, such as tracks, feeding marks and droppings, as well as direct observations. For bats, the main focus was on evaluation of suitable habitats to support roosting bats. Bird species were recorded by sight and sound. However, as the survey was confined to one date, the likely presence in other seasons of bird species of conservation importance was assessed based on habitats present.
During all surveys, particular attention was given to assessing the presence of rare or protected species. Each species identified was assessed in term of the EU Habitat Directive (92/43/EEC), Bird Directive (2009/147/EC), the Wildlife Act (1976), the Wildlife Amendment Act (2000) and the Red Data Lists for threatened and protected species, published on the NPWS website (www.npws.ie).
For inspection purposes only. 6.1.3 LIMITATIONS Consent of copyright owner required for any other use.
The biodiversity assessment was carried out within the optimum time for botanical survey. It is noted that survey in early spring is particularly relevant to woodland habitats.
Survey for ground mammals was somewhat impeded by high vegetation growth though the habitats present are limited in the species that could be supported on site. Optimum period for mammal survey is winter.
The survey was undertaken within the optimum period for breeding birds, with early May particularly suitable for breeding birds associated with woodland habitats. The likely presence of birds in other seasons (mainly winter) can be assessed by the diversity of habitats present.
Overall, it is considered that there are no significant limitations to the present assessment of the ecological importance of the site.
20 Smith, George F., et al. "Best practice guidance for habitat survey and mapping." The Heritage Council: Ireland (2011) 21 Fossitt, J.A., 2000. A guide to habitats in Ireland. Heritage Council/ Chomhairle Oidhreachta 22 Rose, F., O'Reilly, C., Smith, D.P. and Colling
by Environmental Impact Services 31
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity
6.2 CHARACTERISTICS OF THE PROPOSED DEVELOPMENT
6.2.1 OVERVIEW The current Regeneron facility was built in 1999 by Dell on previously undeveloped land. The Dell facility closed in 2009, and was purchased and repurposed by Regeneron in 2014. The current site is bordered by disused lands some of which are now proposed to be developed.
The various elements of the proposed extension are described in Section 4.
6.3 RECEIVING ENVIRONMENT
6.3.1 OVERVIEW The study site is located adjacent to the existing Regeneron facility within the Raheen Business Park. The Business Park is located within the townland of Ballycummin, to the southwest of Limerick City (ref. Figure 4.1). The Park is bounded to the north and west by the R526 road and to the south and east by the M20 motorway.
A protected structure, Roche Castle, occurs adjacent to the site, along with a complex of disused farm buildings. There are no open watercourses on site. Drainage is northwards to the Shannon Estuary, 3 km from the study site via Loughmore Common Canal, Barnakyle River and the River Maigue.
Overall, the study site can be described as an industrial facility former agricultural land and woodlands adjacent; within an area dominated by industry and on the outskirts of an urban complex.
6.3.2 ZONE OF INFLUENCE The operational phase works are not anticipated to have any impacts beyond the site boundary due to the proposed characteristics of the extension and the existing activities within the Regeneron Site. The construction phase works may have some effects beyond the boundary due to increased noise pollution, imposing of artificial lighting conditions and possible water quality effects to the surrounding area. Following the source-pathway-receptor model identifying the potential likely sources a Zone of Influence (ZOI) was established; 2x2 km2 was used as impacts are not foreseen to be significant beyond this distance; given For the inspection nature purposes of the only. proposed works. Consent of copyright owner required for any other use.
6.3.3 DESIGNATED AREAS In accordance with the European Commission Methodological Guidance (EC2001), a list of European Designated Sites that can be potentially affected by the works has been compiled. A dedicated Appropriate Assessment Screening, reviewing all European Sites within the zone of influence of the project, was undertaken. A review of the conservation objectives and qualifying interests of these sites was undertaken in order to identify what habitats and/or species could be vulnerable to risk of impact from the proposed development. This was done by assessing whether any source receptor links existed between the qualifying interests of the designated sites and the site.
When assessing ecological impacts, the CIEEM Guideline recommend a 15 km zone of influence as an adequate buffer for effects. Due to the characteristics of the project, all other Natura 2000 sites and pNHA/NHA sites beyond threshold distances of 15 km are considered to be far enough away that no significant effects could be caused either directly or indirectly or in combination with other plans or projects to their interest features. Any impacts caused by the Regeneron development have no valid impact pathway to transfer along to reach any of the receptor interest features. These sites are ‘screened out’ and not considered further.
In addition to examining European sites, NHAs and pNHA have been considered. Although NHAs and pNHAs do not form part of the Natura 2000 Network, they often provide an important supporting role to the network, particularly when it comes to fauna species which often do not obey site boundaries.
by Environmental Impact Services 32
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity
There are however, NHAs and pNHAs that are designated for features that are not important at an international level and may not interact with the Natura 2000 network.
Table 6.2 summarises the designated sites close enough to the Regeneron site to be potentially affected by the development. They are ‘Screened in’ and will now be assessed in this report. Figure 6.2 shows the designated sites within and outside a 15 km radius buffer of the proposed Regeneron site.
A stand-alone Screening Report expands on the potentially affected designated sites and their conservation objectives in more detail. The screening identified five European Sites within the zone of influence of Regeneron (Table 6.2).
No other Natura 2000 Sites with hydrological linkages of 20 km or less were found beyond those already identified within the 15 km ZOI. The drainage network of the proposed site would flow towards the River Shannon Lower, within the Ballynaclough sub catchment.
Table 6.2 The Designated Natura 2000 Sites within 15 km of site, or 20 km with a hydrological link23 Site Name Code SAC SPA NHA pNHA Distance [km] Loughmore Common Turlough 000438 0.64 Lower River Shannon 002165 2.50 River Shannon and River Fergus 004077 2.50 Estuaries Inner Shannon Estuary - South Shore 000435 2.71 Fergus Estuary And Inner Shannon, 002048 3.93 North Shore Knockalisheen Marsh 002001 7.35 Tory Hill 000439 8.20 Adare Woodlands 000429 9.41 Garrannon Wood 001012 9.73 Skoolhill 001996 9.78 Dromore & Bleach Loughs 001030 9.83 Cloonlara House 000028 11.25 Askerton Fen Complex SAC 002279 11.85 Castleconnell (Domestic Dwelling, 000433For inspection purposes only. 12.33 Consent of copyright owner required for any other use. Occupied) Curraghchase Wood 000174 13.39 Lough Gur 000437 14.19
23 arranged according to distance
by Environmental Impact Services 33
EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity
Legend D Site Boundary bd NHA [Il] pNHA
Figure 6.1 NHA’s and proposed pNHA’s within the zone of influence Legend
Zone Cf Influence For inspection purposes only. Consent of copyright owner required for any other use. ISkm r lOl Figure 6.2 SAC’s and SPA’s within the zone of influence by Environmental Impact Services 34 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity 6.3.3.1 Loughmore Common Turlough 000438 A variety of plant communities occur, depending on substrate type and degree of wetness. In the western half of the site, and along the eastern shore, the substrate is peaty, and the vegetation is dominated by sedges (Carex spp.), with Tufted Hair-grass (Deschampsia cespitosa), Marsh Horsetail (Equisetum palustre), Tall Fescue (Festuca arundinacea), Early Marsh-orchid (Dactylorhiza incarnata), Hard Rush (Juncus inflexus) and Yellow Loosestrife (Lysimachia vulgaris). The rare plant species, Opposite-leaved Pondweed (Groenlandia densa), occurs on the site, as does Meadow Barley (Hordeum secalinum). Loughmore provides suitable winter habitat for Lapwing and Golden Plover, and Snipe breed here. The main threats to the site are drainage, agricultural reclamation, pollution and afforestation. 6.3.3.2 Lower River Shannon SAC 002165 The Shannon and Fergus Rivers flow through Carboniferous limestone as far as Foynes, but west of Foynes Namurian shales and flagstones predominate. The Shannon and Fergus Estuaries form the largest estuarine complex in Ireland. Both the Fergus and inner Shannon Estuaries feature vast expanses of intertidal mudflats, often fringed with saltmarsh vegetation. In the transition zone between mudflats and saltmarsh, specialised colonisers of mud predominate. Freshwater rivers have been included in the site, most notably the Feale and Mulkear catchments, the Shannon from Killaloe to Limerick (along with some of its tributaries, including a short stretch of the Kilmastulla River), the Fergus up as far as Ennis, and the Cloon River. These systems are very different in character: the Shannon is broad, generally slow flowing and naturally eutrophic; the Fergus is smaller and alkaline; while the narrow, fast flowing Cloon is acid in nature. The Feale and Mulkear catchments exhibit all the aspects of a river from source to mouth. Semi-natural habitats, such as wet grassland, wet woodland and marsh occur by the rivers, but improved grassland is the most common habitat type. One grassland type of particular conservation significance, Molinia meadows, occurs in several parts of the site and the examples at Worlds end on the River Shannon are especially noteworthy. Alluvial woodland occurs on the banks of the Shannon and on islands in the vicinity of the University of Limerick. The woodland is up to 50 m wide on the banks and somewhat wider on the largest island. There is a small area of actively regenerating cut-away raised bog at Ballyrorheen. It is situated approximately 5 km north-west of Cappamore in Co. Limerick. There is a resident population of For inspection purposes only. Bottle-nosed Dolphin in the ShannonConsent Estuary. of copyright ownerFive required species for any of other fish use. listed on Annex II of the E.U. Habitats Directive are found within the site. These are Sea Lamprey (Petromyzon marinus), Brook Lamprey (Lampetra planeri), River Lamprey (Lampetra fluviatilis), Twaite Shad (Allosa fallax fallax) and Salmon (Salmo salar). The three lampreys and Salmon have all been observed spawning in the lower Shannon or its tributaries. Analyses for trace metals suggest a relatively clean estuary with no influences of industrial discharges apparent. Further industrial development along the Shannon and water polluting operations are potential threats. 6.3.3.3 River Shannon and River Fergus Estuaries SPA 004077 The site has vast expanses of intertidal flats which contain a diverse macroinvertebrate community, e.g. Macoma-Scrobicularia-Nereis, which provides a rich food resource for the wintering birds. Salt marsh vegetation frequently fringes the mudflats and this provides important high tide roost areas for the wintering birds. Elsewhere in the site the shoreline comprises stony or shingle beaches. The site is the most important coastal wetland site in the country and regularly supports in excess of 50,000 wintering waterfowl. It holds internationally important populations of four species, i.e. Light- bellied Brent Goose, Dunlin, Black-tailed Godwit and Redshank. In addition, there are 17 species that have wintering populations of national importance. The site also supports a nationally important breeding population of Cormorant. by Environmental Impact Services 35 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity 6.3.3.4 Inner Shannon Estuary - South Shore 000435 No Information Available on the NPWS pNHA Database. 6.3.3.5 Fergus Estuary And Inner Shannon, North Shore 002048 No Information Available on the NPWS pNHA Database. 6.3.3.6 Knockalisheen Marsh 002001 No Information Available on the NPWS pNHA Database. 6.3.3.7 Tory Hill SAC & pNHA 000439 Tory Hill supports areas of scrub and woodland. Areas of orchid-rich calcareous grassland are found on the eastern side of the hill and on its summit. A disused quarry also contains excellent examples of this grassland type. Four orchid species have been recorded here - Bee Orchid (Ophrys apifera), Pyramidal Orchid (Anacamptis pyramidalis), Early-purple Orchid (Orchis mascula) and Common Spotted-orchid (Dactylorhiza fuchsii). Lough Nagirra has a thick fringe of Common Reed (Phragmites australis) and areas of alkaline fen and calcareous fen vegetation referable to the Caricion davallianae alliance with Great Fen-sedge (Cladium mariscus). 6.3.3.8 Adare Woodlands 000429 These dry, broad-leaved woodlands are believed to be amongst the oldest in the country, and remnants of a much larger forest that developed in the River Shannon Basin after the last ice age. Much of the site was actively used for forestry purposes up until about 30 years ago, but since then the site has, in the main, been left reasonably undisturbed and as a result is now a haven for local wildlife. The woodland has developed a distinct canopy, shrub and ground layer vegetation. In the canopy, species such as Sessile Oak (Quercus petraea), Ash (Fraxinus excelsior) and Downy Birch (Betula pubescens) occur, intermingled with exotics such as Turkey Oak (Quercus cerris), Beech (Fagus sylvatica) and Sweet Chestnut (Castanea sativa). The shrub layer contains native species such as Hazel (Corylus avellana), Hawthorn (Crataegus monogyna), Blackthorn (Prunus spinosa) and Spindle (Euonymus europaeus), with exotics For like inspection Snowberry purposes only. (Symphoricarpos albus), Rhododendron Consent of copyright owner required for any other use. (Rhododendron ponticum) and Cherry Laurel (Prunus laurocerasus). 6.3.3.9 Garrannon Wood 001012 The main tree species of the wood is oak (Quercus spp.), which is mature and forms a closed canopy over much of the site. Downy Birch (Betula pubescens) and Hazel (Corylus avellana) occur in places. Part of the western section of the site has been clear-felled recently and replanted with Beech (Fagus sylvatica), larch (Larix spp.) and oak. Some Beech has also become established within the woods. The understorey is rather sparse and mostly of Bramble (Rubus fruticosus agg.). Holly (Ilex aquifolium) occurs throughout, with Hazel, oak and Ash (Fraxinus excelsior) in places. 6.3.3.10 Skoolhill 001996 Two woodlands occur here, with a mixture of native tree species such as Ash (Fraxinus excelsior), Hazel (Corylus avellana), awthorn (Crataegus monogyna) and oak (Quercus spp.) as well as exotics like Beech (Fagus sylvatica) and Sycamore (Acer pseudoplatanus). The ground vegetation in the woods is quite sparse, with Ivy (Hedera helix), Bramble (Rubus fruticosus agg.), ferns and Hogweed (Heracleum sphondylium) present. Rough grassland exists on the hill outside the woods, with quite natural vegetation present around the limestone rock outcrops. Plants such as Yarrow (Achillea millefolium), Common Knapweed (Centaurea nigra) and Selfheal (Prunella vulgaris) are found there. The outstanding value of this site is as the only known location in Ireland of the grass Various-leaved Fescue (Festuca heterophylla). by Environmental Impact Services 36 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity 6.3.3.11 Dromore & Bleach Loughs 001030 The lakes are fed by drains running through the fen which separates the lakes. While some peripheral drains have been cleared others have been allowed fill with vegetation. Near the reed-beds these drains support a diverse flora including White Water-lily (Nymphaea alba), Bogbean (Menyanthes trifoliata) and Common Spike-rush (Eleocharis palustris). Aside from the lakes the second major habitat in this site is the area of fen between the lakes. The fen between the lakes is variously regenerating, where cutover, and possibly developing a transitional phase to raised bog formation. Threats to the site are likely to be scrub clearance. 6.3.3.12 Cloonlara House 000028 This bat site is located in a three-storey domestic dwelling house and contains over l00 Leisler's Bats (Nyctalus leisleri) during the summer months. The main stairway of the house leads to a large room in the attic where a partition wall separates the room from the roosting site of the bats. The bats roost in the fascia boards and roof space at one of the gable ends. 6.3.3.13 Askerton Fen Complex SAC 002279 In Askeaton Fen Complex SAC a diversity of fen types are represented in a gradation from open water to drier seepage areas. One of the more important fen types, Cladium fen, which contains Great Fen-sedge (Cladium mariscus), occurs in various forms and is the most common fen type within the SAC. Alkaline fen is characterised by the presence of Black Bog-rush in association with brown mosses and a small sedge community. The soil is permanently waterlogged but generally not flooded unless for a short period. Examples of this fen type are Version date: 4.01.2014 2 of 2 002279_Rev13.Doc found at the edge of almost all the sites, but its extent is much less than the Great Fen-sedge fen type within the SAC. A small area of limestone species-rich grassland is found to the north of Balinvirick fen. Species found which are typically associated with the habitat include the Earlypurple Orchid (Orchis mascula), Carline Thistle (Carlina vulgaris) and Mountain Everlasting (Antennaria dioica). Land use in the area is quite intensive, with improved grassland extending down relatively steep slopes to the edge of the fens/loughs. New drainage or the deepening of existing drains poses a threat to the aquatic habitats at the site. In some instances, the fens appear to be drying out. For inspection purposes only. Consent of copyright owner required for any other use. 6.3.3.14 Castleconnell (Domestic Dwelling, Occupied) 000433 No Information Available on the NPWS pNHA Database. 6.3.3.15 Curraghchase Wood SAC & pNHA 000174 One of the main interests at the site is the presence of a hibernation site of the Lesser Horseshoe Bat. The bats hibernate in the cellars of the former mansion Curraghchase House. The entrance to the cellar is now grilled and all other access points blocked to prevent disturbance. In recent years bats have remained within the cellar throughout the year. The semi-natural habitats within the site provide ideal foraging habitat for the Lesser Horseshoe Bat. Further planting of conifer tree species at the expense of deciduous species should be avoided and attempts should be made to increase the area of deciduous woodland. The combination of a secure hibernation site and suitable foraging habitat and the presence of over 60 individuals make Curraghchase Woods an internationally important site for the Lesser Horseshoe Bat. The woodland consists of both deciduous species and stands of commercial conifers. Beech (Fagus sylvatica) is the most frequent deciduous species, but Pedunculate Oak (Quercus robur), Ash (Fraxinus excelsior), Sycamore (Acer pseudoplatanus) and Hornbeam (Carpinus betulus) are also present. by Environmental Impact Services 37 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity The alluvial forest occurs in the southern part of the site and occupies low ground in a stream valley and some areas adjacent to a small lake. A series of small lakes and fens runs the length of the site. Some of these lakes are overgrown with vegetation. 6.3.3.16 Lough Gur 000437 Two large wetlands are associated with the site: Lake Bog lies to the east, between Loughgur cross and Knockadoon Hill, and Red Bog occupies an area to the south. The water quality of the lake is notoriously poor – high levels of nutrients promote regular blooms of algae, which lead to oxygen debt and its associated problems, including offensive smells. There are also areas of wet grassland and marshland. Knockadoon Hill is a limestone hill whose surface runoff drains into the wetlands of the site. The open water and wetlands support a great variety, and important numbers of waterbirds. The open water however shows obvious signs of nutrient enrichment and must now be regarded as vulnerable to a collapse in the current ecological function, to be replaced by a system unfavourable for higher aquatic plant growth. 6.3.4 RECORDS OF PROTECTED, RARE OR OTHER NOTABLE FLORA AND FAUNA SPECIES The digital database of the National Biodiversity Data Centre (NBDC) was consulted to assess known records of rare, protected and invasive species that occur in the surrounding landscape. The collation of this information, as well as examination of aerial photographs allowed areas of potential ecological importance to be highlighted prior to field survey work. A search was undertaken of records of Red Data Book and Protected species held by the National Biological Data Centre Database. Records of Rare or Protected Species from the 10 km x 10 km grid squares occupied by the study area (R55; see Figure 6.3Figure 6.3) are listed in Appendix 6.1[NBDC data]. For inspection purposes only. Consent of copyright owner required for any other use. Figure 6.3 Site location within the NBDC hectad (10 x 10 km Grid Square); R55. by Environmental Impact Services 38 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity 6.3.4.1 Invasive Flora Species Publicly available NBDC data was accessed to identify invasive species in the hectads in which the Project is located (R55). Four of flora species listed below are subject to restrictions (Third Schedule) under Regulation 49 of the European Communities (Birds and Natural Habitats) Regulations, 2011. Scientific Name Common Name Flora Acer pseudoplatanus Sycamore Azolla filiculoides Water Fern Buddleja davidii Butterfly-bush Clematis vitalba Traveller's-joy Elodea canadensis* Canadian Waterweed Elodea nuttallii* Nuttall's Waterweed Erucastrum gallicum Hairy Rocket Fallopia japonica* Japanese Knotweed Heracleum mantegazzianum* Giant Hogweed Impatiens glandulifera Indian Balsam Lemna minuta Least Duckweed Leuciscus leuciscus Dace Thlaspi arvense Field Penny-cress Fauna Anser anser Greylag Goose Candidula intersecta Wrinkled Snail Cornu aspersum Common Garden Snail Crocidura russula Greater White-toothed Shrew Dama dama Fallow Deer Dreissena (Dreissena) polymorpha Zebra Mussel Mus musculus House Mouse Myodes glareolus Bank Vole Oryctolagus cuniculus European Rabbit For inspection purposes only. Physella acuta Consent of copyright owner requiredAcute for any Bladder other use. Snai Potamopyrgus antipodarum Jenkins' Spire Snail Rattus norvegicus Brown Rat Sciurus carolinensis Eastern Grey Squirrel Tandonia budapestensis Budapest Slug Tandonia sowerbyi Keeled Slug * subject to restrictions (Third Schedule) under Regulation 49 of the European Communities (Birds and Natural Habitats) Regulations, 2011 6.3.5 FIELD SURVEY RESULTS 6.3.5.1 Flora None of the habitats on the site were found to contain Annex I type habitat; additionally, all of the habitats present on site were of low or moderate ecological importance at both landscape and local scales. Habitats recorded on site include Buildings and Artificial Surfaces (BL3), Re-colonised Bare Ground (ED3), Hedgerows (WL1) & Treelines (WL2), Scrub (WS1), Dry Meadows and Grassy Verges (GS2), and Amenity Grassland (GA2); a full habitat map can be found in Figure 6.3Figure 6.3. No invasive species were found on site. by Environmental Impact Services 39 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity Figure 6.4 Habitats present on site24 Buildings and Artificial Surfaces (BL3) The Existing facility consists of a manufacturing plant and associated carpark, and access roads. For inspection purposes only. Re-colonised Bare Ground (ED3) Consent of copyright owner required for any other use. The recolonized areas are all heavily overgrown with weed species, especially nettles Urtica dioica and thistles, and with developing dense brambles in parts. A short remnant hedge section is dominated by willows. Hedgerows (WL1) & Treelines (WL2) There are some hedgerows present on site; Hawthorn Crataegus monogyna and blackthorn are the principal species, with ash Fraxinus excelsior the main tall tree species. Scrub (WS1) In the westernmost sector there is a ridge of rubble with scrub (WS1), including gorse Ulex europaeus, brambles Rubus fruticosus, willows Salix spp. and blackthorn Prunus spinosa. Associated with the rubble is an area of dry, open grassland with a calcareous element and including cowslip Primula veris and bird’s-foot trefoil Lotus corniculatus. 24 at 4th May 2017 by Environmental Impact Services 40 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity Dry Meadows and Grassy Verges (GS2) The western sector is former agricultural grassland but which now is reverting to a more semi-natural sward and can best be classified as Dry meadows and grassy verges (GS2). It is a tall (c.30 cm), coarse sward dominated by grasses such as Yorkshire fog Holcus lanatus, cock’s-foot Dactylis glomerata, and rye grass Lolium perenne. Herbaceous species are relatively scarce, with creeping buttercup Ranunculus repens, narrow-leaved plantain Plantago lanceolata, dandelions Taraxacum spp. and thistles Cirsium spp. Amenity Grassland (GA2) This habitat occurred in the south-western corner of the proposed development site in the form of what once was an agricultural field which was fragmented by the construction of Roches Avenue, providing access into the Raheen Business Park. It was dominated by Perennial Rye Grass Lolium perenne, Sweet Vernal Grass Anthoxanthum odoratum and Meadow Grass Poa pratensis with other common species indicative of artificial seeding and intensive management such as White Clover Trifolium perenne, Creeping Buttercup Ranunculus repens, Daisy Bellis perennis, Docks Rumex spp. and Creeping Thistle Cirsium arvense. It is currently maintained as an amenity area. Significant Adjacent Habitats found directly adjacent to the site were also mapped and considerations were made to assess the potential effects to these habitats that could arise from the proposed development (Figure 6.5Figure 6.5). These sites include ED3, WL1 and GS2 habitats which are Formatted: Font: 10 pt, Not Italic consistent with those described above. In addition to theses there are BL3 and Broadleaf Woodland (WD1) habitats present with ecologically distinctive characteristics. so 100 150 For inspection purposes only. Consent of copyright owner required for any other use. I Bl3 - Building and Artifical Surfaces I ED3 - Recolonised Bare Ground I G/Kl. - Amenity Grassland r GS2 - Dry Meadows and Grassy Verges I WDl - Mixed Broadleafed Woodand -.,,:~• • WLl - Hedgerow • WSl -Scrub Figure 6.5: Habitat map of significant habitats adjacent to the Regeneron Site Buildings and Artificial Surfaces (BL3) Adjacent to the site there are some existing farmhouse buildings (Figure 6.4) and associated courtyards. by Environmental Impact Services 41 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity Figure 6.6 Farm buildings and farmyard in site no. 47 Broadleaf Woodland (WD1) The main feature of the receiving environment is a stand of woodland which extends from the south- southwest of the castle and farm complex. It covers an area estimated at 2 ha. This woodland is dominated by beech Fagus sylvatica and ash Fraxinus excelsior trees, with sycamore Acer pseudoplatanus occasional along with a few oaks Quercus spp. A group of mature cypress (Cupressus spp.) trees is present near the farm complex and at least one further cypress occurs within the main woodland stand. Hawthorn occurs as an understorey species. The trees are mostly mature with some notably large specimens. The ground layer is dominated by ivy Hedera helix, with a range of typical woodland herbaceous species such as bluebell Hyacinthoides non-scripta, lords and ladies Arum maculatum, lesser celandine Ranunculus ficaria, dog violet Viola reichenbachiana, and sanicle Sanicula europaea. Brambles are frequent in places. Ferns are present including Asplenium scolopendrium and Dryopteris felix-mas. 6.3.5.2 Fauna Mammals For inspection purposes only. Consent of copyright owner required for any other use. Rabbits are frequent throughout the site, with several sightings and much evidence of burrowing. Evidence of red fox was also present. While there was no evidence in the survey of badger presence, it is possible that badgers would occur on site and full search would be required in winter (when vegetation has died back) to establish their status on site. Various small mammal species would be expected, including brown rat, field mouse, pygmy shrew and possibly hedgehog (latter two species protected in Wildlife Acts). The site has low potential to support bats, with the hedgerow providing a foraging line though negligible or low value for roosts. Birds Five Amber-listed species were recorded breeding directly adjacent to the site in the woodland patch – robin, stonechat, swallow, starling and linnet. The woodland supports a range of common species of woodland and scrub habitats, including blackbird, song thrush, mistle thrush (Amber-listed), wren, chaffinch, willow warbler, blackcap and treecreeper. Sparrowhawk would be expected. There is a low chance that barn owl could occur within the buildings and/or mature trees. The habitats within the site would not be expected to support any wintering bird species of conservation importance. The habitats on site would not be expected to support any wintering bird species of conservation importance. by Environmental Impact Services 42 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity Protected Fish, Amphibians & Reptiles The survey did not locate any frog breeding ponds though the common frog is a widespread species and would be expected in drains and damp patches within the adjacent woodland. The site does not have suitable habitat for the common lizard. 6.3.6 SUMMARY OF ECOLOGICAL EVALUATION Overall, the sites of the proposed car parking and contractors' compound areas can be considered as having low ecological value, which reflect their past use as agricultural land. The grassland and disturbed ground habitats are of negligible interest, with the hedgerow strip of some local interest due to the presence of sparse large trees. The fauna species associated with the site are all widespread and common species of the countryside. Based on the site survey and other available information The presence of cowslips in the grassland is of some note as this species is listed in the Irish Red Data Book as being threatened in Northern Ireland, though the status is not of concern in the Republic (Wyse Jackson et al. 2016). The adjacent woodland area is a feature of some ecological interest. While of planted origin, it comprises a significant number of mature trees, including native ash, and of particular interest is it appears that the ground here has been in woodland since at least the early 1990s. It is of moderate size (c.2 ha) and similarly sized woodland stands would not be common, especially close to a city. The woodland is functioning well, with regeneration of trees, and it has a typical ground flora. The wood is expected to support bat species and is useful to a range of other fauna species (though most would be common in similar habitats). The value of the wood could be improved by appropriate management, including removal of litter and undesirable alien species. Overall, the wood is rated as Local Importance (higher value). The accompanying strip of unmanaged grassland is not of any particular value though does complement the adjoining woodland. The fauna species associated with the site are all widespread and common species of the countryside. Based on the site survey and other available information, a rating of Local Importance (between lower to higher values) is assigned to the site. 6.3.6.1 Previous Assessments For inspection purposes only. Consent of copyright owner required for any other use. The results shown above are consistent with the ecological evaluation of the site in 2013. The Flora and Fauna section of an EIS for the conversion of the former Dell factory for use by Regeneron (prepared by Scott Cawley on behalf of PM Group, with ecological assessment carried out in November 2013) found low value ecological habitat at a local level, and there were 2 designated sites in proximity to the site that had sensitive ecological receptors. Results from this report are summarised in Table 6.3 below. by Environmental Impact Services 43 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity Table 6.3 Summary of the Ecological evaluation from the Flora and Fauna section of a previous EIS Habitat / Species Highest Ecological Sensitive Valuation Level Ecological (Importance) Receptor? Designated Sites River Fergus and River Shannon SPA and International Yes Lower River Shannon cSAC downstream of the proposed development site Loughmore Common Turlough pNHA National-International No Protected Fauna Species Potential Roosting Bats (in buildings on site with low Local (Lower Value) No potential for supporting bats) Foraging/Commuting Bats (within habitats Local (Lower Value) No with low suitability for bats) Pygmy Shrew & Hedgehog Local (Lower Value) No Breeding Birds Local (Lower Value) No Non-protected Fauna Small mammals (e.g. Pygmy Shrew, Local (Lower Value) No Hedgehog, rats and mice) Habitats & Flora GA2 Amenity Grassland Local (Lower Value) No GS2 Dry meadows & grassy verges Local (Lower Value) No WS1 Scrub Local (Lower Value) No WS3 Ornamental/non-native shrub Local (Lower Value) No WL1 Hedgerows Local (Lower Value) No BL3 Buildings and artificial surfaces Local (Lower Value) No 6.4 POTENTIAL IMPACTS Based on the baseline ecological environment and the extent and characteristics of the proposed For inspection purposes only. development the following potentialConsent impacts of copyright have owner been required identified: for any other use. Impacts on Surface Water Earthworks Lighting during construction and operation Noise and vibration These potential impacts are discussed in the following paragraphs. Impacts on Surface Water The CEMP details measure to prevent accidental spill offs and to enact a SUDs scheme across the site. Interactions with surface water are therefore thought to be minimal as there are no existing water courses across the site or in the immediate vicinity. Earthworks The CEMP dictates that a dust control strategy must be implemented for all construction works. The existing site is a construction site and there are no habitats present on site that are of any ecological value. The earthworks proposed within the project description will not have effects beyond the site boundary. by Environmental Impact Services 44 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity Lighting during construction and operation Strong lighting in the area of the proposed development could spill outward to the perimeter if not carefully controlled. Bats, other mammals, and birds would be sensitive to any significant changes in lighting within semi-natural habitat to the north of the development site. In the case of bats, they would be likely to find alternative routes around the lit areas but this can result in changes to local populations if feeding areas cannot be reached. The potential risk to bat populations is very low as the area has low-moderate habitat suitability for bats. None-the-less it is important to minimise light pollution as a matter of good practice. This is reflected in the CEMP for the site. Noise/vibration The construction phase and movement of heavy vehicles across the site could cause localised disturbance of breeding birds that may use the perimeter vegetation. This would be expected to have a probable, significant short-term impact at a local level but there is likely to be an existing degree of habituation to regular traffic on the site so this impact may not be across the whole area. Bird species are particularly sensitive to disturbance effects due to increased noise and on-site activity; no protected bird species were recorded on site; however, 5 amber listed species were noted. An assessment of the project detail outlined in Section 4 indicates the potential impacts to biodiversity are predominantly associated with construction phase works which are temporary/short term. The site was found to have predominantly low ecological value, with higher local value associated with the adjacent broadleaf woodland patch, following the CIEEM (2016) Ecological Impact Assessment Guidelines informed by the results of both the desktop study and the field surveys. The operational phase elements of the project are thought to have negligible impacts given the low ecological value of the existing habitats. The potential operational phase impacts are predominantly associated with dust and noise associated with increased traffic and activity on site facilitated by the additional onsite parking. 6.4.1 POTENTIAL IMPACTS ON DESIGNATED SITES The AA Screening Report sets out the likelihood and significance of any potential impacts on European designated sites. There are no significant adverse effects foreseen to be likely to affect the ecological integrity of any European Sites. There are no NHA’s within the zone of influence of the project. The Loughmore Common Turlough pNHA is within 1 km of the Regeneron site however, the For inspection purposes only. main threats to the site are drainage,Consent agriculturalof copyright owner reclamation, required for any other pollution use. and afforestation. None of the proposed characteristics of the project will impose additional threats to this site as best practice guidelines outlined in the construction environmental management plan will be followed to ensure minimal interaction with the hydrodynamic properties of the surrounding area. 6.5 MITIGATION MEASURES An outline Construction Environmental Management Plan (CEMP) accompanies Project Description and provides additional management measures which will be implemented during construction. The CEMP has detailed methods relating to the control of the following potential impacts: Noise Chemicals – Other Than Fuel, Lubricants and Solvents Dust Water Protection Waste Management Protection of Flora and Fauna Site Lighting by Environmental Impact Services 45 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Biodiversity 6.6 CUMULATIVE IMPACTS A review of planning applications in proximity to the proposed development was undertaken to assess the possibility of cumulative impact arising from proposed development at Regeneron and proposed developments in the sites environs. No largescale developments have been identified within proximity to the Regeneron facility. The planning applications within the area relate to site use change and small single-story developments or permission retention applications. A full list of projects in the surrounding area can be found in the planning report. The receiving environment has low ecological value, except for the broadleaf woodland habitat which has been identified at site no. 47. The proposed project will not directly impact the woodland patch and the operational phase of the project has very-low levels of impacts identified. These factors combined with the robust mitigation measures within the CEMP further reduce potential impacts. Therefore, the project is not expected to contribute significant cumulative impacts. 6.7 RESIDUAL IMPACTS The broadleaf woodland area identified above will not be directly impacted by the proposed project. Given the low local ecological value of the receiving environment and the current site usage, the potential impacts to ecological processes are negligible. Following the management measures detailed in the project description and within the CEMP, potential impacts to the flora and fauna of the existing environment are foreseen to be very low. The characteristics of the development detailed above indicate any potential impacts will be localised due to the magnitude of works being undertaken. The existing site is of low ecological value, with no protected species or habitat features identified. 6.8 MONITORING The impacts are foreseen to be very low due to the characteristics of the project, and the ecological value of the receiving environment is also low. Monitoring measures are proposed during construction phase and compliance with the CEMP; this is detailed in the policies of the plan which commit to ensure compliance with the CEMP by all contracted workers. This process is foreseen to be sufficient monitoring with regard to ecological impacts and the integrity of the wider landscape ecology. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 46 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. 7 LAND, SOILS, GEOLOGY & HYDROGEOLOGY 7.1 INTRODUCTION/METHODOLOGY 7.1.1 INTRODUCTION The following section presents an assessment of the impacts of the proposed development in terms of land, soils, geology and hydrogeology of the local environment as defined in the Environmental Protection Agency (EPA) Guidelines, refer to Section 2.1 where these guidelines are explained. Also, in accordance with the Institute of Geologists (IGI) ‘Guidelines for the Preparation of Soils, Geology and Hydrogeology Chapters of Environmental Impact Statements’ (IGI, 2013). In assessing likely potential and predicted impacts on the land, soils, geology and hydrogeology, account has been taken of both the importance of the attributes and the predicted scale and duration of the likely impacts. 7.1.2 METHODOLOGY The rating of potential environmental impacts on the soils and geology environment is based on the matrix presented in Appendix 7.1, Table 7.1 – ‘Glossary of Impacts following EPA Guidance Documents’ which takes account of the quality, significance, duration and type of impact characteristic identified. In the EIAR assessment, consideration is given to both the importance of an attribute and the magnitude of the potential environmental impacts of the proposed activities on that attribute. The principal attributes (and impacts) to be assessed include the following: Geological heritage sites in the vicinity of the perimeter of the subject site; Landfills, industrial sites in the vicinity of the site and the potential risk of encountering contaminated ground; The quality, drainage characteristics and range of agricultural uses of soil around the site; Quarries or mines in the vicinity, the For potentialinspection purposes implications only. (if any) for existing activities and Consent of copyright owner required for any other use. extractable reserves; The extent of topsoil and subsoil cover and the potential use of this material on site as well or requirement to remove it off-site as waste for disposal or recovery; High-yielding water supply springs/ wells in the vicinity of the site to within a 2 km radius and the potential for increased risk presented by the proposed development; Classification (regionally important, locally important etc) and extent of aquifers underlying the site perimeter area and increased risks presented to them by the proposed development associated with aspects such as for example removal of subsoil cover, removal of aquifer (in whole or part), drawdown in water levels, alteration in established flow regimes, change in groundwater quality; Natural hydrogeological/ karst features in the area and potential for increased risk presented by the activities at the site; and Groundwater-fed ecosystems and the increased risk presented by operations both spatially and temporally. by Environmental Impact Services 47 EPA Export 30-11-2018:04:49:40 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. Sources of Information Desk-based geological information on the substrata (both Quaternary deposits and bedrock geology) underlying the extent of the site was obtained through accessing databases and other archives where available. Data was sourced from the following: Geological Survey of Ireland (GSI) - on-line mapping, Geo-hazard Database, Geological Heritage Sites & Sites of Special Scientific Interest, Bedrock Memoirs and 1:100,000 mapping; Teagasc soil and subsoil database; Ordnance Survey Ireland - aerial photographs and historical mapping; Environmental Protection Agency (EPA) – website mapping and database information; National Parks and Wildlife Services (NPWS) – Protected Site Register; and Limerick City & County Council - illegal landfill information. Site specific data was derived from the following sources (refer also Appendix 7.2 and 7.3): Jacobs Engineering Site Layout Drawings; Environmental Impact Statement for Regeneron Ireland, PM Group, December 2013; and Environmental Site Assessment Former Dell EMF3 Facility Raheen Business Park Limerick, O’Callaghan Moran Associated, September 2013. 7.2 THE PROPOSED DEVELOPMENT The proposed development is described in detail in Section 4 Project Description. Specific elements relevant to this section are described below. 7.2.1 CONSTRUCTION PHASE The proposed construction works are anticipated to take approximately 36 months. The proposed development is an extension to the existing Regeneron manufacturing facility with a total footprint of 12,707m2. The key civil engineering works which For will inspection have purposes potential only. impact on the land, soils, geology and hydrogeology environment at the proposedConsent of copyright development owner required include: for any other use. Excavation for levelling and foundations. The proposed development is to be located on an existing area of hardstanding to the east of the current Regeneron facility. The excavation phase will involve stripping surface hardstanding and excavating into gravelly clays of up to c. 2.5m below ground level (bgl). No significant dewatering is expected based on the nature of the shallow ground conditions and recorded water table levels. Site development including enabling works will result in localised removal of the ‘protective’ hardstanding (i.e. no change in hardstanding area), tarmacadam, topsoil and subsoil cover in an area to the north east of the site where the new facility is to be constructed. This will be replaced by hardstand including buildings which will also provide a protective cover when built. 7.2.2 OPERATIONAL PHASE There will be no direct discharge to ground required for the operation of the proposed development of this facility. Water supply will be from the public water supply and domestic effluent and trade effluent (post-treatment) discharge will be to public sewer in accordance with existing infrastructure on the site. by Environmental Impact Services 48 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. The potential operational impacts which require consideration include the following: Any changes to stormwater and surface water runoff from the site. The storage of bulk chemicals and fuels onsite. Management of accidental discharges. The area proposed for redevelopment is already zoned for E2 ‘General Enterprise and Employment’. The land is currently used as a bio-pharma production facility and therefore there is no change in current land use. 7.3 THE RECEIVING ENVIRONMENT 7.3.1 SITE AREA DESCRIPTION The Regeneron Site is located within an established industrial park in Raheen, Limerick approximately 5 km south east of Limerick City centre. The site has a number of access roads to the west, south- west and south-east. A number of industrial buildings are situated to the south, north and east with some agricultural and green-field sites to the west. 7.3.2 SITE TOPOGRAPHY The topography of the site is moderately undulating and varies in elevation between 22 m AOD (approx.) to 25 m AOD (approx.). The gradient of the ground is in a south-south westerly direction. 7.3.3 DRAINAGE The existing drainage is discussed in more detail in Section 8 Water & Hydrology. Arterial drainage is in a western direction from the Raheen Business Park. Storm water drainage from the business park site passes through a petrol interceptor before joining a public culvert/pipe storm water route to Loughmore Common Canal, which enters the Barnakyle River (Water body code IE_SH_24_1704) which subsequently flows into the Maigue River and then discharges to the River Shannon. The Maigue River (7.2 km to the west) and River Shannon (3.8 km to the north) fall within both special areas of conservation (SAC) 2165 and special protection area (SPA) 4077. Process water is treated onsite before release to the public sewer system. For inspection purposes only. 7.3.4 LAND USE Consent of copyright owner required for any other use. The site is located in Raheen Business Park, Limerick which is within the townland of Ballycumin to the south west of Limerick City. The Regeneron site is bounded to the west by Roches Avenue, industrial units to the north and east, with further industrial units separated by green fields to the south. There are no private residences in close proximity to the existing facility or proposed development. The site and all immediate surrounding lands have been zoned for enterprise and employment under the Limerick County Council Southern Environs Local Area Plan 2011-2017 (extended to May 2021). According to the EPA website, there is one other IPPC/IED licensed facility in the locality (Stryker Orthopaedics). There are no licensed waste sites in the vicinity (1 km) of the subject site. The site is currently occupied by Regeneron Ireland and was previously the site of a Dell computers production facility. 7.3.5 SOILS AND SUBSOILS Figure 7.1 presents the soil and subsoil types predominantly at and surrounding the Regeneron site25. The site including the proposed development consist of tills derived from the underlying limestone and made ground. 25 GSI (2017) Online Mapping accessed August 2017 http://gsi.ie/Mapping.htm by Environmental Impact Services 49 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. Figure 7.1 Soil Maps26 The natural subsoil type located at the proposed development is predominantly glacial tills (carboniferous limestone till). Based on the site investigation undertaken at the site between 3rd and 6th of September 201327 the site is underlain by gravelly clays at the western boundary, fill material underlain by sandy gravely clays with boulders to the east with gravelly clays to the north west of the For inspection purposes only. site. Consent of copyright owner required for any other use. 4 no. trial pits were advanced throughout the site during the investigation mentioned above, figure 7.2 shows the location of these. Topsoil was found to extend to a maximum depth of 0.60 m below ground level (bgl). The underlying subsoils at the south western boundary where TP-1 was excavated, compromise granular fill (0.6 m to 1.2 m bgl) underlain by sandy gravely clay to 2.3 m bgl. TP-2 was excavated at the western boundary to the north of TP1, here the ground compromises topsoil to 0.5 m bgl which is underlain by stiff gravelly clay. Bedrock was encountered at 1.3m bgl in TP-3 to the north east of the site. Subsoils at TP-3 compromise clean fill material, sandy gravely clay with boulders to a depth of 3 m bgl. At TP-4 the soils compromise a layer of topsoil underlain by gravelly clay and gravels with clay lenses to 2.2 m bgl. As part of the same investigation 5 no. shallow exploratory boreholes and 4no. soil bores (reference figure 7.2) were installed throughout the site. The soils excavated from the trial pits were inspected for any visual signs of contamination (odours or staining etc.). Soil quality testing was undertaken from soil samples recovered from all four trial pits and 3 no. soil bore locations (SB-1, SB-2 & SB-3) for VOCs, PAHs, PCBs, BTEX, total petroleum hydrocarbons, inorganics, pH, pesticides, asbestos and 26 GSI (2017) Online Mapping accessed August 2017 http://gsi.ie/Mapping.htm 27 Environmental Site Assessment Formel Dell EMF3 Facility Raheen Business Park Limerick, OCM, September 2013. by Environmental Impact Services 50 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. soluble sulphate. The laboratory analysis detected no soil contamination in any of the samples. Analytical results from the 2013 investigation can be viewed in Appendix 7.2 Bedrock was encountered at 4.1 m below ground level (bgl) at MW-1, at 2.2 m bgl at MW-2, 1.5 m at MW-3, 0.8 m at MW-4 and 1.2 m at MW-05. Project Regeneron EIAR Reference 17_9473 FlgUfe 7.2 Site Investigation Location September 2013 ~ awnc nsulunq Untt 5, ATS Building. C.trigalin. Industrial Est.lit•. Carrig81M. Co CoR T: +3!SJ 21 438 7400 F +353 21 483 4000 Figure 7.2 Site Investigation Locations28 7.3.6 GEOLOGY For inspection purposes only. Consent of copyright owner required for any other use. Information obtained from the GSI (2017) indicates a sequence of different lithological groups within the area surrounding the site. As shown in Figure 7.3 below, it is perceived that the site is underlain by basalt and other volcanic rocks. However, during the site investigation undertaken on site in 2013 the presence of fine to medium grained limestone beneath the site at depth from 0.8 m to 4.1 m bgl. The limestone is described as Carboniferous limestone of the Waulsortian Formation. The Waulsortian Formation consists of large areas of unbedded limestone which is prone to karstification. 28 PM Group (2013) Environmental Impact Statement for Regeneron Ireland by Environmental Impact Services 51 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. N A VIS Legend Geology Basalt \isean limestones (undifferentiated) Volcanldastoe Rocks D s.1. eound•v Olun 0.Slun 1.0lun Sa.ic. E.sr Oqt.Gcibl> GtcE • Ea1'illafC«9•~o O,f>"-~tO ..1i.C,._ V$Ci .._cOfUC' o-... ng .. 1or-.~ ... - Oflly Dona oc.o• rot.to.GIS 1«~~ Figure 7.3 Site Geology29 7.3.7 GEOLOGICAL HERITAGE The GSI Public Viewer on-line mapping30 was reviewed to identify sites of geological heritage for the site and surrounding area. There is no evidence of any site which could be considered suitable for protection under this programme or recorded in the Limerick City and County Council’s Southern Environs Local Area Plan 2011-2017 (extended until May 2021). The nearest recorded site i.e. Mungret Quarry, which is located 3.5 km northwest of the site. For inspection purposes only. Consent of copyright owner required for any other use. 7.3.8 ECONOMIC GEOLOGY The extractive industry register31 and the GSI mineral data base were consulted to determine whether there were any mineral sites close to the subject site. There are no active extractive or mineral sites located within 5 km from the site. 7.3.9 GEO-HAZARDS According to the GSI on-line database, there are no records of geo-hazards (i.e. landslides) with a 10 km radius of the site. 7.3.10 RADON Based on the National Reference level of 200 Becquerel (Bq)/m3, radon concentrations for the area around the proposed development are considered low with 1-5% of homes in exceedance. 29 GSI (2017) Online Mapping accessed August 2017 http://gsi.ie/Mapping.htm 30 GSI (2017) Online Mapping accessed August 2017 http://gsi.ie/Mapping.htm 31 EPA (2017) Online Envision EPA Mapping accessed August 2017 http://gis.epa.ie/Envision by Environmental Impact Services 52 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. 7.3.11 AQUIFER CLASSIFICATION Groundwater can be defined as water that is stored in, or moves through, pores and cracks in sub- soils. The potential of rock to store and transport water is governed by permeability of which there are two types, inter-granular and fissure permeability. Inter-granular permeability is found in sediments, sands, gravels and clays as are also present at the subject site, and fissure permeability which is found in bedrock, where water moves through (and is stored in) cracks, fissures, fracture planes and solution openings for example. Aquifers are generally classified as rocks or other matrices that contain sufficient void spaces and which are permeable enough to allow water to flow through them in significant quantities. The GSI (2017) classifies the principal aquifer types in Ireland as: Bedrock Aquifer o Lk - Locally Important Aquifer - Karstified o Ll - Locally Important Aquifer - Bedrock which is Moderately Productive only in Local Zones o Lm - Locally Important Aquifer - Bedrock which is Generally Moderately Productive o Pl - Poor Aquifer - Bedrock which is Generally Unproductive except for Local Zones o Pu - Poor Aquifer - Bedrock which is Generally Unproductive o Rkd - Regionally Important Aquifer (karstified diffuse) Gravel Aquifer o Lg - Locally Important Aquifer - Sand & Gravel o Rg - Regionally Important Aquifer - Sand & Gravel Reference to the GSI (2017) National Draft Bedrock Aquifer Map for the site (see Figure 7.4 below) indicates that the site is underlain by a (Ll) Locally Important Bedrock Aquifer, which is moderately productive, only in local zones. N A For inspection purposes only. Consent of copyright owner required for any other use. Lm Legend DE SCRIPT Locallyl mportantAQLMfer- Bedroet which a G~erallyM oder1tely Produc:DVe locally Im port.nt Aq1J1ltr. Bedroet wtweh • WoderatelyP roduct:.,.e only 1n loC»I Zones c::J Site Boundary 0 0125 025 05 ----====i------•Kilometers Scum Eu C>g.t410ct» C«!E..1• Ur -.r.rc.;egirapt by Environmental Impact Services 53 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. LI classified aquifers characteristically have well yields in the order of 100 m3 per day however according to the GSI well data base well yields are poor in the area around the site (refer Table 7.1 Appendix 7.1). This would indicate a low transmissivity (T) of the underlying bedrock formation. 7.3.12 AQUIFER VULNERABILITY Aquifer vulnerability is a term used to represent the intrinsic geological and hydrogeological characteristics that determine the ease with which groundwater may be contaminated generally by human activities. Due to the nature of the flow of groundwater through bedrock in Ireland, which is almost completely through fissures, the main feature that protects groundwater from contamination, and therefore the most important feature in protection of groundwater, is the subsoil (which can consist solely/ or of mixtures of peat, sand, gravel, glacial till, clays or silts). The GSI (2017) Interim Vulnerability Map (see Figure 7.5 below32) presently classifies the aquifer in the area of the subject site as predominantly High (H) which indicates an overburden depth of 3-5 m of low permeability soil is present. The bedrock boreholes installed onsite during the September 2013 site investigation encountered rock at 0.8-4.1 m bgl indicating that the aquifer vulnerability ranges from high to extreme33. N A For inspection purposes only. Legend Consent of copyright owner required for any other use. c:J Site Boundary Groundwat..- Vulner.ibility 2013 Aquif..-VulnwabNity l, low M, Moderete H,HI~ E, Extreme X. Roc:k 1t or near Surfloeor Kerst Figure 7.5 Aquifer Vulnerability Map 7.3.13 GROUNDWATER QUALITY The European Communities Directive 2000/60/EC established a framework for community action in the field of water policy, (commonly known as the Water Framework Directive [WFD]). The WFD required ‘Good Water Status’ for all European waters by December 2015, to be achieved through a 32 GSI (2017) Online Mapping accessed August 2017 http://gsi.ie/Mapping.htm 33 O’Callaghan Moran Associated (2013) Environmental Site Assessment Formel Dell EMF3 Facility Raheen Businees Park Limerick, September 2013. by Environmental Impact Services 54 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. system of river basin management planning and extensive monitoring. ‘Good status’ means both ‘Good Ecological Status’ and ‘Good Chemical Status’. The Groundwater Body (GWB) underlying the site is Limerick Southwest. Currently, the EPA (2017) on-line mapping classifies the Limerick Southwest body as having ‘Poor Status’, with a WFD risk of not achieving good status. Groundwater samples are collected and analysed on a biannual basis in compliance with Regeneron’s IED licence (Reg. No. P0991-01) from four onsite well AGW1, AG2, AG3 & AG4 the locations of these wells can be seen in Figure 7.6 below. For inspection purposes only. Consent of copyright owner required for any other use. Figure 7.6 Aquifer Vulnerability Map The groundwater boreholes were sampled and analysed for a full range of parameters including; - Diesel Range Organics (DRO) - COD & pH - Metals (As, Cd, Cr, Pb, Hg, Cu, Ni, K, Zn, Mn, Fe and B) - Polychlorinated Biphenyls (PCB) - Volatile Organic Compounds (VOC) - Semi Volatile Organic Compounds (SVOC) - Major Cations & Anions (Chloride, Sulphate, Nitrate, Nitrite, Sodium, Potassium) - Pesticides - E-Coli - Glycols (Alcohols) - Total PAH’s - Total Coliforms The results summarised in Appendix 7.3 shows no exceedances above the available groundwater threshold values (GTV’s) for a number of indicator parameters in the samples tested from all 4 monitoring wells. These include PCB’s, pesticides, VOCs, sodium, total PAH’s and glycols. The by Environmental Impact Services 55 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. chemicals of concern stored in bulk onsite are ethanol, phosphoric acid and sodium hydroxide. The slight exceedances of the GTVs seen for some parameters do not indicate any connection to onsite activities. 7.3.14 GROUNDWATER WELLS (OFF-SITE WELLS) There is no licencing system for wells in Ireland at present and as such no complete data set exists. The GSI (2017) Well Card data search included the nearest approximate wells to the subject quarry site; these are presented in Figure 7.6 below. The wells recorded by the GSI in the area surrounding the site were generally installed within the underlying bedrock at depths ranging from of ~4.9 m to ~62.5 mbgl. The groundwater yield for these wells is recorded as ranging from poor to moderate with recorded yields as little as ~5.5 m3/d in a well drilled to 4.9 mbgl in Derrybeg (well closest to the site with available information), up to ~76.4 m3/day in a well drilled to 62.5 mbgl in the townland of Routagh. Table 7.134 below presents a summary of the groundwater supply wells included in the GSI well search for the general area surrounding the subject quarry site, and provides an indication of the yield estimates for each. Table 7.1 GSI Well Index Table from Well Search Depth to GSI Name Depth Bedrock(m) Townland County Use Yield Class Yield m3/d 1415SEW026 30.5 GOULDAVOHER Limerick Unknown 1415SEW027 4.9 DERRYBEG Limerick Unknown Poor 5.5 1415SEW028 18.9 14.3 BALLYSHEEDY WEST Limerick Unknown Poor 16.4 1415SEW029 5.2 5.2 DERRYBEG Limerick Unknown Poor 21.8 1415SEW030 18.3 6.7 BALLYSHEEDY EAST Limerick Unknown Poor 27.3 1415SEW033 36.6 2.4 ROXBOROUGH Limerick Unknown Poor 27.3 1415SEW068 62.5 6.1 ROUTAGH Limerick Domestic use only Moderate 76.4 For inspection purposes only. Consent of copyright owner required for any other use. 34 GSI (2017) Online Mapping accessed August 2017 http://gsi.ie/Mapping.htm by Environmental Impact Services 56 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. c:J :)jte Boundary • GSI GroundVleterWelSea rci'I( 10~0m) c:J GSI Weis (250~500m) GSI Weis (1 km) Figure 7.7 GSI Well Search 7.3.15 GROUNDWATER LEVEL AND FLOW Currently there are 4 onsite groundwater monitoring well. The standing water level of these was measured on the 24th April 2017 the results can be viewed in Table 7.2 below. For inspectionth purposes only. Table 7.2 Onsite Groundwater Consentlevels of 24copyright April owner required2017 for any other use. Well I.D. Well Survey Relative Groundwater Level Ground Water Elevation (mASD) 35 mbtoc36 Level (mASD) (17/04/17) AGW-01 10.17 5.83 4.34 AGW-02 10.45 6.46 3.99 AGW-03 6.075 3.45 2.63 AGW-04 9.4 6.57 2.83 Groundwater flow is interpreted to be in the direction of the Barnakyle River approximately 200m west of the site i.e. flow is likely to be mainly from north and north east to the south and southwest. Groundwater flow is also depicted as part of the Conceptual Site Model (CSM) for the site which shows the assumed direction of groundwater flow along the profile indicated (refer Figure 7.7). Overburden and bedrock levels are based on the 2013 Site Investigations performed by O’Callaghan Moran Associates37. Figure 7.8 illustrates the regional cross section. 35 mASD – metres above site datum 36 Mbtoc – metres below top of casing 37 O’Callaghan Moran Associated (2013) Environmental Site Assessment Formel Dell EMF3 Facility Raheen Businees Park Limerick, September 2013. by Environmental Impact Services 57 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. Note: Drawing is for illustrative purposes only; Do not scale Note: For the purpose of the regional section, elevation has been taken from Ordnance Survey 1:50,000 Discovery. Superficial deposits are generalised for presentation -bedrock inferred from Geological Survey of Ireland Vulnerability Mapping, and is indicative only. Refer to local section/ geological setting of site. KEY SWL (Static Water Level) Monitoring Well (MW) Regional Groundwater Flow Direction Inferred potentiometric surface WEST X 24 22 X' 20 18 EAST Extension 16 QC Lab 14 Current Production Building mASD 12 AGW2 12 AGW1 10 AGW4 10 8 Sandy-gravelly Clay 8 6 6 4 4 2 2 0 0 Ground Elevation (mASD) Elevation Ground -2 Groundwater Flow (Assumed) -2 -4 -4 -6 -6 -8 Waulsortian Limestone -8 -10 -10 -12 420 400 380 360 340 320 300 280 260 240 220 200 180 160 140 120 100 80 60 40 20 0 For inspection purposes only. Horizontal ProfileConsent (0.6Km) of copyright (Scale owner is Exaggerated; required for anyApproximate other use. only) Figure 7.8 Site Conceptual Site Map by Environmental Impact Services 58 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. Note: Drawing is for illustrative purposes only; Do not scale Note: For the purpose of the regional section, elevation has been taken from Ordnance Survey 1:50,000 Discovery. Superficial deposits are generalised for presentation -bedrock inferred from Geological Survey of Ireland Vulnerability Mapping, and is indicative only. Refer to local section/ geological setting of site. KEY Alluvial Deposits Marine/Esturine Silts & Clays Made Ground Limestone Bedrock Sandy Gravelly Clay NORTH WEST Y1 24 Lower River River Shannon & River 22 Green Fields/Agriculture Residential Industrial Shannon SAC Fergus Estuary SPA Y 20 Proposed Site 18 Development SOUTH EAST 16 14 Bunlicky (see local mASD section) 12 WWTP 12 BARNAKYLE 10 AGW1 10 8 8 6 6 4 4 2 2 0 0 Ground Elevation (mASD) Elevation Ground -2 -2 -4 -4 -6 -6 -8 For inspection purposes only. -8 -10 Consent of copyright owner required for any other use. -10 -12 Approx. 1480m Approx. 950m Approx. 1480m Approx. 790m Approx. 750m Horizontal Profile (5.45Km) (Scale is Exaggerated; Approximate only) Figure 7.9 Regional Cross Section by Environmental Impact Services 59 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. 7.3.16 RATING OF SITE IMPORTANCE Based on the NRA and IGI methodology (refer Appendix 7.1, Table 2 and 3) and criteria for rating site importance of hydrogeological features, the importance of the hydrogeological features at this site is rated as having a ‘Low Importance’ based on the fact that the bedrock underlying the site is a Locally Important aquifer and has been indicated to not be providing water supply to >50 homes. The geological attribute has a medium quality significance or value on a local scale. 7.4 PREDICTED IMPACTS Predicted impacts during construction and operation are outlined below. The implementation of the mitigation measures outlined in Section 7.5 below will ensure that any accidental releases and management of run-off during the construction phase as well as during the operational phase are minimised. Impacts considered are summarised in the following subsections 7.4.1 CONSTRUCTION PHASE Soil Removal Excavation of soil will be required for construction of the extension development. Site investigation (September 201338) and laboratory analysis has not identified any existing soil contamination and the previous use of the site not indicate that any contaminated soil should be encountered. However, if contaminated soil/water is encountered during development works it will be removed by a licensed waste contractor. Land There is no loss of soil or land resource for this proposed development. The land is already developed and is in an area designated for enterprise and employment under the Limerick County Council Southern Environs Local Area Plan 2011-2021. There will be no removal of productive land from potential agricultural or other beneficial uses. Accidental Fuel Spillages and Leakages For inspection purposes only. During construction of the development,Consent of there copyright is ownera risk required of localised for any other accidentaluse. pollution incidences from the following sources: • Spillage or leakage of temporary oils and fuels stored on site. • Spillage or leakage of oils and fuels from construction machinery or site vehicles. • Spillage of oil or fuel from refuelling machinery on site. • Alkaline run-off from concrete and cement construction. Accidental spillages if not mitigated could result in localised contamination of soils and groundwater underlying the site, should contaminants migrate through the subsoils and impact underlying groundwater. Groundwater vulnerability at the site is currently classified as High to Extreme, therefore any soil stripping will reduce the natural protection they provide to the underlying aquifer. Surface/Storm Water Runoff Surface water run-off during the construction phase may contain increased silt levels or become polluted from construction activities. Run-off containing large amounts of silt can cause damage to groundwater underlying the site. Silt-laden water can arise from exposed ground and soil stockpiles (prior to reinstatement). 38 O’Callaghan Moran Associated (2013) Environmental Site Assessment Formel Dell EMF3 Facility Raheen Businees Park Limerick, September 2013. by Environmental Impact Services 60 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. Localised Dewatering It is not envisaged that any significant dewatering will be required during the construction phase which would result in the localised lowering of the water table. 7.4.2 OPERATIONAL PHASE In terms of predicted specific impacts during site operation the following points are of note: There are no areas of geological heritage, quarrying or mineral deposits within the footprint of the development or local environs. No dewatering is required therefore there is no impact to the natural groundwater regime and as such no impact on sensitive groundwater receptors or groundwater supplies in the vicinity of the proposed development site. There will be no direct discharges of contaminated water to the subsurface environment during the operational phase. As such, impact could only occur due to accidental emissions such as localised accidental leakages from cars/vehicles in the car park area or accidental leakage from the bulk chemical/diesel storage. As surface flow from car parks will be preferentially transported through stormwater drainage and discharged through a petrol interceptor there is no likely significant impact to underlying soil and groundwater. Bulk chemical storage will be fully bunded and maintained as per licence requirements and as such the potential for discharge to ground will be low. Emissions from the onsite water treatment plant. The operation of an Environmental Management Plan (EMP) and operation within the requirements of an EPA licence will minimise the likelihood of any spill or leaks at the site. 7.5 MITIGATION MEASURES 7.5.1 CONSTRUCTION PHASE An outline Construction Environmental Management Plan (CEMP) has been prepared for the proposed development. This CEMP will ensure effective soil and water management during construction. The CEMP will cover potentially polluting activities and include an emergency response procedure. All relevant personnel working on the site will be trained in the implementation of the procedures. Construction of the development is to take place within the current licence boundary and as such will be undertaken within current licence requirements. For inspection purposes only. Soil Removal and Compaction Consent of copyright owner required for any other use. Construction works will require shallow excavation works for foundations, services and landscaping. The volume of soil to be removed to facilitate the development is estimated to be c. 20,000m3. Suitable engineering fill material will be required to be brought onto site to be placed under foundations, floors and new access routes. Temporary storage of excavated soil will be carefully managed in such a way as to prevent any potential negative impact on the receiving environment and the material will be stored away from any open surface water drains. Movement of material will be minimised in order to reduce degradation of soil structure and generation of dust. Although there is no evidence of historical contamination from site investigation undertaken to date, all excavated materials will be visually assessed for signs of possible contamination such as staining or strong odours. Should any unusual staining or odour be noticed, samples of this soil will be analysed for the presence of possible contaminant. Should it be determined that any of the soil excavated is contaminated, this will be appropriately disposed of by a licensed waste disposal contractor. Fuel and Chemical Handling To minimise any impact on the underlying subsurface strata from material spillages appropriate bunding shall be provided for all tank and drum storage areas. These storage areas shall be rendered impervious. Appropriate signage will be in place at each dedicated storage unit. The amount of chemicals stored will be kept to a minimum. All chemical containers will be labelled and copies of SDS sheets shall be maintained in the storage unit. by Environmental Impact Services 61 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. In the event of a spillage, drainage from bunded areas shall be inspected and diverted for collection and safe disposal if required. The integrity and water tightness of all bunding structures shall be tested and demonstrated. All fuel oil areas will have an appropriate spill apron. With respect to portable equipment containing fuel oil, drip trays or approved equipment shall be used. Adequate spill clean-up materials will be available on site at all times. Refuelling of construction vehicles, and the addition of hydraulic oils or lubricants to vehicles, will take place in a designated area (or where possible off site) which will be away from surface water gulleys or drains. In the event of a machine requiring refuelling outside of this area, fuel will be transported in a mobile double-skinned tank. An adequate supply of spill kits and hydrocarbon adsorbent packs will be stored in this area and made available. All relevant personnel will be fully trained in the use of this equipment. Guidelines such as ‘Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors’ (CIRIA 532, 2001) and other CIRIA guidelines regarding good practice (CIRIA 692, 2011; CIRIA 715, 2012) will be complied with. All ready-mixed concrete will be brought to site by truck. A suitable risk assessment for wet concreting will be completed prior to works being carried out which will include measures to prevent discharge of alkaline waste waters or contaminated storm water to the underlying subsoil. The construction trucks will be sent back to their depots for wash down as per CIRIA C648 recommendations so as not to compromise an EPA licenced site. In the case of drummed fuel or other chemicals which may be used during construction containers should be stored in a dedicated internally bunded chemical storage cabinet and labelled clearly to allow appropriate remedial action in the event of a spillage. Bunding of chemicals including integrity testing of bunds and transfer lines is a requirement of the EPA licence and EMP. Surface Water Run-Off As the construction of the new development will take place on an area of current hardstanding, surface water run-off will be directed to the existing storm water drainage system. Silt traps and fences will be installed as required to prevent suspended solids loading of the storm water network. There will be no additional areas of hardstanding created as part of this proposed development. Some areas of the contractors compound may be required to be temporarily surfaced to facilitate construction traffic, however the additional run-off from these areas will be small in volume and short- term in duration. For inspection purposes only. Consent of copyright owner required for any other use. Regular monitoring of construction mitigation measures will be undertaken e.g. concrete pouring procedures, concrete wash-out, fuel storage and containment, refuelling etc. Site Dewatering The proposed development will not require any significant removal of rock. As such, no significant dewatering is expected to be required for the foundations and subsurface infrastructure during construction. Accidental Releases Emergency response procedures are in place at the existing facility in line with the requirements of the IED Licence. Appropriate procedures for dealing with accidental releases during the construction phase are outlined in the CEMP and will be further detailed prior to commencement of construction. All relevant personnel working on the site will be trained in the implementation of the procedures. 7.5.2 OPERATIONAL PHASE The current facility has an environmental management plan (EMP) (accredited to an ISO Standard) in place to ensure compliance with licencing requirements. This includes full and adequate containment and management of potential contaminants, site-specific emergency response measures and all relevant personnel are trained accordingly. The new production facility will come under the same EMP which is maintained as part of the sites Environmental Management System. Specific mitigation measures related to soil and groundwater protection for the operational phase include: by Environmental Impact Services 62 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. Fuel and Chemical Handling Diesel fuel is kept onsite as this may be required in the case of the backup 2500kVA generators being utilised. All diesel containers are stored and bunded appropriately and no instance of a spillage has occurred since the beginning of operations at the Regeneron facility. Drainage from the bunded areas will be via appropriate drainage connections which will be inspected and maintained on a regular basis. Onsite Wastewater Treatment and Groundwater Monitoring Operation of any new plant will be according to BAT (Best Available Technology) principles and in compliance with the discharge limits set for the facility to ensure that inputs to the municipal wastewater network will not result in any accidental release to soil or groundwater. Groundwater monitoring will be undertaken in compliance with licence requirements. Underground Drains & Pipes Production and process supply lines and pipes will run over ground, where possible, as part of the integrated design for the proposed development. To minimise the risk of any accidental emissions to soil and groundwater, the integrity of all underground pipelines will be tested in accordance with the requirements of the facilities IED Licence and testing will be carried out in accordance with EPA guidelines. There are currently no underground process or chemical distribution lines installed on site (Jacobs to confirm). Groundwater monitoring will be undertaken as required by any IED licence requirements. The location of the new development will require the decommissioning of the existing AGW1 monitoring well. A new monitoring location will be agreed with the EPA as part of amendments to the facility licence. 7.5.3 REINSTATEMENT No reinstatement within public lands is anticipated with respect to the Land, Soils, Geology and Hydrogeology environment. 7.5.4 INTERACTIONS 7.5.4.1 Hydrology As stated there is an inter-relationship between hydrology and land, soils, geology and hydrogeology. Surface water run-off may have the potential For inspection to purposes enter only. soil and groundwater. Implementation of Consent of copyright owner required for any other use. appropriate mitigation measures as outlined above will eliminate the potential for the influx of surface contaminants into the underlying geology and hydrogeology which would otherwise affect its quality. 7.5.4.2 Air Quality There is a potential for soil excavation activity to impact on air quality in terms of dust generated but the implementation of suitable mitigation measures as outlined in the Section 9 Air Quality and Climate will ensure a neutral impact. 7.5.4.3 Ecology There are potential impacts on the surrounding ecology during the construction of the new extension. An assessment of the project detail outlined in Section 4 indicates the potential impacts to biodiversity are predominantly associated with construction phase works which are temporary/short term. The site was found to have predominantly low ecological value. These impacts and mitigation measures associated with the impacts are discussed further in Section 6 Biodiversity. by Environmental Impact Services 63 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Land, Soils, Geo. & Hydrogeo. 7.5.5 POTENTIAL CUMULATIVE IMPACTS The proposed development is within the boundary of the current Regeneron site which in turn is located within Raheen Business Park. Any potential impacts on the soil environment will be within the confines of the site boundary. With the implementation of the mitigation measures highlighted above, the cumulative effect on the land, soils, geology and hydrogeology local environment with any adjacent developments is deemed to be insignificant. 7.6 RESIDUAL IMPACTS Based on the natural conditions present and with appropriate mitigation measures (see Section 7.5) to reduce the potential for any impact of accidental discharges to ground during this extension development, the potential effect on land soils, geology and hydrogeology during construction (following EPA, 2017) is considered to have a short term, imperceptible significance, with a neutral effect on quality. There are no likely significant impacts on the land, geological or hydrogeological environment associated with the proposed operational development of the site with mitigation in place. As such the effect is considered to have a long term, imperceptible significance with a neutral effect on quality i.e. an impact capable of measurement but without noticeable consequences. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 64 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology 8 WATER & HYDROLOGY 8.1 INTRODUCTION/METHODOLOGY The following section presents an assessment of the impacts of the existing environment and the proposed development in terms of water and hydrology of the local environment. 8.2 METHODOLOGY In addition to the EPA Guidelines and Advice Notes referred to in Section 2.1, consideration has also been given to t h e document entitled Guidelines on Procedures for Assessment and Treatment of Geology, Hydrology and Hydrogeology for National Road Schemes, NRA (2009). These guidelines are referenced where the methodology for assessment of impact is appropriate (refer Appendix 8.1). The following sources of information were consulted: Current EPA on-line database -Envision water quality monitoring data for watercourses in the area; Shannon International River Basin District (SIRBD) Management Plan; The Planning System and Flood Risk Management, Guidelines for Planning Authorities (Department of the Environment, Heritage and Local Government (DoEHLG) and the Office of Public Works (OPW)); Office of Public Works (OPW) flood mapping data (www.floodmaps.ie); Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors’, CIRIA 532 (2001); The attributes (and impacts) to be assessed include inter alia the following: River and stream water quality in the vicinity of the site (where available); Surface watercourses near the site and potential impact on surface water quality arising from proposed development related works including any discharge of surface water run- off; For inspection purposes only. Localised flooding (potentialConsent increase of copyright or owner reduction) required for anyand other floodplains use. including benefitting lands and drainage districts (if any); and Surface water features within the area of the site. Site-specific data was derived from the following sources: Various design site plans and drawings; Consultation with site engineers; Jacobs Engineering Construction Environmental Management Plan for the proposed development; PM Group Regeneron Ireland Environmental Impact Statement (2013); Regeneron Annual Environmental Reports (AER) 2015; Regeneron Annual Environmental Report (AER) 2016; and Current site details provided by Regeneron Ireland. The potential impacts in relation to surface water during construction have been assessed under the following headings: Increased run-off and sediment loading Potential for contamination of local water courses by Environmental Impact Services 65 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology The potential impacts in relation to water during operation have been assessed under the following headings: Impact on public water supply and water infrastructure Impact on storm water run-off Impact on water quality as a result of accidental discharge from bulk storage or fuel leakage Impact on flooding 8.3 THE PROPOSED DEVELOPMENT The proposed development is for the expansion of Regeneron’s existing production facility at Raheen Business Park, Limerick. The current facility operates within the terms of an Industrial Emissions Licence (IED) (Register number: P0991-01). A description of the proposed development is available in Section 4 Project Description. Relevant items for this section are outlined below. 8.3.1 CONSTRUCTION PHASE The key civil engineering works at the proposed development will involve (i) the excavation of material for foundations and deliveries of imported engineering fill, crushed stone, concrete, reinforcement and other construction materials, (ii) hardstanding and management of surface water, foul sewer drainage and process water, (iii) new drainage constructed as part of the extension, and (iv) temporary contractors compound will be constructed with hardcore. Other construction activities will include site storage of soils, cement & concrete materials and temporary oils and fuels. An outline Construction Environmental Management Plan (CEMP) has been developed which incorporates relevant mitigation measures for management of surface water during construction activities to ensure that proposed development is compliant with licence requirements and will not impact on the natural surface water regime. 8.3.2 OPERATIONAL PHASE Water will be supplied from public mains water supply. Domestic effluent and trade effluent (post- treatment) discharge will be to the public sewer. Storm water will be discharged as current. During operation, the following will apply: For inspection purposes only. Consent of copyright owner required for any other use. Water supply The water demand for the overall development will be up to a maximum of 3,000m3 per day. Drinking water will be supplied via public water main. Consultation with Irish Water has been undertaken and it has been confirmed that there is sufficient capacity within the public water supply system to provide the required volume of water for this development. Surface Water It is proposed to continue to use current arrangements for the discharge of storm water run-off from the proposed development. Storm water from the site arises from buildings run-off, car-parks, road- ways, service yards and other developed areas of the site which discharge via a petrol interceptor to the main Raheen Business Park storm water system. The storm water discharge from the Raheen Business Park exits the estate and follows the route of a culvert and pipe to Loughmore Common Canal, which enters the Barnakyle River, which in turn flows into the Maigue River, which ultimately discharges to the River Shannon Estuary, see Figure 8.1. The onsite petrol interceptor was upgraded as part of the initial preparatory works for the existing manufacturing plant. This also included the installation of an actuated valve arrangement and a Total Organic Carbon (TOC) controlled actuated valve on the outlet of the storm water drainage system to facilitate greater release of storm water from the site. As the area proposed for development is already mostly hard standing area and the development is designed in accordance with SUDS there will be no significant change in run-off from the site and as by Environmental Impact Services 66 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology such no change in the receiving environment. Internal storm water infrastructure will be upgraded as part of the proposed development but will continue to discharge as its current rate of run-off. Foul and Process Effluent As the proposed development is an extension to an existing facility, process (after onsite treatment) and foul water will discharge through services currently utilised. Foul water will comprise domestic effluent from welfare facilities such as toilets, showers and canteen facilities. Process effluent will arise from manufacturing processes on-site and will have a similar make up to the process water currently discharged from the site under the facilities effluent discharge licence P0991-01. Consultation with Irish Water has been undertaken and agreement has been reached that a volume of 3,000m3 per day will be emitted from the site to the public foul sewer network. Process waste will be pumped to the onsite waste neutralisation system prior to discharge. The effluent arising from the proposed development will undergo the same primary treatment onsite as the current facility. Table 8.1 Table 8.1 outlines the current emissions limits in place for the facility in accordance with Regeneron’s current IED Licence. Prior to commencement of operations at the new facility, amendments to the existing licence limits (namely wastewater quantity and quality) which have been agreed with Irish water will be agreed with the EPA and updated emissions limits issued. Table 8.1 Emission Limits to Shannon Development Pipeline SE-01 Parameter Emission Limit Value Temperature 350C (max) pH 6-10 For inspection purposes only. Consent of copyright owner required for any other use. Values per day [kg mg/l unless otherwise noted] Max wastewater flow per day 1,500 (m3/day) (current) Max wastewater flow per day 3000 (m3/day) (Post development) BOD per day 1200 1800 COD per day 2000 3000 Suspend Solids 450 675 Total Kjeldahl Nitrogen 60 - Total Phosphorous (as P) 100 - Sulphates 600 - by Environmental Impact Services 67 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology 8.4 THE RECEIVING ENVIRONMENT 8.4.1 HYDROLOGY AND DRAINAGE The proposed development site is located within the Shannon International River Basin District (SIRBD) in Hydrometric Area No. 24 Shannon Estuary South of the Irish River Network. The First Cycle Shannon River Management Plan (2009-201539) is to be superseded by Second Cycle River Basin Management Plan (2018-2021) and has recently completed public consultation in August 2017. The Shannon River Management Plan shows that the area of the proposed development is within the Maigue catchment and the Ballynaclough sub catchment. The River Shannon is located approximately 4.0 km northwest of the facility with the Lower River Shannon Tributary approximately 3 km to the northeast of the facility. The Limerick City & Environs Municipal WWTP located in Bunlicky, which will receive and treat waste water from the Regeneron site, discharges treated effluent within the tidal reach of the River Shannon at the eastern limit of Limerick City. This stretch of the river is within both the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA. This is EPA data indicates that water quality in this transitional estuarine reach of the River Shannon into which the WWTP discharges is of “moderate” status. The closest surface water feature to the facility is the Barnakyle River, which skirts the southern end of Raheen Business Park. The Barnakyle River is a tributary of the River Maigue which flows into the River Shannon approximately 10 km west of Limerick City (refer Figure 8.1) For inspection purposes only. Consent of copyright owner required for any other use. Figure 8.1 Local Hydrology 8.4.2 SURFACE WATER QUALITY The proposed development is located within the Shannon International River Basin District (SIRBD), as defined under the European Communities Directive 2000/60/EC, establishing a framework for 39 Shannon River Basin Management Plan (2009-2015) by Environmental Impact Services 68 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology community action in the field of water policy – this is commonly known as the Water Framework Directive (WFD). The WFD requires ‘Good Water Status’ for all European waters to be achieved by 2015 through a system of river basin management planning and extensive monitoring. ‘Good status’ means both ‘Good Ecological Status’ and ‘Good Chemical Status’. In 2009 the SIRBD River Management Plan (RMP) 2009-2015 was published. In the SIRBD RMP, the impacts of a range of pressures were assessed including diffuse and point pollution, water abstraction and morphological pressures (e.g. water regulation structures). The purpose of this exercise was to identify water bodies at risk of failing to meet the objectives of the WFD by 2015 and include a programme of measures to address and alleviate these pressures by 2015. The SIRBD is to be replaced by the River Basin Management Plan (2018-2021). The strategies and objectives of the WFD in Ireland have influenced a range of national legislation and regulations. These include the following: Statutory Instrument (SI) No. 293 of 1988, European Communities (Quality of Salmonid Waters) Regulations 1988, Local Government (Water Pollution) Acts 1977-1990 SI No. 258 of 1988, Water Quality Standards for Phosphorus Regulations, 1998 SI No. 272 of 2009 European Communities Environmental Objectives (Surface Waters) Regulations, 2009 S.I. No. 386 of 2015, European Communities Surface Water Regulations (Amendment) In accordance with the WFD, each river catchment within the SIRBD was assessed and a water management plan detailing the programme of measures was put in place for each. For the purpose of this assessment the Barnakyle River was assessed. Q-Values are used by the EPA to express biological water quality, based on changes in the macro invertebrate communities of riffle areas brought about by organic pollution. Table 8.2 below summarises an explanation of the ratings; for example, Q1 indicates a seriously polluted water body while Q5 indicates unpolluted water of high quality. Table 8.2 also indicates the key used by the EPA mapping format to indicate quality status. Table 8.2 EPA Biological Q ratings & key40 Quality Ratings (Q) Status Water Quality Key Q5, Q4-5 High Unpolluted For inspection purposes only. Q4 ConsentGood of copyright owner required for anyUnpolluted other use. Q3-4 Moderate Slightly Polluted Q3, Q2-3 Poor Moderately Polluted Q2, Q1-2, Q1 Bad Seriously Polluted Available data for 2013 from the EPA on-line mapping database Envision is presented in Table 8.3 below together with the most recent Q-Value for the watercourse at the locations closest to the site. 40 EPA Q Rating Table Accessed Online (August 2017) http://www.epa.ie/QValue/webusers/ by Environmental Impact Services 69 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology Table 8.3 EPA monitoring data for Barnakyle River Entity Name BARNAKYLE Br SW of Kilpeacon Station Name: Doneen Br Br SE of Clarina Crossroads Station ID: RS24B050400 RS24B050600 RS24B050300 WFD CODE: IE_SH_24B050600 IE_SH_24B050600 IE_SH_24B050300 Type of water monitored: River Water River Water River Water River Basin District: SIRBD SIRBD SIRBD Station Type (WFD): Operational Operational Operational Easting: 155257 151076 156258 Northing: 149914 153043 147710 Last Q Year: 2003 2014 2014 Last Q Value: 3-4 3 3 Q Legend: Moderate Poor Poor Q Linear Value: 3-4 3 3 Figure 8.2 below presents the river catchment map and water quality status (including current EPA monitoring stations). The values listed above are for monitoring stations located both upstream and downstream of the subject site. As is shown on Figure 8.2 the downstream monitoring location (RS24B050600) has a Q Linear Value of 3 (‘Poor Status’) this is similar to the upstream monitoring location (RS24B050300) which also has a Q Linear Value of 3 (‘Poor Status’). The overall recorded status of the river Barnakyle is Poor. The Barnakyle River is classified as being ‘at risk of not achieving good status’. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 70 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology Br SE of Clarina Doneen Br Br SW of Kilpeacon Crossroads Figure 8.2 River Catchment Map and Quality41 For inspection purposes only. Consent of copyright owner required for any other use. In accordance with the WFD, each river catchment within the SIRBD was assessed and a water management plan detailing the programme of measures was put in place for each. For the Maigue WMU (Water Management Unit) the main pressure preventing achievement of Good Status is diffuse agricultural pollution. Full implementation of the Maigue WMU Action Plan is expected to correct this; however, it is estimated that the Barnakyle River will not achieve ‘Good’ status until 2021. EPA’s Envision Database was also consulted to determine if any designated salmonid waters (S.I. 293/1988-European Communities (Quality of Salmonid Waters) Regulations, 1988) existed close to the site or are located so that they may be adversely impacted by the proposed development or operation of the facility. The Barnakyle River was previously not included in the register of salmonid waters included in those regulations. The GSI (2017) database identifies no groundwater source protection zones (SPZ) in the immediate vicinity of the subject site. The nearest source protection zones are located at ~10 km south (near Fedamore). 41 EPA Mapping Online (2017) Accessed August 2017 http://gis.epa.ie/Envision by Environmental Impact Services 71 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology 8.4.3 FLOODING In accordance with the guidelines produced by the Department of the Environment, Heritage and Local Government (DoEHLG) - The Planning System and Flood Risk Management (FRM) Guidelines for Planning Authorities, November 2009, a Stage 1 Flood Risk Assessment has been carried out and is submitted as part of this planning application. It finds that no flood events have been recorded at the proposed development site. As part of the CFRAM programme the OPW developed Provisional Flood Risk Assessment (PFRA) maps to highlight areas that may be at risk of flooding and may require further assessment. The PFRA maps for the area were researched and did not indicate risks of fluvial or pluvial flooding at the site. 8.4.4 ON SITE SURFACE WATER DRAINAGE The proposed development is an extension to the existing Regeneron bio-pharma facility which has been in operation since 2015 and was previously the site of the Dell EMF3 plant. Surface water discharge from Raheen Business Park exits the estate and follows the route of a culvert and pipe to Loughmore Common canal which enters the Barnakyle River which in turn flows into the Maigue River, which then discharges into the River Shannon Estuary. The existing on-site surface water drainage network currently covers the entire site (including the proposed location of the development) and collects rainwater runoff from three distinct catchment areas; - Shipping and receiving yards and site road - Car Park areas - Building roofs Although some internal modification will be undertaken for the proposed development the overall discharge will be similar to the current stormwater discharge in terms of flow and quality. 8.4.5 ON SITE SURFACE WATER QUALITY Under EPA licence (P0991-01) requirements, weekly visual inspections are carried out at surface water emission point SE-02 to ensure no obvious contamination is reaching the surface water drainage systems. For inspection purposes only. As recorded in Regeneron’s 2015 &Consent 2016 of AER,copyright no owner contamination required for any other was use. recorded. Regeneron undertake continuous monitoring of pH, Volumetric Flow and Temperature at emission point SE-02, all three parameters were below the ELV’s as highlighted in Table 8.4. The licence parameter (COD) is sampled at SE-02 weekly and this was also fully compliant with Regeneron’s current IED licence. It is expected that this monitoring programme will continue following the proposed development. Table 8.4 Emissions from SE-02 as per 2015 & 2016 Annual Environmental Reports Parameter Result 216 AER 2015 AER ELV COD (Average) 22 11 N/A42 pH 7.79 7.5 6-9 Flow (Yearly Average kg) 178,819 N/A 54750043 Temp (0C Average)) 12.56 13.99 35 42 Trigger values may be agreed with the agency outside of license conditions. 43 Based on licensed allowed flow of 1500 m3 per day X 365 days. by Environmental Impact Services 72 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology 8.4.6 WATER SUPPLY The water supply for the site comes from the public water supply. In the most recent AER the water usage for the site was c.170,894 cubic metres per year (AER, 2016). c.152,428 cubic metres per year of this is discharged back to the environment with the remainder released as steam. The maximum water supply demand for the facility once the proposed development is operational will be 3,000m3/day. Irish Water (IW) have confirmed the availability of this additional demand in the public system. The pre-existing water supply infrastructure is provided by the Raheen Industrial Estate and the water demand from the proposed development is within the capabilities of this infrastructure. 8.4.7 WASTE WATER Waste water from the proposed development will emanate from sources similar to the current facility, these are; Production areas 1. Compromising inactivated preculture, cell culture and harvest waste streams. 2. Waste Streams from recovery purification and formulation. 3. Clean in Place (CIP) wash water. These waste streams can be characterised as medium strength BOD/COD, high nitrogen, high phosphorous, low solids. Centralised Utilities 1. Reverse osmosis (RO) reject 2. Water softener brine 3. Boiler/cooling tower blowdown These are characterised by low BOD/COD and low solids. Laboratory Emissions Characterised by low flow volumes. Sanitary wastewater Sewage from toilets, lockers, showers and canteen. For inspection purposes only. Consent of copyright owner required for any other use. Process effluent currently undergoes preliminary treatment onsite before discharge to the municipal sewer. The onsite waste water management facility has been designed to facilitate modular expansion and includes the following operations; - Heat inactivation of streams potentially containing cells from the process - Balancing and neutralisation of all process waste waters - Cooling, odour management and monitoring. The facility is currently licensed to dispose of up to 1,500m3 of wastewater per day. IW have agreed to an increased wastewater discharge into the municipal network up to 3,000m3 per day subject to agreement with the EPA under the terms of the facilities IED Licence, this is double the waste water flow prior to this proposed increase. Regeneron currently monitors the quality of wastewater discharged to sewer via SE-01 in line with its IED Licence requirements, monitoring the performance of its effluent for pH, flow and temperature with a continuous monitoring system. BOD, COD, suspended solids, nitrogen, total phosphorus and sulphate are monitored monthly. A similar monitoring programme will continue once the new development is operational subject to agreement with the EPA. As part of the IPC licence (P0991-01) requirement, monthly monitoring of flow, physical and chemical parameters are measured at SE-01. There has been no result in breach of Regeneron’s licence requirement since operations began in 2015. by Environmental Impact Services 73 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology Regeneron was subject to an audit by the EPA on 28th July 2016 where a sample from emission point SE-01 was recovered and sent for analysis by the agency. All analysed parameters were within the prescribed emission limit values as per the facilities licence. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 74 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology Rating Of Site Importance of The Hydrological Features Based on the NRA methodology (See Appendix 8.1-Table 3), the site importance of hydrological features at this site is rated Low to Medium Importance based on the following: Quality Class C (Biotic Index Q2-3) There are no surface water sources of potable water in surrounding area. 8.5 PREDICTED IMPACTS Predicted impacts during the construction and operational phases are outlined below. The implementation of the mitigation measures outlined in Section 8.6 below will ensure that accidental releases and management of run-off during construction as well as during the operational phase are minimised. These measures will ensure that the development does not impact on receiving surface water resource. 8.5.1 CONSTRUCTION Surface Water Run-off Surface water run-off during construction may contain increased silt levels or become polluted from construction activities. Run-off containing large amounts of silt can cause damage to surface water systems and receiving watercourses. Silt water can arise from dewatering excavations, exposed ground, stockpiles and access roads. The total volume of surface water run-off is believed to slightly increase as the development of the temporary contractors’ compound increase the amount of hardstanding present. Fuel and Chemical Handling During construction, there is a risk of accidental pollution incidences from the following sources if not adequately mitigated: Spillage or leakage of oils and fuels stored on site; Spillage or leakage of oils and fuels from construction machinery or site vehicles; and Run off from concrete and cement. Machinery on site during the construction For may inspection result purposes in contamination only. of surface water. The potential Consent of copyright owner required for any other use. impacts could derive from accidental spillage of fuels, oils, paints and solvents, which could impact surface water and groundwater quality if allowed to infiltrate to run-off to surface water systems and/ or receiving watercourses. Concrete operations carried out near surface water bodies or local surface water drainage systems during construction activities could lead to a discharge of wastewater to a watercourse. Concrete (specifically, the cement component) is highly alkaline and any spillage to a local watercourse would be detrimental to water quality and local fauna and flora. 8.5.2 OPERATION Surface Water The pre-existing surface water infrastructure is capable for the surface run-off (see attached report). It is proposed that there will be a new surface water drainage system servicing the proposed extension development which will be incorporated into the pre-existing infrastructure of the Raheen Industrial Estate. Therefore, there will be no impact on the surface water drainage system. by Environmental Impact Services 75 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology Wastewater Process effluent undergoes a rigorous treatment process onsite before emission to the Shannon Development foul sewer. The onsite waste water management system consists of 4 distinctive steps; Wastewater Balancing, Cooling, Neutralisation and Monitoring. In the highly unlikely event that any of these steps should fail, the untreated process water may increase organic load on the WWTP at Bunlicky. This is highly unlikely and a number of robust mitigation measures are currently utilised at the facility, these are discussed in more detail in section 8.5 below. Flooding As there is no proposed change to the overall hardstand on the site there will be no significant change to the run-off rate or discharge from the site and therefore no additional flood risk as a result of the proposed development. Fuel and Chemical Handling There will be no direct discharges of contaminated water to surface water during the operational phase. As such, an impact could only occur due to accidental emissions such as localised accidental leakages from cars in the car park areas or accidental leakage from the bunded areas or effluent treatment system and chemicals during refuelling or transport, if mitigation failed. Table 8.4 lists the bulk chemicals kept on site and their corresponding volumes. All chemicals are bunded to at least 110% required of their storage vessel’s capacity. We understand there are no additional external bulk chemical storage requirements for the proposed development. All bunds/containment structures have passed hydraulic integrity testing as per Regeneron’s 2016 Annual Environmental Report. The volume of chemicals stored on site is relatively small. There will be a new waste handling area constructed as part of the new development. This is located on the western side of the proposed extension. It is currently proposed that this waste handling area will have capacity to store chemical waste in IBC’s depending on the facility requirements. Where liquid storage is required, appropriate bunding will be provided. Table 8.5 Bulk chemicals stored on site and bund capacity. Bulk Chemical Volume m3 44 Bund/Storage Vessel Capacity Required Volume Ethanol 25 39.6 27.5 Phosphoric Acid 25 45.9 27.5 For inspection purposes only. Sodium Hydroxide Consent25 of copyright owner required for45.9 any other use. 27.5 44 by Environmental Impact Services 76 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology 8.6 MITIGATION MEASURES During operation, the site will operate in compliance with licence requirements. It is not anticipated that any significant mitigation is required above what currently exists. During construction, additional mitigation measures are included in the CEMP for the site to manage water quality during construction. These measures seek to avoid or minimise potential effects in the main through the implementation of best practice construction methods and adherence to licence requirements and relevant legislation. 8.6.1 CONSTRUCTION PHASE The construction area is mostly within the boundary of the Regeneron site and as such is subject to compliance with the site’s current IED Licence . In addition, a project-specific outline Construction Environmental Management Plan (CEMP) has been prepared and will require adherence to by the contractor during the construction phases of the proposed project. The CEMP will cover all potentially polluting activities and include an emergency response procedure for the full construction area. A summary of these measures is described below: BPGCS005, ‘Oil Storage Guidelines’ CIRIA, (2001) ‘Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors’, Construction Industry Research and Information Association, CIRIA reference C532, January 2001 CIRIA, (2005). ‘Environmental Good Practice on Site’ (C650). London: Construction Industry Research and Information Association (CIRIA) (Connolly S. and Charles P.) CIRIA, (2011). ‘Environmental good practice on site’; Construction Industry Research and Information Association publication C692 (3rd Edition - an update of C650 (2005); (I. Audus, P. Charles and S. Evans) CIRIA, (2012). ‘Environmental good practice on site’ –pocket book; Construction Industry Research and Information Association publication C715 (P. Charles, and G. Wadams) EA, (2004) ‘UK Pollution Prevention Guidelines’ (PPG), Environment Agency. Surface Water Run-off Surface water run-off will not be discharged directly to any local watercourses during construction. Water containing silt will be treated to ensure effective silt removal as set out in CEMP. After excavation, any potential new surface water discharges will be settled via temporary settlement tanks/silt traps/siltbusters prior to dischar Forge. inspection purposes only. Consent of copyright owner required for any other use. Temporary storage of soil will be carefully managed in such a way as to prevent any potential negative impact on the receiving environment and the material will be stored away from any open surface water drains (where present). Movement of material will be minimised in order to reduce degradation of soil structure and generation of dust. Excavations will remain open for as little time as possible before the placement of fill. This will help to minimise potential for water ingress into excavations. All affected surface water drains and gulleys are to be protected for the duration of construction works. Weather conditions will be taken into account when planning construction activities to minimise risk of run-off from the site and the appropriate distance of topsoil piles from drainage ditches to be maintained. Fuel and Chemical Handling To minimise any impact on the underlying subsurface strata from material spillages, all tank and drum storage areas will be bunded. Oil and fuel storage tanks shall be stored in designated areas, and these areas shall be bunded to a volume in compliance with EPA standards. Drainage from the bunded area(s) shall be inspected and properly managed in compliance with licence requirements. by Environmental Impact Services 77 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology Refuelling of construction vehicles, and the addition of hydraulic oils or lubricants to vehicles, will take place in a designated area (or where possible off site) which will be away from surface water gulleys or drains. In the event of a machine requiring refuelling outside of this area, fuel will be transported in a mobile double-skinned tank. An adequate supply of spill kits and hydrocarbon adsorbent packs will be stored in this area. All relevant personnel will be fully trained in the use of this equipment. Guidelines such as ‘Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors’ (CIRIA 532, 2001) and other CIRIA guidelines regarding good practice (CIRIA 692, 2011; CIRIA 715, 2012) will be complied with. All ready-mixed concrete will be brought to site by truck. A suitable risk assessment for wet concreting will be completed prior to works being carried out which will include measures to prevent discharge of alkaline wastewaters or contaminated storm water. Concrete trucks will not be washed out onsite. Concrete trucks will be required to return to the ready-mix depot for cleaning. The contractor company will ensure adequate spill clean-up materials will be available onsite at all times. Accidental Releases All personnel working on the site will be suitably trained in the implementation of the procedures. In the event of a spillage drainage from bunded areas will be inspected and diverted for collection and safe disposal if required. 8.6.2 OPERATIONAL PHASE The site will operate in compliance with licence requirements during operation. No significant additional mitigation measure above what currently exists are anticipated . Appropriate mitigation measures are summarised below. Fuel and Chemical Handling No additional bulk chemical storage is required for this proposed development. Any additional process materials, product and chemicals will be delivered to the site in tamper proof and/or lockable containers or tankers, which are approved for transport use. Internal storage areas for new or waste hazardous liquids will be fully bunded and protected in line with current site requirements. Surface Water Run-off and Monitoring For inspection purposes only. All proposed new buildings will be Consentdrained of copyright to the owner current required water for any otherdrainage use. network. Surface water from these areas will be routed through the existing petrol interceptor (upgraded to facilitate the initial Regeneron development). The petrol/oil interceptor is located to the south west of the site, upstream of SE-02 (the existing connection to the surface water sewer). This will prevent discharge of oils/fuels which may potentially be present in surface water run-off from the car park and main building areas. The upgraded petrol interceptor is also flitted with a Total Organic Carbon (TOC) controlled actuated valve on the outlet to facilitate greater control on the release of storm water from the site. Wastewater The current wastewater discharge limit of 1,500m3 per day is proposed to be increased to 3,000m3 per day upon completion of the new extension and commencement of operations. Irish Water has confirmed that the municipal WWTP at Bunlicky has sufficient capacity to cater for the increased hydraulic loading associated with the extension of the current facility. The preliminary treated effluent from the Regeneron facility will not contain any gross solids or other constituents that would damage the Irish Water sewer or treatment equipment. In particular, parameters such as pH, temperature and sulphate will be controlled below levels that could impair the integrity of the concrete sewers. The WWTP at Bunlicky is currently in compliance with its current discharge licence (as per the plant’s 2016 AER) and the increased loading from the proposed development will not alter its ability to meet its discharge limits in the future. The treated effluent will not contain material and constituents the could impede the operation of the Limerick City and Environs WWTP including the treatment of sludge. Furthermore, the treated effluent by Environmental Impact Services 78 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Water & Hydrology will not contain materials or constituents that cannot be readily treated in conventional municipal wastewater treatment facilities to the standards required under all Community Standards relevant to the receiving waters. Primarily treated wastewater from the Regeneron facility will not impact on the ability to dispose of sludge from the Bunlicky WWTP. Regeneron wastewater will not affect the classification of the WWTP sludges in the context of the Waste Management (Use of Sewage Sludge in Agriculture) Regulations (SI No, 148 of 1998) as amended. 8.6.3 MONITORING 8.6.3.1 Construction Phase In addition to routine surface water monitoring undertaken as part of licence requirements, regular inspection of surface water run-off content and sediment controls e.g. silt traps, will be carried out throughout the construction phase. Regular inspection of construction mitigation measures will be undertaken, e.g. in respect of concrete pouring, truck wash-out, refuelling, storage of chemicals etc. 8.6.3.2 Operational Phase Regular inspection and maintenance of all bunds, spill containment vessels, emission point, interceptors and actuated valves will be undertaken in line with Regeneron’s IED Licence and the existing site Environmental Management Procedures. 8.7 RESIDUAL IMPACTS The residual impacts are those that would occur after the mitigation measures, as outlined in Section 8.5, above have taken effect. 8.7.1 CONSTRUCTION PHASE In relation to the construction phase, the impact on the water during construction is considered to be short term of imperceptible significance with a neutral impact on quality, i.e. an impact capable of measurement but without noticeable consequences. This is based on the following assessment: There will be no significant increase in run-off quantity from the site during construction and the quality of run-off will be monitored For inspection and purposes mitigation only. measures implemented, if required. Consent of copyright owner required for any other use. 8.7.2 OPERATIONAL PHASE There are no likely significant impacts on the hydrological environment associated with the proposed development of the site. It is not anticipated that any impacts will arise following the implementation of the mitigation measures discussed in Section 8.5 previously. As such the impact is considered to be long term, of imperceptible significance with a neutral impact on quality i.e. an impact capable of measurement but without noticeable consequences. The proposed development will not negatively impact on any surface waterbody during operations. There will be no increase in flood risk as result of the site operation. There is adequate capacity within the surface water and wastewater infrastructure. The site will operate within the conditions set by the EPA in the facility IED Licence and in agreement with Irish Water. by Environmental Impact Services 79 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate 9 AIR QUALITY & CLIMATE 9.1 INTRODUCTION & METHODOLOGY The following chapter presents an assessment on the air quality and climate impacts of the proposed extension to the Regeneron facility at Raheen, Co. Limerick, on the local environment as defined in the “EPA Advice Notes On Current Practice In The Preparation of EIS, (2003; Draft 2015)”45 and the “Guidelines On The Information To Be Contained In EIS, (2002; Draft 2017)”46. The modelling of air emissions from the site was carried out to assess the concentrations of Nitrogen Dioxide (NO2) and Carbon Monoxide (CO) and the consequent impact on human health. The air dispersion modelling input data consisted of information on the physical environment, design details for all emission points on-site and a full year of meteorological data. Using this input data, the model predicted ambient concentrations at various receptors for each hour of the meteorological year. This study adopted a worst-case approach which will lead to an over-estimation of the actual levels that will arise, in keeping with good EIA practice. Emissions from the site have been modelled using the AERMOD dispersion model (Version 16216r) which has been developed by the U.S Environmental Protection Agency (USEPA) and the American Meteorological Society (AMS). The model is recommended as an appropriate model for assessing the impact of air emissions from industrial facilities in the EPA Guidance document “Air Dispersion Modelling from Industrial Installations Guidance Note (AG4) (2010)”47. The model is a “new-generation” steady-state Gaussian plume model used to assess pollutant concentrations associated with industrial sources. The model is an enhancement of the Industrial Source Complex-Short Term 3 (ISCST3) model which has been widely used for emissions from industrial sources. Details of the model are given in Appendix 9.1. Fundamentally, the model has made significant advances in simulating the dispersion process in the boundary layer. This will lead to a more accurate reflection of real world processes and thus considerably enhance the reliability and accuracy of the model particularly under those scenarios which give rise to the highest ambient concentrations. Due to the proximity to surrounding buildings, For inspection the purposes PRIME only. Building Downwash Program (BPIP Prime) Consent of copyright owner required for any other use. has been incorporated into the model to determine the influence (wake effects) of these buildings on dispersion in each direction considered. The AERMOD model incorporated the following features: A Cartesian Receptor Grid was identified at which concentrations would be modelled. The receptors were mapped with sufficient resolution to ensure all localised “hot-spots” were identified without adding unduly to processing time. Modelling was carried out covering an area of approximately 10 km2 with the site at the centre. The fine grid consisted of receptors every 100 m extended to approximately 2 km from the site giving 1,681 gridded receptors. The coarse grid consisted of receptors every 500 m extended to approximately 5 km from the site giving 441 gridded receptors. The total calculation points for the gridded modelling including boundary receptors are 2,169. All on-site buildings and significant process structures were mapped into the computer to create a three dimensional visualisation of the site and its emission points. Buildings and process structures can influence the passage of airflow over the emission stacks and draw 45 EPA (2003; Draft 2015) EPA Advice Notes on Current Practice in the Preparation of EIS 46 EPA (2002; Draft 2017) Guidelines On The Information To Be Contained in EIS 47 EPA (2010) Air Dispersion Modelling from Industrial Installations Guidance Note (AG4) by Environmental Impact Services 80 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate plumes down towards the ground (termed building downwash). The stacks themselves can influence airflow in the same way as buildings by causing low pressure regions behind them (termed stack tip downwash). Both building and stack tip downwash were incorporated into the modelling. Hourly-sequenced meteorological information has been used in the model covering the years 2011 - 2015 from Shannon Airport as shown in Formatted: Default Paragraph Font Figure 9.1 Figure 9.1. AERMOD incorporates a meteorological pre-processor AERMET 7 which allows AERMOD to account for changes in the plume behaviour with height using information on the surface characteristics of the site. AERMET 7 calculates hourly boundary layer parameters for use by AERMOD, including friction velocity, Monin-Obukhov length, convective velocity scale, temperature scale, convective boundary layer (CBL) height, stable boundary layer (SBL) height, and surface heat flux. Terrain has been mapped out in the model using SRTM data (30 m resolution) using AERMAP although in the general vicinity, the Regenreon site is located in an area of relatively flat terrain. Shannon Airport 2011 Shannon Airport 2012 Shannon Airport 2013 N N ..... _ N ~... .,.,,. ,,,. - -·-Ult"""l)tt. E E 'fll8 w E ...... ,. ..,"~ "' "' •»::rt1 "'°'"" 1u"n '"•"-' ..... tu:Mn Ut J1' .. , .. !If"- ...... , .. c- .... ,..,, s •••N .... " $ ...... - $ Shannon Airport 2014 Shannon Airport 2015 N N ..... ,,,. . ,., .._.. ... For inspection purposes only. ... 1ll0~1 Consent of copyright owner required for any other use. w e ..... nj t.ur.::•' ~H()tn '" 17 , .. ,,.. s s ... ~ awn isultrnq TM T...cpro6 ~. Clor.:sM.;¢ S..~*."'ld Ttcl'.oalcgy ~. Dt;blri 17 T: .,3M t &47 4220 F ..m 1 847 42!i7 Figure 9.1 Shannon Airport Windrose 2011 – 2015 9.1.1 AMBIENT AIR QUALITY STANDARDS In order to reduce the risk to health from poor air quality, national and European statutory bodies have set limit values in ambient air for a range of air pollutants. These limit values or “Air Quality Standards” are health or environmental-based levels for which additional factors may be considered. The applicable standards in Ireland include the Air Quality Standards Regulations 2011, which incorporate EU Directive 2008/50/EC. The ambient air quality standards applicable for NO2 and CO are outlined in this Directive (see Table 9.1). These standards have been used in the current assessment to determine the potential impact of NO2 and CO emissions from the facility on air quality. by Environmental Impact Services 81 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate Table 9.1 EU Air Quality Standards48 Regulation Pollutant Note 1 Limit Type Value Hourly limit for protection of human health - not to be exceeded more than 200 μg/m3 18 times/year Nitrogen Dioxide 2008/50/EC Annual limit for protection of human 40 μg/m3 health Critical level for protection of 30 μg/m3 (NO + vegetation NO2) 8-hour limit (on a rolling basis) for Carbon Monoxide 2008/50/EC 10,000 μg/m3 protection of human health Note 1 EU 2008/50/EC – Clean Air For Europe (CAFÉ) Directive replaces the previous Air Framework Directive (1996/30/EC) and daughter directives 1999/30/EC and 2000/69/EC 9.1.2 CLIMATE AGREEMENTS Ireland has signed up to a number of Climate Agreements which all have an aim of lowering annual greenhouse gas emissions by setting achievable targets for countries which have signed up. The Kyoto Protocol aimed to reduce the net anthropogenic growth of six GHGs under the Kyoto Protocol to 13% above the 1990 level over the period 2008 to 201249. Ireland is one of 200 nations who has signed up to the Paris Agreement which aims to limit global temperature increases to no more than 2°C above pre-industrial levels with efforts to limit this rise to 1.5°C. The aim is to limit global GHG emissions to 40 gigatonnes as soon as possible. Under the EU agreement to the “2030 Climate and Energy Policy Framework”50 the European Council has endorsed a binding target of at least 40% domestic reduction in GHG emissions by 2030 compared with 1990. This will be achieved under the EU emissions trading scheme (ETS). There is also a binding target of at least a 27% share in renewable energies consumed by the EU in 2030. Ireland as a member state is bound to these targets. In relation to the project, the greenhouse gas emissions resulting from site activities will contribute to Ireland’s overall annual emission levels. Any emissions targets are assessed on a national scale and individual project contributions similar to the proposed development are of a minor scale with little contribution to annual emissions thus impacts to climate are generally considered to be insignificant For inspection purposes only. and negligible. Consent of copyright owner required for any other use. 9.2 THE PROPOSED DEVELOPMENT The existing facility has five boiler stacks: A1-1 to A1-5 which have a height of 25 m above ground level. The proposed extension to the facility will have two new boiler stacks ‘New B01’ and ‘New B02’ which will be at a height of 20 m above ground level. The source information for the modelled emission points can be seen in Table 9.2. The new boiler stacks have been based on the current boiler design details. All stacks have been assessed at the relevant EPA licence limits as a conservative approach. The current boiler licence limits have been applied to the new boilers for the purposes of this modelling assessment. 48 Based on European Commission Directive 2008/50/EC (transposed as S.I. 180 of 2011) 49 ERM (1998) Limitation and Reduction of CO2 and Other Greenhouse Gas Emissions in Ireland 50 EU (2014) EU 2030 Climate and Energy Framework by Environmental Impact Services 82 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate Table 9.2 Summary of Source Information Height Max Exit NO Note 3 CO Note 3 Above Exit Cross- Volume 2 Stack Temp Velocity Ground Diameter Sectional Note 1 Flow Mass Mass Reference 2 (K) 3 (m/sec Level (m) Area (m ) (Nm /hr) Emission Emission Note 2 actual) (m) (g/s) Note 4 (g/s) A1-1 25 0.6 0.28 399.2 6227 8.94 0.173 0.104 A1-2 25 0.6 0.28 390.2 6371 8.94 0.177 0.106 A1-3 25 0.6 0.28 384.1 6472 8.94 0.180 0.108 A1-4 25 0.6 0.28 380.8 6528 8.94 0.181 0.109 A1-5 25 0.6 0.28 358.6 6933 8.94 0.193 0.116 New B01 20 0.6 0.28 472.2 5265 8.94 0.146 0.088 New B02 20 0.6 0.28 472.2 5265 8.94 0.146 0.088 Note 1 Kelvin (K) SI Unit for Temperature Note 2 (Nm3/hr) Cubic Metres per Hour measured under normal temperature and pressure conditions Note 3 Fuel type for boilers is natural gas Note 4 (g/s) Grams per Second 9.3 THE RECEIVING ENVIRONMENT 9.3.1 AIR QUALITY Air quality monitoring programs have been undertaken in recent years by the EPA and Local Authorities. The most recent annual report on air quality “Air Quality Monitoring Report 2015”, details the range and scope of monitoring undertaken throughout Ireland. As part of the implementation of the Framework Directive on Air Quality (1996/62/EC), four air quality For inspection purposes only. 51 zones have been defined in IrelandConsent for air of copyright quality owner management required for any otherand use. assessment purposes . Dublin is defined as Zone A and Cork as Zone B. Zone C is composed of 23 towns with a population of greater than 15,000. The remainder of the country, which represents rural Ireland but also includes all towns with a population of less than 15,000 is defined as Zone D. In terms of air monitoring, Raheen, Limerick is categorised as Zone C51. NO2 monitoring was carried out at the Zone C monitoring stations of Kilkenny, Portlaoise and 51 Mullingar in 2015 . The NO2 annual average in 2015 for the locations of Kilkenny and Portlaoise were 5 and 10 μg/m3, respectively. This is significantly lower than the annual average limit value of 40 μg/m3. The average results over the last four years at a range of Zone C locations suggests an upper average of no more than 13 µg/m3 as a background concentration as shown in Table 9.3. Based on the above information, a conservative estimate of the 2017 background NO2 concentration, for the region of the proposed development is 10 µg/m3. CO concentrations for the representative Zone C monitoring stations, between 2011 and 2015, average 1.9 mg/m3 for the maximum 8 hour value. This is significantly below the 10 mg/m3 limit value. This value of 1.9 mg/m3 will be used as the background concentration in the region of the proposed development. The Plume Volume Molar Ratio Method (PVMRM) was used to model NO2 concentrations. The PVMRM is currently a non-regulatory option in AERMOD which assumes that the amount of NO converted to 51 Air Quality Monitoring Report 2015, EPA (2016) by Environmental Impact Services 83 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate 52,53 NO2 is proportional to the ambient ozone concentration . The PVMRM uses both plume size and O3 concentration to derive the amount of O3 available for the reaction between NO and O3. NOx moles are determined by emission rate and travel time through the plume segment. The concentration is usually limited by the amount of ambient O3 that is entrained in the plume. Thus, the ratio of the moles of O3 to the moles of NOx gives the ratio of NO2/NOx that is formed after the NOx leaves the stack. In addition, it has been assumed that 10% of the NOx in the stack gas is already in the form 52,53 of NO2 before the gas leaves the stack (in reality the levels are usually closer to 5% ). The model has also assumed a final equilibrium ratio for NO2/NOx of 0.90 which again is pessimistic and more likely to be in the range 0.7 – 0.852,53. The equation used in the algorithm to derive the ratio of NO2/NOx is: NO2/NOx = (moles O3/ moles NOx) + 0.10 A background file of hourly ozone monitoring data for the period 2011 – 2015 from the EPA’s Macehead monitoring station was used in the PVMRM model runs for each year of the assessment.51. 3 Table 9.3 Annual Mean NO2 Concentrations in Zone C Locations (µg/m ) Year Kilkenny Portlaoise Mullingar 2012 4 - 7 2013 4 - 6 2014 5 16 4 2015 5 10 - Average 4.5 13 5.7 9.3.2 CLIMATE Anthropogenic emissions of greenhouse gases in Ireland included in the Kyoto Protocol are outlined in the most recent review by the EPA54. Combustion of fossil fuels for energy purposes is the greatest source of emissions at 97% of CO2 (2012 data). The largest share of energy emissions in 2015 is from fuel combustion for power generation (19.7% of total emissions) and road transport (19.8%). Industry and commercial sources account for 4.9% of emissions. The dominant primary fuels, on which the electricity generation system currently relies in terms of electricity generation output, are gas (62%), coal (14%), renewables (16%), peat (8%) and oil (2%) (based on 2011 data55). For inspection purposes only. Consent of copyright owner required for any other use. Anthropogenic emissions of GHGs in Ireland included in the EU 2020 strategy are reported each year by the EPA. 2015 was the third year where compliance with the European Union’s Effort Sharing Decision “EU 2020 Strategy” (Decision 406/2009/EC) was assessed. Ireland had non-ETS sectors emissions of 43.037 Mt CO2eq in 2015, when emissions covered by the EU’s emissions trading scheme for stationary and aviation operators were removed. This is 1.593 Mt CO2eq lower than Ireland’s annual target for emissions in 2015. However, the latest note from the EPA in 2016 indicates that compliance with the EU 2020 targets will be very challenging56. 52 Hanrahan, P (1999a) The Plume Volume Molar Ratio Method for Determining NO2/NOX Ratios in Modeling – Part 1: Methodology J. Air & Waste Management Assoc. 49 1324-1331. 53 Hanrahan, P (1999b).The Plume Volume Molar Ratio Method for Determining NO2/NOX Ratios in Modeling – Part 21: Evaluation Studies J. Air & Waste Management Assoc. 49 1332-1338. 54 EPA (2016) Ireland’s Final Greenhouse Gas Emissions 2015 55 SEAI Energy Forecast for Ireland to 2020 – 2011 Report 56 EPA (2016) Ireland’s Greenhouse Gas Emissions to 2020 – An Update by Environmental Impact Services 84 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate 9.4 PREDICTED IMPACTS 9.4.1 CONSTRUCTION PHASE The greatest potential impact on air quality during the construction phase of the proposed development is from construction dust emissions and the potential for nuisance dust. While construction dust tends to be deposited within 200 m of a construction site, the majority of the deposition occurs within the first 50 m. There is the potential for a number of greenhouse gas emissions to the atmosphere during the construction phase of the development. Construction vehicles, generators etc., may give rise to CO2 and NO2 emissions. When the dust minimisation measures detailed in the mitigation section of this chapter are implemented, fugitive emissions of dust from the site will be insignificant and pose no nuisance at nearby receptors. Due to the size and temporary nature of the construction activities, CO2 and NO2 emissions during construction will have a imperceptible impact on climate. 9.4.2 OPERATIONAL PHASE There is the potential for a number of emissions to the atmosphere during the operational phase of the development. In particular, boiler related air emissions may impact concentrations of NO2 and CO in ambient air at nearby receptors. Additional traffic generated due to the opening of the proposed development may also lead to increased pollutant concentrations in ambient air. Air Quality Impact from Traffic Emissions The UK DMRB guidance57, on which the Transport Infrastructure Ireland (TII) guidance is based, states that road links meeting one or more of the following criteria can be defined as being ‘affected’ by a proposed development and should be included in a local air quality assessment: • Road alignment change of 5 metres or more; • Daily traffic flow changes by 1,000 (the equivalent of 500 x 2 way car trips ) AADT or more; • HDV flows change by 200 vehicles per day or more; • Daily average speed changes by 10 km/h or more; or For inspection purposes only. • Peak hour speed changes byConsent 20 ofkm/h copyright or owner more. required for any other use. Concentrations of key pollutants are calculated at sensitive receptors which have the potential to be affected by the proposed development. Road links which are affected by the proposed development and within 200 m of the chosen sensitive receptors are required for the model. There are no road links which meet the above assessment criteria and therefore, modelling of traffic related impacts on air quality is not necessary. As a result, it can be determined that there will be no impact on air quality from traffic emissions as a result of the development. Air Quality Impact From Boiler Emissions NO2 The NO2 modelling results at the worst-case off-site receptor i.e. the highest NO2 concentrations measured off-site (including the site boundary), are detailed in Table 9.4. The results indicate that the ambient ground level concentrations are below the relevant air quality standards for NO2. For the worst-case year, emissions from the site lead to an ambient NO2 concentration (including background) which is 72% of the maximum ambient 1-hour limit value (measured as a 99.8th%ile) and 48% of the annual limit value at the worst-case off-site receptor. The geographical variations in 57 UK Highways Agency (2007) Design Manual for Roads and Bridges, Volume 11, Section 3, Part 1 - HA207/07 (Document & Calculation Spreadsheet) by Environmental Impact Services 85 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate th the 1-hour mean (99.8 %ile) and annual mean NO2 ground level concentrations are illustrated as concentration contours in Figure 9.2Figure 9.2 and Figure 9.3Figure 9.3. Table 9.4 Dispersion Model Results at Worst Case Offsite Receptor – NO2 Annual Process Pollutant / Predicted Emission Standard Mean Contribution Meteorological Averaging Period Concentration NO (µg/m3) Background NO 2 Year 2 (µg/m3) Note 1 (µg/m3) (µg/m3) 10 Annual Mean 8.5 18.5 40 NO2 / 2011 99.8th%ile of 1-hr 20 120.1 140.1 200 means 10 Annual Mean 9.0 19.0 40 NO2 / 2012 99.8th%ile of 1-hr 20 123.2 143.2 200 means 10 Annual Mean 8.4 18.4 40 NO2 / 2013 99.8th%ile of 1-hr 20 122.0 142.0 200 means 10 Annual Mean 7.8 17.8 40 NO2 / 2014 99.8th%ile of 1-hr 20 122.3 142.3 200 means 10 Annual Mean 8.1 18.1 40 NO2 / 2015 99.8th%ile of 1-hr 20 118.5 138.5 200 means Note 1 Air Quality Standards 2011 (from EU Directive 2008/50/EC and S.I. 180 of 2011) For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 86 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate 16000 N Background mapp-ing from Google Earth Project EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Lirneric k Max 1-Hour N02 Concentrations (as 99.8%ile) (µg/m') (excluding background ;?;- concentrations) awn 'lnsulting The reepe Suiding, Cbn~b.lrugh~ sud T~ P~ OctJin 17 r: = 1847 mo ''""' 1847 <257 Year 2012 Figure 9.2 Maximum 1-Hour NO2 Concentrations (as a 99.8th%ile) (µg/m3) For inspection purposes only. Consent of copyright owner required for any other use. -N Project EIAR for Extension of Bulk Biologics Fac~ity at Regeneron Co. llrnenc k Annual Mean N02 Concentrations (µg/m'} (excluding background ,?;;;- concentrations) awn 1sult1ng The T.opo Suidft9, Ckm•~h :Lr:;;;·~~~~ ~1~ ~~ Year 2012 3 Figure 9.3 Annual Mean NO2 Concentrations (µg/m ) by Environmental Impact Services 87 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate CO The CO modelling results are detailed in Table 9.5Table 9.5 and Figure 9.4 below. The results indicate that the ambient ground level concentrations are well below the relevant air quality standards for CO. Emissions from the seven steam boilers lead to an ambient CO concentration (including background) which is 20% of the maximum 8-hour average at the worst-case receptor. Table 9.5 Dispersion Model Results at Worst Case Offsite Receptor - CO Annual Predicted Pollutant / Process Standard Mean Emmission Meteorological Averaging Period Contribution (mg/m3) Background Concentration Note 1 Year CO (mg/m3) (mg/m3) CO (mg/m3) CO / 2011 1.9 8-Hour Maximum 0.06 1.96 10 CO / 2012 1.9 8-Hour Maximum 0.06 1.96 10 CO / 2013 1.9 8-Hour Maximum 0.07 1.97 10 CO / 2014 1.9 8-Hour Maximum 0.07 1.97 10 CO / 2015 1.9 8-Hour Maximum 0.07 1.97 10 Note 1 Air Quality Standards 2011 (from EU Directive 2008/50/EC) D Site boundary Maximum concentration:0 .07 mglm3 For inspection purposes only. Consent of copyright owner required for any other use. Scale 1·4000 Background mapping from Google Earth Project EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Reference 1719617 8-Hour Maximum CO Concentrations (µg/m'} (excluding background ~ concentrations) awn 1sulting The TecpteS!dd.inig, Cb'tsha~.h BllmessandTed'lnobgyPaJk.DWin 17 r. +353 1w mo ''+35318<1 <257 Year 2014 Figure 9.4 8-Hour Maximum CO Concentrations (µg/m3) Climatic Impact Overall, due to the size and nature of the development, emissions of CO2 and other greenhouse gases are likely to be insignificant in terms of Ireland’s national emissions and Ireland’s agreements under by Environmental Impact Services 88 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Air Quality & Climate the Kyoto Protocol and other climate strategies (Section 9.1.2). Therefore any impact to climate will be long-term and negative but overall imperceptible. 9.5 MITIGATION MEASURES 9.5.1 CONSTRUCTION PHASE In order to ensure that no dust nuisance occurs, a series of measures will be implemented. In summary the measures which will be implemented will include: Hard surface roads will be swept to remove mud and aggregate materials from their surface while any un-surfaced roads will be restricted to essential site traffic. Furthermore, any road that has the potential to give rise to fugitive dust will be regularly watered, as appropriate, during dry and/or windy conditions. Vehicles using site roads will have their speed restricted, and this speed restriction must be enforced rigidly. On any un-surfaced site road, this will be 20kph, and on hard surfaced roads as site management dictates. Vehicles delivering material with dust potential (soil, aggregates) will be enclosed or covered with tarpaulin at all times to restrict the escape of dust. Public roads outside the site will be regularly inspected for cleanliness, and cleaned as necessary. Material handling systems and site stockpiling of materials will be designed and laid out to minimise exposure to wind. Water misting or sprays will be used as required if particularly dusty activities are necessary during dry or windy periods. During movement of materials both on and off-site, trucks will be stringently covered with tarpaulin at all times. Before entrance onto public roads, trucks will be adequately inspected to ensure no potential for dust emissions. At all times, these procedures will be strictly monitored and assessed. In the event of dust nuisance occurring outside the site boundary, movements of materials likely to raise dust would be curtailed and satisfactory procedures implemented to rectify the problem before the resumption of construction operations. For inspection purposes only. 9.5.2 OPERATIONAL PHASEConsent of copyright owner required for any other use. There are no mitigation measures required for the operational phase of the development as there are no significant air quality or climate related impacts. 9.6 RESIDUAL IMPACTS The results of the air dispersion modelling study show that the residual impacts of the proposed development on air quality & climate will be insignificant. by Environmental Impact Services 89 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration 10 NOISE & VIBRATION 10.1 INTRODUCTION This section presents an assessment into the likely noise and vibration impact associated with the construction and operation of the proposed development. In addition to following the EPA guidance referred to in Section 2.1, the following methodology has been adopted: Review appropriate guidance in order to identify appropriate noise criteria for the site. Carry out noise monitoring at a number of critical locations (e.g. in the vicinity of nearest sensitive properties) to identify existing levels of noise in the vicinity of the development. Predict the level of noise emissions at the nearest noise sensitive locations for both construction and operational phases. Assess the predicted noise levels against the appropriate criteria and existing noise levels and outline required mitigation measures (if any). Appendix 10.1 presents a glossary of the acoustic terminology used in this section. Appendix 10.2 presents an overview of the basic fundamentals of acoustics to assist in understanding of this part of the EIAR. 10.2 THE PROPOSED DEVELOPMENT When considering a development of this nature, the potential noise & vibration impact on the surroundings must be considered for each of two distinct stages: Temporary construction phase and; Long term operational phase. Although a detailed description of the development has been outlined in Section 4 - Proposed Development, an overview of the aspects of the proposed development relevant to Noise and For inspection purposes only. Vibration is provided here. Consent of copyright owner required for any other use. 10.2.1 CONSTRUCTION PHASE For details of the sequence and activities associated with the construction phase please refer to the outline Construction and Environmental Management Plan (CEMP) document. The proposed works will involve minor demolition works, the construction of a new building and ancillary services, landscaping and road works. 10.2.2 OPERATIONAL PHASE The primary sources of outward noise in the operational context are deemed long term and will involve: Building Services and Factory Process Plant; and; Additional vehicular traffic on public roads. The main operational noise sources associated with building services and factory process plant will include cooling towers, boiler stacks, air handling units (AHU’s), condenser units and various rooftop mounted fan and exhaust units. It is expected that all of the plant items will operate continuously 24/7. These issues are discussed in detail in the following sections. by Environmental Impact Services 90 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration 10.3 THE RECEIVING ENVIRONMENT The proposed new building and works will be located at the northern end of the current Regeneron site parallel to the existing building at Raheen Business Park, Raheen, Co. Limerick. The site is deemed to be in an urban location and is bound on all sides by commercial and industrial development or lands zoned for such development. The nearest noise sensitive locations to the development site are the residential units located to the east and north of the site along Ballycummin Road over 400 m from the proposed development. The next nearest receptors are the residential units located to the west of the site along the R526 over 600 m from the proposed development. A location map and site plan are included in Section 4. Figure 10.1 shows the site location in the context of the nearest noise sensitive locations. NSL 2 NSL 1 For inspection purposes only. Consent of copyright owner required for any other use. Figure 10.1 Site Context and Noise Sensitive Receivers58 10.3.1 EXISTING NOISE ENVIRONMENT The existing baseline noise environment has been established through reference to the annual noise monitoring reports conducted by Regeneron as part of the conditions of their existing Industrial Emissions licence (Licence No. P0991-1) from the Environmental Protection Agency (EPA). A summary of the noise monitoring conducted in the vicinity of the noise sensitive locations identified in Figure 10.1 is presented in the following sections. Appendix 10.3 presents the noise survey reports carried out in 2015 and 2016 as part of the on-going IPPC license monitoring for the existing site operations. 58 Imagery Source: Google Earth by Environmental Impact Services 91 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration 10.3.2 CHOICE OF MEASUREMENT LOCATIONS Noise measurements were conducted in the vicinity of the two noise sensitive locations identified in Figure 10.1; each of these locations are described in turn below. NSL 1 Situated along the R526 to the west of the development site over 600m from the proposed development. NSL 2 Situated along the Ballycummin Road to the north of the development site over 400m from the proposed development. 10.3.3 SURVEY PERIODS Noise measurements were conducted over the course of daytime, evening time and night-time periods as follows, 2015 11:30 to 15:31hrs on 30 September 2015 21:42 to 22:51hrs on 30 September 2015 01:22 to 02:37hrs on 1 October 2015 2016 15:57 to 19:06hrs on 31 May 2016 19:07 to 20:17hrs on 31 May 2016 01:20 to 02:14hrs on 19 July 2016 10.3.4 MEASUREMENT PARAMETERS The survey results are presented in terms of the following three parameters: LAeq is the equivalent continuous sound level. It is a type of average and is used to describe a fluctuating noise in terms of a single noise level over the sample period. For inspection purposes only. Consent of copyright owner required for any other use. LAF90 is the sound level that is exceeded for 90% of the sample period. It is typically used as a descriptor for background noise. LAFMax is the instantaneous maximum sound level measured during the sample period. The “A” suffix denotes that the sound levels have been “A-weighted” in order to account for the non- linear nature of human hearing. The “F” suffix denotes that the parameter has been measured with ‘Fast’ time-weighting applied. All sound levels in this report are expressed in terms of decibels (dB) relative to 2x10-5 Pascal (pa). by Environmental Impact Services 92 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration 10.3.5 RESULTS AND DISCUSSION NSL 1 The survey results for NSL 1 are summarised in Table 10.1. Table 10.6 Summary of Measured Noise Levels at NSL 1 Measured Noise Levels (dB re. 2x10-5 Pa) Year Period Time LAeq LAFMax LAF90 11:30 – 12:00 58 73 45 Daytime 12:00 – 12:30 60 72 51 12:30 – 13:00 59 72 51 2015 Evening 21:42 – 22:12 65 98 42 Night- 01:22 – 01:37 57 87 35 time 01:39 – 01:54 62 83 39 17:36 – 18:06 69 86 52 Daytime 18:06 – 18:36 70 84 51 18:36 – 19:06 68 94 48 2016 Evening 19:07 – 19:37 67 82 47 Night- 01:20 – 01:50 56 84 34 time 01:50 – 02:20 59 81 35 During daytime survey periods, the main sources of noise noted in the area was road traffic on the R526 and birdsong. Daytime noise levels were in the range of 58 to 70dB LAeq and 45 to 52dB LA90. During the evening time survey period, the main sources of noise noted in the area was road traffic on the R526 and some pedestrian activity. Evening time noise levels were in the range of 65 to 67dB LAeq and 42 to 47dB LA90. The noise sources of significance observed during the night-time noise measurements were from road traffic noise and some distant plant noise. Night time noise levels were in the range of 56 to 62dB LAeq and 34 to 39dB LA90. For inspection purposes only. No significant source of vibration wasConsent noted of copyright during owner the required survey for any periods. other use. NSL 2 The survey results for NSL 2 are summarised in Table 10.2. by Environmental Impact Services 93 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration Table 10.7 Summary of Measured Noise Levels at NSL 2 Measured Noise Levels (dB re. 2x10-5 Pa) Year Period Time LAeq LAFMax LAF90 13:30 – 14:00 58 84 46 Daytime 14:00 – 14:30 57 79 47 15:01 – 15:31 58 76 50 2015 Evening 22:21 – 22:51 53 73 37 Night- 02:07 – 02:22 49 64 39 time 02:22 – 02:37 53 81 38 15:57 – 16:27 58 82 50 Daytime 16:27 – 16:57 58 80 50 16:57 – 17:27 58 76 52 2016 Evening 19:42 – 20:12 57 86 49 Night- 01:29 – 01:59 49 81 29 time 02:59 – 02:29 55 81 28 During daytime survey periods, the main sources of noise noted in the area were road traffic on the Ballycummin Road and pedestrian activity. Other sources included birdsong and some distant house alarms. Daytime noise levels were in the range of 57 to 58dB LAeq and 46 to 52dB LA90. During the evening time survey period, the main source of noise noted in the area was road traffic on the Ballycummin Road. Evening time noise levels were in the range of 53 to 57dB LAeq and 38 to 49dB LA90. The noise sources of significance observed during the night-time noise measurements were from road traffic noise. Night time noise levels were in the range of 49 to 55dB LAeq and 28 to 39dB LA90. No significant source of vibration was noted during the survey periods. 10.4 PREDICTED IMPACTS 10.4.1 ASSESSMENT CRITERIA For inspection purposes only. Consent of copyright owner required for any other use. Construction Phase – Noise Criteria There is no published Irish guidance relating to the maximum permissible noise level that may be generated during the construction phase of a project. Local authorities normally control construction activities by imposing limits on the hours of operation and consider noise limits at their discretion. In the absence of specific noise limits, appropriate criteria relating to permissible construction noise levels for a development of this scale may be found in the British Standard BS 5228 – 1: 2009+A1:2014 Code of practice for noise and vibration control on construction and open sites – Noise. The approach adopted in BS 5228– 1: 2009+A1:2014 calls for the designation of a noise sensitive location into a specific category (A, B or C) based on exiting ambient noise levels in the absence of construction noise. This then sets a threshold noise value that, if exceeded at this location, indicates a potentially significant noise impact is associated with the construction activities. The document sets out guidance on permissible noise levels relative to the existing noise environment. Table 10.8Table 10.8 presents the values which, when exceeded, signify a significant Formatted: English (U.K.) effect at the facades of residential receptors as recommended by BS 5228– 1: 2009+A1:2014. by Environmental Impact Services 94 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration Table 10.8 Example Threshold of Significant Effect at Dwellings59 Assessment category and threshold Threshold value, in decibels (dB) 60 61 62 value period (LAeq) Category A Category B Category C Night-time (23:00 to 07:00hrs) 45 50 55 Evenings and weekends63 55 60 65 Daytime (07:00 to 19:00) and 65 70 75 Saturdays (07:00 to 13:00) The following method should be followed: For the appropriate periods (i.e. daytime, evening and night time) the ambient noise level is determined and rounded to the nearest 5dB. A review of the baseline noise survey results (ref. Section 10.3.5) would indicate that the categories detailed in Table 10.4 are appropriate in terms of the nearest noise sensitive locations being considered. Table 10.9 Rounded Baseline Noise Levels and Associated Categories Rounded Baseline Appropriate Noise Period Noise Level LAeq,1hr Category Limit (dB) LAeq,1hr (dB) Daytime (07:00 – 19:00) and Saturdays 60 A 65 (07:00 – 13:00) If the construction noise level exceeds the appropriate category value, then a significant effect is deemed to occur. Construction Phase – Vibration Criteria Vibration standards come in two varieties: those dealing with human comfort and those dealing with cosmetic or structural damage to buildings. In both instances, it is appropriate to consider the magnitude of vibration in terms of Peak Particle Velocity (PPV). It is acknowledged that humans are particularly sensitive to vibration stimuli and that any perception of vibration may lead to concern. In the case of road traffic, vibration is perceptible at around 0.5 mm/s and may become disturbing or annoyingFor inspection purposes at higher only. magnitudes. However, higher levels of vibration are typically tolerated forConsent single of copyrightevents owner or events required for of any short other use. duration are typically tolerated at vibration levels up to 12 mm/s and 5 mm/s respectively. This guidance is applicable to the daytime only; it is unreasonable to expect people to be tolerant of such activities during the night. Guidance relevant to acceptable vibration within buildings is contained in the following documents: British Standard BS 7385: 1993: Evaluation and measurement for vibration in buildings Part 2: Guide to damage levels from ground borne vibration, and; British Standard BS 5228-2:2009+A1 2014: Code of practice for noise and vibration control on construction and open sites – Vibration. 59 Source: British Standard BS 5228 – 1: 2009+A1:2014 Code of practice for noise and vibration control on construction and open sites – Noise 60 Category A: threshold values to use when ambient noise levels (when rounded to the nearest 5dB) are less than these values. 61 Category B: threshold values to use when ambient noise levels (when rounded to the nearest 5dB) are the same as category A values. 62 Category C: threshold values to use when ambient noise levels (when rounded to the nearest 5dB) are higher than category A values. 63 19:00 – 23:00 weekdays, 13:00 – 23:00 Saturdays and 07:00 – 23:00 Sundays. by Environmental Impact Services 95 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration Both standards contain the same guidance relating to building damage criteria. The standards note that the risk of cosmetic damage to residential buildings starts at a Peak Particle Velocity (PPV) of 15 mm/s at 4 Hz rising to 20 mm/s at 15 Hz and 50 mm/s at 40 Hz and above for unreinforced or light framed structures. The standard also notes that below 12.5 mm/s PPV the risk of damage tends to zero. Taking the above into consideration the vibration criteria in Table 10.10 Table 10.10 are recommended. Table 10.10 Allowable Vibration during Construction Phase Allowable vibration (in terms of peak particle velocity) at the closest part of sensitive property to the source of vibration, at a frequency of Less than 4Hz 15 to 40Hz 40Hz and above 12 mm/s 20 mm/s 50 mm/s Operational Phase – Noise Criteria Regeneron will be required to apply for and obtain an updated Industrial Emissions Licence (IED) from the Environmental Protection Agency (EPA) in order to carry out the activities associated with the proposed development. As the facility will be licenced by the EPA, reference has been made to the publication Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4) 2016, which is used to set operational noise limits from activities under the control of the EPA (manufacturing, industrial, waste management etc.). This document sets out a procedure for applying appropriate operational noise limits from this type of facility at the nearest noise sensitive receptors taking account of the background noise environment. Table 10.11Table 10.11 summarises the criteria Formatted: English (U.K.) applied, depending on the prevailing background noise environment. Table 10.11 External Noise Limits from Licenced Sites64 Day, dB L 65 Evening, dB L Night, dB L 66 Location Ar,T Ar,T Aeq,T (07:00 to 19:00hrs) (19:00 to 23:00hrs) (23:00 to 07:00hrs) Areas of Low Background Noise For inspection45 purposes only. 40 35 All Other Areas Consent of copyright55 owner required for any other50 use. 45 In order to establish whether the noise sensitive receptors in the vicinity of the site would be considered a ‘low background noise’ area, the noise levels measured during the environmental noise survey need to satisfy the following criteria: Arithmetic Average of LA90 During Daytime Period ≤40dB LA90, and; Arithmetic Average of LA90 During Evening Period ≤35dB LA90, and; Arithmetic Average of LA90 During Night-time Period ≤30dB LA90. On review of the noise survey results, the background noise levels measured are above the assessment criteria outlined in Table 10.6. In this instance, the operational noise limits for areas of low background noise would therefore not be applicable for the proposed development. 64 Source: Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4) 2016 65 The Rated Noise Level, LA,r,T is equal to the LAeq during a specified time interval (T), plus specified adjustments for tonal character and/or impulsiveness of the sound 66 During night time periods the LAeq parameter is applicable as no tonal or impulsive noise from the facility should be clearly audible or measurable at any NSL. by Environmental Impact Services 96 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration The following noise criteria are appropriate for this development at the nearest noise sensitive locations: For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 97 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration Table 10.12 Proposed Operational Noise Criteria Day Evening Night (07:00 to 19:00hrs) (19:00 to 23:00hrs) (23:00 to 07:00hrs) 55dB LAr (15mins) 50dB LAr (15mins) 45dB LAeq (15mins) The noise limits stated here apply to all noise emissions from the facility. In this context this applies to all existing and proposed process plant as well as onsite mobile and intermittent activity. Operational Phase – Additional Vehicular Activity on Public Roads There are no specific guidelines or limits relating to traffic related sources along the local or surrounding roads. In this instance, in order to assess the potential noise impact from any changes in road traffic, Formatted: Font: Not Bold Table 10.13 Table 10.13 offers guidance as to the likely impact associated with a particular change in traffic noise levels. Table 10.13 Likely Impacts Associated with Change in Traffic Noise Level Change in Sound Level Subjective Reaction Magnitude of Impact (dB LA10) < 3 Typically Inaudible Imperceptible 3 – 5 Perceptible Slight 6 – 10 Up to a doubling of loudness Moderate 11 – 15 Significant Over a doubling of loudness >15 Profound Operational Phase – Vibration Criteria It is considered that the proposed development will not give rise to any significant levels of vibration in the receiving environment. Vibration criteria are therefore not deemed to be necessary for the operational phase of this development. 10.4.2 NOISE AND VIBRATION EMISSIONS For inspection purposes only. Consent of copyright owner required for any other use. Construction Phase – Noise The Phase 1 construction works are expected to occur over a period of approximately 24 months. It is expected that any significant construction activities will be carried out between the hours of 07:00 to 19:00 Monday to Friday 08:00 to 16:00 on Saturdays. It is possible that the building contractor may wish to carry out certain external operations outside of regular daytime hours (for example, weekends and evenings) subject to written approval by Limerick City & County Council. It is anticipated that any activities occurring during these times will be significantly reduced and where they do occur contractors will ensure they take place over as short a timeframe as possible and that relevant noise criteria values are not exceeded at sensitive locations. During the construction phase of the proposed development, a variety of plant items and heavy machinery will be in use with the potential to generate significant levels of noise. Details of the methods and procedures to be followed during the construction phase are outlined the associated CEMP that has been prepared for the project. Reference is made to BS 5228-1:2009+A1:2014 and BS 5228-2:2009+A1:2014, which offers detailed guidance on the control of noise and vibration from demolition and construction activities. Various mitigation measures will be considered and applied during the construction of the proposed development. Specific examples of such measures are: by Environmental Impact Services 98 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration • Limiting the hours during which site activities likely to create high levels of noise or vibration are permitted; • Establishing channels of communication between the contractor/developer, Local Authority and residents; • Appointing a site representative responsible for matters relating to noise and vibration; • Monitoring levels of noise and/or vibration during critical periods and at sensitive locations, and; • All site access roads will be kept even so as to mitigate the potential for vibration from lorries. These measures have been included in the assessment carried out of the potential noise impact during the construction phase. Due to the scale of the construction, a detailed construction programme has not yet been advanced. In the absence of such a detailed programme it is not possible at this stage to calculate the actual magnitude of construction phase noise emissions to the local environment. However, based on the expected activities as detailed in the CEMP, it is possible to predict typical noise levels using guidance set out in BS 5228-1: 2009+A1 2014. Table 10.14Table 10.14 outlines typical plant items and associated noise levels that are anticipated at the nearest noise sensitive location to significant construction works. Assuming that significant construction activities take place at a distance of 400 metres to the nearest noise sensitive location (NSL2) noise prediction calculations have been prepared. Predictions are based on the utilisation of construction associated plant for a minimum of 66% of a working day (i.e. 8hrs of a 12hr day). The results of this assessment are presented in Table 10.14Table 10.14. Table 10.14 Predicted Noise Emission Levels at Nearest NSL during Construction Phase Predicted Plant Noise Level at Construction Plant Item Phase 10 m Distance67 Noise Level (BS 5228 Ref.) 68 (dB LAeq) at NSL 2 (dB LAeq,1hr) Tracked excavator (C2.22) 72 Dump Truck (C4.2) 78 Site Clearing Wheeled Lorry Loader (D3.1) 75 52 & Preparation Tracked Semi For-Mobile inspection Crusher purposes only. (C9.14) 90 Consent of copyright owner required for any other use. Pneumatic Breaker (D2.2) 81 Sheet Pile (C12.31) 81 Compressor (D7 6) 77 Excavations & Concrete Poker Vibrator (C4 33) 78 49 Foundations Concrete Mixer Truck (C4.20) 80 Concrete Pump (C3.24) 78 Concrete Mixer Truck (C4.20) 80 Wheeled Mobile Crane (C4.38) 78 Structural Steel Erection Articulated lorry (C11.10) 77 43 Tower Crane (C4.48) 76 Compressor (D7 6) 77 Diesel Hoist (C7.98) 76 Shell Construction Articulated lorry (C11.10) 77 45 Pneumatic Circular Saw (D7.79) 75 Generator (C4.84) 74 67 All plant noise levels are derived from BS 5228: Part 1 68 Assumes the methods for noise reduction outlined in Annex F of BS5228: Part 1 by Environmental Impact Services 99 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration The assessment demonstrates that the noise levels from typical construction activities at the nearest noise sensitive receptors should be well below the recommended construction noise limits outlined in Table 10.8Table 10.8. The impact is therefore considered to be moderate at the nearest noise sensitive locations. The predicted noise levels referred to in this section are indicative only and are intended to demonstrate that it will be possible for the contractor to comply with current best practice guidance. The impact on the noise environment due to construction activities will be transient in nature and significant impacts at the noise sensitive locations are not expected. Notwithstanding this, good practice measures will be implemented to minimise any potential impacts from construction activities on the noise environment. These measures will also reduce the noise impact on the wider surrounding environment, including other commercial buildings in the vicinity. Construction Traffic Access for the majority of construction vehicles will be the M20 and direct to the site, therefore the bulk of traffic will not pass nearby noise sensitive locations. Notwithstanding the above, following a review of the traffic data supplied by Jacobs Engineering, the additional traffic introduced onto the local road during the construction phase is not considered significant in terms of the potential for noise impact. Construction Phase – Vibration With respect to the potential vibration impact, the only significant source of vibration is expected to be due to excavations and foundation activities. However, the distance between the areas where these activities are to occur and the nearest noise sensitive locations are such that all vibration transmission would be both imperceptible and well below recommended guideline criteria. Operational Phase – Noise There are three expected primary sources of noise in the operational context. Building services noise; Additional vehicular traffic on public roads, and; Car park activity For inspection purposes only. Consent of copyright owner required for any other use. Each of these primary noise sources is addressed in turn in the following sections. Building Services Noise There are a number of plant items associated with the operation of the proposed development. Most of this plant will be capable of generating noise to some degree. Noisy plant items located externally will potentially have the greatest impact on the receiving environment. The following assessment is based upon the preliminary information which will be developed further during the detailed design phase in accordance with the requisite operational noise criteria. In this instance the existing prevailing background noise level measured during the noise survey ranges from 28 to 34dB LA90 during the most sensitive night-time period. Making the assumption that the majority of mechanical plant serving the development will operate 24/7 the mechanical plant noise emissions must be designed to achieve the specified criteria during the night-time period taking into account the cumulative impact of the existing noise environment. Most of the noise generating plant items will be located within fully enclosed plant rooms or ventilated plant enclosures louvred with attenuation such that the noise emission level at a distance of 1m from these louvres will be a maximum of 65 dB LAeq. by Environmental Impact Services 100 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration All air handling units, boiler stacks and extract fans will be hard ducted to louvres or will have noise attenuation in series, therefore noise breakout will be minimal. Appropriate louvres (standard weatherproofing or acoustic) will be provided such that the noise emission level at a distance of 1m from these louvres will be a maximum of 65 dB LAeq. Transformers located externally will be selected such that the noise emission level at a distance of 1m from individual transformers will be a maximum of 65dB LAeq. Cooling Towers located externally will be selected such that the noise emission level at a distance of 1m from individual cooling towers will be a maximum of 84 dB LAeq. In addition, all plant will be selected such that there are no tonal or impulsive emissions. Based on the noise levels listed here and taking into account the distance to the nearest noise sensitive locations the plant noise levels at the nearest sensitive locations will be in the range of 35 dB to 38 dB LAeq. This is within the adopted criteria of 45 dB LAeq during the most sensitive night-time period. Additional Vehicular Traffic on Public Roads In terms of the additional traffic on local roads that will be generated as a result of this development the following comment is presented. It is important to note that in order to increase traffic noise levels by 1dB traffic volumes would need to increase by the order of 25%. AADT flows with and without development for the years 2021 and 2036 have been assessed. The additional traffic introduced onto the local road network due to this development will result in an increase of traffic volumes of far less than 25% at all locations. The resultant change in noise level due to road traffic is less than 1dB at all locations which is an imperceptible change. Car Park Activity For inspection purposes only. In this instance, the main car parkingConsent facilities of copyright for owner the required development for any other use. will be provided by means of new surface level spaces located along the main entrance to the south of the existing car park. The nearest noise sensitive locations to this element of the development are over 350m away to the north along the R526. At this distance, the noise from car park activity will be inaudible at any noise sensitive location. In summary, the likely noise impact of car park activities on the local environment is not significant. In Combination Effects Note that due to the imperceptible impacts associated with both car parking activity and additional vehicular traffic on the public roads where will be no additional in combination effect due to multiple sources operating simultaneously. The operational noise impact will in effect be limited to the noise emissions from building services plant as assessed here. Note that while the assessment presented here is focused on the nearest residential noise sensitive locations the potential operational noise impact on the surrounding area within Raheen Business Park is not expected to be significant. The existing noise climate within the Business Park is dominated by commercial and industrial noise sources and while there may be an increase in the noise levels, this character of noise will not change as a result of the development. The impact is therefore not considered significant. by Environmental Impact Services 101 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration Operational Phase – Vibration Emissions It should be noted that the proposed development will not give rise to any significant levels of vibration off site and therefore the associated impact is not significant. 10.4.3 CUMULATIVE IMPACTS Existing Developments The baseline surveys take account of noise emissions from existing developments. Formatted: Font: (Default) Tahoma Typical Cumulative EPA Noise Predicted Background EPA Definition Loc. Noise Level Limit for dB LAeq Level dB of Impacts Formatted: Not Superscript/ Subscript ,T (dB(A)) Licenced Sites LA90,T Formatted: Not Superscript/ Subscript NSL 1 31 34 36 45 Slight NSL 2 38 28 38 45 Slight Typical Cumulative EPA Noise Predicted Background EPA Definition Loc. Noise Level Limit for dB LAeq Level dB of Impacts ,T (dB(A)) Licenced Sites LA90,T NSL 1 31 34 36 45 Slight NSL 2 38 28 38 45 Slight presents the predicted cumulative noise level associated with the proposed development at the nearest noise sensitive locations during night time periods when any potential impact will be greatest. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 102 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration Table 10.15 Review of Predicted Changes in Existing Noise Levels Typical Cumulative EPA Noise Predicted EPA Definition Loc. Background Noise Level Limit for dB LAeq,T of Impacts Level dB LA90,T (dB(A)) Licenced Sites NSL 1 31 34 36 45 Slight NSL 2 38 28 38 45 Slight Review of the predicted increases in noise level at the nearest noise sensitive locations conclude that the associated impact is ‘slight’ during the operational phase. The predicted changes will have an impact on the existing baseline but will not affect the character of the noise environment significantly at the nearest noise sensitive locations. Future Developments There is no information available at present as to the potential noise emissions from future developments at the nearby noise sensitive locations when, or should, these developments become operational. With consideration of the operational noise criteria discussed in Section 10.4, it can be assumed that the worst case allowable noise emissions at the nearest noise sensitive locations from any of these developments will be 45 dB LAeq,T during night time periods. Given that the worst case predicted noise levels from the proposed development assessed here are in the order of 38 dB LAeq,T, it can therefore be concluded that there is the potential for some cumulative noise impacts in the future, however, as long as the overall cumulative noise level does not exceed 45 dB LAeq,T the impact would be moderate. 10.5 MITIGATION MEASURES In order to sufficiently ameliorate the potential noise impact from this site, a schedule of control measures has been formulated. 10.5.1 CONSTRUCTION PHASE The impact assessment has found that predicted levels of construction noise at nearby noise sensitive locations is likely to be well below the proposed For inspection criterion purposes only.levels. Consent of copyright owner required for any other use. We recommend that vibration from construction activities to off-site residences be limited to the values set out in Formatted: Font: Not Bold Table 10.10 Formatted: English (U.K.), Do not Table 10.10 It should be noted that these limits are not absolute, but provide guidance as to check spelling or grammar magnitudes of vibration that are very unlikely to cause cosmetic damage. Magnitudes of vibration slightly greater than those in the table are normally unlikely to cause cosmetic damage, but construction work creating such magnitudes should proceed with caution. 10.5.2 OPERATIONAL PHASE Building Services and Factory Process Plant The impact assessment has found that predicted noise levels associated with the day to day operations of the site will be well with the proposed criteria applicable to a site of this nature. Notwithstanding this due consideration as part of the detailed design process will ensure that the new development will operate within the noise limits stipulated in the site IED licence issued by the EPA. by Environmental Impact Services 103 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Noise & Vibration Additional Vehicular Traffic on Public Roads The noise impact assessment outlined previously has demonstrated that mitigation measures are not required. 10.6 RESIDUAL IMPACTS This section summarises the likely noise and vibration impact associated with the proposed development, taking into account the mitigation measures. 10.6.1 CONSTRUCTION PHASE During the construction phase of the project there may be some moderate noise impacts on nearby noise sensitive properties due to noise emissions from site traffic and other activities. The application of noise limits and hours of operation, along with implementation of appropriate noise and vibration control measures, will ensure that noise and vibration impacts are kept to a minimum. Also it is reiterated that any construction noise impacts will be temporary and short term in nature. 10.6.2 OPERATIONAL PHASE Building Services and Factory Process Plant Proprietary noise and vibration control measures will be employed in order to ensure that noise emissions from building services plant do not exceed the adopted criterion at the façade of any nearby noise sensitive locations. In addition, noise emissions should be broadband in nature and should not contain any tonal or impulsive elements. The resultant noise impact is considered to be slight which will cause a noticeable change in the baseline environment without affecting its sensitivities. Additional Vehicular Traffic on Public Roads Any change in noise levels associated with vehicles at road junctions in the vicinity of the proposed development is expected to be imperceptible. The resultant noise impact is imperceptible. Car Parking Activity For inspection purposes only. Consent of copyright owner required for any other use. The noise impact due to car park activity in the vicinity of the proposed development is expected to be imperceptible. The resultant noise impact is imperceptible. by Environmental Impact Services 104 EPA Export 30-11-2018:04:49:41 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact 11 LANDSCAPE & VISUAL IMPACT 11.1 INTRODUCTION This landscape and visual impact assessment has been prepared to identify and assess the effects on the appearance and character on the local environs arising from the proposed development. It analyses the existing landscape character and significance, and provides an evaluation of the potential for landscape and visual impacts of the development. The assessment is made having regard to the vulnerability of the landscape to change and to the location of visual receptors relative to the proposed development. The main landscape features and landscape character areas were identified through a combination of site visit and documentation surveys. Landscape impacts were analysed based on: The capacity of the existing landscape to absorb the proposed development; Effects on landscape character and features (e.g. removal or alteration); Proximity of sensitive viewpoints (e.g. routes) and visual receptors; The details of the development. Visual impacts are evaluated taking account of: The potential level of visual intrusion (i.e. effect impinged upon a view); The potential for visual impact dependant on the proximity and elevation of structures to a sensitive viewpoint/visual receptor. The County Development Plan was consulted to identify Landscape Character Areas and significant landscape features as well as designated Scenic Routes and Landscape. Related provisions of the Plan – such as the proximity of Protected Structures to the site, were also considered. For inspection purposes only. 11.2 THE PROPOSED DEVELOPConsent of copyright ownerMENT required for any other use. A full development description is included in Section 4 of this document. In summary, the aspects of the proposed development that have a potential to give rise to landscape of visual impacts consists of: A Manufacturing facility which is an extension to the existing facility Related items of external industrial plant and equipment New permanent and temporary car parking and associated site works by Environmental Impact Services 105 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact 11.3 RECEIVING ENVIRONMENT Figure 11.1 External Context69 The proposed development site is located within the large scale industrial estate at the Raheen Business Park, 4.9 km to the southwest of Limerick City Centre. The Park covers an area of 178 ha. Having started in the 1970s the park has evolved over the decades and contains a wide range of manufacturing and office buildings. The Park contains a range of large scale manufacturing and logistical warehouses as well as offices. To the north of the business park is the residential neighbourhood of Ballycummin/ Glencairin. South of the R510 road is primarily agricultural landscape. The proposed site is located in the centre of the Business Park with manufacturing and office buildings to the south, east and north. The lands to the west of the site remain undeveloped and available for future park development. A protected structure, Roche Castle (No. 32 Limerick Southern Environs LAP and NIAH Structure 21901309), is located outside the proposed development site on the north-western boundary. The site of the proposed development comprises developed industrial lands that are currently used for access, circulation and ancillary industrial activities and equipment. For inspection purposes only. Consent of copyright owner required for any other use. Figure 11.2 Internal Context 69 The appearance and character of the landscape in the immediate environs of the proposed development. by Environmental Impact Services 106 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact Figure 11.3 The Site [red] in the Landscape Context70 11.4 CHARACTER & APPEARANCE The established general character of the area arises from the mixture of land-uses and structures Within the Limerick County Development Plan (2010-2016) this area and wider landscape are located within the Shannon Coastal Zone Landscape Character Area. This regional level character area For inspection purposes only. comprises a large area of northernConsent part of copyright of County owner required Limerick for any other and use. is bounded on one side by the Shannon Estuary while its southern boundary is defined by the gradually rising ground, which leads onto the agricultural zone and the western hills zoned to the south. One of the main features of the area is the presence of the estuary, which is perhaps the defining characteristic of the region. The landscape itself is generally that of an enclosed farm type, essentially that of a hedgerow dominant landscape. At a more localised level, the landscape can be characterised as a typical peri-urban or edge of city landscape type with a mixture of industrial, agricultural land with low density sporadic housing with medium density housing to the north east at the edge of the city. The presence of large scale industrial buildings, road infrastructure, overhead pylons and relatively level topography results in a landscape with a high capacity to accommodate further development, without significantly altering its character. 70 Where the Limerick’s urbanising edge meets farmland by Environmental Impact Services 107 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact H Figure 11.4 Existing Views towards the site from surrounding roads [Note Views C and H are discussed later] For inspection purposes only. View A Consent of copyright ownerView required E for any other use. View B View F View D View G by Environmental Impact Services 108 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact 11.4.1 SIGNIFICANCE AND SENSITIVITY There are no designated scenic views or prospects close to the site within the Limerick County Development Plan as shown by Figure 11.5 below. - • ~I. "OIPl - Umetlck County Cound ___ Nc:Nembet Map Views & "'°'Peet> ,..,,o ... f ! ..., ,.. ,_('_ __ .... 2010 7 6 Figure 11.5 Views or Prospects For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 109 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact 11.4.2 LANDSCAPE As shown in Figure 11.6 below, the site is located on the southern outskirts of Limerick City. Within the Limerick County Development Plan (2010-2016) this site and wider landscape are located within the Shannon Coastal Zone Landscape Character Area. _°"'.,.. r•~ -~...... ~,..,,-~ , .. , .,.,,,t»<¥1..-.J< SITE -Arlfso,.... . ,,14•.10. ~"-'nUtbJ1 LOCATION -""'°"' _-,"""· tln« ..l"IMt"of) IMZ - ~~~lf~C:::/ Umeric~C ovnly Councl l.ondocope Chcrroetor .,_ f For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 110 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact 11.5 PREDICTED IMPACTS This is the nearest public view towards the proposed development will be partially and distantly visible behind mature vegetation and in the context of existing structures The effect will be discernible, though not significant because it will conform with the established appearance. View A Roches Avenue looking south-east The proposed development will be partially and distantly visible behind mature vegetation and in the context of existing structures The effect will be discernible, though not significant because it will conform with the established appearance. View B Ballycummin Ave Roundabout looking north-east The proposed development will be For inspection purposes only. partially and distantly Consent of copyright owner required for any other use. visible behind mature vegetation and in the context of existing structures The effect will be discernible, though not significant because it will conform with the established appearance. View D Loughmore Avenue, looking north Views A- D from the west and south will generally be screened by mature woodland planting in the vicinity of Roche’s Castle. Where there is visibility towards the development only the upper portions will be visible in the context of an established industrial facility within an established industrial and commercial area For these reasons the development, though distantly and partially visible, will not give rise to significant landscape effects by Environmental Impact Services 111 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact No part of the proposed development will be visible because of the combined factors of distance, intervening vegetation, topography and buildings View E Pearse Road looking north-west The proposed development will be I - - partially and distantly --- . visible behind mature vegetation and in the context of existing structures The effect will be discernible, though not significant because it will conform with the established appearance. View F Loughmore Ave at Derryknockane View looking north-west No part of the proposed development will be visible because of the combined For inspection purposes only. Consent of copyright owner required for any other use. factors of distance, intervening vegetation, topography and buildings View G Ballycummin Road looking west Views E- G from the east and north will generally be screened by of the combined factors of distance, intervening vegetation, topography and buildings. Where there is visibility towards the development only the upper portions will be visible in the context of an established industrial facility within an established industrial and commercial area for these reasons the development, though distantly and partially visible, will not give rise to significant landscape effects by Environmental Impact Services 112 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Landscape & Visual Impact View C View at existing entrance. New car parking will be developed at this location. The trees and shrubs mark the route of an old road. The new development will retain and incorporate these features to ensure the continuity of the landscape and cultural heritage of the area. View H from within the existing industrial site looking towards Roche Castle [left of centre of photo in trees]. The new development – at the location of the photograph view point – will retain the established appearance and character of the context and setting of the structure. For inspection purposes only. The context and setting of the ProtectedConsent of copyright Structure owner required will notfor any change other use. from that established by prior consent. 11.6 MITIGATION MEASURES The layout of the car parking was amended to incorporate the existing trees, relict hedgerow and old road alignment to improve the continuity of the landscape and cultural heritage of the area. Landscaping works will otherwise be carried out in accordance with the works specified in the planning application. by Environmental Impact Services 113 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Material Assets 12 MATERIAL ASSETS 12.1 INTRODUCTION The prescribed environmental factor of Material Assets is described in 2002 in the EPA Guidelines as including Architectural, Archaeological and Cultural Heritage, Designed Landscapes, Natural Resources of Economic Value, Building & Structures and Infrastructure. Subsequent regulations together with evolution of practice in EIA have led to most of these subjects normally being covered under other headings. These headings typically include Cultural Heritage, Landscape, Water and Traffic. In this EIAR the impacts on the various material assets described above are addressed in various sections, principally: Section 8 Land, Soils, Geology & Hydrogeology Section 9 Water & Hydrology Section 11 Landscape & Visual Impact Section 13 Traffic & Transportation Section 14 Waste Management Section 15 Archaeology & Cultural Heritage This section covers the proposals for services- comprising surface water, electrical supply, water supply, wastewater, telecommunications and gas supply. The draft revised EPA Guidelines (ref section 2.1) support this approach, confirming that ‘Material assets can now be taken to mean built services and infrastructure’. 12.2 ELECTRICAL SUPPLY The existing site is served by a twin underground 38kV supply to a location in the South West of the site. An on-site substation to the south of the site steps this down for distribution around the site. The site’s existing electrical demand is 12 MVA71. The extension will increase this demand to 2/3 MVA (ESB Networks confirm that the local network has adequate capacity for the additional demand). No new grid connection or overhead lines will be required. For inspection purposes only. Consent of copyright owner required for any other use. Existing emergency generators provide capacity of 12.5 MVA which is sufficient back-up in event of a loss of network power to the site. 12.3 GAS CONNECTION Existing natural gas is supplied from the local Bord Gáis network from the South of the site. This gas is distributed around the site via a pressure reducing station in the South of the existing site. The extension will be supplied from this existing on-site network. It will only use natural gas for steam production which will utilise direct digital combustion control, oxygen trim and heat recovery through economisers and flash steam recovery. A high level of condensation recovery will also be implemented. Bord Gáis have confirmed that the local network has adequate capacity to meet the additional demand of the proposed extension. The two additional gas fried boilers in the facility extension will be separate fed from the existing gas supply network in the Raheen Business Park. 71 MVA = Mega Volt Amps by Environmental Impact Services 114 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Material Assets 12.4 WATER The water supply and waste water discharge needs of the extension will be met through the infrastructure that serves the existing site. Irish Water has confirmed that the public foul sewer and water supply networks have adequate available capacity to supply water and to receive the proposed volume of wastewater from the extension. Irish Water have confirmed that the maximum anticipated demand of 3,00 m3/day water in and waste water out can be supplied on a phased basis to match the anticipated phased production demands of the expanded Regeneron facility. The levels of the changes in demand for these services relative to available network capacities are further discussed in Section 8 Water & Hydrology. The surface water design for the proposal is detailed in the separate Civil Drainage Report and is also assessed in Section 8 Water & Hydrology. 12.5 TELECOMS The telecoms requirements of the extension will be met through the existing on-site network. Telecoms providers have confirmed that existing connections to the site have adequate capacity to cater for the demand of the extension. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 115 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation 13 TRAFFIC & TRANSPORTATION 13.1 INTRODUCTION/METHODOLOGY This section presents an assessment of the impact of the proposed Regeneron Development expansion on local traffic and transport operations. The assessment focuses on the effects of increased traffic on the local road network during construction of the development and also the post construction (operational) situation. The volume and type of traffic generation in relation to the development and the likely effects of this traffic have been considered within this section. The assessment considers the impact of the development traffic on the baseline traffic levels. While this chapter should be read in conjunction with the standalone Traffic and Transport Assessment (TTA), this assessment has been undertaken to meet the requirements of ‘EPA Guidelines on the information to be contained in Environmental Impact Statements’. The existing Regeneron site and proposed development site is located within Raheen Business Park, Limerick. The site is bound by Roches Avenue to the north; and Cloughkeating Avenue to the east, south and west. A summary of the existing sustainable infrastructure and services is provided below. Further detail on baseline accessibility is contained within the TTA. 13.1.1 WALKING The site is located within a good proximity to local amenities in Raheen such as public transport and the residential areas located to the north and east. Furthermore, the pedestrian infrastructure around the site is of reasonable quality and is well lit. 13.1.2 CYCLING Nearby residential areas are located within a feasible cycle journey time and distance from the site. Furthermore, cycle access to the site benefits from a combination of segregated and non-segregated cycle lanes running alongside the R526 east of the Raheen Business Park roundabout, which is easily accessible from the Business Park . There For are inspection no cycle purposes lanes only. on the R526 to the west of the Raheen Business Park roundabout and cycleConsent access of copyright on this owner section required for and any otherwithin use. Raheen Business Park is all on- road. 13.1.3 PUBLIC TRANSPORT 13.1.3.1 Bus Provision There are a total of two bus stops within the vicinity of the site which provide direct services between Limerick City Centre and Raheen Business Park. 13.1.3.2 Rail The nearest railway station is Limerick Colbert which is located within Limerick City Centre, over 5 kilometres north-east of the development site. by Environmental Impact Services 116 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation 13.2 THE PROPOSED DEVELOPMENT The proposed development consists of a proposed plant expansion, with a view to catering for additional staff bringing the total to 800 plus contract support personnel e.g. kitchen and cleaning, etc). The proposed development, which is located within Raheen Business Park, is currently accessed from the following two junctions: Raheen Gardens arm of Raheen Business Park Roundabout; and Ballycummin Avenue arm of the Ballycummin Roundabout. The Ballycummin Avenue access is accessible from the M20 in the south and the R526 in the north. 13.2.1 CONSTRUCTION PHASE The construction programme for the new development will have a duration of approximately 22 months (88 weeks) and assessment of the impacts of construction phase vehicles is based on daily traffic movements above the baseline level. It is predicted, during the peak month of construction, that 500 contractors on-site will generate approximately 813 daily construction trips, above the baseline level. Construction is expected to begin at the end of 2018 and be completed in 2020. Construction traffic distribution will be managed through a Construction Traffic Management Plan, however for the purposes of this assessment, construction traffic distribution has been based on existing turning movements in the same way as was undertaken in support of the 2013 Regeneron development. It is proposed that construction staff will park within the new temporary contractor car park and new adjoining staff car park, both of which are accessed via the main western site access junction. These car parks accommodate 500 parking spaces which can comfortably accommodate the peak levels of construction traffic associated with the proposed development. 13.2.2 OPERATIONAL PHASE A year of opening of 2021 is forecast and during the operational phase of the proposed development, 366 daily trips are forecast to be generated For inspection by purposes the only.150 additional staff expected on-site. The operational traffic is predicted toConsent route of copyright through owner required the localfor any other road use. network in line with existing distributions, derived from junction turning count data. It is proposed that 150 new car parking spaces will be provided as part of the development proposals to accommodate the additional staff that the proposals will generate. This provision is on top of the 685 spaces already in place for existing staff. In all, once the proposed development becomes operational, a total parking provision of 835 spaces will be in place to accommodate 800 staff plus contract support personnel which is appropriate for the needs of the Regeneron site. 13.3 THE RECEIVING ENVIRONMENT The month of September is considered to be a neutral month in terms of traffic as schools re-open after the summer break, with traffic considered to be operating under typical conditions. The days between Tuesday and Thursday are considered as normal workday since Monday and Friday are observed to have a skewed traffic behaviour. The survey was conducted on a Tuesday and therefore within normal workday range. Both roundabouts have slip roads and traffic on these slip roads were also considered carefully. by Environmental Impact Services 117 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation Traffic growth for the surrounding road network is based on the medium growth rates for Mid-West obtained from Project Appraisal Guidelines, Table 5.3.2: Link-Based Growth Rates: Annual Growth Factors. High growth rates have been applied to the base flows for the following scenarios: Baseline (2017); Construction (2020) A potential opening year (2021); and Opening year + 5 (2026); and Opening year + 15 (2036). Applied growth rates are shown in Table 13.1Table 13.1 below: Table 13.1: Annual Average Growth Rates for Mid-West region High Growth for Light High Growth for Heavy Years Good Vehicles Goods Vehicles 2013 – 2030 1.0112 1.0242 2030 – 2050 1.0010 1.0165 13.3.1 BASELINE AND CONSTRUCTION START (2017) The baseline that is utilised in the assessment has been established from observed traffic counts, as detailed above. The baseline (2-way) AADT flows for 2017 are detailed in the Table 13.2Table 13.2 below which provides a sound basis upon which to assess the future impacts of construction. Table 13.2: Baseline (2-way) AADT 2017 Junction Link AADT HGV %HGV Ballycummin R510 7017 207 2.9% Roundabout Raheen Business Park Access 7876 391 5.0% M20 Link 10605 486 4.6% Raheen R526 North 17240 376 2.2% Roundabout Raheen Business Park Access 3991 134 3.4% R526 South 9373 229 2.4% R510 West For inspection purposes only. 9661 255 2.6% Consent of copyright owner required for any other use. 13.3.2 OPENING YEAR (2021) It has been assumed that operational traffic will route through the local traffic network via a variety of routes, in line with current traffic distribution observed at the site. These routes are detailed below in Table 13.3Table 13.3. As traffic survey data is for 2017, and the opening assessment year is 2021, the observed traffic counts were factored in line with factors in Table 13.1Table 13.1. Table 13.3: Projected (2-way) AADT 2021 Junction Link AADT HGV %HGV Ballycummin R510 7398 227 3.1% Roundabout Raheen Business Park Access 8459 429 5.1% M20 Link 11257 533 4.7% Raheen R526 North 18112 413 2.3% Roundabout Raheen Business Park Access 4373 147 3.4% R526 South 9829 251 2.6% R510 West 10194 279 2.7% by Environmental Impact Services 118 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation 13.3.3 OPENING YEAR + 5 (2026) The forecast 2026 Design Year (Opening Year + 5) AADT levels are detailed in the Table 13.4Table 13.4 below: Table 13.4: Projected (2-way) AADT 2026 Junction Link AADT HGV %HGV Ballycummin R510 7803 252 3.2% Roundabout Raheen Business Park Access 8924 476 5.3% M20 Link 11880 592 5.0% Raheen R526 North 19098 456 2.4% Roundabout Raheen Business Park Access 4604 163 3.5% R526 South 10367 279 2.7% R510 West 10749 310 2.9% 13.3.4 OPENING YEAR + 15 (2036) The forecast 2036 Design Year (Opening Year + 15) AADT levels are detailed in the Table 13.5Table 13.5 below: Table 13.5: Projected (2-way) AADT 2036 Junction Link AADT HGV %HGV Ballycummin R510 8188 292 3.6% Roundabout Raheen Business Park Access 9379 553 5.9% M20 Link 12487 687 5.5% Raheen R526 North 20025 532 2.7% Roundabout Raheen Business Park Access 4826 190 3.9% R526 South 10874 324 3.0% R510 West 11275 360 3.2% 13.4 PREDICTED IMPACTS In terms of the transport review, the effects that may result from an increase in traffic volume For inspection purposes only. without mitigation measures may include:Consent of copyright owner required for any other use. Congestion; Air pollution; Journey delays; and Reduction in safety levels. The most discernible environmental effects of traffic may be noise, severance, pedestrian delay and intimidation. The effects of noise are detailed within the Section 10 of this EIAR Noise & Vibration. Pedestrian delay and intimidation relate to the impact on pedestrian movement and the perceived difficulty and discomfort in crossing a road. Severance, which is the perception of communities and facilities being divided by a road, is not predicted to be an environmental effect given the existing road network in the vicinity of the site. Air pollution effects are addressed along with effects of greenhouse gas emissions in Section 9 Air Quality & Climate. The traffic volumes forecast during each phase (during construction and post construction) of the proposed development are described below. 13.4.1 CONSTRUCTION PHASE – DEVELOPMENT IMPACT This scenario identifies and assesses the impact of the proposed daily construction traffic on the baseline traffic levels on the links and volumes detailed in Table 13.2Table 13.2. The TTA has assessed the impact of the proposed development on key junctions on the local road network. The by Environmental Impact Services 119 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation TTA, which should be read in conjunction with this chapter, considers the operation of these junctions for all assessment scenarios and provides commentary on any capacity, queuing or delay issues. The overall construction period duration for the proposed development is estimated to be approximately 22 months (88 weeks) and the construction traffic impact will be temporary for this duration. Details on the predicted traffic levels during the peak hours are summarised below. During construction, potential impacts may include: - Increased vehicles movements associated with construction staff and management travelling to / from the site; Increased vehicle movements consisting of HGVs and construction plant that may result in traffic congestion on roads; Increased queuing and congestion; Increased conflict between pedestrians / cyclists and vehicle traffic; and Severance of pedestrian and cycle routes. In addition to the aforementioned temporary impacts, there is the potential for impacts on air quality, noise and vibration to occur as a result of construction traffic. These potential impacts and any associated mitigation measures are considered separately within the relevant sections. Table 13.6Table 13.6 details a comparison of the forecast construction traffic levels against baseline traffic levels. Table 13.6: Traffic Increase Associated with the Development Construction AADT (2-way) Baseline Traffic Increase Baseline Traffic + Regeneron (% of Junction Link Flows 2017 Construction Baseline) Traffic 2020 AADT HGVs AADT HGVs AADT HGVs Ballycummin R510 7017 207 7387 222 5.27% 7.25% Roundabout Raheen Business Park 391 7876 8624 419 9.5% 7.16% Access M20 Link 10605 486 11320 521 6.74% 7.2% Raheen R526 North 17240 376 18016 404 4.5% 7.45% Roundabout Raheen Business Park For inspection purposes134 only. Consent of copyright3991 owner required for any other4568 use. 144 14.46% 7.46% Access R526 South 9373 229 9754 246 4.06% 7.42% R510 West 9661 255 10191 273 5.49% 7.06% During the busiest day of construction, the anticipated increases in trips on M20 Link Road represents an additional 715 two-way vehicles over the course of an entire day. This equates to a worst case percentage increase of 6.74%, 7.2% (HGV) respectively on the Ballycummin Avenue south of the roundabout. As such, the impact of the construction phase is therefore considered negligible, with no need for any mitigation measures other than a Construction Traffic Management Plan. 13.4.2 POST CONSTRUCTION PHASE – DEVELOPMENT IMPACT Following completion of the proposed development, the construction trips will be removed from the network. These will be replaced, however, by trips associated with permanent staff, over and above the current traffic baseline level. The impact of these trips against the opening year baseline (2021), opening years + 5 years (2026) and opening years +15 years’ baseline (2036) are detailed in Table 13.7Table 13.7 to Table 13.9Table 13.9 below. by Environmental Impact Services 120 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation Table 13.7: Traffic Increase against 2021 Opening Year Baseline AADT (2-way) Baseline Traffic Increase Baseline Traffic + Regeneron (% of Junction Link Flows 2021 Operational Baseline) Traffic AADT HGVs AADT HGVs AADT HGVs Ballycummin R510 0 227 7398 227 0.78% 0.0% Roundabout Raheen Business Park 8248 429 8459 429 0.0% Access 2.56% M20 Link 11104 533 11257 533 1.38% 0.0% Raheen R526 North 18029 413 18112 413 0.46% 0.0% Roundabout Raheen Business Park 4176 147 4373 147 0.0% Access 4.72% R526 South 9803 251 9829 251 0.27% 0.0% R510 West 10106 279 10194 279 0.87% 0.0% Table 13.8: Traffic Increase against 2021 Opening Year + 5 Baseline AADT (2-way) Baseline Traffic Increase Baseline Traffic + Regeneron (% of Junction Link Flows 2026 Operational Baseline) Traffic AADT HGVs AADT HGVs AADT HGVs Ballycummin R510 7746 252 7803 252 0.74% 0.0% Roundabout Raheen Business Park 8713 476 8924 476 0.0% Access 2.42% M20 Link 11727 592 11880 592 1.30% 0.0% Raheen R526 North 19015 458 19098 458 0.44% 0.0% Roundabout Raheen Business Park 4407 163 4604 163 0.0% Access 4.47% R526 South 10341 279 10367 279 0.25% 0.0% R510 West 10661 310 10749 310 0.83% 0.0% Table 13.9: Traffic Increase against 2021 Opening Year + 15 Baseline AADT (2-way) For inspection purposes only. Consent of copyright owner required for any otherBaseline use. Traffic Increase Baseline Traffic + Regeneron (% of Junction Link Flows 2036 Operational Baseline) Traffic AADT HGVs AADT HGVs AADT HGVs Ballycummin R510 8130 292 8188 292 0.71% 0.0% Roundabout Raheen Business Park 9168 553 9379 553 0.0% Access 2.30% M20 Link 12334 687 12487 687 1.24% 0.0% Raheen R526 North 19942 532 20025 532 0.42% 0.0% Roundabout Raheen Business Park 4628 190 4826 190 0.0% Access 4.28% R526 South 10848 324 10874 324 0.24% 0.0% R510 West 11187 360 11275 360 0.79% 0.0% by Environmental Impact Services 121 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation The main traffic impact in 2021, 2026 and 2036 is forecast on the Raheen Business Park Access (from the Raheen roundabout), although this represents a negligible increase given that the road is currently operating comfortably within capacity. Furthermore, the road network within Raheen Business Park has been designed to accommodate the level of development associated with the proposed development and other developments. Also, as the traffic distributes through the traffic network the impact decreases and the overall impact is considered negligible. 13.5 MITIGATION MEASURES It is considered that the predicted increases in network traffic as a result of construction and operational development will be of negligible impact and therefore no intervention or physical mitigation is required. Notwithstanding this, the Construction Traffic Management Plan will mitigate traffic impact through: Programming deliveries outside of peak periods; and Ensuring construction vehicles route to site via agreed routes. The more detailed aspects of the Construction Management Plan will be agreed in consultation with Limerick City & County Council. For the operational phase, a Mobility Management Plan will be adopted, with the aim of reducing vehicular traffic and promoting sustainable modes. A Mobility Management Plan has also been submitted as part of the planning application. The objectives are: To improve travel options; To improve awareness of the sustainable modes of travel that is available; To minimise the need to use private vehicles; and To promote health and environmental benefits of sustainable travel. A Mobility Management Plan can also: Assist in increasing accessibility while reducing congestion; Improve local air pollution, greenhouse gases and noise; Increase business efficiency and equality; Reduce the carbon footprint of the organisation/development; Reduce the traffic impact on the local highway network; Reduce adverse impacts on local residents and businesses; and Improve the health and wellbeing of the workforce through the formation of active travel patterns. For inspection purposes only. Consent of copyright owner required for any other use. Some of the measures to be promoted within the Mobility Management Plan include the following, however the Mobility Management Plan should be read in conjunction with this chapter: Walking & Cycling Review cycleways and footpaths in the immediate vicinity of the site to assess surfacing, lighting, safety etc. Inform the relevant local authorities of any instances of poor pedestrian and cyclist infrastructure; Review and seek to upgrade any internal footpaths that are poorly maintained, including for appropriate crossing points and street lighting; Review existing cycle space provision, location and safety. Cycle parking provision should be increased within the site as interim targets are met; and Review quality and quantity of existing changing and shower facilities within the Regeneron site and seek to improve on where required. by Environmental Impact Services 122 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Traffic & Transportation Public Transport Promotion of local bus services to all staff, contractors and visitors; Ensure that any new bus services or bus infrastructure proposed in the vicinity of site is suitable for Regeneron users, considering aspects such as user disabilities, timetabling and staff home locations; and Liaison with local authorities and public transport operators to examine opportunities to re- route services in order to better serve Regeneron staff, contractors and visitors. Promotion of sustainable and active travel Provision of a Travel Options Leaflet for the site, available in hard and electronic formats; Provide and promote an on-site Green Travel Day; Promote the staff Cycle to Work scheme, while ensuring the process is as efficient as possible in terms of administration; and Provision of an on-site emergency cycle repair kit and schedule visits from the ‘Bike Doctor’. Promotion of smarter working measures Review staff travel policy to include criteria to encourage tele-video conferencing use; and Provide training for tele-video-conferencing facility use. A Mobility Management Plan is a continuous and evolving document requiring monitoring, review and revision to ensure that it remains relevant to all users of the site. The Mobility Management Plan contains more details on the requirement for the appointment of a Mobility Management Plan co- ordinator, to deal with promotion, engagement and monitoring of the effectiveness of the implemented measures. Baseline staff surveys will be carried out within 6 months of the opening of the development. Travel surveys will subsequently be undertaken bi-annually. These will be carried out in order to monitor the impact of the Mobility Management Plan and to establish how successful it has been in inducing modal shift. The measures implemented will be reviewed so that they can be adjusted and new measures introduced, where necessary. Monitoring reports will be submitted to Limerick City & County Council at an agreed frequency and these reports and revised versions of the Mobility Management Plan can be made available as required. On-going monitoring will take place via the Mobility Management Plan Coordinator who will collect any feedback and suggestions from For inspectionusers at purposes site only.about the Mobility Management Plan and its measures. Consent of copyright owner required for any other use. 13.6 RESIDUAL IMPACTS 13.6.1 CONSTRUCTION Considering that the nature of traffic increase will be short term, the mitigation measures outlined previously will ensure that there will be no significant residual impacts. A summary justification is as follows: a Construction Traffic Management Plan will minimise, as far as practicable, traffic impacts during construction; the maximum traffic increases as a result of construction related traffic will be temporary; and the environmental effects identified previously will be managed through the mitigation measures outlined above, thus ensuring the impacts are not significant. 13.6.2 OPERATION The mitigation measures outlined previously will ensure that there will be no significant residual impacts. A summary justification is as follows: a Mobility Management Plan will be implemented which will reduce vehicular traffic and promote sustainable modes. by Environmental Impact Services 123 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management 14 WASTE MANAGEMENT 14.1 INTRODUCTION / METHODOLOGY This section of the EIAR has been prepared to address the potential impacts associated with waste management during the construction and operational phases of the proposed development. The assessment has been conducted in the context of current relevant standards and guidance as described in Section 1 Introduction and identified any requirements or possibilities for mitigation. The assessment of the impacts of the proposed development arising from the consumption of resources and the generation of waste materials, was carried out taking into account the methodology specified in relevant guidance documents; the Draft Advices Notes for Preparing Environmental Impact Statements (EPA, Sept 2015) and in accordance with the Draft Guidelines on the Information to be contained in Environmental Impact Assessment Reports (EPA, August 2017), along with an extensive document review to assist in identifying current and future requirements for waste management including national and regional waste policy, waste strategies, management plans, Directives and relevant reports. This section is based on the project description, as described in Section 4 Project Description and considers the following aspects: The legislative context; The construction phase (including excavations); and The operational phase. A desk study was carried out which includes the following tasks: Review of applicable policy and legislation which creates the legal framework for resource and waste management in Ireland; Description of the typical waste materials that will be generated during the construction and operational phases; and Identification of mitigation measures to prevent waste generation and promote management of waste in accordance with the waste hierarchy. For inspection purposes only. Consent of copyright owner required for any other use. Estimates of waste generation during the construction and operational phase of the project have been calculated. The waste types and estimated quantities are based on published data by the EPA in National Waste Reports72, data recorded from similar previous developments, Irish and US EPA73 waste generation research and other available research. Mitigation measures are proposed to minimise the effect of the proposed development on the environment during the construction and operational phases, to promote efficient waste segregation and to reduce the quantity of waste requiring final disposal. This information is presented in section 14.5. A detailed review of the existing ground conditions on a regional, local and site specific scale are presented in Section 7 Land, Soils, Geology and Hydrogeology. This Section of the EIAR also discusses the environmental quality of soils which will have to be excavated to facilitate construction of the proposed development. The direct and indirect effects of waste related transport are considered in Section 13 Traffic and Transportation. 72 Environmental Protection Agency (EPA), National Waste Database Reports 1998 – 2012. 73 US EPA, Characterisation of Building Related Construction and Demolition Debris in the United States (Online - Accessed 30 August 2017). by Environmental Impact Services 124 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management 14.1.1 LEGISLATION AND GUIDANCE Waste management in Ireland is subject to EU, national and regional waste legislation which defines how waste materials must be managed, transported and treated. The overarching EU legislation is the Waste Framework Directive (2008/98/EC) which is transposed into national legislation in Ireland. The cornerstone of Irish waste legislation is the Waste Management Act 1996 (as amended). In addition, the Irish government issues regular policy documents which outline measures aimed to improve waste management practices in Ireland and help the country to achieve EU targets in respect of recycling and disposal of waste. The most recent policy document A Resource Opportunity – Waste Management Policy in Ireland74 was published in 2012 and stresses the environmental and economic benefits of better waste management, particularly in relation to waste prevention. The strategy for the management of waste from the construction phase is carried out in line with the requirements of the Best Practice Guidelines for the Preparation of Waste Management Plans for Construction and Demolition Projects75 published in 2006. The guidance document Construction and Demolition Waste Management: A handbook for Contractors and Site Managers 76 was also consulted in the preparation of this assessment. There are currently no Irish guidelines on the assessment of operational waste generation and guidance is taken from industry guidelines, British Standards and other relevant studies and reports. 14.2 THE PROPOSED DEVELOPMENT The proposed development is outlined in Section 4 Project Description. With regard to waste management, the proposed development will generate waste during the construction phase and when the new building is operational. 14.2.1 CONSTRUCTION PHASE A Construction & Demolition (C&D) Waste Management Plan (WMP) has been prepared for the proposed works and is included as Appendix 14.1. Excavation works will involve the removal of an asphalt hardstanding area of approximately 12,707m2, which equates to approximately 432 tonnes of asphalt (assuming a waste asphalt density of 0.68 tonne/m3). For inspection purposes only. Consent of copyright owner required for any other use. Subsoil will be excavated during the construction phase to facilitate construction of the new development foundations and underground services. It has been estimated that approximately 20,000m3 of subsoil will be required to be excavated (approximately equivalent to 35,000 tonnes based on an average density of 1.75 tonnes per m3) Based on the site investigation data from the 2013 EIS, it is assumed that some rock will be required to be excavated to facilitate construction of the proposed development. Results of environmental soil analysis conducted as part of the Site Investigation for the works in 2013 showed there was no contamination of the soil in the area of the proposed development. Regardless of these results, a watching brief and discovery procedure for contaminated material will be prepared and adopted by the contractor prior to excavation works commencing on site. In the event that any potentially contaminated material is encountered, it will be segregated from clean/inert material, tested and classified as non-hazardous or hazardous using the HazWasteOnline 74 Department of the Environment, Community and Local Government (DoECLG), A Resource Opportunity – Waste Management Policy in Ireland (2012) 75 National Construction and Demolition Waste Council (NCDWC) and Department of the Envrionment, Heritage and Local Government (DoEHLG), Best Practice Guidelines on the Preparation of Waste Management Plans for Construction and Demolition Projects (2006) 76 FÁS and the Construction Industry Federation (CIF), Construction and Demolition Waste Management – a handbook for Contractors and Site Managers (2002) by Environmental Impact Services 125 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management application (or similar approved method), and then classified as inert, non-hazardous or hazardous in accordance with the European Communities (EC) Council Decision 2003/33/EC, which establishes criteria for the acceptance of waste at landfills. It is expected that throughout the construction phase, waste will be produced from surplus materials such as broken or off-cuts of timber, plasterboard, concrete, tiles, bricks, etc. Waste from packaging (cardboard, plastic, timber) and oversupply of materials may also be generated. The contractor will be required to ensure that oversupply of materials is kept to a minimum and opportunities for reuse of suitable materials are maximised. If the material is deemed to be a waste, removal and reuse/recycling/recovery/disposal of the material will be carried out in accordance with the Waste Management Act 1996 (as amended), the Waste Management (Collection Permit) Regulations 2007 (as amended) and the Waste Management (Facility Permit & Registration) Regulations 2007 (as amended). The volume of waste requiring recovery/disposal will dictate whether a Certificate of Registration (COR), permit or licence is required by the receiving facility. The estimated construction waste amounts (as detailed in Table 4.2 of the C&DWMP included as Appendix 14.1) are presented in Table 14.1 below. Table 14.1 Estimated on- and off-site reuse, recycling and disposal rates for construction waste Reuse Recycle Disposal Waste Type Tonnes % Tonnes % Tonnes % Tonnes Mixed C&D 126 10 13 80 101 10 13 Timber 107 40 43 55 59 5 5 Plasterboard 38 30 11 60 23 10 4 Metals 30 5 2 90 27 5 2 Concrete 23 30 7 65 15 5 1 Other 57 20 11 60 34 20 11 Total 381 87 259 36 For inspection purposes only. It should be noted that until finalConsent materials of copyright and owner detailedrequired for any construction other use. methodologies have been confirmed, it is difficult to predict with complete accuracy the construction waste that will be generated from the proposed works as the exact materials and quantities may be subject to some degree of change and variation during the construction process. Waste materials generated will be segregated on site, where it is practical. Where the on-site segregation of certain waste types is not practical, off-site segregation will be carried out. Non- hazardous waste will be placed in suitably sized and labelled receptacles, located in proximity to the area of waste generation. When full the receptacles will be transferred to a dedicated waste storage area (WSA) in the construction compound and the waste placed in the appropriate, suitably sized skips or, in the case of Waste Electrical and Electronic Equipment (WEEE), cages. Hazardous waste will be placed into labelled bins and transported to a designated hazardous WSA to be placed in suitable receptacles, drums or UN approved boxes as appropriate. All waste receptacles leaving the site will be covered or enclosed and transported off site by an approved waste contractor holding a current waste collection permit. All waste will be brought to facilities holding the appropriate Certificate of Registration (COR), waste permit or waste/IED licence, as required. by Environmental Impact Services 126 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management 14.2.2 OPERATIONAL PHASE The proposed development will give rise to a variety of waste streams when the project is completed and manufacturing processes are operational. The waste will be generated from process and non- process related activities. The processes in the new production building are expected to generate similar waste types to the current manufacturing activities and can be broken down into two main types: hazardous and non- hazardous waste. The multipurpose manufacturing building is designed for the phased construction of manufacturing suites and the formulation of bulk medicines according to needs. The proposed development will include the construction of a new waste handling facility (c. 626 m2) with provision for IBC storage, waste compactors, skip storage, chemical storage and dry recyclable baling equipment. Process related waste that will be generated from the manufacturing activities will include: Single use mixer bags; Single use bioreactor bags and rocker bags; Storage bags; Drum liners; Tubes and hoses; Packaging elements; Filters; Vials, bottles and flasks; Support implements e.g. spatulas, probes, funnels; and Wastewater treatment sludge. The types of non-hazardous, non-process waste anticipated to be generated on site will include: Paper (confidential and non-confidential) Cardboard Plastic For inspection purposes only. Glass Consent of copyright owner required for any other use. Metal Compostable food waste Empty printer toner cartridges Waste batteries (non-hazardous) WEEE (non-hazardous) Mixed non-recyclable waste Non-hazardous waste will be segregated for recycling/recovery/disposal and dedicated bins for segregated waste will be located throughout the facility. Other non-hazardous wastes that will be generated on site in smaller quantities on an infrequent basis are likely to include textiles (rags), furniture and landscaping wastes. Typical non-process hazardous waste generated in this type of setting usually consists of hazardous batteries, WEEE, fluorescent light tubes, cleaning products and paints. Hazardous waste will be segregated at source and will be packaged, labelled and transferred to the designated waste storage area (WSA) by Regeneron facilities personnel. The management of waste during the operational phase will continue in accordance with the existing procedures in place at the facility and in accordance with the requirements of Regeneron’s IED Licence (Licence Reg. No. P0991-01). Waste management companies, as authorised by Regeneron, will be responsible for the transfer of waste off-site to authorised recovery/disposal facilities. by Environmental Impact Services 127 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management The estimated waste quantities to be generated on an annual basis at the proposed facility are detailed in Table 14.Table 14.2. Table 14.2 Current and estimated future annual waste streams for Regeneron facility Process Waste Type Quantity (tonnes/year) Current Future Hazardous 144.9 192.7 Non-Hazardous: 364.0 484.1 Total 508.9 676.8 The Regeneron Environmental Health and Safety (EHS) Department will be responsible for overseeing the implementation of waste management procedures during the operational phase. The EHS department will also ensure that all waste contractors used by the facility and all recovery/disposal outlets, are suitable for use, appropriately authorised and audited, as required. 14.3 THE RECEIVING ENVIRONMENT In terms of waste management, the baseline environment is largely defined by Limerick City and County Council (LCC) - as the local authority responsible for administering waste management activities in the area in which the proposed development is located. The Southern Region Waste Management Plan 2015 – 2021 77 is the current regional waste management plan for the LCC area. The Regional Plan sets out the strategic targets for waste management in the region but does not set a specific target for C&D waste. However, the Waste Framework Directive sets Member States a target of “70% preparing for reuse, recycling and other recovery of construction and demolition waste” (excluding natural soils and stones and hazardous wastes) to be achieved by 2020. Municipal landfill charges in Ireland are based on the weight of waste disposed. Landfill charges in the region are approximately €120 per tonne of waste which includes a €75 per tonne landfill levy introduced under the Waste Management (Landfill Levy) (Amendment) Regulations 2015. The Limerick County Development Plan 2010 – 2016 78 (extended) contains several objectives in relation to waste management. The waste objectives most relevant to this development are as follows: For inspection purposes only. Consent of copyright owner required for any other use. IN O41: Regional Waste Management Plan It is the objective of the Council to implement the provisions of the Waste Management Hierarchy and the Regional Waste Management Plan 2006-2011, and any subsequent review of this Waste Management Plan as it applies to this Council area. All prospective developments in the County will be expected to take account of the provisions of the Regional Waste Management Plan and adhere to those elements of it that relate to waste prevention and minimisation, waste recycling facilities, and the capacity for source-segregation. IN O42: Education and Awareness It is the objective of the Council to promote education and awareness on all issues associated with waste management, both at industry and community level. This will include the promotion of waste reduction by encouraging the minimisation, re-use, recycling and recovery of waste within the County. IN O45: Proposed waste disposal 77 Southern Waste Region, Southern Region Waste Management Plan 2015 – 2021 (2015) 78 Limerick City and County Council (LCC), Limerick County Development Plan 2010 – 2016 (Extended), (2010) by Environmental Impact Services 128 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management It is the objective of the Council in assessing planning applications to have regard to the waste produced by proposed developments including the nature and amount produced and proposed method of disposal. Developments should ensure that production/disposal methods do not give rise to environmental pollution, result in undue loss of amenity or be detrimental to public health. IN O46: Construction Demolition Waste It is the objective of the Council to ensure that all significant construction/demolition projects include construction and demolition waste management plans. These plans should seek to focus on waste minimisation in general and optimise waste prevention, re-use and recycling opportunities and are required for developments of five or more housing units or commercial or industrial developments on sites in excess of 0.5 hectares 14.4 PREDICTED IMPACTS This section details the predicted waste impacts associated with the proposed development for both construction and operational phases. 14.4.1 CONSTRUCTION PHASE The construction phase of the project will generate a range of non-hazardous and hazardous waste materials. Correct segregation, storage, handling and transport of waste will ensure litter is not generated at the existing Regeneron facility or neighbouring areas and does not become a nuisance to the public. Construction activities will inevitably generate quantities of waste where materials are oversupplied, incorrect materials delivered or materials are cut to size on-site. General housekeeping and excess packaging will also generate waste materials as well as typical municipal wastes generated by construction employees including food waste. The use of permitted waste hauliers and permitted/licensed facilities will ensure appropriate management of waste and avoidance of off-site environmental impacts/pollution. Compliance with regional and national legislation as outlined previously and the allocation of adequate time and resources dedicated to ensuring efficient waste management practices as outlined in the attached C&DWMP (Appendix 14.1) will ensure that adverse impacts are avoided. As the project progresses, waste materials will be required to be temporarily stored on site pending collection by a waste contractor. Dedicated For inspection areas purposesfor waste only. skips and bins will need to be identified across the site and will be temporarilyConsent storedof copyright in owner the requiredconstruction for any other compound use. pending collection. This area will need to be easily accessible to waste collection vehicles as it is anticipated that waste will need to be collected on a near-daily basis during peak construction. Subsoils will be excavated to facilitate the construction of the new building foundations, services and access routes. Results of site investigations undertaken indicate there is no evidence of contamination of the soil to be excavated. In the event that localised contamination is encountered, material will be correctly identified, segregated and classified to ensure there is no negative impact to workers as well as water and soil environments, both on and off site. With the necessary measures in place to mitigate the waste impacts of the proposed development as outlined above and in Section 14.5, the impacts on the environment are expected to be neutral, short-term and imperceptible. Implementation of the C&DWMP will ensure that the target recycling rate of 70% (outlined in the Waste Framework Directive and the Southern Region Waste Management Plan 2015 - 2021) can be achieved. by Environmental Impact Services 129 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management 14.4.2 OPERATIONAL PHASE Waste management during the operational phase of the proposed development will follow the priorities of the waste hierarchy and avoid significant volumes of waste being sent unnecessarily to landfill. The requirements of the Limerick County Development Plan 2010 – 2016 (extended), and the objectives outlined in the Southern Region Waste Management Plan 2015 – 2021 will also be followed. The use of permitted/licensed waste hauliers and facilities will ensure appropriate management of waste and will avoid environmental impacts or pollution. In addition, the correct management and storage of waste will avoid litter or pollution issues at the facility and at adjacent Raheen Business Park properties. Appropriate litter control reduces the likelihood of the presence of vermin within the overall site and surrounding areas. Conversely, incorrect management of waste materials at the proposed development may have a knock-on effect on operations at the facility and a negative impact on manufacturing processes and production. The management of waste materials during the operational phase will be carried out in accordance with existing waste management procedures and the requirements of the facility IED Licence (Licence Re. P0991-01). Existing arrangements for waste collection and recording will be maintained and amended as required to account for the new development. There will not be a significant cumulative impact from the production of waste material in the new building with wastes currently generated in the existing Regeneron facility as there is an established network for hazardous and non-hazardous waste management in the region and there is sufficient capacity to manage the additional waste volumes estimated. 14.5 MITIGATION MEASURES This section outlines the measures that will be employed in order to reduce the amount of waste produced at the development, manage the For inspectionwastes purposes generated only. responsibly and minimise the effects of the waste that is generated on the Consentenvironment. of copyright owner required for any other use. 14.5.1 CONSTRUCTION PHASE As stated earlier, a project specific C&DWMP has been prepared to deal with waste generation during the excavation and construction phases of the project and is included as Appendix 14.1. The C&DWMP will be employed to ensure effective waste management and reuse, recycling, recovery and disposal of waste material generated at the site. Mitigation measures aimed to increase the efficiency of waste management during the construction phase of the development include: Building materials should be chosen with an aim to ‘design out waste’; A watching brief and discovery procedure for contaminated material will be prepared and adopted by the contractor prior to excavation works commencing on site; All wastes will be segregated at source, where possible; All waste materials will be stored in skips or other suitable receptacles in designated areas of the site and/or construction compound; and Left over materials (e.g. timber off-cuts) and any suitable construction materials shall be reused on-site where possible. by Environmental Impact Services 130 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management All excavated material is intended to be taken off-site. Prior to removal of material from site, any nearby sites requiring clean fill material will be contacted to investigate reuse opportunities for clean and inert material. If any of the material is to be reused on another site as by-product (and not as a waste), this will be done in accordance with Article 27 of the EC (Waste Directive) Regulations (2011) as detailed in the C&DWMP. 14.5.2 OPERATIONAL PHASE Existing operational waste management procedures at the facility will be amended to ensure that waste generated from operations at the new development will be managed appropriately, efficiently and in compliance with the relevant legislation. Mitigation measures will include: Adoption of source segregation procedures for operational waste and amending the existing Regeneron procedures to allow for activities in the new waste handling facility; Deactivation of all biowaste to reduce impact on the wastewater treatment system and municipal network – new biowaste inactivation area will be provided in the proposed building; Storage of the main waste materials in appropriately labelled bins or other suitable receptacles in the designated WSAs. Bins will be clearly identified with the approved waste type to ensure there is no cross contamination of waste materials; and Installation of compaction and baling equipment to minimise waste volumes and increase efficiency of collections for non-hazardous wastes. 14.6 RESIDUAL IMPACTS The implementation of the mitigation measures outlined in Section 14.5 will ensure that a high rate of reuse, recovery and recycling is achieved at the development during the construction phase as well as during the operational phase. It will also ensure that European, national and regional legislative requirements with regard to waste are met and that associated targets for the management of waste are achieved. Primarily, implementation of the waste management plan during the construction phase and adherence to existing operational waste management procedures during the operational phase will minimise the volume of waste generated and also requiring disposal at landfill. For inspection purposes only. Consent of copyright owner required for any other use. 14.6.1 CONSTRUCTION PHASE A carefully planned approach to waste management and adherence to the C&DWMP during the construction phase will ensure that the impact on the environment will be neutral, short-term and imperceptible. The objective of setting targets for waste management is only achieved if the actual waste generation volumes are calculated and compared. This is particularly important during the construction phase where there is a potential for waste management to become secondary to progress and meeting construction schedule targets. The C&DWMP specifies the need for a waste manager to be appointed who will have responsibility to monitor the actual waste volumes being generated and to ensure that contractors and sub-contractors are segregating waste, as required. Where targets are not being met, the waste manager should identify the reasons for targets not being achieved and work to resolve any issues. Recording of waste generation during the project will enable better management of waste contractor requirements and identify trends. The data should be maintained to advise on future projects. by Environmental Impact Services 131 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Waste Management 14.6.2 OPERATIONAL PHASE During the operational phase, implementation of Regeneron’s existing waste management procedures will ensure that all waste materials are segregated and collected from the facility with no residual impact on the environment. During the operational phase, facility management personnel should monitor waste generation volumes against the predicted waste volumes outlined in Table 14.Table 14.2. A structured approach to waste management will promote resource efficiency and waste minimisation. Provided the mitigation measures are implemented and a high rate of reuse, recycling and recovery is achieved, the predicted impact of the operational phase on the environment will be neutral, long-term and imperceptible. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 132 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage 15 ARCHAEOLOGY & ARCHITECTURAL HERITAGE 15.1 INTRODUCTION The proposed development is located within the existing Regeneron complex on lands that have largely been previously disturbed. The project includes the following elements associated with groundworks - the construction of the new extension and associated infrastructure within the existing site and the construction of the temporary contractors compound and a car park extension on greenfield areas adjoining the site. The site of the proposed development contains a recorded monument LI013-233 - Fulacht fiadh. Two additional recorded monuments (LI013-229 and LI013-230) both classified as Fulachta fiadh are located just outside the site. The site also contains a protected structure (RPS 1671) recorded within the Limerick City Development Plan and the National Inventory of Architectural Heritage (NIAH), (Reg. No. 21901309), and is described as a detached three-bay one-one-and-half storey Gothic Revival style house, built c. 1830. A number of archaeological assessments have been previously carried out within the proposed development site and include a previous EIS for the Regeneron Facility by Margaret McCarthy, an Archaeological & Architectural Heritage Assessment of adjacent sites within the Raheen Business Park, Ballycummin, County Limerick by IAC in June 2017, and a programme of archaeological testing carried out under Licence No. 99E0116 for the construction of the original facility in 1999. A multi‐stage archaeological investigation took place ahead of the construction of a Dell facility between 1998 and 1999 (Licence No. 98E0433). This involved 4 phases of archaeological assessment: Phase 1 involved archaeological testing of the site. Phase 2 involved the monitoring of groundworks. A Fulacht fiadh was uncovered in Phase 2 during the digging of a trench for a temporary telecom supply to the contractor's compound. The ploughed‐out burnt spread was identified immediately under the sod and was 15‐19m long and 0.1‐0.55 m deep. It is likely that this feature represents the For inspection purposes only. Fulacht fiadh LI013‐233. Consent of copyright owner required for any other use. The Phase 3 construction of the dual carriageway to the factory and an ancillary road, necessitated the removal of portions of a trackway (LI013‐151). Phase 4 comprised the monitoring of the construction of the dual carriageway, ancillary road and associated storm and foul drains during. Four Fulachta fiadh were uncovered and subsequently excavated (Bennett, 1999:483). Archaeological excavations were also undertaken in advance of the construction of the R510 (Licence No. 98E0108). A significant number of pits and postholes were excavated and at least one structure. Artefacts recovered include a spindle whorl, several saddle quern fragments and many sherds of coarse‐ware pottery. It is likely that the features relate to a Bronze Age settlement (Bennett, 1998:382). A site inspection was conducted by the author on Monday 30th August 2017 as part of the development of this EIAR chapter. The field survey revealed that much of the area proposed for development comprises hard standing ground underlain by predominantly made ground. The existing facility consists of a large assembly area, a warehouse and manufacturing support area, a utility building, a two-storey office building, service yards, car parking spaces and an access road linking the site to the R526. The only green areas that appear to be undisturbed by previous ground works are the site of the temporary construction compound located to the rear of Roches Castle. The area for the proposed car park extension appears to have been stripped at some stage in the past after which it reverted to an overgrown field. No surface evidence of any potential archaeological features or by Environmental Impact Services 133 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage deposits were identified. However, despite the developed nature of much of the site, areas that may not have been subject to previous archaeological assessment such as the carpark extension and the temporary contractors compound may still have the potential to contain previously unrecorded archaeological features and deposits. 15.2 METHODOLOGY 15.2.1 DOCUMENTARY SOURCES For the purposes of this report, archaeology, architectural & cultural heritage is considered to include the following elements: Sites listed in the Sites & Monuments Record (SMR) Record of Monuments & Places (RMP) National Monuments Archaeological sites listed on the National Monuments Service website: www.webgis. archaeology.ie/historicenvironment Sites reported in the Excavations Database Any previously unrecorded sites A list of protected monuments. A list of architectural heritage structures (NIAH) A list of protected structures (Limerick County Development Plan 2013-2016) The following sources were consulted in order to identify and map archaeological sites within and adjacent to the proposed development site: Sites and Monuments Record (SMR) and Record of Monuments & Places (RMP) www.archaeology.ie A primary cartographic source and base-line data for the assessment was the consultation of the Sites and Monuments Record (SMR) and Record of Monuments and Places (RMP) for County Limerick (Se Figure 15.2). All known recorded archaeological monuments are indicated on 6inch Ordnance Survey (OS) maps and are listed in this record. The SMR/RMP is not a complete record of all monuments as newly discovered sites may not appear in the list or accompanying maps. In conjunction with the consultation of the SMR and RMP the electronic database of recorded monuments which may be accessed on their website79, was also consulted. For inspection purposes only. National Monuments Consent of copyright owner required for any other use. List of Monuments covered by Preservation Orders and List of National Monuments in the ownership / guardianship of the Minister for Arts, Heritage and the Gaeltacht. National Monuments in the ownership / guardianship of the Minister for Arts, Heritage, Regional, Rural and Gaeltacht Affairs are listed on the Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs website80 Excavations Database81 The excavations database is an annual account of all excavations carried out under license. The database includes excavations from 1970 to present. This database was consulted as part of the desktop research for this assessment to establish if any archaeological excavations had been carried out on or near to the proposed development area. Topographical Files, National Museum of Ireland The topographical files of the National Museum of Ireland contain information pertaining to archaeological finds (mainly artefactual) and excavations in numerous townlands throughout the 79 www.webgis.archaeology.ie/historicenvironment 80 www.archaeology.ie. 81 www.excavations.ie by Environmental Impact Services 134 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage country which were reported to the museum from the 1920s. While many of these find spots are not recorded monuments, they can provide an indication of archaeological activity in a townland and consequently add to the archaeological potential of an area. Cartographic Sources A number of cartographic sources were also consulted as part of the desktop assessment, namely the Down Survey maps of the area (1656-8), the first (1837) and second edition (1909) OS maps and available aerial photography. Architectural Heritage (NIAH)82 The National Inventory of Architectural Heritage was consulted to determine if any protected structures were present within the proposed development site. Site Survey / Walk over Field inspection is necessary to determine the extent and nature of archaeological and historical remains. It can also lead to the identification of previously unrecorded or suspected sites and portable finds through topographical observation and local information. The archaeological and architectural field inspection entailed – The walking over of the development site and its immediate environs. Noting and recording the terrain type and land usage. Noting and recording the presence of features of archaeological, architectural or historical significance. Verifying the extent and condition of any recorded sites. Visually investigating any suspect landscape anomalies to determine the possibility of their being anthropogenic in origin. 15.3 THE PROPOSED DEVELOPMENT A full description of the proposed development is given in Section 4 above. The proposed new facility impacts on three specific areas; the existing plant and site which has already been fully archaeologically investigated; the temporary contractors compound which has not been previously tested and the proposed car-park extension which may have been stripped or disturbed previously but has since reverted to green space . Details For inspection of proposed purposes only. design layout and details can be found in Consent of copyright owner required for any other use. Section 4. 15.4 THE RECEIVING ENVIRONMENT The field survey revealed that much of the area proposed for development comprises hard standing ground underlain by predominantly made ground. The existing facility consists of a large assembly area, a warehouse and manufacturing support area, a utility building, a two storey office building, service yards, car parking spaces and an access road linking the site to the R526. While there are no recorded archaeological monuments within the area of the proposed development, a sufficiently large number of recorded sites are present in the surrounding landscape. These sites provide evidence for extensive late prehistoric and early medieval settlement in the area. The closest upstanding monument of significance is located c.400m east of the facility and is listed in the Record of Monuments and Places for Co. Limerick as a ring fort (LK013-039002). The monument is depicted on the 1st and 2nd edition OS maps as a sub-circular area enclosed by a high bank. It is now inaccessible as it completely overgrown with dense vegetation and scrub. Ringforts are usually known by the names rath or lios and are circular or sub-circular areas enclosed by a single or multiple earthen bank(s) formed of material thrown up from a concentric fosse (ditch) on its outside. Although 82 www.buildingsofireland.ie by Environmental Impact Services 135 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage comparatively few ringforts have been excavated, it is accepted that they had a long period of use, from about 600-900AD. There are seven ancient cooking sites (fulachta fiadh) in the environs of the proposed development, including four (LK013:229-230, LK013:233-234) that were exposed during construction work on the facility in 1999. The remaining three fulachta fiadh (LK013-183, LK013-231 & LK013-235) are clustered together in the townland of Ballycummin to the west of the proposed development. These archaeological features usually survive as small horseshoe-shaped mounds of charcoal-enriched soil packed with fragments of heat-shattered stones. They are often located close to a water source in marshy ground adjacent to springs. Many of the sites have been reduced to level spreads of burnt stones and charcoal through intensive ploughing activity and are often only encountered when topsoil is disturbed. The dating evidence available at present indicates that this site type has a long tradition, spanning from the Early Bronze Age to early historic times, but there appears to be a concentration of sites in the Middle to Late Bronze Age. Their presence is a strong indicator of Bronze Age activity. Previously unknown examples may be encountered beneath the topsoil in the greenfield area located in the southwest corner of the proposed development (proposed car park extension) close to the roundabout where two fulachta fiadh (LK013:229-230) were excavated in 1999. 15.4.1 HISTORICAL AND ARCHAEOLOGICAL BACKGROUND Prehistoric Period Mesolithic Period (6000–4000 BC) Although recent discoveries may push back the date of human activity in Ireland by a number of millennia (Dowd and Carden, 2016)83, the Mesolithic period is the earliest recorded time for which there is clear evidence of prehistoric activity. During this period people hunted, foraged and gathered food and appear to have had a mobile lifestyle. The most common evidence indicative of Mesolithic activity at a site comprises of scatters of worked flint material; a by‐product from the production of flint implements or rubbish middens consisting largely of shells (Stout & Stout, 1997)84. Neolithic Period (4000–2500 BC) During the Neolithic period communities became less mobile and their economy became based on the rearing of stock and cereal cultivation. This transition was accompanied by major social change. Agriculture demanded an altering of the physical landscape. Forests were rapidly cleared and field boundaries constructed. There was a greater concern for territory, which saw the construction of For inspection purposes only. large communal ritual monumentsConsent called of copyrightmegalithic owner requiredtombs, for anythat other are use. characteristic of the period. In Ireland four main types of megalithic tomb have been identified: court‐tombs, portal‐tombs, passage‐ tombs and wedge‐tombs. The first three types are earlier in date (pre‐2000 BC) and are largely confined to the northern half of the country, while wedge‐tombs are slightly later in date and are most numerous in the west and south‐west. There are no recorded megalithic tombs located within the vicinity of the proposed development areas. There is however evidence of Neolithic activity within the wider context of the surrounding landscape. A megalithic tomb (LI012‐099) is located c. 4.7 km to the southwest at Attyflin and a possible Neolithic stone axe was found with a variety of animal bones on the lower part of the estuary foreshore in peats that were dated to the Mesolithic period (O’Sullivan 2001)85. Neolithic settlement, in the form of houses with associated domestic activity, is becoming more common within the archaeological record. Rectangular Neolithic houses have also been excavated at Tankardstown, c. 30 km to the southwest. 83 Dowd, M. and Carden, R. 2016. "First evidence of a Late Upper Palaeolithic human presence in Ireland." Quaternary Science Reviews: 158‐163 84 Stout, G. and Stout, M., 1997. Early Landscapes: from Prehistory to Plantation. In: F.H.A. Aalen, F.H.A., Whelan, K. and Stout, M., (eds.) Atlas of the Irish Rural Landscape. Cork: Cork University Press. 85 O’Sullivan, A., 2001. Foragers, Farmers & Fishers in a Coastal Landscape: An Intertidal Archaeological Survey of the Shannon Estuary. Dublin: Royal Irish Academy. by Environmental Impact Services 136 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage Bronze Age (2500–500 BC) The Bronze Age period is characterised by the introduction of metalworking technology to Ireland and coincides with many changes in the archaeological record, both in terms of material culture as well as the nature of the sites and monuments themselves. Though this activity has markedly different characteristics to that of the preceding Neolithic period including new structural forms and new artefacts (such as Beaker pottery), it also reflects a degree of continuity. In addition to changes in material culture, there were changes in burial rite from communal megalithic tombs to single burial in cists, which were then frequently covered by cairns or barrows (mounds of earth and/or stone) (Buckley and Sweetman, 1991)86. There are no recorded sites of this type within the site of proposed development areas. The most common Bronze Age site within the archaeological record is the burnt mound or fulacht fiadh. Over 4500 fulachta fiadh have been recorded in the country making them the most common prehistoric monument in Ireland (Waddell, 2010).87 These sites are generally interpreted as Bronze Age cooking/industrial sites. Fulacht fiadh generally consist of a low mound of burnt stone, commonly in horseshoe shape, and are found in low lying marshy areas or close to streams. Often these sites have been ploughed out and survive as a spread of heat shattered stones in charcoal rich soil with no surface expression in close proximity to a trough. A number of fulachta fiadh are recorded within the immediate vicinity of the proposed development site, most crucially is LI013‐233. Iron Age (500 BC–AD 400) There is increasing evidence for Iron Age (c. 600 BC – AD 500) settlement and activity in recent years as a result of development‐led excavations. There are two phases of the Iron Age in Ireland, the Hallstatt and the La Tène, which are associated with distinct artwork and metalwork. Whilst the Shannon as a route way was known to Ptolemy in the second century AD (O’Sullivan, 2001)88, there is very little in the way of recorded Iron Age activity within the landscape surrounding the development. Sites, including burial evidence, have been identified within the wider area, including Ballysimon 1, Rathbane South and Coonagh West 4 that were excavated as part of the Limerick Southern Ring Road (Bermingham et al. 2013, 24)89. Furthermore two Roman coins are recorded as being discovered in the banks of the River Shannon at Sreelane in the 1970s. A bronze sestertius of Domitian coin, dating to AD 81–94, was found within the River Shannon to the immediate south of Thomond Bridge (NMI Ref.: 1978:327). For inspection purposes only. Consent of copyright owner required for any other use. Early Medieval Period (AD 400–1169) During this period Ireland was not a united country but rather a patchwork of minor kingdoms all scrambling for dominance, with their borders ever changing as alliances were formed and battles fought. Kingdoms were a conglomerate of clannish principalities with the basic territorial unit known as a túath. Byrne (1973) estimates that there were probably at least 150 kings in Ireland at any given time during this period, each ruling over his own túath. In Munster the Eóganachta formed the ruling dynasties until the middle of the 10th century. These kings were distributed strategically throughout the region and ruled over many tribal units. When the Irish annals refer to a place called Luimneach, they specify an area by the Shannon estuary, but make no reference to any town or fort existing there. The name Luimneach, which can be dated to around 561 AD (when it was used in an ancient poem), is generally taken to mean ‘the 86 Buckley, V M. and D.P. Sweetman. 1991. Archaeological Survey of County Louth, Dublin: Government Publications Office. 87 Waddell, J., 2010. The Prehistoric Archaeology of Ireland. Dublin: Wordwell. 88 O’Sullivan, A., 2001. Foragers, Farmers & Fishers in a Coastal Landscape: An Intertidal Archaeological Survey of the Shannon Estuary. Dublin: Royal Irish Academy. 89 Bermingham, N., Coyne, F., Hull, G., Reilly, F. & Taylor, K., 2013. River Road: The Archaeology of the Limerick Southern Ring Road. Dublin: NRA (Scheme Monograph 14). by Environmental Impact Services 137 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage bare marsh’; however, as Ó Maolfabhail points out, the word is also an adjective meaning ‘cloaked’ or ‘shielded’ and may well indicate a sheltered area or harbour (1990, 213). The range and variety of monuments of an early medieval date in the vicinity of Limerick City attest to the intensive settlement in the area during this period. Field monuments of this period, notably ringforts and ecclesiastical enclosures, occur in large numbers around the city and there are suggestions from the historical record that the city area itself formed the focus of settlement before the Viking period (c. early 9th century; Spellissy 1998)90. During this often violent period, roughly circular defensive enclosures known as ringforts were constructed to protect farmsteads and these are considered to be the most common indicator of settlement during the early medieval period. One of the most recent studies of the ringfort (Stout, 1997)91 has suggested that there are a total of 45,119 potential ringforts or enclosure sites throughout Ireland. They are usually defined as a broadly circular enclosure delimited by an earthen bank and ditch (ringfort) or by a stone wall (cashel). Ringforts represent individual defended family homesteads (Lynn, 1975)92. The smaller single‐banked type of ringfort (univallate) was more likely to be home to the lower ranks of society while larger examples with more than one bank (bivallate/trivallate) housed the more powerful kings and lords. This period was also characterised by the introduction of Christianity to Ireland and the foundation of a large number of ecclesiastical sites throughout the country. The new religion was a catalyst for many changes, one of the most important being literacy. Irish was written down for the first time using the ogham script. The ogham alphabet is thought to be based on the Latin alphabet of the later Roman Empire and today the majority of the inscriptions that survive are located on pillar stones or boulders. As well as this form of the written word, the church created impressive tomes in their official language, Latin. Examples of these include the Book of Kells and the Book of Durrow as well as other works such as The Annals, which were an account of the history of the church and other significant events. Monasticism was known in the time of St. Patrick (mid‐5th century) but it was not until the 6th and 7th centuries that the famous monastic houses such as Glendalough, Bangor, Clonfert, Clonard, Clonmacnoise and Durrow were founded. The most significant early medieval ecclesiastical foundation within the vicinity of the proposed development area is located at Mungret, c. 2.3 km to the northwest. Founded in the 6th century by St. Nessan its abbots are recorded from the middle of the 8th century indicating its significance by this time. The monastery was raided on a number of occasions between the 10th and 12th centuries. In 1152, at the Synod of Kells, it claimed to be recognised as an episcopal seat (www.archaeology.ie)93. For inspection purposes only. Many holy wells can be found associatedConsent of with copyright early owner eccl requiredesiastical for any other sites. use. Most have no artificial features associated with them and where such do occur they can usually be shown to be of very recent origin. What is clear, however, is that the veneration of wells is a very widespread and ancient tradition in Ireland. Plummer (1910) demonstrates that at least some holy wells in Ireland were important venues of pre‐Christian ritual activity. Most wells are springs but occasionally other water sources, such as hollowed stones which collect water, are treated as holy wells. The closest holy well to the three sites in Raheen is LI013‐009006 located c. 1.8 km to the northwest. It was during the latter part of this period that attacks by the Norse on the lower Shannon area were recorded. The Annals of Clonmacnoise record that in AD 843 Foranan, Primate of Armagh, was taken hostage by the Vikings and held on their ships in Limerick (Lenihan, 1866). In AD 812 the Vikings plundered a small settlement in Limerick and later in the tenth century Tamar, a Norse King, went on to establish a maritime settlement and centre of trade on the southern portion of the island at the lowest fording point of the River Shannon, bounded to the west by the Shannon and all other sides 90 Spellissy, S., 1998. The History of Limerick City. Limerick: The Celtic Bookshop. 91 Stout, M., 1997. The Irish Ringfort. Dublin: Four Courts Press. 92 Lynn, C. J. 1975. ‘The medieval ringfort – an archaeological chimera?’. In Irish Archaeological Research Forum 2: 29‐36. 93 (www.archaeology.ie) by Environmental Impact Services 138 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage by the Abbey River (O’Rahilly 1988;94 Spellissy 1998)95. While there is no archaeological evidence for an enclosure around Viking Limerick; it is likely that the Viking town north of the Abbey River was enclosed by an earthen bank and ditch with a palisade in a manner similar to other Viking settlements in Ireland. The location of the Norse settlement in the following century is notable as the lowest fording point of the River Shannon, at the head of the tidal reach (O’ Rahilly, 1988). Later known as “Kings Island”, this naturally defended location had the double advantage that it was navigable from the sea and was presumably a crossing point over the Shannon. This provided the Vikings with a secure base from which raids could be conducted along the river upstream of Limerick (ibid.). This settlement was one of the five major Viking coastal towns; the other urban centres were at Dublin, Cork, Waterford and Wexford. As with Dublin (Dubhlinn to Dyflin), the Vikings adopted the Irish name Luimneach, but corrupted it slightly, using one of their terms Laemrich, Hlimrek, or Allymrick, which means rich land, rich soil, and rich loam respectively. Later known as “Kings Island” after an English monarch but also possibly once Odensay – Odin’s Island (Spellissy, 1998), this naturally defended location had the double advantage that it was navigable from the sea and was presumably a crossing point over the Shannon. This provided the Vikings with a secure base from which raids could be conducted along the river upstream of Limerick, and trade from Atlantic Europe could be managed. The strategic importance of Limerick and its environs was appreciated by both the neighbouring native clans and the advancing Anglo‐Normans in the middle ages. Brian Bóru sacked the town in AD 967 and 968, allowing the Viking inhabitants to remain within the walls on payment of heavy tributes. By the time of the Battle of Clontarf, the Limerick Vikings had renewed their alliance with Bóru. His descendants, the O’Brien’s, held sway over much of Limerick’s hinterland, and by the 11th century were designated Kings of Thomond, establishing a new seat in the old Norse town of Limerick in AD 1100. St. Mary’s Cathedral, built in the style of the Cistercians, was originally erected between 1168 and 1172 by Donal O’Brien, and is the sole surviving monument in the city from the pre‐Norman occupation (O’ Rahilly, 1988). There is no evidence for Viking occupation in the vicinity of the proposed development areas during this period outside of the raids on the ecclesiastical centre in Mungret c. 2.3 km to the northwest. Medieval Period (AD 1169–1600) The beginning of the medieval period was characterised by political unrest that originated For inspection purposes only. from the death of Brian BorumhaConsent in of copyright1014. owner Diarmait required for MacMurchadha, any other use. deposed King of Leinster, sought the support of mercenaries from England, Wales and Flanders to assist him in his challenge for kingship. Norman involvement in Ireland began in 1169, when Richard de Clare and his followers landed in Wexford to support MacMurchadha. Two years later de Clare (Strongbow) inherited the Kingdom of Leinster and by the end of the 12th century the Normans had succeeded in conquering much of the country (Stout & Stout, 1997)96. The arrival of the Anglo‐Normans in 1175 took Limerick City by storm. They were forced to withdraw in 1176, and did not succeed in occupying the town until 1190 (Lee, 1997)97. Prince John granted Limerick a charter seven years later, declaring that the citizens would have all the liberties and free customs through all Ireland that were enjoyed by the citizens of Dublin (ibid.). In 1210, on a visit to Ireland, King John created counties from the portions of land under Anglo‐Norman control, one of which became the county of Limerick. During this visit, John erected a castle (King John’s Castle) and a bridge (Thomond Bridge) within the English town of the settlement. The North Liberties of Limerick 94 O’Rahilly, C., 1988. Recent Research in Limerick City. Archaeology Ireland, Vol. 2, No. 4. 140‐144. 95 Spellissy, S., 1998. The History of Limerick City. Limerick: The Celtic Bookshop. 96 Stout, G. and Stout, M., 1997. Early Landscapes: from Prehistory to Plantation. In: F.H.A. Aalen, F.H.A., Whelan, K. and Stout, M., (eds.) Atlas of the Irish Rural Landscape. Cork: Cork University Press. 97 Lee, D., (ed.) 1997. Remembering Limerick: historical essays celebrating the 800th anniversary of Limerick's first charter granted in 1197 Limerick. Limerick Civic Trust in Association with FAS. by Environmental Impact Services 139 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage remained with Clare in Connaught until 1660 (Spellissey, 1998)98. However, there are references to a castle within Limerick in 1202 and it is possible that this refers to the earlier ringwork, which was constructed by the Norman garrison in 1175 (Wiggins, 2016)99. The 12th century ringwork ditch was identified during excavations at the castle in 1990‐91, beneath the 13th century masonry (Wiggins, 2000). A royal mint was also established between 1195 and 1199, which continued to operate sporadically until 1483 (ibid.). Despite the proliferation of Anglo‐Norman activity within Limerick City, there are no recorded medieval sites located within the vicinity of the proposed development area. Post-Medieval Period (AD 1600–1900) The 17th century in County Limerick, as with other parts of the country, was a turbulent period of warfare, religious strife and political upheaval, characterised by two particular conflicts ‐ the Irish Confederate Wars (1641–53) and the Williamite War (or War of the Two Kings; 1688–91). In 1651 a protracted siege by Cromwell’s forces left Limerick City besieged with famine, pestilence and death. The city finally surrendered with a death toll of 5000 inhabitants. The Williamite Wars of the late 17th century saw the reactivation of the city mint to finance James II’s campaign. Gun money was minted in Dublin and Limerick, allegedly from the brass of old cannons, hence its name. The city withstood attacks by Williamite forces throughout 1690 and 1691, becoming the last Jacobean stronghold to repel William’s army. After the slaughter of 600 inhabitants who had become trapped outside the city walls and the failure of French reinforcements to arrive, Patrick Sarsfield signed the Treaty of Limerick in October 1691 (Spellissy, 1998)100. With the onset of the 18th century, the political climate settled, the Old Gaelic order was dismantled and replaced by English governance and a Protestant Ascendancy class were installed as landowners across the vast majority of the county. This saw a dramatic rise in the establishment of large residential houses around the country. This was largely due to the fact that after the turbulence of the preceding centuries, the success of the Protestant cause and effective removal of any political opposition, the country was at peace. The large country house was only a small part of the overall estate of a large landowner and provided a base to manage often large areas of land that could be dispersed nationally. During the latter part of the 18th century, the establishment of a parkland context (or demesnes) for large houses was the fashion. Although the creation of a parkland landscape involved working with nature, rather than against it, considerable constructional effort went into their creation. Earth was moved, field boundaries disappeared, streams were diverted to form lakes and quite often roads For inspection purposes only. were completely diverted to avoidConsent travellin of copyrightg anywhere owner required near for any theother use. main house or across the estate. Major topographical features like rivers and mountains were desirable features for inclusion into, and as a setting, for the large house and parkland. Castle Roche (RPS 1671, NIAH Reg. No.: 21901309) is one such house and demesne, albeit on a much smaller scale than some examples found within the county. Castle Roche was built c.1830 in the Gothic Revival style and included a four storey octagonal‐plan tower with an octagonal turret. The structure and its associated range of outbuildings are listed as protected structures within the County Development Plan and have also been included within the NIAH survey. The Roche family have an illustrious history in the area. George Roche was Mayor of Limerick at the beginning of the 18th century and also represented the city in Parliament. Sir David Roche’s County Limerick estate was in the parishes of Mungret, Bruree, Drehidtarsna and Dysert. His grandson David Roche of Carass, agent to Lord Carbery, married Frances Maunsell of the Maunsell banking family who established Limerick City’s first bank at Bank Pace and rented the mill at Carass in the late 18th century. Their son David became a baronet in 1838 and owned a number of flour mills. 98 Spellissy, S., 1998. The History of Limerick City. Limerick: The Celtic Bookshop. 99 Wiggins, K., 2016. A Place of Great Consequence: Archaeological Excavations at King John’s Castle, Limerick, 1990‐8. Dublin: Wordwell. 100 Spellissy, S., 1998. The History of Limerick City. Limerick: The Celtic Bookshop. by Environmental Impact Services 140 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage At the time of Griffith’s Valuation (1848‐64) the Roche Castle is recorded as being held by the Bishop of Limerick and was valued at £30. It seems likely that David Roche lived here during that time (www.landedestates.nuigalway.ie)101. For inspection purposes only. Consent of copyright owner required for any other use. 101 (www.landedestates.nuigalway.ie) . by Environmental Impact Services 141 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage 15.4.2 NATIONAL MONUMENTS The term ‘National Monument’ is defined by the National Monuments Act (1930) as being ‘a monument or the remains of a monument the preservation of which is a matter of national importance by reason of the historical, architectural, traditional, artistic, or archaeological interest attaching thereto’. The aforementioned Act states that the consent of the Minister is required for archaeological works at or near a national monument in the ownership or guardianship of the Minister or a local authority or to which a preservation order applies. The Minister is required to consult with the Director of the National Museum of Ireland in relation to such an application for consent. No National Monuments are located on or within close proximity to the proposed development site. 15.4.3 RECORDED MONUMENTS The site of the proposed development contains a recorded monument LI013-233 - Fulacht fiadh. Two recorded monuments LI013-229 and LI013-230 both classified as Fulachta fiadh are located outside of the site. The following is a description of the recorded monuments within and directly adjacent to the site of the proposed development (Figure 15.3). LI013-233 Class: Fulacht fia Townland: BALLYCUMMIN Scheduled for inclusion in the next revision of the RMP: Yes Description: No description currently available. LI013-229 Class: Fulacht fia Townland: BALLYCUMMIN Scheduled for inclusion in the next revision of the RMP: No Description: No description currently available. LI013-230 Class: Fulacht fia Townland: BALLYCUMMIN Scheduled for inclusion in the next revision of the RMP: No Description: No description currently available. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 142 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Cultural Heritage The following is a list of the nearest recorded monuments: Table 15.1 Recorded monuments within 2 km of the development site boundary RMP CLASSIFICATION TOWNLAND LK013-036 Ballycummin Ring fort/ Rath LK013-039001 Ballycummin Redundant record LK013-039002 Ballycummin Ring fort / Rath LK013-146 Ballycummin Ring fort / Rath LK013-151 Ballycummin Road/track way LK013-166 Ballycummin Excavation – misc LK013-167 Ballycummin House 18th/19th century LK013-183 Ballycummin Fulacht Fiadh LK013-229 Ballycummin Fulacht Fiadh LK013-230 Ballycummin Fulacht Fiadh LK013-231 Ballycummin Fulacht Fiadh LK013-232 Ballycummin Fulacht Fiadh LK013-233 Ballycummin Fulacht Fiadh LK013-233 Ballycummin Fulacht Fiadh LK013-235 Ballycummin Excavation – misc ,,,.. - ~ ~ 11> • • ,/' ;;,-1'(' \ / (;,~"'IJ-~ 'l 'i. ... C'lonb . "'1f \ ., • LI013-146 Rlngfort ~ LI013-231 Fulacht Fiadh '\ • \ Ll013• -232 Fulacht Fiadh LI013-03.9002. Rmgfort i.. LI013-234 Fulacht Fiadhe LI013-230 Fulacht F1adh\ U013--235 Excavationmisc . \ For inspection purposes only. ConsentLI013~151 of Road/track copyrightw ay\ owner required for any other use. LI013-036 Rlngtone "'o LI013-229 Fulacht F1adh LI013~166 Excavation misc.• . - 911 .. LI013-167 House 18th/19th century • ·~"""'" • • LI013-183 Fulacht Fiadh • • INO Key: • National Monuments Service site • National Inventory Of Architectural Heritage site • Record Of Protected Structures site SOOm Figure 15.1 Location of Recorded Monuments and Protected Structures (RPS). 15.4.4 PREVIOUSLY UNRECORDED SITES No above ground previously, unrecorded sites were noted within the proposed development area during the site walk-over survey conducted on the 30th August 2017. It should be noted, however, that previous archaeological investigations carried out on this site in 1998 and 1999 did reveal the presence of previously unrecorded sub-surface archaeological features. by Environmental Impact Services 143 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage 15.4.5 SITES REPORTED IN THE EXCAVATIONS DATABASE The Excavations Bulletin is both a published annual directory and an on-line database that provides summary accounts of all the excavations carried out on the island of Ireland from 1970 to the present. The southern environs of Limerick city have been subject to considerable development and infrastructural works in recent years. Archaeological excavations since 1999 during work on the former Dell manufacturing facility and the M20 motorway revealed a number of previously unknown archaeological features. Brief summaries of the archaeological excavations carried out in the vicinity of the proposed development in Ballycummin townland in recent years are provided in the following paragraphs. Ballycummin Excavation Licence No. 96E379 As part of the Adare-Annacotty Road Improvement Scheme the southwest corner of a field was tested owing to its proximity to a ringfort to its immediate west. A linear feature representing either a drain or a field boundary was exposed as was a possible cremation pit closer to the boundary of the ringfort. Another trench exposed a deep ditch and two postholes associated with the outer defences of the ring fort102. Ballycummin Excavation Licence No. 96E380 As part of the Adare-Annacotty Road Improvement Scheme two trenches were excavated to assess the antiquity of two buildings which are depicted within a sub rectangular enclosure on the 1st edition OS map. The assessment confirmed that this is the location of a settlement indicated on the map and material finds suggested that the houses were occupied during the 19th century.103 Ballycummin Excavation Licence No. 98E0108 Excavations were carried out in the former grounds of Roche Castle during road improvement works. Many features of archaeological significance were uncovered including pits, postholes and ditches and the recovered finds indicated that the site was Bronze Age in date.104 Ballycummin Excavation Licence No. 98E0504 Work on the Loughmore Link road within the townland of Ballycummin identified five areas of archaeological significance. All of these were interpreted as representing Bronze Age activity.105 Howmedica Link Road Ballycummin Townland Excavation Licence No. 99E0376 For inspection purposes only. This link road was constructed 500mConsent east of copyright of the owner N20 required and for 250m any other southuse. of Raheen Business Park. It was constructed as part of the infrastructure for the former Dell manufacturing facility (EMF3) close to where four fulachta fiadh and a 19th century trackway had previously been excavated in 1999. The only feature uncovered as part of this excavation was a further section of the 19th century trackway.106 Ballycummin, Raheen Excavation Licence No. 99E0116 A test excavation was undertaken in Raheen Business Park prior to the construction of a large office block. An aerial photograph indicated the presence of a large enclosure to the immediate north of a ringfort (LK013-039002). The test excavation revealed naturally occurring sand and stone and no habitation layers or features were revealed. Archaeological monitoring of the groundwork associated with the development exposed nothing of archaeological significance107. 102 Eogan, J. 1997 Ballycummin: Searchable database of Excavations. www.archaeology.ie 103 Logue, P. 1999 Ballycummin: Searchable database of Excavations. www.archaeology.ie 104 Gahan, A. 1999 Ballycummin: Searchable database of Excavations. www.archaeology.ie 105 Finn, D. 2000 Howmedica Link Road, Ballycummin: Searchable database of Excavations. www.archaeology.ie 106 Wiggins, K. 2000 Ballycummin, Raheen; Searchable database of Excavations. www.archaeology.ie 107 Dunne, N. 2000 Ballycummin: Searchable database of Excavations. www.archaeology.ie by Environmental Impact Services 144 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage Ballycummin Excavation Licence No. 98E0433 Various stages of archaeological excavation were undertaken at Ballycummin between September 1998 and May 1999 in association with the construction of a new computer factory by Dell (EMF3). The excavations also covered the installation of a dual carriageway connecting the factory with the new Loughmore link road. Phase 1 involved the pre-development testing of seven potential archaeological sites noted in the archaeological impact assessment and on aerial photographs of the factory. Phase 2 involved monitoring of groundworks during the construction of the factory and most of the uncovered finds related to farming activity associated with Roche Castle demesne. However to the southwest of the site a fulacht fiadh was exposed during the excavation of a trench for a temporary telecom supply to the compound. Phase 3 construction of the dual carriageway to the factory necessitated the removal of portions of a trackway. The trackway is 19th century in date and may have been used to ferry stone from a nearby quarry to Roche Castle. Phase 4 continued construction of the dual carriageway, uncovered four fulachta fiadh of Bronze Age date. 15.4.6 TOPOGRAPHICAL FILES The topographical files of the National Museum of Ireland were consulted. There are no stray archaeological finds listed within the topographical files of the National Museum of Ireland associated with the townlands of Ballycummin or its surrounding townlands of Loughmore Common, Cloghkeating, Sluggary or Derrybeg. 15.4.7 PLACENAME EVIDENCE The database of Irish placenames, www.logainm.ie were consulted for the meaning of the placenames within and surrounding the proposed development site. Ballycummin is in the Electoral Division of Ballycummin, in the Civil Parish of Mungret, in the Barony of Pubblebrien, in the County of Limerick. The Irish name for Ballycummin is Baile Choimín. Ballycummin Castle may have been the original name of Roche Castle Raheen (Irish: An Ráithín, meaning "small ringfort") is a large suburb of Limerick, Ireland. Initially developed to ease population overspill For from inspection the purposes city only. of Limerick, Raheen is socio-economically Consent of copyright owner required for any other use. diverse, ranging from older, working class housing estates to relatively affluent areas. 15.4.6 CARTOGRAPHIC SOURCES AND AERIAL PHOTOGRAPHY Down Survey Map of the Barony of Pubblebrien 1654-56 the Down Survey map depicts no evidence of any features of historical or cultural heritage significance directly adjacent to the site of the proposed development (Figure 15.4) First Edition Ordnance Survey Map, 1844 This is the first accurate historic mapping coverage of the landscape along the proposed development. It depicts a rural landscape of agricultural field systems and it clearly depicts recorded monuments LI013-039002 and LI013-036 two recorded ringforts – rath sites. The only feature located within the site of the proposed development is Roche Castle and its associated gardens to the front and rear of the buildings (Figure 15.5). Ordnance Survey Map, 1901, and third Edition Ordnance Survey Map, 1918-24 Depicts a very similar view of the site and its surrounding landscape as the First Edition Ordnance Survey Map, 1844. A rural landscape of agricultural field systems, it clearly depicts recorded monuments LI013-039002 and LI013-036, two recorded ringforts – rath sites. The only feature located within the site of the proposed development is Roche Castle (RPS 1671, NIAH Reg. No. 21901309) which is depicted as the main house with associated outbuildings to the north and associated gardens to the front and rear of the buildings (Figure 15.6-15.7). by Environmental Impact Services 145 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage Figure 15.2 Down Survey Map of the Barony of Pubblebrien, 1654-56 For inspection purposes only. Consent of copyright owner required for any other use. r tun.d Figure 15.3 First Edition Ordnance Survey Map, 1844 by Environmental Impact Services 146 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage i / ,. ,, / / v J ©Ore I,., I ...... - I<-- •• ~ ·~- Figure 15.4 Ordnance Survey Map, 1901 ,-' ,' , , ' ; ,' ,' For inspection purposes only. Consent of copyright owner required for any other use. 200m Figure 15.5 Third Edition Ordnance Survey Map, 1918-24 by Environmental Impact Services 147 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage Aerial Photography Aerial photography from the Geological Survey of Ireland and other sources including the Cambridge University Collection of Aerial Photographs and more recent google and bing images were consulted. The most recent photographs show the location of Ringfort LL013-039002 as being a large sub circular monument defined by shrubs growing upon the monuments banks. No other crop marks or features within the landscape were identified that suggest the presence of any further archaeological features located within or directly adjacent to the site of the proposed development (Figure 15.8). Figure 15.6 Aerial photography of the site For inspection purposes only. Consent of copyright owner required for any other use. 15.4.7 SITE INSPECTION A site inspection was conducted by Donald Murphy of ACSU on Monday 30th August 2017. The field survey revealed that much of the area proposed for development comprises hard standing ground underlain by predominantly made ground (Figure 15.9). The existing facility consists of a large assembly area, a warehouse and manufacturing support area, a utility building, a two-storey office building, service yards, car parking spaces and an access road linking the site to the R526. The only green areas that appear to be undisturbed by previous ground works are the site of the temporary contractors compound, which is located to the rear of Roches Castle and possibly the proposed car park extension (Figure 15.10). by Environmental Impact Services 148 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage Figure 15.7 Site of proposed extension looking north-west For inspection purposes only. Consent of copyright owner required for any other use. Figure 15.8 Site of proposed car park extension looking south-west by Environmental Impact Services 149 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage 15.4.8 RECORD OF PROTECTED STRUCTURES The County Limerick Development Plan 2010-2016 was consulted to determine if any protected structures were present within the proposed development site. The site contains one recorded protected structure listed with the County Limerick Development Plan 2010-2016. This consists of Roche Castle and outbuildings (RPS 1671) - a Detached three-bay one to one-and-half storey Gothic Revival style house, built c. 1830 (see below for description). 15.4.9 NATIONAL INVENTORY OF ARCHITECTURAL HERITAGE The national inventory of architectural heritage108 was consulted to determine if any buildings or structures of architectural heritage significance were present within the proposed development area. There is one NIAH structure located within the site of the proposed development, Roche Castle (NIAH Ref.: 21901309): Reg. No: 21901309 Date: 1820 - 1840 Previous Name: N/A Townland: BALLYCUMMIN County : County Limerick Coordinates: 155249, 152384 Categories of Special Interest: ARCHITECTURAL ARTISTIC Rating: Regional Original Use: House In Use As: Office Description Detached three-bay one-one-and-half storey Gothic Revival style house, built c. 1830, with four-stage octagonal-plan tower to south having octagonal turret to north-west corner. Now in use as office. Pitched slate roof having projecting eaves and rendered chimneystack and cast-iron rainwater goods. Limestone snecked ashlar walls with peck dressed quoins, base batter to tower section. Crenellated parapets tower having curved corbelling and stringcourse below. Decorative bulbed-cross shaped recess loop to second stage angled walls of octagonal tower, with bulbed-loop over. Square-headed window openings with tooled limestone splayed surrounds and limestone sills, one dormer window to main house. Timber framed casement with multiple-paned awning windowpanes over. Recent steel bars to ground floor window openings. For Round inspection-headed purposes only. window openings to upper stage of tower Consent of copyright owner required for any other use. having narrow six-over-six pane timber sliding sash windows. Paired round-headed window openings with tooled limestone surrounds and label mouldings over to north and south elevations, third stage of tower. Multiple-pane timber framed casement windows with traceried upper panes to these window openings. Square-headed door opening with splayed tooled limestone surround. Timber panelled door with brass door furniture boarded over with plywood. Coursed rubble limestone boundary walls, partially rendered, terminating in square-profile piers with pointed caps. Curved carriage entrance to far west. Limestone ashlar walls with tooled coping and cast-iron railings. Square-plan gate piers with decorative stringcourse and pointed caps having bevelled support. Cast- iron traffic gate and pedestrian gates. Appraisal The regularity of the courses and formality of the carriage entrance gives a fitting introduction to this house, which may have been built by the Pain brothers. The building itself retains all the elegance of its original construction, with the ceremony and drama of a folly or castle. The juxtaposition of the tall thin octagon with the shorter thicker one creates a dramatic visual effect. The angles of the building itself reflect those of the base batter while the vertical lines of the decorative loops draw the eye up into the castellated parapet, enhancing the appearance of height which forms so pleasing a contrast to the relatively small house attached. 108 www.buildingsofireland.ie by Environmental Impact Services 150 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage 15.5 PREDICTED IMPACTS 15.5.1 DIRECT IMPACTS ON RECORDED ARCHAEOLOGICAL MONUMENTS There will be no direct impact on recorded archaeological monuments. The only recorded monument located within the site of the proposed development is LI013-233 - a Fulacht fia. This was preserved by record under Licence No: 98E0433. 15.5.2 DIRECT IMPACTS ON KNOWN AND POTENTIAL ARCHAEOLOGICAL FEATURES Despite the developed nature of much of the site, areas that have not been subject to previous archaeological assessment such as the carpark extension and the temporary contractors compound may still have the potential to contain previously unrecorded archaeological features and deposits. If such are present the proposed development of these areas will have a direct impact. 15.5.3 INDIRECT IMPACTS Indirect impacts here are those which may have a negative (or positive) effect on the archaeological landscape after the construction phase of the development (i.e. operational). Indirect impacts may include visual impact on the surrounding archaeological landscape. The nearest recorded standing monument is a ringfort (LK013-039002). Clear views of this monument were not possible from the proposed development area given the presence of intervening field boundaries and associated screening of other developments. The introduction of the proposed development to the area will result in a change to the general setting of this monument, although its immediate setting will remain unchanged. Provided the aforementioned screening is maintained a slight to negligible indirect impact to the monument is noted. It is noted that there may be a visual impact on the setting of Roches Castle which is a protected structure (RPS 1671) recorded within the National Inventory of Architectural Heritage (NIAH), (Reg. No. 21901309). The existing facility already has a negative visual impact on the castle and the proposed development is not regarded as adding significantly to this. For inspection purposes only. Consent of copyright owner required for any other use. 15.6 MITIGATION MEASURES The predicted impacts on the known recorded archaeological, architectural & cultural heritage are regarded as being low with no direct impacts on the recorded archaeological resource identified and a slight-negligible indirect (visual) impact on the nearest recorded monument outside the proposed development site boundary and Roches Castle. Archaeological monitoring of all remaining topsoil removal associated with the proposed development will be carried out. The monitoring will be carried out under licence from the National Monuments Service of the DAHRRGA by a suitably qualified archaeologist. Any further archaeological sites and/or features identified during topsoil removal and which will be directly impacted by the development will be preserved by record (excavation). The appointed archaeologist shall consult with the Licensing Section of the NMS if further archaeological features are uncovered and methodologies agreed regarding their resolution. Adequate time and resources will be provided by the developer for the resolution of any archaeology identified within the development site which will be directly impacted upon by ground works. Time and resources will also be allowed for any post-excavation work and specialist analysis necessary following any archaeological excavation that takes place. A report is required to be compiled on completion of the archaeological monitoring and will be submitted to the relevant authorities. by Environmental Impact Services 151 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Archaeology & Architectural Heritage All mitigation measures outlined in this report should be reflected in the outline Construction Environmental Management Plan (CEMP) for the site. 15.7 RESIDUAL IMPACTS The residual impacts are likely to be low or negligible if the recommended mitigation measures are implemented. Table 15-2 below summarises the residual impacts of the proposed development on the archaeological landscape. Residual impacts are defined as the overall impact of the development on the archaeology on the basis of implementing the mitigation measures recommended in this report. Table 15.2 Summary of Residual Impacts Potential impacts Mitigation strategy Residual impacts Construction impacts Topsoil removal associated Archaeological monitoring of all topsoil removal Low with development. Excavation associated with the development. Consultation of foundations and service with Licensing Section of National Monuments trenches etc. Service should further archaeological sites or features be uncovered. Impacts to recorded No mitigation required. None monuments - none Operational impacts Nearby Recorded Monuments No mitigation required. None are screened from view. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 152 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Interactions & Cumulative Effects 16 INTERACTIONS & CUMULATIVE EFFECTS 16.1 INTRODUCTION This section of the EIAR identifies and outlines where and how interactions between the various impacts identified in the different sections have been addressed in this EIAR. This covers both the construction and operational phases of the proposed development. The project team, in conjunction with the assistance of a variety of specialist environmental consultants, each one an expert in their chosen field, assessed the potential impact arising from the construction and operation of the proposed development. The interaction of environmental aspects was clearly identified at an early stage in the project to be an important factor to be considered in the full evaluation of the environmental impacts associated with the proposed development. In the interests of clarity, significant interactions and inter-dependencies have been taken into consideration, and are addressed, under each specialist heading in the EIAR. We refer the reader to the relevant sections. 16.2 MATRIX OF INTERACTIONS This section of the EIAR provides a simple matrix identifying environmental components and recording where interactions are identified. These are then expanded upon in the text that follows, with cross references made to the more detailed assessments outlined in the relevant chapters of the EIAR. Again, for detailed descriptions and accounts, we refer the reader to the relevant sections of the EIAR. For inspection purposes only. Consent of copyright owner required for any other use. by Environmental Impact Services 153 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Interactions & Cumulative Effects Table 16.1 Matrix of Interactions Population Biodiversity Soils, Water & Air Quality Noise & Landscape Material Traffic & Waste Archaeology & Human Geology & Hydrology & Climate Vibration & Visual Assets Transport Manage- & Cultural Interaction Health Hydro- ment Heritage geology Con. Op. Con. Op. Con. Op. Con. Op. Con. Op. Con. Op. Con. Op. Con. Op. Con. Op. Con. Op. Con. Op. Population & Human Health Biodiversity Soils, Geology & Hydro- geology Water & Hydrology Air Quality & Climate Noise & Vibration Landscape & Visual Material Assets Traffic & Transport Waste Manage- For inspection purposes only. Consent of copyright owner required for any other use. ment Archaeology & Cultural Heritage No Interaction Weak Interaction Con. construction phase Op. operational phase Some Interaction See following pages for descriptions of interactions and cumulative that correspond to grid boxes marked with a ‘tick’. Strong Interaction Boxes with an ‘x’ indicate that no interactions or cumulative effects are likely to occur. by Environmental Impact Services 154 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Interactions & Cumulative Effects 16.3 INTERACTIONS AND CUMULATIVE EFFECTS 16.3.1 HUMAN BEINGS Noise & Vibration Interactions: Increasing industrial activity has the potential to increase ambient noise levels at nearby sensitive receptors for people – dwellings and amenities. Project mitigation measures (see Section 10) address this effect during construction and the EPA does so during operations. Cumulative Effects: Increasing loss of silence is part of a cumulative process. Cumulative noise effects are predicted in Section 10 to be imperceptible. Traffic & Transportation Interactions: It is considered that the predicted increases in network traffic as a result of construction and operational development will be of negligible impact. Cumulative Effects; This is also addressed in Section 13. 16.3.2 BIODIVERSITY Noise & Vibration Interactions: Increasing industrial activity has the potential to increase ambient noise levels which could affect sensitive fauna. Noise and vibration mitigation measures (see Section 10 address this potential effect. Cumulative Effects: Cumulative noise effects are predicted in Section 10 to be imperceptible. 16.3.3 SOILS, GEOLOGY AND HYDROGEOLOGY Water & Hydrology Interactions: Surface and ground waters are inherently linked. In the case of this development, no significant environmental effects are predicted on either that would cause an adverse interactive effect on the other. For inspection purposes only. Consent of copyright owner required for any other use. Cumulative Effects: The mitigation measures in sections 7.5 ensure that potential significant cumulative effects are avoided. by Environmental Impact Services 155 EPA Export 30-11-2018:04:49:42 EIAR for Extension of Bulk Biologics Facility at Regeneron Co. Limerick Interactions & Cumulative Effects 16.3.4 AIR QUALITY & CLIMATE Traffic & Transport Interactions: Air quality could be affected by increased traffic during construction and operation. This is assessed in sections 9.4 and 13.5. Cumulative Effects: The potential cumulative effects are also assessed in sections 9.4 and 13.5 16.3.5 NOISE & VIBRATION Traffic & Transport Interactions: Increasing traffic leads to increased levels of local ambient noise which adds to the background noise of plant operations. Mitigation Measures address this effect. Cumulative Effects: Any change in noise levels associated with vehicles at road junctions in the vicinity of the proposed development is expected to be imperceptible. The resultant noise impact is imperceptible. 16.3.6 WASTE MANAGEMENT Interactions: Interaction between construction/demolition and waste management are addressed in section 14 and in the Appended Construction Waste Management Plan. Cumulative Impact: Sections 9.5, 10.4 and 13.5 all address potential cumulative effects relating to handling of wastes. 16.3.7 ARCHAEOLOGY & ARCHITECTURAL HERITAGE Landscape & Visual Impact Interactions: Increasing industrial activity may impact on the setting of Roches Castle which is a protected structure (RPS 1671). The existing facility already has a negative visual impact on the castle and the proposed development is not regarded as adding significantly to this. Cumulative Impact: Sections 11.5 and 1 5 For.5 inspectionaddress purposes potential only. cumulative effects relating to impact on protected structure. Consent of copyright owner required for any other use. 16.3.8 BROADER INTERACTIONS Each section of the EIAR considers how this proposed project will incrementally contribute to the establishment of the overall envelope of effects caused by the proposed development. by Environmental Impact Services 156 EPA Export 30-11-2018:04:49:42